Detention Standards Implementation Initiative

ABA Conmiission on Imrtrigration

Facility Name: Mira Lorna Detention Center
Date of Tout:
2004
Tour participants
& Watkins)
ICE Standard
Telephone Access

•

•

m.E.4 "[the facility shall pennit the
detainee to make direct calls] to legal
service providers .....
m.B. "[The facility] shall post these
rules where detainees may easily see
them"

Voluntary Work PrograItl
III.K. "Detainees shall receive
, monetary compensation for work
completed in accordance with the
facilitv'.s standard policY."
Grievance

•

•

Tour Observation
• The delegation noted that some
detainees were unaware of their
ability to place direct calls (p7,
line 21 and p8, line 4))
• The delegation observed that the
notice regarding free caIls and
was posted outside the library,
not readily accessible and not
near any telephones (p8, line 2)
While
the detainees may
•
participate in the voluntary work
program, they are not
compensated for their work
(p20, line 2) ,
• the delegation learned from the
detainees of a mass strip search
conducted over Memorial Day
weekend. (p21, line 15)

Source

ICE Response
Not noted in
2004 re'View.

•

According to delegation
observations ·and
interviews with detainees

•

According to detainee
interviews

2004 review.

•

According to detainee
interviews

2004 review.

Not noted iii

Not noted iIi

650 Town Cenler Drive. 20Ih Floor
'Cosla Mesa. california 92626-1925
Tel: (714) 540-1235 Fax: (714) 755-8290

www.lw.com

LAT'HAM&WATK1 NSLLP

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MEMORANDUM
August 27, 2004

Waahlnglon. D.C.

CONFIDENTIAL

To:
From:

Fileno:
Copies to:

Subject:

Victor Cerda, Acting Director, Office of Detention and Removal
Immigration and Customs Enforcement
Latham & Watkins, Mira Lorna Detention Center Delegation

~A Commission on Immigration
Delegation Observational Rc:mort of Mira Lorna Detention Center. Lancaster.
California

I. INTRODUCTION
On July 8, 2004, a delegation of three attorneys and three summer clerks from
Latham .& Watkins' Oranfe County office visited the Mira Lorna Detention Center in Lancaster,
California (the "Genter"). We met with inembers of both the Center's Immigration and .
Customs Enforcement ("ICE") staff and the Los Angeles County SherifPs Department, which
with the staff, toured the Center, and interviewed 20
operates the facility for ICE. 2 We
detainees.
ICE officer stationed at the Center, and Captain
the
tour

2 The Mira Loma Detention Center was previously operated by the Sheriff's Department for the Immigration and
Naturalization Service ("INS"). As of March 1, 2003, the INS ceased to exist as an agency of the Department of
lustice. The immigration enforcement functions of the INS were assigned to ICE, an investigative bureau within the
Department of Homeland Security ("DHS'').

J Prior to our yisit, the Center informed us that only a small number of detainees wished to speak with us. Following
our arrival, however, we learned that more than SO detainees volunteered to be interviewed. Due to time constraints,
we were able to interview only 20 detainees.

()C\69S081.2

LATHAMaWAT.KI NSLLP

_ and

Depu~ere also present on the tour and assisted in answering our

questIons.

.

This memoran4um summarizes the information gathered by our delegation's
observations regarding implementation of the Detention Standards with a particular focus on the
legal access standards.

IL EXECUTIVE SUMMARY
The staff at the Mira Lorna Detention Center have made substantial efforts both to
familiarize themselves with and implement the Detention Standards. Officers also seem to make
valid attempts to address detainees' concerns. Overall, the Center appeared well-run, clean, and
secure. From our observations, the staff was extremely professional and humane.
Through our observations and interviews, the delegation became aware of a few
concerns which need to be addressed. First, despite the staff's statements to the contrary, almost
no detainees received a Detainee Handbook upon arrival. Many of these det~inees did, however, .
receive a handbook the day before :ourdelegation toured the Center, and this procedure should be
continued for all arriving detainees. The group rights videos should be shown to those detainees
in the segregated barracks, instead of only to the general population. Additionally, detainees
should be paid for the work that they perform.
Finally, the delegation was notified ofa strip search that officers conducted over
Memorial Day weekend. In one barrack, about 14 to 15 officers observed the strip 'search, which
occurred for no apparent reason and humiliated the detainees. One detainee reported that this
strip search was filmed The detainees were told that the iricident would be investigated, but
nothing has resulted from any investigation. Our delegation strongly recommends that a further
examination of this incident be conducted.

In.s:rANDARDS
In November 2000, the Immigration and Naturalization Service ("INS")
promulgated the INS Detention Standards, which are contained in its Detention Operation
Manual. The Detention Standards were created to ensure the "safe, secure and hwpaIie treatment
of individuals detained by the lNS." The 36 Standards ~ncompass a broad range of issues, from
visitation policies to food service to grievance procedures. The Standards are meant to establish
minimum guidelines for treatment of immigration detainees; they are not intended to place a
ceiling on treatment requirements.
This memorandum evaluates the Standards in the following areas: (1) Visitation; (2)
Telephone Access; (3) Access to the
Library and Legal Materials; (4) Group Rights
Presentations; and (5) Additional Miscellaneous Issues.

Law

2
.0CI69S0S1.2

LATHAM&.WATKINSI.U'

A. General Information
1. The Facility

The Mira Lorna Oetention Center is located in Lancaster. California. Lancaster is a
city with an estimated population of 120,000 and is located in the Antelope Valley near
Palmdale, approximately 80 miles north of Los Angeles.
The Mira Lorna facility consists of approximately 30 buildings, including 20
barracks, a recreation center, library, classroom, mess hall, and infirmary. There is also an
administrative building, 3 Executive Office of Immigration Review courtrooms and the central
building that holds the main guard center and visitation rooms.
2.

