Banking On Detention
2016 Update

About Us

Detention Watch Network (DWN) works through the collective strength and diversity of its members to
expose and challenge injustices of the U.S. immigration detention and deportation system and
advocate for profound change that promotes the rights and dignity of all persons.
Website:

http://detentionwatchnetwork.org

The Center for Constitutional Rights (CCR) is dedicated to advancing and protecting the rights
guaranteed by the U.S. Constitution and the Universal Declaration of Human Rights. Founded in 1966
by attorneys who represented civil rights movements in the South, CCR is a non-profit legal and
educational organization committed to the creative use of law as a positive force for social change.
Website:

http://ccrjustice.org

Primary authors:

Dawy Rkasnuam and Conchita Garcia of Detention Watch Network

Contributions by:

Mary Small and Silky Shah of Detention Watch Network and Ghita Schwarz
and Ian Head of Center for Constitutional Rights

Design:

Strictly District, LLC.

Translation:

Eleana Gómez

Cover Image:

Alonso Yáñez/La Opinión

© 2016, Detention Watch Network. All Rights Reserved.

Introduction

Photo: Steve Pavey

The United States has the largest immigration detention infrastructure in the world, with hundreds of
thousands of people passing through detention each year. The large scope of the system is in part due
to an arbitrary quota created by Congress in 20091 which, in its current version, requires Immigration
and Customs Enforcement (ICE) to maintain a minimum of 34,000 detention beds at all times.2 This
policy, known as the detention bed quota, is unprecedented; no other law enforcement agency operates on a quota system for the number of people to incarcerate. It is also unethical and financially
wasteful, costing American taxpayers over $2 billion a year3 and separating hundreds of thousands of
families.
In addition to the national quota, the immense size of the U.S.’s immigration detention system is
bolstered by a series of local-level quotas, written into detention facility contracts as “guaranteed
minimums.” Guaranteed minimums, which appear mostly in ICE contracts with private contractors
(though some exist with local governments), guarantee that ICE will pay for a minimum number of
people to be detained at any given time. Because the government seeks to avoid paying for detention
space that isn’t being used,4 guaranteed minimums are essentially local “lockup” quotas that influence
ICE’s decision-making about immigration enforcement, whether or not people will be released, where
people will be detained, and ultimately, who will profit or benefit from their detention.
The first national snapshot of local lockup quotas throughout the immigration detention system was
exposed in Banking on Detention: Local Lockup Quotas and the Immigrant Dragnet, published by
Detention Watch Network (DWN) and the Center for Constitutional Rights (CCR) in June 2015.5 Since
then, additional documents have become available which cast further light on local lockup quotas.
First, these quotas are even more widespread than previously reported, covering at least 24 detention
facility contracts. Second, while the overwhelming majority are found in ICE contracts with private
companies, local lockup quotas do exist in a limited number of contracts with public entities. Third,
these local lockup quotas exist in two of the three family detention center contracts. This report update
aims to expose newly discovered guaranteed minimums, clarify the relationship between local lockup
quotas and privatization, and explore in more depth the particular barriers to transparency that impede
access to data and obscure the scope of the problem.

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Methodology
The additional guaranteed minimums included in this report come from documents obtained through
the Freedom of Information Act (FOIA), which allows the public to request access to records from
federal agencies.6 The documents come from three sources: a subset of contracts recently obtained
through FOIA litigation by the National Immigrant Justice Center (NIJC),7 a different subset of contracts
ICE made available through its FOIA Library,8 and a spreadsheet obtained by the Transactional
Records Access Clearinghouse (TRAC) at Syracuse University through a FOIA request.9 While this
report offers an updated tally of the number and location of guaranteed minimums across the country,
the list likely remains incomplete because the document sets are incomplete, heavily redacted, and not
always up to date. The scattered and incomplete nature of the information is the result of larger transparency failures detailed below.
For this report update, as in the initial report, we conducted a comprehensive review of all available
contracts to identify guaranteed minimums. These included contracts for the management of entire
detention facilities, as well as contracts for detention-related services such as security services or
transportation. In some cases, the number of people included in the guaranteed minimum was visible;
in others we were able to calculate the number using other available data; and in the remaining cases
there is still uncertainty about how many detained people have been promised to the subcontractor.
We have included in our analysis all facilities for which we found a guaranteed minimum, and have
noted those for which we are uncertain about the number.

