A prison guard sued the state Friday alleging the Corrections Department failed to protect her from being held hostage and sexually assaulted by an inmate.

The complaint lays out in horrific detail the ordeal Katie Jackson, a correctional officer who worked the Sierra Conservation Center, allegedly suffered after Robert Lawrence Ransom Jr. managed to hold Jackson hostage in a control booth for four hours, where she claims he repeatedly threatened, strangled and raped her.

“I was alone for four hours with an assault rifle pointed at me, with no help, no hope of rescue, and my partners having no idea what was going on,” Jackson recalled on the Capitol step Monday.

In the complaint filed in Tuolumne County Superior Court on Friday, Jackson alleged the California Department of Corrections and Rehabilitation failed to alert correctional officers that inmates with violent conviction had been transferred to facilities designed for lower-level offenders.

Jackson said Ransom threatened to kill her, her fellow officers and her children if she did not agree to help him bring contraband into the facility on Jan. 20, 2024.

Jackson’s attorneys said CDCR showed deliberate indifference to correction officers’ safety by failing to inform officers that individuals with violent convictions were moved to a facility that is designed for a population that poses lower-level safety threats.

“Level upon level, some of the most basic, rudimentary safety measures were ignored, were not maintained in the institution,” said Paul Goyette, Jackson’s attorney. The lawsuit also included sexual harassment claims under the California Fair Employment and Housing Act, alleging CDCR failed to protect a female guard from the assault despite knowing that security issues at the facility were present.

CDCR spokesperson Terri Hardy said the agency does not comment on pending litigation.

“However, CDCR’s top priority is the safety and well-being of our staff and those who reside in our institutions,” Hardy said in a statement. “When incidents occur within a facility, CDCR conducts internal investigations and refers matters to the local district attorney as appropriate.”

Hardy said CDCR referred the incident to the Tuolumne County District Attorney’s Office. The local district attorney charged Ransom with 11 felony counts, including aggravated kidnapping and rape, on Jan. 7. Ransom’s arraignment is scheduled for Feb. 10, 2025.

In 2018, Ransom was convicted of murdering two women and attempting to murder a third in Los Angeles. He was sentenced 85 years to life in prison. Because of the violent nature of his crimes, Ransom was initially designated as a “Level 4 Inmate,” the complaint states.

Ransom was moved to Sierra Conservation Center, a prison in Tuolumne County, after he was reclassified, Jackson’s attorneys said Monday. SCC is designed for people classified as lower-level risks, the filing stated. The facility also serves as a training location for incarcerated wildland firefighters.

Roughly two weeks after Ransom’s transfer, he was assigned to work as a “porter” in the facility. The filing stated that porters, whose primary responsibilities include cleaning and maintenance tasks, often gain a better understanding of the inner workings of a facility, such as correctional officers’ uniforms and shift change times, because of their involvement in the prisons day-to-day operations.

Ransom then leveraged that knowledge to avoid detection from officers after hiding in a laundry basket and pretending to be a relief officer who had come the control booth where Jackson was working to replace her.

The complaint outlines the security measures Jackson claims she took before allowing Ransom to enter the secure control booth. The lawsuit stated that a broken security mirror, dimly lit facilities and an unmanned security post were all “hazardous conditions” that left Jackson dangerously exposed and improperly equipped to do her job safely.

Ransom allegedly held Jackson hostage for four hours, threatened to kill her and her family and raped her. While Jackson was trapped in the control booth with Ransom, who was armed with a gun, she claims she did not alert fellow officers of the danger she was facing in attempt to protect them. Jackson managed to trick Ransom into thinking she would meet his demands to bring drugs and cell phones into the facility for him. He returned to his cell undetected, without harming other officers, the filing said.

“I am forever haunted by the fact that after saving myself from this monster and alerting my supervisors, I was treated like a suspect and denied medical care and attention for nearly six hours,” Jackson said. Goyette said that CDCR placed Jackson under investigation following the incident.

Jackson said she is still an employee of CDCR but has been on leave for a year since the incident.

Jackson and her attorneys said a new model for California prisons is putting the lives of correctional officers and others in prisons at risk by giving certain inmates more freedom within facilities and opportunities to communicate outside of the facility.

CDCR officials unveiled the California Model after touring the Norwegian prison system, touting it as a means of reducing recidivism and improving the state’s prisons for employees who staff them. The model attempts to normalize prison conditions to life outside of CDCR facilities so individuals can more easily return to civilian life after serving their sentence, according to the agency’s website.

“We have to work around certain rules and policies of the California Model in order to do our job,” Jackson said Monday. “It makes our job harder to keep each other safe and to keep the public safe and to keep other inmates safe.”

In addition to seeking unspecified damages, Jackson and her team of attorneys are calling on the state to make changes to the California Model to better protect prison guards and other incarcerated people from future dangers posed by some inmates.

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