U.S. Department of Justice
Civil Rights Division

Assistant Attorney General
950 Pennsylvania Avenue, NW - RFK
Washington, DC 20530

March 15, 2007

The Honorable Rick Perry
Governor of Texas
P.O. Box 12428
Austin, Texas 78711-2428
Re:

Evins Regional Juvenile Center, Edinburg, Texas

Dear Governor Perry:
I write to report the findings of the Civil Rights
Division’s investigation of conditions at the Evins Regional
Juvenile Center (“Evins”). On June 9, 2006, we notified you of
our intent to conduct an investigation of Evins pursuant to the
Civil Rights of Institutionalized Persons Act (“CRIPA”), 42
U.S.C. § 1997, and the Violent Crime Control and Law Enforcement
Act of 1994, 42 U.S.C. § 14141 (“Section 14141”). As we noted,
both CRIPA and Section 14141 give the Department of Justice
authority to seek a remedy for a pattern or practice of conduct
that violates the constitutional or federal statutory rights of
children in juvenile justice institutions.
On September 12-15, 2006, we conducted an on-site inspection
at Evins with an expert consultant in juvenile justice. We
interviewed staff, youth residents, teachers, school
administrators, and administrative staff. Before, during, and
after our visits, we reviewed an extensive number of documents,
including policies and procedures, incident reports,
investigation reports, infirmary logs, medical records,
grievances from youth residents, staff personnel files, internal
quality assurance reports, unit logs, orientation materials,
staff training materials, and school records. In keeping with
our pledge of transparency and to provide technical assistance
where appropriate regarding our investigatory findings, we
conveyed our preliminary findings to facility and Texas Youth
Commission (TYC) officials at the close of our on-site visit.
We commend the staff at Evins for their helpful and
professional conduct throughout the course of the investigation.
1


We received full cooperation with our investigation and
appreciate the State’s receptiveness to our consultant’s on-site
recommendations.
Consistent with the statutory requirements of CRIPA, we now
write to advise you of the findings of our investigation, the
facts supporting them, and the minimum remedial steps that are
necessary to address the deficiencies we have identified.
42 § U.S.C. 1997b. As described more fully below, we conclude
that certain conditions at Evins violate the constitutional
rights of the youth residents. In particular, we find that
children confined at Evins are not adequately protected from
harm.
Notwithstanding the foregoing, we are pleased to report that
many of the youths that we interviewed at Evins had favorable
things to say about specific staff members and indicated that
these individuals carried out their job responsibilities in a
professional and fair manner. In addition, our investigation
found that in many instances, Evins has taken strong disciplinary
action, including termination of employment, against employees
who use inappropriate force techniques.
I.

BACKGROUND

The State of Texas, through TYC, owns and operates the Evins
Regional Juvenile Center, located in Edinburg, Texas. Evins
houses male juveniles who have been adjudicated delinquent by the
Texas juvenile courts and committed to TYC care. Evins
originally opened in 1994 as a 48 bed unit. However, Evins
expanded to 240 beds–-its present capacity–-in 1997. Evins
houses youths who are typically between the ages of 15 and 20.
Evins houses youths in several manners. First, the original
two housing units, known as “Building 1" and “Building 2,” have
24 individual sleeping rooms that are divided into 12 room pods
with a day room (i.e., common living area) in each pod. Building
1 houses youths in Evins’ chemical dependency treatment program,
while Building 2 houses youths on psychotropic medications and
youths who are too young to be placed in the general population.
Second, the two newer housing units, known as “Building 3" and
“Building 4" are open bay dormitory styled constructions. Each
building is divided into four 24 bed pods that have no individual
rooms. Each of these buildings contains a security station in
the middle of each pod.
The Evins campus also contains an administration building,
two school buildings, a medical/social services office, a dining
2


