Fields v. Smith
653 F.3d 550
7th Cir.2011Background
- Three male-to-female transgender inmates with Gender Identity Disorder (GID) sued to challenge Wisconsin Act 105, which bars DOC from providing hormonal therapy or sex reassignment surgery.
- The district court found GID a serious medical need and Act 105 unconstitutional under the Eighth and Fourteenth Amendments, issuing an injunction barring enforcement of Act 105.
- DOC previously prescribed hormone therapy to inmates; Act 105 compelled withdrawal of ongoing hormone treatment and barred future treatment.
- Trial evidence showed hormone withdrawal caused negative medical and psychological outcomes; plaintiffs presented expert testimony that hormones are often the only effective treatment for GID.
- Defendants argued Act 105 was permissible to protect prison security and that alternatives to hormones exist; they failed to prove adequate replacement treatments or security benefits.
- On appeal, the Seventh Circuit affirmed the district court’s injunction, holding Act 105 unconstitutional on Eighth Amendment grounds and addressing the scope of relief under the PLRA.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Act 105 violate the Eighth Amendment by denying effective treatment for a serious medical need? | Fields contends GID is a serious medical need; hormones are necessary for proper treatment. | Smith argues legislature may restrict medical treatments if other options exist and security concerns justify the ban. | Act 105 violates the Eighth Amendment as applied and on its face. |
| Is the challenge to Act 105 facially invalid given some inmates might not need hormones? | The law applies across the board and thus inherently violates constitutional rights. | Facial challenges can succeed only if no set of circumstances would permit the law to be valid; the district court erred by focusing on applicability to some inmates. | The district court properly found the statute unconstitutional both on its face and as applied. |
| Can the state justify Act 105 on prison security grounds given the record? | Hormones do not meaningfully enhance violence risk; security justification is unsupported by evidence. | Providing hormones could increase targets for sexual assault; security can justify restricting treatment. | The security justification is not supported by the record; court refused to defer to the security rationale. |
| Did the district court abuse the PLRA standard in enjoining Act 105 in its entirety? | The injunction should be limited to unconstitutional applications; the PLRA requires narrow relief. | The court should enjoin Act 105 as applied to all inmates to prevent constitutional violations. | The injunction extending to the entire Act was proper and narrowed to prevent constitutional violations. |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (U.S. 1976) (deliberate indifference standard for serious medical needs)
- Meriwether v. Faulkner, 821 F.2d 408 (7th Cir. 1987) (serious medical need; right to treatment noted, not specific type)
- Maggert v. Hanks, 131 F.3d 670 (7th Cir. 1997) (Eighth Amendment does not require esoteric, expensive treatments)
- Roe v. Elyea, 631 F.3d 843 (7th Cir. 2011) (case upholding treatment related to hepatitis C policy in prison)
- Gonzales v. Carhart, 550 U.S. 124 (U.S. 2007) (state may regulate medical procedures; medical uncertainty does not prove efficacy of alternatives)
- Doe v. Heck, 327 F.3d 492 (7th Cir. 2003) (facial challenges and precedents on restricted rights)
- Planned Parenthood of Southeastern Pa. v. Casey, 505 U.S. 833 (U.S. 1992) (focus on group affected by restriction when evaluating constitutionality)
- Whitley v. Albers, 475 U.S. 312 (U.S. 1986) (deference to prison administrators limited by constitutional rights)