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FIRM / AFFILIATE OFFICES

MEMORANDUM
September 26, 2003

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DRAFT (Final)

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Subject:

U.S. Dept. of Homeland Security, Bureau of Immigration and Customs Enforcement
American Bar Association Delegation to DuPage County Jail
502130-0004
(b)(6)
ABA Commission on Immigration Policy, Practice and Pro Bono,
Detention Standards Implementation Initiative
Report on Observations during a General Tour of the DuPage County Jail, in Wheaton,
Illinois on July 25, 2003

This memorandum summarizes and evaluates information gathered at the DuPage County Jail,
Wheaton, Illinois, facility (“DuPage facility”), through observation by delegation participants and
discussions with DHS and DuPage facility personnel on the July 25, 2003 visit. The delegation was not
able to interview any detainees.
I.

ICE Detention Standards

The Immigration and Naturalization Service (INS, now working as the Department of Homeland
Security, Bureau of Immigration and Customs Enforcement (ICE)) promulgated the “INS Detention
Standards” in November 2000 to insure the “safe, secure and humane treatment of individuals detained
by the INS.” The thirty-six Standards contained in the Detention Operations Manual cover a broad
spectrum of issues ranging from visitation policies to grievance procedures and food service. These
standards apply to INS Service Processing Centers (“S.P.C.”), Contract Detention Facilities (“C.D.F.”),
and state and local government facilities used by the INS through Intergovernmental Service Agreements
(“I.G.S.A.”). The Detention Standards went into effect at INS S.P.C.s on January 1, 2001. The INS
aimed to phase-in the standards in its contract facilities, and state and local facilities, over the next two
years. The INS Detention Standards constitute a “floor” not a “ceiling” for treatment of INS detainees.
In other words, they are meant to establish the minimal requirements that the INS must adhere to in its
facilities. Each District Office or Officer in Charge ("OIC") may, in his or her discretion, promulgate
policies and practices affording INS detainees more enhanced rights and protections than those provided
for by the Standards.
II.

Introduction

CH\619343.1

The DuPage facility is a contract detention facility housing up to 32 detainees from various
nations, and a maximum of 863 total inmates. The national origin of most detainees is Mexico, though
some are from India, Africa, and other nations.1 The detainees are usually held at DuPage for a short
period of time (only a couple of days to a week), although some stay a little longer. The longest any
(b)(6), (b)(7)c
detainee has stayed at the DuPage facility is probably only 15 days, according to Officer
2
the officer who led our tour. Generally, the detainees housed at the DuPage facility are either about to be
transferred to a larger detention facility or about to be deported.3 The facility is located in what looks like
a complex of office buildings in Wheaton, IL, less than an hour outside of Chicago.
This memorandum discusses observations regarding implementation of the ICE Detention
Standards of the Detention Operations Manual at the DuPage County Jail.4The memo focuses on select
portions of the standards which are specifically aimed at the attainment of “safe, secure, and humane
treatment” of immigration detainees. In particular, this memo highlights the following four legal access
Standards: (1) Legal Access; (2) Telephone Access; (3) Legal Materials; (4) Group Rights Presentations;
as well as general observations not relating to legal access that were observed.
III.

Observations of Implementation of Legal Access Standards
A.

Legal Access / Visitation
i.

Visitation by Attorneys

The Standards provide that facilities should allow detainees to meet privately and in a
confidential area with their current or prospective legal representatives, legal assistants and their consular
officials. The facility must permit legal visitation seven days a week, including holidays, and for a
minimum of eight hours per day on regular business days and a minimum of four hours per day on
weekends and holidays.5
At the DuPage facility, although the written rules concerning legal visitation hours meet this
minimum requirement, it is unclear whether the facility normally does so in practice. Attorneys can visit
detainees at the DuPage County Jail everyday and the visiting hours are 7:30 a.m. through 11:00 a.m. and
1:00 p.m. through 4:00 p.m.6 Officer (b)(6), (b)(7)c explained that if necessary, evening visits could be
arranged upon special request for about an hour, usually between 6:30 p.m. and 7:30 p.m..7 The
Inmate/Detainee Handbook says that the professional visitation hours also include 6:00 p.m. through 7:30
p.m.8

(b)(6)

notes on conversation with Officer

(b)(6), (b)(7)c3

Officer (b)(6), (b)(7)c is not the officer usually in charge of leading the tours of the DuPage facility; she admitted she
was less informed than the officer who usually leads the tours.
(b)(6)
notes on conversation with Officer
immigration attorneys in the Chicago area.

