In the face of repeated instances of sexual abuse and misconduct by prison guards in its women’s prisons, the state of Washington determined that a primary driver was the lack of female correctional officers to oversee female offenders and administer sensitive tasks such as observing inmates showering and dressing and performing pat-downs and strip searches. The state undertook a comprehensive assessment and ultimately designated a limited number of female-only correctional positions. In response, the prison guards’ union, Teamsters Local No. 117, challenged the number of positions reserved for females (claiming it should be no more than 50 instead of 110) and claimed discrimination based upon sex in violation of Title VII. The district court granted summary judgment in favor of the state, and the United States Court of Appeals for the Ninth Circuit affirmed, holding that “the Department was well-justified in concluding that rampant abuse should not be an accepted part of prison life and taking steps to protect the welfare of inmates under its care.”