Report on 

Sexual 

Victimization 

in Juvenile 

Correctional 

Facilities

Review Panel                 

on Prison Rape

October 2010
Review Panel on Prison Rape 

Report on Sexual Victimization in Juvenile Correctional Facilities 

The Review Panel on Prison Rape’s Report on Sexual Victimization in Juvenile Correctional 

Facilities is available online at http://www.ojp.usdoj.gov/reviewpanel/reviewpanel.htm. 

Obtaining prior permission is not necessary for copying and distributing this report. To contact 

the Review Panel on Prison Rape, email PREAReviewPanel@usdoj.gov or call (202) 307-0690. 

Review Panel on Prison Rape, U.S. Department of Justice, Washington, DC (October 2010)
i 

Review Panel on Prison Rape 

Report on Sexual Victimization in Juvenile Correctional Facilities 

Executive Summary ..................................................................................................................... iii 

Background ................................................................................................................................... 1 

BJS Juvenile Report....................................................................................................................... 1 

National Prison Rape Reduction Commission and National Standards.................................. 3 

Selection of Juvenile Justice Facilities for the Public Hearings ................................................ 4 

Hearings on Sexual Victimization in Juvenile Correctional Facilities ..................................... 5 

Institutions with the Lowest Prevalence of Sexual Victimization ............................................ 6 

Ft. Bellefontaine ...................................................................................................................... 6 

Facility Description ........................................................................................................... 6 

Facility’s Explanation of Low Incidence of Sexual Victimization ................................ 7 

Rhode Island Training School ............................................................................................. 12 

Facility Description ......................................................................................................... 12 

Facility’s Explanation of Low Incidence of Sexual Victimization .............................. 13 

Institutions with the Highest Prevalence of Sexual Victimization.......................................... 16 

Pendleton ............................................................................................................................... 16 

Facility Description ......................................................................................................... 16 

Response to the BJS Juvenile Report and Corrective Actions .................................... 17 

Woodland Hills ...................................................................................................................... 21 

Facility Description ......................................................................................................... 21 

Response to the BJS Juvenile Report and Corrective Actions .................................... 22 

Corsicana ............................................................................................................................... 26 

Facility Description ......................................................................................................... 26 

Response to the BJS Juvenile Report and Corrective Actions .................................... 27 

General Observations ................................................................................................................. 32 

The Selected Facilities Have Distinctive Characteristics .................................................. 32 

Policies and Practices May Not Predict Outcomes ............................................................ 32 

The Selected Facilities Differ on the Causes of and Effective Prevention 

Methods for Sexual Victimization .............................................................................. 33 

The Small Number of Reviewed Facilities Limits Reliable Generalizations ................... 33 
ii 

Common Themes ........................................................................................................................ 33 

Culture ................................................................................................................................... 33 

Staff Training ........................................................................................................................ 34 

Facility Size ............................................................................................................................ 34 

Unresolved Institutional Questions that Warrant Further Study .......................................... 35 

What are the factors that lead female staff to become involved emotionally 

or sexually with male juveniles? ................................................................................. 35 

What is the most effective training to encourage healthy professional 

boundaries? .................................................................................................................. 35 

What are the best practices for maintaining the appropriate professional 

boundaries between staff and juvenile offenders? .................................................... 36 

How can institutions better screen staff to avoid sexual misconduct? ............................. 36 

For youth in custody, what are the common characteristics of victims 

and perpetrators of sexual victimization? ................................................................. 36 

How can juvenile justice systems assist staff falsely accused of sexual 

misconduct? .................................................................................................................. 37 

What are the factors that contribute to youth-on-youth sexual assault in 

juvenile justice facilities? ............................................................................................. 37 

Taking into account youth development, what are healthy, realistic 

expectations for youth in managing sexual expression while in custody? .............. 38 

Conclusion ................................................................................................................................... 38 

Appendices 

 

 Appendix A Overview of the Juvenile Justice System in the United States 

 Appendix B Data Request (Mar. 31, 2010) 

Appendix C Side-by-Side Matrix of Juvenile Facility Responses to Review Panel 

on Prison Rape Data Request (June 2, 2010) 

 

Appendix D Witness List for Review Panel on Prison Rape Hearings on Sexual 

Victimization in Juvenile Correctional Facilities (June 3-4, 2010) 
iii 

Executive Summary 

In accordance with the Prison Rape Elimination Act (PREA) of 2003, the Bureau of Justice 

Statistics (BJS) published Sexual Victimization in Juvenile Facilities Reported by Youth, 2008-09

(Jan. 2010). The report, the first of its kind that relied on data from juvenile offenders, surveyed 

the incidence of sexual victimization in the United States by facility. 

Mindful that even one incident of sexual victimization of a youth in custody is unacceptable, the 

Review Panel on Prison Rape (Panel) found that BJS’ report indicated that violent sexual assault 

in juvenile facilities was relatively rare and facility staff, for the most part, did not victimize 

juvenile offenders. 

Also in accordance with PREA, the Panel held public hearings in Washington, DC, on June 3-4, 

2010, to identify, based on the BJS’ survey of juvenile facilities, the common characteristics of 

the following: (1) victims and perpetrators, (2) two facilities with the lowest prevalence of sexual 

victimization, and (3) three facilities with the highest prevalence of sexual victimization. In light 

of the hearing testimony and other collected data, the Panel is issuing this Report, which offers 

general observations, identifies common themes, and poses questions for further study. 

General Observations 

Given the small number and the unique characteristics of each selected facility, the Panel 

recognizes the limits in making generalizations. The Panel also notes that some widely 

recommended practices do not necessarily lead to positive results. For example, the two 

facilities with the lowest prevalence of sexual victimization did not have express PREA policies. 

Common Themes 

Culture 

Institutional culture plays an important part in creating a safe environment. Facilities that foster 

a therapeutic model, emphasizing rehabilitation, were more likely to have less prevalence of 

sexual victimization than facilities that rely on a corrections model, emphasizing punishment. 

Staff Training 

The administrators of all of the selected facilities agreed on the need to train staff on the perils of 

crossing professional boundaries that lead to inappropriate relationships with youth. 

Facility Size

Small facilities tend to have less prevalence of sexual victimization. 
iv 

Unresolved Institutional Questions that Warrant Further Study 

● What are the factors that lead female staff to become involved emotionally or 

 sexually with male juveniles? 

● What is the most effective training to encourage healthy professional boundaries? 

● What are the best practices for maintaining the appropriate professional 

 boundaries between staff and juvenile offenders? 

● How can institutions better screen staff to avoid sexual misconduct? 

● For youth in custody, what are the common characteristics of victims and 

 perpetrators of sexual victimization? 

● How can juvenile justice systems assist staff falsely accused of sexual 

 misconduct? 

● What are the factors that contribute to youth-on-youth sexual assault in juvenile 

 justice facilities? 

● Taking into account youth development, what are healthy, realistic expectations 

 for youth in managing sexual expression while in custody? 
1

The Review Panel on Prison Rape 

Report on Sexual Victimization in Juvenile Correctional Facilities

In accordance with the Prison Rape Elimination Act (PREA) of 2003,1 the Review Panel on 

Prison Rape (Panel) conducted public hearings and gathered relevant data based on the survey 

that the Bureau of Justice Statistics (BJS) published in January of 2010 on the incidence of 

sexual victimization in juvenile correctional facilities in the United States, Sexual Victimization 

in Juvenile Facilities Reported by Youth, 2008-09.

2

 The Panel presents this Report, which 

contains its observations and recommendations, to assist both practitioners and advocates in the 

juvenile justice community to eliminate sexual victimization in the nation’s juvenile correctional 

facilities.3

 

Background 

On January 1, 2010, with delegation from the Attorney General, Laurie Robinson, Assistant 

Attorney General for the Office of Justice Programs, appointed the current Panel members, who 

are Dr. Reginald Wilkinson, Panel Chairperson, President and Chief Executive Officer of Ohio 

College Access Network; Ms. Gwendolyn Chunn, retired Executive Director, Juvenile Justice 

Institute, Center for Criminal Justice Research and International Initiatives, Department of 

Criminal Justice, North Carolina Central University; and Ms. Sharon English, retired Deputy 

Director, California Youth Authority, Office of Prevention and Victim Services. 

The Attorney General, through BJS, identified juvenile justice facilities as one of the prison 

categories under PREA meriting a survey on the incidence of sexual victimization.4

 PREA 

entrusted to the Panel the mission of holding annual public hearings—in this instance, on 

juvenile justice facilities—to assist BJS in identifying the common characteristics of (1) victims 

and perpetrators of sexual victimization, (2) the two correctional facilities with the lowest 

incidence of prison rape, and (3) the three correctional facilities with the highest incidence of 

prison rape.5

 

BJS Juvenile Report 

In a society that values the dignity of each individual, any incident of sexual victimization of a 

youth in custody is unacceptable. From this perspective, the Panel reviewed the BJS Juvenile 

Report and noted that violent sexual assault in juvenile facilities is relatively rare and that facility 

                                                           

1

 42 U.S.C. §§ 15601-15609 (2006) (Pub. L. No. 108-79, 117 Stat. 972). 

2

 BJS, Sexual Victimization in Juvenile Facilities Reported by Youth, 2008-09 (Jan. 2010) (A. Beck et al.), available 

at http://bjs.ojp.usdoj.gov/content/pub/pdf/svjfry09.pdf [hereinafter BJS Juvenile Report]. 3

 For general information on the juvenile justice system in the United States, see Appendix A. 4

 42 U.S.C. § 15603(c)(4). 

5 Id. § 15603(b)(3)(A). 
2

staff members, for the most part, do not victimize juvenile offenders. The Panel commends 

juvenile justice administrators who have, as a whole, worked hard toward eliminating sexual 

victimization in their facilities. 

The BJS Juvenile Report found that of the estimated 26,551 adjudicated youth held in state 

facilities or large non-state facilities in 2008-09, about 12.1% (3,220) reported experiencing 

sexual violence.6 About 2.6% of these reported incidents involved other youths, whereas about 

10.3% involved facility staff members.7 For the reported youth-on-youth incidents, 2.0% 

involved nonconsensual acts;8 for the reported staff-on-youth incidents, 4.3% involved force and 

6.4% did not involve force.9

 Facilities that housed only female youth offenders had the highest 

rates of youth-on-youth victimization (11.0%), whereas facilities that housed only male youth 

offenders had the highest rates of staff sexual misconduct (11.3%).10 

Small juvenile facilities had lower victimization rates than larger ones.11 Facilities that held 

between ten and twenty-five adjudicated youth had the lowest overall rates of sexual 

victimization (6.3%), a result of the relatively low rate of staff sexual misconduct (2.7%), 

whereas facilities that held one hundred or more adjudicated youth had the highest overall rates 

of sexual victimization (12.9%).12 

The more time that youth offenders spent in a juvenile facility, the more likely they were to 

experience sexual victimization: for youth held under five months, the victimization rate was 

7.4%; for youth held between five and six months, the victimization rate was 12.7%; and for 

youth held between seven and twelve months, the victimization rate was 14.2%.13 

The BJS Juvenile Report found that the rate of sexual victimization varied among youth 

depending on a variety of characteristics, including some of the following: males were more 

likely than females to experience sexual activity with staff; females were more likely than males 

to report forced sexual activity with other youth; black youth were more likely than white youth 

to experience sexual victimization by facility staff; youth with a sexual orientation other than 

heterosexual were significantly more likely to experience sexual victimization than heterosexual 

youth; youth who had a prior history of sexual assault were twice as likely to report sexual 

victimization than youth with no history of sexual assault; and among youth who reported being 

victims of sexual assault at another facility, two-thirds reported being sexually victimized at the 

                                                           

6 BJS Juvenile Report 3 & tbl.1. 7 Id.

8

 The BJS Juvenile Report excluded from its reporting of sexual victimization sexual acts between youth in which 

there was no report of force. Id. 9 Id. 

10 Id. 10 & tbl.7. 11 Id. 12 Id. 13 Id.
3

facility that currently housed them.14 For youth reporting youth-on-youth incidents of sexual 

victimization, 81% reported more than one incident, and 43% reported more than one 

perpetrator.15 For youth reporting staff-on-youth incidents of sexual victimization, 95% reported 

that the perpetrator involved a female staff member.16 In regard to incidents of staff sexual 

misconduct, 92.0% involved male youth and female staff members; 1.7% involved male youth 

and male staff members; 2.5% involved male youth and both male and female staff members; 

3.0% involved female youth and male staff members; 0.0% involved female youth and female 

staff members; and 0.8% involved female youth and both male and female staff members.17 In 

2008, males made up 91% of all adjudicated youth in the sampled facilities; and in facilities 

under state jurisdiction, females represented 42% of the staff.18 Victims of staff sexual 

misconduct reported that for incidents involving physical force or other forms of coercion, 14% 

of the perpetrators were male, whereas for incidents that did not involve any force, 4% of the 

perpetrators were male.19 Nearly all youth (95%) who reported being a victim of staff sexual 

misconduct reported that the incident did not result in physical injury.20

National Prison Rape Reduction Commission and National Standards 

In addition to the Panel, PREA created the National Prison Rape Elimination Commission 

(NPREC or Commission)21 and charged it with the task of conducting a comprehensive study on 

the impact of prison rape on communities, social institutions, and every level of government and 

of assessing the relationship between prison rape and prison conditions.22 According to the 

scheme set forth in PREA,23 the Commission held public hearings and then published a report of 

its findings with recommendations for national standards for reducing prison rape.24 The 

Commission disbanded shortly after the publication of its report. 

According to PREA, the Attorney General is to rely on the Commission’s recommendations in 

issuing regulations that establish “national standards for the detection, prevention, reduction, and 

punishment of prison rape.”25 As of the date of the writing of this Report, the Justice 

Department is in the process of reviewing the Commission’s recommended standards. 

                                                           

14 Id. 10, 11 & tbl.8. 15 Id. 12 & tbl.9. 16 Id. 13 & tbl.11. 17 Id. 18 Id. 13. 19 Id. 20 Id. 14 & tbl.12. 21 42 U.S.C. § 15606(a). 

22 Id. § 15606(d). 23 Id. § 15606(d)(3). 24 NATIONAL PRISON RAPE ELIMINATION COMMISSION REPORT (June 2009), available at

http://www.cybercemetery.unt.edu/archive/nprec/20090820154816/http://nprec.us/publication/. 25 42 U.S.C. § 15607(a)(1). 
4

Mindful of the Commission’s thorough recommendations and the Justice Department’s current 

posture in issuing regulatory national standards, the Panel recognizes that its mission differs from 

that of the Commission. Relying on the surveys of correctional institutions that BJS produces, 

the Panel has focused on its role in identifying the common characteristics of facilities with the 

highest incidence of sexual victimization and the facilities with the lowest incidence. In 

undertaking this task, the Panel may be able to provide insight into the results of BJS’ surveys, to 

highlight examples of promising practices that complement the work of the Commission, and to 

suggest topics for further study. 

Selection of Juvenile Justice Facilities for the Public Hearings 

The BJS Juvenile Report was unable to provide an exact ranking of juvenile justice facilities in 

the United States based on the incidence of sexual victimization because the study relied on a 

sampling of youth responses at 195 juvenile facilities rather than on a complete enumeration.26 

Nonetheless, the BJS Juvenile Report identified eleven facilities with the lowest prevalence of 

sexual victimization and thirteen facilities with the highest.27 Relying on this information as a 

starting point, the Panel selected the following institutions to appear at the PREA-mandated 

public hearings: the two facilities representing the lowest incidence of sexual victimization were 

(1) the Fort Bellefontaine, Missouri, Campus (Ft. Bellefontaine) and (2) the Rhode Island 

Training School (RITS); the three facilities representing the highest incidence of sexual 

victimization were (1) the Pendleton, Indiana, Juvenile Correctional Facility (Pendleton); (2) the 

Woodland Hills, Tennessee, Youth Development Center (Woodland Hills); and (3) the 

Corsicana, Texas, Residential Treatment Center (Corsicana). 

The Panel chose Ft. Bellefontaine because it had a high response rate with no reported incidents 

of sexual abuse.28 The Panel was also interested in learning more about Ft. Bellefontaine 

because the Missouri Department of Social Services (MDSS), which operates Ft. Bellefontaine, 

had another facility listed in the BJS Juvenile Report with one of the lowest reported incidence of 

sexual victimization.29 The Panel chose the RITS because it had few reported incidents of sexual 

abuse; it housed both male and female juvenile offenders; and in comparison to other lowincidence facilities that serve both males and females, it had a relatively large number of 

respondents.30 The Panel chose Pendleton because it had the highest rate of reported sexual 

victimization,31 the second highest rate of reported sexual victimization by facility staff,32 and 

the third highest rate of reported staff sexual misconduct with force.33 One of the factors that 

                                                           

26 BJS Juvenile Report 4. 27 Id. 4, 5. 28 Id. 5 tbl.3. 29 Id. 4 tbl.2 (Ft. Bellefontaine and Montgomery City Youth Center). 30 Id. 5 tbl.3. 31 Id. 4 tbl.2. 32 Id. 8 tbl.5. 33 Id. 9 tbl.6. 
5

contributed to the Panel’s decision to select Pendleton was that the Indiana Department of 

Correction (IDOC), which operates Pendleton, also had another facility that the BJS Juvenile 

Report identified as having one of the highest rates of sexual victimization.34 The Panel chose 

Woodland Hills because of the high rate of reported sexual victimization, the relatively large 

number of respondents, and the relatively high response rate in comparison to other highincidence facilities that required juvenile offenders to obtain parental/guardian consent (PGC) to 

participate in BJS’ survey.35 The Panel chose Corsicana because it had the fifth highest rate of 

reported sexual victimization,36 the sixth highest rate of reported sexual victimization by facility 

staff,37 and the third highest rate of reported juvenile-on-juvenile sexual victimization.38

Hearings on Sexual Victimization in Juvenile Correctional Facilities 

After selecting the facilities to appear at the hearings, the Panel sent data requests to all of the 

invited facilities.39 On receiving the responses from the facilities, the Panel prepared a chart that 

compares the facilities’ responses.40 The Panel and its staff also conducted onsite visits to all of 

the facilities invited to the hearings, touring the buildings and meeting informally with 

administrators. 

