Angela Richardson, an inmate in Arkansas, filed a lawsuit against Krystle Reed Duncan, a former prison security officer, under 42 U. Richardson claimed that between November and January , she and Duncan engaged in a consensual sexual relationship, which included kissing and digital penetration. Richardson did not report the relationship to prison officials until late , after learning that Duncan had been involved with other inmates, which caused her emotional distress.
Duncan did not respond to the complaint, leading to a default entry. A magistrate judge held a hearing and recommended vacating the default and dismissing the complaint for failure to state a claim. The magistrate judge found that Richardson's allegations described consensual sexual activity and did not support a claim of coercion or non-consensual conduct. The district court adopted this recommendation and dismissed the complaint.
The court affirmed the district court's decision, holding that Richardson failed to state a claim under the Eighth Amendment. The court applied its precedent from Freitas v. Ault, which held that consensual sexual interactions, even if inappropriate, do not constitute "pain" under the Eighth Amendment.
The court found that Richardson's complaint and testimony did not allege any coercion, force, or threats by Duncan, and thus did not meet the objective component of an Eighth Amendment violation. The judgment of the district court was affirmed. Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies.
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