M E M O R A N D U M
November 13, 2002
To:

Anthony S. Tangeman, Deputy Executive Associate
Commissioner Office of Detention and Removal

From:

American Bar Association Delegation to Santa Ana Detention Facility 1

File:

09999:2658

Re:

INS Compliance with Detention Standards at the Santa Ana, California
Detention Facility

This memorandum summarizes and evaluates information gathered at the Santa
Ana City Jail located at 62 Civic Center Plaza, Santa Ana, California 92702 (the “Santa
Ana Facility”) through interviews of detainees, observation by delegation staff, and
b6, b7C
discussions with Detention Supervisor
on October 2, 2002. 2
INS Detention Standards
The Immigration and Naturalization Service (INS) promulgated the “INS
Detention Standards” in November 2000 to ensure 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 range of issues as described more fully
below. These standards apply equally to state and local government facilities used by
the INS through Inter-Governmental Service Agreements (“I.G.S.A.”), such as the
Santa Ana Facility. The Detention Standards went into affect at INS Service Processing
Centers on January 1, 2001, but do not appear to have been completely phased-in at the
Santa Ana Facility.
I.

General Information

As noted above, the Santa Ana Facility is an I.G.S.A. detention facility. Of the
251 persons housed at the Santa Ana Facility, approximately 83 are INS detainees.
Approximately 80% of the INS detainees are classified as criminal aliens. 3 The
countries of origin most represented by the INS detainees housed at the Santa Ana
1

b6
b6
b6
b6
The delegation was comprised of
,
b6
b6
, and
of Fried, Frank, Harris, Shriver & Jacobson (Los Angeles, CA).
b6
Also present during the delegation’s tour was
Esq. of the Catholic Charities of Orange
County.

2

According to her business card (“Attachment A”), Ms. b6, b7C can be reached at Police Department
Santa Ana, CA 92702.
b6, b7C

3

According to Officer b6, b7C an INS detainee at the Santa Ana Facility is classified as criminal if his
or her record indicates a criminal history.
A Partnership
Including
Professional
Corporations

#81109

Facility are Mexico, El Salvador, Viet Nam, and Guatemala.
II.

Legal Access/Visitation

The Santa Ana Facility has four general visitation non-contact booths and two
open contact visitation rooms. The contact rooms each contain one small round table
and four chairs. According to Ms. b6, b7C visitors are permitted at any time other than
“lock down” periods, which are generally from 12:00 - 1:00 p.m., 5:30 - 6:30 p.m., and
11:00 - 6:00 a.m. 4 Detainees are strip searched after each contact visit with an
attorney. 5 Otherwise, detainees did not have many complaints concerning problems
with visitation.
III.

Telephone Access

There does not appear to be any problems regarding the number of telephones
available to detainees at the Santa Ana Facility. There were approximately a dozen
telephones available in the processing unit (including one in each private interview
room). There were also six telephones available in the housing module visited by the
delegation, which houses up to 64 detainees. Thus, detainee access to telephones is
generally not a problem, though, as discussed below, access is denied during occasional
“lock downs” of up to 72 hours due to staff shortages.
The INS Detention Standards for telephone access, Section III.D. provides:
Even if telephone service is generally limited to collect
calls, the facility shall permit the detainee to make direct
calls:

4

Mr.

5

Mr.

1.

to the local immigration court and the Board of
Immigration Appeals;

2.

to Federal and State courts where the detainee is
or may become involved in a legal proceeding;

3.

to consular officials;

4.

to legal service providers, in pursuit of legal
representation or to engage in consultation
concerning his/her expedited removal case;

5.

to a government office, to obtain documents
relevant to his/her immigration case; and

6.

in a personal or family emergency, or when the
detainee can otherwise demonstrate a compelling
need (to be interpreted liberally).

notes.

b6
b6

and Mr.

b6

notes.