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

(b)(6)

notes on conversations with pro bono

4

Detention Operations Manual, http://www.immigration.gov/graphics/lawsregs/guidance.htm.

5

Detention Operations Manual, Visitation, at 8.

6
7

(b)(6)

’s notes.

Id.

8

DuPage County Corrections Bureau Rules and Regulations (Revised January 1, 1999) (“Inmate/Detainee
Handbook”), at 17.

2
CH\619343.1

The family visitation rooms and the attorney visitation rooms are in the same area.9 This
visitation area consists of a small room.10 There are two contact rooms/attorney visitation rooms on the
floor.11 If there are more than two attorneys visiting on a floor, a detainee can meet with his attorney in
one of the visitation rooms on another floor.12 The contact rooms have a glass wall which separates the
attorney from the detainee and there is a slot through which items can be passed.13 The delegation did not
see any of the attorney visitation rooms on the detainee’s floor. We did pass by the attorney visitation
room by the medical unit. In that room, two walls are made out of clear glass (Plexiglas) so that the
guards sitting in the guards station can see into the room.14 We walked through a hallway that passes by
one of these walls and we could hear what was being said by two men inside the visitation room.15
Officer (b)(6), (b)(7)c said that there would not be a reason for a guard to stand in the hallway and that guards
would only pass through.16 The room itself contained sufficient lighting, chairs, and table space.17
Attorneys can call ahead to determine if a detainee is at the facility. The attorney would talk to
Officer (b)(6), (b)(7)c to determine if a detainee is still at the DuPage Facility.18 There is no requirement for
G-28 forms for intake interviews.19 Attorneys are required to present bar cards when visiting.20 Under
the attorney visitation rules, non-attorneys (i.e., law students, legal assistants, etc.) can visit if they have a
letter from the attorney.21 According to the Inmate/Detainee Handbook, all professional visitors must
submit to a pat search before entering a contact room.22 After a contact visit, a detainee is not subject to a
strip search but the detainees can be patted down.23
When in segregation, an inmate or detainee needs to request special permission to visit with an
attorney.24 In order to have experts or independent medical service providers visit, there needs to be
approval from the Officer in Charge (OIC).25 Interpreters can visit with permission. There is a set time

9

See

10

Id.

11

Id.

12

(b)(6)

(b)(6)

notes.

s notes on conversation with Officer

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

13

Id. We did not see the rooms. This information was provided by Officer

14

Ms.

15

Id.

16

Ms.

(b)(6)

s notes.

notes on conversation with Officer

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

(b)(6)

17

Ms.

18

Id.

19

Id.

20

Id.

21

Id.

22

Inmate/Detainee Handbook at 17.

23

Ms.

24

Id.

25

Id.

notes.

(b)(6)

notes on conversation with Officer

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

3
CH\619343.1

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

for recreation and the detainee has to choose between attorney visits and recreation time.26 This
requirement does not reflect the Standard.
According to Officer (b)(6), (b)(7)c , attorneys cannot continue visits through meal times or head
counts but the allotted time for visitation would not interfere with meals.27 This does not fully reflect the
Standard, which requires that “[o]n regular business days, legal visitations may proceed through a
scheduled meal period. In such cases, the detainee shall receive a tray or sack meal after the visit.”28
ii.

Visitation by Family, Friends and the Media

The Standards provide that facilities should permit authorized persons to visit detainees within
security and operational constraints. To maintain detainee morale and family relationships, INS
encourages visits from family and friends. Additionally, facilities should permit members of the media
and non-governmental organizations to have access to non-classified and non-confidential information
about the facility’s operation.29 The Standards further provide that visits by family and friends “shall be
permitted during set hours on Saturdays, Sundays and holidays” for a minimum of 30 minutes under
normal conditions (emphasis added). And, “INS encourages more generous limits when possible…”30
The DuPage facility policies do not appear to implement this requirement.
The DuPage Inmate/Detainee Handbook indicates that family and friends visitation hours for
“Immigration” or detainees are Tuesday or Saturday, only, from 8:00 a.m. to 10:30 a.m. and 1:00 p.m. to
3:00 p.m.31 Contrary to the Standards, Sundays and holidays apparently are not included among the
permissible detainee visitation times for family, friends and media.
The other aspects of the visitation by family, friends and media appear do observe the minimum
requirements set out by the Standards. The length of a visitation with family or friends is limited to one
visit for 30 minutes per week, in accordance with the minimum time mandated.32 Only four people may
visit at any one time and rotating of visitors is not permitted.33 The room seems very cramped to fit four
people trying to visit at one time.34 The visiting room’s layout is similar to a small closet with two walls
and a glass door. The visitors are separated from the detainee by a thick glass wall. Visitors are separated
from other visitors by walls. Communication between the detainee and visitor takes place via telephone
system/intercom. Contact visits with friends and family are not permitted.35

