GRAND RAPIDS, Mich. (WOOD) — An inmate at the Kent County Correctional Facility is suing a jail counselor who is charged criminally with sexually assaulting him.

In the federal lawsuit, the inmate alleges Theresa Lyn Simmons, 43, of Wyoming, called him her “personal sex slave.”

Simmons, a social worker who is not a county employee but with whom the jail contracted to counsel inmates with mental health issues, was charged Aug. 5 in Grand Rapids District Court with second-degree criminal sexual conduct.

According to the affidavit of probable cause, the alleged sex acts occurred “on different occasions during January of 2022.”

“Theresa Simmons while employed as a third-party contractor at the Kent County Jail… engaged in sexual contact (with an inmate). (The victim) told investigators he received sexual favors from Theresa Simmons. Some of those acts were described (by the victim) as being handjobs,” a detective wrote in the affidavit.

According to court records, Simmons was to be housed at the Ionia County Jail, which is standard procedure when the defendant has worked inside the jail where the offense occurred. A judge set her bond at $15,000 in the criminal case.

Five months before Simmons was charged criminally, an inmate sued her in federal court in Grand Rapids. The lawsuit claims Simmons violated her alleged victim’s constitutional rights by subjecting him to “manipulative mental abuse, excessive sexual abuse, frequent sexual assaults,” and bribes to entice him to perform sexual acts.

News 8 has confirmed the inmate in the suit is the alleged victim in the criminal case against Simmons.

HANDWRITTEN TESTIMONY: ‘I TRIED TO IGNORE IT’

In seven pages of neatly handwritten testimony, the lawsuit explains in detail the plaintiff’s alleged sexual interactions with Simmons. He said he first met her while he was housed in a disciplinary unit referred to as the ‘Hole.’

“(The Hole) is where I first met the DEFENDANT THERESA SIMMONS,” he wrote, capitalizing the counselor’s name throughout his handwritten complaint.

“She is a mental health sheriff and she asked about what was going on,” he wrote, referring to the reason he was in the Hole.

In the suit, the inmate claimed he was in the disciplinary unit because he had helped another inmate file a complaint against a corrections officer in an unrelated matter.

“The first day I met the DEFENDANT during me talking to her; she would often repeatedly push her tounge (sic) into her cheek and lick her tongue up and down at me. I tried to ignore it and just talk to her,” he wrote.

The lawsuit alleges Simmons later wrote a note to the plaintiff in which she asked him to expose his genitals every time she visited his cell.

“I didn’t know what I was supposed to do. She repeatedly came to visit me and I only exposed myself once for her but only talked to her (sic),” the lawsuit claims.

Later, he said the mental health counselor would knock on his cell door with her breasts exposed.

“I would be asleep … so when I wake up her breasts are the first thing I see,” he wrote, noting the defendant has a tattoo in a spot that is usually clothed. “This was a frequent thing she would do. I tried to ignore it.”

According to the lawsuit, Simmons wrote multiple notes to the plaintiff, including one in which she tried to convince him it was OK for him to show her his genitals.

“I figured I had to listen to her. Because she liked me even though I tell her the truth that I hear voices in my head, and that I have three people living in my head and that I see spirits … (Simmons) also told me that I have to write her letters and tell her about the voices I heard and to tell her what kind of sex I wanted to have with her,” the lawsuit claimed.

The plaintiff noted he still had possession of some of the explicit letters she wrote him, as well as “FREAKY SONG LYRICS” she had printed off and given to him.

‘SHE WAS TRICKING ME … I’M EASY TO BE TRICKED’

According to the plaintiff, Simmons wrote of sexual acts she wanted to do with him.

“She would also tell me she can loose (sic) her license for telling me that. But, I don’t understand what a drivers license has to do with sex,” he wrote.

According to Simmons’ LinkedIn profile, she earned a master’s of social work from Western Michigan University in 2019. The state of Michigan licenses social workers.

According to the lawsuit, at Simmons’ request, the inmate masturbated in his cell and touched the counselor “through a hole in her pants” while she stood at his cell door.

“I did it when ever she did the hand signal to come please her. I was very scared to do it the voices in my head were afraid also,” the plaintiff wrote.

