Month: June 2024

TPI is filing complaints about PREA (Prison Rape Elimination Act) auditor failures to provide proper audits. This is one of our abbreviated deficiency reports for facilities where we have little specific documentation about violence and PREA noncompliance.

Content warning: Some of these letters describe threats and incidents of violence that may be disturbing. We will note whether each letter is considered a low, moderate, or high risk for being disturbing. We consider this letter to be low risk.

The following file is the TPI complaint against the auditor. The audit report by the auditor, which we feel was inappropriately submitted as final documentation of “compliance” with the PREA standards, can be accessed here. Some noteworthy points include:

• The auditor fails to comply with Auditor Handbook encouragement to use person-first language.
• The auditor falsely states the Hobby-Marlin Complex houses only “females.”
• The auditor failed to conduct the minimum number of targeted interviews, even though there were clearly sufficient persons at the complex meeting target criteria.
• PREA § 115.15: The auditor fails to appropriately assess cross-gender searches for compliance of this standard by refusing to acknowledge the actual gender of persons housed within the Hobby-Marlin Complex.
• PREA § 115.21: The auditor fails to appropriately assess access to forensic medical examinations given that not even 1 of the 15 allegations of sexual abuse, including 10 allegations of sexual abuse by staff, involved forensic evidence collection via SANE.
• PREA §§ 115.43 and 115.68: The auditor fails to properly assess the use of PREA protective custody within the Hobby-Marlin Complex.
• PREA §§ 115.73 and 115.86: The auditor fails to make clear statements of compliance concerning these standards. It is not clear what or whether documentation was reviewed that would indicate actual compliance.

TPI is filing complaints about PREA (Prison Rape Elimination Act) auditor failures to provide proper audits. This is one of our abbreviated deficiency reports for facilities where we have little specific documentation about violence and PREA noncompliance.

Content warning: Some of these letters describe threats and incidents of violence that may be disturbing. We will note whether each letter is considered a low, moderate, or high risk for being disturbing. We consider this letter to be low risk.

The following file is the TPI complaint against the auditor. The audit report by the auditor, which we feel was inappropriately submitted as final documentation of “compliance” with the PREA standards, can be accessed here. Some noteworthy points include:

• The auditor failed to complete the required minimum number of targeted interviews, including interviews of persons present at the unit and reporting sexual victimization.
• PREA § 115.21: The auditor does not adequately address why the documented allegation against staff for sexual abuse did not include a SANE exam.
• PREA § 115.43: The auditor makes contradictory and confusing statements about persons being housed in protective custody, indicating compliance with PREA § 115.43 was not adequately assessed.
• PREA § 115.68: The auditor makes problematic statements about this standard, indicating possible manipulation of “voluntary” and “involuntary” determinations. The auditor also indicates a failure to appropriately address PREA § 115.68 (and possibly 115.43) compliance for persons in what might be considered involuntary protective custody longer that 24 hours but less than 30 days.
• PREA § 115.71: The auditor fails to address the lack of forensic medical evidence collection in the case of a sexual abuse allegation against a staff member, indicating compliance with this standard should be questioned.

TPI is filing complaints about PREA (Prison Rape Elimination Act) auditor failures to provide proper audits. This is one of our abbreviated deficiency reports for facilities where we have little specific documentation about violence and PREA noncompliance.

Content warning: Some of these letters describe threats and incidents of violence that may be disturbing. We will note whether each letter is considered a low, moderate, or high risk for being disturbing. We consider this letter to be low risk.

The following file is the TPI complaint against the auditor. The audit report by the auditor, which we feel was inappropriately submitted as final documentation of “compliance” with the PREA standards, can be accessed here. Some noteworthy points include:

• The auditor found no corrective actions were necessary, even though presenting information indicating noncompliance.
• The auditor misrepresented the genders of persons housed at Lewis Unit.
• The auditor falsely states that 0 persons had ever been placed in segregated housing or isolation for risk of sexual victimization at Lewis Unit.
• PREA §§ 115.21: The auditor failed to address the apparent failure to offer survivors of sexual abuse access to SANE exams.
• PREA §§ 115.43 and 115.68: The auditor failed to understand and appropriately assess the use of protective custody for PREA compliance.

TPI is filing complaints about PREA (Prison Rape Elimination Act) auditor failures to provide proper audits. Under PREA § 115.401(o), auditors “shall attempt to communicate with community-based or victim advocates who may have insight into relevant conditions in the facility.” TPI has seldom been contacted concerning information we have about Texas prisons, and the National PREA Resource Center, which oversees the audit process, has failed to hold auditors accountable to this requirement. TPI has developed a simple auditor tool for auditors to see current information about any unit that we have in our system, so they do not have to even contact us. They are required to list if they tried to contact others about prison information and who they contacted. We are seeing many auditors list no contacts, or contacts that are perfunctory and likely provided no information.

Content warning: Some of these letters describe threats and incidents of violence that may be disturbing. We will note whether each letter is considered a low, moderate, or high risk for being disturbing. We consider this letter to be low risk.

The following file is the TPI complaint against the auditor. The audit report by the auditor, which we feel was inappropriately submitted as final documentation of “compliance” with the PREA standards, can be accessed here. Some noteworthy points include:

• The auditor has potential conflicts of interest.
• The auditor found no corrective actions were necessary, even though presenting information indicating noncompliance.
• The auditor misrepresented the genders of persons housed at Lewis Unit.
• The auditor did not contact sufficient community-based organizations and advocates.
• The auditor falsely states that 0 persons had ever been placed in segregated housing or isolation for risk of sexual victimization at Lewis Unit.
• The auditor failed to conduct the minimum number of interviews.
• PREA § 115.13: The auditor failed to address the impact of staff shortages on PREA compliance.
• PREA § 115.15: The auditor failed to appropriately assess cross-gender searches.
• PREA §§ 115.21 and 115.64: The auditor failed to address the apparent failure to offer survivors of sexual abuse access to SANE exams.
• PREA § 115.31: The auditor failed to appropriately assess staff PREA training practices.
• PREA § 115.41: The auditor failed to appropriately assess screening practices.
• PREA § 115.42: The auditor failed to appropriately assess use of screening information.
• PREA §§ 115.43 and 115.68: The auditor failed to understand and appropriately assess the use of protective custody for PREA complaince.
• PREA §§ 115.51, 115.52, 115.53, and 115.54: The auditor failed to appropriately assess PREA incident reporting practices.
• PREA § 115.72: The auditor failed to appropriately assess the evidentiary standard being applied in investigations of sexual violence.
• PREA § 115.73: The auditor failed to appropriately assess compliance with reporting investigation findings to incarcerated persons.
• PREA § 115.86: The auditor failed to appropriately assess required incident review by Lewis Unit.