Williams v. Kincaid - 45 F.4th 759 (4th Cir. 2022)

Rule:

The text of the ADA does not define the term gender identity disorders and does not mention gender dysphoria at all. Thus, although the ADA specifically lists a number of exclusions from the definition of disability, that list does not include gender dysphoria. To determine whether gender identity disorders include gender dysphoria, courts must look to the meaning of the ADA's terms at the time of its enactment.

Facts:

Plaintiff, a transgender woman with gender dysphoria, spent six months incarcerated in the detention center. Though prison deputies initially assigned her to women's housing, they quickly moved her to men's housing when they learned that she was transgender. There, she experienced delays in medical treatment for her gender dysphoria, harassment by other inmates, and persistent and intentional misgendering and harassment by prison deputies. Following her release from the detention center, plaintiff filed the present § 1983 action against the Sheriff of the County, a prison deputy, and a prison nurse alleging violations of the Americans with Disabilities Act ("ADA"), the Rehabilitation Act, the United States Constitution, and state common law. The district court dismissed the case, holding that the complaint failed to state grounds for relief with respect to some claims and that the statute of limitations barred others. Plaintiff appealed. 

Issue:

Did the district court correctly dismiss plaintiff’s complaint on the basis that gender dysphoria was not an ADA disability? 

Answer:

No.

Conclusion:

The court reversed the district court’s decision. The court held that plaintiff plausibly alleged that plaintiff's gender dysphoria fell within the ADA's safe harbor for gender identity disorders that were due to physical impairments. The court noted that although the ADA specifically listed a number of exclusions from the definition of disability, that list did not include gender dysphoria.