Category: Prison services committee

TPI is submitting comment reports about deficient PREA audits of Texas prisons. We note that even though funding has been cut for all PREA support activities by the current administration, TPI will continue to post PREA audit comments as long as they are released, and we will continue to bring to light abuses that sometimes are and always should be covered by PREA.

TPI has developed a simple auditor tool for auditors to see current information about any unit that we have in our system, providing important PREA-related information concerning these facilities.

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 2025 audit of the TDCJ Middleton Unit. Access to the audit report is currently denied at the PREA Resource Center web site, and TDCJ has not posted the report online (they are required to make the report publicly available). If anyone would like a copy of the report, please contact TPI at admin@tpride.org.

Audit deficiencies discussed in our comment letter include the reporting of questionable information, reporting of false information, use of problematic problematic language, and apparent failures to comply with minimum audit requirements. The report overall is cursory and provides scant detail substantiating conclusions. Very little information from interviews was used. Based on the deficiencies identified in this comment, it appears that compliance is questionable for at least 11 standards, there is an indication compliance is not met for one standard, and the report documents a failure to comply with three standards with no corrective action required.

TPI is submitting comment reports about deficient PREA audits of Texas prisons. We note that even though funding has been maliciously cut for all PREA support activities by the current administration, TPI will continue to post PREA audit comments as long as they are released, and we will continue to bring to light abuses that sometimes are and always should be covered by PREA.

TPI has developed a simple auditor tool for auditors to see current information about any unit that we have in our system, providing important PREA-related information concerning these facilities.

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 the TDCJ Lynaugh-Fort Stockton Complex. The audit report can be accessed at this link.

Audit deficiencies discussed in our comment letter include the reporting of questionable information, reporting of false information, use of problematic problematic language, and apparent failures to comply with minimum audit requirements. In addition, this comment letter documents questionable information in the discussion of at least 11 standards, false information for at least five standards, that one standard was assessed as exceeding compliance with absolutely no justification, and vague or inappropriate discussion of at least eight standards. Based on these deficiencies, it appears that compliance is questionable for at least eight standards, there is an indication of compliance is not met for three standards, and the report documents a failure to comply with two standards with no corrective action required.

TPI is submitting comment reports about deficient PREA audits of Texas prisons.

TPI has developed a simple auditor tool for auditors to see current information about any unit that we have in our system, providing important PREA-related information concerning these facilities.

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 Clemens Unit. The audit report can be accessed at this link.

Deficiencies noted in our report include a failure to spend the minimum required time conducting the audit, failure to provide accurate and truthful information (information about the numbers of interviews appears to be intentionally falsified), failure to meet minimum interview requirements, and failures and apparent failures to identify noncompliance and require corrective actions.

TPI is submitting comment reports about deficient PREA audits of Texas prisons.

TPI has developed a simple auditor tool for auditors to see current information about any unit that we have in our system, providing important PREA-related information concerning these facilities.

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 Murray Unit. The audit report has not been posted on TDCJ’s web site yet (reports MUST be published on the agency web site per PREA regulations), but can be accessed at the PREA Resource Center audit directory.

TPI’s review of the audit provides the following conclusions:

• Audit report overall includes questionable information, reporting of false information, use of problematic problematic language, and apparent failures to comply with minimum audit requirements.
• Questionable information provided for at least five standards.
• False information for at least two standards.
• Two standards assessed as exceeding compliance with inadequate justification.
• Compliance is questionable for at least eight standards.
• Indication of compliance not met for five standards.
• Report documents a failure to comply with two standards with no corrective action required.

TPI is submitting comment reports about deficient PREA audits of Texas prisons.

TPI has developed a simple auditor tool for auditors to see current information about any unit that we have in our system, providing important PREA-related information concerning these facilities.

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 Montford Unit. The audit report has not been posted on TDCJ’s web site yet (reports MUST be published on the agency web site per PREA regulations), but can be accessed at the PREA Resource Center audit directory.

