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
South Texas Detention Complex
Pearsall, Texas

February 7- 9, 2012

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
In reference to ICE Policy 17006.1, issued 09/22/05; any disclosure,
deficiencies.
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
SOUTH TEXAS DETENTION COMPLEX
SAN ANTONIO 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
PERFORMANCE BASED NATIONAL DETENTION STANDARDS
Detention Standards Reviewed ................................................................................ 8
Funds and Personal Property ................................................................................... 9

EXECUTIVE SUMMARY
The Office of Professional Responsibility (OPR), Office of Detention Oversight (ODO)
conducted a Compliance Inspection (CI) of the South Texas Detention Complex (STDC) in
Pearsall, Texas, from February 7-9, 2012. STDC is owned by Frio County and operated by the
GEO Group (GEO). STDC opened in May 2005 under contract with U.S. Immigration and
Customs Enforcement (ICE) as a contract detention facility (CDF). STDC accommodates male
ICE detainees of all three classification levels for periods in excess of72 hours. Female
detainees are not housed at STDC. The ICE Health Service Corps (IHSC) and contractor STG
provide medical services. GEO provides food service. STDC is accredited by the American
Correctional Association (ACA) and the National Commission on Correctional Health Care
(NCCHC).
The ICE Office ofEnforcement and Removal Operations (ERO), Field Office Director, San
Antonio, Texas (FOD/San Antonio) is responsible for ensuring STDC maintains compliance
with ICE policies and the ICE Performance Based National Detention Standards (PBNDS). The
Assistant Field Office Director (AFOD) assigned to the ERO office in Pearsall, Texas, which is
co-located at the facility, maintains oversight of STDC. The ERO staff consists of
full-time
b6, b7c
positions. Supervisory ERO staff consists ob6, b7cSupervisory Detention and Deportation
Officers (SDDO), and
Supervisory Immigration Enforcement Agents (SIEA). A Detention
b6, b7c
Service Manager (DSM) assigned to the facility is also co-located at STDC. GEO staff consists
of
b6, b7cpositions. The highest ranking GEO official at STDC is the Warden, who is responsible
for oversight of daily operations. Supervisory GEO security staff is comprised of a Deputy
Warden,b6, b7cAssistant Wardens,b6, b7cMajors,b6, b7cCaptains,b6, b7c
Lieutenants, and
Sergeants.
b6, b7c
The medical staff consists of
employees.
The
clinic
staff
includes
a
Health
Services
b6, b7c
Administrator (HSA), an Assistant HSA, a Clinical Director (CD), a physician,b6, b7cmid-level
providers, a Nurse Manager,
registered nurses (RN),
licensed vocational nurses (L VN),
b6, b7c
b6, b7c
and
medical record technicians. Total housing capacity at STDC is 1,904, which is dedicated
b6, b7c
entirely to ICE detainees. At the time of the CI, 1,686 ICE detainees were housed at STDC. The
average length of stay for a detainee at STDC is 37 days.
This is the first ODO inspection of STDC under the PBNDS. ODO previously inspected the
STDC in August 2009 when STDC was obligated to comply with the National Detention
Standards (NDS). At the completion of the NDS inspection, STDC was found to be in
compliance with 14 of the 31 standards reviewed. ODO found 26 deficiencies in the remaining
17 areas: Access to Legal Material (1 deficiency), Admission and Release (1 ), Correspondence
and Other Mail (1), Detainee Grievance Procedures (4), Detainee Handbook (1), Detention Files
(1), Emergency Plans (1), Food Service (1), F:unds and Personal Property (2), Hold Rooms in
Detention Facilities (3), Key and Lock Control (2), Medical Care (3), Population Counts (1 ),
Post Orders (1), Security Inspections (1), Suicide Prevention and Intervention (1), and Use of
Force (1).
On March 31,2011, ERO Detention Standards Compliance Unit contractor, MGT of America,
Inc., conducted an annual review of the ICE PBNDS at STDC. The facility received an overall
rating of"Meets Standards," and was found compliant with 41 of the 41 standards reviewed.

