A Missouri transgender women is suing the Missouri Department of Corrections and Corizon LCC, which contracts with the MDOC to provide medical care at its various facilities, over their refusal to allow her access to medically necessary care to treat her gender dysphoria.

On Tuesday, Lambda Legal asked a federal court to issue an injunction that allows Jessica Hicklin, a 38-year-old inmate at the Potosi Correctional Center in Mineral Point, Mo., to receive hormone therapy, access to permanent body hair removal, and gender-affirming canteen items, and prevents the Missouri Department of Corrections from enforcing its “freeze-frame” policy that bars her from accessing those things, which her doctors have said is essential to treating her gender dysphoria.

Under the “freeze-frame” policy, inmates and others in custody who have been diagnosed with gender dysphoria are unable to receive treatment if they were not already receiving such treatment prior to their incarceration. A number of federal courts have found that such policies violate the Eighth Amendment’s prohibition on cruel and unusual punishment.

In a legal brief filed with the court, Lambda Legal, which is representing Hicklin, argues that her motion for a preliminary injunction meets all the requirements that should be considered: that denying the treatment can cause her “irreparable harm,” that she is likely to succeed in her lawsuit alleging that the “freeze-frame” policy violates her Eighth Amendment rights, and that preventing the Missouri Department of Corrections from enforcing the policy serves the public interest.

“Defendants’ own doctors have documented the serious harms that Ms. Hicklin has suffered and will continue to suffer without medical treatment in accordance with the prevailing Standards of Care. Ms. Hicklin already suffers from depression, anxiety, and intrusive thoughts of self-castration as a result of Defendants’ conduct and it will only worsen with time,” the brief reads.

“Ms. Hicklin has established both a serious medical need — serious psychological and physical symptoms of distress from untreated gender dysphoria — and a substantial risk of future serious harm — continued anguish, auto-castration, and possibly suicide — if her medically necessary treatment continues to be withheld,” the brief continues. “Courts, including the Eighth Circuit, have routinely held that gender dysphoria is a serious medical need. There is no question that Ms. Hicklin has persistent and well-documented gender dysphoria that requires treatment, and therefore, meets the requirement that her medical need is objectively serious.”

Lastly, Hicklin’s lawyers argue, issuing the injunction would serve the public interest by protecting other transgender inmates from being denied medically necessary care under the “freeze-frame” policy.

“Defying the recommendations of mental health and medical experts, the Missouri Department of Corrections is denying Jessica Hicklin critical and potentially life-saving care,” Demoya Gordon, Transgender Rights Project Attorney for Lambda Legal, said in a statement. “The policies behind this cruel decision, including MDOC’s ‘freeze-frame’ policy, are discriminatory and unconstitutional and must end immediately.

“By continuing to deny Ms. Hicklin medically necessary treatment, Defendants are putting her at serious risk of permanent harm,” Gordon continued. “Their ‘freeze-frame’ policy serves no other purpose than to single out transgender people for discrimination.”