hall, a vocational building, a security building, a staff
training building, and a maintenance shop.
II. LEGAL STANDARDS
The Eighth Amendment requires that a state provide detainees
with basic human needs, including protection from harm. Hare v.
City of Corinth, 135 F.3d 320, 324 (5th Cir. 1998) (citing Farmer
v. Brennan, 511 U.S. 825, 832 (1994)). In Morales v. Turman, the
U.S. District Court for the Eastern District of Texas made clear
that physical abuse of juveniles was intolerable under the
Constitution. 364 F. Supp. 166, 173 (E.D. Tex. 1973) See also
Bright v. Hickman, 96 F. Supp. 2d. 572, 576–77 (E.D. Tex. 2000).
Additionally, corrections officers have a duty to protect
inmates from violence at the hands of other inmates. Farmer, 511
U.S. at 833. Officials violate the Constitution when they act
“with ‘conscious or callous indifference’ to their duty to
protect [a] prisoner from others.” Hare, 135 F.3d at 327
(quoting Johnston v. Lucas, 786 F.2d 1254, 1260 (5th Cir. 1986)).
Corrections officials may be constitutionally liable when they
“have failed to control or separate prisoners who endanger the
physical safety of other prisoners and the level of violence has
become so high . . . it constitutes cruel and unusual
punishment.” Gullatte v. Potts, 654 F.2d 1007, 1012 (5th Cir.
1981) (citation omitted).
The Eighth Amendment’s prohibition against cruel and unusual
punishment forbids the unnecessary and wanton infliction of pain,
which includes the unwarranted or excessive use of restraints.
See Hope v. Pelzer, 536 U.S. 730, 737 (2002). Minimal
constitutional standards require that physical restraints only be
used when a youth is out of control and poses a serious danger to
himself or others. See also Morales, 562 F.2d at 998 n.1
(incidences of prolonged isolation and unsupervised use of
physical restraints could be adequately addressed under the
Eighth Amendment).
III.

FINDINGS

We find that Evins fails to adequately protect the youths in
its care from youth and staff violence.
A.

Youth Violence

Juveniles in institutions have a constitutional right to be
reasonably safe from harm inflicted by other juveniles.
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Facilities must maintain sufficient structure, safeguards, and
staffing to ensure reasonable safety. Our investigation revealed
an unacceptably high rate of youth violence at Evins. The
atmosphere at Evins is chaotic and dangerous. Youths frequently
fight with each other without detection or intervention by staff.
Staff members and youths we interviewed consistently reported
that staff members are unable to manage youths’ behavior due to
inadequate staffing. According to information provided by TYC,
there were 1,025 reported youth-on-youth assaults at Evins in
2005, an average of 2.8 per day. For the first six months of
2006, there were 568 reported youth-on-youth assaults, an average
of 3.1 per day. This frequency of assaults is a substantial
departure from generally accepted professional standards.
Nationally, facilities comparable to Evins typically report an
average of .241 youth on youth assaults per 100 days of
confinement which, for Evins, correlates to 1.235 assaults per
100 days of confinement.1 Thus, the rate of assaults at Evins is
approximately five times the national average.
While the number of youth-on-youth assaults at Evins is
alarming, the actual number of youth assaults is likely even
higher than what is reported. During our tour, youths
consistently reported that there are numerous incidents of youthon-youth violence about which staff are unaware. Although Evins
has installed cameras to monitor the dormitories, youths are able
to avoid being recorded by fighting in the cameras’ blind spots.
Residents reported that it is easy to arrange fights out of
staff’s line of sight during recreation by “catching the wall,”
which refers to a fight that occurs near a building but outside
the vision of either staff or the security cameras. Youths we
interviewed indicated that they plan fights in the bathrooms on
the living units, which are also outside the range of the
security cameras. In light of the high potential for undetected
and unreported youth violence, the amount of violence is likely
much higher than what the facility documents.
The following examples illustrate the serious nature of
youth-on-youth assaults:
•	

On August 25, 2006, a youth assaulted another youth who
was coming out of a meeting with his caseworker,
striking him with closed fists on his back and head.
The youths continued to strike each other with closed

1

Data comparison based upon Performance-based Standards
(PbS), a self-improvement and accountability system developed by
the Council of Juvenile Correctional Administrators.
4


fists. The initiating youth escaped from an attempted
physical restraint by a Juvenile Correctional Officer
(“JCO”) and grabbed a broom, which he started swinging
at the other youth before staff were able to restrain
him.
•	

On June 22, 2006, at least seven youths were involved
in a riot in the cafeteria. Staff attempted several
unsuccessful physical restraints and ultimately had to
deploy pepper spray to subdue two youths.

•	

On May 27, 2006, one youth attacked another youth while
they were in line to go to the cafeteria, punching him
in the face and the back of the head. While staff were
attempting to restrain the youths, one youth headbutted
the other in the face, seriously injuring his jaw.

•	

On April 16, 2006, a youth was assaulted from behind by
another youth, striking him with closed fists on his
neck, shoulders, and face.

