Waller County's Motion For Summary Judgment

Case 4:15-cv-02232 Document 39 Filed in TXSD on 11/11/15 Page 1 of 39
IN THE UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
GENEVA REED-VEAL,
Individually and as Mother and
Personal Representative of the
Estate of SANDRA BLAND,
deceased,
Plaintiff,
VS.
BRIAN ENCINIA, ET AL.,
Defendants.
CIVIL ACTION NO. 4:15-CV-02232

(JURY TRIAL REQUESTED)
COUNTY DEFENDANTS MOTION FOR SUMMARY JUDGMENT

TO THE HONORABLE JUDGE OF SAID COURT:
COME NOW WALLER COUNTY, ELSA MAGNUS, and OSCAR PRUDENTE
(collectively County Defendants), file this their Motion for Summary Judgment,
and would respectfully show unto the Court as follows:
I.
INTRODUCTION
Plaintiff Geneva Reed-Veal (Plaintiff or Reed-Veal) is the mother of
Decedent Sandra Bland (Decedent or Bland). She asserts wrongful death and
survival causes of action against the County Defendants arising from Blands July
13, 2015 suicide, while detained in the Waller County Jail.
Bland was arrested by a state law enforcement officer on Friday, July 10,
2015 for a traffic violation and assault on a public servant. The County defendants
had no involvement in the stop, Blands arrest, or her transport to the Waller
County Jail. Similarly, the County Defendants had no personal knowledge of the
events that led to Bland being arrested and transported to the Jail, other than what
was provided by the arresting trooper.
When Bland arrived at the jail, Defendant Oscar Prudente performed an
initial intake screening in which Bland confirmed she was not currently suicidal,
although she acknowledged a prior attempted suicide after losing a baby on or
about May 30, 2014.
Approximately two hours and forty-five minutes later,
Defendant Elsa Magnus completed Blands booking process and performed a

separate suicide screening. At that time, Bland again confirmed she was not
suicidal, although she acknowledged the prior suicide attempt after losing a baby.
Screening officers observed that Bland appeared angry she had been arrested, but
not that she was depressed or suicidal. Based on Blands answers to the screening
questions, and the screening officers observations of Bland, she was not identified
as a candidate for suicide watch. Pursuant to state standards, Bland was classified
as medium-assaultive, and she was assigned to a group cell. However, because
the jail had no other female detainees who shared that classification, she was
housed alone.
Although detainees are generally required to use a phone with a pin account
(charged to the detainee), jail staff allowed Bland numerous free phone calls on
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their staff phone on Friday and Saturday (July 10-11, 2015). Bland also had access
to a phone in her cell with which she could make unlimited collect calls. A
magistrate set Blands bond at $5,000 midday Saturday, and she could have
bonded out any time thereafter for approximately $515, which included bail bond
fees.
Despite several calls to family and friends, no bond was posted. Bland
exhibited no signs of suicidal tendencies through the weekend. Nonetheless, she

committed suicide on Monday July 13, 2015, by hanging herself in her cell
between 7:55 a.m. and 8:58 a.m.
Reed-Veal claims that Defendants Prudente and Magnus violated Blands
rights through deliberate indifference to an alleged serious risk of suicide. She also
claims Waller Countys customs or policies were the moving force behind
violations of Blands rights. However, as set forth below, Defendants Prudente
and Magnus did not have any subjective knowledge of and were not deliberately
indifferent to any alleged serious risk of suicide. Further, they are entitled to
qualified immunity because their actions did not violate clearly established law,
and because their actions were objectively reasonable. In addition, no policy or
custom of Waller County resulted in any violation of Blands rights. Read-Veal
also asserts negligence claims against Prudente, Magnus, and the County.
However, those claims are barred by governmental immunity.
summary judgment is appropriate.
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Accordingly,
II.
ISSUES PRESENTED
1.
Whether Defendants Elsa Magnus and Oscar Prudente violated Blands

rights.
2.
Whether Defendants Elsa Magnus and Oscar Prudente are entitled to

qualified immunity.
3.
To the extent Defendants Magnus and Prudente violated Blands rights,

whether Defendant Waller County had any custom or policy that was the
moving force behind any such alleged violation of rights.
4.
Whether Defendant Waller County had any official custom or policy that
violated Blands rights.
5.
Whether County Defendants immunity has been waived for negligence

claims.
III.
UNDISPUTED MATERIAL FACTS
A.
Blands History
Reed-Veal alleges that Bland was a resident of Naperville, Illinois.1
However, she is believed to have been moving to the Prairie View, Texas and/or
Houston areas in July 2015. Although not principally relevant here, all indications
are that she was staying with her male friend LaVaughn Mosley on July 10, 2015,
and that she had a job interview at Prairie View A&M the same day, in Prairie
View, Waller County, Texas.
See Document No. 11 at 1.
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B.
Blands Arrest
Co-Defendant Brian Encinias, a Texas Department of Public Safety Trooper,
arrested Bland in Prairie View, Texas at approximately 4:30 p.m. on Friday, July
10, 2015, for a traffic violation and assault on a public servant.2 Bland declined
medical treatment by emergency medical personnel who responded to the scene of
the arrest,3 and there is no indication Bland was suicidal at this time. However, it
was discovered in her autopsy performed four days later that she was under the
influence of marijuana.4 Trooper Encinias transported Bland to the Waller County
Jail, in Hempstead, Texas, and they arrived at the jail at approximately 5:30 p.m.5
C.
Intake / Booking
Upon arrival at the Waller County Jail, Trooper Encinias completed a form
which asked his opinion as to whether Bland was suicidal or mentally ill, to which
he responded No.6
Thereafter, Defendant Jailer Oscar Prudente conducted an initial intake

screening of Bland at approximately 5:30 p.m., and he asked her several questions
to identify potential suicide risk and other illnesses or conditions which may
See Exhibit A (Affidavit and Complaint for Arrest Warrant).

See Exhibit B (EMS Records from Arrest).
4
See Exhibit C (Autopsy Report)
5
See Exhibit D (Intake Form Completed by Encinias).
3
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require special treatment.7 He documented her answers as follows, which noted

that she was not thinking about killing yourself today:8
Further, Blands reported previous suicide attempt was a year before and related to
losing a baby, not anything to do with the reason for her arrest, or the fact that she
had been arrested or was in jail.9
Simply put, Bland did not provide any
information to suggest she may be suicidal, and the circumstances surrounding her
arrest did not suggest that she may be suicidal. Accordingly, Jailer Prudente did
not have any subjective awareness that Bland may be suicidal.10 Jailer Prudentes
See Exhibit D (Intake Form Completed by Encinias).

See Exhibit E (Intake Form Completed by Prudente).
8
9
10
See Exhibit F (Prudente Affidavit).
7
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shift ended at 7:00 p.m. on July 10, 2015, and he did not work again at the jail until
after Blands suicide on July 13, 2015.11
Defendant Jailer Elsa Magnus came on duty at 7:00 p.m. on July 10, 2015.12
Approximately two hours and forty-five minutes after Bland arrived at the jail,
Jailer Magnus formally booked Bland into the jail at approximately 8:15 p.m.
During that process, Jailer Magnus asked Bland several of the same questions
Jailer
Prudente
previously
asked,
and
electronically, as follows:13
11
See Exhibit F (Prudente Affidavit).

See Exhibit G (Magnus Affidavit).
13
See Exhibit H (Screening Form Completed by Magnus).
12
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documented
Blands
responses
Thereafter, Jailer Magnus asked Bland questions specifically relating to suicide,

and Bland provided answers conflicting with the answers she had previously
provided:
Despite providing conflicting informationwhich is not unusual as detainees

cool off in the time between intake and bookingBland did not provide any
information to suggest she may be suicidal, and the circumstances surrounding her
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arrest did not suggest that she may be suicidal.14 Bland also had not been arrested
for any particularly embarrassing offensei.e., child pornography or sexual
assaultor for any offense which would likely carry a lengthy prison sentence,
offenses which are more likely to result in suicide.15 She was also more angry than
depressed, expressly telling Magnus, Im not depressed.
Im pissed off.16
Finally, Bland was allowed, as a courtesy to her, to make free telephone calls on
the jail staffs phone. She made telephone contact with a male friend (LaVaughn
Mosley), and she was expected to bond out of jail the following day.17
Accordingly, Jailer Magnus did not have any subjective awareness that Bland may
be suicidal.18
Given the lack of information to suggest Bland may be suicidal, Jailer
Magnus proceeded to classify Bland for housing. According to state standards,
Bland was classified as medium-assaultive.19 The cell at the Waller County Jail
for medium-assaultive female detainees is a multi-person cell. However, there
were no other female detainees in that classification when Bland was arrested, and
Bland was housed alone.20
14

16
17
18
19
See Exhibit I (Classification Records).
20
15
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Jailer Magnus remained on duty until 7:00 a.m. on July 11, 2015.21 During
the remainder of that shift, she had no other significant interaction with Bland, and
she did not observe any behavior that would suggest Bland may have been
suicidal.22 After Jailer Magnus shift ended at 7:00 a.m. on July 11, she next
worked from 7:00 p.m. on July 11 to 7:00 a.m. on July 12 (Saturday night and
early Sunday morning).23 During that shift, she had no significant interaction with
Bland, and she did not observe any behavior that would suggest Bland may have
been suicidal.24 After Magnus shift ended Sunday morning at 7:00 a.m. on July
12, Magnus did not work in the jail again until after Blands suicide on July 13,
2015.25
Although Magnus was not involved in the process of presenting Bland to a
magistrate, Bland saw a magistrate judge on Saturday, July 11, 2015.26 After her
bond was set, Bland was given several additional free phone calls.27 She attempted
to reach LaVaughn Mosley several times, but it appeared he was intentionally
ignoring her calls.28 She also made contact with at least one of her sisters, who
advised she would not bail Bland out of jail.29 Bland also made contact with a bail
21

23
24
25
26
See Exhibit J (Smith Affidavit).
27
28
29
22
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bondsman, who in turn made contact with Blands mother and possibly other
relatives. However, none of her friends and family provided the approximately
$515 necessary to bail her out of jail.
D.
Blands Suicide
As noted above, Prudente did not work over the weekend, and Magnus did
not work after 7:00 a.m. on July 12. At that time, Bland had not exhibited any
signs of suicidal tendencies. On the morning of Monday, July 13, 2015more
than 60 hours since Prudente had worked, and more than 24 hours since Magnus
had workedjail personnel visually observed Bland at 5:01 a.m. and 5:54 a.m.30
Jail personnel also visually observed Bland at 6:42 a.m. and 6:56 a.m.31 There was
a shift change at 7:00 a.m., and jail personnel again visually observed Bland at
7:07 a.m.32 The jail controller also had an intercom communication with Bland at
7:55 a.m., in which she requested additional free phone calls.33
Shortly thereafter, and at some point between 7:55 a.m. and 8:58 a.m.and
likely between 7:55 a.m. and 8:30 a.m.34Bland committed suicide by hanging
herself in the jail cell, using a rolled/twisted plastic trash bag as a ligature, and
tying it around the support of a privacy partition in the cell.35 It is apparent now
30
See Exhibit K (Video from July 13, 2015). Blands cell is to the right side of the video and is not visible.
However, jail personnel who walk in that hallway and look to the left are looking into Blands cell.
31
See Exhibit K (Video from July 13, 2015).
32
See Exhibit K (Video from July 13, 2015).
33
See Exhibit L (Door & Intercom Log); Exhibit M (Incident Report) at pp. 2-4.
34
See Exhibit N (EMS Records from Suicide) (noting likely death 20-50 minutes before EMS arrived at 9:06 a.m.).
35
See Exhibit C (Autopsy Report).
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that Blands inability to secure her release from jailand her family and friends
refusal to bail her out of jailled her to commit suicide.
Jail personnel discovered Bland at 8:58 a.m. At that time, Jailer Prudente
had not been on duty in over 60 hours, since 7:00 p.m. on Friday, July 10, 2015.
Jailer Magnus had not been on duty in over 24 hours, since 7:00 a.m. on Sunday,
July 12, 2015.
Accordingly, they could not possibly have been involved in
providing any medical care, or the alleged lack of same.

Nonetheless, jail personnel responded immediatelyjailers used a radio to
request that the cell door be opened, the controller immediately opened same, and
jail personnel held Bland up while removing the ligature.36 Jail personnel notified
EMS, who arrived within minutes.37
personnel administered CPR.38
While waiting for EMS to arrive, jail
EMS personnel declared Bland dead within
minutes of arriving on site.39 The autopsy confirmed that Bland had committed
suicide by hanging herself.40
E.
County Policies
The Waller County Sheriffs Office has Jail and Detention Policies and
Procedures which provide, in relevant part:
36
See Exhibit M (Incident Report) at pp. 2-4.

See Exhibit M (Incident Report) at pp. 2-4; Exhibit N (EMS Records from Jail).
38
39
40
See Exhibit C (Autopsy Report).
37
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- How to Use This Manual. Jail personnel must understand and follow
the procedures, and it is an important requirement to be familiar with
the details of this manual and readily apply its guidelines. Jail personnel
are further instructed to read the operational policies, ask questions as
needed, and repeat the process until you are confident you know each
policy well enough to apply it in spirit as well as in practice.41
- Objective Statements. The first objective is Protection of Life and
Property.42
- Management Philosophy & Goals. The Jail Division provides
reasonable detention services in a safe, secure, and humane
environment, according to applicable statutes and regulations, and
within prescribed ethical and constitutional limits. Goals include
providing clean, safe, and healthy living conditions, providing for
basic medical, dental, and psychiatric needs, and providing due
process and other legal safeguards.43
- Professional Conduct. All jail personnel are instructed to remember
that they are sworn to uphold the law and abide by the policies and
procedures of this agency, while protecting the rights of all people as
afforded by the Constitution of the United States of America and the
State of Texas.44
- Rules of Staff Conduct. Jail personnel are instructed to follow both the
spirit and content of the rules and policies established, and to obey all
general and special rules and orders, and all applicable laws.45 Jail
personnel are further instructed to be attentive to their duties at all
times.46 Supervisors are further instructed to enforce the rules, policies,
and procedures, including preventing violations of rules and taking
immediate action to correct deficiencies.47
- Officer & Employee Discipline. Supervisors are instructed to discipline
jail personnel for violations of policies.48
In addition to these general provisions, the Policies and Procedures also
provide specific guidance on operations, including:
41
See Exhibit O (Jail Policies) at Policy 1.01, How to Use This Manual.
See Exhibit O (Jail Policies) at Policy 1.02, Objective Statements.
43
See Exhibit O (Jail Policies) at Policy 2.01.
44
45
See Exhibit O (Jail Policies) at Policy 2.07, General Guidelines, and Rules 1.1 1.3.
46
See Exhibit O (Jail Policies) at Policy 2.07, Rules 2.1 and 2.3.
47
See Exhibit O (Jail Policies) at Policy 2.07, Rule 2.2.
42
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- Jail Admission. At initial intake, jail personnel are required to observe

the arrestee for obvious signs of injury or illness, and refer any arrestee in
need of immediate emergency medical or mental attention to the
appropriate provider. If the arrestee is accepted into the jail, then jail
personnel are required to observe inmates in holding or detoxification
cells at intervals of every 30 minutes.49 Thereafter, detainees are given at
least two telephone calls within the first four hours, on a prepaid or
collect basis.50 Upon booking, the Medical, Dental, Mental, and Suicide
Screening form must also be completed based on jail personnels
interview of the detainee, with suicidal claims or threats to be reported to
the Jail Administrator.51 Finally, detainees must be housed in accordance
with the classification system.52
- Management of Security Program. Jail personnel on the floor for
direct inmate supervision must provide visual, face-to-face observation
of inmates at least once every hour. Observation is performed at least
every thirty minutes in areas where inmates are known to be assaultive,
potentially suicidal, mentally ill, or who have demonstrated bizarre
behavior. There must be two-way voice communication capability
between inmates and staff at all times.53
- Sanitation Plan. The jail has a sanitation plan which describes the
cleaning duties and schedule to maintain a healthy housing and work
environment,54 which includes a waste disposal plan.55
- Health Services Plan. The jail has a comprehensive health services plan
for medical, dental, and mental health evaluation and treatment, which
provides that medical and mental health services will not be neglected,
and care will be provided on a reasonable basis. The plan also calls for
an initial intake evaluation, along with continued observation and
evaluation, and a plan for addressing emergency medical situations.56
- Mental Disabilities & Suicide Prevention Plan. In addition to the
comprehensive health services plan, the jail also has a separate policy
addressing suicide prevention. The policy is to provide the appropriate
care for any inmates who have mental problems or who may be suicidal.
48

See Exhibit O (Jail Policies) at Policy 4.02, Initial Processing, Steps 2 and 9.
50
See Exhibit O (Jail Policies) at Policy 4.02, Telephone Access; Policy 12.05, Telephone Plan.
51
See Exhibit O (Jail Policies) at Policy 4.02, Medical, Dental, Mental, and Suicide Screening.
52
See Exhibit O (Jail Policies) at Policy 4.02, Housing Assignment; Policy 4.03, Classification Plan.
53
See Exhibit O (Jail Policies) at Policy 5.01, Staff Visibility.
54
55
56
49
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To accomplish that goal, all staff receive two hours of annual training on
recognizing, supervising, documenting, and handling potentially suicidal
inmates.57 In the event of any outcry or other information indicating an
inmate may be suicidal, jail personnel are to contact the local MHMR
agency for an immediate mental health screening.58
- Mental Disabilities & Suicide Prevention Plan (contd). Further,
potentially suicidal inmates will be placed on suicide watch, with no
personal property or bed linens, and only a paper gown to wear.
Depending on the determination of the local MHMR agency as to the
degree of suicide risk posed, potentially suicidal inmates will then be
observed every 5, 15, or 30 minutes.59
- Mental Disabilities & Suicide Prevention Plan (contd). In the event
of an attempted suicide, specific instructions are provided for responding,
including, for example, cutting down the inmate if hanging, and
rendering first aid.60
The County also took other action to ensure that jail personnel were
reminded of policies and procedures. For example, the jail supervisors periodically
sent reminder emails to jail personnel, and the jail maintained a Memo Book,
which all jail personnel could access and were instructed to review. The Memo
Book contained printed versions of some of the emails jail supervisors sent to jail
personnel, including reminders on how to complete suicide screening forms, what
to do with detainees placed on suicide watch, and conducting regular face-to-face
observation of detainees.61
57
See Exhibit O (Jail Policies) at Policy 11.02, Training.

See Exhibit O (Jail Policies) at Policy 11.02, Identification.
59
See Exhibit O (Jail Policies) at Policy 11.02, Housing & Supervision.
60
See Exhibit O (Jail Policies) at Policy 11.02, Response to Suicide or Suicide Attempt.
58
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F.
Jailer Training
Jailer Elsa Magnus has been a licensed jailer in Texas since March 19, 2008,
and held a temporary jailers license before that.62 Becoming a licensed jailer
requires a 96-hour course on jail operations from an accredited academy, and
passing a written test. Jailer Magnus had the following, formal training:
Feb. 22, 2008:
Sep. 30, 2009:
Jul. 9, 2010:
May 9-13, 2011:
May 31, 2011:
Sep. 29, 2011:
Dec. 11, 2012:
Jun. 13, 2014:
Dec. 16, 2014:
Dec. 17, 2014:
Completed Basic Jail Course (96 hours)

Completed LEMIT Jail Course (8 hours)
Completed County MHMR Course (2 hours)
Completed TJA Jail Course (appx. 32 hours)
Completed County Suicide Prevention Course (2 hours)
Completed Jail Classification Course (4 hours)
Completed LEMIT Legal Issues Course (4 hours)
Completed LEMIT Suicide Course (4 hours)63
Jailer Oscar Prudente became a licensed jailer in Texas on April 15, 2014.
He also became a licensed peace officer in Texas on May 11, 2015. He received
the following, formal training:
Apr. 4, 2014:
Jun. 13, 2014:
May 6, 2015 :
Completed Basic Jail Course (96 hours)

Completed Jail Classification Course (4 hours)
Basic Peace Officer Course (643 hours)64
61
See Exhibit P (Excerpts from Memo Book).

See Exhibit Q (Excerpts from Magnus Training Records); see also Exhibit G (Magnus Affidavit).
63
See Exhibit Q (Excerpts from Magnus Training Records); see also Exhibit G (Magnus Affidavit).
64
See Exhibit R (Excerpts from Prudentes Training Records); see also Exhibit E (Prudente Affidavit).
62
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IV.
SUMMARY JUDGMENT EVIDENCE
In support of this Motion, County Defendants rely on, and incorporate by
reference as if set forth at length herein, the following evidence:
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Exhibit L
Exhibit M
Exhibit N
Exhibit O
Exhibit P
Exhibit Q
Exhibit R
Affidavit and Complaint for Arrest Warrant;

EMS Records from Arrest;
Autopsy Report;
Trooper Encinias Intake Form;
Jailer Prudentes Intake Form;
Jailer Prudentes Affidavit;
Jailer Magnus Affidavit;
Jailer Magnus Screening Forms;
Classification Records;
Jailer Dormic Smiths Affidavit;
Video from July 13, 2015 (on CD/DVD);
Door/Intercom Log;
Excerpts from Waller County Incident/Offense Report;
EMS Records from Suicide;
Excerpts from Waller County Jail Policies & Procedures;
Excerpts from Waller County Jail Memo Book;
Excerpts from Jailer Magnus Training Records; and
Excerpts from Jailer Prudentes Training Records.
V.
SUMMARY JUDGMENT STANDARD
A party in a lawsuit may move a court to enter summary judgment before

trial. FED. R. CIV. P. 56. Summary judgment is appropriate when the moving party
establishes that there is no genuine dispute of material fact and/or the moving party
is entitled to judgment as a matter of law. FED. R. CIV. P. 56; Celotex Corp. v.
Catrett, 477 U.S. 317, 322-24 (1986); Stewart v. Murphy, 174 F.3d 530, 533 (5th
Cir. 1999). [T]he substantive law will identify which facts are material, and only
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disputes about those facts will preclude the granting of summary judgment.
Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). A material fact is one
that might affect the outcome of the suit under governing law, and a dispute
about a material fact is genuine if the evidence is such that a reasonable jury could
return a verdict for the nonmoving party. Id.; Smith v. Brenoetty, 158 F.3d 908,
911 (5th Cir. 1998).
Once the movant meets its burden under Rule 56, the non-movant must
designate specific facts showing that there is a genuine dispute for trial.
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 586-87 (1986).
Conclusive assertions, unsupported by specific facts presented in admissible
evidence opposing the motion for summary judgment, are insufficient to defeat a
proper motion for summary judgment. Lujan v. Natl Wildlife Fedn, 497 U.S. 871
(1990). The party opposing summary judgment must respond by setting forth
specific evidence in the record and articulating the precise manner in which that
evidence supports his or her claim. Forsyth v. Barr, 19 F.3d 1527, 1537 (5th Cir.),
cert. denied, 513 U.S. 871 (1994).
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VI.
ARGUMENTS & AUTHORITIES
A.
Section 1983 Failure to Prevent Suicide Claims Against Jailers Magnus

and Prudente Fail as a Matter of Law.
It appears Plaintiff is claiming that Jailers Magnus and Prudente were (1)
deliberately indifferent to Blands alleged serious risk of suicide by failing to

adequately monitor her and (2) deliberately indifferent to Blands serious medical
need after she was discovered hanging in her cell.65 As set forth below, the
evidence conclusively establishes Jailers Magnus and Prudente were not
deliberately indifferent to any serious risk of suicide or serious medical need.
Further, Jailers Magnus and Prudente are entitled to qualified immunity because
they did not violate any of Blands clearly established rights, and their conduct was
objectively reasonable.
i.
No Subjective Awareness of Serious Risk of Suicide.
Bland had a right under the Fourteenth Amendment to the United States
Constitution to protection from known suicidal tendencies during her detention.
See Thompson v. Upshur County, Tex., 245 F.3d 447, 457 (5th Cir. 2001); Jacobs
v. West Feliciana Sheriffs Dept, 228 F.3d 388, 393 (5th Cir. 2000); Nunez v.
Deviney, 4:06CV0579BE, 2007 WL 2059726, at *2 (N.D. Tex. July 17, 2007)
(citing Hare v. City of Corinth, Miss., 74 F.3d 633, 639 (5th Cir.1996)).
65
See Document No. 22 at Count III (claims against Elsa Magnus) and Count V (claims against Oscar Prudente).
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In Hare, the Fifth Circuit adopted the subjective deliberate indifference test
for claims of failure to protect from suicide risk. See Hare v. City of Corinth,
Miss., 74 F.3d 633, 647-48 (5th Cir.1996). To establish such a claim, a plaintiff
must establish: (1) that the defendant had subjective knowledge of a substantial
and serious risk that the pretrial detainee might commit suicide; and (2) that the
defendant nevertheless disregarded the risk of suicide by responding to it with
deliberate indifference. Id. at 650. In other words, the official must both be aware
of facts from which the inference could be drawn that a substantial risk of serious
harm exists, and he must also draw that inference.
Jones v. Throckmorton
County, Tex., 1:02CV182C, 2004 WL 419811, at *4 (N.D. Tex. March 8,

2004) (quoting Farmer v. Brennan, 511 U.S. 825, 837 (1994)). An officials
failure to alleviate a significant risk that he should have perceived but did not,
while not commendable, does not rise to the level of deliberate indifference.
Nunez v. Deviney, 4:06CV0579BE, 2007 WL 2059726, at *2 (N.D. Tex. July
17, 2007) (citing Farmer, 511 U.S. at 838).
Courts have noted that [s]uicide is inherently difficult for anyone to predict,
particularly in the depressing prison setting. Domino v. Texas Dept. of Criminal
Justice, 239 F.3d 752, 756 (5th Cir. 2001) (citing Collignon v. Milwaukee Co., 163
F.3d 982, 990 (7th Cir. 1998)). As such, a detainees comments that his arrest will
cause him to lose everything or that his life will be over or other comments
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that he is exasperated with living, do not demonstrate that officials have actual
knowledge of a substantial risk of suicide. See, e.g., Branton v. City of Moss Point,
261 Fed. Appx. 659, 661 (5th Cir. 2008). Additionally, a detainees affirmative
answer on an intake screening exam, indicating that he recently lost a family
member or was worried about other major problems, does not establish actual
subjective knowledge of a suicide risk. See, e.g., Whitt v. Stephens County, 236
Fed. Appx. 900, 903 (5th Cir. 2007).
When a detainee reports a prior suicide attempt, courts look to its temporal
proximity. In such scenarios, courts have held that knowledge of a suicide attempt
three years before the detention could not establish actual awareness of a serious
risk of suicide, see, e.g., Calton v. Livingston, No. H092507, 2011 WL 2118700,
at *13 (S.D. Tex. May 27, 2011), but courts have found a fact issue as to whether a
jailer who personally placed a detainee on suicide watch three months before the
detention at issue had actual awareness of a serious risk of suicide, see, e.g.,
Shepard v. Hansford County, --- F.Supp.3d ---, No. 2:14 CV-00147, 2015 WL
3368001 (N.D. Tex. May 22, 2015).
Here, Bland reported a prior suicide attempt after she lost a baby on or about
May 30, 2014. However, she also reported that she was not suicidal. Jailers
Prudente and Magnus were face-to-face with Bland, and observed her demeanor,
and both concluded that she was not facing a serious risk of suicide. For example,
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Blands prior suicide attempt was remote in time, and the circumstances
surrounding her prior suicide attempti.e., taking pills after losing a babywere
not of the same nature as being arrested in connection with a traffic stop. Bland
also had not been arrested for any particularly embarrassing offensei.e., child
pornography or sexual offenseor any offense that would likely carry a lengthy
prison sentence, offenses which are more likely to result in a suicide attempt. She
was also more angry than depressed, expressly telling Magnus, Im not depressed.
Im pissed off.
Finally, she made telephone contact with a male friend
(LaVaughn Mosley) when she was booked, and she expected to be bonded out of
jail the following day. None of these circumstances support a conclusion that
Bland faced a serious risk of suicide.
Jailers Magnus and Prudente have also both confirmed that they were not
subjectively aware of any risk of suicide. That conclusion is supported by the fact
that Bland did not attempt suicide until after she had been in jail for two-and-a-half
days, and her family and friends had refused to bail her out of jail. For the
foregoing reasons, the evidence conclusively establishes that Jailers Magnus and
Prudente were not subjectively aware of any serious risk of suicide, defeating
Plaintiffs claims against them.
- 22 -
ii.
No Deliberate Indifference.
As noted above, Jailers Magnus and Prudente were not subjectively aware of
any serious risk of suicide. Accordingly, they could not have been deliberately
indifferent to any such risk. See, e.g., Brumfield, 551 F.3d at 332 (cannot be
deliberately indifferent if no known suicide danger).
Further, [d]eliberate indifference is an extremely high standard to meet.
Domino v. Texas Dept. of Criminal Justice, 239 F.3d 752, 756 (5th Cir. 2001). It
must be proven that the officials refused to treat him, ignored his complaints,
intentionally treated him incorrectly, or engaged in any similar conduct that would
clearly evince a wanton disregard for any serious medical needs. Id. Put another
way, a plaintiff must establish more than mere negligence, and even more than
gross negligence. See Hare v. City of Corinth, Miss., 74 F.3d 633, 646 (5th Cir.
1996). In this case, there is no evidence of deliberate indifference, and Plaintiffs
claims fail as a matter of law.
iii.
Qualified Immunity No Violation of Clearly Established Law.
Defendant Jailers Magnus and Prudente are also entitled to qualified

