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1:24-cv-00306
D. Idaho
Aug 29, 2025
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Background

  • Plaintiff Katie Heredia, a transgender woman incarcerated in Idaho, challenges the constitutionality of Idaho Code § 18-8901, which bans use of public funds for gender-affirming medical care inconsistent with an individual's biological sex.
  • Heredia brings the claim as a class action on behalf of all IDOC inmates diagnosed with gender dysphoria and who are, or would be, receiving hormone therapy.
  • The court previously certified the class and granted four successive 90-day preliminary injunctions, enjoining the enforcement of the Act as it applies to hormone therapy for the class.
  • Idaho law (18 U.S.C. § 3626(a)(2)) mandates that injunctions related to prison conditions expire after 90 days absent a final order with specified findings, necessitating repeat motions for preliminary relief.
  • The court’s fifth preliminary injunction, at issue here, would continue to block enforcement of the Act as to hormone therapy for 90 more days, pending a final decision on the merits.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the Act violates Eighth Amendment rights Denial of necessary medical care (hormones) for gender dysphoria is cruel and unusual punishment Medical necessity of gender-affirming care is debatable and not clearly established Serious questions remain; injunction warranted
Irreparable harm from halting hormone therapy Discontinuing medication will cause severe physiological and psychological harm State interest in enforcing laws and skepticism of harm Harm "tips sharply" in favor of Plaintiffs
Balance of equities and public interest Hardships of denying care outweigh State interests Burden on prison and state's interest in law enforcement Factors weigh in favor of Plaintiffs
Needs-narrowness-intrusiveness under the PLRA Relief is limited to class members already eligible for care under old policies No new argument Injunction is appropriate and narrowly tailored

Key Cases Cited

  • Mayweathers v. Newland, 258 F.3d 930 (9th Cir. 2001) (successive preliminary injunctions permitted under the PLRA)
  • Armstrong v. Schwarzenegger, 622 F.3d 1058 (9th Cir. 2010) (injunctive relief must be narrowly drawn under the PLRA)
  • Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7 (2008) (sets the primary standard for preliminary injunctions)
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Case Details

Case Name: Robinson v. Labrador
Court Name: District Court, D. Idaho
Date Published: Aug 29, 2025
Citation: 1:24-cv-00306
Docket Number: 1:24-cv-00306
Court Abbreviation: D. Idaho
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    Robinson v. Labrador, 1:24-cv-00306