U.S. Department of Homeland Security
Immigration and Customs Enforcement
Office of Professional Responsibility
Inspections and Detention Oversight
Washington, DC 20536-5501

Office of Detention Oversight
Compliance Inspection
Enforcement and Removal Operations
Miami Field Office
Glades County Detention Center
Moore Haven, Florida

October 25 - 28, 2011

FOR INTERNAL USE ONLY. This document may contain sensitive commercial, financial, law
enforcement, management, and employee information. It has been written for the express use of the
Department of Homeland Security to identify and correct management and operational deficiencies. In
reference to ICE Policy 17006.1, issued 09/22/05; any disclosure, dissemination, or reproduction of this
document, or any segments thereof, is prohibited without the approval of the Assistant Director, Office of
Professional Responsibility.

COMPLIANCE INSPECTION
GLADES COUNTY DETENTION CENTER
MIAMI FIELD OFFICE
TABLE OF CONTENTS
EXECUTIVE SUMMARY ...............................................................................................1
INSPECTION PROCESS
Report Organization .................................................................................................5
Inspection Team Members .......................................................................................5
OPERATIONAL ENVIRONMENT
Internal Relations .....................................................................................................6
Detainee Relations ...................................................................................................6
ICE NATIONAL DETENTION STANDARDS
Detention Standards Reviewed ................................................................................7
Access to Legal Material .........................................................................................8
Admission and Release ..........................................................................................10
Detainee Grievance Procedures .............................................................................11
Detainee Handbook ................................................................................................12
Disciplinary Policy.................................................................................................13
Funds and Personal Property .................................................................................14
Special Management Unit (Administrative Segregation) ......................................15
Staff-Detainee Communication .............................................................................16
Telephone Access ..................................................................................................17
Use of Force ...........................................................................................................18
Visitation ................................................................................................................19

EXECUTIVE SUMMARY
The Office of Professional Responsibility (OPR), Office of Detention Oversight (ODO),
conducted a Compliance Inspection (CI) of the Glades County Detention Center (GCDC) in
Moore Haven, Florida, from October 25 to 27, 2011. The facility is owned by Glades County
Development Corporation and operated by the Glades County Sheriff’s Office (GCSO). GCDC
accommodates ICE detainees of classification levels two and three for periods in excess of 72
hours. The facility was opened in June 2007, and ICE began housing male and female detainees
at GCDC under an intergovernmental service agreement (IGSA) in July 2007. A total of 450
bed spaces are approved for ICE detainees. At the time of the CI, 400 ICE detainees (320 males
and 80 females) were housed at GCDC. Armor Correctional Health Services provides medical
care and GCDC is accredited by the National Commission on Correctional Health Care
(NCCHC). GCSO provides food service.
The Enforcement and Removal Operations (ERO), Field Office Director in Miami, Florida
(FOD/Miami) is responsible for ensuring GCDC complies with ICE policies and the ICE
National Detention Standards (NDS). The Assistant Field Office Director (AFOD) at the Krome
Service Processing Center (SPC) has oversight responsibility of GCDC. ICE staff at GCDC
consists of a Supervisory Detention and Deportation Officer (SDDO), four Deportation Officers
(DOs), one Supervisory Immigration Enforcement Agent (SIEA), and six Immigration
Enforcement Agents (IEA). One IEA position was vacant during the period of review. A
Detention Service Manager (DSM) is assigned to GCDC. The total number of non-ICE staff
employed at GCDC is 102, with 5 vacancies during this review.
ODO conducted a Quality Assurance Review (QAR) of GCDC in January 2009 and a Follow-up
Inspection in March 2010. During the 2009 QAR, ODO found 67 deficiencies in the following
standards: Access to Legal Material; Detainee Classification System; Detainee Grievance
Procedures; Detainee Handbook; Detention Files; Environmental Health and Safety; Food
Service; Funds and Personal Property; Hold Rooms in Detention Facilities; Hunger Strike;
Issuance and Exchange of Clothing, Bedding, and Towels; Medical Care; Population Counts;
Recreation; Security Inspections; Special Management Units; Staff-Detainee Communication;
Suicide Prevention and Intervention; Telephone Access; Terminal Illness, Advance Directives,
and Death; and Use of Force.
During the March 2010 Follow-up Inspection, ODO found improvement in the majority of the
areas; however, four repeated deficiencies (one in each area) were noted in the Detainee
Classification System, Environmental Health and Safety, Security Inspections, and StaffDetainee Communication.
In April 2011, ERO Detention Standards Compliance Unit contractor MGT of America, Inc.
conducted an annual review of the NDS at GCDC. The facility received an overall rating of
“acceptable,’’ and was found in compliance with all 38 standards reviewed.
ODO reviewed a total of 21 NDS for this inspection; 10 areas were found to be fully compliant,
while 19 deficiencies were found in the following 11 standards: Access to Legal Materials
(3 deficiencies), Admission and Release (2), Detainee Grievance Procedures (1), Detainee
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Handbook (1), Disciplinary Policy (1), Funds and Personal Property (1), Special Management
Unit (Administrative Segregation) (1), Staff-Detainee Communication (1), Telephone Access
(2), Use of Force (2), and Visitation (4).
This report includes descriptions of all deficiencies and refers to the specific, relevant ICE NDS.
The report will be provided to ERO to develop corrective actions to resolve identified
deficiencies. All deficiencies were discussed with GCDC personnel on-site during the
inspection, as well as during the closeout briefing conducted on October 28, 2011.
Overall, ODO found few deficiencies in the standards reviewed at GCDC; however, internal
relations with detainees, security, and safety in the housing units posed significant areas of
concern. ODO also found a lack of direct supervision of male detainee housing units by GCDC
officers, since officers are not posted in each unit housing male detainees with classification
levels two and three. GCDC staff informed ODO they are working on plans to have direct
supervision of detainees in the housing units. ODO visited the female housing units and
observed officers are stationed in the housing units. These units were clean and well-managed.
During this compliance review, ODO found no deficiencies in the medical care standard. ODO
found best practices in related areas of the Hunger Strike, and Suicide Prevention and
Intervention standards. GCDC maintains a binder in the medical department containing the
suicide watch protocol, a monthly suicide watch summary sheet with start and stop times and
dates, record of daily rounds, and copies of check sheets documenting 15-minute checks. The
binder centralizes critical suicide watch documentation and supports efficient verification of
compliance with the standard. In addition, GCDC has established a training book for
documenting hunger strike, and suicide prevention and intervention training. Recording training
in this manner ensures medical staff meets NDS training requirements.
ODO conducted a pre-inspection analysis to determine areas of increasing complaint. The
pre-inspection review indicated a significant increase in the use of force incidents at GCDC.
During the inspection, ODO’s interviews of staff and detainees and review of the Use of Force
NDS revealed the majority of the use of force incidents occurred when officers were intervening
in physical confrontations between detainees. ODO noted male detainees were often
disrespectful of GCDC officers, and ignored facility’s rules. A review of documentation on ten
calculated use of force incidents revealed audiovisual recordings are maintained as required by
the standard, but are not cataloged. Cataloging audiovisual recordings supports accountability
and ensures they may be easily located and retrieved when necessary. ODO’s review of files on
three immediate use of force incidents revealed all required documentation was present and well
detailed; however, copies of use of force reports were not placed in the detainees’ detention files.
GCDC has a designated law library, which contains four computers, two printers, one typewriter,
desks, and chairs. The four computers at the law library were not equipped with the latest
version of Lexis-Nexis software.
ODO found in reviewing the Admission and Release NDS that detainees did not have the
opportunity to shower during intake processing. This deficiency was discussed during the

