COLE ROBINSON, et al. v. RAUL LABRADOR, et al.

Summary

The United States District Court for the District of Idaho granted Plaintiffs’ seventh motion for a preliminary injunction in a putative class action challenging Idaho Code § 18-8901 as applied to incarcerated individuals receiving hormone therapy. The court concluded that Plaintiffs continued to present a serious question regarding their Eighth Amendment claims, faced irreparable harm, and satisfied the balance-of-equities, public-interest, and Prison Litigation Reform Act requirements. The injunction prohibits enforcement of the statute’s prohibition on using state funds to provide hormone therapy to the certified class for 90 days beginning March 2, 2026.

Holdings

1. Plaintiffs continued to present a serious question as to whether enforcing Idaho Code § 18-8901 to deny hormone therapy to eligible incarcerated persons with gender dysphoria violates the Eighth Amendment.
2. Plaintiffs satisfied the preliminary-injunction requirements because they presented a serious question on the merits, showed likely irreparable physiological and psychological harm, and established that the balance of equities and public interest favored continued relief.
3. The court could issue a successive preliminary injunction after the prior preliminary injunction expired; it could not merely extend the initial injunction without making the relief final.
4. The seventh preliminary injunction satisfied the PLRA because it was narrowly drawn, extended no further than necessary, and used the least intrusive means necessary to protect the class members' rights.

Questions Presented

1. Whether plaintiffs continued to raise a serious question going to the merits of their Eighth Amendment challenge to Idaho Code § 18-8901.
2. Whether plaintiffs showed likely irreparable harm, a favorable balance of equities, and that a preliminary injunction would serve the public interest.
3. Whether the Prison Litigation Reform Act permitted the court to issue a successive preliminary injunction after the prior injunction expired and whether the continued relief satisfied the PLRA's needs-narrowness-intrusiveness requirements.

Disposition

other