The Panel conducted two public hearings on June 3-4, 2010, at the Office of Justice Programs 

Building in Washington, DC.41

This Report presents each of the five facilities invited to the public hearings, providing a brief 

description of each one along with the facility’s explanation for its either high or low incidence 

of sexual victimization. Taking these data into account, the Panel’s Report offers general 

observations, identifies common themes, and encourages research on unresolved institutional 

questions that warrant further study. 

                                                           

34 Id. 4 tbl.2 (Indianapolis Juvenile Correctional Facility). 35 Id. In gathering information on sexual victimization from juvenile offenders, BJS distinguished between 

institutions that were able to provide consent for juvenile offenders to participate in the survey (i.e., in loco parentis) 

and institutions that had to obtain the prior consent of parents or guardians for juvenile offenders to participate in the 

survey (i.e., PGC). Id. 2. Woodland Hills was the only PGC facility that the Panel invited to the hearings. Id. 4 

tbl.2, 5 tbl.3. The Panel was interested in learning whether Woodland Hills’ designation as a PGC institution 

contributed to the reported high level of sexual victimization at the facility. 

36 Id. 4 tbl.2. 37 Id. 8 tbl.5. 38 Id. 39 A copy of the Data Request appears in Appendix B. 

40 App. C (Side-by-Side Data Matrix of Juvenile Facility Responses to Review Panel on Prison Rape Data Requests 

(June 2, 2010)). 

41 For a list of the witnesses who testified at the hearings, see Appendix D. 
6

Institutions with the Lowest Prevalence of Sexual Victimization 

 

Ft. Bellefontaine 

 

Facility Description 

The Missouri Division of Youth Services (DYS), which is part of the MDSS, operates Ft. 

Bellefontaine, which is a medium-security, residential facility serving about twenty young men, 

located on a campus with other similar facilities in an expansive, wooded area adjacent to a state 

park on the west bank of the Mississippi River, north of downtown St. Louis.42 DYS refers to Ft. 

Bellefontaine as a “cottage,” but it is actually a large, two-storey, box-like building.43 Ft. 

Bellefontaine has two sections, each with about a dozen residents.44 The residents of each 

section sleep together in an open dormitory; bunk beds line the walls of the room, surrounding 

the desk of a staff person who monitors the sleeping arrangements throughout the night.45 

Although it may share some facilities with the other nearby cottages (e.g., computer labs and 

classrooms), Ft. Bellefontaine operates independently, offering programming, including 

counseling services, to all of its residents.46 Ft. Bellefontaine has about twenty-four staff 

persons.47 The staff-student ratio is one-to-six, which is the same for all moderate and secure 

care facilities in DYS.48 DYS does require a background check for employees, which includes 

verifying educational background and professional licenses, fingerprinting, and reviewing 

disqualification lists from state agencies.49 

Ft. Bellefontaine residents have a variety of avenues for reporting sexual abuse: filing a 

grievance or speaking to a personal advocate, facility manager, nurse, parent, service 

coordinator, volunteer, DYS staff person, or another trusted adult.50 According to the BJS 

Juvenile Report, Ft. Bellefontaine had no reported incidents of sexual victimization during the 

reporting period.51 

                                                           

42 Transcript of Record: Panel Hearings on Sexual Victimization in Juvenile Correctional Facilities, T. Decker, 

49:20-21 (June 3-4, 2010), available at http://www.ojp.usdoj.gov//reviewpanel/pdfs_june10/transcript_060410.pdf 

[hereinafter Tr.]; Interview with Timothy Decker, Director of DYS, et al. in Ft. Bellefontaine, Mo. (July 20, 2010) 

[hereinafter Decker Interview]. 

43 Id. 44 Tr., T. Decker, 50:21-51:1, 61:5-6. 

45 Decker Interview. 

46 Id. 47 Tr., T. Decker, 49:22-50:2. 

48 Id. 61:8-9. 49 App. C 10-11 (Ft. Bellefontaine response to Question 9(b)). 

50 Id. 14 (Ft. Bellefontaine response to Question 12). 51 BJS Juvenile Report 5 tbl.3. 
7

    Facility’s Explanation of Low Incidence of Sexual Victimization 

Mr. Timothy Decker, Director of DYS, testified on June 3, 2010, that one could attribute the lack 

of any reported sexual victimization at Ft. Bellefontaine to DYS’ philosophy, focusing on 

rehabilitation over punishment.52 

Mr. Decker said that, like other states, Missouri at one time operated a large, central, residential 

training school for boys.53 A federal report condemning Missouri’s operation of the school led to 

reform, creating smaller regional facilities, like Ft. Bellefontaine, that allow residents to be as 

close as possible to their families.54 Mr. Decker testified, “The punitive culture of the early days 

has been replaced with a safe, structured and therapeutic environment.”55 At DYS, he said, 

“Young people are in the constant presence of caring staff, learning firsthand what it means to 

have healthy relationships with peers and adults.”56 

Mr. Decker testified that each DYS facility divides the residents into groups of ten or twelve, and 

this group then does everything together, including chores, school activities, and group 

sessions.57 

Mr. Decker said that one of the distinctive features of DYS programming is the building of group 

cohesion through a culture of open communication. “When a conflict or concern arises, a group 

circle is called by a group member or staff. Everyone stops what they are doing to share 

observations, feelings, discuss alternatives and help each other achieve their goals.”58 Mr. 

Decker stated that DYS supports this therapeutic culture with specialists and group leaders who 

work as a team.59 The involvement of families and community groups with youth in DYS 

programs also contributes to “creating a culture of openness, engagement and transparency.”60 

Commenting on the number of juvenile justice systems that come to visit DYS facilities to learn 

from them, he said that he emphasizes to visitors the importance of focusing on institutional 

culture: 

A common message to our visitors is simple but compelling. Changing your end 

destination often involves starting from a fundamentally different place. To 

create safer institutions, leaders must often question the very philosophical 

foundations of their work and address the underlying organizational culture within 

facilities along with strengthening and changing fundamental practices. . . . 

                                                           

52 Tr., T. Decker, 49:8-17, 55:17-56:8. 

53 Id. 48:21-49:5. 54 Id. 49:12-13. 55 Id. 50:11-13. 56 Id. 50:17-19. 57 Id. 50:21-51:2. 58 Id. 51:3-6. 59 Id. 51:7-12. 60 Id. 51:13-15. 
8

Missouri DYS is very deliberate in aligning all practices with our core values. . . . 

The very assumptions of which many youth correctional programs are based are 

counter to the research and experience related to the cognitive behavioral and 

emotional development of adolescents. If we view young people in the system as 

a product of their past experiences, a work in progress, and a potential resource to 

others, we are compelled to weave together a safe and humane system that 

supports personal development and change, and to continually try to make it 

better.61 

Mr. Decker contrasted DYS’ therapeutic approach to the punitive approach that many other 

states use, noting that there are a range of services available, from placing youths back in the 

community to group homes, moderate care facilities, and secure facilities.62 He said, “The 

emphasis is on actually rehabilitation of the youth as opposed to control of their behaviors. 

Positional power, autocratic approaches . . . are de-emphasized, and instead we emphasize 

healthy hierarchy, boundaries, and development of healthy relationships.”63 

Mr. Decker said that the terms used in a juvenile justice system tellingly reflect its culture: 

Instead of viewing the young people as inmates, we see them as young people. 

Instead of having majors, lieutenants and sergeants, we have leaders, managers 

and directors. There’s a lot to be said for what you call things in these systems. 

We don’t have correctional officer[s] or security workers or security. We have 

youth care workers. We have service coordinators, and we have counselors.64 

Mr. Decker said that the youth’s family plays an important part in the rehabilitation process. The 

family is not a problem, he observed, but a partner.65 

Mr. Decker testified that there is a correlation between the institutional methods for treating 

youth in custody and sexual victimization; when coercion is the tactic for controlling youth, one 

should not be surprised to find youth relying on coercion as well: 

Many aspects of traditional institutional and correctional practices in juvenile 

justice include punitive and coercive approaches that devalue and objectify young 

people creating fertile ground for safety issues and sexual victimization. It should 

be no surprise that if the way we control the kids is through coercion that we will 

. . . have a growth of other coercive behavior such as sexual victimization. 

                                                           

61 Id. 52:2-53:13. 62 Id. 54:2-9. 63 Id. 54:10-15. 64 Id. 54:16-55:1. 65 Id. 55:2-4. 
9

It has been our experience that in order to protect youth from being sexually 

victimized in our programs, we must address the issue systemically by creating 

physically and emotionally safe environments that protect our youth from all 

forms of harm, whether that be emotional, verbal, physical, sexual, et cetera. 

Sexual victimization in institutions cannot be effectively dealt with in isolation or 

as a singular issue. At the core, all forms of institutional abuse create a lack of 

safety for young people, staff, and eventually for the public because young people 

get released without having the root causes addressed.66 

Missouri’s emphasis on building a therapeutic culture in its juvenile correctional facilities, Mr. 

Decker testified, does not come at the expense of weakened security: 

Security is a very important aspect of all programming. . . . Missouri has found 

that even with the best security tools and high-tech equipment, youth are still not 

protected from harm, and public safety may be compromised. Safety and security 

is actually enhanced by creating a humane culture of care. This is ultimately what 

keeps young people safe, not hard work, fences or cameras.67 

Mr. Decker stated that a safe environment in DYS facilities relies on five building blocks: 

(1) basic expectations, (2) basic needs, (3) engaged supervision, (4) clear boundaries in 

communication, and (5) unconditional positive regard.68 

“Basic expectations are norms created for the program environment and how staff and students 

are expected to treat one another.”69 

Basic needs are food, clothing, and shelter. Many young people who come under the protection 

of juvenile facilities come from backgrounds where they did not get their basic needs met.70 

Unless juvenile facilities meet the residents’ basic needs in a healthy way, residents may seek to 

meet them in unhealthy ways, through bartering, hoarding, or misuse of power.71 

Engaged supervision differs from the traditional custodial-care approach in that the staff is 

involved in all group activities, not posting themselves on a stand or patrolling from the 

sidelines.72 Mr. Decker said, “In all programs staff are required to see all youth at all times, 

except during hygiene, and even then staff are strategically placed and aware. . . . By keeping 

                                                           

66 Id. 55:17-56:14. 67 Id. 56:15-57:3. 68 Id. 57:20-58:1. 69 Id. 58:5-8. 70 Id. 59:12-14. 71 Id. 59:14-18. 72 Id. 60:21-61:4, 61:13-15. 
10

youth productively engaged and structuring staff member involvement, opportunities for 

unproductive or harmful interactions are decreased.”73 

Setting clear boundaries in communication is essential for establishing safe relationships, not 

only in the institution, but also when the young person returns home.74 Because many young 

people come to juvenile institutions with compromised boundaries, Mr. Decker testified, it is 

critical that the staff has extensive training on “staff roles, ethical conduct, adolescent 

development . . . [and] indicators in what we call slippery slopes, and team responsibilities.”75 

DYS requires all staff members to participate in professional boundary training sessions within 

the first three months of employment; the DYS offers more advanced training to staff members 

within their first three to twelve months of employment.76 DYS also provides training to staff in 

providing feedback to peers, supervisors, and direct reports by offering coaching to all leaders at 

DYS.77 

A program with staff members who have an unconditional positive regard for youth and their 

families enhances safety by cultivating an environment that does not tolerate harmful behavior.78 

According to Mr. Decker, one has to be able to see beyond the problematic behavior that brought 

a young person into the juvenile justice system, otherwise one cannot address the underlying 

core issues that led to the misconduct.79 

Mr. Decker added five other observations. First, juvenile justice facilities need to recognize that 

they are responsible for insuring the safety of youth in custody and that “juveniles have rights to 

a safe, humane, and developmentally appropriate environment.”80 Second, juvenile justice 

systems should focus on changing the culture within juvenile correctional institutions.81 Mr. 

Decker noted that sexual victimization is often a symptom of the compromised safety young 

people experience in institutional settings. “Developing action plans to proactively address the 

systemic problems with prevention of institutional victimization will pay greater dividends than 

action and efforts focused only on education, detection, investigation, and disciplinary responses 

to sexual abuse. In other words, culture trumps everything.”82 Third, there are drawbacks in 

relying too heavily on a medical model for classification and treatment.83 Mr. Decker said that 

when placement decisions rely only on professional, medical, and mental-health assessments, 

youths may remain unnecessarily in custody.84 Fourth, national standards need to take into 

                                                           

73 Id. 61:9-12, 61:17-20. 74 Id. 61:22-62:4. 75 Id. 62:10-15. 76 Id. 61:16-20. 77 Id. 63:3-16. 78 Id. 63:17-21. 79 Id. 64:3-9. 80 Id. 64:15-20. 81 Id. 64:21-65:1. 82 Id. 65:9-15. 83 Id. 65:16-18. 84 Id. 66:3-8. 
11

account the successes of state juvenile justice systems.85 “Overly prescriptive models for 

achieving standards and capacity-building risk compromising the structure and goals of effective 

systems.”86 Fifth, juvenile justice systems need to address the cycle of offending that leads to 

sexual victimization.87 When youth who have been sexually victimized return to their 

communities, they not only need effective support, but those who were involved in inappropriate 

sexual behavior also need effective intervention programs.88 

DYS provides training to its staff on a broad range of topics, including programs on conducting 

investigations and identifying child abuse and neglect.89 Within the first two years of 

employment, all DYS staff must complete at least 180 hours in adolescent care with forty hours 

of on-the-job coaching.90 After the initial training, each staff person receives annually forty 

hours of professional development training.91

In response to the Panel’s request, DYS provided after the hearing more information on its 

training program for staff on maintaining professional boundaries.92 The training program 

identifies what it terms “the zone of helpfulness,” the optimal professional relationship staff 

should have with juvenile residents.93 Staff members miss this mark when they are either underinvolved or over-involved with the youth in their care.94 From the youth’s perspective, an 

example of a staff person being under-involved is “[s]taff doesn’t know anything about my 

family.”95 Again, from the youth’s perspective, an example of a staff person being overinvolved is “[s]taff spends time with me even when not on shift.”96 The training program 

addresses the “gray areas” in professional boundaries, noting that when the relationship between 

a staff member and a resident becomes confused, the boundaries blur.97 

The training program cautions employees that they may encounter professional boundary issues 

under circumstances that do not rise to the level of a legal or policy violation.98 According to the 

staff training program, warning signs of inappropriate boundary-crossing may include the 

following actions: “isolating yourself with youth . . . confiding secrets to youth; relying on a 

youth for emotional support . . . telling sexual jokes or stories; giving or receiving gifts; 

                                                           

85 Id. 66:15-18. 86 Id. 66:18-20. 87 Id. 67:7-9. 88 Id. 67:1-5. 89 App. C 19-20 (Ft. Bellefontaine response to Question 17(b)). 

90 Id. 21 (Ft. Bellefontaine response to Question 19(a)). 91 Id. 92 Supplemental Materials (Ft. Bellefontaine) (on file with the Panel) [hereinafter Supp.]. 93 Supp. (Slide 1(b)). 

