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

Office of Detention Oversight
Compliance Inspection

Enforcement and Removal Operations
Los Angeles Field Office
Santa Ana Jail
Santa Ana, California

October 25-27, 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
SANTA ANA JAIL
LOS ANGELES FIELD OFFICE
TABLE OF CONTENTS
EXECUTIVE SUMMARY ...............................................................................................1
INSPECTION PROCESS
Report Organization .................................................................................................3
Inspection Team Members .......................................................................................3
OPERATIONAL ENVIRONMENT
Internal Relations .....................................................................................................4
Detainee Relations ...................................................................................................4
NATIONAL DETENTION STANDARDS
Detention Standards Reviewed ................................................................................5
Detainee Transfers ...................................................................................................6
Use of Force .............................................................................................................7

EXECUTIVE SUMMARY
The Office of Professional Responsibility (OPR), Office of Detention Oversight (ODO),
conducted a Compliance Inspection (CI) of the Santa Ana Jail (SAJ) in Santa Ana, California,
October 25-27, 2011. ICE houses detainees in SAJ under an intergovernmental service
agreement (IGSA). SAJ is owned by the City of Santa Ana and managed by the Santa Ana
Police Department. The facility is authorized to house adult male and female ICE detainees for
periods in excess of 72 hours. SAJ has a total capacity of 512, 200 of which are allocated to ICE
detainees. At the time of the inspection, 191 detainees (162 male; 39 female) were housed at the
SAJ. Correctional Managed Care Medical Corporation provides health care and Aramark
provides food service. SAJ holds no accreditations.
The Office of Enforcement and Removal Operations (ERO) Field Office Director (FOD), Los
Angeles, California (FOD/Los Angeles), is responsible for ensuring SAJ is in compliance with
ICE policies and the ICE National Detention Standards (NDS). There are no ICE personnel
physically located at SAJ. An Assistant Field Office Director (AFOD) assigned to the FOD/Los
Angeles is designated as the Officer-in-Charge (OIC), and a Supervisory Detention and
Deportation Officer (SDDO) is the Assistant OIC. There are 112 full-time non-ICE employees
on staff at SAJ.
In November 2010, ODO conducted a Quality Assurance Review (QAR) of the ICE NDS at
SAJ. During that inspection, ODO recorded 29 deficiencies in 10 of the 19 standards reviewed.
In June 2011, the ERO Detention Standards Compliance Unit contractors, MGT of America, Inc.
(MGT), conducted an annual review of the ICE NDS at SAJ. The facility received an overall
rating of “Acceptable” and was found to be in compliance with 32 of the 34 standards reviewed.
During the last ODO QAR, ICE Staff had failed to implement the Change Notice, National
Detention Standards, Staff/Detainee Communication Model Protocol, issued by ERO
Headquarters (HQ) on June 15, 2007, as a supplement to the Staff-Detainee Communication
standard of the ICE NDS. This inspection confirmed implementation of the change notice,
which was intended to ensure that medical, special management unit, and staff-detainee
communication issues are properly administered at detention facilities housing ICE detainees.
During this inspection, ODO reviewed a total of eight ICE NDS that directly relate to the wellbeing of ICE detainees. ODO conducted this inspection without the resources of its MGT
contract support team and analyzed the deficiencies noted in the previous ODO 2010 QAR and
the June 2011 ERO annual inspection to best determine relevant standards for this review. ODO
found no deficiencies in six of the NDS: Detainee Classification System, Detainee Grievance
Procedures, Detainee Handbook, Law Libraries and Legal Material, Telephone Access, and Staff
Detainee Communications. ODO found three deficiencies in this inspection: two in Detainee
Transfers and one in Use of Force.
Although ODO almost always reviews the Medical Care standard at inspected facilities, ODO
did not review it at SAJ due to the unavailability of a medical subject matter expert at the time.
During the last ODO QAR, the review of the Medical Care standard identified deficiencies
regarding maintaining detainee privacy, the cardiopulmonary resuscitation training of facility
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ERO Los Angeles, CA

