Wood v. Beauclair

In a prisoner's claim against a prison for violation of constitutional rights flowing from sexual harassment by a prison official, the inmate is entitled to the presumption that the conduct was not consensual.

Lance Wood, a prisoner in the State of Idaho, developed a romantic but not sexual relationship with a guard, Sandra de Martin. Wood attempted to terminate the relationship upon discovering that Martin had recently married, after which Martin made sexual advances towards Wood on at least two occasions. Wood filed a grievance against Martin and was transferred to a different prison. Wood brought four claims under 42 U.S.C. § 1983: “(1) sexual harassment by Martin in violation of the Eighth Amendment; (2) repeated body searches by Martin in violation of Wood’s privacy rights under the Fourth Amendment; (3) the failure by the defendants to protect Wood from Martin in violation of the Eighth Amendment; and (4) retaliation against Wood for reporting grievances in violation of the First Amendment.” Wood appealed the district court’s grant of summary judgment to defendants on his first, third and fourth claims, because the district court assumed Martin’s advances were consensual. The Ninth Circuit reversed the district court’s summary judgment on Wood’s Eighth Amendment claim, providing that a prisoner is entitled to the presumption that conduct advanced by a prison official on an inmate is not consensual, given the power imbalance. The Court held that Martin’s behavior was “offensive to human dignity” and served no penological purpose. The Ninth Circuit affirmed the district court’s grant of summary judgment on Wood’s third and fourth claims. The Court determined that defendants had protected Wood by removing him to a different facility so that Martin would no longer be a threat, and found that the move was not done in retaliation. REVERSED in part, AFFIRMED in part and REMANDED for trial.