LeRoy Nellis II
4845 Twin Valley Dr.
Austin, Texas 78731
Email: leroynellis2@gmail.com
Date: October 28, 2025
VIA CERTIFIED MAIL & EMAIL
Office of the Attorney General of Texas
Open Records Division
P.O. Box 12548
Austin, Texas 78711-2548
Email: publicrecords@oag.texas.gov
Subject: Acknowledgment of 10-Day Letter — Texas Commission on Jail Standards
ORR 2025-10-6 / PIA ID #40621
To the Open Records Division:
I acknowledge receipt of the Texas Commission on Jail Standards’ (TCJS) October 28, 2025 “10-Day Letter” seeking an Attorney General ruling under Texas Government Code §552.301(b) regarding my Public Information
Act request dated October 14, 2025.
Position Summary
I respectfully maintain that the requested TCJS materials—complaints, investigations, death-in-custody submissions, inspection findings, and correspondence with Williamson County officials—are administrative records central to state oversight and do not qualify for withholding under §552.108 (law-enforcement), §552.103 (litigation), or blanket privacy claims under §552.101. Consistent with §552.006 and §552.301(e-1), any confidential portions should be narrowly redacted and the remainder produced.
Key Points
1) Administrative/Oversight Nature: TCJS files document compliance monitoring under 37 Tex. Admin. Code ch. 273 (e.g., §273.2 physician availability; continuity of care; suicide prevention; recordkeeping). They are not criminal case files and thus fall outside §552.108.
2) Segregability Requirement: Even if an exemption were partially applicable, TCJS must release all reasonably segregable non-exempt portions. See §552.006; §552.301(e-1).
3) Public Information by Category: Contracts, position postings, and personnel role descriptions related to the provision of medical services are presumptively public under §552.022(a)(2) (completed reports) and longstanding ORD guidance regarding administrative oversight records.
4) Consent to Medical Information: To the extent my own medical or psychiatric records appear in TCJS’s files, I affirmatively consent to their release for oversight purposes; this removes common-law privacy barriers as to my records.
Supplemental Exhibit (Public-Interest Basis)
Enclosed as Exhibit J is a compiled, citation-based “Williamson County Jail Medical & Psychiatric Staffing Record and Outcome Analysis (2008–2025).” It demonstrates a sustained reliance on part-time psychiatric coverage (≤16–20 hrs/week) and mid-level substitution without continuous physician oversight—conditions directly regulated by §273.2 and repeatedly implicated in inspection deficiencies and adverse outcomes. This exhibit is offered to assist the Open Records Division in evaluating the substantial public interest in disclosure and the administrative (non-investigatory) character of the requested TCJS records.
Request
Please associate this acknowledgment and Exhibit J with PIA ID #40621. I intend to provide any additional comments after TCJS submits its 15-Day Letter and index. I respectfully request a ruling compelling release of non-exempt records, with only narrowly tailored redactions where required by law.
Respectfully submitted,
_________________________
LeRoy Nellis II
Complainant / Requestor
cc:
Alyssa McMahon, Program Specialist, TCJS (alyssa.mcmahon@tcjs.state.tx.us)
Civil Rights Division, U.S. Department of Justice (special.litigation@usdoj.gov)
Williamson County Sheriff’s Office (wcso-openrecords@wilcotx.gov)
Attachments:
1. TCJS “10-Day Letter” (Oct. 28, 2025)
2. Summary of Public-Interest Basis for Disclosure (Excerpt from PIA #40621 Appeal)
3. Exhibit J — Williamson County Jail Medical & Psychiatric Staffing Record and Outcome Analysis (2008–2025)
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🩺 WILLIAMSON COUNTY JAIL
MEDICAL & PSYCHIATRIC STAFFING RECORD AND OUTCOME ANALYSIS
(2008 – 2025)
By LeRoy Nellis II | Prepared October 2025
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I. OVERVIEW
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This record documents seventeen years of medical and psychiatric
staffing within the Williamson County Jail (Georgetown, Texas),
showing persistent reliance on part-time contractors and mid-level
providers rather than full-time licensed physicians.
The pattern demonstrates structural non-compliance with
Texas Administrative Code § 273.2 (24-hour physician availability)
and supports findings of deliberate indifference under
*Estelle v. Gamble* (1976) and *Farmer v. Brennan* (1994).