staff, and the communication of appropriate medical clearances for release, transfer, or removal
of detainees. During MGT’s most recent June 2011 annual inspection of the facility, ERO did
not identify any deficiencies during the medical care standard review
Overall, ODO found SAJ to be in compliance with the standards inspected; however, review of
the Use of Force standard confirmed that no incident reports for the only four use of force
incidents in the last year had been placed in detainee detention files in accordance with the NDS.
Detainee files are complete records documenting time in custody. Inclusion of use of force
reports ensures that information describing behaviors precipitating use of force is available to
personnel having responsibility for handling the movement, transportation, or classification of
detainees. Full documentation supports safety and security by providing accurate information to
facility management on potentially violent detainees.
ICE management and staff conduct both weekly announced visits and regular unannounced visits
to address detainee concerns and inquiries. ERO uses the weekly facility visitation liaison check
list to document these visits and to verify proper oversight by the FOD/Los Angeles.
There was one suicide attempt during the past year at SAJ. The detainee who attempted suicide
was placed on suicide watch in accordance with ICE NDS and applicable SAJ policies. There
have never been any deaths and there were no hunger strikes at the facility in the past year.
This report includes descriptions of all identified deficiencies and refers to the specific, relevant
ICE NDS. The report will be provided to ERO to develop corrective actions to resolve the three
identified deficiencies. All deficiencies were discussed with SAJ personnel on-site during the
inspection and during the closeout briefing conducted on October 27, 2011.

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INSPECTION PROCESS
ODO inspections primarily focus on areas of noncompliance with the ICE NDS or the ICE
Performance Based National Detention Standards, as applicable. In addition, focus may be
applied to the inspection with information provided on detention management by the Office of
Enforcement and Removal Operations (ERO) Headquarters and ERO field offices, and to issues
of high priority or interest to ICE executive management. Inspection objectives are to evaluate
the welfare, safety, and living conditions of detainees, and to determine compliance with
applicable laws, policies, regulations, and procedures.
ODO reviewed the processes employed at SAJ 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 best prepare for the site visit at SAJ.

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 ICE 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 defines a deficiency as a violation of written policy that can be specifically linked to the
ICE NDS, or to ICE policy or operational procedure. Deficiencies are highlighted in bold
throughout the report and are encoded sequentially according to a detention standard designator.
When possible, the report includes contextual and quantitative information relevant to the cited
standard.
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

Special Agent (Team Lead)
Special Agent
Special Agent

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ODO, Phoenix, AZ
ODO, Phoenix, AZ
ODO, Phoenix, AZ

Santa Ana Jail
ERO Los Angeles, CA

OPERATIONAL ENVIRONMENT
INTERNAL RELATIONS
ODO interviewed ICE and SAJ personnel. Facility management and officers assigned who are
familiar with the ICE NDS stated SAJ met the level of care required by the ICE NDS. SAJ staff
indicated they maintain a positive relationship with ICE, and morale is good. ICE supervisory
personnel described the relationship with SAJ as “good” and “positive.” An SDDO stated the
excellent working relationship between ICE and contract employees has enabled the facility to
run smoothly. SAJ management stated ICE supervisors and officers visit detainees in the
housing units a minimum of twice a week. ICE staff indicated they have adequate resources and
equipment to carry out their duties and responsibilities.

DETAINEE RELATIONS
ODO interviewed ten randomly-selected ICE detainees to assess the overall living and detention
conditions at SAJ. Five of ten detainees could not identify their Deportation Officer (DO) and
did not know how to contact a DO. Those detainees were also unaware of how to contact the
DHS Office of Inspector General or the local ERO office. During the inspection, ODO verified
all of this information is conspicuously posted in the living area where detainees have general
access. All of the detainees interviewed stated medical services were adequate, and they were
given hygiene supplies upon arrival. Two detainees stated food portions were too small. ODO
verified that a registered dietitian certifies the menu, and SAJ is in full compliance with the ICE
NDS regarding Food Service.
There were no detainee complaints concerning access to telephones, the law library, recreation,
or sending and receiving mail. Overall, detainees were pleased with the accommodations at SAJ.

