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
ERO San Diego Field Office
San Diego Contract Detention Facility
San Diego, California

April 14–16, 2015

COMPLIANCE INSPECTION
SAN DIEGO CONTRACT DETENTION FACILITY
ERO SAN DIEGO FIELD OFFICE
TABLE OF CONTENTS
INSPECTION PROCESS
Report Organization .............................................................................................................1
Inspection Team Members ...................................................................................................1
EXECUTIVE SUMMARY ...........................................................................................................3
OPERATIONAL ENVIRONMENT
Detainee Relations ...............................................................................................................7
ICE 2011 PERFORMANCE BASED NATIONAL DETENTION STANDARDS
Detention Standards Reviewed ............................................................................................8
Admission and Release ........................................................................................................9
Funds and Personal Property .............................................................................................11

INSPECTION PROCESS
The U.S. Immigration and Customs Enforcement (ICE), Office of Professional
Responsibility (OPR), Office of Detention Oversight (ODO) conducts broad-based compliance
inspections to determine a detention facility’s overall compliance with the applicable ICE
National Detention Standards (NDS) or Performance-Based National Detention
Standards (PBNDS), and ICE policies. ODO bases its compliance inspections around specific
detention standards, also referred to as core standards, which directly affect detainee health,
safety, and well-being. Inspections may also be based on allegations or issues of high priority or
interest to ICE executive management.
Prior to an inspection, ODO reviews information from various sources, including the Joint Intake
Center (JIC), Enforcement and Removal Operations (ERO), detention facility management, and
other program offices within the U.S. Department of Homeland Security (DHS). Immediately
following an inspection, ODO hosts a closeout briefing at which all identified deficiencies are
discussed in person with both facility and ERO field office management. Within days, ODO
provides ERO a preliminary findings report, and later, a final report, to assist in developing
corrective actions to resolve identified deficiencies.

REPORT ORGANIZATION
ODO’s compliance inspection reports provide executive ICE and ERO leadership with an
independent assessment of the overall state of ICE detention facilities. They assist leadership in
ensuring and enhancing the safety, health, and well-being of detainees and allow ICE to make
decisions on the most appropriate actions for individual detention facilities nationwide.
ODO defines a deficiency as a violation of written policy that can be specifically linked to ICE
detention standards, ICE policies, or operational procedures. Deficiencies in this report are
highlighted in bold and coded using unique identifiers. Recommendations for corrective actions
are made where appropriate. The report also highlights ICE’s priority components, when
applicable. Priority components have been identified for the 2008 and 2011 PBNDS; priority
components have not yet been identified for the NDS. Priority components, which replaced the
system of mandatory components, are designed to better reflect detention standards that ICE
considers of critical importance. These components have been selected from across a range of
detention standards based on their importance to factors such as health and safety, facility
security, detainee rights, and quality of life in detention. Deficient priority components will be
footnoted, when applicable. Comments and questions regarding this report should be forwarded
to the Deputy Division Director, OPR ODO.

INSPECTION TEAM MEMBERS

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

Inspections and Compliance Specialist (Team Lead)
ODO
Inspections and Compliance Specialist
ODO
Inspections and Compliance Specialist
ODO
Contractor
Creative Corrections
Contractor
Creative Corrections

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

Contractor
Contractor
Contractor

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Creative Corrections
Creative Corrections
Creative Corrections

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EXECUTIVE SUMMARY
ODO conducted a compliance inspection of the San Diego Contract Detention Facility (SDCDF)
in San Diego, California, from April 14 to 16, 2015. SDCDF, which opened in 1998, is owned
by the County of San Diego and operated by Corrections Corporation of America. ERO began
housing detainees at SDCDF in May 1998 under an Intergovernmental Service Agreement.
Male and female detainees of security classification levels I through III are detained at the
facility for periods in excess of 72 hours. The inspection evaluated SDCDF’s compliance with
the 2011 PBNDS.
Capacity and Population Statistics

The ERO Field Office Director
(FOD) in San Diego, California, is
responsible for ensuring facility
compliance with the 2011 PBNDS
and ICE policies. An ERO Assistant
Field Office Director (AFOD) and(b)(7)e
ERO staff members are located at the
facility. A Detention Services
Manager is assigned to SDCDF.

