'Creative
~corrections

6415 Calder, Suite B • Beaumont, Texas 77706
409.866.9920 • www.correctionalexperts.com
Making a Difference!

July 23,2008

MEMORANDUM FOR:

FROM:

James T. Hayes, Jr.
Acting Director
Office of Detention and Removal Operations
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Reviewer-In-Charge
SUBJECT:

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Joe Corley Detention Facility
Headquarters Review (Over-72)

Creative Corrections conducted the Pre-Activation Detention Assessment (P ADA) of the
Joe Corley Detention Facility (JCDF), located in Conroe, Texas, on July 15-17, 2008. ICE is
contemplating a contract with GEO Corporation to house detainees. As noted in attached
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Health
documentation, my team of Subject Matter Experts (SME) included
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Services SME;
Safety SME;
Food Services SME; and
,
Security SME.
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A closeout meeting was conducted on July 17, 2008 with Warden
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Compliance Officer;
Assistant Field Office Director; and
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ICE Agent, during which all deficiencies, concerns, and recommendations were discussed.

Facility History
The facility is newly constructed in Montgomery County, Texas, and operated by GEO
Corporation. It is an 1100 bed facility with both dormitories and individual cells (in specified
areas) and designed to house lower, security level detainees. The county health department
issued a food permit and certified the facility's health care operation on June 19, 2008. The
facility received a Certificate of Occupancy on July 1, 2008 from authorized city officials.
The facility is operated by GEO Corporation, which has a contract with Montgomery County
who will maintain as an IGSA should a contract with ICE be awarded.

Construction of aI, 1OO-bed facility was recently completed. Within this facility 100 beds are
designed to house High security detainees. The remaining 1,000 beds will house detainees in
dormitory style housing units.
Type of Review

This review is an unscheduled Detention Standard Review with ICE National Detention
Standards for facilities used over 72 hours, to determine activation readiness at this facility.
Review Summary

The JCDF is not accredited by American Correctional Association (ACA), National Commission
on Correctional Health Care (NCCHC), or the Joint Commission on Accreditation of Healthcare
Organizations (JCAHO). The Facility has been accredited by the Texas Jail Commission.
Standards Compliance

This facility has been just recently been constructed, therefore, previous Standards Compliance
statistical data does not apply to this review.
RIC Issues and Concerns
Life Safety

The Joe Corley Detention Facility Center is not fully equipped with a sprinkler system and
therefore, not compliant with NFP A requirements (Life Safety Code 101, Chapter II,
New Detention/Correctional Occupancies, Sect. 22.3.5.2). No sprinklers were installed in any of
the 80 dorms or 100 single cells. Administrative offices, corridor areas, dorm common areas,
and select cells in the holding and hospital areas have sprinkler protection. This fire suppression
design was developed on November 2,2006, during a meeting of the Texas Commission on Jail
Standards, when a waiver was granted to approve Montgomery County's request that sprinklers
NOT be required in inmate housing areas in the new jail. (The Conroe Fire Department
conversely requested sprinklers be installed throughout all building areas.) The facility has
smoke detection throughout, a smoke extraction system, strobe and audio fire alarms, fire hoses,
fire extinguishers and cameras.
There are· no approved fire prevention and evacuation plans. The total fife plan should be
approved by the fire department providing services to the facility. Further, fire exit diagrams and
evacuation plans should be developed and appropriate signage posted in the facility.
Policy Development

The team completed a review of corporate policies provided by the GEO Cooperation. GEO
should systematically develop site-specific policy for the JCDF, incorporating ICE standards as
they apply to each area. Policies should then be submitted to ICE for approval. Many local
policies and procedures have yet to be drafted and local procedures for many programs and
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FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

services were not developed to the point of affording them any meaningful critical review.
Those programs and services for which policy and protocols are not available are: Detainee
Handbook, Suicide Prevention / Intervention, Hunger Strikes, Post Orders, Key/Lock Control
(the facility is transitioning from the master lock/key system in place during construction), Food
Service menus, common fare program and standard operating procedures, and Emergency Plans,
to name a few. All told, about 85% o flo cal policy remains underdeveloped.

Physical Plant
The facility's perimeter fence should be secured with a concrete footer. The fence is anchored
by posts set in concrete, and a fence rail secures the bottom portion of fence. The perimeter fence
is protected by interior fence alarm, which was not operational during review.
The sallyport windows, located by Central Control, should be fortified with security bars. The
entrance door to the Bus Bay should be equipped with security bars to enhance overall security.