Detainee Population

The current popUlation of the Detention Center is 524. The Center has the capacity
detainees. All detain~ at Mira Lorna are adult male detainees. According to Mr.
apJ)ro:Kinlatlely 80% of the aliens detained at anyone time are being held for criminal
acts,
the other 20% are noncriminal aliens. The largest ethnic group represented at the
Center were Mexicans, with a variety. of countries making up the remainder, i~
American citizens, Guatemalans, Hondurans, EI Salvadorians, and Armenians _ _ _
informed us that the average length of stay for the detainees varies greatly on a case-by-case
basis. In general, detainees are in the Center for a week or two and then deported to their home
countries. However, if a detainee chooses to submit an asylum application, he can remain at
Mira Lorna for over a year, depending -on which appeals the detainee chooses to file.
Both
us that every detainee receives a
Detainee Handbook
in English, Spanish; Chinese and
Arabic. Despite
almost none of the detainees with
whom we met
large number of detainees reported
receiving the Handbook the day before our delegation toured the facility.
IV. OBSERVATIONS OF IMPLEMENTATION OF LEGAL ACCESS STANDARDS

A. Visitation
1. Attorneys
Th~ Standards provide that facilities holding immigration detainees shall pennit
authorized persons to visit detainees and such facilities should encourage visits from family and

4

Only one detainee reported receiving a Handbook upon arrival. Interview With
Other requests for Handbooks were explicitly denied. Interviews with
8,2004).

3
OC\69S081.2

LATHAM&.WATKINSLLP

friends. Such holding facilities should also pennit private meetings with a detainee and his legal
s
representative or legal assistant.

In order to properly facilitate visitations to detainees, an immigration detention
facility shall provide written visitation procedures, including a schedule and hours of visitation,
to the detainee within the Detainee Handbook and posted where detainees can easily See them,
and to the public in written fonn and telephonically.6 Legal visitations shall be pennitted seven
days a week, including holidays, and shall be for a period of eight hours per day during the week
and four hours per day on weekends. 7 Persons allowed to visit include attorneys and other legal
representatives, including legal assistants upon presentation of a letter of authorization from the
legal representative under whos~ supervision he/she is working. 8 All lawyers and assistants must
provide identification prior to each visit, may not be asked to state the legal subject matter of the
meeting and shall be subject to search ofhis/ber person or belongings at any time. 9 .
Meetings between a detainee and his attorney or legal representative shall be
confidential and not subject to auditory supervision. lo Such meetings shall be held in private
consultation rooms and an officer shall not be present in the room, unless requested by the
attorney, although officers may visually observe such meetings through windows or a camera II
Prior to a visitation by a legal representative, if standard operating procedures require strip
searches, the facility must provide for noncontact, confidential visits with legal representatives. 12
During our visitation of the Center, we were able to observe the attorney visitation
room, the general visitation room and the posted schedule of visitation hours and rules and
regulations. Mira Lorna has one attorney visitation room that is located directly across from the
main guard control room. The room has windows on two sides which allows the staff to visually
observe the room from either the control roomlhallway or the main visitation room. The room
was finnished with a bench and chaiJ:s and appeared to be adequately sized. From our
observation, the visitation room appeared to be private and out of the earshot of staff. If the
attorney visitation room is already occupied, an attorney may meet with hislher client in the
general visitation room. The general visitation room is a large room with l<V1g benches ~parated
by a low partition. Attorney visitations in the room are confidential. The hours of visitation and
a poster containing the rules and regulations were visible within the visitation area as well as at
the entrance to the two barracks that we observed and the library.

, Standards, Ch. 1: Visitation, Sec. I.
6 ld.

at Sec. III. A.

71d. at Sec. III. I. 2.

• ld. at Sec. III. I. 3. a-c.
91d. at Sec. III. I. 4.

10ld. at Sec. III. I. 9.
11

ld.

Illd. at Sec. ill. I. 11.

4
OC\69SOS1.2

LATHAM&WATKINSLLP

Attorneys and other legal representatives are permitted to visit their clients 2~
a day, 7 days a week. Attorneys must show their bar cards upon arrival and legal visitati~
allowed for paralegals and law students as long as they present a letter confirming th~ visit on an
active attorney's letterhead. An attorney or other legal representative does not need to call ahead
to schedule an appointment, although we were told that most do. Attorney visits are noncontact,
although there is no physical barrier separating the attorney and his/her client. Deputy Carey
informed us that.detainees are only subject to physical searches, including strip searches, if a
reasonable belief exists that contraband was exchanged during the legal visitation. The attorney
visitation policy is exactly the same as stated above for detainees that are held in administrative
or disciplinary segregation. No detainees reported access problems with visitation by attorneys
or legal representation, although one man reported that detainees are subjected to a strip-search
unless they opt for noncontact visits with their attorney. 13
2. Family and Friends
According to the Standards, immigration detention facilities should establish a
visiting schedule based on detainee popUlation and visitation demand, but in any case, should
permit visitations during set hours on Saturdays, Sundays and holidays.14 Visitations should be
-for a minimum of 30 minutes. IS Visitation should take place in a secure but comfortable area,
and all visits should be quiet and oroerly.16 .
.
Upon OUT visit to the Center, we observed a general visitation room that was large,
open and able to hold a maximum of70 detainees at one time. The room was furnished with
long benches with a short partition separating the detainees from their family and friends. It was
explained to us that detainees are led in on one side after the families are seated. Guards are
positioned at a small station in order t9 observe the visits. The visitation room appears to be
adequately comfortable, spacious and private.
Family and friends are able to visit detainees at Mira Lorna from 8:00 a.m. until
4:00 p.m. on Saturdays, Sundays and holidays. Most detainees were aware of the visitation

hours, although one detainee reported a problem with the posting of visitation hours. 17
Generally, all visitation requests are granted, including those by minors and unrelated friends.
Only one detainee reported an.instance of such a request being denied. The detainee's brother
came to Mira Lorna to visit, but was turned away because his drivers license had expired. 18

13

Interview with

14

Standards, Ch. 1: Visitation, Sec. ill. H.l.

IS

ld.

8,2004).

161d. at Sec. III.G.
17 One detainee reported that visitation hours are posted in the back room of the barracks, outSide of the staff's
office. The hours are ·.difficult to find because of the large amount of infonnation in this area. The detajnee was
fearful of remaining there too long while reading the infonnation because, if the staff believes that a detainee is
~? are sent to the disciplinary barracks while the case is reviewed. Interview with detainee
~y 8, 2t>04). No other detainee corroborated ¢is report.

