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Prison Warden Attitudes
Toward Prison Rape and
Sexual Assault
Findings Since the Prison Rape
Elimination Act (PREA)
Aviva N. Moster
Elizabeth L. Jeglic
John Jay College of Criminal Justice, New York
This study examines the attitudes and beliefs of U.S. state prison wardens
toward prison rape since the implementation of the Prison Rape Elimination
Act (PREA), signed into law in 2003. PREA mandates a zero-tolerance policy
for sexual assaults within correctional systems and requires comprehensive
collection of national data on prison rape and sexual assault. Prison wardens
play a key role in the implementation and enforcement of prison policies and
it is important to assess their attitudes and beliefs toward prison rape. To date,
there has been only one study conducted that examines wardens’ attitudes
toward prison sexual assault, and it was completed before the implementation
of PREA. It found that a majority of the wardens surveyed reported that their
prison rape and sexual assault policies were considerably less effective than
staff training and increased inmate supervision. The current study replicates
the prior study in a post-PREA environment.
Keywords: prison rape; prison wardens; Prison Rape Elimination Act;
PREA
T
here is a common perception that prison rape is widespread and under-
reported (Dumond, 2003; Hensley, 2002; Hensley, Struckman-Johnson,
& Eigenberg, 2000; Hensley, Dumond, Tewksbury, & Dumond, 2002;
Hensley, Koscheski, & Tewksbury, 2003; Struckman-Johnson and Struckman-
Johnson, 2000; Struckman-Johnson, Struckman-Johnson, Rucker, Bumby,
& Donaldson, 1996; Wooden & Parker, 1982). However, there has been a
great deal of controversy about the true pervasiveness of prison rape and
sexual assault. Current findings suggest that the prevalence of male prison
The Prison Journal
Volume 89 Number 1
March 2009 65-78
© 2009 SAGE Publications
10.1177/0032885508329981
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rape ranges anywhere from 0.3% to 14.0% (Hensley, Koscheski, &
Tewksbury, 2003; Nacci & Kane, 1983). It is hypothesized that this discrep-
ancy in base rate estimations is a result of underreporting by offenders
because of shame and fear of retribution (Eigenberg, 2000; Nacci & Kane,
1983; Saum, Surratt, Inciardi, & Bennett, 1995; Struckman-Johnson et al.,
1996), the failure of authorities to identify a common definition of sexual
assault, and the misinterpretation of coerced sexual activity as being con-
sensual (Eigenberg, 2000; Hensley et al., 2002).
The Prison Rape Elimination Act (PREA)
Although rape within prison walls was identified as a problem as early
as the 1930s and 1940s (Fishman, 1934; Kinsey, Pomeroy, & Martin,
1948), only within the past decade have male prison rape and prison assault
become widely recognized by the prison system, the public, and legislators
alike (Davis, 1968; Gardner, 1986; Hensley et al., 2002; Human Rights
Watch, 2001; Nacci & Kane, 1983, 1984; Struckman-Johnson et al., 1996;
Wooden & Parker, 1982). As a result of growing concern, President George
W. Bush signed PREA (2003) into law on September 4, 2003 (Bureau of
Justice Statistics [BJS], 2004). PREA applies to all federal and state cor-
rectional and detention facilities as well as local jails, private facilities, and
police lock-ups (Stop Prisoner Rape, 2005). PREA was created to address
many issues surrounding prison rape and sexual assault. The new act man-
dates a new zero-tolerance policy for sexual assaults within correctional
systems, provides funding for research and program development, and
requires a comprehensive collection of national data on prison rape and
sexual assault. In addition, PREA created a federal commission tasked with
developing standards for addressing the problem of prison rape (BJS, 2004;
PREA, 2003; Stop Prisoner Rape, 2005).
PREA requires BJS to collect national data on the incidence and preva-
lence of sexual assault within correctional facilities. The bureau conducted
its first national study in 2004 and surveyed more than 2,700 correctional
facilities holding 79% of all adults and juveniles in custody (BJS, 2005).
This study was conducted by reviewing administrative records, a method
that BJS admits is insufficient for fully understanding the problem. In a June
2004 status report, BJS reported that it is “tasked with developing reliable
methods to measure the problem so that it can be addressed and eliminated”
(BJS, 2004, p. 1). BJS indicated that although it was unable to develop a
reliable method of measuring sexual violence for its first study, it reported
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that future data collections will be based on victim reports of sexual violence
of both current and former inmates “to permit reliable comparisons that
overcome the limitations of administrative records” (BJS, 2005, p. 1).
