Florida Inmates Earn Class Status in Suit Over ‘Unbearable’ Heat

A group of Florida inmates can bring a class action claiming a lack of air conditioning violates their constitutional rights, a federal court has ruled.

Inmates at Dade Correctional Institution near Miami can collectively bring their Eighth Amendment claims arguing their heat exposure is cruel and unusual punishment, US District Court for the Southern District of Florida Judge Kathleen M. Williams said Sept. 26.

Despite the Florida Department of Corrections’ decision to not record the temperatures in its facilities, that doesn’t block inmates from relying on high temperature readings from nearby government facilities like Miami International Airport, she said.

“By failing to maintain the ventilation systems and enforcing climate control policies that create unbearable heat conditions, Defendants have forced the class members to live in an environment that significantly increases their risk of developing health issues,” Williams said in her order. “Defendants’ policies of restricting access to air-conditioned rooms and other mitigation measures apply generally to each class member” in a potential class of more than 1,500 inmates.

Williams’ ruling follows in the pathway tread by other approved classes in the Fifth and Eleventh circuits in which incarcerated plaintiffs pointed to statistics on harms of extreme and prolonged heat exposure, in particular to sub-groups with medical conditions.

The Florida plaintiffs claim access to their facility’s limited air-conditioned rooms are restricted. To alleviate the heat, they allegedly build tunnels from windows out of cardboard, plastic, or whatever materials they can scrounge, and those often confiscated and considered contraband.

In addition to an overall class, Williams approved a “heat” subclass of those with a condition that could increase their chances of heat-related injury—such as diabetes, asthma, or thyroid dysfunction—as well as those that receive certain medications and those over age 65.

The Florida Justice Institute and Udelsman Law PLLC represent the inmates. Lawson Huck Gonzalez PLLC and The Ferraro Law Firm, PA represent the state.

The case is Wilson v. Dixon, S.D. Fla., No. 1:24-cv-24253, class certified 9/26/25.