J8

Interview with anonymous detainee (July 8, 2004):

5
00695081.2

LATHAM&WATKINSLIJ'
Special visitations may be set up on a case-by-case basis, although some detainees were unaware
of this provision. 19 Visits last for a maximum of one hour, but we were infonned that visitors
may leave and sign right back in. During visits, family and friends may leave money for the
detainee.
B. Telephone Access
The policy of the Standards is to permit "reasonable and equitable access to
telephones.,,2o Accordingly, the facility should allow access to telephones during waking hours,
and should .provide at least one telephone for every 25 detainees. 21 Additionally, the facility
should 'n ot restri~ the number or duration of calls, unless it is necessary for security purposes,
and even then, the time limit should be no sho~er than 20 minutes. 22
Detainees should be pennitted to make free calls to the local immigration court and
'the Board ofhnmigration Appeals, to Federal and State courts where the detainee is or may
become involved in a legal proceeding, to consular offices, to legal service providers, to a
government office to obtain documents regardin~ his case and in the case of a personal or family
emergency or for an otherwise compelling need. A list of pro bono legal organizations
provided to the facility by ICE shall be posted by the facility prominently in each of the detainee
housing units and other appropriate areas. 24 Furthennore, the Standards require that the facility
enable all detainees to make calls to the INS-provided list of pro bono legal service providers and
consulates at no charge to the detainee or receiving party.25
The Standards provide that the facility should take and deliver telephone messages
to 4etainees. 26 If such call is an emergency, care should be taken to deliver the message as soon
as possible, and the detainee should be permitted to return the emergency call as soon as
reasonably possible. 27 The Standards require messages to be delivered three times a day in
Service Processing Centers ("SPCs") and Contract D~ention Facilities ("CDFs"). Altho~gh this
Standard is not directly applicable to this IGSA facility,28 it should serve as a realistic goal for
29
which to aim.

19

Interviews with detain:
8,

..

I

~ll

.. J

'c

Ill;

20

Standards, Ch. 2: Telephone ActeSS, Se.c, I.

21

ld. at Sec. mA, C.

22

[d. at Sec. mF.

23

ld. at Sec. III-E.

:z.4

Standards, Ch. 1: Visitation, Sec. ill.1.14

25

Standard; Ch. 2: Telephone Access, Sec. ill.E.

26

ld. at Sec. ill.l.

27 [d.

21 IGSA facilities
, 29 Standards,

are operated through an agreement between ICE and state and/or local governments.

Ch. 2: Telephone Access, Sec. III.!.

6
OC\695081.2

tainee

LATHAM&WATKINSup

Finally, the Standards require'measures of privacy be put in place with regard to
telephone calls, especially those of a legal nature. The staff may not electronically monitor
detainee phone calls relating to legal rnattet:S without a court'order.. 30 Additionally, the facility
should maintain a sufficient number of phones on which detainees can make calls without being
overheard by officers, staff, or other detainees.31
.
During our visit we observed the barracks, which can house up to 65 people (though
usually there are less than 65 detainees in a barracks at any given time). Each barracks contain~
four phones, which is well within the ratio of phones required by the Standards. There are signs
posted n . o n e s stating the time limit for a phone call is 15 minutes. However, according
to Depu
these signs are left over from when the facility was used as a jail, and are not
enforced. e a ed that as long as there is not a wait for the phones, which does not happen
often, there is no time limit enforced for phone calls. The detainees had no complaints about 't he
number of phones available for their use or the time limits.
indicated that 1-800 numbers could be dialed from the telephones,
which allows detainees to contact pro bono legal services (though, at least one detainee reported
that 1-80Q calls were not free from the phones in the Center32). Unfortunately, these 1-800
numbers for pro bono legal services are not posted near the phones; instead, they are posted in a
small room in the back of the barracks, near the guard's office. Several detainees noted the
phone numbers were difficult ~o fmd, while others indicated that thel were not aware they could
make such calls, otherthari with a phone card or 'by calling collect. 3 Detainees who knew of the
pro bono lists expressed C9ncerns that none of these services help detainees if there is a criminal
conviction involved in the case, which is the situation in which approximately 80% of the
detainees at Mira Lorna find themselves. 34
Mira Lorna Detention Center should also consider posting the list more prominently,
as required by the Standards. 35 The current placement of the list is in a small room in the back
of.the barracks, just outside the guard's office. The walls of this small room are cluttered with
various bits of infonnation for the detainees, in no particular order. Furthermore, one detainee
reported fear of getting into trouble with the staff for "loitering" in this back room, while trying
to fmd some piece of information, causing the detainee to be sent to the disciplinary barracks
until the situation was reviewed. 36 Even aside from detainee concerns about getting into trouble
for "loitering," since this area is so crowded with various postings, it is difficult for detainees ~o
ascertain whicJl postings are important for them to read.

30

Id. at Sec. mJ.

]) Id.
32

Interview with anonymous detainee (July 8, 2004).

:::::::::::::=an~d~an;onymOus detainee (iuly 8, 2004).

34

Interviews with detainee
Interviews with detainee

35

Standards, Ch. 1: Visitation, Sec. llI.I.14

36

Interview with detain~uly 8,2004).

33

uly 8, 2004).

7
()CI69S081.2

tATHAM&WATKINSllP

Information about dialing a detainee's consular office, different courts, or
government offices was posted near phones outside the library, but this information did not
appear to be posted near the phones in the barracks. Many detainees were unaware of their
ability to make phone calls regarding pro bono legal services or to their consular office at no cost
to them. 37 Since the phones are not preprogrammed with the ability to make such calls, it might
be helpful to provide detainees with a notice ofthdr telephone privileges and how they can use
them. Since the Standards require the facility to enable such calls' at no cost to the detainee,
perhaps instructions and numbers should be placed next to the phones in the barracks to enable
the detainees to utilize this opportunity.
During the tour, Deput44
indicated that phone cards were available to be
purchased, but he was not aware of the details of such phone cards as they were handled by the
"store," which comes in daily to allow detainees to purchase items during their recreation time,
such as stamps, snacks, phone cards, and other similar items that they request. 38 Almost all the
·detainees with whom we spoke reported that the available phone cards were inadequate because
the cards were too expensive, often ended up with money left on them in sD:lall amounts (e.g.
$3.00 or less) that were not sufficient alone to place a call, and that they could not be
consolidated with other cards to utilize the extra money left over.39
Mira Lorna does not actively monitor phone calls made by the detainees, which goes
above and beyond the requirements by the Standards. Few detainees complained of privacy
concerns during their phone calls, but observations during the tour seemed to indicate that it may
_be hard for a detainee to have a phone conversation that would not be readily overheard by other
detainees or facility staff, as required by the Standards. 4O pveraU, however, since the phones are
not monitored, and there seem to be many phones from which a detainee can make a call, the
privacy concerns may not be a big concern.
One area that is of greater concern lies in the Center's message-taking procedures.
indIcated that the Center generally does not take messages·for detainees unless it
is an emergency. He specifically indicated that the Center does not take messages from
attorneys, commentingiQat if an attorney wants to contact a detainee, they can come to Mira
·Loma in person, and that detainees are always free to contact an attorney on their own. Since the
Standards provide that messages should be delivered to detainees as promptly as possible, the
Center's policy not to take messages for detainees except in cases of emergency is an area in
need of improvement:41
2004).