immunity on the claim that they failed to prevent Blands suicide. At the outset,
qualified immunity shields government officials from civil damages liability
unless the official violated a statutory or constitutional right that was clearly
established at the time of the challenged conduct. Taylor v. Barkes, 575 U.S. ---,
- 23 -
135 S.Ct. 2042, 2044 (Jun. 1, 2015). To be clearly established, a right must be
sufficiently clear that every reasonable official would have understood that what he
is doing violates that right. Id. As such, qualified immunity protects all but the
plainly incompetent or those who knowingly violate the law. Id.
The United States Supreme Court recently addressed the issue of whether
detainees have a clearly established right to the proper implementation of adequate
suicide prevention protocols. See Taylor, 135 S.Ct. at 2044. That is essentially the
issue in this case because, whatever allegations Plaintiff makes, she is arguing that
Prudente and Magnus violated Blands rights by failing to prevent her suicide. On
that issue, the Supreme Court held that there is no such clearly established right.
More specifically, in Taylor, a nurse used a screening form to ask the
arrestee questions that might indicate whether he was suicidal.
Id. at 2043.
Although he was on psychiatric medication and disclosed a prior suicide attempt,

he indicated he was not suicidal at the time of the screening. Id. Accordingly, the
nurse did not put him on suicide watch. Id. The following morning, jail personnel
observed the detainee acting normally, but he committed suicide at approximately
11:35 a.m., on the morning following his arrest. Id.
On June 1, 2015, the Taylor court held that there was no clearly established
right, as follows:
No decision of this Court establishes a right to the proper
implementation of adequate suicide prevention protocols.
No
- 24 -
decision of this Court even discusses suicide screening or prevention

protocols. And to the extent that a robust consensus of cases of
persuasive authority in the Courts of Appeals could itself clearly
establish the federal right respondent alleges, City and County of San
Francisco v. Sheehan, 575 U.S. , , 135 S.Ct. 1765, 1779,
L.Ed.2d (2015), the weight of that authority at the time
of Barkes's death suggested that such a right did not exist.
See, e.g., Comstock v. McCrary, 273 F.3d 693, 702 (6th Cir.
2001) (the right to medical care for serious medical needs does not
encompass the right to be screened correctly for suicidal
tendencies); Tittle v. Jefferson Cty. Comm'n, 10 F.3d 1535, 1540
(11th Cir. 1994)(alleged weaknesses in the [suicide] screening
process, the training of deputies[,] and the supervision of prisoners
did not amount to a showing of deliberate indifference toward the
rights of prisoners); Burns v. Galveston, 905 F.2d 100, 104 (5th Cir.
1990) (rejecting the proposition that the right of detainees to
adequate medical care includes an absolute right to psychological
screening); Belcher v. Oliver, 898 F.2d 32, 3435 (4th Cir.
1990) (The general right of pretrial detainees to receive basic
medical care does not place upon jail officials the responsibility to
screen every detainee for suicidal tendencies.).
Id. at 2044-45. The Taylor court went on to hold that the individual defendants at
issue were entitled to qualified immunity. Id. at 2045.
Similarly, Fifth Circuit precedent provides that jailers must take measures
to prevent inmate suicides, but only once they know of the suicide risk, Calton
v. Livingston, No. H092507, 2011 WL 2118700, at *16 (S.D. Tex. May 27,
2011) (emphasis added), and there is no clearly-established right to any specific
actions jail officials must take, once they know of a suicide risk. See Jacobs v.
West Feliciana Sheriffs Dept., 228 F.3d 388, 39495 (5th Cir. 2000).
- 25 -
Further, to the extent Plaintiff would argue that alleged violations of state
statutes or regulations relating to suicide screening and prevention give rise to a
clearly-established right, that argument has already been considered and rejected.
More specifically, in Davis v. Scherer, the Supreme Court held that [o]fficials
sued for constitutional violations do not lose their qualified immunity merely
because their conduct violates some statutory or administrative provision because
the law requires that the constitutional right allegedly violated be clearly
established, and not simply that a state statutory or administrative provision be
clearly established. 468 U.S. 183, 194-96 & n.12 (1984). Accordingly, state
statutes and regulations, or the alleged violation of same, have no relevance to the
issue of whether a constitutional right was clearly established, or was violated. Id.
In this case, Defendant Jailers Magnus and Prudente conducted suicide
screenings of Bland, and she indicated she was not suicidal. She disclosed a prior
suicide attempt, but based on the totality of the circumstances, including Blands
demeanor and the charges against her, Magnus and Prudente did not find her to be
suicidal. Bland did not have a clearly-established right to any different or more
effective implementation of suicide prevention protocols.
There is also no
evidence that any different or more effective protocols would have prevented her
suicide in this case. Accordingly, Defendant Jailers Magnus and Prudente are
entitled to qualified immunity.
- 26 -
iv.
Qualified Immunity No Objectively Unreasonable Conduct.
Next, even if Bland had a clearly established right to the proper

implementation of adequate suicide prevention protocolswhich is denied, and is
contrary to Supreme Court authority from June 2015Defendant Jailers Magnus
and Prudente would still be entitled to qualified immunity because their actions
were objectively reasonable.
More specifically, the qualified immunity analysis is two-fold; even if there
was a violation of a clearly-established right, the governmental actor is still entitled
to qualified immunity if his actions were objectively reasonable. See Freeman v.
Gore, 483 F.3d 404, 41011 (5th Cir. 2007). Whether an official's conduct was
objectively reasonable is a question of law for the court, not a matter of fact for the
jury. Williams v. Bramer, 180 F.3d 699, 703 (5th Cir. 1999). The Court simply
asks whether it would be objectively reasonable for an officer to believe that his
actions were constitutional. See Lytle v. Bexar County, Tex., 560 F.3d 404, 410
(5th Cir. 2009).
At the summary judgment stage, a plaintiff must present evidence to raise a
fact issue material to the resolution of the questions whether the defendants acted
in an objectively reasonable manner in view of the existing law and facts available
to them. Calton v. Livingston, No. H092507, 2011 WL 2118700, at *15 (S.D.
Tex. May 27, 2011) (quoting Lampkin v. City of Nacogdoches, 7 F.3d 430, 435
- 27 -
(5th Cir. 1993)). Notably, the Supreme Court has rejected the argument that
conduct that violates even clear state statutes or regulations is objectively
unreasonable; all that matters is whether the conduct was objectively
unreasonable in light of the clearly established constitutional right at issue. Davis
v. Scherer, 468 U.S. 183, 194-96 & n.12 (1984) (rejecting lower courts holding
that if an official violates his agencys explicit regulations, which have the force
of state law, that is evidence that his conduct is unreasonable.)
In this case, there is no evidence that Defendant Jailers Magnus and
Prudentes actions were objectively unreasonable. To the contrary, they assessed
Bland, asked her several questions in an attempt to determine whether she was
suicidal, and concluded based on the totality of the evidence that she was not.
Accordingly, summary judgment is appropriate.
B.
Section 1983 Failure to Provide Medical Care Claims Against Jailers

Magnus and Prudente Fail as a Matter of Law.
i.
No Subjective Awareness of Serious Medical Need.
Plaintiff alleges that Jailers Magnus and Prudente were deliberately

indifferent to Blands need for medical treatment after she was found hanging in
her cell on Monday morning. However, Jailers Magnus and Prudente had not
worked in the jail in over 24 and 60 hours, respectively, and were not present when
Bland committed suicide, or the time shortly thereafter. Accordingly, they could
- 28 -
not possibly have had any subjective awareness of any serious medical need after
Bland was discovered hanging, and this claim fails as a matter of law.
ii.
No Deliberate Indifference.
Because Jailers Magnus and Prudente were not present when Bland
committed suicide, or the time shortly thereafter, they were not aware of any
serious medical need.
Accordingly, they could not have been deliberately
indifferent to any such need, and this claim fails as a matter of law.
iii.
Qualified Immunity.
Jailers Magnus and Prudente would also be entitled to qualified immunity on

this claim because there is no evidence that any of their actions with respect to any
alleged lack of medical care after Bland was discovered hanging violated any
clearly-established constitutional rights, or were objectively unreasonable.
C.
Negligence Claims Against Jailers Magnus and Prudente Fail as a Matter

of Law.
As noted above, negligent acts and omissions are categorically below the
threshold of constitutional torts. Nonetheless, Plaintiff asserts negligence claims

against Jailers Magnus and Prudente, alleging that they (1) failed to adequately
monitor Sandra Bland to keep her safe and secure, (2) failed to keep her free from
injury, (3) failed to keep her in a safe and suitable environment, (4) failed to
provide adequate medical care after she was found hanging, and (5) failed to
- 29 -
transport her to a medical facility after she was found hanging.66 As set forth
below, however, these state-law claims must be dismissed under the Texas Tort
Claims Act (TTCA) in favor of claims against the County.
The TTCA contains an election of remedies provision, which forces a
plaintiff to elect whether to assert claims against a governmental unit, or its
employees. TEX. CIV. PRAC. & REM. CODE 101.106. Where a plaintiff files suit
against both a governmental unit and its employees, the employees shall
immediately be dismissed on the filing of a motion by the governmental unit. Id.
at (e). In this case, Plaintiff asserts negligence claims against Defendant Jailers
Magnus and Prudente, and against their governmental employer, Waller County.67
Accordingly, County Defendants move for dismissal of Plaintiffs negligence
claims against Defendant Jailers Magnus and Prudente.
D.
Negligence Claims Against Waller County Fail as a Matter of Law.

Plaintiff also asserts negligence claims against Waller County, alleging (1)
inadequate training of jail personnel, (2) inadequate policies regarding face-to-face

observation of jail detainees, (3) inadequate monitoring of Sandra Bland, (4)
failure to keep her safe and secure, (5) failure to keep her free from injury, (6)
failing to keep her in a safe and suitable environment, (7) failing to provide
adequate medical care after she was found hanging, and (8) failing to transport her
66
See Document No. 22 at Count IV (claims against Elsa Magnus) and Count VI (claims against Oscar Prudente).
- 30 -
to a medical facility after she was found hanging.68 However, none of these
allegations relates to operation or use of motor-driven vehicles or equipment, and
none of these allegations relate to the condition or a governmental employees use
of tangible property, and Waller County is therefore immune from such claims.
More specifically, Waller Countys immunity for negligence claims is only
waived under the TTCA, which provides as follows:
A governmental unit in the state is liable for:
(1)
property damage, personal injury, and death proximately caused

by the wrongful act or omission or the negligence of an
employee acting within his scope of employment if:
(A)
(B)
(2)
the property damage, personal injury, or death arises

from the operation or use of a motor-driven vehicle or
motor-driven equipment; and
the employee would be personally liable to the claimant
according to Texas law; and
personal injury and death so caused by a condition or use of

tangible personal or real property if the governmental unit
would, were it a private person, be liable to the claimant
according to Texas law.
TEX. CIV. PRAC. & REM. CODE 101.021. Plaintiff has not alleged any operation
or use of a motor-drive vehicle or motor-drive equipment, and the Countys
immunity is not waived under section (1). Next, Plaintiff has not alleged any
condition or use of tangible personal or real property, and the Countys
67
See Document No. 22 at Count IV (claims against Elsa Magnus), Count VI (claims against Oscar Prudente), and
Count VII (claims against Waller County).
68
See Document No. 22 at Count VII (claims against Waller County).
- 31 -
immunity is not waived under section (2). Plaintiff has not alleged any other
waiver of the Countys immunity, and there is none. Accordingly, Plaintiffs
negligence claims against the County should be dismissed for lack of subject
matter jurisdiction.
E.
Section 1983 Claims Against Waller County Fail as a Matter of Law.

Plaintiff also asserts Waller County is liable under Monell because it had an
official custom or policy that was the moving force behind alleged violations of
Blands rights.69 As set forth below, this claim fails as a matter of law because
Blands rights were not violated, and the County did not have any custom or policy
that was the moving force behind any alleged violation of Blands rights. In
reality, Waller County has policies and provisions in place to prevent suicides.
Plaintiff also asserts a failure to train claim against the County, alleging the
County did not train Jailers Magnus and Prudente on recognizing, supervising,
documenting, and handling mentally disabled and suicidal detainees.70 As set forth
below, this is demonstrably false as both Magnus and Prudente were trained on
these issues. Finally, Plaintiff alleges the County failed to have an established
procedure for visual, face-to-face observation of detainees every 60 minutes (or 30
minutes for suicidal detainees).71 This is also demonstrably false, as set forth
69
See Document No. 22 at Count VIII.

See id.
71
See id.
70
- 32 -
below, because the County had policies providing for such observation, and
published reminders for all jailers.
i.
No Respondeat Superior Liability.
To the extent Plaintiff seeks to impose liability on the County for the actions
of its employees, a local governmental entity cannot be held liable for a
constitutional tort simply because it employs a tortfeasor. Board of the County
Commrs of Bryan County, Okla. v. Brown, 520 U.S. 397, 403 (1997).
ii.
No Monell Liability in This Case.
To establish liability against the County, Plaintiff would have to establish

the County adopted a policy or custom that caused a constitutional violation. See
id.; City of St. Louis v. Praprotnik, 485 U.S. 112, 122 (1988); see also Duvall v.
Dall. County, Tex., 631 F.3d 203, 209 (5th Cir. 2011); Piotrowski v. City of Hous.,
237 F.3d 567, 578 (5th Cir. 2001). Plaintiff alleges the County violated Blands
rights in numerous respects, but her allegations are factually unsupported and
legally insufficient to support liability, as set forth below.
a.
Ignoring Threat of Suicide.
Plaintiff alleges it was County policy to ignore Blands threat of suicide.

However, Bland never threatened suicide, but instead confirmed to two different
jailers that she was not suicidal. See discussion supra at Part III.C. Accordingly,
this claim is factually baseless. In any event, the County had a suicide prevention
- 33 -
policy that required jailers to screen detainees for suicide risks, and to take action if
suicide risks were notedi.e., place the detainee on suicide watch, and refer the
detainee to a Mental Health and Mental Retardation (MHMR) facility. See
discussion supra at Part III.E. Accordingly, even if Bland presented a risk of
suicide which should have been discovered but was not, that was not the result of
any County policy.
b.
Screening Inmates for Suicide
As set forth above, the County had a suicide prevention policy that included
screening, referrals to MHMR, and suicide watch. See discussion supra at Part
III.E. The County also ensured that its screening officers were appropriately
trained on these issues. Plaintiffs claim that the County did not have any such
policy is baseless.
Again, to the extent any jailers did not follow County policies, same is
insufficient to support County liability. See, e.g., Calton v. Livingston, No. H09
2507, 2011 WL 2118700, at *12 (S.D. Tex. May 27, 2011) (officers failure to
follow prison rules does not warrant relief).
c.
Training Jailers on Suicide Risk Detection & Prevention.
Plaintiff next alleges the County failed to implement a suicide prevention

plan to train personnel on recognizing, supervising, documenting, and handling
suicidal detainees. This claim is also factually baseless because the County had
- 34 -
appropriate policies in place, and because all jailers were trained on these matters,
including Defendant Jailers Magnus and Prudente. See discussion supra at Part
III.E; Part III.F. Further, there is no evidence that any County policy was the
moving force behind Blands suicide, or the failure to prevent same. Ultimately,
Blands decision to commit suicide was hers alone, after she denied any suicidal
intentions to jail personnel, and after her friends and family refused to bail her out
of jail.
d.
Face-to-Face Observation of Detainees.
Plaintiff alleges the County violated Blands rights by failing to have an

established procedure for face-to-face observation of detainees every 60 minutes,
or 30 minutes for suicidal detainees.
However, this allegation is factually
unsupported because County policy required such observation, and the County
routinely reminded jailers of the policy. See discussion supra at Part III.E.
To the extent any jailers failed to make a face-to-face observation, despite
County policy, that would not be sufficient to support County liability. See, e.g.,
Estate of Pollard v. Hood County, 579 Fed. Appx. 260 (5th Cir. 2014) (failure to
strictly comply with 15-minute observation orders not actionable); Calton v.
Livingston, No. H092507, 2011 WL 2118700, at *12 (S.D. Tex. May 27, 2011)
(officers failure to follow prison rules does not warrant relief). Further, there is no
- 35 -
evidence that any County policy was the moving force behind Blands suicide, or
the failure to prevent same.
e.
Structural Design of the Jail.
Plaintiff alleges the structural condition of the facility did not facilitate faceto-face observations.
However, this is, again, factually unsupported.
Jail
personnel were not prevented from performing face-to-face observations by any

structural limitations at the Waller County Jail. Moreover, this complaint goes to
whether the County had a policy requiring face-to-face observation, which it did,
as discussed in the preceding sections. In any event, there is no evidence that the
jail had any structural condition that violated Sandra Blands rights.
f.
Inadequate Staffing.
Next, Plaintiff alleges that inadequate staffing prevented face-to-face

observations. This allegation is also factually unsupported. The jail had adequate
staffing under State Jail Commission standards, and there is no evidence that any
inadequate staffing affected jailers ability to perform face-to-face observations.
Moreover, this complaint goes to whether the County had a policy of requiring
face-to-face observation, which it did, as discussed above.
g.
Assigning Hashtags to Detainees Records
Plaintiff next alleges the County violated Blands rights by failing to assign
a hashtag to Blands records to bring Bland to the attention of mental health
- 36 -
personnel. This allegation is factually unsupported because the County had a

policy requiring screening detainees for suicide watch, and referring suicidal
detainees to Mental Health and Mental Retardation (MHMR). See discussion
supra at Part III.E.
To the extent any jailers failed to refer Bland for an MHMR evaluation,
despite County policy, that still would not be sufficient to support County liability.
See, e.g., Calton v. Livingston, No. H092507, 2011 WL 2118700, at *12 (S.D.
Tex. May 27, 2011) (officers failure to follow prison rules does not warrant
relief).
h.
Classification for Housing Assignments
The State Commission on Jail Standards publishes instructions on

classifying detainees for housing assignments. Waller County has adopted and
implemented those instructions as policy, and Bland was properly classified for
housing assignments in this case. See discussion supra at Part III.C. Further, any
failure to follow rules or regulations regarding housing classifications is not
actionable, and claims based on same are frivolous. See, e.g., Reed v. Mgmt. &
Training Corp., No. 3:12-CV-1264-P-BH, 2012 WL 3020082 at *3 (N.D. Tex.
June 15, 2012).
- 37 -
i.
Medical Care
The County also had a comprehensive policy addressing medical care for
detainees, including care in emergency situations. See discussion supra at Part
III.E. Despite Plaintiffs baseless allegation that County personnel did not provide
medical care after Bland was discovered hanging, the evidence establishes that
EMS personnel were immediately notified and responded within minutes. See
discussion supra at Part III.D. While jail personnel waited for EMS to arrive, they
performed CPR. See id. EMS personnel made the decision not to transport Bland
to see a physician after declaring her dead.
For all the foregoing reasons, Waller County did not have any official policy
or custom that was the moving force behind Sandra Blands decision to commit
suicide, or behind any alleged violation of her rights. Accordingly, Plaintiffs
claims fail as a matter of law, and summary judgment is appropriate.
VII.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Defendants WALLER
COUNTY, ELSA MAGNUS, and OSCAR PRUDENTE pray that their Motion for
Summary Judgment be granted, that Plaintiffs section 1983 claims be dismissed
with prejudice, that her negligence claims be dismissed for lack of subject matter
jurisdiction, that all costs be borne by the party incurring same, and for such other
and further relief to which Defendants may be justly entitled.
- 38 -
Respectfully submitted,
____________________________________
Larry J. Simmons Attorney-in-Charge
State Bar No. 00789628
Southern District of Texas No. 18830
B. Eliot New Of Counsel
State Bar No. 24060328
Southern District of Texas No. 884608
GERMER PLLC
P.O. Box 4915
Beaumont, TX 77704
(409) 654-6700 Telephone
(409) 835-2115 Facsimile
COUNSEL FOR DEFENDANTS,
WALLER COUNTY, ELSA MAGNUS AND
OSCAR PRUDENTE
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of County Defendants Motion
for Summary Judgment has been forwarded to all known counsel of record
pursuant to the Federal Rules of Civil Procedure on this the 11th day of November
2015.
_________________________________
Larry J. Simmons
- 39 -
Case 4:15-cv-02232 Document 39-1 Filed in TXSD on 11/11/15 Page 1 of 2

HOUSTON DIVISION
GENEVA REED-VEAL,
deceased,
Plaintiff,
VS.


Defendants.
STATE OF TEXAS
COUNTY OF WALLER
AFFIDAVIT OF BRIAN CANTRELL
BEFORE ME, the undersigned authority, on this day personally appeared
BRIAN CANTRELL, who is personally known to me and who, being duly sworn
on oath to tell the truth, testified as follows:
I.
"My name is Brian Cantrell. I am over the age of eighteen (18) years, have
never been convicted of a felony or crime of moral turpitude, and am
competent to make this Affidavit. I have personal knowledge of the facts
contained herein, and those facts are true and correct.
2.
I am a Captain in the Waller County Sheriff's Office, the Jail Administrator

for the Waller County Jail, and a custodian of records for Waller County,
Texas ("County"). The records listed below and attached to County
Defendant's Motion for Summary Judgment are true and correct copies and
exact duplicates of records maintained by the County in the ordinary course
of business. It was in the regular course of business for an employee or
representative of the County, with knowledge of the act, event, condition, or
opinion recorded, to make the record or to transmit information thereof to be
Page 1 of 2
included in such records, and such records were made at or near the time of
the event or events recorded, or reasonably soon thereafter. The following
exhibits attached to Defendant's Motion for Summary Judgment are true and
correct copies of the originals:
Exhibit A
Affidavit and Complaint for Arrest Warrant;
Exhibit D
Trooper Encinias ' Intake Form;
Exhibit E
Jailer Prudente's Intake Form;
Exhibit H
Jailer Magnus' Screening Forms;
Exhibit I
Classification Records;
Exhibit J
Video from July 13, 2015 (on CD/DVD);
Exhibit L
Door/Intercom Log;
Exhibit M
Excerpts from Waller County Incident/Offense Report;
Exhibit 0
Excerpts from Waller County Jail Policies & Procedures;
Exhibit P
Excerpts from Waller County Jail Memo Book;
Exhibit Q
Excerpts from Jailer Magnus' Training Records; and
Exhibit R
Excerpts from Jailer Prudent& s Training Records.
FURTHER AFFIANT SAYETH NOT.
BRI N CANTRELL
SUBSCRIBED AND SWORN TO, BEFORE ME, by

this the
Brian Cantrell,
on
/04'day of November, 2015, to certify which witness my hand and seal of
office.
diejr.
74
f.f
"4,WO
JUSTIN E ....LEY LANE

't.te
- of Texas
Notary Pul
Com!
Sepiely
qn10.
1\ rotar Public for the State of Texas
:.'"Ne"irdiroN,
Page 2 of 2
Cause Number ea,.
/-1".20/57
X IN THE (MUNICIPALXJUSTIDE)
X ICOUNTYX018TRICT) COURT
(PCT OR C.C. AT LAW _J
x IN WALLER COUNTY, TEXAS
THE STATE OF TEXAS

COUNTY OF WALLER
AFFIDAVIT and COMPLAINT FOR WARRANT OF ARREST AND DETENTION

' IN THE NAME AND BY THE AUTHORITY OF THE STATE OF TEXAS
The Undersigned Merit, who after being duly sworn by me, on oath makes the following statement:
1, Trot, er BRIAN T ENCINIA #14271, have ood reason to believe and do believe that BLAND,
SANDRA ANNETTE B/F DOB
TX, DUID#1111.111 on or about the 10July, 2015 in
WALLER County, Texas, did then and there commit the offense of:
ASSAULT PUBLIC SERVANT (TXPC 22.01 (b)(1))

Felony -Class 3
My belief of the foregoing statement is based upon personal knowledge, who personally observed such offense:
On Friday, July 10, 2015, at approximately 04:27 p.m., I, Trooper Brian Encinia was on routine patrol in Waller
County, Texas. I observed a sliver passenger car traveling southbound on Fm 1098 for failing to signal lane change.
The vehicle was identified as a H undat Aura Illinois LP; B45378187638. The driver was identified as Bland, Sandra
Annette TX DL
D08:
1; through DPS Pierce Communications. I had Bland exit the vehicle to
further conduct a safe traffic investigation. Bland became combative and uncooperative. Numerous commands were
given to Bland ordering her to exit the vehicle. Bland was removed from the car but became more combative. Bland
was placed in handcuffs for officer safety. Bland began swinging her elbows at me and then kicked my right leg in the
shin. I had a pain in my right leg and suffered small cuts on my right hand. Force was used to subchie Bland to the
ground to which Bland continued to fight back. Bland was placed under arrest for Assault on Public Servant(TXPC
22.01 (B) (1)). The vehicle was inventoried and released to Crown Towing. Bland was transported and booked into
the Waller County Jail for Assault an Public Servant(TXPC 22.01 (B) (1)).
This offense was committed against the peace and dignity of the state of Texas.
Affiant Trooper BRIAN T ENCINIA #14271

SWORN AND SUBSCRIBED TO before me by the said Affiant on this the 10July, 2015.
F7 ,r"
114
Notary Public
ElPeace Officer, in and for
The State of Texas WALLER County
day of FOUY
On this the I
, 20l-5 I hereby acknowledge that I have examined the
foregoing Affidavit and have determined that probable cause does exist for the Issuance of an arrest warrant
for the individual accused herein.
Magistrate In and tr. WALLER County. Texas
Page 1 of 1
BTE #14271
Texas DPS - Affidavit
TXDPS Report# TX4DHIONFW19
DEF000820

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County EMS
Patient Care Record
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MEDIC 20 DISPATCHED TO A TRAUMA CALL FROM D2 STATION. AOSTF A PT IN CUSTODY OF LE. PT DID NOT WANT EMS. PT WOULD NOT ALLOW
EMS TO ASSESS OR TAKE VITALS. PT WAS NOT IN ANY DISTRESS. PT LEFT IN CUSTODY OF LE AND MEDIC 20 RETURNED TO SERVICE. FOR
T.GARRETT EMT-B
.....
Page 1 of 5
07/10/2015 17.12
PCRI 3af03I;e4-80013-47f2-1,8e7-a4d1011e857;
Electronically Signed by.. GARRETT, TIMOTHY
EXHIBIT
DEF000821
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3
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Patient Care Record
Name: ,
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Date: 07/10/2015
Patient 1 of 1
Incident Details
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Page 2a'5
07/10/201517.31
PCRID: 3a103be4-80c8-47t2-Me744d101 le867.5
Electronically Signed by: GARRETT, TIMOTHY
DEF000822

Wa0 e;:6ounty EMS
Patient Care Record
Name:,
Facili Si natures
Date: 07/10/2015
Patient 1 of 1
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Page 5 of 5
07/10/201517.32
PCRID: 3af036e4-8008-4712-68e7-a4d1011e8675
Electronically Signed by: GARRETT', TIMOTHY
DEF000823
HARRIS COUNTY
INSTITUTE OF FORENSIC SCIENCES

SCIENCE. SERVICE. INTEGRITY.
Luis A. Sanchez, M.D,

Executive Director &
ChM Medical Examiner
AUTOPSY REPORT
Case No. OC1 5-030
July 14, 2015
ON THE BODY OF
Sandra Annette Bland
CAUSE OF DEATH: Hanging

MANNER OF DEATH: Suicide
DATE OF DEATH: July 13, 2015
_L(A0
Sara N. Doyle, M.D.
Assistant Medical Examiner
112-2-11c
MMDDYY
EXHIBIT
C
,Noglog
.
/.1411.
18135 Old Spanish Trail, Houston, Texas 77054 1 71 34004202 I 713-796-6844 (F) I harrispounlytx.govfifs
DEFO 0 08 7 9

0C15-030
-2POSTMORTEM EXAMINATION ON THE BODY OF
This 28-year-old black woman, positively identified by fingerprint
HISTORY:
comparison as Sandra Annette Bland, was pronounced dead at 9:06 a.m. on July 13,
2015 in the Waller County Jail at cell block 95, where she was found hanged in her
solitary jail cell.
AUTOPSY: The autopsy is performed at the Harris County Institute of Forensic Sciences
by Assistant Medical Examiner Sara N. Doyle, M.D., at the request and upon the written
authorization of the Honorable Charles J. Karisch, Justice of the Peace, Precinct 1, Waller
County, Texas, beginning at approximately 10:15 a.m. on July 14,2015. Texas Ranger
Ellison and investigator Parinello of the Waller County Sheriff's office are in attendance.
CLOTHING AND PERSONAL EFFECTS: When first viewed, the decedent is clad in two
orange shirts, a pair of orange pants, and underlying orange shorts. There are no
personal effects.
Received in the body bag with the decedent is a paper bag labeled " Trash Bag Used as
Ligature; Removed on 7-13-15 @12:14 PM; Bland, Sandra Annette; B/F OMB
Custodial Death; Waller Co. Jail" containing a transparent white plastic trash bag tied into
a ligature, which is subsequently described under the EVIDENCE OF INJURY paragraph.
EXTERNAL APPEARANCE: The body is that of a normally developed, 70 inch, 1 64-1 /2
pound black woman who appearance is consistent with the given age of 28 years. The
curly black hair measures up to approximately 4-1/2 inches in length. The eyes have
brown irides. The conjunctivae have no hemorrhage, petechiae or Jaundice. Each
earlobe is pierced twice. Multiple tattoos are over the body as documented on
photographs. A 1-Inch curvilinear scar is at the umbilicus. A 4-inch horizontal linear
scar is on the lower abdomen. A 1/4-inch scar is on the lateral left antecubital fossa.
A 3/8-inch oval raised scar is on the dorsal left wrist. The oral cavity has natural teeth
in good repair. The oral mucosa is atraumatic and has no petechiae. The neck is
remarkable for a ligature furrow as subsequently described under the EVIDENCE OF
INJURY paragraph. The torso and extremities are normally developed. The fingernails
are short and intact. The hands have no injuries. The genitalia, including the labia
DEF0068805/144

OCI 5-030
-3majora, labia minora, posterior fourchette, and vaginal canal are free of injuries. Pasty
white discharge is at the vaginal introltus. The anus is unremarkable and has no
injuries.
POSTMORTEM CHANGES: There is marked rigor mortis of the upper and lower
extremities, neck, and jaw. Lividity is blanching, pink-purple and is visible posteriorly
in the dependent areas as well as over the palms. The body is cold, subsequent to
refrigeration.
THERAPEUTIC INTERVENTION:
Defibrillation pads are over the torso.
An
electrocardiogram adhesive pad is on the upper right arm.

