County Not Liable For Sergeant’s Assault On Deputy

Angela Branford was a deputy sheriff with the Washington County Sheriff’s Office in Oregon. Branford met Sergeant Jonathan Christensen when he led a training session. Sometime in 2013 or 2014, Branford and Christensen began a consensual romantic and sexual relationship. During the course of the relationship, Branford described Christensen’s behavior as growing more controlling. Branford attempted on several occasions to end her relationship with Christensen but was unsuccessful. On…

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Rape And The ‘Course And Scope Of Employment’

There are times when court decisions reach contrary results that are simply irreconcilable. And so it was in September 2018, when two neighboring courts reached opposite results in cases involving whether an employer could be civilly liable for sexual assaults committed on the job. One of the cases involved Milwaukee County Corrections Officer Xavier Thicklen. On five occasions, Thicklen sexually assaulted inmate Shonda Martin, both when she was pregnant…

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