For the purposes of its study, BJS used the PREA Section 10 definition of
rape as “the carnal knowledge, oral sodomy, sexual assault with an object,
or sexual fondling of a person, forcibly or against the person’s will . . . or
achieved through the exploitation of the fear or threat of physical violence or
bodily injury” (BJS, 2005, p. 3; PREA, 2003). Although BJS used a specific
definition of rape, it found during its study that “correctional administrators
frequently expressed concern about the absence of uniform definitions”
(BJS, 2005, p. 4). Because of problematic issues such as disparate definitions,
differential reporting capabilities of institutions, and the lack of uniform
tracking of sexual violence, BJS warns that caution should be taken when
interpreting the results of this 2004 national survey (BJS, 2005).
BJS published its first report in July 2005, titled “Sexual Violence
Reported by Correctional Authorities, 2004.” The study uncovered 8,210
allegations of sexual violence reported nationwide for 2004, with 37% of
these allegations concerning inmate-on-inmate nonconsensual sexual acts.
When converted to base rates, the researchers found 3.15 reported allega-
tions of sexual violence per 1,000 inmates, with 1.16 allegations of inmate-
on-inmate nonconsensual sexual acts per 1,000 inmates. Overall, however,
BJS found that only 30% (2,100) of the original 8,210 allegations of sexual
violence were substantiated (BJS, 2005).
Prison Wardens and PREA
PREA has significant implications for both the detection and the
prevention of prison rape and sexual assault. Many of the policies introduced
in PREA require the support of prison administrators such as wardens.
Hensley et al. (2002) noted that wardens and correctional administrators are
the people who most completely affect and direct the everyday lives of
inmates because they are the ones who create policies and set them in
motion. Wardens are also the ones who determine whether researchers can
have access to their institution’s inmates and records. Because of a warden’s
status, his or her beliefs and attitudes toward rape and sexual assault can
have a great impact on the rules and culture of the penal institution that he
or she oversees.
Research on wardens’ attitudes and beliefs regarding prison rape and
sexual assault is sparse. In a literature review on correctional environments
in general, Sims (2001) reviewed wardens’ beliefs about overcrowding,
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race issues, and prison amenities. However, attitudes specific to sexual
assault were not addressed. Although there are many studies that have
derided prison wardens and administrations for their apathy and neglect of
prison rape (Hensley et al., 2002; Human Rights Watch, 2001; Wooden &
Parker, 1982), there are very few that have actually studied the causes of
such apathy and neglect. Without such data, we have no way of knowing
whether wardens aid or hinder the perpetration of prison rape and what
beliefs and attitudes lead to their subsequent dealings with these issues.
To date, there has been only one study conducted that dealt directly with
wardens’ attitudes and beliefs toward prison sexual assault. Hensley et al.
(2002) distributed anonymous surveys to 441 wardens from all over the
United States to determine (a) their beliefs on the effectiveness of prison
policy in preventing sexual assault, (b) their beliefs on the effectiveness of
staff training to stop prison rape, and (c) their beliefs about the effectiveness
of increasing inmate supervision to deter sexual assault. The authors had a
51.2% return rate (N = 226) and found that slightly more than half (53.3%)
of the wardens believed that institutional policies were “somewhat effective”
and that 6.7% of the wardens found them to be “not at all effective.” A slight
majority (51.3%) of the wardens agreed that training of staff members can be
“completely effective,” whereas 4.9% of the wardens marked staff training as
“not at all effective.” A large majority of the wardens (74.4%) believed that
increased inmate supervision by staff would be “completely effective,” with
only 1.2% of wardens finding the supervision “not at all effective” (Hensley
et al., 2002). These results suggest that a majority of the wardens not only
viewed their prisons’ pre-PREA rape and sexual assault policies as consider-
ably less effective than staff training and increased inmate supervision but
also seemed to have relatively little faith in the policies to begin with.
This study replicates Hensley et al.’s previous research conducted prior
to PREA in an effort to investigate the attitudes and beliefs of U.S state
prison wardens toward different aspects of male prison rape following the
implementation of PREA.
