“Terrified of a System I Didn’t Understand”: Reporting Staff Sexual Misconduct Against Women on Parole

Abstract

Incarcerated women experience staff-perpetrated sexual victimization at high rates, yet limited research exists regarding women’s experiences of this victimization while on probation and parole, particularly regarding their formal reporting decisions. This qualitative study explored the formal reporting decisions for 10 women who experienced staff-perpetrated sexual victimization while on parole. Women who formally reported their victimization experiences qualitatively differed from non-reporting women in terms of the dynamics and their identification of victimization (e.g., viewing as support vs. fear) and in the types of structural barriers (e.g., vulnerability and cautionary tales) they encountered. These findings highlight policy, practice, theory, and research directions.

Keywords

parole women’s re-entry sexual violence staff sexual misconduct community corrections

Correctional staff-perpetrated sexual victimization violates institutional policies, state-level criminal laws, and federal policy mandates, yet a high number of incarcerated women experience this form of victimization, which is often framed as a form of gendered social control (Beck et al., 2014; Thomas & Zaitzow, 2003). Little attention is given to detecting, addressing, and preventing correctional staff-perpetrated sexual victimization that occurs while women are under forms of community-based correctional supervision, contributing to a neglect of this form of victimization (Yarussi & Smith, 2013). Some women who experience this form of victimization may formally report these experiences in order to stop the abuse and to receive assistance. The context of their decision-making about reporting includes multiple forms of system-level power dynamics that work to circumvent and constrain women’s power and choice (Goffman, 1961; Goodstein et al., 1984; Kubiak et al., 2018). Existing research is limited in regards to women’s decision-making with attention to the power dynamics of this context. Thus, this study utilized grounded theory methods to qualitatively explore the reporting decisions of 10 women on parole regarding their experiences of correctional staff-perpetrated sexual victimization and found a striking dynamic of individual-level and structural factors that influence women’s decision-making. The implications of this study push for nuanced, deepened theory advancement about the experiences of this population of women that explicitly account for multiple forms of power dynamics, as well as policy and practice changes.

Background

Rape and other types of sexual assault perpetrated against incarcerated women by correctional staff have received both national and international attention (Culley, 2012; Human Rights Watch, 1996; Siegal, 1991; Smith, 2020). This abuse (referred to formally as staff sexual misconduct) encompasses a wide range of behaviors, including privacy violations, sexual harassment, indecent exposure, inappropriate touching, and oral, vaginal, and anal penetration (Beck et al., 2013). Justice-involved women disproportionately experience sexual victimization by correctional staff; they represent 41% of victims, despite the fact that they make up only approximately 7% of all prisoners in the United States (Beck et al., 2014).

While the United States has close to 2.3 million people currently under correctional supervision, the vast majority of them are under some form of community supervision, an umbrella term for a complex array of agencies, supervision structures, and facilities (Jones, 2018; National Prison Rape Elimination Commission, 2009). In 2019, most justice-involved women (over 1 million women) were under community supervision (Carson, 2020). Women under community supervision face a number of issues, including needing to obtain stable housing, establish sufficient employment, and report to and comply with probation or parole officers’ conditions (Holtfreter & Morash, 2003; Morash, 2010). However, as with women’s pathways to criminal justice system involvement, their barriers to re-entry differ from men (Blackwell, 2020; Burgess-Proctor, 2006; Daly, 1992; Voorhis, 2012). For example, women are more likely to experience more tenuous family support and difficulty reunifying with their children, and report stigmatization that continues beyond release from incarceration that is gendered and racialized (Boppre & Reed, 2021; Opsal, 2015).

Staff sexual misconduct is an under-recognized barrier and harm for women on probation and parole. The American Probation and Parole Association and the International Community Corrections Association identified the potential for abuse in community supervision settings due to the dramatic power differences between correctional staff and women under supervision and the potential for this abuse to go undetected (Abner et al., 2009). The Prison Rape Elimination Act (PREA), which was passed in 2003 and fully implemented in 2012, puts forth a “zero tolerance” policy on all forms of sexual victimization in correctional institutions and seeks to improve the monitoring, prevention, and responses to sexual victimization (including staff sexual misconduct) in prisons, jails, immigration detention centers, and community-based residential correctional sites. However, PREA excluded preventing and addressing staff sexual misconduct that occurs in non-residential community supervision settings; these forms of abuse were removed from the final draft due to concerns about the feasibility of implementing this policy with great breadth successfully (Yarussi & Smith, 2013). Thus, the rates, dynamics, and reporting decisions related to staff sexual misconduct for women while under non-residential community supervision are vastly under-studied and under-addressed.

While there is no national data collection for this form of abuse, women on probation and parole report sexual abuse perpetrated by both probation officers and correctional staff (Bess, 2017; Webster, 2020). One study found that dynamics in prisons were replicated on parole, in which relational power imbalances facilitated abuse by correctional staff of women on probation and parole (Fedock et al., 2021). Probation and parole officers have access to sensitive and personal information about the people they supervise and they require contact, which can open the door to abuse (Fedock et al., 2021; Mccoy, 2014). Lawsuits filed in California and New Mexico by justice-involved women have included allegations of parole officers taking advantage of their positions of power, and women reported fearing that their probation/parole would be revoked if they refused the officers’ advances or refused to engage in sexual acts with the officers (Bess, 2017; Mccoy, 2014). Reporting is one mechanism through which changes can occur, including preventing and ending the abuse. Yet, little research has explored women’s experiences of staff sexual misconduct after prison, especially regarding women’s reporting decisions after they have experienced staff sexual abuse.

