Braggs v. Dunn
367 F. Supp. 3d 1340
M.D. Ala.2019Background
- Court previously found ADOC's mental-health care violated the Eighth Amendment and reserved ruling on whether ADOC conducted adequate periodic mental-health evaluations of prisoners in segregation; this opinion resolves that discrete issue.
- ADOC regulations require a mental-health evaluation at 30 days in segregation and every 90 days thereafter for any inmate held in segregation, plus more frequent "segregation rounds."
- The court found segregation causes serious psychological harms (including suicide, psychosis, decompensation), especially for those with serious mental illness; ADOC segregation conditions (isolation, poor cell conditions, limited out-of-cell time, poor visibility, understaffing) exacerbate risk.
- The evidentiary record shows multiple inmates—both on and off the mental-health caseload—spent extended periods in segregation and either received no periodic evaluations or received cursory, checkbox evaluations that failed to note self-harm, suicidality, or changed condition.
- Psychological autopsies of several suicides in segregation (by inmates not on the caseload) and expert testimony support that ADOC’s monitoring (evaluations and rounds) is infrequent, perfunctory, and ineffective.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ADOC conducts constitutionally adequate periodic mental-health evaluations in segregation | ADOC fails to perform timely, substantive 30-day/90-day evaluations; forms are perfunctory and do not detect decompensation | ADOC points to regulations and testimony asserting required evaluations and rounds occur; compliance is adequate | Court: ADOC's periodic evaluations are systemicly inadequate—irregular, perfunctory, and fail to identify serious needs; contributes to Eighth Amendment violation |
| Whether inadequate evaluations pose actual or substantial risk of serious harm | Plaintiffs: segregation causes severe, sometimes permanent harm; lack of monitoring produces substantial risk (and actual suicides) | Defendants: written policies satisfy constitutional requirements; recent steps have reduced suicides so risk is abated | Court: failure to provide adequate evaluations, given segregation's harms and ADOC conditions, creates substantial risk of serious harm; policy compliance on paper is insufficient |
| Whether relief can extend to prisoners who enter segregation mentally healthy | Plaintiffs: segregation can induce mental illness; adequate evaluations must cover all in segregation to detect new/undetected illness | Defendants: class limited to prisoners with serious mental-health disorders; healthy inmates not entitled | Court: Relief can extend to those who develop illness in segregation or whose illness was previously unidentified; Plata permits relief protecting current and future class members |
| Whether defendants acted with deliberate indifference | Plaintiffs: ADOC knew risks (regulations, expert consensus, suicide data) yet failed to ensure meaningful monitoring | Defendants: adherence to regulations and recent improvements rebut indifference | Court: Defendants were deliberately indifferent in failing to provide adequate periodic evaluations in segregation |
Key Cases Cited
- Farrow v. West, 320 F.3d 1235 (11th Cir. 2003) (defines "serious" medical/mental-health need for Eighth Amendment claims)
- Farmer v. Brennan, 511 U.S. 825 (1994) (Eighth Amendment liability for conditions posing substantial risk of serious harm)
- Helling v. McKinney, 509 U.S. 25 (1993) (Eighth Amendment protects against objectively serious future harms)
- Gates v. Cook, 376 F.3d 323 (5th Cir. 2004) (multiple policies/practices can combine to deprive an inmate of an identifiable human need)
- Wilson v. Seiter, 501 U.S. 294 (1991) (standards for prison-conditions Eighth Amendment claims)
- Brown v. Plata, 563 U.S. 493 (2011) (relief may cover healthy inmates because they risk future harm from systemic deficiencies)
- Palakovic v. Wetzel, 854 F.3d 209 (3d Cir. 2017) (summarizes scientific evidence on harms of long-term isolation)
- Rogers v. Evans, 792 F.2d 1052 (11th Cir. 1986) (repeated examples of delayed or denied medical care can show systemic deficiencies)
- Lewis v. Casey, 518 U.S. 343 (1996) (distinct limits on claims by healthy inmates; cited for contrast)
- Thomas v. Bryant, 614 F.3d 1288 (11th Cir. 2010) (discusses deliberate indifference standard)