•	

On March 17, 2006, a staff member walked into a group
room and witnessed a youth bleeding from his lip and
crying. The youth initially refused to identify his
assailant, but eventually did.

•	

On February 17, 2006, two youths were involved in a
fight in their dorm. One staff member tried to
intervene, and fell to the floor trying to execute a
physical restraint. The staff member injured himself
and was out of work for two months. In an Accident
Review Board meeting on March 31, 2006, Evins staff
assessed the situation, saying that in order to prevent
reoccurrence, “We need to have less youths on pods,
this is when we were over populated and short of
coverage.”

•	

On or about February 3, 2006, a youth requested to go
to security because he was being assaulted by other
youths. He reported that they were assaulting him
because he would not let them take his food. He
reported that another youth hit him with closed fists
near his left eye and again on his right cheek.
Security was called and the youth was taken to
security.

5


•	

On June 26, 2005, a JCO unlocked the door to a group
room and left it unsupervised. Two pairs of youths
seized this opportunity to fight after they were left
unsupervised. Although two staff were aware of this
incident, neither reported the incident, documented the
incident in any manner, or referred the youths
involved.

Many of the youths we interviewed stated that fights are a
regular part of the culture on the living units. Youths
consistently reported that they did not feel safe. One said,
“It’s not safe for me to be on this campus.” Another related,
“In a gang you’re not safe, but safer.” Our investigation
revealed that the unacceptable level of youth violence at Evins
results from the following systemic deficiencies: inadequate
staffing; inadequate programming; inadequate classification; and
a dysfunctional grievance system.
1.

I
	 nadequate Staffing

The most striking factor contributing to the frequency of
youth-on-youth violence is the absence of sufficient staff to
adequately supervise youths at Evins. Without adequate numbers
of trained staff on duty, it is not possible to respond in a safe
and timely manner when violence and other crises occur.
Moreover, without adequate numbers of qualified staff,
correctional officers do not have the time to build the
relationships with youths that are necessary to identify
potential conflicts on their unit and prevent incidents from
occurring.
The physical layout of Evins further exacerbates the current
staffing deficiencies. Most assaults at Evins take place in
Buildings 3 and 4, which are each broken into four pods each
housing 24 youths in open bay dormitory style sleeping
arrangements with the youths sleeping in bunk beds. In this open
physical environment, it is difficult for staff to adequately
supervise youths. Increasing the number of JCOs available to
supervise youth would enable staff to be aware of early signs of
trouble and to take measures to defuse problems before violence
erupts. Moreover, additional JCOs are needed at the facility to
provide shift relief. We found that Evins staff are extremely
overworked because there are not a sufficient number of staff to
cover shifts. Staff reported that they are frequently required
to work double shifts of 16 hours, often without advance warning,
leaving them tired, short-tempered and less alert. The high
level of violence that we found at this facility is not
surprising given these circumstances. One JCO said that staff
6


don’t have control of the units that they supervise and that the
staff to youth ratio was not good. Another officer said that
over the past two weeks he had worked about eight 12-hour shifts.
It is often the case at Evins that one staff member is left
to oversee the entire pod of 24 youths. Youths and staff
reported that, at times, one of the two staff in a Building may
leave the area to perform other duties. Such absences place the
youths – as well as staff – at significant risk of serious harm.
Supervision is inadequate at night, as well. One youth reported
that he has been assaulted at night by other youths on at least
four separate occasions. The facility investigator confirmed
that in each instance staff provided inadequate supervision.
We also found that there is inadequate staff to control
movements between buildings on Evins’ sizable campus. Subsequent
to our on-site tour, we were informed by TYC officials that on
October 1, 2006, after dinner, 20 of the 24 youths from one dorm
broke from their line and scattered around the campus. It
apparently took staff hours before these 20 youths, and 4 others
who left the cafeteria to join them, were brought under control.
That same evening, several other youths from another dorm took
advantage of the disorder, kicking open the exterior door from
their pod and dispersing about Evins’ grounds. It took most of
the night for staff to bring these youths under control. This
event highlights ongoing concerns at Evins regarding the ability
of staff to gather intelligence regarding security risks and to
take sufficient measures to control youths’ behavior.
The safety concerns related to inadequate staffing noted
above are exacerbated when the facility is over populated, as it
was during our tour. While we were on site, we were told the
facility’s population was 251 (its capacity is 240).
Overpopulation at Evins extends the already stressed staffing
beyond already unacceptable levels, and the logistical challenges
of supervising youths in excess of the population maximum creates
additional difficulties in properly maintaining order.
Our findings regarding the inadequate number of staff at
Evins are not likely to surprise its staff or residents. Staff
readily acknowledged to us that there are not enough of them to
safely supervise the youths in their care. Several staff members
opined candidly that Evins was inadequately staffed. One JCO
stated, “We react, not prevent.” Several staff confirmed that
they found it difficult to provide adequate supervision in the
open bay dormitory style living units. One JCO commented,
“[e]ven with two staff working the room, things can happen really
fast. You can get distracted and something bad can happen.”
7