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ICE NATIONAL DETENTION STANDARDS
ODO reviewed a total of eight NDS and found SAJ fully compliant with the following six
standards:
Detainee Classification System
Detainee Grievance Procedures
Detainee Handbook
Law Libraries and Legal Material
Telephone Access
Staff Detainee Communications
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 two NDS:
Detainee Transfers
Use of Force
ODO findings for each of these standards are presented in the remainder of this report.

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DETAINEE TRANSFER (DT)
ODO reviewed the Detainee Transfer standard at SAJ to determine if transfers of detainees from
one field office to another are responsibly managed in regard to notification, detention records,
safety and security, and protection of detainee funds and property, in accordance with the ICE
NDS. ODO reviewed records and interviewed staff. At the time of the inspection, there were no
instances of detainees being transferred to SAJ; therefore, ODO was unable to observe the
procedures in practice.
ICE ERO sends SAJ proper documentation when transferring detainees to SAJ, such as
Form I-216 (Record of Persons and Property Transferred), DIHS-796 (Nursing Intake
Screening/Transfer Summary), Form I-203 (Order to Detain/Release), and Classification Sheets.
These forms facilitate proper medical treatment and the appropriate assignment of housing by the
receiving facility.
ODO verified that when legal counsel represents a detainee and a Form G-28 (Attorney of
Record) has been filed, ERO does not document whether the attorney has been notified of the
transfer. This notification is required to be in writing, recorded in the detainee’s A-File, and
documented in ENFORCE (Deficiency DT-1). This notification allows detainees’ attorneys of
record to maintain contact with their clients as they handle the immigration cases.
ODO verified that ERO has not been providing detainees the written notification regarding
facility transfers as required by the standard (Deficiency DT-2). Providing in writing, the name,
address and telephone number of the facility they are being transferred to, ensures detainees
know have this essential information about their detention and allows them to notify others of
their transfer.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DT-1
In accordance with the ICE NDS, Detainee Transfer, section (III)(A)(1), the FOD must ensure
when legal counsel represents a detainee, and a G-28 has been filed, ICE shall notify the
detainee’s representative of record that the detainee is being transferred from one detention
facility to another. This notification shall be recorded in the detainee’s A-file, if available, or
work file, and the notification shall be notated in the comments screen in DACS [ENFORCE].
DEFICIENCY DT-2
In accordance with the ICE NDS, Detainee Transfer, section (III)(A)(3), the FOD must ensure, at
the time of the transfer, ICE will provide the detainee, in writing, with the name, address and
telephone number of the facility he/she is being transferred to.

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USE OF FORCE (UOF)
ODO reviewed the Use of Force standard at SAJ 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, in accordance with the
ICE NDS. ODO interviewed staff and reviewed local policy, training records, and use of force
documentation.
Overall, ODO found SAJ to be in compliance with the Use of Force standard; however, review
confirmed that no incident reports for the only four use of force incidents in the last year had
been placed in detainee detention files in accordance with the NDS (Deficiency UOF-1). In
accordance with the ICE NDS, Detention Files, a detainee’s file is to be a complete record of his
or her time in custody. Inclusion of use of force reports ensures information describing
behaviors precipitating use of force is available to personnel responsible for handling the
movement, transportation, or classification of the detainee. Full documentation supports safety
and security by providing accurate information to facility management on potentially violent
detainees.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY UOF-1
In accordance with the ICE NDS, Use of Force, section (III)(J), the FOD must ensure staff shall
prepare detailed documentation of all incidents involving the use of force, chemical agents, or
non-lethal weapons. Staff shall likewise document the use of restraints on a detainee who
becomes violent or displays signs of imminent violence. A copy of the report shall be placed in
the detainee’s detention file.

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