Read A.G. Bondi's memo purporting to implement Trump's anti-trans attacks
The following internal memorandum, issued on April 22, 2025 by Attorney General Pam Bondi, was obtained by Law Dork and is being published here in full.
To be perfectly clear: This is a divisive, anti-transgender document. It is only, however, an internal memorandum from the attorney general — guidance implementing an earlier anti-transgender executive order from President Donald Trump that has itself already been partially enjoined in multiple courts.
Bondi’s internal memorandum is not the law, and I will be following up with analysis if time and circumstances allow.
There is, however, intense interest in the text of the memo itself after news of the memo was initially reported in a right-wing outlet, so Law Dork is publishing it as a resource for those who need it.
Office of the Attorney General
Washington, D.C. 20530
April 22, 2025
MEMORANDUM FOR SELECT COMPONENT HEADS
FROM: THE ATTORNEY GENERAL [signed, Pam Bondi]
SUBJECT: PREVENTING THE MUTILATION OF AMERICAN CHILDREN
There is a radical ideological agenda being pushed throughout every aspect of American life—from TV programming and Hollywood film production to children's books and elementary school classrooms—that teaches children to deny biological reality. Gender ideology, masked as science, teaches that children should process adolescent stress and confusion as a case of mistaken identity and that the solution is not to root out and eliminate the underlying condition but to acquiesce in it permanently through life-altering chemical and surgical intervention. That ideology, pushed by far-left politicians, celebrities, politically captured academics, and legacy media, has infected an entire generation of children, who have in turn pushed transgenderism on their peers through social media and other means. Dissenting voices are bullied into silence, and "allies" are praised and rewarded. Tragic and absurd as it is that 1.4% of 13- to 17-year-olds now identify as transgender,[1] that is the predictable result of a coordinated, unchecked ideological attack on America's children.
The medical community, with its roots in hard science, is well-positioned to serve as a bulwark against this sociological disease. And indeed, parents who are desperate to help their confused, frustrated children have understandably turned to medical professionals for help. Unfortunately, those parents have been betrayed by politically captured profiteers at every step. These "professionals" have deployed junk science and false claims about the effects of so-called "gender-affirming care" to justify the barbaric practice of surgically and chemically maiming and sterilizing children. Between 2019 and 2023, an estimated 14,000 children received "Treatment" for gender dysphoria, with more than 5,700 subjected to life-altering surgeries.[2] The practitioners who provided this so-called “care” profited while their patients were left permanently disfigured, scarred, and sterilized. Those children will struggle for the rest of their lives to overcome regret, and their parents will struggle equally to overcome the guilt of ruining their children's lives on the
1 Azeen Ghorayshi, Report Reveals Sharp Rise in Transgender Young People in the U.S., N.Y. Times (June 10, 2022), https://www.nytimes.com/2022/06/10/science/transgender-teenagers-national-survey.html.
2 Rikki Schlott, Over 5,700 American children had trans surgery between 2019 and 2023, medical group claims: 'Treated like guinea pigs,' N. Y. Post (Oct. 8, 2024), https://nypost.com/2024/10/08/us-news/over-5700-americans-under-18-had-trans-surgery-from-2019-23/.
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false and misleading advice of medical providers who told them that surgery or hormone replacement was the best solution to their problems.[3]
Consider the case of Chloe Cole, whose story, sadly, is not unique.[4] At just 11 years old, Chloe joined Instagram and was bombarded with "LGBT content and activism.”[5] She "saw how trans people online got an overwhelming amount of support," and that "really spoke to [her] because, at the time," she was just a child and "didn't really have a lot of friends of [her] own."[6] She was especially vulnerable at that age because, like many young girls, Chloe felt that her "body didn't match beauty ideals," so she "started to wonder if there was something wrong with" her, even wondering whether she would "be better off as a boy."[7] By the age of 12, Chloe identified as transgender, and she "was fast-tracked through her entire transition—from blockers to a mastectomy—in just two years."[8] "The only pushback she ... encountered came from the first endocrinologist she saw," but she bypassed that easily by going "to another doctor who gave her the prescription with no trouble.”[9] Despite the "vitriol from the transgender activist community," Chloe has bravely shared her regret with the world at just 17 years old because she simply "can't let this happen to other kids.”[10] Neither can I, and neither can President Trump.
The Biden administration bears enormous responsibility for the medical community's fraud and exploitation of parents and children who have fallen prey to radical gender ideology. President Biden personally advanced the agenda by hosting transgender activist influencers like Dylan Mulvaney at the White House,[11] opposing state-level bans on gender-affirming care for minors,[12] threatening legal action against Medicaid and Obamacare providers who fail to offer
3 See, e.g, Dr. Marc Siegel et al., Detransitioning becomes growing choice among young people after gender-affirming surgery, Fox News (Dec. 19, 2022), https://www.foxnews.com/health/detransitioning-becomes-growing-choice-young-people-gender-affirming-surgery.
