IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
CLERK.
UNITED STATES OF AMERICA
V. CRIMINAL NO.23-cr-68
SHRONDA COVINGTON,
TONYA FARLEY, Deprivation ofRights Under Color ofLaw
18U.S.C.§242
(Counts 1,2, and 3)
and
False Report
18U.S.C.§1519
YOLANDA BLACKWELL, (Count4)
False Statements
Defendants. 18 U.S.C. § 1001
(Counts 5 and 6)
SUPERSEDING INDICTMENT
August 2023 Term -at Richmond, Virginia.
THE GRAND JURY CHARGES THAT:
INTRODUCTION
At all times relevant to this Superseding Indictment:
1. Defendant SHRONDA COVINGTON served as a Lieutenant with the federal Bureau of
Prisons(BOP)at the Federal Correctional Institution at Petersburg, Virginia(FCI
Petersburg), within the Eastern District of Virginia.
2. As a Lieutenant, defendant SHRONDA COVINGTON was responsible for the custody,
control, care, and safety ofinmates at FCI Petersburg.
3. Defendant TONYA FARLEY served as a Registered Nurse with BOP at FCI Petersburg.
4. As a Registered Nurse, defendant TONYA FARLEY was responsible for providing
medical care to inmates at PCI Petersburg.
5. Defendant YOLANDA BLACKWELL served as a Senior Officer Specialist with BOP at
FCI Petersburg.
6. As a Senior Officer Specialist, defendant YOLANDA BLACKWELL was responsible
for the custody,control, care, and safety ofinmates at FCI Petersburg.
7. On or about January 9,2021,defendant SHRONDA COVINGTON was on duty at FCI
Petersburg and acting in her official capacity as a Lieutenant. During her shift, defendant
SHRONDA COVINGTON was the highest-ranking officer at FCI Petersburg.
8. On or about January 9,2021,defendant TONYA FARLEY was on duty at FCI
Petersburg and acting in her official capacity as a Registered Nurse.
9. On or about January 10,2021,defendant YOLANDA BLACKWELL was on duty at FCI
Petersburg and acting in her official capacity as a Senior Officer Specialist.
10. W.W.,an individual known to the Grand Jury, was a 47-year-old inmate at FCI
Petersburg.
COUNT ONE
(Deprivation ofRights Under Color ofLaw)
On or about January 9, 2021, at or near Petersburg, Virginia, in the Eastem District of
Virginia, the defendant, SHRONDA COVINGTON, while acting under color of law, willfully
deprived W.W. of his right to be free fi*om cruel and unusual punishment, a right secured and
protected by the Constitution and laws ofthe United States, when she was deliberately indifferent
to W.W.'s serious medical needs. Specifically,defendant COVINGTON,knowing that W.W.had
serious medical needs, willfully failed to ensure that W.W. was provided with necessary medical
care,thereby acting with deliberate indifference to a substantial risk ofserious harm to W.W. This
offense resulted in bodily injury to W.W.and resulted in W.W.'s death.
(In violation ofTitle 18, United States Code,Section 242).
COUNT TWO
(Deprivation ofRights Under Color ofLaw)
On or about January 9, 2021, at or near Petersburg, Virginia, in the Eastern District of
Virginia, the defendant, TONYA FARLEY, while acting under color of law, willfully deprived
W.W.of his right to be free from cruel and unusual punishment, a right secured and protected by
the Constitution and laws of the United States, when she was deliberately indifferent to W.W.'s
serious medical needs. Specifically, defendant FARLEY,knowing that W.W.had serious medical
needs, willfully failed to ensure that W.W. was provided with necessary medical care, thereby
acting with deliberate indifference to a substantial risk of serious harm to W.W. This offense
resulted in bodily injury to W.W.and resulted in W.W.'s death.
(In violation ofTitle 18, United States Code,Section 242).
COUNT THREE
(Deprivation ofRights Under Color ofLaw)
On or about January 10, 2021, at or near Petersburg, Virginia, in the Eastern District of
Virginia, the defendant, YOLANDA BLACKWELL, while acting under color of law, willfully
deprived W.W. of his right to be free from cruel and unusual punishment, a right secured and
protected by the Constitution and laws ofthe United States, when she was deliberately indifferent
to W.W.'s serious medical needs. Specifically, defendant BLACKWELL, knowing that W.W.
had serious medical needs, willfully failed to ensure that W.W. was provided with necessary
medical care, thereby acting with deliberate indifference to a substantial risk of serious harm to
W.W. This offense resulted in bodily injury to W.W.and resulted in W.W.*s death.
(In violation of Title 18, United States Code,Section 242).
