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Greenwashing “Modern Day Slavery” through the Mystique of Prison Farm Labor

Published online by Cambridge University Press:  15 January 2024

Chin Jou
Chin Jou*
Affiliation:
University of Texas at San Antonio, San Antonio, TX, USA
*
Email: chin.jou@utsa.edu
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Extract

In Charleston, Maine, a town of about 1,500 near the center of the state, there is an orchard with 750 apple trees and a farm where a variety of produce is grown.1 This bucolic setting is on the grounds of the Mountain View Correctional Facility, a 374-bed minimum- and medium-security state prison.2 Incarcerated people tend to the apple trees and vegetables, and every year they cultivate 100,000 pounds of produce that wind up on their prison cafeteria, or chow hall, trays.3 Writing for the New York Times in 2021, Patricia Leigh Brown highlighted how Mountain View's prison food service manager Mark McBrine, who also happened to be “an organic farmer with dirt under his fingernails,” was “making the prison a pioneer in a nascent farm-to-prison table movement.”4 According to multiple media outlets that have reported on Mountain View's food system, it is a model to be emulated—both an antidote to dreary prison food and a cost-saver for the state of Maine.5

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International Labor and Working-Class History , First View , pp. 1 - 15
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Copyright © The Author(s), 2024. Published by Cambridge University Press on behalf of International Labor and Working-Class History, Inc.

In Charleston, Maine, a town of about 1,500 near the center of the state, there is an orchard with 750 apple trees and a farm where a variety of produce is grown.Footnote 1 This bucolic setting is on the grounds of the Mountain View Correctional Facility, a 374-bed minimum- and medium-security state prison.Footnote 2 Incarcerated people tend to the apple trees and vegetables, and every year they cultivate 100,000 pounds of produce that wind up on their prison cafeteria, or chow hall, trays.Footnote 3 Writing for the New York Times in 2021, Patricia Leigh Brown highlighted how Mountain View's prison food service manager Mark McBrine, who also happened to be “an organic farmer with dirt under his fingernails,” was “making the prison a pioneer in a nascent farm-to-prison table movement.”Footnote 4 According to multiple media outlets that have reported on Mountain View's food system, it is a model to be emulated—both an antidote to dreary prison food and a cost-saver for the state of Maine.Footnote 5

Nearly twenty-three hundred miles west of the Mountain View Correctional Facility is a goat farm with a population of twenty-five hundred in Cañon City, Colorado.Footnote 6 The goat farm is in the same town as six state prisons. Incarcerated people milk the goats, and the resulting milk is made into cheese sold by large food retailers, including, until 2015, Whole Foods.Footnote 7 In his 2017 feature on the goat farm, National Public Radio's (NPR) Dan Charles marveled at the scenery:

[W]hen you're there, you can almost forget you're in a prison. The goats, in their pens, look out over irrigated corn fields, the Arkansas River in the distance, and barren hillsides on the other side. To be perfectly honest, it's beautiful.Footnote 8

Charles also recounted his exchange with incarcerated man Jeremiah Pate. When he asked Pate if milking goats was a “bad thing” or a “good thing,” Pate responded: “It's a great thing.”Footnote 9 “It beats the alternative. Rather than sitting in your tiny little cell, you get to come out here,” Pate added.Footnote 10 According to Charles, “[e]very man I meet echoes that thought,” including two people who had already been released from prison and were presumably less concerned about how their interview responses would be received by corrections authorities.Footnote 11

The benefits of prison agricultural labor, these and other new stories suggest, are more than practical. Having incarcerated people cultivate some of their own food not only saves taxpayers’ money and offers incarcerated workers respite from life inside gray prison walls, but prison farm labor holds special transformative potential.Footnote 12 A Maine television news station waxed poetic about how the Mountain View Correctional Facility farm grew not just crops, but people, pointing to how an incarcerated man named “Julio” had been “growing” by “spending time in the sun,” working hard, and learning to be patient.Footnote 13 Prison farm labor has also been presented as a way for incarcerated people to repay their debts to society, especially at carceral institutions that donate some of the surplus crops they harvest to food banks. A 2015 Washington Post article quoted Walter Labord, a man incarcerated at the Eastern Correctional Institution in Westover, Maryland, reflecting on the healing effects of his labor. Labord, who worked on the prison grounds cultivating strawberries, squash, eggplant, lettuce, and peppers, shared that, “it makes it feel like you still have it in you to do something good.”Footnote 14

This Washington Post article quoting Labord and the NPR story on the Colorado prison goat farm did acknowledge some less-than-ideal dimensions of prison agricultural labor. The Post described the type of labor Labord performed as “grueling,” with “10-hour days” that involved being “scorched by the sun and tormented by flies.”Footnote 15 Meanwhile, the NPR story on the Cañon City goat farm hinted at the issue of low prison wages and how consumers may be unwittingly supporting an exploitative labor regime through their purchases, though it ultimately reconciled these thorny issues by quoting a formerly incarcerated agricultural worker who seemed to almost give consumers permission to buy products derived from prison labor. When NPR's Dan Charles asked Chad Redding about controversies surrounding Whole Foods selling cheese made from goats milked by incarcerated people, Redding, who had worked at the farm before his release from Colorado's Skyline Correctional Center, offered a response that was both diplomatic and unsettling: “It's no different than having some Chinese shoe shop make your Nikes for, like, a dollar.”Footnote 16

As these examples illustrate, the overall tone of these representative popular news stories on prison agricultural labor is ultimately more approving than ambivalent; farm labor is presented as a win-win scenario for society, self-sustaining prisons, and incarcerated people. Such narratives, this article underscores, are unique to agricultural work and rely on associations of the outdoors and farm foods with healthfulness and purity. The work of manufacturing license plates, for example, would be much more difficult for corrections systems and media reports to romanticize as labor that has the power to transform incarcerated people.Footnote 17

Penal reformers have long framed the rural outdoors as sites of redemption for people from the city. There is also a long history to the sentimentalization of agricultural labor in carceral settings, especially at it involves putatively wayward urbanites working up a sweat in the countryside. As criminologist Anthony M. Platt and sociologist David Garland have pointed out, turn-of-the-twentieth-century reformers in the United States and Europe believed that incarcerated people—including juveniles in reformatories—could benefit from laboring on rural farms, and they made both practical and philosophical arguments in favor of compulsory agricultural labor.Footnote 18 Such work could prevent incarcerated people from becoming “idle” and engaging in antisocial activities while in prison, and exposure to the “pure” and “natural” rural outdoors could rehabilitate “degenerates” who had been sullied by the inherent “corruption” of urban environments.Footnote 19