2.

Inadequate Programming

Compounding the concerns with safe supervision of youths, we
found that Evins does not provide youths with adequate
programming or incentives to promote positive behavior. There is
a behavior modification system, but it offers no incentive to the
considerable percentage of the population that is facing long
term confinement. As such, some residents have no incentive to
conform their behavior to meet the requirements of the behavior
modification system. Due to determinate sentences, these
residents will not be able to shorten their time at the facility.
Another deficiency that both youths and staff mentioned is
the lack of incentives for youths to behave appropriately. One
JCO commented, “Kids need incentives. Kids need to be able to
earn more privileges.” A resident said, “There’s nothing to do
especially on weekends.” Another resident said he believed that
boredom contributed to fights between residents. He said, “Kids
get bored and they fight over little things. Little things just
get out of hand.”
Evins’ large day rooms and open sleeping dormitories permit
significant numbers of residents to congregate in largely
unstructured settings, increasing the potential for serious
problems to develop among the youths. Juveniles who are not
engaged in structured activities are more likely to engage in
horseplay which, if adequate staffing is not provided, has the
potential to spiral into fighting, assaults and other dangerous
activities.
3.

Inadequate Classification

The absence of an adequate classification system negatively
impacts the frequency of youth-on-youth assaults at Evins.
Generally accepted professional standards require that youths be
housed and supervised in accordance with their classification.
Reliable classification systems take into consideration such
information as a youth’s age, charged offense, history of
violence and escape, gang membership or affiliation, health and
mental health concerns, and institutional history.
By these measures, Evins does not have an adequate
classification system. Unless a youth is especially young (12
individual rooms are reserved for such youths), in a chemical
dependency program, or on psychotropic medication, housing unit
assignments are largely a function of where there is an available
bed. Staff do not separate violent and non-violent youths.
8


Youths are not classified by age or by the seriousness of their
charged offenses.
Our interviews with direct care staff, youths, and other TYC
employees confirmed that the above examples of youth violence are
representative of recurrent problems at the facilities and are
not aberrational. The recurrent nature of the incidents reflects
a lack of appropriate staffing, training, supervision, and
reporting at Evins. Significantly, incidents that come to light
appear to be appropriately investigated, and often lead to
disciplinary measures against involved staff. This is consistent
with generally accepted practices and we commend Evins for these
systems. Nevertheless, Evins fails to implement systemic
measures to ensure that similar incidents do not recur.
4.

Dysfunctional Grievance System

The dysfunctional grievance system at Evins also contributes
to the State’s failure to ensure a reasonably safe environment.
An adequately functioning grievance system ensures that youth
residents have an avenue for bringing serious allegations and
other complaints to the administration’s attention. It also
provides an important tool in evaluating the culture at the
facility, and alerting the administration about dangers and other
problems in the facility’s operations. Few of the youths we
interviewed expressed any confidence in the system. One youth
reported that he was sitting at a table writing a grievance when
a staff member came by and took it away from him. One JCO said
that responses to grievances are slow and as a result, animosity
and resentment builds among the youths.
B.

Staff-on-Youth Violence

Juveniles at Evins have a right to be free from unnecessary
restraint and the use of excessive force. We were pleased to
learn that in many instances Evins has taken appropriate
disciplinary action, including termination of employment, against
employees when an inappropriate use of force is identified.
Additionally, some youths identified specific members of the
corrections staff who they felt were fair and conscientious in
executing their duties. These are admirable attributes for a
juvenile facility. Nevertheless, our investigation revealed an
unacceptably high degree of physical abuse of youths by staff at
Evins. We also found a disturbing consistency in the youths’
accounts of the use of unnecessary physical restraint and
excessive force by many Evins’ staff. The following examples are
illustrative:

9


•	

On December 5, 2005 a resident alleged that a staff
person slammed him to the ground and hit him. The
resident was taken to the emergency room where he
received eleven stitches. While there the resident had
a mild seizure. TYC’s internal investigation resulted
in a finding of confirmed abuse and unprofessional
conduct.

