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
San Antonio Field Office
Karnes County Civil Detention Center
Karnes City, Texas

January 29 - 31, 2013

COMPLIANCE INSPECTION
KARNES COUNTY CIVIL DETENTION CENTER
SAN ANTONIO FIELD OFFICE
TABLE OF CONTENTS
EXECUTIVE SUMMARY ...........................................................................................................1
INSPECTION PROCESS
Report Organization .............................................................................................................8
Inspection Team Members ...................................................................................................8
OPERATIONAL ENVIRONMENT
Internal Relations .................................................................................................................9
Detainee Relations ...............................................................................................................9
ICE PERFORMANCE-BASED NATIONAL DETENTION STANDARDS
Detention Standards Reviewed ..........................................................................................10

EXECUTIVE SUMMARY
The Office of Professional Responsibility, Office of Detention Oversight (ODO) conducted a
Compliance Inspection (CI) of the Karnes County Civil Detention Center (KCCDC) in Karnes
City, Texas, from January 29 to 31, 2013. KCCDC opened in March 2012, and is owned and
operated by the GEO Group, Incorporated (GEO). In March 2012, U.S. Immigration and
Customs Enforcement (ICE), Office of Enforcement and Removal Operations (ERO) began
housing detainees at KCCDC under an intergovernmental service agreement between ICE and
GEO. Level I (lowest threat) and Level II (medium threat) male detainees are held at KCCDC
for periods in excess of 72 hours. KCCDC does not house females or Level III (highest threat)
detainees. KCCDC allocates a total of 608 beds for ICE detainees. At the time of this CI, the
facility housed 535 detainees. The average daily detainee population is 566, and the average
length of stay for a detainee is 36 days. GEO provides medical care and food service at KCCDC.
KCCDC holds no accreditations.
The ERO Field Office Director (FOD) in San Antonio, Texas (FOD San Antonio) is responsible
for ensuring facility compliance with ICE policies and the ICE Performance-Based National
Detention Standards (PBNDS). An Assistant Field Office Director (AFOD) permanently
stationed at KCCDC is the highest ranking ERO official at the facility. In addition to the AFOD,
ERO staff at KCCDC is comprised of(b)(7)eSupervisory Detention and Deportation Officers, (b)(7)e
Supervisory Immigration Enforcement Agents (b)(7)e Deportation Officers, b)(7)emmigration
Enforcement Agents, (b)(7)eEnforcement and Removal Assistants, and(b)(7)eMission Support
Specialists. A Supervisory Immigration Enforcement Agent position and a Deportation Officer
position are currently vacant. A permanently-assigned Detention Service Manager monitors
facility compliance with the PBNDS.
The Facility Administrator is the highest-ranking GEO official at KCCDC, and is responsible for
oversight of daily operations. In addition to the Facility Administrator, staff at KCCDC includes
the Deputy Facility Administrator, the Chief of Security,(b)(7)e executive officers, (b)(7)e security
supervisors, and(b)(7)edetention officers. At the time of the ODO inspection, GEO had no staffing
vacancies at KCCDC. The total number of GEO non-supervisory staff is (b)(7)e
KCCDC was designed to accommodate civil detention and is the result of a collaboration
between GEO and ICE. KCCDC does not have a Special Management Unit (SMU). If the
facility has a detainee that meets the criteria for placement in the SMU, the detainee is
transferred to a facility equipped to provide this type of housing. The SMU PBNDS is not
applicable to the facility and was not reviewed during this CI.
In January 2012, the ERO Detention Standards Compliance Unit contractor, the Nakamoto
Group, Inc., conducted a pre-occupancy inspection of KCCDC for PBNDS compliance.
KCCDC received an overall rating of “Does Not Meet Standards,” and was found compliant
with 38 of 40 standards reviewed. The Nakamoto report cited KCCDC as deficient for not
having an SMU. KCCDC was also found deficient in two mandatory components of the
Environmental Health and Safety PBNDS; however, posting of emergency exit plans, and
approval of fire prevention, control, and evacuation plans were pending at the time of the ERO
inspection.

