Quarterly Newsletter

SEPTEMBER 2017-NOVEMBER 2017

FOREWORD
The Project on Addressing Prison Rape works with policymakers, correctional administrators, and the public to address sexual abuse in custodial settings. This newsletter highlights recent cases, rulings, scholarly articles, and upcoming events related to sexual violence in custody. The Project searched for all cases involving inmate sexual abuse, LGBTI inmates, and cases directly citing the Prison Rape Elimination Act (PREA). We have separated the cases in four ways: cases that discuss sexual assault, cases that address PREA, cases that highlight the sexual abuse of LGBTI inmates, and cases where inmates have failed to exhaust all administrative remedies. Of the 25 cases found, 56 percent addressed sexual assault in the case, 24 percent mentioned PREA, and 16 percent of the cases provided no discussion of the sexual assault and/or dismissed the cases for failure to exhaust administrative remedies. When providing case summaries, the language in the summary is the language of the case. Further, while the cases may contain multiple counts against defendants, this newsletter only discusses those counts related to PREA and/ or sexual assault.

Sexual Assault

Kerch v. Johnson, No. 5:17-cv-00186-MTT-CHW 2017 WL 4563841 (M.D. Ga. Aug. 2, 2017).  Plaintiff inmate brought a claim under 42 U.S.C. § 1983 alleging Defendant corrections officers violated his Eighth Amendment and First Amendment rights.  Plaintiff alleged that Defendant officer told him to "suck his dick."  Plaintiff claimed that when he filed grievances and PREA complaints, Defendant officer verbally and physically retaliated against him. Defendant officer slammed Plaintiff's hand in a tray slot and made numerous threats against Plaintiff's life.  Defendants refused Plaintiff medical care for the damage to his hand after officer slammed it in the food tray slot.  Plaintiff further alleged that Defendant supervisors did nothing to intervene despite the numerous grievances he filed.  Plaintiff also alleged that Defendant officers disposed of his grievance forms when he attempted to file more for the on-going harassment. Defendants eventually transferred the Plaintiff, but the Plaintiff claims he was already emotionally distraught as a result of the past harassment and proceeded to swallow razorblades.  The court allowed the claims against both Defendant officer and Defendant supervisors to proceed. The court also allowed First Amendment claims for retaliation and disposing of grievances to proceed.

Gregg v. H.I. Dept. of Public Safety, 870 F.3d 883 (9th Cir. Aug. 29, 2017). Former inmate brought suit pursuant to 42 U.S.C. § 1983 alleging cruel and unusual punishment and deliberate indifference under the Eighth Amendment arising from her participation in therapy sessions during incarceration. Plaintiff claimed that the sessions involved “public sexual shaming,” where inmates were forced to stand at a lectern and speak about their sexual histories before large groups of men and women inmates and staff. Plaintiff alleged that Defendant Warden asked Plaintiff whether she had sex while on drugs,” “how many partners [she] previously had sex relations with,” and “whether she had been raped.” Plaintiff claimed that Defendant Warden also “ordered her to elaborate on previous incidents of rape” in which she was the victim, as well as hold up “sexual photographs” of themselves while the Defendant Warden called them “whores.” These Defendants videotaped the sessions and showed them to the broader inmate population. The court ruled that the district court erred in denying Plaintiff’s leave to amend her complaint to try to make a plausible showing that it was not until January 2012 that she first became aware of her injuries from her purported treatment and awarded Plaintiff costs of appeal.

Payne v. Coburn, No. 915CV00392GLSTWD, 2017 WL 4330372 (N.D.N.Y. Aug. 29, 2017). Plaintiff brought suit pursuant to 42 U.S.C. § 1983 alleging violations of his First, Eighth, and Fourteenth Amendment rights. Plaintiff alleged Defendant officer verbally abused him and engaged in acts of sexual abuse by squeezing Plaintiff's penis and fondling his testicles while another officer watched. Plaintiff also claimed that Defendant officers retaliated against him for filing a grievance, submitted false misbehavior reports against him, and placed him in the special housing unit. Court denied Defendant officers’ motion for summary judgment on the Eighth Amendment excessive force and failure to intervene claims but granted summary judgment for Defendants on all other claims.