Corrections authorities continued to echo such sentiments throughout the twentieth century. In 1942, William T. Hammack, the assistant director of the (Federal) Bureau of Prisons, expressed hope that farm labor would “perhaps provide the incentive and initiative for the return to the soil of men who have drifted from farms into urban areas and who would be better off in agriculture.”Footnote 20 Like contemporary news stories on Maine's Mountain View prison, mid-twentieth-century prison authorities touted agricultural labor by emphasizing how it enabled incarcerated people to consume nourishing, farm-fresh foods without burdening the taxpayer. In a 1960 booklet about the Bureau of Prisons’ agricultural work program, the corrections agency described how the Federal Reformatory in Chillicothe, Ohio, had an onsite, seventeen-hundred-acre farm that generated “over 5 million pounds of food and animal feed annually.”Footnote 21 This yield included all the pork, milk, eggs, “most” of the vegetables and poultry, and one-fifth of the beef, served at the prison, allowing for “an interesting and wholesome diet despite budgetary limitations.”Footnote 22

This article considers how prison agricultural labor continues to be promoted as a particularly uplifting type of prison labor, and highlights what is elided and obscured from media stories on the topic. How prison farm labor is presented matters, in part, because it is still practiced at many carceral institutions; there are some seven hundred state prisons across the country that maintain work sites engaged in the production of plants, food, and animal husbandry.Footnote 23 Approving stories on prison agricultural labor are also not just feel-good stories of little consequence. Such stories, which rely on the cooperation of corrections officials for access to prisons and incarcerated people, reassure the public about U.S. carceral conditions.

Just as household and food manufacturers market their products as “green” (sometimes with green-colored packing) to suggest that their products are natural, pure, and sustainable, geographer Evan Hazelett has argued that corrections systems use “the symbolic power of ‘green’” to legitimate prisons.Footnote 24 (The very term “gardens” is significant, as corrections systems may refer to even large farms as gardens to suggest that labor in such spaces is a leisure activity.) Such attempts to greenwash prisons by touting their onsite “gardens” may be especially useful during moments when critiques of the harms of prisons and injustices of mass incarceration are most salient, as they allow carceral authorities to “produce institutional legitimacy without having to invest significant resources in substantive reform, let alone systematic decarceration.”Footnote 25

In conjunction with Hazelett's observation that prison “gardens” help launder U.S. carceral systems, this article stresses that, by representing agricultural labor as wholesome and rehabilitative, stories idealizing prison farm labor also sanitize objectionable features of prison labor in particular and thus legitimate prisons as “places of production as well as punishment,” to borrow a phrase from historian Heather Ann Thompson.Footnote 26 The reality of carceral “places of production” is that they involve coerced labor, extraordinarily low or no wages at all, and the absence of health and safety guarantees that also undercut working Americans on the outside.

Incarcerated people have consistently sought to bring attention to, and contest, these features of prison labor. Within the context of prison agricultural labor, they have, as this article shows, attempted to circumvent work requirements by injuring themselves and used work stoppages to protest what they call “modern day slavery.” This article proposes that earnestly considering incarcerated people's characterization of their work as “modern day slavery” profoundly changes how we might view news stories about prison agricultural labor. Rather than fluff stories, they become justifications for a racialized system of state-sponsored, forced labor that is anything but feel-good.

History

Corrections systems have been legally able to force incarcerated people to work because the Thirteenth Amendment's abolition of slavery and involuntary servitude excluded those convicted of a crime. State legislation and state-level judicial rulings, such as Ruffin v. Virginia (1871), which declared incarcerated people “slaves of the State,” also provide legal sanction for this “modern day slavery”; as of 2023, the ban on slavery in sixteen states’ constitutions include an exception for people who are being punished for their crimes.Footnote 27

Even before the ratification of the Thirteenth Amendment in 1865, however, labor had been a part of carceral punishment.Footnote 28 It was not unusual for early-nineteenth century state penitentiaries to require work; at the Eastern State Penitentiary in Philadelphia, incarcerated people spun wool and made shoes as part of correctional authorities’ efforts to “reform” them.Footnote 29 After the Civil War, Southern states codified Black Codes to limit African Americans’ mobility and coerce them into labor; those found in violation of Black Codes would be incarcerated and leased to private business and agricultural interests where their working conditions were so deplorable that mortality rates were as high as forty percent.Footnote 30 Although convict leasing declined by the early-twentieth century, Southern states relied on chained “road gangs” that built infrastructure until well into the mid-twentieth century.Footnote 31

Penal labor during this era was not limited to the South, however. As historian Ariel Ludwig has chronicled, in 1884, a “Municipal Farm” opened on the jail grounds of New York's Rikers Island to extract labor from people incarcerated there.Footnote 32 Notably, women, though incarcerated in far fewer numbers than men, have also been forced to labor since the nineteenth century.Footnote 33 Incarcerated women served as domestic servants in jails and prisons—cooking, cleaning, washing clothes, and sewing uniforms for carceral staff and their households; the Black women among them also performed strenuous field labor in the nineteenth and twentieth centuries.Footnote 34 Carceral authorities viewed Black women as irredeemable and unfeminine, in contrast to the white women whom they spared from the harshest physical labor.Footnote 35

Contemporary Work Mandates

Like their predecessors from earlier eras, some people incarcerated in state and federal prisons today work because they have no choice in the matter. One 2022 report by the American Civil Liberties Union (ACLU) and the University of Chicago Law School Global Human Rights Clinic found that over sixty-five percent of people incarcerated in state and federal prisons work.Footnote 36 Using survey data from 2016, a 2023 Bureau of Justice Statistics report noted that eighty-three percent of people incarcerated in federal prisons and seventy-one percent of people in state prisons said they were required to work.Footnote 37 Indeed, the (Federal) Bureau of Prisons’ own policy states that, “sentenced inmates” must work “if they are medically able.”Footnote 38

At many prisons, those who refuse to work can be punished with solitary confinement, lose family visitation privileges, barred from purchasing food and other essential supplies at prison commissaries, and see the erasure of “good time,” or previously earned credits, that can reduce one's sentence.Footnote 39 Some states do not specify the types of punishment that await incarcerated people who resist labor mandates, but ominously refer to the meting out of “disciplinary action.”Footnote 40