Quantity

Total Bed Capacity

1040

ICE Detainee Bed Capacity

696

Average Daily Population

987

Average ICE Detainee Population

658

Average Length of Stay (Days)

60

Male Detainee Population (as of 04/14/2015)

576

Female Detainee Population (as of 04/14/2015)

44

A Warden is responsible for oversight of daily facility operations and is supported by (b)(7)e
personnel. Trinity Food Services provides food services and the ICE Health Services Corps
(IHSC) provides medical services. The facility holds an American Correctional Association
accreditation.
In September 2012, ODO conducted an inspection of the SDCDF under the 2008 PBNDS. ODO
reviewed 18 standards and found SDCDF compliant with 16 standards. ODO found one
deficiency in each of the remaining two standards: Law Libraries and Legal Materials, and
Suicide Prevention and Intervention.
During this inspection ODO reviewed 16 2011 PBNDS and found SDCDF compliant with 14
standards. ODO found a total of two deficiencies in the remaining standards: Admission and
Release (1), and Funds and Personal Property (1).
This report details all deficiencies and refers to the specific relevant sections of the 2011
PBNDS. ERO will be provided a copy of this report to assist in developing corrective actions to
resolve all identified deficiencies. ODO discussed preliminary findings with SDCDF and ERO
management during the inspection and at a closeout briefing conducted on April 16, 2015.
Facility staff coordinates the movement of detainees through the booking and release process.
Detainees enter a secure vestibule where they are identified and restraints are removed. They are
then searched by way of walk-through metal detector; a pat-search; and, a B.O.S.S. chair™, a
non-invasive electronic device which scans body cavities for hidden metal objects. Detainee
property is screened using a conveyer belt x-ray machine, and is later hand searched and
inventoried in the presence of the detainee. Per policy, an arriving detainee may be strip
searched only if there is reasonable suspicion that he or she is hiding contraband. All strip
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searches require written report supporting probable cause, supervisory authorization, and
documentation of the details of the search. A copy of the report must be provided to the
detainee.
SDCDF classifies detainees using the ICE Custody Classification worksheet. Documentation
provided by ERO, including the detainee’s criminal history, is used to complete the process.
Classification levels are reviewed and approved by the classification supervisor at the conclusion
of the intake process, and a case manager and unit manager review and approve classification
levels within 72 hours of intake. Classification levels are reviewed at the following intervals: 60
to 90 days following the initial classification, and every 60 to 90 days thereafter; when new
charges or mitigating information is received from ICE are received; and, within 24 hours before
a detainee is released from administrative or disciplinary segregation.
Detainees are issued the ICE National Detainee Handbook and the SDCDF detainee handbook
during admission. A review of 40 randomly selected detainee files revealed signed receipts for
both handbooks. The English version of the SDCDF detainee handbook addresses all required
information outlined in the standard. ODO found the orientation video provided by SDCDF was
not approved by ERO and did not contain all of the elements required by the 2011 PBNDS.
Detainee’s funds and personal property are inventoried during admission. The detainee and an
intake staff member sign a receipt, which is placed in the detainee’s detention file. Property,
such as clothing, is placed in a bag and stored in a secure storage room; valuables are secured in
a locked filing cabinet in a separate secure room. Funds are secured in a lock-box until they are
deposited into the detainee’s commissary account. Foreign currency is placed in a sealed bag
with the valuable property, and the number of bills and denomination are written on a form and
sealed in the bag. The SDCDF detainee handbook does not address the procedures for accessing
personal funds to pay for legal services.
