GPS RESEARCH LIBRARY: Heat, Cooling, and the Eighth Amendment in U.S. Prisons: A Georgia Focus and Deep South Comparative Landscape ============================================================ Georgia Prisoners' Speak — gps.press Generated: 2026-10-04 14:55:24 EDT Research Date: 2026-05-03 Topic: Environmental Conditions / Heat Exposure JSON: https://gps.press/research-data/heat-cooling-and-the-eighth-amendment-in-us-prisons-a-georgia-focus-and-deep-south-comparative-landscape/?format=json SUMMARY ---------------------------------------- This addition to the GPS research collection establishes the binding heat precedent for Georgia's federal courts (Chandler v. Crosby, 379 F.3d 1278 (11th Cir. 2004), plus pre-1981 Fifth Circuit decisions adopted via Bonner v. City of Prichard), surveys the Eleventh Circuit's unpublished post-Chandler heat decisions, and contrasts the Fifth Circuit line binding in Texas. A GPS review of GDC's published SOP library (1,449 documents) found that GDC sets no maximum temperature for general-population housing, but does impose 85-degree monitoring and response rules for prisoners on psychotropic medication in lockdown and mental-health units, a 68-78 degree thermostat design range for areas with HVAC, and an 88-degree emergency-notification threshold for its egg-production livestock houses. The number of fully air-conditioned Georgia prisons remains unresolved, with three incompatible figures from GDC (2016), Prison Journalism Project (2022), and SCHR (2024). LEGAL FACTS (61) ---------------------------------------- - [confirmed] Chandler v. Crosby is the controlling heat precedent for Georgia federal courts Chandler v. Crosby, 379 F.3d 1278 (11th Cir. Aug. 6, 2004), is the Eleventh Circuit's controlling heat decision, binding on federal courts in Georgia, Florida and Alabama. A class of Florida death-row prisoners at Union Correctional Institution challenged summer heat and ventilation; after a bench trial the district court ruled for the state and the Eleventh Circuit affirmed. Date: 2004-08-06 Tags: legal,conditions,heat,eighth_amendment Sources: Chandler v. Crosby, 379 F.3d 1278 (11th Cir. 2004) - [confirmed] Texas C.U.R.E. v. Lumpkin final order issued September 22, 2026 The Western District of Texas (Judge Pitman) signed a 150-page order containing findings of fact, conclusions of law, a declaratory judgment, and a permanent injunction in Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350, on September 22, 2026, following an eight-day bench trial held March 30 through April 9, 2026. Date: 2026-09-22 Tags: legal,conditions,policy Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [confirmed] Chandler holds Eighth Amendment applies to inadequate cooling and ventilation Chandler v. Crosby: "the Eighth Amendment applies to prisoner claims of inadequate cooling and ventilation" (379 F.3d at 1294). Date: 2004-01-01 Tags: legal,conditions,heat,eighth_amendment Sources: Chandler v. Crosby, 379 F.3d 1278 (11th Cir. 2004) - [confirmed] Chandler: Eighth Amendment concerned with severity and duration of exposure Chandler v. Crosby: "Second, the Eighth Amendment is concerned with both the 'severity' and the 'duration' of the prisoner's exposure to inadequate cooling and ventilation." (379 F.3d at 1295). Date: 2004-01-01 Tags: legal,conditions,heat,eighth_amendment Sources: Chandler v. Crosby, 379 F.3d 1278 (11th Cir. 2004) - [confirmed] Chandler: mere discomfort does not offend the Eighth Amendment Chandler v. Crosby: "Third, a prisoner's mere discomfort, without more, does not offend the Eighth Amendment" (379 F.3d at 1295). Date: 2004-01-01 Tags: legal,conditions,heat,eighth_amendment Sources: Chandler v. Crosby, 379 F.3d 1278 (11th Cir. 2004) - [confirmed] March 2025 preliminary injunction denied in Texas heat case On March 26, 2025, the court denied a preliminary injunction (Tiede v. Collier, 796 F. Supp. 3d 275 (W.D. Tex. 2025), 'Tiede II'). It found that installing temporary air conditioning as preliminary relief was not in the public interest, while also finding, in words Dkt. 350 quotes at page 4, that '[t]his case concerns the plainly unconstitutional treatment of some of the most vulnerable, marginalized members of our society.' Date: 2025-03-26 Tags: legal,conditions Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [confirmed] Chandler holding: heat at Union CI not unconstitutionally excessive The Eleventh Circuit held in Chandler: "while no one would call the summertime temperatures at the Unit pleasant, the heat is not unconstitutionally excessive" (379 F.3d at 1297), and "Under the standards we apply, we cannot say that the prisoners at the Unit have cleared this high bar." (at 1298). Because the objective element failed, the court did not reach deliberate indifference. Date: 2004-01-01 Tags: legal,conditions,heat,eighth_amendment Sources: Chandler v. Crosby, 379 F.3d 1278 (11th Cir. 2004) - [confirmed] Chandler did not hold air conditioning is never required Chandler did not hold that air conditioning is never required. It held that that record showed discomfort, not a substantial risk of serious harm. Date: 2004-01-01 Tags: legal,conditions,heat,eighth_amendment Sources: Chandler v. Crosby, 379 F.3d 1278 (11th Cir. 2004) - [confirmed] Bonner v. City of Prichard adopts pre-1981 Fifth Circuit precedent as binding Bonner v. City of Prichard, 661 F.2d 1206 (11th Cir. 1981) (en banc), adopted the decisions of the former Fifth Circuit handed down before the close of business on September 30, 1981 as Eleventh Circuit precedent, which "shall be binding as precedent in the Eleventh Circuit, for this court, the district courts, and the bankruptcy courts in the circuit." Georgia was in the Fifth Circuit until October 1, 1981, so these older Fifth Circuit decisions bind Georgia's federal courts today. Date: 1981-01-01 Tags: legal,eighth_amendment Sources: Bonner v. City of Prichard, 661 F.2d 1206 (11th Cir. 1981) - [confirmed] Smith v. Sullivan limits federal court temperature-range orders Smith v. Sullivan, 553 F.2d 373 (5th Cir. 1977), an El Paso County jail case, held (at 381): "The District Court's order must be limited by deleting the requirement of maintaining a specific temperature range. If the proof shows the occurrence of extremes of temperature that are likely to be injurious to inmates' health relief should be granted, but beyond these limits a federal court may not issue commands in the name of the Constitution." Date: 1977-01-01 Tags: legal,conditions,heat,eighth_amendment Sources: Smith v. Sullivan, 553 F.2d 373 (5th Cir. 1977) - [confirmed] Smith v. Sullivan cuts both ways for Georgia For Georgia, Smith v. Sullivan is binding authority that proof of temperature extremes likely to injure health warrants relief, and also binding authority that a federal court may not order a fixed temperature range as such. The Texas ruling of September 22, 2026 quotes the first half of this passage. Smith v. Sullivan limits what a federal court may order; it does not limit what a legislature may enact. Date: 1977-01-01 Tags: legal,conditions,heat,eighth_amendment Sources: Smith v. Sullivan, 553 F.2d 373 (5th Cir. 1977) - [confirmed] Gates v. Collier: fund shortage no defense to unconstitutional conditions Gates v. Collier, 501 F.2d 1291 (5th Cir. 1974) (Mississippi State Penitentiary at Parchman), at 1319: "Where state institutions have been operating under unconstitutional conditions and practices, the defenses of fund shortage and the inability of the district court to order appropriations by the state legislature, have been rejected by the federal courts." The Texas court relied on this passage for its order that cost is no excuse. Date: 1974-01-01 Tags: legal,conditions,budget,eighth_amendment Sources: Gates v. Collier, 501 F.2d 1291 (5th Cir. 1974) - [confirmed] Wyatt v. Aderholt: obligation to remedy does not depend on legislature or governor Wyatt v. Aderholt, 503 F.2d 1305 (5th Cir. 1974) (Alabama state mental institutions), adopted by quotation from Holt v. Sarver (E.D. Ark. 1970) the principle that "the obligation of the Respondents to eliminate existing unconstitutionalities does not depend upon what the Legislature may do, or upon what the Governor may do, or, indeed, upon what Respondents may actually be able to accomplish." The Texas ruling cites Wyatt at 1315 for this point. Date: 1974-01-01 Tags: legal,conditions,eighth_amendment Sources: Wyatt v. Aderholt, 503 F.2d 1305 (5th Cir. 1974) - [confirmed] Court finds Lumpkin's failure to plan air conditioning is deliberate indifference The court held: 'In the face of clear evidence of risk—including ongoing injuries, deaths, and suffering every summer—Director Lumpkin's failure to enact a meaningful, committed plan to install air-conditioning on the timeline that TDCJ has repeatedly indicated is possible is deliberate indifference.' (Dkt. 350 at 136). Date: 2026-01-01 Tags: legal,conditions,heat Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [confirmed] Green v. Secretary: discomfort without more not an Eighth Amendment violation Green v. Secretary for the Department of Corrections, 212 F. App'x 869 (11th Cir. 2006): a Florida prisoner at Glades Correctional Institution alleged the dormitories had no air conditioning or adequate ventilation; affirmed for the warden under Chandler: "Discomfort, without more, does not amount to an Eighth Amendment violation." Date: 2006-01-01 Tags: legal,conditions,heat,eighth_amendment Sources: Green v. Secretary for the Department of Corrections, 212 F. App'x 869 (11th Cir. 2006) - [confirmed] Green v. Mowery: cooling claim failed for lack of causal connection Green v. Mowery, 212 F. App'x 918 (11th Cir. 2006): a cooling and ventilation claim; affirmed for the defendant for lack of a causal connection to him. Date: 2006-01-01 Tags: legal,conditions,heat,eighth_amendment Sources: Green v. Mowery, 212 F. App'x 918 (11th Cir. 2006) - [confirmed] Hernandez v. Florida DOC applies Chandler at pleading stage Hernandez v. Florida Department of Corrections, 281 F. App'x 862 (11th Cir. 2008): applies Chandler to a temperature claim at the pleading stage. Date: 2008-01-01 Tags: legal,conditions,heat,eighth_amendment Sources: Hernandez v. Florida Department of Corrections, 281 F. App'x 862 (11th Cir. 2008) - [confirmed] Ivory v. Warden: heat record must identify conditions and health impact with specificity Ivory v. Warden, 600 F. App'x 670 (11th Cir. 2015): an Alabama prisoner's challenge to conditions including heating, cooling and ventilation at Easterling failed because "the evidence regarding the temperature, ventilation, overcrowding, and supervision at Easterling fails to identify with specificity the nature of the conditions and their impact on Ivory's health." This shows what a heat record in this circuit must contain: specific measurements and specific effects on health. Date: 2015-01-01 Tags: legal,conditions,heat,eighth_amendment Sources: Ivory v. Warden, 600 F. App'x 670 (11th Cir. 2015) - [confirmed] Guthrie v. Evans: temperature control included in consent decree Guthrie v. Evans, filed September 29, 1972, produced one of the most comprehensive prison consent decrees in U.S. history. Judge Anthony A. Alaimo's orders specifically addressed 'prison sanitation, food preparation, temperature control, fire control, industries, and ventilation in the prison system' — meaning that by 1985, GDC was operating Georgia State Prison under federal oversight that included environmental conditions. Tags: legal,conditions Sources: Civil Rights Litigation Clearinghouse, Guthrie v. Evans case page - [confirmed] Groover v. Broward County Sheriff: heat-stroke transport claim vacated for amendment Groover v. Broward County Sheriff, 684 F. App'x 782 (11th Cir. 2017): a 52-hour August transport in a van cage with inadequate ventilation, with heat stroke alleged; the court said the complaint sufficiently alleged a constitutional violation but not facts tying it to the named defendants, and vacated the dismissal so he could amend. Date: 2017-01-01 Tags: legal,conditions,heat,transfers,eighth_amendment Sources: Groover v. Broward County Sheriff, 684 F. App'x 782 (11th Cir. 2017) - [confirmed] Saunders v. Sheriff of Brevard County: single vent example insufficient for qualified immunity denial Saunders v. Sheriff of Brevard County, No. 16-17607 (11th Cir. May 17, 2018): a Florida jail claim of dangerously high cell temperatures; the court treated it as a serious allegation but held the one specific example (an air-conditioning vent blowing no air for up to two days) insufficient and reversed the denial of qualified immunity. Date: 2018-01-01 Tags: legal,conditions,heat,eighth_amendment Sources: Saunders v. Sheriff of Brevard County, No. 16-17607 (11th Cir. 2018) - [confirmed] Declaratory judgment: un-air-conditioned TDCJ prisons violate Eighth Amendment Order paragraph 1: 'The conditions of confinement in TDCJ's un-air-conditioned prisons are declared to violate the Eighth Amendment rights of all inmates confined in those facilities, and TDCJ's current response to heat conditions is declared to be insufficient to remedy that violation.' (Dkt. 350 at 149). Date: 2026-01-01 Tags: legal,conditions,heat Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [confirmed] Stallworth v. Wilkins: poor ventilation allegations do not state Eighth Amendment claim Stallworth v. Wilkins, No. 18-12445 (11th Cir. Jan. 17, 2020): "Stallworth's allegations about poor ventilation in his cell do not give rise to an Eighth Amendment claim." Date: 2020-01-01 Tags: legal,conditions,heat,eighth_amendment Sources: Stallworth v. Wilkins, No. 18-12445 (11th Cir. 2020) - [confirmed] Estelle v. Gamble: deliberate indifference to medical needs established Estelle v. Gamble, 429 U.S. 97 (1976), established that 'deliberate indifference to serious medical needs of prisoners constitutes the unnecessary and wanton infliction of pain proscribed by the Eighth Amendment.' Date: 1976-12-01 Tags: legal,medical Sources: Estelle v. Gamble, 429 U.S. 97 (1976) - [confirmed] Air conditioning installation deadline of December 31, 2029 Order paragraph 2 requires the Director to develop and implement a plan to install air conditioning 'in every Texas prison, with installation to be completed not later than December 31, 2029.' (Dkt. 350 at 149). Tags: legal,facilities,policy,heat Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [confirmed] Turner v. Warden: Georgia strip-cell cold claim failed under Chandler Turner v. Warden, 650 F. App'x 695 (11th Cir. 2016), a Georgia case from the special management unit at Georgia Diagnostic and Classification Prison in Jackson (events of 2009 to 2010): a cold strip-cell claim failed under Chandler. Date: 2016-01-01 Tags: legal,conditions,solitary,facilities Sources: Turner v. Warden, 650 F. App'x 695 (11th Cir. 2016) - [confirmed] Rhodes v. Chapman: minimal civilized measure of life's necessities Rhodes v. Chapman, 452 U.S. 337 (1981), held that the Constitution 'does not mandate comfortable prisons' but 'neither does it permit inhumane ones,' and that conditions which deprive inmates of 'the minimal civilized measure of life's necessities' violate the Eighth Amendment. Date: 1981-01-01 Tags: legal,conditions Sources: Conditions of Confinement, Constitution Annotated, Library of Congress, 2024 - [confirmed] Six-month status reports required, first due March 22, 2027 Order paragraph 3: 'Defendant shall submit status reports to the Court every six months, with the first such report due on or before March 22, 2027.' (Dkt. 350 at 149). The first report must set out phases of construction, procurement and design, and 'the amounts he intends to request from the Legislature to fund each stage of the plan' (order paragraph 4, Dkt. 350 at 150). Date: 2027-01-01 Tags: legal,budget,policy Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [confirmed] Helling v. McKinney: future harm from environmental conditions can ground Eighth Amendment claim Helling v. McKinney, 509 U.S. 25 (1993), held that 'an injunction cannot be denied to inmates who plainly prove an unsafe, life-threatening condition on the ground that nothing yet has happened to them'; future harm from environmental exposures can ground an Eighth Amendment claim. Date: 1993-06-01 Tags: legal,conditions Sources: Helling v. McKinney, 509 U.S. 25 (1993) - [confirmed] Court: financial considerations not a legitimate reason for noncompliance Order paragraph 6: 'Defendant is advised that financial considerations will not be considered a legitimate reason for his failure to comply with this Court's order.' (Dkt. 350 at 150). The court supports this with Gates v. Collier, 501 F.2d 1291, 1319 (5th Cir. 1974), and Wyatt v. Aderholt, 503 F.2d 1305, 1315 (5th Cir. 1974). Date: 2026-01-01 Tags: legal,budget,policy Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [confirmed] Gates v. Cook heat-index injunction requirements Gates v. Cook, 376 F.3d 323 (5th Cir. 2004) (Parchman death row, Mississippi), upheld an injunction requiring that "If the heat index reaches 90 degrees or above, the defendants will insure that each cell is equipped with a fan, that ice water is available to each inmate, and that each inmate may take one shower during each day when the heat index is 90 degrees or above." Date: 2004-01-01 Tags: legal,conditions,heat,eighth_amendment Sources: Gates v. Cook, 376 F.3d 323 (5th Cir. 2004) - [confirmed] Farmer v. Brennan: deliberate indifference defined Farmer v. Brennan, 511 U.S. 825 (1994), defined 'deliberate indifference' as actual subjective awareness of, and disregard for, 'a substantial risk of serious harm.' Date: 1994-06-01 Tags: legal Sources: Farmer v. Brennan, 511 U.S. 825 (1994) - [confirmed] Gates v. Cook: probability of heat-related illness extreme at Unit 32-C Gates v. Cook, 376 F.3d 323 (5th Cir. 2004): "Based on the evidence presented, we cannot say that the trial court's finding that the probability of heat-related illness is extreme at Unit 32-C was clearly erroneous." Date: 2004-01-01 Tags: legal,conditions,heat,medical Sources: Gates v. Cook, 376 F.3d 323 (5th Cir. 2004) - [confirmed] Hope v. Pelzer: outdoor heat exposure held obviously unconstitutional Hope v. Pelzer, 536 U.S. 730 (2002), held that handcuffing a prisoner to a hitching post for seven hours in the Alabama sun, without access to water or bathroom breaks, constituted obvious cruel and unusual punishment, and that Alabama prison guards were not entitled to qualified immunity. The case arose from prolonged heat-related outdoor exposure directly analogous to the Ramirez death at