Certain prisoners are targeted for sexual assault the moment they enter a penal facility: their age, looks, sexual orientation, and other characteristics mark them as candidates for abuse. A clear example is that of Dee Farmer, a young preoperative transsexual with "overtly feminine characteristics" who was placed in regular housing in a maximum-security federal prison.(187) Brutally raped within two weeks of arriving, Farmer sued in federal court--later bringing the case all the way up to the U.S. Supreme Court--arguing that as a transsexual she was extremely likely to face sexual assault in prison. But a prisoner does not have to look like a woman to be vulnerable to such abuse. Rather, a broad range of factors are correlated with increased vulnerability to rape, some related to perceived femininity, some entirely unrelated.
Specifically, prisoners fitting any part of the following description are more likely to be targeted: young, small in size, physically weak, white, gay, first offender, possessing "feminine" characteristics such as long hair or a high voice; being unassertive, unaggressive, shy, intellectual, not street-smart, or "passive"; or having been convicted of a sexual offense against a minor. Prisoners with any one of these characteristics typically face an increased risk of sexual abuse, while prisoners with several overlapping characteristics are much more likely than other prisoners to be targeted for abuse.
The characteristics of prison rapists are somewhat less clear and predictable, but certain patterns can nonetheless be discerned. First, although some older inmates commit rape, the perpetrators also tend to be young, if not always as young as their victims--generally well under thirty-five years old. They are frequently larger or stronger than their victims, and are generally more assertive, physically aggressive, and more at home in the prison environment. They are "street smart"--often gang members. They have typically been convicted of more violent crimes than their victims.
The myth of the "homosexual predator" is groundless. Perpetrators of rape typically view themselves as heterosexual and, outside of the prison environment, prefer to engage in heterosexual activity. Although gay inmates are much more likely than other inmates to be victimized in prison, they are not likely to be perpetrators of sexual abuse.
The elements of race and ethnicity have a complex and significant bearing on the problem of prisoner-on-prisoner sexual abuse. As previously discussed, racial and ethnic distinctions are nowhere more salient than they are in prison: all social interaction is refracted through the prism of these group differences. Inter-racial sexual abuse is common only to the extent that it involves white non-Hispanic prisoners being abused by African Americans or Hispanics. In contrast, African American and Hispanic inmates are much less frequently abused by members of other racial or ethnic groups; instead, sexual abuse tends to occur only within these groups.
While all of the above factors are relevant and important, none should not viewed as controlling. In the wrong circumstances, it should be emphasized, almost any prisoner may be at risk of sexual abuse. Proper classification and monitoring of vulnerable prisoners should be one aspect of a rape prevention plan, but only one aspect: other prevention policies are equally necessary to stop sexual abuse in prison.
Young or youthful-looking inmates are at particular risk of rape.(188) The expression "kid," frequently used in prison to describe the victim of a coercive sexual relationship, suggests the connection between youth and victimization. Examples such as Rodney Hulin, the seventeen-year-old Texas inmate whose case is described above, illustrate this linkage. Placed in an adult prison and repeatedly raped by older inmates, Hulin committed suicide in 1995.(189)
Human Rights Watch has had only a few direct contacts with juvenile prisoners in the course of research for this report, although it has received numerous reports about their treatment from other prisoners, in addition to hearing from some older prisoners about incidents that occurred when they were minors. In 1998, the mother of an Arkansas prisoner contacted Human Rights Watch to report that her son, a friend of his who was only sixteen, and a third prisoner were all raped in the same cellblock in April of that year.(190) Human Rights Watch wrote to the young prisoner, who was being held in an adult prison, asking about his situation. He responded:
