Dear Travis County District Attorney’s Office,

My name is LeRoy Nellis, and I am submitting a formal criminal complaint and request for prosecutorial review regarding a pattern of unlawful conduct, including medical neglect, unlicensed medical practice, administrative torture, HIPAA violations, ADA violations, and evidence falsification that occurred at the Williamson County Jail during the period of January 1, 2024 through July 11, 2025.

I am attaching (or providing upon request) a complete prosecutorial packet titled:
“WILLIAMSON COUNTY CORRUPTION — MASTER PROSECUTORIAL BINDER.”
This packet contains factual allegations, named actors, statutory violations, and exhibits.

SUMMARY OF CRIMINAL VIOLATIONS REPORTED

I am requesting immediate review into the following conduct:

1. Withholding of Life-Sustaining Medical Care

Insulin denied for 47 consecutive days
Blood glucose repeatedly exceeding critical ranges
Emergency transport refused

2. Unlicensed Practice of Medicine

Psychiatric prescribing by Dr. Ghulam M. Khan without an active Texas medical license
EMT-level staff (Davis, Ransom, Ivie) administering injections, performing clinical evaluations, and marking falsified “Seen by MD” entries

3. Forced Injection / Assault

A ~50cc forced injection administered by unlicensed personnel
Immediate neurological and systemic injury
Classified as attempted murder based on medical impact and intent

4. Administrative Torture & Retaliatory Housing

326 days of solitary confinement
MHMR/suicide-watch used punitively after passing evaluations
Environmental manipulation: cold exposure, constant lighting, sensory assault, sleep deprivation
Religious retaliation (Bible confiscated; restraint chair for 2.5 hours, paraded in front of other inmates)

5. HIPAA & Texas Privacy Law Violations

PHI disclosed to inmates, trustees, and non-medical staff
Medical conditions discussed openly during rounds
Medication lists and diagnoses released without consent

6. Record Tampering & Evidence Suppression

Medical logs altered to show physician contact that never occurred
Kites and grievances destroyed or reclassified
Camera timestamps inconsistent with logged actions
Housing records modified after injury events

7. ADA Violations

Non-ADA compliant cells (B9R1 and B7R6)
Denial of accommodations for visual impairment and diabetic status

8. Supervisory & Command-Level Liability

Includes but is not limited to:

Chief Kathleen A. Pokluda
Former Sheriff Mike Gleason
Sheriff Matthew Lindemann
Lt. Christopher Watts
Sgt. Bruce E. Young Jr.
Sgt. Rebecca Rodriguez

Their actions constitute:

Deliberate indifference
Failure to protect
Supervisor liability under §1983
Criminal negligence
Accessory liability in attempted murder by forced injection

REQUEST FOR ACTION

I respectfully request that your office:

Open a criminal investigation into the named personnel and supervisory actors.
Review the attached Master Prosecutorial Binder and its supporting exhibits.
Subpoena medical logs, housing records, grievance files, shift rosters, and video archives from January 2024 through July 2025.
Coordinate with the Texas Rangers and U.S. Department of Justice, given the pattern-and-practice implications.
Provide written confirmation of receipt and assigned investigator/contact.

This complaint involves life-threatening medical neglect, unlicensed medical practice, intentional infliction of harm, and constitutional violations against a pretrial detainee — conduct that meets criminal, civil-rights, and federal oversight thresholds.

I am prepared to supply all supporting documents, authorizations, and sworn statements necessary.

Complainant Information

/s/ LeRoy Nellis
LeRoy Nellis
4845 Twin Valley Dr.
Austin, TX 78731
Email: LeRoyNellis2@gmail.com
Phone: 512-450-1533

WILLIAMSON COUNTY JAIL

SYSTEMIC MEDICAL NEGLECT, ADMINISTRATIVE TORTURE, AND CIVIL RIGHTS VIOLATIONS

(January 1, 2024 – July 11, 2025)

MASTER PROSECUTORIAL BINDER

Prepared for Criminal Review, Civil Rights Investigation, and Government Oversight

SUBMITTED TO:

• Travis County District Attorney

• Texas Attorney General — Criminal Investigations Division

• U.S. Department of Justice — Civil Rights Division (CRIPA)

• Texas Commission on Jail Standards

• U.S. Marshals Service — IGSA Oversight Unit

SUBMITTED BY:

LeRoy Nellis

4845 Twin Valley Dr.

Austin, TX 78731

Email: LeRoyNellis2@gmail.com

Phone: 512-450-1533

DATE OF SUBMISSION:

December 4, 2025

────────────────────────────────────────────

EXECUTIVE FINDINGS — SUMMARY OF CRIMINAL, CIVIL, TECHNOLOGICAL, AND CONSTITUTIONAL VIOLATIONS

WILLIAMSON COUNTY JAIL
(January 1, 2024 – July 11, 2025)
Prepared for Prosecutorial and Oversight Review — December 4, 2025
────────────────────────────────────────────

This prosecutorial packet establishes a multi-month, multi-system, and multi-agency pattern of:

1. SYSTEMIC MEDICAL NEGLECT

• 47 consecutive days of denied insulin and glucose monitoring
• Forced injections performed by unlicensed staff resulting in near-fatal hyperglycemia, vision loss, and progressive neuropathy
• No full-time physician or psychiatrist on staff at any time during confinement
• EMTs and uncredentialed personnel allowed to make medical decisions
• Medical orders deliberately ignored, falsified, or destroyed
• ADA-related neglect in non-compliant cells (B9R1, B7R6)

Legal Exposure:
Texas Penal Code §§22.04, 22.02, 37.10, 39.04;
42 U.S.C. §1983; ADA Title II; TAC §§273–283

2. UNLICENSED PRACTICE OF MEDICINE & FORCED-INJECTION ASSAULTS

Dr. Ghulam M. Khan — Psychiatrist (No Active Medical License)

Misconduct:

• Acted as a psychiatrist without an active Texas medical license

• Conducted psychiatric evaluations while unlicensed

• Prescribed and renewed non-psychotropic and chronic-care medications without lawful authority

• Authorized medications for a pretrial detainee while legally prohibited from practicing medicine

• Failed to diagnose or respond to obvious medical emergencies (uncontrolled diabetes, neurological decline)

• Enabled unlicensed medical staff (Davis, Ransom, Miller, Ivie) to carry out clinical decisions under his name

• Participated in a system that concealed the absence of a licensed physician

• Wrote prescriptions on at least two visits despite lacking legal authority to prescribe in Texas

• Allowed or failed to correct false “Seen by MD” entries in medical logs

• Disclosed or permitted disclosure of PHI to non-medical personnel through improper documentation practices

Criminal & Civil Violations:

• Texas Occupations Code §155.001 — Unlicensed Practice of Medicine (Felony)

• Texas Health & Safety Code §481 — Unauthorized prescription of controlled substances

• Texas Penal Code §37.10 — Tampering with Government Records (prescription entries, evaluation logs)

• Texas Penal Code §22.04 — Injury by Omission (failure to treat life-threatening conditions)

• Texas Penal Code §39.04 — Civil Rights Violations of a Person in Custody

• Federal: 42 U.S.C. §1983 — Deliberate Indifference under color of law

• Federal: Prescription Fraud (DEA regulatory violations)

• HIPAA Violations:

– 45 C.F.R. §164.502(a) — Impermissible PHI disclosure

– 45 C.F.R. §164.530(c) — Failure to safeguard PHI

• Texas Medical Privacy Act — Texas HSC Ch. 181

• Tex. Occ. Code §159.002 — Breach of physician-patient confidentiality

Aggravating Factors:

• Psychotropic and non-psychotropic medications were issued despite lack of licensure

• Jail relied on his signature to justify medication plans for 550+ detainees

• His unlicensed actions allowed EMTs and jailers to pose as clinical decision-makers

• His omissions contributed to:

– 47 days of untreated hyperglycemia

– Vision loss

– Peripheral neuropathy

– Psychological deterioration

• His role perpetuated a fraudulent appearance of medical oversight, enabling systemic harm

Recommended Action:

• Immediate referral to Texas Medical Board for unlicensed practice investigation

• Criminal prosecution for unlicensed medical practice and prescription fraud

• Inclusion in §1983 civil-rights suit as a direct and proximate cause of injury

• HIPAA and Texas privacy-law enforcement referral

• Full subpoena of all psychiatric logs, prescriptions, and digital entries created under his name