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During this CI, ODO reviewed a total of 15 PBNDS; 14 standards were found to be fully
compliant, including Admissions and Release, Classification System, Detainee Handbook,
Detainee Transfers, Food Service, Grievance Procedures, Hunger Strikes, Law Libraries and
Legal Material, Medical Care, Special Management Units, Staff-Detainee Communication,
Suicide Prevention and Intervention, Telephone Access, and Use of Force. One deficiency was
found in the Funds and Personal Property standard. This deficiency is not related to the
deficiencies found in the Funds and Personal Property NDS during the 2009 ODO inspection.
This report details the lone deficiency and refers to the specific, relevant section of the ICE
PBNDS. OPR will provide ERO a copy of this report to assist in developing corrective actions
to resolve the identified deficiency. This deficiency was discussed with STDC and ERO
personnel on-site during the inspection, as well as during the closeout briefing conducted on
February 9, 2012.
Overall, ODO found STDC to be well-managed and in compliance with the standards inspected.
ODO found STDC policies and procedures were constructed using language found in the
PBNDS to ensure compliance with the PBNDS. The lack of deficiencies can be attributed to the
use of compliance teams at STDC, which ODO has identified as a best practice. ICE and STDC
management have created two compliance units to monitor adherence to applicable standards
STDC and
and practices. Both units consist of
b6, b7c
b6, b7cemployees, and each unit is comprised of
ICE employee. The units achieve compliance with ICE detention standards through routine
b6, b7c
auditing and oversight. During the CI, the lone deficiency identified was the lack of secure
storage for detainee personal property in the housing areas as required by the ICE PBNDS.
ODO noted no deficiencies during a review of the Medical Care PBNDS. ODO toured the
clinic, reviewed policies and procedures, interviewed staff, examined 25 medical records, and
verified all medical staff credentials. ODO confirmed intake screening was performed by an RN
who triages all arriving detainees for any signs of respiratory symptoms as well as chronic
disease. Detainees with such symptoms or other identified medical issues are the first to undergo
full intake screening during admission. Tuberculosis (TB) testing, medications, treatment for
special and chronic needs, and follow-up care are provided. During the admissions process,
detainees sign a consent form prior to receiving a chest x-ray (CXR) to screen for TB. The
results of the CXR are read by a radiologist and received within four hours. If pathology other
than TB is found on the CXR, the radiologist recommends further evaluation.
Detainees access care by submitting written medical requests available in English and Spanish,
which are placed in secure "Medical Request" boxes located in the housing areas. Nursing staff
collect and triage the sick call slips in a timely manner to determine priority for care. Sick call is
conducted daily. ODO verified cardio-pulmonary resuscitation (CPR) training for all medical
staff and for 15 randomly reviewed custodial staff.
Physical examinations (PE) are conducted by mid-level practitioners and RNs who have been
trained by the physician to perform this function. ODO reviewed 25 detainee files and
determined all 25 detainees had received aPE within the required 14-day timeframe. The
physician had reviewed and signed every PE conducted by the RN. Detainees with chronic care
needs are seen for follow-up every three months or more frequently based on need. ODO
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verified medications for chronic conditions were ordered and documented in medication
administration records. ODO verified medical transfer summaries were included in the medical
records of detainees being released or transferred from STDC. There were no reports of suicide
attempts or detainee deaths at STDC during the 12 months preceding this CI.
One detainee hunger strike had been reported in the past 12 months. A review of the Hunger
Strike PBNDS confirmed the staff is knowledgeable ofhunger strike policies and procedures.
Detainees on hunger strike housed at STDC are properly monitored. Ac~ording to STDC policy,
if a detainee on a hunger strike deteriorates beyond the level of care available at the facility, the
detainee is transferred to the local hospital.
STDC serves meals to detainees in their housing units via a satellite system. A satellite system
consists of meal preparation in the facility food service area and the provision of meals to
detainees in their respective housing units for consumption. ODO verified all personnel had
received appropriate medical clearances prior to beginning work in food service. A registered
dietitian certifies all menus are nutritionally complete and balanced. Religious and medical diets
are provided in accordance with the standard. Inspection of the food service area confirmed
compliance with food temperature requirements. Temperatures of coolers and freezers were
consistent, and utensils and knives were properly controlled. Overall, the kitchen, food
preparation, dishwashing, and food cart areas were found to be well-managed and properly
maintained.
Deportation Officers (DO) and/or Immigration Enforcement Agents (lEA) visit the housing areas
on a daily basis to address detainee concerns and to monitor living conditions. ODO interviews
of STDC staff confirmed that supervisory ERO personnel make frequent unannounced and
unscheduled visits to the activity areas and housing units. All ofthese visits are properly logged.
STDC has a grievance system that allows detainees to file informal and formal grievances, and to
appeal grievance decisions. At the time ofthe CI, there were no unresolved grievances. STDC
has designated two grievance officers responsible for performing investigations and resolving
grievances. A Grievance Committee consisting of managerial staff also works to resolve
grievances. A review of grievances processed during the six months preceding the CI confirmed
the process is effective and does not reflect patterns or trends indicative of operational,
procedural, or personnel problems. Detainees interviewed stated they believe the grievance
system is fair and functions as described in the detainee handbook.
ODO inspection ofthe Administrative and Disciplinary Special Management Units (SMU)
confirmed the units are well ventilated, adequately lit, appropriately heated, and maintained in a
sanitary condition. Documentation verified the administrator (or designee) makes daily visits to
the SMU. ODO confirmed medical staff is notified when a detainee is placed in SMU to ensure
medical assessments and reviews are conducted. Detainees in SMU are afforded basic living
conditions that mirror those provided to detainees in the general population.
All detainees have access to daily recreation, a law library, and telephone services. Detainees
have the option to participate in religious services and family visitation. Every detainee receives
a copy of the ICE National Detainee Handbook and the local facility handbook supplement.
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Both are available in English and Spanish, which are the predominate languages spoken by
detainees at STDC. The facility has made other foreign language versions available as needed.
There were 12 immediate use offorce incidents and 16 calculated use offorce incidents at STDC
between January 2011 and January 2012. It is worthy of note that one detainee accounted for six
of the 16 calculated use of force incidents. By definition, an immediate use of force situation is
created when detainee behavior constitutes a serious and immediate threat to self, staff, another
detainee, property, or the security and orderly operation of the facility. It may be necessary for
staff to respond to these situations without a supervisor's direction or presence. A calculated use
of force occurs when there is no immediate threat to the detainee or others, and time is available
for officers to formulate strategy and assess the possibility of resolution in the least
confrontational manner.
A review of documentation pertaining to the 12 immediate use of force incidents verified
compliance with the PBNDS and facility policy. ODO also reviewed documentation and viewed
videotapes related to the 16 calculated use of force incidents. All incident reports were
complete, and videos were attached to the reports forwarded to the local ICE office. After-action
reviews were conducted as required. There are five handheld video cameras located throughout
STDC. Each shift has designated response officers as well as assigned camera operators. STDC
personnel receive training in the use of force policy annually.