•	

On December 14, 2005 a resident showed a staff person
large bruises on his chest. He said he had been
attacked by gang members. TYC’s internal investigation
revealed that three staff had allowed the beating to
continue and did not intervene on the victim's behalf.
A finding of neglect was made on the three employees.
Allegations against a fourth employee were not
confirmed.

•	

On January 12, 2006 a resident alleged that a staff
person hit him in the throat and hit his head several
times against the wall. The youth had a large bump on
his forehead and hurt his hand. The incident was
confirmed by TYC officials as abuse.

•	

On January 15, 2006 a staff member allegedly pushed a
resident, slammed him into a wall, threw him on a bunk
and on the floor. The ensuing TYC investigation did
not confirm abuse but did confirm an unnecessary use of
force.

•	

On January 26, 2006 a resident alleged that during a
restraint a staff person pushed the resident's eyes
"back into his face." The ensuing TYC investigation
confirmed abuse and noted that prohibited physical
restraint techniques had been used.

Interviews with Evins staff indicate that inadequate
staffing ratios contribute to the use of more force than
necessary in many incidents of physical restraint. Virtually
every correctional officer we interviewed expressed concern about
maintaining control of the facility. As detailed above, we have
found that this facility suffers from inadequate staffing, and
that many of the staff at Evins have not been adequately trained
nor do they have much practical experience on-the-job. When
staff feel outnumbered and stretched too thin, they are more
likely to apply extra force during a restraint to emphasize to
the youth that non-compliant behavior will not be tolerated.
These factors have a significant detrimental effect on the morale
of Evins staff. One staff person summed it up by saying, “Staff
10


are tired.
low.”

Working 12 hour shifts day after day.

Morale is

Additionally, staff communicated to us that they do not feel
appropriately trained. Many staff were critical of the training
they receive on how to deal with non-compliant and aggressive
youths. One JCO flatly stated, “Core training is a waste of
time.” Our staff interviews consistently revealed a sense of
helplessness that greatly contributes to the low morale among
those staff who have the most contact with the youths. Our
investigation revealed that Evins is well behind in on-the-job
training, partially because staff turnover is so high. One staff
member said that the lack of training and turnover among JCO
staff is the biggest problem the facility has. We note that the
training concerns our investigation revealed closely mirror those
identified by TYC as having contributed to the well-publicized
October and November 2004 riots.2 An internal monitoring review
from the Director of Juvenile Corrections, dated December 13,
2004, noted that the JCO staff did not express confidence in
their ability to perform their jobs. “Several of the JCO staff
interviewed did not express confidence in their ability to
perform the requirements of the job adequately.” Elsewhere, the
same report stated, “Several of the JCO staff interviewed did not
know what verbal judo was because of the turnover in staff and
the lack of training. They did not express confidence in their
ability to conduct huddle ups and behavior groups.”3 Our
investigation indicates that the facility still has large
deficits in its training.
Related to the deficiencies in training, we also observed
deficiencies in the way Evins staff document and review
incidents. Our review revealed that incident reports filled out

2

Small gang-related race riots reportedly occurred on
October 25, 2004 and October 28, 2004. The second riot, which
reportedly took place in the cafeteria, began after two youths
were allegedly stabbed by youths affiliated with a gang.
According to the TYC, one youth was injured by other youths,
while another youth injured himself when he broke a glass window.
3

“Huddle ups” are short individual and small group talks
that are administered when staff observe a situation that may
evolve into an incident. Huddle ups are designed to defuse a
situation before it escalates by helping youths learn how to
appropriately handle a situation. “Behavior groups” are larger
group sessions designed to assist youths properly conduct
themselves in the general population.
11