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In June 2012, Nakamoto conducted a 90-day follow-up PBNDS inspection. Nakamoto found
KCCDC compliant with 39 of 40 standards reviewed. The SMU standard was again found
deficient due to the absence of an SMU, which resulted in a repeat rating of “Does Not Meet
Standards.”
During this CI, ODO reviewed 16 PBNDS. ODO found KCCDC to be orderly, well-managed,
and in full compliance with every standard inspected. ODO observed a high level of sanitation
throughout the interior and exterior of the facility.
ODO attributes the high level of PBNDS compliance to the positive working relationship and
effective communication between ICE and facility staff. KCCDC staff works closely with ICE
management and staff to align facility policies with the PBNDS. ICE personnel are permanently
stationed at the facility, and interact closely with detainees and facility staff in a proactive effort
to identify and resolve compliance issues. ODO cites the presence of a dedicated ERO standards
compliance team and the presence of an on-site Detention Service Manager as major factors in
the outstanding level of PBNDS compliance at KCCDC.
KCCDC has a comprehensive policy addressing detainee classification. The Classification
System User Manual and Appendix 1 of the PBNDS are used as guidance. Detainees are
classified upon admission to the facility and before being placed in general population housing.
A review of the KCCDC detainee roster found 532 detainees classified as Level I detainees, and
three detainees classified as Level II. According to the policy, any detainee reclassified to
Level III for disciplinary or other reasons is immediately transferred to another facility. A
review of 15 detention files and 15 alien files found all contained necessary documentation
supporting appropriate classifications. ODO confirmed there have been no appeals or grievances
related to detainee classification. ICE personnel train KCCDC intake screening staff in the
Classification System standard, and each staff member is provided a certificate of achievement
after successful completion of training. ODO cites this security classification training as a best
practice, because it enhances staff knowledge and promotes adherence to the standard.
Each detainee receives the ICE National detainee handbook and the KCCDC facility handbook,
and both are available in English and Spanish. The KCCDC facility handbook explains rules,
sanctions, the disciplinary system, the grievance system, mail, medical care, recreation, religious
programs, and visitation. The facility handbook also describes classes, such as English as a
Second Language and Life Skills. If a detainee speaks a language other than English or Spanish,
interpretation services are available to explain the detainee handbook. ODO reviewed
15 randomly-selected detention files to determine if detainees had received handbooks. All files
contained documentation signed by each detainee acknowledging receipt of both handbooks.
ODO found KCCDC maintains a high level of sanitation inside and outside of the facility. The
Environmental Specialist/Fire Safety Manager provided documentation of extensive weekly fire
and safety inspections, as well as the required monthly inspections. Evacuation plans, which
include locations of emergency equipment and directional arrows for traffic flow, are
conspicuously posted throughout the facility in English and Spanish. The facility maintains a
master index of hazardous substances and a master file of Material Safety Data Sheets. The
inspection confirmed the master index includes the locations of hazardous substances and
emergency telephone numbers. Inventories of hazardous substances are current and accurate.
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The KCCDC water management system for laundry services is cited by ODO as a best practice.
Water drained from the washing machines flows into a holding tank where it is filtered,
processed, and moved to a storage tank. The recycled water is then pumped back into the
washers. Recycling water for laundry operations reduces water consumption and lowers
associated operating costs.
GEO manages the food service operation at KCCDC. The Food Service Administrator has been
trained by SERVSAFE, which is a food safety training and certification program administered by
the National Restaurant Association. The Food Service Administrator has also successfully
passed the Food Safety Manager Certification Examination administered by the Director of
Public Health for Bexar County, Texas. Approximately(b)(7)edetainees are assigned to each of two
shifts in the kitchen to maintain sanitation and assist with meal preparation. ODO observed the
staff visually assess detainees for health concerns and cleanliness prior to beginning work duties.
Detainee clothing and grooming complied with requirements of the standard. Review of
documentation for (b)(7)e detainee workers confirmed all had received medical clearances and
food service training.
All meals are served in the dining hall, with the exception of meals served to detainees in the
medical and intake screening areas. As detainees enter the dining hall, their identification cards
are scanned into a “Meal Tracker” system. ODO cites this as a best practice, because it tracks
the number of meals served. This system also identifies detainees who miss meals. During the
review, ODO ate the noon meal in the dining room and found the food appetizing. ODO verified
the GEO Corporate Director of Food Service and a dietary consultant have certified the menus as
nutritionally adequate. ODO observed the level of sanitation in the dining hall and food
preparation areas to be at a high standard. ODO confirmed the most recent annual inspection of
the food service operation by the Texas Department of Health Services, which occurred on
February 17, 2012, found KCCDC to be in compliance with applicable health and safety codes.
The property storage area at KCCDC is clean and well-organized. It is located in the admission
and release area behind a locked door, and is accessible only to supervisory staff and the Facility
Administrator. The area is monitored 24 hours a day via closed circuit cameras and KCCDC
staff. All detainee property bags are clearly marked to document the name and alien number of
each detainee. Property is stored and organized using a numerical system. Any property left or
abandoned by a detainee is turned over to ERO for proper disposition. KCCDC conducts weekly
audits of the property storage area, and the results are documented on a facility property form.