Sorry for taking so long to write, but I have been having a lot of trouble. I'm 16teen. I got into a fight and I got a broke bone in my arm. It don't hurt that bad. Now about the trouble I have been having. I have had 2 people try to rape me . . . . I have tryed to go to P.C. [protective custody] but they wouldn't let me.(191)
In his next letter to Human Rights Watch, R.P. explained:
When I was in B pod I had 3 dude's coming to me that said they was the only thing that was keeping me from getting raped, and they wanted to jack off and look at me. The pod I'm in now I had 2 people come to me and put a ink pen to my neck and tell me that if I didn't let them jack off on me they were going to rape me. I told the officer but they didn't do any thing about it.(192)
R.P. never directly said that he was raped but he has complained about severe and continuing sexual harassment from adult prisoners. Prisoners in other institutions have confirmed that R.P.'s situation is typical, stating that young prisoners like R.P. are viewed as more attractive sexually and more easily abused. A Florida prisoner said:
Mostely young youthful Boy's are raped because of their youth and tenderness, and smooth skin that in the mind of the one duing the raping he think of the smooth skin and picture a woman . . . . Prisoners even fight each other over a youth without the young man knowing anything about it to see whom will have the Boy first as his property.(193)
An inmate in Nebraska told Human Rights Watch:
The kids I know of here are kept in the hospital part of the prison until they turn 16. Then they are placed in general population. . . . At age 16, they are just thrown to the wolves, so to speak, in population. I have not heard of one making it more than a week in population without being "laid."(194)
As described below, small size is another risk factor; small young prisoners are thus especially vulnerable to sexual abuse. A Utah inmate told Human Rights Watch:
[When I was sent to prison,] I was just barely 18 years of age, about 90 pounds. I did nine years from March 1983 to November 1991. In that 9 years I was raped several times. I never told on anyone for it, but did ask the officer for protective custody. But I was just sent to another part of the prison. Than raped again. Sent to another part of the prison. Etc.(195)
Some inmates told Human Rights Watch of hardened convicts who prey on young prisoners. One spoke of "a guy who has served over 20 years, and he is a tough guy. What he has done for years, is gets the young guys in his cell & gets them high & then chokes them unconsious & proceeds to rape them."(196) Belying the stereotype of the older predator, however, is the much more common story of the young perpetrator of sexual abuse, generally someone between twenty and thirty years old. Although very young prisoners--those under twenty--are likely to be abused by prisoners who are older than them, most inmates in their twenties who reported abuse to Human Rights Watch were not abused by inmates significantly older than they were.(197)
If a person is timid or shy or as prison inmates term him 'Weak,' either mentally or physically, he stands to be a victim of physical and/or sexual assault.(198)
Unsurprisingly--given that physical force, or at least the implicit threat of physical force, is a common element of rape in prison--victims of rape tend to be smaller and weaker than perpetrators. In one extreme example, an inmate who described himself as "a small person weighing only about 140 pounds" told Human Rights Watch of an attack "by a man about 6'7" and weighing approximately 280 pounds."(199) Many more inmates described being intimidated or overpowered by larger, stronger perpetrators.
Very small inmates face an especially difficult time in prison. Human Rights Watch interviewed a Texas prisoner who was only five feet tall. He said he was so vulnerable he felt like "a hunted animal" most of the time.(200) He claimed to have been sexually abused on countless occasions.
