“Confirmed Judges, Confirmed Fears” is a blog series documenting the harmful impact of President Trump’s judges on Americans’ rights and liberties. It includes judges nominated in both his first and second terms.
Trump Second Circuit Judge Michael Park wrote a 2-1 decision, joined by Trump judge Richard Sullivan, that reversed a lower court and directed summary judgment for prison officials based on qualified immunity against a transgender prisoner’s claim that she failed to receive minimally adequate care for gender dysphoria. Biden judge Beth Robinson strongly dissented from the October 2025 ruling in Clark v Valletta.
What happened in this case?
Veronica May Clark is a transgender prisoner in Connecticut. She contended that she did not receive even minimally adequate medical treatment for gender dysphoria and related conditions. She filed suit against prison officials, who sought qualified immunity and summary judgment against her. The district judge, Judge Vanessa Bryant who was nominated by George W Bush, denied the officials’ motion. Based on the record, she found that the defendant officials had violated Clark’s right to be free from deliberate indifference to serious medical needs and that qualified immunity did not apply.
Prison officials appealed to the Second Circuit, contending that the case against them should be dismissed based on qualified immunity.
How did Trump judges Park and Sulllivan rule and why is the Second Circuit majority holding harmful?
In a 2-1 decision, Trump Judge Park, joined by Trump Judge Sullivan, reversed Judge Bryant and directed that the case should be dismissed on summary judgment based on qualified immunity. They claimed that no “clearly established right” had been violated and that “reasonable officers could disagree” concerning what treatment should be given to Clark.
Judge Robinson strongly dissented. She explained that the case had arisen from the officials’ failure to “facilitate any treatment” at all for Clark’s “serious medical condition” for thirteen months, despite her “evident anguish,” and one of the officials’ later failure to comply with an endocrinologist’s treatment plan for another 30 months “despite clear evidence of Clark’s distress.” The majority, Robinson wrote, was ignoring the clear distinction in the case law between challenges to prison medical providers’ “considered medical judgments” and to “blanket policies” as in this case that are “inconsistent with medical standards of care and wholesale failures to comply” with adequate treatment plans.
In addition to the harm caused to Veronica Clark, Judge Robinson explained the wider damage done by the decision by Trump judges Park and Sullivan. The majority had “created a rule”, she explained, that “shields prison officials from denying medical treatment” to prisoners unless and until courts have “specifically concluded” that a particular prisoner “has a right to that specific treatment for that specific serious medical condition.” This requirement, she went on, contradicts guidance from the Supreme Court as well as appellate courts and improperly “transforms’ qualified immunity into absolute immunity.” The majority’s approach is also “damaging,” Judge Robinson explained, because it “makes it even more difficult for incarcerated individuals to access the medical care they are constitutionally entitled to; and paves the way for correctional facilities to deny care to an already marginalized community.” In addition, the ruling in this case illustrates the importance of our federal courts to health, welfare and justice and the significance of having fair-minded judges on the federal bench.