EVIDENCE OF INJURY:
I. HANGING: When first viewed, a ligature furrow is around the neck. Anteriorly, it is
oblique, and is located at the level of the superior thyroid cartilage to the right of
midline, and above the thyroid cartilage to the left of midline. It cants upward posterior
to the left ear across the left side of the neck. It is roughly horizontal at the right side of
the neck, canting slightly upward posteriorly. The furrow at the anterior, right lateral,
and left lateral neck is dried, brown and ranges from approximately 1/4 to 3/8 inch in
width. The highest point of the furrow is posteriorly at the central occipital
scalp/superior neck region, where it is located slightly below the occipital prominence,
and consists of a faint purple furrow approximately 3/8 - 1/2 inch wide which cants
downward toward the right side of the neck. The furrow is absent at the posterior left
neck for approximately 2 inches in horizontal dimension.
Internal examination of the anterior and posterior neck strap muscles reveals no focal
hemorrhages. Slight drying and compression involve the superficial superior neck strap
musculature directly underlying the furrow. The hyoid bone, thyroid cartilage, and
crlcoid cartilage are intact without fractures. The cervical vertebrae are intact without
injury.
No petechiae of the face, conjunctivae, oral mucosa, or airway are identified.
A ligature received in the labeled paper bag previously described consists of a plastic
transparent white trash bag which is tied into a slip knot that forms a circle at one end
and a knotted area at the opposite end, with two cut ends extending from the knot
DEF000881

Oci 5-030
-4opposite the circular area. The circular area formed by the slipknot is approximately
6-1/2 inches in internal diameter. The area from the slip knot of the circular end to the
opposite knotted end of the ligature is 21 inches in length. The two cut ends extending
from the knotted end opposite the circular area are approximately 5 inches and 3 inches
in length. The plastic trash bag ligature and paper bag are photographed, and the
ligature is submitted to EVIDENCE in the paper bag in which it was received, placed into
an additional outer evidence bag.
II. SUPERFICIAL HEALING CUT MARKS, VOLAR LEFT FOREARM: The volar left forearm
contains approximately 25 to 30 horizontal faint linear healing scabbed superficial
incised wounds with focal pale, scarred regions of healing, which are parallel and range
in length from 3/16 to 1 inch.
Ili.
HEALING BLUNT INJURIES: The superior right shoulder has a 1 inch oval faint
purple contusion with underlying red-brown subcutaneous hemorrhage. A 6 by 6 inch

area of the right upper back contains multiple scabbed horizontal linear and irregular
abrasions ranging from 1/4 to 1-1/2 inch. A 3-inch area of faint red-brown patchy
subcutaneous hemorrhage underlies this area of abrasions. A fragment of foreign
material consistent with plant (dried leaf) material is adherent to one of the healing
abrasions of the upper back, and measures approximately 1/4 inch in greatest
dimension. It is photographed and submitted to evidence in an envelope labeled
"Foreign material from scabbed area of right upper back".
The right upper extremity has a 1-1/2 inch-faint brown-purple contusion of the medial
elbow region with underlying red-brown subcutaneous hemorrhage. Multiple adjacent
small scabbed healing abrasions ranging from 1/16 to 1/4 inch are also in the medial
right elbow region. A 1 inch faint purple-brown contusion is on the dorsal left forearm
with underlying red-brown subcutaneous hemorrhage.
The radial left wrist has a 3/8 inch horizontal linear scabbed healing abrasion. The
subcutaneous tissue of the left wrist has 3/4 inch areas of brown-red hemorrhage at the
radial and ulnar surfaces of the wrist. The right wrist has a 3/4 inch horizontal linear
scabbed healing abrasion at the radial edge. The right wrist has faintly visible
red-brown subcutaneous hemorrhage approximately 1/4 to 1/2 inch in greatest
dimension at the ulnar and radial edges of the wrist.
DEF000882

0C15-030
-5The injuries above, having been described, will not be repeated.
INTERNAL EXAMINATION:
BODY CAVITIES: The organs are in their normal sltus. The pleural, pericardial, and
peritoneal cavities contain no abnormal fluid accumulations or adhesions.
HEAD: The scalp has no contusions. The skull has no fractures. There are no
epidural, subdural, or subarachnoid hemorrhages. The brain weighs 1325 grams and is
normal size and shape. The leptomeninges have no exudates. The cerebral vessels
have no aneurysms or atherosclerosis. The external aspects of the brainstem and
cerebellum are unremarkable. Corona! sections of the cerebrum reveal no focal lesions
of the cortex, white matter, or deep nuclear structures. The ventricles are normal size
and configuration. The brainstem and cerebellum have the usual patterns on cut
surface.
NECK: Evidence of hanging is previously described under EVIDENCE OF INJURY. The
cervical vertebrae, hyoid bone, tracheal and laryngeal cartilages, and paratracheal soft
tissues have no visible injuries. The upper airway is patent. The tongue is
unremarkable.
CARDIOVASCULAR SYSTEM: The heart weighs 300 grams and has a right-dominant
coronary artery circulation without atherosclerosis of the epicardial vessels. The
myocardium has no focal lesions. The left ventricular free wall and Interventricular
septum are each 1.2 centimeters and the right ventricle is 0.3 centimeters thick. The
endocardial surfaces and four cardiac valves are unremarkable. The aorta has no
atherosclerosis. The venae cavae and pulmonary arteries contain no thrombi or emboli.
RESPIRATORY SYSTEM: The right lung weighs 400 grams and left weighs 350 grams.
The lungs are slightly congested and have no masses or consolidation. The bronchi are
unremarkable.
LIVER, GALLBLADDER AND PANCREAS: The liver weighs 1320 grams and has an intact
capsule and brown-red parenchyma without focal lesions. The gallbladder contains 15
milliliters of green bile without stones. The gallbladder mucosa is unremarkable. The
pancreas is unremarkable in lobulation, color, and texture.
DEF000883
10()

OC1 5-030
-6SPLEEN AND LYMPH NODES: The spleen weighs 100 grams and has an Intact capsule.
The color, red and white, pulp and consistency are unremarkable. There are no
enlarged lymph nodes. The bone marrow, where viewed, is unremarkable.
ENDOCRINE SYSTEM: The thyroid and adrenal glands are normal color, size, and
consistency.
GENITOURINARY SYSTEM: The right kidney weighs 125 grams and the left weighs 150
grams. Each kidney has a smooth, red-brown surface with an unremarkable
architecture and vasculature. The ureters maintain uniform caliber into an
unremarkable bladder which contains less than 1 milliliter of cloudy yellow urine. The
ovaries and fallopian tubes are unremarkable. The vagina has no trauma or lesions, and
has focal pasty white film over its mucosa. The uterus has a slightly thick, red-tan
endometrium and has no evidence of pregnancy. The cervix is unremarkable.
GASTROINTESTINAL SYSTEM: The esophagus and gastroesophageal junction are
unremarkable. The stomach contains approximately 170 milliliters of gray-tan fluid
without solid particles. The gastric mucosa has no focal lesions. The serosal surfaces
of the small intestine and large intestine are smooth and glistening. The vermiform
appendix is absent, with surgical staples at its resection site.
MUSCULOSKELETAL SYSTEM: The vertebrae, clavicles, sternum, ribs, and pelvis have no
fractures. Examination of the subcutaneous tissues and musculature of the anterior
and posterior torso and upper and lower extremities reveals no hemorrhages or injuries
except those as previously described under EVIDENCE OF INJURY.
TOXICOLOGY: Specimens including blood, vitreous, urine, bile, stomach contents, liver
and brain submitted to toxicology.
HISTOLOGY: Specimens including heart, lungs, liver, kidney, spleen, brain, and uterus
submitted to histology.
PHYSICAL EVIDENCE: Specimens including clothing, ligature (white plastic trash bag) In
the paper bag in which it was received with the decedent's body, fingernail scrapings
and clippings, sexual assault evidence collection kit, and foreign material from scabbed
area of right upper back are sealed in evidence containers and released to Investigator M.
DEF000884
0;)

0C1 5-030
-7Parinelio of the Wailer County Sheriff's Office. (NOTE: Despite absence of injuries to
the genitalia or anus, a sexual assault evidence collection kit is obtained should future
testing be warranted.)
PATHOLOGICAL FINDINGS
1. Hanging
A. Ligature furrow around neck
B. Internal examination negative for neck musculature hemorrhages
C. Internal examination negative for fractures of hyoid bone, thyroid cartilage,
cricoid cartilage and cervical vertebrae
D. Investigative information Indicates the decedent was found hanging from a beam
In her solitary jail cell by a ligature made of a transparent white plastic trash bag
E. Ligature (plastic trash bag) recovered and submitted as evidence
II. Healing superficial parallel horizontal incised wounds numbering approximately
25-30 of volar left forearm
Ill. Healing superficial blunt injuries

A. Healing abrasions and contusions, right upper back and shoulder
B. Healing abrasions and contusions, right elbow region
C. Healing contusion, left forearm
D. Healing abrasions and contusions, bilateral wrists
DEF000B85
904)

0C15-030
-8HARRIS COUNTY INSTITUTE OF FORENSIC SCIENCES
1885 OLD SPANISH TRAIL
HOUSTON, TEXAS 77054-2001
Sara N. Doyle, M.D.

OCI 5-030
MICROSCOPIC EXAMINATION
Summary: Five H&E-stained slides are examined.
HEART - Sections from the left and right ventricles have focal mild myocyte hypertrophy
and otherwise no significant pathologic change. Three sections of myocardium are
examined.
BRAIN - Sections of the hippocampus and frontal lobe have no significant pathologic
change.
LUNG - Vasculare congestion. Intra-alveolar edema and congestion. Focal mild
peribronchial chronic inflamthation.
LIVER - Vascular congestion, otherwise no significant pathologic change.
KIDNEY - Vascular congestion, otherwise no significant pathologic change.
SPLEEN - Congestion of red pulp, otherwise no significant pathologic change.
UTERUS - Unremarkable late secretory endometrium and normal myometrium.
5SMP
_AAD
Sara N. Doyle, M.D.

MMDDYY
DEF000886
QW, Harris County Institute of Forensic Sciences

Case Number:
orcrc-7. P6-1 3 - (25
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Length:
Decedent's Name: e2a.,,d,,,
6lo C(
Examiner:
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Sectiorr Pathology
autopsy Diagram Adult Female, Front/ Back
form
Rev
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Time: /0 !/gipi
Authorized by: DA Wolf

;orm
P4TAX12
Rev date: 11.1S/11
DEF000887

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DEF000888

Harris Count institute of Forensic Sciences
Case Number'
Decedent's Name:
Date:
r section:
paoti2/v
Form Title: Autopsy Dia w am Hands, all views

1 Rev.:
Authorized b DA wolf
Form No.: PAT.010
Rev. date: 11/5/13
DEF000889
HARRIS COUNTY INSTITUTE OF FORENSIC SCIENCES

1885 Old Spanish Trail
Houston, Texas 77054-2001
Phone: 713-796-6830 Fax: 713-796-6838
LABORATORY REPORT
July 21, 2015
LABORATORY NUMBER: OC15-030
1111 II 11111111M
I 1 01 1 1 1 is11111111111111
Deceased: SANDRA ANNF,TTE BLAND
Submitted By:
Sara N. Doyle, M.D.
Harris County Institute of Forensic Sciences
1885 Old Spanish Trail
Houston, TX 77054
Agency Number: 0C15-030

Submission Date: July 14, 2015
[pecimen: Blood (femoral)

A,natyte
Result
Analytical Method
Analyst
Della-9-ictrahydrocannabinol
Norcarboxytetraltydrocannabinol
18*4 ugli
120.127 ug/L
GC/MS/MS
GC/MS/MS
D. Mike
D. Mike
Specimen: Blood (femoral)

Analyte
Result
Analytical Method
Analyst
Ethanol, Methanol, Isopropanol, Acetone
None Detected
Hoadspace GC
A. Salazar
Analyst
[fleeitnen: Blood (subclavian)

An alyte
Result
Analytical Method
Amphetamine
None Detected
Immunoassay - ELISA
M. Lenoir
Barbiturates
None Detected
Immunoassay - E.1.1SA
M. Lenoir
Benzoditreepines
None Detected
Inununoassay - ELISA
M. Lenoir
CocaineNletabolite
None Detected
immunoassay - ELISA
M. Lenoir
Methadone
None Detected
Immunoassay - ELISA
M. Lenoir
Melliamplietamine
None Detected
Immunoassay - ELISA
M. Lenoir
Opiates
None Detected
Immunoassay - ELISA
M. Lenoir
Phencyclidine
None Detected
Immunoassay - ELISA
INsTiTuti 605RENS1C SCIENCES
JUL 2 2 2015
Level of Confidence: The uncertainty value for ethanol represents an expanded uncertainty exiiresscd at the 99.73% love
confidence. The Uncertainty values for all other annlyteq represent an expanded uncertainty expressed at the 95.45% leve
RECEIVED
CORDS CUSTODIAN
rtmildenro,
Anna Kelly, Ph.D.,

Technical Reviewer
Toxicologist LI .Speeialist
July 21, 2015
Fessessework Clink DVM, D-A}3VT, 0-ABET-FT

Expert Reviewer
Toxicology Analytical Operations Manager
July 21,
2015 Medical Examiner's initial AVO7 / 1- ?')/C

Unless otherwise requested, toxicology specimens will he discarded one year after date of receipt.
Page 1 of 1
This Laboratory is Mdredited by ASCLDILAB-International and ABFT,
ncstmexitepoeoulis
DEF000890
1)011. Lo1, 1
A I L
eivf:4LLER COUNTY SHERIFF'S OFFICE
INFORMATION
SU:SP ECT
NAME:
. PRISONER INFORMATION
ii
i
MEDDLE
FIRST
LAST
SEX.PerteatO DOB: 11111.1111
RACE: FW'Af
ALIAS
DL NUMBER: 111111111111___
1
AGENCY CASE NUMBER: 'TX
14DHJ01-4Fvv 1 (j
ARREST 'IN'E; 0.,R :M A 7 I- 0 N

TIME:
DATE : #SePaStran
Le; e
PHYSICAL CONDITION (OFFICER OBSERVATION)

IS PRISONER suiaDAL DR mEli:TALLY ILL (V0
ARRESTING OFFICER:
NO...M.
pps
LIST FIREARMS IN POSSESSION OF PRISONER'
.3- rierArck
BADGE:
C HARGE
LIST EACH OFFENSE
u48
LOCATION :
IIV1 1 AGENCY
IN-TOkiviA-T:1 0 N
WARRANT
NUMBER
COUNTY
DATE OF
OFFENSE
COURT
CLASS
CODE
--owe
?/la/ r, Dair,t7L
EvA,lie r
BLE CAUSE STATEmENTNo wARRANT / commr.imEwr WRITE BRIEF FR
icetre
LP.:DE
g2t.
(ADM:TT:01M_ comAENTS DR REVERSE SIDE)
PRISONEIR
\
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COIN
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iL
.PROPERTY NMENTORY
7Kum)Caen s
Live. tiAtkeAL-
6Icitk
(*r M/55
b an
)81111111111111111111
/4
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I re
VEHICLE=.)
.AR11.5.1_:E0=i;DliAtaftIN DEVvIATION.
WAS THE ARRESLEO' SUBJECT: DRIVING A MOTOR VEHICLE YES, NO COMRERCIAL VEHICLE
NO 141 RESPONSIBLE FOR A VEHICLE. YES NO d/r/
YES
*** IF YES SEE BELOW --'"
NIEARahel 13
MKE
pIDDELA2-erdA.
il-iyvAde.;
LP Tili1A-0'.$
ST TE aIIIIMIIIg
COLOR ElltleP
VIN:
n..
of #
O
LOCATION iro 1,
1657` Tail-ieL
[ (it,
EXHIBIT
aa-44,ix
SIGNATURES :
DEPUTY / OFFICER DELIVERING PRISONER & PROPERTY
JAILER RECEIVING PR ISOMER ,& FROPERTY
DATE:
rak_
TIME:
177
5
DEF000824
co
County
Screening Form for Suicide and Matfical and Mental Impairments
Par Jail Sitnderd g273.5(1): ALL Quesdons Si-LA LL be Complei74 in Full Immediete/y Upon Admission of Ini-n=re
Del- of Striti:
Ste ID Number known
S.0 #
Compist.d $y.
DEdice.1 r.13,71dmon
ti in7zEts = rtsk
ErEtiEa
mantel illness, mantel retardation, Zr S'uizids cozzarn?
(Vide one or More. ii
Doesemer....-1:- CaZC.7..r
o+ al
N otni nti Pcodas
L'ommeTit.:
SELF-REORT QUES110NS (please _!=boats as needed):
vi III...o'i:_s: orotliemz, rezant hoso:ta.*;zsas w YE7131...5 inFiries oz =poems ...bout witid=v,s.17

A.-.). oulet
YE NM0
yt.:1
Yes
hro
Not S:ire.
Y-
Yase.No
TEknr: Madezatiz-77
stir.rzes "or mama' Ilse:, or mere'
yo., even.
Do -put7_oaree z at= af marl;/

you FAT,:
de'pone
Yea0 N
som=ltdu..T.tion7
Yaa Nye
Ya5 Nre
Do pu ha-..re any ormy.ms map.r/ sarJ eav
you hear arty nmistm or votota that ci_Phti..r. people. don't seem to hear?
Yes0
vs")'
Have yoo evEr
D you fsei thr. vrai 71=w';
Yea _1 Nop
Have you had thoughts e kahn9 yourself rr tre ;eet year
STAFF OBSERVATIONS (please slaborau as na-enedl:
\
Do7.5 '6'R-individual seem (area eF -iet epply). confused , pre-occupied. hopalas..s, sEdzo,...
paranoid, in an unusually good mood or believes hers he is someone else?
N.!
=
thE
or childlike"?
ttet apiyj rapid hard to understand hesitant,
NI
Obs,,rved to be :mder l-re iii
V0 1
Akohol?
Drugs? MIMI-swats? NO
Obss.-ri.e.d to hs v!atie ns of sell harr fi e outs on arms

boas tha soreenar
rya. when Es
USps-ct menial illnassimental retardation?
2 maglsh-ate noted?
OstariTne
Yes fl
'rasp
Howl Writes I Electronic (=kola)
Additional comments:
This tune is Noi a substitute fsr a SE1;121.t.31-ioreith Screening Reoord required under 273.4
Revised 9/10/2014
DEF000826

HOUSTON DIVISION
GENEVA REED-VEAL,
deceased,
Plaintiff,
VS.


Defendants.
STATE OF TEXAS
COUNTY OF WALLER
AFFIDAVIT OF OSCAR PRUDENTE
Oscar Prudente, a person whose identity is known to me, and who being first duly
sworn by me, upon his oath stated:
1. "My name is Oscar Prudente. I am over the age of eighteen (18)
years, have never been convicted of a felony or crime of moral
turpitude, and am competent to make this Affidavit. I have
personal knowledge of the facts contained herein, and the facts are
true and correct.
2. I was employed by Waller County ("County") as a Jailer before
and during Sandra Bland's detention.
3. Prior to July 10, 2015, I was a licensed jailer in the State of Texas,
which required completion of a 96-hour courseincluding course
EXHIBIT
instruction on, for example, recognizing, supervising,

documenting, and handling suicidal detainees, housing
classification for detainees, and monitoring detaineesand
successful completion of a written test.
4. Also prior to July 10, 2015, I received on-the-job training as a
jailer from Waller County, in addition to reviewing the Waller
County Jail Policies and Procedures, and the Waller County Memo
Book.
5. Also prior to July 10, 2015, I became a licensed peace officer in
the State of Texas, which required completion of a 643-hour
courseincluding course instruction on dealing with individuals
suffering from mental health issues and who may be suicidaland
6. On Friday, July 10, 2015, at approximately 5:30 p.m., Sandra
Bland was arrested and brought to the Waller County Jail. I
performed the initial intake screening on Ms. Bland. Part of that
screening involved interviewing Ms. Bland to attempt to identify
any potential mental health issues, or any potential suicide risk.
7. During the screening process, Ms. Bland was angry, with her anger
directed at the arresting officer, and her perception that she should
not have been arrested. Her emotional state was very similar to a
large percentage of arrestees. She did not appear depressed or sad,
and she was alert and oriented. She did not appear to suffer from
any mental health issues, and she credibly told me she was not
contemplating suicide.
8. When she reported to me that she had attempted suicide in 2014,
after losing a baby, I asked her follow-up questions, and she
disclosed she had taken pills at the time, but that she no longer felt
that way. Based on her demeanor, her responses to questioning,
the charged offense, her perception that she would be bailed out of
jail quickly, and the totality of the circumstances, and in light of
my training, education, and experience, I did not believe her to be
a suicide risk. Accordingly, I placed her in a regular holding cell,
to wait to be booked.
-2-
9. I had no further interaction with Ms. Bland, and my shift ended

shortly thereafter at 7:00 p.m. on Friday, July 10, 2015. I did not
work over the weekend and had no other interaction with Ms.
Bland during her detention in the Waller County Jail. I was not
present when she was discovered hanging in her cell on Monday,
July 13, 2015.
Further affiant sayeth not."
Oscar Prude
SUBSCRIBED AND SWORN TO, BEFORE ME, by Oscar Prudente, on
ay of November, 2015, to certify which witness my hand and seal of
this the
office.
POrtiNI:t,
Notar
A.t My
4;;Ii:t7
Sep;:rrabs. 1j
NIMEMIMMINOWNIIIMIN.ne
..A
Texas
sires
A016
Notary Public for the State of Texas

HOUSTON DIVISION
GENEVA REED-VEAL,
deceased,
Plaintiff,
VS.


Defendants.
STATE OF TEXAS
COUNTY OF WALLER
AFFIDAVIT OF ELSA MAGNUS
Elsa Magnus, a person whose identity is known to me, and who being first duly
sworn by me, upon her oath stated:
1. "My name is Elsa Magnus. I am over the age of eighteen (18)
true and correct.
2. I was employed by Waller County ("County") as a Jailer both
before and during Sandra Bland's detention.
3. Prior to July 10, 2015, I was a licensed jailer in the State of Texas,
which required completion of a 96-hour courseincluding course
EXHIBIT
I er
instruction on, for example, recognizing, supervising,

documenting, and handling suicidal detainees, housing
classification for detainees, and monitoring detaineesand
4. Also prior to July 10, 2015, I received on-the-job training as a
jailer from Waller County, in addition to reviewing the Waller
County Jail Policies and Procedures, and the Waller County Memo
Book.
5. Also prior to July 10, 2015, I received formal classroom training
on recognizing, supervising, documenting, and handling suicidal
detainees, housing classification for detainees, and monitoring
detainees, including:
Feb. 22, 2008:
Sep. 30, 2009:
Jul. 9, 2010:
May 9-13, 2011:
May 31, 2011:
Sep. 29, 2011:
Dec. 11, 2012:
Jun. 13, 2014:
Dec. 16, 2014:
Dec. 17, 2014:
Completed Basic Jail Course (96 hrs)

Completed LEMIT Jail Course (8 hrs)
Completed County MHMR Course (2 hrs)
Completed TJA Jail Course (appx. 32 hrs)
Completed County Suicide Prevent Course (2 hrs)
Completed Jail Classification Course (4 hrs)
Completed LEMIT Legal Issues Course (4 hrs)
Completed LEMIT Suicide Course (4 hrs)
6. I started my shift at 7:00 p.m., on Friday, July 10, 2015. At that

time, Sandra Bland was already in the Waller County Jail. She had
been through initial intake, and she was in a holding cell.
7. At approximately 8:15 p.m., I booked Ms. Bland into the jail. Part
of that process involved interviewing Ms. Bland to attempt to
identify any potential mental health issues, or any potential suicide
risk.
8. While I was interviewing Ms. Bland, she appeared upset that she
had been arrested, primarily because she did not think she should
have been arrested for what she called a "minor" offense. She did
not appear depressed or sad, and she was alert and oriented. When
I asked her if she was depressed, she said, "I am not depressed. I
-2-
am pissed off." However, she was teary-eyed at one point during

our interview which is not unusual during the booking process.
She did not appear to suffer from any mental health issues, and she
credibly told me she was not contemplating suicide.
9. When she reported to me that she had previously attempted suicide
after losing a baby, I asked her follow-up questions, and she
disclosed she had taken pills at the time, but that she no longer felt
that way. We also discussed that she would be making a phone
call soon, and she expressed that her friend would be bailing her
out of jail.
10.1 noted that she had not been charged with any particularly
embarrassing offenseL e., child pornography or sexual assault
and her charge was unlikely to result in a lengthy sentence, which
could make her more likely to contemplate suicide.
11.Based on her demeanor, her responses to questioning, the charged
offense, her perception that she would be bailed out of jail quickly,
and the totality of the circumstances, and in light of my training,
education, and experience, I did not believe her to be a suicide risk.
Accordingly, I proceeded to the next step in the booking process.
12.The next step was to perform Ms. Bland's housing classification.
To do that, we follow a classification tree. Based on a number of
objective criteria, detainees are classified and then housed
according to that classification. In Ms. Bland's case, she was
classified as medium-assaultive. In the Waller County Jail,
females with that housing classification are assigned to Cell 95, a
multi-person cell. At that time, however, Ms. Bland was the only
female meeting that classification, and she was therefore housed
alone.
13.Once we completed Ms. Bland's booking process, I allowed her to
make a free phone call from the booking station, as opposed to a
collect call from within her cell. I do not know who she called, but
she mentioned she was calling her friend. The call was answered,
and I heard her explain that she had been arrested for what she
considered a minor offense. Thereafter, she was placed in her
assigned cell. I would have seen Ms. Bland throughout that shift,
-3-
which ended at 7:00 a.m. on Saturday, July 11, 2015. However,

do not have any specific recollection of any interaction I had with
her, and I did not observe her exhibiting any behavior suggestive
of a risk of suicide.
14.My next shift began at 7:00 p.m. on Saturday, July 12, 2015. At
that time, Ms. Bland had seen a magistrate judge and had her bail
set. However, I was not present for that process. I also was not
present when she may have been given free phone calls at the
booking desk following the setting of her bail.
15.1 would have seen Ms. Bland throughout that shift, which ended at
7:00 a.m. on Sunday, July 12, 2015. However, I do not have any
specific recollection of any interaction I had with her, and I did not
observe her exhibiting any behavior suggestive of a risk of suicide.
16.1 had no further interaction with Ms. Bland after my shift ended at
7:00 a.m. on Sunday, July 10, 2015. I was not present when she
was discovered hanging in her cell on Monday, July 13, 2015.
Further affiant sayeth not."
Elsa Magnus
SUBSCRIBED AND SWORN TO, BEFORE ME, by Elsa Magnus, on this
the 3 n-l-hday of November, 2015, to certify which witness my hand and seal of
office.
fu
Public for the State of Texas
-4-
BLAND, SANDRA ANNETTE

SO # 026981
DOB 1111111111. Desc
Black Female 175
Medical Intake
07/10/2015 8:17 PM
Insurance
Carrier
Comment
No
TB Test Date
Date Test Read
X-Rays Ordered
Treatment for TB Given
Booked 07/10/2015 6:15 PM

Officer
MAGNUS, ELSA
Badge # EM3679
Policy #
Test Results
Reaction
X-Ray Results
by
by
by
No
intake Questionnaire
No
No
8, Alcoholism?
No
9. Mental Illness?
No
10. Venereal Disease? No
15. Other Conditions?

