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Hormone Therapy Case: 3:17-cv-00264-wmc Document #: 123 Filed: 06/29/18 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN ALINA BOYDEN and SHANNON ANDREWS, Plaintiffs, v. Case No. 17-CV-0264 STATE OF WISCONSIN DEPARTMENT OF EMPLOYEE TRUST FUNDS, et al., Defendants. SUPPLEMENTAL DECLARATION OF COLIN ROTH IN SUPPORT OF OPPOSITION TO PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT I, COLIN ROTH, pursuant to 28 U.S.C. § 1746, declare as follows: 1. I am employed as an Assistant Attorney General at the Wisconsin Department of Justice (DOJ). I am one of the attorneys for the State of Wisconsin Department of Employee Trust Funds, State of Wisconsin Group Health Insurance Board, and Robert J. Conlin in the above-captioned matter. 2. This declaration is based on my personal knowledge. 3. Attached hereto as Exhibit S is a true and correct copy of the World Professional Association for Transgender Health (WPATH) Standards of Care for the Health of Transsexual, Transgender, and Gender Nonconforming People (7th Version). I obtained these standards of care from Case: 3:17-cv-00264-wmc Document #: 123 Filed: 06/29/18 Page 2 of 5 WPATH’s website, www.wpath.org, where these were presented as the most recent version of the standards of care. 4. Attached hereto as Exhibit T is a true and correct copy of Exhibit 7 to the deposition of Tara S. Pray, Dkt. 69. 5. Attached hereto as Exhibit U is a true and correct PDF copy of a letter entitled Dear Colleague Letter on Transgender Students dated May 13, 2016, issued by the U.S. Department of Justice, Civil Rights Division, and U.S. Department of Education, Office for Civil Rights. I obtained this document from the U.S. Department of Education website, https://www2.ed.gov/about/offices/list/ocr/letters/colleague-201605-title-ix- transgender.pdf. 6. Attached hereto as Exhibit V is a true and correct PDF copy of what appears on the “Know Your Rights: Transgender People and the Law” page, which is a link on the ACLU’s website found at, https://www.aclu.org/know-your-rights/transgender-people-and-law. 7. Attached hereto as Exhibit W is a true and correct PDF copy of what appears on the “National Equality Map” page, which is a link on the Transgender Law Center website found at, https://transgenderlawcenter.org/equalitymap. 2 Case: 3:17-cv-00264-wmc Document #: 123 Filed: 06/29/18 Page 3 of 5 8. Attached hereto as Exhibit X is a true and correct PDF copy of the Wikipedia entry entitled, Transgender rights in the United States. I obtained this document from Wikipedia’s website, https://en.wikipedia.org/wiki/Transgender_rights_in_the_United_States. 9. Attached hereto as Exhibit Y is a true and correct PDF copy of the “Values” page, which is a link on the Transgender Law Center website, found at https://transgenderlawcenter.org. 10. Attached hereto as Exhibit Z is a true and correct PDF copy of the “About Us” page, which is a link on the National Center for Transgender Equality website, found at https://transequality.org. 11. Attached hereto as Exhibit AA is a true and correct PDF copy of the “LGBT Rights” page, which is a link on the ACLU website, found at https://www.aclu.org/issues/lgbt-rights. 12. Attached hereto as Exhibit BB is a true and correct PDF copy of the “About Us–History” page, which is a link on the Lambda Legal website, found at https://www.lambdalegal.org. 13. Attached hereto as Exhibit CC is a true and correct PDF copy of homepage for the Movement Advancement Project website, found at http://www.lgbtmap.org. 3 Case: 3:17-cv-00264-wmc Document #: 123 Filed: 06/29/18 Page 4 of 5 14. Attached hereto as Exhibit DD is a true and correct PDF copy of an online opinion editorial in The New York Times entitled, Trump’s Heartless Transgender Military Ban Gets a Second Shot, NY Times (Mar. 28, 2018), found at https://www.nytimes.com/2018/03/28/opinion/trump- transgender-military- ban.html?rref=collection%2Ftimestopic%2FTransgender%20issues&action=cl ick&contentCollection=timestopics&region=stream&module=stream_unit&ve rsion=latest&contentPlacement=28&pgtype=collection. 15. Attached hereto as Exhibit EE is a true and correct PDF copy of an online opinion editorial in the Washington Post entitled, Trump’s transgender troop ban is as insidious as ever, Wash. Post (Mar. 28, 2018), found at https://www.washingtonpost.com/opinions/trumps-transgender- troop-ban-is-as-insidious-as-ever/2018/03/28/773283be-32b6-11e8-8abc- 22a366b72f2d_story.html?utm_term=.c6ff0fb7dd0b. 16. Attached hereto as Exhibit FF is a true and correct PDF copy of an online editorial in the Los Angeles Times entitled, Time for transgender rights opponents to give up the fight, L.A. Times (Dec. 27, 2015), found at http://www.latimes.com/opinion/editorials/la-ed-transgender-ballot-initiative- 20151227-story.html. Online comments at the end of this editorial are excluded from this copy. 4 Case: 3:17-cv-00264-wmc Document #: 123 Filed: 06/29/18 Page 5 of 5 17. Attached hereto as Exhibit GG is a true and correct copy of Pages 1–2 of the Federal Register, Vol. 81, No. 96, May 18, 2016, Part IV, Dept. of Health and Human Services, Office of the Secretary, which