Crawford v. Cuomo

Simon Prindle (defendant) was a corrections officer at a New York prison. Former prisoner James Crawford and current prisoner Thaddeus Corley (plaintiffs) sued New York Governor Andrew Cuomo, Prindle, and others in federal district court for violating their Eighth Amendment rights. Crawford alleged that Prindle grabbed him, forced him against a wall, and fondled his genitals and thighs for an extended period under the guise of a search. When Crawford objected, Prindle said Crawford had no rights and that Prindle could touch him anywhere he wanted. Prindle also threatened to harm Crawford or place him in solitary confinement if he resisted. Corley alleged that Prindle kicked Corley’s wife out of a visiting room, then fondled and threatened Corley like he had Crawford, claiming he was searching for an erection. Crawford and Corley also alleged that other prisoners had complained to the prison that Prindle had made sexually demeaning comments to them, such as referencing their penises, and forced them to bend over and expose their anuses under the guise of anal-cavity searches. The district court dismissed the complaint, ruling that (1) Crawford and Corley had each alleged only a single incident and (2) sexual abuse by a corrections officer could violate the Eighth Amendment only if it occurred repeatedly. Crawford and Corley appealed.