LeRoy Nellis

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COMPLAINT LETTER — UNLICENSED MEDICAL PRACTICE Williamson County Sherriff’s Office / Jail

FRAUDULENT PRESCRIPTIONS, AND PUBLIC HEALTH VIOLATIONS IN WILLIAMSON COUNTY JAIL

o:

  • U.S. Food and Drug Administration (FDA) — Office of Criminal Investigations
  • Texas Department of State Health Services (DSHS) — Health Care Quality / Professional Licensing Division
  • Texas Medical Board (TMB) — Enforcement Division
  • Texas EMS / Trauma Systems Licensing Division

From:
LeRoy Nellis II
Email: leroynellis2@gmail.com
Address: [Insert mailing address]
Date:10/23/2025

Subject:

Formal Complaint — Unlicensed Medical Practice, Fraudulent Prescription Handling, and Concealment of Medical Licensing Information within Williamson County Jail

Summary of Allegations

I am filing this formal complaint regarding systemic medical misconduct occurring within the Williamson County Jail (Georgetown, Texas) involving Alan Brooks, Greenwood, Kahn, and other individuals who are practicing medicine and administering controlled substances without valid medical or EMS licensure. These acts violate multiple Texas medical, health, and administrative laws, as well as federal FDA and DEA regulations governing prescription integrity and medical supervision.

The evidence suggests that no physicians practicing within Williamson County Jail are licensed under the Texas Medical Board, and that all medical orders and prescriptions are being funneled through a single remote physician located in Houston, Texas, who has never personally examined or evaluated any of the inmates.
This constitutes unlicensed medical practice, prescription fraud, and dangerous deviation from established FDA and TMB medical standards.

Specific Incidents and Evidence

  1. Unlicensed Practice of Medicine
    • Alan Brooks, Greenwood, and Kahn are representing themselves as medical or psychiatric providers within Williamson County Jail, engaging in diagnosis, prescribing, and patient treatment without valid licenses.
    • Public record checks with the Texas Medical Board (TMB License Lookup) confirm that these individuals do not hold active medical licenses in Texas.
  2. Remote Prescribing Without Patient Contact
    • All prescriptions within Williamson County Jail are being routed through a Houston-based physician who never meets or evaluates inmates, violating 22 TAC §190.8(1)(L) and 22 TAC §174.9 (telemedicine and proper supervision requirements).
    • Controlled substances are being dispensed without a legitimate medical purpose as required under 21 CFR §1306.04(a).
  3. Use of Unverified EMS Personnel
    • Every medic working within Williamson County Jail wears EMS patches on their uniforms, creating the appearance of licensed emergency medical professionals.
    • When detainees request the names or license numbers of the medical staff, these individuals refuse to identify themselves or provide licensing information, contrary to Texas Administrative Code §157.36(b)(1), which requires EMS personnel to present proper identification and operate only under a valid, verifiable certification.
    • This concealment of identity and credentialing prevents lawful patient consent, undermines medical accountability, and suggests that non-licensed or uncredentialed individuals are performing restricted medical duties under the false representation of being EMS-certified.
  4. Improper Injection and Medication Handling
    • Inmates, including myself, have been injected with medications and vaccines—including COVID-19–related injections—without informed consent or medical supervision.
    • Medication storage and administration practices violate 21 CFR §§ 211.125–211.137, governing labeling, control, and expiration of drug products.
  5. Pattern Across Texas Counties
    • The conditions in Williamson County mirror widespread state-level patterns of unlicensed medical practice, delayed emergency care, and wrongful injections (see Acosta v. Williamson County, 5th Cir. 2024; Estate of Melissa De La Cruz v. Hidalgo County, 2025).
    • Exhibit A – Texas Jail & Pretrial Detention Summary (2024–2025) documents over thirty similar incidents of medical negligence, lack of physician oversight, and concealment of provider credentials.
  6. Intergovernmental Oversight Failure
    • Williamson County Jail operates under an Intergovernmental Service Agreement (IGSA) with the U.S. Marshals Service, placing it under dual state–federal jurisdiction.
    • This jurisdictional overlap has enabled regulatory evasion, as neither the FDA nor TMB maintains consistent oversight of medical activities conducted under this contract.

Legal Basis for Complaint

  • Texas Occupations Code §§155.001–165.151 — Prohibits unlicensed medical practice.
  • Texas Administrative Code §190.8(1)(L) — Requires physician supervision and direct evaluation prior to prescribing.
  • Texas Health & Safety Code §481.071 — Mandates controlled-substance prescriptions to serve legitimate medical purposes.
  • Texas Administrative Code §157.36(b)(1) — Requires EMS personnel to provide identification and operate under valid certification.
  • 21 U.S.C. §331(k) — Prohibits the misbranding or dispensing of drugs contrary to FDA labeling and supervision standards.
  • 42 U.S.C. §1983 / 28 C.F.R. Part 35 (CRIPA) — Encompasses deprivation of medical care under color of state law.

Requested Investigations

  1. FDA Office of Criminal Investigations — Investigate improper medical injections, unauthorized use of pharmaceuticals, and labeling/storage violations.
  2. Texas Medical Board — Audit all individuals providing medical or psychiatric care within Williamson County Jail; take disciplinary action against unlicensed practitioners.
  3. Texas EMS / Trauma Systems Licensing — Verify licensing and certification of all staff wearing EMS insignia and investigate refusal to identify licensure status.
  4. Texas DSHS / Health Care Quality Division — Inspect jail medical operations for noncompliance and forward findings to the Texas Attorney General.
  5. U.S. Department of Justice Civil Rights Division — Review systemic medical deprivation under the Civil Rights of Institutionalized Persons Act (CRIPA).

Supporting Documentation (Available Upon Request)

  • Exhibit A: Texas Jail & Pretrial Detention Summary (2024–2025)
  • Exhibit B: Liberty Before Conviction – Constitutional and Human Rights Dimensions of Pre-Trial Detention in the United States
  • Exhibit C: WILCO Abuse Summary — detailing administrative torture and medical neglect
  • Exhibit D: MAP-Federalism Excerpt — Intergovernmental oversight voids within county detention systems

Conclusion

The Williamson County Jail medical unit is operating in clear violation of Texas medical and EMS laws, FDA regulations, and federal civil rights statutes. The presence of individuals impersonating licensed medical staff, combined with remote prescribing and refusal to provide license verification, creates an immediate public health danger and constitutes both fraudulent representation and medical malpractice under color of law.

I request acknowledgment of this complaint, initiation of formal investigation by each agency, and written confirmation of case or tracking numbers for follow-up.

Respectfully submitted,
LeRoy Nellis II
Email: leroynellis2@gmail.com
[Mailing Address]
[Phone Number if applicable]

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