As coercive as such compulsory labor policies are, states couch them as a service for incarcerated people. The Louisiana Department of Public Safety and Corrections claims that “[a]griculture work at the [Angola] prison provides offenders with a skill they may use once they are released from prison, and the produce [they grow] helps feed the offenders at the state's prisons.”Footnote 41 But most of the men at Angola will never get a chance to apply their “skills” in society. A majority of them are serving life sentences.Footnote 42 Meanwhile, North Carolina state law acknowledges that prison labor is used to “reduce the costs of maintaining the inmate population,” but it also claims that its work requirements “enable inmates to acquire or retain skills and work habits needed to secure honest employment after their release.”Footnote 43

Such perfunctory defenses of mandatory prison labor elide the reality that, in spite of their work experiences while incarcerated, joblessness among people who have previously been incarcerated may still be as high as sixty percent, according to an estimate by the nonpartisan Prison Policy Initiative in 2022.Footnote 44

Lack of Workplace Protections and Pay

Incarcerated people are not afforded labor protections like those spelled out in the National Labor Relations Act (NLRA), which legally authorizes workers’ right to unionize and collective bargaining without retaliation from employers. Unlike the Thirteenth Amendment, the NLRA did not explicitly exclude incarcerated people. Courts have nonetheless decided that incarcerated people's relationship with corrections systems is primarily penal rather than economic, and therefore they are not “employees” entitled to NLRA protections.Footnote 45 In 1973, five hundred and forty out of seven hundred people incarcerated at Central Prison in Raleigh, North Carolina, established a union, prompting incarcerated workers in other parts of the state and in Delaware, Maine, Massachusetts, Michigan, Minnesota, Ohio, Pennsylvania, Washington, D.C., and Wisconsin, to follow suit.Footnote 46 The North Carolina Department of Corrections responded by banning the prison union that had begun at Central Prison, after which the union fought the ban in the courts; the Supreme Court ultimately upheld the ban in Jones v. North Carolina Prisoners’ Union (1977).

Incarcerated workers are also mostly excluded from health and safety laws. The Occupational Health and Safety Act (OSHA), which “assure[s] safe and healthful working conditions for working men and women,” has only applied to the roughly 10 percent of people incarcerated in federal institutions, according to the ACLU and the University of Chicago Law School Global Human Rights Clinic.Footnote 47

Perhaps the most well-publicized dimension of prison labor is how little incarcerated workers are paid. Just as the NLRA and the OSHA have not applied to most incarcerated workers, corrections systems are exempt from the Fair Labor Standards Act entitling workers to a minimum wage and overtime pay. Their labor can even be entirely unpaid. As of 2022, at least six states—Alabama, Arkansas, Georgia, Mississippi, South Carolina, and Texas—did not compensate the majority of their incarcerated workers.Footnote 48 Meanwhile, the states that do pay incarcerated workers do so at far below the federal minimum wage of $7.25 per hour.Footnote 49 Among incarcerated people whose work is classified as supporting “prison facilities,” which includes working on prison farms, average hourly wages ranged from a low of thirteen cents to a high of fifty-two cents in 2022.Footnote 50 As modest as incarcerated people's pay rates already are, corrections systems deduct taxes, court fines, child support, restitution, jail or prison “room and board,” and medical co-pays and other fees, from their paychecks.Footnote 51

A Link in the Commercial Food Chain

Along with receiving paltry or no wages for their agricultural work, some incarcerated people are even denied the right to consume the literal fruits of their labor. As illustrated by the example of cheese sourced from a Colorado prison goat farm that found its way to Whole Foods store shelves, until 2015, not all the food produced on prison farms are for incarcerated people. In some instances, all the food from a prison farm may be sold or donated, considered too high quality or expensive for the very people who produced that food. This is not a recent phenomenon, but longstanding practice at some prisons. When the Bureau of Prisons surveyed Tennessee state prisons in 1950s, it reported that, “it is a general practice in most of the state institutions to sell the meat produced on their farms and to use some part of this money to buy the salt pork which is cheaper[,] and the meat requirement [for incarcerated people] can be met at a lower cost.”Footnote 52 More recently, a 2021 report surveying incarcerated people in Maryland found that those who worked in state prison farms were prohibited from consuming any of the produce they harvested, though that food would be donated to food banks, nonprofits, and local government agencies, rather than sold.Footnote 53

More often, onsite prison farms source both carceral kitchens and produce food for the commercial food supply.Footnote 54 In Texas, incarcerated men and women cultivate some thirty different vegetables, which the Texas Department of Criminal Justice said produced nearly twelve million pounds of food in 2017; the state also relies on incarcerated labor for meat processing, canning, and a “poultry program” that yielded 4.9 million eggs that year.Footnote 55 A portion of Texas's prison farm and livestock operations fed “the offender population,” while the rest was for commercial sale, according to the state.Footnote 56

A report by the food journalism nonprofit The Counter in 2017 also found that the food industry purchases tens of millions of dollars’ worth of food derived from prison labor—both crops from prison farms and processed food items from various states’ factories or correctional industries.Footnote 57 Buyers of food sourced from prison labor included industry behemoths Cargill—the largest privately held company in the United States—and Dairy Farmers of America, the dairy cooperative accounting for nearly a quarter of the U.S. milk market.Footnote 58 Given this, it is a near certainty that Americans shopping at conventional supermarkets have encountered products made with prison labor.

That prison labor is behind part of the commercial food supply is not just a problem for American consumers concerned about ethical implications. This reliance on incarcerated labor is also a problem for nonincarcerated workers whose wages and working conditions are undermined by the use of prison labor, as Heather Ann Thompson pointed out in her 2010 study of the effects of mass incarceration on postwar historical developments, including the decline of the U.S. labor movement.Footnote 59 Labor unions saw this coming. When the federal government proposed what would become Federal Prison Industries in 1934, the American Federation of Labor (AFL) protested, and when federal and state correctional industries expanded in subsequent decades, labor unions also registered their opposition.Footnote 60

Incarcerated people are not, of course, the only workers whose exploitation has furthered the degradation of labor in the contemporary United States. Employers have used migrant farmworkers to such an extent that three-quarters of farm workers in the United States are foreign-born and roughly half are unauthorized, according to the Migration Policy Institute in 2017.Footnote 61 During the Obama and Trump Administrations, vigorous enforcement of anti-immigration measures even contributed to farm labor shortages.Footnote 62

Tellingly, a number of states responded to the shortages by expanding their prison labor programs, resulting in incarcerated workers harvesting some of the Georgia onions, Arizona watermelons, Washington apples, and Idaho potatoes that would have been harvested by migrant farm laborers in the past.Footnote 63 Had prison agricultural labor not been available in these states, farm owners would have had to raise wages and improve working conditions to appeal to nonincarcerated people to work jobs previously held by unauthorized migrant farm laborers. The use of prison farm labor to harvest crops destined for market, then, perpetuates a system of agricultural production that undercuts wages and working conditions for all workers.

