Automatic Mootness and Munsingwear Vacatur for Expired PLRA Preliminary Injunctions: Commentary on Voice of the Experienced v. LeBlanc (5th Cir. 2025)

I. Introduction

Voice of the Experienced v. LeBlanc, No. 25-30478 (5th Cir. Nov. 21, 2025), is the third in a trilogy of per curiam, unpublished Fifth Circuit opinions arising from challenges to working conditions on the “Farm Line” at the Louisiana State Penitentiary at Angola. The plaintiffs—Voice of the Experienced (a membership organization) and several incarcerated individuals—allege that Angola’s use of hard agricultural labor in extreme heat violates the Eighth Amendment’s prohibition on cruel and unusual punishment.

Yet, once again, the Fifth Circuit does not reach the Eighth Amendment merits. Instead, the opinion crystallizes a procedural rule at the intersection of Article III mootness, the Prison Litigation Reform Act (“PLRA”), and the doctrine of Munsingwear vacatur:

Preliminary injunctive relief in prison-conditions litigation governed by 18 U.S.C. § 3626(a)(2) automatically expires 90 days after entry unless converted to final relief under § 3626(a)(1);
Once such relief expires, any pending appeal from that preliminary order is moot because the court can no longer grant “effectual relief” regarding that order; and
When mootness arises by operation of law while the appellant is actively pursuing an appeal, the underlying preliminary order should be vacated under the Munsingwear doctrine to prevent unreviewed decisions from having lingering legal consequences.

This commentary analyzes the opinion’s background, its reinforcement of this trilogy’s procedural rule, the precedents on which it relies, and the implications for PLRA litigation and appellate practice.

II. Factual and Procedural Background

A. The Angola Farm Line and Heat-Related Risks

The “Farm Line” is a work program at Angola through which incarcerated men are compelled to perform hard, outdoor agricultural labor, often picking vegetables by hand under intense Louisiana summer heat. Any of Angola’s approximately 4,000 incarcerated men may be assigned to the Farm Line as a disciplinary measure, unless medically exempt.

The plaintiffs (collectively “VOTE”) contend that Farm Line conditions in high heat are “life threatening” and that Angola’s policies are constitutionally inadequate to protect them from serious risk of heat-related illness and death.

B. The Evolution of Angola’s Heat Policies

1. The 2018 Policy and 2019 Angola Directive

In 2018, the Department of Public Safety and Corrections (“DPSC”) adopted a statewide policy designed to “reduce the exposure to inmates identified as more vulnerable to heat” (the “2018 Policy”). Key provisions included:

Monitoring temperature every two hours; and
Issuing a “Heat Alert” whenever the outdoor heat index (apparent temperature) exceeded 88°F.

When a Heat Alert was called at or above 88°F, DPSC was required to:

Provide water and ice at least every 30 minutes; and
Provide a rest break of at least 5 minutes every 30 minutes.

In 2019, Angola implemented Directive 13.067 (the “2019 Directive”), specific to that facility, which mirrored the 88°F Heat Alert threshold and monitoring every two hours for Farm Line workers.

2. The 2024 Policy and the 2025 Directive

After litigation began, DPSC revised its policies in October 2024 (the “2024 Policy”). The most legally significant change was increasing the Heat Alert threshold from 88°F to 91°F. The 2024 Policy also:

Promised water and ice, shaded areas, and sunscreen for outdoor laborers at all times, regardless of whether a Heat Alert was in effect;
Maintained temperature monitoring every two hours; and
Was supplemented by a 2025 Angola-specific Directive requiring hourly monitoring and written documentation of Heat Alerts and rest breaks.

VOTE’s subsequent preliminary motions focused on the increased threshold (91°F instead of 88°F) and the frequency of temperature monitoring.

C. The Underlying Class Action and Three Rounds of Preliminary Relief

In September 2023, VOTE filed a putative class action challenging Angola’s operation of the Farm Line as cruel and unusual punishment under the Eighth Amendment. A five-day bench trial on the merits is set for February 3, 2026.