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review, and GCDC staff opened the shower stall in the intake processing area allowing detainees
the opportunity to shower, correcting the deficiency on-site.
GCDC has a functioning grievance system which allows detainees to file formal and informal
grievances. Grievance forms are available upon request and detainees are able to appeal
grievance decisions. Minor grievances are resolved informally and the resolutions are
documented as required. ODO found one deficiency during the review of the Detainee
Grievance Procedures standard. An informally resolved allegation of officer verbal misconduct
was not reported to ERO. Regardless of severity, all detainee grievances pertaining to officer
misconduct must be forwarded to the FOD, as per the NDS.
ICE management conducts unannounced visits to the facility. ICE personnel at GCDC make
regular contact with detainees and also visit detainee living areas. Detainees have opportunities
to file requests to ICE staff, but the logbook does not contain all required information, including
the date the request was returned to the facility.
GCDC issues a detainee handbook upon admission, available in English and Spanish, the
dominant language spoken by detainees.
ODO interviewed detainees in administrative segregation to determine if they were issued a copy
of the segregation order and if they were verbally informed of why they were in administrative
segregation. Detainees were verbally informed of why they were in administrative segregation,
but were not issued a written order.
ODO observed GCDC had designated a separate telephone in the booking area for detainees to
make calls regarding legal matters. However, conversations can be overheard by staff and other
detainees when using the telephone. Additionally, all housing units’ telephones did not have
notices stating detainee calls are subject to monitoring. The NDS require facilities to provide for
unmonitored, private telephone calls to counsel.
GCDC has a well-managed food service operation. ODO noted from interviews of staff and
detainees that detainees have access to religious diets, religious services, and recreation.
ODO noted four deficiencies in the Visitation NDS including lack of: separate logbooks for
general and legal visitation, written procedures that allow legal service providers to telephone the
facility in advance of a visit to determine if someone is detained, documented “pre-representation
meetings” in the logbook for legal visitation, and the Notice of Entry of Appearance as Attorney
or Accredited Representative (Form G-28) in the visitor reception areas. Separating the
logbooks for general and legal visitors allows staff to easily locate information regarding all
visitors at the facility and differentiate between attorneys and general visitors. This deficiency
was corrected on-site during the inspection.
ODO noted areas of concern regarding living condition in the housing units. ODO discussed the
conditions in the male housing units including: underclothes hanging on walls and chairs,
unmade beds, excessive trash on floors, and left-over food beside detainees’ beds. Detainees

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stack up chairs to climb onto their upper bunk beds. The facility has contracted with a company
to affix step ladders to the beds, which would eliminate the need to stack up chairs.