• “Dr.” Alan Brooks acted with no verifiable Texas medical license
• EMT-level staff (Davis, Ransom, Ivie) performed medical injections and clearances outside legal scope
• A ~50cc forced injection in 2024 triggered immediate systemic illness — constituting aggravated assault and attempted murder by medical means
• No informed consent, no physician examination, no documentation
• Pattern matches prior detainee injuries under Texas Rangers investigation (3 deaths in 2024)

Legal Exposure:
Texas Occ. Code §155.001;
Texas Penal Code §§22.02, 22.04;
Federal Bodily Integrity doctrine under §1983

3. DELIBERATE INDIFFERENCE TO SERIOUS MEDICAL NEEDS

• Multiple medical collapses ignored
• Emergency symptoms labeled “behavioral,” “manipulative,” or “non-compliant”
• Refusal to transport to ER despite glucose >400 mg/dL
• Medical logs altered to create appearance of care that never occurred
• Chronic-care protocols for diabetes intentionally bypassed
• Use of untrained trustees and ISFs for health-related decisions

Legal Exposure:
Estelle v. Gamble; Farmer v. Brennan; §1983 deliberate-indifference standard

4. ADMINISTRATIVE TORTURE, RETALIATORY HOUSING & EXTREME CONDITIONS

• 326 days of solitary confinement unrelated to disciplinary action
• Suicide-watch placement used as punishment after passing MHMR evaluation
• Environmental coercion:
– cold cells
– constant bright lighting
– baby-music loops
– sleep disruption every 15 minutes
– deprivation of clothing or ability to cover face
• Denial of toilet function (valves shut off)
• Exposure to black mold → persistent cough requiring medication
• Retaliation for possessing a Bible → restraint chair for ~2.5 hours, wheeled past 50–100 inmates for public humiliation
• Assaults by officers:
– cuff twisting
– striking in back of head
• Sexual humiliation by a supervisor with handheld camera: “It’s okay, I’ve seen it already.”
• Torture devices (vibratory units) embedded in individual cells: B5L6, B9R1, B7R6, C14R8

Legal Exposure:
Eighth Amendment; Fourteenth Amendment; ICCPR Article 7; UN Mandela Rules 1, 43–45

5. RECORD FALSIFICATION & EVIDENCE DESTRUCTION

• Medical logs stating “Seen by MD” when no MD existed
• Medication refusals forged to hide omissions
• Suicide-watch logs falsified
• Kites systematically destroyed
• Grievances blocked or rerouted
• Intake documents altered
• Security footage selectively preserved or withheld

Legal Exposure:
Texas Penal Code §37.10; §39.04; Civil obstruction

6. HIPAA, MEDICAL-PRIVACY, AND CONFIDENTIALITY VIOLATIONS

• Medical staff disclosed diagnoses, medications, and test requests in front of inmates and officers
• PHI shared through classification, line officers, and trustees
• MHMR evaluations discussed openly
• Protected information used as retaliation

Legal Exposure:
HIPAA (45 C.F.R. §§164.502, 164.530);
Texas Health & Safety Code Ch. 181;
Tex. Occ. Code §159.002

7. FEDERAL LIABILITY UNDER IGSA DUAL SOVEREIGNTY

• Williamson County housed federal detainees under U.S. Marshals Service IGSA contract
• County and federal government share responsibility under:
– Bivens
– §1983
– ADA
– CRIPA
• Violations apply concurrently at federal and state levels

8. ARTIFICIAL INTELLIGENCE–RELATED CIVIL RIGHTS VIOLATIONS

Documented incidents during and after confinement include:
• AI voice-clone calls made using your voice
• Calls made to your mother arranging fake appointments
• Harassing telephone activity to numbers not publicly listed
• Online impersonation
• Account intrusion patterns matching automated/botnet behavior
• Attempts to interfere with legal communication
• Targeted harassment consistent with misuse of government-grade AI systems

Combined with 30 years of IT background and 21 years as a network security engineer, the patterns indicate organized, state-adjacent or state-enabled AI exploitation.

Legal Exposure:
Wire fraud, computer intrusion, unlawful surveillance, civil-rights harassment, First Amendment retaliation, and interference with legal processes.

9. CYBER INTRUSIONS & DIGITAL STALKING (POST-CUSTODY DAMAGES)

Repeated hacking incidents targeting:
• Google
• Apple/iCloud
• LinkedIn
• Instagram
• Dating platforms (resulting in bans)
• Financial accounts

Despite 100-character rotating passwords updated every 7 days, accounts were compromised — indicating high-sophistication intrusion consistent with privileged system access.

These attacks:
• obstruct legal defense
• destroy digital evidence
• create emotional distress
• violate privacy laws
• justify restraining orders and digital-forensics involvement

10. CIVIL RIGHTS VIOLATIONS BEYOND THE JAIL WALLS — RETALIATORY POLICING

Including the 2019 incident:
• 50+ deputies deployed
• Media staged
• Sheriff tweeting during response
• Harassment attempts to remove you from your neighborhood
• Officers continuing patterns into 2024–2025

These show motive, bias, and targeted enforcement that tie past administrations (Chody → Gleason → Lindemann) into a continuous chain of constitutional violations.

11. ADA VIOLATIONS & FAILURE TO ACCOMMODATE

• Placed in non-ADA cells despite medical disabilities
• Denied visual accommodation after vision loss
• Denied diabetic dietary requirements
• Denied safe access to medication and toileting

12. PATTERN-AND-PRACTICE EVIDENCE (CRIPA TRIGGER)

Williamson County reflects — and exceeds — statewide patterns of unconstitutional medical neglect.
Key elements:
• systemic medical failure
• extreme solitary confinement
• forced injections
• record falsification
• privacy violations
• retaliatory classification
• environmental torture

This satisfies DOJ pattern-or-practice requirements.

CONCLUSION — FULL LIABILITY ESTABLISHED

The violations documented satisfy every element required for:

CRIMINAL PROSECUTION

Assault, aggravated assault, evidence tampering, HIPAA crimes, civil-rights violations, attempted murder via medical assault.

FEDERAL CIVIL RIGHTS ACTION

§1983, Bivens, ADA, Rehabilitation Act.

DOJ CRIPA INTERVENTION

Pattern-or-practice investigation warranted.

STATE CIVIL LIABILITY & TORT ACTIONS

Texas Tort Claims Act, Texas Medical Privacy Act, negligence, gross negligence.

RESTRAINING ORDER

Justified due to digital harassment, impersonation, AI-generated intrusion, and ongoing threat.

VALUATION

Based on combined physical, psychological, constitutional, economic, and technological damages, the bottom limit for damages exceeds $100 million, and the upper-range valuation would support nine-figure federal civil-rights litigation.

────────────────────────────────────────────
END OF EXECUTIVE FINDINGS
────────────────────────────────────────────

────────────────────────────────────────────
MASTER SECTION INDEX
Williamson County Corruption — Prosecutorial Binder
────────────────────────────────────────────

SECTION 1 — COVER PAGE & CERTIFICATION
• Binder title, case scope, complainant information
• Certification of accuracy and submission
• Distribution list (Travis County DA, Texas AG, DOJ CRIPA, etc.)

SECTION 2 — EXECUTIVE FINDINGS
• Summary of all criminal, civil, constitutional, ADA, and HIPAA violations
• 2024–2025 systemic failures
• Attempted murder (forced injection) findings
• Dual-sovereignty and federal exposure analysis

SECTION 3 — FACTUAL OVERVIEW (January 1, 2024 – July 11, 2025)
• Timeline of custody
• Summary of misconduct categories
• Overview of medical, housing, and cyber intrusion events
• 2019 excessive-force background to establish pattern intent

SECTION 4 — STATUTORY VIOLATIONS SUMMARY
• Texas Penal Code
• Texas Occupations Code
• Texas Administrative Code
• HIPAA + Texas Health & Safety Code Ch. 181
• ADA Title II
• Federal constitutional violations (1st, 5th, 6th, 8th, 14th)

SECTION 5 — MEDICAL & PSYCHIATRIC MISCONDUCT
• Unlicensed practice
• Forced injection incident
• 47-day insulin deprivation
• Mishandled PHI
• MHMR retaliation and misuse
• Suicide-watch abuse

SECTION 6 — ADMINISTRATIVE & OVERSIGHT FAILURES
• Suppression of grievances & legal mail
• TCJS failures
• Environmental torture systems (cold, heat, valves, mold, vibration devices)
• Retaliatory classification
• ADA non-compliance (cell architecture)

SECTION 7 — PATTERN-AND-PRACTICE EVIDENCE
• Texas statewide comparison
• Federal case precedents
• Williamson County as extreme outlier
• Pattern continuation from Chody → Gleason → Lindemann eras