Operational Features
Housing unit telephones are installed, were but not operational during the review. Phones should
be programmed with access numbers as required by ICE standards.
There should be a contract with a community hospital for outpatient/inpatient detainee care.
The ICE required notifications should be posted in the living units.
Law library use, including the Lexis Nexis program (provided by ICE), should be provided
specifically for ICE detainees.
Facility management should specify that detainees undergo a strip search when cause has been
established, not as a matter of routine.
Facility policy should direct that tools be marked so they are readily identifiable. Proper tool
storage and accountability measures should comply with ICE standards.

Staff Training
As local policies, procedures, and practices are developed, staff training should be ongoing.
Familiarization with GEO policy has benefits in terms of general philosophy. Further training
and application of site-specific protocols will enable the staff to perform in the best possible
manner as detainees arrive.
Local staff should be properly trained and qualified to facilitate the land transportation of
detainees, as they intend per their activation plan.

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Recommended Rating and Justification

A presumptive rating of "Acceptable" is recommended by the RIC contingent upon submittal of
a viable Plan of Action by JCDF to ICE, addressing all RIC issues and concerns. With
implementation of suggestions by the RIC, it is recommended the JCDF be used by ICE.
RIC Assurance Statement

All [mdings ofthis review have been documented on the Detention Review Worksheet attached
and are supported by the written documentation contained in the review file.

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FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

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..
corrections

DETENTION FACILITY INSPECTION FORM
FACILITIES USED LONGER THAN 72 HOURS
A. TYPE OF FACILITY REVIEWED
ICE Service Processing Center
ICE Contract Detention Facility
ICE Intergovernmental Service Agreement
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C. PREVIOUS/MOST RECENT FACILITY REVIEW
Date[s] of Last Facility Review

N/A

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0

Acceptable

0

Deficient 0 At-Risk

D. NAME AND LOCATION OF FACILITY
Name
Joe Corely Detention Facility
Address
500 Hilbig Road
City, State and Zip Code
Conroe, TX
County
Montogmery
Name and Title of Chief Executive Officer
(Warde
ent)
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Warden
Telephone Number (Include Area Code)
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936
Field Office 1 Sub-Office (List Office with Oversight)
Houston, Tx
Distance from Field Office
30 miles
E. CREATIVE CORRECTIONS INFORMATION
Name ofInspector (Last Name, Title and Duty Station)
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RIC 1
Member 1 Title 1Duty Location
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SME Medical 1 I .
Name of Team Member 1 Title 1Duty Location
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SME Food Service 1
Name of Team Member 1 Title 1 Duty Location
SME Safety 1
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Name of Team Member 1 Title 1 Duty Location
1 SME Security 1
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Name of Team Member 1 Title 1 Duty Location
1
1
F. CDFIIGSA INFORMATION ONLY
Contract Number
Date of Contract or IGSA

N/A

r

I N/A

; IZl N/A

Estimated Man-days Per Year

N/A
G. ACCREDITATION CERTIFICATES 0 N/A
List all State or National Accreditation[s] received:
Texas State Jail Commission Jul 2008

B. CURRENT INSPECTION
Type of Inspection
Field Office IZl HQ Inspection
Date[s] of Facility Review
July 15-17,2008 Initial Review

Previous Rating
Superior 0 Good

Other Charges: (If None, Indicate N/A)

H. PROBLEMS 1 COMPLAINTS (COPIES MUST BE ATTACHED)
The Facility is under Court Order or Class Action Finding
Court Order
0 Class Action Finding
The Facility has Significant Litigation Pending
Major Litigation
0 Life/Safety Issues
IZl None

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FACILITY HISTORY
Date Built
2008
Date Last Remodeled or Upgraded

N/A
Date New Construction 1 Bed Space Added

N/A
Future Construction Planned
DYes IZl No Date:
Current Bed space
I Future Bed Space (# New Beds only)
1100
Number: NIA Date:

J. TOTAL FACILITY POPULATION
Total Facility Intake for Previous 12 months

N/A
Total ICE Man Days for Previous 12 months

N/A
K. CLASSIFICATION LEVEL (ICE SPCs AND CDFs ONLY)

I AdultMale
l Adult Female

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L-2

L-3

N/A
N/A

N/A
N/A

N/A
N/A

L.

FACILITY CAPACITY
Operational . Emergency
·Rated
Adult Male
N/A
N/A
N/A
Adult Female
N/A
N/A
N/A
Facility Holds Juveniles Offenders 16 and Older as Adults

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M. AVERAGE DAILY POPULATION
ICE
[ Adult Male
N/A
N/A
I Adult Female

I

USMS

Other

N/A
N/A

N/A
N/A

N. FACILITY STAFFING LEVEL
ort:
b2High

Basic Rates per Man-Day

N/A
FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

SIGNIFICANT INCIDENT SUMMARY WORKSHEET
In order for Creative Corrections to complete its review of your facility, you must complete the following worksheet prior to your
scheduled review dates. This worksheet must contain data for the past twelve months. We will use this worksheet in conjunction with
the ICE Detention Standards to assess your detention operations with regard to the needs of ICE and its detainee population. Failure
to complete this worksheet will result in a delay in processing this report, and may result in a reduction or removal of ICE detainees
from your facility.

