Edward Tuffly v. USDHS

Filing

FILED OPINION (SIDNEY R. THOMAS, STEPHEN REINHARDT and EDWARD R. KORMAN) AFFIRMED Judge: SR Authoring, FILED AND ENTERED JUDGMENT. [10578647]

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2015-ICFO-06247.000061

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 68 of 470

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2015-ICFO-06247.000062

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 69 of 470

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2015-ICFO-06247.000063

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 70 of 470

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2015-ICFO-06247.000064

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 71 of 470

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2015-ICFO-06247.000065

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 72 of 470

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2015-ICFO-06247.000066

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 73 of 470

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2015-ICFO-06247.000067

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 74 of 470

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2015-ICFO-06247.000068

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 75 of 470

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2015-ICFO-06247.000069

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 76 of 470

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2015-ICFO-06247.000070

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 77 of 470

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2015-ICFO-06247.000071

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 78 of 470

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2015-ICFO-06247.000072

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 79 of 470

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2015-ICFO-06247.000073

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 80 of 470

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2015-ICFO-06247.000074

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 81 of 470

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2015-ICFO-06247.000075

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 82 of 470

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2015-ICFO-06247.000076

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 83 of 470

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2015-ICFO-06247.000077

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 84 of 470

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2015-ICFO-06247.000078

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 85 of 470

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2015-ICFO-06247.000079

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 86 of 470

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2015-ICFO-06247.000080

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 87 of 470

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2015-ICFO-06247.000081

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 88 of 470

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2015-ICFO-06247.000082

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 89 of 470

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2015-ICFO-06247.000083

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 90 of 470

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2015-ICFO-06247.000084

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 91 of 470

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2015-ICFO-06247.000085

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 92 of 470

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2015-ICFO-06247.000086

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 93 of 470

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2015-ICFO-06247.000087

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 94 of 470

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2015-ICFO-06247.000088

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 95 of 470

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2015-ICFO-06247.000089

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 96 of 470

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2015-ICFO-06247.000090

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 97 of 470

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2015-ICFO-06247.000091

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 98 of 470

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2015-ICFO-06247.000092

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 99 of 470

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2015-ICFO-06247.000093

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 100 of 470

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2015-ICFO-06247.000094

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 101 of 470

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2015-ICFO-06247.000095

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 102 of 470

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2015-ICFO-06247.000096

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 103 of 470

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2015-ICFO-06247.000097

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 104 of 470

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2015-ICFO-06247.000098

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 105 of 470

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2015-ICFO-06247.000099

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 106 of 470

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2015-ICFO-06247.000100

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 107 of 470

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2015-ICFO-06247.000101

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 108 of 470

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2015-ICFO-06247.000102

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 109 of 470

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2015-ICFO-06247.000103

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 110 of 470

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2015-ICFO-06247.000104

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 111 of 470

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2015-ICFO-06247.000105

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 112 of 470

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2015-ICFO-06247.000106

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 113 of 470

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2015-ICFO-06247.000107

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 114 of 470

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2015-ICFO-06247.000108

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 115 of 470

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2015-ICFO-06247.000109

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 116 of 470

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2015-ICFO-06247.000110

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 117 of 470

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2015-ICFO-06247.000111

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 118 of 470

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2015-ICFO-06247.000112

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 119 of 470

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2015-ICFO-06247.000113

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 120 of 470

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2015-ICFO-06247.000114

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 121 of 470

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2015-ICFO-06247.000115

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 122 of 470

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2015-ICFO-06247.000116

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 123 of 470

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2015-ICFO-06247.000117

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 124 of 470

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2015-ICFO-06247.000118

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 125 of 470

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2015-ICFO-06247.000119

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 126 of 470

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2015-ICFO-06247.000120

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 127 of 470

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2015-ICFO-06247.000121

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 128 of 470

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2015-ICFO-06247.000122

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 129 of 470

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2015-ICFO-06247.000123

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 130 of 470

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2015-ICFO-06247.000124

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 131 of 470

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2015-ICFO-06247.000125

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 132 of 470

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2015-ICFO-06247.000126

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 133 of 470

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2015-ICFO-06247.000127

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 134 of 470

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2015-ICFO-06247.000128

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 135 of 470

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2015-ICFO-06247.000129

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 136 of 470

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2015-ICFO-06247.000130

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 137 of 470

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2015-ICFO-06247.000131

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 138 of 470

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2015-ICFO-06247.000132

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 139 of 470

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2015-ICFO-06247.000133

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 140 of 470

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2015-ICFO-06247.000134

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 141 of 470

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2015-ICFO-06247.000135

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 142 of 470

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2015-ICFO-06247.000136

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 143 of 470

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2015-ICFO-06247.000137

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 144 of 470

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2015-ICFO-06247.000138

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 145 of 470

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2015-ICFO-06247.000139

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 146 of 470

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2015-ICFO-06247.000140

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 147 of 470

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2015-ICFO-06247.000141

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 148 of 470

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2015-ICFO-06247.000142

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 149 of 470

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2015-ICFO-06247.000143

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 150 of 470

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2015-ICFO-06247.000144

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 151 of 470

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2015-ICFO-06247.000145

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 152 of 470

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2015-ICFO-06247.000146

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 153 of 470

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2015-ICFO-06247.000147

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 154 of 470

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2015-ICFO-06247.000148

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 155 of 470

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2015-ICFO-06247.000149

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 156 of 470

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2015-ICFO-06247.000150

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 157 of 470

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2015-ICFO-06247.000151

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 158 of 470

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2015-ICFO-06247.000152

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 159 of 470

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2015-ICFO-06247.000153

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 160 of 470

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2015-ICFO-06247.000154

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 161 of 470

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2015-ICFO-06247.000155

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 162 of 470

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2015-ICFO-06247.000156

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 163 of 470

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2015-ICFO-06247.000157

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 164 of 470

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2015-ICFO-06247.000158

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 165 of 470

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2015-ICFO-06247.000159

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 166 of 470

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2015-ICFO-06247.000160

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 167 of 470

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2015-ICFO-06247.000161

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 168 of 470

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2015-ICFO-06247.000162

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 169 of 470

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2015-ICFO-06247.000163

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 170 of 470

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2015-ICFO-06247.000164

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 171 of 470

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2015-ICFO-06247.000165

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 172 of 470

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2015-ICFO-06247.000166

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 173 of 470

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2015-ICFO-06247.000167

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 174 of 470

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2015-ICFO-06247.000168

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 175 of 470

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2015-ICFO-06247.000169

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 176 of 470

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2015-ICFO-06247.000170

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 177 of 470

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2015-ICFO-06247.000171

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 178 of 470

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2015-ICFO-06247.000172

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 179 of 470

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2015-ICFO-06247.000173

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 180 of 470

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2015-ICFO-06247.000174

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 181 of 470

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2015-ICFO-06247.000175

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 182 of 470

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2015-ICFO-06247.000176

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 183 of 470

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2015-ICFO-06247.000177

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 184 of 470

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2015-ICFO-06247.000178

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 185 of 470

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2015-ICFO-06247.000179

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 186 of 470

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2015-ICFO-06247.000180

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 187 of 470

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2015-ICFO-06247.000181

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 188 of 470

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2015-ICFO-06247.000182

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 189 of 470

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2015-ICFO-06247.000183

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 190 of 470

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2015-ICFO-06247.000184

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 191 of 470

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2015-ICFO-06247.000185

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 192 of 470

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2015-ICFO-06247.000186

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 193 of 470

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2015-ICFO-06247.000187

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 194 of 470

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2015-ICFO-06247.000188

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 195 of 470

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2015-ICFO-06247.000189

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 196 of 470

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2015-ICFO-06247.000190

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 197 of 470

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2015-ICFO-06247.000191

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 198 of 470

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2015-ICFO-06247.000192

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 199 of 470

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2015-ICFO-06247.000193

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 200 of 470

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2015-ICFO-06247.000194

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 201 of 470

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2015-ICFO-06247.000195

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 202 of 470

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2015-ICFO-06247.000196

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 203 of 470

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2015-ICFO-06247.000197

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 204 of 470

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2015-ICFO-06247.000198

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 205 of 470

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2015-ICFO-06247.000199

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 206 of 470

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2015-ICFO-06247.000200

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 207 of 470

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2015-ICFO-06247.000201

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 208 of 470

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2015-ICFO-06247.000202

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 209 of 470

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2015-ICFO-06247.000203

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 210 of 470

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2015-ICFO-06247.000204

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 211 of 470

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2015-ICFO-06247.000205

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 212 of 470

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2015-ICFO-06247.000206

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 213 of 470

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2015-ICFO-06247.000207

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 214 of 470

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2015-ICFO-06247.000208

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 215 of 470

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2015-ICFO-06247.000209

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 216 of 470

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2015-ICFO-06247.000210

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 217 of 470

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2015-ICFO-06247.000211

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 218 of 470

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2015-ICFO-06247.000212

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 219 of 470

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2015-ICFO-06247.000213

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 220 of 470

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2015-ICFO-06247.000214

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 221 of 470

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2015-ICFO-06247.000215

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 222 of 470

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2015-ICFO-06247.000216

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 223 of 470

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2015-ICFO-06247.000217

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 224 of 470

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2015-ICFO-06247.000218

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 225 of 470

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2015-ICFO-06247.000219

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 226 of 470

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2015-ICFO-06247.000220

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 227 of 470

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2015-ICFO-06247.000221

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 228 of 470

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2015-ICFO-06247.000222

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 229 of 470

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2015-ICFO-06247.000223

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 230 of 470

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2015-ICFO-06247.000224

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 231 of 470

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2015-ICFO-06247.000225

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 232 of 470

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2015-ICFO-06247.000226

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 233 of 470

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2015-ICFO-06247.000227

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 234 of 470

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2015-ICFO-06247.000228

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 235 of 470

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2015-ICFO-06247.000229

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 236 of 470

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2015-ICFO-06247.000230

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 237 of 470

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2015-ICFO-06247.000231

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 238 of 470

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2015-ICFO-06247.000232

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 239 of 470

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2015-ICFO-06247.000233

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 240 of 470

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2015-ICFO-06247.000234

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 241 of 470

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2015-ICFO-06247.000235

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 242 of 470

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2015-ICFO-06247.000236

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 243 of 470

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2015-ICFO-06247.000237

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 244 of 470

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2015-ICFO-06247.000238

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 245 of 470

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2015-ICFO-06247.000239

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 246 of 470

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2015-ICFO-06247.000240

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 247 of 470

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2015-ICFO-06247.000241

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 248 of 470

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2015-ICFO-06247.000242

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 249 of 470

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2015-ICFO-06247.000243

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 250 of 470

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2015-ICFO-06247.000244

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 251 of 470

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2015-ICFO-06247.000245

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 252 of 470

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2015-ICFO-06247.000246

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 253 of 470

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2015-ICFO-06247.000247

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 254 of 470

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2015-ICFO-06247.000248

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 255 of 470

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2015-ICFO-06247.000249

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 256 of 470

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2015-ICFO-06247.000250

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 257 of 470

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2015-ICFO-06247.000251

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 258 of 470

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2015-ICFO-06247.000252

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 259 of 470

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2015-ICFO-06247.000253

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 260 of 470

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2015-ICFO-06247.000254

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 261 of 470

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2015-ICFO-06247.000255

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 262 of 470

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2015-ICFO-06247.000256

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 263 of 470

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2015-ICFO-06247.000257

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 264 of 470

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2015-ICFO-06247.000258

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 265 of 470

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2015-ICFO-06247.000259

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 266 of 470

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2015-ICFO-06247.000260

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 267 of 470

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2015-ICFO-06247.000261

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 268 of 470

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2015-ICFO-06247.000262

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2015-ICFO-06247.000263

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2015-ICFO-06247.000264

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 271 of 470

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2015-ICFO-06247.000265

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 272 of 470

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2015-ICFO-06247.000266

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 273 of 470

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2015-ICFO-06247.000267

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 274 of 470

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2015-ICFO-06247.000268

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 275 of 470

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2015-ICFO-06247.000269

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 276 of 470

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2015-ICFO-06247.000270

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 277 of 470

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2015-ICFO-06247.000271

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 278 of 470

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2015-ICFO-06247.000272

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 279 of 470

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2015-ICFO-06247.000273

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 280 of 470

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2015-ICFO-06247.000274

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 281 of 470

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2015-ICFO-06247.000275

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 282 of 470

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2015-ICFO-06247.000276

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 283 of 470

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2015-ICFO-06247.000277

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 284 of 470

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2015-ICFO-06247.000278

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 285 of 470

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2015-ICFO-06247.000279

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 286 of 470

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2015-ICFO-06247.000280

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 287 of 470

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2015-ICFO-06247.000281

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 288 of 470

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2015-ICFO-06247.000282

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 289 of 470

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2015-ICFO-06247.000283

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 290 of 470

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2015-ICFO-06247.000284

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 291 of 470

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2015-ICFO-06247.000285

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 292 of 470

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2015-ICFO-06247.000286

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 293 of 470

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2015-ICFO-06247.000287

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 294 of 470

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2015-ICFO-06247.000288

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 295 of 470

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2015-ICFO-06247.000289

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 296 of 470

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2015-ICFO-06247.000290

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 297 of 470

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2015-ICFO-06247.000291

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 298 of 470

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2015-ICFO-06247.000292

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 299 of 470

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2015-ICFO-06247.000293

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 300 of 470

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2015-ICFO-06247.000294

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 301 of 470

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2015-ICFO-06247.000295

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 302 of 470

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2015-ICFO-06247.000296

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 303 of 470

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2015-ICFO-06247.000297

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 304 of 470

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2015-ICFO-06247.000298

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 305 of 470

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2015-ICFO-06247.000299

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 306 of 470

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2015-ICFO-06247.000300

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 307 of 470

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2015-ICFO-06247.000301

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 308 of 470

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2015-ICFO-06247.000302

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 309 of 470

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2015-ICFO-06247.000303

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 310 of 470

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2015-ICFO-06247.000304

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 311 of 470

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2015-ICFO-06247.000305

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 312 of 470

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2015-ICFO-06247.000306

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 313 of 470

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2015-ICFO-06247.000307

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 314 of 470

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2015-ICFO-06247.000308

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 315 of 470

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2015-ICFO-06247.000309

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 316 of 470

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2015-ICFO-06247.000310

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 317 of 470

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2015-ICFO-06247.000311

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 318 of 470

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2015-ICFO-06247.000312

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 319 of 470

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2015-ICFO-06247.000313

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 320 of 470

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2015-ICFO-06247.000314

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 321 of 470

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2015-ICFO-06247.000315

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 322 of 470

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2015-ICFO-06247.000316

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 323 of 470

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2015-ICFO-06247.000317

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 324 of 470

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2015-ICFO-06247.000318

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 325 of 470

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2015-ICFO-06247.000319

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 326 of 470

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2015-ICFO-06247.000320

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 327 of 470

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2015-ICFO-06247.000321

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 328 of 470

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2015-ICFO-06247.000322

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 329 of 470

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2015-ICFO-06247.000323

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 330 of 470

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2015-ICFO-06247.000324

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 331 of 470

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2015-ICFO-06247.000325

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 332 of 470

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2015-ICFO-06247.000326

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 333 of 470

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2015-ICFO-06247.000327

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 334 of 470

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2015-ICFO-06247.000328

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 335 of 470

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2015-ICFO-06247.000329

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 336 of 470

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2015-ICFO-06247.000330

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 337 of 470

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2015-ICFO-06247.000331

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 338 of 470

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2015-ICFO-06247.000332

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 339 of 470

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2015-ICFO-06247.000333

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 340 of 470

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2015-ICFO-06247.000334

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 341 of 470

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2015-ICFO-06247.000335

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 342 of 470

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2015-ICFO-06247.000336

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 343 of 470

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2015-ICFO-06247.000337

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 344 of 470

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2015-ICFO-06247.000338

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 345 of 470

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2015-ICFO-06247.000339

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 346 of 470

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2015-ICFO-06247.000340

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 347 of 470

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2015-ICFO-06247.000341

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 348 of 470

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2015-ICFO-06247.000342

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 349 of 470

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2015-ICFO-06247.000343

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 350 of 470

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2015-ICFO-06247.000344

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 351 of 470

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2015-ICFO-06247.000345

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 352 of 470

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2015-ICFO-06247.000346

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 353 of 470

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2015-ICFO-06247.000347

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 354 of 470

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2015-ICFO-06247.000348

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 355 of 470

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2015-ICFO-06247.000349

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 356 of 470

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2015-ICFO-06247.000350

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 357 of 470

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2015-ICFO-06247.000351

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 358 of 470

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2015-ICFO-06247.000352

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 359 of 470

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2015-ICFO-06247.000353

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 360 of 470

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2015-ICFO-06247.000354

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 361 of 470

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2015-ICFO-06247.000355

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 362 of 470

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2015-ICFO-06247.000356

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 363 of 470

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2015-ICFO-06247.000357

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 364 of 470

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2015-ICFO-06247.000358

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 365 of 470

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2015-ICFO-06247.000359

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 366 of 470

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2015-ICFO-06247.000360

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 367 of 470

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2015-ICFO-06247.000361

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 368 of 470

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2015-ICFO-06247.000362

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 369 of 470

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2015-ICFO-06247.000363

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 370 of 470

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2015-ICFO-06247.000364

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 371 of 470

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2015-ICFO-06247.000365

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 372 of 470

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2015-ICFO-06247.000366

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 373 of 470

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2015-ICFO-06247.000367

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 374 of 470

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2015-ICFO-06247.000368

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 375 of 470

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2015-ICFO-06247.000369

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 376 of 470

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2015-ICFO-06247.000370

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 377 of 470

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2015-ICFO-06247.000371

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 378 of 470

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2015-ICFO-06247.000372

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 379 of 470

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2015-ICFO-06247.000373

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 380 of 470

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2015-ICFO-06247.000374

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 381 of 470

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2015-ICFO-06247.000375

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 382 of 470

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2015-ICFO-06247.000376

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 383 of 470

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2015-ICFO-06247.000377

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 384 of 470

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2015-ICFO-06247.000378

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 385 of 470

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2015-ICFO-06247.000379

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 386 of 470

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2015-ICFO-06247.000380

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 387 of 470

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2015-ICFO-06247.000381

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 388 of 470

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2015-ICFO-06247.000382

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 389 of 470

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2015-ICFO-06247.000383

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 390 of 470

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2015-ICFO-06247.000384

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 391 of 470

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2015-ICFO-06247.000385

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 392 of 470

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2015-ICFO-06247.000386

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 393 of 470

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2015-ICFO-06247.000387

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 394 of 470

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2015-ICFO-06247.000388

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 395 of 470

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2015-ICFO-06247.000389

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 396 of 470

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2015-ICFO-06247.000390

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 397 of 470

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2015-ICFO-06247.000391

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 398 of 470

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2015-ICFO-06247.000392

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 399 of 470

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2015-ICFO-06247.000393

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 400 of 470

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2015-ICFO-06247.000394

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 401 of 470

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2015-ICFO-06247.000395

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 402 of 470

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2015-ICFO-06247.000396

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Tuffly v DHS 06247 Records List - Judicial Watch

