Category: Prison services committee

TPI’s audit comment reports include abbreviated reports for facilities where TPI has few or no reports of violence, but audit report review still indicates issues that should have resulted in either the audit report not being considered final, or a corrective action negotiated between the auditor and facility.

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 low risk.

The following letter report is TPI’s report of deficiencies we were able to identify with the 2024 audit of TDCJ Hamilton Unit. The audit report can be accessed here. Some noteworthy points include:

• The auditor failed to conduct the minimum required 20 targeted interviews.
• PREA § 115.21: Due to the information in this audit report that only 1 of 7 persons reporting sexual abuse were afforded a forensic medical exam, and because no explanation to justify the near absence of such exams, it cannot be determined whether or not Hamilton Unit is 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.

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.

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.

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 low risk.

The following letter report is TPI’s report of deficiencies we were able to identify with this audit. Allred Unit is a facility that TPI feels is one of the worst in the entire Texas prison system, and the problems with this audit do nothing to alleviate that assessment. The audit report itself, which TPI feels should be considered as deficient for documenting “compliance” with the PREA standards, can be accessed here. Some noteworthy points include:

• The auditor failed to do due diligence to identify persons housed in segregated housing due to risk of sexual victimization.
• PREA § 115.15: Documentation of “opposite-gender” staff viewing surveillance cameras with point and zoom capabilities and failure to recognize the gender of transgender persons indicate compliance with this standard is not sufficiently supported.
• PREA § 115.21: Only 3 out of 44 persons alleging sexual abuse (at least 24 of which appear to have been provided within 120 hours) were provided forensic medical exams, indicating a failure to comply with this standard.
• PREA § 115.33: Possible misinformation on signage indicates potential noncompliance with this standard.
• PREA § 115.42: Apparent inappropriate assessment of providing adequate access to separate showers for transgender persons indicates compliance cannot be determined.
• PREA § 115.43: Failure to appropriately assess segregated housing and documentation of use of transient housing that constitutes segregated housing indicate unlikely compliance with this standard.
• PREA § 115.52: Documentation that not all administrative remedies received a response indicates probable noncompliance with this standard.
• PREA § 115.64: Auditor documents only 25% compliance with separation of abuser from victim, and apparently only 7% to 13% compliance with forensic medical evidence collection, indicating the facility is not compliant with this standard.
• PREA § 115.72: With less than 5% of sexual abuse allegations and less than 6% of sexual harassment allegations substantiated, it appear unlikely the facility uses the preponderance of evidence assessment required by this standard, and thus fails compliance.
• PREA § 115.73: It appears that at least 1 person was not notified of the outcome of the investigation into the report of sexual abuse, indicating noncompliance with this standard.
• PREA § 115.82: Apparent failures to provide medical and mental health services and possibly appropriate prophylaxis indicate it cannot be determined if the facility is compliant with this standard.
• PREA § 115.86: The auditor only documents 22 of the required 29 incident reviews, indicate the facility is not compliant with this standard.

TPI is filing complaints about PREA (Prison Rape Elimination Act) auditor failures to provide proper audits.

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 low risk.

The following letter report is TPI’s report of deficiencies we were able to identify with this audit. Allred Unit is a facility that TPI feels is one of the worst in the entire Texas prison system, and the problems with this audit do nothing to alleviate that assessment. The audit report itself, which TPI feels should be considered as deficient for documenting “compliance” with the PREA standards, can be accessed here. Some noteworthy points include:

• The auditor made false statements that only “males” are housed at Allred Unit.
• The auditor defined no corrective actions, in spite of evidence of need for corrective actions.
• Audit entries 38 and 39: The auditor appears to have failed to conduct adequate due diligence to determine the veracity of the claims by Allred Unit staff about the absence of documented persons with physical, cognitive, or functional disabilities.
• Audit entry 45: The auditor makes contradictory statements that either 60 or 64 persons alleged sexual abuse at Allred Unit.
• Audit entry 47: The auditor claims that both 0 and 1 person had been placed in segregated housing for risk of sexual victimization, both of which are inaccurate.
• Audit entry 48: The auditor documents that Allred Unit does not distinguish between sexual orientation and gender identity, which calls into question how Allred Unit staff can meet obligations for properly screening individuals.
• PREA § 115.15: The auditor failed to properly assess compliance with cross-gender viewing and searches.
• PREA § 115.16: Apparent manipulation of data concerning persons with physical, psychiatric, and intellectual disabilities.
• PREA § 115.22: The auditor reports that 2 out of 5 interviewees did not understand this standard, but claims the facility is in compliance.
• PREA § 115.31: Statements by the auditor indicate training ineffectiveness.
• PREA § 115.33: Statements by the auditor indicate a number of problems with training of incarcerated persons about the PREA standards.
• PREA § 115.34: Staff training in investigations appear to be lacking.
• PREA § 115.41: Auditor data indicates problems with screening persons for risk of sexual violence.
• PREA § 115.42: Auditor statements indicate questionable use of data concerning LGBTI persons housed at Allred Unit, and apparent dismissal of interviewee information that Allred Unit does not offer opportunities for transgender persons to shower separate, the assessment in this audit appears dubious.
• PREA § 115.43: Auditor information shows clear misunderstanding of how TDCJ and Allred Unit implements PREA protective custody.
• PREA § 115.52: Questionable and conflicting data indicates assessment problems related to investigations.
• PREA § 115.53: Auditor states that one-third of the incarcerated persons interviewed about their reports of sexual abuse stated they did not receive information required by this standard, which is not compliant with this standard.
• PREA § 115.64: Auditor statements indicate problems with first responder duties or with the assessment of those duties during the audit.
• PREA § 115.67: Auditor states that 2 out of 5 persons interviewed did not feel protection from retaliation, but the auditor dismissed those concerns.
• PREA § 115.72: Extremely low rates of substantiation indicate a preponderance of evidence standard is not being used, as required.
• PREA § 115.73: Auditor states at least 1 out of 6, possibly 2 out of 6, persons interviewed did not receive reports about investigation outcomes, which is not complaint with the standard.
• PREA § 115.82: Auditor states 1 of 6 persons reporting sexual abuse was not seen by medical or mental health staff and did not receive prophylaxis information, which may not be compliant with the standard.
• PREA § 115.83: Auditor reports 1 of 6 persons did not recall being offered follow-up or ongoing medical and mental health care, which is not compliant with the standard.
• PREA § 115.401: The auditor appears to have not conducted due diligence in contacting sufficient community advocates with information about Allred Unit.
• PREA §§ 115.401 and 115.402: The auditor appears to have multiple conflicts of interest, as discussed in the “auditor qualification issues” section.

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.

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 considered final an accepted as documenting “compliance” with the PREA standards, can be accessed here. Some noteworthy points include:

• 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 Memorial Unit.
• The auditor failed to conduct the minimum number of interviews.
• The auditor misrepresented the genders of persons housed at Memorial Unit.
• PREA § 115.15: Due to the misrepresentation of the genders of persons housed at Memorial Unit, the auditor failed to appropriately assess compliance with cross-gender searches and viewing.
• PREA § 115.21: The auditor reported only 10 out of 50 allegations of sexual abuse included forensic evidence collection.
• PREA § 115.42: Due to discrepancies and inconsistencies in the collection of screening data, it cannot be determined from this audit if Memorial Unit meets compliance with this standard or not.
• PREA § 115.43: Due to the numerous inaccuracies in how screening data is used to assure safety, it cannot be determined if Memorial Unit meets compliance or not.
• PREA § 115.68: Due to the failure of the auditor to address compliance with this standard in the report–stating both that not one person out of 50 alleging sexual abuse were housed in protective custody and that all staff stated anyone alleging sexual abuse would be placed in protective custody–it cannot be determined if Memorial Unit meets compliance with this standard or not.
• PREA § 115.72: Due to the limited number of substantiated allegations of sexual violence, as documented in the audit report, it appears unlikely that Memorial Unit meets compliance with PREA evidentiary standards.
• PREA § 115.86: Based on the evidence presented in this report, Memorial Unit is not compliant with this standard, in spite of auditor claims otherwise.