Telfair. Date: 2002-01-01 Tags: legal,conditions,violence Sources: Hope v. Pelzer, 536 U.S. 730 (2002), Northwestern Journal of Criminal Law analysis - [confirmed] Court declined heat score system and special master under PLRA The court explained its remedy choice under the Prison Litigation Reform Act (PLRA), which requires relief to be narrowly drawn and the least intrusive means: it adopted TDCJ's own engineering timeline, declined to appoint a special master, and stated that 'the Court is not implementing a heat score system' that would move only medically heat-sensitive people into cooled beds, because that would intrude further into prison management and would still leave healthy people at risk (Dkt. 350 at 148 to 149). Date: 2026-01-01 Tags: legal,policy,heat Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [confirmed] Ball I: Eighth Amendment violation affirmed but injunction vacated as broader than PLRA allows Ball v. LeBlanc, 792 F.3d 584 (5th Cir. 2015) ("Ball I"): affirmed the Eighth Amendment violation for three Angola death-row prisoners but vacated the injunction as broader than the PLRA allows. Date: 2015-01-01 Tags: legal,conditions,heat,eighth_amendment Sources: Ball v. LeBlanc, 792 F.3d 584 (5th Cir. 2015) - [confirmed] PLRA physical injury requirement bars emotional-only claims The PLRA's physical injury requirement (42 U.S.C. § 1997e(e)) bars recovery for mental or emotional injury without a prior showing of physical injury. Heat plaintiffs typically plead documented heat illness, dehydration, hypertension exacerbation, or death. Tags: legal Sources: Conditions of Confinement, Constitution Annotated, Library of Congress, 2024 - [confirmed] Attorney's fee briefing due October 20, 2026; post-trial intervention motions denied Other orders in Dkt. 350: attorney's fee briefing due October 20, 2026; motions to intervene filed after trial denied as untimely; final judgment to be entered by separate order (Dkt. 350 at 150). Date: 2026-01-01 Tags: legal,budget Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [confirmed] Ball I lists acceptable heat remedies short of facility-wide air conditioning Ball v. LeBlanc, 792 F.3d 584 (5th Cir. 2015): "Plaintiffs' own expert, Dr. Vassallo, explained that there are many acceptable remedies short of facility-wide air conditioning," listing among them diverting cool air from the guards' pod, access to air-conditioned areas, cool showers at least once a day, cold drinking water and ice, personal ice containers and individual fans, and additional ice machines. Date: 2015-01-01 Tags: legal,conditions,heat,policy Sources: Ball v. LeBlanc, 792 F.3d 584 (5th Cir. 2015) - [confirmed] PLRA narrowness requirement constrains heat remedies Under the PLRA (18 U.S.C. § 3626), injunctive relief must be 'narrowly drawn, extend no further than necessary to correct the violation … and the least intrusive means necessary.' This provision was invoked by the Fifth Circuit in Ball v. LeBlanc to vacate a district-court order requiring full air conditioning at Angola death row. Tags: legal Sources: Ball v. LeBlanc, 792 F.3d 584 (5th Cir. 2015), FindLaw - [confirmed] Ball I: relief must be limited to named plaintiffs, not facility-wide Ball v. LeBlanc, 792 F.3d 584 (5th Cir. 2015): "The district court also erred because it awarded relief facility-wide, instead of limiting such relief to Ball, Code, and Magee." Date: 2015-01-01 Tags: legal,conditions,heat,eighth_amendment Sources: Ball v. LeBlanc, 792 F.3d 584 (5th Cir. 2015) - [confirmed] Ball I vacated Louisiana death row air conditioning injunction as PLRA-overbroad Ball v. LeBlanc, 792 F.3d 584 (5th Cir. 2015) ('Ball I') vacated an injunction that effectively required air conditioning on Louisiana's death row as broader than the PLRA allows. The Texas court distinguishes it: 'that holding was on a record indicating that mitigation measures could address the risks faced by inmates.' (Dkt. 350 at 144). The court found that, on this record, fans, water and respite measures have not controlled the risk. Date: 2015-01-01 Tags: legal,conditions,heat Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [confirmed] Ball II reversed Angola injunction for setting maximum heat index Ball v. LeBlanc, 881 F.3d 346 (5th Cir. 2018) ('Ball II') reversed a later Angola injunction because it set a maximum heat index: 'It is by effectively requiring a temperature ceiling that the district court went astray.' The Texas order sets a completion date for air conditioning rather than a temperature ceiling. Date: 2018-01-01 Tags: legal,conditions,heat Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026); Ball v. LeBlanc, 881 F.3d 346 (5th Cir. 2018) - [confirmed] Ball II: injunction reversed for incorporating a maximum heat index Ball v. LeBlanc, 881 F.3d 346 (5th Cir. 2018) ("Ball II"): reversed a later injunction because it incorporated a maximum heat index: "It is by effectively requiring a temperature ceiling that the district court went astray." The court left open that on remand "the court may require Icy-Breeze units or temperature triggers." Date: 2018-01-01 Tags: legal,conditions,heat,eighth_amendment Sources: Ball v. LeBlanc, 881 F.3d 346 (5th Cir. 2018) - [confirmed] Cole v. Collier settlement: 88°F heat index ceiling and permanent AC The March/May 2018 Cole v. Collier settlement required TDCJ to install temporary air conditioning at the Pack Unit and replace it with permanent AC by May 1, 2020; maintain heat indices at or below 88°F in housing areas between April 15 and October 15 each year; and pay $4.5 million in attorneys' fees. Date: 2018-06-08 Tags: legal,conditions,policy Sources: Cole v. Collier, Case No. 4:14-cv-01698 (S.D. Tex.), Civil Rights Litigation Clearinghouse - [confirmed] Parker v. Hooper vacated system-wide remedial order under PLRA Parker v. Hooper, No. 23-30825 (5th Cir. Mar. 30, 2026), a Louisiana State Penitentiary medical-care class case, vacated and remanded a system-wide remedial order under the PLRA. Its opening sentence: 'This appeal arises from atavistic court rulings that seek to control prison management in violation of constitutional law and fundamental principles of federalism.' The Texas ruling cites Parker for the rule that deliberate indifference is judged by officials' current attitudes and conduct (Dkt. 350 at 118). Parker is not a heat case, but it is the Fifth Circuit's most recent word on system-wide Eighth Amendment remedies. Date: 2026-03-30 Tags: legal,medical,conditions Sources: Parker v. Hooper, No. 23-30825 (5th Cir. Mar. 30, 2026) - [confirmed] Hinojosa v. Livingston: open and obvious hot conditions support deliberate indifference inference Hinojosa v. Livingston, 807 F.3d 657 (5th Cir. 2015): a heat-stroke death in a Texas prison; affirmed an order allowing limited discovery before ruling on qualified immunity. "In any event, the open and obvious nature of the dangerously hot conditions would also support an inference of deliberate indifference." Date: 2015-01-01 Tags: legal,conditions,heat,death,eighth_amendment Sources: Hinojosa v. Livingston, 807 F.3d 657 (5th Cir. 2015) - [confirmed] Texas ruling binds only parties, not precedent for other courts The Texas ruling is a trial-court decision. It binds only the parties and is not precedent for other courts. Date: 2026-01-01 Tags: legal Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [confirmed] Yates v. Collier: TDCJ officials defendants in numerous heat cases Yates v. Collier, 868 F.3d 354 (5th Cir. 2017): affirmed class certification for the Wallace Pack Unit heat case. At 360: "TDCJ officials are, or have been, defendants in numerous other cases alleging Eighth Amendment violations based on excessive heat in prison." Date: 2017-01-01 Tags: legal,conditions,heat,eighth_amendment Sources: Yates v. Collier, 868 F.3d 354 (5th Cir. 2017) - [confirmed] Blackmon v. Garza: judgment for officials reversed and remanded for new trial Blackmon v. Garza, 484 F. App'x 866 (5th Cir. 2012): reversed judgment for prison officials at the Garza East Unit and remanded for a new trial. Date: 2012-01-01 Tags: legal,conditions,heat,eighth_amendment Sources: Blackmon v. Garza, 484 F. App'x 866 (5th Cir. 2012) - [confirmed] Webb v. Livingston: appeals over five Texas heat deaths dismissed for lack of jurisdiction Webb v. Livingston, 618 F. App'x 201 (5th Cir. 2015): appeals over the heat deaths of five Texas prisoners dismissed for lack of jurisdiction. Date: 2015-01-01 Tags: legal,conditions,heat,death Sources: Webb v. Livingston, 618 F. App'x 201 (5th Cir. 2015) - [confirmed] Valigura v. Mendoza: bunk-area temperatures into the nineties and hundreds Valigura v. Mendoza, 265 F. App'x 232 (5th Cir. 2008): bunk-area temperatures into the nineties and hundreds; qualified-immunity appeal affirmed in part. Date: 2008-01-01 Tags: legal,conditions,heat,eighth_amendment Sources: Valigura v. Mendoza, 265 F. App'x 232 (5th Cir. 2008) - [confirmed] Coones v. Cogburn: Eighth Amendment heat-death claim reinstated against TDCJ director Coones v. Cogburn, No. 24-10777 (5th Cir. July 25, 2025): heat death at a Texas unit; reinstated the Eighth Amendment claim against the TDCJ director and others: "inmates have a right to be free from excessive heat". Date: 2025-07-25 Tags: legal,conditions,heat,death,eighth_amendment Sources: Coones v. Cogburn, No. 24-10777 (5th Cir. 2025) - [confirmed] Judge Pitman: Texas prison heat 'plainly unconstitutional' (March 2025) On March 26, 2025, U.S. District Judge Robert Pitman issued a 91-page preliminary-injunction opinion finding that 'excessive heat is likely serving as a form of unconstitutional punishment' and that conditions in Texas's roughly two-thirds-uncooled prisons are 'plainly unconstitutional.' Date: 2025-03-26 Tags: legal,conditions Sources: Federal judge says heat in Texas prisons is unconstitutional, KUT, March 26, 2025 - [confirmed] Ball v. LeBlanc: 88°F heat index ceiling ordered for Angola death row In Ball v. LeBlanc, Chief U.S. District Judge Brian Jackson found Eighth Amendment violations and issued an injunction effectively requiring the State to maintain death-row heat indices at or below 88°F (December 19, 2013). The Fifth Circuit affirmed liability but vacated the remedy as overbroad under the PLRA. Date: 2013-12-19 Tags: legal,conditions Sources: Ball v. LeBlanc, 792 F.3d 584 (5th Cir. 2015), FindLaw - [confirmed] Fifth Circuit Ball I: remedies short of facility-wide air conditioning The Fifth Circuit's Ball I decision (792 F.3d 584, 2015) vacated an injunction that effectively required air conditioning on Angola's death row, stating: “Plaintiffs’ own expert, Dr. Vassallo, explained that there are many acceptable remedies short of facility-wide air conditioning.” The court's examples: diverting cool air from the guards' pod into the tiers, access to air-conditioned areas during tier time, cool showers at least once a day, an ample supply of cold drinking water and ice, personal ice containers and individual fans, and additional ice machines. It held: “These are precisely the types of remedies this court endorsed in Gates v. Cook and that the PLRA requires.” Date: 2015-07-08 Tags: legal,conditions Sources: Ball v. LeBlanc, 792 F.3d 584 (5th Cir. 2015), FindLaw - [confirmed] Wilson v. Dixon class certified: 1,500+ inmates at Dade CI On September 26, 2025, Judge Kathleen Williams certified a class of more than 1,500 inmates at Dade CI in Wilson v. Dixon. Date: 2025-09-26 Tags: legal,conditions Sources: Florida Inmates Earn Class Status in Suit Over 'Unbearable' Heat, Bloomberg Law, September 29, 2025 - [confirmed] Graves v. Arpaio: 85°F ceiling for psychotropic-medicated detainees upheld Graves v. Arpaio, 623 F.3d 1043 (9th Cir. 2010), upheld an injunction requiring Maricopa County to house pretrial detainees on psychotropic medication in temperatures not exceeding 85°F. Date: 2010-01-01 Tags: legal,conditions,mental_health Sources: Parsons v. Ryan, 754 F.3d 657 (9th Cir. 2014), FindLaw - [confirmed] Nelson Mandela Rules require attention to climatic conditions in prison accommodation The UN Standard Minimum Rules for the Treatment of Prisoners (Nelson Mandela Rules), Rule 13, requires that 'all accommodation provided for the use of prisoners and in particular all sleeping accommodation shall meet all requirements of health, due regard being paid to climatic conditions and particularly to cubic content of air, minimum floor space, lighting, heating and ventilation.' Rule 35 requires inspection and advice on 'the sanitation, temperature, lighting and ventilation of the prison.' Date: 2015-12-01 Tags: legal,conditions,policy Sources: UN General Assembly Resolution 70/175 - [confirmed] Texas county jails required to maintain 65-85°F Texas county jails are statutorily required to maintain temperatures between 65°F and 85°F — a benchmark cited repeatedly by Texas plaintiffs and by Judge Pitman in Tiede. Tags: legal,policy,conditions Sources: Texas Prison Heat Declared Unconstitutional, Prison Legal News, May 2025 - [confirmed] OSHA does not have jurisdiction over incarcerated workers OSHA does not have jurisdiction over incarcerated workers, and there is no enforceable federal heat-exposure standard for prison labor. Proposed OSHA heat rules under the Biden administration were focused on free-world workers and did not extend to incarcerated workforces. Tags: legal,policy,operations Sources: Litigation Heats Up Over Extreme Temperatures in Prisons, Jails, Prison Legal News, June 2018 STATISTICS (50) ---------------------------------------- - [disputed] Only 3 of 35 GDC prisons fully air-conditioned (Feb 2024) Only three of the Georgia Department of Corrections' 35 prisons were fully air-conditioned as of February 2024, according to documents reviewed by the Southern Center for Human Rights. Value: 3.0 fully air-conditioned prisons out of 35 (vs. 35 total GDC prisons) Date: 2024-02-01 Tags: conditions,facilities,policy Sources: A Matter of Life and Death: As Temperatures Soar, People Incarcerated in Georgia's Prisons Endure Cruel and Possibly Deadly Conditions - [confirmed] Global annual deaths associated with non-optimal temperatures An estimated 5,083,173 deaths per year (95% empirical CI 4,087,967 to 5,965,520) were associated with non-optimal temperatures globally. Value: 5083173.0 deaths per year Tags: death,conditions Sources: Global, regional, and national burden of mortality associated with non-optimal ambient temperatures from 2000 to 2019: a three-stage modelling study - [reported] 9 of 11 Southwest Georgia prisons have broken AC in dorms In nine of the eleven prisons in Georgia's hot Southwest region, dorms have broken AC units. Value: 9.0 prisons with broken AC units out of 11 in Southwest region (vs. 11 Southwest Georgia prisons) Date: 2024-01-01 Tags: conditions,facilities Sources: A Matter of Life and Death: As Temperatures Soar, People Incarcerated in Georgia's Prisons Endure Cruel and Possibly Deadly Conditions - [confirmed] Percentage of all global deaths attributable to non-optimal temperatures Non-optimal temperatures accounted for 9.43% of all deaths globally (95% eCI 7.58 to 11.07). Value: 9.43 percent of all deaths Tags: death,conditions Sources: Global, regional, and national burden of mortality associated with non-optimal ambient temperatures from 2000 to 2019: a three-stage modelling study - [confirmed] Cold-related share of global temperature-attributable mortality Cold-related deaths accounted for 8.52% of all global deaths (95% eCI 6.19 to 10.47). Value: 8.52 percent of all deaths Tags: death,conditions Sources: Global, regional, and national burden of mortality associated with non-optimal ambient temperatures from 2000 to 2019: a three-stage modelling study - [confirmed] Heat-related share of global temperature-attributable mortality Heat-related deaths accounted for 0.91% of all global deaths (95% eCI 0.56 to 1.36). Value: 0.91 percent of all deaths Tags: death,conditions Sources: Global, regional, and national burden of mortality associated with non-optimal ambient temperatures from 2000 to 2019: a three-stage modelling study - [confirmed] Global temperature-related excess death rate per 100,000 residents The overall temperature-related excess death rate was 74 per 100,000 residents (95% eCI 60 to 87). Value: 74.0 deaths per 100,000 residents Tags: death,conditions Sources: Global, regional, and national burden of mortality associated with non-optimal ambient temperatures from 2000 to 2019: a three-stage modelling study - [confirmed] Heat indexes outside TDCJ prisons reached 134 degrees The court found 'heat indexes measured outside of TDCJ prisons reaching 134 degrees and indoor temperatures consistently exceeding 85 degrees across the system and often reaching far higher' (Dkt. 350 at 119). Value: 134.0 degrees heat index (vs. 85 indoor temperatures consistently exceeding (degrees)) Date: 2026-01-01 Tags: conditions,facilities,heat Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [disputed] GDC 2016 self-reported 16 fully AC facilities In a 2016 GDC press release announcing summer-heat measures during a series of facility lockdowns, the agency stated that '16 facilities are fully air-conditioned and six facilities with some air-conditioned living units, to include medical, geriatric and the majority of mental health units.' The mismatch between the 2016 self-reported 16 and the 2024 SCHR-documented 3 is unresolved. Value: 16.0 facilities self-reported as fully air-conditioned (vs. 3 facilities documented as fully AC in 2024) Date: 2016-07-01 Tags: conditions,facilities,policy Sources: GDC Facilities Lockdown Update, Georgia Department of Corrections, July 11, 2016 - [confirmed] Asia's share of global excess deaths from non-optimal temperatures Of all excess deaths associated with non-optimal temperatures, 2,617,322 (51.49%) occurred in Asia. Value: 2617322.0 deaths (vs. 51.49 percent of global excess deaths) Tags: death,conditions Sources: Global, regional, and national burden of mortality associated with non-optimal ambient temperatures from 2000 to 2019: a three-stage modelling study - [confirmed] Three heat-related deaths in summer 2023 acknowledged by TDCJ The court found 'three heat-related deaths in the summer of 2023 acknowledged by TDCJ and at least six further heat-related deaths from 2023 through 2025' (Dkt. 350 at 120). Value: 3.0 deaths (vs. 6 further heat-related deaths 2023-2025) Tags: death,heat,conditions Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [disputed] Prison Journalism Project: 25% of Georgia prisons fully AC (2022) The Prison Journalism Project (September 