747 F.Supp.3d 1331
D. Idaho2024Background
- Plaintiffs are two transgender women incarcerated in Idaho Department of Corrections (IDOC) facilities, diagnosed with gender dysphoria and prescribed hormone therapy.
- Idaho enacted Idaho Code § 18-8901 (the "Act"), effective July 1, 2024, prohibiting the use of public funds for medical interventions to alter an individual's appearance to affirm gender identity inconsistent with biological sex.
- Plaintiffs filed for a temporary restraining order (TRO), preliminary injunction, and provisional class certification, arguing the Act violates their Eighth Amendment rights by denying necessary medical care.
- The court initially granted a TRO, then held hearings and permitted discovery to further develop the record particularly on class certification.
- The defendants consist of various Idaho state officials (the "State Defendants") and Centurion, the prison healthcare provider (which did not oppose the motion).
- The present order grants a preliminary injunction against enforcement of the Act (as to hormone therapy for gender dysphoria) and certifies a class of similarly situated incarcerated individuals.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Preliminary Injunction: Serious Questions | Hormone therapy is medically necessary; denial risks harm | The Act sets the standard of care; state may regulate | Serious legal questions are raised; favors injunction |
| Irreparable Harm | Loss of hormone therapy causes imminent, significant injury | Plaintiffs' affidavits insufficient; no qualified testimony | Plaintiffs made sufficient showing of harm |
| Balance of Equities/Public Interest | Withholding care is harmful and contrary to IDOC past policy | No articulated burden to defendants or public interest issue | Equities/public interest favor plaintiffs |
| Class Certification | Satisfies numerosity, commonality, typicality, adequacy | Class not sufficiently numerous or typical; premature motion | All Rule 23 requirements met; class certified |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (Supreme Court established deliberate indifference to serious medical needs as an Eighth Amendment violation)
- Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7 (Supreme Court set the test for preliminary injunctive relief)
- Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338 (Supreme Court clarified Rule 23 class certification requirements)
- Parsons v. Ryan, 754 F.3d 657 (Ninth Circuit on class certification for prison conditions claims)
- Hanlon v. Chrysler Corp., 150 F.3d 1011 (Ninth Circuit expounded on typicality/commonality for class actions)
- Hanon v. Dataproducts Corp., 976 F.2d 497 (Ninth Circuit articulated typicality standards for class actions)
- Gen. Tel. Co. of the Sw. v. Falcon, 457 U.S. 147 (Supreme Court explained typicality and adequacy in class actions)
- Chalk v. U.S. Dist. Court Cent. Dist. of Cal., 840 F.2d 701 (Ninth Circuit on irreparable harm in the context of injunctions)
- Brown v. Plata, 563 U.S. 493 (Supreme Court affirmed classwide injunctive relief for prisoners' Eighth Amendment claims)