Taken from ICEʼs Broward Transitional
Center contract with The GEO Group.

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Local Lockup Quotas
Guaranteed minimums require ICE to pay contractors for a minimum number of detention beds
regardless of how many people are detained. This means that contractors receive a set payment for a
minimum number of detention beds even if some of the detention beds are empty. Because ICE does
not want to appear wasteful or inefficient with the number of beds it must pay for, these contractual
provisions create an incentive to detain as many people as possible in facilities with guaranteed minimums. These guaranteed minimums essentially function as a local lockup quota. Through this
perverse incentive, guaranteed minimums act as a mechanism through which other entities—mostly
private prison companies—influence ICE’s decisions regarding how many people are detained, where
they are detained, and how long they are kept in detention.
When Banking on Detention was initially published in 2015, available information indicated that local
lockup quotas existed exclusively in contracts with private entities that either operated detention
facilities or provided detention-related services. New information reveals that there are a small number
of guaranteed minimums in public contracts as well. This indicates that guaranteed minimums are a
more common contracting mechanism than previously thought. However, while this report update
reveals four guaranteed minimums in public contracts, they represent only a small fraction of the total
known guaranteed minimums and do not lessen the concern that private companies influence ICE’s
practices. Guaranteed minimums or local lockup quotas account for at least 12,821 of the 34,000
beds funded by the detention bed quota. Of these 12,821, 93 percent, or 11,936, exist in facilities that
contract with private companies.
In addition to the fifteen guaranteed-minimum facilities exposed in Banking on Detention, this report
documents an additional nine contracts with guaranteed minimums. These include Berks Family
Residential Center, Calhoun County Correctional Center and the Dearborn Police Department (which
have a joint contract and thus a shared guaranteed minimum), California City Correctional Facility,
Essex County Correctional Facility, Farmville Detention Center, T. Don Hutto Residential Center, Imperial Regional Detention Facility, Mesa Verde Detention Facility, and Monroe County Detention Center. All
nine contracts are intergovernmental service agreements (IGSAs); of the nine, five facilities have subcontracts with private companies.
Additionally, this report confirms the existence of local lockup quotas for families—at the Karnes
County Residential Center in Texas and the Berks Family Residential Center in Pennsylvania. The local
quota at Berks is an entirely new discovery, and it stands out as one of the four guaranteed minimums
found in public contracts where no private subcontractor is implicated. The presence of a local quota
at Karnes was noted in the original publication of Banking on Detention, but it was unclear whether the
local quota remained operative after the facility was converted from an all-male facility to a family
detention center in 2014. However, through the review of a newly-available 2015 contract, we can now
confirm the continuation of the guaranteed minimum. Thus, at least one private company, The GEO
Group, Inc. (GEO), is benefiting from a local lockup quota to detain mothers and children.

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“

“

93 percent of the total number of guaranteed
minimums exist in facilities with private contracts.

Guaranteed Minimums in Both Public & Private Facilities
SERVICE PROCESSING CENTER
(owned and operated by ICE, which
subcontracts with private companies
for services)

FACILITY NAME

CONTRACT DETENTION FACILITY
(owned and operated by a private
prison company)

INTERGOVERNMENTAL SERVICES AGREEMENT (IGSA)
(contract is with local government, which may subcontract
with private company to operate facility and/or for
detention-related services)

PRIVATE COMPANY INVOLVED

GUARANTEED MIN.

Adelanto Detention Facility

GEO

1,45510

Berks Family Residential Center

None

6011

Broward Transitional Center12

GEO

50013

Buffalo (Batavia) Service Processing Center

Akal-Akima JV

40014

Calhoun County Correctional Center & Dearborn Police Dept.

