Crawford v. Cuomo
796 F.3d 252
| 2d Cir. | 2015Background
- Case concerns Prindle’s alleged sexual abuse of Corley and Crawford at ECF, leading to Eighth Amendment claims and district court dismissal for failure to state a claim under Boddie v. Schnieder.
- Court remanded to consider whether Boddie’s standard applies under evolving societal decency standards.
- Appellants challenge the district court’s narrow reading of Boddie; the court reverses.
- Allegations include Corley’s March 12, 2011 abuse during a visit and Crawford’s later, extensive search abuse, with threats and humiliating conduct.
- Complaint also alleges extensive inmate grievances and supervisor Brown’s role in alleged neglect or deliberate indifference.
- Procedural posture: district court dismissed; on appeal court reverses and remands for further proceedings, including qualified immunity questions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Boddie’s standard applies to evolving decency standards | Crawford/Corley argue Boddie is broader than framed | Prindle/Brown contend Boddie is narrow | Boddie applies but must reflect evolving decency |
| Whether a single gratuitous sexual act can violate the Eighth Amendment | Single incident can suffice if severe | Not necessarily sufficient without more | Yes, a single incident can violate if sufficiently severe or serious |
| Whether the alleged acts were sufficiently purposeful and non-penological | Acts served arousal/humiliation, not penological | Searches may be penologically justified | Conduct was non-penological and injurious; violated Eighth Amendment |
| How contemporary standards of decency affect Boddie’s applicability | Evolving standards broaden liability | Standards remain governed by Boddie’s framework | Contemporary standards expand the reach of Boddie; conduct violates today |
Key Cases Cited
- Boddie v. Schnieder, 105 F.3d 857 (2d Cir.1997) (sexual abuse may violate Eighth Amendment if severe or repetitive)
- Wilson v. Seiter, 501 U.S. 294 (U.S. 1991) (two-prong test for Eighth Amendment claims)
- Hudson v. McMillian, 503 U.S. 1 (U.S. 1992) (culpable state of mind and seriousness of conduct)
- Whitley v. Albers, 475 U.S. 312 (U.S. 1986) (contextual analysis of force; purpose for use matters)
- Estelle v. Gamble, 429 U.S. 97 (U.S. 1976) (standard: cruel and unusual punishment requires more than de minimis harm)
- Graham v. Florida, 560 U.S. 48 (U.S. 2010) (evolving standards of decency guide constitutional analysis)
- Atkins v. Virginia, 536 U.S. 304 (U.S. 2002) (objective indications of contemporary values inform analysis)
- Kennedy v. Louisiana, 554 U.S. 407 (U.S. 2008) (evolving standards of decency affect application of Eighth Amendment)