No, Officers Cannot Sexually Abuse Inmates 2nd Cir. Rules
You think it would go without saying: corrections officers cannot sexually abuse inmates without violating those inmates' rights. Apparently not. The Second Circuit felt the need to restate the obvious after a district court tossed two inmates' suit, which alleged that they were fondled by correctional officers in violation of the Eighth Amendment's prohibition on cruel and unusual punishment.
Such abuse is clearly unconstitutional, the Second Circuit wrote. Further, it emphasized that the Circuit's Eighth Amendment precedents must be applied broadly to comport with evolving "societal standards of decency" regarding inmate sexual abuse.
More Than Just a Search
Two inmates sued after they were allegedly groped by a corrections officer at the Eastern Correctional Facility, a maximum security prison in New York. Thaddeus Corley alleges that Officer Simon Prindle interrupted a visit from his wife and groped him in order to "make sure Mr. Corley did not have an erection." James Crawford, another inmate, alleged that Prindle stopped him for a search, then grabbed, held, and fondled his crotch, threatening the inmate when he objected.
Corley and Crawford weren't alone in their allegations either, according to their complaint. Prindle routinely strip searched, fondled, and demeaned inmates, they alleged. Indeed, more than 20 other inmates had reported Officer Prindle's sexual abuse, though the prison refused to take action.
Revisiting Boddie After Two Decades
The district court didn't see the problem. Under the Second Circuit's decision in Boddie v. Schneider, the district court dismissed the suit for failure to state a claim. Under Boddie, "there can be no doubt that severe or repetitive sexual abuse" can violate the Eighth Amendment. In that case, an inmate alleged that an officer had squeezed his hand, touched his penis, and rubbed against him. The Second Circuit dismissed his suit. The district court, analogizing Corley and Crawford's claims to Boddie's, did the same.
That was too narrow an application of Boddie, the Second Circuit now ruled, 18 years after Boddie was decided. To make sure there was no future confusion, the Second Circuit set forth as clear a statement as one could want:
A corrections officer's intentional contact with an inmate's genitalia or other intimate area, which serves no penological purpose and is undertaken with the intent to gratify the officear's sexual desire or to humiliate the inmate, violates the Eighth Amendment.
Further, had Boddie been decided today, applying the same rules Boddie established in 1997, it would have been decided differently, the court held. In those 18 years, standards regarding prison sexual abuse have evolved and Eighth Amendment jurisprudence must reflect that, the court held, meaning that Boddie, if not wrongly decided then, would come out differently today.
- 2nd Circuit Broadens Definition of Unconstitutional Prison Sex Abuse (Politico New York)
- Man, Exonerated After 18 Years in Prison, Can Pursue 1983 Suit (FindLaw's U.S. Second Circuit Blog)
- Second Circuit Reinstates Prison Sex Abuse Lawsuit (FindLaw's U.S. Second Circuit Blog)
- 2nd Cir. Vacates Weak Child Porn Sentence Imposed by Judge Weinstein (FindLaw's U.S. Second Circuit Blog)
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