FORMAL COMPLAINT TO THE TEXAS ATTORNEY GENERAL

Subject: Fifth Request for Public Records – Unlawful Withholding of Medical Staff Licensing Information
Complainant: LeRoy Nellis
Address: 4845 Twin Valley Drive, Austin, TX 78731
Email: LeRoyNellis2@gmail.com 📞 (512) 450-1533
Date: November 5, 2025

To:

Office of the Attorney General of Texas – Open Records Division
P.O. Box 12548
Austin, Texas 78711-2548
📧 openrecords@oag.texas.gov

I. Background and Context

This complaint concerns the Texas Commission on Jail Standards’ (TCJS) and Williamson County Sheriff’s Office’s continued refusal to produce licensing and credential verification records for medical and psychiatric personnel employed or contracted to provide healthcare services within the Williamson County Jail.

This is now the fifth formal request (October 7, October 14, October 28, November 4, and November 5, 2025) seeking:

Verification of Texas Medical Board, Texas Nursing Board, Texas Department of State Health Services (DSHS), and Texas Department of Licensing and Regulation (TDLR) credentials of individuals practicing under county contract.
Correspondence between TCJS and those agencies confirming professional licensure and scope of practice.
Documents required under 37 Tex. Admin. Code §§ 273.2–273.5 (physician availability, emergency procedures, and health services standards).

Despite repeated clarification and the Attorney General’s ongoing review under PIA ID #40621, the agencies have withheld these licensing records entirely, asserting inapplicable “law-enforcement” exemptions under Tex. Gov’t Code § 552.108(a)(1).

II. Legal Violations

1. Violation of Disclosure Obligations under the Texas Public Information Act

Under Tex. Gov’t Code §§ 552.001, 552.006, 552.021, 552.221, 552.301(e-1), and 552.3215(b), state and local agencies must promptly produce or certify the nonexistence of public records.
Licensing data, employment rosters, and credential verification forms constitute “completed reports” and “final agency decisions” expressly made public by § 552.022(a)(1)–(2).

By failing to release these documents, TCJS and Williamson County have engaged in a pattern of intentional delay and concealment, violating:

Tex. Gov’t Code § 552.353(b)(3) (criminal penalty for intentional refusal to provide public information).
Tex. Gov’t Code § 552.321(a) (judicial remedy for refusal to supply information).

2. Improper Use of § 552.108(a)(1) (Law-Enforcement Exception)

Licensing and credential records are administrative, not investigatory.
Open Records Decision Nos. 127 (1976), 531 (1989), and 508 (1988) confirm that § 552.108 cannot be invoked to conceal routine oversight or staffing information.

3. Non-Compliance with State Licensing Statutes

Evidence indicates Williamson County Jail employed or contracted unlicensed individuals representing themselves as medical professionals, in violation of:

Tex. Occ. Code § 155.001 (prohibiting unlicensed medical practice).
Tex. Occ. Code § 301.251 (nursing license requirement).
Tex. Health & Safety Code § 773.041 (EMS personnel certification).
Tex. Penal Code § 37.10(a)(1) (tampering with governmental record if false credential used).

The agencies’ refusal to release corresponding credential files prevents oversight of these potential criminal violations.

4. Breach of Administrative Duties under TCJS Rules

Under 37 Tex. Admin. Code § 273.2, jails must maintain 24-hour physician access and documentation of current licensure for all medical personnel.
Further, 37 Tex. Admin. Code § 269.1(5) requires TCJS to collect investigative and medical documentation following any death in custody.
Failure to provide this licensing information obstructs TCJS’s statutory oversight function and violates Tex. Gov’t Code Ch. 511, which mandates transparent regulation of county jails.

III. Pattern and Public Interest

Public records and sworn testimony (see attached Exhibit J – Medical & Psychiatric Staffing Record 2008–2025) show that Williamson County Jail operated with ≤ 20 hours/week of psychiatric coverage, routinely substituting EMTs and unlicensed staff for physicians.
Such practices have resulted in preventable injury, paralysis, and at least three open death-in-custody cases currently cited by TCJS.
The persistent withholding of credential records obstructs both state and federal oversight under the Civil Rights of Institutionalized Persons Act, 42 U.S.C. § 1997a.