Assault:
Offenders on
Offenders l

With
Without

Assault:
Detainee on
Staff

Number of Forced Moves, incl.
Forced Cell Moves3
Disturbances4
of Times Chemical

# Times Four/Five Point
Restraints Applied/Used

Offender / Detainee Medical
Referrals as a Result ofInjuries
Sustained.
Escapes
Actual
Grievances:
of

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

Deaths

Psychiatric / Medical Referrals

Number
# Medical Cases Referred for
Outside Care
# Psychiatric Cases Referred
for Outside Care

Any attempted physical contact or physical contact that involves two or more offenders
Oral, anal or vaginal penetration or attempted penetration involving at least 2 parties, whether it is consenting or non-consenting
Routine transportation of detainees/offenders is not considered "forced"
Any incident that involves four or more detainees/offenders, includes gang fights, organized multiple hunger strikes, work stoppages, hostage situations,
major fires, or other large scale incidents.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

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DRS/ICE DETENTION STANDARDS REVIEW SUMMARY REpORT
1. ACCEPTABLE

5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.

2. DEFICIENT

3. AT-RISK

4. REPEAT

5. NOT

FINDING

ApPLICABLE

Admission and Release
Classification System
Correspondence and Other Mail
Detainee Handbook
Food Service
Funds and Personal Property
Detainee Grievance Procedures
Issuance and Exchange of Clothing, Bedding, and Towels
Marriage Requests
Non-Medical Emergency Escorted Trip
Recreation
Religious Practices
V
Work Pr{)or,,'m

HEALTH SERVICES

18.
19.
20.

Hunger Strikes
Medical Care
Suicide Prevention and Intervention
Terminal Illnes Advanced Directives and Death

23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35..
36.
37.
38.

Detention Files
Disciplinary Policy
Emergency Plans
Environmental Health and Safety
Hold Rooms in Detention Facilities
Key and Lock Control
Population Counts
Post Orders
Security Inspections
Special Management Units (Administrative Detention)
Special Management Units (Disciplinary Segregation)
Tool Control
Transportation (Land management)
Use of Force
Staff / Detainee Communication (Added August 2003)
Detainee Transfer

ALL FINDINGS OF DEFICIENT AND AT-RISK REQUIRE WRITTEN COMMENT DESCRIBING THE FINDING AND
WHAT IS NECESSARY TO REACH COMPLIANCE.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

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RIC REVIEW ASSURANCE STATEMENT
By SIGNING BELOW, THE REVIEWER-IN-CHARGE (RIC) CERTIFIES THAT:
1.

ALL FINDINGS OF NON-COMPLIANCE WITH POLICY OR INADEQUATE CONTROLS, AND FINDINGS OF NOTEWORTHY
ACCOMPLISHMENTS, CONTAINED IN THIS INSPECTION REpORT, ARE SUPPORTED BY EVIDENCE THAT IS SUFFICIENT AND
RELIABLE; AND
WITHIN THE SCOPE OF THIS REVIEW, THE FACILITY IS OPERATING IN ACCORDANCE WITH APPLICABLE LAW AND POLICY, AND
PROPERTY AND RESOURCES ARE BEING EFFICIENTLY UTILIZED AND ADEQUATELY SAFEGUARDED, EXCEPT FOR ANY
DEFICIENCIES NOTED IN THE REPORT.

2.

REVIEWER-IN-CHARGE
Reviewer-In-Charge: (Print Name)
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Title & Duty Location
Jul 23,2008

TEAM MEMBERS
Print Name, Title, & Duty Location

Print Name, Title, & Duty Location

SME Medical

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SME Safety
Print Name, Title, & Duty Location

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& Duty Location
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SME Food Service

RECOMMENDED RATING:

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SME Security

SUPERIOR
GOOD

ACCEPTABLE
DEFICIENT
OAT-RISK

COMMENTS:

A presumptive rating of "Acceptable" is recommended by the RIC. This rating anticipates a viable plan of action
submitted by the facility to ICE in correction of those areas of concern pointed out by the RIC, which ultimately brings the facility into
compliance with ICE standards.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

© 2007 Creative Corrections, LLC (Rev. 12/8/07)

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