Federal courts are ordering states to spend millions on prison cooling systems as aging facilities struggle with extreme temperatures that pose serious health risks to inmates. A Texas federal judge ruled that extreme heat in state prisons is “plainly unconstitutional” and ordered the state to install air conditioning in all its prisons by the end of 2029, about three years away. The decision reflects a broader crisis: many U.S. correctional facilities, built during a prison-construction boom that began in the 1970s, rely on heat-trapping concrete and steel, with outdated or nonexistent cooling systems.
Steve Brooks, incarcerated at San Quentin Rehabilitation Center in California, experiences the problem daily. His cell has no windows or air conditioning. He relies on two eight-inch fans and has no access to ice or cold water. During an eight-hour power outage in 2024, his cell temperature reached between 90 and 100 degrees Fahrenheit. “It’s kind of like you’re hyperventilating. The room’s closing in,” Brooks said, describing how the heat felt like running out of oxygen.
The Scale of Infrastructure Failure
Research from MIT found that most U.S. prisons experienced at least 10 summer days hotter than any previous summer. The problem isn’t merely uncomfortable—it’s deadly. A study published in the National Library of Medicine linked hotter days to increased deaths from heart disease and suicide among incarcerated people, particularly those newly incarcerated or age 65 or older. Julie Skarha, who led the research on prison deaths linked to hotter temperatures, explained why people face particular risks: “Some people are sentenced to serve in places they’ve never lived before. ... So suddenly someone is having to adapt to this environment very quickly, something they’re not used to.”
Damon Gilbert, a fellow with New York Lawyers for the Public Interest, says heat-related prison deaths are underreported. “It’s incredibly dangerous and it’s only getting more dangerous. And so far we are not keeping up as a country to adapting these facilities,” he said.
At Minnesota Correctional Facility in Lino Lakes, built in 1992, about 336 prisoners live in two medium-security units that the state acknowledges lack effective cooling. Greg Andreotti, who spent two summers in those units, described cells with large untinted windows that “bake all day in the sun.” Personal fans cost $27.53, but many inmates can’t afford them, and they’re often out of stock. Ice access is limited to specific hours. When 200 people compete for ice during a three-hour window, Andreotti noted, “There’s no ice.” Josh Mcmillen, formerly incarcerated in a unit without effective cooling, recalled: “It’s oppressive. It’s like sitting in a tomb slash sauna. When you shut that door and it’s absolutely stifling, you can’t breathe.”
The Minnesota Department of Corrections acknowledged that the system is “undersized for the space.” The department has added window tinting, placed large industrial fans in common areas, and provided continuous ice access. Still, it’s seeking state funding for improvements.
Mounting Legal and Financial Costs
Heat-related prison lawsuits have been filed in Missouri, Florida and Texas. In Georgia, Carlos Ramirez Bibiano was found vomiting and lying in his own excrement in an outdoor cell during summer 2023, when temperatures reached 96 degrees. He was taking medications that impaired temperature regulation. The lawsuit, recently settled with his family for $3.25 million, alleged that staff left him five hours without water, shade or ice before he died that evening of heart and lung failure caused by heat exposure.
California’s Department of Corrections and Rehabilitation says changes could cost billions but might save millions in health care costs related to heat illness. North Carolina, Vermont and Texas are already spending millions to upgrade or install cooling systems. State budgets, already stretched thin, bear the financial burden.
Carlee Purdum, assistant professor at the University of Houston, outlined what’s required: “It’s going to take funding. It’s going to take attention and investment and collaborations between those agencies and the experts who are wanting to engage in this issue.” The challenge is clear: states must either invest heavily now or face escalating litigation costs and liability settlements later.
California’s Department of Corrections and Rehabilitation said it follows a heat illness prevention plan and monitors temperatures, providing water stations, ice, showers and fans during extreme heat. The agency notes that staff receive cold water, breaks and access to climate-controlled areas—privileges inmates don’t share. Staff can go home after shifts; inmates cannot. Some states’ extreme-temperature workplace rules don’t extend protections to incarcerated people.
Why This Matters:
This crisis shows the fiscal consequences of deferred infrastructure maintenance. States built facilities decades ago using cheap materials without accounting for climate variables or future costs. Now they face three expensive options: massive capital expenditures to retrofit aging buildings, mounting legal judgments and settlement payouts, or continued operational failures. Beyond the immediate budget impact, the situation raises questions about the proper role of government in managing state facilities. Advocates argue for significant investment, but the scale of required spending—potentially in the billions—raises tough questions about how states should prioritize limited resources. The Texas court order mandates air conditioning by 2029, shifting responsibility to taxpayers to fund infrastructure corrections. Whether this represents necessary constitutional compliance or judicial overreach into budgetary matters remains contested among policymakers.