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INSPECTION PROCESS
ODO inspections evaluate the welfare, safety, and living conditions of detainees. ODO primarily
focuses on areas of noncompliance with the ICE National Detention Standards (NDS) or the ICE
Performance Based National Detention Standards (PBNDS), as applicable. The NDS apply to
GCDC. In addition, ODO may focus its inspection based on detention management information
provided by the ERO Headquarters (HQ) and ERO field offices, and on issues of high priority or
interest to ICE executive management. Inspection objectives are to evaluate the welfare, safety,
and living conditions of detainees.
ODO reviewed the processes employed at GCDC to determine compliance with current policies
and detention standards. Prior to the inspection, ODO collected and analyzed relevant
allegations and detainee information from multiple ICE databases, including the Joint Integrity
Case Management System (JICMS) and the ENFORCE Alien Booking Module (EABM) and
Alien Removal Module (EARM). ODO also gathered facility facts and inspection-related
information from ERO HQ staff to prepare for the site visit at GCDC.

REPORT ORGANIZATION
This report documents inspection results, serves as an official record, and is intended to provide
ICE and detention facility management with a comprehensive evaluation of compliance with
policies and detention standards. It summarizes those NDS that ODO found deficient in at least
one aspect of the standard. ODO reports convey information to best enable prompt corrective
actions and to assist in the on-going process of incorporating best practices in nationwide
detention facility operations.
OPR classifies program issues into one of two categories: deficiencies and areas of concern.
Specific deficiencies and areas of concern are identified in bold with sequential numbers in this
report. OPR defines a deficiency as a violation of written policy that can be specifically linked
to the PBNDS, or to ICE policy or operational procedure. OPR defines an area of concern as
something that may lead to or risk a violation of the NDS or ICE policy or operational procedure.
When possible, the report includes contextual and quantitative information relevant to the cited
standard. Deficiencies are highlighted in bold throughout the report and are encoded
sequentially according to a detention standard designator.
Comments and questions regarding the report findings should be forwarded to the Deputy
Division Director, OPR, Office of Detention Oversight.

INSPECTION TEAM MEMBERS

(b)(6), (b)(7)c

Detention and Deportation Officer (Team Lead)
Detention and Deportation Officer
Management Program Analyst
Management Program Analyst
Contract Inspector
Contract Inspector

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ODO, Headquarters
ODO, Headquarters
ODO, Headquarters
ODO, Headquarters
MGT of America, Inc.
MGT of America, Inc.

Glades County Detention Center
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OPERATIONAL ENVIRONMENT
INTERNAL RELATIONS
ODO interviewed the GCDC Chief Deputy and the Assistant (Major), Correctional Officers
(CO), the ERO AFOD, an SDDO who also serves as the Contracting Officer’s Technical
Representative (COTR) at the facility, an SIEA, the DSM responsible for GCDC, and the
FOD/Miami COTR.
ICE ERO management stated the staffing level for ICE officers (12 full-time positions) assigned
at GCDC is adequate to support the facility. Both GCDC and ICE staff stated morale is good,
and there were no complaints from either ICE or GCDC staff regarding unfavorable treatment at
the facility. GCDC and ERO staff stated the working relationship between them is excellent.
Despite the good working relationship, GCDC is experiencing financial constraints resulting
from several unfunded requests from ICE, including creating space to accommodate the
immigration court/video teleconference room, barber shop, and separate office space for ICE
staff. GCDC management expressed major frustration with ERO’s termination of 100 bed
spaces reserved for ICE female detainees at the GCDC Annex for women, resulting in the
elimination of 80 full-time facility positions. GCDC also lost income when ERO mandated that
the facility not charge commission on detainees’ telephone services surcharge.

DETAINEE RELATIONS
ODO interviewed 18 detainees (11 males and 7 females), randomly selected from classification
levels two and three to assess detention conditions at GCDC. All detainees interviewed stated
they participate in outdoor recreation at a minimum of one hour each day. Detainees may send
and receive mail, use telephones, and have access to a law library. All had received the detainee
handbook.
There were no complaints regarding medical care. Detainees complained that food portions were
small. Several detainees alleged they were served bologna for lunch more than three times a
week. ODO review of the Food Service NDS and food menu posted on each housing units’
bulletin board revealed food portions and 30 day menu are compliant with ICE NDS. Three
different bolognas (beef, chicken, and ham) were each served once a week.
GCDC management informed ODO they are aware of some detainees’ bad-manners towards
officers, and several procedures have been implemented including: a designated “special
trustees” housing unit. The unit was established to serve as an incentive for detainees. Wellbehaved individuals are placed in the special housing area and are provided with work privileges
and other rewards not available to detainees in other units.