Theoretical Frame

Decades of research display that the carceral context shapes responses to situations by justice-involved individuals. Prisons have been identified as extremely controlling environments and this organizational context produces “total institutions,” that is, institutions that have surveillance and power over aspects of daily life and are rife with restrictions that strip residents of autonomy, limit legal rights, and reduce control over their surroundings (Foucault, 1977, 1982; Goffman, 1961; Goodstein et al., 1984). Individuals are forced to relinquish control over their own choices and day-to-day decisions, creating a dependency on the institution to control and dictate their behavior, which may erode their own systems of internal controls (Haney, 2003). While increasing personal control has benefits (e.g., improved self-perception and sense of agency; reduced stress), prolonged decreased control during incarceration often creates psychological harms including “learned helplessness” (Goodstein et al., 1984; Schill & Marcus, 1998). Learned helplessness theory argues that individuals may respond passively to harmful situations because they have learned that efforts to control or receive a predictable outcome are futile (Goodstein et al., 1984; Schill & Marcus, 1998).

In the prison context, the institutional dynamics and factors reinforce multiple forms of power imbalances and severely restrict and punish self-agency for incarcerated adults. These dynamics include staff’s inconsistent enforcement of rules, staff discretion in sanctions, and potential threats to bodily safety and release. Learned helplessness theory posits that prolonged exposure to uncontrollable aversive dynamics and events during incarceration will lead to a more negative and helpless attributional style (Goodstein et al., 1984; Schill & Marcus, 1998). This learned helplessness commonly results in emotional distress, cognitive constraints (e.g., thoughts of self-blame; feelings of hopelessness), reduced motivation to respond, and behavioral limitations and has been used to help understand why victims might stay in abusive relationships (Dunn, 2005; Maier & Seligman, 1976; Schill & Marcus, 1998). The ways that justice-involved individuals adapt to and survive within carceral settings (including developing learned helplessness) can complicate their re-entry process to the community, including how they respond to experiences of staff-perpetrated sexual abuse (e.g., they might experience a diminished sense of self-worth, which might deter reporting abuse) (Haney, 2003, 2012).

Understanding women’s decision-making regarding reporting their sexual assault victimization experiences requires explicitly examining environmental, institutional, and system factors that decrease their personal control and contribute to power imbalances between correctional staff and women; their decisions are restricted by detrimental power dynamics. Burdened agency theory was introduced by Meyers (2011) to understand how trafficked sex workers make decisions in violent contexts with few alternatives. Burdened agency helps understand decision-making as on a continuum of agency, taking into account constrained choice sets (Lentz, 2018; Meyers, 2011), has been applied in a criminal justice leadership context (Morabito & Shelley, 2018), and to understand domestic violence and food insecurity (Lentz, 2018). Burdened agency “acknowledges that victims can not escape from powers that inflict or threaten to inflict needless and terrible suffering, but it doesn’t strip them of the agentic complexity and resilience that are characteristic of humanity” (Meyers, 2011). Understanding how incarcerated individuals perceive their ability to exercise personal control and agency in the context of carceral settings is central to understanding their behavior (Goodstein et al., 1984). Burdened agency allows us to examine women’s understanding of control and reporting decisions surrounding staff sexual misconduct on parole.

Correctional supervision in community settings has some similarities to supervision in prisons or jails, but there are also important differences that may shape reporting decisions. Individuals have greater freedom and access to education, employment, and support systems while in the community (National Prison Rape Elimination Commission, 2009). However, there is still an imbalance of power in relationships with correctional staff (Abner et al., 2009). Similar uncertainties and lack of control (e.g., discretion in sanctions such as a return to prison for parole violations, access to information through formal systems) exist (Fedock et al., 2021; Goodstein et al., 1984). Additionally, legal gaps to addressing staff sexual misconduct on probation and parole persist: while 42 states prohibit sexual contact between community corrections staff and individuals, these laws may only apply to staff with supervisory or disciplinary authority over the justice-involved individual (American University Washington College of Law, 2020). Importantly, this narrow focus on only directly supervising staff “overlooks the possibility of a community corrections staff member who does not directly supervise a parolee but who can still influence that person’s community corrections status” perpetrating sexual violence (National Prison Rape Elimination Commission, 2009, p. 166).

Research on reporting sexual assault in prison has identified a range of factors at both individual and structural levels that uniquely deter reporting staff sexual misconduct in correctional settings (Kubiak et al., 2018). Behaviors by staff are often difficult for justice-involved women to identify as abuse. Barbara Owen and colleagues’ (2008) research on dynamics of staff sexual abuse of justice-involved women found that abuse occurs on a “continuum of coercion,” ranging from love and seduction, inappropriate comments, sexual requests, voyeurism, inappropriate searches, sexual exchange, intimidation, and non-violent and violence sex, making it hard to identify some behaviors as abusive. Additionally, correctional staff are given authority and instructions to search and have surveillance over incarcerated women’s bodies, making the lines between sexual abuse and sexual contact “in the line of duty” difficult to distinguish (Calhoun & Coleman, 2002). Even when women identify staff behaviors as abusive, the precarious legal circumstances of justice-involved women may make them less likely to report abuse to mainstream institutions, in part because institutions may have discounted, blamed, failed, and further harmed them (Brenner et al., 2016; Fedock et al., 2019; Richie, 2002).