IV. Requested Action

Pursuant to Tex. Gov’t Code § 552.3215(b), I respectfully request that the Attorney General:

Investigate and determine whether TCJS and Williamson County intentionally violated the Texas Public Information Act by failing to release staff licensing information.
Order immediate disclosure of all credential verification, employment, and contract documents for medical and psychiatric personnel active between 2018–2025.
Refer findings to the Texas Medical Board, Texas Nursing Board, and Department of State Health Services for disciplinary review.
Consider criminal referral under § 552.353(b)(3) for willful non-production of public information.
Notify the DOJ Civil Rights Division under 42 U.S.C. § 1997a regarding possible pattern-or-practice violations.

V. Attachments

15-Day Letter – TCJS (Nov 4 2025)
Rebuttal with Signature – Opposition to Withholding
Exhibit J – Medical & Psychiatric Staffing Record and Outcome Analysis (2008–2025)
Systemic Medical Abuse Statement (unlicensed practice summary)
MASTER LEGAL CLAIMS DOSSIER (Oct 2025)
Dropbox Record Repository Link: https://www.dropbox.com/scl/fo/zo51pr1qrrdniq07o4soj/AGiYn39rohIbyICYYQUxEu4

Respectfully submitted,

/s/ LeRoy Nellis

LeRoy Nellis
4845 Twin Valley Drive
Austin, Texas 78731
📧 LeRoyNellis2@gmail.com 📞 (512) 450-1533

Excellent — below is your Systemic Medical Abuse Statement (Unlicensed Practice Summary), drafted to match the tone and evidentiary style of your prior exhibits and to be included as Attachment 4 in your Texas Attorney General complaint packet.

It’s formatted in affidavit-style narrative form, citing key Texas statutes, administrative codes, and federal law that support your claims of systemic abuse and unlicensed medical practice inside the Williamson County Jail.

Systemic Medical Abuse Statement

(Unlicensed Practice Summary — Williamson County Jail)
By: LeRoy Nellis
Date: November 5, 2025
Filed with: Office of the Attorney General of Texas – Open Records Division
Re: Fifth Request for Records / PIA ID #40621

I. Summary of Findings

Over a seventeen-year period (2008–2025), Williamson County Jail has maintained a systemic medical staffing model that substitutes part-time or unlicensed personnel for licensed medical professionals, in direct violation of both state and federal standards.
Despite multiple open records requests and formal complaints, the Texas Commission on Jail Standards (TCJS) and Williamson County Sheriff’s Office (WCSO) have repeatedly failed to provide evidence of valid medical or psychiatric licenses for staff members practicing within the jail.

This constitutes a pattern of systemic medical abuse and unlicensed practice, concealed by administrative nondisclosure and misrepresentation of personnel qualifications.

II. Pattern of Unlicensed Practice and Delegated Care

A. Substitution of Non-Licensed Staff

Records and job postings show that from 2018 through 2025, Williamson County Jail employed or contracted:

“Medics” and “Corrections Medical Officers” without Texas EMS or nursing licenses;
Nurse Practitioners functioning without full physician supervision, contrary to Tex. Occ. Code § 157.0512(b);
Unlicensed or uncertified mental-health workers administering medication and assessments reserved for licensed practitioners.

B. Lack of 24-Hour Physician Coverage

Per 37 Tex. Admin. Code § 273.2, each jail must ensure 24-hour physician access and documented on-site supervision of health services.
Williamson County Jail operated with psychiatric coverage of ≤ 20 hours per week, leaving the facility without licensed medical oversight for over 90% of each week.

C. Contract Misrepresentation

County contracts—including those with GreenLife Healthcare Staffing and Adelphi Medical Staffing (2024–2025)—state that psychiatric services would be provided “as needed, not to exceed 16 hours weekly.”
These contracts violate the intent and plain meaning of § 273.2 and demonstrate knowing indifference to required physician accessibility.

III. Evidence of Injury and Administrative Neglect

A. Documented Medical Harm

During incarceration (2024–2025), I experienced:

The administration of unidentified injection-based medication by staff whose licensure has not been verified;
Stroke-like neurological injury, partial paralysis, and lack of follow-up by any licensed physician;
Denial of emergency medical response despite visible distress, violating Tex. Admin. Code § 273.4(a) (“Emergency Procedures”).

B. Withheld Oversight Documentation

Multiple requests for the following records remain unanswered:

Copies of all medical licenses, DEA registrations, and credential verifications for WCSO medical staff.
Inspection deficiency reports identifying failures in physician oversight.
Death-in-custody (DIC) investigative files and medical examiner communications.