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ICE NATIONAL DETENTION STANDARDS
ODO reviewed a total of 21 ICE NDS and found GCDC fully compliant with the following
10 standards:
Correspondence and Other Mail
Detainee Classification System
Detainee Transfer
Food Service
Hold Rooms in Detention Facilities
Hunger Strikes
Medical Care
Recreation
Special Management Unit (Disciplinary Segregation)
Suicide Prevention and Intervention
As these standards were compliant at the time of the review, a synopsis for these areas was not
prepared for this report.
ODO found deficiencies in the following 11 standards:
Access to Legal Materials
Admission and Release
Detainee Grievance Procedures
Detainee Handbook
Disciplinary Policy
Funds and Personal Property
Special Management Unit (Administrative Segregation)
Staff-Detainee Communication
Telephone Access
Use of Force and Restraints
Visitation
Findings for each of these standards are presented in the remainder of this report.

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ACCESS TO LEGAL MATERIALS (ALM)
ODO reviewed the Access to Legal Material NDS at GCDC to determine if detainees have
access to a law library, legal materials, courts, counsel, and document copying equipment to
facilitate the preparation of legal documents. ODO interviewed detainees and staff; reviewed
policies, procedures, and the detainee handbook; and toured the law library.
GCDC has a dedicated law library available for detainee use. GCDC staff ensures legal
materials and equipment are not damaged. The law library can accommodate four detainees per
session. According to GCDC staff, the library is equipped with adequate resources to facilitate
detainee legal research and writing, including four computers, two printers, one typewriter,
desks, and chairs.
ODO observed the computers contained the Lexis-Nexis software, but were not updated with the
latest version (Deficiency ALM-1). The Case Law section of the Lexis-Nexis program was
operational, but the ICE law section was not working. GCDC staff informed ODO that FOD
personnel had been notified of the need to have the latest Lexis-Nexis software updates.
GCDC does not have written procedures for assisting unrepresented illiterate or non-English
speaking detainees who wish to pursue a legal claim related to their immigration proceedings.
Additionally, there are no procedures for assisting detainees who have difficulty using the law
library and drafting legal documents (Deficiency ALM-2). GCDC staff stated the procedures
and functions for providing assistance are in place but are not documented. ODO recommends
GCDC develop and implement clear written procedures for providing required services to
detainees.
ODO also observed the rules and procedures governing access to legal material are not posted in
the law library (Deficiency ALM-3). The detainee handbook does apprise detainees of the
procedures for requesting additional time in the law library.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY ALM-1
In accordance with the ICE NDS, Access to Legal Material, Change Notice - Access to Legal
Materials and Lexis-Nexis CD-ROMs, the FOD must ensure updated Lexis-Nexis CD-ROMs are
distributed to facilities quarterly, and fulfils ICE’s requirement to provide legal reference
materials.
DEFICIENCY ALM-2
In accordance with the ICE NDS, Access to Legal Material, section (III)(L), the FOD must
ensure unrepresented, illiterate, or non-English speaking detainees who wish to pursue a legal
claim related to their immigration proceedings or detention, and indicate difficulty with the legal
materials, must be provided with more than access to a set of English-language law books.
Facilities shall establish procedures to meet this obligation, such as: 1. helping the detainee
obtain assistance in using the law library and drafting legal documents from detainees with

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appropriate language and reading-writing abilities; and 2. assisting in contacting pro bono legalassistance organizations from the ICE-provided list. If such methods prove unsuccessful in
providing a particular non-English-speaking or illiterate detainee with sufficient assistance, the
facility shall contact ICE to determine appropriate further action.
DEFICIENCY ALM-3
In accordance with the ICE NDS, Access to Legal Material, section (III)(Q), the FOD must
ensure the detainee handbook or equivalent shall provide detainees with the rules and procedures
governing access to legal materials, including the following information: 1. that a law library is
available for detainee use; 2. the scheduled hours of access to the law library; 3. the procedure
for requesting access to the law library; 4. the procedure for requesting additional time in the law
library (beyond the 5 hours per week minimum); 5. the procedure for requesting legal reference
materials not maintained in the law library; and 6. the procedure for notifying a designated
employee that library material is missing or damaged. These policies and procedures shall also
be posted in the law library along with a list of the law library’s holdings.

