Subject: Systemic Medical Misconduct, Record Tampering, Unlicensed Practice, and Defamation
Facility: Williamson County Sheriff’s Office – Medical Division (HealthSecure EMR System)
Patient: LeRoy William Nellis II (SO# 19-184130; DOB 11/24/1971)
Period Reviewed: December 20, 2024 – February 27, 2025
Prepared for: Office of the Attorney General of Texas — Public Integrity & Health Care Fraud Division
I. Purpose and Scope
This report examines medical, operational, and reputational misconduct within the Williamson County Jail Medical Division using data from the HealthSecure EMR system and related public disclosures.
The scope includes:
1. Medical adequacy and record accuracy,
2. Compliance with Texas and federal law, and
3. Defamation and public dissemination of mugshots during pending litigation.
Dataset: Over 2,100 EMR entries covering 70 days of scheduled medication passes (AM/PM/QHS).
No licensed physician or RN signatures appear anywhere in the data.
II. Key Medical Findings
Category Pattern Identified Clinical Concern
Antibiotic therapy Amoxicillin 500 mg / Doxycycline 100 mg scheduled daily (BID/TID) → 0% delivered Chronic infection left untreated >60 days
Wound care “Bandage Change – Meds Unavailable” repeatedly logged No wound management despite medical orders
Hypertension Benazepril 10 mg alternates between “Delivered,” “Missed,” and “Refused” Uncontrolled blood pressure; falsified refusals
Chronic pain Gabapentin 600 mg consistently “Delivered” Selective compliance to simulate activity
Psychotropic/sleep Trazodone & Melatonin inconsistently logged Sleep deprivation; anxiety exacerbation
Inventory control “QOH” counts increase without restock Fraudulent inventory; data falsification
Record integrity Repeated timestamps, cloned headers Tampering indicators; absent audit trail
Summary:
The EMR reveals consistent denial of antibiotics and wound care, irregular chronic-med delivery, fabricated refusals, false inventory logs, and zero licensed supervision.
III. Medical Standards Violated
1. Texas Health & Safety Code §501.148(a)-(b) — Requires adequate care by qualified personnel.
Finding: No licensed provider participation; chronic infection ignored.
2. Texas Administrative Code Title 37 §273.2 — Requires physician supervision and substitute procedures.
Finding: “Meds Unavailable” repeated without substitute orders.
3. Texas Medical Practice Act (Occ. Code §§151.002, 157.001) — Unlicensed practice and prescribing without delegation.
Finding: LVNs/CMAs logged meds without MD oversight.
4. Texas Pharmacy Act §§551.003 & 558.001 — Prohibits unlicensed dispensing of legend drugs.
Finding: EMR shows dispensing and administration by non-pharmacists.
5. Texas Penal Code §37.10 — Tampering with a Government Record.
Finding: Batch-entered identical timestamps and falsified QOH counts.
6. Texas Penal Code §32.46 — Securing Execution of Document by Deception.
Finding: False documentation submitted to TCJS for certification.
7. Texas Deceptive Trade Practices Act §17.46 — False representation of services (applies to public contractors).
Finding: Contractor billed for services not rendered.
8. Federal Law:
42 U.S.C. §1983 & §1985 — Deprivation of rights under color of law.
8th Amendment — Deliberate medical indifference.
14th Amendment — Substantive due process violation for pretrial detainees.
HIPAA 42 U.S.C. §1320d-6 & 45 C.F.R. §164.530(j) — Alteration of medical records.
IV. Evidentiary Indicators of Fraud or Tampering
Indicator Evidence Legal Relevance
Identical timestamps Dozens of daily rounds logged at same time Violates authenticity; Penal Code §37.10
Inflated QOH counts Stock increases while doses logged daily False inventory record
“Meds Unavailable” >60 days No shortage notices filed Deliberate indifference
Cloned data blocks Identical headers mid-page Evidence of copy-paste tampering
No licensed credentials Only LVN/CMA initials Unlicensed practice
V. Constitutional & Federal Civil-Rights Analysis
A. Eighth & Fourteenth Amendments — Farmer v. Brennan (511 U.S. 825, 1994)
1. Objective: Serious medical need (infection, neuropathy, hypertension).
2. Subjective: Conscious disregard — repeated “unavailable” entries despite ongoing infection.
B. 42 U.S.C. §1983 — Municipal/Contractor Liability
Policy/custom caused deprivation: No MD oversight, falsified MARs, unlicensed care.
C. 42 U.S.C. §1985(3)
Coordinated falsification to conceal misconduct = conspiracy under color of law.
D. 18 U.S.C. §287 — False Claims
If billing submitted for full “daily coverage,” EMR disproves performance.
VI. Defamation, Privacy Violations, and Mugshot Dissemination
A. Overview
In addition to internal misconduct, Williamson County has released LeRoy Nellis’s mugshots to public websites while criminal proceedings were ongoing. These websites profit from publishing arrest photos that imply guilt — permanently harming reputation and violating constitutional protections.
B. Legal Basis
1. Texas Civil Practice & Remedies Code §73.001 — Defamation
Publishing false or misleading material that harms reputation constitutes defamation.
Mugshot publication implying guilt before conviction is defamation per se.
2. Texas Government Code §552.108 — Public Information Exception
Law enforcement may withhold mugshots if release interferes with ongoing investigation or invades privacy.
Williamson County’s proactive release violates this protective intent.
3. Texas Tort Claims Act §101.021
County liability attaches when official acts cause reputational injury.