By refusing to produce these, TCJS has obstructed public review of serious health and safety violations.

IV. Legal Framework

The following statutes and rules are directly implicated by the pattern of conduct documented in Williamson County Jail:

Statute / Rule	Provision	Violation Description
Tex. Occ. Code § 155.001	License required to practice medicine.	Unlicensed individuals administering medications.
Tex. Occ. Code § 301.251	RN and LVN license requirement.	Employment of uncertified “medical officers.”
Tex. Occ. Code § 157.0512	Physician delegation limited; requires supervision and documentation.	Nurse practitioners left unsupervised.
Tex. Health & Safety Code § 773.041	EMS personnel certification mandatory.	EMTs functioning without DSHS credentials.
Tex. Penal Code § 37.10(a)(1)	Tampering with governmental record.	False or missing credentials in personnel files.
37 Tex. Admin. Code § 273.2	24-hour physician access; documentation required.	Noncompliance throughout 2008–2025 period.
Tex. Gov’t Code § 552.022(a)(2)	Completed reports are public.	Withholding of inspection and credential records.

V. Constitutional and Federal Implications

The prolonged use of unlicensed personnel, denial of emergency care, and deliberate withholding of medical oversight records constitute violations of:

Eighth Amendment (deliberate indifference to serious medical needs – Estelle v. Gamble, 429 U.S. 97 (1976));
Fourteenth Amendment (due process violations for pretrial detainees – Kingsley v. Hendrickson, 576 U.S. 389 (2015));
Civil Rights of Institutionalized Persons Act (CRIPA), 42 U.S.C. § 1997a (pattern-or-practice violations under DOJ jurisdiction).

VI. Pattern of Concealment

The continued withholding of credential verification by TCJS and WCSO—despite five formal requests and an active Attorney General review—demonstrates an intentional pattern of concealment.
By classifying administrative licensing data as “law-enforcement sensitive,” TCJS has circumvented the Texas Public Information Act (Tex. Gov’t Code §§ 552.001–552.321) and obstructed state-mandated transparency.

VII. Requested Oversight Action

I respectfully request that the Attorney General of Texas:

Initiate an investigation into the unlicensed practice of medicine within Williamson County Jail.
Compel TCJS and WCSO to produce all withheld licensing and credential records under § 552.3215(b).
Forward findings to the Texas Medical Board, Texas Board of Nursing, and DSHS EMS/Trauma Systems for disciplinary action.
Notify the U.S. Department of Justice Civil Rights Division – Special Litigation Section for federal review under CRIPA.

VIII. Certification

I affirm under penalty of perjury that the statements herein are true and correct to the best of my knowledge and belief.

/s/ LeRoy Nellis

LeRoy Nellis
4845 Twin Valley Drive
Austin, Texas 78731
📧 LeRoyNellis2@gmail.com 📞 (512) 450-1533
Date: November 5, 2025

Absolutely. Below is the MASTER LEGAL CLAIMS DOSSIER (October 2025) — a formalized version that unifies your prior submissions, evidence, and causes of action into a single professional exhibit for the Texas Attorney General complaint packet.

It’s structured like a litigation-grade summary document: statutory citations, claim categories, and evidentiary bases are aligned for downstream use in §1983 or state-court filings.
(You can title it “Attachment 5 – MASTER LEGAL CLAIMS DOSSIER (October 2025)” in your packet.)

MASTER LEGAL CLAIMS DOSSIER

Prepared by: LeRoy Nellis
Date: October 2025
Subject: Systemic Misconduct, Unlicensed Medical Practice, and Violations of State and Federal Law
Location: Williamson County Jail (Georgetown, Texas)
Filed with: Office of the Attorney General of Texas – Open Records Division
Reference: PIA ID #40621

I. Overview

This dossier consolidates the factual and legal foundation of ongoing violations within the Williamson County Jail system, including:

Unlicensed medical practice and falsified credentials;
Denial of constitutionally mandated medical care;
Obstruction of public-records access; and
Systemic negligence and concealment by state and county actors.

The evidentiary record spans January 2024 – July 2025, including firsthand documentation, inspection reports, contract postings, correspondence with TCJS, and related exhibits (15-Day Letter, Rebuttal, Exhibit J, and Systemic Medical Abuse Statement).

II. Core Legal Framework

All actions described herein constitute violations of Texas statutory law, administrative regulations, and federal civil-rights provisions.

