Robinson v. Labrador, 1:24-cv-00306

Idaho passed Idaho Code § 18-8901, which bans public funds for medical interventions altering a person's appearance to affirm their gender identity if it differs from their biological sex, effective July 1, 2024.
Plaintiffs (Katie Heredia and Rose Mills) are inmates challenging the Act, claiming it denies medically necessary hormone therapy in violation of the Eighth Amendment and 42 U.S.C. § 1983.
The district court has issued a series of preliminary injunctions blocking enforcement of the Act as it relates to hormone therapy for the class of affected inmates; these expire every 90 days under the PLRA.
The latest (third) injunction is set to expire June 2, 2025, prompting Plaintiffs to file this fourth motion for continued relief.
Defendants, Idaho state officials, argue the legislature may act due to medical debate over hormone therapy, while Plaintiffs assert irreparable harm if care is discontinued.
The court reviewed the motion based on submitted briefs, incorporating prior findings as the parties presented no new evidence or arguments.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Denial of necessary medical care under Eighth Amendment	Heredia: Act denies necessary hormone therapy, causing harm	State officials: Medical debate exists; legislature has authority to regulate	Preliminary injunction granted; serious question remains as to medical necessity
Irreparable harm	Heredia: Discontinuing care causes severe psychological harm	State officials: Public interest in law enforcement; no new arguments	Harm to Plaintiffs outweighs; irreparable harm found
Balance of equities/public interest	Heredia: Protecting constitutional rights paramount	State officials: Law should be enforced as enacted	Balance favors Plaintiffs; preliminary injunction appropriate
Compliance with PLRA requirements	Heredia: Relief is narrow, affects only class members	State officials: No argument; no new burden shown	Injunction remains narrow and minimally intrusive

Mayweathers v. Newland, 258 F.3d 930 (9th Cir. 2001) (successive preliminary injunctions permissible under PLRA)
Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7 (2008) (articulates standard for preliminary injunctions)
Chalk v. U.S. District Court Central District of California, 840 F.2d 701 (9th Cir. 1988) (psychological harm can constitute irreparable harm)
Armstrong v. Schwarzenegger, 622 F.3d 1058 (9th Cir. 2010) (PLRA requires relief be narrowly tailored and minimally intrusive)