Strong, physically imposing inmates are safer from sexual abuse. An inmate's size and strength is particularly important in terms of fending off unwanted advances from cellmates, a fairly common problem. Yet size and strength alone, inmates emphasized, are never an absolute guarantee against abuse. "I don't care how big and bad you are, if you've got five dudes up against you, you're in trouble," one prisoner pointed out.(201)
More important than sheer physical characteristics, in many inmates' view, is "heart"--the courage to fight and not give up even when losing--and a willingness to resort to violence when provoked. An inmate has to prove that he will stand up for himself against intimidation. A strong, aggressive attitude is just as necessary as physical strength. Inmates perceived as timid, fearful, "passive," or not aggressive are likely to be targeted for victimization, whereas inmates who have gained the respect of their fellows are likely to be safe. As one inmate explained:
Smaller, weaker, meeker individuals are usually targets. Meeker individuals tend to "act Gay" is how it's described here and in turn invites assault through the agressors mind. A new inmate needs to come into the system ready to fight and with a strong mind.(202)
It is thus unsurprising that mentally ill or retarded prisoners, whose numbers behind bars have increased dramatically in recent years, are at particular risk of abuse.(203) An Indiana prisoner suffering from schizophrenia told Human Rights Watch that he was constantly being coerced into unwanted sex. Describing his situation, he said:
So one day I goes to the day room going to get my medication there was a big Black guy both of them call me to the back of the day room. they were punking me out. I didn't want to fight them they made me call them daddy, made kept repeating it. . . . these things keeps happening to me. . . . these officers and these inmate they take avantige of the weak give them coffee, cigerette to make them do things for them. . . . there was a White guy that took advanteges of me in prison at another facility. . . . I don't no my rights or about the law, so I'm hit everytime I go to prison.(204)
By all reports, perpetrators tend to be stronger, more physically aggressive, and more assertive than their victims. Even more importantly, they tend to be better established in the inmate hierarchy. Often they are gang members with a network of inmate allies. This is, of course, particularly true with gang rapes, but it is also true with individual acts of abuse. A less established prisoner may be intimidated into submitting to sex with a powerful inmate or gang member out of fear that, were he to refuse, a more violent gang attack would ensue.
As this might suggest, newly incarcerated first offenders are especially vulnerable to sexual abuse. Lacking allies, unfamiliar with the unwritten code of inmate rules, and likely to feel somewhat traumatized by the new and threatening environment, they are easy prey for experienced inmates. "It's a sink or swim situation," said one prisoner who was beaten and raped soon after entering prison. "I sunk."(205) He explained:
My first mistake was not hanging out with the ignorant tough guys, and staying in my cell most of the time: they take that as a sign of weakness. I wasn't ready for the clique action. The prison was a gladiator farm back then; I kept getting into fights and finally I couldn't do it any more. I was getting beaten up every day for a month.
Describing the dangers of this initial entry period, an Arkansas prisoner told Human Rights Watch:
When a new inmate enters an open barracks prison it triggers a sort of competition among the convicts as to who will seduce and subjugate that new arrival. Subjugation is mental, physical, financial, and sexual. Every new arrival is a potential victim. Unless the new arrival is strong, ugly, and efficient at violence, they are subject to get seduced, coerced, or raped . . . Psychosocially, emotionally, and physically the most dangerous and traumatic place I can conceive of is the open barracks prison when first viewed by a new inmate.(206)
A Minnesota prisoner gave a similar account of the reception awaiting new inmates:
When an inmate comes in for the first time and doesnt know anyone. The clicks and gangs. Watch him like Wolves readying there attacks. They see if he spends time alone, who he eats with. Its like the Wild Kingdom. Then they start playing with him, checking the new guy out. (They call him fresh meat.)(207)
Numerous judicial decisions, newspaper and magazine stories, and even some scholarly articles describe the threat of "predatory homosexuals" in prison and the problem of "homosexual rape."(208) Yet prisoners who self-identify as gay are much more likely than other prisoners to be targeted for rape, rather than being themselves the perpetrators of it.(209)
To some extent, the talk of predatory homosexual inmates simply reflects a lack of semantic clarity. Since prisoner-on-prisoner rape is by definition homosexual, in that it involves persons of the same sex, its perpetrators are unthinkingly labeled predatory homosexuals. This terminology is deceptive, however, in that it ignores the fact that the vast majority of prison rapists do not view themselves as gay. Rather, most such rapists view themselves as heterosexuals and see the victim as substituting for a woman. From this perspective the crucial point is not that they are having sex with a man; instead it is that they are the aggressor, as opposed to the victim--the person doing the penetration, as opposed to the one being penetrated. Indeed, if they see anyone as gay, it is the victim (even where the victim's sexual orientation is clearly heterosexual).
