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.

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