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ADMISSION AND RELEASE (AR)
ODO reviewed the Admission and Release NDS at GCDC to determine if procedures are in
place to protect the health, safety, security, and welfare of each person during the admission and
release process. ODO reviewed policies and procedures, detention files, observed admission and
intake procedures, and interviewed staff and detainees.
ODO observed intake and release processing of detainees at GCDC. GCDC provides the facility
orientation through a video available to detainees in both English and Spanish. A review of ten
active detention files showed that not all of the required forms and documents associated with
the admission process are maintained. One out of the ten detention files was missing a Form
I-203, Order to Detain or Release Alien (Deficiency AR-1).
Interviews of detainees revealed they were not permitted a shower during their initial admission
processing at the facility. The detainees stated they took showers in the assigned housing units
(Deficiency AR-2). According to the NDS, detainees are required to shower in the intake
processing area before entering assigned housing units. Allowing detainees to shower during
intake processing is good practice for health and sanitary reasons and to prevent contaminants
from being introduced to the facility. The lack of showers during intake processing was
discussed during the review, and GCDC staff implemented corrective action on-site.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY AR-1
In accordance with the ICE NDS, Admission and Release, section (III)(H), the FOD must ensure
an order to detain or release (Form I-203 or I-203a), bearing the appropriate official signature,
shall accompany the newly arriving detainee. IGSA facilities shall forward the detainee’s A-file
or temporary work file to the ICE office with jurisdiction. Staff shall prepare specific documents
in conjunction with each new arrival to facilitate timely processing, classification, medical
screening, accounting of personal effects, and reporting of statistical data.
DEFICIENCY AR-2
In accordance with the ICE NDS, Change Notice, National Detention Standard Strip Search
Policy, dated October 15, 2007: Required Action - effective immediately, the FOD must ensure
all facilities housing ICE detainees shall permit detainees to change clothing and shower in a
private room without being visually observed by a staff member unless there is reasonable
suspicion that the individual possesses contraband. A staff member of the same gender will be
present immediately outside the room when the detainee changes and showers, with the door opened
to hear what transpires inside. This includes Service Processing Centers (SPCs), Contract Detention
Facilities (CDFs), and those locations having Intergovernmental Service Agreements (IGSAs) with
ICE.

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DETAINEE GRIEVANCE PROCEDURES (DGP)
ODO reviewed the Detainee Grievance Procedures NDS at GCDC to determine whether a
process to submit formal or emergency grievances exists, and responses are provided in a timely
manner, without fear of reprisal. In addition, ODO reviewed the standard to determine whether
detainees have an opportunity to appeal responses and whether accurate records are maintained.
ODO interviewed staff and reviewed grievance policy, procedures, records, and the detainee
handbook.
GCDC has written policies and procedures for detainees to submit informal and formal
grievances. Grievance forms are available in English and Spanish. Assistance in filing
grievances is available, if needed, through language services and facility staff who speak the
same language as the detainee. Detainees are encouraged to resolve grievances informally, but
may pursue formal grievances. Detainees are able to appeal the grievance decision. All
grievances are recorded in a log and reviewed by the grievance officer.
GCDC staff is trained to handle emergency grievances, ensuring detainees’ safety or welfare.
Any officer who is approached by a detainee with an emergency grievance must report the
grievance to supervisory personnel for immediate action. Medical grievances are submitted to
the medical staff and the completed forms are kept in the detainees’ medical records, as required.
ICE is notified of any medical grievance that cannot be immediately addressed by the facility
medical staff.
ODO reviewed three detention files of detainees who have filed grievances. One of the three
grievances alleged officer verbal misconduct. The allegation involved a racial slur directed at a
detainee, which was resolved informally. ODO noted that although the allegation had been
resolved informally and determined to be unfounded, GCDC should have reported the instance to
FOD personnel (Deficiency DGP-1). Reviews of the detainee grievance logbook showed
several minor complaints (or nuisances) were usually resolved informally. ODO informed
GCDC staff that according to the ICE NDS, any allegations of officer misconduct, regardless of
severity, must be reported to ERO. ODO also recommends that GCDC report all instances of
alleged misconduct to ICE prior to the resolution phase, if possible. It is critically important for
all FOD’s to be informed of these issues in order to best provide effective oversight of all ICE
detention facilities.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DGP-1
In accordance with the ICE NDS, Detainee Grievance Procedures, section (III)(F), the FOD must
ensure facility staff must forward all detainee grievances containing allegations of officer
misconduct to a supervisor or higher-level official in the chain of command. CDFs and IGSA
facilities must forward detainee grievances alleging officer misconduct to ICE. ICE will
investigate every allegation of officer misconduct.

