The brief notes that Manning is housed in the U.S. Disciplinary Barracks, a maximum security military prison for men at Fort Leavenworth in Kansas.
“Manning is confined at the USDB, a military prison for men that has a uniform rule of no hair longer than two inches,” reads the brief. “Making an exception to the USDB’s generally applicable hair restriction would pose a significant security risk, and would undermine the USDB’s important military mission.”
Manning in a statement the American Civil Liberties Union released on Thursday criticized the brief.
“I believe that defining ourselves in our own terms and in our own languages is one of the most powerful and important rights that we have as human beings,” she said. “Presenting myself in the gender that I am is about my right to exist. What the government is basically telling me is ‘you cannot exist,’ that ‘you are wrong,’ and that ‘you do not exist.’ What they are doing is taking away our right to exist. I think this is the kind of situation that justifies all kinds of terrible things like ignorance, maltreatment, torture, murder and genocide.”
Manning — an Army private — is serving a 35-year prison sentence after a military court convicted her of charges related to the leaking of classified documents and diplomatic cables to Wikileaks.
A Kansas judge last year approved Manning’s request to legally change her name. Manning in February began receiving hormone therapy after her the ACLU reached an agreement with the Pentagon.
Manning in 2013 announced through her attorney that she is transgender.