Kyles v. Beaugard, 2017 U.S. Dist. LEXIS 150764 (N.D. Ill. Sept. 18, 2017).  Plaintiff filed a complaint under 42 U.S.C. § 1983 for violation of his First and Eighth Amendment rights.  Plaintiff alleged that he was placed in temporary confinement with a general population inmate who beat and raped him.  Plaintiff alleged that the guards laughed at him when he attempted to report the assault.  The court allowed a First Amendment retaliation claim, Eighth Amendment failure to protect claim, Eighth Amendment medical care claim, an Eighth Amendment failure to intervene claim, a state law intentional infliction of emotional distress claim, and a Monell policy claim, to proceed.  The court dismissed remaining claims.  Under Monell v. Department of Social Serv., 436 U.S. 658 (1978), a municipal government can be held liable under § 1983 if a plaintiff can demonstrate that a deprivation of a federal right occurred due to a policy of the local government or local officials. The court determined that Defendants did not meet their burden in showing that Plaintiff failed to exhaust his First Amendment retaliation claims.  The court further determined Plaintiff's Eighth Amendment and policy claims could proceed, as the Eighth Amendment claims do not require Plaintiff meet a time limit under PREA.

Moore v. Lamas, 2017 U.S. Dist. LEXIS 153964 (M.D. Pa. Sept. 21, 2017).  Plaintiff inmate filed suit under 42 U.S.C. § 1983.  Plaintiff alleged that Defendant Unit Manager physically and sexually assaulted him.  Plaintiff further alleged that when he attempted to file grievances, the Defendants retaliated against him and did not give the Plaintiff appropriate responses. The court determined that regarding the assault claims, Plaintiff had sufficiently exhausted administrative remedies, as prison officials failed to respond to his attempts to seek redress.

Washington v. Hoffman, 2017 U.S. Dist. LEXIS 157659 (W.D. Pa. Sept. 25, 2017).  Plaintiff inmate filed a claim under 42 U.S.C. § 1983 alleging sexual harassment.  Plaintiff alleged that Defendant officer made numerous inappropriate statements to him, such as: "I don't want to see your dick every morning," called him "faggot," and said "eat a dick."  Plaintiff alleged that these comments amounted to sexual harassment.  The court granted Defendant's motion to dismiss for failure to state a claim on which relief could be granted, as the comments did not rise to a constitutional violation. 

Silva v. Nathu, No. 2:15-cv-1721 KJM DB P, 2017 WL 4284635 1, 1 (E.D. Cal. Sept. 27, 2017).  Plaintiff, a transgender inmate, brought a complaint under 42 U.S.C. § 1983.  Plaintiff alleged that Defendants sent him to a holding cage to have a one-on-one appointment with Defendant psychiatrist.  Defendant psychiatrist allegedly began massaging his own penis and asking Plaintiff to "perform" for him.  Plaintiff claimed that he refused, and Defendant psychiatrist left the holding cage. Plaintiff sought damages for the psychological and emotional distress that resulted from this incident. The court determined that without touching the victim, verbal harassment does not generally rise to the level of an Eighth Amendment violation.

Reynolds v. Smith, No. 2:11-cv-277, 2017 WL 4310508 (S.D Ohio Sept. 28, 2017). Plaintiff, formerly an inmate at the Ohio Reformatory for Women (“ORW”), brought suit pursuant to 42 U.S.C. § 1983 alleging violations of her Fourth, Eighth, and Fourteenth Amendments rights. Plaintiff alleged that Defendant officer sexually assaulted her over an extended period, and that Defendant Correctional Agency and Defendant employees failed to protect her. The court granted motion for summary judgment for Defendant employees but allowed Plaintiff’s claims to proceed against Defendant Correctional Agency, as there was a genuine issue of material fact as to whether Defendants should have taken further action to protect the Plaintiff.

