Kentucky Parole Officer Gets Three Years for Sexually Assaulting Probationers
by Matt Clarke
Former Kentucky Department of Corrections (DOC) parole officer Ronald R. Tyler, 57, was sentenced to three years in federal prison on March 21, 2024, for sexually assaulting three probationers. Victims Stephanie Logsdon Smith, Cammie Musinski and Bridgett Dennis—later known as Bridgett Parson—filed suit against Tyler. DOC fired both him and supervisor Jonathan Hall, who was also named in the victims’ suit, after he admitted failing to act on credible misconduct reports about the errant parole officer before their assaults in 2017 and 2018, as PLN reported. [See: PLN, Aug. 2019, p.15.]
Smith’s claims in the October 2019 complaint read like the script for a bad movie. On just her second visit to his office, Tyler “threw [her] against the wall and kissed [her] by force,” according to the complaint. The next time she saw him, he ordered her into his vehicle and “unzipped his zipper and took out his penis and just pushed [her] head down and had [her] do oral sex.” A month after that, he summoned her to a motel room, where she found him waiting naked, though he helpfully left his gun on the TV while he raped her. Afterward, he warned that “[n]obody is going to believe you” if she reported the rape “and you will go back to jail.”
Parson was able to rebuff Tyler’s physical demands, but she caved and sent him nude photos; much like Smith, she said, “I didn’t want to make him mad” because “I didn’t want to go back to prison.” Tyler’s third victim, Cammie Musinski, suffered a fatal overdose in 2020, after which her Estate was represented by her daughter, Alayna Musinski, who recalled that Tyler raped her mom under threat to make sure her next urine test came back “dirty”—positive for illegal drugs. All three victims cooperated with FBI investigators, leading to Tyler’s indictment.
Tyler pleaded guilty in December 2023 to federal charges of engaging in unwanted sexual contact with the three and then lying about it to investigators. Though he faced life in prison, his sentence included just one year in prison and one year of supervised release for depriving the three victims of their civil rights under color of law, plus a concurrent three-year term and two years of supervised release for obstruction of justice by lying to the FBI. He was also ordered to pay a $100 special assessment. See: United States v. Tyler, USDC (W.D. Ky.), Case No. 3:22-cr-00066
Meanwhile, homeowner’s insurer State Farm Co. filed suit against Tyler and all three of his victims, successfully negotiating the limits of its liability under his policy in an August 2022 partial settlement. Terms of that agreement, however, were not disclosed. See: State Farm v. Smith, USDC (W.D. Ky.), Case No. 3:21-cv-00250. The settlement also resolved all claims against Tyler, but it did not extinguish claims against Hall. See: Smith v. Tyler, USDC (W.D. Ky.), Case No. 3:21-cv-00721.
The federal court for the Western District of Kentucky then dismissed claims against Hall by Smith and Musinski for being filed outside the one-year statute of limitations that state law provides. Hall filed for summary judgment on the remaining claim by Parson, who filed a cross-motion for summary judgment. On March 6, 2024, the district court denied both motions, preserving Parson’s claims for a jury to hear. See: Smith v. Tyler, 2024 U.S. Dist. LEXIS 40256 (W.D. Ky.).
When it became clear that some of their claims may be time-barred, the three victims filed a separate suit in the district court against the state, arguing that the Thirteenth Amendment provided another cause of action, one sufficient to defeat Kentucky’s sovereign immunity. But the district court dismissed that suit, and the U.S. Court of Appeals for the Sixth Circuit affirmed dismissal on June 3, 2022.
As the appellate court noted, the Supreme Court of the U.S. (SCOTUS) “has never recognized a cause of action arising directly under the Constitution in a case where § 1983 was available.” In this case, Plaintiffs “had, and simply missed, the opportunity to avail themselves of a statute through which to properly bring their lawsuit,” the Court said. Further, Kentucky is entitled to Eleventh Amendment immunity which had neither been waived nor abrogated. See: Smith v. Kentucky, 36 F.4th 671 (6th Cir. 2022). Plaintiffs then turned to SCOTUS, but their request for a petition of certiorari was denied on October 3, 2022. See: Smith v. Kentucky, 143 S. Ct. 213 (2022).
The Sixth Circuit is not through, however; Hall has appealed denial of summary judgment on Parson’s remaining claim. PLN will update developments as they are available. Tyler’s victims have been represented in their suits by Louisville attorneys Jeffrey A. Sexton and John W. Byrnes. See: Smith v. Tyler, USCA (6th Cir.), Case No. 24-05296.
Additional source: Lexington Herald Leader, WAVE, WDRB
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