U.S. District Court: SEXUAL ASSAULT OFFICE ON PRISONER ASSAULT.

Daniels v. Delaware, 120 F.Supp.2d 411 (D.Del. 2000). A state inmate who had been raped by a correctional officer and became pregnant as a result, sued prison officials under [sections] 1983 and the Violence Against Women Act (VAWA). The district court granted summary judgment in favor of the defendants. The court held that the inmate failed to establish that the officials had been deliberately indifferent to her health and safety, even though they had previously investigated the correctional officer for taking female inmates outside their cells after lockdown. The court noted that there was not evidence that the previous incident involved sexual misconduct and the officials had disciplined the officer and changed lock down procedures following the investigation.

The court found that the inmate failed to establish a failure to train violation because the prison's training programs were found to be sufficient under national standards promulgated by the American Correctional Association. The offending officer had received an adequate number...