Williamson County Jail Medical Misconduct DOJ Complaint

Williamson County jail medical misconduct DOJ complaint is documented through a formal filing submitted to federal and state oversight agencies alleging systemic medical and psychiatric violations within the Williamson County Jail in Georgetown, Texas. Based on documented records, statutory citations, and preserved complaint materials, this article establishes a structured evidentiary record. This constitutes a record derived from official filings and supporting exhibits, presented without alteration for transparency, review, and accountability.

U.S. Department of Justice – Special Litigation Section
U.S. Department of Health and Human Services – Office for Civil Rights
Williamson County Master Timeline
LeRoy Nellis Blog Archive

Williamson County Jail Medical Misconduct DOJ Complaint Overview

The following section preserves the original complaint as an evidence layer. Therefore, no edits, summaries, or modifications have been made to the underlying document. This constitutes a record of submission as reflected in official documentation. :contentReference[oaicite:0]{index=0}

Williamson County Jail Medical Misconduct DOJ Complaint Evidence Record

– SPECIAL LITIGATION SECTION
950 Pennsylvania Avenue NW
Washington, D.C. 20530

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FORMAL COMPLAINT
Systemic Medical & Psychiatric Misconduct
Williamson County Jail – Georgetown, Texas
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Complainant: LeRoy Nellis
Email: leroynellis2@gmail.com
Date: October 24, 2025

Agencies for Concurrent Notice:
• U.S. Department of Justice – Civil Rights Division (Special Litigation Section)
• U.S. Department of Health and Human Services – Office for Civil Rights
• Texas Medical Board
• Texas Department of State Health Services
• Texas EMS Licensing & Trauma Systems Office
• Texas Commission on Jail Standards (TCJS)
• U.S. Food and Drug Administration – Office of Criminal Investigations

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I. EXECUTIVE SUMMARY
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This complaint details systemic medical and psychiatric violations at the Williamson County Jail (Georgetown, TX), including the prescription of psychotropic medication without continuous oversight by licensed physicians, unlicensed medical staff dispensing drugs, and prolonged solitary confinement causing measurable physical and psychological harm.

The practices described herein violate the Eighth and Fourteenth Amendments, 42 U.S.C. § 1983, and 34 U.S.C. § 12601 (CRIPA). Supporting evidence is attached as Exhibits A–F and Addendum G.

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II. ALLEGATIONS SUMMARY
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1. Unlicensed or Insufficiently Supervised Prescribing
• Psychotropic medications dispensed while psychiatrist coverage limited to 16–20 hours per week.
• No full-time physician presence; reliance on mid-level practitioners.

2. Misrepresentation of Credentials
• Jail medics and correctional medical officers wore EMS patches yet refused to disclose license numbers.
• Individuals identified as “Dr. Alan Brooks” and “Dr. Ghulam M. Khan” practiced without active Texas Medical Board licenses.

3. Failure of Care and Emergency Access
• Delayed or denied diabetic medications and glucose readings.
• Injection of “50 cc’s of COVID vaccine” by EMT Larry Davis without physician order.
• Refusal of hospital transport during active bleeding and poisoning symptoms.

4. Improper Delegation of Medical Authority
• Mid-level staff operated outside their scope under Texas Occupations Code §157.
• Nurse Practitioner handled daily care for 550–600 inmates with intermittent telephonic MD consultation.

5. Dr. Ghulam M. Khan and Medical Neglect
• Complainant held in solitary confinement for 326 consecutive days.
• Deprivation of exercise, nutrition, sunlight, and routine medical assessment.
• No psychiatrist visit recorded for extended periods.

6. Systemic Pattern
• 2019 TCJS inspection found failures to carry out physician orders.
• 2024–2025 lawsuits produced settlement outcomes related to denial of care and restraint use.
• Ongoing investigations into jail medical oversight practices.

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III. REQUESTED DOJ ACTIONS
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1. Open a pattern-or-practice investigation under 34 U.S.C. § 12601.
2. Audit prescription and delegation logs.
3. Verify licensure and contractor roles.
4. Coordinate with state agencies for oversight compliance.
5. Ensure public reporting of findings.

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IV. LEGAL FRAMEWORK
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• Estelle v. Gamble, 429 U.S. 97 (1976)
• Kingsley v. Hendrickson, 576 U.S. 389 (2015)
• 42 U.S.C. § 1983
• 34 U.S.C. § 12601
• Texas Occupations Code §157
• Texas Health & Safety Code Chs. 571–578

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V. SUPPORTING EXHIBITS
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Exhibits A–G document statewide patterns, staffing records, classification matrices, and supporting analysis.

Closing Record Statement

This document is presented as a structured record based on preserved complaint materials, statutory references, and supporting exhibits. It reflects the presence of allegations, documentation, and legal framing without modification or interpretation.

This record is maintained for transparency, evidentiary continuity, and public reference. The current version supersedes prior versions and will be updated as additional filings, investigative responses, or official findings become available.

Future updates will incorporate verified records, agency responses, and supplemental documentation as they are obtained.