Law360 (October 9, 2026, 7:40 PM EDT) -- A Florida sheriff must face a former immigrant detainee's civil rights suit alleging the sheriff failed to address known risks at the county jail where a deputy sexually assaulted her, a Florida federal judge ruled Friday.

U.S. District Judge Claire R. Kelly denied Baker County Sheriff Scotty Rhoden's motion to dismiss a suit by a woman, known as Jane Doe, seeking to hold him responsible for her rape by an officer during her detention in 2019.

Rhoden was on notice of security deficiencies in the Baker County jail because of 59 previous reports made under the Prison Rape Elimination Act between 2014 and Doe's assault in May 2019, according to the order. The reports describe multiple episodes of staff sexual abuse and harassment, according to the order.

The judge said the fact that the PREA reports from 2018 and 2019 are addressed directly to Rhoden "plausibly establishes that he was aware of the incidents within the PREA reports here."

He also knew about security and training deficiencies and was on notice of existing blind spots that were supposed to be addressed by a plan for installing 28 additional cameras, according to the order.

"At the motion to dismiss stage, plaintiff has established a plausible causal connection between defendant Sheriff Rhoden and his subordinates' unconstitutional conduct," the judge said. "These facts — if proven — support plaintiff's inference that defendant Sheriff Rhoden was aware of his subordinates' unconstitutional conduct and failed to stop it."

She also rejected his argument that he is entitled to qualified immunity because Doe cannot establish "beyond debate" that Rhoden violated her constitutional rights.

"Defendant conflates the need to show a right is clearly established to overcome qualified immunity with plaintiff's obligation to allege sufficient factual content to support the inference that defendant Sheriff Rhoden acted with deliberate indifference," Judge Kelly said. "Plaintiff need not establish 'beyond debate' that defendant violated plaintiff's constitutional rights at the motion to dismiss stage."

Doe arrived at the Baker County Corrections Management Corp. facility Feb. 25, 2019, according to the complaint, filed in May 2023. She was placed in the facility under a contract between BCCMC and U.S. Immigration and Customs Enforcement, in which ICE pays for the local facility to house immigrant detainees.

She says that from her arrival through July 30, 2019, she was assaulted on several occasions by Brian Louis Robinson, a deputy at the jail. He would intimidate and coerce her and sexually assault her by putting his hands under her clothes and his fingers into her vagina, according to the complaint.

On May 25, 2019, he ordered her to the library, where he forced her pants down and began raping her, according to the suit. She says she tried to physically resist him but could not and then told him that she might become pregnant. At that point, he ordered her to perform oral sex on him, according to the suit.

Doe says Robinson would threaten to fabricate criminal charges against her to ensure that she would be removed from the U.S. He also would give her goods of value like toilet paper, feminine pads and other items in an attempt to groom her for sexual acts and buy her silence, according to the suit.

Robinson was criminally charged and convicted in 2024. He was sentenced to 25 years in prison.

Doe says that after she reported the assaults to ICE in an immigration proceeding, other deputies retaliated against her by locking her in the location of the rape for at least two hours and by putting her in solitary confinement.

An attorney for the plaintiff declined to comment.

An attorney for Rhoden did not respond to a request for comment.

Doe is represented by Mark W. Tanner and Samuel Mukiibi of Feldman Shepherd Wohlgelernter Tanner Weinstock Dodig LLP and by James C. Poindexter of Delegal Poindexter & Underkofler PA.

The defendants are represented by Michael P. Spellman and Christen Ann Petruzzelli of Spellman Law PA.

The case is Jane Doe v. Baker County et al., case number 3:23-cv-00609, in the U.S. District Court for the Middle District of Florida.

--Editing by Lief Nielsen.

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