Resistance

Incarcerated workers have challenged every dimension of prison work, including being forced to work. Some incarcerated people have focused their efforts on labor mandates that include an exception for those with medical exemptions or disabilities, as the history of compulsory labor at the Louisiana State Penitentiary at Angola exemplifies. The Angola Prison has been so closely associated with agricultural labor that it is nicknamed “The Farm,” and since the end of convict leasing, perhaps no U.S. prison has evoked slavery more.Footnote 64 Not only does the sight of Black bodies toiling in fields with little or no pay as armed guards on horseback oversee them conjure up images of antebellum slavery, but the prison itself sits on land that used to house plantations. The very name of the prison—Angola—is derived from the name of one of those plantations, and that plantation was named after the ancestral homeland of people enslaved on the property.

The Angola Prison was racially segregated until the 1960s, and carceral Jim Crow at Angola, like at other Southern state prisons, was not limited to physical separation of the races.Footnote 65 Carceral Jim Crow also meant that African Americans were assigned the most undesirable prison jobs, subject to harsher supervision than whites, and excluded from access to library reading rooms and other privileges incarcerated whites enjoyed.Footnote 66 At Angola in the mid-1960s, incarcerated whites were usually assigned to work as prison clerks, mechanics, cleaners, canners, sugar-mill workers, and license-plate makers, while African Americans were forced to perform grueling field labor, according to the late Albert Woodfox, the survivor of more than four decades of solitary confinement at Angola.Footnote 67 In these ways, race—not the particular crime for which one had been convicted— determined how incarcerated people at Angola and other Southern prisons would be treated.

While the Angola Prison is no longer segregated, its system of compulsory labor remains intact. Men incarcerated at Angola grow the vegetables served in its chow halls and work at the prison's processing plant, packaging and freezing “The Farm's” produce.Footnote 68 Those who labor in the fields have described the work as long hours of bending down, tending and harvesting produce under a blazing sun while lacking water to drink and under constant threat by armed guards.Footnote 69 In 2018, a Louisiana Department of Public Safety and Corrections spokesperson insisted that Angola provided its incarcerated workforce with “abundant water,” though the spokesperson confirmed “a use of force policy” in which armed guards patrolled the workers.Footnote 70 The state paid its incarcerated farm laborers wages between four cents and one dollar an hour as of 2017—a raise from as low as two pennies an hour in 2015.Footnote 71

Since the early-twentieth century (the prison opened in 1901) until the 1970s, men at Angola were also made to work in the prison's five thousand acres of sugar cane fields.Footnote 72 Before beginning his four-plus decades of solitary in the 1970s, Woodfox was put to work cutting sugar cane at Angola—drudgery he described as “the hardest job I ever had in my life.”Footnote 73 It required him to bend over constantly, wield a machete-like knife with short handles that was hard to grasp for extended periods, and “grab” and “whack” sugar cane stalks as fast as he could.Footnote 74 When sugar cane needed harvesting each fall, Woodfox performed this labor seven days a week. “[I]t was the speed they pushed on us that made it so hard,” he wrote in his 2019 memoir.Footnote 75

Some men at Angola mutilated themselves rather than work in the sugar cane fields. In the infamous “heel-stringing” protest of 1951, more than thirty men lacerated their Achilles tendons to liberate themselves from field labor and to protest their working and living conditions.Footnote 76 The “Heel String Gang,” as they were called, succeeded in drawing attention to their plight, as the national news media reported on their desperation and dramatic act of defiance, with one magazine designating Angola “America's worst prison.”Footnote 77 This negative publicity led the Louisiana governor, Earl K. Long, to form a committee of community leaders and experts to investigate the prison.Footnote 78 The committee found that the prison was filthy, rife with violence, and lacked treatment programs and medical care.Footnote 79 State officials responded to the committee's findings by spending eight million dollars to improve Angola and build a new prison, which opened four years after the “heel-stringing” protest.Footnote 80

A decade-and-a-half later, not much had changed, according to Woodfox's account. Angola was still a hellhole. People still maimed themselves to avoid toiling in the sugar cane fields. As generations of men at Angola had done before them, Woodfox wrote that his incarcerated contemporaries “would pay someone to break their hands, legs, or ankles, or they would cut themselves during cane season.”Footnote 81 Self-harm as a strategy to elude compulsory labor was not only practiced at Angola, and has continued into the mass incarceration era to such an extent that some states and corrections systems have explicit rules against it. North Carolina attempts to discourage the practice by threatening incarcerated people and those who they might enlist to injure them with additional felony counts and more prison time. The state issues this warning to people seeking to evade labor, or those who might assist them:

Any person serving a sentence or sentences within the State prison
system who, during the term of such imprisonment, willfully and
intentionally inflicts upon himself any injury resulting in a permanent
or temporary incapacity to perform work or duties assigned to him by
the Division of Adult Correction and Juvenile Justice of the Department
of Public Safety, or any prisoner who aids or abets any other prisoner in
the commission of such offense, shall be punished as a Class H felon.Footnote 82

A Class H felony in North Carolina carries a maximum of thirty-nine months in prison.Footnote 83

Charging “Modern Day Slavery”

Apart from individual, ad hoc instances of resistance, incarcerated workers have also engaged in direct, collective protest by striking for higher wages and better working conditions, and asserting that they “are not slaves.”Footnote 84 Groups like Jailhouse Lawyers Speak (JLS), which describes itself as “a national collective of imprisoned persons who fight for human rights, by providing other prisoners with access to legal education, resources, and assistance,” as well as the Incarcerated Workers Organizing Committee, the prison arm of the Industrial Workers of the World, have been involved in strikes at carceral institutions across the United States.Footnote 85 In 2018, there were strikes in multiple states following a violent episode that led to the deaths of seven incarcerated people at the Lee Correctional Institution in Bishopville, South Carolina, in April of that year.Footnote 86 The prison was overcrowded and understaffed, and critics maintained that the deaths could have been prevented had corrections officers intervened sooner.Footnote 87

