Does physical sexual assault violate the Eighth Amendment?

Physical sexual assault violates the Eighth Amendment. Schwenk v. Hartford, 204 F.3d 1187, 1196-97 (2000). On the other hand, claims alleging brief inappropriate touching with sexual overtones have been dismissed as non-cognizable under the Eighth Amendment. See Watison v. Carter, 668 F.3d 1108, 1112-14 (9th Cir. 2012) (finding defendant's conduct "not objectively harmful enough" and prisoner's humiliation not severe enough to state an Eighth Amendment claim where defendant officer allegedly entered prisoner's cell while he was on the

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