Background
This case stems from nearly a decade of class action litigation against the Alabama Department of Corrections regarding the mental and physical health of inmates. The district court trifurcated the case, with Phase Two A addressing Eighth Amendment claims related to inadequate mental healthcare. After a seven-week trial, the district court found the Department liable for deliberate indifference, citing factors such as understaffing, overcrowding, and failures in screening, treatment, and suicide prevention. The court issued a comprehensive, system-wide injunctive relief order, which the Department of Corrections appealed.
The court’s reasoning
The Eleventh Circuit first addressed whether it had jurisdiction to hear the appeal. The court determined that the Phase Two A Omnibus Remedial Order was an injunction subject to appeal under Section One Two Nine Two of Title Twenty-Eight of the United States Code. The court rejected the Department’s argument that the order was a preliminary injunction that had expired after ninety days under the Prison Litigation Reform Act. The court found the order was permanent because it followed full findings of liability on the merits and was intended to remain in effect until the violations were corrected. The court noted that the Department had consistently treated the order as permanent in its prior filings and that the order contained full findings of liability rather than the likelihood of success required for preliminary relief.
We have said federal courts do not sit as super-wardens over the day-to-day operations of the country’s prison systems.
Pesci v. Budz, 935 F.3d 1159, 1166 (11th Cir. 2019)
What it means going forward
The decision confirms that the district court’s system-wide injunctions regarding mental healthcare in Alabama prisons remain in effect and enforceable. It establishes that such remedial orders, once entered after a full trial on liability, are permanent injunctions that do not expire automatically under the Prison Litigation Reform Act, ensuring continued federal oversight of the Department of Corrections’ mental health practices.