Edmo v. Corizon, Inc.
United States Court of Appeals for the Ninth Circuit
935 F.3d 757 (2019)
- Written by Liz Nakamura, JD
Facts
Adree Edmo (plaintiff), a male-to-female transgender woman, was a prisoner in a men’s prison run by the Idaho Department of Corrections (IDOC) (defendant) at which Corizon, Inc. (defendant) (collectively, the state) provided medical services. Edmo suffered from genital-focused gender dysphoria, which the state treated with hormone therapy. However, the hormone therapy was insufficient, and Edmo’s gender dysphoria became severe enough that she attempted to self-castrate on two separate occasions. Regardless, the state denied Edmo’s request for gender-affirming surgery. Edmo sued the state for violating the Eighth Amendment, arguing that the state’s refusal to provide her with gender-affirming surgery constituted deliberate indifference to Edmo’s serious medical needs. The state countered, arguing that gender-affirming surgery was not medically necessary to treat Edmo’s gender dysphoria. It was undisputed that the appropriate diagnostic criteria for gender-affirming surgery were the World Professional Association of Transgender Health Standards of Care (WPATH standards). At a hearing, Edmo presented expert testimony from two witnesses who had each treated hundreds of patients with gender dysphoria, both of whom testified that, under the WPATH standards, gender-affirming surgery was necessary because (1) hormone therapy was demonstrably insufficient, (2) Edmo was in severe distress that would be cured only if her genitals matched her gender identity, and (3) Edmo had lived as a women for a significant period of time. The state’s experts, neither of whom had treated patients suffering from gender dysphoria, testified that Edmo did not meet the WPATH standards because her self-castration attempts were uncontrolled and because she had never lived as a woman outside of prison. The district court held that the state’s failure to provide Edmo with medically necessary gender-affirming surgery violated the Eighth Amendment. The state appealed.
Rule of Law
Issue
Holding and Reasoning (Per curiam)
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