2022) reported that 'only a quarter of the state's prisons are fully air-conditioned.' GPB (July 2024) reported the same baseline. Value: 25.0 percent of Georgia prisons fully air-conditioned Date: 2022-09-01 Tags: conditions,facilities Sources: Sweltering Days in a Georgia Prison Without Air Conditioning, Prison Journalism Project, September 2022 - [confirmed] TDCJ acknowledges at least 23 inmate deaths due to heat The court states that 'TDCJ acknowledges at least twenty-three inmate deaths due to heat' (Dkt. 350 at 59), a longer-period figure than the summer 2023 count. Value: 23.0 deaths Tags: death,heat,conditions Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [disputed] Nearly 15,000 heat grievances over three summers (page 59) The court describes the heat grievances as 'nearly 15,000' over the last three summers at page 59 of Dkt. 350, while at page 120 it states 'more than 15,000.' The two pages of the same order differ, so cite the page. Value: 15000.0 grievances Tags: conditions,heat,operations Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [confirmed] More than 100,000 of roughly 140,000 TDCJ inmates heat-vulnerable The court found 'more than 100,000 of the roughly 140,000 inmates incarcerated in TDCJ prisons had medical conditions or prescriptions increasing their heat vulnerability' (Dkt. 350 at 33). Value: 100000.0 inmates (vs. 140000 total TDCJ inmate population) Date: 2026-01-01 Tags: medical,heat,demographics,conditions Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [confirmed] 88,697 TDCJ inmates (63 percent) in un-air-conditioned housing summer 2026 The court found 'approximately 88,697 inmates, some 63 percent of the TDCJ population, were living in un-air-conditioned housing in the summer of 2026' (Dkt. 350 at 119). Value: 88697.0 inmates (vs. 63 percent of TDCJ population) Date: 2026-01-01 Tags: conditions,facilities,heat,demographics Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [confirmed] TDCJ estimates systemwide permanent air conditioning would cost $1.5 billion The court notes 'TDCJ's own estimate that systemwide permanent air conditioning would cost approximately $1.5 billion' (Dkt. 350 at 98). Value: 1500000000.0 dollars Date: 2026-01-01 Tags: budget,facilities,heat,policy Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [confirmed] Cole v. Collier: Pack Unit heat indices exceeded 100°F on 74 days in 2011 Outdoor heat indices at the Pack Unit exceeded 100°F on 74 days during the 2011 heat wave that killed 11 Texas prisoners; the index exceeded 100°F on 73 days in 2013 and 34 days in 2014. Value: 74.0 days exceeding 100°F heat index in 2011 Date: 2011-01-01 Tags: conditions Sources: Cole v. Collier, Case No. 4:14-cv-01698 (S.D. Tex.), Civil Rights Litigation Clearinghouse - [reported] Iowa corrections officials sought air conditioning funding for 15 years Iowa corrections officials have spent 15 years asking lawmakers to fund air conditioning at two prisons; Gov. Kim Reynolds included $8.1 million for the projects in her budget this year and lawmakers again declined. Value: 8100000.0 dollars (vs. 15 years of requests) Date: 2026-01-01 Tags: budget,facilities,policy,heat Sources: Jamiles Lartey, "From Sweltering Cells to Frigid Tents: The Extreme Temperatures of Incarceration," The Marshall Project, Closing Argument newsletter, September 26, 2026 - [confirmed] TDCJ acknowledged 23 heat-related deaths 1998-2012 From 1998 through 2012, TDCJ has formally acknowledged 23 heat-related deaths. Value: 23.0 heat-related deaths Tags: death,conditions Sources: Heat-related Deaths in Texas Prisons Lead to Lawsuits, Reluctant Changes, Prison Legal News, August 2014 - [reported] Arizona cut roughly a third of prison heating and cooling funds in 2024 Arizona: the legislature had allocated nearly $170 million over several years for modern heating and cooling in state prisons, then cut roughly a third of it in 2024; 24 Arizona prison units still rely on evaporative 'swamp' coolers. Value: 170000000.0 dollars (vs. 24 prison units relying on swamp coolers) Date: 2024-01-01 Tags: budget,facilities,policy,heat Sources: Jamiles Lartey, "From Sweltering Cells to Frigid Tents: The Extreme Temperatures of Incarceration," The Marshall Project, Closing Argument newsletter, September 26, 2026 - [confirmed] 11 Texas prisoners killed in 2011 heat wave The 2011 heat wave killed 11 Texas prisoners, coinciding with outdoor heat indices exceeding 100°F on 74 days at the Pack Unit. Value: 11.0 prisoner deaths Date: 2011-01-01 Tags: death,conditions Sources: Cole v. Collier, Case No. 4:14-cv-01698 (S.D. Tex.), Civil Rights Litigation Clearinghouse - [reported] California $38 million air conditioning pilot at three of 31 prisons California: a $38 million pilot is testing air conditioning, insulation or both at three of the state's 31 prisons, with the goal of keeping all indoor temperatures at or below 78 degrees; results are not expected until mid-2029 and the pilot requires no state action whatever the outcome. Value: 38000000.0 dollars (vs. 78 target maximum indoor temperature (degrees)) Date: 2026-01-01 Tags: budget,facilities,policy,heat Sources: Jamiles Lartey, "From Sweltering Cells to Frigid Tents: The Extreme Temperatures of Incarceration," The Marshall Project, Closing Argument newsletter, September 26, 2026 - [confirmed] 134,500 Texas prisoners face substantial risk from heat Judge Pitman found that approximately 134,500 prisoners face 'a substantial risk of serious harm from the extreme heat in unair-conditioned facilities.' Value: 134500.0 prisoners at risk Date: 2025-03-01 Tags: conditions Sources: Federal judge says heat in Texas prisons is unconstitutional, KUT, March 26, 2025 - [confirmed] TDCJ heat-score system covers only ~10% of prisoners Judge Pitman found that TDCJ's 'heat score' system — under which only roughly 10% of prisoners qualify for prioritized cool beds — is 'arbitrary, inadequate, and ineffective.' Value: 10.0 percent of prisoners qualifying for cool beds Date: 2025-03-01 Tags: conditions,policy Sources: Federal judge says heat in Texas prisons is unconstitutional, KUT, March 26, 2025 - [disputed] 10 Texas prisoner heat deaths since 2023 alleged by plaintiffs Plaintiffs' attorney Kevin Homiak argued that 10 prisoners had died of heat-related causes since 2023 (TDCJ acknowledged three). Value: 10.0 heat-related deaths alleged since 2023 (vs. 3 TDCJ-acknowledged heat deaths since 2023) Tags: death,conditions Sources: TDCJ's estimated cost to fully cool Texas prisons rises to $1.5B, The Texas Tribune, March 31, 2026 - [reported] TDCJ estimates $1.5 billion for full system-wide AC TDCJ now estimates that full system-wide AC would cost approximately $1.5 billion, with annual operating costs near $20 million. Value: 1.5 billion dollars estimated cost (vs. 20 million dollars annual operating cost) Date: 2026-01-01 Tags: budget,conditions Sources: TDCJ's estimated cost to fully cool Texas prisons rises to $1.5B, The Texas Tribune, March 31, 2026 - [reported] TDCJ: approximately 52,000 cool beds in 140,000-person system As of trial, TDCJ reports approximately 52,000 cool beds in a 140,000-person system, with 9,000 more planned by year-end 2026. Value: 52000.0 cool beds (vs. 140000 total prisoner population) Date: 2026-04-01 Tags: conditions,facilities Sources: Texas prisoners await a judge's ruling and another hot summer after federal trial, KUT/TPR, April 10, 2026 - [reported] Texas: 85,000 of 134,500 prisoners in uncooled housing Approximately 85,000 of 134,500 prisoners are in uncooled housing in Texas. 32 of 101 units are fully air-conditioned, 55 partially, 14 with little or none. Value: 85000.0 prisoners in uncooled housing (vs. 134500 total Texas prisoners) Date: 2025-01-01 Tags: conditions,facilities Sources: Federal judge says heat in Texas prisons is unconstitutional, KUT, March 26, 2025 - [confirmed] Texas 2023: $32.7B surplus but no direct prison AC funding The 2023 Texas session — when Texas had a $32.7 billion surplus — produced no direct prison AC funding; the House had budgeted $545 million but the Senate offered nothing. Lawmakers ultimately allocated $85 million for roughly 10,000 cool beds. Value: 85.0 million dollars allocated (vs. 545 million dollars House had budgeted) Date: 2023-01-01 Tags: budget,policy Sources: House panel passes bill requiring air conditioning in Texas prisons by 2032, The Texas Tribune, April 2025 - [reported] Texas 2025 supplemental: $118M for 11,000 cool beds, $301M for new AC dorms The 2025 Texas supplemental appropriations bill included $118 million for approximately 11,000 new air-conditioned beds and $301 million for new air-conditioned dorms. Value: 419.0 million dollars total ($118M + $301M) Date: 2025-01-01 Tags: budget,policy Sources: House panel passes bill requiring air conditioning in Texas prisons by 2032, The Texas Tribune, April 2025 - [estimated] Louisiana spent $1M+ defending Ball while AC would have cost less Louisiana paid more than $1 million over three years to defend the Ball v. LeBlanc litigation — by some estimates, four times what installing AC on death row would have cost. Value: 1.0 million dollars in litigation defense costs Tags: budget,legal Sources: Ball v. LeBlanc, 881 F.3d 346 (5th Cir. 2018), Justia - [confirmed] Mississippi DOJ: temperatures as high as 145.1°F at Parchman restrictive housing The DOJ's April 20, 2022 findings letter on Mississippi State Penitentiary at Parchman documented temperatures 'as high as 145.1 degrees' in restrictive housing; the report tied at least one prisoner's suicide to excessive heat. Value: 145.1 °F documented temperature Date: 2022-04-20 Tags: conditions,death,mental_health Sources: DOJ Finds Unconstitutional Conditions at Mississippi State Penitentiary in Parchman, Prison Legal News, October 2022 - [reported] Alabama: 698 incarcerated people died since 2019 DOJ report As of the four-year-anniversary review by Alabama Appleseed in April 2023, 698 incarcerated people had died in Alabama state prisons since the 2019 DOJ report. Value: 698.0 deaths since 2019 DOJ report Tags: death Sources: People incarcerated in Alabama's prisons face heat dangers, Alabama Reflector, August 3, 2023 - [confirmed] Florida: 75% of prison housing units lack AC Florida DOC Secretary Ricky Dixon has testified that 75% of Florida's prison housing units lack AC. Value: 75.0 percent of housing units without AC Date: 2024-01-01 Tags: conditions,facilities Sources: FJI Files Lawsuit Over Sweltering Heat at South Florida Prison, Florida Justice Institute, October 31, 2024 - [reported] Wilson v. Dixon: heat index exceeded 103°F for 154 hours in 2024 at Dade CI The Wilson v. Dixon complaint documents that the heat index at Dade CI exceeded 90°F nearly every day from May 1 to September 30 in 2023 and 2024, and exceeded 103°F for 154 hours in 2024. Value: 154.0 hours exceeding 103°F heat index in 2024 Date: 2024-01-01 Tags: conditions Sources: FJI Files Lawsuit Over Sweltering Heat at South Florida Prison, Florida Justice Institute, October 31, 2024 - [confirmed] Arizona Jensen/Parsons: $2.5M+ in contempt fines against officials The Arizona Parsons/Jensen litigation has produced two contempt findings and over $2.5 million in fines against Arizona officials. Value: 2.5 million dollars in contempt fines Date: 2022-01-01 Tags: legal Sources: Jensen v. Thornell, ACLU - [confirmed] Skarha (2022): 13% of warm-month Texas prison deaths attributable to extreme heat Skarha et al. (JAMA Network Open, November 2022) found that approximately 13% of deaths in Texas prisons during warm months were attributable to extreme heat days. An average of 14 people died each year from heat-related causes in Texas prisons without air conditioning. Not a single heat-related death occurred in climate-controlled prisons. Value: 13.0 percent of warm-month deaths attributable to heat Tags: death,conditions Sources: Provision of Air Conditioning and Heat-Related Mortality in Texas Prisons, JAMA Network Open, November 2022 - [confirmed] Skarha (2022): 14 heat-related deaths per year in uncooled Texas prisons Brown University reporting summarized: 'An average of 14 people died each year from heat-related causes in Texas prisons without air conditioning. Not a single heat-related death occurred in climate-controlled prisons.' Value: 14.0 heat-related deaths per year in uncooled prisons Tags: death,conditions Sources: Extreme temperatures take deadly toll on people in Texas prisons, Brown University, November 2022 - [confirmed] Skarha (2022): 0.7% mortality increase per degree above 85°F in uncooled prisons Skarha et al. found that a 1-degree increase above 85°F in prisons without AC was associated with a 0.7% increase in daily mortality risk. Value: 0.7 percent increase in daily mortality per degree above 85°F Tags: death,conditions Sources: Provision of Air Conditioning and Heat-Related Mortality in Texas Prisons, JAMA Network Open, November 2022 - [confirmed] Skarha (2023): 10-degree temp increase associated with 5.2% death increase nationally Skarha et al. (PLOS ONE, March 2023) found a 10-degree temperature increase above location-specific average was associated with a 5.2% increase in deaths overall and 6.7% for heart-disease deaths in U.S. prisons nationally. Value: 5.2 percent increase in deaths per 10-degree increase (vs. 6.7 percent increase for heart-disease deaths) Tags: death,conditions Sources: Heat-related mortality in U.S. state and private prisons: A case-crossover analysis, PLOS ONE, March 2023 - [confirmed] Skarha (2023): 22.8% increase in suicides after extreme-heat days Skarha et al. (PLOS ONE, 2023) found a 22.8% increase in suicides in the three days after extreme-heat days in U.S. prisons. Value: 22.8 percent increase in suicides post-extreme-heat Tags: death,mental_health,conditions Sources: Heat-related mortality in U.S. state and private prisons: A case-crossover analysis, PLOS ONE, March 2023 - [confirmed] Skarha (2023): two-day heat waves produce 21% mortality increase in Northeast prisons Two-day heat waves produced a 21% mortality increase in Northeast prisons, 8.6% in the West, 1.3% in the South, and 0.8% in the Midwest. Value: 21.0 percent mortality increase in Northeast from 2-day heat waves (vs. 1.3 percent increase in South) Tags: death,conditions Sources: Heat-related mortality in U.S. state and private prisons: A case-crossover analysis, PLOS ONE, March 2023 - [reported] One in five Texas prisoners prescribed psychotropic medications As many as one in five Texas prisoners are prescribed psychotropic medications that impair thermoregulation. Value: 20.0 percent of Texas prisoners on psychotropic medications Date: 2025-01-01 Tags: medical,mental_health,conditions Sources: Psychotropic prescriptions in the context of extreme heat, CMAJ, 2025 - [reported] Hutchins Unit logged 149°F+ heat index on July 19, 2011 The Hutchins Unit logged a 10:30 a.m. heat index of more than 149°F on July 19, 2011, per the Human Rights Clinic at the University of Texas. Value: 149.0 °F heat index Date: 2011-07-19 Tags: conditions Sources: Heat-related Deaths in Texas Prisons Lead to Lawsuits, Reluctant Changes, Prison Legal News, August 2014 - [reported] Federal BOP: just over 80% of federal prisons have universal AC Just over 80% of federal prisons have universal AC, per The Appeal survey. Value: 80.0 percent of federal prisons with universal AC Date: 2024-01-01 Tags: conditions,facilities Sources: As Climate Change Worsens, Deadly Prison Heat Is Increasingly an Everywhere Problem, The Appeal, 2024 - [confirmed] PPI identified 13 states without universal AC in 2019 The Prison Policy Initiative's 2019 baseline analysis identified 13 states without universal AC in their prisons; 10 of those are in the South. Value: 13.0 states without universal AC (vs. 10 Southern states without universal AC) Date: 2019-01-01 Tags: conditions Sources: Cruel and unusual punishment: When states don't provide air conditioning in prison, Prison Policy Initiative, June 2019 - [confirmed] TDCJ: 92 heat-related guard illnesses in 2012, 162 workers' comp claims 2011-2013 Texas Department of Criminal Justice tracked 92 heat-related illnesses or injuries among guards in 2012 alone, and 162 heat-related workers' compensation claims by guards between 2011 and 2013 — meaning that guards have legal redress that prisoners working alongside them do not. Value: 162.0 heat-related workers' comp claims by guards (2011-2013) Tags: staffing,conditions Sources: Heat-related Deaths in Texas Prisons Lead to Lawsuits, Reluctant Changes, Prison Legal News, August 2014 - [reported] AJC 2023: 37 homicides and 32 suicides in Georgia prisons The AJC's 2023 review of in-custody death records identified 37 homicides and 32 suicides — one of the deadliest years in Georgia prison history — but that analysis depended on data the GDC has now restricted. Value: 37.0 homicides (vs. 32 suicides) Date: 2023-01-01 Tags: death,violence,mental_health Sources: A Georgia inmate died from heat exposure, GPB, July 26, 2024 - [reported] Texas at least 41 deaths in 2023 heat wave in uncooled prisons Texas Tribune analysis (2024): 'At least 41 people died in uncooled prisons during a record-breaking heat wave' in 2023, with autopsies citing heat as a possible cause for several. Value: 41.0 deaths in uncooled prisons during 2023 heat wave Date: 2023-01-01 Tags: death,conditions Sources: TDCJ's estimated cost to fully cool Texas prisons rises to $1.5B, The Texas Tribune, March 31, 2026 CASE DETAILS (20) ---------------------------------------- - [confirmed] Case originated as Tiede v. Collier filed by Bernie Tiede in 2023 The suit was filed in 2023 as Tiede v. Collier by one man, Bernie Tiede. The Western District of Texas later held his individual claims moot because TDCJ moved him into air-conditioned housing on account of his age (Tiede v. Lumpkin, 2026 WL 751904 (W.D. Tex. Mar. 16, 2026), 'Tiede III'). The case proceeded to trial on the claims of organizations whose members or constituents are incarcerated. Tags: legal,conditions Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [reported] Death of Juan Carlos Ramirez Bibiano at Telfair State Prison On July 20, 2023, 27-year-old Juan Carlos Ramirez Bibiano died at Telfair State Prison after officers left him in an outdoor recreation cage for five hours in a 105-degree heat index. He arrived at the hospital with an internal body temperature of 107°F. GDC reported his death as 'natural causes.' Officers placed Ramirez in a 12-by-8.5-foot fenced concrete 'rec cell' with no shade at 10:20 a.m. Within 20 minutes, Ramirez told guards he