None

7515

California City Correctional Facility

CCA

10016

Denver (Aurora) Contract Detention Facility17

GEO

35018

El Paso Service Processing Center

Doyon-Akal JV

50019

Elizabeth Contract Detention Facility

CCA

28520

Essex County Correctional Facility

None

70021

Farmville Detention Center

Immigration Centers of America

50022

Florence Service Processing Center

Asset Protection & Security Services LP

37423

Houston Contract Detention Facility

CCA

75024

[T. Don] Hutto Residential Center

CCA

46125

Imperial Regional Detention Facility

Management and Training Corporation

64026

Jena/LaSalle Detention Facility & Alexandria Staging Facility

GEO

1,17027

Karnes County Residential Center

GEO

45628

Krome North Services Processing Center

Akima Global Services

45029

Mesa Verde Detention Facility

GEO

32030

Monroe County Detention Center

None

5031

Northwest Detention Center32

GEO

80033

Otay Detention Facility (Otay Mesa)

CCA

90034

Port Isabel Service Processing Center

Ahtna Technical Services, Inc.

80035

South Texas Detention Complex (Pearsall)36

GEO

72537

TOTAL

12,821

* Bold indicates either that the guaranteed minimum for the facility has been updated or that the facility was not included in the original report
* Italicized indicates that the guaranteed minimum appeared in a contract solicitation obtained from the federal website FedBizOpps.

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The updated table lays out the facilities with guaranteed minimums, the private company with which
they contract, and the best known guaranteed minimum amount. The GEO Group, Inc. (GEO), Corrections Corporation of America (CCA), Immigration Centers of America (ICA), and Management and
Training Corporation (MTC) operate detention facilities, while other private contractors provide detention-related services. As indicated by the table, GEO has more guaranteed minimums than any other
private company.

Buffalo/Batavia: 400

Northwest: 800

Essex: 700
Elizabeth: 285
Calhoun: 75
Calif. City: 100
Mesa Verde: 320

Berks: 60
Farmville: 500

Aurora: 350

Adelanto: 1,455
Otay Mesa: 900

Jena/LaSalle: 1,770

Imperial: 640
Florence: 374

El Paso: 500
Pearsall: 725

Houston: 750

Broward: 500
Krome: 450

Hutto: 461

Karnes: 456

Port Isabel: 800

* The map is divided by color into ICE’s Enforcement and Removal Operations (ERO) field office jurisdictions.

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Monroe County: 50

Absence of Transparency
The findings presented in Banking on Detention and this update provide only a partial understanding of
the scope and impact of guaranteed minimums. Due to ICE’s lack of transparency and the resulting
unavailability of data, it is currently unclear what percentage of detention facilities are subject to guaranteed minimums, what the costs of guaranteed minimums are, and the degree to which they influence ICE’s practices in controlling the pipeline into and out of detention. By obstructing access to its
contracts, ICE leaves the public with an incomplete understanding of how pervasive and harmful
guaranteed minimums truly are.
ICE demonstrates a lack of transparency at multiple levels, beginning with its failure to proactively
disclose contract information for detention facilities and services. The main avenue to information on
guaranteed minimums—and on detention contracts more generally—is through FOIA requests, which
can be costly and time-consuming both to the parties filing the requests and to the agency, in this
case ICE, which must process and respond to the requests. Another way to access contract
information is through FedBizOpps, the federal website that publishes contract solicitations,38 which
provides the best available information for facilities whose contracts are redacted or otherwise inaccessible through ICE. To date, nearly all data on guaranteed minimums have been obtained through
FOIA requests.39
When individuals or organizations do attempt to access information through FOIA requests, ICE resists
transparency by delaying its responses and then redacting most of the critical information from its
documents.40 In November 2013, DWN and CCR filed a FOIA request for access to information
pertaining to the national detention bed quota. ICE did not comply with this request until it was
required to do so by court order in July 2014, over seven months later.41 When ICE finally released
documents in response to the FOIA request, figures on government-contracted unit prices, bed-day
rates, and staffing plans were redacted. This redacted information, if disclosed, would clarify the cost
of detention in each facility and allow the public to better understand the fiscal and human impact of
detention quotas, including guaranteed minimums. Instead, ICE claims that such information constitutes “confidential or privileged information” that would cause substantial competitive harm to private
contractors if released to the public.42
As of June 2016, the appropriateness of ICE’s redactions is still pending in the federal district court for
the Southern District of New York. Notably, ICE’s legal position depends heavily on support from
private contractors themselves, who have submitted sworn declarations attesting to the need for
keeping the terms of government contracts secret. In the case of GEO, one of the largest private
prison contractors in the country, the support comes from a former ICE official, David Venturella, who
is now the Senior Vice President of Business Development at GEO.43 In December 2015, Venturella
submitted a declaration on behalf of GEO defending ICE’s decision to withhold information from its
FOIA document releases.44 This relationship between ICE and its private contractors attests to the