94 Id. 95 Id. 96 Id. 97 Id. (Slide 1(d)). 98 Id.
12

‘defending’ the youth’s inappropriate behavior . . . unauthorized and personal letters, email, 

calls, text[s] . . . staff covering for staff in regard to inappropriate behavior.”99 

The program also identifies practices that support healthy boundaries and the practices that 

undermine them.100 Examples of practices supporting healthy boundaries include hiring the right 

staff, having one-on-one conversations with youth in view of others, scheduling inexperienced 

staff to work with more experienced colleagues, and staying on the topic in team meetings.101 

Examples of practices that undermine healthy boundaries are transporting a youth alone in a staff 

person’s personal vehicle, talking to a youth about another staff person, making inappropriate 

self-disclosures to a youth, and having a conversation with a youth at night when the rest of the 

residents are sleeping.102 

In regard to training for supervisors and coworkers, DYS’ training program notes the following 

areas that require watchfulness: a staff member’s distress or upset, therapeutic drift, lack of 

counseling goals, counseling that exceeds the usual time limit, reluctance to refer a youth to 

another staff person for help, and becoming overly involved in a youth’s life.103 The 

watchfulness list also flags “unwise techniques” and “unique vulnerabilities.”104 Unwise 

techniques include establishing a relationship with routine hugging or excessive touching, 

counseling in non-traditional settings, socializing with a youth, and intervening inappropriately 

in a youth’s life.105 Unique vulnerabilities include being attracted to the youth, over-identifying 

with the youth, having similar family dynamics as the youth’s, experiencing divorce or loss, or 

undergoing identity confusion.106 

Rhode Island Training School 

 Facility Description 

The RITS, located in Cranston, Rhode Island, operates under the auspices of the Rhode Island 

Department of Children, Youth and Families (DCYF), a unified state agency responsible for 

child welfare, child protection, behavior health, juvenile probation, parole, detention, and secure 

corrections.107 

Since January of 2009, the RITS has undergone a major change, moving to new facilities and 

reorganizing the services it provides residents.108 Prior to January 2009, the RITS had a total 

                                                           

99 Id. (Slide 1(e)). 100 Id. (Slide 1(g)). 101 Id. 102 Id. 103 Id. (Slide 1(i)). 104 Id. 105 Id. 106 Id. 107 Tr., P. Martinez, 145:8-12. 108 Id. 146:6-20. 
13

capacity of 205 residents, housing both male and female residents in eight units, including a 

detention center, a maximum security unit, a specialized unit, a substance abuse unit, and four 

general population units.109 The RITS has moved to three smaller facilities: two facilities for 

male residents (i.e., a youth assessment center with fifty-two beds and a youth development 

center with ninety-six beds), and one facility for female residents with twenty-four beds, which 

houses both detailed and adjudicated youth.110 The youth development center has a specialized 

treatment program, which houses two distinct populations: youth with aggressive behavior and 

youth with a history of sex-offender behavior.111 The development center also has a specialized 

treatment program for substance abuse.112 For juvenile program workers, the staff-to-student 

ratio is one to eight.113

The RITS staff includes administrators, unit managers, clinical social workers, and juvenile 

program workers.114 The RITS has a staff that provides a regular education program for 

residents (i.e., principal, guidance counselor, psychologist, and teachers).115 The RITS also has 

five registered nurses, and a private vendor, the Life Span hospital system, provides medical and 

psychiatric services.116 

In the time period of the survey that produced the BJS Juvenile Report, there was a single 

reported juvenile-on-juvenile sexual encounter at the RITS, but a thorough investigation 

concluded that the charge was unfounded.117 

 Facility’s Explanation of Low Incidence of Sexual Victimization 

Ms. Patricia Martinez, Director of DCYF, testified at the Panel hearing on June 3, 2010, that in 

addition to a commitment to a zero-tolerance policy regarding sexual misconduct,118 there may 

be three factors that contributed to the low prevalence of sexual victimization at the RITS: (1) the 

training program for staff, (2) the assessment procedures for youth, and (3) transition planning.119 

In regard to training, before DCYF hires each staff member, the applicant must complete six 

weeks of training, with forty hours each week.120 The training academy covers a wide range of 

topics, including laws on identifying and reporting abuse, with a special emphasis on the staff of 

                                                           

109 Id. 146:6-12. 110 Id. 146:13-147:1. 111 Id. 147:9-13; id., K. Aucoin, 166:17-21. 112 Id., P. Martinez, 147:13-17. 113 App. C 13 (RITS response to Question 11). 114 Tr., P. Martinez, 148:4-9. 115 Id. 148:10-14. 116 Id. 148:15-19. 117 App. C 17 (RITS response to Question 16). 118 Tr., P. Martinez, 145:13-15. 119 Id. 148:20-149:2, 150:14-16, 151:5-9. 120 Id. 149:2-6. 
14

the RITS.121 Topics include issues related to the abuse of residents, the investigative process, 

and the various treatment programs available to residents.122 In addition to this training program, 

DCYF partners with the Rhode Island College’s School of Social Work through the Child 

Welfare Institute to provide in-service training for each RITS staff member.123 Every week, staff 

members attend a training session offering professional development.124 

In regard to student assessment, within forty-eight to seventy-two hours of a youth being 

admitted to the detention facility at the RITS, the staff conducts assessments.125 The RITS uses 

the Massachusetts Youth Screening Inventory (MAYSI) to evaluate safety and risk issues for 

each new student.126 Once the youth is adjudicated, the RITS makes another assessment using a 

global assessment instrument to determine the youth’s treatment plan during the youth’s tenure 

at the RITS.127 

In regard to transition planning, Ms. Martinez testified that DCYF understands its mission as 

planning for transition from the first day that the youth comes to the RITS, which entails 

working with the youth’s family to prepare for the success of the youth’s eventual discharge.128 

Ms. Martinez said, “[I]t’s our mission to do transitioning from day one, from the day that that 

youth comes into the Training School.”129

Mr. Kevin Aucoin, the Acting Superintendent of the RITS, identified additional factors that 

contributed to the RITS’ low incidence of sexual victimization. Consistent with Ms. Martinez’s 

testimony, Mr. Aucoin emphasized the importance of transition planning.130 Mr. Aucoin said, 

“Our goal is to decrease the length of time youth have to spend in institutional care, and I think 

that culture has very much helped us and achieved some of the results that you have before you 

today.”131 Mr. Aucoin said, “My feeling is the longer [a] youth stays in institutional care, the 

worse off the outcome is going to be for that youth, both in-house and out of the facility.”132 

In addition to transition planning, Mr. Aucoin said the RITS’ success relies on the programming 

it provides its residents.133 Mr. Aucoin noted that the RITS has been under a federal court 

consent decree since the 1970s, which is still in effect.134 One of the key elements of the consent 

decree is that within thirty days of adjudication, every youth must have an individualized 

                                                           

121 Id. 149:7-13. 122 Id. 149:13-19. 123 Id. 149:20-150:6. 124 Id. 150:7-9. 125 Id. 150:14-19. 126 Id. 150:19-21. 127 Id. 150:22-151:4. 128 Id. 151:5-14; id., K. Aucoin, 165:17-21. 129 Id., P. Martinez, 151:7-9. 130 Id., K. Aucoin, 163:9. 131 Id. 163:9-13. 132 Id. 168:21-169:2. 133 Id. 164:11-14. 134 Id. 164:15-18. 
15

treatment plan.135 Once a youth has a treatment plan, the RITS reviews the plan bimonthly and 

includes in the program transition planning.136 

Mr. Aucoin noted that the relatively high educational level of RITS staff members contributes to 

its success; all have at least an associate’s degree, and many have a bachelor’s degree.137 

Mr. Aucoin said that the RITS benefits from being part of DCYF; as a unified agency, DCYF is 

concerned about the broader project of community development—being able to provide services 

that involve children’s health and welfare, not just juvenile justice services.138 

Mr. Aucoin said that the RITS considers whether an alternative program would better serve a 

youth who is in custody, which may lead DCYF to placing the youth at home with a variety of 

services.139 

In 2006 and 2007, the RITS had a population of over 200; at the time of the hearing on June 3, 

2010, it had a population of 146.140 Mr. Aucoin said that the reduction in numbers reflects the 

ability of the RITS to integrate juvenile offenders back into the community, shortening the length 

of time in the program.141 “It [the reduced population] has communicated a culture both inside 

and outside the Training School that we will work together. We will work with the family. We 

will work with community providers to insure . . . the safety of youth both in the facility and 

outside the facility.”142 

According to Mr. Aucoin, youth who arrive at the RITS immediately become aware of the RITS’ 

process for investigating complaints: they meet with the unit manager and the unit social worker 

and they receive the rules for the facility.143 One of the clear rules in all units is zero tolerance 

for abuse and neglect, and the RITS encourages youth to meet with the unit manager or with a 

social worker if an issue arises that needs attention.144 Residents are also aware of the right to 

call (or have administrative management call) the child-abuse hotline.145 They also have access 

to nurses, doctors, clinicians, and therapists to report sexual victimization; and as Rhode Island is 

a mandatory reporting state, any of these professionals who has reason to believe a child has 

been abused has a duty to report the suspected abuse to the child-abuse hotline.146 In Rhode 

Island, the Child Advocate’s Office serves as an ombudsman for all youth in DCYF’s care; it has 

                                                           

135 Id. 165:6-16. 136 Id. 137 Interview with K. Aucoin, Acting Superintendent of RITS, et al., in Cranston, R.I. (July 22, 2010). 138 Tr., K. Aucoin, 163:2-8. 139 Id. 165:22-166:7. 140 Id. 178:6-9. 141 Id. 178:10-12. 142 Id. 178:13-17. 143 Id. 170:14-21. 144 Id. 171:6-11. 145 Id. 171:11-17. 146 Id. 171:18-172:3. 
16

unrestricted access to all youth at the RITS at any time to inspect conditions of confinement 

without obtaining prior permission.147 Citing the role of the Child Advocate’s Office, Mr. 

Aucoin noted that it promotes a culture of deterrence and safety within the facility.148 

Included in the orientation packet for new arrivals at the RITS is the Rhode Island Children’s 

Bill of Rights, which clearly states the civil and due process rights of children in DCYF’s care, 

and the RITS displays posters with the same information in all living units.149

Child Protective Services (CPS), which is part of DCYF but separate from the RITS, provides 

training to RITS staff on its duty to protect children and report abuse; operates the child-abuse 

hotline; and investigates any allegations of child abuse, including sexual victimization at the 

RITS.150

   

In the RITS facilities, there is constant video surveillance in the two programs for boys.151 Mr. 

Aucoin said that he thought the cameras provided “a very strong deterrent in terms of conduct, 

[for] both residents and . . . staff.”152 

Institutions with the Highest Prevalence of Sexual Victimization 

 Pendleton 

 Facility Description 

Pendleton, located in Pendleton, Indiana, about an hour’s drive northeast of Indianapolis, 

operates under the auspices of the Division of Youth Services (DYS) of the IDOC. Pendleton is 

a 360-bed maximum security facility for males between the ages of twelve and twenty-one.153 

“Pendleton typically holds Indiana’s most violent youth, including all adjudicated male sex 

offenders. The facility’s sex offender population currently accounts for approximately 37 

percent of the overall population.”154 Pendleton also holds youth with special needs and mental 

health issues.155 

The complex for sex offenders at Pendleton, which has ninety-six beds, has cameras in all of the 

rooms; the other housing units do not have cameras, except for the segregation unit.156 

                                                           

147 Id. 172:4-21. 148 Id. 172:22-173:3. 149 Id. 199:11-14; app. C 25 (RITS response to Question 20(a)). 150 Tr., S. Fogli-Terry, 153:20-155:16. 151 Id., K. Aucoin, 177:5-8. 152 Id. 177:17-19. 153 Id., E. Buss, 219:11-13. 154 Id. 219:13-17. 155 Id. 219:19-21. 156 Id., L. Commons, 264:2-5. 
17

The Panel noted that during the onsite visit to Pendleton, it would be difficult on first impression 

to distinguish Pendleton from an adult facility—residents wore orange jumpsuits and the 

atmosphere had a heavy corrections emphasis.157 

The BJS Juvenile Report found that 36.2% of the youth at Pendleton reported sexual 

victimization,158 with 18.1% reporting staff sexual misconduct with force and 16.8% reporting 

staff sexual misconduct without force.159 During the time period of review, Pendleton reported 

nineteen complaints with allegations of sexual victimization of a youth.160 

Response to the BJS Juvenile Report and Corrective Actions 

In preventing prison rape in IDOC facilities, and especially at Pendleton, Mr. Edwin Buss, 

Commissioner of IDOC, testified that IDOC has taken the following actions: (1) implementing 

policies and procedures to enforce zero tolerance for sexual victimization, including the issuance 

of an executive directive in the wake of the findings of the BJS Juvenile Report; (2) having a 

Prison Rape Oversight Group (PROG), which is responsible for working with both adult and 

juvenile facilities to address issues related to prison rape and to respond to incidents of sexual 

assault; (3) restructuring the DYS; (4) adopting a balanced and restorative justice model, moving 

toward a more therapeutic model in managing corrections facilities; (5) adhering to the Council 

of Juvenile Correctional Administrators’ performance-based standards; (6) reducing the stay for 

youths in secure facilities; (7) working to return youth to community-based supervision; (8) 

reducing the population of residents; (9) maintaining staffing levels despite budget constraints; 

(10) moving the youngest offenders at Pendleton to a separate facility; (11) partnering with a 

private service provider to oversee the sex offender treatment program at Pendleton; (12) 

conducting sexual victimization interviews with all Pendleton residents; (13) developing a 

digital, web-based education training video on PREA and prevention of sexual abuse in a secure 

environment; (14) requiring all staff to complete the National Institute of Corrections’ online 

course on responding to sexual abuse and providing staff with other opportunities for training; 

(15) creating a PREA-awareness public-service announcement, which Pendleton shows to every 

new resident at intake and broadcasts to residents every week over its TV-video system during 

school hours; (16) enhancing reporting procedures for incidents of sexual victimization; (17) 

requesting technical assistance from the Indiana Juvenile Justice Task Force to strengthen staff 

hiring and screening practices; (18) removing solid doors to coat closets, living areas, and 

storage rooms at Pendleton; (19) relocating and installing cameras at Pendleton to avoid blind 

spots in housing units, the kitchen, and the laundry; (20) creating a camera surveillance 

monitoring room at Pendleton, staffed eighteen hours per day, seven days per week; (21) 

                                                           

157 Id., R. Wilkinson, 234:15-235:2. 158 BJS Juvenile Report 4 tbl.2. 159 Id. 9 tbl.6. 160 App. C 17 (Pendleton response to Question 16). 
18

initiating a staff-to-youth mentoring program; and (22) adding correctional officer positions, 

especially during the evening shift.161 

Mr. Buss noted the reduction of the average length of stay at Pendleton from 256 days in 2007 to 

186 days in 2009.162 The overall population at Pendleton has also decreased; at one time it was 

over 360, whereas in recent months, it has remained about 270.163 

Ninety-four percent of the staff at Pendleton has undergone a six-hour training program on 

offender manipulation and sexual misconduct.164 

The BJS Juvenile Report also prompted a review of every place at Pendleton a staff person could 

be alone with a student, which led to making as many changes as possible not only to protect the 

youth but also to prevent the staff from being in a vulnerable position.165 Pendleton has also 

developed an employee council to listen to the concerns of staff members who were affected by 

the negative publicity connected to the reported high incidence of staff sexual misconduct at the 

facility.166 Training and the publication of the BJS Juvenile Report have raised awareness among 

employees of the responsibility that they share to pay attention to one another and to hold each 

other accountable.167 

There are different reporting mechanisms now in place at Pendleton than there were at the time 

of the BJS study.168 One of the changes in the reporting process is the establishment of an 

anonymous tip line that residents may call by pressing #22 (pound twenty-two) on the key pad of 

telephones readily accessible to them.169 Pendleton has also posted PREA posters in the facility 

with relevant information on preventing and reporting sexual abuse.170 

Intake at Pendleton is a two-week process and preventing sexual victimization is one of the 

issues covered.171 During the orientation for new residents, the staff discusses the PREA manual 

and has a lesson on preventing sexual victimization; moreover, the staff calls each new resident’s 

home and has the same discussion with the youth’s parents.172 Every Wednesday, a multidisciplinary committee convenes to classify residents; for new residents, one of the factors the 

committee considers is prevention of sexual victimization.173 In placing residents, DYS 

                                                           

161 Tr., E. Buss, 220-27. 162 Id. 222:4-6. 163 Id. 222:17-20. 164 Id., M. Grady, 250:20-251:3. 165 Id., L. Commons, 277:9-15. 166 Id. 277:22-278:5. 167 Id. 278:6-13. 168 Id. 267:2-4. 169 Id. 267:4-5. 170 Id. 267:5-8, 10-11. 171 Id., M. Greathouse, 271:7-11. 172 Id. 271:12-15. 173 Id. 240:11-241:8. 
19

separates younger students from older ones; it also separates residents by their offenses.174 For 

example, in the sex offender unit, predators and victims do not share the same room.175 

After reviewing the data on sexual incidents in the facility, Pendleton found that most of them 

occurred during the evening shift.176 To address this problem, Pendleton increased the frequency 

of staff tours from every fifteen minutes to every five minutes.177 Now staff members must have 

their eyes on offenders every five minutes.178

Ms. Commons, the current superintendent at Pendleton, stated that Pendleton is currently 

involved in a program to assess its cultural competency by having outside officials work with 

staff members by listening to their comments and coaching them to develop values statements 

for the facility.179 Echoing the testimony from Missouri, Ms. Commons stressed the importance 

of institutional culture: 

[C]ulture is the issue, and if you can change that culture, if you can find the areas 

that are weak or wanting in your culture, you can make all of the difference in the 

world, and when you empower staff to be involved in that process so that it comes 

from the bottom up, it can be very powerful.180 

In regard to institutional culture, Mr. Buss observed that, contrary to his own viewpoint, IDOC in 

the past, reflecting the national mood at the time, had a philosophy of operating juvenile facilities 

similar to adult facilities.181 He said that two years ago, when he walked into his first juvenile 

facility at DYS, he was surprised to find a twelve-year-old boy in a segregation cell similar to 

one found in an adult facility.182 Up to a few years ago, adult and juvenile policies were in the 

same book; and superintendents transferred back and forth from adult facilities to juvenile 

facilities, as there was no thought to whether a superintendent needed special skills to work with 

youth offenders.183 There was also a time when the distinctions between staffing adult and 

juvenile facilities blurred; staff members who worked in juvenile facilities received training that 

allowed them to work in adult facilities.184 IDOC has been moving away from this model, 

training youth service officers through a separate training academy with the focus on serving 

young people.185 

                                                           

174 Id., L. Commons, 239:10-13, 19. 175 Id. 239:20-240:3. 176 Id. 263:15-16. 177 Id. 263:16-17. 178 Id. 263:18-19. 179 Id. 233:4-17, 234:3-13. 180 Id. 233:18-234:2. 181 Id., E. Buss, 235:15-20. 182 Id. 235:21-236:6. 183 Id. 284:2-3, 9-13. 184 Id., M. Dempsey, 256:10-20. 185 Id.
20

In assessing why Pendleton had a high incidence of sexual victimization, Mr. Michael Dempsey, 

Executive Director of DYS, who was also previously the superintendent at Pendleton, identified 

a number of contributing causes. 