Before trial, plaintiffs sought interim protection during the summer heat seasons. This produced three rounds of preliminary relief and three corresponding appeals:

1. The July 2024 Order (“2024 Order”) and VOTE I

In May 2024, VOTE moved for a temporary restraining order (“TRO”) and preliminary injunction, requesting that all Farm Line labor be enjoined when the heat index exceeded 88°F. In July 2024, the district court:

Declined to halt all work above 88°F; but
Issued a TRO (the “2024 Order”) imposing five protective measures, including improvements in shade, rest, equipment (e.g., sunscreen), medical exemption procedures, and an additional policy for extreme heat (≥113°F).

A Fifth Circuit motions panel stayed three of the five provisions as overbroad (extending beyond Angola), but allowed two Angola-specific Farm Line protections to stand.

Both parties agreed that, under the PLRA, the 2024 Order expired 90 days after entry (September 30, 2024). Nonetheless, another Fifth Circuit panel later heard argument and, on August 5, 2025, dismissed the appeal as moot and vacated the order under United States v. Munsingwear, Inc. (“VOTE I”).

2. The May 2025 TRO (“May 2025 Order”) and VOTE II

In March 2025, with summer approaching, VOTE again sought preliminary relief. This time it requested:

A requirement that Angola issue a Heat Alert for the Farm Line when the heat index reaches at least 88°F (rather than 91°F); and
Monitoring of the heat index every 30 minutes (rather than hourly or every two hours).

VOTE supported its motion with expert evidence from Dr. Susi Vassallo, whose opinions the district court had previously credited, and with deposition testimony from DPSC’s Chief Medical Officer, Dr. Randy Lavespere. Plaintiffs argued that:

They were likely to succeed on their Eighth Amendment claim; and
Defendants were deliberately indifferent in raising the threshold to 91°F despite contrary medical evidence and court findings about heightened risk at 88°F.

On May 23, 2025, the district court issued a TRO (the “May 2025 Order”), finding a substantial risk of serious harm and likely deliberate indifference. It:

Ordered Angola to use an 88°F threshold for Heat Alerts; and
Required more frequent (30-minute) heat index monitoring.

The court later clarified that, under the PLRA, this relief would automatically expire on August 21, 2025, unless converted to permanent relief or extended in compliance with § 3626. Louisiana appealed and obtained expedited review. At oral argument, the parties agreed that the May 2025 Order would expire on August 21, 2025.

On August 28, 2025, the Fifth Circuit panel in VOTE II dismissed the appeal as moot and vacated the May 2025 Order under Munsingwear; a petition for rehearing en banc remains pending.

3. The August 2025 Order and the Present Appeal

Even before the May 2025 Order’s expiration, VOTE filed (July 28, 2025) a motion for a “renewed, successive preliminary injunction granting the same relief.” On August 22, 2025, the district court granted this motion in part, issuing the “August 2025 Order.”

Key features of the August 2025 Order:

The court expressly relied on its prior factual and legal findings in the May 2025 Order, noting no “intervening changes in fact or law.”
It held that neither the PLRA nor any Fifth Circuit ruling barred a “successive preliminary injunction.”
It again found the 91°F threshold posed a substantial risk of serious harm and that an 88°F threshold was medically necessary.
It therefore enjoined use of the 91°F Heat Alert threshold for the Farm Line and imposed an 88°F threshold “for the same compelling reasons described” earlier.
It declined to repeat the order for 30-minute monitoring, noting that Angola’s 2025 Directive required hourly monitoring and that the marginal difference between hourly and half-hourly monitoring did not warrant further preliminary relief.

Louisiana again appealed, moved for consolidation with the VOTE II appeal (denied after VOTE II was held moot), and sought a stay. A motions panel stayed the August 2025 Order and expedited the appeal. Oral argument was held on November 5, 2025—15 days before the order would automatically expire on November 20, 2025, under the PLRA.

On November 21, 2025, the Fifth Circuit issued the opinion at hand, dismissing Louisiana’s appeal as moot and vacating the August 2025 Order.

