Keohane v. Inch
What's at Stake
The American Civil Liberties Union (ACLU), the American Civil Liberties Union of Florida, and DLA Piper LLP filed a federal lawsuit challenging the Florida Department of Corrections’ (DOC) denial of medically necessary care for Reiyn Keohane, a transgender woman currently detained in a men’s prison.
Summary
The complaint seeks an injunction directing Defendants to provide Reiyn with medically necessary hormone therapy and access to female clothing and grooming standards.
Reiyn, 22, has known that she has a female gender identity since the age of 12. “Gender identity” refers to a person’s internal sense of their own gender. For transgender individuals, one’s gender identity differs from the sex assigned to them at birth. The medical diagnosis for the incongruence between one’s gender identity and assigned sex and the clinical distress resulting from this incongruence is “gender dysphoria.”
With the support of medical and mental-health professionals, Reiyn has been living as female since age 14. At age 17, she had her name legally changed from a traditionally male name, and she began hormone therapy under the care of an endocrinologist at the age of 19. While awaiting trial after her arrest in 2013, Keohane was abruptly removed from her hormone therapy by the Lee County Jail. Believing she would be allowed to resume hormone therapy after being transferred to DOC custody, Keohane accepted a plea deal in 2014.
In July 2014, Keohane repeatedly made clear to DOC officials that she needed to continue her treatment for her gender dysphoria, which included both hormone therapy and the ability to groom and dress consistent with her female gender identity. Not only was she denied restoration of the hormone therapy, but her hair was forcibly cut and she had her female clothing items confiscated. She filed numerous grievances to restore her treatment, but they were repeatedly denied.
“Comprehensive treatment for gender dysphoria is critically important for the health and wellbeing of many transgender people,” stated ACLU of Florida staff attorney Daniel Tilley. “It is unconstitutional for the DOC to deny inmates any care that is medically necessary to treat their serious medical needs, and that is exactly what the DOC has done to Reiyn.”
Reiyn wrote a letter describing her experiences and the discrimination and harassment she has faced as a transgender woman being denied treatment for her gender dysphoria in prison. It reads in part: “I know that I am not alone, that other women have been in my situation before, and had it better, or worse. […] I will fight this prejudice every step of the way so that there will be a better future for all other people who are thrown in prison, so that we may all have the treatment, dignity, and respect that every human being deserves, even if they have done wrong.”
The lawsuit asks the court to find that the DOC’s denial of treatment for Reiyn’s gender dysphoria is a violation of the Eighth Amendment to the U.S. Constitution’s ban on cruel and unusual punishment.
Legal Documents
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06/15/2021
Reply Brief of Petitioner -
06/01/2021
Brief in Opposition -
05/03/2021
Petition for Writ of Certiorari
Date Filed: 06/15/2021
Court: Supreme Court (U.S.)
Download DocumentDate Filed: 06/01/2021
Court: Supreme Court (U.S.)
Download DocumentDate Filed: 05/03/2021
Court: Supreme Court (U.S.)
Download Document-
12/03/2020
Order Denying En Banc Review -
04/15/2020
En Banc Petition -
03/11/2020
11th Circuit Panel Decision -
01/09/2019
Amicus Briefs in Support of Appellee -
- Civil Rights and Legal Services Organizations Amicus Brief
- Health Care Organizations Amicus Brief
Keohane v. InchLegal DocumentsCivil Rights and Legal Services Organizations Amicus BriefDate Filed: 01/09/2019
Court: Appeals Court (11th Cir.)
Download DocumentKeohane v. InchLegal DocumentsHealth Care Organizations Amicus BriefDate Filed: 01/09/2019
Court: Appeals Court (11th Cir.)
Download Document -
01/09/2019
Brief of Plaintiff-Appellee -
11/19/2018
Appellant's Brief
Date Filed: 12/03/2020
Court: Appeals Court (11th Cir.)
Download DocumentDate Filed: 04/15/2020
Court: Appeals Court (11th Cir.)
Download DocumentDate Filed: 03/11/2020
Court: Appeals Court (11th Cir.)
