Reid v. Griffin, No. 15-1678 (8th Cir. 2015)
Annotate this CasePlaintiff, an incarcerated state inmate, filed suit under 42 U.S.C. 1983, alleging deliberate indifference to her serious medical needs. Plaintiff alleged that defendants refused to provide hormone replacement therapy for her Gender Identity Disorder (GID).The district court granted summary judgment for defendants. The court concluded that the district court properly granted summary judgment where the district court found that plaintiff's claims against defendants in their official capacities are barred by sovereign immunity. The court agreed with the district court that plaintiff's claims against defendants in their individual capacities were barred by qualified immunity where the evidence, viewed in the light most favorable to plaintiff, did not establish an Eighth Amendment violation. In this case, numerous mental-health professionals have evaluated plaintiff, but none have diagnosed her with GID or concluded that GID treatment is appropriate. Plaintiff's disagreement with these diagnoses and treatment decisions is not actionable under section 1983. Accordingly, the court affirmed the judgment.
Court Description: Per Curiam - Before Wollman, Bye and Gruender, Circuit Judges] Prisoner case - Prisoner civil rights. Plaintiff's claims against defendants in their official capacities were barred by sovereign immunity; with respect to her claims against them in their individual capacities, the district court did not err in concluding the claims were barred by qualified immunity as the evidence did not establish an Eighth Amendment violation; numerous mental-health professionals have examined plaintiff but none have diagnosed her with Gender Identity Disorder or concluded that GID treatment is appropriate; plaintiff's disagreement with these diagnoses and treatment decisions is not actionable under Section 1983. Judge Bye, dissenting. [ December 16, 2015
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