Elements of incarceration, including disparate power differentials between guards and prisoners, contribute to the widely-recognized problem of custodial rape. However, in 1996 when Congress enacted the Prison Litigation Reform Act to combat frivolous lawsuits on behalf of prisoners, it may have prevented some prison rape victims from vindicating their rights in court. The statute requires a "physical injury" before a prisoner may file a civil suit, but that key term was left undefined. As a result, it is unclear whether rape qualifies, and court rulings to date go different ways on this question. Deborah Golden’s article, The Prison Litigation Reform Act – Closing the Loophole for Rapists, addresses this problem in depth and proposes a solution.