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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
PBNDS, as applicable. The PBNDS apply to STDC. 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.
ODO reviewed the processes employed at STDC 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 STDC.

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 classifies program issues into one of two categories: deficiencies and areas of concern.
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 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 Office of Detention Oversight.

INSPECTION TEAM MEMBERS

b6, b7c

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

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

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OPERATIONAL ENVIRONMENT
INTERNAL RELATIONS
ODO interviewed the STDC Warden, the Assistant Warden, and the ICE AFOD. During the
interviews, ERO management stated they have the necessary resources and equipment to carry
out their duties and responsibilities, but funding for training and training opportunities are
limited. As a result, ERO personnel assigned to STDC have limited familiarity with ERO
functions outside ofthe detention environment. Requested training includes: Fugitive
Operations, Prosecutions, and Defensive Tactics. The general morale for both STDC and ERO
staff is high. STDC and ERO personnel stated their working relationship is excellent.
The Warden stated STDC personnel levels are sufficient to handle the current ICE detainee
population. ICE DOs and lEAs visit housing units daily to address questions and concerns of
detainees. The AFOD conducts weekly meetings with personnel from ERO, STDC, IHSC, and
the Executive Office for Immigration Review, as well as with the DSM. These meetings enable
roundtable discussions about issues concerning the overall management of the facility and areas
of concern, and provide an open forum to encourage communication by all parties involved.