One of the 2018 strikes took place at Angola, where incarcerated people had been organizing for three years.Footnote 88 At a prison where almost eighty percent of the incarcerated population was African American, the Incarcerated Workers Organizing Committee released a statement on behalf of men at Angola, asserting: “We demand a national conversation inquiring how state prison farms across the country came to hold thousands of people from African descent against their will.”Footnote 89 Three months later, as the forty-seventh anniversary of the police killing of Black prison revolutionary George Jackson and the bloody uprising at New York's Attica Prison approached, strike organizers said additional work stoppages, along with commissary boycotts and protests on prison yards, took place in prisons and detention centers in Washington, California, South Carolina, and Ohio.Footnote 90 Strike participants demanded “an immediate end to prison slavery,” along with humane prison conditions.Footnote 91

Conclusion

That striking incarcerated workers have called their condition “prison slavery” is significant, and should not be dismissed as hyperbole. It suggests that, among incarcerated African Americans, protesting compulsory labor is not solely a matter of securing practical improvements such as wage increases and better working conditions. These protests reflect, as anthropologist Orisanmi Burton has recently argued about Black-led prison rebellions, strike participants’ understanding of prisons as a site of “white supremacist systems of power,” and their attempts to carve out “zones of autonomy, freedom, and liberation” within prisons.Footnote 92

If, as incarcerated Black radicals have maintained, prisons are sites of modern-day slavery, there is no dimension of prison life that is more evocative of planation slavery than the farms and “gardens” across the United States where disproportionately Black and brown bodies are forced to work to maintain prisons and, in some cases, grow food for American consumers. Seeing contemporary, compulsory prison agricultural labor as analogous to antebellum field slavery also has major implications for what to make of media coverage on prison farms. News stories about prison farms, such as those described at the outset of this article, are no longer benign or uplifting accounts of the invigorating outdoors and farm-fresh food in otherwise grim environments. Rather, they become greenwashed narratives that, even if unintentionally, do the work of obscuring connections between prison agricultural labor and field slavery by framing such labor as wholesome and rehabilitative (notwithstanding an eighty-three percent recidivism rate at state prisons nationwide).Footnote 93

That the news organizations that have produced such stories include leading, national print media sources like the New York Times and the Washington Post, and National Public Radio, which is syndicated to over one thousand public radio stations across the United States and reaches an audience of forty-four million, raises the imperative for critically examining media narratives of prison farm labor.Footnote 94 While the contemporary media landscape is diverse, and people consume news from a multitude of sources, such media organizations carry considerable cultural capital and can still shape Americans’ ideas about prison life and conditions, especially if readers and listeners do not have firsthand experiences with incarceration. Of course, no relatively short news article or six-minute radio story can include all the intricacies of prison labor policies and practices, but news organizations could, at the very least, clarify whether incarcerated people are being forced or coerced into working, and the wages—if any—they are earning. The elision of such details can discourage Americans from critically engaging with uncomfortable, urgent questions about prison conditions and carceral labor practices that have been justifiably called “modern-day slavery.”

References

Notes

1. Patricia Leigh Brown, “The ‘Hidden Punishment’ of Prison Food,” Mar. 2, 2021, The New York Times, https://www.nytimes.com/2021/03/02/opinion/prison-food-farming-health.html.

2. Ibid.; “Mountain View Correctional Facility,” State of Maine Department of Corrections, 2020, https://www.maine.gov/corrections/adult-facilities/mountain-view-correctional-facility; Leslie Soble, Kathryn Stroud, and Marika Weinstein, Eating Behind Bars: Ending the Hidden Punishment of Food in Prison, Impact Justice, 2020, 80–81, https://impactjustice.org/impact/food-in-prison/#report.

3. Leigh Brown, “The ‘Hidden Punishment’ of Prison Food”; “Mountain View Correctional Facility”; Soble et al., Eating behind Bars, 80–81; “Farm-to-Table: A Maine Prison Program Provides Better Food for Inmates,” YouTube, 3:16, posted by News Center Maine, Aug. 19, 2021, https://www.youtube.com/watch?v=T2kSWR9FI0U.

4. Leigh Brown, “The ‘Hidden Punishment’ of Prison Food.” While “farm-to-prison table” arrangements are nothing new, some prison farm and garden programs ceased operation during the height of the mass incarceration era in the last three decades of the twentieth century. See Michael S. Rosenwald, “Can Gardening Transform Convicted Killers and Carjackers? Prison Officials Get behind the Bloom,” The Washington Post, Jun. 7, 2015, https://www.washingtonpost.com/local/can-gardening-transform-convicted-killers-and-carjackers-prison-officials-get-behind-the-bloom/2015/06/07/bf5c4cf0-0afb-11e5-a7ad-b430fc1d3f5c_story.html; Malcolm Burnley, “How Prison Gardens Help Inmates and Save Money,” Next City, Jul. 25, 2017, https://nextcity.org/urbanist-news/prison-gardens-help-inmates-save-money.

5. Leigh Brown, “The ‘Hidden Punishment’ of Prison Food”; Soble et al., Eating behind Bars, 13, 36, 81, 88, 119; “Farm-to-Table.”

6. Dan Charles, “What's It Really Like to Work in a Prison Goat Milk Farm? We Asked Inmates,” National Public Radio, Jul. 20, 2017, https://www.npr.org/sections/thesalt/2017/07/20/538062911/whats-it-really-like-to-work-in-a-prison-goat-milk-farm-we-asked-inmates.

7. “Canon City,” Colorado Department of Corrections, 2022, https://cdoc.colorado.gov/facilities/canon-city.

8. Charles, “What's It Really Like to Work in a Prison Goat Milk Farm?”

9. Ibid.

10. Ibid.

11. Ibid.

12. For more on what Craig Gilmore calls the “reproductive labor” of prisons in which incarcerated workers are responsible for their own carceral maintenance, see Gilmore, Craig, “An Interview with James Kilgore,” The Abolitionist (Fall 2014): 6Google Scholar.

13. “Farm-to-Table.”

14. Rosenwald, “Can Gardening Transform Convicted Killers and Carjackers?”

15. Ibid.

16. Charles, “What's It Really Like to Work in a Prison Goat Milk Farm?” Redding's analogizing of the Colorado prison goat farm with overseas sweatshop labor notorious for coercive labor practices, low pay, and brutal working conditions was seemingly intended to normalize the exploitation that occurs in the supply chain for many consumer goods. But for Whole Foods, cheese sourced from the prison goat farm threatened the image it had crafted as a purveyor of ethically produced food (the veracity of that image notwithstanding). An activist group called End Mass Incarceration Houston had been protesting the upscale grocer's sale of multiple food products derived from prison labor, and in 2015, Whole Foods announced that it was going to stop carrying all such items. See Allison Aubrey, “Whole Foods Says It Will Stop Selling Foods Made with Prison Labor,” National Public Radio, Sept. 30, 2015, https://www.npr.org/sections/thesalt/2015/09/30/444797169/whole-foods-says-it-will-stop-selling-foods-made-by-prisoners. (The Skyline Correctional Center closed in 2021.)