Certain structural (e.g., institutional and cultural) barriers inherent to the prison also constrain the choices a justice-involved individual can make and present barriers to reporting staff sexual misconduct. These include a culture of silence and proscriptions against “snitching,” although this is more likely to deter incarcerated men from reporting abuse than incarcerated women (Department of Justice & Institute of Corrections, 2009; Garland & Wilson, 2013). Fearing and/or actually experiencing forms of retaliation from staff serves as a serious deterrent to reporting (Struckman-Johnson & Struckman-Johnson, 2002). A lack of safe, accessible, and confidential reporting mechanisms, and reports that were not investigated all contribute to reluctance to report (Kubiak et al., 2018; National Prison Rape Elimination Commission, 2009). Additionally, fears of harassment by other incarcerated adults and a fear of being put in protective custody (which denies women access to programs and privileges available in the general population) have been identified as serious deterrents (Levan Miller, 2010). In a recent study, women described how stigmas were associated with reporting sexual abuse and that reporting was seen as “rocking the boat,” resulting in harassment (Surrell & Johnson, 2020). Other aspects specific to prison staff culture, including officers’ protection of each other, play an important role in regards to when abuse is reported and if it is taken seriously by staff (National Prison Rape Elimination Commission, 2009; Surrell & Johnson, 2020).

Perceptions of control, agency, and reporting decisions for women on probation and parole have not been explored, and without such research, the ability to improve reporting-related policies and practices is limited. This current study focused on addressing these gaps with the following research questions: (1) What factors explain why women report and not report sexual abuse by correctional staff on parole? (2) How do women who report abuse differ from those who do not report?

Method

The present study utilizes data from litigation case files from Neal v. MDOC (Michigan Department of Corrections), a class action lawsuit¹ on behalf of 809 women against the state department of corrections. The lawsuit alleged sexual abuse civil rights violations by male correctional staff that occurred from 1996 until 2009 resulting in a settlement against the state for $100 million to the class members.² Data sources included all evidence compiled for litigation, which resulted in an extensive case file for each individual. The case file included a claim form filled out by each woman, describing demographic information, abuse, locations of correction supervision, years, instances of retaliation, and reporting information. This was supplemented with notes from attorneys, corrections files (e.g., internal investigation files), and documentation provided by the women, including letters and photos. Women in the class were notified by the lead attorney that their case files would be involved in research and were given an option to remove their file from the study. From the 809 women who participated in Neal v. MDOC and received a settlement, n = 7 decided to opt-out of having their records reviewed for this study. The methods for this study were approved by a university-based institutional review board.³

A total of 191, or 24%, of the class experienced penetrative victimization, which comprised the most severe victimization type. In contrast to improper touching or inappropriate comments (which could be construed as potentially valid parts of an officer’s discretion in performing their job duties), this penetrative contact is illegal under state law and against DOC policy. Of the women in the lawsuit who experienced penetrative sexual victimization, 11% (n = 21) described parole as the first or second location of this victimization. It is important to note that while the lawsuit focused on staff sexual misconduct during incarceration some women unexpectedly brought up abuse on parole in their description of penetrative abuse, which precipitated this study.

The subsample selected for this study included women who participated in the lawsuit and experienced vaginal, anal, oral, and/or digital penetrative abuse while on parole. To better understand reporting decisions, we utilized purposive sampling. To meet this goal, we constructed a subsample of women whose experiences reflected various dynamics of abuse that occurred on parole, was racially diverse, and captured those who reported abuse and those who did not. We selected 10 women who had experienced abuse during parole, and purposefully selected five women who reported the abuse formally (to a parole officer, correctional staff, or police) and five women who did not report. Our selection of these cases was intended to capture a variety of types of settings in which abuse had begun and was further shaped by the availability of case materials. Thus, the final sample included four women who described experiencing penetrative abuse that began on parole or immediately before release from prison, while the remaining six described some level of abuse that had occurred while incarcerated and continued or escalated on parole. Of the abuse discussed in the findings, eight women’s experiences included a male correctional facility staff member perpetrator, one included a male parole officer perpetrator (not directly supervising the participant) and one included a male parole officer who was directly supervising the participant. Of the 10 women in the sample, five women identified as African American/Black, four women as white, and one woman as multiracial. Over half of the women had been incarcerated for property offenses, two for drug-related offenses, and two for assaultive offenses, and the length of their sentences ranged from maximums of 4–20 years.

Analysis

The litigation data sources were analyzed inductively using constant comparative analysis and grounded theory methods (Glaser & Strauss, 1967). Constant comparison was utilized at every stage of analysis to facilitate joint coding and analysis and required revisiting the data numerous times to identify key emergent themes in the data (Auerbach & Silverstein, 2003). In order to make comparisons across groups about decisions to report the abuse, the case files were coded in two separate groups: those women who reported formally and those women who did not. To apply the process of constant comparison, we adapted Auerbach and Silverstein’s (2003) step-by-step approach to data analysis. This process culled the case files into relevant text to analyze and entailed a three-level categorization system analyzing the content. First, we identified low-level text-based categories, then developed middle-level themes, and, finally, developed higher-level theoretical constructs (Auerbach & Silverstein, 2003).

