Formal Complaint to the Texas Attorney General
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Exhibit J – Williamson County Jail Medical & Psychiatric Staffing Record and Outcome Analysis (2008 – 2025) Prepared by LeRoy Nellis | October 2025 This WilCo jail staffing record documents seventeen years of medical and psychiatric staffing within the Williamson County Jail (Georgetown, Texas), showing persistent reliance on part-time contractors and mid-level providers rather than full-time licensed physicians.
The pattern demonstrates structural non-compliance with Texas Administrative Code § 273.2 (24-hour physician availability) and supports findings of deliberate indifference under Estelle v. Gamble (1976) and Farmer v. Brennan (1994). See related records on the Williamson County index page and official reporting from the Texas Attorney General custodial death database . II.
WilCo Jail Staffing Ledger (2008 – 2025) Year | Position / Provider | Employer / Contract | Hours | Pay Rate | Prescribing Authority | Source / Notes 2008 — Dr.
Michael Musgrove, Psychiatrist — Williamson Co – Professional Services — ≤ 20 hrs/wk — $85/hr — Licensed MD — Public contract PDF 2018 Sep 17 — Medic – Jail — Williamson Co Sheriff’s Office — FT 40 hrs — $18.83/hr — None — GovJobs archive 2019 Mar 13 — Corrections Medical Officer — Williamson Co Sheriff’s Office — FT 40 hrs + benefits — $23.74/hr — None — GovJobs listing 2022 Aug — Nurse Practitioner – Jail Medical Unit — Williamson Co Sheriff’s Office (ARPA funded) — FT 7-day coverage — ≈ $95 k–$110 k annual — Mid-level only — Williamson Co Recovery Plan (2025) 2024 FY 22–25 — Dr.
Ghulam M.
Khan – Psychiatric Provider — Commissioners Court Professional Services Agreement — Contract — Not listed — Licensed Psychiatrist — County record PDF 2025 Sep 19 — Part-Time Psychiatrist — GreenLife Healthcare Staffing — Part-time / ~16 hrs/wk — $110 – $135/hr — Prescriptive Authority — Get.it · ZipRecruiter 2025 Oct — Psychiatrist Physician Ref # BD-649-01 — Adelphi Medical Staffing LLC — Contract (4 yrs min 16 hrs/wk) — $250 – $285/hr — Prescriptive Authority — DocCafe listing · ZipRecruiter III.
Patterns & Key Findings Coverage Model: All psychiatric providers are contract-based, ≤ 20 hours per week. Day-to-day care handled by Nurse Practitioners and EMTs without continuous MD oversight. Prescribing Authority: Psychotropics formally restricted to psychiatrists, but intermittent presence means mid-levels and corrections staff often execute orders. Pay Evolution: 2008 – $85/hr → 2025 – $250–$285/hr (tripled).
Inspection Context: 2019 TCJS inspection found failure to complete physician-ordered specialist referrals. Transparency: No public record confirms 24-hour licensed physician coverage at any time between 2008–2025. IV.
Chronological Event Timeline 2008 – Initial psychiatric contract 2018 – Transition to internal non-licensed roles 2019 – TCJS inspection deficiency 2022 – NP coverage expanded 2023 – Increase in complaints and deaths 2024 – Wrongful-death settlement 2025 – Continued recruitment and vacancy V.
Outcome Correlation 2018–2019: Minimal staff → TCJS deficiency 2020–2021: Intermittent coverage → medication complaints 2022: NP expansion → temporary stabilization 2023: Psychiatrist vacancy → increased incidents 2024: Settlement confirms risk 2025: Continued staffing gaps → ongoing claims VI.
Legal and Policy Interpretation Failure to maintain coverage impacts constitutional protections Non-compliance with Texas Administrative Code provisions Federal contract obligations may trigger dual liability Long-term pattern supports review under DOJ standards VII. Conclusion Williamson County Jail has operated for nearly two decades without continuous licensed medical oversight.
Part-time psychiatric contracts and mid-level substitution remain standard practice. Inspection deficiencies, settlements, and ongoing recruitment gaps indicate foreseeable operational risk. © 2025 LeRoy Nellis | All Rights Reserved
What the Record Shows
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