37lnterviews with

31 The "store" is a traveling cart which comes to the recreation building daily. It offers numerous items .that the
debunees may purchase using cash.
J ' "

ID" )1
r~

. ..,.;

I

,

: ,'I"

40

Standards, Chapter 2, Telephone Access, Sec. III.J.

41

[d. at Sec. III.I.

8
OC\69S081.2

'~J," Jr

detainee
anonymous

LATHAM&WATKINSLLP

In general, Mira Loma is doing a fairly good job of providing reasonable access to
telephones. However, additional steps can be taken in order to fully implement the Standards.
The Center should work to fully implement the Standards with regard to taking messages from
attorneys for the detainees. Additionally, the Center should better inform the detainees of their
telephone privileges, and should consider posting the list of pro bono legal service providers and
instructions on how to use telephone privileges by all of the phones, instead ofjust a few select
phones, so that detainees can effectively exercise their telephone priVileges.

c.

Access to the Law Library and Legal Materials

According to the Standards, immigration detention facilities should have and
maintain a library with current copies of various immigration-related legal materials. 42 The
facility's library must be adequate in size so as to pennit detainees to research and Write. 43
Additionally, the library should be well-lit, reasonably quiet, and have a sufficient number of
tables and chairs to accommodate all detainees requesting use of the libi"ary.44

In order to comply with the Standards, Mira Lorna is required to provide legal
materials, ~uipment, and office supplies necessary to meet detainees' needs in preparing legal
documents. 4 Additionally, a "flexible" schedule should allow detainees to utilize the library for
at least five hours per week. 46 Detainees in disciplinary or administrative segregation must have
the same access to the library and legI materials as the other detainees, unless compelling
security concerns dictate otherwise.

The library is housed in one fairly large room with seating for about 20 to 2S
people. The library is well-lit with high ceilings, and it has a fairly pleasant atmosphere. There
are three separate tables with five chairs each, and there are a number of chairs around two
computers. At the time of our visit, two detainees were reading in tlie library.
The nonlegal collection of books is .organized and catalogued, similar to what one
might find in a municipal or school library . The non-legal section contains an assortment of
fiction, nonfiction, and educational books and materiais. It appears that most of the nonlegal
books are in English, but a fair number of Spanish and Asian-language materials ilfe also present
The library is open Monday through Friday from 8:00 a.m. until 3:30 p.m.
Detainees are allowed access to the library during their recreation time. Additionally, detainees

42

Standards, Ch. 4: Access to Legal Material, Sec. I.

43

Id. at Sec. lILA.

44

Id.

45

Id. at Sec. m.B.

46

Id. at Sec. Ill.G.

47

Id. at Sec. m.N.

9
0C'I69S081.2

LATH -AM&WATKf NSLlP

may request additional time to use the library. According to the Center's staff, such requests are
liberally granted, and Mira Lorna has a policy of permitting detainees as much legal research
time as they request and need. One detainee reported that detainees who work have trouble
using the library because of the limited hours. 4 Other detainees noted that they had to forego
their recreation time to use the library, but did not seem to find this problematic. 49 Additionally,
the Sheriff's Department stated that detainees in administrative or disciplinary segregation are
pennitted the same access to the library as other detainees, unless oveniding security concerns
would prevent such access. Two detainees reported that they were denied library access for two
months when their barrack was under disciplinary restrictions. so Therefore, while Mira Lorna
seems to adequately meet most of the Standard's allowance requirements for library use, they
must ensure that detainees subject to disciplinary restrictions also have equal access to the
library.
2. Legal Materials
The Standards list a number of legal materials that facilities are required to possess
and maintain for detainee use. SI These "legal materials must be updated regularly, and ICE is
responsible for updating the Standards' list regularly. 51 According to the Standards, detention
facilities should designate an employee to update the legal materials, ins~ct them weekly, and
maintain them in good condition, and replace them promptly as needed.
.
All legal materials possessed by the library are kept on approximately 14 shelves
behind the librarian's desk. None of these legal materials are directly accessible by detainees. In
orner to access any legal materials, detainees must specifically request the material from the
librarian. Almost all legal materials are in English, with the exception of the "Florence Project's
"Know Your Rights" binder, which was available in both English and Spanish.
The number oflegal books and materials available in Mira Loma's library is
relatively small, but almost all detainees thought that the legal materials were helpful. Several of
the legal materials required by the Standards are not present in the library. ·Despite this, the
library did maintain a number of important legal materials, such as Black's Law Dictionary and a
number of West publications. Our delegation was informed that the Center regularly compares
its materials with the Standards' list, and a designated officer had actually reordered a number of
missing publications very recently. Furthermore, a detainee may request additional legal

41 Interview with detain~uly 8, 2004); Detaine4!M"Wreported that he was forced to
request ajob change so ~coinCided with the library hours.
(ti!! j) (.J" 7,(;

....

(b)(G) (rJ{7)c
\ ) "

, ....

l~)r

I.

'

••

•

•

:

I •.

'0 Interviews with detain~d anonymous detainee (July 8, 2004).

'I Stan~s, Ch. 4: Access to Legal Material, Sec. me.
'2 ld. at Sec. m.E.
531d.

10
{)C\69S081.2

LATHAM&WAT'KINSLLl'
materials that the library does not currently possess. Requests for legal forms are almost always
granted, and requests for legal books are orderedat the discretion of the Center's staff.
OveraIl, the library at Mira Lorna was quite impressive. Detainees benefit from the
great number of reading materials, and library facility is large, bright, and accessible. The legal
,materials, however, do not fully meet the Standards' requirements. Once the recently ordered
materials are received, the legal holdings'may fulfill the requirements. In addition to maintaining
the .required legal materials, our delegation recommends that the legal books and materials be
moved to a more accessible place in the library; Detainees should not be forced to specifically
request each legal material needed, and detainees interested in gaining lmowledge about their
legal rights could more easily e~ne the materials.
3. Legal Material Retention
The Standards allow detainees to keep legal documents in their personal
possession. S4 The Mira Loma Detention Center appears to be in compliance with the Standards
regarding Legal Material Retention.
At the Mira Lorna Detention Center detainees are pennitted to keep a "reasonable"
number of legal documents in their personal possessi on. ss If a detainee has an excessive amount
of legal documents, they will be stored on-site and the detainee can request them ifneeded. s6 In
addition, the Center will copy legal documents for detainees free of charge at the library.
Detainees reported no complaints about the personal retention oflegal materials.
4. Photocopies
According to the Standards, a detention facility should pennit all "reasonable and
necessary" photocopies of legal materials. 57 The Standards list a number of possible exceptions
to this general rule. Requests for photocopies may be denied for security concerns, copying in
,
violation of the law, and "clearly abusive or excessive" requests.58
The Mira Lorna Detention Center library contains one photocopier, and an unlimited
number of legal-related copies.are permitted. The procedure for
is quite
request photocopies from
is stationed in
informal.
the library. 59 ,
that she pro!Jlptly grants all
of a legal
nature at no cost to
60 Requests for photocopies ofpersonal materials or artwork are