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“

“

By obstructing access to its contracts, ICE leaves the public with an incomplete
understanding of how pervasive and harmful guaranteed minimums truly are.

enormous influence that private prison companies have, not only on detention operations, but on
government transparency itself. The more the detention system relies on private corporations, the less
transparent it is. This is all the more reason to be concerned about the growing privatization of detention, which now accounts for roughly 62 percent of beds.45
ICE’s lack of transparency is especially troubling when looking at local quotas. To date, the majority of
guaranteed minimums have been found in private contracts, either with privately-operated detention
facilities or publicly-operated jails that subcontract to private companies for detention services, such
as guard services or facility operations and maintenance support.46 Given that ICE is contractually
obligated to pay for guaranteed minimums regardless of how many detention beds are filled, ICE has
an incentive to detain as many people as possible in privately-operated detention facilities. In addition
to the guaranteed minimum, to maximize efficiency, ICE takes advantage of “tiered pricing” where
available, which provides a discount to ICE for immigrants detained above the guaranteed minimum
amount.47 This results in ICE potentially changing its practices to satisfy the guaranteed minimum in
each facility, essentially helping private contractors secure profits. As discussed in Banking on
Detention, communications released by ICE through FOIA litigation indicate that officials make
significant efforts to steer immigrants to facilities with guaranteed minimums.48
Guaranteed minimums thus subject detention and placement decisions—which have enormous
human impact on individuals detained, as well as their families and communities—to cost considerations that benefit private contractors. Without transparency and accountability, we cannot determine
the full extent of guaranteed minimums and the degree to which private prison companies influence
ICE and benefit from detention policies. However, by failing to disclose contracts and resisting
attempts to access information, ICE demonstrates that it is more accountable to private prison companies than to the public, whose tax dollars fund the guaranteed minimums.

T. Don Hutto Residential Center

Photo: Cristina Parker

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Conclusion
Immigration detention places people in inhumane and sometimes even fatal conditions. In February
2016, DWN collaborated with the American Civil Liberties Union (ACLU) and the National Immigrant
Justice Center (NIJC) to publish Fatal Neglect: How ICE Ignores Deaths in Detention, a report exposing
medically negligent deaths in ICE custody. Of the eight deaths discussed in the report, five occurred at
detention facilities known to have guaranteed minimums.49 These deaths, and the corresponding
negligence at the facilities where detained people died, have had no impact on the advantages that
private companies enjoy from guaranteed minimums. With guaranteed minimums incentivizing ICE to
pursue more aggressive enforcement and create barriers to people’s release from detention, the end
result is an inhumane, quota-based immigration detention system that functions as taxpayer-funded
profit insurance for private prison companies.
Since the release of Banking on Detention, Representative Ted Deutch (D-FL) and eight additional
co-sponsors introduced the Protecting Taxpayers and Communities from Local Detention Quotas Act,50
which would prevent ICE from participating in any legal agreement that mandated a bed quota at the
local level. In addition to the representatives’ statements on the quotas being “inhumane,” Representative
Deutch stated that by eliminating the national bed quota, “Congress could save taxpayers nearly $15
billion over the next decade.”51 Because ICE spends over $2 billion each year on detention, the elimination of national and local quotas, with a corresponding decrease in detention, could save significant
tax dollars and prevent immeasurable human suffering.52
There is a growing consensus that the mass detention of immigrants is unnecessary and inhumane.
The U.S. government should move towards ending the use of immigration detention altogether. Unfortunately, corporate interests and the absence of job growth for the constituents of many local governments that contract with ICE have converted the detention of human beings into a market-based
activity. Detention capacity and arbitrary quotas must never be a factor in making decisions regarding
immigration enforcement.
As immediate next steps, this report reiterates many of the recommendations from Banking on Detention and calls on:
•
•
•
•

•
•

ICE to remove guaranteed minimums, tiered pricing, or any other provisions that could
function as a local lockup quota, from all detention contracts.
ICE to make all information pertaining to detention contracts and the bidding process publicly
accessible and transparent.
ICE to stop contracting with private companies that lobby to pervert public policy via
guaranteed minimums and other contractual giveaways.
ICE to bar (1) the transfer of individuals between detention facilities; (2) the manipulation of
bond or parole determinations; and (3) the initiation of enforcement actions based in whole or
in part on empty detention beds, unmet guaranteed minimums, or tiered pricing.
Congress to remove the national detention bed quota from the FY 2017 Department of
Homeland Security (DHS) Appropriations bill.
Congress to pass the Protecting Taxpayers and Communities from Local Detention Quotas
Act, which would prevent ICE from participating in any legal agreement that mandated a bed
quota at a local level.