was overheating. He asked repeatedly to be removed; he reported difficulty breathing, dehydration, and feeling sick from new psychiatric medication. He cried that he felt he was going to die. Guards allegedly responded with: 'F— him. If he dies, he dies.' On the same morning, guards had already discharged a full can of pepper spray into Ramirez's poorly ventilated cell during a cell inspection. Five hours after he was placed outside, nurses found him naked, vomiting, in his own excrement, with a body temperature later measured at 107°F at the hospital. He died at 8:25 p.m. of cardiopulmonary arrest from heat exposure. Date: 2023-07-20 Tags: death,conditions,violence,medical Sources: A Georgia inmate died from heat exposure, GPB, July 26, 2024; Lawsuit: 27-year-old man died from extreme heat exposure at state prison, Atlanta News First, July 25, 2024; 'If he dies, he dies' | Telfair State Prison inmate left to die, 13WMAZ - [confirmed] Plaintiff organizations in Texas heat case The case went to trial on the claims of three organizations whose members or constituents are incarcerated: Texas C.U.R.E., Texas Prisons Community Advocates (TPCA), and Lioness Justice Impacted Women's Alliance. The defendant is Bobby Lumpkin, Executive Director of the Texas Department of Criminal Justice (TDCJ), in his official capacity. It is not a class action. Date: 2026-01-01 Tags: legal,conditions Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [reported] Telfair Warden's heat warning on morning of Ramirez's death On the morning of Juan Carlos Ramirez Bibiano's death, Telfair Warden Andrew McFarlane convened an 8 a.m. meeting at which department heads were instructed to keep inmates hydrated, distribute ice, and avoid leaving people outside too long in the heat. Despite this, officers placed Ramirez in an outdoor recreation cage at 10:20 a.m. Date: 2023-07-20 Tags: death,conditions,staffing,policy Sources: 'If he dies, he dies' | Telfair State Prison inmate left to die, 13WMAZ - [confirmed] DOJ visited 17 Georgia facilities during investigation The DOJ investigation visited 17 facilities including Lee Arrendale, Ware, Hays, Walker, Calhoun, Pulaski, Baldwin, Georgia Diagnostic, Macon, Coastal, Smith, Telfair, Rogers, Dooly, Wilcox, Phillips, and Augusta State Medical Prison. Tags: investigations,facilities Sources: DOJ Findings Report: Investigation of Georgia Prisons (October 2024) - [reported] Georgia State Prison closed in 2022, erasing physical evidence Georgia State Prison at Reidsville opened in 1937 and was closed by GDC in 2022; its closure removed evidence of conditions but the Guthrie record documented the heat-retentive concrete construction. Date: 2022-01-01 Tags: facilities,legal Sources: Civil Rights Litigation Clearinghouse, Guthrie v. Evans case page - [reported] Texas state has said it will appeal to Fifth Circuit The state has said it will appeal to the U.S. Court of Appeals for the Fifth Circuit (reported by the Marshall Project). CourtListener's copy of the docket showed no filing after September 22, 2026 when checked on September 27, 2026; its copies of district dockets are incomplete, so this is not proof that no notice of appeal exists. Date: 2026-09-01 Tags: legal,investigations Sources: Jamiles Lartey, "From Sweltering Cells to Frigid Tents: The Extreme Temperatures of Incarceration," The Marshall Project, Closing Argument newsletter, September 26, 2026 - [confirmed] TDCJ paid $750K to climate-control pig buildings while prisoners lacked AC Plaintiffs in Cole v. Collier proved that TDCJ had, in 2011, paid $750,000 to climate-control buildings used to raise pigs for the prison food program while prisoner housing lacked air conditioning. Date: 2011-01-01 Tags: conditions,budget,legal Sources: Cole v. Collier, Case No. 4:14-cv-01698 (S.D. Tex.), Civil Rights Litigation Clearinghouse - [confirmed] Larry McCollum heat death: body temp 109.4°F after 7 days in prison Larry Gene McCollum, a 58-year-old serving a one-year forgery sentence at Hutchins State Jail, collapsed July 22, 2011 with a body temperature of 109.4°F after just seven days inside. Date: 2011-07-22 Tags: death,conditions Sources: Heat-related Deaths in Texas Prisons Lead to Lawsuits, Reluctant Changes, Prison Legal News, August 2014 - [confirmed] Kenneth Wayne James heat death: body temp 108°F Kenneth Wayne James, 52, was found dead at the Gurney Unit on August 13, 2011 with a body temperature of 108°F. Autopsy listed 'environmental hyperthermia-related classic heat stroke.' Date: 2011-08-13 Tags: death,conditions Sources: Heat-related Deaths in Texas Prisons Lead to Lawsuits, Reluctant Changes, Prison Legal News, August 2014 - [reported] Robert Buel died at Anamosa State Penitentiary July 15 Robert Buel, 57, died of a heart attack on July 15 at Anamosa State Penitentiary, where the piece reports more than half the cells lack air conditioning; his official cause of death was heart disease, and his sister believes the prison's heat contributed. Date: 2026-07-15 Tags: death,heat,conditions,medical Sources: Jamiles Lartey, "From Sweltering Cells to Frigid Tents: The Extreme Temperatures of Incarceration," The Marshall Project, Closing Argument newsletter, September 26, 2026 - [confirmed] TDCJ falsified temperature logs at Stiles Unit Judge Pitman found that TDCJ had falsified temperature logs at the Stiles Unit in Beaumont. At an August 2024 hearing he declared: 'This is not a mistake. This is a fabricated document. Somebody needs to look into this.' A subsequent internal investigation confirmed that temperature logs were falsified in at least one unit; the report was completed in November 2024 but not shared with the court until March 2025. Date: 2024-08-01 Tags: corruption,conditions,legal Sources: Texas Prison Heat Declared Unconstitutional, Prison Legal News, May 2025 - [confirmed] Texas 2021 AC bill passed House 123-18, died in Senate In 2021, a Texas AC mandate bill cleared the Texas House 123-18 but died in Senate Finance without a hearing. Date: 2021-01-01 Tags: legal,policy,budget Sources: House panel passes bill requiring air conditioning in Texas prisons by 2032, The Texas Tribune, April 2025 - [confirmed] Texas HB 3006 passed committee 7-1, mandates phased AC by 2032 HB 3006 (Rep. Terry Canales) cleared a House Corrections Committee 7-1 on April 23, 2025, mandating phased AC installation by 2032. Date: 2025-04-23 Tags: legal,policy Sources: House panel passes bill requiring air conditioning in Texas prisons by 2032, The Texas Tribune, April 2025 - [confirmed] Angola remedies: IcyBreeze units at ~$500 each The Ball litigation ultimately produced a regime under which death-row prisoners receive 15-minute cold showers daily, ice, fans, and 'IcyBreeze' portable units — described by the Fifth Circuit as 'basically ice chests with fans attached,' costing about $500 each. Date: 2018-01-01 Tags: conditions,legal Sources: Ball v. LeBlanc, 881 F.3d 346 (5th Cir. 2018), Justia - [reported] Alabama prisoners pay $50 for disassembled microwave motors to make fans Alabama Reflector reporting in August 2023 documented prisoners paying $50 to disassemble microwaves for the motors so they can fashion improvised fans. Date: 2023-08-01 Tags: conditions,contraband Sources: People incarcerated in Alabama's prisons face heat dangers, Alabama Reflector, August 3, 2023 - [confirmed] DeSantis vetoed $300K AC pilot for Florida prisons in 2025 In 2025, Gov. Ron DeSantis vetoed $300,000 appropriated for an AC pilot at three Miami-Dade facilities. Date: 2025-01-01 Tags: policy,budget Sources: Left in the heat, Florida Politics, 2026 - [reported] Jerome Murdough death at Rikers: cell above 100°F, on psychiatric medication Jerome Murdough, 56, USMC veteran on antipsychotic and antiseizure medication, found dead at Rikers Island in February 2014 with cell temperature reportedly above 100°F. Date: 2014-02-01 Tags: death,conditions,mental_health Sources: Litigation Heats Up Over Extreme Temperatures in Prisons, Jails, Prison Legal News, June 2018 - [reported] Georgia Diagnostic and Classification Prison: 1969 facility housing death row Georgia Diagnostic and Classification Prison (Jackson) opened in 1969 and houses death row. Its AC status is not publicly documented. Date: 1969-01-01 Tags: facilities,conditions Sources: A Matter of Life and Death: As Temperatures Soar, People Incarcerated in Georgia's Prisons Endure Cruel and Possibly Deadly Conditions - [confirmed] Bibiano lawsuit filed in Telfair Superior Court The Ramirez/Bibiano case (Bibiano v. McFarlane et al.) was filed in Telfair Superior Court under the Georgia State Tort Claims Act, with Eighth and Fourteenth Amendment claims. Counsel are Spears & Filipovits LLC and the Chadha Jimenez Law Firm. Date: 2024-01-01 Tags: legal,death Sources: Bibiano lawsuit reporting, Atlanta Press Collective, August 2024 FINDINGS (25) ---------------------------------------- - [reported] GDC reported Ramirez death as 'natural causes' GDC officially reported the heat-exposure death of Juan Carlos Ramirez Bibiano as 'natural causes,' despite his body temperature reaching 107°F and his death being from cardiopulmonary arrest from heat exposure. Date: 2023-07-01 Tags: death,conditions,policy,data_gap Sources: A Georgia inmate died from heat exposure, GPB, July 26, 2024 - [confirmed] Chandler factual record: Union CI temperatures and ventilation In Chandler, the district court found the building stayed "between approximately eighty degrees at night to approximately eighty-five or eighty-six degrees during the day"; inmates "may have experienced temperatures over ninety degrees nine percent of the time" in the peak months measured; there were no readings "that exceeded 100 degrees"; and the ventilation system was "designed to provide nearly sixty air changes per hour." Date: 2004-01-01 Tags: conditions,heat,facilities,legal Sources: Chandler v. Crosby, 379 F.3d 1278 (11th Cir. 2004) - [confirmed] DOJ October 2024 findings: pattern or practice of constitutional violations in Georgia prisons The U.S. Department of Justice's October 1, 2024 findings letter on Georgia prisons documented a system in catastrophic Eighth Amendment failure across the dimensions of violence, sexual abuse, medical care, and physical-plant conditions. The 93-page report describes 'critical understaffing and systemic deficiencies in physical plant' and concludes that these produce 'horrific and inhumane' conditions. The DOJ found that GDC engages in a 'pattern or practice of violating incarcerated persons' constitutional rights' with 'deliberate indifference.' Date: 2024-10-01 Tags: legal,conditions,violence,medical,staffing,investigations Sources: DOJ Findings Report: Investigation of Georgia Prisons (October 2024) - [confirmed] Heat-attributable mortality rising while cold-attributable mortality decreasing The directional signal shows heat-attributable mortality increasing while cold-attributable mortality decreases, consistent with the argument that warming will make heat exposure a growing rather than static danger. Tags: death,conditions Sources: Global, regional, and national burden of mortality associated with non-optimal ambient temperatures from 2000 to 2019: a three-stage modelling study - [reported] No published Eleventh Circuit prison-heat decision after Chandler A CourtListener search on September 27, 2026 (Eleventh Circuit opinions filed after August 6, 2004, published and unpublished, for Chandler with heat, temperature or ventilation; "inadequate cooling"; "heat index" with "Eighth Amendment"; "excessive heat" with prison; "air conditioning" with "Eighth Amendment") found no published Eleventh Circuit prison-heat decision after Chandler. The decisions that apply Chandler to heat are unpublished, so under Eleventh Circuit Rule 36-2 they are persuasive only. Date: 2026-09-27 Tags: legal,conditions,heat,eighth_amendment Sources: GPS CourtListener search, September 27, 2026 - [reported] SCHR: ice calls unreliable due to staffing emergency SCHR has documented that 'ice calls' are unreliable in practice given the staffing emergency in 60% of Georgia prisons. Date: 2024-01-01 Tags: staffing,conditions,policy Sources: A Matter of Life and Death: As Temperatures Soar, People Incarcerated in Georgia's Prisons Endure Cruel and Possibly Deadly Conditions - [confirmed] Eastern Europe had highest heat-related excess death rate Eastern Europe had the highest heat-related excess death rate among all regions studied. Tags: death,conditions Sources: Global, regional, and national burden of mortality associated with non-optimal ambient temperatures from 2000 to 2019: a three-stage modelling study - [confirmed] Sub-Saharan Africa had highest cold-related excess death rate Sub-Saharan Africa had the highest cold-related excess death rate among all regions studied. Tags: death,conditions Sources: Global, regional, and national burden of mortality associated with non-optimal ambient temperatures from 2000 to 2019: a three-stage modelling study - [confirmed] Largest decline in overall excess death ratio in South-eastern Asia The largest decline in the overall excess death ratio occurred in South-eastern Asia; the ratio fluctuated in Southern Asia and Europe. Tags: death,conditions Sources: Global, regional, and national burden of mortality associated with non-optimal ambient temperatures from 2000 to 2019: a three-stage modelling study - [confirmed] TDCJ spent millions to keep poultry in safe temperatures The court found: 'TDCJ has spent millions of dollars to ensure that poultry are housed in safe temperatures.' (Dkt. 350 at 27). Date: 2026-01-01 Tags: budget,conditions,facilities Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [confirmed] Authors' interpretation: basis for preparedness and prevention strategies The authors conclude that non-optimal temperatures are associated with a substantial mortality burden that varies across space and time, and frame the work as a basis for developing preparedness and prevention strategies to reduce weather-related mortality both immediately and under future climate-change scenarios. Tags: conditions,policy Sources: Global, regional, and national burden of mortality associated with non-optimal ambient temperatures from 2000 to 2019: a three-stage modelling study - [confirmed] Cold-related deaths substantially outnumber heat-related deaths globally Cold-related deaths substantially outnumbered heat-related deaths globally over the full study period 2000-2019. Tags: death,conditions Sources: Global, regional, and national burden of mortality associated with non-optimal ambient temperatures from 2000 to 2019: a three-stage modelling study - [reported] Turner v. Warden records Georgia Diagnostic and Classification Prison temperature settings Turner v. Warden, 650 F. App'x 695 (11th Cir. 2016), records that "The prison temperature was set at 78 degrees in the summer and 74 in the whiter" ("whiter" is the stored text's misprint for "winter"). That is a statement about one unit's settings in that record, not a finding about Georgia prisons generally. Date: 2016-01-01 Tags: conditions,heat,facilities,legal Sources: Turner v. Warden, 650 F. App'x 695 (11th Cir. 2016) - [confirmed] Marshall Project frames ruling with poultry comparison The Marshall Project piece frames the ruling with the poultry comparison and quotes TDCJ's poultry language about 'excessive moisture and heat buildup' and that 'great care must be taken to maintain a comfortable environment.' It quotes Judge Pitman that such protections 'do not exist in inmate housing facilities,' which matches Dkt. 350 at 27. Date: 2026-09-26 Tags: conditions,facilities,heat Sources: Jamiles Lartey, "From Sweltering Cells to Frigid Tents: The Extreme Temperatures of Incarceration," The Marshall Project, Closing Argument newsletter, September 26, 2026 - [reported] Immigration detainees reported dangerously hot conditions in three states Immigration detention: detainees at immigrant detention sites in Virginia, Mississippi and New Jersey reported dangerously hot conditions this summer when air-conditioning systems temporarily failed (the Mississippi account attributed to The Guardian). Date: 2026-01-01 Tags: conditions,heat,facilities Sources: Jamiles Lartey, "From Sweltering Cells to Frigid Tents: The Extreme Temperatures of Incarceration," The Marshall Project, Closing Argument newsletter, September 26, 2026 - [disputed] Camp East Montana tent facility reported near-freezing; DHS denies claims The Marshall Project piece reports the opposite problem of heat: chronically frigid cells, the 'hieleras' (ice boxes) near the border, and uninsulated tent facilities such as Camp East Montana in El Paso, which The Guardian reported 'felt like near-freezing temperatures.' The Department of Homeland Security told The Guardian that 'claims facilities at Camp East Montana are unsafe or exposed are FALSE.' Date: 2026-01-01 Tags: conditions,facilities,transfers Sources: Jamiles Lartey, "From Sweltering Cells to Frigid Tents: The Extreme Temperatures of Incarceration," The Marshall Project, Closing Argument newsletter, September 26, 2026 - [confirmed] GDC mental-health audit tools use conflicting 85 and 90 degree thresholds The Mental Health Comprehensive Audit Tool (SOP 508.12, Attachment 5) asks whether "When housing temperature exceeds 85° F" the log shows ice, fluids, fans and extra showers, and whether "There are fans in the non-air-conditioned supportive living units and restrictive housing units." The Integrated Treatment Facility audit tool (SOP 508.12, Attachment 7) uses 90 degrees: "When housing temperature exceeds 90° F". The policy says 85; one audit tool checks 90. Date: 2022-01-01 Tags: policy,heat,mental_health,conditions Sources: GDC SOP 508.12, Mental Health Comprehensive Audit Tool and Integrated Treatment Facility Audit Tool - [confirmed] No GDC SOP or Board rule sets maximum temperature for general-population housing No GDC SOP or Board rule in the published library sets a maximum temperature or heat index for general-population housing, requires cooling in housing that lacks HVAC, or sets a facility-wide heat-emergency procedure for housing. The only housing temperature threshold found (85 degrees, SOP 508.24) is limited to people on psychotropic medication in lockdown or mental-health units, and the measures it requires are fans, fluids, ice, extra showers and a transfer recommendation, not cooling. This refines the earlier collection entry stating that no published GDC SOP sets a maximum permissible heat index: that remains true for a ceiling, but GDC does have written 85-degree