SECTION 8 — HOUSING & CLASSIFICATION ABUSES
• 326 days solitary confinement
• Punitive suicide-watch after passing MHMR
• Toilets disabled, showers restricted, sensory deprivation
• Forced exposure, 24/7 lighting, sleep disruption
• ADA violations in B9R1 and B7R6

SECTION 9 — ADMINISTRATIVE TORTURE SYSTEM
• Environmental manipulation
• Forced injection trauma
• Restraint chair event and humiliation
• Sexual humiliation incident
• Mold exposure
• Hands tortured via cuffs
• “Baby-song” conditioning and sleep-cycle destruction

SECTION 10 — AI & CYBER-INTRUSION HARASSMENT
• Unlawful surveillance & impersonation
• Government-grade AI harassment
• Unauthorized phone calls using cloned voice
• Hacking of Google, Apple, LinkedIn, financial accounts
• Identity disruption and interstate conduct
• IT expertise establishing credibility of detection

SECTION 11 — 2019 EXCESSIVE-FORCE OPERATION (HISTORICAL PATTERN)
• 50+ sheriff’s deputies
• Media presence and political theater
• Harassment of complainant in neighborhood
• Pattern linking Chody → Gleason → Lindemann administrations
• The relevance to 2024–2025 deliberate indifference

SECTION 12 — RECORD FALSIFICATION & EVIDENCE TAMPERING
• MD entries falsified
• Medication logs altered
• Grievances destroyed or reclassified
• Watch-status logs manipulated
• PHI distributed to inmates
• Metadata concerns and timestamp anomalies

SECTION 13 — ADA, HIPAA, & PRIVACY VIOLATIONS
• Denial of diabetic accommodations
• Blindness-related disability ignored
• PHI distributed to inmates and trustees
• HIPAA + Texas Medical Privacy Act violations
• Maximum statutory penalties

SECTION 14 — DEFENDANT LIABILITY MATRIX
• Tier 1 — Direct medical actors (Davis, Ransom, Ivie, etc.)
• Tier 2 — Supervisory actors (Watts, Young, Henderson, etc.)
• Tier 3 — Policy architects (Chody, Gleason, Lindemann, Pokluda)
• Tier 4 — Jailers & operators
• Applicable charges, penalties, and statutes

SECTION 15 — IGSA & FEDERAL LIABILITY ANALYSIS
• Bivens remedies
• Dual-sovereignty exposure
• CRIPA intervention triggers
• U.S. Marshals Service accountability

SECTION 16 — EXHIBIT SET (A–E)
• Exhibit A — Systemic Medical Abuse
• Exhibit B — Hiring & Credential Records
• Exhibit C — Oversight Failures (TCJS)
• Exhibit D — Pattern Evidence & Statewide Data
• Exhibit E — Surveillance / Timeline / Metadata Evidence
(Expandable for additional exhibits)

SECTION 17 — DAMAGES & HARM SUMMARY
• Physical harm
• Psychological trauma
• Constitutional injury
• Economic loss
• Punitive damages model ($100M+ justifiable ceiling)

SECTION 18 — LEGAL REQUESTS & REQUIRED ACTIONS
• Criminal charges
• Civil-rights litigation
• Federal investigation
• Injunctive relief
• No NDA / no confidentiality requests
• Restraining orders
• Full independent review

SECTION 19 — CLOSING STATEMENT & CERTIFICATION
• Final sworn statement
• Signatures
• Submission confirmation

────────────────────────────────────────────
END OF MASTER SECTION INDEX
────────────────────────────────────────────

TABLE OF CONTENTS

Executive Findings — Summary of Criminal, Civil, Technological, and Constitutional Violations

Systemic Medical Neglect

Unlicensed Practice of Medicine & Forced-Injection Assaults

Deliberate Indifference to Serious Medical Needs

Administrative Torture & Retaliatory Housing

Record Falsification

Federal Liability Under Dual Sovereignty

Pattern-and-Practice Evidence

Section 1 — Legal Framework & Statutory Overview

Section 2 — Constitutional Violations Summary

Section 3 — Statutory Violations Summary

Section 4 — Medical & Psychiatric Misconduct

Section 5 — Administrative & Oversight Failures

Section 6 — Systemic Pattern Evidence (Statewide & Federal)

Section 7 — Housing, Classification, and Administrative Torture

Section 8 — Digital, Phone, and AI-Driven Constitutional Violations

Section 9 — Attempted Murder via Forced Injection

Section 10 — Technological Harassment, Account Intrusions, Cyber-Targeting

Section 11 — ADA, Disability, and Medical-Accommodation Violations

Section 12 — Religious Retaliation and First Amendment Violations

Section 13 — Record Suppression, Grievance Destruction, and Evidence Manipulation

Section 14 — Defendant Liability Matrix

Section 15 — Medical Personnel Misconduct Index

Section 16 — Supervisory and Policy-Level Actors

Section 17 — Damages & Harm Summary

Section 18 — Requested Criminal, Civil, and Federal Actions

Section 19 — Defendant Exhibit Folder (Detailed Actors, Violations, Penalties)

Exhibit A — Systemic Medical Abuse Narrative (2018–2025)

Exhibit B — Medical & Psychiatric Hiring Record

Exhibit C — Oversight & TCJS Failures

Exhibit D — Systemic Pattern Comparison (Texas & Federal)

Exhibit E — Master Personnel Roster (Medical, MHMR, Jailers, Supervisors)

Exhibit F — Defendant Liability Folder

Certification & Signature Page

______________________________________________________________________________

END OF TABLE OF CONTENTS

WILLIAMSON COUNTY CORRUPTION — MASTER PROSECUTORIAL BINDER

Prepared for Criminal Review, Civil Rights Investigation, and Government Oversight

Submitted by: LeRoy Nellis

Date: December 4, 2025

Re: Systemic Medical Neglect, Administrative Torture, State-Created Danger,

Record Falsification, Unlicensed Medical Practice, and Constitutional Violations

at the Williamson County Jail (2018–2025)

This prosecutorial binder presents a comprehensive evidentiary record documenting a

multi-year pattern of institutional misconduct inside the Williamson County Jail.

The material establishes probable cause for:

• Criminal prosecution under the Texas Penal Code

• Civil liability under 42 U.S.C. §1983 for deliberate indifference

• Administrative sanctions under Texas law and TCJS regulations

• Federal intervention under the Civil Rights of Institutionalized Persons Act (CRIPA)

• Civil actions under the Texas Tort Claims Act

• Investigation into unlicensed medical practice (Texas Occ. Code §155.001)

• Violations of the Texas Administrative Code §§ 273, 275, 283

Evidence contained in this binder demonstrates:

• A deliberate medical staffing model built around no full-time physician coverage

• Reliance on unlicensed and underqualified staff for injections and medication decisions

• Falsification of government records to conceal medical absence or misconduct

• Retaliatory segregation, administrative torture, and MHMR misuse

• Systemic obstruction of grievances, legal mail, and attorney access

• A supervisory structure that enabled and concealed constitutional violations

This packet is intended for review by:

– Travis County District Attorney

– Texas Attorney General, Criminal Investigations Division

– U.S. Department of Justice, Civil Rights Division (CRIPA)

– Federal oversight and audit agencies

– Civil litigation counsel evaluating supervisory and Monell liability

– Citizens of the State of Texas and the United States of America

All statements, exhibits, and documents submitted herein are accurate to the best of

my knowledge, supported by firsthand experience, county records, public documents,

and corroborating evidence.

Submitted by:

/s/ LeRoy Nellis

4845 Twin Valley Dr.

Austin, TX 78731

Email: LeRoyNellis2@gmail.com

Phone: 512-450-1533

EXECUTIVE FINDINGS — SUMMARY OF CRIMINAL, CIVIL, AND CONSTITUTIONAL VIOLATIONS

Williamson County Jail (2018–2025)

Prepared for Prosecutorial and Federal Oversight Review

Date: December 4, 2025

______________________________________________________________________________

This binder establishes a multi-year pattern of systemic violations at the Williamson

County Jail that satisfy criminal elements under Texas law, constitutional violations

under 42 U.S.C. §1983, and federal intervention criteria under the Civil Rights of

Institutionalized Persons Act (CRIPA).

The findings below are supported by direct evidence, sworn statements, staffing records,

inspection data, and medical documentation.

────────────────────────────────────────────

1. SYSTEMIC MEDICAL NEGLECT (ONGOING)

────────────────────────────────────────────

• Insulin withheld for 48 consecutive days (May 25–July 11, 2025).

• Glucose checks refused despite readings >400 mg/dL.

• Emergency transport denied during known medical crises.