DETAINEE RELATIONS
ODO randomly selected and interviewed 65 detainees to assess the overall living and detention
conditions at STDC. Detainees had no complaints regarding food service, recreation, the law
library, visitation, or sending and receiving mail.
Of the detainees interviewed, 56 detainees (86%) could not identify their DO, and 42 detainees
(65%) did not know how to contact a DO. ODO reviewed the ERO Daily Logbook maintained
at STDC, and confirmed a DO or an lEA visits detainee housing and activity areas on a daily
basis to address detainees' concerns and monitor living conditions. ODO also confirmed the
schedule for ERO visits was posted in the detainee housing areas listing DO assignments
according to alien number.
Seven detainees (II%) complained about the medical care and responsiveness to their medical
requests. ODO reviewed medical care at STDC and found it to be well-managed. Medical care
is appropriately triaged and provided in a timely manner according to the priority of the
requested or required care.
Three detainees (5%) stated they were not aware that grievance forms were available. ODO
visited housing areas, interviewed staff and detainees, and reviewed policies and procedures,
the detainee handbook, and grievance logs. ODO determined grievance forms are available.
Interviews determined the majority of detainees feel the system is fair and functions as
described in the detainee handbook.
Two detainees (3%) stated they had difficulty connecting to an outside line when using the
telephones. ODO inspected telephones in the 23 housing units and found an adequate number

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of telephones are available. ODO successfully placed calls to a random sample of speed dial
locations. ODO verified telephones are checked daily by STDC staff to ensure all are in
working order. ODO also verified ICE staff inspects the telephones weekly and documents that
speed dial checks are performed.
Three detainees (5%) complained STDC staff members had referred to them by culturally
insensitive slurs, and used profanity when directing detainees. ODO found there were no
grievances filed by any detainees regarding these allegations with either ERO or STDC. ODO
discussed the issue with the STDC Warden during the CI. The Warden stated he was unaware
of any recent incidents, but had disciplined or removed staff for similar conduct in the past.
The Warden stated such conduct is not permitted or tolerated.

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ICE PERFORMANCE BASED
NATIONAL DETENTION STANDARDS
ODO reviewed a total of 15 PBNDS and found STDC fully compliant with the following 14
standards:
Admission and Release
Classification System
Detainee Handbook
Detainee Transfers
Grievance System
Food Service
Hunger Strikes
Law Libraries and Legal Material
Medical Care
Special Management Units
Staff-Detainee Communication
Suicide Prevention and Intervention
Telephone Access
Use ofForce and Restraints
As these standards were compliant at the time of the review, a synopsis for these standards was
not prepared for this report.
ODO found a deficiency in the following standard:
Funds and Personal Property
Findings for this standard are presented in the remainder of this report.

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·FUNDS AND PERSONAL PROPERTY (F&PP)
ODO reviewed the Funds and Personal Property PBNDS at STDC to detennine if controls are in
place to inventory, receipt, store, and safeguard detainees' personal property. ODO toured the
facility, reviewed local policies, interviewed staff, and inspected property storage areas.
ODO found STDC accounts for and safeguards detainee property from the time of admission
until the detainee's release or transfer. Required safeguards are in place to prevent contraband
from entering the facility. An inspection of detainee storage lockers in housing units revealed
the number oflockers is appropriate for the detainee population; however, the facility does not
provide a means to secure personal items placed in the storage lockers (Deficiency F&PP-1).
Providing securable storage lockers prevents theft of detainees' authorized personal property and
limits facility liability.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY F&PP-1
In accordance with the ICE PBNDS, Funds and Personal Property, section (V)(E), the FOD must
ensure every housing area shall have lockers or other securable space for storing detainees'
authorized personal property. The amount of storage space shall correspond to the number of
detainees assigned to that housing area.

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