Mr. Dempsey stated that the “number one factor” was overcrowding.186 He testified, “When you 

put that many kids in one facility like that, bad things tend to happen. Regardless of your best 

efforts, they do.”187 Mr. Dempsey said that another contributing factor was staffing; at the time 

BJS interviewed residents at Pendleton, there were significant hiring delays.188 

Mr. Dempsey said that another one of the principal failings of Pendleton was failing to train staff 

on dealing with adolescent development: 

I think if there is any one particular area where we’re failing, it’s in providing . . . 

training where they [staff members] can effectively manage and deal with 

adolescent development, particularly as it relates back to sexual growth. I think 

that many times they just simply don’t know how to deal with those situations 

with those children as they’re growing and developing inside a correctional 

facility.189 

Reflecting on staff members who cross professional boundaries to become sexually involved 

with residents, Mr. Dempsey said that a traumatic event in the life of a staff person might have 

caused a serious lapse in judgment: 

I have seen seasoned correctional professionals who have been in the business for 

many, many years, who you would at first never believe to be involved in . . . a 

situation like that . . . at some point they grew close to that child. They developed 

a personal relationship and a professional one at that, and at some point in time, 

some sort of traumatic event took place in that person’s life, a death, a divorce, 

something occurred, and the situation was manipulated from there.190 

Mr. Dempsey said that staff members becoming involved in these misguided relationships is just 

one source of youth sexual victimization; he recognized that other sources included staff 

members who are predators and staff members who fail to follow proper procedures and find 

themselves manipulated by a resident.191 

In thinking about why supervisors and colleagues fail to recognize the indicators that may 

identify a staff person becoming overly involved with a youth, Mr. Dempsey suggested that 

                                                           

186 Id. 260:19-21, 261:1-2. 187 Id. 261:4-6. 188 Id. 262:2-6. 189 Id. 242:13-20. 190 Id. 247:7-20. 191 Id. 247:21-248:1-7. 
21

employees may discount what they are observing because they have a relationship with the 

coworker and they know that the ramifications of falsely accusing a colleague are grave: 

I think that in most cases people work so closely with one another that they 

believe in that person, and they don’t believe that that other person would get off 

into a situation like that or do anything that would harm a kid, and they know that 

those are serious allegations to raise against another fellow staff member, and if 

you’re going to raise that type of allegation, you need to be 100 percent sure that 

that’s what’s taking place.192

Mr. Dempsey expressed frustration in not being able to identify reliable screening mechanisms 

that would identify candidates for employment who have a propensity for entering into 

inappropriate relationships with youth: 

I think when you’re looking at the perspective of how we screen and qualify staff 

to work in our juvenile facilities, I have looked at . . . what the other states are 

doing, and I have yet to find anything that anybody is doing that we’re not already 

doing or at least looking into. . . . So I don’t think there’s an easy answer and I 

don’t believe that there’s any one system that anybody has employed that helps 

fight this issue. It’s an incredibly complex issue when you look at it from the 

perspective of staff sexual misconduct with youth, and it’s not something that is 

unique to prisons.193 

The Panel noted in response to its Data Request that Pendleton reported a high rate of attempted 

suicides and one suicide during the time period under review.194 Pendleton administrators 

reported that there was no linkage between sexual victimization and the suicide or the attempted 

suicides.195 

Woodland Hills 

 Facility Description 

Woodland Hills, located in Nashville, Tennessee, serves 120 male youth offenders, and is one of 

the five secure youth development centers that the Division of Juvenile Justice (DJJ) of the 

Tennessee Department of Children’s Services (TDCS) operates.196 The staff-to-resident ratio is 

one to twelve.197 

                                                           

192 Id. 249:13-21. 193 Id. 245:22-246:20. 194 App. C 9 (Pendleton responses to Questions 8(a) and 8(b)). 195 Tr., L. Commons, 274:14-275:9; id., M. Dempsey, 275:19. 196 Id., S. Hornsby, 305:4-12. 197 Id., A. Dawson, 320:21-321:2. 
22

According to the BJS Juvenile Report, the only incidents of sexual victimization at Woodland 

Hills involved staff and youth; there were no youth-on-youth incidents.198 Twenty-six percent of 

youths reported sexual victimization by staff,199 but the reported incidents with staff did not 

involve force, coercion, or pressure.200 

Response to the BJS Juvenile Report and Corrective Actions 

Steven C. Hornsby, Deputy Commissioner, DJJ, TDCS, testifying at the hearing on June 4, 2010, 

explained the organization of TDCS and summarized the TDCS response to the publication of 

the BJS Juvenile Report. Neither Mr. Hornsby nor any of the other witnesses from Tennessee 

provided an explanation for the high incidence of sexual victimization at Woodland Hills, as 

TDCS questioned the accuracy of the BJS Juvenile Report as it pertains to Woodland Hills. 

Mr. Hornsby stated, “Tennessee has long recognized the need for a juvenile justice system that is 

separate and distinct from the adult correctional system and which is focused on rehabilitation, 

treatment and training of young offenders.”201 Mr. Hornsby explained that Tennessee was one of 

the leading states, beginning in the 1970s, to recognize that issues relating to juvenile justice are 

completely separate from adult corrections; and in 1987, the state created a separate juvenile 

justice department, which later merged with child welfare and mental health services for youth to 

become the TDCS in 1996.202 TDCS “handles all child protection, dependency, abuse, neglect 

and delinquency” in Tennessee.203 Youth in custody who are not in the development centers, 

such as Woodland Hills, are in a variety of other placements, “including private and stateoperated group homes, therapeutic foster care and adolescent mental health facilities.”204 

As DJJ is part of a larger child welfare organization, external organizations undertake any 

investigations of DJJ facilities related to sexual victimization.205 The external investigatory 

organizations are the Internal Affairs (IA) unit, which is under the Office of the Inspector 

General (OIG), and the Special Investigations Unit (SIU), which is under the Division of Child 

Safety.206 

Each year, the Tennessee Commission of Children and Youth (TCCY or Commission) conducts 

an onsite quality service review of all of the youth development centers.207 A component of the 

review is an examination of safety issues and concerns, and it includes private interviews with 

                                                           

198 Id., A. Beck, 339:11-14; see also BJS Juvenile Report 8 tbl.5. 199 Id. 200 Tr., A. Beck, 339:20-340:1. 201 Id., S. Hornsby, 303:22-304:4. 202 Id. 304:12-305:1. 203 Id. 305:2-4. 204 Id. 305:14-16. 205 Id. 305:17-19. 206 Id. 305:19-306:1. 207 Id. 306:5-10. 
23

residents, families, service providers, and staff.208 After its review, the Commission releases its 

findings and recommendations and works with TDCS on making improvements.209 For the last 

three years, the Commission’s quality service reviews gave Woodland Hills top scores on child 

safety.210 

Following the publication of the BJS Juvenile Report, DJJ asked TCCY and SIU to conduct 

another review of the youth development centers in Tennessee, including in-depth interviews of 

residents, to determine whether they are safe from sexual victimization.211 The survey concluded 

that there was no evidence of current sexual abuse.212 

Mr. Hornsby said, “After thoroughly reviewing all of the facts, we have significant concerns that 

Woodland Hills was identified and labeled as having a high . . . prevalence of sexual 

victimization . . . .”213 214

In addition to resurveying youth development centers, in response to the BJS Juvenile Report, the 

DJJ convened a PREA compliance task force, which undertook a comprehensive review of DJJ 

operations to identify deficiencies and to address them.215 Consequently, the task force drafted a 

new PREA-specific policy.216 The new policy includes notification forms that both residents and 

staff must sign, acknowledging that they are aware of their legal rights and obligations; the forms 

then become part of the employee’s personnel file and the resident’s file.217 DJJ has also 

initiated a PREA-awareness campaign, with all of the superintendents of the youth development 

centers meeting with each staff member to review applicable policies and state laws.218 DJJ 

created a frequently-asked-question sheet related to PREA and produced a hotline-reporting 

poster for distribution at its facilities.219 DJJ is in the process of revising the student handbook 

and expanding the section on sexual abuse, noting in particular how to report violations.220 

Woodland Hills is revising its staff-training curriculum to include PREA-related materials, 

focusing in particular on how to identify and protect vulnerable youth.221 The TDCS’ medical 

                                                           

208 Id. 306:10-14. 209 Id. 306:14-22. 210 Id. 306:22-307:2. 211 Id. 312:18-313:5. 212 Id., C Aaron, 325:2-6. 213 Id., S. Hornsby, 316:7-10. 214 Dr. Allen Beck, the principal author of the BJS Juvenile Report, provided testimony supporting the methodology 

of the BJS’ findings related to Woodland Hills. He distinguished between surveys based on personal interviews, 

which are less reliable because they introduce into the data-collection process the elements of embarrassment and 

fear of retaliation, and surveys that use self-administered instruments, such as BJS’ survey, which are more reliable 

because these elements are less present. See id., A. Beck, 337:1-338:4, 338:7-343:16, 349:13-350:22. 215 Id., S. Hornsby, 309:18-310:1. 216 Id. 310:3-8. 217 Id. 310:9-13. 218 Id. 310:13-18. 219 Id. 310:19-21. 220 Id. 311:6-9. 221 Id. 311:9-12. 
24

staff is also receiving enhanced PREA-specific training, and each member of the nursing staff is 

being trained on Sex Abuse Nurse Examiner (SANE) procedures.222 

Mr. Albert Dawson, Superintendent of Woodland Hills, testified that in response to the BJS 

Juvenile Report, he met with the staff of Woodland Hills in small groups to provide a forum for 

questions, to emphasize the DJJ’s zero-tolerance policy concerning sexual abuse, and to remind 

the staff of its responsibility under state law to report misconduct.223 Mr. Dawson stated that his 

staff also reminded students at Woodland Hills of the various ways in which they can report 

abuse, which include filing a grievance or by notifying case managers, therapists, legal aid staff, 

or other staff members.224 

In addition to serving as the superintendent at Woodland Hills, Mr. Dawson is the facility’s 

PREA coordinator.225 

In responding to the Panel’s inquiry about what was happening at Woodland Hills during the 

period of the BJS survey, Mr. Dawson said that the population was manageable, noting that the 

facility’s capacity is 144; and at the time of the survey, the population was about 120.226 Also, 

during the relevant time period, Mr. Dawson said there were no staff shortages at Woodland 

Hills.227 At the time BJS was interviewing youth, Mr. Dawson said that Woodland Hills was in 

the process of eliminating blind spots in the facility and implementing programs to encourage 

residents though positive incentives.228 

Mr. Dawson said that in regard to providing training to staff on inappropriate relations with 

youth, staff members receive a two-hour orientation on PREA at the pre-service training 

academy.229 One of the most important components of the nine-week, pre-service training 

academy is that newly hired staff shadow selected veteran employees who are aware of issues 

regarding adolescents, supervision, and reporting.230 

According to Mr. Dawson, among the warning signals that indicate that a staff person may be 

crossing a professional boundary in relating to youth are the following: working with a youth in a 

one-on-one setting, selecting a youth for a work project, bringing things into the institution for 

the youth, giving the youth unusual attention, or calling the youth after hours.231

                                                           

222 Id. 311:12-15. 223 Id., A. Dawson, 319:21-320:9. 224 Id. 320:17-321:7. 225 Id. 354:14. 226 Id. 351:16-21. 227 Id. 352:3-6. 228 Id. 352:14-353:17. 229 Id. 373:16-22. 230 Id. 374:1-16. 231 Id. 376:9-15. 
25

When a youth comes to the DJJ, the youth undergoes two assessments, one for risk and one for 

clinical needs.232 This information is available for the classification process.233 

The staff at the medical center at Vanderbilt University conducts a psychological evaluation of a 

Woodland Hills resident on arrival; the staff then makes recommendations regarding the youth’s 

care.234 According to Mr. Dawson, most residents at Woodland Hills have mental health issues, 

but Mr. Dawson distinguishes between having mental health issues and suffering mental 

illness.235 Woodland Hills refers residents with mental health issues to individual, group, or 

family therapy, which the Vanderbilt University staff provides.236 All students have a case 

manager or family service worker,237 and DJJ contracts with private vendors to provide behavior 

health services, including substance abuse and sex offender treatment as well as individual and 

group counseling.238 

Parents or guardians participate in the initial classification meeting with their son and Woodland 

Hills staff, and they contribute to the decisions regarding the youth’s program.239 Woodland 

Hills also invites parents to participate in monthly and quarterly institutional team reviews of 

their son’s progress, and it notifies the parents of any significant events (e.g., illness or injury) 

affecting their son.240 

Residents of Woodland Hills with mental illness have access to the services of a psychologist 

who is available around the clock.241 If there is a need for an outside evaluation, then Woodland 

Hills will refer the resident to a local hospital for screening.242 If the hospital determines that the 

youth is suffering from mental illness, then Woodland Hills arranges for the youth’s transfer to 

another facility, as Woodland Hills does not provide treatment for mental illness.243 

The student handbook at Woodland Hills contains information on how a student should report 

any concerns related to sexual activity.244 Woodland Hills, like other youth development centers 

in Tennessee, has a policy that designates a staff member as the responsible person to receive 

and deal with reports from residents alleging sexual abuse.245 

                                                           

232 Id., S. Hornsby, 364:15-22. 233 Id. 365:5-12. 234 Id., A. Dawson, 366:17-367:1. 235 Id. 367:2-4. 236 Id. 367:4-9. 237 Id., S. Hornsby, 364:8-12. 238 Id. 307:3-6. 239 Id., A. Dawson, 385:13-21. 240 Id. 385:22-386:9. 241 Id. 367:10-18. 242 Id. 367:19-22. 243 Id. 368:3-7. 244 Id., S. Hornsby, 309:3-5. 245 Id. 308:20-309:2. 
26

In processing a complaint of alleged sexual victimization, Woodland Hills has the following 

protocols: the resident files a complaint alleging staff sexual misconduct, either through the 

grievance process or by notifying a staff member; Woodland Hills immediately reports the 

complaint to Child Protective Services; the complaint comes to the attention of the 

superintendent, who then enforces a no-contact period between the accused staff member and the 

youth; Woodland Hills then notifies Internal Affairs; and if there is a need, Woodland Hills 

secures medical attention for the resident.246 A student can also request at any time protective 

custody.247 

Although the process began in 2007, by December of 2009, the DJJ installed cameras in all of its 

youth development centers to improve its surveillance capacity to promote safety.248

Corsicana 

 Facility Description 

Corsicana, which originally served as an orphanage in the nineteenth century, operates under the 

auspices of the Texas Youth Commission (TYC) and houses 145 adjudicated youth (i.e., 133 

males and twelve females) who have either a serious mental illness or a delay in mental 

development.249 What is unique about Corsicana is that all residents have a medical diagnosis.250 

The current staff-to-resident ratio is one to twelve.251 Corsicana contains a special fourteen-bed 

unit, the Crisis Stabilization Unit, which provides hospital-level care to residents.252 Corsicana 

employs 162 correctional officers, twenty caseworkers, and eight psychologists; it contracts with 

the University of Texas Medical Branch for psychiatric services.253 As many as thirty-six 

percent of Corsicana residents have past trauma abuse.254 The population of Corsicana poses 

special challenges in terms of safety and treatment,255 as many residents have prior histories that 

make them particularly vulnerable to sexual assault.256

According to the BJS Juvenile Report, 32.4% of the residents of Corsicana reported sexual 

victimization,257 with 13.9% reporting sexual victimization involving another youth and 23.7% 

reporting sexual victimization involving a staff member.258 

                                                           

246 Id., A. Dawson, 382:2-383:22. 247 Id., S. Hornsby, 384:20-22. 248 Id. 309:11-13. 249 Id., C. Townsend, 402:10-17; id., L. Cazabon-Braly, 402:10-12; Interview with C. Townsend, et al., in Corsicana, 

Tex. (Apr. 27, 2010) [hereinafter Townsend Interview]. 

250 Tr., L. Cazabon-Braly, 402:20-21. 251 Id., J. Smith, 397:15-16. 252 Id., L. Cazabon-Braly, 402:18-20. 253 Id. 403:6-11. 254 Id. 406:10-13. 255 Id., C. Townsend, 393:18-22. 256 Id. 394:1-2. 257 BJS Juvenile Report 4 tbl.2. 
27

Response to the BJS Juvenile Report and Corrective Actions 

In the wake of a highly publicized scandal at TYC involving, among other matters, staff sexual 

abuse of residents,259 Cheryln (Cherie) Townsend, Executive Director, appointed by Texas 

Governor Rick Perry on October 14, 2008, testified to the Panel that the TYC has been in the 

process over the last few years of undertaking significant, systemwide reform.260 Ms. Townsend 

said that given the TYC’s recent problems (BJS’ interviews with youth took place close in time 

to the emergence of the scandal), she was not surprised to learn that the BJS Juvenile Report

identified TYC as having a high prevalence of sexual victimization, but she was surprised to 

learn that Corsicana had such a high response rate.261 

Like the other juvenile justice administrators who testified before the Panel, Ms. Townsend 

highlighted the importance of institutional culture. “I think the greatest challenge that our 

agency faces, and certainly this is true at the Corsicana Residential Treatment Center . . . is 

changing our culture from one of correctional focus only to one that also emphasizes treatment 

as well as accountability.”262

Ms. Townsend said that in recent years TYC has been moving away from a corrections culture to 

a more therapeutic model: 

I think that there was a time in Texas when the juvenile correction system was 

known as the youth prison system and there was an effort at that time probably to 

make our facilities more like the adult prison systems and less like a positive 

youth development culture of change for young people. 

And I think that what we’ve seen, especially in the last two years, is a major shift 

back to not forgetting accountability, but really focusing on youth development. 

As we’ve done that, [w]e’ve really, I think, tried to hire a different kind of person. 

We’ve tried to train for something different.263

Ms. Townsend noted that among the achievements in the recent reform efforts at TYC are the 

following: (1) establishing a twenty-four hour hotline, the Incident Reporting Center (IRC), 

(2) providing trauma-informed care and cognitive therapy to youth, (3) changing the physical 

                                                                                                                                                                                                258 Id. 8 tbl.5. 259 More than eighty news reports and official documents published in 2007-08 related to a scandal involving the 

mismanagement of TYC, which ultimately led both to the criminal conviction of an administrator for sexually 

victimizing residents and to legislative reform, are available online on the Investigative Reports page (Scandal at 

TYC: Abuse and Mismanagement in Texas Juvenile Corrections) at the website of The Dallas Morning News, which 

is available at http://www.dallasnews.com/investigativereports/tyc/. 260 Tr., C. Townsend, 393:13-17 (While other witnesses appeared before the Panel in person, Ms. Townsend 

presented her testimony by telephone). 

