being indefinitely taken off hormone therapy. The authors wrote: "withdrawal of therapy was also associated with adverse symptoms in 60 of the 86 transsexuals. Rebound androgenization, hot flashes, moodiness, and irritability or depression were the most frequent complaints." At the time, no right to access gender appropriate care existed in California state prisons. According to the Vera Institute, 16% of trans adults in the US have been incarcerated, compared to 2.7% of cis adults, and trans people make up 59% of prison sexual assault victims. In September 2011, a California state court denied the request of a California inmate, Lyralisa Stevens, for sex reassignment surgery at the state's expense. On January 17, 2014, in Kosilek v. Spencer a three-judge panel of the First Circuit Court of Appeals ordered the Massachusetts Department of Corrections to provide Michelle Kosilek, a Massachusetts inmate, with sex reassignment surgery. It said denying the surgery violated Kosilek's Eighth Amendment rights, which included "receiving medically necessary treatment ... even if that treatment strikes some as odd or unorthodox". On April 3, 2015, the U.S. Department of Justice intervened in a federal lawsuit filed in Georgia to argue that denying hormone treatment for transgender inmates violates their rights. It contended that the state's policy that only allows for continuing treatments begun before incarceration was insufficient and that inmate treatment needs to be based on ongoing assessments. The case was brought by Ashley Diamond, an inmate who had used hormone treatment for seventeen years before entering the Georgia prison system. On May 11, 2018, the US Bureau of Prisons announced that prison guidelines issued by the Obama Administration in January 2017 to allow transgender prisoners to be transferred to prisons housing inmates of the gender which they identify with had been rescinded and that assigned sex at birth would once again determine where transgender prisoners are jailed. In August 2022, a federal judge in Nebraska ruled against a transgender woman that'd been denied gender affirming care in prison, and placed in a cell with a male sex offender that proceeded to sexually assault her. In his ruling, the judge declared there to be insufficient evidence of deliberate indifference on the prison's part to the plaintiff's gender dysphoria, and that the plaintiff hadn't sufficiently proven that she'd suffered more than minimal injuries from the sexual assault, stating that he found no support for the notion that a substantial risk of