An Illinois prisoner explained inmates' views on the question:
The theory is that you are not gay or bisexual as long as YOU yourself do not allow another man to stick his penis into your mouth or anal passage. If you do the sticking, you can still consider yourself to be a macho man/heterosexual, according to their theory. This is a pretty universal/widespread theory.(210)
Equal and voluntary gay relationships do not fit comfortably within this dichotomy. Although outsiders may perceive male prisons as a bastion of gay sexuality, the reality is quite different. Gay relationships typical of regular society are rare in prison, and usually kept secret. Indeed, many gay inmates--even those who are openly gay outside of prison--carefully hide their sexual identities while incarcerated. They do so because inmates who are perceived as gay by other inmates face a very high risk of sexual abuse. Human Rights Watch has received reports of rape from numerous gay inmates, all of whom agree that their sexual orientation contributed to the likelihood of victimization.(211)
Some prisoners have told Human Rights Watch that inmate views on homosexuality are gradually changing, with a lessening of prejudice against gays as changing societal mores begin to permeate prison culture. Even these prisoners, however, acknowledge that gay inmates are still severely stigmatized--they just believe that their treatment has lately been improving.
Gay inmates with stereotypically "feminine" characteristics are especially vulnerable to sexual abuse. As one such inmate described:
I have long Blond hair and I weigh about 144 lbs. I am a free-world homosexual that looks and acts like a female . . . . In 1992 I came to this Unit and was put into population. There was so many gangs and violence that I had know choice but to hook up with someone that could make them give me a little respect . . . . All open Homosexuals are preyed upon and if they don't choose up they get chosen.(212)
Unsurprisingly, transsexual prisoners like Dee Farmer, whose case went to the Supreme Court, face unrelenting sexual harassment unless another inmate is protecting them. Such inmates nearly always have an inmate "husband," someone powerful enough in the inmate hierarchy to keep other inmates away.
Past studies have documented the prevalence of black on white sexual aggression in prison.(213) These findings are further confirmed by Human Rights Watch's own research. Overall, our correspondence and interviews with white, black, and Hispanic inmates convince us that white inmates are disproportionately targeted for abuse.(214) Although many whites reported being raped by white inmates, black on white abuse appears to be more common. To a much lesser extent, non-Hispanic whites also reported being victimized by Hispanic inmates.
Other than sexual abuse of white inmates by African Americans, and, less frequently, Hispanics, interracial and interethnic sexual abuse appears to be much less common than sexual abuse committed by persons of one race or ethnicity against members of that same group. In other words, African Americans typically face sexual abuse at the hands of other African Americans, and Hispanics at the hands of other Hispanics. Some inmates told Human Rights Watch that this pattern reflected an inmate rule, one that was strictly enforced: "only a black can turn out [rape] a black, and only a chicano can turn out a chicano."(215) Breaking this rule by sexually abusing someone of another race or ethnicity, with the exception of a white inmate, could lead to racial or ethnic unrest, as other members of the victim's group would retaliate against the perpetrator's group. A Texas inmate explained, for example: "The Mexicans--indeed all latinos, nobody outside their race can 'check' one without permission from the town that, that person is from. If a black dude were to check a mexican w/out such permission & the mexican stays down & fights back, a riot will take place."(216)
The causes of black on white sexual abuse in prison have been much analyzed. Some commentators have attributed it to the norms of a violent black subculture, the result of social conditioning that encourages aggressiveness and the use of force.(217) Others have viewed it as a form of revenge for white dominance of blacks in outside society.(218) Viewing rape as a hate crime rather than one primarily motivated by sexual urges, they believe that sexually abused white inmates are essentially convenient surrogates for whites generally. Elaborating on this theory, one commentator surmised that "[i]n raping a white inmate, the black aggressor may in some measure be assaulting the white guard on the catwalk."(219)
Some inmates, both black and white, told Human Rights Watch that whites were generally perceived as weaker and thus more vulnerable to sexual abuse. An African American prisoner, describing the situation of incarcerated whites, said:
When individuals come to prison, they know that the first thing that they will have to do is fight. Now there are individuals that are from a certain race that the majority of them are not physically equip to fight. So they are the majority that are force to engage in sexual acts.(220)
Another African American inmate, while generally agreeing with the idea of whites as easy victims, gave a more politically-oriented explanation for the problem of black on white sexual abuse:
Before I continue, let me explain that I consider myself to be speaking from mainly a black perspective. The reason I say that is not to be racist, but to emphasize that on the main, blacks, whites, hispanics, etc. . . . have a different outlook on prison rape from a convict viewpoint. Most [blacks] feel that the legal system is fundamentally racist and officers are the most visible symbol of a corrupt institution & with good reason . . . . [B]lacks know whites often associate crime with black people. They see themselves as being used as scapegoats . . . . So is it any wonder that when a white man comes to prison, that blacks see him as a target. Stereotypes are prevalent amongst blacks also that cause bad thinking. The belief that all or most white men are effete or gay is very prevalent, & that whites are cowards who have to have 5 or 6 more to take down one dude . . . . Whites are prey and even a punk will be supported if he beats up a white dude.