261 Id. 423:7-13. 262 Id. 394:4-9. 263 Id. 443:14-444:3. 
28

plants, (4) increasing the ratio of staff-to-youth supervision, (5) establishing a centralized Office 

of Inspector General (OIG) to conduct investigations, (6) creating a Special Prosecution Unit to 

insure consistency in enforcing TYC’s zero-tolerance policy concerning sexual abuse, and 

(7) implementing safe-housing assessments to make appropriate residential placements.264 TYC 

also retained a consultant to conduct an agency-wide and facility-specific review to identify how 

it can improve its approach to eliminating sexual assault through new or refined policies, 

procedures, or practices.265

Affirming Ms. Townsend’s testimony, Mr. James Smith, the director of youth services at TYC, 

who is responsible for supervising residential facilities, noted that as a consequence of recent 

legislation,266 many reforms at TYC were already underway prior to the publication of the BJS 

Juvenile Report.

267 

In addition to the reforms that Ms. Townsend mentioned, Mr. Smith said that as a result of recent 

Texas legislation, the TYC implemented a new treatment modality, the connections model, an 

evidence-based approach to promote positive youth development by “empowering our youth to 

self-direct their behavior and to work on their issues.”268 In programming and counseling for 

youth, TYC also focuses on reentry and continuity of services, providing for the needs of both 

the youth and the youth’s family.269 

TYC also installed over 11,000 cameras in its facilities, with almost 900 at the Corsicana facility 

alone.270 All direct-care staff attended at least 300 hours of training,271 including additional 

training on PREA,272 and all employees underwent extensive background checks.273 The Texas 

legislature also lowered the maximum age of residents in TYC facilities from twenty-one to 

nineteen.274 

Mr. Smith explained that since January of 2009, TYC’s housing policy requires staff to screen all 

new residents at intake to identify those who may be most vulnerable to sexual assault and then 

to place them in suitable housing units, often in close proximity to staff.275 

TYC published a student handbook, which contains information on PREA standards, and it also 

published a parents’ bill of rights, which empowers parents to exercise the rights they retain even 

                                                           

264 Id. 394:11-395:1. 265 Id. 469:4-8; Townsend Interview; Tr., J. Smith, 401:3-7. 266 Act of May 25, 2007, ch. 263, 2007 Tex. Gen. Laws 421 (effective June 8, 2007). 267 Tr., J. Smith, 396:19-22. 268 Id. 397:5-14. 269 Id. 462:16-463:8. 270 Id. 397:16-18. 271 Id. 397:18-21. 272 Id. 397:3-4. 273 Id. 397:22-398:1. 274 Id. 397:22-398:2. 275 Id. 398:7-12; id., L. Cazabon-Braly 405:1-9. 
29

when their children are in state custody.276 Mr. Smith stated that TYC tries to go beyond just 

providing parents with information; instead, it encourages parent involvement.277 

Along with creating the OIG, the reform legislation created the Office of the Independent 

Ombudsman, which has ready access to TYC facilities to interview both staff and residents and 

to assess conditions of confinement.278

Mr. Smith testified that following the publication of the BJS Juvenile Report, Corsicana has been 

engaged in analyzing data related to incidents of sexual victimization, such as the time of day, 

the location, and the facility’s operational practices.279 As part of this analysis, Corsicana closed 

access to a restroom, installed bubbled mirrors and cameras, and plans to relocate cameras to 

multi-occupancy sleeping rooms.280 Corsicana added psycho-educational groups for residents 

and held a brown-bag lunch for staff to discuss issues related to professional boundaries and 

PREA reforms.281 Corsicana is planning to have an outside organization survey every resident to 

ensure that each is safe.282 

In regard to training staff, Mr. Smith emphasized the importance of maintaining professional 

boundaries: 

So a lot of our information and training with our staff centers around 

understanding what those boundaries are, such things as terms of endearment with 

the staff, calling them mama this or they have some pet name that they use for the 

staff. And while initially to the staff it’s flattering or it sends a sense that they are 

developing a good relationship with the kid, unfortunately for the kid, it’s a door 

opening for them to maybe perhaps take advantage of the staff or create a 

situation. 

What we really find is making sure the staff understand[s] that there [are] traps 

that you need to be aware of and while it may be well-intentioned on your part, it 

could certainly be perceived on the youth’s part as an opportunity. And so we are 

looking to enhance our training, especially for our female staff, because we do 

have some young men who are very sophisticated . . . .”283 

TYC’s training programs are not only for staff but also for supervisors.284 Ms. Townsend 

testified that supervisors may not recognize a staff person’s misconduct, because the staff person 

                                                           

276 Id., J. Smith, 398:12-16. 277 Id. 398:17-18. 278 Id. 399:1-8. 279 Id. 399:18-400:2. 280 Id. 400:2-5; id., C. Townsend, 428:6-11. 281 Id., J. Smith, 400:12-17; id., L. Cazabon-Braly, 404:1-7, 12-13. 282 Id., J. Smith, 400:18-401:2. 283 Id. 433:18-434:12. 284 Id., C. Townsend, 438:5-6. 
30

is capable in so many ways that it is hard to conceive that he or she may be crossing the line with 

residents.285 The training for supervisors focuses on their responsibility to coach employees in 

respecting appropriate boundaries and to recognize the indicators when an employee may be 

developing an inappropriate relationship with a youth.286

Ms. Laura Cazabon-Braly, Superintendent of Corsicana, stated that each month Corsicana holds 

town hall meetings with staff, and a topic at every meeting is supervision strategies.287 The 

clinical staff has also provided an eight-hour training program for casework staff to discuss signs 

indicating when a staff member may be crossing a professional boundary when dealing with 

residents.288 

Ms. Cazabon-Braly stated that since the reform of TYC, Corsicana has expanded specialized 

treatment groups for residents.289 One significant change has been moving the psychologists on 

staff to the dormitories in the living units so that residents have greater access to them.290 

Mr. Cris Love, Inspector General for the TYC, reported that for the first seven months of fiscal 

year 2010, the IRC received about 1,100 complaints per month.291 From those incident reports, 

the OIG initiated 150 investigations.292 For Corsicana, each month the IRC receives about 190 

complaints, and the OIG investigates close to forty of them.293 The IRC refers most of the 

complaints to the TYC Youth Services Division; the IRC refers thirty-seven percent of the 

complaints to the TYC’s grievance department.294 The OIG currently employees forty-three 

staff; twenty are peace officers.295 

Mr. Love noted the following recent accomplishments of the OIG: establishing and operating the 

IRC, establishing and operating a system for monitoring use-of-force (i.e., reviewing 

surveillance camera footage on a daily basis to assess whether the staff treats residents 

appropriately), establishing and operating three databases related to complaints and 

investigations (i.e., the IRC database, a criminal complaint database, and an administrative 

complaint database), apprehending absconded youth, reducing the response time for initiating 

investigations, reducing the time to complete investigations, and responding effectively to 

emergencies involving TYC (e.g., hurricane evacuation).296 

                                                           

285 Id. 438:11-15. 286 Id. 438:15-18. 287 Id., L. Cazabon-Braly, 404:8-12. 288 Id. 404:13-16. 289 Id. 403:14-16. 290 Id. 403:18-21. 291 Id., C. Love, 409:14-17. 292 Id. 409:17-20. 293 Id. 409:21-410:7. 294 Id. 410:8-13. 295 Id. 411:8-10. 296 Id. 412:4-413:8. 
31

The management team at Corsicana, not just the superintendent and assistant superintendent, 

assist the OIG in monitoring random samples of video footage of the facility, and then they 

evaluate what they observed.297 By assigning monitoring of the footage to managers, TYC is 

encouraging them to realize that they have a stake in creating the culture of the institution, 

identifying good practices, and correcting inappropriate ones.298 Reviewing video footage may 

also be a way for supervisors to identify the warning signs that a staff person may be crossing a 

professional boundary. Ms. Cazabon-Braly testified that her reviewing of surveillance video 

footage sometimes allows her to recognize incipient staff problems: 

[W]e want to stop things before they escalate to a serious situation. If I’m 

watching video footage and I see a staff member maybe touch a kid on the arm 

too much, proximity is maybe too close, they brought in something to the kid, 

they’re calling the facility about the kid, that’s a red flag for me, and that’s 

somebody we’re going to watch.299 

On admission to Corsicana, a resident receives an immediate psychological screening to 

determine whether the staff should monitor the youth as a suicide risk; all residents receive a full 

psychological evaluation within fourteen days of admission.300 If the youth needs placement in a 

mental health facility, TYC will make the arrangements.301 All TYC facilities have 

psychologists on staff, and they are on call to respond to any needs around the clock.302 

Residents at Corsicana can report incidents of sexual misconduct, attempted sexual misconduct, 

or any other harmful activity by calling the “blue phone” hotline, which is accessible to all 

residents in housing units.303 

In the case of an incident, the chief local administrator or administrative duty officer would do 

the following: notify the superintendent of the facility; ensure, if necessary, that the youth 

receives medical treatment from the infirmary; and contact a mental health professional on call to 

respond.304 If needed, the youth would go to the hospital for an examination by a SANE.305 The 

SANE would then contact the Child Advocacy Center or a local rape crisis center.306 Recent 

legislation requires TYC to track and provide services to a youth abused or injured while in 

TYC’s custody.307

                                                           

297 Id., J. Smith, 439:6-13. 298 Id. 439:14-22. 299 Id., L. Cazabon-Braly, 441:12-19. 300 Id., L. Robinson, 445:18-446:1. 301 Id. 446:2-13. 302 Id. 446:14-16. 303 Id., J. Smith, 421:7-13. 304 Id., L. Robinson, 448:5-15. 305 Id. 448:16-20. 306 Id. 448:22-449:2. 307 Id. 449:19-22. 
32

When the IRC receives a sexual misconduct complaint, it contacts the OIG staff and the 

executive staff, and regardless of the time, the OIG will send an investigator to the scene.308 

 General Observations 

 The Selected Facilities Have Distinctive Characteristics 

Although the Panel’s mandate is to identify common characteristics among the juvenile 

correctional institutions that have the lowest prevalence of sexual victimization and the juvenile 

correctional institutions with the highest prevalence, the Panel recognizes that the institutions 

that it selected for study all have unique, distinguishing characteristics. Ft. Bellefontaine, with 

only twenty-four beds, is a comparatively small institution. The RITS and Corsicana have 

undergone significant transitions since the time of the BJS survey. In the last year, the RITS has 

reorganized its programs and has moved to three smaller facilities, two of them recently 

constructed. The RITS is also unique in that unlike most states, Rhode Island does not have 

juvenile correctional institutions at the county level, so the juvenile justice system operates 

exclusively at the state level. In the last two years, in the wake of a devastating scandal, 

Corsicana, along with the rest of the TYC, has been implementing significant legislative reform 

to address many of the problems that the BJS Juvenile Report identified. In addition, Corsicana 

is the only institution among the five selected juvenile facilities that exclusively serves a 

mentally ill and developmentally delayed population. Pendleton is unique among the five in that 

it serves only maximum security residents. Woodland Hills is unique in that it is the only 

institution that questions the accuracy of the BJS Juvenile Report in finding a high prevalence of 

sexual victimization at the facility. Some might suggest that the populations of the five selected 

juvenile facilities may differ so significantly (i.e., medium security residents at Ft. Bellefontaine, 

maximum security residents at Pendleton, and mentally ill residents at Corsicana) that comparing 

these institutions may not be particularly helpful. The Panel notes these distinctions (as well as 

anticipated concerns) and is aware that, at least in some instances, the unique characteristics of 

each institution may partially explain its appearance in the BJS Juvenile Report. 

Policies and Practices May Not Predict Outcomes 

In reviewing the facilities’ responses to the Panel’s Data Request, the Panel discovered that some 

widely accepted recommended practices did not necessarily correspond with an institution’s 

incidence of sexual victimization. For example, Ft. Bellefontaine does not have a PREA 

coordinator, a written PREA-specific policy, an orientation on sexual victimization for residents, 

or specific policies on dealing with the aftermath of sexual assault.309 Yet, despite these lacunae, 

                                                           

308 Id., C. Love, 452:20-453:16. 309 App. C 2 (Ft. Bellefontaine responses to Questions 2(a) and 3). 
33

the BJS Juvenile Report identified Ft. Bellefontaine as having no incidents of sexual 

victimization in the time period under review.310 311

In contrast, among the five selected facilities, Pendleton had one of the most thorough, 

documented procedures for investigating allegations of sexual abuse;312 yet the strength of the 

investigative procedures did not prevent Pendleton from having, according to the BJS Juvenile 

Report, a relatively high number of reported incidents.313 

The Selected Facilities Differ on the Causes of and Effective Prevention Methods for 

Sexual Victimization 

The Panel heard discrepancies in the experiences of the facilities. For example, Pendleton 

attributed the high incidence of sexual victimization at its facility, at least in part, to 

overcrowding and staff shortages, whereas Woodland Hills, which also had a high prevalence of 

sexual victimization, was operating under capacity with an adequate number of employees. Ft. 

Bellefontaine, which did not rely on cameras for security, had no reported incidents of sexual 

victimization, whereas Corsicana, which has hundreds of cameras, reports a significant number 

of allegations of sexual victimization each month. 

The Small Number of Reviewed Facilities Limits Reliable Generalizations 

The Panel is mindful, given the small number of facilities that participated in the hearings, that 

its findings may not lead to reliable generalizations. Nonetheless, aware of the inherent 

limitations in its effort to identify common characteristics among the selected facilities, the Panel 

has identified common themes that emerged from the hearings that corrections administrators, 

practitioners, and researchers should consider exploring in eliminating sexual victimization in 

facilities that serve youth.

Common Themes 

   

Culture

Every administrative leader of a juvenile correctional system who testified before the Panel 

stressed the importance of institutional culture. They recognized that in the world of juvenile 

corrections, there is a spectrum of competing models, with the therapeutic-rehabilitation model 

on one end and the punitive-correction model on the other. Among the institutions that the Panel 

selected to study, Ft. Bellefontaine presents an example of the therapeutic approach, whereas 

                                                           

310 BJS Juvenile Report 5 tbl.3. 311 Similar to Ft. Bellefontaine, the RITS, a facility with a low prevalence of sexual victimization, also does not have 

a PREA-specific policy. See app. C 1 (RITS response to Question 1). 312 In the Panel’s view, Pendleton had sound investigative procedures in place, and based on the documentation of 

the investigations that Pendleton submitted to the Panel for review, Pendleton’s investigative team did a thorough, 

professional job. Id. 3, 15 (Pendleton responses to Questions 3 and 13). 313 BJS Juvenile Report 7 tbl.4. 
34

Pendleton presents, at least until the recent past, an example of the punitive approach. 

Regardless of how they may characterize their own institutions, all of the administrators who 

presented testimony to the Panel said that they valued a therapeutic culture, and they were either 

already committed to one or were taking steps to achieve one. All of the administrative leaders 

who testified also underscored the significance of differentiating juvenile correctional systems 

from their adult counterparts. Youth who are in custody are still in development, and institutions 

that serve young people well have programs and staff that take youth development into account. 

Another aspect of institutional culture on which all testifying officials agreed is that it is 

important to return youth offenders as quickly as possible to their communities and to work with 

families and community-based organizations to plan for successful reentry. The consensus 

among the leaders of juvenile correctional institutions, a consensus that the Panel supports, is 

that in creating safe institutions that are free of sexual abuse, juvenile correctional systems 

should promote a therapeutic culture, promoting programming that focuses on rehabilitation and 

engages families in planning for a youth offender’s successful transition back to the community. 

Staff Training 

All of the institutions that appeared at the Panel hearings agreed on the importance of providing 

staff training. Many of them have already instituted training programs for their staffs on the 

importance of maintaining professional boundaries in youth correctional settings. The training 

programs often identify early indicators, called “red flags” or “slippery slopes,” that should put 

staff members on notice that either they or one of their colleagues may be in danger of crossing a 

professional boundary that could lead to an inappropriate relationship with a youth. Some of the 

training programs include quite a long list of examples; among them are bringing presents to a 

youth, sharing personal information with a youth, treating a youth more favorably in comparison 

to others, and spending time with a youth beyond regular duty hours. Many institutions also 

noted that when female staff members are experiencing difficulties in their personal lives (e.g., 

divorce or other loss), they may be especially vulnerable to developing inappropriate 

relationships with male youth offenders. Again, the consensus among the juvenile corrections 

administrators who appeared at the Panel hearings, which the Panel also endorses, is that 

providing effective training to staff, especially female staff, on recognizing behavior that risks 

crossing a professional boundary would strengthen prevention of staff-on-juvenile sexual 

misconduct. 

Facility Size 

The Panel recognizes that some juvenile justice systems in the country may acknowledge Ft. 

Bellefontaine’s positive record but dismiss it as a replicable model because it serves only twentyfour residents. In contrast, Pendleton has well over two hundred. Juvenile justice systems 

dealing with budget constraints and existing large physical plants may view emulating Ft. 

Bellefontaine’s approach to juvenile corrections as impractical. According to Missouri DYS, the 
35

size of Ft. Bellefontaine is a deliberate organizational decision; no facility in the Missouri system 

has more than fifty beds.314 Although the Panel is aware of the financial, political, and 

institutional pressures that may prevent states from following Missouri’s example, many of the 

administrators of juvenile correctional facilities who presented testimony at the Panel’s hearings 

recognized the importance of placing youths in small facilities close to their homes.315 

Consistent with the views of the administrators who testified at the Panel hearings, the Panel 

encourages state juvenile correctional systems to consider adopting the strategic goal, perhaps as 

part of a long-term plan, of placing youth offenders in smaller facilities. 

