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Formal Civil Rights, Telecommunications, and AI Surveillance Complaint

Request for Federal & State Investigation — Williamson County, Texas (Allegations)

Addressees

U.S. Department of Justice
Civil Rights Division
950 Pennsylvania Avenue, NW
Washington, DC 20530

United States Attorney’s Office
Western District of Texas
601 NW Loop 410, Suite 600
San Antonio, TX 78216

Federal Communications Commission
Enforcement Bureau
45 L Street NE
Washington, DC 20554

Office of the Texas Attorney General
Law Enforcement Division / Civil Rights Enforcement
P.O. Box 12548
Austin, TX 78711-2548

Master Complaint

I. Introduction

I submit this complaint to request federal and state investigation into alleged misconduct involving

AI-enabled surveillance, telecommunications interference, harassment, analytics, and retaliation connected to

Williamson County, Texas, including the Sheriff’s Office and associated contractors/vendors involved in correctional telecommunications.

The allegations herein implicate federal civil-rights and telecommunications statutes, and Texas biometric and consumer-protection laws.

This is a good-faith request for oversight, preservation of evidence, and formal review.

II. Summary of Allegations

• Unauthorized access to and interference with personal digital accounts, consistent with account intrusion, monitoring, or manipulation.
• AI-assisted monitoring/transcription/analytics of communications while in custody beyond what was disclosed, consented to, or lawfully authorized.
• Telecommunications harassment, including repeated or suspicious calls to me and my family members consistent with spoofing or automated patterns.
• Behavioral analytics/profiling used in a retaliatory or coercive manner during pretrial detention.
• Retaliation for protected activity including grievances, complaints, and legal research activity.

III. Potential Federal Law Implications

• Title III — Wiretap Act (18 U.S.C. § 2510 et seq.)
• Stored Communications Act (18 U.S.C. § 2701 et seq.)
• Federal Communications Act (47 U.S.C. § 151 et seq.)
• 42 U.S.C. § 1983 / Fourteenth Amendment (rights deprivation under color of law)
• First Amendment Retaliation (protected speech / petition activity)

IV. Potential Texas Law Implications

• Texas Business & Commerce Code § 503 (Capture or Use of Biometric Identifiers Act)
• Texas Deceptive Trade Practices Act (DTPA)
• Texas privacy/harassment/abuse-of-office provisions as applicable

V. FCC-Specific Concerns

• Undisclosed AI monitoring/analytics within a telecom environment
• Patterns consistent with unlawful or harassing calling practices
• Carrier transparency and disclosure failures where applicable

VI. Requested Action

1. Open a formal investigation and assign an intake/complaint reference number.
2. Issue preservation notices and retain all relevant communications and access logs.
3. Review vendor contracts, AI monitoring disclosures, consent notices, and retention policies.
4. Coordinate inter-agency review where appropriate and refer for enforcement if warranted.

Sworn Declaration

I, LeRoy Nellis, declare as follows:

1. I am the complainant submitting this packet.
2. The statements made herein are based on my personal knowledge, records in my possession, and direct experiences.
3. I submit this declaration voluntarily and in good faith to request investigation and oversight.

I declare under penalty of perjury under the laws of the United States and the State of Texas that the foregoing is true and correct to the best of my knowledge and belief.

Executed on January 2, 2026, in Austin, Texas.

/s/ LeRoy Nellis

LeRoy Nellis

Exhibits

• Exhibit A — Legal Research Study: “Securus & NCIC Artificial Intelligence Systems”
  Attach as PDF. Link (optional): Download Exhibit A
• Exhibit B — Call logs / phone records / harassment indicators
• Exhibit C — Account-access anomalies / digital interference records
• Exhibit D — Grievances, complaints, and retaliation timeline
• Exhibit E — Correspondence and notices

Footer: This packet is a request for investigation and preservation of evidence. It is based on allegations and public-interest concerns.

All parties are entitled to due process.