• No full-time physician or psychiatrist at any time between 2008–2025.

• Forced injections and chemical exposure resulted in permanent vision loss and neuropathy.

• Physician orders ignored or overridden by non-licensed staff.

Constitutes:

– Criminal negligence (Tex. Penal Code §6.03(d))

– Injury by omission (Tex. Penal Code §22.04)

– Deliberate indifference (Estelle; Farmer)

– Administrative Code violations §§273, 275

────────────────────────────────────────────

2. UNLICENSED PRACTICE OF MEDICINE (TEX. OCC. CODE §155.001)

────────────────────────────────────────────

• “Dr.” Alan Brooks practiced inside the jail with no medical license on record.

• EMT-level personnel (Larry R. Davis, Joshua D. Ransom) administered controlled substances,

injections, and medical clearances outside their legal scope.

• Psychiatric medications were prescribed or adjusted without personal evaluation.

Constitutes:

– Felony-level unlicensed medical practice

– False entries in medical charts

– Delegation violations under Texas law

────────────────────────────────────────────

3. RECORD FALSIFICATION & EVIDENCE TAMPERING

────────────────────────────────────────────

• Medical charts altered to state “Seen by MD” when no doctor was present.

• Digital timestamps modified after events.

• Medication refusal forms fabricated after-the-fact.

• Grievances and kites destroyed, hidden, or unlogged.

• TCJS inspection files sanitized to eliminate deficiencies.

Violations:

– Texas Penal Code §37.10 (Tampering with Government Records)

– Texas Government Code §552 (Suppression of public records)

– Civil rights violations via concealment (§1983)

────────────────────────────────────────────

4. ADMINISTRATIVE TORTURE & RETALIATION

────────────────────────────────────────────

• 326 days in solitary confinement used not for discipline, but for control and retaliation.

• Suicide-watch placement weaponized against inmates who passed MHMR evaluations.

• Restraint chair used for nonviolent religious conduct.

• Environmental manipulation: extreme cold, bright lights, sleep disruption.

Violations:

– Eighth Amendment (cruel and unusual punishment)

– Fourteenth Amendment (substantive due process)

– International standards under Mandela Rules 43–45

────────────────────────────────────────────

5. SUPERVISORY & MONELL LIABILITY — FINAL POLICYMAKER INVOLVEMENT

────────────────────────────────────────────

• Chief Kathleen A. Pokluda, final policymaker for the jail, oversaw all medical, MHMR,

custodial, grievance, and compliance functions.

• She had actual or constructive knowledge of:

– Part-time medical staffing

– Unlicensed medical practice

– Retaliatory segregation

– Suppressed grievances

– TCJS conflict of interest

– Record falsification

This establishes county liability and eliminates qualified immunity defenses.

────────────────────────────────────────────

6. FEDERAL LIABILITY VIA DUAL SOVEREIGNTY (IGSA)

────────────────────────────────────────────

• The intergovernmental contract with the U.S. Marshals Service creates joint federal–state

liability for constitutional violations.

• Bivens, §1983, and CRIPA exposure apply concurrently.

────────────────────────────────────────────

7. PATTERN-AND-PRACTICE EVIDENCE (STATEWIDE)

────────────────────────────────────────────

• Identical violations observed across Harris, Bexar, Dallas, Hidalgo, Tarrant, and Denton

Counties during 2024–2025.

• Williamson County displays unique aggravators:

– Forced injections

– Extreme solitary durations

– Falsification patterns

– Administrative obstruction

Indicates a statewide crisis and supports immediate DOJ review.

────────────────────────────────────────────

CONCLUSION

────────────────────────────────────────────

The evidence demonstrates a deliberate, systemic structure built around:

• Medical neglect

• Administrative torture

• Unlicensed practice

• Record falsification

• Supervisory concealment

• Constitutional violations

This packet supports:

• Immediate criminal investigation

• Federal civil rights action

• State-level administrative sanctions

• DOJ CRIPA intervention

______________________________________________________________________________

END OF EXECUTIVE FINDINGS

SECTION 3 — STATUTORY VIOLATIONS SUMMARY

Williamson County Jail (2018–2025)

Prepared for Criminal, Civil Rights, and Federal Oversight Review

______________________________________________________________________________

This section identifies every statutory, constitutional, and regulatory violation supported

by the evidence in this prosecutorial binder. The conduct described satisfies the legal

elements required for state criminal charges, federal civil rights litigation, administrative

sanctions, and DOJ intervention under CRIPA.

Each subsection provides:

1. The specific statute violated

2. The conduct satisfying the violation

3. The resulting legal exposure

────────────────────────────────────────────

I. TEXAS PENAL CODE VIOLATIONS

────────────────────────────────────────────

1. TEX. PENAL CODE §22.04 — INJURY TO A CHILD, ELDERLY, OR DISABLED INDIVIDUAL (BY OMISSION)

Conduct:

• Withholding insulin for 48 days.

• Denial of glucose tests during symptoms of hyperglycemia.

• Refusal to transport to ER despite blood sugar >400 mg/dL.

Legal Exposure:

• Serious bodily injury by omission.

• Enhanced penalties due to disability classification (diabetes/vision impairment).

2. TEX. PENAL CODE §22.02 — AGGRAVATED ASSAULT (SERIOUS BODILY INJURY)

Conduct:

• Forced injection by unlicensed staff (~50cc).

• Resulting permanent vision damage and neuropathy.

Legal Exposure:

• Second-degree felony or first-degree enhancement.

3. TEX. PENAL CODE §22.01 — ASSAULT (BODILY INJURY)

Conduct:

• Unlicensed personnel repeatedly administering injections and psychotropic medications.

• Medication adjustments performed without consent or oversight.

4. TEX. PENAL CODE §37.10 — TAMPERING WITH GOVERNMENT RECORDS

Conduct:

• Medical charts altered to show “Seen by MD” when no doctor was present.

• Medication refusals fabricated after the fact.

• Digital timestamps modified.

• Grievances destroyed or suppressed.

• TCJS inspection logs sanitized.

Legal Exposure:

• State jail felony to second-degree felony depending on record type.

5. TEX. PENAL CODE §39.04 — VIOLATION OF CIVIL RIGHTS OF PERSON IN CUSTODY

Conduct:

• Denial of medical care.

• Retaliatory segregation.

• MHMR misuse as punishment.

• Exposure to harm via lack of protective custody.

• Destruction of grievances.

Legal Exposure:

• State jail felony; enhanced for bodily injury.

6. TEX. PENAL CODE §6.03(d) — CRIMINAL NEGLIGENCE

Conduct:

• Known risk of diabetic harm ignored by staff and supervisors.

• Statements such as “Doctor’s not here until Monday” used to deny care.

Legal Exposure:

• Criminal negligence supporting injury charges.

────────────────────────────────────────────

II. TEXAS OCCUPATIONS CODE VIOLATIONS

────────────────────────────────────────────

1. TEX. OCC. CODE §155.001 — PRACTICE OF MEDICINE WITHOUT A LICENSE

Conduct:

• “Dr.” Alan Brooks practicing without a license (no record in Texas).

• EMTs (Davis, Ransom) conducting medical evaluations, injections, and medication decisions.

Legal Exposure:

• Third-degree felony for unlicensed practice.

2. TEX. OCC. CODE §157 — IMPROPER DELEGATION OF MEDICAL ACTS

Conduct:

• Supervising physicians absent for 96%+ of operational hours.

• Delegation of clinical decisions to individuals not authorized under Texas law.

Legal Exposure:

• Professional sanctions; liability for supervisors and county.

────────────────────────────────────────────

III. TEXAS ADMINISTRATIVE CODE VIOLATIONS

────────────────────────────────────────────

1. TAC §273.2 — PHYSICIAN AVAILABLE AT ALL TIMES (VIOLATED)

Conduct:

• No full-time physician in 17+ years.

• Part-time psychiatrists contracted for 8–20 hours per week only.

• Zero coverage during nights/weekends.

2. TAC §275 — HEALTH SERVICES OPERATIONAL STANDARDS (VIOLATED)

Conduct:

• Failure to follow physician orders.

• Failure to provide emergency transport.

• Failure to document vital signs or emergency responses.

3. TAC §283 — SUICIDE PREVENTION PLAN (VIOLATED)

Conduct:

• Suicide-watch used punitively, not clinically.

• Inmates stripped of bedding/clothes after PASSING MHMR evaluations.

Legal Exposure:

• Administrative sanctions; civil exposure; evidence of deliberate indifference.