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Tuffly v DHS 06247 Records List

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Number of Pages:6

Date Created:July 13, 2015
Date Uploaded to the Library:July 13, 2015
Tags:Tuffly, Illegal Immigration

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March 15, 2017 | Number 1

Criminal Immigrants
Their Numbers, Demographics, and Countries of Origin
By Michelangelo Landgrave and Alex Nowrasteh

I

n his first week in office, President Donald Trump
crime in locations where they y
settle, finding a general
curitsecond broad strand of reissued an executive order directing the Departdecrease in crime d Se The 7
rates.5
lan
1
search examines immigrant institutionalization rates and
ment of Homeland Security to deport most illegal
ome er, 8, 20
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uniformly embthat that native-born Americans are more
finds
immigrants who come in contact with law enforce-ep't
e be
1
S. D on Stopt incarcerated than immigrants as a percentage
U.
ment. His order is based on the widespread perception d likely
.
e
fly vof crime in
that illegal immigrants are a significantuf
T source2 archiv of their population.6
in
d
cit uses 6-153 Community
Illegal immigrant incarceration rates are not well
the United States.2 This brief e American4
1
Survey data to analyze incarcerated immigrants according studied, although one investigation estimated that 4.6
No.
to their citizenship and legal status. All immigrants are
percent of Texas inmates are illegal immigrants while illess likely to be incarcerated than natives relative to their
legal immigrants comprise 6.3 percent of that state’s total
shares of the population. Even illegal immigrants are less
population.7 The best research on illegal immigrant crime
exploits a natural experiment to see how the removal of
likely to be incarcerated than native-born Americans.
illegal immigrants from an area through the Secure Communities (SCOMM) program affects local crime rates.
BACKGROUND
SCOMM was an interior immigration enforcement proEstimates of the total criminal noncitizen population
gram started in 2008 that checked the fingerprints of local
vary widely, from about 820,000 according to the Migraand state arrestees against federal immigration databases.
tion Policy Institute to 1.9 million according to ImmiIf ICE suspected the arrestee of being an illegal immigration and Customs Enforcement (ICE), but rarely is
grant, then ICE would issue a detainer to hold the arrestee
the number of those incarcerated estimated.3 Empirical
until ICE could pick them up. The Obama administration
studies of immigrant criminality generally find that immi- ended SCOMM in 2014, but the Trump administration
grants do not increase local crime rates and are less likely
reactivated it. If illegal immigrants were more crime prone
to cause crime than their native-born peers, and that nathan natives, the crime rates in those local areas that
tives are more likely to be incarcerated than immigrants.4
were first enrolled in the program should have seen crime
There are two broad strands of this literature. The first
decline relative to areas that were not. As it turned out,
is an area approach that analyzes how immigrants affect
SCOMM had no significant effect on local crime rates,
Michelangelo Landgrave is a doctoral student in political science at the University of California, Riverside. Alex Nowrasteh is an immigration policy
analyst at the Cato Institute’s Center for Global Liberty and Prosperity.

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2
which means that illegal immigrants were not more crime
prone than natives.8

METHODOLOGY

about the immigrant population as a whole, because the
ACS releases macro-demographic snapshots of inmates
in correctional facilities, which allows us to check our
work.13 This ambiguity in illegal immigrant incarceration
rates is why we narrowed the age range to 18–54 so as to
exclude inmates in mental health and retirement facilities.
Few prisoners are under the age of 18, but many in mental
health facilities are juveniles. Many of those above the
age of 54 are in elderly care institutions. Few illegal immigrants are elderly, so narrowing the age range does not
exclude many individuals from our analysis.14 Our count
of all prisoners between the ages of 18 and 54 is 8 percent
below that of the ACS snapshot.15 Natives in our results
include both those born in the United States and those
born abroad to American parents.

This brief uses the United States Census’s American
Community Survey (ACS) to focus on immigrants aged
18 to 54 who are incarcerated in the United States, their
incarceration rates, and their demographics for 2014. ACS
inmate data is reliable because it is ordinarily collected
by or under the supervision of correctional institution
administrators.9 We do not attempt to count the number
of immigrant ex-felons, criminally inadmissible aliens who
entered unlawfully, or other non-incarcerated foreigners.
The ACS counts the incarcerated population by their
nativity and naturalization status, but local and state governments do not record whether the prisoner is an illegal
immigrant.10 As a result, we have to use common statistical INCARCERATIONS
There were an estimated 2,007,502 natives, 122,939 ilmethods to identify illegal immigrant prisoners by excluding incarcerated respondents who have characteristics that legal immigrants, and 63,994ilegal immigrants incarcerated
r ty
Secu 7
in 2014. The incarceration rate was 1.53 percent for natives,
they are unlikely to have.11 In other words, we can identify
land
1
likely illegal immigrants by looking at prisoners with indi0.85 percente illegal , 20
om for er, 8immigrants, and 0.47 percent for
fH
o
vidual characteristics that are highly correlated with being ep't immigrants (see Figure 1). Illegal immigrants are 44
legal
emb
S. D on Sept likely to be incarcerated than natives. Legal
an illegal immigrant. Those characteristics are v. Uthe
that .
d percent less
uffly 1982chive immigrants are 69 percent less likely to be incarcerated
immigrant must have entered the country after ar (the
T
in
2
cited 6-1534
cut-off date for the 1986 Reagan amnesty), cannot have
1 Social Security or than natives. Legal and illegal immigrants are underrepbeen in the military, cannot be receiving
resented in the incarcerated population while natives are
No.
Railroad Retirement Income, cannot have been covered by overrepresented (see Figure 2). If native-born Americans
Veteran Affairs or Indian Health Services, was not a citizen were incarcerated at the same rate as illegal immigrants,
of the United States, is not living in a household where
about 893,000 fewer natives would be incarcerated. If nasomebody received Food Stamps (unless the individual has tives were incarcerated at the same rate as legal immigrants,
a child living with them as the child may be eligible if they
about 1.4 million fewer natives would be incarcerated.
are a U.S. citizen), and was not of Puerto Rican or Cuban
The ACS data include illegal immigrants incarcerated
origin if classified as a Hispanic.
for immigration offenses and in ICE detention faciliAnother limitation of the ACS data is that our estities.16 Subtracting out the 17,000 convicted for immigration offenses and the 34,000 in ICE detention to focus
mates of the illegal immigrant population include some
on non-immigration alien offenders lowers the illegal imlegal migrants who are here on other visas but whose
answers are consistent with those of illegal immigrants. As migrant incarceration rate to 0.50 percent, which brings
it close to the legal immigrant incarceration rate of 0.47
a result, we likely overestimate the number of illegal impercent.17
migrants who are incarcerated. Thus, our estimates of the
illegal immigrant incarcerated population and incarceration rate are likely greater than they really are due to ACS’s Robustness Checks for Counting the
Illegal Immigrant Population
data limitations.
The variable choices we made in analyzing the ACS data
The majority of inmates in the public-use microdata
can affect the number of illegal immigrants we identify. We
version of the ACS are in correctional facilities, but the
altered some of the variables to see if the results signifidata also include those in mental health, handicapped,
cantly changed. First, we decided to include illegal immiand elderly care institutions.12 This adds ambiguity to our
findings about the illegal immigrant population but not
grants who lived in households with users of means-tested

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3
Figure 1
Incarceration Rates by Immigration Status, Ages 18–54
Natives

Illegal Immigrants

Legal Immigrants

1.53%

0.85%

0.47%

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Natives
Illegal Immigrants
and
lLegal Immigrants
1
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Figure 2
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Share of Total Population iCompared to Share of Incarcerated Population, Ages 18–54
1
No.
Share of Incarcerated Population

Share of Total Population

91.48%
82.43%

5.61%
Natives

9.08%

Illegal Immigrants

Source: Authors’ analysis of the American Community Survey data.

8.49%
2.92%
Legal Immigrants

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4
snapshot of adult correctional facilities.18
Immigrants from certain parts of the world are more
likely to be incarcerated than others (see Table 2). Of all
legal immigrants, those from Oceania, North America,
and Latin America have, respectively, the three highest
incarceration rates. For illegal immigrants, those from
other regions of the world have the highest incarceration
rate of any group followed by those from Latin America.
Across all broad groups, those born in the United States
have the highest incarceration rate. Curiously, those born
to American parents overseas in the Middle East have the
highest incarceration rate of any native-born subgroup
at 2.15 percent. The distribution of prisoners by their
immigration status and region of origin shows that a full
7.27 percent of all prisoners are from Latin America while
90.64 percent were born in the United States (see Table
3). Latin American illegal and legal immigrant prisoners
are about 50 percent more likely to be incarcerated than
their percent of the population would suggest.
Almost 89 percent of all rity
prisoners are men, while only
Secu Table 4). The percentage
11.47 percent are women (see 7
land
1
DEMOGRAPHIC AND
of legal immigrant prisoners who are men or women is
ome er, 8, 20
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to
SOCIAL CHARACTERISTICS
ep'very similar mb of natives. However, illegal immigrant
eto that
S. D on Sept even less likely to be in prison than native or
U.
Different racial groups in the United States.have
women are
fly v rchived legal immigrant women.
widely varying incarceration ratesin Tuf
even within each im2a
c ted 6-1534
migrant category (see Table i1). All racial groups exclude
Prisoners in every group are more likely to have less
1
Hispanics, and the Hispanic No.
category includes those who education (see Table 5). Very few more highly educated
self-identify as Hispanic regardless of race. By race and
illegal immigrants and natives are in prison. A full 56.4 perethnicity, every group of legal and illegal immigrants has
cent of all natives have some college education or above
a lower incarceration rate than their native peers. Even
compared to 18.1 percent of native prisoners. Although
the incarceration rate for illegal immigrants is lower than 38.9 percent of illegal immigrants have at least some colthe incarceration rate for native white Americans. The
lege education, only 13.2 of illegal immigrant prisoners
racial and ethnic incarceration rates reported here are
have at least some college.19 More highly educated people
in every immigration category tend to avoid incarceration.
very close to those in the ACS’s macro- demographic
welfare benefits. Illegal immigrants do not have access to
these benefits but U.S. citizens and some lawful permanent
residents in their households do. This dropped the illegal
immigrant incarceration rate to 0.81 percent, increased the
legal immigrant incarceration rate to 0.49 percent, and did
not affect the native incarceration rate.
Our second robustness check excluded all immigrants
who entered the United States after 2006. Immigrants
on lawful permanent residency can apply for citizenship
after five years, guaranteeing that most of the lawful permanent residents who are able to naturalize have done so,
which decreases the pool of potential illegal immigrants
in our sample. This robustness check shrinks the size of
the incarcerated illegal immigrant population to 89,402
but slightly raises their incarceration rate to 0.93 percent
because the size of the non-incarcerated illegal immigrant
population in the general population shrank more. Those
variable changes did not affect our results enough to undermine our confidence in the findings.

Table 1
Incarceration Rates by Race, Ethnicity, Nativity, Ages 18–54
Natives (%)

Legal Immigrants (%)

Illegal Immigrants (%)

All (%)

White

0.90

0.31

0.31

0.87

Black

4.21

0.57

0.85

3.83

Asian

0.49

0.21

0.19

0.28

Hispanic (any race)

1.95

0.68

1.23

1.51

Other

2.54

0.97

0.40

2.34

All

1.53

0.48

0.85

1.38

Source: Authors’ analysis of the American Community Survey data.

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5
Table 2
Incarceration Rates by Country or Region of Birth, Ages 18–54
Natives (%)

Legal Immigrants (%)

Illegal Immigrants(%)

All (%)

USA

1.54

NA

NA

1.54

Other North America

1.00

0.79

0.20

0.57

Latin America

1.56

0.68

1.20

1.00

Europe

0.81

0.29

0.38

0.44

East Asia

0.96

0.27

0.25

0.31

Indian Subcontinent

0.00

0.07

0.08

0.08

Middle East

2.15

0.37

0.22

0.46

Other Asia

0.00

0.00

1.07

0.43

Africa

0.89

0.36

0.52

0.45

Oceania

0.59

0.80

0.28

0.50

Other

0.00

0.00

3.40

1.46

rity
Secu 7
land
1
Table 3
ome er, 8, 20
f H 18–54
Percentage of All Prisoners by Country or Region of Birth,o
ep't Ages emb
S. D Legaln Sept (%) Illegal Immigrants (%)
U
Natives.(%) .
d o Immigrants
yv
uffl99.08 archive
USA
NA
NA
in T
2
cited 6-1534
1
Other North America
0.04
2.39
0.35
No.

Source: Authors’ analysis of the American Community Survey data.

All (%)
90.64
0.13

Latin America

0.32

70.52

88.03

7.27

Europe

0.30

6.69

3.24

0.65

East Asia

0.16

12.24

4.00

0.72

Indian Subcontinent

0.00

1.36

0.85

0.09

Middle East

0.06

1.92

0.47

0.14

Other Asia

0.00

0.00

0.23

0.01

Africa

0.03

4.20

2.50

0.29

Oceania

0.01

0.69

0.20

0.04

Other

0.00

0.00

0.13

0.01

Source: Authors’ analysis of the American Community Survey data.

Table 4
Characteristics of Prisoners by Sex and Nativity, Ages 18–54
Natives (%)

Legal Immigrants (%)

Illegal Immigrants (%)

All (%)

Female

11.47

10.73

4.58

11.06

Male

88.53

89.27

95.42

88.94

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6
Table 5
Characteristics of Prisoners by Education and Nativity, Ages 18–54
Natives (%)

Legal Immigrants (%)

Illegal Immigrants (%)

Less than High School

30.6

38.0

52.8

High School Graduate

51.3

38.1

34.0

Some College

15.8

16.2

10.1

College Graduate

1.8

4.7

2.3

Post-Graduate

0.5

3.0

0.8

Source: Authors’ analysis of the American Community Survey data.

CONCLUSION

and Deportation,” NBER Working Paper no. 13229, National
Bureau of Economic Research, July 2007; Alex Nowrasteh, “Immigration and Crime—What the Research Says,” Cato at Liberty,
July 14, 2015, https://www.cato.org/blog/immigration-crime-whatresearch-says.
5. Jacob I. Stowell, Steven F. Messner, Kelly F. McGeever, and Lawrence E. Raffalovich, “Immigration and the Recent Violent Crime
y
curit
Drop in the United d SeA Pooled, Cross-Sectional Time-Series
States:
lan , 2017
Analysis ofme
o Metropolitan Areas,” Criminology 47, no. 3 (2009): 889–
8
t of H ember,
ep'928; LesleytWilliams Reid, Harald E. Weiss, Robert M. Adelman,
S. D and Sep
v. U. ived on Charles Jaret, “The Immigration–Crime Relationship: Eviffly
NOTES
dence across US Metropolitan Areas,” Social Science Research 34,
in Tu 342 arch
cited Safety15the Interior of the no. 4 (2005): 757–80; Matthew T. Lee, Ramiro Martinez, and Rich1. “Executive Order: Enhancing Public 6- in
1
United States,” Executive Order of the President, January 25, 2017, ard Rosenfeld, “Does Immigration Increase Homicide?” The SocioNo.
https://www.whitehouse.gov/the-press-office/2017/01/25/presidential- logical Quarterly 42, no. 4 (2001): 559–80.
6. Butcher and Piehl, “The Role of Deportation in the Incarexecutive-order-enhancing-public-safety-interior-united.
2. Lesley Stahl, “President-Elect Trump Speaks to a Divided ceration of Immigrants”; Butcher and Piehl, “Why Are ImmiCountry on 60 Minutes,” CBS News, November 13, 2016, grants’ Incarceration Rates So Low?” ; Walter A. Ewing, Daniel
http://www.cbsnews.com/news/60-minutes-donald-trump-family- E. Martinez, and Ruben G. Rumbaut, “The Criminalization
melania-ivanka-lesley-stahl/.
of Immigration in the United States,” American Immigration
3. U.S. Department of Homeland Security, “U.S. Immigration and Council Special Report, July 2015.
Customs Enforcement Salaries and Expenses,” Congressional Sub- 7. Nicole Cobler, “Less Than 5 Percent of Texas Prison Inmates
mission (Washington: Department of Homeland Security, 2013), p. Are Undocumented,” Texas Tribune, February 19, 2016, https://
61, https://www.dhs.gov/library/assets/mgmt/dhs-congressional- www.texastribune.org/2016/02/19/ice-records-reveal-makeupbudget-justification-fy2013.pdf. Marc R. Rosenblum, “Under- undocumented-prison-popu/.
standing the Potential Impact of Executive Action on Immigra- 8. Thomas J. Miles and Adam B. Cox, “Does Immigration Enforcetion Enforcement,” Migration Policy Institute, July 2015, p. 11, ment Reduce Crime? Evidence from Secure Communities,” Journal
http://www.migrationpolicy.org/research/understanding-potential- of Law and Economics 57, no. 4 (2014): 937–73; Elina Treyger, Aaron
Chalfin, and Charles Loeffler, “Immigration Enforcement, Policing,
impact-executive-action-immigration-enforcement.
4. Kristin F. Butcher and Anne Morrison Piehl, “The Role of and Crime,” Criminology & Public Policy 13, no. 2 (2014): 285–322.
Deportation in the Incarceration of Immigrants,” in Issues in the 9. Butcher and Piehl, “The Role of Deportation in the IncarceraEconomics of Immigration, George J. Borjas, ed. (Chicago, IL: Uni- tion of Immigrants,” pp. 351–86.
versity of Chicago Press, 2000), pp. 351–86; Kristin F. Butcher 10. Steven Ruggles, et al.,“Integrated Public Use Series: Version
and Anne Morrison Piehl, “Why Are Immigrants’ Incarceration 6.0,” 2015, Minneapolis: University of Minnesota; incarceration
Rates so Low? Evidence on Selective Immigration, Deterrence, rates and characteristics of immigrants incarcerated in the United

Legal and illegal immigrants are less likely to be incarcerated than natives. Our numbers do not represent the
total number of immigrants who can be deported under
current law or the complete number of convicted immigrant criminals who are in the United States, but merely
those incarcerated. This report provides numbers and
demographic characteristics to better inform the public
policy debate over immigration and crime.