Unresolved Institutional Questions that Warrant Further Study 

In reviewing carefully the testimony from the hearings and the facilities’ response to the Data 

Request, the Panel has identified the following questions that merit further study. 

What are the factors that lead female staff to become involved emotionally or 

sexually with male juveniles? 

One of the most striking outcomes of the BJS Juvenile Report is its identification of the relatively 

high incidence of female staff having inappropriate sexual encounters with male youth 

offenders.316 Without further study of this phenomenon, juvenile correction administrators 

speculate on the underlying dynamics that led to this result. In the absence of additional 

research, the Panel has heard two competing narratives that try to make sense of the data. One 

narrative is that sophisticated older youth manipulate young, vulnerable female staff into 

emotional relationships that evolve into sexual ones. The other narrative is that female staff 

members who are unable for a variety of reasons to build satisfying personal relationships with 

men gravitate, by design or by default, to juvenile facilities, where they find young men who are 

only too ready under the circumstances to enter into relationships with them that have a sexual 

component. Only additional research would show whether either of these competing narratives 

has any merit. Designing prevention strategies and providing effective staff training depend on 

solid research that sheds light on the underlying dynamics of the sexual encounters between 

female staff and male youth offenders. 

What is the most effective training to encourage healthy professional boundaries? 

Some of the administrators of the facilities that the Panel selected for study provided information 

on the training programs that they have developed for promoting healthy staff-youth professional 

boundaries. The Panel encourages research on the effectiveness of various training programs in 

                                                           

314 Tr., T. Decker, 104:2-3. 315 See also BJS Juvenile Report 10 tbl.7. In noting the correlation between small facility size and the low incidence 

of sexual victimization, the Panel recognizes that large facilities might achieve similar positive results by providing 

services to youth in small programmatic units. 

316 Id. 13 & tbl.11. 
36

creating institutional cultures that achieve healthy staff-youth professional boundaries. The 

Panel encourages the development of validated training models and materials that juvenile 

justice facilities throughout the country could use in preventing inappropriate relationships 

between staff, especially female staff, and youth offenders in custody. 

What are the best practices for maintaining the appropriate professional boundaries 

between staff and juvenile offenders? 

Although training must certainly be one of the key elements in maintaining appropriate 

professional boundaries between staff and juvenile offenders, there is a need for research on 

what additional practices are effective in creating healthy staff-youth relationships. How do 

juvenile correctional agencies build professional communities that allow supervisors and 

colleagues to intervene effectively when they recognize an early indicator that a staff person 

risks violating a professional boundary? Are there staffing practices (e.g., periodic rotations, 

reassignment requests, peer support groups) that prevent inappropriate relationships while not 

damaging the positive relationships that staff and youth may have that promote rehabilitation? 

The Panel encourages research that would produce a compendium of good management practices 

that support healthy, professional, staff-youth relationships. 

How can institutions better screen staff to avoid sexual misconduct? 

Despite administering standard background tests and employing other screening procedures, 

Pendleton administrators were at a loss in finding a reliable way to identify prospective staff 

members who might have a propensity to enter into inappropriate relationships with youth 

offenders.317 The Panel encourages research that identifies the most effective screening tools for 

identifying applicants for positions in juvenile justice facilities who may be at risk for crossing 

professional boundaries. If the tools already exist, then the Panel encourages validation studies 

that show the correlation between the testing procedures and the reduction of inappropriate staffyouth conduct. If the tools do not exist, then the Panel encourages research on developing 

screening protocols that would assist juvenile justice facilities in identifying applicants who may 

stray from their duty to keep the youth they serve safe. 

For youth in custody, what are the common characteristics of victims and 

perpetrators of sexual victimization? 

Although the Panel heard some testimony on factors that may characterize victims and 

perpetrators of sexual victimization in juvenile correctional facilities, the information was 

incomplete.318 In reflecting on the characteristics of juvenile victims of sexual abuse, a 

Pendleton administrator noted that the longer young people are in the juvenile correctional 

                                                           

317 See supra note 193. 318 The BJS Juvenile Report provides some information on the characteristics of victims and perpetrators. BJS 

Juvenile Report 10-13 & tbls.8, 9, 11 & 12; see supra pp. 2-3. 
37

system, the more likely they are to become victims.319 A Corsicana administrator, conceding 

that there were no reliable data, nonetheless posited that there are “themes” related to victims, 

including that they are often younger, have a history of trauma or gender identity issues, and may 

be hyper-sexualized.320 Noting also the absence of reliable data regarding perpetrators, another 

Texas administrator observed that when a female staff person becomes involved in an 

inappropriate relationship with a resident, she is often struggling with self-esteem issues, 

recovering from a broken relationship, or dealing with something else in her personal life.321 

Perpetrators of juvenile sexual victimization may also, of course, be male staff members (as a 

prior BJS survey found, using a different methodology than the BJS Juvenile Report)

322 or other 

youths in custody; but the Panel did not obtain information from the selected facilities that would 

allow it to draw any conclusions about the common characteristics of either of these categories 

of perpetrators, or any others. In the absence of reliable data from the selected facilities, the 

Panel encourages researchers to study further the incidents of sexual victimization in juvenile 

facilities so as to identify additional common characteristics of victims and perpetrators. 

How can juvenile justice systems assist staff falsely accused of sexual misconduct? 

On both ethical and legal bases, the Panel acknowledges that under no circumstances is a staff 

person ever a victim when it comes to an inappropriate relationship with a youth, no matter how 

vulnerable the staff person nor how seductive the youth. Still, in a juvenile justice facility, 

allegations of sexual misconduct against a staff person can be one of the ways that a savvy youth 

can retaliate against a facility employee who conscientiously enforces institutional policies. The 

Panel is aware that staff persons may face unfounded charges. The Panel would like to 

encourage further study on how to support staff persons when these unfounded charges occur 

and whether there are institutional practices that take allegations of sexual misconduct seriously 

while also protecting an innocent staff person’s professional reputation. 

What are the factors that contribute to youth-on-youth sexual assault in juvenile 

justice facilities? 

In reviewing incident reports from juvenile facilities, the Panel noted that in some of the facilities 

with the highest prevalence of sexual victimization, there were multiple cases of youth forcing 

other youth into sexual activities. The Panel encourages research to develop a profile of a youth 

in custody who is most likely to become a sexual predator. The Panel also encourages research 

on institutional practices that prevent youth-on-youth sexual victimization. Some of the issues 

                                                           

319 Tr., M. Dempsey, 260:7-10. 320 Id., L. Cazabon-Braly, 458:8-14; id., L. Robinson, 460:2-7. 321 Id., J. Smith, 459:6-10. 322 BJS, Sexual Violence Reported by Juvenile Correctional Authorities, 2005-06 (July 2008), available at 

http://bjs.ojp.usdoj.gov/index.cfm?ty=pbdetail&iid=1218. “[M]ost perpetrators of staff misconduct were male, age 

25 to 29.” Id. 6. This report relied on data that juvenile correctional authorities reported, whereas the BJS Juvenile 

Report relied on data that juvenile offenders reported. Tr., A. Beck, 36:22-38:2, 38:5-6, 38:8-39:12. 
38

that researchers should consider include whether a youth’s history of sex crimes significantly 

predisposes the youth to predatory behavior while in custody, whether a facility’s classification 

procedures at intake can reduce sexual victimization, and whether institutional housing policies 

can successfully keep vulnerable youth safe. 

Taking into account youth development, what are healthy, realistic expectations for 

youth in managing sexual expression while in custody? 

In reviewing the BJS Juvenile Report and reading incident reports from the facilities selected for 

the hearings, the Panel is aware of the problem that many juvenile correctional systems have in 

interrupting uncoerced youth-on-youth sexual activity. Young people in custody are usually in 

the midst of significant psycho-sexual development while they are in an environment that does 

not permit any form of sexual expression. The Panel would like to encourage research from 

developmental psychologists and professionals in related disciplines that would address the issue 

of how a young person in custody deals with sexuality in a healthy way. The Panel would hope 

that this research would inform juvenile justice policies and lead to supportive programming for 

youth offenders. 

Conclusion 

    

Making sure that the youth who are entrusted to the care of the nation’s juvenile justice systems 

are safe, free of sexual victimization, is an imperative that the Panel shares not only with the 

sponsors of PREA but with all the citizenry of the United States. The BJS Juvenile Report is an 

important tool for corrections administrators because it sheds light on both the prevalence and 

dynamics of sexual victimization in juvenile facilities. Despite the sobering data in the report, 

the Panel is aware that most correctional administrators are working hard to make their facilities 

as safe as possible. The Panel also recognizes that no single policy or practice may guarantee a 

low incidence of sexual victimization. The Panel issues this Report to highlight existing and 

evolving practices and to encourage further research that will assist juvenile justice facilities 

better serve youth in custody as well as their families and communities. 

Addendum: While retaining the same citations, the Panel would like to amend the second and 

third sentences in the first full paragraph on page two of this report as follows: 

About 2.6% (700) of the total youth surveyed reported experiencing incidents involving 

other youths, whereas about 10.3% (2,730) of the total youth surveyed reported incidents that 

involved facility staff members. Approximately 2.0% (530) of the total youth surveyed reported 

an experience that involved nonconsensual acts; for the reported staff-on-youth incidents, 4.3% 

(1,150) of the total youth surveyed reported an incident that involved force and 6.4% (1,710) of 

the total youth surveyed reported an incident that did not involve force.
Appendix A 

Overview of the Juvenile Justice System in the United States 
Overview of the Juvenile Justice System in the United States 

The juvenile justice system in the United States is complex and varied. States treat juvenile 

offenders in many different ways; some feature more therapeutic rehabilitation-focused 

programs, while others operate juvenile facilities in much the same manner as adult correctional 

facilities. Despite these differences, it may be useful for placing the work of the Panel and the 

BJS Juvenile Report in context to have an understanding of the nationwide characteristics of the 

country’s juvenile justice population. 

According to the most recent available data,1

 there were 92,854 adjudicated juvenile offenders 

held in residential placements on any given day in 2007. There were an additional 12,105 

residents in these facilities on any given day; these included individuals over the age of twentyone and youth who have not yet been charged or adjudicated. Of the adjudicated youth in 

residential placements, 64,163 individuals resided in public facilities and 28,558 were held in 

private facilities. The juvenile population in these facilities is 85% male and 15% female. 

Minority youth outnumber white youth by a nearly three-to-one ratio. Most states have a greater 

proportion of juveniles held for person crimes than for property crimes (i.e., 34% being detained 

for person crimes as opposed to 25% being detained for property crimes). One third of juveniles 

remain in placement six months after admission; for offenders held for person crimes, this rate 

jumps to 45%. 

Juvenile delinquency rates have changed over the past decades. For example, the percentage of 

youth held for person offenses has increased markedly. In 1985, only 16% of youth were held 

on person crimes, but by 2006, the rate had jumped to 34%. The percentage of youth held for 

property crimes has steadily decreased over the same time frame, falling from a high of 61% in 

1985 to 24% in 2007. The total delinquency case rate increased 43% between 1985 and 1997, 

and then it declined 15% to the 2007 level. This means that the overall delinquency case rate 

was 22% higher in 2007 than in 1985. All told, in 2007, juvenile justice systems in the United 

States processed more than 1.6 million delinquency cases. 

   

                                                           

1 See Office of Juvenile Justice and Delinquency Prevention Statistical Briefing Book, 

http://www.ojjdp.gov/ojstatbb/faqs.html (last visited Sept. 23, 2010); National Center for Juvenile Justice, Juvenile 

Court Statistics 2006-2007 (Mar. 2010) (Charles Puzzanchera et al.), available at

http://ww.ncjjservehttp.org/ncjjwebsite/pdf/jcsreports/jcs2007.pdf. 
Appendix B 

Data Request (Mar. 31, 2010)

   
March 31, 2010 

VIA ELECTRONIC MAIL AND 

FEDERAL EXPRESS

[Name] 

[Title] 

[Facility] 

[Address] 

Re: Juvenile Facility Hearings of Review Panel on Prison Rape

Dear [Name]: 

As you know, the Bureau of Justice Statistics (BJS) at the United States Department of Justice 

recently issued the report Sexual Victimization in Juvenile Facilities Reported by Youth, 2008-09, 

which identified the [facility] as having among the [highest/lowest] prevalence of sexual 

victimization. In response to that report, the Review Panel on Prison Rape (Panel) has selected 

the [facility] to participate in a hearing at [time] on [date] at the following location: Main 

Conference Room, Third Floor, Office of Justice Programs; 810 7th Street, N.W.; Washington, 

DC 20531. 

In anticipation of that upcoming hearing, we have enclosed pertinent document and data 

requests. To prepare for the hearing, we would appreciate receiving responsive documents and 

information no later than May 1, 2010. Please submit the requested information (an original 

and four copies) to the following address: 

Christopher P. Zubowicz, Attorney Advisor 

Review Panel on Prison Rape, Office of Justice Programs 

U.S. Department of Justice 

810 7th Street, N.W. 

Washington, DC 20531 

We often experience substantial delays in the delivery of regular mail as a consequence of 

security precautions. Therefore, we recommend that the [facility] send its response to the Panel 

via a private, overnight mail delivery service. If the [facility] sends its response by an overnight 

courier, the zip code in the above address should be changed to 20001. 

We also have enclosed a list of witnesses whom we would ask you to identify by name and make 

available for sworn testimony at the hearing. In connection with your oral testimony, the Panel 

encourages you to submit brief written testimony in response to the BJS’s finding that the 
[Name, Title] 

March 31, 2010 

Page 2 

[facility] has a [high/low] prevalence of sexual victimization to Mr. Zubowicz no later than May 

21, 2010. The Panel also may identify additional witnesses as it reviews the facility’s responsive 

documents and information and prepares for the hearing. The Panel will cover all reasonable 

costs that invited witnesses may incur in traveling to the hearing. 

We will contact you again shortly to make travel and other arrangements related to the hearing. 

Sincerely, 

Michael L. Alston 

Attorney Advisor 

Enclosure
1 

Requested Documents and Data 

Pursuant to section 4(b)(3)(C) of the Prison Rape Elimination Act (PREA) of 2003, Public Law 

108-79, 117 Stat. 972 (codified, as amended, at 42 U.S.C. §§ 15601-15609 (2006)), the Review 

Panel on Prison Rape (Panel) requests that the (name of agency) produce the information 

itemized below regarding the (name of institution) on or before May 1, 2010. In preparing the 

response to the document and data request (please submit an original and four copies), restate 

each numbered question in full before providing a complete, written answer or supplying the 

requested documentation. Please organize and label all produced documents to correspond with 

the numbered questions and, if applicable, their subparts. However, it is not necessary to 

produce more than one copy of any particular document. The request for information is an 

ongoing one. Until the date of your hearing before the Panel, we ask the (name of agency) to 

update its responses to the document and data request as appropriate. 

Policy 

1. Please provide copies of any relevant state or local laws, internal memoranda, general 

orders, policy manuals, standard operating procedures, or other documents, any of which 

applied to allegations of sexual abuse1 at the (name of institution) from January 1, 2008, 

through April 30, 2009. 

2. For the period of time from January 1, 2008, through April 30, 2009: (a) please state 

which staff person was responsible for coordinating administrative efforts to eliminate 

sexual abuse at the (name of institution) in conformity with the goals of PREA; and 

(b) please provide the name and title of the PREA coordinator for the (name of 

institution). 

3. Please provide the document setting forth the (name of institution)’s standard operating 

procedures from January 1, 2008, through April 30, 2009, for investigating allegations of 

sexual abuse, noting in particular any differences in investigating SOJ, VOJ, JOJ, JOS, 

and JOV allegations. See supra note 1. 

4. For the period of time from January 1, 2008, through April 30, 2009: (a) please provide 

the document setting forth the (name of institution)’s standard operating procedures for 

the use of cross-gender supervision/observation and searches; and (b) describe the extent 

to which the (name of institution) had any gender-based bona fide occupational 

qualifications for certain posts. 

5. Please provide information describing your security classification and housing 

assignment process. 

                                                           

1 For this document and data request: the term “sexual abuse” includes staff‐on‐juvenile (SOJ), volunteer‐on‐

juvenile (VOJ), juvenile‐on‐juvenile (JOJ), juvenile‐on‐staff (JOS), and juvenile‐on‐volunteer (JOV) sexual assault;

“inmate” is a youthful offender who is incarcerated in a juvenile detention facility or a state training school.
2 

Operations 

6. Please provide the average age of offenders at the (name of institution) and the age range 

of offenders at the (name of institution). 

7. Please describe your facility’s relationship with external organizations related to 

responding to allegations of sexual assault or inappropriate conduct and provide copies of 

any formal Memoranda of Understanding (MOUs) that (a) were in place from January 1, 

2008, through April 30, 2009, and (b) are currently in place (e.g., with hospitals, medical 

centers, mental health services, training organizations, and victims services). 

8. For the period of time from January 1, 2008, through April 30, 2009, how many 

juveniles, while housed at the (name of institution), (a) committed suicide, (b) attempted 

suicide, (c) were homicide victims, (d) were victims of attempted homicide, (e) were 

diagnosed as mentally ill, (f) were alcohol and other drug abusers, and (g) were sexually 

abused prior to being institutionalized (if known)? 

Human Resources 

9. (a) What are the minimum qualifications for custody staff (e.g., age, education, and prior 

criminal record)? (b) Describe the background screening process for applicants and 

employees in custody staff positions. (c) What is the turnover rate for custody and 

program staff? 

10. For the period of time from January 1, 2008, through April 30, 2009, (a) how many of the 

custody staff and program staff were terminated from employment for sexually-related 

inappropriate conduct or sexually-related criminal behavior?; (b) how many custody staff 

and program staff were allowed to resign for similar conduct or behavior?; and (c) if 

available, how many custody staff and program staff were reprimanded or warned about 

similar conduct or behavior? 

