69 .Plaintiff Nadia Romero (“Nadia”) is a female offender currently incarcerated in Central California Women’s Facility. Nadia is a survivor of severe sexual and physical abuse beginning in childhood. Nadia has a history of anxiety, depression, and substance abuse. Sharing a housing unit with men has led to Nadia experiencing panic attacks, insomnia, and self-harm ideation. Nadia filed a grievance describing an incident where she was grabbed by a man in her unit informing the prison of her heightened risk of rape and violence from male offenders; the prison’s response referred to men in her unit as “transgender females.” Nadia does not believe that sex is determined by a person’s internal identity. Nadia is a Catholic whose faith is deeply important to her, and whose religious practice is impaired by being placed in an intimate setting with unrelated men.
Plaintiff Krystal Gonzalez (“Krystal”) is a female offender currently incarcerated in Central California Women’s Facility. Krystal was sexually assaulted by a man transferred to her unit under S.B. 132. Krystal filed a grievance and requested single-sex housing away from men; the prison’s response to Krystal’s grievance referred to her assault by a “transgender woman with a penis.” Krystal does not believe that women have penises, and she the psychological distress caused by her assault is exacerbated by the prison’s refusal to acknowledge the sex of her perpetrator.
Plaintiff Janine Chandler (“Janine”) is a female offender currently incarcerated in Central California Women’s Facility. Janine is an observant Muslim whose right to privacy and right to exercise her religion are both violated when she is housed in facilities with men. She is also a survivor of domestic violence.
STOP DEFENDING THE RIGHTS OF MEN TO RAPE AND VIOLATE WOMENS PRIVACY’S AND RELIGION