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Keywords

lawsuitplaintiffappealdiscrimination
jurisdictionappellee

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Kadel v. Folwell, 100 F.4th 122, 118 Fed.R.Serv.3d 1293, Med & Med GD (CCH) P 308,061, 124 Fed. R. Evid. Serv. 1406

Facts

The North Carolina State Health Plan and West Virginia's Medicaid Program both excluded coverage for treatments related to gender dysphoria, despite covering similar procedures for non-gender dysphoria diagnoses. Transgender individuals, who were denied coverage for medically necessary treatments, filed lawsuits claiming these exclusions violated their rights under the Equal Protection Clause and other federal laws. The district courts ruled in favor of the plaintiffs, leading to the appeals.

Appellees in both cases are transgender individuals who were denied coverage for healthcare prescribed for their gender-dysphoria diagnoses.

Issue

Do healthcare plans that cover medically necessary treatments for certain diagnoses but bar coverage of those same medically necessary treatments for a diagnosis unique to transgender patients violate the Equal Protection Clause or other provisions of federal law?

Do healthcare plans that cover medically necessary treatments for certain diagnoses but bar coverage of those same medically necessary treatments for a diagnosis unique to transgender patients violate either the Equal Protection Clause or other provisions of federal law?

Rule

The court applied heightened scrutiny under the Equal Protection Clause, determining that exclusions based on gender dysphoria constitute discrimination based on sex and gender identity, which must meet an 'exceedingly persuasive justification' to be upheld.

The Equal Protection Clause of the Fourteenth Amendment forbids a state from denying 'to any person within its jurisdiction the equal protection of the laws.'

Analysis

The court found that the coverage exclusions in both North Carolina and West Virginia facially discriminated against transgender individuals by denying them medically necessary treatments based on their gender identity. The court rejected the argument that the exclusions were neutral, emphasizing that they disproportionately affected transgender individuals and did not serve a legitimate government interest.

The district courts considered the coverage exclusions under intermediate scrutiny because they viewed the exclusions as facially discriminating on the basis of sex and gender identity.

Conclusion

The court affirmed the district courts' rulings, holding that the coverage exclusions violated the Equal Protection Clause and other federal laws, and enjoined the states from enforcing these exclusions.

We affirm the judgments of the district courts.

Who won?

The plaintiffs (transgender individuals) prevailed because the court found that the coverage exclusions discriminated against them based on their gender identity and did not meet the required legal scrutiny.

The district court concluded that the Plan's coverage exclusion facially discriminates based on sex and transgender status and, therefore, must withstand intermediate scrutiny.

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