Lamb v. Norwood, No. 17-3171 (10th Cir. 2018)Annotate this Case
Michelle Renee Lamb was born a male, but from a young age, however, displayed feminine characteristics and identified as a female. Lamb was in state prison experiencing gender dysphoria. For this condition, she received medical treatment. However, she claimed the treatment was so poor that it violated the Eighth Amendment. The undisputed evidence showed Lamb received hormone treatment, testosterone-blocking medication, and weekly counseling sessions. A 1986 precedent, Supre v. Ricketts, 752 F.2d 958 (10th Cir. 1986), suggested these forms of treatment would preclude liability for an Eighth Amendment violation. Based partly on this precedent, the district court granted summary judgment to the prison officials. Lamb challenged the grant of summary judgment. After review, the Tenth Circuit concluded no genuine issue of material fact existed: “In light of the prison’s treatment for Michelle’s gender dysphoria, no reasonable factfinder could infer deliberate indifference on the part of prison officials. And the district court did not improperly curtail Michelle’s opportunity to conduct discovery. Thus, we affirm the award of summary judgment to the prison officials.”
The court issued a subsequent related opinion or order on August 15, 2018.