Formal Rebuttal & Complaint: Williamson County Jail

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

Agencies Notified

• Texas Commission on Jail Standards (TCJS)
  tcjs@tcjs.texas.gov
• U.S. Department of Justice — Civil Rights Division
  special.litigation@usdoj.gov
• Texas Attorney General – Civil Rights Division
  https://www.texasattorneygeneral.gov

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Summary of Violations

• 326 days in solitary confinement under constant lighting and vibration (cruel and unusual punishment).
• 126-day denial of diabetes treatment, insulin, and blood sugar testing — resulting in permanent harm.
• Use of physical restraints for 2.5 hours for refusing to surrender a Bible (religious discrimination).
• Prescription of medication by unlicensed staff, with no oversight by a licensed physician (state violation).
• Charges for unwrapped over-the-counter medication — violating TCJS medical standards and the Texas Constitution.
• Medical decisions made without doctor approval, including mood-altering substances and insulin withdrawal.
• Abuse of the restraint chair without imminent danger or suicide risk — medical and civil rights violation.

Legal Citations

• 8th Amendment – U.S. Constitution
• 14th Amendment – Due Process Clause
• Civil Rights of Institutionalized Persons Act (CRIPA), 34 U.S.C. § 12601
• Texas Commission on Jail Standards – Minimum Jail Standards, Subchapter G, Medical
• Americans with Disabilities Act (ADA), 42 U.S.C. § 12101 et seq.
• Texas Health & Safety Code § 1701.404 – Medical Protocols in County Jails

Actions Requested

• Federal investigation by DOJ CRIPA and the Special Litigation Section.
• Reinspection by TCJS with neutral federal observers present.
• Public release of staff licensure records, disciplinary history, and current inmate complaints.
• Permanent record annotation that prior TCJS determination (“no deficiencies”) is under federal challenge.

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Certification: I certify under penalty of perjury that the information above is true and accurate to the best of my knowledge.

Signed,
LeRoy Nellis II