AELE LAW LIBRARY OF CASE SUMMARIES:
Employment & Labor Law for Public Safety Agencies
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Sexual Harassment - By Inmates in Correctional Facilities
Federal appeals
court affirms judgment for a woman corrections employee that was raped
by an inmate janitor. The plaintiff previously complained about the inmate's
behavior, but no remedial action was taken. Erickson v. Wis. Dept. of Corr.,
#05-4516, 2006 U.S. App. Lexis 28125 (7th Cir. 2006); 2005 U.S. Dist. Lexis
19529 affirmed (W.D. Wis.). {N/R}
Second Circuit reinstates
a hostile environment claim brought by women correctional officers, who
alleged that management tolerated the circulation of two inmate letters
that degraded them. Although a certain amount of lewd behavior is anticipated
in a prison environment, the plaintiffs claimed that management inaction
undermined their authority and made their job more dangerous. Dawson v.
Co. of Westchester, #03-7858, 2004 U.S. App. Lexis 11595, 93 FEP Cases
(BNA) 1697 (2d Cir. 2004). [2004 FP Sep]
Federal appeals court affirms a $125,000
verdict because a male coworker encouraged male inmates to engage in sexual
harassment. Slayton v. Ohio Dept. of Youth Services, #98-4528, 206 F.3d
669, 82 FEP Cases (BNA) 289, 2000 U.S. App. Lexis 3751, 2000 FED App. 0091P
(6th Cir.). [2000 FP 75-6]
Federal court dismisses woman corrections
officer's bias lawsuit which claimed that the Dept. of Corrections failed
to adequately discipline male inmates who exposed themselves in her presence.
Wright v. Dept. of Corr., 1998 U.S. Dist. Lexis 20074, 31 F.Supp.2d 1336,
78 FEP Cases (BNA) 1520 (M.D. Ala.). [1999 FP 43-4]
Minn. Dept. of Corrections pays $460,000
to settle the claims of three ex-officers who said they were subjected
to derogatory comments, were required to view inmate shower areas although
it was against DoC policy. Semrau v. Minn., Ramsey Co. Dist. Ct. #C9-94-933,
33 (1627) G.E.R.R. (BNA) 1051 (1995). {N/R}
California jail employee awarded $50,000
in her suit for sexual harassment by inmates and retaliatory discharge.
Troxa v. Contra Costa Co., Super. Ct. #C9304028, 107 (126) L.A. Daily J.
[Verd. & Setlmts.] 3 (1994). [1994 FP 157]
Federal appeals court requires all-male prisons
to adopt procedures to prevent women correctional officers from seeing
undressed inmates. Canedy v. Boardman, 16 F.3d 183 (7th Cir. 1994). [1994
FP 124]
Female corrections officer, depressed from
viewing a male inmate who repeatedly masturbated in her presence, had "good
cause" to resign and collect unemployment benefits. State Dept. of
Corrections v. Stokes, 558 So.2d 955 (Ala. 1990).