17. For analyses of prison labor more broadly in this journal, see “Invisible Labor in Carceral Spaces,” International Labor and Working-Class History 101 (Spring 2022).

18. Platt, Anthony M., The Child Savers: The Invention of Delinquency (Chicago, IL: University of Chicago Press, 1977)Google Scholar; Garland, David, Punishment and Welfare: A History of Penal Strategies (New Orleans, LA: Quid Pro Books, 2018)Google Scholar.

19. Platt, The Child Savers, 51, 59, 65; Garland, Punishment and Welfare, 135.

20. W.T. Hammack, Gearing Federal Prisons to the War Effort (Atlanta, GA: United States Penitentiary, 1942), Box 241, “Reports and Memorabilia Relating to Bureau-Wide Operations and Programs, 1917-71”), Record Group 129 (Records of the Bureau of Prisons, 1870-1981), National Archives at College Park, College Park, MD. Hammack had suggested, as contemporary corrections officials tend to do in promoting prison work programs, that laboring in prison would make formerly incarcerated people more employable. But by the 1980s, the federal prison system had significantly curtailed its prison farm operations. According to the historian of federal prisons Paul W. Keve, this was because “farming was not cost effective when staffs worked forty-hour weeks, nor was it useful to urban-oriented inmates.” See Keve, Prisons and the American Conscience: A History of U.S. Federal Corrections (Carbondale, IL: Southern Illinois University Press, 1991), 240.

21. Chillicothe: Federal Reformatory, Chillicothe, Ohio (booklet), (Washington, D.C.: Bureau of Prisons, 1960), 19; Folder “4-49-09,” Box 235, Reports and Memorabilia Relating to Individual Institutions, 1907–1970, Record Group 129 (Records of the Bureau of Prisons, 1870-1981), National Archives at College Park, College Park, MD.

22. Ibid., 19–20.

23. Chennault, Carrie and Sbicca, Joshua, “Prison Agriculture in the United States: Racial Capitalism and the Disciplinary Matrix of Exploitation and Rehabilitation,” Agriculture and Human Values 40 (2023): 175CrossRefGoogle Scholar.

24. Hazelett, Evan, “Greening the Cage: Exploitation and Resistance in the (Un)Sustainable Prison Garden,” Antipode: A Radical Journal of Geography 55 (2023): 436CrossRefGoogle Scholar.

25. Ibid., 437.

26. Thompson, Heather Ann, “Rethinking Working Class Struggle through the Lens of the Carceral State: Toward a Labor History of Inmates and Guards,” Labor: Studies in the Working-Class History of the Americas 8 (Fall 2011): 15Google Scholar.

27. Meg Anderson, “Colorado Banned Forced Labor Five Years Ago. Prisoners Say It's Still Happening,” National Public Radio, Nov. 13, 2023, https://www.npr.org/2023/11/13/1210564359/slavery-prison-forced-labor-movement.

28. Talitha L. LeFlouria and Vivien M.L. Miller, “Introduction,” International Labor and Working-Class History 101 (Spring 2022): 2.

29. Ibid., 3; Eisen, Lauren-Brooke, Inside Private Prisons: An American Dilemma in the Age of Mass Incarceration (New York: Columbia University Press, 2018), 16Google Scholar.

30. The forty percent mortality figure refers to Alabama in 1870. See Shane Bauer, “5 Ways Prisoners Were Used for Profit throughout U.S. History,” PBS, Feb. 26, 2020, https://www.pbs.org/newshour/arts/5-ways-prisoners-were-used-for-profit-throughout-u-s-history. For more on convict leasing, see LeFlouria, Talitha L., Chained in Silence: Black Women and Convict Labor in the New South (Chapel Hill, NC: University of North Carolina Press, 2015)CrossRefGoogle Scholar; Blackmon, Douglas A., Slavery by Another Name: The Re-Enslavement of Black Americans from the Civil War to World War II (New York: Anchor Books, 2008)Google Scholar; Lichtenstein, Alex, Twice the Work of Free Labor: The Political Economy of Convict Labor in the New South (New York: Verso, 1996)Google Scholar; Oshinsky, David M., “Worse Than Slavery”: Parchman Farm and the Ordeal of Jim Crow Justice (New York: Simon & Schuster, 1996)Google Scholar; Mancini, Matthew J., One Dies, Get Another: Convict Leasing in the American South, 1866-1928 (Columbia, SC: University of South Carolina Press, 1996)Google Scholar; Lynn Weinstein (posted by Ellen Terrell), “The Convict Leasing System: Slavery in Its Worst Aspects,” Library of Congress, Jun. 17, 2021 https://blogs.loc.gov/inside_adams/2021/06/convict-leasing-system/; Bauer, Shane, American Prison: A Reporter's Undercover Journey into the Business of Punishment (New York: Penguin, 2018)Google Scholar.

31. James T. Wooten, “Prison Road Gangs Fading Fast in South,” The New York Times, Oct. 23, 1971, 35.

32. Ariel Ludwig, “The Labor of Care in Carceral Spaces: The Work of Resistance in New York City Jails,” International Labor and Working-Class History 101 (Spring 2022): 64.

33. LeFlouria and Miller, “Introduction,” 3.

34. Ibid.

35. See LeFlouria, Chained in Silence; Kali Nicole Gross, “African American Women, Mass Incarceration, and the Politics of Protection,” Journal of American History 102 (Jun. 2015): 25–33; Nathalie Rech, “Black Women's Domestic Labor at Angola (Louisiana State Penitentiary) during Jim Crow,” International Labor and Working-Class History 101 (Spring 2022): 44–63.

36. Captive Labor: Exploitation of Incarcerated Workers, American Civil Liberties Union and University of Chicago Law School Global Human Rights Clinic, 2022, 8, https://www.aclu.org/sites/default/files/field_document/2022-06-15-captivelaborresearchreport.pdf.

37. Lauren Beatty and Tracy L. Snell, “Work Assignments Reported by Prisoners, 2016,” Bureau of Justice Statistics, Apr. 2023, 1.