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 416 of 470
7
States who are between 18 and 54 years of age for the years 2008
to 2014 (Figure 1).
11. Butcher and Piehl, “Why Are Immigrants’ Incarceration
Rates So Low?” Enrico A. Marcelli and David M. Heer, “The Unauthorized Mexican Immigrant Population and Welfare in Los
Angeles County: A Comparative Statistical Analysis,” Sociological
Perspectives 41, no. 2 (1998): 279–302; Robert Warren, “Democratizing Data about Unauthorized Residents in the United States:
Estimates and Public-Use Data, 2010 to 2013,” Journal on Migration and Human Security 2, no. 4 (2014): 305–28; Pia M. Orrenius
and Madeline Zavodny, “Do State Work Eligibility Verification
Laws Reduce Unauthorized Immigration?” IZA Journal of Migration 5, no. 1 (2016): 1–17.
12. Butcher and Piehl, “The Role of Deportation in the Incarceration of Immigrants,” pp. 351–86; Butcher and Piehl, “Why Are
Immigrants’ Incarceration Rates so Low?”
13. American Community Survey, “Characteristics of the Group

Quarters Population by Group Quarters Type,” Table S2601B
1-Year Estimates, 2014.
14. Jeffrey S. Passel and D’Vera Cohn, “A Portrait of Unauthorized Immigrants in the United States,” Pew Research Center,
April 14, 2009.
15. American Community Survey, “Characteristics of the Group
Quarters Population by Group Quarters Type.”
16. 2015 American Community Survey/Puerto Rico Community
Survey Group Quarters Definition, https://www2.census.gov/
programs-surveys/acs/tech_docs/group_definitions/2015GQ_
Definitions.pdf.
17. Bureau of Justice Statistics, Corrections Statistical Analysis
Tool (CSAT)—Prisoners; https://www.bjs.gov/content/pub/pdf/
p08.pdf.
18. American Community Survey, “Characteristics of the Group
Quarters Population by Group Quarters Type.”
19. Passel and Cohn.

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No.

Who We Are
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What We Do
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Report Crimes: Email or Call 1-866-DHS-2-ICE

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VOICE Fact
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Sheet

https://www.ice.gov/voice[9/8/2017 12:31:29 PM]

U.S. Immigration and Customs Enforcement (ICE) established the Victims of
Immigration Crime Engagement (VOICE) Office to acknowledge and serve
the needs of crime victims and their families who have been impacted by
crimes committed by removable criminal aliens.

SHARE

Victims of Immigration Crime Engagement (VOICE) Office

Home

Official Website of the Department of Homeland Security

Victims of Immigration Crime Engagement (VOICE) Office | ICE

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https://www.ice.gov/voice[9/8/2017 12:31:29 PM]

Dedicated toll-free VOICE Hotline to answer questions from victims (1855-48-VOICE).

Types of Support Available

The men and women comprising the VOICE Office will be guided by a
singular, straightforward mission – to ensure victims and their families have
access to releasable information about a perpetrator and to offer assistance
explaining the immigration removal process. ICE wants to ensure those
victimized by criminal aliens feel heard, seen and supported.

4. Provide quarterly reports studying the effects of the victimization by
criminal aliens present in the United States.

3.

2.

1.

ity
ecur
S
Use a victim-centered approach to acknowledge and supporteland
17
om er, 8, 20
immigration crime victims and their families.
fH
p't o ptemb
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Promote awareness of rights and services available Se
.S. D on to immigration
.U
crime victims.
ffly v rchived
Tu
d in 5342 a community stakeholders assisting
cite
Build collaborative partnerships with
16-1
. victims.
immigration crime
No

Objectives

With honor and integrity, we will support victims of crimes committed by
criminal aliens through access to information and resources.

Mission Statement

***ICE may not be able to provide information regarding certain offenders to
victims of a crime with a nexus to immigration due to the information being
protected by policy or law. ***

This office was explicitly called for in the President’s Executive Order
titled, “Enhancing Public Safety in the Interior of the United States,” dated
January 25, 2017.

Victims of Immigration Crime Engagement (VOICE) Office | ICE

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https://www.ice.gov/voice[9/8/2017 12:31:29 PM]

Why was I told no information was available on the
perpetrator?

What is DHS VINE? How does it work? Are you
collecting my personal information?

Who is considered a victim of immigration crime?

What is the ICE VOICE Office?

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Frequently Asked Questions

ity
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A victim of crime(s);
elan 8, 2017
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A witness of crime(s);
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An individual with a legal ffly
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witness (e.g.,ed in
attorneys, parents, legal guardians, etc.); or
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Individuals acting at
request of a victim or witness.
No.

Who can VOICE help?

Access to skilled social science professionals available to refer victims
to appropriate services.

Local contacts to help with unique victims’ requests, and

Additional criminal or immigration history may be available about an
alien to victims or their families;

Assistance signing-up to receive automated custody status information
about an alien in custody (DHS-VINE);

*This is not a hotline to report crime. To report crime, please
contact your local law enforcement agency or call 1-866-DHS-2ICE.

Victims of Immigration Crime Engagement (VOICE) Office | ICE

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https://www.ice.gov/voice[9/8/2017 12:31:29 PM]

Other toll-free hotlines (domestic violence, sexual assault, suicide
prevention): www.ovc.gov/help/tollfree.html

Department of Justice Office for Victims of Crime: www.ovc.gov

DHS-VINE: https://vinelink.dhs.gov/

ICE VOICE Office website: www.ice.gov/voice

Important Links

the VOICE office?

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Will this office assist illegal aliens who request
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help?
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. 16How do ICE’s o
N community relations officers support

If I call the VOICE office, what services or resources
will I receive?

How are immigration cases tracked? What is an “ANumber”?

Can I find out where a criminal alien is being held?

Do I need to register as a victim to receive
information through VOICE?

How do I report criminal activity by aliens?

What services are available to me as a crime victim
through VOICE

Victims of Immigration Crime Engagement (VOICE) Office | ICE

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IMMIGRATION AND CUSTOMS ENFORCEMENT

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cited 6-15
1
No.

Immigration Detention
Overview and
Recommendations

Dr. Dora Schriro
October 6, 2009

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Executive Summary
This Report provides a comprehensive review and evaluation of the U.S. Immigration and
Custom Enforcement (ICE) system of Immigration Detention. It relies on information gathered
by Dr. Dora Schriro, most recently the Director of the Office of Detention Policy and Planning,
during tours of 25 facilities, discussions with detainees and employees, meetings with over 100
non-governmental organizations and federal, state, and local officials, and the review of data and
reports from governmental agencies and human rights organizations.
The findings are based on analyses of the ICE detainee population and arrest activities conducted
specifically for this review. The Report describes the policy, human capital, informational, and
management challenges associated with the rapid expansion of ICE’s detention capacity from
fewer than 7,500 beds in 1995 to over 30,000 today, without the benefit of tools for population
forecasting, management, on-site monitoring, and central procurement.
The Report identifies important distinctions between the characteristics of the Immigration
Detention population in ICE custody and the administrative purpose of their detention—which is
to hold, process, and prepare individuals for removal—as compared to the punitive purpose of
y
the Criminal Incarceration system.
curit

e
nd S
elawith8, 2017
The Report underscores the opportunity for ICE, in coordination r, stakeholders, to design and
Hom be
't ofprograms, and oversight mechanisms that
implement a detention system with policies, facilities, eptem
Dep S
U.S. d on Detention.
align with the administrative purpose. of Immigration
yv
e
Tuffl 2 archiv
in
4
cit ad 6 15 framework for meeting the challenge of developing a new
The Report providese seven-part3
1
No.
system of Immigration Detention. It concludes with concrete recommendations for reform in
each of the seven areas of focus.
Core Findings
ICE operates the largest detention and supervised release program in the country. A total of
378,582 aliens from 221 countries were in custody or supervised by ICE in FY 2008;
activities in 2009 remain at a similar level. On September 1, 2009, ICE had 31,075 aliens in
detention at more than 300 facilities throughout the United States and territories, with an
additional 19,169 aliens in Alternative to Detention programs.
Of the aliens in detention on September 1, 66 percent were subject to mandatory detention
and 51 percent were felons, of which, 11 percent had committed violent crimes. The majority
of the population is characterized as low custody, or having a low propensity for violence.
With only a few exceptions, the facilities that ICE uses to detain aliens were built, and
operate, as jails and prisons to confine pre-trial and sentenced felons. ICE relies primarily
on correctional incarceration standards designed for pre-trial felons and on correctional
principles of care, custody, and control. These standards impose more restrictions and

2

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carry more costs than are necessary to effectively manage the majority of the detained
population.
ICE is comprised primarily of law enforcement personnel with extensive expertise
performing removal functions, but not in the design and delivery of detention facilities and
community-based alternatives.
ICE utilizes a number of disparate strategies to detain aliens in its custody, supervise aliens
on community supervision, and provide medical care to the detained population.
Key Recommendations
ICE should establish a system of Immigration Detention with the requisite management tools
and informational systems to detain and supervise aliens in a setting consistent with assessed
risk. ICE should provide programs to the detained population commensurate with assessed
need and create capacity within the organization to assess and improve detention operations.
In coordination with stakeholders, ICE should develop a new set of standards, assessments,
and classification tools to inform care, custody restrictions, privileges, programs, and
delivery of services consistent with risk level and medical care needs of the population. ICE
y
should expand access to legal materials and counsel, visitation, andecurit practice. ICE
S religious
should also develop unique provisions for serving special eland
populations such as women,
17
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families, and asylum seekers.
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ICE should establish a well-managed medical care system, with comprehensive initial
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inhousing42 arch
assessments to inform
cited 6 of 53
establish clear standards -1 care for detainees and monitor conditions systematically.
1
No.

ICE should provide federal oversight of key detention operations and track performance and
outcomes. It should place expert federal officials on-site to oversee detention operations, to
intercede as necessary, and to ensure that there are appropriate grievance and disciplinary
processes.
Next Steps
Some recommendations can be actualized soon; others will require further analysis, including a
comprehensive budget review. In order for ICE to achieve sustainable, organizational change, it
must continue the progress of recent months.

3

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Introduction
Information for this report was gathered during tours of 25 Immigration and Customs
Enforcement (ICE) facilities; conversations with detainees and staff; meetings with over 100
non-governmental organizations (NGOs); discussions with state and local elected officials,
employees at the Department of Homeland Security and the Department of Justice, and members
of Congress and their staff. The data was reviewed along with reports from a variety of
organizations including the Government Accountability Office, Department of Homeland
Security, the United Nations, the American Bar Association, and other NGOs.
The Challenge and the Opportunity: A System of Immigration Detention
For purposes of this report, the Criminal Incarceration system refers to the authority the
government has to incarcerate an individual charged with, or convicted of, a criminal offense.
Immigration Detention refers to the authority ICE has to detain aliens who may be subject to
removal for violations of administrative immigration law.1
As a matter of law, Immigration Detention is unlike Criminal Incarceration. Yet Immigration
Detention and Criminal Incarceration detainees tend to be seen by the public as comparable,
y
2
and both confined populations are typically managed in similar ways.SEachrit
ecu group is
ordinarily detained in secure facilities with hardened perimetersand
locations at
l in remote 017
,2
ome With, only a few exceptions,
fH
considerable distances from counsel and/or their communities. ber 8
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em
the facilities that ICE uses to detain aliens were originally built, and currently operate, as jails
S. D on Sept
U.
and prisons to confine pre-trialfand v.
fly sentenced ed Their design, construction, staffing
iv felons.
arch
in Tu 34strategies are based largely upon the principles of
plans, and population management 2
5
cited
command and control.o. 16-1 ICE adopted standards that are based upon corrections law
Likewise,
and promulgated by N
correctional organizations to guide the operation of jails and prisons.
Establishing standards for Immigration Detention is our challenge and our opportunity.
An Introduction to the Organization of the Report
The Report begins with a description of the current ICE system of detention. It incorporates
findings from analyses of populations, systems, and infrastructure. The Report then outlines a
framework of reforms and recommendations based on seven components that ICE must address
in order to design a successful system of Immigration Detention. These seven components,

1

ICE does not have authority to detain aliens for criminal violations. That authority lies exclusively with the
Department of Justice, subject to review of the federal courts. For instance, although many aliens who enter
illegally have committed a misdemeanor criminal offense in violation of 8 U.S.C. 1325, ICE does not have authority
to detain aliens for that criminal violation while criminal proceedings are pending. Instead, the Department of
Justice holds that authority. Although ICE has no criminal detention authority, ICE has administrative authority
pursuant to the Immigration and Nationality Act to detain aliens during the removal process.
2
Immigration proceedings are civil proceedings and immigration detention is not punishment. Zadvydas v. Davis,
533 U.S. 678, 609 (2001). Conditions of confinement in immigration detention may change based upon a detainee’s
criminal and immigration record.

4

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summarized below, are Population Management, Alternatives to Detention, Detention
Management, Programs Management, Medical Care, Special Populations, and Accountability.
Population Management encompasses the continuum and the conditions of control
exercised by ICE over aliens in its custody from least to most restrictive, and the
strategies by which aliens are managed pending removal or granting of relief from
removal. Population Management consists of the policies and the processes that
collectively create a system for administratively supervised and detained aliens.
Alternatives to Detention (ATD) are the community-based supervision strategies that
make up a significant portion of less restrictive conditions of control. These alternatives
relate closely to Population Management, but for the purposes of this report, ATD is
presented as a distinct component.
Detention Management focuses on the core operating assumptions and regulations that
affect the conditions of detention.
Programs Management addresses the design and delivery of programs provided to
detainees: a law library allowing detainees access to legal information; indoor and
outdoor recreation; family contact including visitation and communication by mail and
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phone; and religious activities.
Secu

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Medical Care, including medical, mental health, and dental 8
't of temb
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p
detainees in ICE custody. Medical care is
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Special Populations include families with minor children, females, the ill and infirm,
asylum seekers, and vulnerable populations. Population, Detention, and Programs
Management are modified to meet the detention requirements of Special Populations.
Accountability concerns the operating framework and process for decision-making by
which ICE provides oversight, pursues improvement, and achieves transparency in the
execution of each part of its plan.
The Report concludes with significant, although not exhaustive, recommendations for reform in
each of the seven areas of focus. Some recommendations can be actualized soon; others will
require further analysis, including a comprehensive budget review.
Overview
A Description of the Program and the Population
The Office of Detention and Removal Operations (DRO) is the largest program within
Immigration and Customs Enforcement (ICE). DRO oversees the apprehension, supervision, and
removal of inadmissible and deportable aliens. DRO has 24 field offices and 186 subfield

5

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offices, as well as the Deport Center in Chicago, Illinois3, and participates in the Justice Prisoner
and Alien Transportation System (JPATS)4 in Kansas City, Kansas. The DRO’s operating budget
for fiscal year (FY) 2009 is $2.6 billion and includes authorization to employ 8,379 fulltime
employees, primarily deportation officers (DO) and immigration enforcement agents (IEA).
ICE operates the largest detention system in the country. During FY 2008, ICE supervised a total
of 378,582 aliens from 221 countries, with 58 percent from Mexico, 27 percent from Central
American nations, and four percent from the Caribbean. ICE also operates the largest system of
community supervision in the country. During calendar year (CY) 2008, more than 51,000 aliens
were released from detention into the community via bond (29,000), order of recognizance
(12,000), order of supervision (10,000), or parole (650). In FY 2009 to date, approximately 90
percent of detainees are either from Mexico (62%), Central American nations (25%), or the
Caribbean (3%). By the end of FY 2009, ICE will have detained approximately 380,000 aliens.
On average, an alien is detained 30 days. The length of detention however, varies appreciably
between those pursuing voluntary removals and those seeking relief. As much as 25 percent of
the detained population is released within one day of admission, 38 percent within a week, 71
percent in less than a month, and 95 percent within four months. Less than one percent of all
admissions, about 2,100 aliens, are detained for a year or more.

y

rt
As of September 1, 2009, ICE was detaining 31,075 aliens in more than 300 ifacilities throughout
Secu 7
nd
the United States and territories. Of this total, 66 percent are subject to mandatory detention and
mela r, 8 201
oUCR Part-1 ,violent crimes5. The most
51 percent are felons, of which, 11 percent had committed
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common crimes committed by criminal aliens
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offenses, simple assault, and larceny.. Ninehived oof the detained population is female, of which
uffly arc percent
T
33 percent are criminal aliens, including three percent who committed UCR Part-1 crimes. As of
ed in 15 42
citICE was-also3supervising 19,160 aliens in alternative to detention (ATD)
September 1, 2009, o. 16
N
programs.
The majority of detention demand results from arrests in the San Antonio (9%), Houston (8%),
Atlanta (7%), Miami (7%), Los Angles (6%), New Orleans (6%), New York (6%), and Phoenix
(5%) field offices. The majority of ICE detention capacity is located in the San Antonio (14%),
Phoenix (9%), Atlanta (8%), Houston (7%), Miami (6%), and New Orleans (6%) field offices
areas. Although the majority of arrestees are placed in facilities in the field office where they are
arrested, significant detention shortages exist in California and the Mid-Atlantic and Northeast
states. When this occurs, arrestees are transferred to areas where there are surplus beds.

