The U.S. Court of Appeals for the Third Circuit case of Burrell v. Staff, 60 F.4th 25 (3d Cir. 2023) (Nygaard, C.J.), raises interesting and rarely used legal procedures for relief.

Plaintiffs William Burrell Jr., Joshua Huzzard and Dampsey Stuckey were held in civil contempt and sentenced to incarceration for not paying child support. They challenged Lackawanna County's policy of conditioning incarcerated civil contemnor child support debtors' access to regularly paid work release—which would have enabled them to earn the money they needed to secure their freedom from incarceration—on first working for half of their sentences sorting through trash at the county recycling center, in purportedly hazardous and disgusting conditions, for sub-minimum wage, 63 cents per hour ($5 per day). The plaintiffs brought several claims against Lackawanna County, the county's Solid Waste Management Authority, Lackawanna County Recycling Center, (the private corporation to which the authority outsources the operation of its Recycling Center) (corporation) and the corporation's owners (brothers Louis and Dominick DeNaples), arising out of the plaintiffs' nearly unpaid labor at the recycling center, including claims that the terms of their incarceration amounted to involuntary servitude.