Buckingham v. Federal Bureau of Prisons, 2:25-cv-00701

Plaintiff Nani Love Buckingham is a transgender female inmate at the Federal Detention Center in SeaTac, serving a 252-month sentence since 2020.
Buckingham alleges Eighth Amendment violations, claiming deliberate indifference to her serious medical needs, specifically the denial of gender-affirming surgery.
She has a history of gender dysphoria, suicide attempts, and self-harm, and is undergoing hormone replacement therapy but has been denied surgery and related accommodations following Executive Order 14168.
Buckingham filed a Motion for Temporary Restraining Order (TRO) seeking immediate medical consultation and, if recommended, surgery, as well as related relief (e.g., undergarments, grooming items).
Defendants argue Plaintiff continues to receive appropriate care, has not been denied prescribed treatment, and no urgent medical need has been documented; they further claim Plaintiff has not exhausted administrative remedies.
The Court denied the TRO, finding insufficient evidence of irreparable harm requiring immediate action and that Plaintiff seeks relief beyond preserving the status quo.

Issue	Plaintiff's Argument	Defendant's Argument	Held
TRO for gender-affirming surgery	Immediate surgery/consultation is medically necessary to prevent self-harm and end suffering	No imminent harm; Plaintiff still receiving adequate care; TRO would alter—not preserve—status quo	Denied; no showing of irreparable harm or need to alter status quo
Necessity of immediate judicial intervention	Delayed or denied care increases mental health crises and risk of self-harm	No urgent medical need per BOP doctor; any surgery would not be immediate even if relief granted	Denied; no imminent mental health emergency requiring extraordinary relief
Exhaustion of administrative remedies	Administrative appeals were made, but process is ineffective/exception applies due to urgency	Plaintiff did not complete BOP appeals process; exhaustion not met	Not dispositive; focus was on lack of irreparable harm for TRO
Public interest and balance of equities	Failing to order relief perpetuates unconstitutional harm and suffering	Granting TRO would inappropriately force a new course of treatment, which is not yet medically recommended	Denied; insufficient showing in favor of Plaintiff on these equitable factors

Winter v. Natural Res. Def. Council, Inc., 555 U.S. 7 (preliminary injunction requires likelihood of success, irreparable harm, balance of equities, and public interest)
Alliance for the Wild Rockies v. Cottrell, 632 F.3d 1127 (Ninth Circuit sliding scale test for preliminary injunctive relief)
E. Bay Sanctuary Covenant v. Trump, 932 F.3d 742 (injunctions should preserve, not upend, the status quo)
Granny Goose Foods, Inc. v. Bd. of Teamsters & Auto Truck Drivers Local No. 70, 415 U.S. 423 (TRO limited to preserving status quo)