Prison advocacy: PREA noncompliance at TDCJ Pack Unit

TPI has been reviewing PREA audits of TDCJ facilities for over a year at the time of this post, and the number of inaccuracies, mistakes, problems, and other issues–none of which seem to be being addressed–is amazing. These reports even provide information indicating clear deficiencies, yet the auditors are not requiring corrective actions.

TPI has developed a simple auditor tool for auditors to see current information about any unit that we have in our system to help give them a heads up about any problems we see, but as far as we know, no auditor to date has used this tool.

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 moderate risk. The information in this report includes several instances of abusive misgendering by the auditor that may be disturbing to some persons.

The following letter report is TPI’s report of deficiencies we were able to identify with the 2024 audit of TDCJ Pack Unit. TPI does not have a lot of date for this facility, but there are some significant problems identified by the reports we do have. The audit report can be accessed here. Some noteworthy points include:

  • The auditor falsely states that the population of Pack Unit consists of “males” only when we know there are transgender persons housed there.
  • The auditor failed to conduct the minimum required 20 targeted interviews.
  • The auditor failed to appropriately identify persons placed in segregated housing for risk of sexual victimization.
  • Problems identified by TPI that indicate manipulation of investigations of sexual violence, as well as the difficult-to-accept low numbers of documented sexual harassment and sexual abuse at the facility, indicate substantial problems with PREA compliance.
  • PREA § 115.11: In this comment report, TPI has identified what are potentially very significant and fundamental problems with the identification, investigation, and documentation of sexual violence at Pack Unit. Based on the failure of the audit to address these issues, Pack Unit cannot be considered compliant with this standard.
  • PREA § 115.15: Due to the failure to appropriately identify the genders of persons housed at Pack Unit, the auditor failed to properly assess compliance with PREA limitations on cross-gender viewing and searches. Due to the failure to recognize actual genders, Pack Unit cannot be considered compliant with this standard.
  • PREA § 115.21: Due to the information in this audit report that not one forensic medical exam was conducted in response to allegations of sexual abuse at Pack Unit, with no explanation to justify the complete absence of forensic medical evidence collection, it cannot be determined whether or not Pack Unit is compliant with this standard.
  • PREA § 115.22: Due reports to TPI concerning sexual harassment incidents that were excluded from the PREA audit by the auditor, the facility, or both, TPI asserts that the audit of this standard was clearly deficient, and that Pack Unit cannot be considered complaint with this standard.
  • PREA § 115.31: Due to both the failure by the auditor to ask incarcerated interviewees about staff actions that may indicate training problems, and a report to TPI that clearly indicates a problem with employee training, Pack Unit cannot be considered compliant with this standard.
  • PREA §§ 115.43 and 115.68: Due to the fact that the auditor failed to understand how PREA protective custody applies to housing in Pack Unit, and the fact that Pack Unit staff manipulated facts concerning how housing at the unit meets the protective custody definition, Pack Unit cannot be considered to be compliant with this standard.

Prison advocacy: PREA noncompliance at TDCJ Boyd Unit

TPI has been reviewing PREA audits of TDCJ facilities for about a year at the time of this post, and the number of inaccuracies, mistakes, problems, and other issues is amazing. These reports even provide information indicating clear deficiencies, yet the auditors are not requiring corrective actions.

TPI has developed a simple auditor tool for auditors to see current information about any unit that we have in our system to help give them a heads up about any problems we see, but as far as we know, no auditor to date has used this tool.

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 moderate risk. The information in this report includes several instances of abusive misgendering by the auditor that may be disturbing to some persons.

The following letter report is TPI’s report of deficiencies we were able to identify with this audit. TPI does not have a lot of date for Boyd Unit, so much of the deficiencies are based on the auditor’s own statements, mistatements, and evident failures to appropriately apply the PREA standards. The audit report can be accessed here. Some noteworthy points include:

  • There appear to be conflicts of interest for both the auditor and the auditor’s employer.
  • The auditor makes statements about transgender persons that indicate bias against and disregard of transgender persons, statements that indicate the auditor cannot assess noncompliance, at a minimum, with PREA § 115.31 requirements for effective and professional communication with LGBTI incarcerated persons.
  • The auditor fails to appropriately consider the gender of the population at Boyd Unit for PREA purposes.
  • Audit entry 47: The auditor falsely states that there were 0 persons ever placed in segregated housing at Boyd Unit.
  • Audit entry 69: The auditor fails to conduct targeted interviews with the minimum number of persons placed in segregated housing at Boyd Unit.
  • PREA § 115.15: The auditor fails to appropriately assess cross-gender viewing and searches at Boyd Unit, in clear defiance of DOJ instructions about how to consider gender for this standard.
  • PREA § 115.21: The auditor fails to explain why only 3 out of at least 12 persons were provided access to forensic medical examinations when the standards state that all victims of sexual abuse should be afforded access to such evidence collection.
  • PREA § 115.31: The auditor fails to appropriately assess whether training is “tailored to the gender” of persons housed at Boyd Unit, erasing the existence of transgender persons housed at the facility in the process.
  • PREA §§ 115.43 and 115.68: The auditor fails to assess any provision of this standard with the appropriate understanding of how segregated housing is used in TDCJ in response to risk or allegations of sexual violence.
  • PREA §§ 115.64 and 115.65: The auditor fails to address why only 3 out of at least 12 victims of sexual abuse were provided access to forensic medical exams, which indicates a problem with one or both of these standards.
  • PREA § 115.82: The auditor fails to explain why only 1 out of 18 victims of sexual abuse received prophylactic medications or, seemingly, subsequent treatment for sexually transmitted infections.