Prior studies have found that the crimes for which victims of rape are incarcerated are generally less serious and less violent than those for which the perpetrators of rape are incarcerated.(221) Although findings by Human Rights Watch on this issue are tentative--especially because many victims of sexual abuse have no idea what crime their rapists were convicted of--they tend to support this argument. A few of the victims who provided information to us were convicted of serious, violent crimes such as murder, but a striking proportion of them were nonviolent felons, many of them convicted of crimes such as burglary, drug offenses, passing bad checks, car theft, etc. Of the minority of victims who were aware of the criminal history of the perpetrator of abuse, many reported serious and violent crimes. This general pattern is consistent, of course, with the idea that perpetrators of rape tend to be more violent people than victims, both inside and outside of prison.
With one exception, no specific crime seems to be associated with either perpetrators or victims. The exception is sexual abuse of a minor. Although the vast majority of victims of prison rape are incarcerated for other crimes, it is apparent that inmates convicted of sex crimes against minors, if their crimes become known to other inmates, are much more apt to be targeted for sexual abuse in prison. A number of inmates convicted of such offenses reported being sexually assaulted by other prisoners; all stated that the nature of their crime inspired the assault or increased its likelihood. "It took about seven months before my crime became known," one such prisoner explained. "Then everyone came down on me. They beat me with mop handles and broom sticks. They shoved a mop handle up my ass and left me like that."(222)
This man was transferred to another institution but other inmates who knew of his crime were transferred with him. Some three weeks after the transfer, his cellmate woke him up at 2:30 a.m. and raped him, bashing him in the back of the head with a combination lock. "The guy told me, 'I will teach you what a baby raper is.'"
Explaining the targeting of prisoners convicted of sexually abusing minors, another inmate said:
Inmates confined for sexual offenses, especially those against juvenile victims, are at the bottom of the pecking order and consequentially most often victimized. Because of their crime, the general population justifies using their weakness by labling rape "just punishment" for their crime. Sexual offenders are the number one target group for prisoner rape.(223)
Most sexual abuse in prison is not between total strangers: the victim and at least one of the perpetrators usually have some prior awareness of each other, however cursory. In some instances, victims have described a long period of harassment that escalates in stages, from leering to sexually aggressive comments to threats, culminating in a physical assault. A Texas inmate described such a scenario to Human Rights Watch:
[My cellmate] was younger, stronger than I and larger. He introduced himself as a bi-sexual. And was for two weeks "touchie-feelie." I had to screem/yell at him to stop. The officers here 1. Ignored my complaints. 2. Asked me if I was his lover. 3. Did nothing. He became more difficult to deal with and started to threaten me. Finally one day he attacked me.(224)
In other instances, the progression is much more rapid: an inmate who makes an ugly comment at lunch may commit rape in the evening.
Of the various forms of sexual abuse, it is violent or forcible rapes, or rapes under threat of violence, that are most likely to involve strangers or inmates with a very slight acquaintanceship. More subtly coercive sexual relationships, in contrast, take time to develop. The perpetrator may initially appear to be a friend, even an apparent protector, but will take advantage of his acquaintance with the victim to intimidate and coerce him into sexual contact.
