Stanley v. Ivey

At a Glance

Date Filed: 

May 1, 2024

Current Status 

On May 1, 2024, the Center for Constitutional Rights filed a complaint on behalf of six incarcerated workers against the State of Alabama and its Department of Corrections to challenge the use of forced labor and involuntary servitude in ADOC facilities.


Case Description 

In Alabama’s complex history, the remnants of slavery in the state’s prison system cast a long shadow. Following the legal abolition of slavery in Alabama, through the ratification of the Thirteenth Amendment to the U.S. Constitution and an analogous provision in Article I, Section 32, of the Alabama Constitution, racial oppression evolved as the State established “Black Codes” and other forms of criminalization and punishment to maintain permanent control over freed Black people. The Thirteenth Amendment and Alabama’s Constitution contained an exception permitting slavery or involuntary servitude for those “duly convicted” of a crime. In the first half of the twentieth century, through the use of convict leasing and chain gangs, Alabama’s prisons became not only the most profitable in the nation, but the most fatal as the state revived some of the most violent practices inherent to – and perfected under – the institution of slavery. 

Marked by this legacy, Alabama’s prison system continues to incarcerate Black people at disproportionate rates while subjecting them to inhumane conditions within the prison system. Following a prison labor strike where thousands of incarcerated people raised demands in response to the grave human rights violations they were experiencing, Alabama voters approved a new state constitution that prohibits slavery and involuntary servitude in all circumstances, including in prisons. This and several other changes were proposed by a joint legislative committee with the express purpose of “removing racist language” from the overtly white supremacist 1901 constitution.

Shortly after the strike and the changes to the Alabama Constitution banning prison slavery, the State responded with three legal measures to punish incarcerated people who resist forced labor: Alabama Executive Order No.725, ADOC Administrative Regulation 403, and revisions to Section 14-9-41(c)(4) of the Alabama Code. Each measure allows prison officials to punish incarcerated workers by revoking earned good time, placing them in solitary confinement, and eliminating opportunities to communicate with loved ones, among other sanctions. To shed light on the ongoing fight for justice within Alabama’s correctional system, six incarcerated workers, Trayveka Stanley, Reginald Burrell, Dexter Avery, Charlie Gray, Melvin Pringle, and Ranquel Smith, are challenging these three state actions and seeking to abolish the practice of forced labor and involuntary servitude in all ADOC prisons.

These plaintiffs, represented by the Center for Constitutional Rights through our Southern Regional Office, seek to support an ongoing national movement to remove the prison slavery exception in all state constitutions and in the Thirteenth Amendment to the U.S. Constitution. Like the plaintiffs in this lawsuit, incarcerated individuals throughout ADOC prisons are forced into involuntary servitude. Their work is essential to the maintenance of the facilities, and they are forced to carry out many jobs within the prison for little to no pay as well as to labor for other state entities and private employers, also for little pay and often under unsafe working conditions. This lawsuit shares each of the plaintiffs' experiences as incarcerated workers subject to ADOC’s systemic policy and practice of forced labor and involuntary servitude.

Case Timeline

May 1, 2024
Plaintiffs file complaint to challenge the use of forced labor and involuntary solitude in ADOC prisons
May 1, 2024
Plaintiffs file complaint to challenge the use of forced labor and involuntary solitude in ADOC prisons