Detainees are provided with information on informal and formal grievance procedures via the
detainee handbook and an orientation video. Information is provided in Spanish and English.
The facility has a comprehensive grievance policy addressing all requirements of the PBNDS.
Review of training files for b)(7)estaff members confirmed completion of initial and annual training
in grievance procedures, including procedures for identifying and handling emergency
grievances.
A social worker is designated as the Grievance Coordinator. Informal and formal grievance logs
are maintained. ODO confirmed 14 informal grievances were filed between March 2012 and the
date of the ODO inspection. Disposition of grievances is documented in individual detention
files. Review of five of the 14 informal grievances identified no patterns or concerns, and
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confirmed each grievance was resolved informally. Ten formal grievances were filed during the
same time period. Five of the formal grievances were filed by detainees placed in medical
isolation to wait for testing to rule out tuberculosis. The detainees objected to being placed in
isolation, because they were asymptomatic; however, ODO confirmed placement in isolation
complies with the Medical Care PBNDS and facility policy. Four formal grievances alleged
staff members were disrespectful. One grievance related to what a detainee considered to be an
unjustified disciplinary report. Documentation reflects all formal grievances were properly
investigated and referred to the grievance committee. No grievance decisions were appealed.
ODO confirmed there were no allegations of staff misconduct.
There are two libraries at KCCDC: a law library and a leisure library. The law library is located
in a quiet room, with sufficient furnishings, equipment, and office supplies to support legal
research and case preparation. There are ten computers equipped with the most recent version of
Lexis-Nexis, and there is a printer accessible to all detainees. The law library is open seven days
a week from 8:00 a.m. to 8:00 p.m. A schedule is conspicuously posted in the law library, along
with a list of the law library’s holdings. Detainees stated they are aware of access procedures for
the law library.
ODO toured the medical clinic, reviewed policies and procedures, verified medical staff
credentials, observed the intake screening process, and interviewed the Health Services
Administrator (HSA). ODO examined 30 medical records for detainees in the following
categories: chronic care, appearing on the sick call log for January 23, 2013, suspect
tuberculosis, suicide watch, and random healthy. Each record was spot-checked for sick call
timeliness, reviewed for transfer documentation, and found to be in full PBNDS compliance.
There have been no detainee deaths at KCCDC.
KCCDC currently holds no accreditations; however, the facility is scheduled for survey by the
American Correctional Association in April 2013. Medical services are provided by GEO. The
clinic is open 24 hours a day, seven days a week, and accepts walk-ins at any hour of the day or
night. Administrative oversight is provided by the HSA, and the designated Clinical Medical
Authority is the full-time Clinical Director. Mental health services are provided by a contract
psychiatrist and a full-time psychologist, who are available via video-teleconference. A contract
dentist and a dental assistant are on-site 20 hours a week. On-call coverage is provided by the
Clinical Director, the dentist, and the psychiatrist. ODO finds staffing sufficient to provide basic
medical services to all detainees housed at KCCDC. ODO verified professional licenses are
current and primary source verified for authentication purposes.
ODO cites the extensive information on medical services and patient education provided to
detainees at KCCDC as a best practice. The facility handbook has three separate sections
offering information regarding medical services at KCCDC.
Detainees are allowed unrestricted movement at KCCDC 24 hours a day. Consequently, the
clinic accepts detainees in the clinic on a walk-in basis around-the-clock. Detainees may also
request healthcare services by completing a written request form. These forms, which are
printed in English and Spanish, are available in each housing unit day room and the dining hall.
Detainees complete the forms and deposit them into lockboxes. A nursing staff member
retrieves the requests twice daily, conducts triage to determine priority for care, and records the
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date of each request. Sick call is conducted on a daily basis and is performed in the clinic. ODO
cites the tracking of sick call appointments to ensure reduced wait times as a best practice.
Upon admission, all detainees are issued four pairs of denim pants, four t-shirts, four pairs of
socks, four pairs of underwear, a pair of gym shorts, one sweatshirt, one pair of canvas shoes,
and one pair of shower shoes. Outerwear, adequate bedding garments, and a hygiene kit are also
provided. Detainees may request to have clothing laundered daily, and bedding laundered once a
week. KCCDC maintains an inventory of clothing and personal hygiene items exceeding the
PBNDS requirement of 200 percent of the maximum funded detainee capacity.
The HSA is the designated Sexual Abuse and Assault Prevention and Intervention (SAAPI)
Coordinator. Review of training records for 11 KCCDC staff members confirmed completion of
pre-service, quarterly, and annual training on the SAAPI program. ODO confirmed the training
curriculum addresses all required elements. All personnel interviewed demonstrated a clear
understanding of their duties and responsibilities with respect to handling reports of sexual abuse
or assault. The SAAPI Coordinator was fully knowledgeable regarding the standard and
KCCDC policy.
Information on the SAAPI program is provided to detainees during orientation, in the detainee
handbook, and by way of a brochure available in English and Spanish. The brochure, which is
provided during the intake process, provides guidance for reporting sexual abuse or misconduct
by other detainees or staff. These brochures are available in the libraries, dayrooms, and
program areas. In addition, informational postings are located in the receiving and discharge
areas, the medical department, in hallways, and in every housing unit. All written materials
include toll-free telephone numbers for reporting incidents. During the review, KCCDC