monitoring and response rules for one group of prisoners, and a 68 to 78 degree thermostat design range for areas that already have HVAC. Date: 2026-09-27 Tags: policy,heat,conditions,data_gap Sources: GPS review of GDC Standard Operating Procedures, September 27, 2026 - [confirmed] GDC egg-house rule vs housing rules comparison GDC's egg-house rule requires sensors that trigger an emergency notification chain above 88 degrees to prevent livestock losses. GDC's housing rules require temperature logs and fans, ice and showers above 85 degrees for people on psychotropic medication in certain units, and set no temperature limit for anyone else. Date: 2026-09-27 Tags: policy,heat,conditions,operations Sources: GPS review of GDC Standard Operating Procedures, September 27, 2026 - [reported] Angola Camp C: no AC and roughly double design capacity (2025) By 2025, Camp C at Angola continued to operate with no AC and roughly double its design capacity. The Lens reported in July 2025 that dozens of Camp C prisoners had filed urgent administrative grievances alleging deliberate indifference. Date: 2025-07-01 Tags: conditions,facilities Sources: Hell on Earth, The Lens, July 29, 2025 - [confirmed] Alabama: no fully air-conditioned prison facilities The Alabama DOC has acknowledged that none of its facilities are fully air-conditioned in housing areas, with industrial fans serving as the principal cooling intervention. Date: 2023-01-01 Tags: conditions,facilities Sources: People incarcerated in Alabama's prisons face heat dangers, Alabama Reflector, August 3, 2023 - [reported] KPMG report: majority of Florida dormitories need retrofitting A 2023 KPMG report commissioned by the Florida DOC found that most Florida dormitories — including Dade CI — require retrofitting to comply with ventilation standards and that more than one-third of FDC facilities are in 'critical' or 'poor' condition. Date: 2023-01-01 Tags: conditions,facilities Sources: FJI Files Lawsuit Over Sweltering Heat at South Florida Prison, Florida Justice Institute, October 31, 2024 - [confirmed] DOJ findings letter establishes subjective awareness for future Georgia heat litigation The DOJ's October 2024 findings report provides the constitutional predicate — a finding that GDC engages in a 'pattern or practice' with 'deliberate indifference' — that makes a future heat-specific case almost inarguable on the subjective prong of the Eighth Amendment test. Date: 2024-10-01 Tags: legal,conditions Sources: DOJ Findings Report: Investigation of Georgia Prisons (October 2024) - [reported] No Georgia legislative push for prison AC as of 2026 As of this writing (May 2026), there is no public legislative push for prison air conditioning requirements in Georgia. Date: 2026-05-01 Tags: policy,legal Sources: A Matter of Life and Death: As Temperatures Soar, People Incarcerated in Georgia's Prisons Endure Cruel and Possibly Deadly Conditions - [reported] GDC administrative offices AC but housing units not A common pattern in Georgia prisons: administrative offices are air-conditioned; the cool air stops at the threshold of the housing units. Date: 2024-01-01 Tags: conditions,facilities Sources: A Matter of Life and Death: As Temperatures Soar, People Incarcerated in Georgia's Prisons Endure Cruel and Possibly Deadly Conditions TRENDS (6) ---------------------------------------- - [confirmed] Decline in global cold-related excess death ratio 2000-2003 to 2016-2019 Comparing the 2000-2003 window with the 2016-2019 window, the global cold-related excess death ratio fell by 0.51 percentage points (95% eCI -0.61 to -0.42). Tags: death,conditions Sources: Global, regional, and national burden of mortality associated with non-optimal ambient temperatures from 2000 to 2019: a three-stage modelling study - [confirmed] Increase in global heat-related excess death ratio 2000-2003 to 2016-2019 Comparing the 2000-2003 window with the 2016-2019 window, the global heat-related excess death ratio rose by 0.21 percentage points (95% eCI 0.13 to 0.31). Tags: death,conditions Sources: Global, regional, and national burden of mortality associated with non-optimal ambient temperatures from 2000 to 2019: a three-stage modelling study - [estimated] Georgia climate: 45-75 days above 95°F projected by 2090 The EPA projects that 'most of Georgia is likely to have 45 to 75 days per year with temperatures above 95°F, compared with about 15 to 30 such days today.' Date: 2016-01-01 Tags: conditions Sources: What Climate Change Means for Georgia, EPA, August 2016 - [estimated] Georgia projected: 20 dangerous heat days now to 90+ by 2050 States at Risk reports Georgia 'currently averages about 20 dangerous heat days a year. By 2050, it is projected to see more than 90.' Date: 2023-01-01 Tags: conditions Sources: Top Georgia Climate Change Risks, ClimateCheck - [reported] Atlanta gained 8 extreme heat days and 80-day longer heat-wave season since 1961 Atlanta has gained roughly eight more extreme heat days since 1961 and the heat-wave season has lengthened by more than 80 days. Tags: conditions Sources: Fifth National Climate Assessment, Chapter 22: Southeast, U.S. Global Change Research Program, 2023 - [confirmed] Southeast climate: substantial increase in extreme heat days projected by 2050 The Fifth National Climate Assessment (2023, Chapter 22) projects that the Southeast — already warming — will experience a substantial increase in extreme heat days (≥95°F) by 2050. Date: 2023-01-01 Tags: conditions Sources: Fifth National Climate Assessment, Chapter 22: Southeast, U.S. Global Change Research Program, 2023 POLICYS (12) ---------------------------------------- - [reported] GDC stopped reporting causes of death in 2024 GDC announced earlier in 2024 that it would stop reporting causes of death for inmates who die in custody, citing the Georgia Secrecy Act. This data suppression occurred after the AJC's 2023 review of in-custody death records and relative to the DOJ findings. Date: 2024-01-01 Tags: policy,death,data_gap Sources: A Georgia inmate died from heat exposure, GPB, July 26, 2024 - [reported] GDC cooling protocol per 2016 press release GDC's publicly stated cooling protocol includes: allowing T-shirts in lieu of state-issued button-up uniforms; 'larger box fans in addition to wall mounted fans'; 'ice delivery with each meal, and during extreme heat, two additional ice deliveries to dorms.' Date: 2016-07-01 Tags: policy,conditions Sources: GDC Facilities Lockdown Update, Georgia Department of Corrections, July 11, 2016 - [reported] California exempted prisons from 2024 indoor heat worker protections California workplace rules: in 2024 California adopted heat protections for indoor workers but exempted prisons and other detention facilities, citing air-conditioning costs that could reach upwards of $6 billion; the state is developing separate correctional rules with some protections starting at 87 degrees, five degrees higher than other indoor workplaces. Date: 2024-01-01 Tags: policy,heat,conditions,budget Sources: Jamiles Lartey, "From Sweltering Cells to Frigid Tents: The Extreme Temperatures of Incarceration," The Marshall Project, Closing Argument newsletter, September 26, 2026 - [confirmed] GDC SOP 409.03.05 egg production temperature sensors and 88-degree emergency notification SOP 409.03.05, Egg Production/Processing Unit (Montgomery State Prison; effective 9/1/2004): "Each house is to be equipped with environmental sensors to prevent temperature related losses." The sensors are programmed to begin emergency notifications when the temperature exceeds 88 degrees Fahrenheit, in order to the Montgomery State Prison Control Room, the Farm Manager, the State Farm Advisor and the State Farm Administrator, and "immediate actions must be taken to prevent significant loss of livestock." PowerDMS document 105475. Date: 2004-09-01 Tags: policy,facilities,operations,heat Sources: GDC SOP 409.03.05, Egg Production/Processing Unit - [confirmed] GDC SOP 409.03.03 swine nursery temperature range SOP 409.03.03, Swine Operations (effective 9/1/2004): "Air temperature in early nursery phase is kept" between 80 and 90 degrees Fahrenheit. PowerDMS document 105473. Whether the Montgomery egg unit still operates was not confirmed. Date: 2004-09-01 Tags: policy,facilities,operations,heat Sources: GDC SOP 409.03.03, Swine Operations - [confirmed] GDC SOP 508.24 heat precautions for prisoners on psychotropic medication SOP 508.24, Psychotropic Medication Use Management (effective 8/15/2022; PowerDMS 106286), section H, "Heat Precautions for Patients Receiving Psychotropic Medications." For people on psychotropic medication in lockdown or in the mental-health units (SLU, ACU, CSU): "If the offender is in lock down, SLU, ACU, or CSU the temperature of the confinement building must be monitored during periods in which the ambient interior temperature exceeds 85 degrees Fahrenheit." Between April 1 and September 30, security records the temperature every 6 hours during daylight on Attachment 3, the "Lockdown SLU/ACU/CSU Temperature Log" (form M60-01-03). "If offender housing areas exceed 85 degrees Fahrenheit, the following measures must be instituted: a. Increased ventilation to the area through utilization of fans to improve airflow and reduce room temperature to less than 85 degrees; b. Provision of increased fluids and ice; c. Allowance of additional showers to provide cooling; and d. Recommendation to the warden to permit temporary transfer of the offender to an area of the institution that is more compatible with the offender's clinical status." Heat education is given each year from April 1 to September 30. Date: 2022-08-15 Tags: policy,heat,mental_health,medical,conditions Sources: GDC SOP 508.24, Psychotropic Medication Use Management - [confirmed] GDC SOP 410.06 HVAC thermostat design range 68-78 degrees Fahrenheit SOP 410.06, Mechanical, Electrical, and Plumbing Design Standards (effective 10/26/2017; PowerDMS 177363), a design standard "for all new construction, renovations, or additions": "Mechanical systems shall be designed to provide temperatures in indoor living and work areas appropriate to the summer and winter comfort zones. Thermostats in areas with HVAC systems will be set at 68-78 degrees Fahrenheit." The thermostat range applies only where HVAC exists. Date: 2017-10-26 Tags: policy,facilities,heat,operations Sources: GDC SOP 410.06, Mechanical, Electrical, and Plumbing Design Standards - [confirmed] GDC SOP 410.04 sets same 68-78 degree thermostat range for training academy areas SOP 410.04, Facility Design and Space Planning (effective 8/30/2022), sets the same 68 to 78 degree thermostat range for training-academy work areas and dorms with HVAC. Date: 2022-08-30 Tags: policy,facilities,heat,operations Sources: GDC SOP 410.04, Facility Design and Space Planning - [confirmed] GDC segregation SOPs require ventilation and heating but not cooling Segregation units: SOPs 209.03 (Disciplinary Isolation), 209.06 (Administrative Segregation) and 209.07 (Tier I) each say cells "shall be well ventilated, adequately lighted, appropriately heated and maintained in a sanitary condition." Board of Corrections rule 125-3-2-.09 (Disciplinary Facilities) requires "adequate light (natural or artificial) and ventilation (natural or mechanical)" and that the cell "shall be properly heated during cool or cold weather." None addresses cooling. Date: 2022-01-01 Tags: policy,solitary,conditions,heat Sources: GDC SOP 209.03, Disciplinary Isolation; SOP 209.06, Administrative Segregation; SOP 209.07, Tier I; Board of Corrections Rule 125-3-2-.09 - [confirmed] GDC Board rule 125-3-5-.04 requires officer alertness to heat exhaustion Board rule 125-3-5-.04 (Work Conditions) tells officers that "During hot weather, all Correctional Officers and Supervisory personnel shall be particularly alert to the early detection of symptoms and the prevention of cases of heat exhaustion." Date: 2022-01-01 Tags: policy,heat,staffing,medical Sources: Board of Corrections Rule 125-3-5-.04, Work Conditions - [confirmed] GDC SOP 507.04.23 provides Heat Intolerance medical profile SOP 507.04.23 (Medical Classification and Profiling) provides a "Heat Intolerance" profile for medical conditions or medications "which have sun/exposure or heat-related side effects warranting work detail restrictions." Date: 2022-01-01 Tags: policy,heat,medical,operations Sources: GDC SOP 507.04.23, Medical Classification and Profiling - [reported] GPS policy analysis: recommended 65-85°F statutory ceiling for Georgia prisons For the 2027 Georgia legislative session, the most defensible policy framing is a statutory ceiling modeled on Texas's county-jail standard: state correctional facilities must maintain housing-area temperatures between 65°F and 85°F, with a phased timeline such as 2027-2032. Date: 2027-01-01 Tags: policy,legal,conditions Sources: Georgia Prisoners' Speak policy analysis: temperature standards for Georgia prisons (research collection note, 2026) METHODOLOGY NOTES (8) ---------------------------------------- - [confirmed] Study methodology: three-stage modelling approach The study used a three-stage approach: (1) fit location-specific temperature-mortality associations using time-series regression; (2) build a multivariate meta-regression relating location-specific estimates to meta-predictors; (3) predict grid-specific temperature-mortality associations for 2000-2019 using the fitted meta-regression and grid-specific meta-predictors. Tags: methodology Sources: Global, regional, and national burden of mortality associated with non-optimal ambient temperatures from 2000 to 2019: a three-stage modelling study - [confirmed] Study data sources: 750 locations across 43 countries The authors collected time-series data on daily mortality and ambient temperature from 750 locations across 43 countries, plus five meta-predictors defined on a 0.5 degree by 0.5 degree grid covering the globe. Tags: methodology Sources: Global, regional, and national burden of mortality associated with non-optimal ambient temperatures from 2000 to 2019: a three-stage modelling study - [confirmed] Poultry climate rule source is TDCJ agricultural documentation, not USDA regulation The poultry temperature rule comes from TDCJ's agricultural documentation for its prison poultry houses, produced in discovery. The court's footnotes 174 and 175 cite Plaintiffs' Trial Exhibit 209 at 5 (TDCJ's response to Request for Production No. 17), trial testimony of a TDCJ witness (Steffa) on April 9, 2026, and the minutes of an October 11, 2024 Texas Board of Criminal Justice committee meeting (Plaintiffs' Trial Exhibit 598). It is not a USDA or animal-welfare regulation. Tags: legal,policy,facilities Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [confirmed] Guthrie archives preserved at UGA Russell Library The Guthrie v. Evans record — including blueprints, transcripts, court findings, and special-master reports — is preserved in the Richard B. Russell Library at the University of Georgia and is a primary source for documented findings on temperature, ventilation, and physical-plant conditions in 1970s-1980s Georgia prisons. Tags: legal,conditions Sources: Civil Rights Litigation Clearinghouse, Guthrie v. Evans case page - [confirmed] GPS review of GDC SOP library scope and method GPS review of GDC's published Standard Operating Procedures, September 27, 2026, covered GPS's copy of GDC's public SOP library: 1,449 active documents (773 SOPs and 676 attachments), collected February to September 2026, latest effective date in the copy November 13, 2025; 9 of the documents have little or no extracted text. Every document's full text was scanned for terms including temperature; heat index; air conditioning, A/C, HVAC; cool, cooling; ventilation; heat stress, heat stroke, heat exhaustion, heat-related, heat illness, heat wave; hot weather; extreme or excessive heat; thermostat; degree, the degree sign and Fahrenheit figures; heat, heating; fans; ice; climate; summer; respite, cooling station, cooling area, cooling room; heat plan, heat emergency, heat advisory, heat alert, heat warning, heat season; maximum temperature, temperature limit, temperature ceiling, temperature range; hyperthermia, heatstroke. Every hit touching housing, health or facility design was then read. The review covers what GDC publishes; any procedure GDC does not publish, and facility-level local procedures, are not covered. Date: 2026-09-27 Tags: policy,conditions,heat,operations Sources: GPS review of GDC Standard Operating Procedures, September 27, 2026 - [confirmed] Prior collection entry on March 2025 opinion should be read with injunction denial The earlier collection entry describing the March 2025 opinion as finding the conditions 'plainly unconstitutional' should be read with this outcome: preliminary relief was refused. This flags a clarification to existing collection data. Tags: legal,conditions Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [confirmed] Records that would settle the air-conditioning count Records that would settle the air-conditioning count: a GDC list, facility by facility and as of a stated date, of housing units with working mechanical cooling, with the definition GDC uses (obtainable through a Georgia Open Records Act request to GDC); the facility list behind the 2016 press release's figure of 16; the SOP 508.24 Attachment 3 temperature logs (form M60-01-03) for lockdown, SLU, ACU and CSU units, which GDC policy requires from April 1 to September 30 each year and which show recorded housing temperatures; GDC Engineering and Construction Services records of HVAC installation, replacement and repair by facility. Date: 2026-09-27 Tags: facilities,heat,data_gap,policy Sources: GPS review of GDC Standard Operating Procedures, September 27, 2026 - [confirmed] Skarha methodology: case-crossover study of 3,464 Texas prison deaths The Skarha (2022) Texas study was a case-crossover study of 3,464 deaths in Texas prisons from 2001 to 2019. The national (2023) study analyzed 12,836 summer deaths from 2001-2019. TDCJ disputed the findings but independent researchers confirmed standard epidemiological methods were used. Date: 2022-01-01 Tags: death,conditions Sources: Provision of Air Conditioning and Heat-Related Mortality in Texas Prisons, JAMA Network Open, November 2022 DATA GAPS (8) ---------------------------------------- - [reported] No published GDC SOP for maximum permissible heat index There is no publicly available GDC SOP that establishes a maximum permissible heat index in housing areas, no