16. Treatment Info:
17. Recent injuries:
Hypertension?
No
11. Tuberculosis?
5.
6.
Diabetes?
Epilepsy?
No
Yes
7.
INMATE STATES
SHE HAS
EPILEPSY
Drug Addiction?
12- Attempted Suicide? No

13. Communicable
No
Diseases?
18. Treatment - Recent N/A

Injury;
19. Special Needs:
N/A
20. Pregnant?
No
No
14. Hepatitis?
1.
Allergies?
2.
3.
Asthma?
Heart Trouble?
4.
No
Printed on 7/13/2015 at 4:56:53 PM
No
No
N/A
N/A
No
Page 1 ofi
DEF000837

Suicide Assessment
SO # 026981
BLAND, SANDRA ANNETTE
Desc Black Female
DOB
L
Booked 07/10/2015 8;15 PM
Suicide Questionnaire
1.
2.
3.
4.
Does arresting
No
officer or any other
person believe that
the inmate is at risk?
Any current medical yes
problems, recent
hospitalizations or
serious injuries or
withdrawal
concerns?
INMATE STATES
SHE HAS
EPILEPSY
If female are you
No
pregnant?
Medications?
Yes
KEPPRA
5.
Have you over

No
received services for
mental health or
mental retardation?
6.
Do you receive a
social security
check?
7.
Have you ever been No

in special
education?
8.
Do you have any

previous military
service?
No
No
No
Do you hear any
noises or voices that
other people don't
seem to hear?
10. Have you ever been, No
depressed?
9.
11. Do you feel this way No

now?
Screening Officer:
Screening Date/Time:
12. Have you had

thoughts of killing
yourself in the last
year?
13. Are you thinking
about killing
yourself today?
No
No
14. Have you ever

Yes
attempted suicide? It
yes... When? Why?
How?
IN 2015,LOST
BABY,BY TAKING
PILLS
15. Have you
Yes
experienced a recent
loss?
GOD MOTHER
PASSED IN LATE
2014
16. Does the Individual No
seem: confused,
pre-occupied,
hopeless, sad,
paranoid, etc...
17. is this person's
No
speech: rapid, hard .
to understand,
hesitant, or
childlike?
18. Observed to be
Ndne (No)
under the influence
of: Alcohol? Drugs?
Withdrawals?
19. Observed to have No
visible signs of harm
(i.e., cuts on arms,
etc.):
20. Does the screener No
suspect mental
illness/mental
retardation?
21. If yes, when was a NA
magistrate notified?
DateMme ? How?
Written/Electronlc
22. Additional
N/A
Comments
MAGNUS, ELSA
07/10/2015 8:18 PM
Comment:
Reviewing Officer:
PAGE 1 OF 2
Printed on 7/13/2013 or 4:57:51 PM
DEF000838
Case 4:15-cv-02232 DocumentOULU

39-9 ii.ssessmem
Filed in TXSD on 11/11/15 Page 3 of 3
Review Dete/Timc
PAGE 2 OF 2
Printed on 7/1012015 at 8:56:03 PM

DEF000840

CLASSIFICATION NOTICE
NAME: (last)
just)
JAIL NO: 0 Ne
Aleiork, 5`a minx.
D.O.B.
RACE: E:o
3)
t
Charges)1) a61# POOlk, Se-CV
h
You have been placed in the following classification:
(middle) An ne_i
SSN: 1.1.1111111.11
SEX:
Coed" Rstk P5ci
This classification is determined by: current/past convictions: current/past institu onal

nding charges or holds in other
Jurisdictions (if any); sentenced or unsentenced; and/or any other information that may be deemed appropriate with regard to your
personal security or the security of the facility. NOTE: Your classification can chanoe when charges are altered or reduced; you are
sentenced; due to administrative hearings; due to regular periodic review; and other reasons recommended by the jail staff.
Appeal Process: any inmate dissatisfied with his or her classification must appeal his / her classification, in writing, writing, within ten
10) days of the primary classification or reclassification by addressing his/her appeal as APPEAL. OF CLASSIFICATION and directing
it to: the Sheriff or his designee.
Classified by:
Comments by staff:
BookingDate:rt
115-Known
Yes
Pest/Present
)-1 Serious inst.
Behavior
Problems No
Yes
Prior
Assaultivs
Felony
Convictions
Current
Offense
Assauitivo
No
i Felony
1
High
Yes
Yes
Prior
Assaultive
Felony
Convictions No
Close Custody
Escape
V History
(secure)
Medium
Asit/esc
Known Yes
Past/Present
Po.
insi Berhavio
Yes
Escape
History
(secure) No
Medium
NI.$ or more Yes

Prior Felony
Convictions
No
($ yrs)
iOverride Reason:
Detainer Yes
Warrants or
Pending
No
Charges
'
High Risk: (Check)
tO Assaultive
ID Escape
17r Suicidal
11 Mental
Gang Leader
Other
5
Medium
Pre-Sentence
Known
F-1. F2, F3
Felony
Yes
6
Minimum
Pre-sentence
FS Felony or
Misdemeanant
Paid/Present
Inst. Behavior
Special Condition: (check) Problems No
O Protective Custody
El Medical
O Juvenile
O Handicap/Disabled
O Body Fluid watch
O Other
No!
Is inmate
Sentenced?
'fed
2011 NOrthPointer Inc- This instrument may be used/cop ed in Its manual version
only. The instrument may not be modified without express written consent of
Northpointe. Inc. Automation of the Instruments must be icensed by Northpointe,
Inc. 888-221.-4615.
EXHIBIT
No
Family Ties
mployment
Yes
7
Minimum
1.
8
low
Current
FI
Offense
Felfftesd Misd.
No
Family Ties
Fmploymenf
Yet
Very Low
DEF000833

HOUSTON DIVISION
GENEVA REED-VEAL,
deceased,
Plaintiff,
VS.


Defendants.
STATE OF TEXAS
COUNTY OF WALLER
AFFIDAVIT OF DORMIC SMITH

Dormic Smith, a person whose identity is known to me, and who being first duly
sworn by me, upon his oath stated:
1. "My name is Dormic Smith. I am over the age of eighteen (18)
true and correct.
2. I was employed by Waller County ("County") as a Jailer before
and during Sandra Bland's detention.
3. On Saturday, July 11, 2015, I was working as a jailer when the
magistrate judge came to the jail to provide magistrate warnings to
EXHIBIT
1 Ulm
several detainees. On this day, Ms. Bland was the last to see the
magistrate because the males went first.
4. Ms. Bland received magistrate warnings from the magistrate judge,
and her bail was set at $5,000. Thereafter, as a favor to her, I gave
her several free phone calls at the booking station, to assist her in
securing bond or bail, so she could be released.
5. When I allow detainees to make free calls at the booking station,
they provide me with the phone number, and I dial it. I do not ask
detainees who they are calling, but they frequently make comments
from which it is apparent who they are calling. Ms. Bland's
comments led me to believe that the first phone number she called
was to a male friend. I dialed the number, heard the phone ring,
and heard it go to voicemail. She teared up a little at that time, and
I told her she could try again.
6. A few minutes later, Ms. Bland had me call the number again, to
the same male friend. Again, the phone rang, and eventually went
to voicemail. Ms. Bland left a message relating to the fact that she
was in the Waller County Jail, and that her bail had been set.
7. Next, Ms. Bland commented that she wanted to call her sister, and
I dialed the number provided. Someone answered the phone, and I
did not hear what the other person said, but I heard Ms. Bland
explain that she was in the Waller County Jail, the charge against
her, and that her bail had been set. After a brief conversation, the
call ended, and Ms. Bland made a comment to the effect that her
sister would not bail or bond her out.
8. Next, Ms. Bland asked to call the original number again, for the
same male friend. I dialed the number, and this time, the phone
rang only once or twice, and then went directly to voicemail. In
my experience, that can occur when the individual being called
presses a button on their phone to "ignore" the call. It was
apparent from Ms. Bland's behavior that she thought the male
friend was "screening" or "ignoring" her call.
9. Ms. Bland did not ask to make any additional calls at that time.
-2-
10.Ms. Bland also had access to a phone in her cell, and she could
make unlimited collect calls from within her cell. I do not know if
she completed any such calls from within her cell.
11.I worked from 7:00 a.m. to 7:00 p.m. on Saturday, July 11, 2015,
from 7:00 a.m. to 7:00 p.m. on Sunday, July 12, 2015, and from
7:00 a.m. to 7:00 p.m. on Monday, July 13, 2015. During my
shifts, I interacted with Ms. Bland during rounds, when bringing
her food, and on other occasions as I walked the jail floor.
However, I did not interact with her on Monday, July 13, 2015
because other jailers were performing rounds that morning, while I
worked at the booking station.
12.When I observed Ms. Bland during my shifts, she did not appear to
suffer from any mental health issues, and she did not appear to be
depressed or sad, or to be contemplating suicide. At no point
during her detention did I perceive her to be a suicide risk.
13.When she was discovered hanging in her cell on Monday, July 13,
2015, at approximately 9:00 a.m., I responded to a distress call
from Jailer Cynthia Whidden. Other jail personnel arrived before
me, and performed CPR until EMS personnel arrived a few
minutes later. EMS took over life-saving efforts, but pronounced
Ms. Bland dead shortly thereafter.
Further afflant sayeth not."
Dormic Smith
SUBSCRIBED AND SWORN TO, BEFORE ME, by formic Smith, on

this the /n ay of November, 2015, to certify which witness my hand and seal of
office.
JUSTIN BRADLEY
My Commission Expires
September 27, 2017
lie for the State of Texas

HOUSTON DIVISION
GENEVA REED-VEAL,
deceased,
Plaintiff;
VS.
Defendants.
EXHIBIT K
DVD CONTAINING VIDEO FROM JULY 13, 2015
Exhibit K to County Defendants' Motion for Summary Judgment is video
from July 13, 2015.
Exhibit K was delivered and filed with the District Clerk's Office via
Certified Mail, RRR (7005 0390 0004 4050 1291), and a copy was delivered to the
Honorable David Hittner via Certified Mail, RRR 7005 0390 0004 4050 1307,
........ .,';
CA No. 4:15-CV-02232
Reed-Veal v. Encinia, et al.
Exhibit K
(County Defendants'
Motion for Summary Judgment)
EXHIBIT
.0a

late
7/13/2015 05:09:00
7/13/2015 08:08:57
7/13/2015 08:08:55
7/13/2015 08:08:55
7/13/2015 08:08:55
7113/2015 08:04:50
7/13/2015 08:04:44
7/13/2015 08:04:42
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07/13/2015 07:41:35
7/14/201311:49:38 AM
PLC
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PLC
PLC
PLC
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PLC
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Station ID
Operator ID
TS1
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32 / MM3333
32 / MM3333
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32 1M11/13333
321 MM3333
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321 MM3333
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321 MM3333
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32 / MM3333
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32 / MM3333
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321 MM3333
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32 / MM3333
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32 / MM3333
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321 MM3333
321 MM3333
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32 / MM3333
Event Class
Door
Door
Door
Door
Door
Door
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Door
Door
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Door
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DEF000871
Page: 89 of 1875

WALLER COUNTY SHERIFF'S OFFICE
Sheriff R. Glenn Smith
(
yiN
'
-100r"
701 Calvit Street, Hempstead, TX 77445-4669
)1*..6s4
Phone: (979)826-8282 Fax: (979)826-7667
INCIDENT / OFFENSE REPORT
Case Number:
CALL INFORMATION
Operator
Kelley, Austin
Nature of Call Reported

Suicide
Reporting Method
Call. Number
3242O4
1501147
Related Incidents
Initial Call Reported By
Offense Address
701 Calvit
Phone
No Known Address
Officer(s) Assigned
Waller County Ems-dist 1
Wailer County Ems-dist 1
Parinello, Mike
Date Assigned
07/13/2015
07/13/2015
07/13/2015
Investigator:Assigned
Parinello, Mike
Notified
9:00 AM
Arrived
9:03 AM
9:01 AM
9:51 AM
9:05 AM
9:51 AM
Att/Compl
Incident Type
Death Investigation
Inc/Off Date
07/13/2015
Offense Code
Hempstead Tx 77445
IndOff Time
8:59 AM
Cleared
Disposition
9:51 AM
9:17 AM
12:21 PM
No Transport (EMS)
Agency Assist
INCIDENT INFORMATION
Area
Report
Subdiv/Grid
LIGR Code
Status
Active
Status Date
07/13/2015
1 Offense
PROPERTY INFORMATION
Cat.
Ivianufact
Make
Model #
Veh. Model
Description
value
Total Est. Value:
Year
Connection
Victim
Make
Address
VIN
NCIC
Disposition
$0.00
VEHICLE PROPERTY INFORMATION

Color
License
Model
Name
Bland, Sandra Annette
Serial #
PARTY INFORMATION
Phone
IIMINER
VIN
Sex
F
DeScripIiOn
Height
6 Ft. 0 In.
Race
B
DOB
IMP
HOUSTON,
b
-
.0.0
a
EXHIBIT
M
DEF000916
Case #: 1501147
OFFENSE REPORT
LANGDON, MARC
JULY 13, 2015/ 12:39 PM
INTRODUCTION
On Monday, July 13, 2015; I, Jail Investigator Marc Langdon, responded to an ongoing suicide attempt in
the Waller County Jail at or about 9:00 A.M. The location in the jail where this incident was ongoing was
female aggravated cell #95.
SCENE SUMMARY
The scene was isolated to cell 95 of the Waller County Jail.
NARRATIVE
On Monday, July 13, 2015; I, Jail Investigator Marc Langdon, was in the Waller County Jail Control Room
along with Lt. Sherry Rochen working on Transmittals to go over to the Waller County District Clerk and
Waller County Clerk's Office. At 8:59 A.M; I heard Deputy Jailer Cynthia Whidden call out for the door to
cell 95 (female aggravated cell) to be opened. The sound of her voice had a sense of urgency that there was
an immediate emergency. Deputy Whidden said, to the effect, that an inmate was hanging in cell 95. With
my attention turned to the control room window that overlooks the booking floor I could see that Deputy
Jailers Zuniga, Serges and Detention Officer Smith were rushing to assist Deputy Whidden's call for help.
Controller Mills said out loud (directed to Lt. Rochen and me) that there was a problem in cell 95. Lt.
Rochen told me to go and inform Chief Hester of a female inmate in cell 95 was just discovered hanging in
cell 95. As I was exiting the control room, Controller Mills was on the phone with Waller County Dispatch
directing them to dispatch Waller County EMS to the jail for a suicide attempt by hanging. The time was
9:00 A.M.
Lt. Rochen immediately went to cell 95 to assist the other officers with the inmate. As I notified Chief
Hester and Asst. Chief Thibodeaux of the emergency that was on going in the jail, I along with Chief
Hester, Asst. Chief Thibodeaux Patrol Lt. J. Lane, Patrol Deputies Henderson and Lewis responded to
assist. Deputy Henderson was sent to stand by the entry/exit doors (doors 7 &8) to the jail to help expedite
egress into the jail by EMS personnel. I arrived with Chief Hester and Asst. Chief Thibodeaux at cell 95
and observed that Lt. Rochen was actively performing CPR on a black female inmate now identified as
Sandra Annette Bland (B/F DOB: 1.111101. Due to the amount of people already inside of cell 95
administering CPR I turned to go back to the control room to assist Deputy Henderson with expediting EMS
into the jail without any unnecessary delay. I heard Deputy Lewis ask Lt. Rochen if he could relieve her
(give her a break) on CPR. I learned that shortly after Deputy Lewis asked Lt. Rochen, she did let him
2
DEF000917
Case : 15071141
know that she needed to switch so she could recover and be ready to switch with him if needed prior to
EMS arrival.
EMS arrived in the parking lot at 9:04 A.M. and was directly escorted to cell 95 without delay. The EMS
paramedic that responded with the ambulance instructed Deputy Lewis to discontinue CPR so they could
attach the heart monitor to Inmate Bland. CPR was continued by EMS. Vitals were checked several times
prior to EMS arrival and even after EMS arrival. At 9:06 A.M. The paramedic told EMS personnel to stop
CPR to recheck Inmate Bland's vital signs. There were no vital signs and the Paramedic asked for Chief
Hester. Chief Hester was already present in cell 95 during this time and was informed that CPR was not
going to resuscitate Inmate Bland. The paramedic called the stop of CPR and time of death at 9:06 A.M.
Waller County EMS personnel left cell 95 with Chief Hester at this time. Lt. J. Lane maintained scene
security of cell 95.
Chief Hester went to the control room of the jail to start calling and making notifications to the Sheriff,
Texas Ranger Shane Ellison, Justice of the Peace Charles Karisch, and Waller County Sheriffs Office
Investigator Parinello.
I began photographing cell 95 starting with the hallway to the vestibule doorway and then the entry/exit
door to cell 95. I photographed the interior of cell 95. The deceased was also photographed as well at the
ligature mark on the neck of the deceased. The deceased was housed alone in this cell at the current time
due to her current classification. Investigator Parinello took his investigative photographs and
asurements after I com leted taking photographs.
I secure vi eo from the Waller County Jail DVR system camera #30. This camera shows the hall way and
the exterior doors to cells 95 and 54. The video that was secured was from midnight of July 13, 2015 until
9:30 A.M. July 13, 2015. The video was secured and burned onto a DVD disc for investigative purposes. A
copy of this DVD was made for Ranger Ellison, Investigator Parinello and Chief Hester. Also I checked the
Waller County Jail inmate phone system (GTL) for any phone calls that Inmate Bland may have made prior
to the incident. There were no phone calls made by the deceased from her cell prior to her discovery at 8:59
A.M.
Texas Ranger Shane Ellison entered the Waller County Jail at 10:37 A.M. to begin his investigation along
with Investi ator Parinello who was already on scene at the Waller County Jail.
As I was securing the Jail DVR video, I discovered that the DVR time stamp was nine (9) minutes and
twenty six (26) seconds faster than the time showing on jail computer clocks. This comparison was made in
the jail control room with Controller Mills assisting as a second set of eyes to confirm the time difference.
This time stamp discrepancy was made known to Chief Hester, Ranger Ellison, and Investigator Parinello.
At the request of Ranger Ellison a cell phone was taken into the Control Room to confirm this again as he
said in his own words that cell phones are more consistent with their clock times. The DVR time stamp was
reconfirmed that it was fast by 9:25 on this comparison with the cell phone.
7ugflh-ElreiaeEharlesKansc1)
an-iv&
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County Jail at 11:39 A.M. and was escorted
to cell 95 for his inquiry.
After Ranger Ellison and Investigator Parinello completed their investigation in cell 95 and Justice of the
Peace Karisch (JP1) responded, the body of the deceased was released to McWilliams transport at 12:11
P.M. to transport the deceased to the Harris County Medical Examiner's Office located on Old Spanish Trail
in Houston, Texas for autopsy at 12:25 P.M.
3
DEF000918
Case #: 150141
I talked with Lt. Rochen after the fact to determine what she saw and did in cell 95. Lt. Rochen told me that
she entered into the cell and grabbed Inmate Bland under her arms and lifted her up to relieve the tension of
the make shift noose that was around her neck. Deputy Jailer Zuniga loosened the noose to from Inmate
Bland's neck and slid it up and over her head so she could lay Inmate Bland on the floor. Lt. Rochen said
she and Deputy Jailer Zuniga checked her for pulse and did not get one. Lt. Rochen said she began active
CPR at this time. That was at 9:01 A.M. Lt. Rochen said during CPR she yelled for someone to go get
Marianne (Waller County Jail Nurse). Lt. Rochen said she was unsure how long it took for Marianne to get
to cell 95 but it had to be fast. Marianne assisted with using a stethoscope to check for a pulse on Inmate
Bland and could only get a pulse during CPR. Lt. Rochen said that Deputy Lewis did ask if she needed to
switch out so he could continue CPR since he could tell Lt. Rochen was visibly getting tired. Lt. Rochen
said she did switch out with Deputy Lewis when she finished her set of chest compressions and during a
check for a pulse on Inmate Bland. Lt. Rochen said she had no further interaction with Inmate Bland from
this point forward because EMS was on location and had begun working on Inmate Bland.
At 7:55 A.M., Monday, July 13, 2015; Controller Mills received a call from the intercom from cell 95. This
happened two (2) times while Lt. Rochen and I were in the control room. The female inmate was asking to
make more free phone calls from the booking counter. Controller Mills informed the female inmate that she
would have to use the phone in her cell (cell 95) to make phone calls. Furthermore she was told by
Controller Mills she had already received two (2) free phone calls; once at booking and another after she
was magistrated on Saturday (July 11, 2015).
I was able to locate and print out the jail/intercom report for supporting this intercom exchange between
Controller Mills and Inmate Bland in cell 95. The print out is attached with this report and also forwarded
to Ranger Ellison and Investigator Parinello.
Notification/Arrival times:
8:59 A.M. Deputy Jailer notification of hanging Inmate cell 95.
9:00 A.M. EMS dispatched to Waller Co. Jail
9:01 A.M. Lt. Rochen begins CPR
9:04 A.M. EMS arrives at Waller Co. Jail
9:06 A.M. Paramedic notified Chief Hester of no vital signs and to discontinue CPR
9:07 A.M. Cell 95 photographed by Jail Investigator Langdon
10:37 A.M. - Texas Ranger Ellison arrived at the Jail for investigation
11:39 A.M. Justice of the Peace Charles Karisch arrived at the Jail
12:11 A.M. - McWilliams transport arrived at the jail.
12:25 A.M. McWilliams transport leaves jail with deceased en-route to Harris County Medical Examiner's
Office; Houston, TX.
Refer to Investigator Parinello's supplement for more detailed information.
4
DEF000919

.
Wrier 6odrity EMS
Patient Care Record
Name:BLAND, SANDRA
Last r'..;.#1:7'7. BLAND ...
Date: 07/13/2015
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'FirSt :.:"..,:.....;_!: SANDRA

iddle. :. -_:: :::
. ANNETIE
Gander:.:4;: Female
DOB:::.!1F:'.',..-41N8~11,*
Patient 1 of 1
Clinical Impression
Patient
..._
...._ In ormation
_ . .
.M
- . .I.-:lp 28 Yrs, 5 Months, 6 Days
Weight:,1,:,..: 17516s - 79kg
RhOiNdrA-7
Pedi:cadrv:
Ethnicity:"'.; Not Hispanic or Latino
SSN.7.4l: 11111111111111MI
Race 'i::':7441:: Black or African American
AdVarioad D'rectiveA:':v5.-477<!.P.:;:t:9...tM:V;;,-:-4 1:,
Resident StatilS2f,.5;7.71;:'1",:l.::,:e..'fi'."...7P.4.K..,^
,PririfeirYArriPriiiiSirkl':liPi. Cardiac Arrest

Seciniiiraiisibri:?e,
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Protocol sed
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Duration
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.).F, Injury - Unspecified -Neck
Signi:&;Syri
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,
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Self Inflicted - Self Inflicted - Other specified

place - 07/13/2015
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Unknown
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Medications
Allergies
History
Vital Signs
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ECG
::::?:::&;:.'%.?..-:,:::. Lead CG'Si :f;T.-& ,:....:;'.1:::.'::..: .,';.'i'.4.:',.1::0:,-:t:,!f.--,:fs:.-Z,:i.:!,-.21Fiz.zF1'f::::',:VA':PM lead
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Asystole
As stole
IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII
Flow Chart
,.!:st,:?:..?"...it;..,:s..:11Ti,teCu.i'-':::;:4N,Wi:V. 4M20.4.0.105ciAtON.6-.4:0;`:!''.5-f;;VF...,:t ":'...f.5i?e ProvicleMv..
me' ...7 Treetrriont.ov,;;;:t.:Vs;,1-:...:D6ibliptickire::0:::1VC.4';'.1:/1':'.4.,
Comments PATIENT LYING SUPINE %MTH FIRST RESPONDER PERFORMING GOOD QUALITY CPR.
THICK AND DEEP LIGATURE MARKS ON NECK, NO PULSE OR RESPIRATIONS; Patient Response: ALEXANDER, CRISTI
p9:05
ALS Assessment
Unchanged;
Comments CPR CONTINUED WHILE DEFIB PADS AND 4 LEAD ARE PLACED.; Patient Response:
09:36
CPR
ALEXANDER, CRISTI
Unchanged;
IV,It:e.:;tTriSittirient
Derib/Cardio/Pace CPR
MS Provider
Treatments Nor To Arrival
Patient
Unchand
Page 1 of 7
GOOD QUALITY MANUAL CPR
07/13/2015 10-05PCRID: b43944894971-4981-b394-a4d400993d2a

Electronically Signed by:ALEXANDER CRISTI
EXHIBIT
DEF000872
Wilr &Lnty EMS

Patient Care Record
Name:BLAND, SANDRA
Date: 07/13/2015
Incident 150713-0917-WCEMSESO
Patient 1 of 1
Initial Assessment
tOebolY.?W,7i. - "iiiii#1.47,24:,;"!, ,MIT.F,14[5:Q:;:!?1 ':;:'1!: .:7.:" ' 116460'..'.,: .". ::';?1,ire,::Pig;IXT-ka;:r !?:.. -5'r-:W,.7.71tr:::,:'r.:.-Ii.3)::,::-27:r'i.::14,!i:::',..1,:.':'.. l'':,;.., '
Mental Status
Skin
HEENT
Chest
Mental Status
MOTTLING HAS BEGUN ON UNDER FLANK
DEEP/THICKENED LIGATURE MARKS IN ''
CIRCUMFERENCE AROUND NECK.
PATIENT IS NOT BREATHING.
Abdomen
Skin
Head/Face
Eyes
Neck
Chest
Heart Sounds
Lung Sounds
General
Left Upper
Right Upper
Left Lower
Right Lower
Cervical
Back
Thoracic
Lumbar/Sacrai
Pelvis/GU/GI
Extremities
NO PULSE FOUND
Pelvis/GU/GI
Left Arm
Right Arm
Left Leg
Neurological
Assessment Time:
Right Leg
Pulse
Unresponsive
()Mottled
Not Assessed
Left: Dilated, Left: Non-Reactive, Right Dilated, Right: Non-Reactive
Other
()Accessory Muscle, Retractions
.
Not Assessed
'LL: Absent, LU: Absent, R L.: Absent, RU: Absent
Not Assessed
Not Assessed
Not Assessed
Not Assessed
Not Assessed
Not Assessed
Not Assessed
Not Assessed
-eIncontinence
Not Assessed
Not Assessed
Not Assessed
Not Assessed
r9Carotid: Absent, Femoral: Absent, Radial: Absent
Capillary Refill
Not Assessed
Neurological
Not Assessed
7113/2015 9:05:00 AM
Page 2 of 7
07/13/201510.05
PCR/D: b4394489-1971-498R2394-a4c1400993d2o
ElectronicallySiglled by: ALEXANDER, CRISTI
DEF000873

A
Wear IA.:a:way EMS

Patient Care Record
Name:BLAND, SANDRA
I.4 *' -:'

Mental Status
Skin
HEENT
---'''.::.:11v
,
;''- "'
NO CHANGE FROM INITIAL

I
t-
Chest
Abdomen
Back
Pelvis/GU/GI
E:dremIties
Date: 07/13/2015
Patient 1 of 1
Ongoing Assessment


1Neurologicai
Assessment Time:
Nl' 7 Abijoirharrues
Mental Status
Skin
Head/Face
Eyes
Neck
Chest
Heart Sounds
,.1-
,),:,.-
...,,,- ,:,.rP '

'.
""'T,Z,'' ; ''', . \: ,': ',..
()Unresponsive
Not Assessed
Not Assessed
OLeft: Dilated, Left: Non-Reactive, Right Dilated, Right Non-Reactive
Other
Not Assessed
Not Assessed
Lung Sounds
Not Assessed
General
Left Upper
Not Assessed
Not Assessed
Right Upper
Left Lower
Right Lower
Cervical
Thoracic
Lumbar/Sacral
Not Assessed
Not Assessed
Not Assessed
Not Assessed
Not Assessed
Not Assessed
PeIvls/GUIGI
Left Arm
Not Assessed
Right Arm
Not Assessed
Left Leg
Right Leg
Pulse
Capillary Refill
Not Assessed
Not Assessed
Neurological
f.
Not Assessed
()Carotid: Absent, Femoral: Absent, Radial: Absent

Not Assessed
Not Assessed
ler-fatly
M10 DISPATCHED TO TRAUMA AT THE JAIL AND RESPONDS FROM STATION 10. S1 DISPATCHED. UPON ARRIVAL, NOTIFIED OF CPR IN
PROGRESS. UPON ARRIVAL, PATIENT WAS UNRESPONSIVE ON FLOOR OF JAIL CELL WITH FIRST RESPONDER DOING CPR. INJURIES
COMPATIBLE WITH HANGING NOTED. PATIENT PLACED ON MONITOR TO FIND ASYSTOLE WITH POSSIBLE 1 HOUR DOWNTIME. CPR IS
DISCONTINUED AND TIME OF DEATH NOTED. SCENE LEFT WITH LAW ENFORCEMENT. <END REPORT...CDA>
CarciacArrestAWZI,:;;;7; Yes, Prior to EMS Arrival

.Cririliga'ArriastEtiolsTWFW. Trauma
ttititeinitlitaitAKSMK >20 Minutes
EttionigcoOtaii,temix.qL.q so Minutes
Ea1liiier.011450,:tdCP,F011:;. 50 Minutes
ArrestWthielogiBsi25F0.6,:-. Not Witnessed
CR.R4fittiatettArg.14. Law Enforcement
Tine1eCP.R.1;V::-.7.';;.'. 09:00 07/13/2015
CPR EeliaiirkieST4.117:5?.. No
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:66,11EidfiticidDik:ontiNeeM
1410-01ritin:iiiif. -- .7::::::
Aildiiiiiitkift:,11.
Page 3 of 7
07/13/2015 1005
POW: b4394489-1971-4981-b394-a4d400993d2o
Electronically Signed by ALEXANDER, CRlSn
DEF000874

.;OLICIty EMS
Wcif.i.i9r-+.1
Patient Care Record
Incident #: 150713-0917-WC EMSESO
Name:BLAND SANDRA
Date: 07/13/2015
Patient 1 of 1
Dostinoon Details
Incident Details
Loeictiolil......:4"; '..': '.
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ALEXANDER, CRISTI
RIGAR, KAYLENE
Lead
Driver
EMT-Paramedic-00=MT-Basic-733478:
Insurance Details
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Authorization
Section 1- Authorization for Billing
Page 4 of 7
07/131201510.05
PCRID: b43944894971-4981-b394-a4d400993d2o
Electronically Signed by: ALEXANDER, CR1S77
DEF000875

