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Case Name Edmo v. Idaho Department of Correction PC-ID-0012
Docket / Court 1:17-cv-00151-BLW ( D. Idaho )
State/Territory Idaho
Case Type(s) Disability Rights-Pub. Accom.
Prison Conditions
Attorney Organization National Center for Lesbian Rights (NCLR)
Case Summary
The plaintiff in this case is a transgender, Native American woman. She was incarcerated at facilities run by the Idaho Department of Corrections. Despite multiple attempts at self-castration, the Idaho Department of Corrections and its employees had denied her medically necessary care, refused to ... read more >
The plaintiff in this case is a transgender, Native American woman. She was incarcerated at facilities run by the Idaho Department of Corrections. Despite multiple attempts at self-castration, the Idaho Department of Corrections and its employees had denied her medically necessary care, refused to transfer her, and failed to provide accommodations for her to express her gender identity. The defendants refused to provide the plaintiff with hormone treatment and gender confirmation surgery. Because of this, the plaintiff attempted to castrate herself on two occasions. Additionally, employees at the facilities punished the plaintiff by placing her in solitary confinement when she attempted to express her gender identity by modifying her clothes and wearing her hair in a ponytail.

Represented by the National Center for Lesbian Rights, the plaintiff filed suit on April 6, 2017, in the U.S. District Court for the District of Idaho under 42 U.S.C. § 1983. She alleged that the Idaho Department of Corrections and its private contractor Corizon violated her Eighth Amendment right against cruel and unusual punishment and her Fourteenth Amendment right to equal protection. She alleged discrimination under the Fourteenth Amendment on the basis of sex as well as violations of the Americans with Disabilities Act and § 504 of the Rehabilitation Act for discrimination on the basis of disability. In addition to constitutional claims, she filed multiple state negligence claims. She requested injunctive, declaratory, and monetary relief in the form of compensatory damages, punitive damages, and attorneys’ fees.

On June 1, 2018, the court granted the defendants’ motion for partial summary judgment with respect to the plaintiff’s negligence claims and the claims she brought under the Americans with Disabilities Act. At this hearing the court also dismissed the plaintiff's request that the court enjoin the defendant to transfer the plaintiff to a female facility.

Over six months later, on December 13, 2018, the court granted the plaintiff’s motion for a preliminary injunction in part. The court ordered the defendants to provide adequate medical care and gender confirmation surgery as promptly as possible. 2018 U.S. Dist. LEXIS 211391, WL 6571203 *51. This order did not address injunctive relief regarding gender-appropriate clothing and commissary items because the Idaho Department of Corrections implemented a gender dysphoria policy addressing these requests on October 5, 2018.

The defendants appealed the district court’s preliminary injunction on January 9, 2019. At the date of writing, the Ninth circuit had not yet scheduled oral argument and the case is ongoing.

Keagan Potts - 02/20/2019


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Issues and Causes of Action
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Issues
Affected Gender
Female
Constitutional Clause
Cruel and Unusual Punishment
Equal Protection
Content of Injunction
Preliminary relief granted
Defendant-type
Corrections
Discrimination-basis
Disability (inc. reasonable accommodations)
Sexual orientatation
General
Disciplinary procedures
Disciplinary segregation
Gay/lesbian/transgender
Suicide prevention
Medical/Mental Health
Medical care, general
Self-injurious behaviors
Suicide prevention
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12111 et seq.
Section 504 (Rehabilitation Act), 29 U.S.C. § 701
State law
Defendant(s) Corizon Incorporated
Idaho Department of Correction
Plaintiff Description Transgender Native American female inmate
Indexed Lawyer Organizations National Center for Lesbian Rights (NCLR)
Class action status sought No
Class action status granted No
Filed Pro Se No
Prevailing Party None Yet / None
Public Int. Lawyer Yes
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Litigation
Filing Year 2017
Case Ongoing Yes
Additional Resources
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  Civil Rights Injunctions Over Time: A Case Study of Jail and Prison Court Orders
N.Y.U. Law Review
Date: May 2006
By: Margo Schlanger (Washington University Faculty)
Citation: 81 N.Y.U. L. Rev. 550 (2006)
[ Detail ] [ PDF ] [ External Link ]

  Judicial Policy Making and the Modern State: How the Courts Reformed America's Prisons
Book
Date: Jan. 1, 1998
By: Malcolm M. Feeley & Edward Rubin (UC Berkeley Boalt Hall School of Law & Vanderbilt School of Law Faculty Faculty)
Citation: (1998)
[ Detail ]

Docket(s)
1:17-cv-00151-BLW (D. Idaho)
PC-ID-0012-9000.pdf | Detail
Date: 02/13/2019
Source: PACER [Public Access to Court Electronic Records]
General Documents
Memorandum of Law in Support of Motion for a TRO and Preliminary Injunction [ECF# 10]
PC-ID-0012-0001.pdf | Detail
Date: 04/13/2017
Source: PACER [Public Access to Court Electronic Records]
Memorandum in Support of IDOC Defendants' First Motion for Dispositive Relief [ECF# 43]
PC-ID-0012-0002.pdf | Detail
Date: 11/01/2017
Source: PACER [Public Access to Court Electronic Records]
Memorandum Decision and Order (2018 WL 2745898) (D. Idaho)
PC-ID-0012-0005.pdf | WESTLAW | Detail
Date: 06/07/2018
Source: Westlaw
Findings of Fact, Conclusions of Law, and Order [ECF# 149] (D. Idaho)
PC-ID-0012-0003.pdf | Detail
Date: 12/13/2018
Source: PACER [Public Access to Court Electronic Records]
Third Amended Complaint [ECF# 172]
PC-ID-0012-0004.pdf | Detail
Date: 01/31/2019
Source: PACER [Public Access to Court Electronic Records]
show all people docs
Judges Winmill, B. Lynn (D. Idaho) show/hide docs
PC-ID-0012-0003 | PC-ID-0012-0005 | PC-ID-0012-9000
Plaintiff's Lawyers Chen, Alexander (California) show/hide docs
PC-ID-0012-0001 | PC-ID-0012-0004 | PC-ID-0012-9000
Durham, Craig (Idaho) show/hide docs
PC-ID-0012-0001 | PC-ID-0012-0004 | PC-ID-0012-9000
Ferguson, Deborah A (Idaho) show/hide docs
PC-ID-0012-0001 | PC-ID-0012-0004 | PC-ID-0012-9000
Rifkin, Lori E (California) show/hide docs
PC-ID-0012-0001 | PC-ID-0012-0004 | PC-ID-0012-9000
Stormer, Dan Lewis (California) show/hide docs
PC-ID-0012-0001 | PC-ID-0012-0004 | PC-ID-0012-9000
Whelan, Amy E. (California) show/hide docs
PC-ID-0012-0001 | PC-ID-0012-0004 | PC-ID-0012-9000
Wilensky, Julie (California) show/hide docs
PC-ID-0012-0001 | PC-ID-0012-0004 | PC-ID-0012-9000
Defendant's Lawyers Crecelius, Marisa Swank (California) show/hide docs
PC-ID-0012-9000
Eaton, Dylan Alexander (Idaho) show/hide docs
PC-ID-0012-9000
Hall, Brady James (Idaho) show/hide docs
PC-ID-0012-0002 | PC-ID-0012-9000
Jensen, Bryce C (Idaho) show/hide docs
PC-ID-0012-9000
West, J Kevin (Idaho) show/hide docs
PC-ID-0012-9000
Other Lawyers England, Christine Gealy (California) show/hide docs
PC-ID-0012-9000

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