Campbell v. Dunn

On September 13, 2023, the U.S. Court of Appeals for the Eleventh Circuit ruled in Campbell v. Dunn. The plaintiff, a transgender woman incarcerated in the Alabama Department of Corrections, sued Commissioner Jeff Dunn and other officials under the Eighth Amendment. She alleged that the prolonged denial of medically necessary gender-affirming care, including hormone therapy and evaluation for surgery, caused her severe harm due to her gender dysphoria. A federal district court had ordered the prison system to provide specific treatments, finding that the officials acted with deliberate indifference to her serious medical needs. The state appealed, arguing that the care was not constitutionally required. The appellate decision largely affirmed the lower court's core findings, holding that the denial of care constituted cruel and unusual punishment and that the injunction requiring treatment was justified under the Constitution.

The Eleventh Circuit affirmed the district court's ruling in part, vacated it in part, and remanded. The court upheld the finding that the prison officials were deliberately indifferent to the inmate's serious medical needs and maintained the injunction requiring the provision of necessary hormone therapy.

Whether the Alabama Department of Corrections' refusal to provide a transgender inmate with gender-affirming medical treatment, including hormone therapy, violates the Eighth Amendment's prohibition against cruel and unusual punishment.

The decision reinforced the constitutional obligation of prison systems to provide adequate medical care to transgender inmates. It has been cited as a significant precedent affirming that deliberate denial of gender dysphoria treatment amounts to cruel and unusual punishment, influencing correctional healthcare policies across the country.