Wiiar 6,1inty EMS
Patient Care Record
Name: BLAND, SANDRA
Date: 07/13/2015
Patient 1 of 1
( request that payment of authorized Medicare, Medicaid, or any other insurance benefits be made on my behalf to [WALLER COUNTY EMS Ambulance
Service, Inc. ("WALLER COUNTY EMS")] for any services provided to me by [WALTER COUNTY EMS] now, in the past, or in the future. I understand that I am
financially responsible for the services and supplies provided to me by [WALLER COUNTY EMS], regardless of my insurance coverage, and in some cases,
may be responsible for an amount in addition to that which was paid by my insurance. I agree to immediately remit to [WALLER COUNTY EMS] any payments
that I receive directly from Insurance or any source whatsoever for the services provided to me and I assign all rights to such payments to [WALLER COUNTY
EMS]. I authorize [WALLER COUNTY EMS] to appeal payment denials or other adverse decisions on my behalf without further authorization. I authorize and
direct any holder of medical information or other relevant documentation about me to release such information to [WALLER COUNTY EMS] and its billing
agents, the Centers for Medicare and Medicaid Services, and/or any other payers or insurers, and their respective agents or contractors, as may be necessary
to determine these or other benefits payable for any services provided to me by WALLER COUNTY EMS, now, in the past, or in the future. A copy of this form
is as valid as an original.
Privacy Practices Acknowledgment: by signing below, I acknowledge that I have received [WALLER COUNTY EMS's] Notice of Privacy Practices.
understand that, in the opinion of Waller County EMS, the services or items that I have requested to be provided to meon the date of service may not be
covered under the Texas Medical Assistance Program as being reasonable a ndmecfically necessary for my care. I understand that the HHSC or its health
insuring agent determines the medica 'necessity of the services or the items that I request and receive. I also understand that I am responsible for paymentof
the services or items that I request and receive if these services or items are determinded not to be reasonableand medically necessary for my
care.Comprendo que segun la opinion del Waller County EMS, es posible que Medicaid no cubra los servicious o lasprovisiones que solicite fecha de servicio
por no considerarlos razonables ni medicamente neceserios pare me salus.Camprendo que el Departamento de Salus de Texas o su agenla de seguros de
salud determine la necesidadmedica de los servicios o de las provislones qua el cliente solicite o reciba. Tambien comprendo que tango laresponsibilidad de
pagar los servicios o provisiones que solicite y que reciba si despues se despues se determine queesos servicios y provisiones no son rezonables ni
medicamente necesarios pare mi salud.
Signature
BiliintrAirtharizationeW4vV14447:rA4
HIPAK'AcknoWledgement4Vol.Ve
Section II - Authorized Representative Signature
Complete this section only if the patient is physically or mentally unable to sign.
Authorized representatives include only the following:(Check one)
[patient's Legal Guardian
Patient's Medical Power of Attorney

Relative or other person who receives benefits on behalf of the patient
' [Relative or other person who arranges treatment or handles the patient's affairs
Representative of an agency or institution that provided care, services or assistance to

patient
I am signing on behalf of the patient to authorize the submission of a claim for payment to Medicare, Medicaid, or any other
payer for any services provided to the patient by the transporting ambulance service now or in the past, (or in the future,
where permitted). By signing below, I acknowledge that I am one of the authorized signers listed below. My signature is not an
acceptance of financial responsibility for the services rendered.
Signature
d;:y.5w.
Section - EMS Personnel and Facility Signatures
Page 5 of 7
07/13/2016 10:05
PCRID: b4394489-1971-498f-b354-84r1400993(12o
Electronically Signed by: ALEXANDER, cRisn
DEF000876

Unty EMS
Patient Care Record
Date: 07/13/2015
Name:BLAND, SANDRA
Complete this section if the patient was mentally or physically incapable of signing, and no Authorized
Representative (section II) was available or willing to sign on behalf of the patient at the time of service.
Patient 1 of 1
EMS Personnel Signature

My signature below indicates that, at the time of service, the patient was physically or mentally incapable of signing, and that none of the authorized
representatives listed in Section II of this form were available or willing to sign on the patient's behalf. I am signing on behalf of the patient to authorize the
submission of a claim to Medicare, Medicaid, or any other payer for any services provided to the patient by the transporting ambulance service. My signature is
not an acceptance of financial responsibility for the services rendered.
[Printed
EReaeogulabietesitie.w1
Facility Representative Signature
The patient named on this form was received by this facility on the date and at the time indicated above. I am signing on behalf of the patient to authorize
the submission of a claim to Medicare, Medicaid, or any other payer for any services provided to the patient by the transporting ambulance service. My
signature is not an acceptance of financial responsibility for the services rendered.
[Printed
rfitleof Representatixe
Page 6 of 7
07/13/2015 1005
PCRID b4394489-f971-4981-b394-a4d400993d2o
Electronically Signed by: ALEXANDER, CRISTI
DEF000B77

.
Wgiikilr boil* EMS

Patient Care Record
Name: BLAND, SANDRA
Incident if: 150713-0917-WCEMSESO

Facjii Si natures
Date: 07/1312015
Patient 1 of 1
Patiertirjarked,:ici,,
AirwarGonfirmation
Provider S. natures
Leat3P6*.ialer rt177:;:4-.:4:Ace.; CRISTr ALEXANDER
KAYLENE GRI GAR
r r
AlloOPfA
Reev ide zg
GertifidatiditLeVek:r.lEMT-Paramedic-00;
CertilicationTeirel.IPM: EMT-Basic-733478
ItettifiditiCKLIV41,2:1;!4m1
-LeVeWir.1.f
Providar%'-'".
Page 7 of 7
07/13/201.5 10:05
PCRID: b4394489-1971-498M394-84d400993d2a
Electronically Signed by: ALEXANDER, CRISTI
DEF000878
Q WALLER COUNTY SHERIFF'S OFFICE
JAIL & DETENTION POLICIES &

PROCEDURES & TEXAS COMMISSION ON
JAIL STANDARDS APPROVED
OPERATIONAL PLANS
'."4
ISSUE DATE: 12/01/2010
EXHIBIT
DEF000001
Waller County Sheriffs Office

Jail and Detention
HOW TO USE THIS MANUAL
Contained in this manual are policies and procedures of the Waller County Jail. This
manual deals with the specifics of operating this detention facility, both administratively
and operationally, and it addresses issues relating to how we manage, supervise, and
communicate with one another.
Operational policies Section 5 through 9 address issues important to your safety and
areas of operation that frequently result in complaints against officers and the detention
facility. These operational policies are periodically updated. You will be notified when
onsibility to understand tfieTeTE
n iFFSFa-nrth
1 o ow the
chg
-i.gs are made
Foredures set forth in this manual.
Our policies and procedures are written to provide a foundation for the day-to-day
operations of the facility. Their purpose is to standardize the facilities approach and
response to recurrent and predictable situations. Policies and procedures are intended
to provide you with guidance regarding the performance of your responsibilities as a
detention officer. They contribute to the overall achievement of the mission by defining
performance expectations, ensuring conformity to legal standards, institutionalizing
detention's "best practices," and establishing a basis for accountability.
It is an important requirement that each of us be familiar with the details of this manual,
and readily apply its guidelines in every aspect 'of what we do in this facility. How well
you study and use what you learn directly affects the safety of our operation.
Begin your education process by paging through the manual. Familiarize yourself with
the format; review how subjects are categorized and numbered; and look for specific
topics. Then read the operational policies of the manual. Read each policy and when
you come to something you don't understand, find confusing, or simply question, write it
down and talk with your supervisor to seek the answers. Keep going through ,this
- process-until you' have- completed' "a review' Of each policy;
oh to. the next
group. Repeat the process until you are confident you know each policy well enough to
apply it in spirit as well as in practice.
DEF000005
Waller County Sheriff's Office

Jail and Detention
OBJECTIVE STATEMENTS
The following objectives have been established to accomplish the mission, within
the budgetary and manpower constraints imposed on the facility:
Protection of Life and Property - To provide reasonable and cost

effective service that contributes to the preservation of life, the protection
of property, and the safety of the jail and detention community.
Maintenance of Public Order - To maintain peace and public order in the

context of a secure and well regulated detention environment. To assist
during times of natural or manmade disasters.
Deterrence, Detection, and Investigation of Criminal Activity - To

reasonably deter crime through aggressive supervision of inmates, and
the establishment and maintenance of policies, procedures, timetables,
and guidelines. To vigorously and effectively investigate crime in the
facility and take corrective action that discourages recurrences of
unacceptable behavior.
Compliance with Ethical Standards and Professionalism - To

encourage and support integrity and adherence to the professional
standards of the facility by investigating complaints against staff
personnel. To provide for the training needs of all employees and
promote a high rate of proficiency in detention officers of the facility.
DEE000006
Wailer County Sheriffs Office

Jail and Detention
Policies and Procedures
Subject: Management Philosophy &
Goals
Policy Number: 2.01
Issue Date:
Revision Date:
Approval Authority
Title and Signature:
POLICY:
Wa iler County Sheriffs Office Jail Division provides reasonable detention services
safe, secure, and humane environment.
PENOLOGICAL INTEREST:
It is in the penological interest of this detention facilityto provide reasonable and necessary
security and safety standards, control, supervision, and a humane environment to all
inmates while confined to this facility.
411)
Philosophy:
WCSO Jail is established in accordance with applicable statutes and regulations. This
detention operation is charged with the goal of aiding public safety through the provision of
professionally managed detention services.
WCSO Jail within the constraints of available resources, offers a practical range of
detention options, including institutionalization, community work programs, and other
similar sanctions, that reasonably serve the needs of society as well as the individual
inmate. Where reasonably possible WCSO Jail enhances the offender's ability to return to
the community and live in a law-abiding manner. WCSO Jail administers its programs in
an equitable, least restrictive environnient ConsiStantwith- Piiblio-ialetY and good order.
WCSO Jail operates under the principle that all administrative and management decisions
either directly or indirectly affect security, safety, and treatment goals of the facility. In this
connection, facility staff often serves as important and productive role models for inmates,
conveying mainstream societal values to the inmate population. Throughout the course of
a day, opportunities for controlled interaction between staff and inmates provide a means
to influence and reinforce appropriate inmate behavior. Employees are expected to
interact, where reasonably possible, with inmates in a manner consistent with the
objectives of this facility.
Mission Statement:
RESTRICTED LAW ENFORCEMENT DATA
This data is proprietary and shall not be duplicated, disclosed, or discussed, without the written permission of this agency. Data
subject to this restriction is contained throughout this publication.
Page 1 of 2
Jail and Detention Policies and Procedures, 2.01 Management Philosophy & Goals
he mission of Waller County Sheriff's Office Jail Division is to maintain social order and
provide professional detention services within prescribed ethical and constitutional limits.
WCSO Jail will enforce the law in a fair and impartial manner, given statutory, budget, and
judicial constraints. WCSO Jail recognizes that no detention facility can operate at its
LT
maximum potential without supportive input from the citizens it serves. WCSO Jail actively
solicits and encourages the cooperation of citizens to reduce the opportunities for crime,
while maximizing use of existing resources.
WCSO Jail Goals:
WCSO Jail has as its prime goal the operation of a safe, humane, and cost effective facility
that provides a place of confinement, punishment, and an opportunity for reflective thought
and positive change.
Specifically, within budget constraints, WCSO jail will operate an integrated system of
detention services that reasonably:
1. Protect society by preventing escape from custody through the use of physical,
procedural, and managerial safeguards;
Maintain
an inmate classification plan for housing, work, and other facility
2.
assinments
3. Provide clean, safe, and healthy living conditions for inmates;
4. Prov'de basic medical, dental, and psychiatric needs of inmates;
Provide opportunities for reflec ive t oug t, t at can lead to positive personal
change;
6. Provide work programs for qualified inmates;
7. Provide safeguards that protects inmates from physical and psychological
lAtimigAtio n ;
8. Provide necessary due rocess and other le al safeguards; &
row e appropriate opportunities or religious practices.
Public Access:
At the election of the WCSO Jail this policy may be made available at the request of the
public.

Page 2 of 2
DEF000008

Jail and Detention
Subject: Professional Conduct for
Corrections Personnel
Policy Number: 2.04
Issue Date:
Revision Date:
Approval Authority
POLICY:
All employees of Waller County Sheriffs Office Jail Division constantly strive to deal
honestly, efficiently, and with integrity while on official duty, and strive to do the same in
their personal lives. Officers and employees of this agency are mindful that their
conduct and the public's perception of that conduct effect the willingness of the public
to support our critical mission.
In order to ensure a reasonably safe and secure detention facility, it is the penological
interest of Waller County Sheriffs Office Jail Division to set and enforce professional
conduct standards for all personnel working in the correctional environment.
PROCEDURES:
1, Sworn and civilian employees are always courteous when interacting with the
general public.
2. Employees avoid behaviors and practices that cause the public to question
individual employee or agency integrity,
3. Off-duty officers conduct themselves as though they were on-duty, while in
uniform.
4. Employees do not reveal or make public, any order, or information to any person
unless the disclosure is authorized and the intended receiver has a need to
know.
5. Officers are governed by reasonable and exemplary rules of good conduct and
behavior whether on or off-duty. Officers always demonstrate morals and values
expected by the community and will not commit any act that could adversely
affect the Waller County Sheriffs Office Jail Division, their fellow employees, or
res ect for the rule of law.
6. Officers always remember that they are sworn to uphold the law and abide by
the policies and procedures of this agency, while protecting the rights of all V
This data is proprietary and will not be duplicated, disclosed, or discussed, without the written permission of this agency. Data
Page 1 oft
DEF00001 6
j Jail Policies and Procedures, 2.04 Professional Conduct for Corrections Personnel
people as afforded by the Constitution of the United States of America and the
State of Texas.

This data Is proprietary and will not be duplicated, disclosed, or discussed, without the written permission of this agency. Data
subject to this restriction Is contained throughout this publication,
Page 2 of 2
DE4-1000017

Jail and Detention
Subject: Rules of Staff Conduct
Policy Number: 2.07
Issue Date:
Revision Date:
Approval Authority
POLICY:
Waller County Sheriffs Office Jail Division employees conduct themselves professionally
and responsibly at all times in order to uphold the trust and confidence placed in them by
the community.
It is in the penological interest of this facility to maintain strict adherence to our standards,
policies, and procedures. This aids us in maintaining the trust and confidence of the
citizens, detainees, and inmates we serve,
DISCUSSION:
A key ingredient of the detention services we provide is maintaining the trust and
confidence of the residents that we serve. We recognize that officers and employees of
our Waller County Sheriff's Office Jail Division are high profile members of our community,
and as such are subject to constant scrutiny. As a result, officers and employees must
always strive to set an exemplary model of citizenship. This often means using restraint,
avoiding conflict, and working well with the public.
For purposes of this policy; 'the use of 'such terms officers, employees, members, or
associate, applies to all employees of Wailer County Sheriffs Office Jail Division. The
uses of terms like inmate, detainee, or prisoner, in this policy are also generally
interchangeable.
PROCEDURES:
General Guidelines:
mp oyees follow both the spirit and content of the rules and policies established by this
enc and encourae compliance by fellow officers and em lo ees. Command and
supervisory sta are the ro e mo e s an are expected to demonstrate eadership and set
subject to this restriction Is contained throughout this publication.
Page 1 of 97
DEF000023
Jail and Detention Policies and Procedures, 2.07 Rules of Staff Conduct
exemplary standards.
Section One - Obedience to Orders, Rules, & Laws:
r 1.1
Obedience to Rules of Conduct

All sworn and civilian employees are governed by the following general rules of
conduct. Violations of any of these rules are considered sufficient cause for
disciplinary action up to and including dismissal.
1.2 Obedience to Laws

Officers and other employees must abide by the laws of the United States, the state
of Texas and the ordinances of Waller.
1.3
Adherence to Waller County Sheriff Office Jail Division Rules

Officers and employees abide by the personnel policy and the general, special, and
tactical orders, rules of conduct, and other properly issued internal directives of the
agency.
1.4 Insubordination
(4
1
Officers and employees promptly obey all lawful orders and directions given by
supervisors and radio dispatchers. The failure or deliberate refusal of officers and
employees to obey such orders is insubordination. Flouting the authority of a
superior by displaying obvious disrespect or by disputing orders is likewise
insubordination.
1.5
Issuance of Unlawful Orders

No supervisory officer or employee will knowingly or willfully issue an order that
violates a federal or state law, a city/county ordinance, or an agency rule or policy.
1.6 Obedience to Unjust or Improper Orders

If an officer or employee receives an order believed to be unjust or contrary to
ethics, policies and procedures of the agency, or contrary to the rule of law, he must
first obey the order to the best of his ability and then may appeal the order to the
Sheriff.
1.7 Obedience to Unlawful Orders
No officer or employee is required to obey an order that is contrary to the laws of the
United States, the state of Texas the ordinances of the City of Hempstead, County
DEF000024
Page 2 of 17
of Waller or policies established by this agency. If an officer or employee receives
an unlawful order, he will report in writing the full facts of the incident and his action
to the Sheriff thru the chain of command. If the order is perceived as dangerous, or
places others at risk, the officer or employee receiving the order will seek immediate
clarification from their next higher supervisor, available before acting.
1.8
Conflict of Orders
If an officer or employee receives an order that conflicts with one previously given
him by a superior officer or employee, the officer or employee receiving the order
shall respectfully point this out to the superior officer or employee who gave the
second order. if the superior officer or employee giving the second order does not
change the order in a way that eliminates the conflict, the-second order stands and
is the responsibility of the second superior officer or employee. If the second
superior officer or employee so directs, the second order is obeyed first. Orders are
countermanded when necessary for the good of the agency and accomplishment of
the mission.
1.9 Duty to Read, Understand, and Comply With Orders
(1)
Failure to read and comply with laws, rules and regulations, general and special
orders, policies and procedures of the agency, or written or verbal orders of a
supervisor is prohibited. It is neglect of duty to fail to inquire of a supervisor the
meaning or application of any directive, policy and procedure, or order that is not
clearly understood.
1.10 Issuance of Orders
Orders from supervisors to subordinates are addressed in professional, clear,
understandable English; civil in tone, and manner; and, issued in pursuit of official
business.
Conduct Unbecoming
...... .
Conduct that adversely affects efficiency, erodes public respect, or reduces

confidence in government service is unbecoming and is prohibited. Examples of
such conduct include, but are not limited to:
a. Fraud in securing employment;
b. Filing a false, incomplete, or misleading report, or record;
c. Giving a knowingly false or misleading location, description of event, or other
information during a radio, telephone, or verbal report;
d. Conviction of any felony or of a misdemeanor involving moral turpitude, or
the entry of a plea of no lo contendere to either;
e. Misuse of government funds or property;
Page 3 of 17
npRaogn25
I Jail and Detention Policies and Procedures, 2.07 Rules of Staff Conduct
f. Falsification or misuse of government records, Including application forms,
time and financial records, incident reports, case files, or personnel records;
g. Reporting to work or working under the influence of alcohol or substances
that significantly impair job performance, or the use of such substances
during working hours; except prescribed medication that does not adversely
affect the ability to perform assigned work tasks;
h. Instigation of, participation in, or leadership of a strike, sit-down, stay-in,
sympathy strike, walk-out, slow-down, sick-out, or any other interference with
normal, efficient workflow;
i. Concealment or failure to report any employment, ownership interest, or
personal activity in conflict with the legitimate interests of the citYcounty;
J. Engaging in infamous, notorious, or disgraceful conduct that adversely
affects the county legitimate interests;
k. Collecting a debt or conducting private business while on-duty or assigned to
duty;
i. Insubordinate, rebellious, disruptive, harassment, or disrespectful behavior
toward other employees or government officials; or
m. Fighting.
Section Two - Attention to Duty:
2.1
Performance of Duty
Officers and employees are to be attentive to their duties at all times, and perform
all duties ascribed to them even if such duties are not specifically assigned to them
in any rules or procedures.
2.2 Duty of Supervisors

Supervisors enforce the ethics, codes, rules, regulations, policies, and procedures
of the agency. They do not permit or otherwise fail to prevent, violations of these
important documents and practices. They take immediate action to correct
deficiencies or report violations to their immediate superiors without delay. When
possible, they actively prevent such violations or interrupt them as necessary to
ensure efficient, orderly operations.
2.3 Truthfulness
Officers and employees will not knowingly give any false or misleading information
concerning the duties, responsibilities, or actions of the agency or any member
thereof, nor withhold any information that is their duty to report, nor falsify any
official document.
2.4 Conduct and Behavior

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DEF000026
Officers and employees, whether on-duty or off-duty, follow the exemplary and
reasonable rules of good conduct and behavior and will not commit any act in an
official or private capacity tending to bring reproach, discredit, or embarrassment to
their profession and the agency. Officers and employees follow established
procedures in carrying out their duties as professional detention officers and
employees of the agency.
2.5
Responsibility to Serve the Public

Officers and employees consider it their duty to be of service to the general public
and to render that service in an impartial, considerate, and patient manner. Officers
and employees promptly serve the public by providing direction, counsel, and other
assistance that does not interfere with the discharge of more critical detention
duties.
2.6
Respffisfingtie Rights
Officers and employees respect the rights of others and do not engage in
discrimination, oppression, or favoritism. Officers and employees must maintain a
strictly impartial attitude toward complainants and violators. Use of profane,
demeaning, or insulting language will not be tolerated, nor will disrespect for the
political or religious views of others be accepted.
2.7 Officers Always Subject to Call of Duty

Officers respond to lawful orders of supervisors and to the call of citizens in need of
assistance. Off-duty officers are expected to take prompt and proper action when
human life is perceived to be in danger. Officers and employees are subject to call
twenty-four (24) hours a day and may be recalled from vacation, leave, or off-day
whenever necessity demands.
2.8 Reporting for Duty & Relief from Duty
Officers-andemployeas ratt"prdrilptlyWort for duty "properly prepared at the time
and place required by assignments, subpoenas, or orders. Officers and employees
must remain at their posts or place of assignment until properly relieved by another
officer or employee or until officially dismissed by a supervisor. It is the relieving
officers' and employees' responsibility to locate and meet with the officer or
employee he is relieving. The officer or employee who is being relieved has the
responsibility to pass onto his relief any and all pertinent information. The relieving
officer or employee must assist the officer or employee he is relieving in any way
possible so as to expedite the relief and complete the officer or employee's tour of
duty in a timely manner.
2.9
Availability White on Duty

Page 5 of 17
DF-g0=327
Officers and employees, while on duty, may not conceal themselves or maintain a
hidden or low profile except for some assigned purpose. Officers and employees
will keep themselves immediately and readily available at all times while on duty.
2.10 Prompt Response to All Calls
Employees must respond to all dispatched assignments without argument and
unnecessary delay. No officer will fail to aid, assist, or protect a fellow officer,
employee, or citizen to the fullest extent of his or her professional capabilities. Calls
are answered in compliance with all policies, procedures, rules, regulations, and
laws.
2.11 Duty to Report All Crimes and Incidents
Officers and other employees must promptly report all serious crimes, emergencies,
incidents, dangers, hazardous situations and relevant information that come to their
attention. Officers and employees may not conceal, ignore, or distort the facts of
such crimes, emergencies, incidents, and information.
2.12 Responsibility to Know Area of Jurisdiction
Officers and other employees know the physical boundaries of the county and know
their areas of jurisdiction.
2.13 Sleeping on Duty
Officers and employees must be alert throughout their tour of duty. Sleeping or
napping while on duty is strictly forbidden.
2.14 Assisting Criminals
Officers and employees do not communicate in any manner, directly or indirectly,
any information that may delay an arrest or enable persons suspected of criminal
acts to escape an interview, interrogation, arrest, or punishment. Nor will officers or
employees dispose or concert to their own use any property or goods seized or
taken from a suspect, or destroy evidence of unlawful activity.
2.15 Reading on Duty
Officers and employees must not read newspapers, books, or magazines while on
duty and in the public view unless authorized by a supervisor.
2.16 Studying on Duty

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Page 6 of 17
Officers and employees must not engage in any studying activity during their
regularly assigned working hours that are not directly related to their current job
assignment unless specifically authorized by their supervisor.
2.17 Maintaining Communications
Officers must be directly available by normal means of communication while they
are on duty or officially on-call, and will promptly respond when called. On-duty
officers must maintain radio communications with the agency dispatcher while
he/she is on-duty and radio equipped. Should an officer experience a technical
malfunction with communications equipment, immediately report the condition and
replace or repair the equipment as soon as practical. The use of personal
communications devices such as cellular phones, or pagers, is approved if the
numbers of such devices are recorded and accessible by the dispatcher. Personal
use of personal communications devices for other that law enforcement duties is to
be limited while on duty.
2.18 Keeping Notes on Detention Activities
Officers and employees are required to maintain written notes on detention and
other operational matters such as calls, arrests, and other activities to the extent
that they may later complete official reports and accurately testify in official
proceedings. Officers are not required or encouraged to keep personal notes after
the data in the notes have been entered into an official report. The written report is
the record of choice.
2.19 Completing Official Reports
Unless otherwise directed, officers and employees must promptly submit all reports
completed prior to going off duty. All reports, forms, memoranda, citations, or other
papers utilized in this agency are completed in ink, computer printed, or typed,
Special projects may require deviation from this requirement.
2.20 R6itiOrtirig-Adaideftt'S,-Iriiiiiiek &-DlibliargeEVehte
Officers and employees must immediately report the following types of accidents
and injuries:
a. On-duty traffic accidents in which they are involved.
b. Personal injuries received in the line of duty no matter how small in nature.
c. Personal injuries not received in the line of duty but which are likely to
interfere with performance of official duties.
d. Property damage or injuries to other persons that resulted from the
performance of his/her official duties.
e. Every discharge of a firearm, explosive, or electronic stun device, except
Page 7 of 17
DEF000029
when engaged in agency training exercise, firearms qualifications, or sporting
event.
2.21 Reporting Address
Telephone Number
Officers and employees must have a working telephone at their residence and must
register their correct residence address and all telephone numbers with the agency.
This includes cellular phones. Any change in address or cellular number must be
reported immediately.
2.22 Testifying in Official investigations
Officers must cooperate fully, make statements, or furnish materials relevant to an
official internal or criminal investigation, as required.
2.23 Overtime
Authorized supervisors must approve overtime requests prior to the actual work
beginning.
2.24 Duty to be Prompt and Punctual
Employees and officers must be prompt and punctual when reporting to their official
duties or assignments.
2.25 Remaining at Duty Station
Employees and officers are required to remain at their duty assignment unless and
until they are properly relieved. Absence from assigned workstation or duty without
permission is prohibited.
2.26 Excessive Absenteeism
Habitual or patterned use of sick leave or leave without pay, not supported by
competent medical evidence or other proof of necessity is prohibited.
2.27 Prohibited Association and Frequenting
Associating with people, organizations, or places known or suspected to be involved
in criminal activity is prohibited unless necessary for official agency business.
2.28 Subversive Organizations
Officers and employees may not knowingly be members of or affiliated with, any
subversive organization whose avowed purpose advocates the overthrow or
subject to this restriction'is contained throughout this publication.
DEF000030
Page 8 of 17
disruption of the lawful function of any federal, state, county, or municipal
government.
2.29 Duty With Regard to Civil Proceedings
No employee may initiate any civil proceeding arising out of an official agency
activity without first notifying the Sheriff. Private civil actions that have no
connection with a member's agency position or official action are not within the
scope of this rule.
2.30 Supplies or Services
Officers and other employees may not use agency supplies or resources for
personal use. The use of the time, authority, facilities, equipment, or supplies of the
citycounty for private gain or advantage is prohibited.
2.31 Bulletin Boards
Employees and officers will regularly read and comply with notices posted on official
bulletin boards maintained at the direction of the Sheriff.
2.32 Refrained From Conducting Personal Business While On-Duty
Employees may not conduct personal business while on-duty without prior approval
from their supervisor.
2.33 Use of Tobacco Products
Use of any tobacco products while in county building, vehicle, or at any time while
in personal contact with the public is prohibited. This policy does not apply to
designated smoking areas at government or other public buildings,
2,34 Harassment Reporting and Protection From Retaliation
A person reporting any form of harassment or unethical conduct is protected to the
extent allowed by law. Any employee or officer reporting legitimate harassment or
unwarranted conduct will not be retaliated against.
Section Three - Cooperation with Fellow Employees and Agencies:
3.1
Respect for Fellow Officers & Employees

Employees and officers treat other employees or officers with respect, as they
would prefer to be treated. Each member of Waller County Sheriff's Office Jail
Division is courteous, civil, and respectful of their superiors and work associates.

