The U.S. Court of Appeals for the Tenth Circuit ruled against an inmate who challenged Wyoming prison labor practices under the Thirteenth Amendment, emphasizing that the constitutional prohibition against slavery and involuntary servitude explicitly exempts prison labor.
Inmate Jett Garriott Adams filed suit against multiple Wyoming Department of Corrections officials, including Warden Seth Norris and Director Daniel Shannon, alleging that prison labor requirements violated his constitutional rights. The case, *Adams v. Wyoming Department of Corrections* (No. 25-8018), was decided Jan. 13, 2026, by a three-judge panel including Circuit Judges Hartz, Eid, and Carson.
The court's order emphasized the established legal principle that prison labor falls outside Thirteenth Amendment protections. "The Thirteenth Amendment's prohibition against slavery and involuntary servitude expressly does not apply to prison labor," the court wrote in its order and judgment.
Adams challenged policies at the Wyoming Department of Corrections Medium Correctional Institution where he is incarcerated. According to the court filing, Adams alleged that the prison violated his Thirteenth Amendment rights through its labor practices, though specific details of the challenged policies were not fully disclosed in the available court documents.
The Thirteenth Amendment, ratified in 1865, abolished slavery and involuntary servitude throughout the United States. However, the amendment contains a crucial exception that reads: "except as a punishment for crime whereof the party shall have been duly convicted." This exception has long been interpreted by courts to permit prison labor programs.
The Tenth Circuit panel determined the case could be resolved without oral argument, finding that such proceedings "would not materially assist in the determination of this appeal." This procedural decision reflects the court's view that the legal principles involved were sufficiently clear to decide the matter based on written briefs and the appellate record alone.
The case originated in the U.S. District Court for the District of Wyoming under case number 1:25-CV-00025-ABJ before reaching the appeals court. Adams represented himself as plaintiff-appellant in the federal litigation against the state corrections officials, who were sued in their official capacities.
Prison labor programs operate in correctional facilities across the United States under the constitutional authority provided by the Thirteenth Amendment's exception. These programs typically involve inmates performing various types of work, from facility maintenance to manufacturing operations, often for minimal compensation.
The legal framework surrounding prison labor has faced renewed scrutiny in recent years as advocates question whether current practices align with rehabilitation goals and fair treatment standards. Some states have initiated reforms to prison labor policies, including efforts to provide market-rate wages or eliminate mandatory work requirements.
However, courts have consistently upheld the constitutional basis for prison labor programs. Federal circuit courts have repeatedly affirmed that the Thirteenth Amendment's explicit exception removes prison labor from constitutional prohibitions against involuntary servitude, making successful challenges difficult under current legal precedent.
The Tenth Circuit's ruling aligns with decisions from other federal appeals courts that have addressed similar constitutional challenges to prison labor practices. Courts have generally held that inmates cannot successfully claim Thirteenth Amendment violations based on work requirements or compensation levels in correctional facilities.
Adams' case represents one of numerous legal challenges inmates have filed against prison labor policies across various jurisdictions. While some litigation has succeeded on other legal grounds, such as workplace safety violations or contract disputes, constitutional challenges based on the Thirteenth Amendment face significant hurdles given the amendment's explicit exception.
The court's order and judgment specifically notes that the decision "is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel." However, the ruling may still be cited "for its persuasive value" in future cases addressing similar issues.
Wyoming Department of Corrections officials named as defendants in the case include current and former personnel in leadership positions overseeing the state's correctional system. The defendants were represented in their official capacities rather than as individuals, meaning the state bears responsibility for legal defense and any potential liability.
The ruling reinforces the established legal framework that permits prison labor programs while highlighting ongoing tensions between traditional corrections practices and evolving perspectives on inmate rights and rehabilitation. As prison reform discussions continue across the country, the constitutional foundation for prison labor remains firmly established through the Thirteenth Amendment's explicit exception for punishment of crimes.
This case adds to the body of federal appellate decisions upholding prison labor programs under current constitutional standards, providing guidance for similar challenges that may arise in the Tenth Circuit's jurisdiction, which includes Wyoming, Colorado, Kansas, New Mexico, Oklahoma, and Utah.