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DETAINEE HANDBOOK (DH)
ODO reviewed the Detainee Handbook NDS at GCDC to determine if the facility provides each
detainee with a handbook, and whether the handbook is available in languages other than
English. ODO’s review includes determining whether the handbook sufficiently describes the
facility’s rules and sanctions, disciplinary system, mail and visiting procedures, grievance
system, services, programs, and medical care. ODO reviewed the handbook and interviewed
detainees and staff.
GCDC detainee handbooks are available in both English and Spanish. A review of the ICE
ENFORCE Alien Removal Module (EARM) database showed the majority of detainees housed
at GCDC are from Spanish-speaking countries such as Mexico and Central America. GCDC
staff indicated that if a detainee speaks a language other than English or Spanish,
accommodations can be made to provide those detainees with a detainee handbook in their native
language. GCDC last revised its handbook on October 19, 2011, about a week before the
inspection.
GCDC staff informed ODO, according to local policy, detainees are provided verbal and video
orientation referencing the handbook, and are required to sign a receipt for the handbook. All
detainees interviewed, and the review of 15 detention files confirmed, that detainee handbooks
were issued and signed for on their property cards.
The GCDC detainee handbook does not provide any information on what areas of the facility are
considered restricted areas (Deficiency DH-1). ODO recommends this missing information be
inserted during the annual handbook revision.
Other omissions are reported under the relevant standards as Deficiencies DP-1, and F&PP-1.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DH-1
In accordance with the ICE NDS, Detainee Handbook, section (III)(C), the FOD must ensure the
handbook will specify in greater detail the rules, regulations, policies, and procedures with which
every detainee must comply, including, but not limited to: smoking policy, restricted areas,
contraband, and so forth.

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DISCIPLINARY POLICY (DP)
ODO reviewed the Disciplinary Policy NDS at GCDC to determine if sanctions imposed on
detainees who violate facility rules are appropriate, and if the discipline process includes due
process requirements. ODO interviewed detainees and staff, reviewed the disciplinary policy,
disciplinary records and the detainee handbook.
GCDC’s disciplinary system includes progressive levels of review and appeals, as well as
documentation procedures. Prohibited acts are classified as low, high moderate, high, and
greatest. Minor violations are resolved by the unit officer or the shift supervisor.
GCDC’s disciplinary system and the detainee handbook do not advise detainees of the right to
protection from personal abuse, corporal punishment, unnecessary or excessive use of force,
personal injury, disease, property damage, and harassment; the right of freedom from
discrimination based on race, religion, national origin, sex, handicap, or political beliefs; and the
right to due process, including the prompt resolution of a disciplinary matter (Deficiency DP-1).
ODO recommends revision of the detainee handbook to include notification of these
fundamental rights.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DP-1
In accordance with the ICE NDS, Disciplinary Policy, section (III)(A)(5)(a)(b)and(e), the FOD
must ensure the detainee handbook or equivalent, issued to each detainee upon admittance,
provides notice of the facility’s rules of conduct, and of the sanctions imposed for violations of
the rules. Among other things, the handbook shall advise detainees of the following: (a) the right
to protection from personal abuse, corporal punishment, unnecessary or excessive use of force,
personal injury, disease, property damage, and harassment; (b) the right of freedom from
discrimination based on race, religion, national origin, sex, handicap, or political beliefs; and
(e) the right to due process, including the prompt resolution of a disciplinary matter (in
accordance with the rules, procedures, and sanctions provided in the handbook).

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FUNDS AND PERSONAL PROPERTY (F&PP)
ODO reviewed the Funds and Personal Property NDS at GCDC to determine if controls are in
place to inventory, issue receipts for, maintain, and safeguard detainees’ personal property.
ODO interviewed staff, reviewed policies and procedures, and observed the processing of
detainees.
GCDC has written policies and procedures which provide for the control and safeguarding of
detainees’ funds and personal property. Property is properly inventoried and logged in the
facility’s computer system, and stored in a secured, neat, and well-organized property room.
Detainees are not authorized to keep money in their possession. Monies are placed in a sealed
envelope and deposited into a drop safe in the processing area. All envelopes are removed by the
Business Manager and Booking Supervisor the next work day and the funds are deposited in
detainees’ commissary accounts.
The detainee handbook does not include notice that upon request, a detainee may be provided an
ICE-certified copy of any identity document placed in the A-File (Deficiency F&PP-1).
STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY F&PP-1
In accordance with the ICE NDS, Funds and Personal Property, section (III)(J)(2), the FOD must
ensure the detainee handbook or equivalent notifies detainees of facility policies and procedures
concerning personal property, including among others things that, upon request, they will be
provided an ICE-certified copy of any identity document, such as a passport or birth certificate,
placed in their A-Files.

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SPECIAL MANAGEMENT UNIT (SMU) - Administrative Segregation
ODO reviewed the Special Management Unit (Administrative Segregation) NDS at GCDC to
determine if the facility has procedures in place to temporarily segregate detainees for
administrative reasons. ODO toured the facility, reviewed policies and procedures, interviewed
staff, and reviewed detainee files for required documentation.
ODO verified written procedures are in place to temporarily segregate detainees for
administrative reasons. GCDC operates two separate SMUs, one for male detainees, the second
for female detainees. There were eight male and no female ICE detainees in administrative
segregation during the review. Inspection revealed the units are well ventilated, adequately lit,
appropriately heated, and maintained in a sanitary condition. All cells are equipped with bunk
beds, securely fastened to the floor.
ODO was informed detainees receive verbal notification when assigned to administrative
segregation but are not provided a copy of the written order. ODO interviewed all detainees in
administrative segregation to determine if they were issued a copy of the segregation order, and
if they were verbally informed of why they were in administrative segregation. All eight
detainees stated they were verbally informed of why they were in administrative segregation, but
were not issued a written order (Deficiency SMU-1). Providing detainees with a copy of the
segregation order supports due process.
ODO assessed the justifications for assignment to administrative segregation for all eight
detainees, as documented on the segregation orders. In all cases, the reason for placement in
administrative segregation was well documented and justified.