Page 9 of 17
DER/00031
Command and supervisory personnel support subordinates in their actions and

orders when they can do so reasonably. They avoid censuring subordinates in the
presence of others and may not injure or discredit those under their authority by
intentional or abusive conduct. This does not prohibit informal oral reprimands or
constructive criticisms directed to a subordinate. Any acts of counseling,
disciplining, complaining, or criticizing is most effective if done positively and
constructively in an appropriate setting.
3.2 Supporting Fellow Employees
Employees and officers must cooperate, support, and assist each other at every
opportunity. Employees may not maliciously criticize the work or the manner of
performance of another. It is the duty of every officer and employee to refrain from
originating or circulating any malicious gossip.
3.3 Case or Operations Interference
Officers and employees may not interfere with cases assigned to others without
receiving clearance from the officer to which the case is assigned or as directed by
a supervisor. Should interference occur, the assigned officer must submit a written
report to his immediate supervisor.
3.4 Cooperation with Other Agencies
Officers and employees of the agency must cooperate with all governmental
agencies by providing whatever aid or information such agencies are legally entitled
to receive. Any doubts will be passed to a supervisor for approval, before
cooperation is rendered.
3.5
Disclosing Information Relating to Official Activities

Discussion of operations and official business of the agency is prohibited outside of
those authorized individuals that have a need to know.
3.6 Misconduct Known to Personnel

Failure to correct and report an employee's violation of a law, rule or regulation,
policy or procedure, or a general or special order is prohibited. Reports are made to
the next level supervisor, unless the supervisor is known or suspected to be
involved in the alleged misconduct.
Section Four - Restrictions on Behavior:

4.1
Interfering with Private Business

DEF000032
Page 10 of 17
O
Employees of the agency will not interfere with the lawful business of any person.
4.2
Use of intimidation
Officers and employees may not use their official positions to interfere, intimidate, or
support persons engaged in a civil controversy.
4.3
Soliciting and Accepting Gifts and/or Gratuities

Unless approved in writing by the Sheriff, officers and employees of the agency will
not solicit or accept any reward, gratuity, gift,' or compensation for services
performed as a result of their relationship with the agency. This restriction applies
regardless of whether the service was performed on-duty or off-duty.
4.4 Soliciting & Accepting Gifts from Suspects, Detainees, or Prisoners

Officers and employees are strictly prohibited from soliciting or accepting any gift,
gratuity, loan, fee or other item of value, or from lending or borrowing, or from
buying or selling anything of value from or to any suspect, prisoner, defendant or
other person involved in any case, or other persons of ill repute, or professional
bondsmen, or other persons whose vocations may profit from information obtained
from law enforcement,
4.5
Reporting Bribe Offers

If an officer or employee receives a bribe offer, he must immediately make a written
report and submit the report his immediate supervisor.
4.5 Accepting Gifts from Subordinates

Without approval from the Sheriff, employees may not receive or accept any gift,
reward, or gratuity from subordinates.,
,. -. e
4.6
Giving Testimonials and Seeking Publicity

As it may pertain to their employment with the agency, officers, and employees will
not give testimonials or permit their names or photographs to be used for
commercial or political advertising purposes. Officers and employees will not seek
personal publicity either directly or indirectly in the course of their employment.
4.7
Soliciting Business
Officers and employees will not solicit subscriptions, sell books, papers, tickets,
merchandise or other items of value nor collect or receive money or items of value

This data is proprietary and will not be duplicated, disclosed, or discussed, without the written permission of this agency, Data
Page 11 of 17
DEF000033
C)
for any purpose while on duty unless specifically authorized in writing by the
aApproval title.
4.8
Intoxication
Officers and employees will not be under the influence of any intoxicating beverage
or substance during their tour of duty or immediately prior to their tour of duty. Nor
will officers and employees be intoxicated off duty while in the public view.
4.9
Drinking While in Uniform or OnDuty

Officers or other employees will not consume alcoholic beverages while in uniform,
on-duty, on government property, or in an official vehicle of this agency unless
specifically authorized to do so in the course and scope of a clandestine
investigation. Officers and other employees will not drive or operate motor vehicles
within eight hours after consuming alcoholic beverage(s).
4.10 Liquor on Official Premises

Officers and employees will not bring containers of intoxicating beverages into a
building or a vehicle except as properly sealed and marked as evidence in a criminal
or juvenile case.
4.11 Entering Bars, Taverns, and Liquor Stores
Other than for the purpose of performing their official duties, officers and employees
on duty or in uniform will not enter or visit any bar, lounge, parlors, club, store, or
any other establishment whose primary purpose is the sale or on-premise
consumption of alcoholic beverages. Officers and employees on duty or in uniform
will not purchase alcoholic beverages, except as part of a documented investigation,
4.12 Playing Games on Duty Officers and employees on duty or in uniform will not engage in any game of cards,
billiards, pool, chess, dominoes, electronic, or other games.
4.13 Political Activity
Officers and employees will not participate (e.g., make political speeches, pass out
campaign or other political literature, write letters, sign petitions, actively and openly
solicit votes) in political campaigns while on duty or in uniform.
4.14 Seeking Personal Preferment
Officers and employees will not solicit petitions, influence, or seek the intervention of
This data is proprietary and will not be duplicated, disclosed, or discussed, without the written permission of this'agency. Data
subject to this restriction is contained throughout this publication,
DEF000034
Page 12 of 17
any person outside the agency for purposes of personal preferment, advantage,
transfer, advancement, promotion or change of duty status for themselves or any
other person.
Section Five - Identification and Recognition:

5,1 Giving Name and Badge Number
Officers and employees must give their names, badge number, and other pertinent
information to any person requesting such facts. Exceptions are those conditions
when doing so would jeopardize the successful completion of an official assignment,
or when requested to do so by a prisoner.
5.2
Carrying Official identification

Officers must have official agency identification available at all times unless involved
in sanctioned covert activities, engaged in athletic or physically challenging
activities.
5.3 Personal Cards

Business cards showing connection to the agency must be approved by the Agency
5.4
Exchange, Alteration, or Transfer of Badge, Patch, or Logo

The official badge, patch, or logo of the agency will not be altered, transferred, or
exchanged except as authorized by Sheriff. The exception to this practice is the
exchanges of patches or lapel pin badges with other law enforcement agencies.
Section Six Maintenance and Use of County Property:

6.1
Use of County Property or Service

Officers and employees will not use or provide any county equipment or service
other than for official county business unless specifically authorized by the Sheriff.
6.2
Responsibility for County Properly

Each officer or other employee is responsible for keeping all agency equipment
clean and in good working order. Careful effort is made to protect property from
loss, damage, or destruction. Employees deemed responsible for the loss or
damage of issued items may, in addition to any other disciplinary action may be
required to compensate the agency for the loss or damage. Any equipment that
becomes damaged or lost is immediately reported in writing,

Page 13 of 17
DEF000035
6.3 Reporting Needed Repairs
Officers and employees must promptly report the need for repair of county-owned
property to their supervisor. This includes needed repairs to safety equipment and
vehicles.
6.4
Responsibility for Private Property

Officers and employees are responsible for protecting private property or equipment
that has come into their possession, by reason of their office, against loss, damage,
or destruction. The agency assumes no responsibility for any personal property of
the officer's in case of loss or damage.
6.5 Care of Quarters

Officers and employees keep their offices, vehicles, lockers, and desks neat, clean,
and orderly.
6.6 Property and Evidence Security
Officers and employees must tag and place all evidence in the custody of the
evidence officer as soon as possible. Officers and employees will not convert to
their own use, manufacture, conceal, falsify, destroy, remove, tamper with, or
withhold any property or evidence held in connection with an investigation or other
official action except in accordance with established procedures.
6.7 Alteration or Modification_ of Agency Equipment
Officers and employees may not use any equipment that does not conform to policy
or specifications. All equipment must be carried and utilized only as issued and
authorized, and no changes, alterations, modifications, or substitutions will be made
to such equipment unless approved by the Sheriff.
6.8
Parking in Unauthorized or Reserved Parking Spaces

Parking in designated handicap permit spaces, reserved or restricted space, or
marked fire lanes, unless responding to an declared emergency, is strictly
prohibited.
6.9 Use of Communications Equipment

The use of county computers, telephones, radios, stationary, fax, mails, delivery
service, or other communication devices or systems for personal use is forbidden.
This includes the use of Internet communications and the downloading of material
personal use or retention.
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Page 14 of 17
Section Seven - Relationships with Courts and Attorneys

7.1
Attendance in Court
Officers and other employees arrive on time for all required court appearances and
are prepared to testify.
7.2 Recommending Attorneys or Bondsmen

Officers and other employees may not suggest, recommend, advice, or counsel the
retention of a specific attorney or bondsman to any person coming to their attention
as a result of their official business.
7.3 Testifying for a Defendant
Any officer or employee subpoenaed or requested to testify for a criminal defendant
or against the ,county or against the interest of the agency in any hearing or trial will
immediately notify the Sheriff through the chain of command. Likewise, employees
or officers subpoenaed to judicial hearings will honor said subpoena and notify their
immediate supervisor in a timely manner.
7.4
Interviews with Attorneys

Interviews between an officer or employee and a complainant's [criminal] or
Plaintiffs [civil] attorney about a case arising from the officer's employment by the
agency is done only in the presence of or with the knowledge and consent of the
Sheriff.
7.5
Assisting in Civil Cases

Officers and other employees will not serve civil-process papers nor render
assistance in civil cases except as required by law and approved by the Sheriff.
Officers and other employees will not volunteer to testify in any civil action arising
from agency duties. Any testimony provided in civil cases, where the agency or
county is not a named party, will be provided by the employee or officer during offduty time. The officer or employee providing such testimony will state in the record .
. . My appearance and testimony in this civil action, is not authorized by, connected
to, or sanctioned by Waller County Sheriffs Office.
7.7 Notice of Lawsuits Against Officers & Employees

Officers and other employees who have had a suit filed against them because of an
act performed in the line of duty will immediately notify the Jail Administrator in
writing and furnish a copy of the complaint as well as a full and accurate account of
Page 15 of 17
DEF000037
the circumstances in question.
7.8
Notice of Investigation, Arrest, or Citation

Officers and employees who become the subject of citations or arrest actions will
immediately notify the Sheriff in writing. Any officer or other employee who has
reason to know they are the subject of a criminal or civil action will immediately
notify their supervisor, who will in turn notify the Sheriff
Section Eight Relationship and Responsibility to Detainees, Inmates, &

Prisoners:
8.1
Relationship to Those Housed in the Facility

Officers and staff do not encourage or allow interpersonal relations between
inmates and those working or having working access to the facility.
8.2 Private Correspondence with Inmates

Officers and staff do not conduct or allow any personal communications with
inmates, former inmates, or the inmate's relatives or acquaintances. All
communications with inmates and their known associates is professional and nonpersonal. Officers will not accept, deliver, or give private from one inmate to
another or from a person to an inmate, except as approved through established
distribution channels.
8.3 Making Inspection Tours
Officers must be meticulous in making assigned rounds, especially as it relates to
inmates with special needs such as those housed in segregation units, suicide
watch, mental watch, or other special watch conditions.
8,4
Touching of Officers, Staff, or Inmates

Special care is taken not to allow casual touching between staff and inmates. All
touching of an inmate must be for a penological purpose. Likewise officers will not
allow inmates to touch officers or staff. For an inmate to touch an officer or staff
member is a punishable offense after an inmate has been advised of the offense
through word or other notice,
8.5
Supervision of Trustees
Officers remain aware that another name of Trustee is Riskee. In other words
trustee require supervision too. Officers exercise due diligence in observing
movements and actions of trustees; and, never allow trustee access to keys, control

DEF000038
Page 16 of 17
or access to monitoring devices. To maintain their trustee status, they submit to
frequent searches, frisks, and limitations in movement with objection.
8.6
Favoritism
Officers and staff never show favoritism of one inmate or group of inmates over
another, unless it is calculated to alter or improve inmate behavior.
8.7
Support for Other Officers & Staff

Officers and staff know and adhere to the principle that inmates detect and use to
their advantage discord between officers and staff. As a result, officers will work as
a close knit team and never allow inmates to hear or observe disharmony between
staff members. Officers discipline inmates that make derogatory, threatening,
sexually explicit, or demeaning comments about other officers and staff.

Page 17 of 17
DEF000039

Jail and Detention
Subject: Officer & Employee
Discipline & Accountability
Policy Number: 3.03
Issue Date:
Revision Date:
Approval Authority
POLICY:
Officers and civilian employees, to the best of their ability, live up to the ideals
expressed in the Code of Ethics, and Objective Statements of WCSO Jail. All
employees obey agency policies and procedures, written and verbal orders, rules,
directives, and standards of conduct. Noncompliance with these goals and standards
results in disciplinary action to improve individual and group performance.
It is in the penological interest of this detention facility to require employees to perform
their duties in a professional manner, dedicated to the standards established in our
policies and procedures and codes.
PROCEDURES:
Discipline in a jail operation is essential to officer and employee survival and is the
determining factor in promoting a safer work environment. There are many things we
cannot control while performing our jobs; however, discipline is one thing we can all
agree needs to be fostered and enforced.
General Guidelines - Disciplinary Action:
r Grounds for disciplinary action include, but are not limited to; noncompliance or violation
of policy; conduct that interferes with operations; or conduct which discredits the
agency; or, is offensive or dangerous. Disciplinary action may be appropriate whether
or not such action is specifically prohibited by written goal, objective, policies and
procedures, order, rule or directive, This policy set does not attempt to define all errant
behavior. Employees use their best efforts to comply with both the *spirit and word of
these guidelines.
Employees are expected to perform assigned tasks efficiently and safely and in accord
with applicable quality standards and safety requirements.
Page 1 of 5
DEF000051
Jail and Detention Policies and Procedures, 3.03 Officer & Employee Discipline &
Accountability
All employees are expected to treat visitors, employees, managers, supervisors,
inmates, and others in the jail with courtesy and respect.
WCSO Jail does not discriminate or show favoritism on the basis of sex, ethnicity, race,
religion, color, age, or physical disability. Disciplinary actions are based on the
concepts of equality and equity.
The Jail Administrator has the sole right to determine the disciplinary process applicable
in particular circumstances as well as the discipline to be imposed for violations or noncompliance.
Progressive disciplinary measures are generally followed. However, circumstances,
officer and employee attitudes, performance, and any extenuating or mitigating factors
may be considered when determining the discipline,to be imposed.
Progressive discipline may include, but is not limited to; counseling, warning,
suspension, or any other remedial steps deemed desirable, such as demotion,
permanent or temporary disqualification, transfer, wage reduction, training and/or
imposing conditions on continued employment.
Termination from the agency may be imposed for a first offense and may be imposed at
any point in a progressive chain, whether or not any other step(s) of progressive
discipline have first been imposed.
The Jail Administrator is designated to oversee disciplinary actions in the jail. He/she
may, in his/her discretion, keep documents, and other records of disciplinary action,
which may be considered in future personnel decisions.
in cases of serious misconduct such as major breaches of policy, violations of law, or
threats to human life, procedures contained in this policy may be waived. Disciplinary
action on the part of the agency does not shield the officer or employee from criminal or
civil charges that may arise out their deliberate or negligent acts.
General Reasons for Disciplinary Action:

An officer or civilian employee may be disciplined or terminated fora number of reasons
including, but not limited to:
1. Dishonesty, such as falsifying or altering any document, record, or report relating
to the agency and/or relating to employment, such as a time card, employment
application, medical report, or expense reimbursement request; and includes
providing false or misleading information and/or failing to provide truthful and
complete information in connection with any investigation.

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Page 2 of 5
Accountability
2. Conviction of a criminal offense, including a felony or certain misdemeanors, or
any other offense involving moral turpitude.
3. Insubordination to the directives of a superior.
4. Violation of the law.
5. Reporting to work under the influence of alcohol or any drug not prescribed by a
licensed physician.
6. Offensive conduct or language toward the public, superior, or other employees.
7. Carelessness or negligence in the use of agency property.
8. Accepting or encouraging the taking of a bribe.
9. Encouraging other persons to commit illegal acts.
10.Failing to report to work, court or official duty assignments without reasonable
cause, or excessive tardiness.
11. Failure to observe starting, quitting, and and/or break times.
12. Horseplay or dangerous acts.
13.Violation of security, health, safety, or environmental standard.
14.Careless workmanship or production.
15.Competing with the interests of the agency.
16.1n4propriate conduct or relationship with an inmate, inmate's family, or their
associates;
17. Allowing or turning a blind eye to an escape or escape plan.
18.Theft, attempted theft, misappropriation, or willful damage to property.
19. Distribution, transfer, sale, possession or consumption at the work place or on
government property of any alcohol, intoxicant, or controlled substance which
has not been prescribed for the one in possession, the recipient, or the one
consuming.
20.Threatening, intimidating, harassment, coercing, abusing, or interfering with a
supervisor, manager, independent contractor, supplier, visitor, Of co-employee,
either by words or action.
21. Unauthorized disclosure of any confidential information.
22.Failure to report any accident, misconduct, or rule violation to an immediate
supervisor, or the Jail_Administrator; or failing to cooperate with and/or failing
to provide information requested in connection with any authorized investigation
or inquiry.
23. Unauthorized disclosure of any confidential information, detention, or law
enforcement work product.
24.Failure to report any accident, misconduct, or rule violation to an immediate
supervisor, or the Jail Administrator, or
25. Failing to cooperate with and/or failing to provide information requested in
connection with any authorized investigation or inquiry.
Reporting of Disciplinary Action:

Whenever disciplinary action is used, the employee is advised of:
1. Exact offense violated;
Page 3 of 5
DEF000053
Accountability
2. How the violation affects ability to be an effective, efficient, or safe employer, or
adversely effects Nameof facility;
3. What the member must do to avoid future disciplinary action;
4. How much time the member has to correct the problem; &,
5, What further disciplinary action, including dismissal, will occur if performance
does not improve?
Non-Disciplinary Action:
Not every supervisory interaction or intervention with a member is to be construed as
discipline. The following are examples of non-disciplinary courses of action:
1. Supervisory Consulting: Except in cases of culpability, correcting undesirable
conduct may be handled by the shift supervisor in an informal atmosphere. This
means taking the member aside and discussing the problem, candidly and
openly. These actions may or may not be formally documented on the first
occasion, depending on the supervisor's discretion, and the seriousness of the
errant behavior. Repeat violations are documented by the supervisor.
2. Counseling: At times, personal problems may interfere with the Member's
ability to perform normally. When the results are not serious enough for
discipline; however, call for a more formal type of corrective action, counseling is
an excellent tool to help the member. Counseling is not a form of discipline, it is
a tool available to correct problems and refocus on performance prioritied.
3. Administrative Leave: Administrative leave occurs any time the member must
be removed from duty until an investigation or other administrative proceeding is
completed.
Usually situations of this nature involve cases of suspected
misconduct, such as alleged criminal activity, fighting, continued non-compliance,
or being mentally or physically unfit for duty. In such cases, leaving the member
in position would create an unreasonable liability or safety issue for fellow
workers or the agency. The shift supervisor can order a relief from duty and then
immediately report the action to the Jail Administrator The Jail Administrator
then initiates an investigation and makes a decision within 24 hours about
whether the relief will continue, for how long, and if the administrative leave will
continue with or without pay and benefits.
4. Administrative Absence Use of Force or injury: Following a deadly use of
force or major injury to the officer, a furlough may help the member adjust and
handle any personal or emotional needs resulting from traumatic events,
Administrative furloughs are mandatory, initiated by the shift_supervisor, or the
senior management official at the scene. An administrative absence for a major
injury or use of deadly force incident may continue until the employee involved
has received counseling by a licensed professional.

DEF000054
Page 4 of 5
Accountability
Steps of Progressive Disciplinary Action:

The following are progressive steps that can be taken in efforts to discipline employees
of WCSO Jail. it is not necessary to start at step one if the seriousness of the
employee's conduct exceeds that form of discipline. At the discretion of the Jail
Administrator the following manners of discipline may be pursued:
1. Written Warning or Reprimand: Written warnings or reprimands are a way of

recording the employee infraction. Such records are placed in the employee's
file and provided to the employee within 48 hours of the infraction.
2. Suspension: An employee may be suspended without pay by the Jail

Administrator. Suspension is the second step in discipline if the act, and/or the
result of the act, is serious enough that a written warning or reprimand would not
be sufficient for disciplinary action. The suspended member may appeal a
suspension by stating justifiable grounds for their action, in writing to Sheriff. The
Sheriff has the option of vacating the suspension, increasing the suspension time
of terms, or allowing the decision stand.
3. Demotion: The employee may be demoted to a position of,a lower grade or

lower responsibility. Demotion as a form of discipline is intended to be punitive
and can occur concurrently with a suspension.
4. Termination: If all other forms of discipline fail to correct the conduct of the
employee, or the actions of the employee are deemed serious termination is the
last resort.

Page 5 of 5
DEF000055

Jail and Detention
cs
Subject: Jail Admission
Issue Date:
'
Policy Number: 4.02

Revision Date:
Approval Authority
POLICY:
Admittance and processing of arrestees and inmates into WCSO Jail includes verification
of legal confinement, screening, classification, searching, and issue of clothing and sundry
items while maintaining security and operational integrity of the jail.
WCSO Jail has a penological interest in processing new or returning inmates in an efficient
and orderly manner, while providing reasonable and necessary security for employees,
officers, and inmates.
PROCEDURE:
Initial Processing:
Initial jailer-offender contact is most often in the receiving or booking area of the jail. This
first meeting normally occurs in the presence of the arresting or transporting officer(s).
All firearms, knives, batons, and other weapons of arresting or transporting officers are
secured under lock and key before entering the secure area of the jail.
The booking officer verifies the identification of the arresting or transporting officer before
the officer and the prisoner are allowed to enter the admission area. If only one corrections
. officer is on duty, the delivering officer should stay until the inmate is locked into the facility.
During in-processing and until the inmate is officially received, transporting or arresting
officers must retain control and custody of his/her detainee at all times.
During the intake procedure the jail officer completing the intake and booking process will:
1. Pat search the arrestee and inspects his property immediately upon entering the
admission area. The search may include any reasonable and lawful means to
determine that no weapon or contraband is introduced into the holding area. More
extensive, searches may be conducted in accordance with WCSO Jail Policy 5.3
Paget of 4
DEF000071
Jail and Detention Policies and Procedures, 4.02 Jail Admission
Searches.
2. Observe the arrestee visually for obvious signs of injury or illness. If the arrestee is
in need of immediate emergency medical or mental attention, the admissions officer
must refuse to acceptthe inmate, and refer the arresting or transporting officer and
his prisoner to the appropriate facility.
3. Require that the peace officer, delivering the inmate, must present a booking slip,
certified court order, Judgment commitment order, or equivalent, which provides
documented authority to commit or detain the inmate.
4. Inspect the documents presented to ensure certification or otherwise verify the
documents as legal, valid, and accurate.
5. Determine if the inmate is eligible for entry and can be appropriately housed in the
facility.
6. Prepare an admission receipt, retaining the original for the inmate's commitment file.
One copy each will be provided to the committing officer and the control center.
7. The transportimtofficer then relinquishes custody of the inmate, and may depart the
facility.
8. Fingerprint and photograph inmates. Copies of the fingerprints are transmitted to
the proper state and federal authorities.
. Observe inmates confined in a holding cell or detoxification cell at irregular intervals
about every 30 minutes:'' Intake officers are cautioned to vary the times of checks,
so as not to establish a discernible pattern.
Inmates must not be accepted into WCSO Jail and will remain in the custody of the
arresting or transporting officers, under the following conditions:
1. Inaccuracies exist in the prisoner's paperwork;
2. There is a question as to the Identity of the prisoner in comparison to the
accompanying paperwork;
3. Transporting or arresting officer refuses or cannot furnish, reasonable background
data about the prisoner;
4. Prisoner has made an outcry, or there are serious indications, that the arresting or
transporting officer(s) have brutalized him, or violated the prisoner's civil or
constitutional rights;
5. Prisoner is in need of medical attention;
6. Prisoner is in need of psychiatric evaluation or observation; &
7. Prisoner requires other special needs that the facility cannot reasonably provide.
In the case where an admissions officer suspects or hears an outcry in which constitutional
rights have been violated, the arresting or transporting officer is instructed to notify their
supervisor to investigate or resolve the complaint. The prisoner may not be admitted into
WCSO Jail until the situation is resolved, and the inmate has spoken to the arresting or
transporting officer's supervisor. If these conditions are not present, the admissions officer
continues with the booking process,
Telephone Access:
0EF000072
Page 2 of 4
Jail and Detention Policies and Procedures, 4.02 Jail Admission
10
Immediately after booking, but in no case later than four [4] hours after arrival, inmates are \
permitted to make at least two [2] completed telephone calls. Toll calls should be made on
a prepaid or collect basis. A free telephone is available for local calls for those inmates
who otherwise would be unable to complete the two required calls.
Commitment Form:
The admitting officer completes the Initial Custody Assessment Scale Form (4.02-1).
Criminal History Checks:
National Crime Information Computer [Ncic], state, and local background checks are
made for each new inmate commitment. This process must be completed during the first
twenty-four hours the inmate is in the facility.
Initiation of the Central File:
The inmate central file is initiated with the gathering of the above information.
Medical, Dental, Mental and Suicide Screening:
Medical, dental, mental health and suicide processing procedures also begin with
admission. The admissions staff interviews the inmate and obtains as many items of
information, required by the facility's medical intake screening form, as possible.
The Jail Administrator or his designee is to be notified, if any of the following conditions are
noted AIDS; HIV infection; TB, heart problems, diabetes; epilepsy; pregnancy; suicidal
claims or threats, or any chronic, potentially life-threatening Illness.
New inmates suspected of harboring communicable diseases are to be isolated at once. In
such a case, unless a medical staff member documents the determination that adequate
facilities are available in the facility, the shift supervisor arranges for a necessary escort to
a proper medical or dental facility.
Refer to specific WCSO Jail procedures for processing inmates who are known or claim to
be HIV-positive, and the medical and non-medical handling of HIV-positive inmates. Once
admitted, inmates who have observed medical or mental health needs are placed in
designated medical housing as space permits. A decision must be made to transport the
inmate for treatment or to refer the situation to medical staff for further evaluation.
Property Processing:
All inmate personal items and clothing are properly stored in accordance with WCSO Jail
Policy 5.9. Cash and personal property is taken from the prisoner upon admission,listed
on a receipt form in duplicate, and either securely stored or handled, pending the prisoner's
release. The receipt is signed by the receiving officer and the prisoner, the duplicate given
to the prisoner, and the original kept for record. If the prisoner is inebriated, there must be
at least one witness to verify this transaction. As soon as the prisoner is able to
understand what he is doing, he signs and is given the duplicate receipt. In the event an
inmate refuses to sign the property receipt, the receiving officer, with a witness present, is
Page 3 of 4
DEE000073
Jail and Detention Pdlicies and Procedures, 4.02 Jail Admission
to note the refusal and sign the receipt.

Orientation, Rules, and Regulations:
A list of inmate rules is given to all inmates, including incoming transfer cases. The inmate
signs a form acknowledging receipt of this material. Staff assists inmates who are illiterate
in understanding applicable rules and may ask the assistance of inmates with the same
language skills and English, to read or translate the rules.
Traffic in the Admission Area:
Movements through the admission section are handled and controlled using traffic patterns
to ensure that proper identification is maintained and that searched and un-searched
inmates and others do not come into contact with each other.
Clothing and Other Issue for New Inmates:
Each incoming inmate held over seventy-two [721hours must be fitted with clothing suitable
for the season and provided toiletry items. Clothing issued to new arrivals consists of the
established quantities of the following items:
1.
2.
3.
4.
5.
6.
Footwear;
Pants;
Shirts;
Blanket and sheets;
Soap; &
Toothbrush and paste.
---,
Housing Assignment:
Following processing, each inmate is assigned to a housing area in accordance with the
classification system. Prior to housing assignment, inmates are showered, issued required
items, and dressed in the appropriate uniform. A corrections officer of the same gender
...-supervises inmate showers.
Inmates suspected of having a reportable communicable disease are to be isolated. In the
event that WCSO Jail is not equipped to safely and effectively segregate and maintain a
medically prescribed course of treatment for the inmate, he is to be immediately transferred
to another facility.

DEF000074
Page 4 of 4

Jail and Detention
Operational Plans
Subject: Classification Plan
Policy Number: 4.03
Issue Date:
Revision Date:
Approval Authority
POLICY:
WCSO Jail classifies inmates confined in its facility, given the physical constraints of the
existing jail structure, in a way that furthers public safety, while providing reasonably safe
and humane housing for like inmates.
It is in the best interest of inmate and staff safety to provide reasonable and necessary
security and safe housing for the inmate population and this objective is aided by a defined
classification process.
DEFINITION:
Inmate Classification - is a means of identifying and categorizing various inmate traits,
characteristics, and potential risk factors. Criteria shall not include race, ethnicity, or
religious preference. This classification plan has as its goal, the objective
categorization of all inmates in the system. This plan outlines those goals and provides
a method of monitoring progress.
PROCEDURES:
Initial Custody Assessment/Custody Reassessment/Review
The WCSO Jail classification system initially assigns inmates based on a preliminary
assessment of their security needs on all newly admitted inmates prior to housing
assignments to determine custody levels, This system operates under the supervision of
the Jail Administrator or designee. Inmates who display special needs during the intake
booking process will be diverted to special housing when such housing space is available.
Staff provides direct supervision to inmates during classification processing. The
classification system will stratify inmate population according to predetermined
classification standards.
subject to this restriction Is.contained throughout this publication.
DEF000076
Page 1 of 4
Jail and Detention Operational Plans 4.03 Classification of inmates

Once classified, each inmate is assigned a housing area, which the inmate will be advised
is his/her responsibility to clean and maintain. A custody reassessment will be conducted
on an established day between thirty [30] to ninety [90] days of Initial Custody Assessment
as assigned by the Jail Administrator and immediately upon any disciplinary and/or change
in legal status which would affect classification. A documented classification review to
determine the necessity for a complete reassessment shall be conducted every 30-90 days
thereafter. The Jail Admistrator will oversee permanent assignments.
Housing Classification:
WCSO Jail shall maintain a housing scheme of minimum, medium and maximum
cells and housing areas appropriate for the shifting inmate population. Custody level
assignments shall not exceed the construction security level.
Initial Intake Screening Classification:
Intake screening classification will entail primary security level assignment to maximum,
medium, or minimum housing by utilizing the classification tree found attached to this
policy. This process is performed in the receiving area according to WCSO Jail admission
procedures. A designated staff member in the admissions area will perform the initial
intake classification immediately after physical intake processing is complete for purposes
of identifying any medical, mental health or other special needs that require placing
inmates in special housing units. Inmates shall be classified and housed in the least
restrictive housing available without jeopardizing staff, inmates, or the public, utilizing risk
factors which include any or all of the following:
1.
2.
3.
4.
5.
6.
Current offense or conviction

Offense history
Escape history
Institutional disciplinary history
Prior convictions
Stability factors
Custody levels and special housing needs shall be assessed to include minimum, medium,
and maximum custody levels and the placement of inmates to and from special units
including protective custody, administrative separation, disciplinary separation, and mental
and medical health housing, including known pregn'ant females.
Special Conditions: May temporarily or permanently override a classification assessment.
a. All Medical C.onditions inmates with confirmed or potential illnesses,
suicide risks, mental defects, handicaps, alcohol or drug related conditions,
temporarily or permanent, will be placed in separate housing and observed
accordingly until an official or medical professional has deemed them well
enough or capable of returning to their regular housing unit. Individuals
assigned to a detoxification cell, or ether cell utilized for this purpose, will
Page 2 of 4
DEF000077
Jail and Detention Operational Plans 4.03 Classification of Inmates

be transferred to housing or holding area as soon as they can properly care
for themselves.
b.
Violent Inmates Inmates who are violently acting out will be confined to a
cell utilized for this purpose. The status of such persons will be reassessed
and documented at least every twenty-four [24] hours for continuance of
status.
c. Protected Custody - inmates identified by committing officers as being
verified protection cases or who provide staff with information that leads to
a reasonable belief they will be endangered, if placed in general population
will be placed in separate housing, ordinarily referred to as Administrative
Separation [See policy on Administrative Separation]. The status of
inmates in Administrative Separation will be reviewed and documented at
least every thirty [30] days for continuance of status. These inmates will
retain access to services and activities unless such access would adversely
affect the safety and security of the facility. Inmates in Administrative
Separation will be provided access to a dayroom for at least one hour each
day.
d. Juveniles - Juveniles will be separated by sight and sound from adults in
accordance with Family Code, Section 51.12
e. Female Inmates Female inmates will be separated by sight and sound
from male inmates. However, males and females may simultaneously
participate in work program activities when under direct, visual and proximate
supervision.
f. Opposite Gender Cases - if on intake an inmate is found to be of the
opposite gender of the population of the facility, he/she will be housed
separately at all times, including when confined in holding cells in the
receiving area. In situations where an inmate has partially completed a
gender change procedure, the situation will be reviewed by the Jail
Administrator, the inmate will be placed in administrative separation pending
completion of the review. Genital status will normally determine the gender
by which Institution staff will classify such an individual.
g. Inmates in single cells for disciplinary separation shall be provided a shower
every other day.
If an officer overrides the determination guided by the classification tree, the

reason for overriding will be written in the space provided on the form.
subject to this restriction Is contained throughout this publication,
DEFG00078
Page 3 of 4
Jail and Detention Operational Plans 4.03 Classification of inmates

Inmates classified at the Minimum and Medium custody levels may be housed together.
Likewise, Medium and Maximum custody inmates may be housed together. However,
Minimum and Maximum custody levellnmates will be housed separately.
When under direct visual supervision, inmates of different custody levels may
simultaneously participate in work and program activities, at the discretion of the Jail
Administrator.
Records;
The classification determinations made will be recorded on the upper portion of the
classification tree under ClassifiCation Notice and kept in the inmate's file, with a dated
notation as to the assignmeht made. Inmate files will be maintained with appropriate
security safeguards consistent with WCSO Jail policy and practices. Other records of
inmate classification, all Initial and subsequent housing assignments, work and program
assignments; reassignments and assignment appeals, etc., will become part of the inmate
file.
Appeals:
An inmate may appeal a classification assessment, housing, work and program
assignment, and/or a reassessment using the grievance procedure. The Jail Adminstrator
will make the final determination of an inmate's classification.
Training:
All staff whose duties include classification will undergo at least four [41 hours of training
regarding the principles, policies, procedures, and instruments utilized for classification
assessments, housing assignments, reassessments and inmate needs.
Audit:
Audit records of the annual, internal audit shall be maintained for Commission review. The
audit will assess the following features of the objective classification system:
1.
2.
3.
4.
Inmates are classified Prior to placement in inmate housing;

Inmates are housed according to their assigned custody levels;
The override rate is acceptable; &
Classification instruments are completed in an accurate and timely manner.