and Personal Property, Sec. III.B.4.
55

Statement ~4'r............

56

[d.

8,2004).

57

Standards, Ch. 4: Access to Legal Material, Sec. m.J.

58

[d.

59 ,Statement -<" r' __....
60

8,2004).

[d.

11
00695081.2

LATHAM&WATKtNSup
not granted. 61 A few detainees reported that their photocopy requests w~e partially denied. 62
As stated above, the Center pennits detainees to keep photocopied legal materials in their
63
possession:

5. Mail
The 'Standards call for indigent detainees to receive free envelopes and stamps for
the purposes of mailing legal-related materials and other correspondence. 64 An immigration
detention facility is also required to have a system for purchasing stainps, and in the absence of
such system, should allow detainees to mail five pieces of "special correspondence" and three
pieces of "general correspondence" per week, at government expense. 65 Furthermore, according
to the Standards, facilities must provide envelopes, paper, and writing instruments to all
66
detainees.
The Center's staffinformed the delegation that paper, writing implements, and
envelopes are provided to detainees free of charge. Stamps are or.Uy provided free of charge to
indigent detainees; all other detainees must pay for stamps.67 Two detainees reported that there
was no limit on the materials provided to indigent detainees. 68 A determination on the indigent
status of a detainee is made when the detainee arrives at Mira Loma. 69
The detainees with whom we spoke reported no problems or concerns with sending
or receiving mail.
'

,6. Computer Access and Equipment
The Standards require immigration detention facilities to maintain an adequ~te
'number of typewriters and/or computers, and to provide writing instruments, paper and office
7o
supplies to be available for use by detainees. Mira Loma's library contains'no typewriters
designated for detainee use, but the Center maintains two computers that detainees may use free
61

••

[d.

..~I1!"

~~f~d an anonymous detainee (July 8,
that 20 'pages of legal documents be copied, but the librarian
others were not important.

63

Statement of

64

Standards, Ch. 4: Access to Legal Material, Sec. III.O.

Sec.

Standards, Ch. 9: Correspondence and Other Mail,
III.I. "Special correspondence," as defined by the
Standards, includes slllegal-related correspondence, correspondence to or from political representatives or
government !l8encies, and correspondence to or from the media. All other correspondence i~ denied as "general
correspondence." Standards, Ch. 10: Definitions.
6S

66
67

Standards, Ch. 9: Correspondence and Other Mail, Sec. III.J.
Statement _L"T' __ •• h
8,2004).

12
OC\695081.2

lATHAM&WATKINSup
of charge. The computers are available upon request, but use can be scheduled if the qemand
exceeds the number of computers available. One detainee complained that the computers used
an obsolete operating system that was somewhat unreliable. 71 The computers are equipped with
immigration law materials, which ,are installed and maintained by ICE. The computers are not
equipped with internet access.
There is one shared printer available for use by detainees. There is no limit to the
amount of legal-related materials that may be·printed. 72 Many detainees corroborated this fact.
Like photocopied legal materials, computer printed legal materials may be retained by detainees
and taken to the detainee barracks.

D. Group Rights Presentations
According to the Standards, facilities should allow authorized persons (attorneys
and legal representatives) to make presentations to groups of detainees to inform the detainees of
immigration law and procedures, and their rights within such law and procedures.73 The facility
·is required to fully cooperate with authorized persons wishing to give pres~ntations, but is not
74
required to arrange such presentations. Presentations are oren to all detainees, except when a
particular detainee's presence would present a security risk. 7 If a detainee in segregation cannot
attend for this reason, and he and the presenters 'b oth request, alternative arrangements shall be
made. 76 Finally, the SU!Ddards require the facility to permit individual detainees or small groups
of detainees to meet with presenters following a group presentation, without ICE or facility staff
n
.
present.
During our tour of-the Center, we learned from Deputy_hat two groups visit
Mira Lorna to make such presentations: Catholic Charities and a group he called the Pacific
South Islanders. Deputy_noted that one or other of these groups probjibly comes bimonthly. He stated that ,detainees are permitted to meet individually or in small groups with the
presenters after the presentations, withdut staff present, in accordance with the Standards. He
also informed us .that detainees in the administrative/disciplinary barracks could generally attend
the presentations, 'unless they are violent offenders, in which case the security risk is too high.
While the Center has implemented the Standard, it would be beneficial to the
detainees ifmore ,g roups came in to Mira Lorna. As DeputyiWMaid, he does not control what
groups come in or how ofieIl: Two years ago, there were no groups coming to make

71

Interview with.anonymous detainee (July 8, 2004).

72

Statement ofDeJ>UtYBllruly 8, 2004.

73

Standards, Ch. 4: Group Presentations on Legal Rights, Sec. 1.

74

ld. atSecs. I, m .B.

7~

ld. at Sec. ID.C.

76

Jd.

n ld. at Sec. ill.G.