3

The ICE Deport Center processes deportation dispositions resulting from the Bureau of Prison (BOP), the Indiana
and Illinois Departments of Corrections, and jails in the Chicago metropolitan area.
4
JPATS provides transportation services for the BOP, the U.S. Marshals Service (USMS), and ICE.
5
The Uniform Crime Reports (UCR) contains official data on crime that is reported to law enforcement agencies
across the United States who then provide the data to the Federal Bureau of Investigation (FBI). For reporting
purposes, criminal offenses are divided into two major groups: Part I offenses (the more serious offenses) and Part II
offenses. In Part I, the UCR is divided into two categories: violent and property crimes. Aggravated assault, forcible
rape, murder, and robbery are classified as violent, while arson, burglary, larceny-theft, and motor vehicle theft are
classified as property crimes.

6

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The following four maps illustrate the distribution of detention demand, detention capacity, and
the variance between demand and capacity.
Detention Demand
FY 2009 Average Daily Population by Arrest Site Location
Spatial Density Analysis

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The majority of detention demand results from arrests in
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7

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Detention Capacity
FY 2009 Average Daily Population by Detention Facility Location
Spatial Density Analysis

urity

The majority of ICE detention capacity is located in the San Antonio (14%), Phoenix ec Atlanta (8%), Houston
d S (9%),17
(7%), Miami (6%), and New Orleans (6%) field offices areas
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Detention Demand v. Capacityly
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ac
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Variance of FY 2009 Averagen
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Spatial Density Analysis
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No.

Although the majority of arrestees are placed in facilities in the field office where they are arrested, significant
detention shortages exist in California and the Mid-Atlantic and Northeast states

8

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Detention Demand v Capacity (Regional Perspectives)
Variance of FY 2009 Average Daily Population by Arrest Site Location and Detention Facility Location
Spatial Density Analysis

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Distribution of regional detention demand, detention capacity, and the mel between demand and capacity
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A Description of Detention Facilities rchived
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The ICE populationtencompasses all of the aliens under the authority of ICE including those
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1 field offices and subfield offices or other locations and then
aliens who are booked-in at
No.

immediately released or removed, as well as those who are held temporarily in holding areas and
staging locations or assigned to detention facilities where they may remain for one day or less to
more than a year.
ICE operates two types of temporary facilities: holding areas and staging locations. Both holding
areas and staging locations are often co-located in field offices and subfield offices. ICE
detention standards dictate that aliens may be held in a holding area for up to 12 hours and in a
staging location up to 16 hours. These facilities do not provide sleeping quarters or shower
facilities. Holding areas and staging locations represent three percent of the average daily
detained population and 84 percent of all book-ins.
There are also two types of detention facilities: those designated to house aliens for fewer than
72 hours and those designated to house aliens for more than 72 hours. Most facilities (93%) are
approved by ICE for detention greater than 72 hours. On occasion, ICE places aliens in other
facilities, usually BOP facilities and medical centers. The degree of difference between detention
facilities and among holding areas and staging locations, as well as the time that a detainee
actually remains at any location, varies.

9

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ICE assigns aliens to over 300 detention facilities. In FY 2009, approximately 88% of the
detainee population was held in 69 facilities. Approximately 50 percent of the detained
population is held in 21 facilities. These include seven Service Processing Centers (SPC) owned
by ICE and operated by the private sector; seven dedicated Contract Detention Facilities (CDF)
owned and operated by the private sector; and seven dedicated county jail facilities, with which
ICE maintains intergovernmental agency service agreements (IGSA)6. The medical care at these
locations is provided by the Division of Immigration Health Services (DIHS). ICE requires that
these facilities comply with its national detention standards.
IGSA, SPC and CDF facilities in use during FY 2009
As of July 25, 2009

rity
Secu 7
land
1
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emb
S. D on Sept
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in T 342
cited 6-15
1
No.
Includes dedicated and non-dedicated IGSA facilities

The other 50 percent of the population is detained primarily in non-dedicated or shared-use
county jails through IGSA. These facilities, approximately 240 in number, also house county
prisoners and sometimes, other inmates. Fewer than 50 of these jails detain on average 100 or
more aliens daily. Many of these IGSA with county correctional systems pre-date ICE. They
were negotiated on behalf of the U.S. Marshal Service prior to the inception of ICE and the terms
of these agreements are out of date. The majority of agreements with IGSA facilities do not
contain the national detention standards. However, an evaluation is conducted annually to
ascertain the extent to which they comply. Congress included language in the FY 2009
appropriations bill requiring ICE to discontinue use of any facility with less than satisfactory
ratings for two consecutive years.
6

The seven Service Processing Centers are El Paso SPC (El Paso TX), Krome (Miami FL), Port Isabel SPC (Los Fresnos TX), Batavia SPC
(Buffalo NY); El Centro SPC (El Centro CA), Florence SPC (Florence AZ) and Aguadilla SPC (Agudilla PR). The seven Contract Detention
Facilities are Pearsall S. Texas CDF (Pearsall TX), Northwest CDF (Tacoma WA), Houston CDF, Otay- Mesa CDF (San Diego CA), Broward
Transitional CDF (Pompano Beach FL), Denver CDF (Aurora CO) and Elizabeth CDF (Elizabeth NJ). The seven dedicated IGSA facilities are
Stewart Detention Center (Lumpkin GA), Eloy FCF (Eloy AZ), Willacy County DC (Raymondville TX), Mira Loma DC (Lancaster CA), Otero
County Processing Center (Chaparral NM), Jena/LaSalle Detention Facility (Jena LA) and Laredo Processing Center (Laredo TX).

10

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Females are assigned to approximately 150 jails, with about half of the women in 18 locations.
Currently, 38 families with minor children are detained in two family residential facilities (FRF);
last month, Assistant Secretary Morton announced the conversion of one of the two FRF to a
female-only facility.
Approximately 1,400 non-criminal asylum seekers are detained daily. As is the case with female
detainees, asylum seekers are dispersed to a number of locations, many of them an appreciable
distance from the services and resources that they need.
Detention Cost
The cost to detain aliens varies appreciably between facilities, as do the terms and conditions of
the contracts and IGSAs. At some locations, ICE pays for every bed, regardless of whether it is
occupied. At other locations, the per diem is reduced when a certain occupancy level is achieved.
The majority of contracts with private prison providers are short in duration (typically five
years), whereas most IGSAs with county sheriffs have no expiration.
The published per diem rate captures much but not all of the direct and indirect bed day cost that
ICE incurs. On-site medical care provided by DIHS and offsite medical care approved by DIHS
represents additional cost. Furthermore, transportation between detention facilities, the education
provided detained minors, and facility rent and other services lead to even greater costs. The
y
published per diem rate for ATD participation represents the contractSecurit and does not
cost only
include ICE personnel assigned to the ATD unit and fugitive eland
operations activities and other
17
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expenditures.
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The Nexus betweened
Policy
5
cit
ICE promotes public safety6-1 national security by ensuring the departure of removable
o. 1 and
N
aliens from the United States. With an estimated 11.6 million immigrants unlawfully present
in the United States today,7 ICE focuses primarily on dangerous and repetitive criminal
aliens.

While aliens are apprehended by a variety of arresting entities, ICE is involved in the arrest
of most deportable immigrants, as the majority of cases involve aliens encountered when
they are in criminal custody.

7

Estimates of the Unauthorized Immigrant Population Residing in the United States: January 2008, DHS Office of
Immigration Statistics

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Aliens Apprehended by Arresting Authority
FY2009 Average Daily Population (ADP) as of 6/30/2009
Agency

Entity

FY 2009 Admissions

ICE

Criminal Alien Program (CAP)

ICE

FY 2009 ADP

178,605 (48%)

15,269 (48%)

Office of State and Local Coordination (287g)

44,692 (12%)

3,159 (10%)

ICE

Office of Investigations

21,969 ( 6%)

2,213 ( 7%)

ICE

DRO, Other

19,017 ( 5%)

2,116 ( 7%)

ICE

Fugitive Operations

16,395 ( 5%)

2,009 ( 6%)

CBP

Office of Border Patrol

70,976 (19%)

4,988 (15%)

CBP

Office of Field Operations

12,187 ( 3%)

1,657 ( 5%)

Other

Other

5,641 ( 2%)

609 ( 2%)

Total
Notes:

369,482 (100%)

32,020 (100%)

FY 2009 Admissions are pro-rated as of 6/30/2009
Does not include BOP and Office of Refugee Resettlement (ORR) facilities

The size of the detained alien population is a function of the number of admissions and
removals or releases and the total number of days in detention. Over time, policies have
ity
changed, priorities have been refined and new strategies have been adopted,rresulting in a
Secu 7
greater number of unlawfully present aliens apprehended andeland While the detained
m detained., 201
f Ho
population has increased appreciably over time, the proportion ofer, 8
b the arrested population
't o
Dep Septem
who are criminal aliens has remained fairly.constant.
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v. U
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i to
Initial Book-ins FY2007n FY2009 to date
2
cited % 6-1534Criminal
Fiscal
Non%
1
.
Year
Criminal No
Initial
Initial
Book-ins

Totals

Book-ins

FY 2007
183,106
66%
94,493
34%
277,599
FY 2008
238,766
68%
114,345
32%
353,111
FY 2009
66%
34%
243,900
125,583
369,483
Notes:
FY2009 Initial Book-ins is pro-rated as of 6/30/2009
Does not include BOP, ORR or Mexican Interior Repatriation Program (MIRP) facilities

Currently, 60 percent of aliens detained by ICE are encountered through the Criminal Alien
Program (48%) and the 287(g) Program (12%). Although these programs are focused on
criminal aliens, not all aliens encountered through these programs have criminal convictions.

12

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Criminal Alien Program (CAP)
FY2009 ADP as of 6/30/2009
Non
Non
Criminal
Criminal
Fiscal Year
Criminal
Total
Criminal
Average Daily Population
FY 2008
7,652
4,532
12,184
63%
37%
FY 2009
9,079
6,190
15,269
59%
41%
Initial Book-ins
FY 2008
69,808
79,259
149,067
47%
53%
FY 2009
77,500
101,105
178,605
43%
57%
Notes:
FY2009 Initial Book-ins is pro-rated as of 6/30/2009
Does not include BOP, ORR or Mexican Interior Repatriation Program (MIRP) facilities

Office of State and Local Coordination 287(g) Program
FY2009 ADP as of 6/30/2009
Non
Non
Criminal
Criminal
Fiscal Year
Criminal
Total
Criminal
Average Daily Population
FY 2008
1,021
1,329
2,349
43%
57%
y
FY 2009
1,490
1,669
3,159
47%
53%rit
Secu 7
Initial Book-ins
land 201
ome er, 8, 72%
FY 2008
10,545
27,231
37,776 of H 28%
b
't
FY 2009
15,533
29,159
44,692
35%
65%
Dep Septem
S.
Notes:
v. U. ived on
fly
FY2009 Initial Book-ins is pro-rated f of 6/30/2009; Does not include BOP, ORR or MIRP facilities
arch
in Tu as

2

cited 6-1534
1
No.

Another program targeted at criminal aliens, Secure Communities, has the potential to
significantly expand criminal alien enforcement through interoperable technology that
improves information exchange between law enforcement agencies and DHS. As evident in
the above tables, many aliens released from jails do not have convictions at the time of their
release. Since this new technology has the potential to identify large volumes of aliens with
low level convictions or no convictions, ICE and its state and local partners expect to
continue to enhance their efforts focusing on the more dangerous criminal aliens and those
with repeat offenses.
The Criminal Alien, State and Local 287(g), and Secure Communities programs impact
admissions; in contrast, the docketing and dispositions of cases by the Executive Office of
Immigration Review (EOIR) affects releases. EOIR is currently allocated 253 immigration
judges. An additional 28 positions are expected in FY 2010. EOIR also receives funds to
provide the Legal Orientation Program (LOP). The LOP provides general information about
the kinds of legal relief available to detainees and is currently provided to newly admitted
aliens at 50 detention facilities. Data indicates LOP participants move an average of 13 days
more quickly through the immigration courts than detainees who do not have access to the
program.

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POPULATION MANAGEMENT
Discussion of ICE Population Management
Organization and Operations
DRO has 24 field offices and 186 subfield offices. Each of the field offices is headed by a Field
Office Director (FOD), who reports directly to the DRO Deputy Director through the Assistant
Director for Field Operations. The FOD oversees the agency’s enforcement activities locally,
including detention and Alternatives to Detention. The majority of staff within DRO at
headquarters and in the field is focused on enforcement, not on detention. In August 2009,
Assistant Secretary Morton established an Office of Detention Policy and Planning (ODPP) in
the Office of the Assistant Secretary, creating the first office specifically dedicated to detention
policy and planning.
Distribution of Detention Responsibilities
Ordinarily, the acquisition and renewal of detention beds, the assignment of detainees to
facilities and ATD programs, and the transportation of detainees between facilities are
accomplished centrally from headquarters and coordinated regionally in the field. ICE delegates
these responsibilities directly to the field as collateral duties. It also delegates the operation of
detention facilities to the private sector and county sheriffs departments. curity

Se
land , 2017
eprimarily by the private sector.
On-site monitoring and annual evaluations are also performed
8
Hom
't of 53 tofmber,
ep
ICE contracts with one vendor for on-site monitoring at ep e the approximately 300
S. D
detention facilities. It contracts with another vendorn S
v. U. ived o to conduct an annual assessment of
ffly
compliance with detention standards at every facility currently in use. ICE also requests
in Tu 342 arch
cited 6 15
assessments of facilities that -have not been recently occupied. The FY 2009 combined cost
1
No.
for oversight and system-wide assessments is $31,000,000. Where deficiencies are identified,
the facility is required to submit an action plan and then remediate within a prescribed period
of time. Action plans should be provided in a more timely fashion and should be monitored
by ICE.
In addition to monitoring contract compliance, ICE maintains a presence at every facility,
primarily through a DO. Every detainee is assigned to a DO, whose duties include at least
one face-to-face contact each week to discuss the alien’s status in the removal process. Site
visits and case conferencing should occur regularly, and mechanisms are needed to ensure
detainees who are transferred to another facility maintain contact with their assigned DO or
are promptly reassigned to another DO.8 Additionally, site visits and case conferencing
should be consistently documented and routinely audited. Clear performance expectations
should be issued, and additional staff training and supervision provided. It may also be

8

When detainees are permanently transferred to another facility outside the area of responsibility of the sending
office, the receiving office reassigns a DO to their case. The exceptions are for detainees transferred for the purposes
of removal (staging of population for a charter or JPATS removal) and room and board cases (R&B). R&Bs are
generally cases where all proceedings have been concluded but removal is not imminent or the issuance of travel
documents are delayed.

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beneficial to conduct a workload analysis to ensure staffing is adequate to ensure weekly
contacts occur.
DRO also assigns a Contract Officer Technical Representative (COTR) and an assistant field
office director (AFOD), to key facilities. The COTR is a specialist in procurement and a
generalist in detention operations. The AFOD, a field office administrator, is a specialist in
enforcement who generally has less specialized experience in managing a detention facility.
The AFOD and the COTR report to the FOD. DRO does not expressly require the FOD, the
AFOD, or the COTR to routinely tour detention facilities. Likewise, documentation of tours
is not systematic and training is not formalized. In August 2009, Assistant Secretary Morton
announced the plan to hire full-time, on-site detention administrators for the first time.
Assistant Secretary Morton also recently transitioned the Detention Facility Inspection Group
(DFIG), which was responsible for auditing detention facilities and investigating for cause, to
the Office of Detention Oversight (ODO) within the Office of the Assistant Secretary, Office
of Professional Responsibility (OPR). DFIG was previously based in Washington D.C, while
ODO will operate from three regional offices in Arizona, Texas and Washington D.C.,
thereby increasing access to the field with a goal of increasing inspections and lowering
costs.

rity
Secu 7On-site
Percent of
On-site
Annual
On-site
land
1
o e ICE , 8, 20 ICE AFOD/
alien
monitoring
evaluation m
r
fH
e
't o
population
by vendor
COTR
SDDO
epby vendor emb
detained
S. D on Sept
U.
v.(11%)
d 100%
11%
7
7 (11%)
6 (11%)
uffly 6 (15%)hive 100%
arc
16%in T
7 (16%)
7 (16%)
2
cited 6-15347 (25%)
25% 1
100%
5 (20%)
7 (25%)
No.

Allocation of Oversight Activities by ICE and Others
Type facility

SPC
CDF
ICE-only
IGSA
Shared IGSA
Other
Total

45%

32 (26%)

100%

2 (5%)

2 (5%)

3%
100%

1 (0%)
N.A.
0 (1%)
1 (0%)
N.A.
23 (57%)
52
23 (53%)
(77%)
A total of 52 facilities in which 77% of the total population is detained, is overseen by an on-site contract
monitor. A total of 23 facilities in which 57% of the total population is detained, is overseen by an on-site
contract monitor, an ICE COTR, and an ICE AFOD/SDDO. At the remaining facilities, in which the remaining
23% of the population is detained, the immigration detainees are monitored by the same staff that oversees the
criminal population and no additional oversight is provided

The oversight of the ATD contracts is provided by the Chief of the Alternatives to Detention
Unit and the COTR.
In addition to oversight and investigation provided by ICE, the DHS Office of the Inspector
General (OIG) and the Office of Civil Rights and Civil Liberties (CRCL) receive complaints
and investigate allegations, each within their domain. The OIG may elect to open a file or
refer the matter to OPR.

