In 2023, Tennessee joined the growing number of States restricting sex
transition treatments for minors by enacting the Prohibition on Medi-
cal Procedures Performed on Minors Related to Sexual Identity, Sen-
ate Bill 1 (SB1). SB1 prohibits healthcare providers from prescribing,
administering, or dispensing puberty blockers or hormones to any mi-
nor for the purpose of (1) enabling the minor to identify with, or live
as, a purported identity inconsistent with the minor’s biological sex, or
(2) treating purported discomfort or distress from a discordance be-
tween the minor’s biological sex and asserted identity. At the same
time, SB1 permits a healthcare provider to administer puberty block-
ers or hormones to treat a minor’s congenital defect, precocious pu-
berty, disease, or physical injury.
Three transgender minors, their parents, and a doctor challenged
SB1 under the Equal Protection Clause of the Fourteenth Amendment.
The District Court partially enjoined SB1, finding that transgender
individuals constitute a quasi-suspect class, that SB1 discriminates on
the basis of sex and transgender status, and that SB1 was unlikely to
survive intermediate scrutiny. The Sixth Circuit reversed, holding
that the law did not trigger heightened scrutiny and satisfied rational
basis review. This Court granted certiorari to decide whether SB1 vi-
olates the Equal Protection Clause.
Held: Tennessee’s law prohibiting certain medical treatments for
transgender minors is not subject to heightened scrutiny under the
Equal Protection Clause of the Fourteenth Amendment and satisfies
rational basis review. Pp. 8–24.
(a) SB1 is not subject to heightened scrutiny because it does not clas-
sify on any bases that warrant heightened review. Pp. 9–21.
Source: 23-477 United States v. Skrmetti (06/18/2025) – 23-477_2cp3.pdf