Page 4 of 4
DEF000079

Jail and Detention
Subject: Management of Security
Program
Policy Number: 5.01
Issue Date:
Revision Date:
Approval Authority
POLICY:
WCSO Jail maintains a secure institutional environment that ensures the safety of the
public, provides a safe working climate for employees, and offers humane and safe living
conditions for inmates.
It is in the penological interest WCSO Jail to provide reasonable and necessary security
and safety standards, control, supervision, and oversight of inmates while confined to this
facility.
PROCEDURE:
The Jail Administrator is responsible for the security, and integrity of all detention
operations of the facility. The only persons that can override a decision of the Jail
Administrator is the Sheriff.
To accomplish the management objectives of WCSO Jaii, the Jail Administrator employs
an organized system of inter-related sub-objectives, policies, procedures, emergency
plans, training, and manpower practices. To assist in carrying out the security and
management plan, the Jail Administrator may from time-to-time appoint individuals to assist
in accomplishing various tasks.
A key element of the management philosophy requires that no inmate or group of inmates
have authority over other inmates, manage institutional programs, or have any policy or
procedure setting role.
Documentation:
The Jail Administrator develops a security and staff management plan that includes:
1. Security-related policies and procedures;
This data is proprietary and wilt not be duplicated, disclosed, or'iacussed, without the written permission of this agency. Data
DEF0000 38
Page 1 oft
Jail and Detention Policies and Procedures, 5.01 Management of the Security Program
2. Management and conservation of human and material resources; &
3. Supervision, testing, drill, and evaluation plans.
Staff Visibility:
No less than one [1] corrections/detention officer per forty-eight [48] inmates or increment
thereof on each floor for direct inmate supervision. This officer provides visual, face-toface observation of inmates at least once every hour. Observation is performed at least
every thirty [30] minutes in areas where inmates known to be assaultive, potentially'
suicidal, mentally ill, or who have demonstrated bizarre behavior. There must be two-way
voice communication capability between inmates and staff at all times.

DEF000089
Page 2 of 2

Jail and Detention
Operational Plans
Subject: Sanitation Plan
Policy Number: 9.02
Issue Date:
Revision Date:
Approval Authority
POLICY:
WCSO Jail provides staff and inmates with a clean, sanitary living environment consistent
with applicable codes, standards, and sound detention practice.
Sanitation is an important element of maintaining a healthy housing and work environment.

PROCEDURE:
The Jail Administrator or designee is responsible for developing, implementing, and

overseeing procedures that ensure the facility sanitation plan is carried out. Ensuring high
standards of housekeeping and sanitary practices is, however, the responsibility of each
shift supervisor and all staff while supervising inmates.
Housekeeping Plan:
A written housekeeping plan is available for each area of the institution to include the
following:
1, Cleaning schedule for the area;
2, Specific jobs for inmates and staff assigned to sanitary duties;
3, Time schedule for duty completion; &
4. Specific instructions for the cleaning and/or maintenance of cells, day rooms and
other common areas, floors and doors, storage areas, other departments and
program areas, walls and windows, toilet and shower facilities, and equipment.
RESTRICTED.I.AW ENFORCEMENT DATA

Page 1 of 3
UthIJUU 14LS-
Jail and Detention Operational Plans, 9.02 Sanitation Plan
Inspection Program:
There are daily inspections of sanitation levels in all areas of the facility. Records of those
inspections will be filed with the Jail Administrator. Inmate personal property limits are
enforced during inspections. No curtains, screen, paper, cellophane, cardboard, or other
screening material, will be hung in the cell or on cell doors, windows, or bars, because of
the fire hazard and supervision obstacles that such materials present.
The officer notifies Inmates of unsatisfactory cell conditions by immediately recalling them
from work or programs; in cases of repeat noncompliance staff will issue an incident report
and recommend disciplinary action.
Monthly inspections of the sanitation program and equipment are conducted by the Jail
Administrator or designee. To assure compliance with all applicable local laws and
regulations, annual inspections by a sanitation specialists are conducted to determine
facility needs, and documents progress on correcting deficiencies when reasonably
practical.
Food preparation areas are inspected at least annually by health authorities. Water and
sewage systems are approved by local and state health departments, as required by
regulations, and concentrated efforts are made to operate in compliance with applicable
regulations. Under no circumstances will an inmate produce or maintain records of these
inspections. Note: state and local laws or regulations take precedence on frequency of
inspections.
Maintenance Issues:
WCSO Jail will have an established system for reporting, responding to, and accounting for
materials and labor relating to facility repairs. Maintenance of toilets, washbasins, sinks,
and other equipment in the facility may be incorporated into the inmate work programs.
Unit Sanitation:
Each day the following items will be issued from unit storage areas by facility staff for
inmate use:
1. Mops, buckets, and brooms;
2. Plastic container with commercial cleaner for use in cleaning toilets, showers and
cells; &
Scrub
brushes and cleaning rags.
3.
Cleaning equipment shall be adequate and safe. The inmate is responsible for the proper
use and care of these articles. A well ventilated place will be provided for storing and
drying mops and other cleaning equipment.

Page 2 of 3
DEF000149
Jail and Detention Operational Plans, 9.02 Sanitation Plan
Inmate Sanitation Responsibilities:

Each inmate is required to maintain sanitary Hying area conditions and is responsible for
the cleanliness of their cell or living area, including walls, floors, sink, toilet, windows, and
other property within the cell, room, or living area. Excessive storage of food in cells and
dayrooms is prohibited. Before departing the living area each day, inmates will.sweep and
mop the floor of their personal living area and deposit trash in the appropriate trash
container.
Isolation Cell Sanitation:
Isolation cells will be cleaned daily and as inmates are transferred or released. This
cleaning includes cleaning the bed and toilet areas and mopping the floor. An assigned
inmate under staff supervision will do cleaning of isolation cells. When a cell has been
vacated, if not clean, the assigned inmate will clean the room after staff has searched it.
Common Area Sanitation:
The Jail Administrator identifies inmates who will be responsible for cleaning corridors and
other common areas of the facility. Waxing of corridors and unit floors will be done as
needed during the week. Floors will be kept clean, dry, and free of hazardous substances.
The shift supervisor will inspect common areas for compliance with all sanitation
standards.
Kitchen Area Sanitation:
Clean washing aids, such as brushes, dishcloths, and other hand aids will be provided for
use in dishwashing operations and for no other purpose.
All counters, shelves, tables, equipment, and utensils with which food or drink comes into
contact will be maintained in a clean condition and in good repair.
Water tight garbage containers with tight fitting lids will be provided in the kitchen.

Page 3 of 3
BCH:30E3450

Jail and Detention
Subject: Waste Disposal & Vermin
Control
Policy Number: 9.03
Issue Date:
Revision Date:
Approval Authority
POLICY:
WCSO Jail provides a safe, clean, pest-free environment for its staff and inmates, and
have in place procedures that ensures those conditions are maintained on a continuous
basis.
It is in the penological interest of WCSO Jail to provide reasonable healthy riving conditions
of inmates, and a safe work environment for staff.
DEFINITION:
Vermin - Applied to various species regarded as pests or nuisances, and especially
to those associated with the carrying of disease. Since the term is defined in
relation to human activities, which species are included will vary from area to area
and even person to person. The term itself derives from the Latin vermis, meaning
worm, and originally had reference to the vermiform larvae of certain insects, many
of which infest foodstuffs. Disease-carrying rodents and insects are the usual case
but the term is also applied to larger animals, on the basis that they exist out of
balance with a desired environment, consuming excessive resources. Pigeons,
which have been , widely introduced in urban environments, may be considered
vermin, or, pejoratively, flying rats. Some varieties of snake are also referred to as
vermin from time to time.
PROCEDURE:
Control of liquid, solid, and toxic waste products generated in the process of normal
operations, and of pests and vermin are life safety issues in a detention setting. Liquid,
solid, and toxic wastes from institutional operations are collected, stored, and disposed of
in a manner that protects the health and safety of inmates, staff, and visitors, while
This data Is proprietary and shall not be duplicated, disclosed, or discussed, without the written permission of this agency. Data
Page 1 of 2
DEF000151
Jail and Detention Policies and Procedures, 9.03 Waste Disposal & Vermin Control
complying with applicable regulations and statutes. Pests are controlled through a
program of regular inspection and extermination.
Garbage Disposal:
Garbage and other waste disposal services are provided. Institutional method's of handling
and dispensing of refuse must be in compliance with the requirements of all local and
federal agencies. Trash and rubbish will be deposited in containers with lids, and are
collected and removed in such a manner as to avoid creating a menace to health and as
often as is necessary to maintain good sanitary conditions.
Vermin:
The Jail Administrator manages the vermin control program. Each facility may have a
contract with a licensed pest control firm or individual who is readily available to provide
vermin and pest control services. Minor pest control action such as spraying must be
conducted on a monthly basis throughout the facility as determined necessary by the Jail
Administrator.

Page 2 of 2
DU -0001'2

Jail and Detention
Operational Plans
Subject: Health Services Plan
Issue Date:
Policy Number: 11.01

' Revision Date:
Approval Authority
POLICY:
WCSO Jail provides medical, dental, and mental health evaluation and treatment, and
housing for inmates who display or have been diagnosed as having medical problems. In
such cases, medical care will be provided on a reasonable and cost-effective basis,
consistent with the facilities that are available.
It is in the penological interest of WCSO Jail to provide reasonable and necessary inmate
medical health services while confined to this facility.
PROCEDURE:
WCSO Jail reasonably provides medical, dental, and mental health services to inmates as
circumstances dictate, and as deemed necessary by the visiting physician or medical
department, In providing these medical services, the custody and control of the inmate will
not be neglected or relaxed,
Inmates have a right to refuse medical attention. All refusals will be documented.
WCSO Jail follows the Universal Precautions as promulgated by the Centers for Disease
Control (CDC) regarding the control, distribution, storage, inventory, and disposal of
medical supplies [i.e. syringes, needles, hazardous waste containers] which support inmate
health services.
Medical services for inmates assigned to the facility may comprise the following:
Initial Intake Evaluation:
1. Any inmate brought into the facility will be medically evaluated before being
accepted into the facility.
2. Before the booking process is completed, personnel will complete a medical
screening of the detainee and complete the medical portion of the intake form.
DEF000158
Page 1 of 6
Jail and Detention Operational Plans, 11.01 Health Services Plan

3. Detainees who claim to be infected with a communicable disease will be
medically isolated from the general population, pending medical evaluation and
review.
4. Reasonable efforts will be made to acquire professional assistance in
processing detainees with special disabilities. If qualified professionals are
available, they will be summoned to assist in the admissions process.
servation and evaluation of the physical and mental condition of detainees
will continue through each phase of intake, including searches, and/or showers.
Medical alert tags worn by the detainee will be noted on the medical and bookin sheets. The inmate is allowed to wear the medical alert tag.
Sick Call:
inmates identified as requiring examination or treatment by a physician will be scheduled
for the next sick call. Sick call will be conducted on a schedule as determined by the Jail
Administrator. All examinations, treatments and other procedures shall be performed in a
reasonable and dignified manner and place.
Emergency Health Care and First Aid:
The facility maintains at least one fully stocked first aid kit and patient evacuation
equipment at the facility that is accessible to officers. At least one officer per shift will be
trained in emergency first aid by an appropriate authority and be able to demonstrate
proficiency in the rendering first aid to inmates and fellow officers in the event of a medical
emergency. With the advent of a medical emergency, the responding officer that is first aid
proficient will:
1. Assist the injured person(s), and instruct other officers to call for professional
medical assistance, as needed;
2. Isolate or remove the injured party to a secure and safe area, if the injuries allow
movement;
3. Provide basic first aid to the injured party such as stop the bleeding, protect the
wound, and treat for shock;
4. Make the injured party as comfortable as possible until other medical help
arrives;
5. Provide security for the injured party until help arrives.
Medication:
All medications will be confiscated from the inmate during admission and kept in a secure
location in the facility to ensure:
1. All medications are reviewed by the WCSO Jail physician or medical services
provider;
2. Prescription medications are issued only by a physician's instruction;
3. An established receipt system for issuance of medication to the inmate; &
Page 2 of 13
oFFnpni

4. A responsible officer distributes the medication to the inmates, and ensures the
inmate takes it, as directed.
Distribution of Prescription Medication and Over-the-counter meds:
All inmates who are prescribed medication from the jail physician or outside medical
authority will be issued that medication in direct accordance with that prescription.
Security of Narcotics, Prescription Drugs and Over-the-counter meds:
All narcotics & prescription drugs are kept in a secure, locked room with only the jail facility
nurse and jail administrator having access to this area. The prescription drug storage area
is inventoried weekly.
Disposal of old prescriptions, over-the-counter meds, syringes, needles & hazardous
wastes:
When needed, a private vendor removes all old prescriptions, syringes, needles and
hazardous wastes from the facility.
Dental Services:
WCSO Jail provides inmates with reasonable dental services as outlined in Dental
Services. Emergency treatment of inmates is referred to competent medical resources,
when appropriate.
Chronic and Convalescent Care:
WCSO Jail refers chronic and convalescent care inmates to competent medical resources
for appropriate treatment based on the needs of the inmate.
Pregnant Females;
The following procedures have been implemented in the Waller County Jail to insure the
best care possible in a jail setting for known pregnant females.
Medical:
All female inmates shall be screened for pregnancy upon arrival. The jail physician will
screen all pregnant females within 72 hours of when she is admitted to the jail.
Prenatal care and checkups will be conducted as directed by the doctor. Pregnant inmates
will also have access to regular sick call by submitting a written request.
Mental:
If a pregnant female inmate exhibits signs of mental illness/mental retardation, the
MHMR/Texas Crisis Hotline will be notified immediately. A mental health screener from
Texana will respond to the jail to evaluate the inmate and take any further action as
required based on the screening process.
Page 3 of 6
DEF000160
(40
A magistrate will be notified by written or electronic notice within (72) hours after receiving
credible information that may establish reasonable cause to believe that an inmate has a
mental illness, or is a person with mental retardation.
If the female is already on the Texana/MHMR patient roster, she will be transported to
Texana/Brookshire clinic for mental health appointments and treatment by their
psychological professionals as needed or required.
Nutritional Requirements:
Physician or licensed dietician prescribed diet plan shall be provided.
Special Housing:
The Waller County Jail has (2) dormitories designated for female inmates. Each dorm has
(7) beds. If the pregnant female condition warranted a single cell then she could be placed
in one of the several single person cells.
Work Assignment:
(110
The Waller County Jail only has four. (4) job assignments and that is the position of trusty.
Pregnant females who are chosen for the trusty position will be assigned to a position
involving light physical activities only, with limited or no contact with harsh chemicals
(bleach, ammonia, etc)
Any pregnant female inmate assigned to a trusty position, upon her request to cease
performance of these duties, shall immediately be returned to her cell and relieved of duty.

This data Is proprietary and Will not be duplicated, disclosed, or discussed, without the written permission of this agency. Data
Page 4 of 6
DEF0001 61

SICK CALL PROCEDURE:
Sick Call - is an organized method of treating inmate health problems through a
regularly scheduled open house. Sick call provides inmates with the opportunity to
report a medical illness or other health problem and to receive diagnosis or treatment to
alleviate the condition, if reasonably possible.
Scheduling:
Inmate medical complaints are solicited daily through a request slip or form system, acted
on by staff personnel, and followed by appropriate triage, and treatment by qualified
personnel.
Sick call is scheduled on a regular basis and the schedule may change from time to time to
meet the penological interests of the facility. Inmates will be advised of the date and times
for sick call. A physician, physician's assistant, nurse practioner, or nurse will be
accessible to general population inmates and conduct sick call on an established schedule.
The person conducting the sick call will, if reasonably possible:
1.
2.
3.
4.
Examine the inmate to the extent required to ascertain the nature of the problem;
Provide appropriate treatment;
Schedule the inmate for further examination or treatment;
Refer the inmate for transfer to the facility clinic or appropriate hospital when
necessary; &
5. Arrange for immediate transfer to appropriate facility, clinic, or hospital in medical
emergencies.
Process:
A member of the facility staff may assist the sick call officer with inmate control and
scheduling. The staff member conducting the sick call or the assisting officer maintains
sick call records.
Review of Sick Call:
A physician reviews sick call requests and records on a regular basis. Reviews may
include:
1. An examination of records;
2, Referrals made by the sick call personnel;
3. Discussion with the staff member who conducted sick call; &
4. Actual examination of the inmate, if necessary.

subject to this. restriction is contained throughout this publication.
DEF000162
Page 5 of 6
DENTAL SERVICES:
WCSO Jail facility encourages inmates to exercise good dental hygiene by providing
toothbrushes and tooth paste, as well as access to emergency and essential dental
services while they are incarcerated.
PROCEDURE:
Initial Screening on Admittance to Facility:
During the health assessment, admission staff observes the inmate's teeth and gums to
identify any gross abnormalities requiring referral to a trained medical diagnostician or
dentist. If the reviewing medical professional determines that dental treatment is
indicated, the medical physician will write an order for the dental referral and the staff will
schedule appointment.
Daily Maintenance of Teeth & Gums:
Inmates are encouraged to exercise good dental hygiene while they are incarcerated in this
facility. As a part of this support, the facility provides toothbrushes and tooth paste to
inmates who do not otherwise have access to these healthcare items.
Security and medical staff encourage inmates to brush their teeth and rinse their mouths
after eating, before bed, and after awakening in the morning.
Request for Medical Services:

A medical doctor oversees the dental programs of the WCSO Jail as a part of regular
medical services. Inmates may request attendance at sick cal/ by completing the required
request form. Additionally, officers and other staff members may recommend that an
inmate attend sick call when conditions indicate the need for medical attention.
Dental services include extractions, temporary fillings, necessary reconstructive and dental
appliance repair work, and x-rays. Dental counseling is available to inmates upon request.
Dental care is provided under the direction of a licensed D.D.S. or D.M.D., and referrals
may be made to a qualified outside dental specialists by the licensed D.D.S. or D.M.D.
when indicated.
A fee may be charged to inmates for dental services and work.
RESTRICTED LAW ElliFORCEMENT DATA

Page 6 of 6
DEF000163

Jail and Detention
Operational Plan
Subject: Mental Disabilities & Suicide
Prevention Plan
Issue Date:
Revision Date:
Approval Authority
Lg
POLICY:
It is the policy of the WCSO Jail to provide the appropriate care for any inmates who have
mental problems or who may be suicidal, both internally and through other available local
gencies
TRAINING:
All jail staff will receive two (2) hours of training yearly by local mental health authority
TEXANA. This training will include recognition, supervision, documentation and handling
of inmates who are mentally disabled and/or potentially suicidal.
IDENTIFICATION:
All inmates will be screened during the booking process, utilizing the approved suicide and
medical and mental impairments screening form to identify inmates who are known to be or
observed to be mentally disabled and/or potentially suicidal.
If during the booking process or anytime thereafter, an inmate makes an outcry that they
want to cause physical harm or death to themselves or the inmate appears to be mentally
disabled, the jailer is to contact the MHMR/TEXANA Crisis Hotline so that a mental health
screener can respond to the jail to evaluate the inmate.
Not later than 72 hours after receiving credible information that may establish reasonable
cause to believe that a defendant committed to the Sheriffs custody has a mental illness or
is a person with mental retardation, the Sheriff shall provide written or electronic notice of
the information to the magistrate.

DEF000164
Page 1 of 4
Jail and Detention Operational Plan, 11.02 Mental Disabilities & Suicide Prevention
Plan
HOUSING & SUPERVISION:
A potentially suicidal inmate will be placed on suicide watch in a single man cell with no
personal property or bed linens. The inmate will be provided a paper gown to wear. The
inmate will be checked according to the following criteria until arrival of the
MHMR/TEXANA screener and these checks shall be documented.
Every five (5) minutes (or continuous watch)
High Risk:
Medium Risk: Every fifteen (15) minutes
Every thirty (30) minutes
Low Risk:
It will be the determination of the MHMR/TEXANA screener as to whether the inmate will
remain on suicide watch.
Passive inmates with mental disabilities will be housed in a single cell to insure their
protection.
COMMUNICATION:
Each shift shall advise the oncoming shift, verbally and in writing of any inmates requiring
special attention and /or any incidents involving mentally disabled and/or potentially suicidal
inmates.
RESPONSE TO VIOLENT INMATES:
If an inmate with mental disabilities becomes violent, the observing jailer will notify the shift
supervisor of the situation and request assistance/back up. The jailer will follow the below
listed guidelines:
Do not enter a living area or single cell without proper assistance/backup.
Remove other non-involved inmates from the area.
Remain in the area to observe inmate actions
The shift supervisor shall notify the dispatch and request further assistance if needed.
The Jail Administrator and Assistant Chief Jailer shall also be notified along with
MHMR/TEXANA mental health officials.
The shift supervisor will determine the need to place the inmate in a more secure area/cell,
the removal of clothing and forthe use of restraints for the protection and safety of staff,
inmate population and the involved inmate.
RESPONSE TO SUICIDE OR SUICIDE ATTEMPT IN PROGRESS:
Page 2 of 4
DEF000165
Plan
The jailer will remain calm and notify the shift supervisor immediately of the situation and
request backup and medical assistance.
Do not enter the area until arrival of necessary personnel.
If possible, remove other non-involved inmates from the area
Upon arrival of assistance the jailer staff must take any action dictated by the situation to
include talking to the inmate, cutting down the inmate if hanging, render first aid and any
other action that may be deemed appropriate.
If it is determined that a suicide has taken place, note the time of discovery, notification of
supervisor and investigators.
The jailer will remain on the scene and secure the immediate area until relieved by the
investigators or anyone with high authority.
NOTIFICATION:
Once a suicide is discovered the following personnel need to be contacted:
Shift supervisor
Dispatch
EMS
Sheriff
Chief Deputy
Jail Administrator
Assistant Chief Jailer
Texas Rangers
Justice of the Peace
REPORTING:
The Sheriff or his designee shall insure that a Custodial Death report is filed with the
Attorney General's Office within thirty (30) days.
The Texas Commission on Jail Standards shall be notified of all deaths of inmates while in
the custody of the Sheriff within twenty-four (24) hours of the death. Upon conclusion of a
complete investigation, a copy of the report shall be forwarded to the Commission within
ten (10) days.
The Sheriff or his designee will notify the inmate's family and respond to media inquiries.
All involved personnel shall file required reports.
This data is proprietary and shall not be duplicated, disclosed, or discussed, without the written permission of this agency, Data
DEF000166
Page 3 of 4
Plan
FOLLOW UP:
The Chief Deputy will conduct an investigation of all completed suicides.
The Sheriff or his designee shall review all polices to determine the need for revisions,
following any attempted or completed suicide.
Counseling will be provided to anyone involved in the incident if requested.

Page 4 of 4
DEF000167

Jail and Detention
Operational Plans
Subject: Telephone Plan
Issue Date:
Revision Date:
Approval Authority
POLICY:
WCSO Jail provides privileged, monitored, and limited telephone access to elegible
inmates under humane conditions while maintaining the security integrity of the facility.
It is in the penological interest of this facility to provide monitored, limited telephone usage
to inmates in a manner that is consistent with reasonable and necessary security and
safety standards, operational controls, and supervision of inmates.
Procedure:
Inmate access and use of telephones is limited to those inmates that are compliant with
facility rules and procedures, and do not pose a risk to self, other inmates, or officers.
Telephone communications may be monitored and recorded without notice. During the
booking and intake process inmates are provided the opportunity to make two [2]
telephone calls within four [41 hours of arrival. For the purpose of these two calls, nocharge local telephone service is available for inmates, who are otherwise unable to
complete the two (2) required calls.
Incoming emergency calls to inmates are allowed, once it has been determined that a true
emergency exists. In an emergency, inmates are provided with a message or allowed to
make a free local return call or long distance call at their own expense.
Other limitations of access, such as the hours of telephone access, are posted. Other than
during the intake process, all telephone usage is at the expense of the inmate, or the
recipient of the call. Telephone privileges may be revoked as a result of a disciplinary
action or abuse telephone privileges.

Page 1 of 2
Jail and Detention Operational Plans, 12.05 Telephone Plan
Occasions may arise when privileged or non-recorded telephone communications are

requested from an attorney to an inmate. Such communications may be allowed between
an inmate and their legal counsel under the following conditions:
1. At no cost to the facility;
2. The inmate must have telephone privileges;
3. The requesting attorney makes the request in writing, specifying:
a. exact date and time;
b. requested duration of the call;
c. legal case name;
d. state bar numbers and names of the attorneys participating in the call;
e. confirmation that no other persons will participate in the discussions, or
monitor the calf;
f. that the conversation will not be recorded; &
g. confirmation that the call is being made and paid for by the requesting
attorney.
Decision to allow a privileged telephone call is at the sole discretion of WCSO Jail, and
permission may be withheld, or limitations imposed without divulging the reasoning or
justification. However, reasonable efforts will be made to make such accommodations
if resources and security conditions allow.