Method
Participants and Procedure
Using the American Correctional Association’s 2004 directory, a ran-
dom sample of 500 wardens working in all-male U.S. state prisons was
invited, via mail, to participate in a survey aimed at examining their
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thoughts on male prison rape. In addition to the survey, the wardens were
mailed a consent form, a debriefing form, and an envelope with the return
postage paid. The approximate time to complete the questionnaire was 10
to 15 minutes.
Demographic characteristics of the wardens are presented in Table 1. Of
the sample (N = 60), 85.2% (n = 46) were male and 14.8% (n = 8) were
female. A majority of the wardens were Caucasian (76.7%), with 18.3% of
respondents identifying themselves as African American or Black and 3.3%
as Latino or Latina. The mean age of the responding wardens was 49.7
years (SD = 6.4 years), and their average number of years as a prison war-
den was 11.3 (SD = 8.0 years). The mean number of years of education of
the warden sample was 16.7 (SD = 3.0 years). Nearly half of the wardens
in the sample worked at state prisons in the South (45.0%), one fourth
worked in the Midwest (26.7%), and 16.7% and 11.7% worked in state
prisons in the West and Northeast, respectively.
Measures
This survey was created using themes, questions, and scales based on
measures used in two previously published studies (Eigenberg, 2000;
Hensley et al., 2002). The questionnaire had five sections: Demographic
Information, Prevalence of Male Prison Rape and Sexual Assault, Classification
of Male Prison Rape and Sexual Assault, Prevention of Male Prison Rape and
Sexual Assault, and Current Institution Policies and Practices.
Demographic information. Demographic variables include age, gender,
ethnicity, religion, educational history, U.S. region, and length of time as
warden.
Prevalence of male prison rape and sexual assault. This section included
questions from Hensley et al. (2002) on the known sexual assault rate
within the warden’s institution, the amount of sexual assaults that occurred
during the past year that the warden knows about, and the estimated per-
centage of consensual sex and forced sex within the institution.
Classification of male prison rape and sexual assault. Ten different sce-
narios of situations between two or more male inmates were presented and
wardens were asked to identify the situations they believed constituted
prison rape or sexual assault. This section is loosely based on Eigenberg’s
(2000) study that presented six vignettes about prison rape.
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Prevention of male prison rape and sexual assault. Directly based on
Hensley et al.’s (2002) questions, wardens were questioned about their opin-
ions on different methods of prison rape prevention. These included the fol-
lowing: (a) “How effective do you believe institutional policies and procedures
can be in preventing sexual assault between inmates?” (b) “How effective do
you believe staff training can be in preventing sexual assault between
inmates?” and (c) “How effective do you believe increased or enhanced super-
vision by staff can be in preventing sexual assault between inmates?”
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Table 1
Demographic Characteristics of Wardens
Characteristic n %
Gender
Male 46 85.2
Female 8 14.8
Ethnicity
African American or Black 11 18.3
Latino or Latina 2 3.3
Caucasian or White 46 76.7
Native American 1 1.7
Age
30 to 39 3 5.9
40 to 49 21 41.2
50 to 59 26 51.0
60 to 65 1 2.0
Education
BA or BS 30 52.6
MA or MS 20 35.1
PhD or PsyD 2 3.5
U.S. Region
Northeast 7 11.7
South 27 45.0
Midwest 16 26.7
West 10 16.7
Religion
Christian 13 21.7
Baptist 20 33.3
Protestant 6 10.0
Catholic 8 13.3
Other 13 21.7
Note: N = 60.
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Wardens were also asked whether they agreed or disagreed with eight
statements about the role of correctional officers in preventing prison sex.
Some examples include “Correctional officers should patrol areas fre-
quently to prevent consensual sexual acts,” “Correctional officers should
talk to inmates about the risk of sexual assault,” and “Correctional officers
should do everything they can to prevent consensual sexual acts.”
Current institution policies and practices. The final segment of the ques-
tionnaire asked the wardens to describe their current policies concerning
prison rape and sexual assault, the origin of these policies, and the method
of reporting prison rape within their institution. Wardens were also ques-
tioned about the consequences of prison rape and how they were applied.