The first level of analysis included reading the content of each case file line by line through the process of open coding. The first author lead the coding, and similar words or phrases that depicted the same concept were extracted and labeled as repeating ideas. The next step entailed organizing the repeating ideas into larger groups that shared a common topic to form themes. This process was performed separately for the group of women who reported and for those who did not. We made systematic comparisons across themes to identify similarities and differences in their experiences and decisions related to reporting. Finally, from the themes, overarching theoretical constructs were identified to encompass all the themes. As the repeating ideas were organized into themes and theoretical constructs, the research team continued to engage in comparison, refinement, and interpretation to identify patterns in the data (Auerbach & Silverstein, 2003; Charmaz, 2006). As an example, the three-tiered coding framework looked for repeating ideas around feeling used, which connected to a theme of being manipulated by abuser, which for reporting women aligned with the theoretical construct of grooming. This method allowed for moving to a more abstract level of understanding reporting sexual abuse on parole.

Results

In this sample, five women on parole reported their experiences of staff-perpetrated sexual abuse to a DOC authority directly (e.g., by filing a grievance at the prison, reporting informally to a staff member or to their parole officer) or indirectly, (e.g., detailing abuse in an investigation) and five did not report. For some of the women, the abuse on parole was a continuation of abuse that occurred within the prison, as Crystal⁴ noted, “I too suffered … not just in prison, but also outside prison.” Below, we detail the common themes that were identified, and while there were not differences in the type of abuse that the women experienced, there were differences between reporting and non-reporting women in terms of perceived control and consent. In addition, both groups faced structural barriers to reporting.

Reporting Women

Control and Consent

Both women who reported and did not report expressed grappling with complex issues of control and consent. The following accounts in this section come from women who reported the abuse. For the women who reported, a consistent theme was women, at some point, being able to identify their experiences with staff as abusive and this realization leading to a reporting decision. Women who reported described abusive relationships that were, at times, supportive and, at other times, adversarial. The supportive aspects of the abusive relationship reflected emotional attachment, developing a sexual relationship, or receiving tangible support from the correctional officer. For example, Bianca acknowledged, “I both developed and carried out both an emotional and sexual relationship with my assigned parole officer.” For other women, the abuse was masked by tangible support that was offered by correctional staff. Anika said “he promised to help me out to get on my feet, while on parole.” These complex and changing relationship dynamics made it difficult to identify abuse in part because it carried aspects of acquaintance rape or “love relationships” identified in prison sexual assault research, in which victims do not usually consider their assaults to be rape or sexual abuse and rarely come forward to identify themselves as victims to authorities (Calhoun & Coleman, 2002; Parrot & Bechhofer, 1991; Warshaw, 1988).

Supportive aspects of the relationship were simultaneously accompanied by adversarial or abusive aspects. Given the illicit nature of the relationship, some officers went out of their way to conceal the relationship. While Anika received support from her perpetrator, she simultaneously described him as “paranoid” about their relationship being discovered. Likewise, Crystal noted how her abuser “didn’t want anyone to know” about his visits to her while on parole. Some officers relied on threats to ensure women kept the abuse quiet. When Crystal violated her parole and was sent back to prison, the officer “threatened that if I did not return his letters he wrote to me he would not only leave me alone and not ‘love’ me anymore, but that he would see that I would not make parole.” In a similar vein, Janice feared that if she reported “[h]e’s gonna call his people out here. He got some crazy nephews and cousins, and I hope he don’t try nothing on my family.” While some were threatened, others were made to feel guilty for attempting to put an end to the relationship. Da’Vonne asserted that when she tried to break up with her abuser he did “a guilt trip about how he quit his job for her and told her he was suicidal.” Consistent with prior research, threats and emotional manipulation are factors that decrease the likelihood of reporting/disclosure of abuse (Owen et al., 2008; Paine & Hansen, 2002).

Once women acknowledged the adversarial aspects of the relationship, they seemed to undergo a cognitive shift to reassess the behavior of the perpetrator and label it as manipulative. Reporting women discovered lies or described feeling that their vulnerability was exploited, leaving them feeling used. Of her parole agent, Anika reflected: “he lied to me on several occasions about his wife…I kept on finding things on him and confronting him and he didn’t like it so he lied about it.” Consequently, women often expressed regret at placing their trust in the officer, as it made it difficult to report the abuse. As Crystal said, “I felt I had to protect him, even to the point of making myself look foolish.” This trust was used against the women due to their vulnerable status in relation to the officer-abusers. Da’Vonne explained, “I began to entrust him with information I soon wished I never would have. . . [including] personal things about myself. . . [and] about my family.”

The cognitive shift to identify the behavior as manipulative still exhibited the complex feelings women held for the perpetrators but may ultimately have related to their decisions to report. As Crystal acknowledged: “[I] cared for this officer. Now [I] feel used.” In fact, upon realizing that she was taken advantage of, she explained “[it] hurt me so bad emotionally it felt physical.” However, feelings of hurt can initiate reporting abuse. Anika asserted, “I talked to [my friend] about turning [the parole officer] in because he really hurt me, he lied to me for the last time!” Nevertheless, this was far from easy, as some remained emotionally attached to their officer-abuser. Janice claimed that despite the abusive nature of the relationship, she was still concerned that if she attempted to end the relationship “he’s gonna be hurt. . . and he’s gonna. . . [feel] betrayed.”