The grievance system allows detainees to file informal, formal, and emergency grievances.
Grievance forms are available in the housing units, and detainees may place completed grievance
forms in a secure lock box mounted on the wall outside the housing area. The lock box is
checked daily by facility staff. Assistance is available for detainees in need of help completing a
grievance form. The SDCDF maintains an electronic grievance log to document and track
grievances filed by detainees. The detainee handbook provides notice to detainees that they may
file both formal and informal grievances, as well as the procedures for filing an appeal to a
grievance response.
SDCDF has a main law library and five satellite law libraries. The main law library contains ten
fully functioning computers with an updated version of LexisNexis. The designated rooms for
the law-libraries are well-lit, contain sufficient furnishings, and are equipped with adequate
equipment and supplies to support legal research and case preparation. Detainees may access the
library by submitting a request form. The SDCDF detainee handbook notifies detainees of the
opportunity and procedures to access the law library.
The food service department is operated by Trinity Services Group. The food service staff is
supported by a work crew consisting of both ICE detainees and U.S. Marshal Service inmates
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who have medical clearance to work in the kitchen. General cycle, religious and medical diet
menus are certified annually by a registered dietitian. ODO observed a noon meal during the
inspection and found the food was the appropriate temperature, and served in the proper portions.
Sanitation was very good throughout the food service department. The walk-in freezer and
coolers were clean and organized. The kitchen is inspected annually by the County of San Diego
Department of Environmental Health. Aztec Pest Control conducts monthly inspections and
treatment for insects and vermin infestations. No signs of pest or vermin infestation were
observed by ODO.
The overall sanitation of the facility was very good. Detainee housing units were clean and well
maintained. The showers were clean, and rooms were organized. The common areas throughout
the facility were kept in a sanitary condition. A master index of hazardous substances is
maintained in the safety office. Material Safety Data Sheets are also maintained in the food
service and maintenance departments. Flammable, toxic, and caustic substances were properly
secured in storage areas and inventories were accurate. Weekly fire and safety inspections are
conducted by designated staff members and monthly safety inspections are conducted by the
safety manager.
Health care at the SDCDF is provided by IHSC. The clinic is open 24 hours a day, seven days a
week and is managed by the Health Services Administrator who is a registered nurse. The
clinical director is a full-time physician. The nursing staff consists of a registered nurse
manager,(b)(7)eregistered nurses, and (b)(7)elicensed vocational and licensed practical nurses.
Mental health services are provided by(b)(7)efull-time psychiatrist, (b)(7)epsychologists (b)(7)e social
worker, and
psychiatric registered nurses. Dental services are provided by a dentist, dental
assistant and a dental hygienist. SDCDF has(b)(7)efull-time pharmacist and (b)(7)efull-time
pharmacy assistant. On call coverage is provided 24 hours a day, seven days a week: by a
physician or mid-level provider for medical concerns, and by a psychologist for mental health
concerns. Detainees in need of emergency care are transported to Alvarado Hospital Medical
Center located in San Diego, California.
ODO verified detainees are screened for suicide risk during the intake process. A review of
training records for all medical and(b)(7)erandomly selected correctional staff confirmed
completion of initial and annual suicide prevention and intervention training. Detainees on
suicide watch are housed in the medical observation area. Six rooms in the medical observation
area are used for suicide watch where detainees are monitored by one-to-one direct observation.