In the past two years, TPI has been filing comment reports about PREA audits of individual facilities within the TDCJ system. Individual facilities are to be audited every three years. The agency as a whole is to be audited annually. TPI chose not to comment on the agency audit in 2023 because it involved a lot more work than we had time to do effectively. However, in 2024, we decided to put the effort into compiling at least some of the agencywide data that was necessary for an appropriate comment report. We also extended our auditor tool to provide agencywide data.

The result was better than expected, and we learned some surprising things that are already known issues published in TDCJ annual reports. We were able to compile some of this data to show that TDCJ acknowledges problems by providing data that any cursory review would identify as problematic, but which is not being addressed by TDCJ, even though that is a requirement under the PREA standards.

One item we have identified previously is the problem adequately staffing facilities, which the auditors all have ignored. This problem was highlighted by the Texas Sunset Commission in their recent audit of TDCJ, and their data well documented the problems that were known, if anecdotally. We could also show that even though TDCJ well knows housing people who are significantly older and larger than their cellmates leads to violence, including sexual violence, mishousing seems to be increasing, not decreasing (see Figures 2 and 3). Even though TDCJ gushes about their staff training related to sexual violence, staff have only identified 4 issues of potential sexual violence over eight years, compared to over 14,000 reports of the same by incarcerated persons (see Table 3). We found that nearly every measure of sexual violence in the system has increased based on available data (see Figure 4 and Table 7). And we found that claims of cameras being effectively used to curb sexual violence are not supported by data, which shows camera placement in areas of the highest incidence of sexual violence appears to have been deprioritized (see Figures 5 and 6).

These are just a few of the comments we had on the agency compliance with PREA standards. We hope that this report will be useful in drawing at least some attention to problems in the TDCJ system.

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. We are making this assessment because we include quotes and examples of incidents of anti-trans and anti-queer violence throughout this comment letter to help illustrate our points.

TPI began looking at PREA audit reports for Texas Department of Criminal Justice prisons and commenting on what we view as deficiencies in the audits in March 2023. By October 2024, when we received our first meaningful response from the Department of Justice PREA Management Office/National PREA Resource Center (PMO/PRC) to these comments, we had submitted 19 audit comment letters.

The response identified seven concerns that TPI raised. This was only a small portion of the concerns we had actually raised, but at least it was a response.

We note that of the concerns that were identified in this response, one had been addressed somewhat, and one would be addressed soon. Concern 2 noted that auditors only defined populations at facilities as “male” or “female,” and that was in part due to restrictions in the auditor tool, which amazingly did not allow any entry except those two identities. This was addressed by an update to the auditor tool in late 2024. Concern 4 had to do with auditors only considering cross-gender viewing and searches relative to the gender of staff and the gender designated (“male” or “female”) of the facility. An update to the FAQ about Standard 115.15 noted that such a simplistic assessment “would not be compliant.”

The response to some of the concerns referenced training for auditors, but it was difficult to tell if this represented additional training or anything other than what has been insufficient to hold auditors accountable to date. There was also an absurd statement that our complaint that regardless of TDCJ policy, the agency practice is to house transgender persons by genital status: the PMO/PRC essentially made a circular argument that TDCJ could not have that practice because their policy says they do not.

The entire response letter is provided below.

TPI chose to respond by letter rather than by email, as the missing and overlooked issues were too many for comfortable email response. We explained in that response that we could not let the lack of response stand on so many issues because, as in the prison systems, a failure to continue to bring up issues not addressed by administrative responses is interpreted as acceptance of the response. We did not accept the PMO/PRC response.

On October 26, 2024, we sent that response to the PMO/PRC. We brought up specific texts in PMO/PRC documents contradicting the provided response, information from PREA audit reports that directly contradict PMO/PRC statements, how the response manipulates the gist of complaints, and provided a list of other issues not addressed in the response.

Our reply to the PMO/PRC is shown below:

Although TPI is pleased to see that our comments are being considered, we hope that the consideration in the future is more appropriate to the overall PREA goals of, as per the PREA Standards themselves, working toward “zero tolerance toward all forms of sexual abuse and sexual harassment” rather than rubber stamping audits in a show of progress.

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.