Laster v. Lee, No. 14-24067-CIV-GAYLES/WHITE, 2017 WL 4324631 (S.D. Fla. Sept. 29, 2017). Inmate brought suit pursuant to 42 U.S.C. § 1983 alleging violation of his Eighth Amendment rights. Plaintiff claimed that while he was waiting in the hall to be treated in the mental health department, Defendant officer made sexual comments, licked her lips, pulled his pants down, told him she was going to search him, and then rubbed and groped his penis with gloves. Plaintiff alleged that the Defendant officer then proceeded to place her right index finger inside her mouth before inserting it inside his rectum. Plaintiff alleged that when he went to file a formal grievance, another officer told him to cease filing complaints and threatened to place him in solitary confinement or have him transferred. The court chose not to adopt the Magistrate Judge’s recommendation and did not grant the Defendant’s motion for summary judgment. The Court found that even if Plaintiff's allegations did not violate the Eighth Amendment, they did violate his Fourth Amendment right to bodily privacy.

Jackson v. Gibbs, No. 2:16-cv-0685-LJM-EFB P, LEXIS 165694 (E.D. Cal. Oct. 5, 2017).   Plaintiff brought a claim under 42 U.S.C. § 1983 for violation of his Eighth Amendment rights.  Plaintiff alleged that Defendant officer sexual assaulted him during a search by reaching into the back side of Plaintiff's pants.  Plaintiff was in a wheelchair and Defendant officer asked to search between Plaintiff's back and the back of the chair.  Defendant officer found a bottle allegedly containing soap.  Defendant officer then reached his hand down Plaintiff's pants, nearly touching his anus.  Defendant officer and another officer then made sexual comments about Plaintiff having sexual relations with other men.  The court determined that Plaintiff failed to state a claim upon which relief could be granted, as the alleged actions did not rise to the level of a constitutional violation.

Bucano v. Austin, et al., No. CV 15-67, 2017 WL 4563948 (W.D. Pa. Oct. 13, 2017). Plaintiff filed suit under 42 U.S.C. § 1983 against Defendant Correctional Agency for violating her Eighth Amendment rights for deliberate indifference and against Defendant officer for violating her Eighth Amendment right by sexually harassing and abusing her. Plaintiff claimed that Defendant officer subjected her to a series of inappropriate sexual comments and directives, and unwanted sexual contact over several months. Plaintiff also alleged prison officials placed her in solitary confinement for three weeks after she reported the sexual harassment.  After three weeks, Defendants allegedly notified Plaintiff that the investigation was over and no abuse had occurred. The court denied the Defendant’s motion for summary judgment and stated that Plaintiff had exhausted administrative remedies in following sexual harassment reporting procedures in the inmate handbook.  The court remanded the case back to the Magistrate Judge.

Fox. v. Lackawanna Cty., No. 3:16-CV-1511, 2017 U.S. Dist. LEXIS 181618 (M.D. Penn. Nov. 2, 2017). Four female inmate Plaintiffs filed suit pursuant to 42 U.S.C. § 1983, § 1985, and § 1986 alleging violations of their First, Fourth, Eighth, and Fourteenth Amendment rights. Plaintiffs claimed that Defendant officers raped, sexually assaulted, and sexually harassed them. The court dismissed two of the Plaintiffs' claims as the statute of limitations had passed.  The court allowed the remaining claims to proceed.