────────────────────────────────────────────

IV. FEDERAL CONSTITUTIONAL VIOLATIONS

────────────────────────────────────────────

1. EIGHTH AMENDMENT — CRUEL AND UNUSUAL PUNISHMENT

(As applied to pre-trial detainees via the Fourteenth Amendment)

Conduct:

• Solitary confinement for 326 days.

• Forced injections.

• Medical deprivation resulting in permanent injury.

Legal Exposure:

• §1983 liability; punitive damages; loss of qualified immunity.

2. FOURTEENTH AMENDMENT — SUBSTANTIVE DUE PROCESS

Conduct:

• Punitive segregation without cause.

• Denial of medical care.

• Retaliation for grievances or medical requests.

3. FIRST AMENDMENT — INTERFERENCE WITH RELIGIOUS EXERCISE

Conduct:

• Restraint chair and segregation used in response to religious conduct.

4. FIRST AMENDMENT — INTERFERENCE WITH RIGHT TO PETITION

Conduct:

• Grievances and legal mail destroyed, intercepted, or delayed.

5. FIFTH & SIXTH AMENDMENTS — RIGHT TO COUNSEL

Conduct:

• Legal calls monitored; legal mail obstructed.

────────────────────────────────────────────

V. FEDERAL STATUTES & CIVIL RIGHTS FRAMEWORK

────────────────────────────────────────────

1. 42 U.S.C. §1983 — DELIBERATE INDIFFERENCE

Satisfied by:

• Serious medical need

• Knowledge by officials

• Disregard causing harm

2. BIVENS LIABILITY — FEDERAL ACTOR INVOLVEMENT (IGSA)

• Joint custodial agreements create dual state–federal liability.

3. CRIPA — CIVIL RIGHTS OF INSTITUTIONALIZED PERSONS ACT

Criteria for DOJ intervention all met:

• Pattern of constitutional violations

• Supervisory knowledge

• Unlicensed practice

• Record falsification

4. ADA TITLE II — FAILURE TO ACCOMMODATE DISABILITY

Conduct:

• Denial of accommodations for visual impairment and diabetes.

──────────────────────────────────────

CONCLUSION OF STATUTORY VIOLATIONS

────────────────────────────────────────────

The actions of Williamson County Jail staff and supervisors meet the legal thresholds for:

• Criminal prosecution

• Civil damages

• Supervisory liability

• Monell liability

• Federal investigation under CRIPA

This is not negligence.

This is a pattern of unlawful conduct knowingly allowed to exist.

______________________________________________________________________________

END OF SECTION 3

SECTION 4 — MEDICAL & PSYCHIATRIC MISCONDUCT

Williamson County Jail (2018–2025)

Prepared for Criminal Prosecution, Medical Licensing Review, and Federal Civil Rights Oversight

______________________________________________________________________________

Overview:

Evidence from 2018–2025 establishes that the Williamson County Jail operated a medical

program in continuous violation of Texas law, constitutional requirements, and basic

clinical standards. The medical unit was not merely under-resourced — it was engineered

to run without legal oversight, enabling unlicensed personnel to perform medical acts,

deny life-sustaining treatment, falsify records, and retaliate against detainees seeking care.

This section documents the misconduct that directly caused bodily injury, permanent

disability, and foreseeable risk of death.

────────────────────────────────────────────

I. NO FULL-TIME PHYSICIAN OR PSYCHIATRIST (2008–2025)

────────────────────────────────────────────

Document review confirms:

• ZERO full-time medical doctors on staff for at least 17 consecutive years.

• Psychiatric coverage restricted to 8–20 hours/week.

• No licensed provider available during nights/weekends — the majority of medical events.

• Nurse Practitioners and EMT-level staff functioned as the sole clinical decision-makers

for 550–600 detainees.

This violates:

• TAC §273.2 (Physician available at all times)

• Estelle v. Gamble (deliberate indifference to serious medical needs)

Operational Impact:

• Chronic-care inmates suffered deteriorating conditions.

• Acute medical emergencies were unmanaged.

• Medication schedules were inconsistent or ignored entirely.

• Intake screenings were performed by individuals without clinical authority.

The medical structure itself was unconstitutional.

────────────────────────────────────────────

II. UNLICENSED PRACTICE OF MEDICINE — CENTRAL SYSTEM FAILURE

────────────────────────────────────────────

The following misconduct is supported by staffing data, chart entries, and eyewitness accounts:

1. “Dr.” Alan Brooks

• Performed medical intake.

• Made medical decisions, diagnoses, and clearances.

• No Texas medical license found.

2. EMT-Level Staff (e.g., Larry R. Davis, Joshua D. Ransom)

• Administered injections and psychotropic medications.

• Performed medical evaluations far outside statutory scope.

• Recorded “Seen by MD” entries when no doctor was present.

• Adjusted medication dosages without physician orders.

3. Psychiatric Misconduct

• Psychiatric medications prescribed without in-person evaluations.

• Remote signatures used in place of medical judgment.

• MHMR referrals made without clinical criteria.

Violations:

• Texas Occupations Code §155.001 — unlicensed practice (felony)

• Texas Penal Code §37.10 — falsification of medical records

• TAC §§273, 275 — clinical standards violations

Outcome:

• Direct causation of injury, permanent vision loss, neuropathy, and psychological harm.

────────────────────────────────────────────

III. 47-DAY DENIAL OF DIABETIC CARE (MAY 25 – JULY 11, 2025)

────────────────────────────────────────────

This was not incompetence.

This was **deliberate withholding of life-sustaining medication**.

Documented:

• Insulin denied for 48 consecutive days.

• Glucose checks refused despite repeated symptoms of hyperglycemia.

• Blood sugar exceeded 400 mg/dL on multiple occasions.

• Request for ER transport met with:

“Doctor’s not here until Monday.”

Medical Consequences:

• Permanent vision impairment

• Progressive neuropathy

• Organ stress and near-fatal hyperglycemia

• Long-term disability

Legal Consequences:

• Criminal negligence (Tex. Penal Code §6.03(d))

• Injury by omission (Tex. Penal Code §22.04)

• Deliberate indifference (§1983)

• TAC §275 violations

This single event is sufficient to trigger DOJ investigation.

────────────────────────────────────────────

IV. FORCED INJECTION — ASSAULT WITH BODILY INJURY

────────────────────────────────────────────

Incident Summary:

• A ~50cc injection was administered by unlicensed staff without explanation or consent.

• Immediately thereafter, detainees in the unit fell ill — indicating contamination or

improper medication handling.

• Vision distortion occurred within minutes.

• No medical evaluation or documentation followed.

Violations:

• Tex. Penal Code §22.02 — Aggravated Assault (serious bodily injury)

• Tex. Occ. Code §155.001 — unlicensed practice

• Eighth and Fourteenth Amendment bodily integrity violations

This constitutes criminal conduct, not clinical care.

────────────────────────────────────────────

V. PSYCHIATRIC ABUSE — MHMR AS A WEAPON

────────────────────────────────────────────

Evidence shows that MHMR classifications were used to punish detainees requesting medical help.

Observed Patterns:

• Inmates passed MHMR evaluations but were still placed on suicide watch.

• Bedding, clothing, and environmental controls were stripped as retaliation.

• Psychiatric referrals issued not for clinical indicators, but to silence grievances.

• Threats of forced sedation used to induce compliance.

Violations:

• TAC §283 — Suicide Prevention Plan

• Fourteenth Amendment — due process

• International standards under Mandela Rules

The MHMR system was weaponized to suppress medical complaints.

────────────────────────────────────────────

VI. SOLITARY CONFINEMENT AS MEDICAL RETALIATION

────────────────────────────────────────────

Detainee was placed in solitary for:

• Requesting medical care.

• Reporting symptoms of hyperglycemia.

• Possessing religious material.

• “Non-compliance” with unlicensed staff.

Conditions documented:

• 326 total days of solitary confinement.

• Constant fluorescent lighting.

• Sleep interruption.

• Minimal access to hygiene or movement.

Legal Assessment:

• Meets federal criteria for punitive segregation without due process.

• Violates Fourteenth Amendment rights for pre-trial detainees.

• Constitutes administrative torture under Mandela Rules 43–45.

────────────────────────────────────────────

VII. MEDICAL RECORD FALSIFICATION — PATTERN EVIDENCE

────────────────────────────────────────────

Documented actions:

• Logs altered to indicate medical evaluations that never occurred.

• Medication refusal forms created days after the fact.

• Digital timestamps overwritten.

• Grievances excluded from logs.

• Suicide-watch logs falsified to appear compliant.

• Intake notes modified to conceal unlicensed practice.