Results
Prevalence of Male Prison Rape and Sexual Assault
When asked about the number of sexual assaults that have occurred
within the past year that they knew about, 51.8% of the wardens reported 0
assaults; 23.2% reported knowing of 1 assault and 25.0% knew of 2 or more
assaults. The highest number of assaults reported was 5. When estimating
the percentage of forced sex within their institutions, 96.6% of the wardens
believed it was below 10% of their inmate population and 3.4% believed it
was between 10% and 25% of their inmate population. By comparison,
when estimating the percentage of consensual sex within their institutions,
47.3% of wardens believed it was below 10%, 30.9% believed it was
between 10% and 25%, and 21.8% estimated that it was 26% or above of
their inmate populations.
Wardens were presented with the question “What is the known sexual
assault rate in your prison?” and asked to write out an answer. The most
prevalent responses were “0” (26.8%), “extremely low/very low/low”
(15.0%), “less than 1% to 1%” (13.6%), and “less than 1 a year” (8.5%).
There were also a few other responses indicating a very low level of known
sexual assault, such as “less than 5%” (1.7%), “less than two a year”
(1.7%), and “1 during my tenure” (1.7%). Very few wardens (5.1%) gave
answers that indicated some form of an elevated sexual assault rate. These
responses were “approximately 6 per year,” “17%,” and “1 or 2 a month.”
In addition, 17.0% of the wardens responded to this question with the
answers “unknown,” “not clear,” “NA,” or “no stats kept at this time.”
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Classification of Male Prison Rape and Sexual Assault
The respondents were provided with 10 different scenarios of male
prison sexuality and asked to answer “which, if any, of these situations [do]
you consider prison rape or sexual assault?” Results for the 10 vignettes are
presented in Table 2. Six of the vignettes had at least two thirds of the war-
dens responding yes that they perceived the situation to be prison rape or
sexual assault. These were, “An inmate is asked for sex by another inmate
in exchange for protection,” with 66.7% of the wardens answering yes; “A
man in prison for sex offending against boys is pressured to have sex by
another inmate,” with 87.9% answering yes; “An inmate is persuaded to
have sex in exchange for commissary goods such as cigarettes and maga-
zines,” with 69.0% of wardens responding yes; “An inmate is asked for sex
and is threatened with the fact that if he does not cooperate, the other
inmates will be told that he is an informant,” with 84.5% choosing yes; “A
new inmate wants to join a certain gang. In order to be initiated, he must
have sex with all of the other members of the gang. He complies and is
initiated,” with 67.2% answering yes; and finally “An inmate known for
sexually assaulting other inmates is forced to have sex by one of his previ-
ous victims,” with 96.6% of the wardens answering yes, it is prison rape or
sexual assault.
The other four vignettes were seen as more ambiguous by the wardens,
and all received the highest percentage of warden’s answers being “maybe, I
am not sure if this is prison rape and sexual assault.” These were, “Two cell-
mates have sex in their cell at night, and neither have sex with other inmates,”
with 55.0% of wardens responding maybe; “Two men are found having sex.
They are known to be good friends,” with 55.2% choosing maybe; “Two men
are found having sex. Both are known homosexuals,” with 58.6% answering
maybe; and finally “Two men are found having sex. One is a known homo-
sexual and one is not,” with 70.7% of all wardens answering maybe.
Prevention of Male Prison Rape and Sexual Assault
When presented with questions about their opinions on methods of
prison rape prevention, the U.S. state prison wardens were asked to reply
whether they believed three different methods would be “not at all effec-
tive,” “somewhat effective,” or “completely effective” at preventing prison
rape and sexual assault. Of the sample, 69.0% believed that institutional
policies and procedures can be “somewhat effective” at preventing sexual
assault, 51.7% of the wardens believed staff training can be “somewhat
effective” at preventing sexual assault, and 70.7% believed that increased
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and enhanced supervision by staff can be “completely effective” at prevent-
ing prison rape and sexual assault.
Current Institution Policies and Practices
The warden sample was asked, “Does your institution currently have
policies concerning prison rape and sexual assault?” and 98.3% (n = 59) of
respondents answered yes. The 1.7% (n = 1) who did not answer yes wrote
that such policies were “under development.” When asked what these poli-
cies concerning prison rape were, 49.1% (n = 27) of the wardens responded
that they enforced PREA or a PREA-related policy, such as “zero toler-
ance” and “mandatory reporting.” Some other policies that prisons devel-
oped on their own or in addition to PREA were protective custody, toll-free
Moster, Jeglic / Male Prison Rape and Sexual Assault 73
Table 2
Warden Responses to “Which, If Any, of These Situations
[Do] You Consider Prison Rape or Sexual Assault?”