Reyes v. Palmer, 2017 U.S. Dist. LEXIS 185026 (W.D. Mich. Nov. 8, 2017).  Plaintiff filed a complaint under 42 U.S.C. § 1983.  Plaintiff alleged that Defendant officer conducted an inappropriate pat-down search in the chow hall when Plaintiff went to get a “spork.”  Plaintiff alleged that Defendant officer squeezed his testicles while conducting the search.  Plaintiff further alleged that when he filed a grievance his claims were not properly investigated.  Plaintiff made claims related to retaliation, sexual misconduct, and due process.  The court determined that by not identifying a constitutional violation, Plaintiff failed to state a claim on which relief could be granted.  The court noted that § 1983 provides an avenue for vindicating federal rights but is not a source of substantive rights in itself.  The court still performed an Eighth Amendment analysis and determined that the allegations did not rise to the level of a constitutional violation.  The court further determined that Plaintiff did not have a due process right to the grievance process. The court allowed the retaliation claims to proceed but dismissed all other claims.

PREA

Brown v. Semple, No. 3:17cv1328 (SRU), 2017 WL 4050308 (S. Conn. Sept. 13, 2017). Plaintiff filed suit pursuant to 42 U.S.C. § 1983 alleging violations of his First and Eighth Amendment rights, and PREA. Plaintiff alleged that over the course of two years, the Defendant Commissioner’s employed mental health doctor sexually abused him during counseling sessions. Plaintiff also alleged that the Defendant Commissioner knew about the conduct but took no action.  Plaintiff further claimed that he filed several grievances that were never investigated. The court allowed all claims to proceed except for claims under PREA, as PREA does not give rise to a private right of action.

Gonzalez v. Cty. Of Merced, No. 1:16-cv-01682-LJO-SAB, 2017 WL 2345681 (E.D. Cal. Sept. 29, 2017). Plaintiff filed suit under 42 U.S.C. § 1983 against Defendant County for constitutional violations under theories of Monellliability, including deliberate indifference, inadequate hiring, and failure to train. Plaintiff also filed suit against the Defendant officer for violating her Fourth and Fourteenth Amendment rights. Under Monell v. Department of Social Serv., 436 U.S. 658 (1978), a municipal government can be held liable under § 1983 if a plaintiff can demonstrate that a deprivation of a federal right occurred due to a policy of the local government or local officials. Plaintiff alleged that Defendant officer groped her vagina on multiple occasions while she was in full-body shackles exiting and sitting in a transport van. Plaintiff alleged that Defendant County was aware of Defendant officer’s history of sexual misconduct because he had sexually harassed other inmates and female coworkers. Plaintiff alleged that Defendant County’s policies, practices, and customs were not adequate to protect female inmates. The Magistrate court granted the Defendant County’s motion to dismiss. In de novoreview of the case, this court allowed the Plaintiff’s Monell claim as to pattern/ custom to proceed but dismissed all other forms of Monell liability. See Gonzalez v. Cty. of Merced, 2017 U.S. Dist. LEXIS 202008 (E.D. Cal., Dec. 7, 2017)  

Bennett v. Parker, No. 3:17-cv-1176, 2017 U.S. Dist. LEXIS 169876 (M.D. Tenn. Oct. 13, 2017). Plaintiff filed suit under 42 U.S.C. § 1983 alleging violations of the Eighth Amendment for sexual assault, deliberate indifference, and failure to protect. Plaintiff alleged that the Defendant Warden raped him several times and made the Plaintiff perform oral sex on him nine times. Plaintiff also claimed that he tried to file a PREA report, but Defendant officers refused to process it. The court allowed the Plaintiff’s Eighth Amendment claims to proceed but dismissed Plaintiff’s PREA claims, as PREA has “not yet been addressed by the Sixth Circuit, [but] several district courts recognized that this statute does not create a private cause of action.”

Hayes v. Dahkle, No. 9:16-CV-1368, 2017 U.S. Dist. LEXIS 180424 (N.D. N.Y Oct. 30, 2017). Plaintiff filed suit under 42 U.S.C. § 1983 alleging violations of his First and Eighth Amendment rights. Plaintiff claimed that Defendant officer sexually assaulted him during a pat-frisk and sexually harassed him saying, “Do you consider yourself a man or woman” and other profane remarks on multiple occasions. Plaintiff alleged that he was placed in solitary confinement pending the investigation of his PREA complaint. Defendants reprimanded the Plaintiff and gave him a misbehavior report for “falsely reporting incidents of sexual abuse.” The court examined the Eighth Amendment claims “by looking beyond historical conceptions to the evolving standards of decency that mark the progress of a maturing society,” and referenced PREA in its analysis. The court allowed the Plaintiff’s Eighth Amendment claims against Defendant officer and First Amendment retaliation claims to proceed.

