The Louisiana Third Circuit Court of Appeal has ruled that an inmate injured while on work release was not entitled to recovery from the state. In Madison v. State of Louisiana, although the injured inmate was seeking civil recovery, the decision hinged upon whether or not the Department of Corrections could be said to have control over Madison’s work duties, and thus, his injuries. Madison suffered injuries related to a fall from the back of a laundry truck at Camp Beauregard, a U.S. military base which utilizes inmate labor from Dabadie, the prison where Madison was being held. Madison’s tort claim against the Louisiana Department of Corrections landed in Rapides Parish District Court, where Judge Yeager granted summary judgment in favor of the state, as Dabadie had no control over Madison’s activities while he was on work release. The Third Circuit affirmed Judge Yeager’s ruling last week. Chief Judge Ulysses Gene Thibodeaux and Judge John D. Sanders dissented, indicating that they were not sure that the Department had given complete control to Beauregard. Madison had previously attempted to sue Beauregard and the employee who was driving the truck at the time of the accident, but his claims were not filed in time. The Third Circuit opinion gives no indication as to who must pay for Madison’s medical treatment or whether he can seek recovery through workers’ compensation.