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Endnotes
1. Department of Homeland Security Appropriations Act of 2010 (October 28, 2009). Government Printing Office.
Available at https://www.gpo.gov/fdsys/pkg/PLAW-111publ83/pdf/PLAW-111publ83.pdf
2. Ibid.
3. Department of Homeland Security. “Congressional Budget Justification FY 2017—Volume II.” Available at
https://www.dhs.gov/sites/default/files/publications/FY%202017%20Congressional%20Budget%20Justification%20-%20Volume%202_1.pdf
4. Government Accountability Office. Immigration Detention: Additional Actions Needed to Strengthen Management and Oversight of
Facility Costs and Standards, p. 18 (October 2014). Available at http://www.gao.gov/assets/670/666467.pdf
5. Detention Watch Network and Center for Constitutional Rights. Banking on Detention: Local Lockup Quotas and the Immigrant
Dragnet (2015). Available at
https://www.detentionwatchnetwork.org/sites/default/files/reports/DWN%20CCR%20Banking%20on%20Detention%20Report.pdf
6. Department of Justice. “What is FOIA?” FOIA.gov. Available at http://www.foia.gov/about.html
7. National Immigrant Justice Center. “Immigration Detention Transparency and Human Rights Project.”
Available at http://immigrantjustice.org/transparencyandhumanrights
8. Department of Homeland Security, Immigration and Customs Enforcement. FOIA Library.
Available at https://www.ice.gov/foia/library
9. Transactional Records Access Clearinghouse. “Detention Facility Reports: Departures from ICE Detention,” Syracuse University
(April 12, 2016). Available at http://trac.syr.edu/immigration/detention/exit.shtml
10. Transactional Records Access Clearinghouse. “Detention Facility Reports: Departures from ICE Detention,” Syracuse University
(April 12, 2016). Available at http://trac.syr.edu/immigration/detention/exit.shtml
11. NIJC v. DHS. 12-cv-05358 (2012). ICE Bates No. ICE.2012FOIA3030000262, 0267.
Available at http://www.documentcloud.org/documents/1636098-berks-county-pa-igsa-modification.html
12. NIJC v. DHS. 12-cv-05358 (2012). ICE Bates No. ICE2012FOIA03030.0032821.
Available at http://www.documentcloud.org/documents/2104924-broward-transitional-facility-cdf-contract.html.
13. Solicitation No. HSCEDM-09-R-00005 for a contract detention facility in the Miami area (January 28, 2009). Available at
https://www.fbo.gov/?s=opportunity&mode=form&id=da740c041090f54247b2055e7dfbe71c&tab=core&_cview=0; Contract No.
HSCEDM-09-D-00006 for a four-month extension (August 28, 2014). Available at
https://www.fbo.gov/index?s=opportunity&mode=form&id=9f2b96fae5bba23fca82dc824e94283d&tab=core&_cview=0;
14. Transactional Records Access Clearinghouse. “Detention Facility Reports: Departures from ICE Detention,” Syracuse University
(April 12, 2016). Available at http://trac.syr.edu/immigration/detention/exit.shtml; Akal Security and Akima Global Services Joint
Venture announcement on taking over operations at the Buffalo facility on February 1, 2015.
Available at http://detentionofficerjobs.com/
15. Transactional Records Access Clearinghouse. “Detention Facility Reports: Departures from ICE Detention,” Syracuse University
(April 12, 2016). Available at http://trac.syr.edu/immigration/detention/exit.shtml
16. NIJC v. DHS. 12-cv-05358 (2012).
Available at http://www.documentcloud.org/documents/1644550-california-city-ca-contract-cca.html, page 2.
17. NIJC v. DHS. 12-cv-05358 (2012). ICE Bates No. ICE2012FOIA03030.0030609.
Available at http://www.documentcloud.org/documents/1699760-denver-county-jail-geo-group-2011-cdf-contract.html
18. Transactional Records Access Clearinghouse. “Detention Facility Reports: Departures from ICE Detention,” Syracuse University
(April 12, 2016). Available at http://trac.syr.edu/immigration/detention/exit.shtml
19. Transactional Records Access Clearinghouse. “Detention Facility Reports: Departures from ICE Detention,” Syracuse University
(April 12, 2016). Available at http://trac.syr.edu/immigration/detention/exit.shtml; contract was extended to November 30, 2015.
Available at http://www.doyongovgrp.com/security/security-contracts-vehicles/ and
http://government-contracts.insidegov.com/l/2559287/HSCEDM09D00004

