The 13th Amendment’s exception is doing a lot of work.
Slavery was abolished in 1865 — except as punishment for a crime. That clause is still fully constitutional today, and it’s why hundreds of thousands of incarcerated Americans work fields that, in some cases, are the exact same land once worked under chattel slavery.
“What is happening on the Farm Line is modern-day slavery, and neither our Constitution nor our conscience should tolerate it.”
“Except as a punishment for a crime”
The Thirteenth Amendment bans slavery and involuntary servitude — with one carve-out, still constitutional in most of the country today.
Prison agricultural labor programs exist well beyond the South, but the throughline is clearest at places like Louisiana State Penitentiary, known as Angola: the nation’s largest maximum-security prison, built on 18,000 acres that were literally slave plantations before they were a prison. Incarcerated workers there grow cotton, corn, soybeans, and sugarcane. Roughly 74% of the people incarcerated at Angola are Black, and nearly everyone who enters the prison starts on the Farm Line — switching out of field work is difficult once assigned.
The same pattern repeats at Mississippi State Penitentiary (Parchman Farm), the Cummins Unit and East Arkansas Regional Unit in Arkansas, and prison farms across Texas, Florida, Pennsylvania, New York, and beyond — some built directly on former plantation land, others built later but organized the same way: field labor as the default assignment, with limited water access, minimal rest, and armed supervision on horseback.
What field assignment at Angola actually looks like
Built on a former plantation
Angola sits on 18,000 acres that were slave plantations before becoming the state penitentiary — incarcerated workers grow cotton, corn, soybeans, and sugarcane, work with direct roots in Black chattel slavery in the same region.
74% Black, and the default assignment
Nearly everyone entering Angola starts in the fields, and transferring to a different job is difficult. Field laborers work with limited water access, minimal rest, no restroom facilities, and supervision by armed correctional officers on horseback.
Little to no wages
Workers aren’t eligible for pay during their first three years on the Farm Line. After that, a 2023 legal complaint reported wages as low as $0.02 an hour — among the lowest incentive pay rates for incarcerated labor of any state.
A pattern, not an outlier
Chattel slavery was legally banned in 1865. Hard agricultural labor by incarcerated people has continued in Mississippi, Florida, Louisiana, Arkansas, Texas, Pennsylvania, New York, and elsewhere ever since.
Convict leasing’s legacy
After slavery’s formal end, many of these same sites became convict-leasing operations, with states leasing incarcerated labor to private farms and companies — a system historians note was often cheaper than slavery, since lessees bore no responsibility for workers’ long-term health.
A national supply chain
The U.S. is the world’s third-largest cotton producer behind India and China, with Texas, Georgia, Mississippi, and Arkansas as the major producing states — and prison labor is a documented part of that supply chain, particularly at large operations like Arkansas’s Cummins Unit and East Arkansas Regional Unit.
VOTE v. LeBlanc
Filed in September 2023 by the Promise of Justice Initiative and Rights Behind Bars, on behalf of incarcerated plaintiffs and the advocacy group Voice of the Experienced (VOTE), this lawsuit directly challenges Angola’s Farm Line.
The suit originally raised a Thirteenth Amendment claim directly — arguing the Farm Line amounts to unconstitutional slavery even under the amendment’s own exception. That specific claim was dismissed early on. What survived were Eighth Amendment claims (the ban on cruel and unusual punishment) and disability-discrimination claims under the ADA, focused on the conditions of the labor itself: workers forced into fields even as the heat index reached 113 degrees.
A federal judge ruled in May 2026 that Angola’s heat conditions were unconstitutional — but declined to order permanent relief, citing a separate Fifth Circuit ruling that constrained his options, and noting the prison had already made some changes (shaded rest areas, more frequent water breaks) during the litigation. Plaintiffs argue those changes could be reversed at any time without a permanent order, and filed a motion for reconsideration in June 2026 asking the court to address the case’s broader claims about the practice’s harm to human dignity. The case remains open.
Seven states have already removed the exception clause
Since 2018, a slow but real wave of state constitutional amendments has stripped the “except as punishment for a crime” language out entirely — though it changes what the law says, not automatically what happens inside any specific prison.
In that same 2022 election, Louisiana — home to Angola — was the only one of five states voting on this kind of amendment where voters rejected it, with about 61% voting no. The amendment’s own legislative sponsor ended up urging a “no” vote, arguing the ballot language was so confusingly worded it might have accidentally re-legalized forms of servitude rather than banning them. He’s said he intends to bring a clearer version back to voters.
Eddie Lee Howard’s wrongful conviction
Howard’s case belongs on this site — it just isn’t a prison-labor case, and deserves to be told accurately rather than folded into a narrative it doesn’t fit.
In 1994, Eddie Lee Howard was sentenced to death in Mississippi for the rape and murder of an 84-year-old woman, based almost entirely on bite-mark evidence — a forensic technique now widely discredited as scientifically unreliable. Howard spent 26 years on Mississippi’s death row before the state Supreme Court vacated his conviction in August 2020, citing the debunked bite-mark testimony and exculpatory DNA evidence that excluded him as the perpetrator. He was fully exonerated in January 2021, becoming the 174th person exonerated from death row in the U.S. since 1973.
