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Filed by Texas Appleseed and Disability Rights Texas. OPENING PARAGRAPH: Dear Mr. Rosenbaum, We are writing to inform you of recurrent, systemic problems in the Texas Juvenile Justice Department’s (TJJD) five state secure facilities that violate federal Constitutional standards as well as jeopardize the health, safety, and rehabilitation of young people. We are aware of these problems through visits to the facilities, reports from the Office of the Independent Ombudsman (OIO), open records requests to TJJD and the Office of the Inspector General (OIG), and direct communication with TJJD-involved young people and families. This complaint details the following issues: ● Inability to ensure safety of young people (ex. staff turnover, reports of safety issues, and excessive restraints); ● Abuse, including sexual victimization, within the facilities (sex abuse, inappropriate use of force, etc.); ● Inadequate mental health care; and ● Over-reliance on short-term security and lack of programming for youth in security (segregation).