Case Explained: JOSHUA DUNN, et al. EDWARD BRAGGS v. COMMISSIONER, ALABAMA DEPARTMENT OF CORRECTIONS DEPUTY COMMISSIONER, OFFICE OF HEALTH SERVICES ALABAMA DEPARTMENT OF CORRECTIONS USCA11 Case: 22-10292 Document: 139-1 Date Filed: 06/24/2026 Page: 1 of 73 2

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-06-24 Docket: 2:14-cv-00601-MHT-JTA The eleventh-circuit affirmed the district court’s findings that the Alabama Department of Corrections (DOC) violated the Eighth Amendment through deliberate indifference to the serious mental healthcare needs of its inmates, but reversed specific provisions of the system-wide injunctive relief ordered to remedy those violations. The court held that while the PLRA does not require a district court to make renewed “current and ongoing” liability findings during a remedial phase if liability was already established in a prior bifurcated trial, the relief must still satisfy the statutory “need-narrowness-intrusiveness” standard. The court applied this standard to determine that while system-wide relief was appropriate given the pervasive nature of the constitutional violations, two specific mandates exceeded the scope of what was necessary to correct the Eighth Amendment violation: a requirement that all stabilization and restricted housing units be suicide-proofed according to the “best practices” Hayes Checklist, and a mandate to fill all “essential” correctional staff posts across the entire system regardless of their direct connection to mental healthcare. Additionally, the court reversed certain monitoring and treatment provisions applicable specifically to the Tutwiler women’s prison, finding that the district court lacked sufficient evidence of constitutional violations there to justify those specific remedies. The practical consequence is that the liability finding and the Monitoring Order remain in effect, but the district court must modify the Omnibus Remedial Order on remand to remove the overbroad suicide-proofing mandate, the broad staffing requirement, and the Tutwiler-specific provisions that were not supported by findings of systemic violation. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.