2

However, the policy of the Santa Ana Facility is that local calls are free of charge for
detainees, and all other calls must be dialed collect. Several detainees disputed this,
stating that all calls must be dialed collect 6 -- even local calls to courts, attorneys or
family members -- though one detainee corroborated that “very” local calls are free.7
The cost of a collect call is $3.25 for the first minute and $1.25 for each minute
thereafter. International calls are not permitted at all. 8 Certain detainees indicated that
the practice at other local INS Facilities of permitting the use of phone cards is the
better system. 9 Detainees also indicated that telephone usage is subject to frequent
disconnections, requiring them to redial calls and incur the $3.25 charge a second
time. 10 The service provider for the Santa Ana Facility is Pac Bell.
The telephone system does not permit detainees to place free “1-800” calls. 11
Nor does the system provide free pre-programmed calls. 12 The facility has plans to
implement an improved telephone service that would provide free 1-800 numbers for
various governmental consulates, legal representatives, and the INS. Facility
representatives were not sure, however, when or how this new system would be
administered and suggested that it may be cell-phone based. 13
A.

Receiving and Delivering Phone Messages

The INS Detention Standards on telephone access, Section III.I., provide:
The facility shall take and deliver telephone messages to
detainees as promptly as possible. When facility staff
receives an emergency telephone call for a detainee, the
caller’s name and telephone number will be obtained and
given to the detainee as soon as possible. The detainee
shall be permitted to return the emergency call as soon as
reasonably possible within the constraints of security and
safety. The facility shall enable indigent detainees to
make a free return emergency call.
However, Officer b6, b7C indicated that the Santa Ana Facility does not take and deliver
phone messages from attorneys because it is generally too difficult to verify who is on
6

This is reflected in the notes of detainee interviews conducted by Ms.
Ms.
b6

7

Mr.

8

Ms.

9

Ms.

b6

, Mr.

b6

, and

’ notes.

b6

and Ms.
b6

and Mr.

b6
b6

notes of interviews with detainees.
notes of interviews with detainees.

10

b6
b6
Mr.
and Ms.
notes. Mr. b6 personal experience corroborates this
complaint. He received a collect call from a detainee that was disconnected midway through the call.
The detainee attempted to call back immediately.

11

Ms.

12

Ms.

13

Ms.

b6

notes.
and Mr.

b6
b6

b6

notes of the interviews with detainees.

notes.

3

the other end of the line. Exceptions may be made if the officer answering the phone
recognizes the voice of an attorney, otherwise messages are not taken and delivered
from any other persons. There is no procedure for taking and delivering emergency
phone calls, though a message may be delivered if a supervisor approves. According to
Officer b6, b7C such approval is rare. 14
The fact that messages are not received -- together with the fact that detainees
are required to make collect calls (as discussed above) -- makes it very difficult for
detainees to keep in contact with their attorneys and family members. According to the
detainees, it is more difficult to leave messages with attorneys calling collect and, in any
event, it does not make much sense to try because attorneys are unable to call back and
speak with detainees. 15 This problem is further exacerbated by the problems with
disconnections discussed above since often, when a detainee’s call with his or her
attorney is disconnected, the attorney is on another line or otherwise unavailable by the
time the detainee calls again. 16
B.

Privacy

Generally, the phone system does not provide physical privacy because the
telephones are located close together in a central location in the housing module. The
telephones in the private interview rooms adjacent to the processing unit do provide
privacy, but detainees do not have access to these rooms after they have completed the
booking process. 17
All calls are electronically monitored unless the detainee submits the name and
telephone number of his or her legal representatives at booking and asks for those calls
to be private. 18 However, Officer b6, b7C is uncertain whether detainees are told at
booking that they have the right to private calls with their attorneys. Even when a
detainee submits the name of his or her attorney, the call still will be monitored unless
an officer is able to validate the attorney’s telephone number and make arrangements
for the detainee’s calls to those numbers to be private. Validating an attorney’s phone
number typically consists of calling the phone number to determine whether it is
answered with the phrase “law office” or a similar phrase. 19 One detainee explained
that he is unable to speak privately with his attorney if his attorney uses a cell phone or
home line. 20 Another detainee indicated that calls with his attorneys are monitored
because his attorney works for the Center for Human Rights and not a law firm. 21
Officers have also indicated that detainees cannot have private phone conversations
14

Ms.