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20. Transactional Records Access Clearinghouse. “Detention Facility Reports: Departures from ICE Detention,” Syracuse University
(April 12, 2016). Available at http://trac.syr.edu/immigration/detention/exit.shtml; NIJC v. DHS. 12-cv-05358 (2012). ICE Bates No.
ICE2012FOIA03030.0029953.
Available at http://www.documentcloud.org/documents/1735386-elizabeth-contract-detention-facility-contract-cdf.html
21. The IGSA contains guaranteed minimum language and specifies that “the Government will maintain an Average Daily Population
(ADP) of 700” people in ICE custody. NIJC v. DHS. 12-cv-05358 (2012). ICE Bates No. ICE2012FOIA3030.000524 (p. 6).
Available at http://www.documentcloud.org/documents/1658066-essex-county-igsa-contract.html
22. Transactional Records Access Clearinghouse. “Detention Facility Reports: Departures from ICE Detention,” Syracuse University
(April 12, 2016). Available at http://trac.syr.edu/immigration/detention/exit.shtml; NIJC v. DHS. 12-cv-05358 (2012). ICE Bates No.
ICE2012FOIA3030000804.
Available at http://www.documentcloud.org/documents/1672361-farmville-va-igsa-and-transportation-contract.html
23. Transactional Records Access Clearinghouse. “Detention Facility Reports: Departures from ICE Detention,” Syracuse University
(April 12, 2016). Available at http://trac.syr.edu/immigration/detention/exit.shtml; NIJC v. DHS. 12-cv-05358 (2012). ICE Bates No.
ICE2012FOIA03030.000339.
Available at http://www.documentcloud.org/documents/2157358-florence-correctional-center-az-cca-2009-cdf.html
24. Transactional Records Access Clearinghouse. “Detention Facility Reports: Departures from ICE Detention,” Syracuse University
(April 12, 2016). Available at http://trac.syr.edu/immigration/detention/exit.shtml
25. NIJC v. DHS. 12-cv-05358 (2012), p. 3.
Available at http://www.documentcloud.org/documents/1672355-hutto-county-corectional-center-williamson.html
26. Transactional Records Access Clearinghouse. “Detention Facility Reports: Departures from ICE Detention,” Syracuse University
(April 12, 2016). Available at http://trac.syr.edu/immigration/detention/exit.shtml
27. Transactional Records Access Clearinghouse. “Detention Facility Reports: Departures from ICE Detention,” Syracuse University
(April 12, 2016). Available at http://trac.syr.edu/immigration/detention/exit.shtml; DWN v. ICE, No. 14-cv-583 LGS (2013), Bates
No. ICE 2014FOIA03585.001228-001789 (minimum stated on ICE Bates No. 001318, 001454, 001578, 001587). Available at
http://ccrjustice.org/sites/default/files/attach/2015/06/DWN%20v%20ICE%20FOIA%20-%20ICE%201228-1789.pdf
28. “Karnes TX IGSA Contract and Wackenhut GEO Subcontract,” p. 159, 161.
Available at http://www.documentcloud.org/documents/2837201-Karnes-TX-IGSA-Contract-and-Wackenhut-GEO.html
29. Transactional Records Access Clearinghouse. “Detention Facility Reports: Departures from ICE Detention,” Syracuse University
(April 12, 2016). Available at http://trac.syr.edu/immigration/detention/exit.shtml; Krome Service Processing Center Contract No.
