Andrew Reid v. Rory Griffin, 2015 U.S. App. LEXIS 21926

Andrew Reid, born male and identifying as female, is an Arkansas state prisoner who sought hormone-replacement therapy for Gender Identity Disorder (GID) while incarcerated.
Reid alleges ADC medical staff denied GID treatment; after an initial self-castration attempt in Feb 2013 (one testicle saved), a GID committee did not diagnose her with GID; in June 2014 she removed her remaining testicle and was placed on suicide watch.
Reid sued under 42 U.S.C. § 1983 alleging deliberate indifference to serious medical needs and appealed the district court’s grant of summary judgment for defendants.
The panel applied de novo review and affirmed: official-capacity claims barred by sovereign immunity; individual-capacity claims defeated by qualified immunity because the record did not show deliberate indifference.
The majority held multiple mental-health professionals evaluated Reid and none diagnosed GID or found GID treatment appropriate; disagreement with treatment decisions does not establish an Eighth Amendment violation.
A dissent argued Reid’s complaint should be read to allege defendants ignored a known risk of self-harm after the first mutilation and that fact disputes precluded qualified immunity for two defendants.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether official-capacity § 1983 damages claims against state officials are permissible	Reid sought damages from officials for denial of treatment	Defendants asserted sovereign/Eleventh Amendment immunity	Held: Official-capacity claims barred by sovereign immunity
Whether defendants were deliberately indifferent to Reid’s serious medical needs (Eighth Amendment)	Reid contends denial of GID treatment and/or ignoring risk of self-harm amounted to deliberate indifference	Defendants argue evaluations and treatment decisions (no GID diagnosis) reflect medical judgment, not deliberate indifference	Held: No genuine fact dispute showing deliberate indifference; summary judgment affirmed
Whether qualified immunity protects individual defendants	Reid argues defendants knowingly disregarded risk of self-harm and are not entitled to immunity	Defendants assert their medical judgments were reasonable and no clearly established violation occurred	Held: Qualified immunity applies; defendants entitled to it
Whether Reid produced sufficient evidence to create a factual dispute to survive summary judgment	Reid points to her history (hunger strike, prior self-mutilation) and alleges lack of adequate follow-up care	Defendants point to multiple evaluations and absence of expert proof contradicting their care	Held: Plaintiff failed to produce evidence (expert/medical affidavits) creating a factual dispute; summary judgment proper

Crain v. Bd. of Police Comm’rs, 920 F.2d 1402 (8th Cir. 1990) (standard of de novo review on appeal)
Murphy v. Arkansas, 127 F.3d 750 (8th Cir. 1997) (Eleventh Amendment bars § 1983 damages against state officials in their official capacity)
Meuir v. Greene Cty. Jail Emps., 487 F.3d 1115 (8th Cir. 2007) (plaintiff must produce evidence beyond conclusory allegations to create fact dispute about adequacy of medical care)
Dulany v. Carnahan, 132 F.3d 1234 (8th Cir. 1997) (prison doctors allowed to exercise independent medical judgment; disagreement over treatment not actionable)
White v. Farrier, 849 F.2d 322 (8th Cir. 1988) (GID prisoner: serious condition found, but denial of hormone therapy did not constitute deliberate indifference)
Nat’l Am. Ins. Co. v. W & G, Inc., 439 F.3d 943 (8th Cir. 2006) (standard for determining genuine dispute of material fact on summary judgment)
Gordon ex rel. Gordon v. Frank, 454 F.3d 858 (8th Cir. 2006) (qualified immunity standard regarding deliberate indifference to risk of harm)
Reed v. Woodruff Cnty., Ark., 7 F.3d 808 (8th Cir. 1993) (same standard applies for protection from self-inflicted harm or suicide)
Johnson v. Arden, 614 F.3d 785 (8th Cir. 2010) (pro se complaints must be read broadly)