Doe v. Anderson, No. 15-cv-13852, 2017 U.S. Dist. LEXIS 180678 (E.D. Mich. Nov. 1, 2017). Plaintiffs brought a 42 U.S.C. § 1983 complaint alleging violations of their First Amendment rights. Plaintiffs, who were housed in adult prisons while under the age of eighteen, claimed that Defendant and Defendant employees retaliated against them after they sued the Defendant for sexual abuse during their incarceration. The court granted part of the Plaintiffs’ motion to compel the production of documents and the deposition of the PREA coordinator.

Denton v. Pastor, 2017 U.S. Dist. LEXIS 181938 (W.D. Wa. Nov. 2, 2017).  Plaintiff filed a claim under 42 U.S.C. § 1983 alleging violation of PREA and his First and Eighth Amendment rights.  Plaintiff alleged that Defendant officers entered his cell without the required handheld cameras.  Defendant officers physically and sexually assaulted the Plaintiff by punching and kicking him before stripping him naked and used a Taser between his butt cheeks.  The Magistrate Judge wrote a report and recommendation allowing the claims to proceed.  However, the District Court dismissed the PREA claims as PREA does not create a private right of action.  The court determined that administrative remedies were not appropriately available, and the claims should therefore survive Defendants' motion to dismiss for failure to exhaust.  The court dismissed in part as to the PREA claim and granted in part as to Constitutional claims.

LGBTI

Hampton v. Meyer, no. 17-cv-0860-MJR, 2017 U.S. Dist. LEXIS 173201 (S.D. Ill. Oct. 19, 2017). Plaintiff brought suit under 42 U.S.C. § 1983 alleging violations of her Eighth Amendment rights. The Plaintiff, a transgender woman housed in a male prison, claimed that Defendant officers sexually harassed and assaulted her on multiple occasions. Plaintiff alleged that Defendant officers forced her “to put on a bra and thong and perform sexual dance moves,” paid her to perform sexual acts, and repeatedly called her names, such as “faggot” and “dick sucker.” When Plaintiff threatened to file a PREA report, Defendant officers allegedly beat her. The court allowed the Plaintiff’s Eighth Amendment claims to proceed.

No Discussion/Failure to Exhaust Administrative Remedies

J.H. v. Management & Training Corp., 2017 U.S. Dist. LEXIS 177397 (S.D. Miss. Oct. 26, 2017). Plaintiff filed suit under 42 U.S.C. § 1983 and a state negligence claim against Defendant and for failure to protect him from another inmate, who raped the Plaintiff. The court dismissed the Defendant’s motion for summary judgment as the Defendant failed to provide a valid legal reason that the court should dismiss a negligence claim and failed to demonstrate that Plaintiff did not exhaust all administrative remedies.  As failure to exhaust is an affirmative defense, the burden was on the Defendant to show that the requirement was not met.

Cruz v. Jeffreys et al., 2017 WL 4581456 (S.D. Cal. Oct. 13, 2017).  Plaintiff inmate filed a claim pursuant to 42 U.S.C. § 1983 alleging that three Defendant corrections officers retaliated against him by reporting him to mental health professionals and arranging for him to be assaulted.  He indicated that he reported Defendant corrections officers for sexual misconduct towards a female corrections officer. Plaintiff inmate stated that Defendant corrections officers retaliated against him as a result.  The court determined that the case should be dismissed, as Plaintiff did not exhaust administrative remedies prior to filing the lawsuit. 