Reflecting the complexity of the relationship, a theme related to simultaneous consent and predation came up for some of the women who reported. Of the correctional officer who took advantage of her, Janice explained, “my thing is, him and the rest...that prey on women in prison. Now, let’s keep it real. Even though I consented, you prey [on women].” This is particularly true given the power imbalance between women on parole and correctional officers who are in positions of power and authority. Thus, it was not possible to have a mutual and equal relationship. In hindsight, Crystal expressed disappointment “[t]hat I could actually believe that [CO] was different from the other officers that were having sex with the other female inmates. . . yes, my actions were consensual, but I now see he used and manipulated me. . . [and] didn’t mean anything he said.” This shift from identifying the behavior as consensual to identifying it as manipulative is unique to the women who reported. Ultimately describing the relationship as abusive may make it seem less like “acquaintance rape,” which previously made it hard to identify themselves as victims. Viewing the behavior as manipulative instead contributes to their decision to report the officer.

Structural Barriers and Retaliation to Reporting

While under community correctional supervision women are expected to have increased personal control, but instead they described how dynamics of powerlessness and reduced control continued. Retaliatory behavior by correctional staff was a common occurrence for women who reported and it made reporting detrimental to their parole status. For instance, Bianca lamented “[I] was sent back on violation by [officer-abuser’s] staff friend who is a parole agent.” She also stated that when her parole officer “found out I was turning in [perpetrator who was a friend of the PO], he sent me to a facility he knew would send me back to prison for medical [issues].” While incarcerated Crystal stated that she, “saw what other women went through when [they] complained [about inappropriate staff] and received retaliation.” Consequently, this served as a serious barrier to reporting. Similarly, Da’Vonne asserted, “I was terrified of a system I didn’t understand and did not want to jeopardize my parole.” Here, women highlight their vulnerability coupled with systemic barriers that made reporting such abuse more challenging.

For the women who reported, these vulnerable positions on parole intersected with structural barriers to reporting. The structural theme of power imbalance inherent in the correctional staff/woman under supervision relationship acted as a powerful obstacle to reporting. As a result of this power imbalance, many women felt as if they lacked control. Anika recalled “he asked me for my address just in case he wanted to send me something in the mail like phone cards, money or what have you.” Da’Vonne described this power flex stating “[h]e knew my parole placement information—address and telephone number.” Similarly, Da’Vonne was made aware of the power of the abusive officer as she witnessed this power directly. She complained that the abusive staff member was “constantly appearing at my approved parole placement until I was evicted from there due to his interference/presence.” In fact, his constant presence (which, in many ways, fit legal definitions of stalking) resulted in her parole violation.

Overall, reporting women made it clear that reporting abuse was not easy due to the complex nature of the relationships and the manipulative behavior of the perpetrator taking advantage of their vulnerabilities. This was compounded by the continued structural inequality of the relationship that continued under community supervision. That is, women were particularly vulnerable because of their status as parolees and their reporting decisions were shaped by prior experiences or perceptions of reporting in prison.

Non-Reporting Women

Control and Consent

Non-reporting women shared some similarities with reporting women when it came to identifying behavior as abusive. However, the dynamics of the manipulation and threats differed in important ways from reporting women. In contrast to the women who reported, these women described the abuse as manipulative from the onset even when offered support. Faith received a letter from her perpetrator that mentions her close relationship to her family, acknowledges the uphill battle she would face upon her release, and offers support in exchange for the relationship continuing. It stated:

So have you given much thought on what you’re going to do when you get out this time? I know how much your son means to you I could see how much he loves you and misses you when your [sic] not there. If there is anything I can do for you when you get out just let a brother know and we will make it so. I[f] you like we can keep up the conversation till you regain your freedom.

However, unlike women who reported their abuse, those who did not had no emotional or sexual connection with their assailant. Heather explained that “[the abuse] was very humiliating and degrading for me… [and that her perpetrator was] the most disgusting and gross to me.” Erin elaborated “I really did not even like him” but he made promises that he could end her parole early, which initiated the onset of the abusive relationship.

Complicated compliance was a theme that arose when non-reporting women described manipulation in conjunction with the power imbalance of the relationship. Irene reflected “[I] had no choice but to accept him,” so while the officer “was a little surprised that I wasn’t happy to see him, well nonetheless he got what he came for.” Georgia was told she “owed” the officer, because “it’s payday for all the (pipe) tobacco I [had] been smoking [in prison].” The women described the relationship in terms of “compliance,” which reflects the terminology used in prison requiring justice-involved individuals to comply direct orders by staff. Heather said, “I did not know what was going to happen if I failed to do as he instructed, so I complied with is request.” It betrays that they felt they had some amount of agency in their decisions, yet these relationships were driven by fear and humiliation and shaped by prison dynamics. This perceived agency simultaneously reflects an inability to escape from victimization (based on the lack of any real choice, fear, and sex-as-exchange dynamics they describe above) that aligns with research on burdened agency (Meyers, 2011; Morabito & Shelley, 2018).