15

Mr.

16

Ms.

b6

notes.

notes of interview with detainee.

b6

notes of interview with detainee.
b6

17

Ms.

18

Detainees must fill out an “Attorney Telephone Number Notification” form (“Attachment B”).

19

Ms.

20

Mr.

21

Ms.

b6
b6
b6

notes.
notes.
notes of interview with detainee.
notes of interview with detainee.

4

with more than one attorney. 22
In addition, there is no procedure for notifying detainees who have retained
attorneys after the initial booking process that calls to the attorney may be excepted
from monitoring upon request and validation. There were no posted notices notifying
detainees of this right. Also, Officer b6, b7C knew of no procedure for allowing calls
made by pro per detainees to be private. 23
C.

Posted Signs

The phones in the processing unit have placards posted nearby notifying
detainees in both English and Spanish that telephone calls are monitored. There are
also signs posted in the processing unit explaining in both English and Spanish how to
place free local calls and long distance collect calls. In the housing module, the
placards were not posted by all of the phones. Instead, there was one sign posted by a
cluster of phones in a central location stating that it is the detainee’s responsibility to
notify the person contacted that the call is being monitored. The delegation did not
notice any posted signs providing a list of pre-programmed free calls.
A sign posted in the housing module notifies detainees that phone calls will be
disconnected if the phone system detects any of the following: a three-way call, call
waiting, call forwarding, a cordless phone too far away from its base, or background
noise. 24
A list of pro bono agencies is posted near the telephone clusters in the housing
modules. However, the list is in English only. With one exception, all of the listed pro
bono service providers are located in Los Angeles, not Orange County. As a result,
detainees are required to call these pro bono providers collect (although detainees claim
that all calls, not just local calls, must be dialed collect). 25
IV.

Legal Materials

The INS Detention Standards on access to legal materials, Section III.A.,
provides:
The facility shall provide a law library in a designated
room with sufficient space to facilitate detainees’ legal
research and writing. The law library shall be large
enough to provide reasonable access to all detainees who
request its use. It shall contain a sufficient number of
tables and chairs in a well-lit room, reasonably isolated
from noisy areas.
22

Ms.

23

Ms.

24

Mr.

25

Ms.

notes of interview with detainee.

b6
b6
b6

notes.

notes.
b6

notes.

5

There is no law library at the Santa Ana Facility. Instead, on-line Westlaw
research is available via computer terminals. There is one computer terminal per
housing module and they are available only to detainees representing themselves pro
per. 26 In making the determination as to whether a particular detainee can have access
to Westlaw, detainees explained that the officer in charge of the housing module (the
“Module Officer”) looks to the detainee’s file to determine whether he or she has an
attorney of record. Detainees who have had trouble contacting their attorneys for
weeks, or even months (often because of the telephone issues described more fully
above), expressed frustration with this policy since they are not permitted to remove
their attorney’s name from the record. 27 Officer b6, b7C also explained that certain
legal forms are available upon request, but admitted that there is really no way for
detainees to determine which forms they need.
Pro per detainees are permitted to print out materials from the computer, but are
not permitted to save any information. Detainees in general, whether pro per or not, are
also permitted to make photocopies and mail documents as reasonably needed. 28 The
detainees did not have any complaints in this regard.
The staff at the Santa Ana Facility was not familiar with the Florence Project’s
“Know Your Rights” packets or video, and admitted that they did not have these
materials on site. 29
V.

Group Rights Presentations

Group rights presentations are conducted at the Santa Ana Facility very
b6
infrequently. Ms.
of the Catholic Charities of Orange County offers
presentations, but staff members and detainees had never heard of the Florence
Project’s “Know Your Rights” video. 30 Detainees reported having the opportunity to
b6
meet with Ms.
one on one to discuss their legal rights. 31
VI.

