Three death row inmates at Angola filed suit against the Louisiana Department of Corrections and various officials alleging that the lack of air conditioning on death row amounted to a violation of the Eighth Amendment, the Americans with Disabilities Act, and the Rehabilitation Act. The inmates argued that their health conditions were made worse by high temperatures, and that their being kept in hot cells amounts to cruel and unusual punishment. The trial court ruled in favor of the Eighth Amendment claim, but rejected the disability claims. The trial court also issued an injunction effectively requiring the installation of air conditioning throughout the death row. The injunction required that the entire death row be kept at a heat index at or below 88 degrees. The trial court reasoned that the three plaintiffs can be moved to any cell, and thus, the entire cell block needed to be kept cool.

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