Violations:

• Texas Penal Code §37.10 — Tampering with Government Records

• Texas Government Code §552 — suppression of public records

• §1983 liability for concealment

Falsification eliminates all “good faith” defenses and establishes **knowing** misconduct.

────────────────────────────────────────────

CONCLUSION:

The Williamson County Jail medical operation was not a mistake — it was a structure built

to function illegally. Clinical authority was replaced with unlicensed personnel, medical

records were altered to conceal misconduct, suicidal classifications were used coercively,

and life-sustaining care was denied with full knowledge of the consequences.

The resulting injuries, disabilities, and constitutional violations satisfy the elements for:

• Criminal prosecution

• Civil rights action

• Professional licensing sanctions

• DOJ CRIPA intervention

This section alone supports immediate legal action.

______________________________________________________________________________

END OF SECTION 4

SECTION 5 — ADMINISTRATIVE & OVERSIGHT FAILURES

Williamson County Jail (2018–2025)

Prepared for Prosecutorial Review, TCJS Oversight, and DOJ Civil Rights Division

______________________________________________________________________________

Overview:

Administrative misconduct inside the Williamson County Jail was not sporadic or accidental —

it was systemic, coordinated, and reinforced through policy, culture, and deliberate inaction.

The failures documented below prove supervisory knowledge, institutional intent, and the

absence of lawful oversight. These patterns eliminate qualified immunity and establish direct

and vicarious liability for the County and its leadership.

Chief Kathleen A. Pokluda, as the final policymaker for jail operations, had direct authority

over medical, MHMR, grievance, staffing, and compliance systems, and therefore bears legal

responsibility for the misconduct described in this section.

────────────────────────────────────────────

I. SUPPRESSION OF GRIEVANCES, MEDICAL KITES, & LEGAL MAIL

────────────────────────────────────────────

Documented Misconduct:

• Grievances disappeared after submission and were never entered into tracking logs.

• Medical kites requesting insulin, glucose checks, or emergency care were destroyed or ignored.

• Legal mail was delayed, scanned, blocked, or reclassified.

• Attorney-client communications were monitored or interrupted.

Legal Impact:

• First Amendment — violation of right to petition and access to courts

• Fourteenth Amendment — denial of due process

• Texas Penal Code §39.04 — Civil Rights violations of persons in custody

Administrative Impact:

• Prevented detainees from reporting abuse

• Concealed medical neglect

• Eliminated the primary internal oversight mechanism

This is deliberate obstruction, not administrative error.

────────────────────────────────────────────

II. TCJS INSPECTION MANIPULATION & CONFLICT OF INTEREST

────────────────────────────────────────────

Evidence Summary:

• TCJS inspections reported “no deficiencies” despite documented failures to follow physician orders.

• Compliance oversight involving former TCJS employee Kathleen A. Pokluda created a direct conflict

of interest, corrupting the integrity of the inspection process.

• Inspection periods correlated with temporary staffing increases, falsified logs, and sanitized entries.

• Medical logs were edited ahead of TCJS visits to artificially inflate compliance.

Legal Impact:

• Government Code §552 — suppression and falsification of oversight data

• Establishes knowledge of wrongdoing

• Proves policy-level concealment

Operational Impact:

• The jail passed inspections based on falsified data.

• The medical unit functioned with no real oversight for years.

────────────────────────────────────────────

III. RETALIATORY HOUSING & COERCIVE PLACEMENT (SOLITARY / MHMR / COLD CELLS)

────────────────────────────────────────────

Patterns Identified:

• Solitary confinement (326 days total) used as punishment for medical requests, grievances, or

religious conduct.

• Suicide-watch placement issued immediately after passing MHMR evaluations.

• Detainees requesting medical help were labeled “behavioral” to justify strip-cell placement.

• Environmental manipulation included extreme cold, 24/7 lighting, and sleep disruption.

Violations:

• Fourteenth Amendment — punitive segregation without due process

• Eighth Amendment — cruel and unusual punishment

• TAC §283 — misuse of suicide prevention protocols

• Mandela Rules 43–45 — administrative torture

Operational Reality:

Isolation was not a disciplinary response; it was a control mechanism.

────────────────────────────────────────────

IV. MISCLASSIFICATION OF MEDICAL EMERGENCIES AS “NON-COMPLIANT” OR “BEHAVIORAL”

────────────────────────────────────────────

Documented Cases:

• Severe hyperglycemia dismissed as “non-compliance.”

• Vision loss attributed to “refusal to participate.”

• Collapsing, weakness, or neurological symptoms filed as “behavioral defiance.”

• Requests for ER transport overridden by unlicensed staff.

Violations:

• Estelle v. Gamble — deliberate indifference

• TAC §275 — failure to provide medical care

• Fourteenth Amendment — denial of substantive due process

Impact:

This practice functioned as a cover-up mechanism for medical neglect.

────────────────────────────────────────────

V. USE OF TRUSTEES & “ISFs” AS SHADOW STAFF

────────────────────────────────────────────

Findings:

• Untrained trustees and Inmate Service Facilitators (ISFs) were used to:

– pressure inmates into saying certain statements to MHMR evaluators

– influence medical outcomes

– control unit behavior

– extract information

• These individuals exercised **de facto authority** without training, oversight, or legal status.

Legal Exposure:

• Liability for delegating governmental functions to unqualified persons

• Eighth and Fourteenth Amendment violations

• Supervisory negligence

Impact:

The jail used inmates as covert extensions of staff power — a known liability factor.

────────────────────────────────────────────

VI. DOCUMENT FALSIFICATION, SUPPRESSION, & POST-HOC FABRICATION

────────────────────────────────────────────

Established Patterns:

• Medical logs edited to indicate evaluations that never occurred.

• Medication refusal forms created after-the-fact to deflect liability.

• Suicide-watch logs fabricated to simulate continuous monitoring.

• Hospital transport logs overwritten or missing.

• Digital audit trails altered to obscure timelines.

• Grievances shredded or reclassified to bury misconduct reports.

Violations:

• Texas Penal Code §37.10 — tampering with government records

• Texas Government Code §552 — suppression of public records

• §1983 liability for concealment of unconstitutional acts

This evidentiary pattern proves knowledge and intent — not negligence.

VII. FAILURE TO PROTECT — ADMINISTRATIVE NEGLIGENCE

The Jail’s Deliberate Exposure of Detainees to Known Danger

Evidence of Failure:

Protective-custody requests were denied despite documented threats of harm.
Staff openly stated: “Protective custody is for judges and celebrities.”
Jail personnel knowingly left detainees in environments where injury, retaliation, and coercion were foreseeable and avoidable.
No meaningful risk assessments were performed, and no intervention occurred even when danger was repeatedly reported.

Legal Violations:

Fourteenth Amendment — deliberate indifference and failure to protect
Texas Penal Code §39.04 — Civil Rights of Person in Custody
State Tort Liability — foreseeable risk and preventable harm

Impact:
The facility did not merely fail to protect detainees — it affirmatively refused protection.
WCJ’s conduct transformed vulnerability into punishment and allowed retaliation, intimidation, and medical deterioration to occur in plain view.

VIII. PATTERN OF ADMINISTRATIVE TORTURE

A Coordinated System of Coercive, Retaliatory, and Illegal Punitive Measures

The following acts were not random, inadvertent, or the product of operational error.
They formed a consistent, intentional set of coercive tactics deployed across units and timeframes — collectively constituting administrative torture.

Cumulative Acts Included:

Medical deprivation, including denial of life-sustaining care
Forced injections administered by unlicensed personnel
Chemical exposure of unknown substances
Prolonged solitary confinement used as retaliation rather than classification
Manipulation of essential living conditions, including deliberate disruption of:
– toilet function
– sink access
– showers
– climate control (extreme cold/heat)
Service of food unfit for human consumption, described by detainees as “dog food”
Threats of excessive force, including officers:
– pointing a taser directly at the detainee’s face
– threatening use of a “shock glove”
Use of the restraint chair as punishment for nonviolent conduct
Operational policies that superseded state and federal law in practice, ignoring regulatory and constitutional boundaries
Denial and confiscation of religious materials, including Bibles
Theft or withholding of commissary items as punishment or coercion
Sleep disruption, including constant illumination and nighttime disturbances
Cold exposure intentionally maintained at harmful levels
MHMR misuse as retaliation, not clinical assessment
Systematic suppression of grievances, including destruction or non-entry
Threats of involuntary medication
Use of built-in vibration devices in cells (reported in B5L6, B9R1, C7R6, C14R8) to intimidate and control detainees

Legal Classification:
This coordinated pattern meets all criteria for administrative torture, recognized under:

UN Mandela Rules 1, 43, and 45
Eighth Amendment jurisprudence (cruel and unusual punishment)
Fourteenth Amendment due-process standards for pretrial detainees
CRIPA pattern-and-practice enforcement triggers

────────────────────────────────────────────

CONCLUSION — ADMINISTRATIVE LIABILITY IS ABSOLUTE

────────────────────────────────────────────

The misconduct outlined above proves that supervisory officials:

• Knew about the violations

• Had authority to prevent them

• Failed to act

• Helped conceal evidence of wrongdoing

This establishes:

• Supervisory liability

• Monell liability

• Civil rights violations under §1983

• Criminal exposure under Texas law

• Grounds for DOJ investigation

Williamson County’s failures were not operational accidents — they were institutional policy.

