The US Court Appeals for the Fifth Circuit [official website] overturned a lower court’s ruling that temperatures in Louisiana’s death-row prison cells be kept below 88 degrees Fahrenheit. In an opinion [text, PDF] by the Chief Judge, the court explained that the district court overstepped its authority by setting a maximum temperature for the cells.

This is the second time the case has come before this court. In the original claim, plaintiffs on Louisiana’s death row complained that in light of their pre-existing medical conditions that made them more susceptible to heat related injury, extreme heat conditions without any access to relief violated the Eight Amendment’s ban on cruel and unusual punishment. The trial court mandated a plan to provide relief to bring prison conditions within Eighth Amendment bounds. On appeal, the plan was overruled and remanded.

After rehearing the case, the district court issued a new plan. Wednesday’s ruling again struck it down as being inconsistent with the last appeals decision in the case. At issue specifically was the idea that heat-relief measures may have a “trigger” temperature but may not have a maximum. Doing so contradicted the mandate of the appeals court. Injunctive relief for constitutional compliance needs to be tailored as narrowly as possible.