Zyst v. Miller

Summary

The Oregon Court of Appeals reviewed habeas corpus relief sought by a transgender incarcerated person challenging the medical treatment of gender dysphoria and placement in intensive management housing. The court affirmed findings that the treatment violated constitutional prohibitions against cruel and unusual punishment and unnecessary rigor. It reversed orders concerning psychiatric care and cellmate selection because they exceeded the permissible scope of relief, while otherwise affirming the judgment and orders.

Holdings

1. The trial court did not err in finding deliberate indifference to Zyst's serious medical need because the Department of Corrections failed to provide the individualized assessment necessary to determine appropriate interventions for her gender dysphoria and followed, at least to some degree, a policy that prohibited certain interventions as cosmetic.
2. The Department of Corrections' failure to provide an individualized assessment of the interventions necessary to treat Zyst's gender dysphoria violated Article I, section 13 of the Oregon Constitution's prohibition against unnecessary rigor.
3. The psychiatric-care and cellmate orders exceeded the scope of permissible habeas relief because they were not sufficiently closely connected to promptly curing the constitutional violations identified in the case.

Questions Presented

1. Whether the Department of Corrections was deliberately indifferent to Zyst's serious medical need by failing to provide an individualized assessment and appropriate treatment for gender dysphoria.
2. Whether the Department of Corrections' treatment of Zyst's gender dysphoria violated Article I, section 13 of the Oregon Constitution's prohibition against unnecessary rigor.
3. Whether the trial court correctly applied the unnecessary-rigor standard to Zyst's placement in the Intensive Management Unit.
4. Whether the trial court's orders requiring a psychiatric evaluation and identification of an appropriate cellmate exceeded the permissible scope of habeas relief.

Disposition

reversed