HSCEDM-13-R-00001 for detention management, transportation and food services (April 11, 2014), citing to the original solicitation. Available at https://www.fbo.gov/?s=opportunity&mode=form&id=406cf61548170f006941dfc6580e0858&tab=core&_cview=1;
Akima Global Services LLC announcement of winning the 10-year contract for full detention services at Krome. Available at
http://www.akimaglobal.com/2014/05/13/dhs-awards-akima-global-services-contract-to-support-krome-detention-center/; Prior to
Akima, Krome was contracted with Doyon-Akal JV with a guaranteed minimum of 250. Available at
https://www.ice.gov/doclib/foia/contracts/hscedm-08-d-00003-doyonakaljv.pdf
30. Transactional Records Access Clearinghouse. “Detention Facility Reports: Departures from ICE Detention,” Syracuse University
(April 12, 2016). Available at http://trac.syr.edu/immigration/detention/exit.shtml; NIJC v. DHS. 12-cv-05358 (2012), p. 13. Available
at http://www.documentcloud.org/documents/2631228-Mesa-Verde-CA-IGSA-Contract.html
31. Transactional Records Access Clearinghouse. “Detention Facility Reports: Departures from ICE Detention,” Syracuse University
(April 12, 2016). Available at http://trac.syr.edu/immigration/detention/exit.shtml
32. NIJC v. DHS. 12-cv-05358 (2012). ICE Bates No. ICE2012FOIA03030.0031543-4.
Available at http://www.documentcloud.org/documents/1813479-northwest-denteion-center-tacoma-wa-cdf-contract.html.
33. Solicitation No. HSCEDM-15-R-00001 for a contractor owned and contractor operated detention facility (November 20, 2014).
Available at https://www.fbo.gov/index?s=opportunity&mode=form&tab=core&id=5070ee30860d8093cb1f7abe0aa9f741&_cview=0; The guaranteed minimum was increased from 750. See
Henterly, Lael. The Seattle Globalist. “Fewer Immigrants filling Tacoma detention center, as doubts grow about new contract.” (April
2, 2015). Available at http://seattleglobalist.com/2015/04/02/tacoma-detention-center-immigrant-ice-contract/35475; In 2009, the
guaranteed minimum was 1181. See Krell, Alexis. The News Tribune. “GEO expected to get new contract to run Tacoma immigrant
detention ctenter.” (March 30, 2015). Available at http://www.thenewstribune.com/news/local/crime/article26273296.html
34. San Diego Otay Mesa Contract No. ODT-5-C-0003 for comprehensive secure detention services (July 1, 2005), p. 2. Available at
http://www.justice.gov/archive/ofdt/otay-mesa-contract.pdf; CCA is building a new facility with greater detention capacity to replace
San Diego. Available at https://www.cca.com/insidecca/a-new-facility-is-underway; Another facility in the area, El Centro SPC
(closed down in 2014), was managed by Asset Protection & Security Services LLP and had a guaranteed minimum of 225 beds.
Contract No. HSCEDM-09-D-00001 for detention services (May 22, 2009), citing to the original solicitation. Available at
https://www.fbo.gov/?s=opportunity&mode=form&tab=core&id=bab95d17227113f8db7e219f9df5fc06&_cview=0