13
OC\69S081.2

LATHAMaW-ATKI NSLLP
presentations, so there has been an improvement 78 Additionally, it appears that many detainees
are unaware that these presentations are taking plape. The Standards require that the
informational posters about a presentation should be prominently displayed at least 48 hours
prior to a presentation. 79 Perhaps the informational sheets notifYing the detainees of such
presentations could be placed in a more prominent location in the barracks, rather than the back
room near the guard's office, where most information is posted.
~nfiDmled us that the Center shows the Florence Project's "Know
Your Rights" video on the closed circuit televisions throughout the facility, two times a day in
English and Spanish. Most of the detainees did not corroborate this infonnation, though their
reports varied. Most detainees confirmed that the video is shown on closed circuit television, but
there was some discrepancy regarding the number of showings per day. One detainee reported
he had seen it once durin his 4O-day stay at Mira Lorna, while another reported it was shown
about 3 times per week. 8f Additionally, the video is not shown in the administrative/disciplinary
barracks,

V. OTHER GENERAL Ol,lSERVATIONS UNRELATED TO THE LEGAL ACCESS
STANDARDS

A. Recreation

Detention Standards require that "all facilities shaH provide INS detainees with
access to recreational programs and activities, under copditions of security and supervision that
protect their safety and welfare.,,81 Every effort is to be made to provide outdoor recreational
facilities with access to sunlight.82 "Each detainee shall have access to outdoor or indoor
recreation for at least one hour daily, five days a week.,,83
The personnel at Mira Loma·indicated that detainees are typically given i:ecreation
time, or ''yard time," twice a day for a minimum of 40 minutes. 84 The majority of detainees with
whom we spoke verified this, though many pointed out that the scheduling of "yard time" was
often unpredictable, and in fact, there would occasionally be days when there was no "yard time"
at all. 8S Those detai~ees who have been segregated from ·the rest of the population are given a
minimum of one hour per day, and the staff makes an effort to give this to them seven days a

71 Arnold and Porter Memorandum Re: Cc;>mpliance with Detention·Standards at INS Mira Lorna Detention Center,
Lancaster, California, dated September 30, 2002.

7'J

Standards, Ch. 4: Group Presentations on Legal Rights, Sec. m.c.

10

Interviews with

B1

Detention Operation Manual, Petainee Services, Recreation, Standard 13, Sec. I.

8,2004).

121d. at Sec. Ill(A).
11

ld. at Sec. III(B); see also Summary of Select Detention Standards, Sec. 10(B).

14

Statement of Mira Lorna Detention Center personnel (July 8, 2004).

IS Jnt.'rvll~W~

14
OC\6~S081.2

LATHAM&WATKINSLLP
week;86 Detainees who have been segregated are given access to the same activities as the rest of
the population, only theY .partake in them when the majority of the population is locked down. 87
One,detainee reported that his recreation time was eliminated because of disciplinary reasons. 88
The ''yard'' is .a large, fenced-in complex containing paved and grassy segments.
There is a track for running, basketball and volleyball courts, facilities for soccer, as well as a
series of pull-up bars. Additionally, the center has indoor recreational facilities in which there is
a large space where detainees may watch television, movies, play cards, etc. Also within this
area, there are what the staff referred to as stores from which detainees may buy envelopes,
89
stamps, and other personal items. Detainees have access to a television within each of their
barracks, and we saw many detainees playing cards and reading within their barracks during our
toUT. Even when detainees are not engaged in "yard time," Mira Lorna is considered an "open
c9rnpound" such that detainees have access.to the grassy areas located outside of their barracks.

B. Classes
Mira Loma Detention Center provides detainees with a number of classes taught by
a credentialed teacher from a local school district.!1O These classes include English as a second
language, computer tutorials, as well.as drug and alcohol abuse seminars; in fact, detainees are
able to earn ,certificates for .certain of the alcohol and drug programs to show to the court during,
their hearin~ as an attempt to demonstrate progress and/or good faith efforts to improve
themselves. 1 Detainees-receive one-on-one direction in these classes, which occur during their
''yard time.,,92 The staft: however, indicated that if an individual needs additional time to work
on a special project, extra c1ass time can be arranged. 93 Atpresent, the majority of the courses
are taught in English and Spanish, though it was explained to us that the Center hopes to hire
additional teachers with more diverse language skills.94 Classes are often very busy, though this
entirely depends upon the population of the Center at any given time. 9S Detainees have access to
general health books and tapes, and there are materials available in Chinese, Spanish, and
Annenian. 96 Even when classes are busy, an effort is made to allow every interested detainee an

16

Statement of Mira Loma Detention Center persoMel (July 8, 2004).

'71d.
.. Interview with detair.cW'.IWJuly 8, 2004).
19 Statement of Mira Lorna Detention
90

Center persoMel (July 8, 2004).

ld.

911d.
9l1d.
931d.
941d. See also interviews with detainee

and anonymous detainees (July 8,2004).

9' Statement of Mira Loma Detention Center persoMel (July 8, 2004).
961d.

15
0CI69S081.2

LATH AM&WATK I NSLLP
opportunity to access these resources. 97 Although only 35 detainees are allowed in at a time,
they will rotate them in and out, one barracks 'at a time. 98

c.

Access to Medical

1. Access to Health Care
It is required by the D~ention Standards that detainees have access to medical
services promoting their health and welfare. 99 Detention facilities must have regularly scheduled
times when a detainee may attend "sick call" to seek medical attention. lOO The number of times
each week will depencJ on how large a population is present in the Center. 101
Mira Lorna personnel informed us that every detainee goes through a screening
process upon arrival, meaning that each detainee is given a complete physical examination
within 14 days of having arrived at Mira Loma. 102 Any detainee with a·medical problem ·may
seek assistance from a registered nurse or nurse practitioner every morning, Monday through
Friday, as a part of "sick call.,,103 There is also a doctor present on various days. 104 If a detainee
is found to have a serious medical condition, th?ot individual will be immediately transported to a
nearby medical facility. lOS The detainees reported a few complaints with the available medical
care. One detainee complained about a lack of attention given to medical problems, stating that
he had to wait too long to 'see a nurse for what he described as a badly cut ear. 106 A detainee also
complained that blisters on his feet were left untreated. 107 One man reported that a detainee has
"to be really dying for them to take action."I08 Another detainee badly needed dental care, but
none was available at the Center. 109 Others reported no complaints and speCifically noted that
they have never been denied medical attention. 110

971d.
'Jild.
99

Detention Operation Manual, Health Serviees, Medical Care, Standard 2, Sec. I.

100

ld. at Sec. m(F).

1011d.
1'02. Statement of Mira Loma Detention

Center personnel (July 8, 2004):

1031d.
104ld.
10' ld.
106

Interview with detainee • • • • • • • • •,uly 8, 2004).

107 Interview
10.

with anonymous detainee (July -8, 2004).

Interview with anonymous detainee (July 8, 2004).

109 Interview

with

8,2004).
and anonymous detainee (July 8, 2004).

