## Facts

- Lavarita D. Meriwether, an Indiana prisoner serving a 35-year sentence, alleged she was a pre-operative transgender woman diagnosed with gender dysphoria.
- She alleged a long pre-incarceration history of physician-supervised estrogen therapy and significant physical feminization procedures, and that prison medical staff acknowledged a diagnosis consistent with gender dysphoria.
- She alleged that, upon entering the Indiana prison system, officials discontinued her estrogen regimen and failed to provide medically appropriate care for her condition, treating her needs as merely cosmetic and subjecting her to humiliating remarks.
- She alleged the abrupt termination of hormones caused withdrawal symptoms and severe distress.
- She further alleged harsh conditions of confinement, including prolonged administrative segregation/protective custody tied to her gender identity, and repeated harassment and violence (including sexual harassment and humiliating treatment) by inmates and staff.
- She filed suit under 42 U.S.C. § 1983 asserting, among other theories, Eighth Amendment violations for deliberate indifference to serious medical needs and for unconstitutional conditions of confinement.
- The district court dismissed under Rule 12(b)(6), reasoning that her condition was not a serious medical need and that segregation was justified for institutional order.

## Issues

1. Whether the complaint plausibly alleged deliberate indifference to a serious medical need, where prison officials allegedly terminated and denied treatment for gender dysphoria, including estrogen therapy.
2. Whether the complaint plausibly alleged cruel and unusual punishment based on the totality of confinement conditions, including prolonged segregation and alleged exposure to harassment and violence.

## Decision

- The Seventh Circuit reversed the Rule 12(b)(6) dismissal and remanded for further proceedings.
- Taking the allegations as true and drawing reasonable inferences in Meriwether’s favor, the court held the complaint stated an Eighth Amendment medical-care claim.
- The court held the complaint also stated an Eighth Amendment conditions-of-confinement claim based on the alleged totality of segregation, harassment, and violence.
- The court emphasized it was assessing pleading sufficiency, not ordering any specific medical protocol or declaring segregation per se unconstitutional.

## Legal Principles

- On a Rule 12(b)(6) motion, courts must accept well-pleaded factual allegations as true and view them, with reasonable inferences, in the plaintiff’s favor.
- The Eighth Amendment prohibits deliberate indifference to prisoners’ serious medical needs, including serious psychological disorders.
- Gender dysphoria may constitute a serious medical need; treating requested care as merely cosmetic can be an error at the pleading stage when the complaint alleges medical necessity and harm from denial.
- Deliberate indifference requires more than negligence; allegations of refusal to provide meaningful treatment, abrupt termination of a longstanding regimen, and trivialization of the condition may suffice to plead deliberate indifference.
- The Eighth Amendment also prohibits confinement conditions amounting to unnecessary and wanton infliction of pain or lacking penological justification; courts must consider the alleged totality of conditions, not isolated features or labels such as “protective custody.”

## Conclusion

The Seventh Circuit held that a transgender prisoner’s allegations of denied medically appropriate treatment for gender dysphoria and of prolonged segregation coupled with harassment and violence were sufficient to state Eighth Amendment claims, requiring reversal of the pleadings-stage dismissal and remand for factual development.


Meriwether v. Faulkner, 821 F.2d 408 (7th Cir. 1987)