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Each of these strategies includes informal and formal notifications and written reports. The
reliability, timeliness, distribution, and storage of the information, as well as the organizational
response, however, are not uniform and can hinder oversight. An additional challenge is ensuring
that the various assessments are complete, ratings are validated, and compliance and
performance problems are identified and resolved. ICE’s challenge is also complicated by issues
related to human capital, its information systems, detention standards, and other population
management tools. These are all critical to creating and sustaining an effective detention system.
Human Capital
Today, DRO is comprised primarily of law enforcement personnel with extensive experience
performing removal functions, but not necessarily in the design and delivery of detention
facilities and community-based Alternatives to Detention. Limited in-house expertise on this
subject matter makes it difficult to develop and evaluate Requests for Proposals and
independently evaluate providers’ performance. Other personnel issues also affect DRO. A
number of management positions at headquarters are filled with staff from the field on shortterm assignments, impeding the development of in-house expertise and institutional
knowledge. The relatively large number of vacancies, the result of turnover and new
positions not yet filled, increases the work load for the current staff in headquarters and the
field and thwarts recruitment and retention efforts. A concerted effort is underway to develop
in-house expertise. The establishment of the Office of Detention Policy and Planning is a
rity
critical first step.
Secu

land
17
ome er, 8, 20
H
Communication and Guidance to the Field
't of temb
Dep operational memoranda are the basis for
Written guidance to the field is limited. A series of Sep
n
U.S.
policy direction. A number ofuthesev. modified in part by superseding memoranda, and
ly are chived o
ff
in ICE
others are revised verbally. T has 2 ar formally publish policy and procedure or technical
yet to
cited 6-1534 should have access to timely, clear and complete
manuals specific to detention. The field
1
No.
written guidance about its critical functions—such as determining an alien’s bond amount,
eligibility for parole, or suitability for placement in an ATD program—so as to ensure
effective staff performance and case processing. Furthermore, training materials and job
performance expectations should be further developed.

ICE relies primarily on correctional detention standards designed for pre-trial felons for field
guidance. The national detention standards that the Immigration and Naturalization Service
(INS) introduced in 2000 with input from NGOs, which were then updated by ICE in 2008,
are based upon the American Correctional Association (ACA) jail detention standards for
pre-trial felons. These standards currently apply to all federal detainees, Immigration
Detention and Criminal Incarceration alike, carrying criminal incarceration policies and
practices into the arena of immigration detention. These standards impose more restrictions
and carry more costs than are necessary to effectively operate the facilities required for the
majority of ICE’s Immigration Detention population. Accordingly, ICE needs to develop
Immigration Detention standards consistent with the needs of its population.

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Observations about the Execution of Population Management Activities
Classification
ICE classifies detainees as low, moderate, or high custody. The primary basis for
classification is criminal history. The majority of the population is classified as low custody;
the minority is classified as high custody.
In general, the current system distinguishes between non-criminal aliens, non-violent
criminal aliens, and violent criminal aliens. In practice, however, non-criminal aliens and
non-violent criminal aliens are frequently housed together, as are non-violent criminal aliens
and violent criminal aliens. Moreover, these disparate groups are often managed similarly.
The present custody classification system needs to be refined to properly distinguish within
categories of crimes for degree of seriousness and to ascertain propensity for violence. ICE
should determine whether or not to maintain three custody levels or adopt two—lower and
higher custody. It should also align the supervision assumptions for each classification level
with the level of assessed risk, as well as provide written guidance and training for field
personnel.
ICE also needs a risk assessment instrument to implement a nationwide Alternatives to
Detention program, in addition to a medical care classification system with a pre-assessment
y
instrument. These two strategies are addressed later in this report. Securit

land
17
ome er, 8, 20
H
Systems for Reporting
't of temb
Dep number of basic reports, including a daily
Comparable detention systems routinely .rely on a
S.
Sep
v. U facility, on
count sheet of all detainees inuffly
custody by hived a roster of the population assigned to ATD
in T detentioncfacilities with information about their operating and
supervision, a current d of all 342 ar
list
5
cite the numbers of beds that are vacant and off-line for repair, and per
emergency capacities, o. 16-1
N
diem pricing. Prior to bringing online the on-site detention managers, ICE needs to work
toward developing these reports and publishing a daily list of individuals in its custody, their
location, and those that are participating in ATD. ICE also needs to centralize and
consolidate its records of contracts, service agreements, renewals, and vendors’ performance.
Population Management Information
ICE maintains a system of records, referred to as Enforce, which is comprised of three main
modules: Enforce Alien Booking Module (EABM), Enforce Alien Removal Module (EARM),
and the Enforce Alien Detention Module (EADM).
EABM is used when an alien is encountered, otherwise known as an arrest or apprehension.
Government officials use it at ports of entry, along the border, and within the United States to
record an arrest, gather biographical and biometric data, and initiate processes and paperwork to
begin administrative removal or immigration court proceedings against the alien.
EARM is the case processing module used to record case actions and decisions some of which
are collected chronologically. It is also used to record dispositions of immigration court hearings
and other administrative decisions, and to track the removal of an alien or record court
terminations or grants of relief such as asylum.

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The EADM module tracks book-ins and book-outs from detention among and between facilities.
It also contains information on the facilities themselves, and needs to be expanded to include
fields to capture information about detainee misconduct, grievances, and medical care. A records
module specific to Alternatives to Detention is currently being added.
An anomaly of this system of records is that the majority of computer entry screens are at
centralized sites such as major facilities, field offices, and sub offices, and not at the places of
detention, particularly IGSA locations. This is especially significant to the EARM and EADM
data bases, as the recording of the book-ins and book-outs frequently occurs after the actual
events. Improvements to this system could better ensure the accuracy of the count as well as
timeliness.
Moving forward, ICE needs more data about its operations for planning and evaluation
purposes. The IGSAs and private prison contracts in place today have few reporting
requirements and DIHS collects some information about its on-site activities, but does not
maintain any information about IGSA on-site activities. Instead, ICE relies primarily upon
contract monitors and facility operators to report information about basic detention activities
and looks to the ATD vendors to provide information about community supervision
activities. ICE should explore ways to optimize its databases, and those of its sister agencies,
y
to enhance the volume of data as well as the timeliness and quality ofSecuritentry. ICE
its data
should also install additional terminals to enter data in real time. Data entry 17
should be
land
ome er, 8, 20
routinely audited for accuracy at headquarters and't othe field. b
in f H

Dep
ptem
U.S. d on Se
y v.
e
Tuffl 2 archiv
in Recommendations
Population Management
cited 6-1534
1
No.
The ideal system should create the capacity to detain and to supervise aliens consistent
with assessed risk. This system should also afford opportunity to deliver programs and
provide for the health and well-being of the population. The size of the system must be
manageable; the design of the facilities must support the delivery of care as well as
custody and control; and the requirements of special detainee populations as well as the
population as a whole must be met. Facility locations and bed capacity should be aligned
with arrest activity and opportunities to utilize ATD. The facilities should be placed
nearby consulates, pro bono counsel, EOIR services, asylum offices, and 24-hour
emergency medical care. The system should be linked by transportation. The oversight
and management of the detention system must be supported by ICE by focusing on
detention as a distinct discipline.
ICE should develop and implement Immigration Detention standards and operating
procedures that specifically reflect the legal requirements of the detained population.
Immigration Detention should be implemented with a uniform policy, promulgated
through standard procedure manuals and staff trainings. Any future ICE detention
facilities should be designed and constructed consistent with these Immigration Detention
standards and existing facilities should be staffed and operated to reflect these standards.
Future requests for proposals and IGSA should incorporate operating assumptions that

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are consistent with Immigration Detention standards. For optimal results, discussions
leading to the development of Immigration Detention policy and its execution through the
drafting of detention standards and operating procedures should reengage governmental
and nongovernmental stakeholders and for-profit and non-profit providers. The
discussions should focus on the underlying assumptions that inform operating decisions
about movement, meal service, housing, dress, visitation, work, and worship, among
other important daily activities. These operating assumptions should be incorporated as
well in the facility design manual.
There should be additional attention given to the efficiency and the effectiveness of
existing and new systems of detention. ICE should improve efficiency by centralizing
certain functions such as bed acquisition and utilization, regionalizing coordination and
implementation, and decentralizing detention oversight. ICE should improve
effectiveness by routinely collecting and analyzing key performance indicators over time.
ICE should create capacity within the organization to assess and improve detention
operations and activities without the assistance of the private sector. ICE should
discontinue contracts and IGSAs when the facility’s performance is unsatisfactory.
ICE should establish a system of data tracking and assessment to inform management
decisions about detention policy. A five-year population forecast with expected rates of
y
growth for violent aliens, other criminal and non-criminal aliens, curit
Se females, families, and a
corresponding bed plan should be prepared and updatedland
e annually. ICE7should maintain a
, 1
omby ICE,and 20 locations, both
fH
count sheet and a current roster of all aliens detained ber 8 their
p't o
m
updated daily. The system should S. De validatedpte
utilize
Se custody and medical care
nto collect information about theinstruments
U.
to individually assess uffly v. detentiond o
aliens in
population
ive and
in T 342 arch medical care, and other program requirements. To
as a whole toed
refine housing, staffing,
5
cit
maintain accurate 16-1
o. detention records and to capture all cost incurred by the agency, ICE
should enter N aliens into its data base immediately upon the transfer of custody to ICE.
all
To maintain complete and accurate records, ICE should have access to secure terminals at
facilities that detain aliens.
ICE should conduct a comprehensive analysis of detention costs, as well as the projected
costs of this report’s recommendations. This study should evaluate the budget impact of
all of the following: renegotiating contracts to include less-restrictive detention strategies
for non-criminal and non-violent populations, as well as other detention standards that
reflect the nature of immigration detention; providing medical care and earlier medical
assessments and classifications; and releasing aliens from detention on Alternatives to
Detention programs. This budget analysis should be updated and renewed regularly.
ICE should adopt informal and formal problem solving processes. This could include an
office within ICE to receive and quickly respond to complaints and concerns about
individual aliens and their detention and to develop processes to find and fix the
underlying issues.

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ALTERNATIVES TO DETENTION
Observations about Alternatives to Detention
Today, ICE operates three ATD programs. Two ATD programs, Intensive Supervision
Appearance Program (ISAP) and Enhanced Supervision Reporting (ESR), are provided by
vendors on contract with ICE. The third ATD program, Electronic Monitoring (EM), is operated
by ICE, and about 250 ICE employees are assigned to the program. ISAP, which has a capacity
for 6,000 aliens daily, is the most restrictive and costly of the three strategies using telephonic
reporting, radio frequency, and global positioning tracking in addition to unannounced home
visits, curfew checks, and employment verification. ESR, which has a capacity for 7,000 aliens
daily, is less restrictive and less costly, featuring telephonic reporting, radio frequency, and
global positioning tracking and unannounced home visits by contract staff. EM, which has a
capacity for 5,000 aliens daily, is the least restrictive and costly, relying upon telephonic
reporting, radio frequency, and/or global positioning tracking.
Some observers have criticized what they see as overly restrictive conditions of supervision
imposed by ICE on aliens who are released to the community on an ATD program.
Aliens should be assigned conditions of supervision according to an assessment of the alien’s
ty
flight risk and danger to the community. In practice, however, assignment uria program is
Sec to 7
determined in part by residency. ISAP and ESR are available eland who live within a 50 to 85
m to aliens 201
f H who live rin8, locations to the
mile radius of the 24 field offices. EM is offered to alienso
be , other
't o
Dep Septem
extent that funds are available.
.S.

v. U
d on
uffly archive
in ICE develop a plan for the nationwide implementation of an ATD
In 2008, Congress directed T to 42
cited 6-15a3contract to provide an ATD program that consolidates all of the
program. ICE recentlyo. 1
awarded
N
supervision strategies into one program. When the plan is underway, it will replace current
routines with practices that increase participation and successful completions. In order to
implement a plan, ICE needs to develop a validated risk assessment instrument specifically
calibrated for the U.S. alien population. The tool should assess initial and ongoing suitability for
participation. As is the case with population management, ICE should ascertain each
participating alien’s need for supervision on the basis of factors such as the alien’s propensity for
violence, and approve a supervision strategy that fits the alien’s profile. The risk assessment
instrument can also be used to ascertain the program’s optimal pool of participants.
Recommendations about Alternatives to Detention
ICE should develop a nationwide implementation plan for the ATD program plan this
fall. The plan should include a risk-assessment instrument that will enable ICE to
estimate the number of aliens that will be enrolled in a nationwide program and to
determine whether additional funds are required for nationwide expansion. The plan
should include publication of a technical manual and provision of additional, ongoing
staff training. The design of the program should be based on a comprehensive review of
existing innovative ATD programs and best practices. The average length of time an alien

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spends in an ATD program should be monitored to ensure it is comparable to aliens who
are detained, in order to maximize the number of successful completions and reduce
overall spending. Finally, to further reduce absconding, fugitive apprehension strategies
should be reviewed and revised. Employing an in-house subject matter expert can
expedite implementation of the plan.
In 2007 ICE modified its parole guidelines in response to a request by organizations
advocating for asylum seekers who had been found to have a credible fear of persecution
or torture. Secretary Napolitano has requested a review of the agency’s parole policy and
the review is underway.
It is likely that additional aliens who are statutorily eligible, but not otherwise qualified
due to a lack of community ties, would qualify for ATD if not-for-profit and NGOs
would sponsor them. ICE should seek community partners and pilot this effort.
DETENTION MANGEMENT
Observations about Detention Management

y
Care, Custody and Control
curit
Detention Management speaks directly to the care, custody andland Se the7
control of 1 alien population.
20
In turn, care, custody, and control constitute the conditions me
r, 8,
f Ho of detention.

e
o
ep't ep emb
S. D onaliens t
S were built as jails and prisons. A
All but a few of the facilities thaty v. U. to ed
ICE uses detain
fl remote v
number of them are located Tufairly2 archiareas and are not near public transportation. In some
in f
in
4
cited 6 assigned
instances, ICE detainees are -153 to facilities where they are housed with pre-trial and
1
No facilities to which ICE detainees are assigned vary in age and
sentenced inmates. The .
architecture. Quite a few do not have windows. A number consist of single and double celled
units and others are dormitories of varying size.
Movement is largely restricted and detainees spend the majority of time in their housing units. A
recreation area is often adjacent to the housing unit and meals are served in the dayroom in quite
a few locations, not in a separate dining hall. Access to recreation, religious services, the law
library, and visitation can be improved. Segregation cells are often used for purposes other than
discipline. For example, segregation cells are often used to detain special populations whose
unique medical, mental health, and protective custody requirements cannot be accommodated in
general population housing. Translation services should be more readily available in order to
minimize staff reliance on other detainees for interpretation.
The demeanor of the Immigration Detention population is distinct from the Criminal
Incarceration population. The majority of the population is motivated by the desire for
repatriation or relief, and exercise exceptional restraint. According to reports provided by
contract monitors and submitted by the field, relatively few detainees file grievances, fights are
infrequent, and assaults on staff are even rarer.

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Numerous changes could be made to improve the care and management of the detainee
population. For example, individual complaints regarding the provision of medical care should
be carefully considered and responded to in a prompt fashion, and the overall provision of
medical care should be systematically managed to ensure appropriate remedies are implemented
where necessary. When an alien is transferred to another facility, ICE should ensure seamless
transfer of communication to a new DO.
Detainee safety and security is a primary responsibility of ICE. It requires a well maintained
physical space and comprehensive infectious disease containment practices. To ensure safety and
security, ICE needs an improved system of record-keeping, with the creation of institutional
detainee files that are continuously updated. ICE must correctly assess custody requirements and
swiftly identify medical and mental health issues as they arise. The system must make better use
of sound practices such as welfare checks, key and tool control, non-invasive searches, a viable
suicide prevention program, and practices that comply with the Prisoner Rape Elimination Act.
New ICE detention standards need to distinguish which detention practices are applicable under
what circumstances. Benefits and restrictions should be related to the assessed level of risk.
Detainee health and well-being is equally important. Nutritional meals and fresh foods,
appropriate and clean clothes, adequate toiletries, access to outdoor recreation, a wellness
program, and contact with counsel and community are all critical. Postage, phone cards, and
rity
other commissary items should be available.
Secu

land , 17
ome ethat is20 from intimidation
Finally, a credible grievance process, sustained in 'an environment r, 8 free
b
t of H
Dep Septem
and retaliation, is critical.
S.
v. U.
d on
uffly archive
in T
Recommendationston Detention 42
Management
ci ed 6-153
1
No.

At many locations, the DO is the government’s only representative. It is essential that a
DO has contact with all of the aliens on his or her caseload as scheduled and that the
contact includes a status report on the alien’s removal or petition for relief. When an alien
is transferred to another facility, ICE should ensure seamless transfer of communication
to a new DO. Further, the DO should receive training to be able to assess the general
well-being or demeanor of persons on their caseload.
ICE should require detention operators to incorporate direct supervision and unit
management into their detention management. Direct supervision would place specially
trained security officers in the housing units to improve communication and enhance
observation. Unit management would assign the identification and resolution of
problematic conditions of detention primarily to housing unit staff. Both detention
management strategies promote timely problem-solving.
ICE should develop specialized caseloads of aliens including those who are chronically,
medically, or mentally ill or have been detained a significant length of time to improve
case management and expedite removal, release or relief. Where aliens have had final
orders of removal and are not likely to be released, discharge and reentry planning should
be completed by caseworkers and carried out in cooperation with nearby NGOs.