Page 2 of 2
DEF00018B

Inmate Suicide & Mental Health Screening
Page 1 of 1
Inmate Suicide & Mental Health Screening

Craig Davis
Sent:
To:
Cc:
Friday, June 25, 2010 1:18 PM

Brandon Busse; Bryan Mace; Christopher Wood; Doris Glover; Danny Kowis; Dana Lewis; Else Magnus; Gary Taylor;
Hazel Smith; Justin Allen; Jerry Creamer; Jaime Madison; Juan Tejeda; Elizabeth Cooke; Linda Holland; Lanny
Thibodeaux; Mary Thibodeaux; Marianne Williams; Preston Goode; Ronald Young; Sandra Garlick; Sharon Rippley;
Scott Robinson; Sherry Stark; Terri Jones; Tara Russell
Glenn Smith
Importance; High
It is extremely important that we do everything within our power to provide care for those inmates who are
depressed or expressing thoughts of injuring/killing themselves or someone else. This goes for all
inmates, whether they have been here for a year or they are being booked into our facility.
I want MHMR/Texana to be notifed whenever an inmates displays signs of depression, suicide etc,
whether it be through words or actions or if during the booking process, the Inmates states that
they have tried to kill themselves in the last year.
I want an information report completed and sent to me explaining the situation and cause for
notifying MHMR.
Please give information as to the date/time and who was notifed at MHMR. If and when MHMR
responds then include that information. There Is no such thing as too much documentation when it
comes to this issue in ourjall. Z also want to be notified of any situation like this 24/7 by phone. If
I don't answer then please leave a message and I will call you back,
I know that the jail staff gets extremely busy sometimes but when we are faced with an Inmate like this then lets
slow down and get the situation handled and documented.
We must never forget our primary function and that Is the care, custody and control of the inmates assigned
to our facility.
Thank you for your help in this matter.
6'3t4-11
Craig T. 'Davis
Jail fidtainIstrator
Offleg
Wallgr Co antg
701 Calvit M.
tipmpistzed, Tgxas 77445
Phonic: 979-82642S2
Vox: 979-826-77S1
e-mail: e.davis@wallzreobLeom
EXHIBIT
0EF000208
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Suicide Prevention. Supplies
Page 1 of 1
Suicide Prevention Supplies
Craig Davis
Sent
Tuesday, October 26, 2010 2:24 PM
To:
Brandon Busse; Bryan Mace; Christopher Wood; Doris Glover; Danny Kowls; Dana Lewis; Else Magnus; Gary Taylor;
Hazel Smith; Justin Alien; Jerry Creamer; Jaime Madison; Juan Tele* Elizabeth Cooke; Linda Holland; Lanny
Thibodeaux; Mary Thibodeaux; Marianne Williams; Preston Goode; Ronald Young; Sandra Garlick; Sharon Rippley;
Scott Robinson; Sherry Stark; Terri Jones; Tara Russell
Importance: High
There are now paper gowns and a "suicide" blanket in the property room.
If an inmate is placed on suicide watch they are to be given a paper gown and the blanket and no other
property or linens,
I also want the inmate placed in a cell with a camera.
Thank you.
rAD
Craig T. Davis
Jell Irldminfatrator
lEgr Countg kagriffs Offfesz
Wit at.
tigmpatgeid, Tom MO
Phone. , 9T9-826-8282
rag: 979-S26-M1
e-mail: e.davlswallveotx.eom
TOI
DEF000209
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Security Checks
Page 1 of 1
Security Checks
Craig Davis
Sent;
Monday, July 25, 2011 11:16 AM
Brandon Busse; Bryan Mace; Charles Alldredge; Christopher Wood; Danny Kowis; Else Magnus; Gary Taylor; Justin
Allen; Jerry Creamer; Jaime Madison; Juan Tejeda; Linda Holland; Lanny Thibodeaux; Marc Langdon; Marianne
Williams; Ronald Young; Sharon Rippley; Scott Robinson; Sherry Stark; Terri Jones
Importance: High
To:
Effective Tuesday 07/26/2011 at 0700 hours, face-to-face security checks of the inmate population will be
conducted every (45) minutes,
Craig T. 'Davis
Jail qciciministrator
Waller Countg 8hgriffia Offiep
TM 0110 at.
tlizmpstgad, Tat115 7445

phone: 979-826-8282
VaX: 979-626-7781
e-mail: a.davis@wallreatx.eom
DEF00021 4
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Suicide Watch
Page 1 of 1
Suicide Watch
Craig Davis
Sent:
Thursday, November 03, 2011 1:05 PM
To:
Brandon Busse; Christopher Wood; Charles Alldredge; Donald Salisbury; Else Magnus; Gary Taylor; Jerry Creamer;
Juan Tejeda; Linda Holland; Lanny Thibodeaux; Marc Langdon; Preston Goode; Ricky Jester; Ronald Young; Sharon
Ripley; Scott Robinson; Sherry Stark; Terri Jones
Importance: High
Please make sure that if an inmate is placed on suicide watch then they are placed in a cell, preferably with a
camera, with a paper gown and the suicide mattress only.
Inmates are on suicide watch or they are not. There is no in between.
Thank you.
Craig T. Davis
Jail fldminIstrator
ViallgrCoantg ghgriffs (Metz
Tor cedvit at.
tompatgad, Tgas 740

Phong: 979-B26-B202
Tax: 979-8.26-7781
c.davls@wallereot:Leom
gri5q3
SiO
DEF000215
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Count Procedures
Page 1 of 1
Count Procedures
Craig Davis
Sent
Monday, November 28, 2011 5:14 PM
Brandon Busse; Christopher Wood; Charles Alldredge; Donald Salisbury; Else Magnus; Gary Taylor; Jerry Creamer;
Juan Tejeda; Linda Holland; Lanny Thibodeaux; Marc Langdon; Marianne Williams; Preston Goode; Ricky Jester;
Ronald Young; Shiron Rlppley; Scott Robinson; Sherry Stark; Terri Jones
Importance: High
To
I hope that there is not a single jailer working in the Waller County Jail that is not counting living, breathing
bodies during count time. If all you see is a bundle under a blanket, then you better find you some flesh under
that blanket before you move to the next cell, dorm, dayroom etc.
Craig Davis
Jail Administrator
701 Calvit St.
Hempstead, Texas 77445
Phone: 979-826-8282 ext. 4030
Fax: 979-826-7781
E-mail: c.davisaawallercountv.us
Please note new e-mail address
513
DEF000216
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Hourly Inmate Observations
Page 1 of 1
Hourly Inmate Observations

Craig Davis
Sent: Thursday, November 08, 2012 2:22 PM
To:
Juan Tejeda; Marc Langdon; Christopher Wood; Michael Parinello; Scott Robinson; Ricky Jester; Linda Holland
(Lholland@wallercobs,com); Jerry Creamer; Terri Jones [t.jones@wallercounty.us]; James Watson; William Murphy; Else
Magnus; Cody Parr; Glenn Cloud; Jerry Henry
Cc:
Lanny Thibodeaux; Sherry Stark
ONLY A TRUE EMERGENCY WILL KEEP THE JAIL STAFF FROM CONDUCTING HOURLY
FACE TO FACE CHECKS ON THE INMATES. IF THERE IS A TRUE EMERGENCY THEN AN
INCIDENT REPORT WILL BE COMPLETED AND A COPY ATTACHED TO THAT DAYS
HOURLY OBSERVATION LOG.
KEEP IN MIND THAT YOU CANNOT WAIT TO START A NEW CHECK AN HOUR AFTER
YOU FINISHED CHECKING YOUR LAST LIVING AREA.
Craig T. Davis
Chief Deputy
701 Calvit St
Phone: 979-826-8282 ext. 4030
Fax: 979-826-7781
E-mail: c.davis@wallercountv.us
DEF000221
Page 1 of 1
Inmate Observation Log 31/32
Inmate Observation Log 31/32

Craig Davis
Sent:
Wednesday, November 07, 2012 3:32 PM
To:
Juan Tejeda; Marc Langdon; Christopher Wood; Michael Parinello; Scott Robinson; Ricky Jester; Linda Holland
[lholland@wallercobc.com]; Jerry Creamer; Terri Jones [t,jones@wallercounty.us]; Else Magnus; James Watson;
William Murphy; Cody Parr; Glenn Cloud; Jerry Henry
Cc;
Importance: High
Reminder: Per Jail Standards, inmates in DETOX or HOLDING require (30) minute checks.
Craig T. Davis
Chief Deputy
701 Calvit St,
Phone 979-826-8282 ext. 4030
Fax: 979-826-7781
E-mail: c,davis@wallercountv,us
X29
DEE000220
Inmate Observation Log
Page 1 of 1
Inmate Observation Log

c
Craig Davis
Sent:
Wednesday, November 07, 2012 3:09 PM
To:
Juan Tejeda; Marc Langdon; Christopher Wood; Michael Parinello; Scott Robinson; Ricky Jester; Jerry Creamer; Linda
Holland [I.holland@wallercotx.com]; Terri Jones Ct.jones@waliercounty.us]; Else Magnus; James Watson; William
Murphy; Cody Parr; Glenn Cloud; Jerry Henry
Cc:
Importance: High
Please disregard my e-mail from 11/6/2012 sent at 10:56 a.m. titled "INMATE OBSERVATION LOG".
There will not be a binder for jailers to carry divided into (5) sections containing observation logs.
There is one single daily observation log sheet for each 24 hour period. The front of the page is for day shift and
the back of the page is for night shift. Day shift will start a new inmate observation log sheet every morning at
7:00 a.m.
If you have any questions, please ask,
Craig T. Davis
Chief Deputy
701 Calvit St.
Phone: 979-826-8282 ext. 4030
Fax: 979-826-7781
DEF000219
Hourly Observation Logs
Page 1 of 1

Craig Davis
Sent:
Friday, November 16, 2012 8:02 AM
To:
Juan Tejeda; Marc Langdon; Tern Jones [t.joneswallercounty.us]; Scott Robinson
Lanny Thibodeaux; Sherry Stark; Else Magnus; James Watson; William Murphy; Cody Parr; Glenn Cloud; Jerry Henry;
Ricky Jester; Jerry Creamer; Linda Holland [I,holland@wallercobc,com]; Christopher Wood; Michael Parineilo
Importance: High
Cc:
It is extremely Important that the hourly face-to-face checks (30 minutes for Holding, Detox, extremely violent &
suicidal inmates) are in compliance according to TOS Rule 275.1.
In the next few days I will send a request to the TCJS for an inspection in reference to these checks.
An inspector will then arrive unannounced to check our logs. Depending on how the logs look will determine if
our jail will be placed back in compliance,
Let take care of business and get our jail back in compliance.
I appreciate all of you very much. It takes a special person to do what you all do on a daily basis.
Craig T, Davis
Chief Deputy

701 Calvit St
Phone: 979-826-8282 ext. 4030
Fax: 979-826-7781
DEF000222
Page 1 of 1

Craig Davis
Sent:
To:
Thursday, November 29, 2012 2:50 PM
Cc;
Juan Tejeda; Glenn Cloud; Michael Parinello; Scott Robinson; Ricky Jester; Jerry Creamer; Cody Parr; Linda Holland
[1,hollandwallercobccom]; Terri Jones [t.jones@wallercounty.us]; Else Magnus; James Watson; William Murphy;
Marc Langdon; Christopher Wood; James Cablness; Jerry Henry
Importance: High
I attempted to get our jail back in compliance by submitting Hourly Observation Logs, dated 11/26 to 11/28.
Unfortunately, we are still out of compliance due to the fact that on 11/26/2012 there was over an hour on night
shift between inmate observations in every area of the jail (the checks were during the 0300-0400 time frame).
Also, there was no documented emergency or incident in the jail that I could show the Jail Commission to explain
the delay. This is very disappointing, for several reasons. I do not like our jail continuing to be out of
compliance especially when I know how hard each of you have worked to improve the hourly inmate
observations.
The Jail Commission will reveiw our records again In a week or so. You all know how extremely important these
hourly Inmate observations are. As I have stated in a previous e-mail, if there is a serious incident or
emergency that delays an hourly check then complete an Incident report and attach a copy to the Hourly
Observation Log.
Also, the night shift needs to put the date that your shift begins on the hourly observation log. It should be the
same date as the day shift was for that day.
All floor jailers on duty need to sign at the bottom and each every space to the right must have a jailers initials.
WE HAVE TO GET THIS RIGHT!
Craig T. Davis
Chief Deputy
701 Calvit St.
Phone: 979-826-8282 ext. 4030
Fax: 979-826-7781
E-mail: c.davis@wailercountv.us
DEF000223
9/15/14
MEMO
TO: ALL JAIL STAFF PERSON L

FROM: CHIEF HESTER
REF: SCREENING F RM F R SUICIDE AND MEDICAL AND MENTAL IMPAIRMENTS
It has come to my attention that the Screening Form for Suicide and Medical and Mental Impairments is
not being properly filled out. In the first section there is a place for Comments. This is where you ask .
the arresting officer if the subject has made any type of comments that we need to know about. You
need to put what the arresting officer said in this space.
The second place for comments is at the bottom of the page and it says Additional Comments. This Is
where you put your comments after you have talked to the prisoner.
You have to fill in those blanks with what the arresting officer told you and then put in the additional
comments what was said are noticed by the booking officer. That means you have to ask the arresting
officer if the
You must fill out those two places for comments on everyone that is booked into the jail. This is
required by the Texas Jail Commission so if you're doing it then start filling it out.
Also make sure that the time and date is put in at the top and who filled out the form.
READ AND INITITAL .
DEF000227
CONFIDENTIAL
Texas Commission On Law Enforcement
Personal Information
Name
TCOLE ID (P ID)
ELSA SfMAGNUS
352050
Citizen Race
Gender
No
Female
Hispanic
STATUS
Federal ID
State ID
Education Information
Hours Education
Institution
0 GED
Total Hours
Total Training Hours
Service History
Service
Appointed As
Department
Jailer
.
Jailer
Service
Start Date End Date
Service Time
WALLER CO. SHERIFF'S Jailer License

OFFICE
3/19/2008
7 years, 4 months
WALLER CO. SHERIFFS Temporary Jailer

OFFICE
License
3/18/2007
Award
3/19/2008
1 years, 0 months
Total Service Time

Service Time
Description
8 years, 4 months
Jailer
Award Information
Award
Type
Temporary Jailer License
License
Action
Action Date
Granted
3/18/2007
Expired - replaced by
permanent license
3/19/2008
Granted
3/19/2008
License
Jailer License
Academy History
Date
Institution
Course Title
Completed
2/22/2008
Brazos Co. Sheriff's Office
Basic County Jail Course
Completed
8/24/2007
EXHIBIT
Print Date:
7/23/2015
Page Nwn.b.ui.)1-u006"63
CONFIDENTIAL
Courses Completed
09/01/2013 08/31/2015
Course
No.
Co arse
3846
P.T.S.D. Related Training
\218
Course
Title
Course Date Hours
Training Mandates
Institution
12/17/2014
Bill Blackwood LEMI of Texas
Assessing for Suicide,

12/17/2014
Medical, and Mental Impairm
Bill Blackwood LEMI of Texas]
3520
What to Expedt During en

Inspection
12/16/2014
3506
Legal Issues for Jail

Personnel
12/16/2014
Bill Blackwood LEMI of Texa
1994
Learn Our TCOLE Site
8/28/2014
TCOLE Online
Objective Jail Classification
6/30/2014
TEEX Central Texas Police

Academy
519
Unit Hours
..
21
09/01/2011 - 08/31/2013
Course
No.
Course Title
Course Date
3939
Cultural Diversity
7/8/2013
Jail
9/29/2011
00
Unit Hours
Course
Hours
Institution
Training Mandates
Hempstead Police Dept.
Cultural Diversity
Intermediate)
16
09/01/2009 - 08/31/2011
Course
No.
Course Title
Course Date
3500
Jail
5/31/2011
000
Jail
9/30/2009
Course
Unit Hours
Hours
Institution
Training Mandates
12
09/01/2007 - 08/31/2009
Course Title
Course
Course Date Hours
2/22/2008
Course
No.
1007
96
Training Mandates
Cultural Diversity
Brazos Co. Sheriffs Office ]
Institution
(Intermediate)
Unit Hours
96
09/0112005 - 08/31/2007
Course
Course
No.
Course Title
Course Date
1007
8/24/2007
Hours Institution
96 Brazos Co. Sheriffs Office
Training Mandates
Cultural Diversity
(Intermediate)
Print Dare:
7/23/2015
Page Number:
DERN:10634
CONFIDENTIAL
Courses Completed
09/01/2005 - 08/31/2007
Course
Course Title
No.
3807
Course
Course Date Hours Institution
Training Mandates
Texas Department of Public

Safety LEA
TC1C/NCIC for Less than Full 5/10/2007

Access Operators
Unit Hours
104
Total Hours
249
Total Hours
Print Dato:
TotalTraining Hours From Education
249
Total Hours
249
7/23/2015
Fag' Ni5L1/P6tio5g5

\_ Waller CGONFIEYENERAILDivision
Suicide Prevention Class
Tuesday' Class
Jones, T.
12/11/2012
p2,5" 09 t()
Magnus, E. t.
12/11/2012
12/11/2012 Murphy, W.
pf 77
41 7/
12/11/2012
Watson, J
s'1:175 6
- 52}
12/11/2012
Robinson, S.
iC46-ivs-orN Ss12/11/2012
Jester, R. R.aSIVE 5a
12/11/2012
Creamer, J.
Holland, L.
12/11/2012
A66,0106
Davis, C.
12/11/2012
12/11/2012 Thibodeaux,
7A4:4/044/
12/11/2012
Rochen, S.
Thursday's Class
Tejeda, J.
12/13/2012
Parr, C.
12/13/2012
Parinello, M. 74,
12/13/2012
Cloud, G.
12/13/2012
Langdon, M.
12/13/2012
Wood, C.
12/13/2012
Henry, J.
12/13/2012
Cabiness, J
12/13/2012
Davis, C.
12/13/2012
12/13/2012 Thibodeaux, L.
Rochen, S.
12/13/2012
fLockpe
DEF000636

CLASS 07-09-10
DATE
SIGNATURE COMLEATION
TEJEDA, JUAN
7.2 416
WOOD, CHRISTOPHER
e7-1,6r1.,
ALLEN, JUSTIN
7-
KOWIS, DANNY
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PRINT NAME
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SHIFT #2
MACE, BRYAN
7-2 to
MAGNUS, ELSA
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CREAMER, JERRY
ROBINSON, Karr
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SHIFT #3
JONES, TERRI
GOODE, PRESTON
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BUSSE, BRANDON
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GARLICK, SANDRA
017 A614
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SHIFT #4
HOLLAND, LINDA
RIPPLEY, SHARON
TAYLOR, GARY
YOUNG, RONALD
/- -
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CONFIDENTIAL
TEXAS JAIL ASSOCIATION
INVOICE
Correctional Management Institute of Texas

Sam Houston State University
Huntsville, TX 77341-2296
David Drosebe, President
Brazos County
(979) 361.4846
citinsselte@cohrarov.mus
Michael Markey, he Vire President
Hendetvon County
(903) 675-9275
mstarkeyPeo.hentforsomtv.os
DATE:
Bill To:
Wailer County Sheriffs Office
Boot Simonton, 2nd Vier President ATTN: Accounts Payable
Palo Pinto County
701 Calvit St
(940) 659-3593
deputysimonton(Qyahoo,com
Hempstead, TX 77445
25th Annual Spring Conference

Austin Renaissance Hotel
Austin, Texas
May9- 13,2011.
Steve Fisher, 3rd Vice Precedent

Walker County
(936)435-2-M
stivlserOco.waikemos
DESCRIPTION
Mary Farley, Pau President

Boll County
(254)933-5783
mary,falley 9/to.bell.txos
Jail Supervisor Linda Holland (new member)
Tetuan Patterson, Secretory

ThuaCaonty
(903) 577.7200
tpattersonqtro.litus,tx.os
Rochelle Arrington, Treasurer
Keniblt County
(830)249.4989
way2boop8'yahoocorn
March 15, 2011
TOTAL,a
Conference Registration & Membership Fee:
$180.00
$540.00
150.00
150.00
Jailer Elsa Magness (new member)

Jailer Scott Robinson (new member)
Conference Registration Fee:

Asst. Chief Jailer Larry Thibodeaux
Todd Allen, Director

Torn Green County
(325) 659-6599
tusk!, allenGumgrooneounlyitgov
Klan Howell, Director
Lobbed: County
(806) 775.1423
khosvell@co.lubbook.mus
Ronny Johns, Director
Wielota County
(940)766-8294
donny Johns@ce.svieltitatzns
',own Manton, Director
Montgomery County
(936) 760-5864
Joysea.moutomBrricts.org
Joey hinnies, Director
Angelina County
(936) 676-9988
jmullinssogelinnecontynel
Carr* Windham, Dioretar
Jones County
(325) 823-3201
Jonesenjalikasbeglobal.nct
Maury Cerliu.no, Director
Et-Wei Sheriff Member
Clegg County
(503) 2364400
novey.ecrlianatace.gregg.txus
Ryan Dorian, Director
x-ortiolts Vendor Member
Crown Correctional Tel:pliant, inc.
{817) 5794970
rhatsculantearildink.net
TOTAL OWED
Todd Murphy, Director

Fat-officio Vendor Member
Correctional Healthcare Management
(214)5634224
todsieJoilcare.onnt
690.00
Please notify us of any changes to those persons attending should you have any.
If you have any questions, please call
Sharese Hurst at (936) 294-1687. Thank you,
Kenneth Johnson, Chaplain

Midland County
(432) 688-4752
sodm204t3tovnidtandts.us
Cannella Jones, Historian
Texas Association of Counties
(512)924.4183
earmellajOcounty,org
Beth floBandMtd1, Sergeant-at-Arm

TOM Green County
(325) 658.7214
Cancellations
bethhBlomgreeocountrst.gov
BW Bryan, Parliamentarian
Bull County - retired
(254)780.0208
wjbBvvrocom
Please make check payable to Texas Jail Association.

The check can be mailed to the following address:
Texas Jail Association
Sam Houston State University
Box 2296
Huntsville, Texas 77341-2296
must be made in writing and received by the Correctional Management Institute of Texas at Sam
Houston State University no later than April 22, 2011, in order for a full refund.
The Correctional Management Institute of Texas reserves the right to retain or collect fees in full for those who
fail to cancel prior to the conference or for those who fail to attend.
Shart5C MICA, rcendre Director
Correctional Management Institute orTezev

(936)29-1687
sharese@shau.edu
DEF000638
CONFIDENTIAL
OFFICE OF THE SHERIFF WALLER COUNTY

701 CALVIT STREET HEMPSTEAD, TEXAS 77445-4699
(979) 826-8282 / (281) 391-8755 / FAX (979) 826-7718
R. GLENN SMITH
JOHN KREMM ER
SHERIFF
CHIEF DEPUTY
The following Waller County Sheriff's Office Jail personnel attended at (4) hour classification training on
May 31, 2011. The training was provided by the Texas Commission on Jail Standards in Austin, Texas.
Charles Alldredge
Marc Langdon
Jerry Creamer
Elsa Magness
Lanny Thibodeaux
Brandon Busse
DEF000639
ma siCSAll-P"Aluil NVVsgxakl, 24,1,
TEXASNkM ENGINEE ":ING EXTENSION SEVICE
uognipsseD pf amgaaigo
CONFIDENTIAL
DEF000645
CONFIDENTIAL
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DEF
CONFIDENTIAL
Texas Commission On Law Enforcement
Personal Information
Name
TCOLE ID (P ID)
OSCAR PRUDENTE
425551
Citizen Race
Gender
Yes
Male
Hispanic
STATUS
State ID
Federal ID
Education Information
Hours Education
Institution
0 High School
Total Hours
Service History
Service
Service
Appointed As
Department
Peace Officer
(Full Time)
WALLER CO. SHERIFF'S Peace Officer

OFFICE
License
5/11/2015
0 years, 2 months
Jailer
WALLER CO. SHERIFF'S Jailer License

OFFICE
4/15/2014
1 years, 3 months
Jailer
(Full Time)
WALLER CO. SHERIFF'S Temporary Jailer

OFFICE
License
2/2/2014
Award
Start Date End Date Service Time
4/15/2014
0 years, 2 months
Total Service Time

Description
Service Time
Jailer
1 years, 6 months
Peace Officer
0 years, 2 months
0 years, 2 months
Total officer time
Award Information
Awa rd
Type
Temporary Jailer License
License
Jailer License
License
Peace Officer License
License
Action
Action Date
Granted
2/2/2014
Expired - replaced by
permanent license
4/15/2014
Granted
4/15/2014
Granted
5/11/2015
EXHIBIT
Print Dale:
7/23/2015
Page Nwnb.x.
utru007e0
CONFIDENTIAL
Academy History
Date
Institution
Course Title
Completed
5/6/2015
Lone Star College System District LEA
Basic Peace Officer Course (643)
Completed
4/4/2014,
Brazos Co. Sheriffs Office
Courses Completed
09/01/2013 - 08/31/2015
Course
Course
Hours Institution
No.
Course Title
Course Date
3275
Missing and Exploited

Children
7/14/2015
Less Lethal Electronic Control 6/18/2015

Device Training
1000643 Basic Peace Officer Course
5/6/2015
(643)
3344
643
Lone Star College System

District LEA
73
Lone Star College System

District LEA
Training Mandates
Children (Advance)
Children (Intermediate)
82nd Session State and

Federal Law Update
83rd Session State and
Federal Law Update
Asset Forfeiture
(Intermediate)
Crisis Intervention Training
Cultural Diversity (Mandate)
Identity Theft (Intermediate)
Racial Profiling
(Intermediate)
S.F.S.T. NHTSA 24hour
Practitioner
Special Investigative Topic
(Mandate)
State and Federal Law
Update
TCIC/NCIC for Less than Full
Access Operators
101
Addendum Basic Peace

Officer
3807
TCIC/NCIC for Less than Full 1/27/2015

Access Operators
Texas Department of Public

Safety LEA
1033
Chapter 33 Rule Overview

Exam
1/20/2015
TCOLE Online
Objective Jail Classification
6/30/2014
TEEX Central Texas Police

Academy
[1007
4/4/2014
96
Cultural Diversity
(Intermediate)
1999
Personnel Orientation by
Dept. Basic Proficiency
3/24/2014
WALLER CO. SHERIFF'S

OFFICE (Training Rosters)
Personnel Orientation
1305
TCOLE Rule Overview

Course
3/21/2014
TCOLE Online
519
Print Dale:
7/23/2015
5/6/2015
Unit Hours
840
Total Hours
840
P'gg MiNgif6b0721
CONFIDENTIAL
Total Hours
Print Date:
TotalTraining Hours From Education
840
Total Hours
840
7/23/2015
PageM5g4foo7A
CONFIDENTIAL
DEF000726
CONFIDENTIAL
DEF000727

HOUSTON DIVISION
GENEVA REED-VEAL,
deceased,
Plaintiff,
VS.
Defendants.

ORDER
The Court, after due and proper notice to all parties, considered County
Defendants Motion for Summary Judgment, and the Court, after reviewing the
motion, any responses or replies, and the evidence, finds the Motion is well
founded and that the motion should be GRANTED in all things; it is, therefore,
ORDERED, ADJUDGED, and DECREED, that all Plaintiffs federal
claims against the County Defendants are hereby dismissed with prejudice;
It is further ORDERED, ADJUDGED, and DECREED that Plaintiffs
state-law claims against County Defendants are hereby dismissed without
prejudice, for lack of subject matter jurisdiction.
SIGNED this ____ day of ____________, 2015.
____________________________________
Honorable David Hittner
United States District Court Judge

Waller County's Motion For Summary Judgment

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Waller County's Motion For Summary Judgment

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Case 4:15-cv-02232 Document 39 Filed in TXSD on 11/11/15 Page 1 of 39

IN THE UNITED STATES DISTRICT COURT

CIVIL ACTION NO. 4:15-CV-02232

COUNTY DEFENDANTS MOTION FOR SUMMARY JUDGMENT

Case 4:15-cv-02232 Document 39 Filed in TXSD on 11/11/15 Page 2 of 39

Approximately two hours and forty-five minutes later,

Defendant Elsa Magnus completed Blands booking process and performed a

Case 4:15-cv-02232 Document 39 Filed in TXSD on 11/11/15 Page 3 of 39

exhibited no signs of suicidal tendencies through the weekend. Nonetheless, she

Case 4:15-cv-02232 Document 39 Filed in TXSD on 11/11/15 Page 4 of 39

Whether Defendants Elsa Magnus and Oscar Prudente violated Blands

Whether Defendants Elsa Magnus and Oscar Prudente are entitled to

To the extent Defendants Magnus and Prudente violated Blands rights,

Whether County Defendants immunity has been waived for negligence

See Document No. 11 at 1.

Case 4:15-cv-02232 Document 39 Filed in TXSD on 11/11/15 Page 5 of 39

Thereafter, Defendant Jailer Oscar Prudente conducted an initial intake

See Exhibit A (Affidavit and Complaint for Arrest Warrant).

Case 4:15-cv-02232 Document 39 Filed in TXSD on 11/11/15 Page 6 of 39

require special treatment.7 He documented her answers as follows, which noted

Simply put, Bland did not provide any

See Exhibit D (Intake Form Completed by Encinias).

Case 4:15-cv-02232 Document 39 Filed in TXSD on 11/11/15 Page 7 of 39

See Exhibit F (Prudente Affidavit).

Case 4:15-cv-02232 Document 39 Filed in TXSD on 11/11/15 Page 8 of 39

Thereafter, Jailer Magnus asked Bland questions specifically relating to suicide,

Despite providing conflicting informationwhich is not unusual as detainees

Case 4:15-cv-02232 Document 39 Filed in TXSD on 11/11/15 Page 9 of 39

See Exhibit G (Magnus Affidavit).

Case 4:15-cv-02232 Document 39 Filed in TXSD on 11/11/15 Page 10 of 39

See Exhibit G (Magnus Affidavit).

Case 4:15-cv-02232 Document 39 Filed in TXSD on 11/11/15 Page 11 of 39

Case 4:15-cv-02232 Document 39 Filed in TXSD on 11/11/15 Page 12 of 39

Accordingly, they could not possibly have been involved in

providing any medical care, or the alleged lack of same.

While waiting for EMS to arrive, jail

EMS personnel declared Bland dead within

Procedures which provide, in relevant part:

See Exhibit M (Incident Report) at pp. 2-4.

Case 4:15-cv-02232 Document 39 Filed in TXSD on 11/11/15 Page 13 of 39

Case 4:15-cv-02232 Document 39 Filed in TXSD on 11/11/15 Page 14 of 39

- Jail Admission. At initial intake, jail personnel are required to observe

See Exhibit O (Jail Policies) at Policy 3.03.

Case 4:15-cv-02232 Document 39 Filed in TXSD on 11/11/15 Page 15 of 39

See Exhibit O (Jail Policies) at Policy 11.02, Training.

Case 4:15-cv-02232 Document 39 Filed in TXSD on 11/11/15 Page 16 of 39

Completed Basic Jail Course (96 hours)

Completed Basic Jail Course (96 hours)

See Exhibit P (Excerpts from Memo Book).

Case 4:15-cv-02232 Document 39 Filed in TXSD on 11/11/15 Page 17 of 39

Affidavit and Complaint for Arrest Warrant;

A party in a lawsuit may move a court to enter summary judgment before

Case 4:15-cv-02232 Document 39 Filed in TXSD on 11/11/15 Page 18 of 39

Case 4:15-cv-02232 Document 39 Filed in TXSD on 11/11/15 Page 19 of 39

Section 1983 Failure to Prevent Suicide Claims Against Jailers Magnus

deliberately indifferent to Blands alleged serious risk of suicide by failing to

No Subjective Awareness of Serious Risk of Suicide.

Case 4:15-cv-02232 Document 39 Filed in TXSD on 11/11/15 Page 20 of 39

County, Tex., 1:02CV182C, 2004 WL 419811, at *4 (N.D. Tex. March 8,

Case 4:15-cv-02232 Document 39 Filed in TXSD on 11/11/15 Page 21 of 39

Case 4:15-cv-02232 Document 39 Filed in TXSD on 11/11/15 Page 22 of 39

Finally, she made telephone contact with a male friend

Case 4:15-cv-02232 Document 39 Filed in TXSD on 11/11/15 Page 23 of 39