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The letter, which was sent to the president of the American Academy of Pediatrics, attempts to use consumer protection laws to make it against the law to support puberty blockers.
On Tuesday, a group of 22 Republican attorneys general, led by Idaho Attorney General Raúl Labrador, sent a letter to the president and vice president of the American Academy of Pediatrics, accusing the organization of violating consumer protection laws by endorsing the use of puberty blockers. The letter also demands answers to 14 probing questions and extensive access to internal documents. While the letter carries no legal authority, states have increasingly used vague and broad consumer protection laws to investigate the records of gender-affirming care and abortion providers, often with little to no judicial oversight.
The letter, bearing the seal of the Idaho Attorney General's office, seeks to prohibit the American Academy of Pediatrics (AAP) from endorsing puberty blockers as a form of reversible gender-affirming care for transgender teenagers, using consumer protection laws as the basis. "Statements made by medical trade organizations, like the AAP, are subject to state consumer protection laws… misleading and deceptive statements of medical trade associations are connected to commerce and reach consumers," the letter states, asserting the authority of Republican-controlled states to challenge the AAP’s endorsement of puberty blockers and justify extensive investigations into the organization's documents.
The letter leans on flawed science and previous hit pieces from far-right, anti-transgender think tanks that have struggled to gain credibility in scientific and medical communities. It criticizes the organization for describing puberty blockers as “reversible,” a stance supported by several medical and scientific organizations, backed by studies, and decades of use in treating precocious puberty and other conditions. A review by the Sax Institute found that “two systematic reviews reported that puberty suppression treatment is reversible,” and that the treatment is “effective, safe, well tolerated, and reversible.”
The letter heavily references the Cass Review. On the second page, for example, it asserts that the claim puberty blockers are reversible is false, “beyond medical debate.” To support this assertion, it cites the Cass Review, which identifies several "possible" irreversible consequences, such as interference with neurocognitive development, bone density, and “blocking normal pubertal experience and experimentation.”
These claims, however, are not well-supported by evidence. For instance, the assertion regarding neurocognitive development in the Cass Review is entirely speculative. In contrast, the Sax Review found that transgender youth who received gender-affirming hormone therapy demonstrated better cognitive development compared to those who did not, meaning that gender affirming care actually improved the cognitive development for many trans youth through a reduction in negative psychological symptoms. It likewise states that one study making this assertion did not control for ASD and anxiety, which have proven impacts on cognitive development. Other studies on brain development primarily focus on sheep or on youth experiencing precocious puberty.
Similarly, bone density concerns are frequently cited to justify bans on puberty blockers. However, the Sax Review notes that bone density reductions are “within one standard deviation of normal,” and that bone density is restored once puberty resumes. Additionally, most youth in the studies showing bone density reductions were deficient in vitamin D, according to the Sax Review. This is why the informed consent form for puberty blockers addresses this risk and its mitigation, stating, “It is important that patients on Lupron Depot® take other measures to protect their bones: keeping active and ensuring good calcium and Vitamin D intake.”
The final claim, that puberty blockers “block normal pubertal experience and experimentation,” is also entirely speculative. Advocates of this position often highlight the high rate of continuation onto gender-affirming hormone therapy (as does the letter itself). However, this could be viewed as evidence of effective treatment protocols rather than evidence of “blocked sexual or identity development,” especially considering the low detransition rates among youth who proceed with hormone therapy.
The letter extensively cites far-right think tanks, fringe journal articles, and even the New York Times to support its argument that the AAP should not endorse puberty blockers as being well-supported by evidence. For example, it references Leor Sapir and City Journal to make inaccurate claims about detransition rates. City Journal, notably, is a conservative online publication operated by the Manhattan Institute—an organization that has received a significant grant from a billionaire donor to oppose transgender care. The letter also draws on the misleading WPATH Files, anti-trans expert Steven Levine, and articles in the New York Times by Azeen Ghorayshi.
After threatening that the AAP could face prosecution for supporting gender-affirming care for transgender youth, the letter demands answers to 14 probing questions. These include requests for all internal communications regarding the WPATH Standards of Care, any communications with the Biden administration about transgender care, and all drafts of its public statements. The letter also asks why the AAP "continues to cite the standards of care released by WPATH even after the release of the WPATH Files," a highly editorialized and misleading document that contains 216 instances of errors and misrepresentations.
While these probing questions do not carry legal authority, many of the state attorneys general could use consumer protection laws to attempt to seize records under a more formal process. This tactic has already been employed to target transgender care in Texas and Missouri, as well as demands targeting Planned Parenthood records. The use of civil investigative demands under consumer protection laws has been controversial, as they do not require the same level of judicial oversight. If the AAP refuses to respond, the attorneys general could threaten lawsuits across multiple states, potentially bankrupting the children’s medical organization in legal fees simply for supporting transgender youth.
The AAP has not yet released a statement on the demands and whether or not it will comply.
This article originally appeared on Erin in the Morning.