Download DocumentDate Filed: 01/09/2019
Court: Appeals Court (11th Cir.)
Download DocumentDate Filed: 11/19/2018
Court: Appeals Court (11th Cir.)
Download Document-
08/22/2018
Order on the Merits -
06/12/2017
FDOC's Motion for Summary Judgment -
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06/19/2017
Plaintiff's Response to Motion for Summary Judgment -
06/26/2017
FDOC's Reply in Support of Motion for Summary Judgment
Keohane v. InchLegal DocumentsPlaintiff's Response to Motion for Summary JudgmentDate Filed: 06/19/2017
Court: District Court (N.D. Fla.)
Download DocumentKeohane v. InchLegal DocumentsFDOC's Reply in Support of Motion for Summary JudgmentDate Filed: 06/26/2017
Court: District Court (N.D. Fla.)
Download Document -
06/19/2017
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07/05/2017
Keohane v. Jones - Order Denying Motion for Summary Judgment -
09/12/2016
Doctor Defendants' Motion to Dismiss -
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09/26/2016
Plaintiff's Response in Opposition to Doctor Defendants' Motion to Dismiss
Keohane v. InchLegal DocumentsPlaintiff's Response in Opposition to Doctor Defendants' Motion to DismissDate Filed: 09/26/2016
Court: District Court (N.D. Fla.)
Download Document -
09/26/2016
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09/12/2016
Florida Department of Corrections Defendants' Motion to Dismiss and Memorandum -
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09/26/2016
Plaintiff's Response in Opposition to FDOC's Motion to Dismiss
Keohane v. InchLegal DocumentsPlaintiff's Response in Opposition to FDOC's Motion to DismissDate Filed: 09/26/2016
Court: District Court (N.D. Fla.)
Download Document -
09/26/2016
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08/15/2016
Plaintiff's Motion for Preliminary Injunction -
- Plaintiff's Motion for Preliminary Injunction
- Florida Department of Corrections Response in Opposition to Motion for Preliminary Injunction
- Defendants' Response in Opposition to Motion for Preliminary Injunction
- Plaintiff's Reply in Support of Motion for Preliminary Injunction
Keohane v. InchLegal DocumentsPlaintiff's Motion for Preliminary InjunctionDate Filed: 08/15/2016
Court: District Court (N.D. Fla.)
Download DocumentKeohane v. InchLegal DocumentsFlorida Department of Corrections Response in Opposition to Motion for Preliminary InjunctionDate Filed: 09/26/2016
Court: District Court (N.D. Fla.)
Download DocumentKeohane v. InchLegal DocumentsDefendants' Response in Opposition to Motion for Preliminary InjunctionDate Filed: 09/26/2016
Court: District Court (N.D. Fla.)
Download DocumentKeohane v. InchLegal DocumentsPlaintiff's Reply in Support of Motion for Preliminary InjunctionDate Filed: 10/06/2016
Court: District Court (N.D. Fla.)
Download Document -
08/15/2016
Keohane v. Jones - Complaint -
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11/02/2016
Defendant Dieguez's Answer -
11/02/2016
Defendant Jones' Answer
Keohane v. InchLegal DocumentsDefendant Dieguez's AnswerDate Filed: 11/02/2016
Court: District Court (N.D. Fla.)
Download DocumentKeohane v. InchLegal DocumentsDefendant Jones' AnswerDate Filed: 11/02/2016
Court: District Court (N.D. Fla.)
Download Document -
11/02/2016
Date Filed: 08/22/2018
Court: District Court (N.D. Fla.)
Download DocumentDate Filed: 06/12/2017
Court: District Court (N.D. Fla.)
Download DocumentDate Filed: 07/05/2017
Court: District Court (N.D. Fla.)
Download DocumentDate Filed: 09/12/2016
Court: District Court (N.D. Fla.)
Download DocumentDate Filed: 09/12/2016
Court: District Court (N.D. Fla.)
Download DocumentDate Filed: 08/15/2016
Court: District Court (N.D. Fla.)
Download DocumentPress Releases
ACLU Sues Florida Prison Officials over Refusal to Recognize, Provide Medical Treatment to Transgender Woman