STANDARD/POLICY REQUIREMENTS DEFICIENT FINDINGS
DEFICIENCY SMU-1
In accordance with the ICE NDS, Special Management Unit (Administrative Segregation),
section (III)(B), the FOD must ensure a written order is completed and approved by a
supervisory officer before a detainee is placed in administrative segregation, except when
exigent circumstances make this impracticable. In such cases, an order shall be prepared as soon
as possible. A copy of the order shall be given to the detainee within 24 hours, unless delivery
would jeopardize the safety, security, or orderly operation of the facility.

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STAFF DETAINEE COMMUNICATION (SDC)
ODO reviewed the Staff-Detainee Communication NDS at GCDC to determine if procedures are
in place to allow formal and informal contact between detainees and key ICE and facility staff,
and if ICE detainees are able to submit written requests to ICE staff and receive responses in a
timely manner. ODO reviewed policies and documentation, and interviewed detainees and staff.
ODO has historically observed that facilities in which ICE has a permanent or a part-time daily
presence, detainee requests and concerns are addressed in a more timely manner, resulting in a
general climate of decreased detainee anxiety levels and negativity, including fewer behavioral
issues. Along with a thorough and universally available detainee handbook, vibrant and healthy
staff-detainee communication is a key component to a well-maintained detention environment.
ICE staff makes daily regular and irregular visits in response to ICE detainee requests and
concerns. There are 12 ERO staff members permanently assigned to the facility, including one
(1) SDDO, one (1) SIEA, four (4) DOs and five (5) IEAs (one vacant IEA position). A DSM is
also assigned to the facility from ERO HQ and is not counted as part of the detained case
management staff. A Deportation Officer (DO) or an IEA visits the GCDC every Thursday to
address detainees’ personal concerns and monitor the living conditions. ODO interviews with
GCDC staff revealed that supervisory ERO staff make frequent unannounced and unscheduled
visits to the activity areas and housing units. These visits are logged into the facility’s computer
system, Smart Cop, and in the ERO Daily Logbook.
ODO reviewed the GCDC detainee request logbook from October 2010 to the present to
determine if required information is maintained and documented in a proper manner. The
logbook records detainee requests and ICE responses, but does not state the date the request was
returned to the facility (Deficiency SDC-1). This means ODO could not assess whether ICE
responded within 72 hours, as required by the standard.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY SDC-1
In accordance with the ICE NDS, Staff-Detainee Communication, section (III)(B)(2), the FOD
must ensure all facilities’ requests are recorded in a logbook, the date the request was forwarded
to ICE, and the date it was returned to the facility.

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TELEPHONE ACCESS (TA)
ODO reviewed the Telephone Access NDS at GCDC to determine if the facility provides
detainees with reasonable and equitable access to telephones to maintain ties with family and
others in the community. ODO interviewed ICE and facility staff and detainees, and conducted
functionality tests of the telephones.
Housing units are equipped with telephones at a ratio of one telephone per 25 detainees. The
special management unit was equipped with one stationary and two rolling telephones. All the
telephones were tested and in good working condition. ICE staff performs the weekly telephone
serviceability checks and worksheets are completed. Facility personnel deliver incoming
messages to detainees. Detainees are also allowed to return emergency telephone calls without
delay.
ODO observed that a telephone designated for making calls regarding legal matters was located
in the booking area; conversations could be overheard by staff and other detainees (Deficiency
TA-1). The standard requires detainees to be afforded privacy for telephone calls on legal
matters. The facility has a written policy on monitoring of detainee telephone calls and the
detainee handbook mentions that telephone calls are subject to monitoring. Upon initiation of a
phone call, a recorded message advises that telephone calls are subject to monitoring. ODO
observed that all housing unit telephones did not have required posted notices stating detainee
calls are subject to monitoring (Deficiency TA-2).

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY TA-1
In accordance with the ICE NDS, Telephone Access, section (III)(J), the FOD must ensure the
facility shall ensure privacy for detainees’ telephone calls regarding legal matters. For this
purpose, the facility shall provide a reasonable number of telephones on which detainees can
make such calls without being overheard by officers, other staff, or other detainees.
DEFICIENCY TA-2
In accordance with the ICE NDS, Telephone Access, section (III)(K), the FOD must ensure the
facility shall have a written policy on the monitoring of detainee telephone calls. If telephone
calls are monitored, the facility shall notify detainees in the detainee handbook or equivalent
provided upon admission. It shall also place a notice at each monitored telephone stating that
detainee calls are subject to monitoring.

