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For background on the U.S. Immigration and Customs Enforcement detention inspection system, read the full October 2015 report by the National Immigrant Justice Center and Detention Watch Network: Lives in Peril: How Ineffective Inspections Make ICE Complicit in Detention Center Abuse.


Facility Profile

Detention Standards (as of 2012):

2008 PBNDS (Performance-Based National Detention Standards)

Facility Type:

IGSA (Intergovernmental Service Agreements)

2012 ICE Average Daily Population:

224

 

2011 ERO
(Office of Enforcement and Removal Operations)

2012 ERO
(Office of Enforcement and Removal Operations)

Private Contract
 Inspector:

MGT

Private Contract
Inspector:

Nakamoto

Rating:

Meets
Standards

Rating:

Does Not
Meet Standards

Deficient Standards:

0

Deficient Standards:

1

Deficient
Components:

8

Deficient
Components:

9

Photo credit: NIJC

The lack of consistency and accountability in the ERO inspections process is apparent in its 2011 and 2012 audits of the Tri-County Detention Center (since renamed Pulaski County Jail) in Ullin, Illinois.1 According to the 2012 Expose and Close report by the Detention Watch Network and National Immigrant Justice Center, grievances were largely ignored, essential medical care was delayed, and general overcrowding was exacerbated by inadequate medical staffing.

In 2011, the ERO inspection marked the facility as having met its obligations under the 2008 PBNDS. However, internal inconsistencies raise concerns as to how meticulous the inspectors were in conducting their reviews. For example, although the hold rooms standard and its components were marked as N/A (not applicable), it was checked off as having met standards in the final summary of the inspectors’ findings. In comments, the inspectors also noted that there were no canines at the facility yet in one of their comments (a portion of which has been redacted), they wrote that “At this time there was a minor altercation between the canine and an ICE detainee which did not result in any serious injury.”

Medical Care and Lack of Accountability

If internal inconsistencies were unsettling in the 2011 inspection, they intensified in the 2012 ERO audit. Despite the Tri-County Detention Center receiving a “does not meet standards” rating according to the lead compliance inspector’s recommended rating at the conclusion of the 2012 inspection worksheet, the memorandum addressed to Field Office Director Ricardo Wong on May 29, 2012, which is affixed at the beginning of the inspection file, reflects an unexplained change in the final determination. The memo states that according to its final rating, the facility “meets standards.” The lead compliance inspector attributes the deficient finding to the detention center’s failure to comply with a mandatory component under the Medical Care standard, specifically concerning oversight over needles. The 2012 inspectors wrote, “[o]nce needles and syringes are placed in the medication cart, no further accountability is maintained. While the current inventory of the bulk stock was inaccurate, the HSA [Health Services Administrator] had conducted an inventory two days ago which showed significant discrepancies in the inventories of Insulin syringes, 5cc syringes with needles, and 3cc syringes with needles.”

The facility also believed its medical staff to be adequate to serve its population, despite the fact that 185 medical cases were referred for outside medical care in 2011 and 411 were referred in 2012. The ERO inspections provide no analysis of whether the medical staff were meeting the actual needs of the individuals detained at Tri-County.

Environmental Health and Safety

Additionally problematic in the 2012 ERO audit are the various components which were not found deficient but should have required follow-up before being marked as having met standards. In particular, a new fire alarm system had been recently installed but had yet to be inspected by the fire marshal and emergency generators did not cover critical areas such as administration, medical, booking, and food service. But because facility staff indicated that they had plans to address these problems, the environmental health and safety standard was preemptively marked as having been fulfilled.

Telephone Access

Photo credit: NIJC

Collectively, the inspections reports for Tri-County present a puzzling picture of the reality in the facility. In early 2012, Senator Richard Durbin (D-IL) visited the facility and expressed his shock at the conditions—particularly referencing the high price of phone calls and inoperable telephones2—yet the 2011 and 2012 ERO inspections reflect no issues with the telephone system, finding that the standard was met and even exceeded. Of course, as discussed earlier, the ERO inspections process leaves no room to even consider whether the exorbitant cost of phone calls undermines the PBNDS’s phone access requirements.

Grievance Procedures

Also troubling are the facility’s grievance procedures. In the 2011 inspection, a component regarding the absence of a secure box through which detained individuals could drop in written comments to communicate with ICE staff was marked deficient but was included in a corrective action plan with a deadline of later that year. Prior to the box’s existence, “ICE Staff receive[d] all requests from facility staff.” With this lack of confidentiality, it is not surprising that there were only six grievances in 2011 and 10 in 2012.

 

Endnotes

1. There was no ODO inspection.

2. Expose & Close: Tri-County Detention Center, Illinois, at 5.