38. “Work Programs,” Bureau of Prisons (undated, accessed Aug. 20, 2022), https://www.bop.gov/inmates/custody_and_care/work_programs.jsp.

39. Benns, “American Slavery, Reinvented.”

40. See, for example, North Carolina General Statues, Chapter 148, Article 3 (undated, but listed as “effective until January 1, 2023”), 1, https://www.ncleg.gov/EnactedLegislation/Statutes/PDF/ByArticle/Chapter_148/Article_3.pdf.

41. Bryce Covert, “Louisiana Prisoners Demand an End to ‘Modern-Day Slavery,’” The Appeal, Jun. 8, 2018, https://theappeal.org/louisiana-prisoners-demand-an-end-to-modern-day-slavery/.

42. “Angola for Life,” YouTube video, 13:18, posted by The Atlantic, Sept. 22, 2015, https://www.youtube.com/watch?v=7ABpWhY5Xzk.

43. N.C. Gen. Stat. § 148-26, Article 3.

44. Leah Wang and Wanda Bertram, “New Data on Formerly Incarcerated People's Employment Reveal Labor Market Injustices,” Prison Policy Initiative, Feb. 8, 2022, https://www.prisonpolicy.org/blog/2022/02/08/employment/.

45. Benns, “American Slavery, Reinvented”; An-Li Herring, “Allegheny County Jail Doesn't Pay Its Incarcerated Workers, A ‘Common Practice’ at Jails,” WESA (Pittsburgh NPR Station), Jul. 6, 2021, https://www.wesa.fm/courts-justice/2021-07-06/allegheny-county-jail-doesnt-pay-its-incarcerated-workers-a-common-practice-at-jails.

46. Thompson, “Rethinking Working Class Struggle through the Lens of the Carceral State,” 24.

47. Occupational Health and Safety Act, 29 U.S.C. §§ 651–678; Captive Labor, 12, 61.

48. Benns, “American Slavery, Reinvented”; Captive Labor, 6, 10; Beth Schwartzapfel (with additional reporting by Lawrence Bartley), “Prison Money Diaries: What People Really Make (and Spend) behind Bars,” The Marshall Project, Aug. 4, 2022, https://www.themarshallproject.org/2022/08/04/prison-money-diaries-what-people-really-make-and-spend-behind-bars?.

49. Minimum wage figure is as of 2022.

50. Captive Labor, 10. These figures do not include incarcerated workers in correctional industries.

51. Ibid., 11. Federal Prison Industries chief operating officer Steve Schwalb even boasted in 1996 that, “[o]f the pay earned by [federal] inmates, 50 percent was paid to the public in the form of fines, restitution, and child support.” See Steve Schwalb, “Foreword: Federal Prison Industries: The Myths, Successes, and Challenges of One of America's Most Successful Government Programs,” in Factories with Fences: The History of Federal Prison Industries, ed. John W Roberts (Sandstone, MN: Federal Prison Industries, 1996), 8.

52. Survey of the Tennessee State Penal Institutions, Publication Date Unknown, but Survey Conducted in 1950, 20, Untitled Folder, Box 6 (Titled, “Tennessee”), Records Relating to Surveys of State Penal Systems, 1945–1962, Record Group 129 (Records of the Bureau of Prisons, 1870–1981), National Archives at College Park, College Park, MD

53. “‘I Refuse to Let Them Kill Me,’” 109.

54. Ashanté Reese and Randolph Carr, “Op-ed: Overthrowing the Food System's Plantation Paradigm, Civil Eats, Jun. 19, 2020, https://civileats.com/2020/06/19/op-ed-overthrowing-the-food-systems-plantation-paradigm/.

55. Texas Department of Criminal Justice Annual Review 2018, Texas Department of Criminal Justice, Sept. 2019, 57, https://www.tdcj.texas.gov/documents/Annual_Review_2018.pdf.

56. Ibid.; Reese and Carr, “Op-ed: Overthrowing the Food System's Plantation Paradigm.”

57. Brown, “How Corporations Buy—and Sell—Food Made with Prison Labor.”

58. Ibid.; Andrea Murphy, “America's Largest Private Companies: Cargill Is Back at No. 1,” Forbes, Nov. 23, 2021, https://www.forbes.com/sites/andreamurphy/2021/11/23/americas-largest-private-companies-cargill-is-back-at-no-1/?sh=7cae946e32b7; “Dairy Farmers of America's Joint Venture with the Chinese,” Dairy Farmers of America, Undated (Accessed Aug. 23, 2022), 5, https://www.usda.gov/sites/default/files/documents/JWaldvogel.pdf.

59. Heather Ann Thompson, “Why Mass Incarceration Matters: Rethinking Crisis, Decline, and Transformation in Postwar American History,” Journal of American History 97 (December 2010): 703–34; Brown, “How Corporations Buy—and Sell—Food Made with Prison Labor.”

60. Rodney Ho, “Mr. Schwalb Puts His Inmates to Work for the Private Sector,” The Wall Street Journal, Jul. 22, 1999, https://www.wsj.com/articles/SB932597190228734471.

61. See Philip Martin, “Immigration and Farm Labor: From Unauthorized to H-2A for Some?” Migration Policy Institute, Aug. 2017, 1, https://www.migrationpolicy.org/sites/default/files/publications/Martin-ImmigrationAgricultureH2AWorkers-FINAL.pdf.

62. Sarah Evans, “Is Prison Labor the Future of Our Food System?” Sept. 7, 2018, https://archive.foodfirst.org/is-prison-labor-the-future-of-our-food-system/.

63. Ibid.; Chuck Abbott, “To Meet Farm-Labor Shortages, Idaho Puts Inmates on the Job,” Successful Farming, Oct. 19, 2017, https://www.agriculture.com/news/to-meet-farm-labor-shortages-idaho-puts-inmates-on-the-job.

64. Some prison abolitionists and incarcerated labor activists have also likened mass incarceration to modern-day slavery. On slavery and imprisonment, political philosopher Joy James suggests that plantation slavery was incarceration and contemporary incarceration is slavery: “Plantations, historically, were penal sites—prisons for the exploitation of agricultural, domestic, and industrial labor and the dehumanization of beings…Prison is the modern day manifestation of the plantation.” James points out that both plantation slavery and contemporary prisons involve “sexual terror and domination, beatings, regimentation of bodies, exploited labor, denial of religious and cultural practices, substandard food, health care, and housing, forced migration, isolation in ‘lockdown’ for punishment and control, denial of birth family and kin.” See James, Joy, “Introduction,” in The New Abolitionists: (Neo)Slave Narratives and Contemporary Prison Writings, ed. James, Joy (Albany, NY: SUNY Press, 2005), xxiiiGoogle Scholar.

