LeRoy Nellis

Contact

Recommendation for RICO Review Williamson County Sheriff’s Office and Coordinated Third-Party Actors

Recommendation for RICO Review

Williamson County Sheriff’s Office and Coordinated Third-Party Actors

Author: LeRoy Nellis II
Location: Austin, Texas
Date: January 2026

Purpose of This Statement

Due to the volume, continuity, and escalation of alleged criminal conduct associated with my civil-rights
complaints, I am formally recommending that state and federal authorities evaluate whether the actions of the
0,
in coordination with private jail-technology vendors, meet the statutory elements of a
Racketeer Influenced and Corrupt Organizations (RICO) enterprise.

This recommendation is submitted for investigative review only and is based on documented patterns,
observable conduct, and circumstantial evidence suggesting coordinated and ongoing activity, rather than
isolated misconduct.

Legal Framework: Why RICO Review Is Appropriate

Under 18 U.S.C. §§ 1961–1968, RICO applies when:

  1. An enterprise exists (formal or informal)
  2. The enterprise affects interstate commerce
  3. Participants engage in a pattern of racketeering activity
  4. Predicate acts are related and continuous
  5. Conduct is used to maintain control, suppress exposure, or retaliate

Government entities and their agents are not immune from RICO review when acting outside lawful authority
or in coordination with private actors for unlawful purposes.

Preliminary Enterprise Structure

Based on publicly observable facts and documented incidents, the following enterprise structure warrants
investigation:

  • Core governmental actor: Williamson County Sheriff’s Office
  • Private operational partners: Correctional technology and communications vendors providing
    AI-driven monitoring, data handling, and digital infrastructure
  • Functional objective (alleged): Control of inmate communications, suppression of complaints,
    data exploitation, and retaliation against complainants
  • Operational means: Exclusive contracts, monopolized communication systems, digital interference,
    evidence suppression, and retaliatory conduct

This configuration satisfies the threshold inquiry for an enterprise-plus-conduct analysis under RICO.

Pattern of Alleged Predicate Conduct

Taken together, the following categories form a potential pattern of racketeering activity and merit review:

1. Retaliation Against a Complainant

  • Adverse actions following protected legal activity
  • Interference with filings and public disclosures
  • Chilling of speech and access to counsel

2. Obstruction and Evidence Tampering

  • Disappearance or corruption of digital records
  • Removal of published investigative content
  • Interference occurring after notice of litigation and complaints

3. Computer-Related Offenses

  • Unauthorized interference with online systems
  • Selective targeting of legal and investigative materials
  • Conduct inconsistent with normal platform or hosting behavior

4. Wire and Electronic Communications Issues

  • Mandatory routing of communications through surveilled systems
  • AI-based interception without valid consent
  • Potential misuse of stored communications

5. Economic Exploitation Through Monopoly Control

  • Forced use of exclusive communication platforms
  • Fees imposed without meaningful choice
  • Misrepresentation of optional versus mandatory services

6. Government–Private Coordination

  • Joint participation in rights-suppressing policies
  • Delegation of governmental authority to private vendors
  • Shared benefit from continued operation of challenged systems

Continuity and Retaliatory Escalation

A critical RICO indicator is continuity. The conduct described shows:

  • Repeated acts over time
  • Escalation following legal exposure
  • Retaliation designed to deter future complaints
  • Ongoing harm rather than a completed event

The alleged conduct is not historical. It is ongoing.

Why RICO Review Is Necessary

Traditional civil-rights analysis often treats abuses as isolated violations. RICO analysis examines
systemic behavior:

  • How misconduct is organized
  • How retaliation is operationalized
  • How silence is enforced
  • How institutional and economic incentives align

When retaliation and suppression become tools of operation rather than anomalies, RICO scrutiny is appropriate.

Requested Action

I respectfully request that appropriate authorities, including the
1,
the 2,
and the 3,
consider:

  1. A preliminary RICO enterprise analysis
  2. Preservation orders for digital and communications records
  3. Review of intergovernmental and vendor contracts
  4. Examination of retaliation patterns following complaints
  5. Assessment of whether alleged predicate acts meet statutory thresholds

Closing Statement

RICO statutes exist for circumstances where misconduct is not accidental or isolated, but
coordinated, retaliatory, and sustained.

When a system responds to lawful complaints with suppression, interference, and escalation rather than
transparency, the issue is no longer policy failure—it is enterprise behavior.

This recommendation is made in the interest of lawful oversight, institutional accountability,
and public integrity.

LeRoy Nellis II
Austin, Texas

Comments

Leave a comment