## Facts

- James Crawford (a former inmate) and Thaddeus Corley (a current inmate) alleged that, while incarcerated at Eastern Correctional Facility, Corrections Officer Simon Prindle conducted pat frisks that included intentional groping of their genital areas.
- The complaint alleged the contact served no legitimate security purpose and was done for Prindle’s sexual gratification or to humiliate the inmates.
- Plaintiffs brought a 42 U.S.C. § 1983 action seeking damages and injunctive relief for Eighth Amendment violations.
- The district court dismissed under Rule 12(b)(6), treating the alleged incidents as isolated and de minimis under the court’s reading of prior circuit precedent.
- Plaintiffs appealed.

## Issues

1. Whether an inmate states an Eighth Amendment claim when a corrections officer intentionally touches the inmate’s genitalia or other intimate area without penological justification and with intent to gratify the officer or humiliate the inmate, even if the incident is brief and causes no serious physical injury.
2. Whether prior circuit precedent required dismissal of such claims as insufficiently serious when the alleged abuse was not repeated.

## Decision

- The Second Circuit reversed the dismissal and remanded for further proceedings.
- The court held that intentional contact with an inmate’s genitalia or other intimate area, without penological purpose and undertaken to gratify the officer’s sexual desire or to humiliate the inmate, violates the Eighth Amendment.
- The court concluded both Crawford and Corley plausibly alleged cognizable Eighth Amendment claims at the pleading stage.

## Legal Principles

- The Eighth Amendment prohibits the unnecessary and wanton infliction of pain and conduct incompatible with contemporary standards of decency.
- A corrections officer’s intentional sexual contact with an inmate’s genitalia or intimate areas, lacking penological justification and motivated by sexual gratification or humiliation, is sufficiently serious to state an Eighth Amendment claim.
- A plaintiff need not allege significant physical injury or repeated abuse where the alleged conduct constitutes purposeful sexual abuse.
- Legitimate searches may involve professional, security-related contact, but gratuitous sexual touching undertaken for improper purposes satisfies the subjective component of an Eighth Amendment claim.

## Conclusion

The Second Circuit held that alleged genital fondling by a corrections officer for sexual gratification or humiliation and without penological justification is actionable under the Eighth Amendment, and it reinstated the inmates’ claims by reversing the Rule 12(b)(6) dismissal and remanding.


Crawford v. Cuomo, 796 F.3d 252 (2d Cir. 2015)