4 Chloe Cole, Hearing on Gender Affirming Care before the Subcommittee on the Constitution and Limited Government of the H. Judiciary Comm., 118th Cong. (2023).
5 Rikki Schlott, '1 literally lost organs:' Why detransitioned teens regret changing genders, N.Y. Post (June 19, 2022), https://nypost.com/2022/06/18/detransitioned-teens-explain-why-they-regret-changing-genders.
6 Id.
7 Id.
8 Id.
9 Id.
10 Id.
11 Emma Colton, Biden legacy includes relentless push for transgender agenda, Fox News (Dec. 8, 2024), https://www.foxnews.com/politics/biden-legacy-includes-relentless-push-transgender-agenda.
12 Edie Heipel, In interview with trans activist. Biden condemns states banning sex changes on kids, (Oct. 24, 2022), Catholic News Agency, https://www.catholicnewsagency.com/news/252633/in-interview-with-trans-activist-biden-condemns-states-banning-sex-changes-on-kids.
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such care,[13] and appointing Rachel Levine—a leading transgender activist who personally identifies as transgender—to serve as Assistant Secretary for Health. Under Levine, the Department of Health and Human Services promoted gender-reassignment surgeries and hormone replacement for the treatment of gender dysphoria in minors[14] and pressured the World Professional Association for Transgender Health ("WPATH") to eliminate age minimums for reassignment surgeries in its 2022 guidelines.[15] All the while, NIH-funded studies admitted that "little to no empirical data" supported the long-term safety of puberty blockers and hormones, let alone sex-reassignment surgery.[16] To address the lack of scientific support for his agenda, President Biden allocated more than $8 million of taxpayer funds for transgender hormone studies on mice.[17]
President Trump has put a stop to this by issuing his executive order "Protecting Children from Chemical and Surgical Mutilation," signed to halt the exploitation enabled by misguided Biden-era policies. Pursuant to the President's directive, I am issuing the following guidance to all Department of Justice employees to enforce rigorous protections and hold accountable those who prey on vulnerable children and their parents.
I. Enforcement of Laws Outlawing Female Genital Mutilation
The Department of Justice will not sit idly by while doctors, motivated by ideology, profits, or both, exploit and mutilate our children. Under my watch, the Department will act decisively to protect our children and hold accountable those who mutilate them under the guise of care. I am putting medical practitioners, hospitals, and clinics on notice: In the United States, it is a felony to perform, attempt to perform, or conspire to perform female genital mutilation ("FGM"*) on any person under the age of 18.[18] That crime carries a maximum prison sentence of 10 years per count.[19] I am directing all U.S. Attorneys to investigate all suspected cases of FGM—under the
13 Executive Order 14075, Advancing Equality for Lesbian, Gay, Bisexual, Transgender, Queer, and Intersex Individuals, 87 Fed. Reg. 37189 (June 15, 2022).
14 Timothy Nerozzi, Biden administration endorses transgender youh sex-change operations, 'top surgery, ' hormone therapy, Fox News, March 31, 2022,
https://www.foxnews.com/politics/biden-administration-transgender-agenda-youth-sex-change-hormone-therapy.
15 Azeen Ghorayshi, Biden Officials Pushed to Remove Age Limits for Trans Surgery, Documents Show, N.Y. Times (June 25, 2024),
https://www.nytimes.com/2024/06/25/health/transgender-minors-surgeries.html
16 Patrick Hauf, Biden administration funds studies on danger of transgender hormonal treatments even as it pushes them on kids, Fox News, (Oct. 20, 2022), https://www.foxnews.com/politics/biden-funds-studies-dangers-transgender-hormone-treatments.
17 The White House, March 5, 2025, https://www.whitehouse.gov/articles/2025/03/yes-biden-spent-millions-on-transgender-animal-experiments.
18 See 18 U.S.C. § 116(a)(1).
19 Id. § 116(a).
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banner of so-called "gender-affirming care" or otherwise-and to prosecute all FGM offenses to the fullest extent possible.
The Department will also ensure that victims and their families are able to report violations to federal law enforcement to expose violators and receive support. The Federal Bureau of Investigation, alongside federal, state, and local partners, will pursue every legitimate lead on possible FGM cases.
