State of Texas Auditor into Williamson County Jail and the Texas Commission on Jail Standards

LeRoy Nellis II

4845 Twin Valley Dr.

Austin, Texas 78731

Email: leroynellis2@gmail.com

Date: October 28, 2025

VIA CERTIFIED MAIL & EMAIL

Texas State Auditor’s Office

Attn: Investigations Division / Fraud, Waste & Abuse Hotline

P.O. Box 12067

Austin, Texas 78711-2067

Email: sao@auditor.texas.gov

Subject: Request for Audit and Whistleblower Report —

Texas Commission on Jail Standards Oversight Failures and

Misuse of Public Funds by Williamson County Jail (2018–2025)

To the Honorable State Auditor:

I am submitting this correspondence as both a whistleblower and a direct victim of

systemic medical neglect, falsified compliance reporting, and administrative concealment

occurring within the Williamson County Jail (Georgetown, Texas) and the Texas Commission on

Jail Standards’ (TCJS) oversight process.  The enclosed materials demonstrate patterns of

mismanagement, misuse of public funds, and potential violations of Texas Government Code

§321.013 and §321.022 concerning agency accountability and fraud-reporting obligations.

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I. PURPOSE OF SUBMISSION

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This report requests that the State Auditor’s Office initiate an independent

performance and investigative audit into:

1.  The Texas Commission on Jail Standards’ monitoring of Williamson County Jail from

    2018 through 2025, including its handling of complaints, inspection follow-ups, and

    death-in-custody reporting.

2.  The use and possible misallocation of ARPA and county funds designated for

    jail-medical staffing, particularly contracts executed with part-time psychiatric

    providers under the Williamson County Sheriff’s Office and Commissioners Court.

3.  Potential falsification or omission of inspection data submitted to TCJS or the

    Attorney General’s Open Records Division.

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II. BASIS AND SUPPORTING EVIDENCE

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My documentation shows that Williamson County Jail operated for nearly two decades

without continuous licensed medical oversight.  Psychiatric services were provided only by

part-time contractors (≤20 hrs/wk) while nurse practitioners and EMTs functioned without direct

physician supervision.  These conditions violate 37 Tex. Admin. Code §273.2 regarding physician availability and continuity of care.  Despite repeated public complaints, TCJS continued to certify the facility as “compliant.”

Supporting exhibits (available upon request) include:

• Exhibit J – Williamson County Jail Medical & Psychiatric Staffing Record and Outcome Analysis (2008–2025)

   – Demonstrates systemic understaffing, repeated vacancy postings, and temporal overlap

     between physician absences and inmate deaths or lawsuits.

• ster Legal Claims Dossier (2025)

   – Summarizes constitutional and administrative violations observed during pre-trial

     detention January 2024 – July 2025.

• Texas Commission on Jail Standards 10-Day Letter (Oct 28 2025) and Attorney General Appeal (PIA ID #40621)

   – Confirm that both the county and TCJS have attempted to withhold medical and oversight

     records from disclosure.

• Summary of Medical Evidence (Scans 1–19)

   – Documents physical injuries and unlicensed medical treatment by non-credentialed staff.

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III. ALLEGED ADMINISTRATIVE FAILURES

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1.  Misuse of public funds for noncompliant medical contracts and vendor payments.  

2.  TCJS failure to verify correction of cited deficiencies after 2019 inspection findings.  

3.  Concealment or falsification of inspection and grievance data to maintain “compliance”

    status.  

4.  Negligent supervision of federal or ARPA funding allocated for jail-health operations.  

5.  Breach of statutory duty under Tex. Gov’t Code §321.022 (failure to report suspected

    criminal activity).  

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IV. REQUESTED ACTIONS

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I respectfully request that the State Auditor’s Office:

1.  Open a performance and investigative audit of TCJS’s enforcement of medical and

    safety standards at Williamson County Jail, with specific review of fiscal and

    inspection records from 2018–2025.

2.  Determine whether state or federal funds intended for jail-medical compliance were

    diverted, misused, or applied to knowingly inadequate staffing models.

3.  Evaluate whether TCJS inspection certifications were issued despite unresolved

    violations, constituting potential administrative fraud or misrepresentation.

4.  Provide written acknowledgment of this report and assign a case or referral number so

    that follow-up documentation may be transmitted securely.

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V. CONTACT AND CONFIDENTIALITY

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I consent to the use of my name and materials for official audit purposes but request

that my identity be treated as confidential under the Texas Whistleblower Act to the extent

allowed by law.  I am prepared to provide all referenced exhibits in digital or physical form

upon request and can make myself available for interview or sworn statement.

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VI. CLOSING STATEMENT

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This request is made in good faith to protect the integrity of Texas’s correctional

oversight system and the public funds supporting it.  The issues described herein have broader

implications for state liability, federal compliance under the Civil Rights of Institutionalized

Persons Act (42 U.S.C. §1997a), and the transparency of TCJS operations.

Respectfully submitted,

__________________________

LeRoy Nellis II

Complainant / Whistleblower

cc:

Texas Commission on Jail Standards (info@tcjs.state.tx.us)

Office of the Attorney General — Open Records Division (publicrecords@oag.texas.gov)

Civil Rights Division, U.S. Department of Justice (special.litigation@usdoj.gov)

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SUPPORTING EXHIBITS — DETAILED INDEX

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EXHIBIT J — WILLIAMSON COUNTY JAIL MEDICAL & PSYCHIATRIC STAFFING RECORD AND OUTCOME ANALYSIS (2008–2025)

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Summary:

This exhibit provides a longitudinal data analysis of medical and psychiatric staffing practices

inside the Williamson County Jail over a seventeen-year period. It reconstructs physician,

psychiatrist, and mid-level provider employment records from 2008 through 2025 using verified

public contracts, county court records, job postings, and Texas Commission on Jail Standards

(TCJS) inspection data.

