Gender dysphoria is psychological distress that results from an incongruence between one’s sex assigned at birth and one’s gender identity. Gender dysphoria and the medical needs of transgender inmates are important topics for correctional officers. One key question often raised is whether discontinuing an inmate’s hormone replacement therapy (HRT) can violate their constitutional rights, especially when a prison physician has determined the inmate does not have gender dysphoria. This was the issue at the center of the case Johnson v. Sanders, where a transgender inmate sued a prison physician and staff after the discontinuation of her HRT medications.
The Case of Lamone M. Johnson
In Johnson v. Sanders, Lamone M. Johnson, a transgender woman, was initially diagnosed with gender dysphoria and was prescribed HRT medications while incarcerated. However, after a psychological evaluation at a different prison, a psychologist determined that Johnson did not meet the criteria for gender dysphoria and instead diagnosed her with a personality disorder. Based on this new diagnosis, a prison physician decided to discontinue Johnson’s HRT medications, arguing that the inmate no longer required them. Johnson, who had been receiving HRT for over a year, experienced physical and mental distress due to the discontinuation of the medications, leading her to file a lawsuit under 42 U.S.C. § 1983 for deliberate indifference to her serious medical needs.
Deliberate Indifference and the Eighth Amendment
In such cases, courts examine whether prison medical staff were “deliberately indifferent” to an inmate’s serious medical needs, as required by the Eighth Amendment. Deliberate indifference occurs when prison officials know or should have known that their actions pose a substantial risk of harm to an inmate and fail to take appropriate measures. However, it is important to note that disagreement with a diagnosis or prescribed treatment is not enough to prove deliberate indifference. Prison officials are not required to provide the exact treatment an inmate prefers, but they must provide treatment that is adequate for the inmate’s medical condition.
In the case of Johnson, the court found that no reasonable jury could determine that the discontinuation of her HRT medications was done with deliberate indifference. The court reasoned that the prison medical staff followed the new diagnosis provided by the prison psychologist, which did not support gender dysphoria as a medical condition. Furthermore, the physician’s decision to discontinue medication was based on the institution’s policy that HRT medications could only be prescribed for inmates diagnosed with gender dysphoria.
Medical Needs vs. Prison Policy
While the physician adhered to the prison’s policy of discontinuing HRT medications based on the diagnosis, the court noted that such policies should not compromise constitutional rights. The key legal principle at play here is that prison policies cannot violate constitutional standards, especially when they lead to inadequate medical treatment. In Johnson’s case, although alternative treatments for gender dysphoria, such as psychotherapy, were available, Johnson declined them. The court concluded that Johnson was not completely denied medical care, but rather, her treatment had been altered according to the updated diagnosis.
Understanding the Legal Implications
This case underscores the importance of ensuring that inmates receive adequate treatment for serious medical conditions, particularly when it involves gender dysphoria. Courts have recognized gender dysphoria as a serious medical need, and failing to provide appropriate treatment can lead to constitutional violations. It is critical for correctional officers and medical staff to understand that gender-affirming care, including hormone therapy, is not simply a matter of inmate preference but a medically necessary treatment for many transgender individuals.
The Role of Correctional Officers in Medical Care
Correctional officers play an essential role in ensuring that inmates receive the proper care they need, and understanding cases like Johnson v. Sanders helps officers recognize their responsibility to safeguard inmates’ medical rights. Officers must be aware of the potential consequences of denying medical care, particularly when a recognized medical need such as gender dysphoria is involved.
While Johnson v. Sanders provides clarity on how the courts assess medical decisions in the prison system, it also highlights the need for correctional facilities to have policies in place that prioritize the health and safety of all inmates. Officers should be equipped with the knowledge to understand when and how medical decisions, such as the discontinuation of HRT, may cross the line into deliberate indifference.
To help correctional officers stay informed about the legal standards and procedures surrounding inmate healthcare, PLS Jail Pro offers monthly online corrections training focused on real legal cases. Our training helps officers navigate complex legal topics, reduce liability risks, and ensure that their actions align with constitutional requirements.
For more information on how PLS Jail Pro online corrections training can assist your agency in meeting training needs, request a demo or schedule a meeting with us today. Let’s ensure that your team is prepared to handle the evolving legal landscape of correctional healthcare.