Iverson v. Bell, No. 16-3102-JTM, 2017 U.S. Dist. LEXIS 165218 (D. Kan. Oct. 5, 2017). Plaintiff brought a 42 U.S.C. § 1983 complaint for violation of his First and Eighth Amendment rights, and PREA. Plaintiff alleged that Defendant officers sexually assaulted and battered him. He further claimed that conditions at the prison were unsanitary. Plaintiff claimed that when he tried to file PREA complaints, Defendants retaliated against him. The court dismissed all claims, stating that the Plaintiff failed to exhaust administrative remedies.

 Turner v. Admin. Security Personell, et al., No. 116CV01643DADSABPC, 2017 WL 4387326 (E.D. Cal. Oct. 3, 2017). Plaintiff brought suit under 42 U.S.C. § 1983 alleging violations of his First and Eighth Amendment rights. Plaintiff claims that while he and his cellmate were engaged in religious prayers, Defendant officers approached their cell, told them to get on the floor, and began administering chemical restraints for a prolonged period of time. Plaintiff further claims that Defendant officers placed him in a headlock, forcing him to pass out.  When Plaintiff regained consciousness, Defendant officers took him to the showers, where they forced his buttocks apart and probed his anal area with a cellphone. The court dismissed all claims for failure to exhaust administrative remedies. 

Karris v. Rodabaugh, No. 15-CV-00190A(F), 2017 U.S. Dist. LEXIS 182091 (W.D. N.Y. Nov. 1, 2017). Plaintiff filed suit under 42 U.S.C. § 1983 alleging violations of his Eighth Amendment rights. Plaintiff alleged that Defendant employee, who was in charge of the Group Therapy Program, ejaculated onto the Plaintiff’s face while his hands were cuffed and sodomized the Plaintiff on several occasions with the help of two corrections officers. Though the Plaintiff filed a grievance through New York’s Inmate Grievance Procedure (IGP), he did not appeal the denial of his grievance, and the court found that he had failed to exhaust all available administrative remedies.

Scholarly Research

Angela Irvine & Aisha Carfield, Reflections on the New National Data on LGBT/ GNCT Youth in the Justice System (2017), https://static1.squarespace.com/static/58ba8c479f7456dff8fb4e29/t/59739d333e00be4843e0263b/1500749110120/irvine.canfield.2017.pdf.

Breea C. Willingham, Black Women and State-Sanctioned Violence: A History of Victimization and Exclusion, Canadian Review of American Studies (2017), http://www.utpjournals.press/doi/pdf/10.3138/cras.2017.018.

GraceAnn Caramico, Thank You Sophia Burnett: A Call to Federal Bureau of Prisons to Break Free of the Chains of Tradition in Order to Protect Transgender Inmates (2017).

Graedon Muir-Pfeiffer, Restorative Justice Responses to Sexual Violence as Non-Domination Promoting Instruments (2017), https://tspace.library.utoronto.ca/bitstream/1807/79485/3/Muir-Pfeiffer_Graedon_S_201711_LLM_thesis.pdf.

Jason Payne-James, Jonathan Beynon, & Duarte Vieira, Monitoring Detention, Custody, Torture and Ill-treatment: A Practical Approach to Prevention and Documentation (2017). https://books.google.com/books?hl=en&lr=&id=nGE1DwAAQBAJ&oi=fnd&pg=PT349&ots=QykakNq1j6&sig=eLHbvFBQbzZGM5KmAL_Y1qEuAkQ#v=onepage&q&f=false.

Joanna Weill & Craig Haney, Mechanisms of Moral Disengagement And Prisoner Abuse (2017), https://spssi.onlinelibrary.wiley.com/doi/epdf/10.1111/asap.12142.

Kimberly A. Thomas, Juvenile Lifers and Juveniles in Michigan Prisons: A Population of Special Concern (2017), http://repository.law.umich.edu/cgi/viewcontent.cgi?article=2858&context=articles.

