Formal Civil Rights, Telecommunications, and AI Surveillance Complaint
Request for Federal & State Investigation — Williamson County, Texas
Date: January 2, 2026
From:
LeRoy Nellis
4845 Twin Valley Dr.
Austin, TX 78731
To:
U.S. Department of Justice — Civil Rights Division
United States Attorney’s Office — Western District of Texas
Federal Communications Commission — Enforcement Bureau
Office of the Texas Attorney General — Civil Rights Enforcement
I. Introduction
This complaint requests a formal investigation into alleged misconduct by Williamson County, Texas, including its Sheriff’s Office and associated telecommunications and AI system vendors.
The conduct described involves surveillance, telecommunications interference, behavioral analytics, and retaliation occurring before, during, and after pretrial detention. These actions implicate federal civil rights statutes, telecommunications law, Texas statutes, and constitutional protections.
This submission is made in good faith and in the public interest.
II. Summary of Allegations
- Unauthorized access to and interference with personal digital accounts
- AI-assisted monitoring and analytics of communications without proper disclosure or authorization
- Use of telecommunications systems to place repeated or harassing calls
- Behavioral profiling used in a coercive or retaliatory manner
- Retaliation related to grievances, legal research, and attempts to seek counsel
These allegations align with documented capabilities of modern correctional telecommunications and AI systems.
III. Potential Federal Law Violations
- Wiretap Act (18 U.S.C. § 2510) — unlawful interception of communications
- Stored Communications Act (18 U.S.C. § 2701) — improper access and retention
- Federal Communications Act (47 U.S.C.) — misuse of telecom systems
- 42 U.S.C. § 1983 — deprivation of rights under color of law
- First Amendment — retaliation for protected activity
IV. Potential Texas Law Violations
- Texas Business & Commerce Code § 503 — biometric data use without consent
- Texas Deceptive Trade Practices Act — misrepresentation of services
- State privacy, harassment, and abuse-of-office provisions
V. FCC-Specific Concerns
- Undisclosed AI monitoring and analytics by telecom providers
- Repeated or spoofed calls through regulated systems
- Failure to disclose recording and analysis practices
- Potential violations of TCPA and carrier transparency rules
VI. Pattern, Practice, and Public Interest
This matter raises systemic concerns regarding AI deployment in detention environments, retaliation through surveillance, and interference with communications.
The public interest in oversight is substantial and immediate.
VII. Request for Action
- Open formal investigations into the conduct described
- Preserve all relevant records and logs
- Review compliance with applicable laws
- Coordinate inter-agency review
- Refer findings for enforcement if warranted
Sworn Declaration
I, LeRoy Nellis, declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge.
Executed January 2, 2026, Austin, Texas.
/s/ LeRoy Nellis
Exhibits
- Exhibit A — AI surveillance system research
- Exhibit B — Call logs and communication records
- Exhibit C — Account access anomalies
- Exhibit D — Grievances and retaliation timeline
- Exhibit E — Correspondence and notices
Conclusion: Technology does not override constitutional protections. This complaint is submitted to ensure accountability and oversight.