Keohane v. Florida Department of Corrections Secretary

Reiyn Keohane (plaintiff) was a male-to-female transgender individual incarcerated in a men’s prison operated by the Florida Department of Corrections (DOC) (defendant). After Keohane was incarcerated, she requested to continue receiving hormone treatments and requested permission to socially transition by physically presenting as female. The DOC ultimately granted Keohane’s request for continued hormone treatment following a protracted initial denial. The DOC also provided counseling, gave Keohane access to private shower facilities, and referred to Keohane using female pronouns. However, the DOC denied Keohane’s request to socially transition, stating that Keohane’s request violated prison grooming policies and that allowing Keohane to present as female would pose security risks in the all-male prison. After the initial denial, Keohane continued to request permission to socially transition. At the same time, Keohane’s mental health declined, and she attempted to self-harm and self-castrate and made three suicide attempts. Keohane ultimately sued the DOC in district court and sought injunctive relief, arguing that the DOC’s refusal to allow her to socially transition violated the Eighth Amendment because it constituted deliberate indifference to Keohane’s gender dysphoria, a serious medical need. At trial, Keohane’s medical expert and the DOC’s medical team disagreed about whether social transitioning was medically necessary to treat Keohane’s gender dysphoria. The district court ruled for Keohane and ordered the DOC to allow Keohane to socially transition. The DOC appealed.