completed installation of a speed-dial option on its detainee telephone system to supplement the
toll-free telephone numbers. This option allows reporting of sexual abuse or assault by dialing
“9” on telephones in housing areas. The detainee is asked in English and Spanish to enter his
alien file number, and is then prompted to record a message reporting the incident. An automatic
e-mail alert is generated and sent to the mobile device of the SAAPI Coordinator. During
demonstration of the system, ODO verified the alert was received by the SAAPI Coordinator
within one minute, which provides a much quicker response than alternate methods. ODO cites
this as a best practice. KCCDC management stated existing materials will be modified to
include information regarding the speed-dial option.
The KCCDC staff-detainee communication policy allows detainees to have informal and
unrestricted access and interaction with ERO and facility staff. ERO visitation schedules are
posted in all detainee housing units. Detainees can also submit formal written questions,
concerns, or requests to ERO and facility staff by completing a request form. From July 2012 to
December 2012, the facility received and processed more than 3,850 formal requests from
detainees. ODO reviewed 248 randomly-selected formal detainee requests submitted during this
time period, and verified each of the 248 requests was documented and recorded in the electronic
request log, a response was provided to the detainee in a timely manner, and a copy of the
completed request was placed in each individual detention file. ODO reviewed the Facility
Liaison Visit Checklists from July 2012 to December 2012, and confirmed ERO officers
consistently conduct scheduled and unannounced visits multiple times each week to interact with
detainees, address questions or concerns, and monitor living conditions in the housing units. The
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AFOD stated ERO officers frequently spend the entire day interacting with detainees during
staff-detainee communication visits, and observing various detainee recreational activities.
KCCDC management conducts town hall meetings with detainees twice a month to facilitate
discussion of complaints and to encourage suggestions from detainees on improving activities
and programs offered within the facility. An intercom system is used to announce meal times,
religious services, special activities, meetings, and commissary and pharmacy operating hours.
All announcements are made in English and Spanish. ODO cites recurring town hall meetings
and the use of an intercom system to facilitate staff-detainee communication as best practices.
ODO inspected the suicide watch cells, interviewed medical and training staff, and reviewed
suicide prevention policies, training curriculum, and staff training records. ODO confirmed local
policy complies with PBNDS requirements. Review of training files by ODO for all medical
personnel and(b)(7)ecustody staff confirmed completion of initial and annual suicide-prevention
training.
KCCDC has a comprehensive detainee transfer policy addressing all requirements of the
Transfer of Detainees PBNDS. During the review, ODO observed 21 detainees being processed
for release on their own recognizance. The property of each detainee was accounted for and
returned, and receipts were exchanged. ODO confirmed medical summary transfer forms were
completed, and medications were forwarded with detainees transferring to other facilities. ODO
reviewed 30 alien files (15 active, 15 archived) and 15 KCCDC detention files. All files
contained required information documenting full compliance with the standard.
Detainees have reasonable and equitable access to telephones at KCCDC. The ratio of
telephones to detainees at KCCDC is one telephone per 4.5 detainees. The PBNDS requires a
ratio of one telephone per 25 detainees. KCCDC provides 118 detainee-accessible telephones
throughout the facility, and all telephones are available 24 hours a day, seven days a week.
Detainees are given emergency messages and allowed to return emergency telephone calls
without delay. Notification that calls are subject to monitoring, and procedures for obtaining
unmonitored legal calls is provided in the detainee handbook and posted near the telephones in
housing units. If a detainee wishes to place an unmonitored telephone call to a legal
representative, an office is available with unmonitored telephones for detainee use. Telephones
are located in each dormitory in areas that provide privacy during calls. Access rules, telephone
numbers, and consulate numbers are posted in English and Spanish near all telephones. ODO
reviewed logbooks and serviceability reports, and confirmed all telephones are inspected daily
by facility staff and weekly by ICE staff.
ODO confirmed there have been no uses of force at the facility since it opened in March 2012.
The KCCDC use of force policy is comprehensive and addresses all requirements of the PBNDS.
Confrontation avoidance is emphasized in policy and in the use of force training curriculum
implemented at KCCDC. ODO reviewed training files fo (b)(7)e taff members and confirmed all
had completed pre-service and annual refresher training in the use of force. KCCDC personnel
do not use electro-muscular disruption devices or a restraint chair. Four-point restraints are
available in the medical area, and their use is discussed in the policy; however, facility
management stated four-point restraints have never been used. ODO confirmed protective gear
and three hand-held video cameras are available in the event a calculated use of force occurs.
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KCCDC policy requires an After Action Review Team consisting of the AFOD or designee, the
HSA, and the KCCDC Facility Administrator. The Deputy Facility Administrator is required to
review all use of force incidents.
KCCDC has a volunteer work program for detainees. Positions available under the program
include: barber, dining hall cleaning crewmember, general cleaner\runner, kitchen worker,
laundry worker, painter, library worker, medical cleaner, and programs cleaner. Compensation
is $3.00 per day for all work assignments. KCCDC management offers various activities for
detainees, such as bingo, outdoor music, movie nights, and cleanest dormitory contests. Arts and
crafts, English as a second language, life skills, and horticulture classes are offered to detainees
at no charge. The amenities at KCCDC promote a detention environment that is non-penal.

