Alex A. v. Edwards

Louisiana planned to house certain high-risk juvenile offenders in an unoccupied wing of Angola, an adult prison. Alex A. (plaintiff) and other juvenile offenders sought a preliminary injunction preventing their transfer to Angola. The federal district court denied the request based on several promises that Louisiana made regarding the conditions of confinement the juvenile offenders would experience. After being transferred, Alex A. again sought a preliminary injunction precluding his further confinement at Angola. The trial court made the following findings of fact: (1) Louisiana promised that use of the Angola site would be short term until a new facility could be completed in April 2023. Due to delays, the new facility would open in December at the earliest. (2) Although Louisiana promised that only 5 percent of juveniles would be eligible for transfer to Angola, over 15 percent had been transferred. (3) Juveniles were frequently confined to cells for days on end despite claims that they would only be in cells at night while sleeping. (4) Although confinement was meant to be rehabilitative, juveniles were frequently subject to retributive punishment such as cell restrictions, denial of family contact, handcuffing, and macing. (5) The facility had inadequate teaching, counseling, and mental-health staff. (6) The facility lacked adequate special-education staff and services, such as speech therapists and occupational therapists. (7) Mental-health services were largely provided by telemedicine, and mental-health professionals were not consulted before imposing cell restrictions. (8) The facility lacked a licensed social worker or professional counselor. The case manager lacked the education or training to provide proper therapeutic counseling.