Recreation Issues

Generally, detainees have access to the indoor and outdoor recreation areas any
time they are not in “lock down.” The officers explained that “lock down” hours are at
night, from 11:00 p.m. to 6:30 a.m.; during lunch, from 12:00 p.m. to 1 p.m.; and at
dinner, from 5:30 p.m. to 6:30 p.m. 32 The facility also goes into “lock down” whenever
a head count is necessary -- a minimum of four times per day according to the Detainee
Handbook. One detainee explained that in his housing module, his access to the
26

Mr.

27

Mr.

28

Mr.

29

Mr.

30

Ms.

31
32

notes.

b6

notes of interview with detainee.

b6

notes.
b6

notes.
notes.

b6

Notes of Ms.
Mr.

b6

b6

Mr.

b6

, and Ms.

b6

notes. See also Detainee Handbook, (May 1, 2002) at 4 (“Attachment C”).

6

recreation areas is limited. Because his housing module contains both criminal and
non-criminal inmates, each group must split time in the recreation areas in order to
avoid “mixing” of the groups. 33 Also, there are sometimes extended “lock down”
periods of up to seventy-two (72) hours because of staff shortages. 34
A.

Outdoor Recreation

The detainees’ access to the outdoors is limited to a small concrete area located
adjacent to each housing module, covering an area of approximately 20 feet by 30 feet.
The outdoor recreation area has high walls and was only partially open to the sky. One
detainee explained that it is difficult to get sun in the enclosed area. 35 The activities
available to the detainees in this outdoor area are handball and ping pong. 36
B.

Indoor Recreation

The indoor recreation area in the housing module contained an open space with
a television at one end and chairs distributed throughout. There were six telephones in
the recreation area, none of which were located in a booth or otherwise enclosed. 37
Throughout the housing module recreation area, the delegation observed posted
materials covering topics such as: pro bono legal services information, INS contact
information, a calendar for various classes, meetings and religious groups, and
information about the telephone system. 38 The delegation did not observe any board
games in the common area, though the Detainee Handbook indicates that they are
available for detainee use.
VII.

Classes

The Santa Ana Facility offers a number of courses for detainees as set forth on
the “Santa Ana Jail School Pre-Application Form” (“Attachment D”). However, as
noted above, the vast majority of inmates at the Santa Ana Facility are criminal inmates
and criminal inmates are not permitted to mix with non-criminals. Thus, as a practical
matter, the most popular courses, such as the computer course, are not available to noncriminal INS detainees. 39 This is especially true since there is a wait-list for the more
popular courses and enrollment is determined by seniority (criminal inmates are
generally detained longer than INS detainees). 40

33

Mr.

34

Ms.

b6

35

Ms.

b6

36

Mr.

37

Ms.

38

Mr.

39

Mr.

40

Mr.

and Ms.

b6

b6

notes of interviews with detainees.

notes.
notes of interview with detainee.
notes.

b6

notes.

b6

notes.
b6

notes of interview with detainee.
notes.

7

VIII. Medical Issues
b6
The delegation met with Ms.
, a Director of Operations with the
Correctional Managed Care Medical Corporation, 41 who explained the medical services
provided for both criminal inmates and INS detainees at the Santa Ana Facility. Ms.
b6 noted that the facility is not accredited by the California Medical Association, but
that it is subject to annual inspections and quarterly audits. 42

During the day, the Santa Ana Facility has one registered nurse, one licensed
vocational nurse, and one medical clerk. During the night shift, there is one registered
nurse, and either one licensed vocational nurse or one nurse practitioner. There is a
doctor on call twenty-four hours a day. The doctor comes in for daily sick calls or as
needed. Only a doctor or registered nurse can diagnose; the licensed vocational nurse
can provide input, but cannot diagnose. 43
When treating or examining detainees who do not speak English, the medical
staff uses a telephone “translation line” for assistance, if a translator is not on site.
A.