______________________________________________________________________________

END OF SECTION 5

SECTION 6 — SYSTEMIC PATTERN EVIDENCE

Texas Statewide Jail Data (2024–2025) & Federal Precedent

Prepared for DOJ Civil Rights Division, Texas Attorney General, and Grand Jury Review

______________________________________________________________________________

Overview:

The misconduct inside the Williamson County Jail is not isolated. Statewide data,

federal caselaw, and inter-county comparisons reveal that Texas jails repeatedly

display patterns of medical neglect, unlicensed practice, administrative concealment,

and retaliation against detainees. Williamson County matches — and in several areas

exceeds — the severity of these statewide trends.

This section establishes:

• Foreseeability

• Knowledge of risk

• Pattern-and-practice liability

• Grounds for DOJ CRIPA action

────────────────────────────────────────────

I. STATEWIDE PATTERN OF MEDICAL NEGLECT (2024–2025)

────────────────────────────────────────────

Data reviewed from TCJS, media reports, and court filings shows that the majority of

Texas jail deaths in 2024–2025 involved:

• Untreated medical emergencies

• Unlicensed or underqualified medical staff

• Delayed or denied ER transport

• Medication withholding

• Documentation inconsistencies

COUNTY-BY-COUNTY COMPARISON:

1. Harris County

– Seizure disorder detainee denied timely transport; DOJ oversight pending.

2. Dallas County

– Multiple deaths linked to failure to monitor water intoxication; Parkland Health under scrutiny.

3. Tarrant County

– Excessive-force fatalities; medical neglect patterns; multimillion-dollar civil verdicts.

4. Bexar County

– Failure-to-protect death; $2.4M settlement; unlicensed psychiatric care issues.

5. Hidalgo County

– Sepsis death after delayed treatment; chronic understaffing.

6. Denton County

– Starvation and dehydration death in solitary confinement.

7. Williamson County

– Diabetic neglect (Acosta v. Williamson County, 2024) affirming County liability.

– Forced injections, record falsification, administrative torture.

– Longest documented stretches of pretrial solitary confinement in Texas.

Conclusion:

The statewide pattern proves that jail administrators knew — or clearly should have known —

the risks associated with inadequate medical care. Williamson County amplified these risks

through deliberate staffing choices and concealment practices.

────────────────────────────────────────────

II. FEDERAL PRECEDENT SUPPORTING SYSTEMIC LIABILITY

────────────────────────────────────────────

The following cases establish controlling standards directly applicable to Williamson County:

1. Estelle v. Gamble, 429 U.S. 97 (1976)

– Medical neglect = Eighth Amendment violation.

2. Farmer v. Brennan, 511 U.S. 825 (1994)

– Officials liable when they know of and disregard substantial risks.

3. Kingsley v. Hendrickson, 576 U.S. 389 (2015)

– Pretrial detainees protected from punitive conditions and excessive force.

4. Acosta v. Williamson County, No. 21-50579 (5th Cir. 2024)

– Fifth Circuit ruling against Williamson County for diabetic neglect.

– Confirms the County had clear notice of medical care deficiencies.

– Establishes binding precedent directly applicable to current misconduct.

Outcome:

Williamson County had **actual notice** from Acosta alone that withholding diabetic care

is unconstitutional. Its continued misconduct establishes willful disregard.

────────────────────────────────────────────

III. IGSA & DUAL SOVEREIGNTY — SHARED LIABILITY WITH FEDERAL GOVERNMENT

────────────────────────────────────────────

The Intergovernmental Service Agreement (IGSA) with the U.S. Marshals Service creates:

• Jointly shared custody

• Split operational jurisdiction

• Overlapping federal/state authority

• Concurrency of liability

Legal Consequences:

Federal detainees housed at Williamson County Jail fall under:

• Bivens (federal actors)

• §1983 (state actors)

• CRIPA (institutional review)

• ADA & Rehabilitation Act (federal disability standards)

Evidence shows:

• Federal detainees experienced the same unlawful medical practices as county detainees.

• The county used “dual sovereignty” as a shield to obscure responsibility.

• Both federal and county authorities may be liable for resulting injuries.

────────────────────────────────────────────

IV. PATTERN-AND-PRACTICE INDICATORS

────────────────────────────────────────────

Indicators confirming systemic misconduct — not isolated actors:

• Seventeen-year gap with no full-time physician.

• Repeated reliance on unlicensed staff for injections and clinical decisions.

• Multiple detainees reporting identical patterns of medical neglect.

• Persistent refusal to provide ER transport for acute emergencies.

• Suppression of grievances across multiple housing units.

• Consistent falsification of logs and timestamp manipulation.

• MHMR misuse as a retaliatory tool, not a clinical instrument.

• Documented retaliation for medical requests and religious conduct.

• Direct conflicts of interest in TCJS oversight structure.

Taken together, these show deliberate operational design — not oversight failure.

────────────────────────────────────────────

V. COMPARATIVE ANALYSIS — WILLIAMSON COUNTY AS A HIGH-RISK OUTLIER

────────────────────────────────────────────

While medical neglect is common statewide, Williamson County is an extreme outlier due to:

• Length of solitary confinement (326 days — unheard of for pretrial)

• Forced, unlicensed injections causing permanent injury

• Systemic record falsification across multiple departments

• MHMR weaponization against compliant detainees

• Complete absence of 24/7 licensed physician coverage

• Document suppression and retaliatory housing patterns

• Prior federal litigation (Acosta) proving notice and deliberate disregard

Williamson County displays **aggravating factors** not found in most Texas counties —

especially the combination of forced injections, administrative torture, and falsification of records.

────────────────────────────────────────────

VI. DOJ CRIPA INTERVENTION — ALL TRIGGERS SATISFIED

────────────────────────────────────────────

Under the Civil Rights of Institutionalized Persons Act (CRIPA), the DOJ intervenes when

a facility demonstrates:

• Pattern of constitutional violations ✔

• Systemic medical neglect ✔

• Supervisory knowledge or deliberate denial ✔

• Retaliation against detainees ✔

• Document falsification ✔

• Use of unlicensed staff for medical acts ✔

• Failure to protect ✔

Williamson County satisfies every single CRIPA trigger.

────────────────────────────────────────────

CONCLUSION:

The systemic pattern evidence proves that:

• The County had knowledge of the dangers.

• The dangers were documented statewide.

• Federal precedent directly warned Williamson County.

• The County continued unlawful practices anyway.

This establishes deliberate indifference, supervisory liability, and grounds for immediate:

• DOJ investigation

• Criminal review

• Civil rights litigation

• Administrative sanctions

______________________________________________________________________________

END OF SECTION 6

EXHIBIT A

SYSTEMIC MEDICAL ABUSE, ADMINISTRATIVE TORTURE, AND DELIBERATE INDIFFERENCE

AT THE WILLIAMSON COUNTY JAIL (2018–2025)

Submitted: December 4, 2025

Prepared for Criminal Review, Federal Civil Rights Investigation, and Medical Licensing Action

______________________________________________________________________________

INTRODUCTION

This Exhibit documents a continuous pattern of illegal medical practices, retaliatory housing,

denial of life-sustaining care, forced injections, MHMR misuse, record falsification, and

administrative torture carried out inside the Williamson County Jail (WCJ) from 2018 through

2025.

The conduct described herein inflicted permanent physical injury, neurological damage, vision loss,

psychological trauma, and placed the detainee at risk of death. The violations were not isolated.

They were institutional practice — predictable, preventable, and known to supervisors.

This Exhibit serves as:

• A factual narrative for prosecutors

• A sworn-impact summary for DOJ CRIPA

• A causation timeline for medical experts

• A defendant matrix foundation for civil rights litigation

• Evidence of unlicensed practice for Texas medical licensing authorities

______________________________________________________________________________

I. MEDICAL SYSTEM STRUCTURE — BUILT TO FAIL AND TO HARM

The WCJ medical operation was designed without licensed oversight:

• No full-time physician for at least seventeen consecutive years.