Lauren Parcher, "An Aura of Disbelief:" Rape Mythology and Victim Blaming in the Legal Response to Disclosure of Sexual Violence, http://scholars.wlu.ca/cgi/viewcontent.cgi?article=1023&context=brantford_sjce.

Valerie Jenness, Lori Sexton, and Jennifer Sumner, Sexual Victimization of Transgender Women in Men’s Prisons: An Empirical Analysis of Institutional and Relational Dynamics*(2017).

News Articles

The Times Editorial Board, L.A. County Has Had Years To Figure Out How To End Rape In Its Jails. It's Time for Action, The LA Times (Nov. 28, 2017), http://www.latimes.com/opinion/editorials/la-ed-prison-rape-elimination-20171128-story.html.

Sara E. Teller, Former Inmate Receives $60K Settlement in Prison Rape Lawsuit, Leagle Reader (Nov. 22, 2017), https://www.legalreader.com/former-inmate-receives-60k-settlement-prison-rape-lawsuit/.

Natasha Lennard, Will The Prison Rape Epidemic Ever Have Its Weinstein Moment?, The Intercept (Nov. 21, 2017), https://theintercept.com/2017/11/21/prison-rape-sexual-assault-violence/.

Amy Miller, State Fights to Deny Teen Inmates Civil Rights, WDET (Nov. 16, 2017), https://wdet.org/posts/2017/11/16/86077-state-fights-to-deny-teen-inmates-civil-rights/.

Jerry Iannelli, Miami Federal Prison Guard Gets Eight Months in Jail for Raping Inmate, Miami New Times (Nov. 15, 2017), http://www.miaminewtimes.com/news/miami-prison-guard-caught-raping-inmate-sentenced-to-eight-months-in-jail-9831049.

Dylan Cowart, Transgender Prisoners Face Sexual Assault and Discrimination at Pittsburgh Jail, ACLU Blog (Nov. 14, 2017), https://www.aclu.org/blog/lgbt-rights/criminal-justice-reform-lgbt-people/transgender-prisoners-face-sexual-assault-and.

Aviva Stahl, Transgender Prisoners: What an Inmate's Surgery Means for Trans Rights, Rolling Stone (Nov. 9, 2017), http://www.rollingstone.com/culture/features/what-an-inmates-surgery-means-for-trans-rights-w511274.

Connecticut Law Tribune Editorial Board, Dignity for Incarcerated Women Act Benefits Us All, Connecticut Law Tribune (Oct. 31, 2017), https://www.law.com/ctlawtribune/sites/ctlawtribune/2017/10/31/connecticut-law-tribune-editorial-board-dignity-for-incarcerated-women-act-benefits-us-all/?cmp=share_twitter.

Charles P. Pierce, This Is an American Prison in 2017, Esquire Magazine (Oct. 26, 2017), http://www.esquire.com/news-politics/politics/a13099638/louisiana-prison-abuse-dog-food/.

At Flagler Jail, 4th Guard This Year Resigns Over “Affair” With Inmate, Whose Wife Was Also Jailed, FlaglerLive.com (Oct. 27, 2017), https://flaglerlive.com/113936/jail-inmate-relations/?platform=hootsuite.

Eric Heishig, Ohio Will Pay $525,000 To Cleveland Woman Who Accused Prison Guard of Sexual Assault, Cleveland.com (Oct. 25, 2017), http://www.cleveland.com/court-justice/index.ssf/2017/10/ohio_will_pay_525000_to_clevel.html.

Frank Stoltze, LA Sheriff Still Hasn’t Complied with a Federal Law on Prison Rape, 89.3 KPPC (Oct. 24, 2017), https://www.scpr.org/news/2017/10/24/76943/la-sheriff-has-yet-to-fully-comply-with-federal-la/.

Jack Kelly, Researchers Tackle Inadequate Transgender Inmate Care, Yale News (Oct. 24, 2017), https://yaledailynews.com/blog/2017/10/24/researchers-tackle-inadequate-transgender-inmate-care/?platform=hootsuite.

