Smith v. Edwards

New Decision

In 2022, the Louisiana Office of Juvenile Justice began incarcerating youth in its custody in the former death row building at the Louisiana State Penitentiary—a maximum-security prison for adults commonly known as Angola Prison. Incarcerated youth brought a class action lawsuit challenging this practice. In September 2023, the United States District Court for the Middle District of Louisiana found that “youth at Angola are being victimized, traumatized, and seriously and irreparably harmed,” and directed Defendants to remove all youth from Angola. Defendants appealed to the U.S. Court of Appeals for the Fifth Circuit.

Juvenile Law Center and Center for Children’s Law and Policy, joined by 50 national, regional, and Louisiana-based youth advocacy organizations and academics, filed an amicus brief in the Fifth Circuit in support of Plaintiffs. Our brief argued that the law requires Louisiana’s juvenile justice system to provide youth with rehabilitative services and protect them from harm. We further detailed the many ways that incarcerating youth in adult facilities causes irreparable harm and has a racially discriminatory impact. Finally, our brief argued that harsh treatment of incarcerated youth is not necessary or productive.

The Fifth Circuit granted Plaintiffs’ requested relief and dismissed Defendants’ appeal as moot, as the District Court’s preliminary injunction had already expired under federal law. Due to this expiration, the Fifth Circuit further vacated the preliminary injunction. The Plaintiffs’ request for a permanent injunction enjoining Defendants from incarcerating youth at Angola remains pending in the District Court.  



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