Rising Temperatures, the Prison Litigation Reform Act, and the Heat Death of Human Dignity in Texas Prisons

This Note seeks to shed light on the life-threatening danger of extreme heat in un-air-conditioned Texas prisons. The Prison Litigation Reform Act (PLRA) starkly limits the relief available to those suffering and dying in these prisons. This Note proposes an amendment to the legislation that could create a path toward lasting relief for incarcerated people. After analyzing the effects of increasing heat on the particularly vulnerable prison population, this Note analyzes how the Supreme Court and the Fifth Circuit have handled claims alleging constitutionally violative prison conditions under the Eighth Amendment—in short, ineffectively, if at all. This Note then details the many ways in which the PLRA thwarts incarcerated people’s ability to even get to the courts in the first place. Given these legislative and judicial hurdles, this Note ultimately proposes an amendment to the PLRA that could allow for relief from dangerous, life-threatening conditions in overheated Texas prisons.