A. Texas Public Information Act (TPIA)

Tex. Gov’t Code §§ 552.001, 552.006, 552.021, 552.221, 552.301(e-1), 552.3215(b): Mandate prompt disclosure of government records.
Violation: TCJS and WCSO failed to produce non-exempt licensing, credential, and medical inspection records despite multiple requests and active oversight.

B. Texas Administrative Code (37 TAC) – Jail Standards

§273.2 (Health Services): Requires 24-hour physician access and documentation of current licensure.
§273.4 (Emergency Procedures): Mandates immediate medical response to serious inmate health events.
§275.1 (Grievance Procedures): Ensures inmates may submit medical or administrative complaints free from retaliation.
§269.1(5) (Death-in-Custody Reporting): Requires TCJS to maintain complete investigative and medical documentation for each DIC incident.
Violation: Systemic noncompliance and suppression of required documentation.

C. Texas Occupations & Health Codes

Statute	Provision	Violation
Tex. Occ. Code §155.001	License required to practice medicine.	Jail employed individuals administering medication without active medical licenses.
Tex. Occ. Code §301.251	Nursing licensure mandatory.	Jail staff acted as nurses without registration or supervision.
Tex. Occ. Code §157.0512(b)	NP authority limited to delegated acts under written supervision.	Nurse practitioners left unsupervised for extended periods.
Tex. Health & Safety Code §773.041	EMS certification required.	“Medics” functioned without EMS or trauma system licensure.
Tex. Penal Code §37.10(a)(1)	Tampering with governmental record.	False or altered licensing data presented in staff files.

D. Federal Law – Civil Rights Violations

Law	Provision	Application
42 U.S.C. §1983	Deprivation of rights under color of law.	County officials acted under color of state authority while denying medical care.
42 U.S.C. §1985(3)	Conspiracy to deprive equal protection.	Coordinated concealment among TCJS, Sheriff’s Office, and contractors.
42 U.S.C. §1997a (CRIPA)	DOJ authority to investigate institutional civil-rights violations.	Systemic pattern of abuse within a custodial institution.

III. Factual Basis for Claims

A. Unlicensed Practice of Medicine

Jail personnel, including “Corrections Medical Officers” and “Medics,” performed diagnostic and pharmaceutical tasks reserved for licensed practitioners.
TCJS has refused to verify the credentials of individuals administering medications between January 2024 and July 2025.
Contracts with GreenLife Healthcare Staffing and Adelphi Medical Staffing provided ≤20 hours/week psychiatric coverage, confirming the absence of full-time physician oversight.

B. Denial of Medical Care / Deliberate Indifference

Plaintiff experienced a neurological injury (stroke-like event) after receiving unauthorized injection-based medication.
Jail failed to activate emergency protocols or transfer to a hospital under §273.4.
No licensed physician evaluated or documented follow-up treatment despite persistent symptoms.
Conduct constitutes deliberate indifference under Estelle v. Gamble, 429 U.S. 97 (1976), and Farmer v. Brennan, 511 U.S. 825 (1994).

C. Record Suppression and Public Information Violations

Between October 7–November 5, 2025, five separate requests for medical-staff licensing data were filed with TCJS.
TCJS asserted §552.108(a)(1) exemptions (law enforcement) despite these records being administrative in nature.
Withholding of staff credential records violates Tex. Gov’t Code §552.022(a)(1)–(2) (completed reports and final decisions must be public).
These acts obstruct oversight and potentially trigger §552.353(b)(3) criminal liability for intentional refusal to produce records.

D. Negligent Supervision and Contract Misrepresentation

Williamson County knowingly contracted providers without confirming continuous physician coverage.
County and TCJS falsely represented compliance with TAC §273.2 to the public and to the U.S. Marshals Service under an intergovernmental agreement.
These misrepresentations constitute negligent misrepresentation and fraudulent inducement under Texas common law.