III. Summary of the Opinion

The Fifth Circuit’s per curiam opinion proceeds in three main steps:

Appellate Jurisdiction: The court first confirms that, regardless of the label, the August 2025 Order had the “practical effect” of a preliminary injunction and is therefore appealable under 28 U.S.C. § 1292(a)(1). The court relies on its prior analysis in VOTE I and VOTE II.
Mootness under Article III and the PLRA: The court holds that the appeal is moot because, by November 20, 2025, the August 2025 Order had automatically expired by operation of 18 U.S.C. § 3626(a)(2), and there is no “effectual relief” that the court can now grant concerning that expired order.
Munsingwear Vacatur: Following VOTE I and VOTE II, the court applies the Munsingwear doctrine to vacate the district court’s August 2025 Order. Mootness was caused not by the parties’ voluntary actions, but by statutory operation of the PLRA while the state was “actively pursuing [its] right to appeal.” Vacatur ensures that the unreviewed district court order has no lingering legal effect.

The opinion closes by dismissing the appeal as moot, vacating the August 2025 Order, and noting that the prior motions-panel stay is now without substantive effect and is lifted.

IV. Analysis

A. Precedents Cited and Their Influence on the Court’s Decision

1. Article III Case-or-Controversy Requirements

The court grounds its mootness analysis in familiar Supreme Court authority:

Already, LLC v. Nike, Inc., 568 U.S. 85 (2013): Cited for the proposition that a case must remain a live “case or controversy” at all stages of review. While Already dealt with voluntary cessation by a private party, the Fifth Circuit borrows its general articulation: the controversy must remain live “through all stages of the litigation.”
Alvarez v. Smith, 558 U.S. 87 (2009): Quoted via Already for the same principle. Alvarez involved the return of seized property; once that happened, claims for injunctive and declaratory relief became moot.
Church of Scientology of California v. United States, 506 U.S. 9 (1992): The Court there explained that a case becomes moot when events make it impossible to grant “any effectual relief whatever to a prevailing party.” That is the precise test the Fifth Circuit employs: when the preliminary injunction expires, there is no effectual relief to grant regarding that order.

Together, these precedents implement the rule that courts cannot issue advisory opinions about an order that no longer has any operative effect.

2. Fifth Circuit PLRA and Mootness Precedent

Several Fifth Circuit cases, including the earlier VOTE decisions, supply the more specific rule that expired PLRA preliminary injunctions are moot:

Yates v. Collier, 677 F. App’x 915 (5th Cir. 2017) (per curiam): In Yates, the Fifth Circuit held that an appeal from a preliminary injunction entered under the PLRA became moot when the injunction expired by its own terms. That decision is quoted for the proposition that “when an injunction expires by its own terms, it is moot and there is nothing to review.”
Smith v. Edwards, 88 F.4th 1119 (5th Cir. 2023): The court recently reiterated that once a PLRA preliminary injunction expires, “there is no remedy we can provide [appellants] at this point.” Smith mirrors the circumstances here: preliminary relief in a prison-conditions case automatically expired, mooting the appeal.
Voice of the Experienced v. Westcott (“VOTE I”), No. 24-30420, 2025 WL 2222990 (5th Cir. Aug. 5, 2025): The first appeal from the district court’s 2024 Order. That panel dismissed the appeal as moot once the PLRA’s 90-day limit passed and vacated the order under Munsingwear.
Voice of the Experienced v. LeBlanc (“VOTE II”), No. 25-30322, 2025 WL 2481382 (5th Cir. Aug. 28, 2025): The second appeal, from the May 2025 Order. Again, the panel held the appeal moot after the 90-day statutory expiration and vacated the underlying TRO, relying on Yates, Smith, and Munsingwear.

The current panel explicitly aligns its reasoning with VOTE I and VOTE II, noting the “strikingly similar” circumstances. Collectively, these decisions form a coherent Fifth Circuit practice: PLRA preliminary injunctions are inherently time-limited, and when that limit runs, any pending appeal about that order is moot.

