Fifth Circuit Slams Louisiana Prison 'Atavistic' Medical Ruling, Axes District Court Order

LitNews.ai Staff · March 30, 2026 · Fifth Circuit

Panel: Chief Judge Elrod, Circuit Judge Edith Hollan Jones, Circuit Judge Smith, Circuit Judge Stewart, Circuit Judge Richman, Circuit Judge Southwick, Circuit Judge Haynes, Circuit Judge Graves, Circuit Judge Higginson, Circuit Judge Willett, Circuit Judge Ho, Circuit Judge Duncan, Circuit Judge Engelhardt, Circuit Judge Oldham, Circuit Judge Wilson, Circuit Judge Douglas, Circuit Judge Ramirez · Opinion by: Circuit Judge Edith Hollan Jones

The Fifth Circuit ruled en banc Wednesday that a Louisiana federal judge's sweeping medical care injunction against the state penitentiary at Angola violated the Prison Litigation Reform Act, calling the district court's rulings 'atavistic' attempts 'to control prison management in violation of constitutional law.'

A class of Louisiana State Penitentiary inmates sued prison officials in 2015, claiming the facility's medical care violated the Eighth Amendment and Americans with Disabilities Act. After a 2018 trial examining years-old evidence, the district court in March 2021 issued a 124-page liability opinion finding systemic constitutional violations. Despite significant improvements by prison officials—including electronic medical records, upgraded personnel, and expanded specialty clinics—the court in November 2023 issued a 104-page remedial order requiring three special masters to oversee sweeping changes.

Circuit Judge Edith Jones wrote that the district court 'violated' the Prison Litigation Reform Act's requirements that injunctive relief be 'narrowly drawn' and 'the least intrusive means necessary.' Jones criticized the court for appointing three special masters instead of one as authorized by the PLRA, requiring Louisiana to pay their costs contrary to federal law, and ignoring the statute's selection process. 'The overall result of the district court's orders...is a mishmash of mandates, some of which are already rendered obsolete by events,' Jones wrote.

The case began after inmates filed suit against LSP Warden Tim Hooper and other officials. Prison authorities 'immediately began renovating their facilities, upgrading personnel, and improving standards of care' after the liability ruling, but the district court 'refused to consider the upgrades' made after the June 2022 remedial trial. A Fifth Circuit panel initially dismissed the appeal for lack of jurisdiction before the full court voted to rehear the case en banc.

The decision reinforces strict limits on federal court oversight of state prisons established by the 1996 PLRA. Jones emphasized that prison administration represents an area where states have their 'strongest interest' and warned that allowing such judicial overreach would set dangerous precedent. The ruling remands the case for reconsideration under proper legal standards, potentially ending years of federal court supervision of the Angola facility's medical operations.

Counsel

Parker is represented by Katie Schwartzmann, Davida Finger, and Rebecca Livesey of Loyola Law Clinic; Gary Clatterbaugh and Elizabeth Kuhn of Kuhn & Associates; and Katherine Mattes of American Civil Liberties Union.

Hooper is represented by Joseph Scott, Rachel Johnson Settoon, and Elizabeth Trosclair of Louisiana Department of Justice.

Case: The case is Parker v. Hooper, case number 23-30825, in the U.S. Court of Appeals for the Fifth Circuit.

Court

Fifth Circuit

Case Name

Parker v. Hooper

Docket

23-30825