4. Fourteenth Amendment – Liberty Interest (Paul v. Davis, 424 U.S. 693, 1976)
Public branding of a person as “criminal” without conviction deprives liberty without due process.
5. 42 U.S.C. §1983 — Retaliation under Color of Law
Release may constitute retaliation for protected whistleblower activity (reporting jail misconduct).
C. Damages and Harm
Reputational: Loss of employment opportunities, community stigma.
Psychological: Anxiety, humiliation, public degradation.
Economic: Diminished earning potential from online defamation.
Constitutional: Presumption of guilt undermined by state action.
D. Causes of Action
Defamation (per se and per quod) – False implication of guilt.
Public Disclosure of Private Facts – Mugshot publication not necessary for public interest.
False Light / Invasion of Privacy – Implies criminality and moral failing.
Retaliatory Dissemination (42 U.S.C. §1983) – County used media exposure to intimidate or retaliate against whistleblower activity.
VII. Potential Criminal & Administrative Exposure
Category Applicable Law Level
Record Tampering Tex. Penal Code §37.10 Felony
Practicing Medicine Without License Occ. Code §165.151 Felony
Fraudulent Billing Tex. Penal Code §32.46; 18 U.S.C. §287 Felony
Civil-Rights Deprivation 42 U.S.C. §§1983, 1985 Federal Civil
Cruel & Unusual Punishment U.S. Const. Amend. VIII Constitutional Tort
HIPAA Record Alteration 42 U.S.C. §1320d-6 Federal
Defamation / False Light / Retaliation Tex. Civ. Prac. & Rem. Code §73.001; 42 U.S.C. §1983 Civil (State + Federal)
VIII. Causation & Damages Overview
Medical: Infection spread, hypertension damage, neuropathy, chronic pain.
Psychological: Anxiety, trauma, humiliation, loss of trust in care.
Systemic: Falsified public health data, obstructed oversight.
Economic: Fraudulent billing, reputational loss due to mugshot distribution.
IX. Recommended Investigative Actions
1. Forensic EMR Audit — export raw database with metadata and user logs.
2. Credential Verification — confirm licensure of all initials in EMR.
3. Pharmacy Reconciliation — review all antibiotic and wound-care records.
4. Chain-of-Command Interviews — Medical Administrator, Nursing Director, Sheriff’s Coordinator.
5. TCJS Cross-Reference — align inspection “all-clear” dates with falsified entries.
6. DOJ Civil Rights Referral — pattern-and-practice investigation.
7. OAG Defamation Review — investigate mugshot distribution practices.
X. Summary of Violations
Domain Statutory Reference Description
Medical Negligence / Indifference HSC §501.148; 42 U.S.C. §1983 Denial of adequate medical care
Unlicensed Practice of Medicine Occ. Code §§151, 157 Unauthorized prescribing/administration
Record Tampering Penal Code §37.10 False entries in official records
Fraudulent Billing Penal Code §32.46; 18 U.S.C. §287 False claims to government
HIPAA Violations 45 C.F.R. §164.530(j) Alteration/destruction of health data
Civil-Rights Deprivation 42 U.S.C. §§1983, 1985 Systemic deliberate indifference
Cruel & Unusual Punishment U.S. Const. Amend. VIII Denial of medical care causing injury
Defamation & False Light Tex. Civ. Prac. & Rem. Code §73.001; Paul v. Davis, 424 U.S. 693 (1976) Mugshot dissemination implying guilt; reputational harm and retaliation
XI. Conclusion
The HealthSecure EMR records, combined with public-release activity, reveal a multi-tiered systemic misconduct:
Medical: Denial of antibiotics and wound care; falsified logs.
Operational: Record tampering and unlicensed practice.
Legal: Violations of Texas Penal, Occupations, and Health & Safety Codes.
Civil-Rights: 8th & 14th Amendment breaches; §1983/§1985 deprivation.
Defamation: Mugshot publication implying guilt and damaging reputation.
These findings warrant immediate state and federal investigation, data preservation orders, and referral for criminal and civil review.
XII. Cover Letter – Office of the Attorney General
Date: November 8, 2025
To:
Office of the Attorney General of Texas
Public Integrity & Health Care Fraud Division
P.O. Box 12548
Austin, TX 78711-2548
From:
LeRoy Nellis
4845 Twin Valley Dr.
Austin, TX 78731
LeRoyNellis2@gmail.com
Re: Request for Investigation — Medical Misconduct, Record Tampering, Unlicensed Practice, and Defamation (Williamson County Jail)
Dear Public Integrity & Health Care Fraud Division:
Enclosed is my Comprehensive Healthcare and Legal Analysis Report, covering the period December 2024 – February 2025, concerning misconduct within the Williamson County Jail’s medical division. The analysis reveals systemic denial of care, record falsification, and unlicensed medical practice under the HealthSecure EMR system.
Additionally, I request review of defamation and privacy violations caused by the unauthorized release of my mugshots to commercial websites during an active legal proceeding.
This act constitutes defamation per se and violates due process liberty interests under Paul v. Davis (424 U.S. 693, 1976) and Texas Civil Practice & Remedies Code §73.001.
Requested Actions:
1. Forensic EMR and audit log preservation.
2. Verification of medical staff licensing and delegation.
3. Pharmacy reconciliation for antibiotics and wound care.
4. Examination of mugshot dissemination chain.
5. Coordination with TCJS and DOJ Civil Rights Division for full review.
Thank you for your attention. I am available to authenticate all attached records and provide sworn testimony.
Sincerely,
/s/ LeRoy Nellis
LeRoy Nellis
LeRoy Nellis 
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