Findings:

• No continuous full-time physician or psychiatrist has been employed by the jail since at least 2008.  

• Psychiatric coverage has been consistently limited to 8–20 hours per week under part-time contracts.  

• Nurse practitioners and EMT-level staff provide primary care without on-site physician supervision.  

• Contract pay rates rose from $85/hr (2008) to $285/hr (2025), showing fiscal inflation but no

  improvement in service hours or oversight.  

• 2019 TCJS inspection records cite “failure to complete physician-ordered referrals.”  

• ARPA funds in 2022 were used to expand mid-level coverage, not to restore 24-hour physician access.  

• Temporal correlation exists between reduced psychiatric coverage and spikes in medical complaints,

  diabetic neglect, and death-in-custody incidents (e.g., the 2024 Johnny Tijerina wrongful-death case).  

Audit Relevance:

Demonstrates a pattern of under-staffing and administrative misrepresentation designed to appear

compliant with §273.2 (Physician Availability) while violating both the Texas Administrative Code

and constitutional standards of medical care.

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EXHIBIT K — MASTER LEGAL CLAIMS DOSSIER (2025)

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Summary:

The dossier serves as a structured evidentiary compilation documenting constitutional,

medical, and administrative violations experienced during pre-trial detention between

January 2024 and July 2025. It consolidates grievances, sworn statements, and cross-referenced

records with legal standards from U.S. Supreme Court precedent and Texas statutory law.

Content Highlights:

• Constitutional Violations: Eighth and Fourteenth Amendment infractions, including prolonged

  solitary confinement (326 days), restraint-chair punishment, and denial of medical care.  

• Medical & Psychiatric Misconduct: Administration of psychotropic and diabetic medication by

  unlicensed staff; absence of physician evaluation following injury and infection.  

• Administrative Failures: Destruction of grievance forms, falsified medical logs, and backdated

  inspection reports.  

• Federal Liability: Identifies U.S. Marshals Service intergovernmental contract exposure under

  CRIPA (42 U.S.C. §1997a).  

• Human Rights: Aligns factual evidence with international frameworks (Mandela Rules, ICCPR, CAT).  

Audit Relevance:

Establishes the factual foundation and direct witness testimony supporting claims of systematic

mismanagement, falsified oversight, and misuse of state and federal resources by Williamson County

and the TCJS inspection apparatus.

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EXHIBIT L — TEXAS COMMISSION ON JAIL STANDARDS 10-DAY LETTER (OCTOBER 28, 2025)

AND ATTORNEY GENERAL APPEAL (PIA ID #40621)

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Summary:

These documents collectively demonstrate the obstruction of public transparency and the failure

of both Williamson County and TCJS to release administrative records concerning inmate medical care.

Findings:

• On October 28, 2025, TCJS invoked Texas Gov’t Code §552.301(b) to seek an Attorney General ruling authorizing nondisclosure of records related to complaints, death-in-custody reports, and inter-agency correspondence.  

• Williamson County’s Open Records Coordinator, Katie Lentz, cited four exemptions (§552.101, §552.103, §552.108, and §552.130), claiming that nearly all requested materials were

  confidential or related to pending litigation.  

• The exemptions were applied blanket-style, without required segregation of non-exempt information, violating §552.301(e-1).  

• The county’s response withheld not only medical records but also staffing logs and TCJS

  communications—documents administrative in nature and statutorily public.  

• Appeal materials filed by the complainant (PIA ID #40621) argue that these records are public

  under §552.022(a)(2) and involve matters of urgent public concern.

Audit Relevance:

Reveals deliberate administrative resistance to lawful transparency and suggests possible

collusion between TCJS and Williamson County officials to conceal inspection deficiencies

and medical noncompliance from public view.

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EXHIBIT M — SUMMARY OF MEDICAL EVIDENCE (SCANS 1–19, 2024–2025)

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Summary:

This exhibit comprises verified diagnostic and clinical documentation collected from within the

Williamson County Jail and related external medical facilities between January 2024 and July 2025.

Each scan or form is authenticated by timestamp, facility identifier, or chain-of-custody notation.

Key Evidence:

• Scan 1 – ER Intake Form documenting acute shoulder and back trauma post-restraint confinement.

• Scan 2 – Infection Log confirming untreated abscess at injection site.

• Scans 3–6 – Medication charts showing orders marked “Resolved—No Action.”

• Scans 7–10 – Lab and vitals sheets indicating missing physician signature lines.

• Scans 11–14 – Radiology images verifying nerve and tissue damage on right side of body.

• Scans 15–19 – Nursing notes showing noncompliance with TAC §273.4 (continuity of care).

Audit Relevance:

Provides primary-source evidence that medical treatment within the facility was rendered by

unlicensed or unsupervised personnel, directly contradicting TCJS certification of compliance

and validating claims of deliberate administrative negligence.

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EXHIBIT N — CROSS-AGENCY CORRESPONDENCE AND OVERSIGHT LINKS (2019–2025)

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Summary:

A reference matrix cross-linking communications among the Williamson County Sheriff’s Office, Texas Commission on Jail Standards, Texas Attorney General’s Open Records Division, and U.S. Department of Justice Civil Rights Division.

Highlights:

• Identifies overlapping case numbers, correspondence chains, and filing dates between county,

  state, and federal entities.  

• Shows how jurisdictional gaps (state vs. federal) enabled avoidance of accountability through

  “dual sovereignty” mechanisms.  

• Includes specific TCJS staff names, email metadata, and inspection identifiers.

Audit Relevance:

Documents intergovernmental coordination failures, revealing how fragmented authority and

inconsistent data-sharing allowed recurring violations to persist without enforcement.