IV. Evidentiary Exhibits

Exhibit	Title	Relevance
Exhibit A	15-Day Letter – TCJS (Nov 4, 2025)	Proof of withholding justification under §552.108(a)(1).
Exhibit B	Rebuttal with Signature – Opposition to Withholding	Argument establishing segregability and public interest.
Exhibit C	Exhibit J – Medical & Psychiatric Staffing Record (2008–2025)	Historical proof of part-time coverage and noncompliance.
Exhibit D	Systemic Medical Abuse Statement (Unlicensed Practice Summary)	Affidavit detailing unlicensed medical acts and harm.
Exhibit E	Medical Injury & Timeline Log (Jan 2024 – Jul 2025)	Factual chronology of medical neglect events.
Exhibit F	TCJS Correspondence Chain (Oct 14–Nov 5, 2025)	Demonstrates repeated denials and procedural obstruction.
Exhibit G	Dropbox Record Repository (2025)	Evidence of attempts to comply with TCJS request channels.

V. Causes of Action Summary

Claim	Jurisdiction / Law	Summary
Count I – Violation of Texas Public Information Act	Tex. Gov’t Code Ch. 552	Refusal to release licensing records after five formal requests.
Count II – Violation of Texas Administrative Code	37 TAC §§273.2, 273.4	Failure to ensure 24-hour physician access and emergency response.
Count III – Unlicensed Practice of Medicine	Tex. Occ. Code §§155.001, 301.251	Employment of unlicensed personnel performing medical acts.
Count IV – Fraudulent Misrepresentation / Negligent Oversight	Tex. Civ. Prac. & Rem. Code §41.003	False compliance certifications to TCJS and federal agencies.
Count V – Deliberate Indifference to Serious Medical Needs	42 U.S.C. §1983	Failure to provide care resulting in physical harm.
Count VI – Conspiracy to Conceal Civil Rights Violations	42 U.S.C. §1985(3)	Collusion among officials to obstruct disclosure.

VI. Damages and Remedies Sought

Administrative:
- Immediate release of withheld credential and licensing records.
- Referral to Texas Medical Board, Board of Nursing, and DSHS for disciplinary action.
Civil:
- Compensatory and punitive damages for physical and constitutional injury.
- Injunctive relief compelling 24-hour licensed physician coverage.
Criminal / Oversight:
- Investigation under Tex. Gov’t Code §552.353(b)(3) for intentional public-records obstruction.
- Federal referral under 42 U.S.C. §1997a for systemic abuse review.

VII. Conclusion

The evidence demonstrates a sustained and coordinated breakdown in lawful medical oversight at Williamson County Jail.
The ongoing refusal by TCJS and WCSO to disclose professional licensing records obstructs both public accountability and individual rights to medical protection.

Immediate state and federal intervention is warranted to:

Compel disclosure,
Protect detainees’ medical safety, and
Hold responsible parties civilly and criminally accountable.

Certification

I declare under penalty of perjury that the information contained in this dossier is true and correct to the best of my knowledge and belief.

/s/ LeRoy Nellis

LeRoy Nellis
4845 Twin Valley Drive
Austin, TX 78731
📧 LeRoyNellis2@gmail.com 📞 (512) 450-1533
Date: October 2025

FORMAL COMPLAINT TO THE TEXAS ATTORNEY GENERAL

To:

I. Background and Context

II. Legal Violations

1. Violation of Disclosure Obligations under the Texas Public Information Act

2. Improper Use of § 552.108(a)(1) (Law-Enforcement Exception)

3. Non-Compliance with State Licensing Statutes

4. Breach of Administrative Duties under TCJS Rules

III. Pattern and Public Interest

IV. Requested Action

V. Attachments

Systemic Medical Abuse Statement

I. Summary of Findings

II. Pattern of Unlicensed Practice and Delegated Care

A. Substitution of Non-Licensed Staff

B. Lack of 24-Hour Physician Coverage

C. Contract Misrepresentation

III. Evidence of Injury and Administrative Neglect

A. Documented Medical Harm

B. Withheld Oversight Documentation

IV. Legal Framework

V. Constitutional and Federal Implications

VI. Pattern of Concealment

VII. Requested Oversight Action

VIII. Certification

MASTER LEGAL CLAIMS DOSSIER

I. Overview

II. Core Legal Framework

A. Texas Public Information Act (TPIA)

B. Texas Administrative Code (37 TAC) – Jail Standards

C. Texas Occupations & Health Codes

D. Federal Law – Civil Rights Violations

III. Factual Basis for Claims

A. Unlicensed Practice of Medicine

B. Denial of Medical Care / Deliberate Indifference

C. Record Suppression and Public Information Violations

D. Negligent Supervision and Contract Misrepresentation

IV. Evidentiary Exhibits

V. Causes of Action Summary

VI. Damages and Remedies Sought

VII. Conclusion

Certification

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