COUNT FOUR
(False Report)
On or about January 9, 2021, at or near Petersburg, Virginia, in the Eastern District of
Virginia, the defendant,TONYA FARLEY,acting in relation to and in contemplation ofa matter
within the jurisdiction of a department and agency of the United States, knowingly falsified,
concealed,covered up,and made a false entry in a record and document with the intent to impede,
obstruct, and influence the investigation and proper administration of that matter. Specifically,
defendant FARLEY, acting in her official capacity as a Registered Nurse for the BOP, wrote a
BOP Clinical Encounter Report purporting to document her January 9,2021, medical assessment
of W.W.; in that BOP Report, defendant FARLEY (1) falsely claimed that W.W. exhibited no
signs or symptoms of"acute distress," when,as defendant FARLEY then well knew, W.W. was
exhibiting multiple signs of acute distress; (2) falsely claimed that W.W. "verbalize[d]
understanding" of his medical care, when, as defendant FARLEY then well knew, W.W. was
incoherent and did not verbalize his understanding ofhis medical care; and(3)falsely claimed that
defendant FARLEY had obtained "a telephone or verbal order"from a physician regarding W.W.,
when, as defendant FARLEY then well knew, she did not consult with a physician regarding
W.W.'s medical needs.
(In violation ofTitle 18, United States Code,Section 1519.)
4
COUNT FIVE
(False Statements)
On or about April 4,2023, at or near Richmond, Virginia,in the Eastem District of
Virginia, the defendant, TONYA FARLEY,knowingly and willfully made false, fictitious, and
fraudulent statements and representations to a Special Agent ofthe Department ofJustice(DOJ),
Office ofthe Inspector General(OIG),as to material facts in relation to a matter within the
jurisdiction ofthe DOJ,an agency ofthe United States. Specifically, defendant FARLEY:(1)
falsely claimed that on January 9,2021,she used a BOP telephone to call physician E.Y.on
E.Y.'s personal cellular telephone;(2)falsely claimed that she discussed inmate W.W.'s medical
symptoms and care with physician E.Y. on January 9,2021;(3)falsely claimed that she did not
send W.W.to the hospital on January 9,2021 because physician E.Y. did not authorize his
hospitalization and instead instructed her to call the facility*s on-call psychologist; and(4)
falsely claimed that the on-call psychologist told her that the psychologist believed W.W.was
malingering on January 9,2021. Those statements and representations by defendant FARLEY
were false, because as defendant FARLEY then well knew,on January 9,2021:(1)she did not
use a BOP telephone to call physician E.Y. on E.Y.'s personal cellular telephone;(2)she did not
discuss W.W.'s symptoms and care with physician E.Y. or with any other physician;(3)
physician E.Y. did not instruct her to call the facility's on-call psychologist rather than
hospitalize W.W.; and (4)the on-call psychologist did not tell her that the psychologist believed
that W.W. was malingering.
(In violation ofTitle 18, United States Code,Section 1001).
COUNT SIX
(False Statements)
On or about Febmaiy 21,2023,at or near Chesterfield, Virginia, in the Eastern District of
Virginia, the defendant,SHRONDA COVINGTON,knowingly and willfully made materially
false, fictitious, and fraudulent statements and representations in a matter within the jurisdiction
ofthe Department ofJustice(DOJ),Office ofthe Inspector General(OIG),an agency within the
executive branch ofthe United States. Specifically, during an interview with DOJ OIG agents,
defendant COVINGTON:(1)falsely denied that on January 9,2021,a BOP correctional officer-
told defendant COVINGTON that W.W. was eating out ofthe trashcan, had urinated on himself,
and had fallen;(2)falsely claimed that on January 9,2021,a BOP correctional officer contacted
her to report that W.W. was walking around his cell, listening to music,and doing push-ups; and
(3)falsely denied that on January 9,2021,she asked a correctional officer to falsely state in BOP
records that defendant COVINGTON had coinpleted heir rounds ofthe unit in which W.W. was
housed, when,in fact, defendant COVINGTON had not conducted rounds ofthat unit. Those
statements and representations by defendant COVINGTON were false, because as defendant
COVINGTON then well knew,on January 9,2021:(1)at least one BOP correctional officer told
defendant COVINGTON that W.W.was eating out ofthe trash can, had urinated on himself, and
had fallen;(2)no correctional officer contacted defendant COVINGTON to report that W.W.
was walking around his cell, listening to music,and doing push-ups;(3)defendant
COVINGTON did,in fact, ask a correctional officer to falsely state in BOP records that
defendant COVINGTON had completed rounds ofthe unit in which W.W. was housed.
(In violation of Title 18, United States Code,Section 1001).
A TRUE BILL:
Pursuanl to the E-Govemment Act,
the original of this page has been filod
under seal in the Clerk's OfficQ
JESSICA D.ABER KRISTEN CLARKE
UNITED STATES ATTORNEY ASSISTANT ATTORNEY GENERAL
CIVIL RIGHTS DIVISION
U.S. DEPARTMENT OF JUSTICE
•• H-Governmcn',
;n!> ^
By: By:
Thomas Gamett ithiyn E. Gilbert
Assistant United States:^ttomey Special Litigation Counsel
Matthew Tannenbaum
Trial Attorney
