Elzie Ball, et al. v. James M. LeBlanc, Secretary, Louisiana Department of Public Safety and Corrections, et al.

The Prison Litigation Reform Act of 1995 (PLRA) provides that before a district court may order prospective relief with respect to prison conditions, it must find “that such relief is narrowly drawn, extends no further than necessary to correct the violation of the Federal right, and is the least intrusive means necessary to correct the violation of the Federal right.” 18 U.S.C. § 3626(a)(1)(A). Petitioners are three prisoners who, due to medical conditions, are uniquely susceptible to serious heat-related injury. After a trial, the district court found overwhelming evidence that respondents, who operate the prison, had violated petitioners’ Eighth Amendment rights by housing them in excessively hot cells (often more than 100 degrees Fahrenheit)—and found that the only way to remedy the violation was for the prison to keep the heat index below 88 degrees. Respondents proposed to install air conditioning. The Fifth Circuit affirmed that respondents were violating the Eighth Amendment, but held that the PLRA prohibits the district court from ordering a maximum heat index, and prohibits air conditioning. The court based its decision on circuit precedent endorsing lesser remedies. Those remedies were then tried, but they failed to cure the violation, so the district court again ordered a maximum heat index— achievable without air conditioning. Citing the mandate rule, the Fifth Circuit reversed. The Question Presented is whether the PLRA’s tailoring requirement prohibits a district court from ordering a prison to maintain a maximum heat index to remedy a constitutional violation caused by heat.