The San Francisco-based US Court of Appeals for the Ninth Circuit ruled on Oct. 6 in Roe v. Johnston that because Arizona’s statute governing amendments to birth certificates does not require a “sex change operation” as a prerequisite for getting an amended birth certificate, Senior US District Court Judge James A. Soto erred by awarding an injunction to transgender plaintiffs who had been unsuccessful in obtaining court orders from state judges to direct the Arizona Department of Health Services to provide them with amended birth certificates.