One relationship that presents a clear danger of sexual abuse, both of the overtly violent and of the coercive sorts, is that of cellmates. With two-man cells becoming more common in American prisons, due to overcrowding and space constraints, inmates are often thrown into intimate living situations with persons whom, according to the factors described above, present them with a high risk of sexual abuse. Prison officials, preoccupied with other priorities, pay inadequate attention to the question of prisoners' compatibility when assigning cell spaces. While they may take care to avoid housing members of different gangs together, or inmates known to be enemies, their attention usually stops there. Prisoners are frequently double-celled with much larger, stronger, tougher inmates, even with prisoners who have a known history of sexual abuse. Unsurprisingly, a large number of inmates report having been raped by their cellmates.
The alarming frequency of such reports indicates to Human Rights Watch that prison officials should take considerably more care in matching cell mates, and that, as a general rule, double-celling should be avoided.
187. See Farmer v. Brennan, 511 U.S. 825 (1994). Farmer's feminine characteristics included silicone breast implants.
188. Previous studies and analyses agree on this point. See, for example, Daniel Welzer-Lang, Lilian Mathieu and Michael Faure, Sexualités et violences en prison (Lyon: Aleas, 1996), pp. 150-53; Carl Weiss and David James Friar, Terror in the Prisons: Homosexual Rape and Why Society Condones It (Indianapolis: Bobbs-Merrill, 1974), p. 74 (explaining that "[n]o age escapes prison rape, but youth is hit the hardest). Accounts of minors imprisoned with adults often make reference to sexual abuse. For example, Amnesty International, in its 1998 report on juvenile justice in the United States, quoted a letter from an incarcerated fifteen-year-old in which the boy stated that adult inmates were "talk[ing] to me sexually." He said: "They make moves on me. I've had people tell me I'm pretty and that they'll rape me . . . I'm even too scared to go eat." Amnesty International, "Betraying the Young: Children in the U.S. Justice System" (AMR 51/60/98), 20 November 1998.
189. See case history described above.
190. Human Rights Watch telephone interview with J.Q., Arkansas, August 25, 1998. The woman said that her son, age twenty, was incarcerated for burglary, while four of the inmates who raped him had life sentences.
191. Letter to Human Rights Watch from R.P., Arkansas, September 14, 1998.
192. Letter to Human Rights Watch from R.P., Arkansas, October 5, 1998.
193. Letter to Human Rights Watch from W.W., Florida, February 19, 1999.
194. Letter to Human Rights Watch from D.A., Nebraska, October 31, 1996.
195. Letter to Human Rights Watch from R.H, Utah, September 10, 1996.
196. Letter to Human Rights Watch from C.B., Minnesota, July 19, 1999.
197. Other studies have also found that both the victims and perpetrators of sexual abuse tend to be young, although perpetrators in mixed-age institutions may be slightly older than victims. See, for example, Lockwood, Prison Sexual Violence, p. 28.
198. Letter to Human Rights Watch from R.B., California, September 1, 1996.
199. Letter to Human Rights Watch from J.C., Texas, December 16, 1998.
200. Human Rights Watch interview, Texas, March 1999.
201. Human Rights Watch interview, California, May 1998.
202. Letter to Human Rights Watch from R.B., Texas, October 13, 1996.
203. It is estimated that between 6 and 15 percent of prison and jail inmates are seriously mentally ill. See Editorial, "Jails and Prisons--America's New Mental Hospitals," American Journal of Public Health, December 1995, p. 1612.
204. Letter to Human Rights Watch from B.S., Indiana, June 16, 1999.
205. Human Rights Watch interview, Texas, March 1999.
206. Letter to Human Rights Watch from L.V., Arkansas, September 25, 1996.
207. Letter to Human Rights Watch from J.G., Minnesota, August 8, 1996.
208. Among the judicial decisions discussing the problem of "homosexual predators" are: Cole v. Flick, 758 F. 2d 124 (3d Cir. 1985) (upholding prison regulations limiting inmates' hair length, in part because allowing inmates to wear long hair could lead to an increase in attacks by "predatory homosexuals"); Roland v. Johnson, 1991 U.S. App. LEXIS 11468 (6th Cir. 1991) (describing "gangs of homosexual predators"); Roland v. Johnson, 856 F. 2d 764 (6th Cir. 1988); Ashann-Ra v. Virginia, 112 F. Supp. 2d 559, 563 (W.D. Va. 2000) (mentioning "inmates known to be predatory homosexuals" who "stalk other inmates in the showers").
