Formal Rebuttal & Complaint: Williamson County Jail (TCJS & DOJ Submission)

Submitted by: LeRoy Nellis II
4845 Twin Valley Drive, Austin, TX 78731
Phone: 512-450-1533 | Email: LeRoyNellis2@gmail.com
Date: October 27, 2025

To:
Texas Commission on Jail Standards (TCJS)
P.O. Box 12985, Austin, Texas 78711-2985
Email: tcjs@tcjs.texas.gov

Cc:
U.S. Department of Justice – Civil Rights Division (CRIPA)
950 Pennsylvania Avenue NW, Washington, D.C. 20530
Email: special.litigation@usdoj.gov

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Complaint Overview

This formal complaint and rebuttal is submitted in response to the TCJS October 24, 2025 determination of “no deficiencies” at the Williamson County Jail. It documents serious allegations of medical neglect, constitutional violations, and systemic oversight failure. It also requests federal investigation under the Civil Rights of Institutionalized Persons Act (CRIPA), 34 U.S.C. §12601.

Key Allegations

• 326 days of solitary confinement under continuous fluorescent lighting and vibration.
• Denied diabetic treatment for 126 days, resulting in permanent damage.
• Injections administered by unlicensed EMTs and jail staff.
• Restraint chair use after refusing to surrender a Bible (religious retaliation).
• Placement in suicide-watch cell despite psychiatric clearance.
• Part-time psychiatric contractors with no 24/7 licensed medical oversight.

Legal Basis

• Tex. Admin. Code §§ 273.1–273.6
• Tex. Occ. Code §157
• Tex. Health & Safety Code Chs. 571–578
• Estelle v. Gamble, 429 U.S. 97 (1976)
• Kingsley v. Hendrickson, 576 U.S. 389 (2015)
• Turner v. Safley, 482 U.S. 78 (1987)
• Civil Rights of Institutionalized Persons Act (CRIPA), 34 U.S.C. §12601

Requested Actions

• Joint re-inspection by TCJS and DOJ with forensic review of medical and restraint records.
• Inspection of vibration-emitting devices in cells B5-L6, B7-R6, B9-R1, C14-R8, and B9/C14 dayrooms.
• License verification for all psychiatric and medical staff from 2024–2025.
• Referral to DOJ CRIPA division for systemic constitutional violations.
• Public release of the September 2025 TCJS inspection report and associated documents.

Certification

I certify under penalty of perjury that the statements provided herein are accurate to the best of my knowledge and are submitted in good faith for lawful oversight.

Respectfully,
LeRoy Nellis II
Austin, Texas
Phone: 512-450-1533
Email: LeRoyNellis2@gmail.com

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Attached Exhibits (Summarized)

• Exhibit A – Texas Jail & Pretrial Detention Summary: Patterns of statewide medical neglect; relevant litigation.
• Exhibit B – Williamson County Medical Research Summary: Staffing data and contract violations.
• Exhibit C – Hiring Records (2018–2025): Part-time psychiatric contracts and EMT dependency.
• Exhibit D – Systemic Medical Abuse in WilCo Jail: First-hand report and legal analysis by LeRoy Nellis.