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Edmo v. Corizon, Inc., 935 F.3d 757, 19 Cal. Daily Op. Serv. 8395, 2019 Daily Journal D.A.R. 8068

Facts

Adree Edmo, a male-to-female transgender prisoner, has been diagnosed with gender dysphoria, which causes her significant distress due to the incongruence between her gender identity and her assigned sex at birth. Despite receiving hormone therapy, Edmo continued to experience severe distress, leading to self-harm attempts, including self-castration. The district court found that Edmo's medical experts convincingly testified that gender confirmation surgery was necessary for her treatment, while the state's experts were deemed less credible.

Adree Edmo (formerly Mason Dean Edmo) is a male-to-female transgender prisoner in the custody of the Idaho Department of Correction (“IDOC”). Edmo's sex assigned at birth (male) differs from her gender identity (female). The incongruity causes Edmo to experience persistent distress so severe it limits her ability to function.

Issue

Did the Idaho Department of Corrections' failure to provide gender confirmation surgery to Adree Edmo constitute a violation of her Eighth Amendment rights?

Rule

The Eighth Amendment prohibits cruel and unusual punishments, which includes deliberate indifference to serious medical needs of prisoners. Courts must ensure that prison authorities provide necessary medical treatment as per established medical standards.

The Eighth Amendment prohibits “cruel and unusual punishments.” U.S. Const. amend. VIII. “The Amendment embodies broad and idealistic concepts of dignity, civilized standards, humanity, and decency ….” Estelle v. Gamble, 429 U.S. 97, 102, 97 S.Ct. 285, 50 L.Ed.2d 251 (1976) (quotation omitted).

Analysis

The court applied the Eighth Amendment standard by evaluating the medical necessity of gender confirmation surgery for Edmo. It credited the district court's findings that Edmo's gender dysphoria was severe and that the treatment prescribed by the WPATH Standards of Care included surgery. The court emphasized that the state's failure to provide this treatment, despite knowledge of Edmo's suffering, constituted deliberate indifference.

Crediting, as we must, the district court's logical, well-supported factual findings, we hold that the responsible prison authorities have been deliberately indifferent to Edmo's gender dysphoria, in violation of the Eighth Amendment.

Conclusion

The Court of Appeals affirmed the district court's order for the state to provide gender confirmation surgery to Edmo, concluding that the denial of such treatment violated her Eighth Amendment rights.

The district court's order entering injunctive relief for Edmo is affirmed, with minor modifications noted below.

Who won?

Adree Edmo prevailed in the case because the court found that the state had been deliberately indifferent to her serious medical needs, as evidenced by the necessity of gender confirmation surgery for her gender dysphoria.

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