1:24-cv-00306
D. IdahoAug 29, 2025Background
- 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)