Women who did not report noted feeling used, manipulated, and lied to in a similar way to those who reported. However, they primarily described feeling used sexually instead of emotionally. Faith asserted “[I was] used and hurt. Like they’re just in it for sex.” Similarly, Erin stated: “I feel like he lied to me so he could get in my panties, and he did.” Perceptions of being used sexually contributed to feeling dehumanized and devalued. Irene reflected “we were only state property then weren’t we? And that is just how they used me.” While women who did not report the assault identified such behavior as abusive, feelings of disempowerment posed a significant barrier to reporting.

Like women who reported, these women also experienced threats designed to keep the abuse quiet. Heather detailed “[e]ven though I was released on parole I still complied with [his] demands for sex because I felt that if I refused, he would or could make a phone call and have me violated.” Similarly, Irene was told:

[I]f I didn’t straighten my attitude out he would send me right back to [prison]—and he made himself very clear. . . if that didn’t work to make sure me nor my 2 sons never said anything against him, he would have us taken care of- permanently.

Overall, an officer’s manipulative behavior coupled with threats and the dehumanization of women align with the research on coercive control behaviors (Stark, 2007). This behavior may be easier to identify as abusive, but also, given the inherently threatening nature of it, it also serves as a crucial barrier to reporting.

Structural Barriers to Reporting

In addition, structural factors shaped non-reporting women’s decisions to report. Like women who reported, vulnerabilities related to their status as parolees were pivotal to their decision-making. However, the role of fear and helplessness played a larger role for women who did not report. Heather stated, “I also felt the sense of helplessness because I feared that if I reported his conduct, I would turn my sentence into a longer sentence.” Georgia expressed “I was afraid to give him a fake # in case he called it before I was released and got me sent back.” The behaviors of coercive control that made women feel like property contributed to the feeling of helplessness. Georgia further identified the structural backdrop of her vulnerability as a parolee which contributed to her fear: “thinking about the power and control he had over my future, I was scared.”

The women who did not report referenced the perpetrator’s elevated status both as how they gained access to the women and as a deterrent to reporting. Faith found out that the officer “called the parole office asking for her phone number, and someone had given it to him ... [so he] started calling” daily. Similarly, Erin reflected, “[a]bout 2 days after I got home, [he] showed up at my house. I don’t know how he got my address but he was there.” Their disempowered status as parolees limited the control they had given the officers’ access to them (see, (Morabito & Shelley, 2018). Unlike the reporting women who refer to paranoid officers, it was not uncommon for officers to use the power imbalance to overtly discourage reporting. For instance, Georgia explained that when she considered reporting while incarcerated her assailant boldly claimed that “nobody would believe a prisoner over him.”

Finally, a unique factor mentioned by the women who did not report related to knowledge of other abuse in the DOC as a deterrent to reporting. Irene was told:

[T]here were plenty of women there who were given more time for allegedly falsifying accusations against the officers. [I was told] that the best thing I could do was do what had to be done and get myself out of there [prison].

The knowledge that the abuser had other victims contributed to the feeling of fear and left women feeling helpless to change or report the abuse. Irene explained that this abuse was detrimental and common: “it’s another thing to emotionally and mentally cripple someone because you can, and that’s what they did to not only myself but quite a few other women that were there.” The feeling that this abuse was prevalent and was not appropriately addressed by the department of corrections is consistent with literature on institutional grooming, in which a perpetrator’s role of authority or status in the institution gives them control to make the organizational environment more facilitative of abuse (McAlinden, 2006). Perceptions that the institution would not or could not address the abuse contributed to feelings of powerlessness that these women felt when making reporting decisions.

While some themes overlapped between reporting and non-reporting women, such as feeling used/manipulated, vulnerability, and power imbalances, the undercurrent of fear and humiliation for the women who did not report make their experiences qualitatively different from those who did report. Importantly, the abusive relationships for women who did not report map onto concepts of coercive control and intersect with a sense of burdened agency in their decision-making. The manipulation experienced by the two groups also differed, with non-reporting women using terms like “compliance,” and reporting women using terms like “consent.” Further, for non-reporting women, actions of the officers suggested to women that abuse was widespread in the department of corrections making reporting seem futile. Compared to the women who reported, these women’s relative feelings of powerlessness differentially shaped whether they were willing to report.

Discussion

This study explored women’s decisions to report or not report experiences of staff sexual abuse that occurred while they were under community-based correctional supervision. While there are parallels between patterns for reporting rape and sexual assault in and outside of prison settings (Surrell & Johnson, 2020), research has identified a range of factors at individual, institutional, and cultural levels that uniquely deter reporting staff sexual misconduct in correctional settings (Kubiak et al., 2018). The findings suggest that a power imbalance from carceral settings continued during parole and that women experienced both individual and structural barriers to reporting. Both groups had difficulty identifying the behavior as abusive (discussing complex dynamics of “consent” and predation or “compliance” and disgust) but both groups ultimately came to view it as unwanted or abusive. Similarly, across reporting and non-reporting women, structural factors related to the criminal justice system played an important role in decisions to report abuse.