Detainees on suicide watch wear a quilted suicide smock and are given a quilted blanket, if
needed. A review of ten detainee suicide watch records confirmed monitoring is in accordance
with the standard, and removal from suicide watch is approved by the mental health provider.
The Associate Warden is the designated Prison Rape Elimination Act compliance manager and
Sexual Abuse and Assault Prevention & Intervention (SAAPI) coordinator. A Supervisory
Immigration Enforcement Agent oversees compliance with the standard on behalf of ERO. The
facility has established a Sexual Assault Response Team. The facility has a memorandum of
understanding to support the SAAPI program with the San Diego Sheriff’s Department and the
Alvarado Parkway Institute. Detainees are screened for sexually aggressive behavior or
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vulnerability during admission. Detainees are notified of the SAAPI program and the facility
“zero tolerance” policy by way of the detainee handbook, postings, and a video shown during
orientation and after the daily lunch meal.
The Special Management Units (SMUs) are equipped with necessary furniture and fixtures that
are secured to the floors or walls. The units have shower facilities, day rooms, and adjacent
outdoor recreation areas. There are two portable telephones in each of the units and a separate
law library. SDCDF’s policy allows visitation privileges, recreation, and laundry and linen
exchange for detainees housed in the SMUs consistent with the general population. ODO’s
review of 40 randomly selected administrative and disciplinary segregation files of detainees
who are currently or were previously housed, revealed segregation orders were completed and
provided to the detainees.
ERO staff conducts scheduled visits to the housing units every Tuesday, Thursday, and Friday to
address detainees’ personal concerns. Housing unit logs of ERO visits were reviewed by ODO
and provided verification that ERO visits are conducted. Detainees can submit written requests
for ERO visits by filling out and submitting an ICE Detainee Request Form. All requests
submitted by detainees are collected daily by ICE staff. The SDCDF detainee handbook notifies
detainees of the opportunity to submit written questions and concerns to ICE staff, and the
availability of assistance in preparing requests.
Detainees have reasonable and equitable access to telephones at SDCDF. The facility provides
telephone access rules in writing to each detainee upon admittance. Talton Communications is
SDCDF’s telephone service provider. The rate for making local debit, long distance debit, long
distance pre-paid collect, and local pre-paid collect calls is $0.10 per minute. The rate for long
distance collect, local collect, and international debit calls is $0.15 per minute. The rate for
international mobile calls is $0.35 per minute. Facility staff indicated that the telephone service
provider has not implemented a surcharge in the phone service. Detainees may add funds to
their calling account by submitting a request to the facility commissary. ODO reviewed
telephone serviceability checklists which provided verification that ERO staff members inspect
phones on a regular basis. Detainees are notified of telephone monitoring in the SDCDF
detainee handbook and postings near the telephones. The procedure for obtaining an
unmonitored call is posted in each housing unit and in the SDCDF detainee handbook.
SCDCF has a program that allows detainees to have messages left at a charge of $1.20 per
message. SDCDF also has a Text Telephone (TTY) for the hearing impaired.
SDCDF has written policies governing the use of force. SDCDF officers complete pre-service
and annual training in the use of force. The facility has an(b)(7)dmember special operations
response team (SORT), which is activated with the approval of the Warden and ERO. Use of
oleoresin capsicum spray may be authorized by a supervisor after consultation with medical
staff. The facility uses video cameras to record calculated use of force incidents. ERO is
notified within two hours of a use of force incident. Use of force after action reviews are
conducted within two business days, and the documentation is forwarded to the FOD
immediately.