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ICE needs to ensure that the detainee grievance and disciplinary processes afford
detainees full and fair consideration. ICE should be directly involved in grievance
appeals and disciplinary findings that result in a loss of privileges or liberties.
ICE should adopt the fewest number of custody classifications necessary to operate safe
and secure detention facilities. ICE should manage the population proportionately to the
risk they present.
Detained aliens should have access to the housing unit dayroom, outdoor recreation,
and to programs and support space in other parts of the detention facility consistent
with their custody classification and comparable with other populations detained at
that location.
ICE should also consider, in consultation with its stakeholders, normalizing the living
environment for low-custody aliens.
ICE should affirm the conditions of detention that it seeks to provide for a Immigration
Detention population and then assess each facility’s performance and physical condition
to determine whether to continue to use the facility in its current capacity, modify its
mission, or cancel the contract.

rity
Secu 7
land
1
ome er, 8, 20
fH
PROGRAMS MANAGEMENT
o
ep't
emb
S. D on Sept
v. U.
Observations about ProgramsflManagement d
uf y archive
in T 3 2
5
cited is required4to provide four programs services in addition to medical care.
Every detention facility . 16-1
o
N
They are 1) Law Library and Other Activities affording Access to the Court; 2) Recreation; 3)
Family Contact including Visitation and Communication by Mail and Telephone; and 4)
Religious Activities and Observances. These requirements are not unique to ICE. Both jails and
prisons are required by statute and case law to offer these services, but ensuring compliance at
detention facilities presents an ongoing challenge.
Law Library and Other Activities affording Access to the Court include attorney and consulate
visits, phone calls and legal mail, the EOIR-funded legal orientation program (LOP), translation
services, and hearings before an immigration judge when provided by law. The libraries vary
appreciably in size and staff with many relying on detainee law clerks for their operation. Many
of the jails used by ICE have non-contact visiting booths only and no room specifically designed
for contact attorney visits. Attorneys report problems contacting their clients by mail and
accessing them in the facility for pre-hearing consultations. They also report that their clients are
transferred to locations prohibitively far away, and that they are not notified when their clients
are moved. A number of facilities can improve counsel meeting rooms, such as by installing
privacy shields which mute telephone conversations and protect the privacy of an attorney-client
phone call. Detainees’ access to consulates and pro bono counsel can be improved by ensuring
that phone numbers are readily provided to detainees and are accurate.

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Recreation encompasses indoor, as well as outdoor, recreation. Outdoor recreation is distinctly
different than outdoor exercise which is usually limited to a “run,” ordinarily without recreation
equipment. Indoor recreation may include a gym in addition to the housing unit dayroom. Aliens
assigned to protective custody and administrative and disciplinary segregation are often limited
to outdoor exercise.
Family visitation is often limited to noncontact visits of fairly short duration. With many
facilities a considerable distance away, some families are unable to afford a facility visit. Phone
calls are also expensive. Steps could be taken to improve a detainee’s ability to contact family
members, such as making phone cards available and enhancing the family visitation meeting
rooms.
Jails, prisons, and ICE detention facilities are all subject to the Religious Land Use
Institutionalized Persons Act (RLUIPA). RLUIPA affords institutionalized persons the
opportunity to practice sincerely held beliefs. Non-denominational religious services are not
always available. Proselytizing is infrequent but occurs. There are often fixed objects unique to a
particular faith on display. Religious diets and religious objects are not always provided. Finally,
religious dress and head coverings, and hair length and facial hair, are not always permitted
consistent with custody classification.

rity
Secu 7
Recommendations for Programs Management
land
1
ome er, 8, 20
fH
p't o
emb
The Law Library should be sufficientDesize andeappropriately staffed to afford aliens
S. in on S pt
v U. iv should be current and complete. There should be
d
daily access. Legal reference .
uffly materialse
ch
T
in contact42 arvisits and opportunity for pre-hearing consultations.
dedicated space for
legal
cited be 153
Legal mail should16-delivered promptly to the alien, or returned immediately to the
No.
attorney. Detainees who are represented by counsel should not be transferred outside the
area unless there are exigent health or safety reasons, and when this occurs, the attorney
should be notified promptly. Privacy shields to mute telephone conversations and protect
the privacy of an attorney-client phone call should be installed on all of the phones that
detainees use. The telephone numbers for legal resources and consulates should be kept
current. Finally, the Legal Orientation Program (LOP) should be expanded to all
detention facilities.
Indoor and outdoor recreation should be available to the general and special populations
consistent with risk and appropriate to each population. Access should be expanded to the
greatest number of hours daily and no less than that afforded other populations.
Family visitation should be improved with expanded hours, appropriate space, affordable
phone calls, and accessible mail service.
ICE should implement, at every facility, opportunities for aliens to practice their faith in a
neutral environment where non-denominational religious services are available and
proselytizing does not occur. Religious diets and religious objects and texts should also
be provided. Finally, religious dress and head coverings, and the choice of hair length and

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facial hair, should be permitted consistent with custody classification. Access to worship
and study should be afforded.
A subject matter expert (SME) should oversee each of the four programs, develop policy
and procedure, provide technical assistance, modify each program to meet the
population’s cultural and language requirements, and audit for compliance.
MEDICAL CARE
Observations about Medical Care
The delivery of detainee medical care is shared by the Division of Immigration Health Services
(DIHS)9, sheriffs departments, and private prison providers.
DIHS coordinates off-site medical care for 100 percent of the population and provides on-site
medical care to about 50 percent of the total population, which is spread out among 21 detention
facilities. The medical care services provided vary considerably by location, as does the staffing
in the specialty areas. DIHS on-site provider staff is comprised predominately of contract
employees, who face more relaxed professional credentialing procedures than regular employees.
rity
DIHS also staffs four ICE holding/staging locations.
Secu

land , 2 17
ome facilities or0
H
ICE does not have an electronic medical records system for all ber, 8
uniform paper
't of
Depcare Septem is available about the
reporting requirements and little reliable.medical
U S. d on information
population as a whole. There uffly medical classification system other than a limited use
is no v.
chive
coding of healthy and d in T 342 there is no mental health classification system. There is
unhealthy, and ar
cite
-15
no policy on the maintenance, retention, and centralized storage of medical records; instead,
o. 16
N
a new medical record is opened each time a detainee is transferred to another detention
facility. After the detainee is transferred from the facility the file remains on site. While a
medical summary should accompany detainees upon their transfer, it does not routinely
occur.
The cost to provide medical care should also be established and updated annually.

The assessment, treatment, and management of pandemic and contagious diseases is inconsistent
across DIHS-staffed and non-dedicated IGSA facilities. Improvements should be made to ensure
that all facilities are capable of managing large scale outbreaks.
The current mental health intake assessment is quite brief and does not lend itself to early
identification and intervention. This is limited primarily to an overview of the detainee
handbook. Routine assessments should be made of aliens who remain detained or who exhibit
symptoms of distress. Staffing varies at DIHS facilities and is frequently quite limited at IGSA
locations. The number of aliens identified as having DSM diagnoses and prescription practices

9

DIHS, a unit within Public Health Services (PHS) at the U.S. Department of Health and Human Services (DHHS),
is detailed to ICE by means of a memorandum of understanding.

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differ appreciably. Few beds are available for in-house psychiatric care for the mentally ill.
Aliens with mental illness are often assigned to segregation, as are aliens on suicide watch.
Steps can be taken to ensure that detainees with other special needs, such as chronic medical
conditions, convalescent care, and infirmities associated with aging, have their needs met
effectively. For example, facilities should provide step down beds and more ADA accessible
facilities should be available to house detainees with special needs. Specialists to diagnose and
treat each of these populations, specialized case management, and prescription reviews are all
indicated.
A comprehensive review upon arrival at the detention facility and preventive clinical services
would help to identify aliens at risk and provide needed stabilization. Aliens with mental illness
would benefit from improved staffing, appropriate housing, access to step down services, and
specialized case management.
Within the last month, ODPP hired a medical care systems administrator and Assistant
Secretary Morton announced that ICE will recruit a Medical Director and establish a medical
care advisory group. ICE recently issued a policy on the notification of detainee deaths in
ICE custody.

rity
Secu 7
land , 201
ome should adopt a coordinated
There should be one integrated medical care of H ICE er, 8
't system. b
Dep care ptem the agency including a system
approach to assessing and managing medical Se across
n
U.S.
of medical care recordsffor all detainees. This would help establish the cost to provide
ly v. chived o
uf
medical caretedinform future budget requests. ICE needs to consider whether IGSA
to in T 342 ar
5
ci with6-1own medical care provider, can participate in a unified system.
facilities, each o. 1 its
N

Recommendations for Medical Care

ICE may benefit from forming an office designated to assume accountability and
authority for the integrated delivery of medical service system-wide.

The ICE infection control program should feature a comprehensive TB control program;
structure a surveillance system; mandate education for staff; and offer continuing medical
education to medical care providers.
ICE should develop and implement a system for a preliminary medical and mental health
screening and the medical and mental health classification for detainees. The preliminary
screening would be designed for use by lay personnel when the alien is transferred to the
custody of ICE. It would be used to inform alien assignments to a detention facility
consistent with medical need. The medical and mental health classification would be
completed by appropriately credentialed medical care personnel at the detention facilities
to which aliens are assigned and would not be delegated to contract employees. Aliens
identified as having elevated medical and mental health requirements should be assigned
to appropriately staffed and equipped detention facilities.

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SPECIAL POPULATIONS
Observations on Special Populations
Special Populations cut across Population Management, Detention Management, and Programs
Management to tailor each of these three components to meet the unique needs of families with
minor children, females, the ill and infirm, asylum seekers, and other vulnerable populations.
Families with minor children are assigned to family residential facilities (FRF), where the
conditions of detention are normalized to the extent possible. Parents oversee their children. A
parent of either sex may room with minor children up to the age of six. A parent may room with
minor children of the same sex up to the age of 18. The children attend school on-site and have
limited access to community resources. Currently ICE operates one FRF, the Berks FRF.
Detained women are impacted in part due to their relatively small number. They make up nine
percent of the detained population and are assigned to approximately 150 detention facilities
across the country where they are often one of very few Immigration Detention females. As a
result, they are not likely to have comparable or gender appropriate access. Many facilities
employ men primarily and assign female detainees to open bay housing where there is little
privacy.

rity
Secu 7
As noted above, ICE assigns aliens to detention facilities prior land
meto completing the medical
, 201
screening. Thus it relies on the facility provider to't of Ho whether 8 alien has been
determine ber, the
m
Dep S medically ill, the mentally ill, the
appropriately placed. As a result, the chronically ill, the epte
n
U.S. in facilities where the staffing, proximity to
elderly, and the handicapped ufflnot .
are y v always ed o
T physical archiv most conducive to their conditions. When the
emergency medicalitcare,in
2 space are
d and
c eand not 1534 the detainee, the alien is often reassigned within the
- transfer
facility elects to keep o. 16
N
facility to segregation for enhanced supervision, a location that is not conducive to recovery.

There are approximately 1,400 non-criminal asylum seekers detained daily. As is the case with
female detainees, asylum seekers are dispersed to a number of locations, some of which are an
appreciable distance from the services and resources that they need. Consolidating non-criminal
asylum seekers into one or several facilities close to systems of support should be considered.
Medical care and other programs services should be provided consistent with the identified needs
of these detainees.
Recommendations for Special Populations
The female population should be consolidated in facilities close to population centers
proximate to their arrest location and near pro bono counsel. The conditions of detention
should be modified to meet their special requirements for safety and well-being. The T.
Don Hutto facility, rededicated as an all female facility, now enables ICE to minimize its
assignment of small numbers of females to a large number of IGSA facilities in remote
locations. It also enables ICE to implement gender specific recommendations and assess

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their effects before implementing gender specific recommendations as part of a national
plan.
Female staff should be assigned to supervise the female population or, male staff should
be required to knock and announce prior to entering female detainee housing units and
holding cells.
NGOs and non-profit agencies should be invited to assist eligible individuals in special
populations, as well as the general population, to establish community ties and develop
viable release plans to qualify for placement in ATD programs, and then to maintain
compliance with their conditions of ATD supervision.
The utilization of segregation cells for medical isolation or observation should be
discontinued immediately.
ACCOUNTABILITY
Observations on Accountability

y

rit
Accountability is the keystone to detention reform. Accountability encompasses government
Secu 7
oversight, transparency, and a commitment to continuous improvement. ICE strives toward
land , 1
ome standards20
r, 8 specific
increased accountability through the development 'ofof H
p t detention e experts, thefor immigration
eon-site ICEemb
detainees, the introduction of newly established
development
S. D
Sept detention
v. U. ived on
of the ODO, and consideration fofya detainee locator system.
l
uf
h
in T
2 arc
cited 6-1534
o. 1
Recommendations N Accountability
for

ICE should review and revise the Performance Based National Detention Standards to
reflect the requirements and other needs that are unique to the population of immigrant
detainees. The new standards should be reassessed periodically.
ICE should continue to establish additional on-site detention administrator positions to
provide government oversight at IGSA locations, and assign a SME with the requisite
education and experience to coordinate, train, and assess this endeavor. The identification
of facilities to be included in this expansion should take into account the size of ICE
population, operating difficulties, and proximity to other IGSA locations.
ICE should continue to establish additional ODO teams to expand government oversight
to IGSA locations. Each interdisciplinary team should conduct routine and random
inspections and investigate for cause. The identification of facilities to be included in this
expansion should consider the size of ICE population, operating difficulties, and
proximity to other IGSA locations. ICE should also determine how many facilities each
team will be assigned.

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ICE should consider how to allocate and integrate the work performed by the on-site
detention administrators and ODO teams with that of the existing contract monitors and
the contractor performing annual evaluations in order to optimize coverage and maintain
optimal conditions of detention at all locations. Private sector participation in oversight, a
core governmental responsibility, should be reviewed and modified, particularly where
there is duplication of effort. Ultimately, ICE should establish and maintain a presence at
each facility in which its population is placed.
ICE should formulate a plan to optimize the presence of other ICE staff, particularly
deportation officers, who are currently assigned to detention facilities and then implement
its plan.
ICE should publish key performance indicators on the ICE website quarterly.
ICE should create and maintain a current detainee locator system on the ICE website.

rity
Secu 7
land
1
ome er, 8, 20
fH
o
ep't
emb
S. D on Sept
v. U.
d
uffly archive
in T 342
cited 6-15
1
No.

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Appendix
Facility Tours
Atlantic City Detention Center
Berks Family Residential Facility
Buffalo Detention Facility
Chicago Deport Center
Chicago Staging Facility
El Centro Service Processing Center
Elizabeth Service Processing Center
Eloy Detention Center
Florence Service Processing Center
Justice Prisoner and Alien Transportation System
Maricopa County Jail
McHenry County Jail
Migrant Operations Center (GITMO)
Mira Loma Detention Facility
Northwest Detention Center
rity
Otay Detention Facility
Secu 7
land
1
Port Isabel Service Processing Center
ome er, 8, 20
fH
o
San Diego Staging (B-18)
ep't
emb
S. D on Sept
San Pedro Service Processing CenterU.
v.
ed
uffly
TCenter2 archiv
South Louisiana Detention
in
ited
534
Springfield MOc oMedical Facility
BOP . 16-1
N
Stewart Detention Center
T. Don Hutto Family Residential Facility
Varick Street Detention Center
Willacy County Detention Center

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NGO and Other Stakeholders
Adult Faith Formation for Catholic Social Teaching and Family Life, Seattle Archdiocese
American Bar Association, Commission on Immigration (ABA)
American Civil Liberties Union (ACLU)
American Corrections Association (ACA)
American Gateways
American Immigration Lawyers Association (AILA)
American of State Correctional Administration (ASCA)
American-Arab Anti Discrimination Committee
Amnesty International USA (AIUSA)
Anti-Defamation League (ADL)
Arab American Institute
Arab Community Center for Economic and Social Services (Michigan)
Asian American Justice Center
Asylum Law
Breakthrough
Bill of Rights Defense Committee (Massachusetts)
Brooklyn Law School
urity
Border Research, Southwest Institute for Research on Women, Bacon ec
S Immigration Law & Policy
land
17
Program
ome er, 8, 20
H
b
't of
Breakthrough (New York)
Dep Septem
S.
Capital Area Immigrants’ Rights v. U.
d on
fly
ufYork archive
Carnegie Corporation ofn T
i New
2
cited 6-1534
Cardozo University School of Law
1
No.
Catholic Legal Immigration Network (CLINIC)
Center for American Progress
Center for National Security Studies
Central American Legal Assistance
Chicago Bar Foundation (CBF)
Citizenship Counts
City Bar Justice Center
Civil Rights Bureau NYS Attorney General's Office
Clinical Associate Professor of Law
Coalition for Humane Immigrant Rights of Los Angeles
Columbia University School of Law
Defending Immigrants (Seattle)
Detention and Asylum Program, Women’s Refugee Commission
Detention Watch Network
Faith & Action for Strength Together (FAST)
Florence Immigrant and Refugee Rights Project
Florida Immigrant Advocacy Center (FIAC)

