Valerie Jackson.

A transgender woman has filed a federal civil rights lawsuit against several officials with the Dallas County Sheriff's Department after she was allegedly forced to expose her genitals while being booked in to jail and on two other occasions housed with male inmates.

According to the recent complaint filed in a Dallas U.S. District Court, plaintiff Valerie Jackson was born male but lives as a transgender woman and had her gender legally changed to female. Jackson was arrested and brought to Dallas County jail in 2016 after she forgot to remove a firearm from her bag before going to the airport.

The suit claims that, during the booking process, jail employees inquired about Jackson's gender, and she told them she was female. Jackson alleges she was later instructed to pull down her pants and underwear, and when Jackson asked why she needed to do this, she was told, “We need to know if you've had a sex change or not. We need to see if you have a penis or a vagina. We have to protect you. We can't put you with men if you have a vagina.”

Jackson responded that she was not going to pull her pants and underwear down, and that she should not have to prove anything to them if none of the other women in jail had to prove anything, the suit claims. She alleges that an officer later replied, “You are coming up in the system as male. It doesn't matter what you do, it can never be changed.”

Jackson later relented and pulled her pants and underwear down to her knees so the officers could verify her genitalia and gender, she claims. She was later placed with men and was referred to as “Mr. Jackson” by a bailiff when taken to court for a pretrial hearing, according to the suit.

“Ms. Jackson was humiliated every time she encountered a new officer. Each time, they would see her and reference her as a woman, only to be told by whichever officer was escorting her in front of everyone that she was a man,” the complaint alleges. “All Ms. Jackson was able to do was cry as she suffered the worst humiliation of her entire life.”

After being released from custody in 2016, Jackson filed a formal complaint regarding her treatment in the jail.

In 2017, Jackson was arrested for a second time, was taken to jail and was again placed with male inmates. She was forced to shower with men, where one of the male inmates masturbated while staring at her, she claims.

Jackson was arrested for a third time in 2018 and was again placed with male inmates, and was again forced to shower while a male inmate masturbated to her, she claims.

“Ms. Jackson suffered severe mental anguish as a result of the unconstitutional searches and harassment she endured,” according to the complaint, which claims she was subjected to an invasive and unconstitutional search.

“The unconstitutional search to 'observe' her genitals and allegedly to 'determine' Ms. Jackson's gender and the harassment that accompanied her incarceration was objectively unreasonable as it violated Dallas County Sheriff's Office written policy and violated plaintiff's rights under the Fourth and Fourteenth Amendment of the United States Constitution.''

The lawsuit names as defendants Lupe Valdez, who served as Dallas County Sheriff from 2005 until January 2018, as well as Marian Brown, who is the current sheriff, among others.

Valdez was the first lesbian and Latina to serve as Dallas sheriff, while Brown is the first African-American woman to hold the job.

Raul Reyna, a spokesman for the Dallas County Sheriff's Office, declined to comment on the pending lawsuit.

Scott Palmer, a Dallas attorney who represents Jackson, noted that the Dallas County Sheriff's Office has a nine-page policy that states its employees “will not exhibit any bias, prejudice, or discriminate against any individual or group, including the transgender/intersex/gender nonconforming community.”

“The problem is the pattern and practice is completely different from the written policy. Either they don't know it, or they are not trained. They were not supposed to do this with this woman,” Palmer said. “She complained about it immediately after it happened. Jail is bad enough, and to be transgender and be humiliated makes it 10 times worse.''

“Failure to train is the hardest thing to prove in civil rights cases,” Palmer added. “But I think we have a really good claim here.''