3. The Munsingwear Doctrine and Its Refinements

Vacatur is governed by:

United States v. Munsingwear, Inc., 340 U.S. 36 (1950): When a case becomes moot while on appeal, and the party seeking review has been prevented “through happenstance” from obtaining appellate review, the appellate court’s “established practice” is to vacate the judgment below and remand with directions to dismiss. The goal is to prevent an unreviewed decision from having residual legal effects.
U.S. Bancorp Mortgage Co. v. Bonner Mall Partnership, 513 U.S. 18 (1994): The Court clarified that vacatur is not automatic; for example, if mootness results from a voluntary settlement, the appellant generally is not entitled to vacatur because it has voluntarily forfeited review. The key question is whether mootness arose from actions attributable to the appellant or from external “happenstance.”
Karcher v. May, 484 U.S. 72 (1987): Often cited for the distinction between mootness caused by a party’s own decisions (e.g., change in officeholders and litigation position) versus external events, affecting whether vacatur is appropriate.
Camreta v. Greene, 563 U.S. 692 (2011): Reinforces that vacatur aims to prevent an unreviewable decision from “spawning any legal consequences,” especially when the would-be appellant is frustrated by external mootness.

The Fifth Circuit reads these authorities to mean that when:

The case becomes moot by statute (here, the PLRA’s automatic 90-day expiry); and
The appellant was actively pursuing appellate review when mootness arose;

vacatur is warranted to avoid unfair preclusive or precedential impact from a decision that could not be reviewed.

B. The Court’s Legal Reasoning

1. Jurisdiction: The “Practical Effect” of a Preliminary Injunction

The court quickly dispatches a threshold issue: whether it has jurisdiction to review the August 2025 Order at all. Citing its prior VOTE decisions, it observes that:

Even if an order is styled as a “TRO” or as a “renewed” injunction, what matters is whether it has the practical effect of a preliminary injunction.
The August 2025 Order imposed ongoing, mandatory obligations (the 88°F threshold) enforceable against Angola until expiration.
Under 28 U.S.C. § 1292(a)(1), orders “granting, continuing, modifying, refusing or dissolving injunctions” are appealable.

Accordingly, the panel holds that it had interlocutory jurisdiction when the appeal was filed. Mootness arises only later, once the injunction expires by operation of law.

2. Mootness: No “Effectual Relief” After Statutory Expiration

The core of the opinion is the mootness analysis. The chain of reasoning is:

Under 18 U.S.C. § 3626(a)(2), any preliminary injunctive relief in a prison-conditions case automatically expires 90 days after entry unless the district court:
- “makes the findings required under subsection (a)(1) for the entry of prospective relief,” and
- “makes the order final before the expiration of the 90-day period.”
The August 2025 Order was entered on August 22, 2025; thus, it expired on November 20, 2025, by “matter of law under the PLRA.”
When the injunction expired, it ceased to have any legal effect on the parties. The obligations it imposed were no longer in force.
Article III allows federal courts to adjudicate only live controversies. A matter is moot if “it is impossible for the court to grant any effectual relief whatever to a prevailing party.”
Once the injunction expired, nothing that the Fifth Circuit might now say about its validity could change the parties’ rights or obligations under that order.

Consequently, the appeal is moot:

“Because the preliminary injunction has expired, there is no remedy we can provide [Appellants] at this point.” (quoting Smith v. Edwards).

The court notes the unusual fact that this is the third such appeal in the same underlying dispute, and that the appeal was expedited and argued only 15 days before automatic expiration. But the panel emphasizes that the PLRA’s 90-day limit “does not provide for any exceptions.” The statutory clock continues to run regardless of how quickly the appellate process moves.

Importantly, the court also records that VOTE “does not intend to seek additional preliminary relief during the winter months,” and it “fully anticipates” that the merits trial set for February 2026 will go forward before heat conditions again become acute. While this does not change the mootness analysis, it underscores the court’s view that the proper vehicle for resolving the underlying Eighth Amendment dispute is a final judgment after trial, not repeated short-lived preliminary injunctions.

