Talbott v. Trump

District Court, District of Columbia·Decided March 26, 2025·No. Civil Action No. 2025-0240·Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

NICOLAS TALBOTT, et al, Plaintiffs,

v.

Civil Action No. 25-cv-00240 (ACR)

UNITED STATES, et al, Defendants.

MEMORANDUM OPINION AND ORDER Defendants ask the Court to dissolve, or stay pending appeal, the preliminary injunction it entered on March 18, 2025.1 Dkt. 91 (Motion to Dissolve (Mot.)). They claim that a newly- issued guidance document—the Military Department Identification Guidance, Dkt. 91-2 (MDI Guidance)—presents a significant change in fact. Id. at 3. This change, they contend, shows that the Court’s Preliminary Injunction Opinion (Op.) is incorrect. Id.

The MDI Guidance is new, but Defendants’ argument is not. Defendants re-emphasize their “consistent position that the [Hegseth] Policy is concerned with the military readiness, deployability, and costs associated with a medical condition.” Id. (emphasis added). Regulating gender dysphoria is no different than regulating bipolar disorder, eating disorders, or suicidality. The Military Ban regulates a medical condition, they insist, not people.

And therein lies the problem. Gender dysphoria is not like other medical conditions, something Defendants well know. It affects only one group of people: all persons with gender

1 The Court assumes the reader is familiar with its March 18, 2025 Opinion. For those who are not, it is available on the public court docket at 25-cv-00240, Dkt. 89. The Court recycles here the defined terms it used in the Opinion.

dysphoria are transgender and only transgender persons experience gender dysphoria. Defs. Concession Tr. (Mar. 21, 2025) at 23–24. Does this mean that all transgender persons have gender dysphoria? No, of course not. But it does mean that when Defendants regulate gender dysphoria, they knowingly and necessarily regulate only transgender persons.

Defendants try to obfuscate this key point at every turn. The Department of Defense (DoD) and Secretary of Defense publicly announced that the Military Ban disqualifies all “transgender troops”? No, they were using “shorthand” for gender dysphoria. Defendants accused transgender persons of inherently lacking honor, truthfulness, and discipline? No, they accused gender dysphoria of having those mission-endangering attributes. The military plans to discharge thousands of transgender troops who have made “America safer”? No, the military plans to discharge gender dysphoria. Total coincidence that gender dysphoria only afflicts transgender people.

This litigation is not about a medical condition. A medical condition has not given its country decades of military service. Or deployed into combat zones throughout the globe. Or earned countless commendations. People have. A medical condition has not fought terrorism. Or analyzed intelligence. Or commanded platoons. People have. A medical condition has not been accused of lacking warrior ethos. Or been branded dishonorable, dishonest, and undisciplined. Or been threatened with the loss of livelihood. People have. Transgender people.

Defendants’ arguments did not sway the Court before; regurgitating them with the MDI Guidance is equally unpersuasive. The Court DENIES the Motion to Dissolve the Preliminary Injunction and Motion for a Stay Pending Appeal. The Court, on its own motion, stays its Order, Dkt. 88, until March 28, 2025, at 7:00 pm eastern to provide Defendants the opportunity to file an emergency stay with the D.C. Circuit.

BACKGROUND

On March 18, 2025, the Court granted Plaintiffs’ Renewed Application for Preliminary Injunction, Dkt. 72, and enjoined Defendants from implementing Executive Order No. 14183 and the Additional Guidance on Prioritizing Military Excellence and Readiness, Dkt. 63-1, as well as any other policies issued pursuant to the Military Ban. Dkts. 88, 89. Three days later, Defendants filed a Motion to Dissolve the Preliminary Injunction. Dkt. 91. They argue that the MDI Guidance issued by DoD’s Office of the Under Secretary of Defense for Personnel and Readiness on March 21, 2025 constitutes a “significant change either in factual conditions or in law.” Mot. at 3 (quoting Horne v. Flores, 557 U.S. 433, 447 (2009)).

Defendants claim that “the [Hegseth] Policy presumptively barring individuals from serving in the military turns on gender dysphoria—a medical condition—and does not discriminate against trans-identifying persons as a class.” Id. at 2. In support, Defendants cite to the MDI Guidance. See id. at 3.

In the MDI Guidance, Defendants define—for the first time—the criteria in the Hegseth Policy, “exhibit symptoms consistent with gender dysphoria.”2 MDI Guidance at 1. In a footnote, the MDI Guidance states that the phrase “refers to the diagnostic criteria outlined in the Diagnostic and Statistical Manual of Mental [(DSM-V)] Disorders” for gender dysphoria and “applies only to individuals who exhibit such symptoms as would be sufficient to constitute a diagnosis (i.e., a marked incongruence and clinically significant distress or impairment for at least 6 months).” Id. The MDI Guidance attaches the DSM-V criteria. Dkt. 92-2.

2 To avoid wordiness, the Court refers to this phrase as “the Symptoms Criteria.” Because Defendants’ Motion concerns the definition of this phrase, the Court only includes the additional criteria “current diagnosis or history of gender dysphoria,” as necessary.

The MDI Guidance explains that the “primary means” military leaders will use to identify servicemembers who meet the Symptoms Criteria “will be through reviewing medical records.” MDI Guidance at 1. To this effect, the MDI Guidance reminds the Secretaries of each Military Department of their “authority to direct unit commanders, in coordination with supporting medical assets, to require that all Service members comply with their obligations.” Id. at 2. Service members must complete a Periodic Health Assessment (PHA) and report any “medical issues . . . that may affect their readiness to deploy, ability to perform their assigned mission, or fitness for retention in military service to their chain of command.” Id.

Moreover, “[w]ithin 45 days” of March 21, 2025, each servicemember’s reporting responsibilities will include attesting “whether they have a current diagnosis or history of, or exhibit symptoms consistent with, gender dysphoria.” Id. “This attestation will be a standard part of the self-assessment done in conjunction with the annual PHA.” Id. If a servicemember self-reports, “the facility or location conducting the PHA will be responsible for conducting or coordinating any follow-up medical evaluation, if necessary, and for notifying the Service member’s command.” Id. Each identified service member “must be categorized as ‘Not Medically Ready’ and non-deployable.” Id. (emphasis added). They will be, consistent with new policies enacted by the Military Ban, “recommended for administrative separation or, where appropriate, enrolled in the Disability Evaluation system (e.g., where a co-morbidity or other qualifying condition is present).” Id.

Defendants contend that this new guidance “confirms that the Court has misconstrued the scope of the DoD Policy,” and they “move to dissolve the March 18, 2025, preliminary injunction.” Mot. at 2–3. In the alternative, they ask the Court to stay its Order pending appellate review. Id. at 3–4.

STANDARD OF REVIEW

A party seeking to dissolve a preliminary injunction must show “‘a significant change either in factual conditions or in law’” that makes continued enforcement of the injunction “‘detrimental to the public interest.’” Doe 2 v. Shanahan, 755 F. App’x 19, 22 (D.C. Cir. 2019) (quoting Horne, 557 U.S. at 447). The moving party “bears the burden of establishing that changed circumstances warrant relief.” Am. Council of the Blind. v. Mnuchin, 878 F.3d 360, 366 (D.C. Cir. 2017) (cleaned up).

ANALYSIS

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