published heat-illness incident reporting system, and no AC-system maintenance log accessible to the public. Date: 2026-01-01 Tags: policy,conditions,data_gap Sources: A Matter of Life and Death: As Temperatures Soar, People Incarcerated in Georgia's Prisons Endure Cruel and Possibly Deadly Conditions - [confirmed] Study contains no prison-specific or Georgia-specific data This is a global, general-population study containing no data specific to incarcerated people, air-conditioning provision, the United States at a usable granularity, or Georgia. It cannot support any claim about deaths inside GDC or any specific facility on its own. Tags: conditions,methodology Sources: Global, regional, and national burden of mortality associated with non-optimal ambient temperatures from 2000 to 2019: a three-stage modelling study - [disputed] Air-conditioning count for Georgia prisons is unresolved with three incompatible figures The number of air-conditioned Georgia prisons is UNRESOLVED. Three sources give incompatible figures, and none should be cited as the current count until a record settles it: GDC (July 11, 2016) said 16 facilities fully air-conditioned and six with some air-conditioned living units; Prison Journalism Project (September 2022) said only a quarter of the state's prisons are fully air-conditioned; Southern Center for Human Rights (2024) said three of GDC's 35 prisons fully air-conditioned as of February 2024. Possible explanations (none verified): different definitions of "fully air-conditioned," different facility counts or facility types in the denominator, systems failing or being taken out of service between 2016 and 2024, or an inaccurate figure in one source. Tags: facilities,heat,conditions,data_gap Sources: A Matter of Life and Death: As Temperatures Soar, People Incarcerated in Georgia's Prisons Endure Cruel and Possibly Deadly Conditions; Sweltering Days in a Georgia Prison Without Air Conditioning, Prison Journalism Project, September 2022; GDC Facilities Lockdown Update, Georgia Department of Corrections, July 11, 2016 - [confirmed] Heat deaths systematically undercounted when reported as 'natural causes' Heat deaths reported as 'natural causes' or as cardiac events are systematically undercounted, as the Skarha studies, Texas plaintiffs' attorneys, and the Texas legislature have all confirmed. This is a critical data gap in Georgia. Tags: death,data_gap,conditions Sources: Provision of Air Conditioning and Heat-Related Mortality in Texas Prisons, JAMA Network Open, November 2022 - [confirmed] Georgia heat-related illness data is poorly documented Georgia heat-related illness and death is poorly documented because GDC stopped reporting causes of death in 2024, citing the Georgia Secrecy Act. Specific data on Georgia heat exposures during work assignments is also a documentation gap. Date: 2024-01-01 Tags: data_gap,death,conditions Sources: A Georgia inmate died from heat exposure, GPB, July 26, 2024 - [reported] GDC 2016 vs. 2024 AC discrepancy unresolved The mismatch between GDC's 2016 self-reported 16 fully air-conditioned facilities and the 2024 SCHR-documented 3 is unresolved and represents either deferred maintenance, decommissioning, or misrepresentation. Tags: conditions,facilities,data_gap Sources: A Matter of Life and Death: As Temperatures Soar, People Incarcerated in Georgia's Prisons Endure Cruel and Possibly Deadly Conditions; GDC Facilities Lockdown Update, Georgia Department of Corrections, July 11, 2016 - [reported] No GDC psychotropic medication heat management data available There is no publicly available data on how many GDC prisoners are on heat-sensitizing medications or how GDC manages their heat exposure during summer months. Date: 2026-01-01 Tags: medical,mental_health,data_gap,conditions Sources: A Matter of Life and Death: As Temperatures Soar, People Incarcerated in Georgia's Prisons Endure Cruel and Possibly Deadly Conditions - [reported] No facility-by-facility GDC AC inventory or maintenance audit exists publicly No facility-by-facility GDC AC inventory and maintenance audit exists publicly. GPS should pursue this through Open Records Act requests and on-site verification. Date: 2026-01-01 Tags: data_gap,conditions,facilities Sources: A Matter of Life and Death: As Temperatures Soar, People Incarcerated in Georgia's Prisons Endure Cruel and Possibly Deadly Conditions QUOTES (10) ---------------------------------------- - [confirmed] TDCJ engineering director testified air conditioning achievable in 36 to 51 months TDCJ's own Director of Engineering, Mr. Cox, testified that with funding the agency could finish air-conditioning 'within 36 to 51 months' and affirmed at trial that this is a 'very doable timeframe' (Dkt. 350 at 101). Date: 2026-01-01 Tags: facilities,policy,heat Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [confirmed] Court closing characterization: 'These are not humane conditions.' The court stated: 'These are not humane conditions.' (Dkt. 350 at 2). Date: 2026-01-01 Tags: conditions,legal,heat Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [confirmed] TDCJ poultry documentation specifies 45-75 degree optimal range for laying hens The court quotes TDCJ's own poultry documentation: 'excessive moisture and heat buildup can adversely affect the overall productivity of a laying flock' and 'great care must be taken to maintain a comfortable environment for the flock,' 'with the optimal temperature range for laying hens being 45 degrees to 75 degrees' (Dkt. 350 at 27). Date: 2026-01-01 Tags: conditions,facilities,policy Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [confirmed] Court: poultry protections do not exist in inmate housing facilities The court stated: 'These protections do not exist in inmate housing facilities.' (Dkt. 350 at 27). Date: 2026-01-01 Tags: conditions,facilities,heat Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [confirmed] Court called 2029 deadline 'an urgent but entirely achievable form of prospective relief' The court described the 2029 deadline as 'an urgent but entirely achievable form of prospective relief' (Dkt. 350 at 149). Date: 2026-01-01 Tags: legal,conditions,heat Sources: Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026) - [confirmed] Judge Ellison quote on Pack Unit AC Judge Keith P. Ellison declared from the bench: 'I never dreamed we'd get air conditioning at the Pack Unit … It's a new day in Texas prisons.' Date: 2018-01-01 Tags: legal,conditions Sources: Cole v. Collier, Case No. 4:14-cv-01698 (S.D. Tex.), Civil Rights Litigation Clearinghouse - [reported] Stephen Knight quote on heat in prisons versus warehouses Stephen Knight of Worksafe, quoted from Capital & Main: 'The human body doesn't handle heat differently in a prison than, you know, an Amazon warehouse'. Date: 2026-01-01 Tags: heat,conditions,policy Sources: Jamiles Lartey, "From Sweltering Cells to Frigid Tents: The Extreme Temperatures of Incarceration," The Marshall Project, Closing Argument newsletter, September 26, 2026 - [reported] Louisiana DPSC Secretary LeBlanc publicly reversed on AC in 2022 Louisiana DPSC Secretary James 'Jimmy' LeBlanc publicly reversed course in 2022, telling reporters that 'these three-digit temperature days … is pretty strong evidence that we need to take a real look at what needs to be done.' Date: 2022-01-01 Tags: policy,conditions Sources: Unlike most Southern states, Louisiana is working to install AC in prisons, The Advocate - [confirmed] Vassallo testimony: heat stroke as 'cells of the body start to cook and fall apart' Dr. Susi Vassallo testified in Cole v. Collier: 'When the humidity is really high, the sweat can't evaporate. It just rolls off your body, without cooling it.' She described heat stroke deaths as the 'cells of the body start to cook and fall apart.' Date: 2017-01-01 Tags: medical,conditions,legal Sources: Cole v. Collier, Case No. 4:14-cv-01698 (S.D. Tex.), Civil Rights Litigation Clearinghouse - [reported] Ronald Marshall quote on Angola heat conditions Ronald Marshall, formerly incarcerated at Angola, told The Advocate that men 'would literally miss their noon chow because the sun sucked life right out of them. They'd rather lay on the floor.' Date: 2022-01-01 Tags: conditions,operations Sources: Unlike most Southern states, Louisiana is working to install AC in prisons, The Advocate DATASETS (4) ---------------------------------------- # Documented Heat-Related Deaths in U.S. Prisons Non-exhaustive roster of documented heat-related prisoner deaths across U.S. states, including body temperatures where recorded and circumstances of death. Name State/Facility Date Body_Temp_F Notes ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------- Larry Gene McCollum Texas/Hutchins State Jail 2011-07-22 109.4 58 years old, forgery sentence, collapsed after 7 days Kenneth Wayne James Texas/Gurney Unit 2011-08-13 108 52 years old, autopsy: environmental hyperthermia-related classic heat stroke Albert Hinojosa Texas/Garza West Unit 2011 Autopsy: environmental hyperthermia-related classic heat stroke Douglas Hudson Texas/Gurney Unit 2011 Heat-related death Rodney Adams Texas/Gurney Unit 2011 Heat-related death Robert Allen Webb Texas/Hodge Unit 2011 Heat-related death Juan Carlos Ramirez Bibiano Georgia/Telfair State Prison 2023-07-20 107 27 years old, outdoor recreation cage 5 hours, 105°F heat index Michael Broadway Illinois/Stateville 2024-06 51 years old, no AC, fifth floor Adrienne 'Twin' Boulware California/Central CA Women's Facility 2024-07 Family told heat stroke; CDCR contested Jerome Murdough New York/Rikers Island 2014-02 56, USMC vet, on antipsychotic/antiseizure meds, cell above 100°F # Southern State Prison Air Conditioning Status State-by-state comparison of air conditioning availability in prison housing units across the Deep South and selected states as of 2024-2026. State Fully_AC_Status Key_Metric Active_Litigation Estimated_Cost --------------------------------------------------------------------------------------------------------------------------------------------------------- Texas 32 of 101 units fully AC ~85,000 of 134,500 in uncooled housing Tiede v. Texas (system-wide) $1.5 billion Georgia 3 of 35 fully AC (SCHR 2024) 9 of 11 SW prisons have broken AC Bibiano v. McFarlane (single death) No public estimate Louisiana Most men's facilities uncooled Angola Camp C: no AC, double capacity Ball v. LeBlanc (concluded) Unknown Mississippi No universal AC Parchman documented at 145.1°F DOJ CRIPA investigation Unknown Alabama No fully AC facilities Industrial fans as principal cooling United States v. Alabama $1B new prison with AC (2026) Florida 75% of housing lacks AC Dade CI: 154 hours >103°F in 2024 Wilson v. Dixon (class certified) $300K pilot vetoed Federal BOP ~80% universal AC N/A None noted N/A # Landmark Prison Heat Litigation Timeline Chronological summary of key court decisions and outcomes in U.S. prison heat litigation. Case Jurisdiction Key_Date Key_Holding_or_Outcome Temperature_Standard --------------------------------------------------------------------------------------------------------------------------------------------------------------- Gates v. Cook 5th Cir. (Mississippi) 2004 Upheld fans/ice/showers remedy, no AC mandate No specific standard Graves v. Arpaio 9th Cir. (Arizona) 2010 85°F ceiling for psychotropic-medicated detainees upheld 85°F Ball v. LeBlanc (district) M.D. La. 2013-12-19 Eighth Amendment violation found, 88°F ceiling ordered 88°F heat index Ball v. LeBlanc I (5th Cir.) 5th Cir. 2015-07-08 Liability affirmed, AC remedy vacated as overbroad under PLRA N/A Cole v. Collier (PI) S.D. Tex. 2017-07-19 Heat conditions at Pack Unit unconstitutional, 88°F ceiling ordered 88°F heat index Cole v. Collier (settlement) S.D. Tex. 2018-06-08 Permanent AC required, $4.5M fees, 88°F standard Apr 15-Oct 15 88°F heat index Ball v. LeBlanc II (5th Cir.) 5th Cir. 2018-01-31 Even heat-index trigger exceeded Ball I mandate, remanded again N/A Tiede v. Texas (PI) W.D. Tex. 2025-03-26 Heat conditions 'plainly unconstitutional,' no temp AC ordered Pending Wilson v. Dixon (MTD denied) S.D. Fla. 2025-05-28 Motion to dismiss denied Pending Wilson v. Dixon (class cert) S.D. Fla. 2025-09-26 Class of 1,500+ certified at Dade CI Pending # Skarha Mortality Studies Summary Summary of three peer-reviewed studies by Julianne Skarha et al. forming the empirical backbone of prison heat advocacy. Study Journal Date Scope Key_Finding ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ Provision of AC and Heat-Related Mortality in Texas Prisons JAMA Network Open 2022-11 3,464 Texas prison deaths, 2001-2019 13% of warm-month deaths heat-attributable; 14 deaths/year in uncooled; 0 in AC'd Heat-related mortality in U.S. state/private prisons PLOS ONE 2023-03 12,836 U.S. summer deaths, 2001-2019 10°F increase = 5.2% death increase; 22.8% suicide increase post-heat Cold-related Mortality in US State and Private Prisons AJPH companion 2024 National prison mortality Cold temperatures also drive mortality, especially through suicide KEY ENTITIES (112) ---------------------------------------- - Alabama DOC [organization]: Alabama state corrections department. No fully air-conditioned facilities. Subject of DOJ April 2019 findings letter and December 2020 federal lawsuit. 698 incarcerated people died since 2019 report. (aka: Alabama Department of Corrections, ADOC) - Anamosa State Penitentiary [facility]: Iowa prison where Robert Buel died July 15; more than half the cells reportedly lack air conditioning. - Andrew McFarlane [person]: Telfair State Prison Warden who convened an 8 a.m. meeting on July 20, 2023 instructing staff about heat precautions on the same morning Juan Carlos Ramirez Bibiano was left to die in an outdoor recreation cage. Named defendant in Bibiano v. McFarlane. (aka: Warden McFarlane) - Angola [facility]: Louisiana's largest prison, 18,000 acres of farmland. Subject of Ball v. LeBlanc. Camp C continues to operate with no AC and roughly double design capacity as of 2025. (aka: Louisiana State Penitentiary, LSP) - Anthony A. Alaimo [person]: U.S. District Court Judge for the Southern District of Georgia (1971–2009) who presided over Guthrie v. Evans for thirteen years. Son of Sicilian immigrants, WWII B-26 bomber pilot and POW, appointed by President Nixon in 1971, Chief Judge 1976–1990. (aka: Judge Alaimo, The Sicilian Judge) - Ball v. LeBlanc [case]: Angola death-row heat case, 988 F. Supp. 2d 639 (M.D. La. 2013). District court found Eighth Amendment violation and ordered 88°F ceiling; Fifth Circuit affirmed liability but vacated AC remedy under PLRA. Resulted in fans, ice, cold showers, and IcyBreeze units. - Bernhardt Tiede II [person]: Texas prisoner who filed the initial August 2023 suit alleging 110°F+ cell temperatures violated the Eighth Amendment. Subject of Richard Linklater's 2011 film Bernie. Case expanded to system-wide challenge. (aka: Bernie Tiede) - Bernie Tiede [person]: Original individual plaintiff in the 2023 suit (Tiede v. Collier); his claims were later held moot after TDCJ moved him to air-conditioned housing. - Bibiano v. McFarlane [case]: Georgia heat-death lawsuit filed in Telfair Superior Court under Georgia State Tort Claims Act with Eighth and Fourteenth Amendment claims, arising from the July 2023 death of Juan Carlos Ramirez Bibiano at Telfair State Prison. - Blackmon v. Garza [case]: Unpublished Fifth Circuit decision reversing judgment for prison officials at the Garza East Unit and remanding for a new trial. (aka: 484 F. App'x 866 (5th Cir. 2012)) - Board of Corrections [organization]: Governing board overseeing the Georgia Department of Corrections, chaired by Larry Haynie. - Board of Corrections Rule 125-3-2-.09, Disciplinary Facilities [legislation]: Georgia Board of Corrections rule requiring adequate light and ventilation and proper heating in disciplinary facilities; does not address cooling. (aka: 125-3-2-.09) - Board of Corrections Rule 125-3-5-.04, Work Conditions [legislation]: Georgia Board of Corrections rule directing correctional officers to be alert to heat exhaustion symptoms during hot weather. (aka: 125-3-5-.04) - Bobby Lumpkin [person]: Executive Director of the Texas Department of Criminal Justice, sued in his official capacity. (aka: Director Lumpkin) - Bonner v. City of Prichard [case]: En banc Eleventh Circuit decision adopting pre-1981 Fifth Circuit precedent as binding in the Eleventh Circuit. (aka: 661 F.2d 1206 (11th Cir. 1981)) - Brian Jackson [person]: Chief U.S. District Judge (M.D. La.) who found Eighth Amendment violations in Ball v. LeBlanc and ordered 88°F heat index ceiling for Angola death row. (aka: Judge Brian Jackson, Chief Judge Jackson) - Camp East Montana [facility]: Uninsulated tent immigration detention facility in El Paso; The Guardian reported near-freezing temperatures, which DHS denied. - Chandler v. Crosby [case]: Eleventh Circuit decision holding that the Eighth Amendment applies to inadequate cooling and ventilation but that mere discomfort does not offend it; controlling heat precedent for Georgia federal courts. (aka: 379 F.3d 1278 (11th Cir. 2004)) - Cole v. Collier [case]: Seminal modern prison heat case, No. 4:14-cv-01698 (S.D. Tex.), filed 2014 by seven prisoners at Wallace Pack Unit. Resulted in 2018 settlement requiring permanent AC and 88°F heat index ceiling. Judge Keith P. Ellison presiding. (aka: Pack Unit litigation) - Coones v. Cogburn [case]: Fifth Circuit decision reinstating an Eighth Amendment heat-death claim against the TDCJ director and others. (aka: No. 24-10777 (5th Cir. 2025)) - Dade Correctional Institution [facility]: Florida state prison in Homestead. Subject of Wilson v. Dixon. Heat index exceeded 103°F for 154 hours in 2024. Class of 1,500+ certified. (aka: Dade CI) - Department of Homeland Security [organization]: Federal agency that told The Guardian claims about Camp East Montana being unsafe or exposed are false. (aka: DHS) - Easterling Correctional Facility [facility]: Alabama prison whose heating, cooling and ventilation conditions were at issue in Ivory v. Warden. - Eleventh Circuit [organization]: Federal appellate court with jurisdiction over Georgia, Florida and Alabama; author of Chandler v. Crosby. (aka: U.S. Court of Appeals for the Eleventh Circuit) - EPA [organization]: Federal agency that published 'What Climate Change Means for Georgia' projecting 45-75 days above 95°F in most of Georgia by 2090. (aka: Environmental Protection Agency) - Estelle v. Gamble [case]: 1976 U.S. Supreme Court decision establishing that