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

Prepared by LeRoy Nellis | October 2025

I. Overview

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).

II. Staffing Ledger (2008 – 2025)

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 + benefits	$23.74/hr	❌ 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 / ~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

III. Patterns & Key Findings

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 chronically under-staffed facility.

4️⃣ Inspection Context
• 2019 TCJS inspection found failure to complete physician-ordered specialist referrals (non-compliance with TAC § 273.2).

5️⃣ Transparency
• No public record confirms 24-hour licensed physician coverage at any time between 2008–2025.

IV. Chronological Event Timeline (Annotated)

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)

Period	Staffing Condition	Documented Outcome	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 (FY 22–25)	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

VI. Legal and Policy Interpretation

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 a deliberate policy of under-staffing, qualifying for pattern-or-practice review by DOJ Civil Rights Division.

VII. Conclusion

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-up.

These findings support claims of systemic medical neglect and unlicensed practice under both Texas and federal law.

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