11. Please state the overall, average daily ratio of sworn staff to juveniles at (name of 

institution) from January 1, 2008, through April 30, 2009 (provide one average daily ratio 

in response to this request; do not provide separate daily ratio figures for each day during 

the designated time period). 

Investigations 

12. For the period of time from January 1, 2008, through April 30, 2009, please describe all 

of the ways that a youthful offender could report an allegation of sexual abuse at (name 

of institution). 

13. Please provide a complete copy of the investigative record involving all allegations of 

sexual abuse at the (name of institution) that occurred from January 1, 2008, through 

April 30, 2009, including the identity of the alleged victim and alleged perpetrator(s). 
3 

14. Please provide copies of all incident reports that refer to alleged sexual abuse (SOJ, VOJ, 

JOJ, JOS, and JOV) at the (name of institution) from January 1, 2008, through April 30, 

2009 (the Panel solely seeks documents that have not been produced in response to 

another request). 

15. Please provide copies of any disciplinary records showing actions taken against staff, 

volunteers, or youthful offenders at the (name of institution) from January 1, 2008, 

through April 30, 2009, involving allegations of sexual abuse or sexually-related 

inappropriate behaviors (the Panel solely seeks documents that have not been produced in 

response to another request). Please separate into categories of SOJ, VOJ, JOJ, JOS, and 

JOV. 

16. (a) Please provide copies of complaints filed by juveniles or on behalf of juveniles from 

January 1, 2008, through April 30, 2009, whether formal or informal, alleging sexual 

abuse at the (name of institution); and include the disposition or resolution (the Panel 

solely seeks documents that have not been produced in response to another request). 

17. (a) Please describe the qualifications and experience that staff members must have to 

investigate allegations of sexual abuse at the (name of institution). (b) What is the 

selection process at the (name of institution) for these staff and how are they trained? 

(c) What is the investigator’s relationship with external resources such as law 

enforcement, medical facilities, and prosecutors? 

18. (a) Has there been any litigation brought against the (name of institution) involving 

sexual abuse during the last five years? (b) If so, please provide a brief description of the 

litigation and any settlement/court actions. 

Orientation and Training 

19. Please describe (a) the staff training process from orientation through in-service sessions, 

(b) any specific training related to inappropriate relationships or behaviors, (c) any 

specific training on how to deal with youthful offenders who solicit inappropriate 

relationships, (d) the training received about reporting sexual misbehavior and any abuse 

reporting requirements, (e) training on investigative procedures, (f) training for the (name 

of institution)’s medical staff on intervention and treatment, (g) training of counseling 

and/or other program staff on sexual abuse/inappropriate relationships related to 

treatment and casework planning, and (h) any training related to “red flags” for 

supervisors or managers in all phases of the operation (e.g., custody area; education area; 

work experience areas; and volunteer, contract, and mentoring activities). 

20. (a) For the period of time from January 1, 2008, through April 30, 2009, please detail the 

processes of how the (name of institution) informed youthful offenders about the 

potential danger of sexual abuse and sexual misconduct, the procedures for reporting 

threats of sexual abuse, and the procedures for reporting allegations of sexual abuse. 

(b) Please detail how the (name of institution) presently informs youthful offenders about 

the potential danger of sexual abuse and sexual misconduct, the procedures for reporting 
4 

threats of sexual abuse, and the procedures for reporting allegations of sexual abuse. 

(c) Please provide samples of instructional materials that the (name of institution) (i) used 

from January 1, 2008, through April 30, 2009, and (ii) uses presently to inform juveniles 

about how they could prevent or report sexual abuse. 

Requested Witnesses 

The Panel requests that the (name of agency) make available for sworn testimony the following 

individuals: 

1. (name of agency) Director _______________; 

2. (name of institution) Superintendent ______________; 

3. (name of institution) PREA Coordinator; 

4. (name of institution) Internal Affairs Manager who heads investigations; and 

5. Others who the Director and/or Superintendent recommend and who are approved to 

attend by the Panel. 

The Panel may also request the appearance of individuals referenced in the documents requested 

above. 

Future Actions 

The Panel is very interested in knowing what actions the Department and/or Institution have 

taken to address deficiencies or to build on the strengths identified in the report Sexual 

Victimization in Juvenile Facilities Reported by Youth, 2008-09 (Study). 

1. Please provide a list of actions taken since the Study results were released to eliminate 

sexual assault, sexual abuse, or sexually-related inappropriate relationships between 

juvenile offenders, between juvenile offenders and staff, or between staff and juvenile 

offenders. Please provide copies of any newly developed materials or training 

information that could be used as guidance on this subject. 

2. Please provide the Panel with any recommendations for other program operators either to 

avoid future sexual assault, sexual abuse, or inappropriate relationships in juvenile 

facilities or to implement successful approaches. 
Appendix C 

Side-by-Side Matrix of Juvenile Facility Responses to 

Review Panel on Prison Rape Data Requests (June 2, 2010)
1

Side-By-Side Data Matrix of Juvenile Facility Responses to Review Panel on Prison Rape 

(matrix created by Creative Corrections, LLC) 

 Missouri Rhode Island Indiana Tennessee 

Policy Missouri Division of 

Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS)

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF)

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center

1) Provide relevant state or local laws, internal memoranda, general orders, policy manuals, standard operating procedures, or other documents, any of which applied to allegations of sexual abuse from January 1, 2008 through April 30, 2009. 

State statutes were provided relative to reporting and investigating child abuse and neglect, but laws for juvenile correctional facilities were vague. No local PREA policies were provided. Respondent states no allegations of sexual abuse during this period, and further states policy requests should be considered “nonapplicable.”

State statutes were provided relative to reporting and investigating child abuse and neglect. Sexual abuse of a “child by another child” is specifically referenced as a “criteria for Child Protective Services (CPS) investigation.” No specific references to PREA policy or policy specific to RITS were provided. Some confusion was evident as RITS was 

State statute and DYS policies clearly outline procedures regarding sexual assault or violence prevention and reporting, including specific PREA policies. See Policy and Administrative Procedures, July 1, 2005 and October 1, 2009. See policy entitled the Operation of the Office of Internal Affairs for DOC for specific 

State statute and DJJ policies and procedures are comprehensive and clear regarding reporting and investigating child abuse and neglect. No PREA policies were provided.
2

Policy Missouri Division of 

Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS)

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF)

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center

excluded from some abuse reporting procedures (DCYF policy Statute 500.0060) without documentation of how RITS cases would be specifically reported. 

information. 

2 (a) Staff person(s) responsible for coordinating administrative efforts to eliminate sexual abuse in conformance with the goals of PREA from January 1, 2008 through April 30, 2009. 

None locally. PREA coordination is provided from Central Office and 5 geographic regions. 

Superintendent, Deputy Superintendents, School Principal, Clinical Director. 

Executive Director of Research and Planning. 

Superintendent Albert Dawson. 

2 (b) Name(s) and title(s) of PREA Coordinator

No response Charles Golembeske 

Jr., Ph.D. 

Amanda Copeland; Christine Blessinger (Jan. 2008 – April 2008); and Timothy Greathouse (April 2008 – April 2009) 

Superintendent Albert Dawson 
3

Policy Missouri Division of 

Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS)

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF)

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center

3) Documentation and procedures for investigating allegations of sexual abuse with differences noted in investigating SOJ, VOJ, JOJ, JOS, and JOV allegations from January 1, 2008 through April 30, 2009. 

All allegations investigated by internal agencies, governed by policies. (A sexual assault is considered a critical incident for reporting within 24 hours to Regional Office). Law Enforcement officials are notified, with option to investigate. No PREA investigation guidelines or policy was provided. 

Allegations are investigated, including employee rights, but reporting requirements confusing as to how RITS alleged abuse cases are to be reported. (Although CPS is a separate division of DCYF, it is responsible for investigating abuse complaints). No specific reference to JOS or JOV incidents of abuse was given. SOJ, VOJ, and JOJ incidents are generically referenced in statute and policy. 

All allegations are guided by strong and clear policy and investigated by the Office of Internal Affairs which coordinates all efforts with local and state authorities. No direct references to PREA investigation guidelines were provided but current policies are comprehensive and coordinated. 

All procedures for investigating allegations are clearly written; allegations are investigated by either the Office of Internal Affairs or Child Protective Services (CPS), Special Investigations Unit (SIU). 

4 (a) Provide operating procedures for cross-gender supervision, observation, searches from January 1, 2008 

Respondent states awareness supervision reduces necessity for body searches. If required, pat 

Procedures provide for posting at least 1 staff person of the same gender of the residents in each unit on each shift. 

Documentation on searches and shakedowns was thorough. It stated at least one person of same gender as 

Documentation ofsearches was thorough, including references to parallel American Correctional 
4

Policy Missouri Division of 

Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS)

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF)

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center

through April 30, 2009. 

searches only are conducted by at least 2 employees, preferably one of same gender. 

resident conducts searches. Facility also provided a staff development training module on the “Making a Change Academy.” 

Association Standards. See Policy and Procedures Manual, Search procedures, 27.19, page 7, f.2, g.2.a. 

4 (b) Extent of gender-based bona fide occupational qualifications for certain posts

There was no response to question regarding crossgender supervision ratios or BFOQ’s. 

Gender-based bona fide occupational qualifications for certain posts are not specified. 

The facility stated that it “does not have any genderbased bona fide occupational qualifications for certain posts...” It “makes every effort to assign male staff to certain posts such as shower or restroom areas.” 

Response was “there were not State of Tennessee, Department of Human Resources interpretations regarding genderbased job descriptions.” 

5) Description of security classification

According to policy, Fort Bellefontaine Campus is considered “moderately secure.” A number of 

Youth are screened and assessed for mental health by the Massachusetts Youth Screening Instrument (MAYSI II), and 

Security classification policies and procedures are comprehensive and clear. The use of 

Security classification policies and procedures were comprehensive and clear. Review 
5

Policy Missouri Division of 

Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS)

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF)

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center

assessment forms are completed at intake to determine placement among various facilities. Bed assignment is unclear. 

individual needs by Global Appraisal of Individual Needs (GAIN). Specialized Treatment Unit staff classifies youth separately for aggression and sexual offending for assignment to the Specialized Treatment Unit. 

assessment instruments is a helpful objective tool in this secure correctional facility to allow classification of all, including high-risk and PREA predator, offenders. 

found no assessment instruments used to classify offenders for security reasons. 

Housing assignment process

Placement per institution is based upon intake documents. No documentation was provided regarding housing assignment process other than by facility criteria. 

Housing assignments are based on structured decision making instruments allowing for secure or nonsecure placement and male detainees step down to the Transition Program. Transition for females was not referenced. 

Policy and Procedure Manual lists extensive housing assignments and options, including “PREA considerations.” 

A psychosexual evaluation is completed on all youth with sexual offender charges. 
6

Operations Missouri Division of 

Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS) 

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF) 

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center 

6) Average age of offenders from January 1, 2008 through April 30, 2009.Age range 

15.4 years 13-17 years 

Boys-17.3 years Girls-17.0 years 13-20 years

16 years 12-19 years 

16 years 14-18 years

7) Relationship with external organizations for responding to allegations of sexual assault or inappropriate conduct.

Respondent reports it is fully integrated into state and local services and with the State Technical Assistance Team. 

The CPS unit of DCYF is responsible for conducting investigations at RITS but reporting requirements are confusing. Reporting requirements are clear for all other child care circumstances. 

Facility has extensive list of partner agencies with whom it interacts, such as the National Alliance on Mental Health and the private, nonprofit Indiana Juvenile Justice Task Force, Inc. 

Facility reports close relationship with Vanderbilt University for responding to assessment and treatment of allegations of sexual assault and inappropriate behavior. 
7

Operations Missouri Division of 

Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS) 

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF) 

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center 

Copies of Memoranda of Understanding (MOUs) duringreporting period 

Health care services are provided through Medicaid-reimbursed services.

There were no copies of MOUs available to review. However, Lifespan, a statewide health organization and hospital, provides services for RITS residents. Lifespan is experienced in treating sexual abuse victims and convenes Multidiscipline Child Protection Teams to discuss RITS incidents of sexual abuse. 

There were no MOUs available to review. 

Health care and some mental health services are provided by Vanderbilt University through a contract for services. MOUs were in place during period with the Disability and Law Advocacy, Inc.; and Metropolitan Hospital for comprehensive health and mental health services as a result of allegations of sexual abuse, sexual assault, or inappropriate behavior.
8

Operations Missouri Division of 

Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS) 

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF) 

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center 

MOUs currently in 

place (e.g., with hospitals, medical centers, mental health services, training organizations, and victims services).

There were no MOUs with other agencies regarding allegations of sexual assault or inappropriate conduct.

There were no copies of MOUs available to review. 

There were no MOUs available to review. 

These services are currently in place.
9

Human Resources Missouri Division of 

Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS) 

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF) 

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center 

8 (a) Number of suicides while housed 

0 0 1 0 

8 (b) Attempted suicide 

0 1 32 3 

8 (c) Homicide victims 

0 Rhode Island does 

not track this data. 

0 0 

8 (d) Victims of Attempted Homicide 

0 Rhode Island does 

not track this data. 

0 0 

8 (e) Diagnosed as Mentally Ill 

32.1% Medications: 15.5% 

males; 30% females Diagnosed with anxiety or mood disorders: 30% males; 32% females 

111-118 (Criteria used were psychosis or depression). 

138 

8 (f) Previously abused drugs and alcohol 

45.3% 76.4% males; 69.2% 

females 

226 (Criteria used were weekly use of drugs and/or alcohol). 

65 

8 (g) Previous sexual abuse

Unknown 5.5% males 

23.1% females 

60 Unknown 

9 (a) Minimum qualifications (custody staff) 

Entry level Specialist 60 college hours w/ 6 hours in discipline orhigh school diploma 

Associates Degree in Behavioral Science or Social Work 

Three years’ work experience, high school diploma or G.E.D. A.A. degree 

Education and experience equivalent to high school degree 
10

Human Resources Missouri Division of 

Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS) 

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF) 

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center 

or GED, and experience in direct care interaction with youth. 

and/or relevant experience in clinical/correctional environment. 

may substitute for work experience only, 21 years of age, background investigation, completion of Correctional Training Institute. 

9 (b) Background screening process for applicants and employees (custody staff) 

Employment history; professional certifications and education; fingerprint checks; child care and foster parent licensing records; Department of Mental Health Employee Disqualification Registry; Department of Health and Senior Services Disqualification list; 

Background screening and criminal record checks are conducted under DCYF Policy 900.0040 and Federal Law. Also, DCYF Policy 700.0105 is followed for Clearance of Agency Activity required by Adam 

Employees must have criminal history check, fingerprint check, sex offender registry, CPS screening, and drug screen. 

Employees must have a criminal history and CPS records check. They must undergo health and substance abuse registry clearance, felony and sexual offender registry clearance. 
11

Human Resources Missouri Division of 

Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS) 

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF) 

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center 

Family Care Safety Registry; Registry for Adult Neglect/Exploitation; Claims Accounting Restitution System for debts owed to the State; Driver’s license status. 

Walsh Federal Act to check abuse/neglect registry prior to employment.

9 (c) Turnover rate: Custody Staff Program Staff 

21.9% for all job title classes 

Turnover was under 5% for all custody staff, which is mostly related to promotion. Program staff turnover not recorded separately. 

Custody Staff – 46% Program Staff – 19% 

Custody and treatment staff – 27%Program staff – 18.5% 

10 (a) Employment terminations during reporting period for inappropriate conduct or sexually-related criminal behavior: 
12

Human Resources Missouri Division of 

Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS) 

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF) 

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center 

Custody Staff Program Staff 

0 0 

0 0

3 1 

0 0 

10 (b) Allowed resignations for same conduct: Custody Staff Program Staff 

0 0 

0 0

1 0 

2 0

10 (c) Reprimanded or warned for similar conduct or behavior: Custody Staff Program Staff

0 0 

One incident of custody staff sexual harassment of another employee was handled through counseling. 0 

1 0 

One staff failed to report allegation. He investigated it himself and found it unproven. Upon learning about this incident, facility administrator investigated allegation and also found it to be 
13

Human Resources Missouri Division of 

Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS) 

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF) 

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center unproven. However, the employee was reprimanded for not following proper reporting procedure. 

11) Staff to juvenile ratio for reporting period-average daily sworn staff to juvenile ratio 

8:00 a.m. – Midnight: 1:6; Midnight – 8:00 a.m.: 1:8; Additional staff present during regular business hours. 

Juvenile Program Workers: 1:8; Unit Managers: 1:24; Clinical Social Workers: 1:24; Educational Staff: 35; Nurses: 3 employed and on duty from 7:00 a.m. to 11:00 p.m. Ratio of employees by category on per-shift basis was not reported. 

1:3 There was no delineation between the three shifts. 

1:5 
14

Investigations Missouri Division 

of Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS 

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF) 

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center 

TCCTC

12) For reporting period, methods by which a youthful offender could report allegation of sexual abuse 

Grievance; Personal Advocate; Group Leader; Facility Manager; Nurse; Teacher; Trusted Adult including Parents; Service Coordinator; Volunteers; All DYS staff. 

There is immediate access to telephone to report abuse. Family Service Unit Worker and Probation Counselor visit facility. Office of the Child Advocate office is located at RITS. There is a Master for the Federal Court and attorney for the plaintiffs. See Rhode Island case entitled Inmates of the Boys Training School v. Patricia Martinez, C.A. no. 4529. Unit Managers, Administrators, Nurses at sick call, Private clinical, vocational and educational providers and parents/guardians can be accessed to report allegation. 

The “Pound 22 System” exists at this facility. This system allows juveniles to use any telephone and dial #22 to report sexual abuse, misconduct or threats. A grievance process is in place at every facility for juveniles not comfortable in using the “Pound 22 System.” Juveniles who cannot talk with staff can tell parents or guardians who can report allegations to the facility on behalf of the youth. 