209. The homophobia that may underlie the judicial stereotype of the inmate "homosexual predator" also shows itself in cases involving gay victims of rape. See, for example, Carver v. Knox County, 753 F. Supp. 1370, 1380 (E.D. Tenn. 1989) (pointing out that an inmate witness admitted on cross-examination that "the rape he witnessed was of a known homosexual whose cries for help may not have been as vigorous as those of a heterosexual inmate under the same circumstances").
210. Letter to Human Rights Watch from P.N.E., Illinois, October 28, 1997. See also Stephen Donaldson, "A Million Jockers, Punks, and Queens: Sex among American Male Prisoners and its Implications for Concepts of Sexual Orientation," February 4, 1993. Donaldson explains that "the sexual penetration of another male prisoner by [a dominant prisoner] is considered a male rather than a homosexual activity, and is considered to validate the penetrator's masculinity." Ibid., p. 5. He later goes on to emphasize that "[f]or the majority of prisoners, penetrative sex with a punk or queen remains a psychologically heterosexual and, in the circumstances of confinement, normal act." Ibid., p. 12.
211. Previous studies have similarly concluded that gays face a higher risk of sexual assault and abuse. See, for example, Wayne S. Wooden and Jay Parker, Men Behind Bars (New York: Plenum Press, 1982), p. 18 (finding that 41 percent of homosexual were sexually assaulted, as opposed to 9 percent of heterosexuals); see also Gregory v. Shelby, 220 F. 3d 433 (6th Cir. 2000) (gay jail inmate sexually abused and killed by another inmate).
212. Letter to Human Rights Watch from M.P., Arkansas, September 24, 1996.
213. See, for example, Leo Carroll, "Humanitarian Reform and Biracial Sexual Assault in a Maximum Security Prison," in Anthony M. Scacco, Jr., ed., Male Rape (1982); Alan J. Davis, "Sexual Assaults in the Philadelphia Prison System," in Male Rape; Daniel Lockwood, Prison Sexual Violence (1980); Hans Toch, Living in Prison (1992); C. Scott Moss, Ray E. Hosford and William R. Anderson, "Sexual Assault in a Prison," Psychological Reports, vol. 44 (1979); David A. Jones, The Health Risks of Imprisonment (1976).
214. Human Rights Watch's sources of information were almost entirely made up of white, African American, and Hispanic inmates; we did not receive enough information from members of other minorities to be able to reach any conclusions as to their general situation.
215. Letter to Human Rights Watch from W.M., Texas, October 31, 1996.
216. Letter to Human Rights Watch from T.D., Texas, March 14, 1997.
217. See, for example, Lockwood, Prison Sexual Violence, pp. 105-06.
218. See, for example, Anthony M. Scacco, Jr., Rape in Prison (Springfield, IL: Charles C. Thomas, 1975).
219. Leo Carroll, "Race, Ethnicity, and the Social Order of the Prison," in Johnson and Hans Toch, The Pains of Imprisonment (1982), p. 194.
220. Letter to Human Rights Watch from V.H., Arkansas, November 17, 1996.
221. See, for example, Davis, "Sexual Assaults," pp. 14-15; Nobuhle R. Chonco, "Sexual Assaults among Male Inmates," The Prison Journal, vol. 68, no. 1 (1989), p. 74.
222. Human Rights Watch interview, Texas, October 1998.
223. Letter to Human Rights Watch from L.V., Arkansas, September 3, 1996.
224. Letter to Human Rights Watch from D.G., Texas, January 15, 1998.