The Price of a Belt: Qualified Immunity and the Angola Rodeo

When Gregory Savage began handcrafting leather belts inside Angola Prison nearly three decades ago, he probably did not anticipate that his handiwork would end up in a federal appellate opinion. Yet in Savage v. Westcott, No. 22-30125 (5th Cir. Sept. 29, 2025), the Fifth Circuit wrestled with a deceptively simple question: does an inmate have a constitutional right to the proceeds from arts-and-crafts sales at the prison’s famous rodeo? And if so, was that right “clearly established” enough to pierce the shield of qualified immunity? The panel’s answer, in short: not clearly enough.

The Backstory: Belts, Commissions, and “Taxes”

For years, Savage sold belts at the Angola Prison Rodeo, a sprawling spectacle that blends carnival, commerce, and corrections. His gross sales across two decades totaled roughly $80,000. Yet, according to Savage, prison officials skimmed off about $16,000 in the name of “taxes,” “commissions,” and “maintenance fees.”

To Savage, this was nothing less than theft dressed up as regulation. He filed grievances, citing Louisiana’s inmate compensation statute, and later turned to state court for mandamus relief. When that stalled, he filed a § 1983 suit in federal court, alleging a conspiracy to deny him due process.

The District Court: A Conspiracy Survives Dismissal

The trial court was not persuaded by the officials’ motion to dismiss. While tossing out standalone claims about grievance denials, it allowed Savage’s conspiracy and due process claims to survive. That meant discovery and potential liability for multiple wardens, attorneys, and administrators. The defendants appealed immediately — invoking the heavy artillery of qualified immunity.

The Fifth Circuit: Immunity Prevails

Writing for the court, Chief Judge Richman took the standard two-prong qualified immunity approach. Did Savage plausibly allege a constitutional violation? And, if so, was the right clearly established at the time?

Savage stumbled on the second prong. Although inmates indisputably have property interests in prison trust accounts (Rosin v. Thaler), the law was murkier when it came to proceeds from crafts produced inside prison, using prison-supplied materials, and sold at a prison-sponsored event.

Only in 2023 did the Fifth Circuit recognize in Calhoun v. Collier that inmates enjoy due process protections for funds already in trust accounts. But even there, the court sidestepped the precise issue presented here: does money from craft sales count as protected property before it hits the account? Because no precedent clearly said “yes,” the defendants walked away shielded by qualified immunity.

What Lurks Beneath: Due Process and Prison Economies

The opinion leaves more questions than answers. If inmates can be required to labor, and if their wages can be cut or withheld with minimal constitutional scrutiny (Guzman v. Hollingsworth), how should courts conceptualize prison-based entrepreneurship? Is the rodeo booth more akin to outside employment, or an extension of prison programming?

The Fifth Circuit dodged the substance, focusing instead on the clarity (or lack thereof) of existing precedent. But the structural issue remains: prisons increasingly blur the line between carceral management and commercial enterprise. When the state itself sponsors and profits from inmate labor and sales, courts will eventually need to decide whether these arrangements implicate protected property rights.

Looking Ahead: The Next Round

Savage may continue pursuing injunctive and declaratory relief in district court, but damages against the named officials are off the table. And for scholars of qualified immunity, the case illustrates yet another example of how the doctrine insulates government actors whenever the law has even a hairline crack of ambiguity.

The irony, of course, is hard to miss: Savage’s belts may have been confiscated penny by penny, but the constitutional currency at stake is far more expensive — the scope of due process itself inside prison walls.