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II. STAFFING LEDGER (2008 – 2025)
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Year | Position / Provider | Employer / Contract | Hours | Pay Rate | Prescribing Authority | Source / Notes
—–|———————-|——————–|——–|———–|———————–|—————-
2008 | Dr. Michael Musgrove, Psychiatrist | Williamson Co – Professional Services | ≤ 20 hrs wk | $85 /hr | ✅ Licensed MD | Public contract PDF
2018 Sep 17 | Medic – Jail | Williamson Co Sheriff’s Office | FT 40 hrs | $18.83 /hr | ❌ None | GovJobs archive
2019 Mar 13 | Corrections Medical Officer | Williamson Co Sheriff’s Office | FT 40 hrs | $23.74 /hr + benefits | ❌ None | GovJobs listing
2022 Aug | Nurse Practitioner – Jail Medical Unit | Williamson Co Sheriff’s Office (ARPA funded) | FT 7-day coverage | ≈ $95 k–$110 k annual | ⚠️ Mid-level only (under MD supervision) | Williamson Co Recovery Plan (2025)
2024 FY 22–25 | Dr. Ghulam M. Khan – Psychiatric Provider | Commissioners Court Professional Services Agreement | Contract | Not listed ( $ / hr basis ) | ✅ Licensed Psychiatrist | County record PDF
2025 Sep 19 | Part-Time Psychiatrist | GreenLife Healthcare Staffing (Contractor for WilCo Jail) | Part-time / as needed (~16 hrs wk) | $110 – $135 /hr | ✅ Prescriptive Authority | Get.it · ZipRecruiter
2025 Oct | Psychiatrist Physician Ref # BD-649-01 | Adelphi Medical Staffing LLC (for WilCo Jail) | Contract (4 yrs min 16 hrs wk) | $250 – $285 /hr | ✅ Explicit (“Prescribe per Sheriff’s formulary”) | DocCafe listing · ZipRecruiter
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III. PATTERNS & KEY FINDINGS
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1️⃣ Coverage Model
• All psychiatric providers are contract-based, ≤ 20 hours per week.
• Day-to-day care handled by Nurse Practitioners and EMTs without continuous MD oversight.
2️⃣ Prescribing Authority
• Psychotropics formally restricted to psychiatrists, but intermittent presence means mid-levels and corrections staff often execute orders.
3️⃣ Pay Evolution
• 2008 – $85/hr → 2025 – $250-$285/hr (Tripled).
• Reflects inflation and difficulty recruiting for chronic under-staffed facility.
4️⃣ Inspection Context
• 2019 TCJS inspection found failure to complete physician-ordered specialist referrals (non-compliance TAC § 273.2).
5️⃣ Transparency
• No public record confirms 24-hour licensed physician coverage at any time between 2008–2025.
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IV. CHRONOLOGICAL EVENT TIMELINE (Annotated)
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2008 – Initial psychiatric contract (Dr. Musgrove, 20 hrs/wk).
2018 – Transition to internal “Medic” and CMO positions without licensure.
2019 – TCJS inspection cites failure to follow physician orders.
2022 – ARPA funds expand NP coverage to 7 days/wk (acknowledging deficit).
2023 – Spike in medical complaints and deaths; county approves temporary ARPA medical extensions.
2024 – Johnny Tijerina wrongful-death settlement ($1.15 M, medical neglect).
2024 – Dr. Khan contract renewed (FY 22–25).
2025 Sep–Oct – GreenLife and Adelphi recruitment ads posted; psychiatric vacancy continues.
————————————————————
V. OUTCOME CORRELATION (Staffing vs Incidents)
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Year / Period | Staffing Condition | Documented Outcome / Event | Interpretation
————–|——————-|—————————–|—————-
2018–2019 | Minimal medical staff; no full-time psychiatrist | TCJS inspection deficiency | Non-compliance acknowledged by state.
2020–2021 | Intermittent contract coverage | Multiple inmate grievances re: medications | Continuity of care failures emerge.
2022 | NP 7-day coverage added | Temporary reduction in complaints but no psychiatric oversight increase | Short-term stabilization.
2023 | Ongoing psychiatrist vacancy | Rise in medical neglect allegations and custodial deaths | Predictable under-coverage outcome.
2024 | Khan contract renewal (FY22-25) | Johnny Tijerina death lawsuit → $1.15 M settlement | Confirms foreseeable harm from systemic neglect.
2025 Q3–Q4 | Adelphi & GreenLife ads (16 hrs/wk coverage) | Persistent vacancy and medical injury claims (PIA #40621 evidence) | Deliberate indifference continuing.
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VI. LEGAL AND POLICY INTERPRETATION
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• Constitutional Impact: Failure to maintain 24-hour medical coverage violates Eighth and Fourteenth Amendments (*Estelle*, *Kingsley*).
• State Law Breach: Non-compliance with TAC § 273.2 and § 273.4 (physician availability and continuity of care).
• Federal Contract Liability: Because the jail operates under an Intergovernmental Service Agreement with the U.S. Marshals Service, failures trigger dual sovereign liability under CRIPA (42 U.S.C. § 1997a).
• Pattern-or-Practice Evidence: Chronological consistency (2008–2025) demonstrates deliberate policy of under-staffing, qualifying for pattern-or-practice review by DOJ Civil Rights Division.
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VII. CONCLUSION
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Williamson County Jail has operated for nearly two decades without continuous licensed medical oversight.
Part-time psychiatric contracts and mid-level substitution have become a structural norm, not an exception.
Inspection deficiencies, wrongful-death settlements, and recurring recruitment ads prove foreseeable harm and administrative cover.
These findings support claims of systemic medical neglect and unlicensed practice under both Texas and federal law.
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Prepared for publication and official record submission.
© 2025 LeRoy Nellis II All Rights Reserved
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LeRoy Nellis 
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