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Four Freedoms Fund
Hebrew Immigrant Aid Society (HIAS)
Highland Park Reform Church
Human Rights First (HRF)
Human Rights Watch (HRW)
Illinois Coalition for Immigrant and Refugee Rights
Immigrant Defense Project
Immigration Advocates Network
Immigration Clinic (University of Texas School of Law)
Immigration Equality
Immigration Project of the Legal Assistance Foundation of Metropolitan Chicago (LAF)
Inter-American Commission on Human Rights
James E. Rogers College of Law, University of Arizona
Justice Sector Reform, Human Rights, Peace and Social Justice Program
Kids in Need of Defense (KIND)
Leadership Conference on Civil Rights & the Leadership Conference on Civil Rights Education Fund
Legal Aid of Western Missouri
Legal Aid Society, Immigration Law Unit
rity
Secu 7
Legal Momentum Immigrant Women Program
land
1
ome er, 8, 20
Lutheran Immigrant and Refugee Services (LIRS) of H
ep't
emb
Migration Policy Institute
S. D on Sept
. U.
Muslim Public Affairs Councilfly v
ived
uf
in T 342 arch Forum
National Asian Pacific American Women’s
cited 6-15
National Coalition NoImmigrant Women’s Rights
for . 1
National Council of La Raza
National Immigrant Justice Center (NIJC)
National Immigrant Project of the National Lawyers Guild (Family Petitioner)
National Immigration Forum
National Immigration Law Center
National Latina Institute for Reproductive Health
New Jersey Immigration Policy Network
New Orleans Workers’ Center for Racial Justice Counsel
New York County District Attorney's Office
New York Immigration Coalition
New York University/Bellevue Hospital Center for Survivors of Torture
New York University School of Law
Northwest Immigrant Rights Project
One America, Seattle
One America, Washington
New Orleans Workers’ Center for Racial Justice
Open Society Policy Center
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Organization of American States
Penn Law University of Pennsylvania
Penn State University Dickinson School of Law
Pew Hispanic Center
ProBAR
Probono
Rights Working Group
Seattle Archdiocese
Seattle University School of Law
Second Circuit Court of Appeals
South Asian Americans Leading Together (Maryland)
Southwest Institute for Research on Women, University of Arizona
Special Opportunities Fund at Carnegie Corp of New York
Tennessee Immigrant and Refugee Rights Coalition
Texas Rio Grande Legal Aide
The Ford Foundation
The Moss Group, Inc.
Unbound Philanthropy
rity
Secu 7
United Nations High Commissioner for Refugees
land
1
ome er, 8, 20
United States Conference of Catholic Bishops (USCCB)
fH
p't o Freedomb(USCIRF)
em
United States Commission on International De
S. ReligiousSept
n
U.
.
ed o
United States Democracy uffly v
T
rchiv
a
n
United States Justice d i at1the 42 Society Institute
cite Fund6- 53Open
1
University of Texas School of Law
No.
University of Washington School of Law Immigration Law Clinic
Vera Institute of Justice
Volunteer Advocates for Immigrant Justice
Washington Defender Association's Immigration Project
Women’s Refugee Commission
Yale University School of Law

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Congressional Contacts and Other Elective Officials and Staff
Congressional Asian Pacific American Caucus
Congressional Hispanic Caucus
Congressional Progressive Caucus
Health, Education, Labor and Pensions (HELP) Committee
House Democratic Caucus State of Washington
House Homeland Security Committee
House Judiciary Committee
House Majority Whip State of Washington
House of Representatives Committee on the Judiciary
House Subcommittee on Immigration, Citizenship, Refugees, Border Security, and International Law
Membership
House of Representative, State of Washington delegation
Permanent Representative of the United States Mission
Representative Carter
Representative Robles-Allard
Senate Drug Caucus
Senate Homeland Security and Governmental Affairs Committee
Senate Judiciary Committee
Senate Subcommittee on Immigration, Citizenship, Refugees, Border Security, and International Law
rity
Membership
Secu 7
Senator Feinstein staff
land
1
ome er, 8, 20
fH
State of Washington Governor
o
mb
ep't
State of Washington Governor’s Office of Executive Policye
S. D on Sept
v. U.
d
State of Washington House of Representatives delegation
uffly archive
in TSecurity Committee on Appropriations
Subcommittee on Homeland
342
ited

c

-15

16
No.

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Disclaimer
This document reflects the opinions and observations of the Special Advisor on ICE Detention
and Removal. This document is not intended to, does not, and may not be relied upon to create
any rights, substantive or procedural, enforceable at law by any party in any matter civil or
criminal. The release of this document in no way limits the otherwise lawful enforcement or
litigative prerogatives of DHS or ICE.

About the Author
Dora Schriro is one of the foremost experts on correctional policies in the country, and served
first as Secretary Janet Napolitano’s Special Advisor on ICE Detention & Removal, then as
Director of the ICE Office of Detention Policy and Planning. She has received prestigious
awards from both Harvard University and the National Governors Association for her immensely
successful recidivism reduction policies as the Director of the Arizona Department of
Corrections for six years. She also served as the Director of the Missouri Department of
rity
Corrections for eight years.
Secu

land
17
ome er, 8, 20
H
b
't of
Dep Septem
S.
v. U.
d on
uffly archive
in T
2
cited 6-1534
1
No.

35

http://trac.syr.edu/immigration/reports/438/[9/8/2017 12:31:45 PM]

This report for the first time seeks to address these fundamental questions. It uses the court's own caseby-case records on each custody hearing, matched with parallel case-by-case records on what ultimately
happens in their subsequent removal proceeding. The underlying court records were obtained by the
Transactional Records Access Clearinghouse (TRAC) at Syracuse University from the Executive Office for
Immigration Review (EOIR) under the Freedom of Information Act (FOIA).

And finally what ultimately happens in their removal cases, does the court find they are actually
deportable?

Do individuals who are released as a result of these decisions then abscond or do they show up for
their subsequent court hearings?

Once they receive a hearing, how often do immigration judges grant bond or release persons on
personal recognizance?

What proportion of detained individuals in Immigration Court hearings actually receive a custody
hearing before a judge?

These questions include:

ity
ecur
dS
elan 8, 2017
m
r,
f Ho
It is unquestioned that the loss of freedom and all that this implies oftenp't o substantial be
imposes
hardships.
mmount a
e
te
Further, it is widely acknowledged that it is more difficult to carry.out activities necessary to
.S D on Sep
successful defense in the deportation proceeding itself when individuals remain locked up.
.U
ly been able ived
ffhavev rchto challenge the necessity of their
Some individuals, but historically only a minority,
a
n Tu 4 judge. However, due in part to court rulings, the
d an
continued detention in a hearing before i immigration 2
ite judge153
c
right to a hearing before an immigration 6- to challenge ICE's decision to keep individuals detained
has been extended to a wider group o. 1
N of individuals. Unfortunately, very little information has been
published by the Immigration Court on these custody hearings, leaving many questions unanswered.

The government argues that continued detention is needed to ensure that these individuals will not
abscond and will show up for their hearing. For a smaller subset, there also may be public safety
concerns. However, detention imposes real costs. There are to begin with the costs to taxpayers who
foot the substantial bill to keep individuals locked up even though there has been no finding that the
individual is actually deportable. But there are also real and significant costs to the individuals who are
being detained, and frequently also to their family members.

Even though detained individuals receive priority in scheduling court hearings, some [2]
individuals remain
locked up for many months and even years before their cases are finally concluded.
A growing number
of lawsuits in federal courts are challenging[3] constitutionality of locking up individuals during this
the
period when their detention is "prolonged."

Court records show that at least half - and in some years upwards of two-thirds - of individuals are held
in ICE custody at the time the Department of Homeland Security (DHS) starts Immigration Court
proceedings seeking to deport them. As the backlog in the Immigration Court continues to grow and wait
[1]
times increase, the issue of whether individuals should remain locked up while their Immigration Court
case is pending has garnered increased attention.

What Happens When Individuals Are Released On Bond in
Immigration Court Proceedings?

What Happens When Individuals Are Released On Bond in Immigration Court Proceedings?

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[4]

How Many Individuals Receive Immigration Court Custody Hearings?

ity
ecur
dS
During FY 2015, immigration court records show that a total of 50,654 individuals received custody
elan 8, 2017
m
hearings before a judge, up from 14,169 twenty years earlier. Much of this increase reflects the growing
f Ho Table er,
o
number of detained individuals in Immigration Court. As shown in Figurep'and Appendix mb 1,
e 1 t epte
individuals detained at the start of their immigration proceedings . D
generally grew from 66,000 in FY 1995
S
S
to nearly 164,000 in FY 2011, and then declined back to . U. 98,000 last n
v roughly ived o year as overall court filings
ly
declined.
ff
in Tu 342 arch
cited 6-15
1
No.

Details on these findings are presented below. This report expands the topics covered in TRAC's
extensive publication series on Immigration Court matters, and was made possible through the support
of Syracuse University and a recent grant from the Carnegie Corporation of New York.

Fourth most individuals who were released prevailed in their court proceedings. Last year fully two
out of every three (68%) won their case and were found not to be deportable.

Third, for those who posted bond and were then released, relatively few individuals currently
abscond. During FY 2015, for example, only 14 percent failed to turn up at their subsequent court
hearing.

Second, the bond request was frequently turned down -- sometimes more, and sometimes a bit
less than half the time. For those granted bond, about one in five remained detained until the end
of their case, presumably because they were unable to post the bond amount set.

First, the proportion of detained individuals in Immigration Court proceedings receiving custody
hearings before an immigration judge has risen from one in five, to about half over the last twenty
years.

Results presented are based upon a detailed analysis of these records by TRAC. The analysis spanned
the last twenty years. In brief, TRAC's findings are as follows:

What Happens When Individuals Are Released On Bond in Immigration Court Proceedings?

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individuals with custody hearings has been falling. What has happened is that the number of individuals
in detained proceedings has fallen faster, so that the proportion with custody hearings still increased.
See Figure 2 and Appendix Table 1.

ity
ecur
dS
elan 8, 2017
om er,
Figure 1. Immigration Court Filings by Detention Status, FY 1995 - f H
FY 2015
b
't o
Dep Septem
.
For many years about one in four initially detained individuals received d on hearings before an
. U.S e
va bit fromiyear custody during the fifteen-year
y
immigration judge. Although this percentage hasfvaried
Tu flas low as rch v to year, than 30 percent.
period between FY 1995 and FY 2010 it in
rarely was
42 a 20 percent, or higher
ited picture has3changed. There are a growing proportion of
5
c
As shown in Figure 2, since FY 2010 the 16-1
. FY 2015 custody hearings were held for half of those detained.
detainees receiving bond hearings. During
No
While hearing numbers jumped to over 66,000 in FY 2011 and FY 2012, since then the number of

What Happens When Individuals Are Released On Bond in Immigration Court Proceedings?

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Figure 3 displays this release rate from a slightly different angle - those released as compared with the
total number of individuals in detained immigration proceedings. Historically, only one in ten detained
individuals had a favorable judge ruling at a bond hearing. Last year three out of every ten detained
individuals had a bond motion granted by an immigration judge. This increase reflects the growing
proportion of detained individuals who had hearings. See Figure 3 and Appendix Table 1.

more likely to grant bond today than they were twenty years ago.

[5]

ity
ecur
dS
elan 8, 2017
m
r,
f Ho
* first 10 months
p't o Hearing embe
Figure 2. Percent of Initially Detained Individuals Afforded Custody
e
t
.S. D on Sep
.U
d
How Often Do Immigration Judges Grant Bondy Releasehive
ffl orv rc on Personal Recognizance?
Tu
in
4 a
i ed 6-1 more 2
On average over this twenty-yeartperiod, slightly53 than half (54%) of bond hearings resulted in the
c
immigration judge denying the bond motion. In the remaining 46 percent, the bond motion was
1
No.
granted. There has been considerable year-to-year variation in these rates. In general, judges are no

What Happens When Individuals Are Released On Bond in Immigration Court Proceedings?

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Figure 4 shows, where bond was granted, the distribution of the amount of bond set by the judge in each
of the past five years. In FY 2015 fully half of all bonds set were between $4,000 and $10,000. A total of
four percent did not have to post any bond, while according to court records, seven individuals had
bonds set of over a million dollars.

When the bond motion was granted, bond amounts naturally varied. A few were granted release on
personal recognizance, or the bond amount was simply set at $0. At the other extreme, occasionally
bond amounts of a million dollars or more were set by the judge. The median bond amount set twenty
years ago was $3,000. By FY 2002 it rose to $5,000 where it remained until FY 2014 when it increased
to $6,000. In FY 2015 the median bond amount was $6,500. See Appendix Table 2.

since court records indicated enforcement officials had not set any bond amount. Accordingly, the judge
was being asked to set a bond to allow the individual to be released.

ity
ecur
dS
elan 8, 2017
m
r,
f Ho
* first 10 months
p't o Bond tembe
e
Figure 3. Percent of Detained with Custody Hearings and Granted ep
.S. D on S
.U
ffly v past twoved Twenty years ago court
The character of bond hearings has also changed over the rchi decades.
Tu
records indicate in three out four cases an initial bond had a
d in the bond amount should be reduced -- not whether the
342 been set by the immigration enforcement
cite
officials and the hearing was over whether -15
6 the number of these cases has steadily dwindled. By FY
1
individual should be released at all. However,
No.
2015, in 94 percent of the cases ICE was apparently insisting that the individual must be kept locked up

What Happens When Individuals Are Released On Bond in Immigration Court Proceedings?

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The appearance rate of those released as a result of a custody hearing before an immigration judge is
generally better - that is, higher -- than for individuals that immigration enforcement officials have
themselves released from custody. The "in absentia" rate overall for released individuals during FY 2015,
[7]
for example, was 23.4 percent , as compared to only 14.0 percent for the subset of those released after
an immigration judge had set bond. This is noteworthy since the cases immigration judges were
reviewing were almost always those where the government had refused to release the individual. Such

The vast majority of individuals who in recent years were released on bond as a result of their custody
hearing before an immigration judge turned up for their court case. During FY 2015, for example, court
records indicate that 86 percent of individuals that were released from detention turned up for their court
hearing when it was finally held. The remaining 14 percent were recorded "in absentia." That is, they
failed to appear and the immigration judge - in their absence -- granted the government's request for a
[6]
removal order to deport them.

Did Released Individuals Turn Up at Their Subsequent Court Hearings?

The remaining sections of this report focus on those individuals who secured their release from
detention. That is, they had a bond hearing before a judge, were then successful in having their motion
granted, and finally were as a result released from ICE custody.

ity
ecur
dS
elan 8, 2017
m
r,
f Ho
Figure 4. Bond Amounts Set by Immigration Judge
p't o ptembe
e
.S. D on Se
.U
For those granted bond, having a bond set still was y v
released. While
ffl not synonymous ed being detained at the figures
ivwith
varied from year to year, according to court Tu
records about arch
one in five remained
in
2
conclusion of their case, presumably d
to post
cases
cite because -they were unable after thethat bond amount. Fordown from
1534
concluded during FY 2015, 13 percent remained detained even
judge granted bond,
6 conclusion of their case in FY 2011 after bond was granted.
1
28 percent who had still been detained.at the
No
See Appendix Table 3.

What Happens When Individuals Are Released On Bond in Immigration Court Proceedings?

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Outcomes in deportation and removal proceedings over the past two decades for individuals released
after a judge granted bond in their custody hearing are shown in Figure 6 and Appendix Table 4. As can
be seen, these individuals who have been released from detention have over time increasingly prevailed
in their Immigration Court cases.

The remaining proportion ordered deported - that is, one out of three - was significantly lower than those
ordered deported overall in Immigration Court proceeding completed last year. As TRAC has previously
reported, in FY 2015 the overall proportion of individuals ordered deported in Immigration Court
proceedings was just under half, or 46 percent.

Individuals who gain their release in a bond hearing also have a very high success rate in establishing
that they should not be deported in the first place, and can therefore remain in the U.S. During FY 2015,
for example, two out of every three individuals (68%) released after the judge granted bond ultimately
prevailed in their Immigration Court proceeding.

Immigration Judge Decisions on Deportation and Removal Proceedings

Figure 5. Whether Individuals Released from Detention After Bond Granted by Immigration Judge Abscond

ity
ecur
dS
elan 8, 2017
m
r,
f Ho
p't o ptembe
e
.S. D on Se
.U
ffly v rchived
Tu
d in 5342 a
cite
1
. 16No

In general, in absentia rates for individuals released as a result of bond decisions made by immigration
judges also were down from levels of ten or more years ago. In absentia rates for individuals released
after their custody hearings peaked at 47 percent during FY 2002 and have generally fallen[8]
since then
despite the increasing percentage of detained individuals being released on bond by judges . See
Figure 5 and Appendix Table 3.

cases, if the system operated logically, would be thought to present a higher, not lower, flight risk.

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[4] These recent declines reflect the decrease in the overall number of court filings after FY 2011 in large part
because of DHS's increasing reliance on administrative deportation procedures that bypass the Immigration Court.

The U.S. Supreme Court, for example, recently granted certiorari to review the Ninth Circuit's Rodriquez opinion
in a class action involving prolonged detention in Immigration Court proceedings holding that those individuals had
a right to a bond hearing before an Immigration judge. See also, Denmore v. Kim, 538 U.S. 510 (2003).

[3]

[2] See, for example, recent EOIR statistics. Also see TRAC report that found legal noncitizens had received the
longest ICE detention times simply because of the lengthy procedures required to prove they had the legal right to
remain in the U.S.

[1] See, for example, July 2016 TRAC report on increasing backlogs, and September 2015 report on ballooning wait
times.

Footnotes

thousands of individuals who ultimately were found not to be deportable to avoid being held during their
lengthy court proceedings. The number of those judged not deportable who escaped unnecessary
detention grew over the last decade from 1,697 individuals in FY 1995 to 9,158 individuals in FY 2015.

ity
ecur
dS
elan 8, 2017
m
r,
f Ho
p't o ptembe
Figure 6. Outcome in Immigration Deportation Proceedings Where Individual Released After Judge Granted Bond
e
.S. D on Se
.U
Conclusion
ffly v rchived
in Tu result a
dthe practical342 of the release of increasing numbers of
Court records so far demonstrate te
ci that significant increase in those who abscond and fail to show up
15
individuals on bond has not resulted in any 6.if 1
for their immigration hearings. Trends, anything, show declines. At the same time, it has allowed
No

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190,170

200,316

189,070

1996

1997

1998

All

98,160 27,636

98,094 19,637

80,423 15,595

15,559

11,462

9,005

9,056

Bond Granted**

Custody Hearings*

66,017 14,169

Individual Detained

http://trac.syr.edu/immigration/reports/438/[9/8/2017 12:31:45 PM]

159,135

Total

New Court Filings

28.2%

20.0%

19.4%

21.46%

With Custody Hearings

15.9%

11.7%

11.2%

13.7%

With Bond Granted

Percentage of Detained

Appendix Table 1. Immigration Court Detained Cases with Custody Hearings

1995

Fiscal Year

Appendix

12,022 cases of all types that had been concluded in which the individual earlier had been released from custody
as a result of immigration judges granting them bond. TRAC found only two out of the 12,022 were identified as
Rodriguez cases and, according to Immigration Court records, both of these released individuals showed up for
their immigration hearings.

