The amended complaint adds two additional plaintiffs and three more years of evidence of the failure of prison “self-ID” policies like SB 132

WoLF’s amended complaint in the case of Chandler v. CDCR details years of abuse and trauma in California women’s prisons following the implementation of a 2020 law that allows male offenders, including rapists, to “self-identify” into being housed with female prisoners.  The new filing includes detailed evidence of harm caused to women under this law, including violations of the First, Eighth, and Fourteenth Amendments. 

This complaint, filed on July 19 2024, also introduces two additional plaintiffs to the case — Channel Johnson and Cathleen Quinn, both of whom were victimized by men transferred under SB 132. They join the four original plaintiffs: Janine Chandler, Krystal Gonzalez, Tomiekia Johnson, and Nadia Romero.

Read the full amended complaint here 

Case Background

In 2020, California Governor Gavin Newsom signed Senate Bill 132 (SB 132) into law. This legislation, which went into effect in January of 2021 as the “Transgender Respect, Agency, and Dignity Act.” This law allows men to “self-identify” as transgender,  nonbinary, or intersex and be housed in women’s facilities.

Women’s Liberation Front (WoLF) filed a lawsuit in 2021 on behalf of four incarcerated women challenging SB132. WoLF asked the court to overturn this law and declare it unconstitutional. The full case background and information on our four plaintiffs is available here.

In May of 2024, the judge granted the state’s Motion to Dismiss on procedural grounds, giving us leave to amend the complaint. Today’s submission is that amended complaint.

Amended Complaint

The First Amended Complaint, submitted today, addresses procedural questions raised by the Judge, and provides more detail into the direct harm caused to our plaintiffs under SB 132. 

“S.B. 132 expressly seeks to protect the “agency” and “dignity” of inmates who identify as “transgender, nonbinary, or intersex” but does so by removing the agency and dignity of biological female inmates, forcing them to live with biological males, and subjecting them to legitimate risk of sexual assault, physical violence, and other emotional trauma that comes as a natural consequence of having been victims of prior abuse.” (pg. 8)

One critical piece of information that has come out is that the California Department of Corrections and Rehabilitations (CDCR) knew that there would be an increased risk to female prisoners by the implementation of SB 132. In a budget request form from early 2021, CDCR stated:

“The CDCR expects the PREA sexual assault allegations to increase as S.B. 132 is implemented “because it will result in the integration of different populations that have not previously been housed together.”” (pg. 10)

We also dive deeper into the harm caused to Janine, Nadia, Tomiekia, Krystal, and two new plaintiifs, laying out in detail the Constitutional violations they each experienced. 

Krystal

“Krystal was sexually assaulted by a trans-identifying biological male inmate transferred to her housing unit. This male inmate thrusted his penis against Krystal’s backside without her consent.…  CCWF ultimately ignored her grievance but did note that Krystal had been assaulted by a “transgender woman with a penis.” (pg.15)

Nadia

“Nadia was repeatedly subjected to unwanted physical touching by a trans-identifying biological male inmate while Nadia was trying to complete a work assignment. She attempted to get the male inmate to stop, but he refused… Nadia’s multiple harmful experiences with a trans-identifying biological male inmate has made her hyperventilate and suffer panic attacks when in proximity to any transidentifying biological male inmate. Since CCWF has placed numerous trans-identifying biological male inmates in the prison, these symptoms erupt constantly. Nadia has also reported feelings of helplessness, despair, anxiety, and depression” (pg. 16-17)

Janine

“Her inability to choose who she undresses around and helplessness to prevent trans-identifying biological male inmates from observing her while she undresses is extremely distressing to Janine. Janine is a Muslim whose faith instructs her to not be unclothed with unrelated males. CCWF is forcing Janine to live in conditions that violate her sincerely held religious beliefs.” (pg.15)

Tomiekia

“Tomiekia continues to be subject to ongoing retaliation from CCWF. CCWF continues to discriminate against Tomiekia for filing grievances and reporting the assault. CCWF has even cited her constitutionally protected right to participate in this lawsuit as proof that she holds bias against trans-identifying biological male inmates. Most disturbingly, despite having consistently met or even exceeded the criteria for re-sentencing or commutation, Tomiekia has been told she is being denied parole for “political reasons.”” (pg. 19)

New Plaintiffs

WoLF introduced two new plaintiffs to this case, Channel Johnson and Cathleen Quinn, in addition to our four existing plaintiffs.

Channel Johnson

Channel was sexually trafficked from the age of 13 until she was incarcerated. After terminating a relationship with Jonathan Robertson, a male offender housed in CCWF under SB 132, he sent threatening messages to Channel and her family members. 

“Channel Johnson was assigned to a cell with a trans-identifying male inmate, Jonathan Robertson… Robertson threatened to rape and murder her. He also stole Channel’s mail, read her family’s home address, and began mailing threats of rape and murder to her family—including her minor younger brother and nephew.” (pg. 17-18)

Cathleen Quinn

Cathleen was up for parole when she was sexually harassed in multiple incidents by a man who watched her while she used the bathroom. 

“The month after she reported Contreras for looking at her while she was half-naked, Cathleen was found suitable for parole… But shortly after she was found suitable for parole, CCWF issued a retaliatory Rules Violation Report (“RVR”) against Cathleen, leading to her parole grant being vacated. At the time of the revocation, she was roughly four months away from freedom.” (pg.17, #73)

Two Law Firms Join WoLF’s Groundbreaking Case

Dhillon Law Group

The Dhillon Law Group, led by Harmeet Dhillon, has joined the case as co-counsel for California. The Dhillon Law Group is a national law firm focusing on Constitutional and business law including First Amendment litigation.

Campbell Miller Payne

Also joining as co-counsel is Campbell Miller Payne (CMP), a Dallas-based law firm representing detransitioners nationwide in cases holding the gender medicine industry accountable for their harm to children and vulnerable populations.

Support our work!

WoLF is the only feminist organization bringing lawsuits to overturn bills like SB 132. We rely entirely on our generous donors to make this resource-intensive legal work possible.

Please consider donating just today to support this case and the brave women fighting for their rights inside California’s prisons! Amounts as small as $5 or $25 make a difference!

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