Louisiana Prisoner Sentenced to Eight Years of… Barbecuing Chicken, Waxing Floors at the Mayor’s Church, and Renting Moon Bounces for the Police Chief’s Side Business
The Fifth Circuit recently ruled on a case out of Louisiana that is, well, not your typical conditions of confinement lawsuit. In 1996, John D. Williams pled guilty to simple burglary and was sentenced to eight years of hard labor:
His duties largely included maintaining city property and facilities such as City Hall, the railroad museum, ball parks, and even the police station. Williams was a trusty and the only inmate at DeQuincy [City Jail] who performed work of this nature. As a result, Williams also enjoyed certain privileges unavailable in most prisons. [Footnote: Williams was permitted to wear civilian clothing often purchased at town expense. He had his own room in which he was allowed to have private visits with women. He had a telephone, internet access, and access to a washing machine and cable television. It was common for Williams to be driven to the store to purchase personal items like food, cigarettes, and magazines.]
Williams asserts that Buddy Henagan, then the mayor of DeQuincy, and Michael Suchanek, DeQuincy’s Chief of Police, forced Williams to work additional hours beyond the regular work week and sometimes for their private gain. Henagan had him wax the floors of Henagan’s church; work 20 hours a day during the city’s railroad festival and cook barbecued chicken continuously for over 26 hours at various local fundraisers. Up to twice a month, he was required to ride around the city with Henagan between 2 a.m. and 3 a.m. to count burned out street lights. Henagan took Williams to Texas once to transport furniture Henagan had been given. Suchanek required him to work off-hours for Suchanek’s private businesses, sometimes until midnight or later and often on weekends. These ventures included Suchanek’s space jump rental and his grass cutting business. Williams admits he was paid occasionally for work he performed for Henagan and Suchanek.
(Williams v. Henagan, et al., 07-30997, 5th Cir., Jan. 28, 2010, pp. 2-3)
Williams’s lawsuit made three sets of claims: (1) a variety of conditions of confinement claims; (2) a claim under the Fair Labor Standards Act, that he was entitled to minimum wage; and (3) a claim under the Thirteenth Amendment’s prohibition on involuntary servitude. The Fifth Circuit affirmed the district court’s grant of summary judgment for the defendant state entities and state employees on all counts. First, certain of Williams’ claims were barred by the Eleventh Amendment, and others by his failure to first exhaust his administrative remedies, as required by the Prison Litigation Reform Act. Then, as to his claims under the Fair Labor Standards Act, the panel held that although there was a question of fact as to whether Williams qualified as an “employee” covered by the FLSA, this was irrelevant because his work was quite localized, and thus he was not engaged in interstate commerce, as required by the statute. Finally, the panel also rejected his Thirteenth Amendment claim, since that amendment specifically allows for involuntary servitude “as punishment for crime whereof the party shall have been duly convicted”. The panel concluded:
Henagan and Suchanek may well have abused their authority over Williams, and they do not deny many of Williams’s allegations about his work for them. None of this conduct, however, rises to the level necessary for an FLSA or Thirteenth Amendment claim. (p. 19)