by Evins staff frequently lack important information such as
details of who was present during the incident, what happened
during the incident, and what precipitated the incident. This
occurs because, apparently, staff are reluctant to cooperate with
Evins’ investigator. In addition, at the time of our tour, Evins
employed only one investigator for the entire facility. Given
the number of residents at Evins, the high number of incidents,
and the investigator’s lack of institutional support and
authority to compel staff statements/documents in a timely
fashion, the incident review process is inadequate.
It also appears that the process for reviewing the use of
restraints is deficient. In most of the reviews we sampled, the
reviewer did not evaluate the restraint at all, but simply noted
that the incident report (IR) form was not filled out completely
and correctly. Additionally, there appears to be a significant
problem in obtaining copies of the security camera’s video for
use in the investigation process. According to the information
technology staff, camera images are only held for 5 to 11 days
before they are overwritten with new data. According to the
investigator, in about two-thirds of the cases, the video of an
incident has been deleted before he is able to secure a copy for
his investigation.
We also note that the climate of violence at Evins also
affects staff safety. Many of the staff we interviewed said they
had been assaulted by residents. On March 31, 2006 Evins’
Accident Review Board met and analyzed seven incidents that
resulted in staff injuries between January 10 and February 24,
2006, four of which resulted in those staff missing work for at
least three weeks. One of the incidents examined took place on
February 17, 2006. Two residents were involved in an argument
that escalated into an assault. A JCO attempted to intervene,
injured his knee and back, and was off work for two months.
One JCO stated that he has been assaulted by youths on
several occasions. During our on-site visit, another staff
member showed us the scars from injuries he sustained when a
youth wielding a shank stabbed him twice in the chest while the
JCO was trying to break up a riot in the cafeteria on June 5,
2006. Another staff member we interviewed told us that a youth
had punched him in the face and body, chipping one of his teeth.

12


IV.

REMEDIAL MEASURES


In order to rectify the identified deficiencies and protect
the constitutional and statutory rights of youths confined at
Evins, this facility should implement, at a minimum, the
following remedial measures:
1.	

Ensure that youths are adequately protected from physical
violence from staff and other youths;

2.	

Ensure that there is sufficient, adequately trained staff to
safely supervise the residents at all times;

3.	

Ensure that there is an adequate and appropriate behavior
modification system in place;

4.	

Provide safe and appropriate housing for youths;

5.	

Develop and implement an adequate classification system to
place youths appropriately and safely;

6.	

Develop and implement a grievance system that ensures
resident access to a functional and responsive grievance
process;

7.	

Develop and implement a use of force policy that provides
clear guidelines and appropriate limits on the use of force;

8.	

Provide adequate training and supervision to correctional
staff regarding safe and appropriate use of force and
physical restraint;

9.	

Ensure that staff adequately and promptly report incidents.
* * *

Please note that this findings letter is a public document.
It will be posted on the Civil Rights Division’s website. While
we will provide a copy of this letter to any individual or entity
upon request, as a matter of courtesy, we will not post this
letter on the Civil Rights Division’s website until ten calendar
days from the date of this letter.
We hope to continue working with the County in an amicable
and cooperative fashion to resolve our outstanding concerns
regarding Evins. Assuming there is a spirit of cooperation from
the State, TYC, and Evins, we also would be willing to send our
13


consultants’ evaluations under separate cover. These reports are
not public documents. Although the consultants’ evaluations and
work do not necessarily reflect the official conclusions of the
Department of Justice, their observations, analysis, and
recommendations provide further elaboration of the issues
discussed in this letter and offer practical technical assistance
in addressing them.
We are obligated to advise you that, in the entirely
unexpected event that we are unable to reach a resolution
regarding our concerns, the Attorney General may initiate a
lawsuit pursuant to CRIPA to correct deficiencies of the kind
identified in this letter 49 days after appropriate officials
have been notified of them. 42 U.S.C. § 1997b(a)(1). We note
that we are also authorized, pursuant to 42 U.S.C. § 14141, to
initiate a suit to address the above described conditions.
We would prefer, however, to resolve this matter by working
cooperatively with you and are confident that we will be able to
do so in this case. The lawyers assigned to this investigation
will be contacting the facility’s attorney to discuss this matter
in further detail. If you have any questions regarding this
letter, please call Shanetta Y. Cutlar, Chief of the Civil Rights
Division’s Special Litigation Section, at (202) 514-0195.
Sincerely,

/s/ Wan J. Kim
Wan J. Kim
Assistant Attorney General
cc:	 The Honorable Greg Abbott
Attorney General
State of Texas
Edward Glenn Owens

Acting Executive Director

Texas Youth Commission

Neil Nichols

General Counsel

Texas Youth Commission


14


Bart Caldwell
Superintendent
Evins Regional Juvenile Center
The Honorable Donald J. Degabrielle, Jr.
United States Attorney
Southern District of Texas

15