3. Why Mootness Exceptions Are Not Invoked

The opinion does not explicitly discuss exceptions such as the “capable of repetition yet evading review” doctrine, but the structure of its reasoning implicitly rejects them with respect to the preliminary orders themselves.

Two points are important:

The “controversy” persists, but the specific order does not. The underlying Eighth Amendment controversy remains live; plaintiffs still seek permanent relief. The mootness at issue concerns only the particular preliminary injunction, which has expired and been superseded by the continuing merits litigation.
Appellate review is available later on the merits. Unlike cases where the entire dispute is too short-lived to be fully litigated, here the issue will eventually be reviewable in the context of final judgment or a permanent injunction. Thus, the primary rationale for the “capable of repetition yet evading review” exception—avoiding total foreclosure of appellate review—does not apply in the same way.

In short, the Fifth Circuit distinguishes between:

The transitory form of relief (a PLRA-governed preliminary injunction, inherently capped at 90 days); and
The enduring substance of the constitutional claim, which will be adjudicated at trial and then subject to full appellate review.

4. Munsingwear Vacatur: No Party “Caused” Mootness

Having found the case moot, the Fifth Circuit turns to whether the district court’s August 2025 Order should nonetheless be vacated. Under Munsingwear and Bancorp, the key inquiry is whether mootness is attributable to the actions of the party seeking review or is instead the result of external happenstance.

Here:

Mootness occurred because the PLRA mandated that preliminary relief “shall automatically expire” after 90 days.
Louisiana did not consent to dismissal or settle; indeed, it “was actively pursuing [its] right to appeal” and had obtained an expedited hearing.
Neither side “caused” mootness in the sense disfavored in Bancorp (e.g., voluntary settlement rendering the case moot).

The panel concludes:

“The August 2025 Order expired on November 20, 2025, by operation of law—not by circumstances attributable to the parties. When this appeal became moot, Louisiana was ‘actively pursuing [its] right to appeal.’ Therefore, vacatur of the August 2025 Order is appropriate.”

Vacatur ensures that:

The district court’s unreviewed findings (for example, its accepting Dr. Vassallo’s medical evidence or its characterization of Angola’s actions as likely deliberate indifference) do not create law-of-the-case constraints or preclusive effects; and
Future courts, including the district court on remand and the Fifth Circuit on later appeals from final judgment, may examine the merits afresh.

5. Serial Preliminary Injunctions and the PLRA

While not squarely deciding the legality of “successive” PLRA preliminary injunctions, the opinion is informed by the practical consequences of serial 90-day orders:

The district court expressly held that successive injunctions were not barred by the PLRA or prior Fifth Circuit decisions, and based its August 2025 Order largely on unchanged factual and legal circumstances.
The Fifth Circuit does not endorse or condemn this practice but implicitly highlights its structural consequence: repeated cycles of preliminary relief followed by automatic expiration, with appeals perpetually mooted before merits review.
By again vacating the underlying order, the court underscores that each new round of preliminary relief starts from a clean slate (as far as binding appellate precedent is concerned), and that the appropriate long-term solution is adjudication on the merits.

In practice, the trilogy may encourage district courts in future PLRA cases to:

Consider consolidating preliminary injunction hearings with trial on the merits under Federal Rule of Civil Procedure 65(a)(2); or
Move more quickly to final injunctive relief with the findings required by § 3626(a)(1), if they conclude that ongoing prospective relief is warranted.

C. Impact on Future Cases and the Relevant Area of Law

1. Clarifying the Procedural Life Cycle of PLRA Preliminary Injunctions

The opinion, together with VOTE I and VOTE II, solidifies a procedural template for PLRA prison-conditions litigation in the Fifth Circuit:

Preliminary injunctive relief can be issued to address urgent harms (here, heat-related risks on the Farm Line);
That relief is strictly time-limited to 90 days unless converted to final relief with § 3626(a)(1) findings; and
Once expired, appeals from such preliminary relief are moot and the orders will be vacated under Munsingwear.