65. See Blue, Ethan, Doing Time in the Depression: Everyday Life in Texas and California Prisons (New York: New York University Press, 2012)Google Scholar, for more on carceral Jim Crow in 1930s Texas.

66. Gottschalk, Marie, The Prison and the Gallows: The Politics of Mass Incarceration in America (Cambridge: Cambridge University Press, 2006), 172Google Scholar; King, Desmond S., Separate and Unequal: Black Americans and the U.S. Federal Government (Oxford, UK: Clarendon Press, 1995), 170Google Scholar.

67. Albert Woodfox (with Leslie George), Solitary: Unbroken by Four Decades in Solitary Confinement. My Story of Transformation and Hope (New York: Grove Press, 2019), 34.

68. Steven Quatrevingt, “Daily Bread,” The Angolite, Sept./Oct. 2002, 21–22, Prison Newspapers and Periodicals Collection, Lloyd Sealy Library, John Jay College of Criminal Justice, New York, NY.

69. Covert, “Louisiana Prisoners Demand an End to ‘Modern-Day Slavery.’” For images of incarcerated people working in Angola's fields, see “Angola for Life.”

70. Ibid.

71. “State and Federal Wage Policies and Sourcing Information,” Prison Policy Initiative, Apr. 10, 2017, https://www.prisonpolicy.org/reports/wage_policies.html; Benns, “American Slavery, Reinvented”; “Angola for Life.”

72. Jeffrey Hilburn, “Raising Cane (Syrup), The Old-Fashioned Way,” The Angolite, Jan./Feb. 2014, 8, Prison Newspapers and Periodicals Collection, Lloyd Sealy Library, John Jay College of Criminal Justice, New York, NY.

73. Woodfox, Solitary, 34.

74. Ibid., 35.

75. Ibid.

76. Kerry Myers, “Sugar Cane Makes a Comeback,” The Angolite, Nov./Dec. 2012, 8, Prison Newspapers and Periodicals Collection, Lloyd Sealy Library, John Jay College of Criminal Justice, New York; Vanessa Tolino, “Louisiana State Penitentiary at Angola,” 64 Parishes, Jul. 30, 2013 (updated Feb. 8, 2019), https://64parishes.org/entry/louisiana-state-penitentiary-at-angola.

77. Myers, “Sugar Cane Makes a Comeback”; Tolino, “Louisiana State Penitentiary at Angola.”

78. Myers, “Sugar Cane Makes a Comeback.”

79. “Angola,” Louisiana: The State We're in, Louisiana Public Broadcasting, Nov. 1976, https://americanarchive.org/catalog/cpb-aacip_17-58pc94tq.

80. Ibid.

81. Woodfox, Solitary, 34.

82. N.C. Gen. Stat. § 148-26, Article 3, (Page) 37.

83. “Classification of a Sample of Offenses,” North Carolina Sentencing and Policy Advisory Commission, Effective Dec. 1, 2017, 2 https://www.nccourts.gov/assets/documents/publications/Sample-list-2017.pdf.

84. See Chase, Robert T., We Are Not Slaves: State Violence, Coerced Labor, and Prisoners’ Rights in Postwar America (Chapel Hill, NC: University of North Carolina Press, 2020)CrossRefGoogle Scholar.

85. “Jailhouse Lawyers Speak,” SwariMedia, Undated (accessed Aug. 30, 2022), https://sawarimi.org/jls-prisoners-initiative; Nicole Lewis, “What's Really Happening with the National Prison Strike?” The Marshall Project, Aug. 24, 2018, https://www.themarshallproject.org/2018/08/24/what-s-really-happening-with-the-national-prison-strike.

86. Tim Smith, Eric Connor, Nikie Mayo, Daniel J. Gross, Kirk Brown, and Paul Hyde, “Death, Violence in SC Prisons: How Lee Correctional Institution Puts Gangs before Safety,” Greenville News, Apr. 21, 2018, https://www.greenvilleonline.com/story/news/local/south-carolina/2018/04/21/why-deaths-and-violence-continue-lee-correctional/532430002/.

87. Meg Kinnard, “7 Inmates Killed as Prisoners Fight over Money, Territory,” Associated Press, Apr. 16, 2018, https://finance.yahoo.com/news/state-police-respond-ongoing-situation-sc-prison-085315357.html.

88. Covert, “Louisiana Prisoners Demand an End to ‘Modern-Day Slavery.’”

89. Ibid. For the eighty percent figure, see Jeffrey Goldberg, “The End of the Line: Rehabilitation and Reform in Angola Penitentiary,” The Atlantic, Sept. 10, 2015, https://www.theatlantic.com/politics/archive/2015/09/a-look-inside-angola-prison/404377/.

90. Lewis, “What's Really Happening with the National Prison Strike?”; German Lopez, “America's Prisoners Are Going on Strike in at Least 17 States,” Vox, Aug. 22, 2018, https://www.vox.com/2018/8/17/17664048/national-prison-strike-2018; “Prison Strike 2018,” Incarcerated Workers Organizing Committee, 2018, https://incarceratedworkers.org/campaigns/prison-strike-2018. Prison officials did not confirm all the strikes.

91. “Prison Strike 2018.” Incarcerated striking workers also sought repeal of the Prison Litigation Reform Act (a 1996 law restricting incarcerated people's ability to file lawsuits in federal courts); sentencing reform to end racial disparities; more funding for, and universal access to, rehabilitation programs; reinstatement of Pell Grants for incarcerated students, and voting rights for all currently and formerly incarcerated people. (Pell Grants for incarcerated students were reinstated in 2020.)

92. Burton, Orisanmi, Tip of the Spear: Black Radicalism, Prison Repression, and the Long Attica Revolt (Berkeley: University of California Press, 2023), 3Google Scholar.

93. Mariel Alper, Matthew R. Durose, and Joshua Markman, “2018 Update on Prisoner Recidivism: A 9-Year Follow-up Period (2005-2014),” Bureau of Justice Statistics, May 2018, https://bjs.ojp.gov/content/pub/pdf/18upr9yfup0514.pdf. The eighty-three percent recidivism rate is within nine years after release from thirty state prisons surveyed.

94. “About NPR,” National Public Radio, 2023, https://www.npr.org/about.