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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 or the ICE
PBNDS, as applicable. The PBNDS apply to KCCDC. In addition, ODO may focus its
inspection based on detention management information provided by the ERO Headquarters and
ERO field offices, and to issues of high priority or interest to ICE executive management.
ODO reviewed the processes employed at KCCDC 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, the ENFORCE Alien Booking Module and the ENFORCE Alien
Removal Module. ODO also gathered facility facts and inspection-related information from
ERO Headquarters staff to prepare for the site visit at KCCDC.

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 PBNDS 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 defines a deficiency as a violation of written policy that can be specifically linked to the
PBNDS, 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 ODO.

INSPECTION TEAM MEMBERS

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

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Special Agent (Team Leader)
Special Agent
Special Agent
Contract Inspector
Contract Inspector
Contract Inspector

8

ODO, Houston
ODO, Houston
ODO, Houston
Creative Corrections
Creative Corrections
Creative Corrections

Karnes County Civil Detention Center
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OPERATIONAL ENVIRONMENT
INTERNAL RELATIONS
ODO interviewed the KCCDC Facility Administrator and Deputy Facility Administrator, and the
ERO AFOD, a Supervisory Detention and Deportation Officer, and the Supervisory Immigration
Enforcement Agent responsible for oversight of the facility. All personnel stated the working
relationship between KCCDC and ICE personnel is good. KCCDC and ICE staff stated morale
is high, and working conditions are adequate to accomplish all required duties.
The Facility Administrator and Deputy Facility Administrator stated GEO is adequately staffed
to manage and handle the current detainee population at the facility. The Facility Administrator
and Deputy Facility Administrator stated ICE staff visit the housing units multiple times each
week to communicate with detainees and to address questions or concerns.

DETAINEE RELATIONS
ODO interviewed 45 randomly-selected detainees to assess detention conditions at KCCDC. No
complaints were noted regarding access to legal materials, issuance and replenishment of
hygiene supplies, sending and receiving mail, recreation, visitation, religious services, or the
grievance process. All detainees interviewed expressed satisfaction with the level of medical
care provided. All detainees interviewed stated they were satisfied with telephone service, the
level of interaction with ICE staff, and the cleanliness of the facility. All detainees stated they
received the ICE National Detainee Handbook and the facility handbook upon admission to
KCCDC.

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ICE PERFORMANCE-BASED
NATIONAL DETENTION STANDARDS
ODO reviewed a total of 16 PBNDS and found KCCDC fully compliant with the following
standards:
Admission and Release
Classification System
Detainee Handbook
Environmental Health and Safety
Food Service
Funds and Personal Property
Grievance System
Law Libraries and Legal Material
Medical Care
Personal Hygiene
Sexual Abuse and Assault Prevention and Intervention
Staff-Detainee Communication
Suicide Prevention and Intervention
Telephone Access
Transfer of Detainees
Use of Force and Restraints
As all reviewed standards were found compliant at the time of the inspection, findings were not
prepared for this report.

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