This template affects:

Prisoners and Advocacy Groups: They may still seek short-term protection but should anticipate:
- That appellate review of preliminary decisions is unlikely to be completed before the 90-day period ends, even on an expedited schedule;
- That any favorable preliminary orders may be vacated if not converted to final relief; and
- That durable change will likely require success at trial and subsequent final injunctive relief.
States and Prison Officials: They can contest preliminary injunctions knowing that:
- Appeals from adverse PLRA preliminary orders will ordinarily become moot upon expiration; and
- Vacatur will wipe away adverse interim rulings, preventing them from binding the parties or influencing other courts as precedent.

2. Strategic and Institutional Incentives

This trilogy of cases may reshape strategic behavior:

For district courts: Judges may be more inclined to:
- Use preliminary injunctions sparingly and with awareness that appellate review might never materialize before statutory expiration; and
- Accelerate merits proceedings (as occurred here, with a trial set for early 2026) where recurring seasonal harms are alleged.
For appellate courts: The Fifth Circuit signals that it will not carve out PLRA exceptions to the 90-day rule, even in recurring, highly consequential disputes. It will strictly apply statutory mootness and vacatur principles rather than attempt to issue advisory guidance before expiration.
For legislatures and policymakers: While not the opinion’s focus, these cases expose a structural tension: in urgent prison-conditions contexts, the PLRA’s 90-day cap can make sustained appellate supervision of preliminary relief practically impossible, especially when conditions (like summer heat) are inherently seasonal.

3. Broader Doctrinal Significance

The opinion contributes, at least at a persuasive level (given its unpublished status), to three doctrinal areas:

Mootness Doctrine: It applies the general “effectual relief” test in a concrete statutory setting, clarifying that automatic statutory expiration can itself be the mootness-triggering event.
PLRA Implementation: It highlights the rigidity of § 3626(a)(2)’s 90-day limit and underscores that the path to longer-term relief is through final, § 3626(a)(1)-compliant orders.
Vacatur Practice: It reinforces that, in the Fifth Circuit, automatic expiration of PLRA preliminary injunctions is classic “happenstance” for Munsingwear purposes, strongly favoring vacatur in such cases.

V. Complex Concepts Simplified

1. What Is the PLRA and Why Does the 90-Day Limit Matter?

The Prison Litigation Reform Act (“PLRA”), codified in part at 18 U.S.C. § 3626, is a federal statute that restricts the scope and duration of court-ordered relief in cases challenging prison conditions. It was enacted to curb what Congress saw as overbroad and judicially micromanaged remedies in prison litigation.

Section 3626(a)(2) governs preliminary injunctive relief:

Any preliminary injunction that “orders any prospective relief” in a prison-conditions case “shall automatically expire” 90 days after its entry;
Unless, before that 90-day mark, the court:
- Makes the specific findings required for final “prospective relief” under § 3626(a)(1) (that the relief is narrowly drawn, extends no further than necessary, and is the least intrusive means to correct the violation); and
- Converts the preliminary order into a final order.

Thus, preliminary injunctions under the PLRA are inherently short-lived unless folded into a final judgment with the required findings.

2. Preliminary Injunction vs. TRO vs. “Practical Effect”

Federal courts distinguish:

Temporary Restraining Order (TRO): Often very fast, sometimes ex parte, short in duration, and meant to preserve the status quo until a more complete hearing can be held.
Preliminary Injunction: Issued after notice and (usually) a hearing, it provides interim relief pending final judgment.

However, for purposes of appellate jurisdiction under 28 U.S.C. § 1292(a)(1), courts look to the order’s practical effect. If an order:

Imposes ongoing, enforceable obligations on a party; and
Functions in substance like a preliminary injunction;

it is treated as appealable, even if labeled a “TRO.”