deliberate indifference by prison personnel to a prisoner's serious illness or injury constitutes cruel and unusual punishment under the Eighth Amendment. - Farmer v. Brennan [case]: U.S. Supreme Court case establishing the deliberate indifference two-part test (objective + subjective components) for Eighth Amendment prison conditions claims. The bedrock case for all prisoner rights litigation. (aka: 511 U.S. 825 (1994)) - Federal Bureau of Prisons [organization]: Federal agency responsible for operating federal prisons in the United States. (aka: BOP, Federal BOP) - Fifth Circuit [organization]: Federal appellate court with jurisdiction over Texas, Mississippi and Louisiana; author of the Gates, Ball, Hinojosa, Yates and Coones heat decisions. (aka: U.S. Court of Appeals for the Fifth Circuit) - Florida DOC [organization]: Florida state corrections department. Secretary Ricky Dixon testified 75% of housing units lack AC. Subject of Wilson v. Dixon. (aka: Florida Department of Corrections, FDC) - Florida Justice Institute [organization]: Legal advocacy organization; counsel in Wilson v. Dixon lawsuit against Dade Correctional Institution over heat conditions. (aka: FJI) - Garza East Unit [facility]: Texas prison unit at issue in Blackmon v. Garza. - Gates v. Collier [case]: Fifth Circuit decision (501 F.2d 1291, 1319 (5th Cir. 1974)) cited for the principle that financial considerations do not excuse noncompliance with a remedial order. - Gates v. Cook [case]: Fifth Circuit case, 376 F.3d 323 (5th Cir. 2004), upholding fans/ice/showers remedy at Mississippi's Parchman death row. Became floor for Fifth Circuit heat remedies. - GDC [organization]: Georgia state corrections department operating 12 reentry centers with 2,344 beds and various cognitive programming initiatives. (aka: Georgia Department of Corrections, Georgia DOC) - GDC SOP 209.07, Tier I [program]: GDC SOP requiring Tier I cells to be well ventilated, adequately lighted, appropriately heated and sanitary. (aka: SOP 209.07) - GDC SOP 409.03.03, Swine Operations [program]: GDC SOP effective 9/1/2004 setting early nursery air temperature between 80 and 90 degrees Fahrenheit. (aka: SOP 409.03.03) - GDC SOP 409.03.05, Egg Production/Processing Unit [program]: GDC SOP effective 9/1/2004 requiring environmental sensors in egg houses that trigger emergency notifications above 88 degrees Fahrenheit. (aka: SOP 409.03.05) - GDC SOP 410.04, Facility Design and Space Planning [program]: GDC SOP effective 8/30/2022 setting a 68-78 degree Fahrenheit thermostat range for training-academy work areas and dorms with HVAC. (aka: SOP 410.04) - GDC SOP 410.06, Mechanical, Electrical, and Plumbing Design Standards [program]: GDC design standard effective 10/26/2017 setting a 68-78 degree Fahrenheit thermostat range for areas with HVAC systems. (aka: SOP 410.06) - GDC SOP 507.04.23, Medical Classification and Profiling [program]: GDC SOP providing a Heat Intolerance profile for medical conditions or medications with heat-related side effects. (aka: SOP 507.04.23) - GDC SOP 508.12, Mental Health Comprehensive Audit Tool and Integrated Treatment Facility Audit Tool [program]: GDC audit tools checking heat-response measures at 85 degrees (Attachment 5) and 90 degrees (Attachment 7). (aka: SOP 508.12) - GDC SOP 508.24, Psychotropic Medication Use Management [program]: GDC standard operating procedure effective 8/15/2022 establishing 85-degree heat precautions for prisoners on psychotropic medication in lockdown and mental-health units. (aka: SOP 508.24) - Georgia Department of Corrections [organization]: State agency responsible for operating Georgia's prison system. Subject of federal DOJ investigation in 2022-2023 for constitutional violations including food-related deaths. (aka: GDC) - Georgia Diagnostic and Classification Prison [facility]: Georgia state prison from which David 'Toro' Zavala operated drug trafficking while serving time for armed robbery. - Georgia Prisoners' Speak [organization]: Advocacy organization documenting conditions inside Georgia prisons through photos and insider accounts, including food inadequacy. (aka: GPS) - Georgia State Prison at Reidsville [facility]: Georgia state prison opened in 1937, subject of Guthrie v. Evans consent decree. Closed by GDC in 2022. Heat-retentive concrete construction documented in Guthrie record. (aka: Georgia State Prison, Reidsville) - Glades Correctional Institution [facility]: Florida prison whose dormitory air conditioning and ventilation were at issue in Green v. Secretary. - Graves v. Arpaio [case]: Ninth Circuit case, 623 F.3d 1043 (9th Cir. 2010), upholding 85°F temperature ceiling for pretrial detainees on psychotropic medication in Maricopa County. Foundational for medication-vulnerability heat claims. - Green v. Mowery [case]: Unpublished Eleventh Circuit decision affirming for the defendant in a cooling and ventilation claim for lack of causal connection. (aka: 212 F. App'x 918 (11th Cir. 2006)) - Green v. Secretary for the Department of Corrections [case]: Unpublished Eleventh Circuit decision affirming for the warden in a Florida heat and ventilation case under Chandler. (aka: 212 F. App'x 869 (11th Cir. 2006)) - Groover v. Broward County Sheriff [case]: Unpublished Eleventh Circuit decision vacating dismissal in a heat-stroke transport case so the plaintiff could amend to tie defendants to the violation. (aka: 684 F. App'x 782 (11th Cir. 2017)) - Guthrie v. Evans [case]: Class action lawsuit filed in 1972 challenging racial segregation and unconstitutional conditions at Georgia State Prison, resulting in the most comprehensive set of remedial decrees ever imposed on a single U.S. prison facility. Presided over by Judge Anthony A. Alaimo for thirteen years. (aka: Guthrie v. MacDougall, Guthrie v. Caldwell, Guthrie v. Ault, Guthrie v. Evans, Civ. No. 3068, Civil Action No. 3068) - HB 3006 [legislation]: Texas House bill (Rep. Terry Canales, 2025 session) mandating phased AC installation in all Texas prisons by 2032. Cleared House Corrections Committee 7-1 on April 23, 2025. - Helling v. McKinney [case]: Supreme Court case holding that exposure to future harm (environmental tobacco smoke) can violate the Eighth Amendment (aka: 509 U.S. 25 (1993)) - Hernandez v. Florida Department of Corrections [case]: Unpublished Eleventh Circuit decision applying Chandler to a temperature claim at the pleading stage. (aka: 281 F. App'x 862 (11th Cir. 2008)) - Hinojosa v. Livingston [case]: Fifth Circuit decision in a Texas heat-stroke death case affirming limited discovery before ruling on qualified immunity. (aka: 807 F.3d 657 (5th Cir. 2015)) - Hope v. Pelzer [case]: U.S. Supreme Court case, 536 U.S. 730 (2002), arising from Alabama. Held that handcuffing a prisoner to a hitching post for seven hours in the sun constituted obvious cruel and unusual punishment. Directly analogous to Georgia heat exposure cases. - Ivory v. Warden [case]: Unpublished Eleventh Circuit decision rejecting an Alabama prisoner's heat, ventilation and overcrowding claim for failure to identify conditions and health impacts with specificity. (aka: 600 F. App'x 670 (11th Cir. 2015)) - James LeBlanc [person]: Louisiana DPSC Secretary and named defendant in Ball v. LeBlanc. Publicly reversed course on prison AC in 2022, acknowledging 'three-digit temperature days' require action. (aka: Jimmy LeBlanc) - Jensen v. Thornell [case]: Arizona class action prison conditions case filed 2012. Ninth Circuit affirmed class certification. Produced two contempt findings and over $2.5 million in fines against Arizona officials. (aka: Parsons v. Ryan, Jensen v. Shinn) - Jerome Murdough [person]: 56-year-old USMC veteran on antipsychotic and antiseizure medication who died at Rikers Island in February 2014 with cell temperature reportedly above 100°F. - Juan Carlos Ramirez Bibiano [person]: 27-year-old prisoner who died on July 20, 2023 at Telfair State Prison after being left in an outdoor recreation cage for five hours in 105°F heat index. Internal body temperature reached 107°F. GDC reported death as 'natural causes.' Subject of Bibiano v. McFarlane lawsuit. (aka: Juan Carlos Ramirez) - Julianne Skarha [person]: Brown University epidemiologist and lead author of three peer-reviewed prison heat mortality studies (JAMA Network Open 2022, PLOS ONE 2023, AJPH 2024) forming the empirical backbone of contemporary prison heat advocacy. - Kathleen Williams [person]: U.S. District Judge (S.D. Fla.) presiding over Wilson v. Dixon. Denied Florida's motion to dismiss in May 2025 and certified class of 1,500+ in September 2025. (aka: Judge Kathleen Williams) - Keith P. Ellison [person]: U.S. District Judge (S.D. Tex.) who presided over Cole v. Collier. Issued 100-page preliminary injunction finding Pack Unit heat unconstitutional and approved 2018 settlement requiring permanent AC. (aka: Judge Ellison) - Kenneth Wayne James [person]: 52-year-old Texas prisoner found dead at the Gurney Unit on August 13, 2011 with body temperature of 108°F. Autopsy: 'environmental hyperthermia-related classic heat stroke.' - Kim Reynolds [person]: Iowa governor who included $8.1 million for prison air conditioning in her budget; lawmakers declined. (aka: Gov. Kim Reynolds) - KPMG [organization]: Consulting firm that produced a 2023 report commissioned by the Florida DOC finding most Florida dormitories require retrofitting and more than one-third of facilities are in 'critical' or 'poor' condition. - Larry Gene McCollum [person]: 58-year-old Texas prisoner serving a one-year forgery sentence at Hutchins State Jail who collapsed July 22, 2011 with a body temperature of 109.4°F after just seven days inside. His death fueled Cole v. Collier litigation. - Lioness Justice Impacted Women's Alliance [organization]: Plaintiff organization in the Texas heat case. - Louisiana DPSC [organization]: Louisiana's state corrections department. Secretary James LeBlanc named defendant in Ball v. LeBlanc; publicly committed to phased AC rollout in 2022. (aka: Louisiana Department of Public Safety and Corrections) - Montgomery State Prison [facility]: GDC facility granted initial ACA accreditation in August 2018 with a score of 98.5 percent. - Nelson Mandela Rules [legislation]: International standards calling for use of the lowest security category consistent with safety and control requirements. (aka: UN Standard Minimum Rules for the Treatment of Prisoners) - OSHA [organization]: Federal workplace safety agency. Does not have jurisdiction over incarcerated workers. No enforceable federal heat-exposure standard for prison labor. (aka: Occupational Safety and Health Administration) - Parchman [facility]: Mississippi's largest prison. DOJ documented temperatures as high as 145.1°F in restrictive housing. Subject of DOJ CRIPA investigation and Gates v. Cook. (aka: Mississippi State Penitentiary) - Parker v. Hooper [case]: Fifth Circuit medical-care class case (No. 23-30825, Mar. 30, 2026) vacating a system-wide remedial order under the PLRA; cited in the Texas ruling for the deliberate indifference standard. - Prison Journalism Project [organization]: Journalism organization covering prison conditions and abuse (aka: PJP) - Prison Litigation Reform Act [legislation]: 1996 federal legislation that imposed filing fees, administrative exhaustion requirements, attorney fee limits, and a 'three strikes' rule on prisoner civil rights litigation. Caused a 33% drop in federal civil rights filings by prisoners between 1995-1997. (aka: PLRA) - Prison Policy Initiative [organization]: Research and advocacy organization focused on prison conditions; published Cut-rate Care and Chronic Punishment reports (aka: PPI) - Rhodes v. Chapman [case]: Supreme Court case holding that double-celling is not per se unconstitutional under the Eighth Amendment (aka: 452 U.S. 337 (1981)) - Robert Buel [person]: 57-year-old incarcerated man who died of a heart attack July 15 at Anamosa State Penitentiary; his sister believes prison heat contributed. - Robert Pitman [person]: U.S. District Judge in the Western District of Texas presiding over Tiede v. Texas. Issued 91-page preliminary injunction in March 2025 finding Texas prison heat 'plainly unconstitutional.' Found TDCJ falsified temperature logs. (aka: Judge Robert Pitman) - Ron DeSantis [person]: Florida Governor who vetoed $300,000 appropriated for an AC pilot at three Miami-Dade prison facilities in 2025. (aka: Gov. DeSantis) - Ronald Marshall [person]: Formerly incarcerated person at Angola prison and organizer with Voice of the Experienced (VOTE). Testified about Angola heat conditions. - Saunders v. Sheriff of Brevard County [case]: Unpublished Eleventh Circuit decision reversing denial of qualified immunity in a Florida jail high-temperature claim. (aka: No. 16-17607 (11th Cir. 2018)) - SB 169 [legislation]: Texas Senate bill (Sen. José Menéndez and six co-authors, 2025 session) seeking to require AC system-wide in Texas prisons. - Smith v. Sullivan [case]: Fifth Circuit case holding that a federal court may not order a fixed temperature range but may grant relief for temperature extremes likely to injure inmates' health. (aka: 553 F.2d 373 (5th Cir. 1977)) - SOP 209.03 [legislation]: GDC SOP capping Disciplinary Isolation at 30 days and prohibiting its use as corporal punishment. - SOP 209.06 [organization]: GDC policy governing involuntary Administrative Segregation assignment appeals. - Southern Center for Human Rights [organization]: Legal advocacy organization that investigated food conditions at Gordon County Jail and sent a formal letter to Sheriff Mitch Ralston in October 2014. (aka: SCHR) - Stallworth v. Wilkins [case]: Unpublished Eleventh Circuit decision holding that poor ventilation allegations do not give rise to an Eighth Amendment claim. (aka: No. 18-12445 (11th Cir. 2020)) - Stephen Knight [person]: Worksafe representative quoted on heat in prisons versus other workplaces. - Susi Vassallo [person]: NYU emergency-medicine professor specializing in thermoregulation. Expert witness in Cole v. Collier and Tiede litigation, testified about medication-impaired thermoregulation and the 88°F heat-index threshold. (aka: Dr. Susi Vassallo) - Telfair State Prison [facility]: Georgia state prison involved in Operation Ghost Busted (Desiree Briley) and Operation Night Drop drone smuggling network. - Texas C.U.R.E. [organization]: Plaintiff organization in the Texas heat case. (aka: Texas Citizens United for Rehabilitation of Errants) - Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin [case]: Federal Eighth Amendment heat conditions case against TDCJ Executive Director Bobby Lumpkin; final order issued September 22, 2026, ordering systemwide air conditioning by December 31, 2029. (aka: Texas C.U.R.E. v. Lumpkin, Tiede v. Collier, Tiede v. Lumpkin, No. 1:23-CV-1004-RP) - Texas Department of Criminal Justice [organization]: Texas corrections agency; former executive director testified as expert witness that overcrowding is 'primary cause' of violations (aka: TDCJ) - Texas Prisons Community Advocates [organization]: Advocacy organization founded by Amite Dominick; plaintiff in Tiede v. Texas; runs '85ToStayAlive' campaign for prison AC. (aka: TPCA) - The Marshall Project [organization]: Nonprofit journalism organization that investigated DCRA data and found nearly 700 law enforcement custody deaths missing from the dataset. - Tiede v. Texas [case]: System-wide Texas prison heat case filed August 2023, expanded April 2024 with advocacy organization plaintiffs. Judge Robert Pitman found conditions 'plainly unconstitutional' in March 2025 preliminary injunction. Two-week bench trial concluded April 9, 2026; ruling expected mid-to-late 2026. (aka: Tiede litigation) - Turner v. Warden [case]: Unpublished Eleventh Circuit decision rejecting a cold strip-cell claim from Georgia Diagnostic and Classification Prison under Chandler. (aka: 650 F. App'x 695 (11th Cir. 2016)) - U.S. Department of Justice [organization]: Federal agency that published October 2024 findings report on unconstitutional conditions in Georgia prisons. (aka: DOJ) - Union Correctional Institution [facility]: Florida prison whose death-row heat and ventilation conditions were at issue in Chandler v. Crosby. - Valigura v. Mendoza [case]: Unpublished Fifth Circuit decision involving bunk-area temperatures into the nineties and hundreds, with qualified-immunity appeal affirmed in part. (aka: 265 F. App'x 232 (5th Cir. 2008)) - Wallace Pack Unit [facility]: TDCJ minimum-security facility in Navasota, Texas, holding approximately 1,300 men. Subject of Cole v. Collier litigation. First Texas prison to receive court-ordered permanent AC. (aka: Pack Unit) - Webb v. Livingston [case]: Unpublished Fifth Circuit decision dismissing appeals over the heat deaths of five Texas prisoners for lack of jurisdiction. (aka: 618 F. App'x 201 (5th Cir. 2015)) - Wilson v. Dixon [case]: Florida prison heat case, No. 1:24-cv-24253 (S.D. Fla.), filed October 31, 2024 by Florida Justice Institute against Dade Correctional Institution. Class of 1,500+ certified September 2025. - Wilson v. Seiter [case]: 1991 Supreme Court case extending deliberate indifference standard to conditions of confinement and establishing Section 1983 liability for administrators - Worksafe [organization]: Worker safety organization; Stephen Knight of Worksafe was quoted on heat protections. - Wyatt v. Aderholt [case]: Fifth Circuit decision (503 F.2d 1305, 1315 (5th Cir. 1974)) cited alongside Gates v. Collier on financial considerations. - Yates v. Collier [case]: Fifth Circuit decision affirming class certification for the Wallace Pack Unit heat case. (aka: 868 F.3d 354 (5th Cir. 2017)) SOURCES (93) ---------------------------------------- - 'Cooking them to death': The lethal toll of hot prisons, NOLA.com / The Marshall Project, NOLA.com / The Marshall Project [journalism, secondary] URL: https://www.nola.com/news/crime_police/cooking-them-to-death-the-lethal-toll-of-hot-prisons/article_ea8096a4-f778-5b1c-abd4-eacb98078682.html - 'If he dies, he dies' | Telfair State Prison inmate left to die, 13WMAZ, 13WMAZ [journalism, secondary] URL: https://www.13wmaz.com/article/news/crime/lawsuit-telfair-state-prison-inmate-left-to-die-in-fenced-in-box-in-prison-yard/93-9d9d4e7f-df4b-4bc2-b083-af38ae1d2d19 - #85toStayAlive TEXAS Litigation, Texas Prisons Community Advocates, Texas Prisons Community Advocates [press_release, primary] URL: https://www.tpcadvocates.org/climatecontrollitigation - A Georgia inmate died from heat exposure, GPB, July 26, 2024, GPB (2024-07-26) [journalism, secondary] URL: https://www.gpb.org/news/2024/07/26/georgia-inmate-died-heat-exposure-left-questions-his-family-suing-the-state - A Matter of Life and Death: As Temperatures Soar, People Incarcerated in Georgia's Prisons Endure Cruel and Possibly Deadly Conditions, Southern Center for Human Rights [official_report, primary] URL: https://www.schr.org/a-matter-of-life-and-death-as-temperatures-soar-people-incarcerated-in-georgias-prisons-endure-cruel-and-possibly-deadly-conditions/ - As Climate Change Worsens, Deadly Prison Heat Is Increasingly an Everywhere Problem, The Appeal, 2024, The Appeal (2024-01-01) [journalism, secondary] URL: https://theappeal.org/prison-heat-deaths-climate-change/ - Ball v. LeBlanc, 792 F.3d 584 (5th Cir. 2015), U.S. Court of Appeals for the Fifth Circuit (2015-07-08) [legal_document, primary] URL: https://www.courtlistener.com/opinion/2815421/elzie-ball-v-james-leblanc/ - Ball v. LeBlanc, 792 F.3d 584 (5th Cir. 2015), FindLaw, FindLaw (2015-07-08) [legal_document, primary] URL: https://caselaw.findlaw.com/court/us-5th-circuit/1707472.html - Ball v. LeBlanc, 881 F.3d 346 (5th Cir. 2018), U.S. Court of Appeals for the Fifth Circuit (2018-01-31) [legal_document, primary] URL: https://www.courtlistener.com/opinion/8439771/ball-v-leblanc/ - Ball v. LeBlanc, 881 F.3d 346 (5th Cir. 2018), Justia, Justia (2018-01-31) [legal_document, primary] URL: https://law.justia.com/cases/federal/appellate-courts/ca5/17-30052/17-30052-2018-01-31.html - Bibiano lawsuit reporting, Atlanta Press Collective, August 2024, Atlanta Press Collective (2024-08-01) [journalism, secondary] URL: https://atlpresscollective.com/2024/08/09/scorching-temperatures-stone-cold-silence-the-death-of-juan-carlos-ramirez/ - Blackmon v. Garza, 484 F. App'x 866 (5th Cir. 2012), U.S. Court of Appeals for the Fifth Circuit (2012-07-30) [legal_document, primary] URL: https://www.courtlistener.com/opinion/805522/eugene-blackmon-v-warden-kukua/ - Board of Corrections Rule 125-3-5-.04, Work Conditions, Georgia Board of Corrections (2003-03-26) [legislation, primary] - Bonner v. City of Prichard, 661 F.2d 1206 (11th Cir. 1981), U.S. Court of Appeals for the Eleventh Circuit (en banc) (1981-11-03) [legal_document, primary] URL: https://www.courtlistener.com/opinion/396175/larry-bonner-v-city-of-prichard-alabama/ - Chandler v. Crosby, 379 F.3d 1278 (11th Cir. 2004), U.S. Court of Appeals for the Eleventh Circuit (2004-08-06) [legal_document, primary] URL: https://www.courtlistener.com/opinion/76715/jim-e-chandler-v-james-crosby/ - Civil Rights Litigation Clearinghouse, Guthrie v. Evans case page, Civil Rights Litigation Clearinghouse, University of Michigan Law School [data_portal, primary] URL: https://clearinghouse.net/case/655/ - Cole v. Collier, Case No. 4:14-cv-01698 (S.D. Tex.), Civil Rights Litigation Clearinghouse, Civil Rights Litigation Clearinghouse (2014-01-01) [legal_document, primary] URL: https://clearinghouse.net/case/14090/ - Conditions of Confinement, Constitution Annotated, Library of Congress, 2024, Library of Congress (2024-01-01) [official_report, primary] URL: https://constitution.congress.gov/browse/essay/amdt8-4-7/ALDE_00000966/ - Coones v. Cogburn, No. 24-10777 (5th Cir. 2025), U.S. Court of Appeals for the Fifth Circuit (2025-07-25) [legal_document, primary] URL: https://www.ca5.uscourts.gov/opinions/unpub/24/24-10777.0.pdf - Cruel and unusual punishment: When states don't provide air conditioning in prison, Prison Policy Initiative, June 2019, Prison Policy Initiative (2019-06-01) [official_report, secondary] URL: https://www.prisonpolicy.org/blog/2019/06/18/air-conditioning/ - Department Of Justice Report Finds Conditions In Alabama Prisons Unsafe, NPR, April 3, 2019, NPR (2019-04-03) [journalism, secondary] URL: https://www.npr.org/2019/04/03/709475746/doj-report-finds-violence-in-alabama-prisons-common-cruel-pervasive - Do prisons have air conditioning?, Kent State Online, Kent State Online [journalism, tertiary] URL: https://onlinedegrees.kent.edu/blog/do-prisons-have-air-conditioning - DOJ Findings Report: Investigation of Georgia Prisons (October 2024), U.S. Department of Justice (2024-10-01) [official_report, primary] URL: https://www.justice.gov/d9/2024-09/findings_report_-_investigation_of_georgia_prisons.pdf - DOJ Finds Unconstitutional Conditions at Mississippi State Penitentiary in Parchman, Prison Legal News, October 2022, Prison Legal News (2022-10-01) [journalism, secondary] URL: https://www.prisonlegalnews.org/news/2022/oct/31/doj-finds-unconstitutional-conditions-mississippi-state-penitentiary-parchman/ - Estelle v. Gamble, 429 U.S. 97 (1976), U.S. Supreme Court (1976-11-30) [legal_document, primary] URL: https://supreme.justia.com/cases/federal/us/429/97/ - Extreme temperatures take deadly toll on people in Texas prisons, Brown University, November 2022, Brown University (2022-11-01) [press_release, secondary] URL: https://www.brown.edu/news/2022-11-04/prison-heat - Farmer v. Brennan, 511 U.S. 825 (1994), U.S. Supreme Court (1994-06-06) [legal_document, primary] URL: https://supreme.justia.com/cases/federal/us/511/825/ - Federal judge says heat in Texas prisons is unconstitutional, KUT, March 26, 2025, KUT (2025-03-26) [journalism, secondary] URL: https://www.kut.org/texas/2025-03-26/texas-prison-heat-lawsuit-federal-judge-ruling - Fifth National Climate Assessment, Chapter 22: Southeast, U.S. Global Change Research Program, 2023, U.S. Global Change Research Program (2023-01-01) [official_report, primary] URL: https://nca2023.globalchange.gov/chapter/22/ - FJI Files Lawsuit Over Sweltering Heat at South Florida Prison, Florida Justice Institute, October 31, 2024, Florida Justice Institute (2024-10-31) [press_release, primary] URL: https://fji.law/what-we-do/criminal-justice-reform/fji-files-lawsuit-over-sweltering-heat-at-south-florida-prison/ - Florida Inmates Earn Class Status in Suit Over 'Unbearable' Heat, Bloomberg Law, September 29, 2025, Bloomberg Law (2025-09-29) [journalism, secondary] URL: https://news.bloomberglaw.com/us-law-week/florida-inmates-earn-class-status-in-suit-over-unbearable-heat - Following DOJ Investigation, Sens. Ossoff, Rev. Warnock Urge State of Georgia, Office of Sen. Ossoff, Office of Sen. Ossoff (2024-01-01) [press_release, primary] URL: https://www.ossoff.senate.gov/press-releases/following-doj-investigation-sens-ossoff-rev-warnock-urge-state-of-georgia-to-swiftly-address-unconstitutional-conditions-in-state-prisons/ - Gates v. Collier, 501 F.2d 1291 (5th Cir. 1974), U.S. Court of Appeals, Fifth Circuit (1974-01-01) [legal_document, primary] - Gates v. Cook, 376 F.3d 323 (5th Cir. 2004), U.S. Court of Appeals for the Fifth Circuit (2004-06-28) [legal_document, primary] URL: https://www.courtlistener.com/opinion/787015/gates-v-cook/ - GDC Facilities Lockdown Update, Georgia Department of Corrections, July 11, 2016, Georgia Department of Corrections (2016-07-11) [press_release, primary] URL: https://gdc.georgia.gov/press-releases/2016-07-11/gdc-facilities-lockdown-update - GDC SOP 209.03, Disciplinary Isolation; SOP 209.06, Administrative Segregation; SOP 209.07, Tier I; Board of Corrections Rule 125-3-2-.09, Georgia Department of Corrections (2021-02-19) [official_report, primary] URL: https://public.powerdms.com/GADOC/documents/105940 - GDC SOP 409.03.03, Swine Operations, Georgia Department of Corrections (2004-09-01) [official_report, primary] URL: https://public.powerdms.com/GADOC/documents/105473 - GDC SOP 409.03.05, Egg Production/Processing Unit, Georgia Department of Corrections (2004-09-01) [official_report, primary] URL: https://public.powerdms.com/GADOC/documents/105475 - GDC SOP 410.04, Facility Design and Space Planning, Georgia Department of Corrections (2022-08-30) [official_report, primary] URL: https://public.powerdms.com/GADOC/documents/177361 - GDC SOP 410.06, Mechanical, Electrical, and Plumbing Design Standards, Georgia Department of Corrections (2017-10-26) [official_report, primary] URL: https://public.powerdms.com/GADOC/documents/177363 - GDC SOP 507.04.23, Medical Classification and Profiling, Georgia Department of Corrections (2022-02-01) [official_report, primary] URL: https://public.powerdms.com/GADOC/documents/106359 - GDC SOP 508.12, Mental Health Comprehensive Audit Tool and Integrated Treatment Facility Audit Tool, Georgia Department of Corrections (2022-06-28) [official_report, primary] URL: https://public.powerdms.com/GADOC/documents/914078 - GDC SOP 508.24, Psychotropic Medication Use Management, Georgia Department of Corrections (2022-08-15) [official_report, primary] URL: https://public.powerdms.com/GADOC/documents/106286 - Georgia Climate Futures, Georgia Tech Drawdown, Georgia Tech by William Drummond et al. [academic, primary] URL: https://drawdownga.gatech.edu/georgiaclimatefutures/ - Georgia Prisoners' Speak policy analysis: temperature standards for Georgia prisons (research collection note, 2026), Georgia Prisoners' Speak by Georgia Prisoners' Speak (2026-05-03) [gps_original, primary] URL: https://gps.press/research-library/heat-cooling-and-the-eighth-amendment-in-us-prisons-a-georgia-focus-and-deep-south-comparative-landscape/ - Global, regional, and national burden of mortality associated with non-optimal ambient temperatures from 2000 to 2019: a three-stage modelling study, The Lancet Planetary Health by Qi Zhao, Yuming Guo, Tingting Ye, Antonio Gasparrini, Shilu Tong, Shanshan Li, et al. (2021-07-01) [academic, primary] URL: https://www.thelancet.com/journals/lanplh/article/PIIS2542-5196(21)00081-4/fulltext - GPS CourtListener search, September 27, 2026, Georgia Prisoners' Speak (2026-09-27) [gps_original, primary] URL: https://www.courtlistener.com - GPS review of GDC Standard Operating Procedures, September 27, 2026, Georgia Prisoners' Speak (2026-09-27) [gps_original, primary] - Green v. Mowery, 212 F. App'x 918 (11th Cir. 2006), U.S. Court of Appeals for the Eleventh Circuit (2006-12-28) [legal_document, primary] URL: https://www.courtlistener.com/opinion/44496/stephen-s-green-v-t-mowery/ - Green v. Secretary for the Department of Corrections, 212 F. App'x 869 (11th Cir. 2006), U.S. Court of Appeals for the Eleventh Circuit (2006-12-27) [legal_document, primary] URL: https://www.courtlistener.com/opinion/44504/green-v-secretary-for-the-department-of-corrections/ - Groover v. Broward County Sheriff, 684 F. App'x 782 (11th Cir. 2017), U.S. Court of Appeals for the Eleventh Circuit (2017-04-04) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4380380/jeffrey-emil-groover-v-broward-county-sheriff/ - Heat waves create dire conditions for the South's incarcerated, Facing South, August 2022, Facing South / Institute for Southern Studies (2022-08-01) [journalism, secondary] URL: https://www.facingsouth.org/2022/08/south-prisons-air-conditioning-heat-wave - Heat-related Deaths in Texas Prisons Lead to Lawsuits, Reluctant Changes, Prison Legal News, August 2014, Prison Legal News (2014-08-01) [journalism, secondary] URL: https://www.prisonlegalnews.org/news/2014/aug/8/heat-related-deaths-texas-prisons-lead-lawsuits-reluctant-changes/ - Heat-related mortality in U.S. state and private prisons: A case-crossover analysis, PLOS ONE, March 2023, PLOS ONE by Julianne Skarha et al. 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Pelzer, 536 U.S. 730 (2002), Northwestern Journal of Criminal Law analysis, Northwestern Journal of Criminal Law and Criminology (2002-01-01) [legal_document, primary] URL: https://scholarlycommons.law.northwestern.edu/cgi/viewcontent.cgi?article=7134&context=jclc - House panel passes bill requiring air conditioning in Texas prisons by 2032, The Texas Tribune, April 2025, The Texas Tribune (2025-04-01) [journalism, secondary] URL: https://www.texastribune.org/2025/04/04/texas-prison-air-conditioning-bills/ - Inmates battle heat, mold and mice inside Mississippi's largest prison, NBC News, August 2024, NBC News (2024-08-01) [journalism, secondary] URL: https://www.nbcnews.com/news/us-news/inmates-battle-heat-mold-mice-mississippis-largest-prison-rcna163635 - Ivory v. Warden, 600 F. App'x 670 (11th Cir. 2015), U.S. Court of Appeals for the Eleventh Circuit (2015-01-27) [legal_document, primary] URL: https://www.courtlistener.com/opinion/2773506/samuel-earl-ivory-v-warden/ - Jamiles Lartey, "From Sweltering Cells to Frigid Tents: The Extreme Temperatures of Incarceration," The Marshall Project, Closing Argument newsletter, September 26, 2026, The Marshall Project by Jamiles Lartey (2026-09-26) [journalism, secondary] URL: https://www.themarshallproject.org/2026/09/26/texas-heat-california-cold-prison - Jensen v. Thornell, ACLU, ACLU [legal_document, primary] URL: https://www.aclu.org/cases/parsons-v-ryan - Justice Department Finds Unconstitutional Conditions in Georgia Prisons, U.S. DOJ Southern District of Georgia (2024-10-01) [press_release, primary] URL: https://www.justice.gov/usao-sdga/pr/justice-department-finds-unconstitutional-conditions-georgia-prisons - Lawsuit: 27-year-old man died from extreme heat exposure at state prison, Atlanta News First, July 25, 2024, Atlanta News First (2024-07-25) [journalism, secondary] URL: https://www.atlantanewsfirst.com/2024/07/25/lawsuit-27-year-old-man-died-extreme-heat-exposure-state-prison/ - Left in the heat, Florida Politics, 2026, Florida Politics (2026-01-01) [journalism, secondary] URL: https://floridapolitics.com/archives/785203-left-in-the-heat-bills-to-require-air-conditioning-in-prisons-stall-again-as-lawsuit-advances/ - Litigation Heats Up Over Extreme Temperatures in Prisons, Jails, Prison Legal News, June 2018, Prison Legal News (2018-06-01) [journalism, secondary] URL: https://www.prisonlegalnews.org/news/2018/jun/29/litigation-heats-over-extreme-temperatures-prisons-jails/ - Order, Texas Citizens United for Rehabilitation of Errants, Inc. v. Lumpkin, No. 1:23-CV-1004-RP, Dkt. 350 (W.D. Tex. Sept. 22, 2026), U.S. District Court for the Western District of Texas by Judge Robert Pitman (2026-09-22) [legal_document, primary] URL: https://www.courtlistener.com/docket/67727449/texas-citizens-united-for-rehabilitation-of-errants-inc-v-lumpkin/ - Parker v. Hooper, No. 23-30825 (5th Cir. Mar. 30, 2026), U.S. Court of Appeals for the Fifth Circuit (2026-03-30) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10830009/parker-v-hooper/ - Parsons v. Ryan, 754 F.3d 657 (9th Cir. 2014), FindLaw, FindLaw (2014-01-01) [legal_document, primary] URL: https://caselaw.findlaw.com/court/us-9th-circuit/1668864.html - People incarcerated in Alabama's prisons face heat dangers, Alabama Reflector, August 3, 2023, Alabama Reflector (2023-08-03) [journalism, secondary] URL: https://alabamareflector.com/2023/08/03/people-incarcerated-in-alabamas-prisons-face-heat-dangers-as-hot-weather-continues/ - Provision of Air Conditioning and Heat-Related Mortality in Texas Prisons, JAMA Network Open, November 2022, JAMA Network Open by Julianne Skarha et al. (2022-11-01) [academic, primary] URL: https://pmc.ncbi.nlm.nih.gov/articles/PMC9631100/ - Psychotropic prescriptions in the context of extreme heat, CMAJ, 2025, CMAJ (2025-01-01) [academic, primary] URL: https://www.cmaj.ca/content/197/29/E915 - Saunders v. 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Wilkins, No. 18-12445 (11th Cir. 2020), U.S. Court of Appeals for the Eleventh Circuit (2020-01-17) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4707632/victor-dontavious-stallworth-v-wilkins/ - Sweltering Days in a Georgia Prison Without Air Conditioning, Prison Journalism Project, September 2022, Prison Journalism Project (2022-09-01) [journalism, secondary] URL: https://prisonjournalismproject.org/2022/09/19/sweltering-days-georgia-prison-without-air-conditioning/ - TDCJ's estimated cost to fully cool Texas prisons rises to $1.5B, The Texas Tribune, March 31, 2026, The Texas Tribune (2026-03-31) [journalism, secondary] URL: https://www.texastribune.org/2026/03/31/texas-prison-ac-trial-heat-deaths-allegations/ - Texas Prison Heat Declared Unconstitutional, Prison Legal News, May 2025, Prison Legal News (2025-05-01) [journalism, secondary] URL: https://www.prisonlegalnews.org/news/2025/may/1/texas-prison-heat-declared-unconstitutional/ - Texas prisoners await a judge's ruling and another hot summer after federal trial, KUT/TPR, April 10, 2026, KUT/TPR (2026-04-10) [journalism, secondary] URL: https://www.tpr.org/news/2026-04-10/texas-prisoners-await-a-judges-ruling-and-another-hot-summer-after-federal-trial - Top Georgia Climate Change Risks, ClimateCheck, ClimateCheck [official_report, secondary] URL: https://climatecheck.com/georgia - Turner v. Warden, 650 F. App'x 695 (11th Cir. 2016), U.S. Court of Appeals for the Eleventh Circuit (2016-05-25) [legal_document, primary] URL: https://www.courtlistener.com/opinion/3206968/marvin-turner-v-warden/ - UN General Assembly Resolution 70/175, United Nations General Assembly (2015-12-17) [legislation, primary] URL: https://www.unodc.org/documents/justice-and-prison-reform/Nelson_Mandela_Rules-E-ebook.pdf - UN Nelson Mandela Rules, Penal Reform International, Penal Reform International [official_report, secondary] URL: https://www.penalreform.org/issues/prison-conditions/standard-minimum-rules/ - Unlike most Southern states, Louisiana is working to install AC in prisons, The Advocate, The Advocate (2022-01-01) [journalism, secondary] URL: https://www.theadvocate.com/baton_rouge/news/politics/legislature/unlike-most-southern-states-louisiana-is-working-to-install-air-conditioning-in-prisons/article_9dcc4d8e-14f7-11ed-8963-ffb80a1fd93d.html - Valigura v. Mendoza, 265 F. App'x 232 (5th Cir. 2008), U.S. Court of Appeals for the Fifth Circuit (2008-02-07) [legal_document, primary] URL: https://www.courtlistener.com/opinion/58891/valigura-v-mendoza/ - Webb v. Livingston, 618 F. App'x 201 (5th Cir. 2015), U.S. Court of Appeals for the Fifth Circuit (2015-07-17) [legal_document, primary] URL: https://www.courtlistener.com/opinion/2818155/gwen-togonidze-v-brad-livingston/ - What Climate Change Means for Georgia, EPA, August 2016, EPA (2016-08-01) [official_report, primary] URL: https://19january2017snapshot.epa.gov/sites/production/files/2016-09/documents/climate-change-ga.pdf - Wyatt v. Aderholt, 503 F.2d 1305 (5th Cir. 1974), U.S. Court of Appeals for the Fifth Circuit (1974-11-08) [legal_document, primary] URL: https://www.courtlistener.com/opinion/321968/wyatt-v-aderholt/ - Yates v. Collier, 868 F.3d 354 (5th Cir. 2017), U.S. Court of Appeals for the Fifth Circuit (2017-08-18) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4420346/david-bailey-v-bryan-collier/