Youthful offenders could report allegations to case manager, medical staff, Family Service worker, contract therapist, family, any staff member, or the attorney on site. An offender can report through the grievance procedure form, upon which CPS is notified. When CPS begins its investigation, that official contacts the Security Manager and Superintendent to ensure there is no contact between those involved in the allegation. 

TtICkhcmGR
15

Investigations Missouri Division 

of Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS 

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF) 

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center 

TCCTC

13) Complete copy of Investigative Record involving all allegations of sexual abuse for reporting period to include identities of alleged victim and alleged perpetrator(s) 

No allegations were reported 

One report of child-onchild sexual abuse (oral sex by fear or intimidation) was reported and complete report was reviewed and appears comprehensive. 

Copies of Investigative Records were reviewed and all were clear, comprehensive and contained allegations, dispositions, and names of perpetrators and victims. 

Copies of Investigative Records were reviewed and all were clear, comprehensive and contained allegations, dispositions, and names of perpetrators and victims.

R

14) Copies of related Incident Reports for the reporting period 

None None except as noted in 

13 above. 

Copies of related incident reports were submitted and reviewed. 

Copies of related incident reports were submitted and reviewed. 

Tp5r0aetetriA2
16

Investigations Missouri Division 

of Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS 

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF) 

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center 

TCCTC

15) Copies of disciplinary records showing actions taken against staff, volunteers or youthful offenders for reporting period involving allegations of sexual abuse or sexually-related inappropriate behaviors: Staff on Juvenile Volunteer on Juvenile Juvenile on Juvenile Juvenile on Staff 

None 0 0 0 0 

None 0 0 In 13 above, complaint was unfounded due to lack of preponderance of evidence. 0 

Disciplinary records were provided of incidences of inappropriate sexual activity in the following manner: 0 0 6 0 

Disciplinary records were provided of incidences of inappropriate sexual activity in the following manner: 6 0 1 0 

Nrdffa0 0 0 0 
17

Investigations Missouri Division 

of Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS 

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF) 

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center 

TCCTC

Juvenile on Volunteer 

0 0 0 0 0 

16) Copies of complaints filed by juveniles or on behalf of juveniles for the reporting period Formal Informal Disposition or Resolution 

None 0 0 0 

One report of child on child sexual abuse (oral sex by fear or intimidation) was reported and complete report was reviewed and appears comprehensive. This complaint was unfounded due to lack of preponderance of evidence. 

19 complaints were received and reviewed. All were investigated initially by a facility administrator. 8 complaints were denied, 2 were resolved at an initial hearing, and 9 were referred to Internal Affairs for further investigation. 9 10 19 

There were 7 allegations during this period. Internal Affairs and CPS staff investigated these allegations. 2 cases were unfounded and 3 were not sustained. One employee was terminated, another employee resigned as the case was investigated. 7 0 7 

cCwTrOsTdcc0 
18

Investigations Missouri Division 

of Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS 

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF) 

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center 

TCCTC

17 (a) Qualifications and experience for staff authorized to investigate allegations of sexual abuse 

The Children’s Division conducts an investigation. A Child Service Worker must possess a bachelor’s degree or higher in the discipline or in Human Servicesrelated fields. 

Associates or Bachelors Degree in Criminal Justice. Experience in Law Enforcement or Social Science gained through full-time employment involving investigations or investigating experience related to law enforcement in areas primarily related to juveniles or related activities. 

The DYS employs Internal Affairs staff to investigate allegations of sexual abuse. They must possess five years’ experience, two as an investigator, a bachelor’s degree and accredited graduate training. 

A Special Investigator with Internal Affairs investigates allegations of sexual abuse. This investigator must have an undergraduate degree with at least one year of experience as a Special Investigator. Investigators are provided formal training on interviewing and interrogation evidence gathering and other training such as forensic interviewing, CPS training, and Wicklund-Zulawski Child Abuse Interview training 

C(BeJcleyeOCLdcptrAIaeeece
19

Investigations Missouri Division 

of Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS 

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF) 

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center 

TCCTC

with the TN Bureau of Investigation. 

aeimwra

17 (b) Selection processTraining Process 

Vacancies are filled using a competitive hiring process, postings, meritbased examination and certification, interview, performance test, and rating system to include background and reference checks. Training provided through Dep’t of Social Services, covering a broad range of topics including: Legal 

Vacancies are filled based on civil service requirements and posted job descriptions by Chief of CPS Unit of DCYF. See staff training process in 19 below. Chief of CPS Unit also provides several weeks of mentoring and supervision related to 

The successful candidate is selected by a panel including the facility administrator or designee, DOC administrator, a current Internal Affairs investigator, and a Human Resources representative. Training process includes graduation from the training academy with specialized training in the Reid 

Vacancies are filled based on civil service requirements and posted job descriptions by Department of Human Resources, State of TN. Training includes CPS training, forensic interviewing, Internal Affairs curriculum, regional 

VssaqpfacFsptei
20

Investigations Missouri Division 

of Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS 

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF) 

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center 

TCCTC

Aspects for Investigators, Child, Abuse/Neglect Investigation,Identification and Treatment of Child Abuse and Neglect

RITS abuse investigations. 

Technique of Interviewing and Interrogation.Sample training certificates were included in the appendices. 

training with a multidisciplinary team of district attorney, law enforcement, medical professionals. 

oAoTLOEc

17 (c) Investigator’s relationship with external resources such as: law enforcement, medical facilities, and prosecutors 

Other agencies with which this investigator interacts include: Legal Services, Office of Civil Rights, DYS. 

DCYF collaborates with law enforcement agencies, Attorney General’s Office and Lifespan health services organization described in question 7 above. 

The investigator must work closely with entities such as the State Police, local prosecutors, hospital, and social service officials, as well as parents, juvenile offenders, and facility staff. 

The relationship of the investigator with external resources between law enforcement officials, District Attorney, Child Advocacy Center staff, and the juvenile courts is defined by statute. 

fOtf

18 (a) Litigation involving sexual abuse during previous five years 

None None None None N

18 (b) Description and court action 

None None None None N
21

Orientation and Training 

Missouri Division of Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS) 

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF) 

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center 

TCCTC

19 (a) Staff training process from orientation through in-service sessions

Within first two years of employment, all DYS staff must complete at least 180 hours in Adolescent Care Treatment and 40 hours of on-the- job coaching. Forty hours of continuing professional development yearly thereafter is required. 

Core Training is provided new DCYF employees prior to and during employment, which includes signs of abuse and specifically sexual abuse. Reporting and investigative protocols are also presented. CPS workers receive cross training with staff from other divisions. All Juvenile Program Workers participate in the sixweek Training Academy. Issues related to abuse are covered in two 4-hour modules, one of which is presented by CPS staff. The other Module is presented by the Unit Manager 

All staff members begin their employment in a four-week training program, followed by a one-week training session in the Making A Change curriculum, followed by a twoweek on-the-job training period. Veteran staff receives forty hours of training per year. 

All staff members receive 40 hours of orientation before attending the TN Correction Academy for a six-week training program. All staff is required to complete 40 hours of in-service training annually at the Academy or at the facility. 

SCOchoaaNSPT
22

Orientation and Training 

Missouri Division of Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS) 

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF) 

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center 

TCCTC

of Specialized Treatment Unit, which provides sex offender treatment. The Child Welfare Institute provides follow-up training in sexual abuse and related topics. 

19 (b) Specific training related to inappropriate relationships or behaviors

Communication, Professional Boundaries, Facilitating for Change are required training.

Topics are covered in six-week Training Academy and by follow-up training through Child Welfare Institute. Specific courses were not referenced but material includes victimization, grooming behaviors, danger signs of abuse, appropriate styles of interaction, problematic behaviors and therapeutic responses. 

Specific related training includes Understanding and Working with Adolescent Sex Offenders, Supervising High Risk JuvenileOffenders, Making a Change Academyand PREA training (see Exhibit 19 2). 

Specific training includes sexual misconduct, workplace professionalism, workplace harassment, student assaults in facilities, PREA: Responding to Student Sexual Assault, the role of Internal Affairs, Ethical Anchors, and Professional Communication. 

ACeTalivv

19 (c) Specific training on how to 

Adolescent Care Treatment Workshops 

Training on these topics is covered by 

Specific training modules include 

Specific training includes managing 

SI
23

Orientation and Training 

Missouri Division of Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS) 

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF) 

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center 

TCCTC

deal with youthful offenders who solicit inappropriate relationships

are provided. Core Training, 

Training Academy and Child Welfare Institute. 

sexual misconduct in an institution. 

the manipulative student, student misconduct, and student assaults in facilities. 

CrJDUY

19 (d) Training receivedreporting sexual misbehavior and any abuse reporting requirements

All employees read and sign policies on abuse. 

This training was provided in Core Training. 

Specific training modules include sexual misconduct, misbehavior, and abuse reporting requirements in an institution. 

Specific training includes mandatory reporting laws, workplace harassment, the role of Internal Affairs, and sexual abuse and assault reporting. 

TPptwnPSo

19 (e) Training on investigative procedures

This training is provided through Department of Social Services on a range of topics including: Legal Aspects for Investigators, Child Abuse/NeglectInvestigation,

Investigative procedures were provided by CPS workers in training academy module. 

Basic training is provided all staff in general investigative procedures. However, specific sexual victimization complaints are investigated by the Office of Internal 

Investigations are conducted by Internal Affairs. They receive training on interviewing and interrogation techniques and evidence gathering. 

OcrtiSp
24

Orientation and Training 

Missouri Division of Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS) 

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF) 

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center 

TCCTC

Identification and Treatment of Child Abuse and Neglect. 

Affairs. 

19 (f) Training for facility medical staff on intervention and treatment

None was identified. Facility medical staff 

received training in ad above. No specific training for facility medical staff on intervention and treatment was noted. 

No specific training for facility medical staff on intervention and treatment was noted. 

Training for medical staff provided for review was extensive, comprehensive, and specific “in the event of a sexual assault” at the facility. 

Estpdp

19 (g) Training of counseling and/or other program staff on sexual abuse and inappropriate relationships related to treatment and casework planning

No specific response was given. 

See a-d above. Specific training 

materials in these areas were provided and reviewed. 

Specific training courses are presented for program staff that includes Sexual Abuse: Building Trusting Relationships with Families and Conducting Family Centered Assessments. 

Cprwc

19 (h) “Red Flag” training for supervisors or managers in all 

None was identified. See a-d above. 

Supervisors and managers received and trained program staff 

Specific training was outlined in the Understanding and Working with 

There is no specific training in this area. This area will be included in the 

EsaM
25

Orientation and Training 

Missouri Division of Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS) 

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF) 

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center 

TCCTC

phases of facility operations (custody, education, work areas, volunteers, contract and mentoring)

in detecting signs of sexual abuse. 

Adolescent Sexual Offenders module. 

current course development. A PREA course has been taught at the Academy since August 2007. 

SCaFpbroocs

20 (a) For the reporting period, process for informing youthful offenders about: (1) Potential danger of sexual abuse and sexual misconduct, (2) Procedures for reporting threats of sexual abuse, and (3) Procedures for reporting 

Youthful offenders were provided information about basic rights and grievance procedures. Facility reports always attempting to create a climate of safety. 

Children’s Bill of Rights for Rhode Island is posted in all living units pursuant to RI General Law 42-72-15. Risk Assessment also reviews safety and resources for reporting with residents during orientation. Daily contact with Clinical Staff and Unit Managers. Youth are encouraged to report all inappropriate 

Youthful offenders were provided information about basic rights and grievance procedures, PREA considerations and guidelines and signed a sheet following instruction. Specific training for youthful offenders on reporting incidences, threats, 

Four staff are designated to complete the intake process for newly admitted youth. During the intake process, each new resident receives a copy of the student handbook. Page 17 has a Sexual Abuse/Assault Reporting section which the resident can use in the event of abuse or assault. 

ApSSEa ptsmpIumia
26

Orientation and Training 

Missouri Division of Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS) 

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF) 

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center 

TCCTC

allegations of sexual abuse 

behavior by staff or residents. 

and allegations of sexual abuse were noted. 

This material is explained and read aloud to the resident. The resident is advised that by law all allegations of sexual or physical abuse to CPS will begin a formal investigation. 

Ze

20 (b) At the present time, process for informing youthful offenders about: (1) Potential danger of sexual abuse and sexual misconduct; (2) Procedures for reporting threats of sexual abuse; and (3) Procedures for reporting allegations of 

Facility acknowledges need to become more deliberate in establishing procedures to address these issues. 

This information is provided during GAIN Assessment tool administration at orientation. 

Youthful offenders receive training on the units of potential danger of sexual abuse and misconduct. Youthful offenders also receive training on the units and at Intake on reporting threats of sexual abuse. The facility staff emphasizes zero tolerance for any sexual abuse or misconduct. 

Same as 20(a) above. F

rpoicRCop
27

Orientation and Training 

Missouri Division of Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS) 

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF) 

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center 

TCCTC

sexual abuse.20 (c) For the reporting period, samples of instructional materials used to inform juveniles about how they could prevent or report sexual abuse 

None was provided. None was provided. Excellent materials 

are provided in Exhibit 20 1 (1). 

None was provided. N

For the present time, sample instructional materials used to inform juveniles about how they can prevent or report sexual abuse 

None was provided. None was provided. Excellent materials 

are provided in Exhibit 20 1(1). 

Excellent materials are provided in Exhibit 21, Book 2 of the Manual provided for review. 

N

Please provide a list of actions taken since the Study results were released to 

See written testimony of Tim Decker and Future Actions Summary. 

See written testimony of Patricia Martinez. 

See written testimony of Edwin Buss and Future Actions Summary. 

See written testimony of Steven Hornsby and related Future Actions Summary. 

SCsS
28

Orientation and Training 

Missouri Division of Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS) 

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF) 

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center 

TCCTC

eliminate sexual assault, sexual abuse, or sexually-related inappropriate relationships between juvenile offenders, between juvenile offenders and staff, or between staff and juvenile offenders. Please provide copies of any newly developed materials or training information that could be used as guidance on this subject.Please provide the Panel with any recommendations 

See written testimony of Tim Decker and Future Actions Summary. 

See written testimony of Patricia Martinez. 

See written testimony of Edwin Buss and Future Actions Summary. 

See written testimony of Steven Hornsby and related Future Actions 

SCsS
29

Orientation and Training 

Missouri Division of Youth Services (DYS) Fort Bellefontaine Campus 

Rhode Island Department of Children, Youth and Families (DCYF) Rhode Island Training School (RITS) 

Indiana Department of Correction, Division of Youth Services (DYS) Pendleton Juvenile Correctional Facility (PJCF) 

Department of Children’s Services, Division of Juvenile Justice (DJJ) Woodland Hills Youth Development Center 

TCCTC

for other program operators either to avoid future sexual assault, sexual abuse, or inappropriate relationships in juvenile facilities or to implement successful approaches.

Summary. 
Appendix D 

Witness List for Review Panel on Prison Rape Hearings on 

Sexual Victimization in Juvenile Correctional Facilities (June 3-4, 2010)
Review Panel on Prison Rape 

Hearings on Sexual Victimization in Juvenile Correctional Facilities 

Witness List 

June 3, 2010 

 Dr. Allen J. Beck, Bureau of Justice Statistics 

For the Fort Bellefontaine Campus, Missouri Division of Youth Services: 

 Timothy Decker, Director, Division of Youth Services 

 Donald Pokorny, Jr., St. Louis Regional Administrator, Division of Youth Services 

 Phyllis Becker, Deputy Director, Leadership Development and Quality Improvement, 

 Division of Youth Services 

For the Rhode Island Training School, Rhode Island Department of Children, Youth and 

Families: 

 Patricia Martinez, Director, Department of Children, Youth and Families 

 Kevin Aucoin, Superintendent (Acting), Rhode Island Training School 

 Stephenie Fogli-Terry, Associate Director of Child Protection/Child Welfare, Department 

 of Children, Youth and Families 

For the Pendleton Juvenile Correctional Facility, Division of Youth Services, Indiana 

Department of Correction: 

 Edwin Buss, Commissioner, Indiana Department of Correction 

 Michael Dempsey, Executive Director, Division of Youth Services, Indiana Department 

 of Correction 

 Dr. Amanda Copeland, Director of Research and Planning, Indiana Department of 

 Correction 

 Linda Commons, Superintendent, Pendleton Juvenile Correctional Facility 

 Tim Greathouse, PREA Coordinator, Pendleton Juvenile Correctional Facility 

 Chris Blessinger, Former PREA Coordinator, Pendleton Juvenile Correctional Facility 

 Mavis Grady, Internal Affairs, Pendleton Juvenile Correctional Facility 
June 4, 2010 

 Dr. Allen J. Beck, Bureau of Justice Statistics 

For the Woodland Hills Youth Development Center, Division of Juvenile Justice, Tennessee 

Department of Children’s Services: 

 Steven C. Hornsby, Deputy Commissioner, Division of Juvenile Justice, Tennessee 

 Department of Children’s Services 

 Albert Dawson, Superintendent, Woodland Hills Youth Development Center 

 Carla Aaron, Executive Director, Division of Child Safety, Tennessee Department of 

 Children’s Services 

 Patricia C. Wade, Lead Reviewer of Quality Service Review Teams, Tennessee 

 Commission on Children and Youth 

For the Corsicana Residential Treatment Center, Texas Youth Commission: 

 Cheryln K. Towsend (via telephone), Executive Director, Texas Youth Commission 

 Laura Cazabon-Braly, Superintendent, Corsicana Residential Treatment Center 

 Cris W. Love, Sr., Inspector General, Texas Youth Commission 

 Lori Robinson, Director, Specialized Treatment Services, Texas Youth Commission 

 James D. Smith, Director of Youth Services/PREA Coordinator, Texas Youth 

 Commission