3. Mootness and “Effectual Relief”

Under Article III of the Constitution, federal courts can only decide live disputes. A case is moot when:

The court cannot grant any “effectual relief whatever” to the prevailing party; or
The court’s decision would be purely advisory, without operative legal consequences.

In the context of expired injunctions:

If an injunction expires by its own terms (or by statute), and the only thing on appeal is that injunction, the appeal is usually moot.
There are exceptions, but they typically require that the underlying controversy itself would evade any future review.

4. The Munsingwear Doctrine in Plain Terms

Munsingwear vacatur is a cleanup tool used by appellate courts:

If a case becomes moot while on appeal, and the appellant has not caused that mootness, the appellate court often vacates (erases) the lower court’s judgment.
This prevents an unreviewed lower-court ruling from having binding or preclusive effects on the parties in future litigation.

Think of it as resetting the legal landscape to what it was before the now-unreviewable decision was issued.

5. “Deliberate Indifference” Under the Eighth Amendment (Context Only)

Although the Fifth Circuit in this opinion does not reach the merits, the underlying case turns on Eighth Amendment standards. In prison-conditions cases, plaintiffs must generally show:

Objective Component: Conditions that pose a “substantial risk of serious harm” to inmates (e.g., life-threatening heat exposure); and
Subjective Component (“Deliberate Indifference”): Officials knew of and disregarded an excessive risk to inmate health or safety. This is more than negligence; it is akin to recklessness.

VOTE argues that:

The medical evidence shows a sharply increased risk of heat-related illness and death at 88°F; and
By raising the Heat Alert threshold to 91°F despite that evidence and prior court findings, Angola officials have been deliberately indifferent.

These issues will be central at the February 2026 trial.

6. Heat Index and “Apparent Temperature”

The opinion references the “heat index” or “apparent temperature,” which is:

A measure that combines air temperature and relative humidity;
Used to express how hot it “feels” to the human body, which is more relevant for heat stress risk than temperature alone.

The dispute here centers on whether heat index readings of ≥88°F require special protective measures (VOTE’s position, supported by their expert) versus a higher threshold of 91°F (DPSC’s position in its 2024 Policy).

VI. Conclusion: Significance in the Broader Legal Context

Voice of the Experienced v. LeBlanc (No. 25-30478) does not answer whether Angola’s Farm Line heat conditions violate the Eighth Amendment. Instead, it solidifies a procedural rule with practical importance in PLRA litigation:

The PLRA’s 90-day cap on preliminary injunctive relief is absolute unless the relief is converted to final, § 3626(a)(1)-compliant prospective relief.
Appeals from such preliminary orders are subject to automatic mootness once the 90 days lapse because the courts can no longer grant effectual relief concerning those orders.
When mootness arises by statutory operation while an appeal is actively pursued, the proper remedy is Munsingwear vacatur of the underlying order to prevent unreviewable, interim decisions from having legal consequences.

Functionally, the decision channels disputes over systemic prison conditions away from repeated cycles of short-lived preliminary injunctions and toward final adjudication on the merits. That orientation is underscored by the panel’s express expectation that the February 2026 bench trial will proceed as scheduled, providing a vehicle for definitive resolution and full appellate review of Angola’s practices.

At the same time, the trilogy exposes a structural tension in the PLRA regime: in contexts involving strongly seasonal or time-sensitive harms (such as extreme summer heat), the 90-day limit, coupled with the pace of appellate review, can render interim appellate oversight practically unattainable. The Fifth Circuit’s answer is not to relax the statutory limit or to carve out doctrinal exceptions, but to apply the PLRA and mootness doctrine strictly, relying on vacatur to cleanse the record of unreviewed preliminary rulings.

In that sense, Voice of the Experienced v. LeBlanc is a clear statement—albeit in nonprecedential form—of how the Fifth Circuit will manage the life cycle of preliminary injunctions in prison-conditions cases: automatic expiration under § 3626(a)(2), automatic mootness of appeals from expired orders, and routine Munsingwear vacatur to ensure that only decisions subject to full appellate review shape the law going forward.