26

Id.

27

Id.

28

Detention Operations Manual, Visitation, at 7.

29

Detention Operations Manual, Visitation, at 1.

30

Detention Operations Manual, Visitation, at 4.

31

See Inmate/Detainee Handbook at 13-14.

32

Inmate/Detainee Handbook at 13-14; Detention Operations Manual, Visitation, at 4.

33

Inmate/Detainee Handbook at 14.

34
35

(b)(6)

notes.

Inmate/Detainee Handbook at 13-14;

(b)(6)

notes.

4
CH\619343.1

A detainee’s visitation privileges may be terminated for any number of reasons including
disorderly conduct, refusal to obey orders from visiting staff, but also for insufficient space.36 There were
four rooms for visits.37 If detainees have 30 minutes per week visitation time, given the visiting hours and
days allotted, then there is space on Tuesday and Saturday for 18 visits x 4 rooms, which is 72 visiting
spots available per week. Given the maximum number of detainees is 32 for this facility,38 the space and
time allotted are adequate.
B.

Telephone Access

The Standards provide that facilities shall permit detainees to have reasonable and equitable
access to telephones. This is to include permitting the detainee to make direct, free calls to: the local
immigration court and Board of Immigration Appeals; Federal and State courts where the detainee is or
may be involved in a legal proceeding; to consular officials; to legal service providers; to a government
office, to obtain documents relevant to his/her immigration case; and in a personal or family emergency.39
The DuPage facility policies do not allow Detainees the access set out by this Standard.
The delegation was not permitted to enter the detainees’ living area in which the phones were
located. However, the Officer leading the tour informed the delegation that the detainees are permitted to
make only collect calls.40 This is in direct contradiction to the above-mentioned Standard.
There is no set time limit on the detainee’s phone calls, and they are free to use the phones as
often as they choose between the hours of 8:30 a.m. and 10:30 p.m.41 According to the Officer, the phones
are not electronically monitored.42
Posted near the phones are instructions in English and Spanish on how to operate the phones.43
The facility does not post a listing of pro bono telephone numbers or consular telephone numbers,
although each of the detainees are given a Know Your Rights Legal Assistance Packet containing such
information upon entry.44
Detainees, like the other inmates, cannot receive incoming telephone calls, and the facility does
not take phone messages from attorneys or others for the detainees.45 In case of an emergency, in order to
reach a detainee, one would have to call the Sergeant’s office.46

36

Inmate/Detainee Handbook at 13-14.

37

(b)(6)

notes.

38

Id.

39

Detention Operations Manual, Telephone Access, at 2.

40
41

(b)(6)

notes on conversation with Officer

Id.; Inmate/Detainee Handbook at 18.

42

(b)(6)

s notes on conversation with Officer

43

Id.

44

Id.

45

Inmate/Detainee Handbook at 18.

4

(b)(6)

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

notes on conversation with Officer

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

5
CH\619343.1

The facility does not inspect the telephones regularly to make sure that they are in working order;
they rely on the complaints of detainees to assess phone maintenance and attempt to repair phones quickly
upon request.47
C.

Legal Materials

The law library in the DuPage facility does not meet the minimum standards set forth by the
Standards. Although the library is large enough to accommodate detainee needs, library access for the
detainees is substantially limited; the library is missing some important materials relating to immigration
law and necessary electronic equipment (typewriters/computers); and, the facility does not appear to
provide the needed assistance for non-English-speaking or illiterate detainees.
i.