• Part-time psychiatrists contracted only 8–20 hours/week.

• Nights and weekends — zero licensed clinical presence.

• EMTs and unlicensed personnel making medical decisions.

• Medication protocols delegated illegally.

• Charting performed by staff unqualified to diagnose or treat.

This structure violates:

– TAC §273.2 (physician required at all times)

– TAC §275 (health services standards)

– Estelle v. Gamble (deliberate indifference)

– Texas Occ. Code §155.001 (unlicensed practice)

The medical system was not understaffed — it was unlawful by design.

______________________________________________________________________________

II. 47-DAY DENIAL OF DIABETIC CARE (MAY 25 – JULY 11, 2025)

This period represents one of the clearest, most egregious episodes of deliberate medical neglect

ever documented in a Texas jail.

Evidence shows:

• Insulin withheld for 48 consecutive days.

• No glucose monitoring despite dizziness, vision loss, collapse, and blood sugar >400 mg/dL.

• Emergency transport denied with the statement:

“Doctor’s not here until Monday.”

• MHMR used to label the medical complaint as “behavioral.”

Medical Consequences:

• Permanent vision impairment

• Worsening neuropathy

• Organ stress

• Risk of coma and death

Legal Consequences:

• Texas Penal Code §22.04 — Injury by omission

• Criminal negligence

• Deliberate indifference under §1983

• Medical malpractice

• Violations of every clinical standard governing diabetes care

This was not a “mistake.”

It was knowing, prolonged, medically lethal neglect.

______________________________________________________________________________

III. FORCED INJECTION INCIDENT — ASSAULT WITH BODILY INJURY

A ~50cc injection was administered without:

• Explanation

• Diagnosis

• Consent

• Licensed personnel

• Medical supervision

• Chart entry

• Follow-up care

Immediately after the injection:

• Vision distortion occurred.

• Other detainees in the cellblock became ill.

• No physician examined the detainee.

• No documentation was created.

Violations:

• Tex. Penal Code §22.02 — Aggravated Assault

• Unlicensed medical practice

• Eighth and Fourteenth Amendment bodily-integrity rights

• TAC §275 (improper administration of medication)

The forced injection represents direct use of chemical force by unlicensed individuals.

______________________________________________________________________________

IV. RETALIATORY MHMR CLASSIFICATION — PSYCHIATRIC ABUSE

The MHMR system was used not for evaluation — but for retaliation:

• Passing an MHMR evaluation triggered punishment.

• Detainees requesting medical care were labeled “suicide risk.”

• Clothing, bedding, and environmental controls removed as retaliation.

• Threats of forced sedation used to control behavior.

• MHMR placements used to silence medical complaints.

This conduct violates:

• TAC §283 — suicide prevention regulations

• Fourteenth Amendment — due process

• International standards for humane treatment

This was not psychiatric care.

This was administrative torture disguised as mental health.

______________________________________________________________________________

V. SOLITARY CONFINEMENT AS A MEDICAL CONTROL MECHANISM (326 CUMULATIVE DAYS)

Solitary confinement was used not for violence or discipline — but for:

• Medical refusal

• Grievance activity

• Religious practice

• Retaliation for reporting injuries

• Controlling a medically vulnerable detainee

Conditions included:

• 24/7 fluorescent lighting

• Sleep disruption

• Extreme cold

• No access to proper bedding or hygiene

• No medical assessment during isolation

Violations:

• Eighth Amendment

• Fourteenth Amendment

• Mandela Rules 43–45

• TAC §275 — denial of adequate health services

Solitary was a weapon, not a classification.

It was used to break the detainee physically, psychologically, and medically.

______________________________________________________________________________

VI. SYSTEMATIC FALSIFICATION OF MEDICAL RECORDS

Documented actions:

• “Seen by MD” entries recorded when no doctor was present.

• Medication refusal forms fabricated days after events.

• Digital timestamps altered.

• Charts created retroactively to conceal harmful outcomes.

• Suicide-watch logs falsified to show nonexistent monitoring.

• Intake assessments modified to hide unlicensed practice.

Violations:

• Texas Penal Code §37.10 — tampering with government records

• Texas Government Code §552 — suppression of public records

• §1983 — concealment as a constitutional violation

Falsification is the strongest form of evidence for knowledge and intent.

______________________________________________________________________________

VII. MEDICAL STAFF ROSTER (2024–2025) — DEFENDANT INDEX

The following individuals participated in medical decision-making, intake, charting,

medication administration, or psychiatric referral processes inside WCJ.

Inclusion does not imply guilt, but establishes potential liability.

●Dr. Kahn — Psychiatrist (No Active Medical License)

Jamie P. Brooks — provider/intake; license status unknown

● Paige P. Altobelli — EMT/intake screener

● Ronald W. Barnett — medical staff

● Luke Cadriel — medical staff

● Larry R. Davis — EMT; performed injections; major unlicensed practice violations

● Rex A. Forehand — medical staff

● Melissa Hallett — mental-health staff

● Matthew Ivie — medical staff

● Rachael C. Lentz — medical staff

● Daniel J. Meisinger — medical staff

● Ronald S. Meissner — medical staff

● David A. Miller — intake/medical screener; conflicting documentation

● Joshua D. Ransom — “medical officer”; documented falsification patterns

● Carlos S. Wheless — medical provider

● Roberto D. Wheless — medical provider

Supervisory Accountability:

• Kathleen A. Pokluda, Chief — final policymaker responsible for all operations,

including medical, MHMR, classification, grievances, training, and compliance.

Each person listed above will appear again in:

• Defendant Matrix (Section 14)

• Unlicensed Medical Practice Table

• Scope-of-Practice Analysis

• §1983 Liability Chart

• Tort Claims Act Negligence Matrix

______________________________________________________________________________

VIII. CAUSATION & PERMANENT INJURY SUMMARY

Documented injuries include:

• Permanent vision impairment

• Neuropathy

• Chronic nerve pain

• Cognitive effects from prolonged hyperglycemia

• Psychological trauma

• Sleep disorder from extended solitary confinement

• Loss of normal glucose regulation

• Emotional distress and PTSD symptoms

These injuries are consistent with:

• Medical neglect

• Forced chemical exposure

• Inadequate diabetic management

• Prolonged sensory deprivation

Causation is direct, medically supported, and legally actionable.

______________________________________________________________________________

CONCLUSION

The medical misconduct at Williamson County Jail was not accidental.

It was structural, deliberate, and concealed through falsification and intimidation.

This Exhibit establishes:

• Criminal exposure

• Civil rights violations

• Supervisory liability

• Medical licensing violations

• State-created danger

• Administrative torture

• Unlicensed practice

• Deliberate indifference

This Exhibit alone justifies:

• Criminal charges

• Civil rights litigation

• TCJS sanctions

• Federal CRIPA intervention

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END OF EXHIBIT A

EXHIBIT B

WILLIAMSON COUNTY JAIL

MEDICAL & PSYCHIATRIC HIRING RECORD (2018–2025)

Full Audit Reconstruction & Legal Exposure Analysis

Submitted: December 4, 2025

______________________________________________________________________________

INTRODUCTION

This Exhibit provides a consolidated, litigation-ready reconstruction of hiring practices,

credentialing failures, licensing gaps, and medical staffing patterns at the Williamson

County Jail between 2018 and 2025. The evidence demonstrates that WCJ operated a

medical system that violated:

• Texas Occupations Code §155.001 (Unlicensed Practice of Medicine)

• Texas Administrative Code §§273–275 (Medical Standards)

• Federal constitutional requirements for detainee medical care

• Basic hiring and credentialing standards applicable to any clinical environment

This Exhibit establishes the County’s **actual knowledge** of risk through:

– staffing patterns,

– contract structures,

– absentee physician coverage,

– reliance on EMT-level personnel, and

– lack of verification for medical credentials.

The hiring record itself is evidence of deliberate indifference.

______________________________________________________________________________

I. MEDICAL STAFFING MODEL (2018–2025)

A SYSTEM DESIGNED WITHOUT LEGAL OVERSIGHT

Review of personnel records and county staffing patterns confirms:

1. No full-time physician from 2008–2025

– Seventeen consecutive years without a licensed doctor on-site.

– No 24-hour coverage; nights and weekends staffed exclusively by non-physicians.

2. Part-time psychiatric coverage only

Dr. Ghulam M. Khan — Psychiatrist (No Active Medical License)