is found on the U.S. Government Publishing Office website at https://www.gpo.gov/fdsys/pkg/FR-2016-05-18/pdf/2016-11458.pdf. I declare under penalty of perjury that the forgoing is true and correct. Executed on the 29th day of June, 2018. s/ Colin T. Roth COLIN ROTH 5 Case: 3:17-cv-00264-wmc Document #: 123-1 Filed: 06/29/18 Page 1 of 120 www.wpath.org Standards of Care for the Health of Transsexual, Transgender, and Gender Nonconforming People The World Professional Association for Transgender Health 7th Version 7th Version Roth Decl. Ex. S Case: 3:17-cv-00264-wmc Document #: 123-1 Filed: 06/29/18 Page 2 of 120 Roth Decl. Ex. S Case: 3:17-cv-00264-wmc Document #: 123-1 Filed: 06/29/18 Page 3 of 120 Standards of Care for the Health of Transsexual, Transgender, and Gender Nonconforming People The World Professiona Association for Transgender Health 7th Version1 | www.wpath.org 1 This is the seventh version of the Standards of Care. The original SOC were published in 1979. Previous revisions were in 1980, 1981, 1990, 1998, and 2001. Roth Decl. Ex. S Case: 3:17-cv-00264-wmc Document #: 123-1 Filed: 06/29/18 Page 4 of 120 Roth Decl. Ex. S Case: 3:17-cv-00264-wmc Document #: 123-1 Filed: 06/29/18 Page 5 of 120 The Standards of Care 7TH VERSION Table of Contents I. Purpose and Use of the Standards of Care ......................................1 II. Global Applicability of the Standards of Care ....................................3 III. The Difference between Gender Nonconformity and Gender Dysphoria ..............4 IV. Epidemiologic Considerations ................................................6 V. Overview of Therapeutic Approaches for Gender Dysphoria ........................8 VI. Assessment and Treatment of Children and Adolescents with Gender Dysphoria .....10 VII. Mental Health ...........................................................21 VIII. Hormone Therapy ........................................................33 IX. Reproductive Health .......................................................50 X. Voice and Communication Therapy ...........................................52 XI. Surgery ..................................................................54 XII. Postoperative Care and Follow-Up ............................................64 XIII. Lifelong Preventive and Primary Care .........................................65 XIV. Applicability of the Standards of Care to People Living in Institutional Environments . .67 XV. Applicability of the Standards of Care to People With Disorders of Sex Development . .69 References .................................................................72 Appendices: A. Glossary .................................................................95 B. Overview of Medical Risks of Hormone Therapy ................................97 C. Summary of Criteria for Hormone Therapy and Surgeries ........................104 D. Evidence for Clinical Outcomes of Therapeutic Approaches ......................107 E. Development Process for the Standards of Care, Version 7 ........................109 World Professional Association for Transgender Health i Roth Decl. Ex. S Case: 3:17-cv-00264-wmc Document #: 123-1 Filed: 06/29/18 Page 6 of 120 Roth Decl. Ex. S Case: 3:17-cv-00264-wmc Document #: 123-1 Filed: 06/29/18 Page 7 of 120 The Standards of Care 7TH VERSION I Purpose and Use of the Standards of Care The World Professional Association for Transgender Health (WPATH)1 is an international, multidisciplinary, professional association whose mission is to promote evidence-based care, education, research, advocacy, public policy, and respect for transgender health. The vision of WPATH is to bring together diverse professionals dedicated to developing best practices and supportive policies worldwide that promote health, research, education, respect, dignity, and equality for transsexual, transgender, and gender nonconforming people in all cultural settings. One of the main functions of WPATH is to promote the highest standards of health care for individuals through the articulation of Standards of Care (SOC) for the Health of Transsexual, Transgender, and Gender Nonconforming People. The SOC are based on the best available science and expert professional consensus.2 Most of the research and experience in this field comes from a North American and Western European perspective; thus, adaptations of the SOC to other parts of the world are necessary. Suggestions for ways of thinking about cultural relativity and cultural competence are included in this version of the SOC. The overall goal of the SOC is to provide clinical guidance for health professionals to assist transsexual, transgender, and gender nonconforming people with safe and effective pathways to achieving lasting personal comfort with their gendered selves, in order to maximize their overall health, psychological well-being, and self-fulfillment. This assistance may include primary care, gynecologic and urologic care, reproductive options, voice and communication therapy, mental health services (e.g., assessment, counseling, psychotherapy), and hormonal and surgical treatments.
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