Library Conditions

The library is a large room with plenty of chairs and tables. It appears that the library could
comfortably accommodate about 20-25 people at a time.48 There were several small tables, which could
seat four detainees or inmates. The library appears to be a good place to do legal work. It is a well lit
area and there is an officer (Officer (b)(6), (b)(7)c who is in charge of taking care of the library and the
library materials.
Officer(b)(6), (b)(7)cseemed to enjoy working in the library and wanted to help the detainees and the
other inmates.49 He was well informed on the library materials and seemed to be making a good faith
effort to help those who wanted to use the library.50
ii.

Library Access

The Standards mandate that each facility devise a flexible schedule so that the detainees “shall be
permitted to use the law library for a minimum of five (5) hours per week.”51 In addition, detainees may
not be forced to forego minimal recreation time, meals, or other planned activities in order to use the
library.52
The library hours are 7:00 a.m. through 3:00 p.m.53 The detainees normally have access to the
library only on Fridays from 7:00 a.m. through 11:00 a.m.54 If a detainee needs more time, he can put in a
request. Officer(b)(6), (b)(7)csaid that he would allow someone to have more library time provided he is
working.55

47

Id.

48

(b)(6)

notes.

49

Id.

50

Id.

51

Detention Operations Manual, Access to Legal Material at 3.

52

Detention Operations Manual, Access to Legal Material at 3.

53

(b)(6)

54

Id.

55

Id.

notes on interview with Officer

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

6
CH\619343.1

Since many of the detainees at the DuPage facility are held there for only a few days, the
provision of library access only one day of the week not only fails to meet the minimum standards set in
the Detention Operations Manual, but also is likely totally insufficient to meet the needs of the majority of
the detainees held there.
iii.

Legal Materials

The Standards require all law libraries to hold the legal materials contained in Attachment A-2 of
the Access to Legal Materials chapter of the Detention Operations Manual. These materials must be
updated regularly and information must be added on significant regulatory and statutory changes
regarding detention and deportation of aliens in a timely manner. In addition, the Standards require that
the facility post a list of holdings in the law library and designate an employee with responsibility for
updating the materials, inspecting them weekly and maintaining them in good order.56
Officer(b)(6), (b)(7)cis in charge of checking and updating the library materials and he says that he does
so on a monthly basis.57 All texts in the library are in English. If a detainee needs a book that is not in the
library, he can request the book be ordered.58 However, the detainee would have to pay for the book. For
a book to be ordered, the request would need to be placed with Officer(b)(6), (b)(7)c.59 Detainees can request
extra supplies such as pens and paper.60 These are provided free of charge.
There is a pile of “Know Your Rights” packets in the library, and a section of books and binders
on immigration law. However, the library did not post a list of the holdings, and, more importantly, the
library did not have several items from the List of Legal Reference Materials (Attachment A-2).62 Some
examples of the missing materials are:
1. Immigration Law and Defense
2. Immigration Law and Crimes
3. Guide for Immigration Advocates
4. Country Reports on Human Practices
5. Human Rights Watch- World Report
6. UNHCR Handbook on Procedures and Criteria for Determining Refugee Status
7. Considerations for Asylum Officers Adjudicating Asylum Claims for Women
8. Immigration and Naturalization Service Basic Law Manual
9. Lawyer’s Committee Handbook on Representing Asylum Applicants
10. Rights of Prisoners
11. Federal Habeas Corpus, Practice and Procedure
12. Legal Research in a Nutshell.63
56

Detention Operations Manual, Access to Legal Materials at 2-3.

57

(b)(6)

58

Id.

59

Id.

60
61

(b)(6)

notes on conversation with Officer

notes on conversation with Officer

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

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

Id.

62

Due to time constraints we were unable to check and see if the library had some of the materials listed in
Attachment A-2, specifically, 23-30.

63

Ms

(b)(6)

notes.

7
CH\619343.1

iv.

Photocopies

The Standards provide that the facility must ensure detainees can obtain photocopies of legal
material, when such copies are reasonable and necessary for a legal proceeding involving the detainee. At
the DuPage facility, Officer(b)(6), (b)(7)cmakes photocopies at the request of the detainees.64 Photocopies are
free and there is no limit to how many a detainee can request. There is no indication that staff members
review confidential materials.65
v.