The lawsuit also claims that Simmons offered the inmate “weed or coke” and “cigarettes or vapes” if he did what she asked.

According to the lawsuit, the inmate’s anxiety attacks had worsened and the voices in his head were louder due to the alleged abuse.

“I feel really used and disgusting; I feel horrible and embarrassed. I feel ashamed some people have laugh (sic) at me. And this new voice in my head tells me she wants me to kill myself,” he wrote.

“She doesn’t love me and was only tricking me because I hear things and see things and I have been to pine rest mental hospital before… she was tricking me because I’m easy to be tricked,” he wrote.

The inmate wrote that he wanted to file a complaint against Simmons but jail staff did not respond to his “kites” (notes).

“I would write many kites asking for grievances because I was unsure any other way to tell on her because I was already in the Hole and I didn’t want to get in more trouble for telling on a staff member,” he wrote.

A letter to the plaintiff dated April 27 acknowledged the “kites” and grievances and informed the plaintiff that evidence was found to substantiate his claims. It informed him the case had been passed along to the county prosecutor but that the prosecutor had twice declined to issue charges.

The letter was included in court documents when the plaintiff tried to add Kent County Prosecutor Chris Becker as a defendant in the lawsuit because he had not filed charges.

It’s unclear what new evidence prompted the prosecutor to ultimately charge Simmons.

The lawsuit originally included the Kent County Correctional Facility as a defendant, but U.S. District Court Judge Janet Neff dismissed Kent County from the suit, noting the county “is liable only when its official policy or custom caused the injury.” The judge determined the plaintiff’s allegations “do not demonstrate a widespread pattern” on the part of Kent County.

“Plaintiff’s allegations against the county essentially rest on a theory of vicarious liability and therefore do not state a claim,” Neff wrote.

The Kent County Sheriff’s Department, which runs the jail, said in a Wednesday statement that as soon as it got the complaint against Simmons, it revoked her access to the jail.

“We became aware of an allegation against Theresa Simmons who worked for the Family Outreach Center providing behavior health services in the jail. Upon receiving the complaint her access to KCSO facilities was immediately removed. The KCSO conducted a criminal investigation and forwarded the case to the prosecutor’s office. The prosecutor’s office has since authorized charges of Criminal Sexual Conduct 2nd – County Inmate. She was not a Kent County Sheriff’s Office employee.”

Kent County Sheriff’s Office

Simmons worked for Grand Rapids-based Family Outreach Center, a mental health services organization. In a Thursday statement, it emphasized its commitment to ethical behavior:

“Family Outreach Center is committed to the provision of quality services and ethical behavior on the part of its employees. All employees are expected to conduct themselves in a manner that reflects professionalism and uphold the code of ethics adopted by her or his professional licensing organization and Family Outreach Center, Inc. When ethical standards have been breached, Family Outreach Center, Inc. is committed to adhering to the legal and professional processes required to rectify the situation and prevent reoccurring issues of this type.”

Family Outreach Center

Simmons is expected back in court for a probable cause conference on Aug. 30 and a preliminary exam has been scheduled for Sept. 6.

According to online jail records, the inmate was booked into the jail in April 2021 and has been awaiting trial on drug and felony firearms charges since. At one point, the criminal case against him was paused so he could undergo a mental competency exam.

Records filed with Kent County Probate Court show the 33-year-old man was taken to the Spectrum Health Butterworth Hospital emergency room in 2019 after he was found sleeping in a Meijer fitting room. At that time, the probate court record described him as homeless and under the influence of amphetamines.

“Patient displays no insight into his current medical condition and need for treatment. He is acutely manic and displayed tangential speech, flight of ideas, and spoke with inappropriate sexual contact,” a doctor who examined the man in 2019 wrote.

The probate court file also noted that the man “required chemical restraints in the hospital for aggression and being sexually inappropriate toward staff at Pine Rest.”

His lawsuit seeks a quarter million dollars.

“I want to be compensated $250,000…” the plaintiff wrote, “so I can get the best mental health counselor and treatment for months of being raped and sexually abused.”