[8]

ity
ecur
dS
elan 8, 2017
m
r,
f Ho
p't o ptembe
e
.S. D analysisSe subset of cases that
n of the
.U
Supplemental Note (October 6, 2016). TRAC just completed a supplemental o
ffly v rc as ved
EOIR recently began identifying as "individuals released from custody hia result of a bond hearing conducted
Tu
pursuant to the decision in Rodriguez v. Robbins, 804 F.3rd 1060 (9th Cir. 2015)." TRAC found there are a
2a
d in thus 534applicable Rodriguez cases. In addition, only a very
relatively small number that EOIR has identified
far as
ite
c
1 on their merits. As a
few of these Rodriguez cases have reached a16much too
. conclusion decided "in absentia."result it isthese very early to even
attempt to determine what proportion ultimately will be
To place
preliminary
No
numbers into context, TRAC reported in Appendix Table 3 that during the first 10 months of FY 2016 there were

[7] This rate, using the same methodology, compares the total number of in absentia decisions in cases in which
the individuals had been released from custody to the total cases involving released individuals concluded that
year. These results are also shown in Appendix Table 3. Where there have been multiple proceedings for the same
individual, the outcome for the last - that is, final -- proceeding is used. TRAC's result differs from what EOIR
publishes as its "in absentia" rate for the following two reasons. First, EOIR's rate is based upon the initial, rather
than the last proceeding. If this rate is being used as an indicator of individuals absconding, rather than simply
failing to appear, then using the first proceeding and ignoring subsequent ones is quite inappropriate. Where, for
example, the individual never received notice of the hearing, the case may be reopened and a later hearing take
place. Use of the last proceeding, rather than the first, is thus a more accurate measure in this context. In fact,
using the last proceeding instead of the first significantly impacts and reduces the calculated rates. Second, EOIR
unlike TRAC does not include all individuals with hearings that conclude their case, choosing to exclude some
because of the particular type of decision the court ultimately made. While anyone who absconded would not be
qualified to receive the type of decision that EOIR labels as "other completions", the agency excludes these from
its total case completion count when computing in absentia rates. Although formerly insignificant in number, these
"other completions" have grown in recent years. They have the same practical effect of closing the case and
allowing the individual to remain in the U.S. In FY 2015, these "other completions" made up around a quarter of
the cases the court decided. EOIR appears to continue to exclude them for what appears to be largely historical
reasons when its case counting methodology was quite different. No rationale now for their current exclusion
remains. Indeed, continuing to exclude them results in publishing misleading and greatly inflated in absentia rates.

[6] Given the Court's backlog, there was typically a long delay between the date of their bond hearing and the
hearing that concluded removal proceedings. For example, the median bond hearing date for FY 2015 dispositions
was back in April 2012.

For individuals who had multiple bond hearings, figures are based upon the outcome of the last hearing. Grant
rates are lower if counts include all hearings since unsuccessful candidates account for most requests for repeat
hearings.

[5]

The larger number in FY 2014 reflects cases from the surge of unaccompanied children and women with children
that arrived that year seeking refuge in this country

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242,932

218,483

2011

2012

$0

145,785 68,014

163,716 66,913

156,999 46,819

165,500 46,707

153,531 42,232

136,200 38,793

114,113 27,117

105,838 23,408

98,907 26,685

104,467 30,040

98,475 29,955

100,980 27,451

89,875 23,116

80,129 21,515

31,688

30,398

18,549

18,563

16,089

15,870

10,658

8,164

9,614

12,415

14,469

13,540

10,328

8,499

46.7%

40.9%

29.8%

28.2%

27.5%

28.5%

23.8%

22.1%

27.0%

28.8%

30.4%

27.2%

25.7%

26.9%

$25,000+

21.7%

18.6%

11.8%

11.2%

10.5%

11.7%

9.3%

7.7%

9.7%

11.9%

14.7%

13.4%

11.5%

10.6%

9,005

11,462

15,559

8,499

10,328

13,540

14,469

12,415

9,614

8,164

10,658

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

$5,000 3.4% 14.5%

$5,000 4.6% 12.8%

$5,000 4.6% 13.0%

$5,000 5.5% 15.2%

$5,000 5.7% 14.1%

$3,500 7.9% 17.6%

$3,000 5.7% 25.7%

$3,000 8.1% 28.3%

$3,500 5.0% 19.6%

$3,000 5.9% 29.9%

$2,500 5.9% 40.7%

$3,000 7.1% 32.6%

22.3%

18.8%

21.0%

24.2%

28.0%

37.7%

35.4%

39.5%

37.7%

26.9%

23.3%

19.2%

$2,500 $5,000

135,434 52,138

127,573 48,722

http://trac.syr.edu/immigration/reports/438/[9/8/2017 12:31:45 PM]

9,056

1995

Amount

268,095

2014

Year

205,142

2013

27.4%

31.2%

29.3%

24.6%

23.5%

23.1%

20.1%

13.9%

17.6%

15.7%

13.3%

16.2%

$7,500

10.1%

9.2%

10.4%

7.9%

7.1%

4.2%

3.3%

3.3%

5.1%

4.3%

5.2%

7.5%

$10,000

25,644

20,587

10.2%

10.7%

9.5%

8.8%

8.6%

4.2%

4.1%

3.6%

7.3%

8.1%

5.7%

8.2%

$12,500

4.7%

4.3%

3.9%

4.9%

4.9%

2.8%

2.5%

1.4%

2.8%

3.6%

2.5%

3.4%

$17,500

2.8%

2.6%

3.4%

2.9%

2.5%

0.6%

0.9%

0.9%

2.6%

2.8%

1.9%

3.1%

$25,000

38.5%

38.2%

4.6% 100.0%

5.9% 100.0%

4.9% 100.0%

6.0% 100.0%

5.5% 100.0%

1.9% 100.0%

2.3% 100.0%

0.9% 100.0%

2.2% 100.0%

2.8% 100.0%

1.6% 100.0%

2.6% 100.0%

Total

18.9%

16.1%

ity
ecur
dS
2015
194,798
97,927 50,654
28,637
51.7%
elan 29.2% 2017
8,
H m ber,29.8%
f53.8%o
2016***
157,664
80,482 43,317
23,996
't o
em
Dep
* The number of individuals with custody hearings.
S. at the laston Sept is used.
** Where an individual had their custody reviewed more than once, the U.
custody hearing
. outcome
***Covers the first 10 months of FY 2016 (through the end offly v
f July). rchived
in Tu 3 Bond a
Appendix Table 2. Bonded
Decisions* to Grant 42 or Release on Personal Recognizance
cit
15 Percentage by Bond Amount
. 16Fiscal
Median
No $2,500< $5,000< $7,500< $10,000< $12,500< $17,500<
Number
$1-

249,452

233,269

2006

2010

287,240

2005

258,036

205,818

2004

2009

196,905

2003

217,088

180,249

2002

231,504

176,230

2001

2007

160,852

2000

2008

164,186

1999

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$6,000 0.8%

$6,500 4.4%

18,563

18,549

30,398

31,688

20,587

25,644

28,637

23,996

2009

2010

2011

2012

2013

2014

2015

2016**

4.1%

6.3%

7.1%

7.4%

12.5%

19.6%

24.4%

25.2%

30.2%

28.8%

30.6%

25.4%

26.2%

22.5%

19.9%

23.7%

28.2%

31.4%

29.9%

27.6%

27.6%

27.7%

28.0%

26.1%

22.6%

19.1%

16.4%

16.8%

14.5%

12.7%

12.2%

12.3%

11.0%

11.3%

18.0%

13.1%

13.0%

10.1%

8.6%

9.7%

8.7%

11.6%

11.9%

11.9%

9.2%

7.3%

5.9%

5.0%

3.7%

4.3%

4.0%

5.3%

4.9%

5.4%

6.5%

3.7%

1.9%

1.6%

1.3%

2.5%

1.8%

2.7%

2.7%

3.3%

6.5% 100.0%

2.7% 100.0%

2.2% 100.0%

1.8% 100.0%

1.4% 100.0%

3.0% 100.0%

1.6% 100.0%

3.4% 100.0%

3.2% 100.0%

3.7% 100.0%

8,227

9,228

12,297

10,214

8,967

9,781

12,574

13,310

9,818

7,765

7,783

9,858

10,656

11,353

12,184

14,211

17,023

18,504

17,221

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

2011

2012

2013

2014

Percent "In
Absentia"

All Completions Where Released

2,951

2,876

4,109

3,985

2,735

3,000

2,635

2,697

2,113

1,969

2,509

3,153

2,855

Remained
Detained

14,270

15,628

12,914

10,226

9,449

8,353

8,021

7,161

5,670

5,796

7,309

10,157

9,719

Gained
Release

12,448

13,370

10,480

8,537

8,322

7,140

6,671

5,368

4,235

4,142

4,648

6,303

5,187

Attended
Court
Hearing

1,822

2,258

2,434

1,689

1,127

1,213

1,350

1,793

1,435

1,654

2,661

3,854

4,532

Did Not
Attend**

12.8%

14.4%

18.8%

16.5%

11.9%

14.5%

16.8%

25.0%

25.3%

28.5%

36.4%

37.9%

46.6%

38,685

36,307

29,573

24,587

20,583

18,336

19,111

19,082

18,387

17,287

20,074

27,258

27,646

9,547

8,260

6,821

5,778

3,845

3,764

4,137

5,243

5,899

5,951

7,362

11,008

13,058

24.7%

22.8%

23.1%

23.5%

18.7%

20.5%

21.6%

27.5%

32.1%

34.4%

36.7%

40.4%

47.2%

Total
Did Not Percent "In
Released Attend** Absentia"

ity
ecur
dS
elan 35.7% 2017
2,381
4,439
3,038
1,401
31.6%
11,898 om
8,
f H 4,249
't o12,484 tember,34.7%
2,546
5,681
4,001
1,680
29.6%
4,328
ep
e
S. D28.7%on 12,767p 4,145
S
2,977
6,251
4,455
1,796
32.5%
U.
ly v. 2,725 hived 16,308 5,775
3,841
8,456
32.2%
35.4%
f
f5,731
arc 34.8% 16,226 6,050
in Tu 5,26042 2,808
2,146
8,068
37.3%
d
cite6,961 6-153 2,860
2,006
4,101
41.1%
17,251
7,641
44.3%
o. 1
2,302 N7,479
4,082
3,397
45.4%
22,986
11,098
48.3%

Immigration Judge Granted Bond*

http://trac.syr.edu/immigration/reports/438/[9/8/2017 12:31:45 PM]

6,820

Total

1995

Fiscal Year
Case Completed

Appendix Table 3. Completed Immigration Court Cases Where Initially Detained Individual Had Been Released

* Where an individual had their custody reviewed more than once, the outcome at the last custody hearing is used.
** Covers the first 10 months of FY 2016 (through the end of July).

$8,000 0.7%

$5,000 0.8%

$5,000 0.5% 10.0%

$5,000 0.5% 10.9%

$5,000 1.1% 12.5%

$5,000 1.4% 10.3%

$5,000 1.8% 10.4%

16,089

2008

$5,000 3.2% 12.6%

15,870

2007

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13,485

2016***

1,463

2,028
12,022

13,241
10,009

11,391
2,010

1,850
16.7%

14.0%
38,770

44,280
7,912

10,379
20.4%

23.4%

5,680
6,249
8,456

1996

1997

1998
8,068

6,961

1999

2000

1,734

1,142

1,457

1,272

Ordered
Deported

6,722

5,107

4,223

3,167

Percent Stay
in U.S.

20.5%

18.3%

25.7%

28.7%

8,351
9,449
10,226
12,914
15,627
14,268
13,225
12,012

2009

2010

2011

2012

2013

2014

2015

2016**

8,040

9,031

9,158

8,814

6,135

4,437

4,415

3,156

2,703

1,528

1,862

3,972

4,194

5,110

6,813

6,779

5,789

5,034

5,195

5,318

5,433

6,206

66.9%

68.3%

64.2%

56.4%

47.5%

43.4%

46.7%

37.8%

33.7%

22.0%

23.1%

http://trac.syr.edu/immigration/reports/438/[9/8/2017 12:31:45 PM]

Report date: September 14, 2016

* Covers deportation and removal proceedings. Slight difference between the totals in Appendix Tables 3 and 4 are because a
small number of non-deportation/removal case types handled by the Immigration Court are not included in this table.
** Covers the first 10 months of FY 2016 (through the end of July).

8,021

2008

2007

2006

2005

2004

2003

2002

2001

Stay in U.S.

ity
ecur
dS
7,479
1,959
5,520
elan 26.2% 2017
om er,20.2%
8,
9,719
1,965
7,754 f H
b
to
'7,801
ep
em
10,156
2,355
23.2%
S. D on Sept
. U.
7,308
1,848
25.3%
yv
ed 5,460
Tuffl 1,697 rchiv 4,099
5,796
29.3%
in
2a
ited 6-15342,106
3,564
37.1%
c5,670
1
7,160 o.
2,363
4,797
33.0%
N

4,439

Total*

1995

Fiscal Year
Case
Completed

Appendix Table 4. Outcome in Immigration Deportation Proceedings
Where Individual Released After Judge Granted Bond

* This table covers only those cases where Immigration Court proceedings were completed. Thus, the outcome is known and
whether the decision was made "in absentia" can be determined. Individuals granted bond by Immigration judge where cases
are still pending are not included.
** Based on court records that decision was made "in absentia" when individual failed to appear for their court hearing.
*** Covers the first 10 months of FY 2016 (through the end of July).

15,269

2015

What Happens When Individuals Are Released On Bond in Immigration Court Proceedings?

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 468 of 470

http://trac.syr.edu/immigration/reports/438/[9/8/2017 12:31:45 PM]

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cite
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Copyright 2016, TRAC Reports, Inc.

What Happens When Individuals Are Released On Bond in Immigration Court Proceedings?

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 469 of 470

Case: 16-15342, 09/13/2017, ID: 10578647, DktEntry: 35-2, Page 470 of 470

Probation and Parole
in the United States, 2015
May 2015
Summary | NCJ 250230 | December 2016

Bureau of Justice Statistics

A

n estimated 4.65 million adults—or about 1 in 53
adults—were on probation, parole, or some other
form of post-prison supervision at yearend 2015.
This was a decrease of about 62,300 offenders from yearend
2014 and the lowest number of adults under community
supervision since 2000.

Adults under community supervision on December 31 and
annual percent change, 2005−2015

Yearend population (in millions)
6

Annual percent change
2

Annual percent change
5

Community supervision definitions
Probation is a court-ordered period of correctional
supervision in the community and is generally used as an
alternative to incarceration. Parole is a period of conditional
supervised release in the community following a prison
term. Probationers accounted for the majority (81%) of
adults under community supervision, and the probation
population was more than four times the parole population.

Recent probation and parole changes

1

4

0

3

-1

2

-2

1

-3
ity
A decrease in the probation population (down by about
ecur
nd S
7
78,700 offenders) contributed to all of the decline in the
0
mela r, 8, 201
o 2007 2008 2009 2010 2011 2012 2013 2014 2015 -4
adult community corrections population from 2014 to 2015.
2005
of H2006 mbe
The decline was slightly offset by an increase in the parole Dep't
pte
Note: Estimates are based on most
population, which grew from about 857,700 to 870,500
U.S. d on Sepublished statistics. recent data and may differ from
previously
y v.
during that period.
chive Source: Bureau of Justice Statistics, Annual Probation Survey and Annual
Tuffl

d in

2 ar

34
Entries onto and exits off ofiprobation declined by more
c te
6-15
12015 (4.01 million).
than 4% from 2014 (4.19 million).to
No
Probation entries declined by about 5% during this period,
down from 2.07 million to 1.97 million. Probation exits
declined by about 4% from 2014 (2.13 million) to 2015
(2.04 million). Entries to parole increased by 14,100 from
2014 to 2015, and exits from parole rose by 10,900.
Long-term community supervision trends

Since 2005, the rate of exits from probation has remained
consistent, ranging from 52 to 55 per 100 probationers. The
completion rate (turnover due to completing the term of
supervision either through a full-term completion or early
discharge) was 33 exits per 100 during 2015, which was
similar to the rate observed in 2005 (32 per 100) and down
slightly from rates that had been consistent since 2009 (35 to
36 per 100).
With the exception of 2009 and 2013, each year from
2005 to 2015 saw an increase in the number of individuals
supervised on parole. The parole exit rate increased from
33 exits per 100 parolees in 2014 to 54 exits per 100 in 2015.
The rate had remained between 35 and 32 exits per 100
parolees since 2008. In 2015, the rate of reincarceration was
14 exits per 100. The rate remained unchanged from 2013 to
2014 but declined from 25 per 100 in 2005.

Parole Survey, 2005−2015.

Characteristics of probationers and parolees
While the majority of probationers were male, the
percentage of females on probation increased from 2005
(23%) to 2015 (25%). In both 2015 and 2005, more than half
(55%) of probationers were non-Hispanic white, 30% were
non-Hispanic black, and 13% were Hispanic or Latino.
During that same period, probationers supervised for a
felony offense increased from 50% in 2005 to 57% in 2015.
The majority (87%) of parolees were male in 2015, which
was similar to percentages observed in both 2014 and 2005
(88% each). In 2015, 44% of parolees were white, 38% were
black, and 16% were Hispanic or Latino. The number of
parolees being supervised for a drug offense decreased from
37% in 2005 to 31% in 2015. The percentage of parolees
being supervised for a violent crime increased from 26% to
32% during that period.
The full report (Probation and Parole in the United States, 2015,
NCJ 250230), related documents, and additional information about
the Bureau of Justice Statistics can be found at www.bjs.gov.

BUREAU OF JUSTICE STATISTICS | Office of Justice Programs | U.S. Department of Justice