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USE OF FORCE (UOF)
ODO reviewed the Use of Force NDS at GCDC to determine if necessary use of force is
employed only after all reasonable efforts have been exhausted to gain control of a subject, while
protecting and ensuring the safety of detainees, staff, and others; preventing serious property
damage; and ensuring the security and orderly operation of the facility. ODO toured the facility,
inspected equipment, and reviewed the local policies, use of force files, training records, and
other pertinent documentation.
GCDC has a comprehensive written policy governing the use of force. The facility does not use
four-point restraints or electro-muscular disruption devices; however, a restraint chair and
Oleoresin Capsicum (OC) spray are used if warranted.
GCDC staff informed ODO there were ten calculated and nineteen immediate use of force
incidents involving detainees between January 2011 and October 25, 2011. ODO review of
documentation on the ten calculated use of force incidents revealed audiovisual recordings are
maintained as required by the standard, but are not cataloged (Deficiency UOF-1). Cataloging
audiovisual recordings supports accountability and ensures they may be easily located and
retrieved when necessary.
ODO review of files on three immediate use of force incidents revealed all required
documentation was present and well detailed. Copies of use of force reports were not placed in
the detainees’ detention files (Deficiency UOF-2). Placing copies of use of force reports in
detainees’ detention files supports accountability and expedient access to the information.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY UOF-1
In accordance with the ICE NDS, Use of Force, section (III)(A)(4)(h), the FOD must ensure
videotapes documenting use of force are catalogued and preserved until no longer needed, but no
less than 30 months after its last documented use.
DEFICIENCY UOF-2
In accordance with the ICE NDS, Use of Force, section (III)(J), the FOD must ensure staff
prepares detailed documentation of all incidents involving the use of force, chemical agents, or
non-lethal weapons. Staff will likewise document the use of restraints on a detainee who
becomes violent or displays signs of imminent violence. A copy of the report will be placed in
the detainee’s detention file.

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VISITATION (V)
ODO reviewed the Visitation NDS at GCDC to determine if authorized persons, including legal
and media representatives, are able to visit detainees within security and operational constraints.
ODO interviewed staff, observed the visiting area, and reviewed logs, policies, procedures, and
the detainee handbook.
Visitation rules and hours, provided in English and Spanish, are posted in each detainee housing
area, to include the disciplinary and administrative special management units. Detainees are
provided daily one-hour access to visitation with family members, including minor children,
friends, clergy, and consular representatives. Visitation is available seven days per week.
Attorney visits are unrestricted. GCDC allows contact visits on a case-by-case basis.
GCDC does not maintain separate logbooks for general and legal visitation (Deficiency V-1).
Separate logbooks for general and legal visitors allow staff to easily locate information regarding
all visitors at the facility, and differentiate between attorneys and general visitors. This
deficiency was corrected on-site during the inspection.
The facility does not have a written procedure to allow legal service providers and their
assistants to telephone the facility in advance of a visit to determine if someone is detained there
(Deficiency V-2). ODO found no reported instances of legal representatives being denied
information regarding the presence of detainees; however, having a policy in place complies with
the standard and ensures attorneys and their assistants have the opportunity to call the facility in
advance thereby avoiding complaints, unnecessary trips, and lost time.
GCDC staff informed ODO that legal “pre-representation meetings” with detainees were
conducted but were not documented in the logbook for legal visitation (Deficiency V-3). ODO
recommends that the facility document “pre-representation meetings” in the legal visitation
logbook as required by the Visitation NDS.
ODO found Form G-28, Notice of Entry of Appearance as Attorney or Accredited
Representative, is not available in the visitor reception areas (Deficiency V-4). The form
informs ICE of the attorney-client relationship. This deficiency was corrected on-site during the
inspection.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY V-1
In accordance with the ICE NDS, Visitation, section (III)(C), the FOD must ensure the facility
shall maintain a log of all general visitors, and a separate log of legal visitors.
DEFICIENCY V-2
In accordance with the ICE NDS, Visitation, section (III)(I)(6), the FOD must ensure each
facility shall establish a written procedure to allow legal service providers and legal assistants to
telephone the facility in advance of a visit to determine whether a particular individual is
detained there.
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DEFICIENCY V-3
In accordance with the ICE NDS, Visitation, section (III)(I)(7), the FOD must ensure each
facility shall document such “pre-representation meetings” in the logbook for legal visitation.
DEFICIENCY V-4
In accordance with the ICE NDS, Visitation, section (III)(I)(8), the FOD must ensure, once an
attorney-client relationship has been established, the legal representative shall complete and
submit a Form G-28, available in the legal visitors’ reception area. Staff shall collect completed
forms and forward them to ICE.

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