Item Yes (%) No (%) Maybe (%)
1. An inmate is asked for sex by another inmate in 66.7 20.0 13.3
exchange for protection.
2. Two cellmates have sex in their cell at night, and 18.3 26.7 55.0
neither have sex with other inmates.
3. Two men are found having sex. They are known 17.2 27.6 55.2
to be good friends.
4. Two men are found having sex. Both are known 17.2 24.1 58.6
homosexuals.
5. Two men are found having sex. One is a known 19.0 10.3 70.7
homosexual and one is not.
6. A man in prison for sex offending against boys 87.9 3.4 8.6
is pressured to have sex by another inmate.
7. An inmate is persuaded to have sex in exchange for 69.0 15.5 15.5
commissary goods such as cigarettes and magazines.
8. An inmate is asked for sex and is threatened with 84.5 6.9 8.6
the fact that if he does not cooperate, the other
inmates will be told that he is an informant.
9. A new inmate wants to join a certain gang. In order 67.2 19.0 13.8
to be initiated, he must have sex with all of the other
members of the gang. He complies and is initiated.
10. An inmate known for sexually assaulting other 96.6 0.0 3.4
inmates is forced to have sex by one of his
previous victims.
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sexual assault hotline, and medical and mental health services for the vic-
tims of sexual violence. When asked about the consequences for inmates
who engage in prison rape and sexual assaults, 88.1% (n = 52) of the war-
dens reported initiating a criminal investigation and pressing charges and
prosecuting the perpetrator if necessary, 64.4% (n = 38) reported bringing
disciplinary sanctions against the offender within their own institution, and
35.6% (n = 21) of the sample reported enforcing a policy of segregation
and/or security increase.
Finally, the wardens were asked if the consequences to the perpetrator
differ because of the identity of the perpetrator or victim, and 91.5% of the
wardens answered no. Some reasons cited by the wardens who answered
yes for a possible difference in consequences because of the identity of the
perpetrator were whether the offender was mentally ill or if he had a prior
history of rape or sexual assault perpetration.
Discussion
The current study found that the majority of U.S. state prison wardens
who responded to the survey reported that male prison rape and sexual
assault is a low base rate phenomenon and that their prison’s current sexual
assault rate is either 0% or below 1%. In addition, the wardens reported that
there is not very much sexual activity happening within their institutions,
either consensual or forced.
U.S. state prison wardens were able to identify sexual assault in situa-
tions where force was used as well as in situations where more covert
coercion was utilized. However, in more ambiguous situations where prison
sex was occurring but there were no signs of either physical force or coer-
cion, U.S. state prison wardens were unsure about the nature of these sexual
activities. This suggests that these wardens are keeping an open mind and
not dismissing sexual activity as consensual merely because the recogniz-
able elements of force or coercion were not present. These finding are
encouraging because there can be no prevention of prison rape without
proper classification of the activity as nonconsensual.
Both institutional policies and procedures and staff training were viewed by
the wardens as being somewhat effective at preventing prison rape and sexual
assault. Most important, they believe that increased inmate supervision by
staff can be completely effective at preventing prison rape and seem to regard
this as the best method of prevention available within their institutions.
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Finally, this study found that U.S. state prison wardens have policies in
place to prevent prison rape and that about half of these are based on PREA
or PREA-related policies. State prisons also have certain consequences for
committing prison sexual violence such as criminal investigation and pros-
ecution, disciplinary sanctions, segregation, and a raise in the inmate’s
security level.
PREA was created to “develop and implement national standards for the
detection, prevention, reduction, and punishment of prison rape” (PREA,
2003). The findings of this study indicate that although still in its nascent
phase, PREA’s creation of common standards appears to be effective. The
fact that half of the wardens in the sample responded that they are currently
implementing PREA-developed or PREA-related policies is indicative of a
major change within the U.S. state prison system. For the first time in penal
history, states are attempting to adhere to a uniform code of prison rape poli-
cies, policies that, in theory, are backed by empirical research. Although it is
still too early to see the changes that PREA in its final form will have on the
U.S. state prison system, the results of this study suggest that prison rape and
sexual assault reform are being recognized by prison administrators.
