Is brief inappropriate touching with sexual overtones cognizable under the Eighth Amendment?

brief inappropriate touching with sexual overtones have been dismissed as non-cognizable under the Eighth Amendment. Id., citing 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 toilet, rubbed his thigh against the prisoner's thigh and began smiling in a sexual way, and left prisoner's cell laughing).