Campbell v. Kallas, No. 18-2075 (7th Cir. 2019)
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In 2007, Campbell pleaded guilty to first-degree sexual assault of a child and was sentenced to 34 years in prison. Campbell has gender dysphoria; she is biologically male but identifies as female. Department of Corrections (DOC) medical staff treat Campbell’s condition with hormone therapy. Beginning in 2013, Campbell repeatedly requested sex-reassignment surgery. National standards of care recommend that patients undertake one year of “real life” experience as a person of their self-identified gender before resorting to irreversible surgery, which presents challenges in sex-segregated prisons. DOC officials consulted an outside expert, who determined that Campbell was a potential surgical candidate if DOC officials developed a safe, workable solution to the real-life-experience dilemma. Citing these concerns and DOC policy, officials denied Campbell’s request. After exhausting administrative remedies, Campbell sued under 42 U.S.C. 1983, alleging deliberate indifference to her serious medical needs.
The Seventh Circuit reversed the denial of defendants’ claim of qualified immunity. Qualified immunity shields public officials from suits for damages unless precedent clearly puts them on notice that an action is unconstitutional. The Eighth Amendment requires prison healthcare professionals to exercise medical judgment when making decisions about an inmate’s treatment; they cannot completely deny care for a serious medical condition. Those broad principles could not have warned these defendants that treating an inmate’s gender dysphoria with hormone therapy and deferring consideration of sex-reassignment surgery violates the Constitution. The defendants followed accepted medical standards and are immune from damages liability.
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