The findings of this study also support the assertion that male prison
rape and sexual assault are low base rate events. These findings are similar
to those of the BJS 2004 survey, which found that prison rape and sexual
assault happen extremely rarely. This study’s results are also analogous to
those of Hensley et al. (2003), who found that 72% wardens reported hav-
ing zero officially reported sexual assaults within their institutions within
the past year. There are a number of reasons why the wardens may have
reported so few sexual assaults within their institutions. It may be true that
sexual assault is in actuality an event with an extremely low base rate, or it
is possible that most prison rapes and sexual assaults are continuing to go
unreported within U.S. state prisons.
The findings of the current study are remarkably similar to those of
Hensley et al. (2002). When questioned about the prevention of prison rape
and sexual assault, 51.3% of Hensley et al.’s sample found staff training to
be “completely effective” and 48.3% of the current study found this method
of prevention to be “completely effective” as well. When asked about the
effectiveness of increased staff supervision, 74.4% of Hensley’s sample and
70.7% of the current study’s sample believed this method to be “completely
effective.” However, when Hensley et al. (2002) examined the effectiveness
of institutional policies on the prevention of prison rape and sexual assault,
only 6.7% of their sample reported that they believed they were “com-
pletely effective.” By contrast, 29.3% of the current study sample responded
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that institutional policies and procedures could be completely effective at
preventing prison rape and sexual assault. One reason for the discrepancy
between studies may be that prison wardens have greater faith in the effec-
tiveness of PREA policies than in other policies of the past and believe that
they will potentially be successful at preventing prison rape.
There are several limitations to this study. The first is that the data pool
used was very small (N = 60; return rate = 14%), and having such a small
sample limits the generalizability of the findings. However, although the
current study’s return rate is considerably lower than that of Hensley et al.
(2002), it falls within the range typical of most survey studies. Another
limitation of the study is that the delicate and politically sensitive nature of
the questions asked in the survey may have influenced how the wardens
responded. Having prison administrators report that their institutions have
low levels of sexual assault is not surprising and furthermore should prob-
ably be expected. The fact that prison rape is such a politically and legally
charged topic makes it almost impossible to obtain accurate estimates of
prevalence, especially from administrators, as is reflected in the prison rape
literature. In the future, it may be effective to ask U.S. state prison wardens
about their estimates of prison rape prevalence within other institutions
because it is possible the administrators may answer less defensively when
discussing inmates out of their jurisdictions. Furthermore, it may have been
helpful to have more information about the population and security level of
the institution. The fact that larger prisons probably have more incidents of
sexual violence and the fact that institutions with higher security give their
inmates less access to each other are ideas that should be incorporated into
any future study of wardens’ thoughts on different aspects of prison rape.
For future study, the psychological community must come up with more
accurate ways of measuring the true prevalence of male prison rape and
sexual assaults. The BJS plan to survey former inmates about their prison
sexual experiences may be the key to obtaining more accurate information.
It is possible that being removed from the prison environment may make
former victims of sexual abuse feel more comfortable reporting the events
truthfully. Until new methods are implemented, there will always be the
same debate within the literature on prevalence of prison rape; studies, such
as this one, will continue reporting supposed low base rates, and the authors
will continue arguing that these base rates are fundamentally flawed and
extremely low.
It will also be essential to continue this line of research in the future as
PREA and its policies become more entrenched and enforced. Because of
PREA’s relatively recent passing in 2003, there may be quite a few years
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until all states have adopted PREA policies, BJS has collected more com-
prehensive statistics on prison rape, and the federal commission has created
an effective body of standards for combating prison rape. Hopefully, as
PREA becomes more ingrained within the federal penal system, the rates
of prison rape and sexual assault will decrease even further.
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Aviva N. Moster is a clinical psychology doctoral student at the University of Rhode Island.
She completed her MA in forensic psychology at John Jay College of Criminal Justice. Her
research interests include prison sexual assault policies, male sex offender treatment, and
forensic evaluation and testimony.
Elizabeth L. Jeglic is an associate professor at the John Jay College of Criminal Justice. Her
research interests include the development and evaluation of treatment programs for offend-
ing populations. She is currently the principle investigator on a National Institute of Justice–
funded grant examining how placement decisions are made for sex offenders in the criminal
justice system.
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