16
OC\695081.2

LATHAM&.WATKI NSLLP

The staff indicated that Mira Lorna is considered a ''wellness facility" meaning that
detainees with serious medical conditions or diseases are not kept at the Center. III This seemed
to be the case, though one detainee reported that a detainee had died of meningitis after being
removed from Mira Lorna 112 Therefore, those with psychological issues, prosthetic limbs, or
l13
serious disease are not admitted.
Many of the health care services at Mira Lorna are
contracted through the Los Angeles County Department of Health Services. 114 There are,
however, registered nurses who are always R~esent at Mira Lorna and who .report directly to the
Los ·Angeles County Sheriff's Department

2. Mental Health Services
Because Mira Lorna is a ''wellness facility," psychological problems are not
addressed at the Center. Consequently, there are no counseling services available at the
facility. 116

D. Religious Issues
It is required by the Detention Standards that detainees of different religious beliefs
be provided reasonable and equitable opportunities to participate in the practices of their
respective faiths. 117 "Those opportunities will exist for all equally, regardless of the number of
practitioners of a given religion, whether the religion is 'mainstream,' whether the religion is
'Western' or 'Eastern: or other such factors.,,118 Opportunities will be constrained only by
concerns of safety, se.curity, the orderly operation of the facility, or extraordinary costs
associated with a specific practice. "119 Additionally, it is suggested that "all reasonable efforts to
accommodate" special dietary requests be made as dictated by a detainee's religion. 120
The staff at Mira Lorna indicated that special dietary requests may be made to a
detainee's supervisor, and they ru:e always accommodated. 121 For example, during Ramadan,
Muslims are allowed to eat at a different time and separate from other detainees in order to

III

Statement of Mim Lorna Detention Center personnel (July 8, 2004).

IJ2

Interview with anonymous detainee (July 8, 2004).

113

Statement of Mira Lorna Detention Center personnel (July 8, 2004).

114

[d.

115

[d.

116

[d.

117 Detention
118

[d.

119

[d.

120 [d.

121

Operations Manual, Detainee Services, Religious Practices, Standard 14, Sec. I.

at Sec. m(M).

Statement of Mira Lorna Detention Center personnel (July 8, 2004).

17

LATHAM&WATKINSLLP

observe the holiday. In addition, a special wristband is given to those who are vegetarians. 122
We were told that all detainees are allowed to keep religious items with their personal belongings
such as a bible, the Koran, rosary beads, etc. l23 In fact, it was indicated that prayer rugs are
provided to detainees if they are not in possession of their own. 124 However, one detainee
complained that an officer:threw his rosary beads away from him during'a search,125 while
another detainee indicated that detainees are not permitted to wear clothing indicative of their
faith. l26 Many detainees, though, were n~t subject to harassment due to their religious beliefs. 127
Mira Lorna personnel said that they do not have major p~blems due to religious differences,
instead, most friction between detainees results from ethnic or gang-related affiliations. 128
Religious services are proVided at the detention center, including a nondenominational chapel in
which different groups of detaineeS may congregate to conduct services. 129 The principle
religions represented by detainees are Catholicism, Protestantism, Buddhism, and Islam. 130
Religious services conducted by outside clergy are performed weekly. 131 For instance, Catholic
and Protestant services occur once or twice each week.132 A number of detainees took advantage
of these services. 133 With regard to those of the Buddhist or Islamic faiths, the Center provides
space and time for detainees to practice their religion, which is typically run by a self-appointed
detainee on behalf of the interested group. 134
E. Detainee Classification
The Standards call for detainees to be classified upon arrival before admission into
the main population. 13S Classification is to be performed by trained officers, and detainees are to
be kept in dete~tion un~l all information necessary for the classification process is received. l36

112ld.
123ld.
1:z.4ld.
123
126

Interview
with ddletain:'::e:::::::::~
Interview with
-iiI

U7 Intf,rvil~w"

detainee
detainees

Statement of Mira
·129 ld.
1:18

Loma Detention Center personnel (July 8, 2004)..

130ld.
131 ld.

mId.

134
135

Statement of Mira Lorna Detention Center personnel (July 8, 2004).
Standards,
6: Detainee Classification System, Sec. III.
~h.

1361d.

'18
OC\69S081.2

anonymous

LAT'HAM&WATKINSup

The classification is based upon security risk, and detainees' security classification 'm ust be
easily identifiable by color-coded uniforms or wristbands. 137 The Standards also bar "Level 1
detainees" (noncriminal detainees or nonviorent detainees guilty of petty offenses) from
interacting with ''Level 3 detainees" (those convicted of aggravated felonies )}38 Classification is
required in order to separate detainees with no or SItlaIl criminal records from inmates with
serious criminal'records. 139 The Standards call for reclassification after 45 to 60 days and every
60 to 90 days thereafter. 140 Detainees should have the right to appeal their classification. 141
At the Mira Loma facility, approximately 80% of the detainees are convicted
criminals; however, the noncriminal detainee popUlation has not been separated from the
criminal population. There is one classification used at the Mira Lorna Detention Center:
"acceptable.,,142 To some extent, the detainees are separated and housed according to ethnicity to
minimize ethnic friction. 143 All detainees at the Mira Lorna Detention Center wear the same
orange clothes. Blue wristbands are issued to those detainees who have special religious dietary
needs. Detainees are not classified based on medical conditions, as detainees with serious
medical or emotion conditions are not housed at Mira Lorna.

Our delegation strongly recommends that ICE takes immediate steps to separate the
noncriminal Mira Lorna Detention Center population from the criminal population.

F. Voluntary Work Program
The Standards require that every physiCally and mentally able detainee have an
opportunity to work. l44 Work assignments are to be made based on a detainee's security
classification. 145 ,Qualified detainees cannot be denied work assignments on the basis offactors
such as race, religion, physical or mental handicap or national origin.l46 Supervisory officials
must consid~r the ~recise limitations of disabled individuals before rejecting them for particular
work assignments. 47 Work is limited to '8 hours per day, and a maximum of 40 hours per week.
Workers are to be paid S1.oo per day and are to be paid daily. 148 '

137 Id.

at Sec. m.B.

mId. at Sec. m.E.
139

Detention Operations Manual. Detainee Services, Standard 3, Sees. mAand m.E.

140

Standards, Ch. 6: Detainee Classification System, Sec. m .G.

141

Id. at Sec. m.H.

142

StatementofDepu~.I'I-I"• •,]uly.s, 2004).

143Id.
144

Standards, Ch. 37: Voluntary Work Program, Sec. ID.A.

14'

Id.

1461d. at Sec. m.F.
1471d. at Sec. m.G.
141

Id. at Sec. m.K.