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OPERATIONAL ENVIRONMENT
DETAINEE RELATIONS
ODO interviewed 40 randomly selected detainees to assess the conditions of confinement at
SDCDF. The 40 detainees consisted of 34 males and six females. Interview participation was
voluntary and none of the detainees made allegations of discrimination. The majority of
detainees reported being satisfied with facility services with the exception of the complaints
below.
Food Service: Two detainees complained about finding rocks in their food. One detainee
claimed he bit down on a rock during a meal consisting of hamburger and broke off a piece of
his tooth. The facility investigated the incident, and the food service provider now performs
quality checks of meals served. The detainee with the cracked tooth was treated and scheduled
to have the damaged tooth removed.
Grievance System: A detainee submitted an ICE Detainee Request Form (IDR) to his
Deportation Officer (DO) requesting information regarding his immigration case approximately
12 days prior to ODO’s interview. The detainee stated his DO advised him to call the 800 toll
free number to obtain information about the case. ODO reviewed the detention file and found an
IDR was submitted and answered the same day by the DO.
Medical Care: Four detainees made allegations regarding medical services at SDCDF. The first
detainee alleged she had a toothache that was not treated. ODO reviewed the detainee’s medical
record, notified the clinic of the detainee’s complaint, and an appointment was made for the
detainee to see the dentist. The second detainee alleged she had a shoulder injury. ODO
reviewed the detainee’s medical record and found the detainee was seen by medical staff on five
different occasions. None of the visits concerned a shoulder injury. The third detainee alleged
he did not receive medical care for a sleep condition. A review of the detainee’s medical record
revealed the detainee was treated for his sleep condition. A follow-up appointment was
scheduled by the medical clinic for the detainee. The fourth detainee complained of a hematoma
(a collection of blood outside of a blood vessel which may be similar to a bruise) located on his
forehead. The detainee stated he requested a medical procedure to remove the hematoma, but
did not receive response. ODO reviewed the detainee’s medical record and found documentation
that the medical clinic assessed the detainee’s hematoma, but did not remove it as the procedure
was deemed cosmetic by the IHSC Field Medical Coordinator.
Telephone Access: A detainee alleged funds were not deposited into his telephone calling
account. ODO reviewed SDCDF’s computerized Offender Management System and found the
funds were deposited in the detainee’s account the day after his admission. The system showed
the detainee began making calls the next day.

