Transsexual prisoners are caught in something of a Catch-22. Access to adequate treatments -- therapy, hormones, or surgery -- often require asserting a medical need the denial of which would trigger an Eighth Amendment bar against cruel and unusual punishment. Transsexual advocates, however, cringe at this reliance upon the medical model, sensing with good reason that its use, among other problems, creates and perpetuates "an image of trans people as mentally diseased or somehow ill-fitted to participate in 'normal' society." The author argues that medical evidence is not an illegitimate strategy, but is rather "both justified and compelled by unique aspects of the prison context.... [As] long as courts adhere to the general principle that individual liberties should be restricted in prison and as long as they continue to construe this principle to require the Eighth Amendment's high standard of objective seriousness, then trans advocates will have to demonstrate that the care they are requesting is indeed serious and necessary and not merely preventive or elective. It follows, of course, that the best way to make such demonstrations is through the use of medical evidence." While conceding that, outside that limited venue other kinds of arguments may serve better, he stops short of marking a course that would keep these independent lines of argument from undermining one another, always a potential danger.