19
OC\69S081.2

LATHAM&WATKINSup
At the Mira Loma Detention Center, detainees are afforded the opportunity to
participate in voluntary work programs. However, the detainees are not paid. Most detainees
did not seem upset with the lack of payment, but were satisfied with the special privileges
received. 149 Detainees who work at Mira Lorna receive special benefits including living in
special barracks with large screen televisions and vending machines, a special meal at least once
a week, and extended visiting.hours.

G. Grievance Procedures
.
The Standards aim for an informal resolution of most detainee grievances. ISO
However, each facility is required to have a formal written grievance process. lSI The facility is
to provide assistance for illiterate, disabled, and non-English speaking detainees l52 and detainees
may obtain assistance in preparing grievances from other detainees, facility staff, and outside
sourceS. IS3 Detainees are to be provided with written grievance forms on request, 154 and forms
may he submitted up t~ five days after an objectionable event. ISS The completed form is to be
delivered without delay to the on-duty supervisor,156 who is to meet with the detainee. IS? If the
supervisor is unable to resolve the Psroblem, a notation is made on the grievance form, which is
forwarded to the department head. S8 If the detainee doeS not accept the department head's
proposed solution, the grievance is forwarded to the Detainee Grievance Committee, which must
make a ruling within five days of convening, stating the reasons for its ruling. IS9 The detainee
can appeal the committee's ruling to the officer-in-charge, who must respond within five days
and may uphold, modify or reverse the committee ruling. l60 The Standards prohibit retaliation
against detainees for filing a grievance,161 and the facilities are required to keep a record of
grievances. 162 Further, the Standards require detainee handbooks to provide an explanation of

Interviews with detainee
and an
anonymous detainee (July 8, 2004). But note, one detainee likened the unpaid work structure to slavery. Interview
wi
u1y8, 2004).
·149

150

Standards, Ch. 18: Detainee Grievance Procedures, Sec. IlIA!.

mId. at Sec. IlIA2.
U2 ld.

at Sec. III.A.2.6.

m ld. at Sec: IlI.A.i.4.
154

ld. at Sec. IlI.A.2.!.

mId. at Sec. III.A.2.
1S61d.
U7

at Sec. IlI.A.2.3.

Ii at Sec. IlI.A.2.

usId.
U9Id.
160 ld.

at Sec. III.C.

1611d.

at Sec. III.D.

162 Id.

at Sec. m.E.

20
OC\69S08\'2

L-ATHAM&WATKINSup

the grievance procedures and prDvide the .opportunity to file a complaint about .officer
miscondud directly with the Justice Department (including the phone number and address). 163
At the Mira Lorna Detention Center, detainees are able to file a grievance by filling
out a fDrm, which·can be found in every barracks. The detainee then places the form in a lock
bDX, which is checked by the SupervisDrafter every shift. The Sheriff's staff reviews the
complaints and sends complaints related tD the Standards tD ICE. The grievances are processed
within ten days. If a detainee is illiterate, he can ask fDr help from the staff. Language is alsD
not an impediment t.o filing a complaint; the staff at the Mira LDma DetentiDn Center will
translate complaints made in foreign languages. 164
The Mira Lorna Detention Center appears tD have an .organized system for filing
grievances and dDes not appear to be dismissing the Standards gDverning the grievance
procedure. Whether Dr nDt th~ grievance system is effective, hDwever, is another matter. SDme
detainees r~rted suspicions that the Center's .officers retaliated against complaining
.
detainees. 16
Additionally, detainees rePDrted .of a strip search that officers and staff conducted
.over MemDrial Day weekend. 166 In .one barrack, abDut 14 to 15 .officers .observed the strip
search..167 Detainees were required t.o strip d.own and bend over, hDlding their butt.ocks apart. 168
Many .of the .officers present were laughing at the detainees during this procedure. 169 The
detainees reported feeling humiliated by this epis.ode. 170 One·detainee reported that the entire
incident was filmed, and that the detainees had filed a petition with the ACLU to have ·the tape
destroyed. 171
The detainee who reported this incident t.o us alS.o noted that ICE was notified of the
situation, an .officer said it would be investigated, but nothing had been done as a result of any
.
.,
In
mvestigatl.on.

163

Detention

Detainee Services, Standard

Sec. m.G.

Angeles Sheriff's Department (July 8, 2004).
two anonymous detainees (July 8, 2004).
8,2004).

I6Ild.

1691d.

170lnterview with anonymous detainee (July 8,2004).
.171

Interview with anonymous detainee (July 8, 2004).

I7l

Interviews with detainece

.IIM•••iiliQIM.:July 8, 2004).
21.

00695081.2

LATHAM&.WATKINSup

H. Immigration Court
The Mira Lorna Detention Center has an Immigration Court on site. It is marked
Building 27 and is located just beyond the security base. Detainees are transported to the
Immigration Court building for their hearings. They are handcuffed-when walking from the
security base to the Immigration Court. There is a list of pro bono legal services posted in the
living quarters; however, due to Mira Lorna's remote location, it is very hard for detainees to
obtain legal counsel. While detainees can attend group rights presentations, which are given in
English and Spanish, it is unclear whether the detainees who speak neither English nor Spanish
have any similar opportunities to receive any kind oflegal adv,ice.

I. ICE Presence
ICE has a sizeable on-site presence at the Mira Lorna Detention Center. The ICE
contingent includes: six deportation officers, eight immigration enforcement agents, in addition
to M
The Mira Lorna Detention Center is an Intergovernmental Service
Agreement (IGSA) facility, and ICE is at Mira ~ma daily. As a consequence of the large onsite ICE presence, ICE is constantly visiting and interviewing detainees.
If a detainee needs to contact the ICE staff, the detainee can also fill out a complaint
form, located in the barracks. The detainee requests are screen
the facility staff, which then
re-routes ICE-related complaints/requests to the ICE sWf. Mr
that ifa'detainee
has an urgent complaint or problem, it will be addressed within 72 hours, and otherwise,
complaints are respOnded to as soon as practicable. MMWWiQiWsaid that a log of detainee
requests sent and responseS received is not kept at the Mira Lorna Detention Center.

VI. CONCLUSION
At the time of the delegation's visit and tour, the Mira Lorna Detention Center
appears well-run, and the officers in charge appear professional and humane. Of particular
concern however, is the strip-search incident noted above. While not all of the Standards have
been fully implemented, as artioulated above, the Center is aware of the Standards and appears to
be working to implement them.
'

22
00695081.2