However, there were important differences between reporting and non-reporting women when it came to identifying abuse. Counter-intuitively, initially identifying the behavior as abusive appeared easier for women who did not report. The complex dynamics of abuse that women described align with some of Owen and colleagues’ (2008) continuum of coercion behaviors used by correctional staff to facilitate abuse in prison. Women described abuse on parole as having aspects of romance and love, exchange (e.g., abuse for less time on parole), intimidation (e.g., threats), and both violent and non-violent sexual acts. However, because correctional supervision is less stringent on probation and parole than in prison, women who reported also described attributes of abuse that mapped on to acquaintance rape (Warshaw, 1988) while women who did not report did not. Reporting women described “consent” and tangible benefits to the relationship, including money and car rides, that at first, seemed beneficial during the immediate period of re-entry, a time when women are in need of support (Zweig et al., 2007). Acquaintance rape is accompanied by notoriously low reporting and has been treated disparagingly by criminal justice actors including police, courts, and prosecutors (Warshaw, 1988; Wilson & Miller, 2015; Xie & Baumer, 2019), but these women under community-based correctional supervision still reported abuse that mimicked dynamics of acquaintance rape.

Reporting women differed from non-reporting women in that they experienced a cognitive shift from identifying the sexual abuse behavior as consensual to identifying it as manipulative. Reporting women described feeling hurt, used, or finding out about other victims of the perpetrator. Ultimately, they began to see more starkly the power imbalance that existed and viewed the behavior less as a choice and more as abuse, and as a response, the women began regain some power by reporting the abuse, despite the huge risk to their safety and their freedom on parole for reporting. Alternatively, non-reporting women described the abuse as manipulative and unwanted from the outset. While that may have made it easier to identify, it did not make it easier to avoid. Reporting women talk about their decisions as “complying” with an officers’ requests, which reflects a perceived ability to maintain some agentic complexity and control some decision-making. On the other hand, women who did not report signaled a type of “burdened agency,” which acknowledges that while victims may not be able to escape from abuse, they still have agentic complexity and resilience, which spares victims the perceived stigma that comes with complete disempowerment (Meyers, 2011; Morabito & Shelley, 2018). The abuse was coupled with threats and resulted in women feeling dehumanized and devalued, an insurmountable barrier to reporting. The dynamics of probation and parole, which carry increased freedom and control along with attributes of supervision similar to prison, created unique difficulty identifying and reporting abuse.

Women who did not report the abuse never described a cognitive shift to viewing behavior as abusive; they were aware of the power imbalance from the beginning and instead described overt threats, fear, and dehumanization, as facilitating the abuse. When they described “compliance,” it was complicated by their vulnerability and disempowered position, reflecting less the dynamics of acquaintance rape and instead the coercive control dynamics associated with rape and intimate partner violence (Stark, 2007). Coercive control describes tactics by the abuser to usurp and dominate a partner’s subjectivity, and it is personalized to the victim, with a focus on imposing sex stereotypes in everyday life (Stark, 2007). Correctional staff perpetrators here capitalized on the vulnerability of parolees, using fear, manipulation, and threats to facilitate abuse with confidence that these behaviors would deter reporting.

Next, both groups of women described vulnerabilities related to their status as parolees, which remained a salient factor in reporting abuse. This was the case regardless of the specific role of the perpetrator (e.g., assigned parole officer, staff member). Reporting women identified behaviors by perpetrators that reminded them of the power imbalance (e.g., asking for their address) and identified confusion in navigating the reporting system, but, perhaps linked to the cognitive shift they experienced, still made the decision to report. Ultimately, for non-reporting women, it was both the reminders of their disempowered status as parolee in conjunction with structural factors that discouraged reporting. While women who reported encountered structural barriers consistent with existing literature (e.g., the power imbalance, not understanding the reporting system, and retaliation from the perpetrator), they were able to overcome those barriers (Kubiak et al., 2018; Struckman-Johnson & Struckman-Johnson, 2002; Surrell & Johnson, 2020). Increased freedom on parole as compared to prison and the cognitive shift to view the behavior as the abuse were key shifts in perspective; while reporting women cited the power imbalance as infuriating (e.g., perpetrator behaviors that threatened their parole), recognition and perspective helped change their mentality and spurned them to report. Additionally, they did not identify other women’s disappointing experiences with reporting as a strong deterrent, meaning perhaps they didn’t view the system as broken or containing an impenetrable culture of silence like the non-reporting women. This adds to research suggesting there are important structural barriers, including the power imbalance, cultures of silence, fears of retaliation, by suggesting that these barriers still exist under community-based supervision, but can be overcome by helping women see behaviors as abusive (Department of Justice & Institute of Corrections, 2009; Kubiak et al., 2018; Struckman-Johnson & Struckman-Johnson, 2002). Moving forward, this research suggests that if PREA standards were applied to parole, these behaviors might be better understood as inappropriate and illegal, which could help increase reporting.

Importantly, women’s experiences in prison shaped their willingness to report abuse on parole. These results contribute to the literature on learned helplessness suggesting that the negative attributional style resulting from prolonged exposure to aversive experiences during incarceration may continue to shape decision-making even on probation and parole for women who are experiencing abuse (Schill & Marcus, 1998). The women who did not report described a culture within the prison that was rife with abuse, making reporting abuse that occurred or continued on parole seem futile. Justice-involved women’s histories with observing or experiencing abuse in other settings has been shown to have an impact on willingness to report subsequent abuse (Richie, 2002). In particular, the justice system may have failed them in the past, or the system may be interwoven with the abuse (e.g., if the abuse began in prison, or if staff used their authority to access women’s information while on parole). While the abuse histories of the women are not known in this sample, justice-involved women are much more likely to have experienced violent victimization in childhood and intimate partner violence than men (Bloom et al., 2003; Tjaden & Thoennes, 2006). Future research can explore how abuse history and perceived cultures of abuse in the prison system to which the women are expected to report shapes decisions to report abuse on probation and parole.