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35. Transactional Records Access Clearinghouse. “Detention Facility Reports: Departures from ICE Detention,” Syracuse University
(April 12, 2016). Available at http://trac.syr.edu/immigration/detention/exit.shtml
36. NIJC v. DHS. 12-cv-05358 (2012). ICE Bates No. ICE2012FOIA03030.0032752.
Available at http://www.documentcloud.org/documents/1813514-south-texas-detention-complex-cdf-contract.html.
37. South Texas Detention Center Contract No. ACD-4-C-0001 for guard services with The Geo Group (June 19, 2008), p. 11.
Available at https://www.ice.gov/doclib/foia/contracts/geogrouphscedm09f00001.pdf
38. Contract solicitations are found on the Federal Business Opportunities website. Available at https://www.fbo.gov/
39. Center for Constitutional Rights. Detention Watch Network v. Immigration and Customs Enforcement (2013). Available at
http://ccrjustice.org/home/what-we-do/our-cases/detention-watch-network-dwn-v-immigration-customs-and-enforcement-ice-and;
National Immigrant Justice Center. National Immigrant Justice Center v. Department of Homeland Security (2012). Available at
http://www.immigrantjustice.org/transparencyandhumanrights; Department of Homeland Security, Immigration and Customs
Enforcement. FOIA Library. Available at https://www.ice.gov/foia/library
40. Government agencies can redact information requested through FOIA if such information falls under one of the nine exemption
categories. Department of Justice. “Frequently Asked Questions.” FOIA.gov. Available at http://www.foia.gov/faq.html#exemptions
41. Detention Watch Network, Center for Constitutional Rights v. United States Immigration and Customs Enforcement, Department of
Homeland Security (2015), 75 14-CV-583 1, United States District Court, Southern District of New York, p. 2. Available at
https://ccrjustice.org/sites/default/files/attach/2016/01/Dkt%2075%20b4%20SJ%20Mem%20of%20Law%2011-17-15.pdf
42. Exemption 4 of FOIA applies to “trade secrets or commercial or financial information that is confidential or privileged.” Department
of Justice. “Frequently Asked Questions.” FOIA.gov. Available at http://www.foia.gov/faq.html#exemptions; Detention Watch
Network, Center for Constitutional Rights v. United States Immigration and Customs Enforcement, Department of Homeland
Security (2015) 75 14-CV-583 1, United States District Court, Southern District of New York, p. 5,
https://ccrjustice.org/sites/default/files/attach/2016/01/Dkt%2075%20b4%20SJ%20Mem%20of%20Law%2011-17-15.pdf
43. The GEO Group, Inc. “Management Team.” Available at http://www.geogroup.com/David_J__Venturella
44. Center for Constitutional Rights. “Immigration Detention Bed Quotas: Private Prison Corporations, Government Collude to Keep
Contracts Secret; Undue Corporate Influence Seen in FOIA Redactions, Attorneys Say” (2015).
Available at http://ccrjustice.org/home/press-center/press-releases/immigration-detention-bed-quotas-private-prison-corporations
45. Grassroots Leadership. Payoff: How Congress Ensures Private Prison Profit with an Immigrant Detention Quota (2015). Available
at http://grassrootsleadership.org/reports/payoff-how-congress-ensures-private-prison-profit-immigrant-detention-quota
46. Detention Watch Network and Center for Constitutional Rights. Banking on Detention: Local Lockup Quotas and the Immigrant
Dragnet (2015), p. 3, 7. Available at
https://www.detentionwatchnetwork.org/sites/default/files/reports/DWN%20CCR%20Banking%20on%20Detention%20Report.pdf
47. Banking on Detention: Local Lockup Quotas and the Immigrant Dragnet (2015), p. 6.
48. Detention Watch Network and Center for Constitutional Rights. Banking on Detention: Local Lockup Quotas and the Immigrant
Dragnet (2015), pp. 6-7, 9. Available at
https://www.detentionwatchnetwork.org/sites/default/files/reports/DWN%20CCR%20Banking%20on%20Detention%20Report.pdf
49. The five deaths occurred at Denver Contract Detention Facility in Aurora, CO; Farmville Detention Center in Farmville, VA;
Adelanto Detention Facility in Adelanto, CA; Elizabeth Detention Center in Elizabeth, NJ; and El Paso Processing Center in
El Paso, TX. Fatal Neglect: How ICE Ignores Deaths in Detention (2016).
Available at https://www.aclu.org/sites/default/files/field_document/fatal_neglect_acludwnnijc.pdf
50. Deutch, Theodore, Bill Foster, and Adam Smith. H.R.2808 - 114th Congress (2015-2016): Protecting Taxpayers and Communities
from Local Detention Quotas Act (2015). Available at https://www.congress.gov/bill/114th-congress/house-bill/2808/text
51 Office of U.S. Representative Ted Deutch. “PRESS RELEASE: U.S. Reps. Ted Deutch, Bill Foster, and Adam Smith Introduce Bill
Banning Local Immigrant Detention Quotas” (June 18, 2015). Available at
http://teddeutch.house.gov/news/documentsingle.aspx?DocumentID=398445
52. Department of Homeland Security. “Congressional Budget Justification FY 2017—Volume II.” Available at
https://www.dhs.gov/sites/default/files/publications/FY%202017%20Congressional%20Budget%20Justification%20-%20Volume%202_1.pdf

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