Il. Investigation of Violations of the Food, Drug and Cosmetic Act and False Claims Act
The Department of Justice will investigate and hold accountable medical providers and pharmaceutical companies that mislead the public about the long-term side effects of chemical and surgical mutilations. To that end:
I am directing the Civil Division's Consumer Protection Branch to undertake appropriate investigations of any violations of the Food, Drug, and Cosmetic Act by manufacturers and distributors engaged in misbranding by making false claims about the on- or off-label use of puberty blockers, sex hormones, or any other drug used to facilitate a child's so-called "gender transition." Even if otherwise truthful, the promotion of off-label uses of hormones—including through informal campaigns like those conducted by sales reps or under the guise of sponsored continuing medical education courses—run afoul of the FDA's prohibitions on misbranding and mislabeling.[20]
I am also directing the Civil Division's Fraud Section to pursue investigations under the False Claims Act of false claims submitted to federal health care programs for any non-covered services related to radical gender experimentation. Examples include but are not limited to physicians prescribing puberty blockers to a child for an illegitimate reason (e.g, gender dysphoria) but reporting a legitimate purpose (i.e., early onset puberty) to the Centers for Medicare & Medicaid Services, and hospitals performing surgical procedures to remove or modify a child's sex organs while billing Medicaid for an entirely different procedure. Falsely billing the government for the chemical or surgical mutilation of a child is a violation of the False Claims Act and is subject to treble damages and severe penalties.
I am also notifying the public that the Department is eager to work with qui tam whistleblowers with knowledge of any such violations. The False Claims Act allows private citizens to file these actions on behalf of the government against those who have defrauded the government. In meritorious cases, the Department of Justice can intervene, and even if the Department takes over the case, the relator may receive a portion of the government's financial recovery. In 2024 alone, qui tam relators received a $344 million share of victories won by the Department. For more information about initiating a qui tam action, please visit the Department's website
20 See 21 U.S.C. §8 321(m)-(n), 331, 352(a), (1); 21 C.F.R. §§ 201.100, 201.128, 202.1(l)(2).
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https://www.justice.gov/archives/im/criminal-resource-manual-932-provisions-handling-qui-tam-suits-filed-under-false-claims-act.
III. Ending Reliance on Junk Science by the Department
Consistent with Section 3 of the President's Order, the Civil Division has already directed that Department employees shall not rely on the ideologically driven WPATH guidelines, and that they should withdraw all court filings that rely on WPATH's guidelines in any case in which the Department of Justice is actively involved, whether as a party, an amicus, or through the submission of a statement of interest. For the avoidance of doubt, I now expressly extend that direction to all Department employees. I further direct the Civil Rights Division to work with the Civil Division to identify and purge all Department policies, memoranda, and publications and court filings based on WPATH guidelines. WPATH has flouted basic standards for clinical guidelines, silenced its own evidence review team to bury doubts about the science PATH promotes, muzzled dissenting members, and worked with the prior administration to push reckless policies—like doing away with age minimums for child surgeries.[21] That is not science; it is radical ideology that endangers children with untested theories, and it has no place in the Department's work. WPATH's guidelines are fundamentally flawed and unreliable, and the Department will not use them in any way that suggests otherwise.
IV. Establish Federal and State Coalition Against Child Mutilation
Federal law enforcement must stand ready to assist states that prioritize children's health over ideology. Accordingly, the Department is launching the Attorney General's Coalition Against Child Mutilation. Through this Coalition, I will partner with state attorneys general to identify leads, share intelligence, and build cases against hospitals and practitioners violating federal or state laws banning female genital mutilation and other, related practices. The Department will support the state-level prosecution of medical professionals who violate state laws that protect children, such as Alabama's Vulnerable Child Compassion and Protection Act,[22] which makes it a felony for doctors to treat children with puberty blockers or hormones to affirm a gender identity inconsistent with biological sex.
V. Promoting New Legislation Protecting Children
I have instructed the Office of Legislative Affairs ("OLA") to draft legislation creating a private right of action for children and the parents of children whose healthy body parts have been damaged by medical professionals through chemical and surgical mutilation. The proposed legislation will establish a long statute of limitations and retroactive liability, so that no one providing such "treatment" will escape liability. The Department of Justice will work with members of the House and Senate Judiciary Committees to bring this bill to President Trump as soon as possible. Further, I have instructed OLA to draft legislation amending 18 U.S.C. § 116 to enhance protections for children whose healthy body parts have been damaged by medical
21 See, eg, Defs.' Mot., Boe v. United States, No. 2:22-cv-00184 (M.D. Ala. Jun. 26,
2024).
22 Ala. Code § 26-26-1.
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professionals practicing chemical and surgical mutilation. I will also work with state legislatures to encourage the passage of similar legislation at the state level.
* * *
Protecting America's children must be our top priority, whether from drug cartels, terrorists, or even our own medical community. Every day, we hear more harrowing stories about children who will suffer for the rest of their lives because of the unconscionable ideology behind "gender-affirming care." Under my leadership, the Department of Justice will bring these practices to an end.
More than half of her citations are to Fox News and NY Post segments.
One thing that Trump and Bondi and Musk and the entire right wing outrage machine will never do is listen to the 99% of transgender people who are happy to have transitioned. Gender-affirming care has saved my life.
They are using the same lies and waving the bloody shirt propaganda that was used in the 1930s to justify force detransitioning, torturing, and murdering trans people. The same G-d damned lies.