Study Limitations

The lawsuit did not specifically gather data on staff sexual misconduct that occurred on parole—as mentioned above, this was not considered under the purview of federal legislation or state law. Therefore, the data were limited to those women who detailed it in their descriptions of abuse; it is possible that women participants in the lawsuit did experience sexual assault on parole but did not mention it. However, our sample was not intended to be representative but was selected to compare those who did report the abuse formally to those who did not, and provides rich insight into this under-examined phenomenon. We also were constrained by the availability of data within the lawsuit materials. Limitations here reflect larger trends in our national data collection on sexual victimization of women in the criminal legal system. There should be a trajectory of research that illuminates these dynamics.

Policy Implications

Structural issues played an important role in shaping reporting decisions. When the prisons from which women were released were perceived to have prevalent abuse and prisoners would not be believed over an officer’s word this shaped their decisions to report staff sexual abuse that continued or began on parole. The women who reported the abuse formally did so directly to parole officers, to internal investigators, and others, but described confusion about navigating a system they did not understand. PREA has made strides in this area, creating confidential reporting mechanisms in prisons, allowing access to mental and physical health resources, and mandating audits and national data collection (Rantala, 2018; Smith, 2020). However, these changes have not been uniformly implemented on parole. Additionally, some structural changes were a part of the settlement of the lawsuit, including changes to hiring, training, and investigating staff (Labelle, 2008). These changes did not specifically contemplate community supervision structures, and some research on the perspectives of women with life sentences suggests that in-prison changes may promote overfamiliarity and abuse (e.g., a policy where officers no longer rotate off housing units every 6 months) (Fedock et al., 2016). Because the states have a patchwork of responses, national guidance in terms of where and to whom to report is necessary in this area. At the very least, increased national data collection on instances of abuse experienced while under community supervision (including those that explore differences based on the specific or supervisory role of the correctional staff perpetrator) are essential to better address the abuse.

The results further highlighted that learned helplessness, constraints on agency, and barriers to reporting that existed in prison extend to reporting sexual assault during community supervision. Thus, some level of carceral deprivations and control over justice-involved individuals continues even upon release, and policy should be updated to reflect this reality. Namely, educating both staff and justice-involved individuals on the power imbalance that continues under community supervision is necessary. Additionally, abuse was described by both supervisory and non-supervisory staff, which suggests that it may be counterproductive for policy to create hierarchies or exclude individuals on the basis of non-supervisory role.

Conclusion

Staff-perpetrated sexual victimization occurs while women are under forms of community-based correctional supervision. The lack of policy, practice, research, and theory attention to these experiences impacts the ability to detect, intervene, and prevent this form of abuse against women. Based on women’s experiences of this form of victimization, the power dynamics circumvent women from safely reporting and create additional precarity while they navigate probation, parole, and other forms of supervision. Further work is needed that centers this population of women’s safety and wellbeing.

Footnotes

Author’s Note

Preparation of this paper was supported by a grant from the National Science Foundation. The opinions or points of view expressed in this document are those of the authors and do not reflect the official position of the National Science Foundation.

Declaration of Conflicting Interests

The author(s) declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article.

Funding

The author(s) disclosed receipt of the following financial support for the research, authorship, and/or publication of this article: This work was supported by the Division of Social and Economic Sciences. Preparation of this paper was supported by a grant from the National Science Foundation. The opinions or points of view expressed in this document are those of the authors and do not reflect the official position of the National Science Foundation.

ORCID iD

Kathleen Darcy

Notes

Author Biographies

Kathleen M. Darcy is an attorney and a doctoral candidate in the School of Criminal Justice at Michigan State University. Her work is aimed at increasing access to justice for survivors of institutional sexual assault. Her research interests include gender-based violence, institutional abuse, civil rights litigation, and intersections of institutional and legal responses within the criminal justice system. [Email: darcykat@msu.edu]

Gina Fedock is an Assistant Professor in the Crown Family School of Social Work, Policy, and Practice. Her work focuses on improving women’s mental health and expands a trauma-informed framework of understanding and addressing women’s health needs. Through a human rights framework, her work incorporates advocacy for addressing social injustices in order to improve women’s mental health and wellbeing. [Email: gfedock@uchicago.edu]

Sheryl Kubiak, Ph.D. is the Dean of and a Professor in the Wayne State University School of Social Work and Founding Director of the Center for Behavioral Health and Justice. Dean Kubiak’s interest in the intersections between criminal/legal systems and behavioral health began 30 years ago when she developed and administered a long-term residential re-entry program in Detroit for pregnant women addicted to crack cocaine. Since then, Dean Kubiak has received funding from national (NIMH, NSF, NIDA) and state (MDOC, MDHHS) government, as well as foundations (i.e., Robert Wood Johnson Foundation, Skillman, Flinn) to research and evaluate projects such as substance abuse treatment within prisons, mental health courts, and integrated substance abuse and mental health treatment for those involved in the legal system. [Email: spk@wayne.edu]

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