Correspondence and Other Mail

The Standards provide that “[t]he facility shall notify detainees of its policy on correspondence
and other mail through the detainee handbook or equivalent provided to each detainee upon
admittance.”66 In addition, “[a]t a minimum, the notification shall specify…. [t]hat general
correspondence and other mail addressed to detainees shall be opened and inspected in the detainee’s
presence, unless the OIC authorizes inspection with out the detainee’s presence for security reasons; [t]hat
special correspondence may only be opened in the detainee’s presence, and may be inspected for
contraband, but not read;” etc.67
At the DuPage facility, the “Inmate/Detainee Handbook” is purportedly given to each arriving
detainee, and it contains a section on mail regulations.68 Therefore, it appears that detainees are advised
of their rights in this area. The facility policies appear generally to reflect the Standard with respect to
delivery of incoming mail (within 24 hours) and regular collection of outgoing mail. However, all
incoming and outgoing mail other than special correspondence is inspected for contraband, but not in the
presence of detainees. Only special correspondence is opened in the presence of detainees.69 This departs
from minimum requirements of the Standards. The procedures where there is dispute on mail allow an
appeal to the Chief and therefore seem to observe the Standards.
According to the Standards, indigent detainees are entitled to free postage for a specified number
of legal and personal documents. Specifically, the Standards provide that “[t]he facility will provide
indigent detainees with free envelopes and stamps for mail related to a legal matter, including
correspondence to a legal representative, potential legal representative, or any court.”70 We were advised
that, although mail supplies (paper and pen/pencil) are supplied to detainees, the detainees were charged
for all postage, which is incompatible with the Postage Allowance provision of the Standards.71

64
65

notes on conversation with Officer

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

(b)(6)

otes

66

Detention Operations Manual, Correspondence and Other Mail, at 1.

67

Detention Operations Manual, Correspondence and Other Mail, at 2.

68

Inmate/Detainee Handbook.

69

Inmate/Detainee Handbook at 19-20;

70

Detention Operations Manual, Access to Legal Materials at 5; see also id., Correspondence and Other Mail, at 6
(“The OIC shall establish procedures to provide indigent detainees the postage allowance that is available at
government expense. Indigent detainees will be permitted to mail a reasonable amount of mail each week,
including at least five pieces of special correspondence and three pieces of general correspondence.”).

7

(b)(6)

(b)(6)

notes on conversation with Office

notes on conversation with Officer

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

8
CH\619343.1

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

vi.

Computer Access, Equipment and Holdings

The Standards mandate that an adequate number of typewriters and/or computers, carbon paper,
writing implements, writing tablets and non-toxic liquid paper be available for use by the detainees.
There are no computers in the library at the DuPage facility and there is only one typewriter for
all of the detainees as well as for all of the inmates.72 This typewriter is the only way a detainee can type
a legal document. We were unable to determine the policy and frequency of repairs of broken typewriters
or restocking of supplies.
vii.

Assistance to Illiterate and Non-English Speaking Detainees

The Standards mandate that: “[u]nrepresented illiterate or non-English speaking detainees who
wish to pursue a legal claim related to their immigration proceedings or detention and indicate difficulty
with the legal materials must be provided with more than access to a set of English-language law
books.”73 Facilities must establish procedures to meet this obligation, such as helping the detainee obtain
assistance from other detainees with appropriate language and reading-writing abilities and assist in
contacting pro-bono legal-assistance organizations.74
It appears this requirement is not being met at the DuPage facility’s library. Although Officer
is willing to help inmates and detainees with their legal research, he does not assist in translating
the materials for the non-English-speaking or illiterate detainees, and there appear to be no procedures in
place for meeting that obligation.75

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

D.

Group Rights Presentations

The Standards provide that facilities shall permit authorized persons to make presentations to
groups of detainees for the purpose of informing them of U.S. immigration law and procedures consistent
with the security and orderly operation of the DHS facility. All facilities must cooperate fully with
authorized persons seeking to make such presentations. Officer (b)(6), (b)(7)c stated that she tries to show an
INS video on a detainee’s rights on Fridays, but that the presentation does not occur every Friday.76
Officer (b)(6), (b)(7)c did not indicate that any in-person group rights presentations are given.77
VI.

Other General Observations Unrelated to the Legal Access Standards
A.

Recreation Issues

The Standards require that “all facilities shall provide INS detainees with access to recreational
programs and activities, under conditions of security and supervision that protect their safety and
welfare.” Every effort is to be made to provide outdoor recreation facilities, but lacking such, the
recreation room should be large, with exercise equipment and access to sunlight. The DuPage County
72

(b)(6)

notes.

