Virginia two-year general statute of limitations applied to plaintiff prisoner's federal civil rights lawsuit claiming that former prison employee threatened to report her for misconduct if she failed to engage in sexual acts with him. A shorter one-year statute of limitations governing lawsuits brought by inmates concerning the conditions of their confinement was not applicable, and the prisoner's lawsuit was therefore timely. The Virginia Supreme Court, in reaching this conclusion, relied on the ruling in Owens v. Okure, 488 U.S. 235 (1989) that courts considering Sec. 1983 claims should "borrow the general or residual" state statute of limitations for personal injury actions. Billups v. Carter, No. 040268, 604 S.E.2d 414 (Va. 2004). [N/R]
     Federal trial court sets aside jury's award of $1 in nominal damages and $30,000 in punitive damages to female prisoner who sued correctional officer who allegedly engaged in an inappropriate relationship with her, including taking photographs of her and writing her love letters. Plaintiff prisoner failed to exhaust available administrative remedies, as required by the Prison Litigation Reform Act, 42 U.S.C. Sec. 1997e(a). Her participation in the departmental investigation that led to the officer's resignation was not the same as pursuing available grievances on her own behalf, and the fact that money damages, the only thing she sought after his resignation, were not available under the grievance procedure did not render those procedures "unavailable." Hock v. Thipedeau, 245 F. Supp. 2d 451 (D. Conn. 2003). [N/R]
     255:46 Louisiana state statute prohibiting correctional officers from engaging with "any sexual conduct" with prisoners was not unconstitutionally vague. Louisiana, State of, v. Hart, 687 So.2d 94 (La. 1997).