Phaedra Haywood, Ex-Guard Receives Light Sentence In Prison Sex Case, Santa Fe New Mexican (Oct. 20, 2017), http://www.santafenewmexican.com/news/local_news/ex-guard-receives-light-sentence-in-prison-sex-case/article_89566d32-c557-5eea-9714-f9a02e7c5847.html?utm_medium=social&utm_source=twitter&utm_campaign=user-share.

Natasha Lennard, Police Reportedly Claim A Brooklyn Teen Consented To Sex In Custody. That’s Impossible, The Intercept (Oct. 20, 2017), https://theintercept.com/2017/10/20/brooklyn-teen-police-rape-consent/.

Evie Litwok, Living in Fear for Her Life, ACLU (Oct. 20, 2017), https://www.aclu.org/blog/mass-incarceration/smart-justice/living-fear-her-life?platform=hootsuite.

Robert Greenwald, A Look Inside Our Abusive Immigrant Prisons, The Nation (Oct. 18, 2017), https://www.thenation.com/article/a-look-inside-our-abusive-immigrant-prisons/.

Jon O’Connell, Protesters Call for Accountability at County Prison, The Times Tribune (Oct. 16, 2017), http://thetimes-tribune.com/news/protesters-call-for-accountability-at-county-prison-1.2255737?platform=hootsuite.

Lex Talamo, David Wade Prison Lawsuits Allege Brutality, Roaches, Sexual Abuse, Shreveport Times (Oct. 14, 2017), http://www.shreveporttimes.com/story/news/crime/2017/10/14/hundreds-civil-rights-violations-lawsuits-fie-against-louisiana-prison-allege-civil-rights-violation/521299001/?platform=hootsuite.

Thomas MacMillan, New York City Jails Often Manage ‘Troublesome’ Inmates With Force, Federal Monitoring Team Finds, The Wall Street Journal (Oct. 11, 2017), https://www.wsj.com/articles/new-york-city-jails-often-manage-troublesome-inmates-with-force-federal-monitoring-team-finds-1507758165?platform=hootsuite.

Fight Club: A Miami Herald Investigation into Florida's Juvenile Justice System, Miami Herald (Oct. 2017), http://www.miamiherald.com/news/special-reports/florida-prisons/article176773291.html.

Deneen Smith, Former Jailer Will Do Prison Time in Inmate Sexual Assault Case, Kenosha News (Oct. 9, 2017), http://www.kenoshanews.com/news/local/former-jailer-will-do-prison-time-for-sexually-assaulting-inmates/article_dff42f6e-77d4-5e69-aa02-77dc652d738b.html.

Tamar Lapin, Worker Busted for Sexual Relationship with Inmate at ‘Shawskank’ Prison, NY Post (Oct. 5, 2017), http://nypost.com/2017/10/05/prison-worker-caught-having-sexual-relationship-with-inmate/?platform=hootsuite.

Wendy Libertore, Jail Officer Accused of Having Sex with Inmate, Times Union (Oct. 5, 2017), http://www.timesunion.com/news/article/Corrections-officer-arrested-for-having-sex-with-12256333.php#photo-14292459.

S.P. Sullivan, Sex Abuse, Contraband, Cover-Ups? Inside A Growing Criminal Probe at N.J. Women's Prison, NJ.com (Sept. 26, 2017), http://www.nj.com/politics/index.ssf/2017/09/sex_abuse_contraband_cover-ups_inside_a_growing_cr.html.

Peter Hirschfeld, Report Puts Spotlight on Sexual Victimization in Vermont Prisons, Vermont NPR (Sept. 18, 2017), http://digital.vpr.net/post/report-puts-spotlight-sexual-victimization-vermont-prisons#stream/0.

James Queally and Maya Lau, Sheriff’s Deputy Arrested On Suspicion of Sexually Assaulting 2 Inmates, LA Times (Sept. 14, 2017), http://www.latimes.com/local/lanow/la-me-ln-lasd-deputy-arrest-20170914-story.html.