73

Detention Operations Manual, Access to Legal Materials, at 4-5.

74

Detention Operations Manual, Access to Legal Materials, at 4-5.

75

(b)(6)

76

Id.

77

Id.

notes.

9
CH\619343.1

facility’s recreation area consists of one large indoor recreation area.78 There are no outdoor recreation
areas at the DuPage County facility.79
Detainees at the DuPage facility are allowed at least 45 minutes to 1 hour per day to relax in the
large indoor recreation facility.80 However certain “Trustees,” those inmates who work in the kitchen, are
permitted an extra hour of recreation per day.81 Officer (b)(6), (b)(7)c indicated that, because detainees do not
typically remain in the DuPage facility for very long and because of DHS work restrictions, detainees are
not eligible for “Trustee” status.82

B.

Detainee Handbook

According to Officer (b)(6), (b)(7)c the handbook is reviewed by the Major approximately once every
three years.83 When we asked for the Detainee Handbook, Officer (b)(6), (b)(7)c gave us a copy of the
Inmates Rules and Regulations. This is purportedly given to all detainees when they enter the facility; it
is the same booklet that is given to the inmates.84 There is a page on the front of the handbook that the
inmate/detainee must sign to show they have received a copy of the rules and regulations.85
The handbook addresses most of the areas specified in the Standards, including stating the
detainee’s basic responsibilities, meal times,86 count procedures,87 visiting hours,88 and it lays out the
initial issue of clothes and what personal items may be retained by the detainee.89 The handbook
describes the telephone policy but does not discuss the Detainee Message System because the facility
does not take messages or allow for in-coming phone calls.90 The handbook did not cover all areas
specified by the Standards. Examples of the areas not covered include: the recreation policy, the location
of the list of pro bono legal organizations, information on legal rights presentations, and the policy on
religious diets. Even though the policies on these areas are not described in the handbook, DuPage
County Jail does have policies concerning some of these areas such as recreation and religious diets.91

78

Id.

79

Id.

80

Inmate/Detainee Handbook at 30.

81

Id.

82

(b)(6)

Notes

83

Id.

84

Id.

85

Inmate/Detainee Handbook at 2.

86

Inmate/Detainee Handbook at 27.

87

Inmate/Detainee Handbook at 29.

88

Inmate/Detainee Handbook at 17.

89

Inmate/Detainee Handbook at 16.

9
91

(b)(6)

notes on conversation with Officer

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

Id.

10
CH\619343.1

IV.

Conclusion

The Detention Standards require that each facility provide detainees with access to make free
calls to the local immigration court and Board of Immigration Court of Appeals, to legal service
providers, and others, and that each facility provide indigent detainees with postage for certain legal
correspondence. The purpose of these requirements is to ensure that indigent detainees’ rights are
protected by offering those detainees opportunities to pursue their legal claims.
Based on our facility visit, it did not appear that the facility was implementing these Standards.
(b)(6), (b)(7)c
According to our conversations with Officer
the facility provides neither
free calls nor free postage to the detainees.
The facilities failure to provide detainees with such free calls and postage has potentially serious
consequences for detainees at the DuPage facility. Because indigent detainees lack the ability to place
calls or send correspondence regarding their immigration cases, they risk missing deadlines, waiving
opportunities to appeal, and other damaging effects to their cases. The purpose of requiring the free
telephone calls and free postage is not only to insure fair and equitable treatment but also to avoid
violations of due process.
Other noteworthy issues of concern include: failure to provide a list of free legal service providers
by the telephones; potentially problematic attorney visitation hours, failure to meet the minimum required
hours of detainee access to the law library, failure to provide a complete set of materials relating to
immigration law in the library, and failure to inform detainees of certain rights and regulations in the
facility’s Inmate/Detainee Handbook.
Overall, the staff at the DuPage County facility did not seem very informed of the Standards.
The fact that so few detainees are detained at the facility and for such a short time seems to greatly impair
the effectiveness of, or inclination towards, attempts at implementing the Standards. As noted by this
delegation, there is significant room for improvement, particularly with respect to the provision of direct,
free telephone access for applicable calls for the detainees, free postage for indigent detainees to mail
special correspondence, increasing access to the library, and updating and improving the legal and
technical resources available to the detainees in the law library.

11
CH\619343.1