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ICE 2011 PERFORMANCE-BASED
NATIONAL DETENTION STANDARDS
ODO reviewed a total of 16 ICE 2011 PBNDS and found SDCDF fully compliant with the
following 14 standards:
1. Custody Classification System
2. Detainee Handbook
3. Environmental Health & Safety
4. Food Service
5. Grievance System
6. Law Libraries and Legal Materials
7. Medical Care
8. Medical Care (Women)
9. Sexual Abuse and Assault Prevention & Intervention
10. Significant Self-Harm and Suicide Prevention and Intervention
11. Special Management Units
12. Staff-Detainee Communication
13. Telephone Access
14. Use of Force and Restraints
Because the standards above were compliant at the time of the inspection, synopses for these
standards are not included in this report.
ODO found 2 deficiencies in the following 2 standards:
1. Admission and Release
2. Funds and Personal Property
Findings for these standards are presented in the remainder of this report.

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ADMISSION AND RELEASE (AR)
ODO reviewed the Admission and Release standard at SDCDF to determine if procedures are in
place to protect the health, safety, security and welfare of each person during the admission and
release process, in accordance with the ICE 2011 PBNDS. ODO reviewed policy and detainee
files, and interviewed staff and detainees.
Seven corrections officers coordinate the movement of detainees through the booking and release
process. Detainees enter a secure vestibule where they are identified and restraints are removed.
They are then searched by way of walk-through metal detector, pat-search, and “Boss Chair,” an
electronic device which identifies secreted metal objects. Property is screened using a conveyer
belt x-ray machine, and physical search. The property is inventoried in the presence of the
detainee. Per policy, an arriving detainee may be strip searched only if there is reasonable
suspicion that he or she is secreting contraband. A written report supporting reasonable
suspicion, supervisory authorization, and documentation of the details of the search is required,
and a copy of the report is provided to the detainee.
At the time of ODO’s review, facility records indicated one detainee was strip searched in 2015,
and 11 detainees were strip searched in 2014. Strip search records confirmed both supervisory
approval and documentation of case-specific reasonable suspicion. Strip searches are conducted
by officers of the same gender, and out of view of non-involved staff and other detainees.
ODO confirmed the admissions process includes the following: completion of initial
classification; inventory and receipting of funds and property; sexual abuse and assault
prevention and intervention screening; medical, mental health and suicide screening; and,
issuance of the detainee handbooks, clothing, linens, and personal hygiene items. Personal
hygiene items issued during the intake process are replenished as needed, free of charge.
Detainees view an orientation presentation during intake processing which includes the
following topics: Know Your Rights, telephone system access, the SAAPI policy and “zero
tolerance” statement, and facility-specific information. The orientation video was not approved
by ERO and it does not address the following topics as required by the standard: an overview of
the facility operations that most affect the detainees; responsibilities and duties of security
officers; standards of conduct including an overview of rules and requirements; disciplinary
procedures; voluntary work programs; and, specific schedules of programs, services and daily
activities (Deficiency AR-1).
ODO confirmed release procedures are in compliance with the standard. A review of 40
randomly selected detainee files confirmed required documentation for the admission and release
process was present.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY AR-1
In accordance with the ICE 2011 PBNDS, Admission and Release, section
(V)(F)(1)(2)(3)(6)(10) and (11), the FOD must ensure, “All facilities shall have a method to
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provide ICE/ERO detainees an orientation to the facility as soon as practicable, in a language or
manner that detainees can understand. Orientation procedures in CDFs and IGSAs must be
approved in advance by the local ICE/ERO Field Office. At SPCs, CDFs, and dedicated IGSAs,
the facility administrator shall produce an orientation video that covers the required topics listed
below and shall screen it for every detainee. The video shall generally be in English and Spanish
and provisions shall be made for other significant segments of the population with limited
English proficiency. The facility administrator shall establish procedures that ensure the
availability of an interpreter for a detainee who does not speak the language(s) used in the video.
The interpreter shall be available for orientation and scheduled meetings with the detainee.
Outside sources may be used if necessary to ensure compliance with this requirement, consistent
with security measures. The orientation shall include the following information:
1. an overview of the facility operations that most affect the detainees
2. typical detention-case chronology (what most detainees can expect);
3. authority, responsibilities and duties of security officers;
6. standards of conduct, including acceptable and unacceptable detainee behavior, with an
overview of other rules and requirements;
10. schedule of programs, services and daily activities, including visitation, telephone usage,
mail service, religious programs, count procedures, access to and use of the law library
and the general library, and sick-call procedures;
11. voluntary work program, with specific detains including how to volunteer.”

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FUNDS AND PERSONAL PROPERTY (F&PP)
ODO reviewed the Funds and Personal Property standard at SDCDF to determine if controls are
in place to inventory, receipt, and store and safeguard detainees’ personal property, in
accordance with the ICE 2011 PBNDS. ODO toured the facility, reviewed policy, interviewed
staff, and inspected areas where detainee property is stored.
Detainees are informed of procedures relating to property through the SDCDF detainee
handbook. The detainee handbook does not address the procedures for accessing personal funds
to pay for legal services (Deficiency F&PP-1).
Upon detainee admission, personal property is inventoried, and the detainee and intake staff sign
a receipt. Property, such as clothing, is secured in a bag and placed in a secure storage room
with appropriate identifying documents. Valuables are secured in separate bags and locked in
filing cabinets in a secure room. The secure room can only be accessed by the sergeant on duty
in the intake area. Funds are secured in a lock-box until they are deposited into the detainee’s
commissary account. Foreign currency is placed in a sealed bag with the valuable property and
the number of bills and denomination are written on a form and sealed in the bag. The oncoming
and outgoing shift supervisors count the money before every shift change.
40 randomly selected detainee files reviewed by ODO all contained inventory sheets and receipts
for both funds and property, as well as a forwarding address or a signed declination to provide a
forwarding address. Property officers conduct ongoing audits and keep track of audit results in
an audit log.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY F&PP-1
In accordance with the ICE 2011 PBNDS, Funds and Personal Property section (V)(C)(6), the
FOD must ensure, “the detainee handbook or equivalent shall notify the detainees of facility
policies and procedures concerning personal property, including:
6. access to detainee personal funds to pay for legal services.”

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