General Procedures for Medical Services

New detainees are given a pre-screening examination upon arrival to the Santa
Ana facility. This examination includes both medical and mental health testing. In
connection with this examination, detainees are asked to provide basic information by
filling out a “Santa Ana Jail Medical/Mental Pre-Screening” form (“Attachment F”).
When an INS detainee is transferred from other INS facilities, the Santa Ana Facility
does not always receive the detainee’s medical records. A detainee may obtain his or
her medical records by signing a release; a court order is not required. 44
If a detainee desires medical attention after being admitted to the facility, he or
she must fill out a “sick call request” form (“Attachment G”). Generally, detainees are
seen by medical personnel within 24 hours of submitting a request, though detainees
interviewed by the delegation indicated that sometimes it takes longer. 45 The facility
has daily sick calls to talk to detainees about their conditions. If a detainee’s problem is
minor and can be treated on-site, the on-site medical staff will treat the detainee. On a
daily basis, a licensed vocational nurse distributes medications as prescribed. 46
If, on the other hand, the problem is an emergency, the detainee is transferred to
Western Medical Center, a nearby hospital. Unless an INS agent is available at the
time, a police officer from the facility will accompany the detainee. If a detainee
41

According to her business card (“Attachment E”), Ms.
b6
Anaheim, CA 92085, phone number (
b6

42

Ms.

43

Ms.

44

Ms.

45

Mr.

46

Ms.

notes.
b6

notes.
notes.

b6
b6

notes of interviews with detainees.
notes.

8

b6

can be reached at

b6

experiences a problem such that the detainee cannot safely stay in the facility, the
medical staff will contact the San Pedro INS facility for assistance. 47
If the problem is not an emergency, but requires an off-site medical procedure,
the process for obtaining permission can take a long time. A doctor will first determine
whether a detainee requires a medical procedure. The request must then be approved by
the INS. Ms. b6 stated that it can sometimes take the INS several weeks to a month (or
longer) to respond to a request for a medical procedure.48 Even when an off-site
medical procedure is approved, at least one detainee reported an instance in which the
INS failed to appear to transport him off site to receive an approved and pre-scheduled
medical procedure and the staff at the Santa Ana Facility refused to transport him. 49
Apparently, it is the responsibility of the INS, and not facility police officers, to
transport INS detainees, but the INS is not reliable in this regard. Another detainee
explained that the Santa Ana doctor repeatedly approved an off-site eye procedure for
him, but the INS keeps denying his request. 50
The facility also offers dental visits one day per week. In order to see a dentist,
detainees must request a dental visit through the same “sick call request” form
discussed above.
B.

Mental Health Services

The facility offers psychiatric clinics twice every month, which are run by a
psychiatrist. Interpreters are generally made available for the psychiatric clinics. On
Thursdays and Saturdays, there are counselors available to meet with detainees.
Otherwise, counselors are available on an on-call basis. Detainees are also observed for
behavior changes by the officers in charge of overseeing the housing units. Officer
b6, b7C
stated that the officers can fill out a form to describe a detainee’s behavior if a
problem is perceived and forward it to the medical staff. Officers can request
psychiatric examinations for the detainees. In addition, there is a crisis intervention
team (called the Psychiatric Evaluation Team, or PET Team) available to determine if
someone needs acute care or other assistance. Alcoholics Anonymous meetings are
held every Monday. 51
According to Ms. b6 if a detainee is taking psychiatric medications when he or
she first arrives at the Santa Ana Facility, the medical staff continues administering the
medications and facilitates continuing treatment from any outside doctors. 52 However,
detainees explained difficulties obtaining medication prescribed prior to being detained

47

Ms.

48

Ms.

49

Mr.

50

Ms.

51

Ms.

52

Ms.

notes.
b6

b6
b6

notes.
notes of interview with detainee.
notes of interview with detainee.
notes.

b6

notes.

9

at the Santa Ana Facility. 53 One detainee explained that when he submitted a request to
receive his prescribed depression medication, the doctor at the Santa Ana Facility would
not permit him to take the medication because “everybody in jail is depressed.” 54
Ms. b6 stated that the facility had a “suicide unit.” Officer b6, b7C noted also
that anyone on a suicide watch is placed into a housing unit with a bunk mate.
C.

Segregation for Medical Reasons

A detainee who has been diagnosed (either by the doctor or registered nurse)
with a contagious disease or illness is isolated from the other inmates. A doctor must
sign off on the isolation protocols. The segregation ends when the person is cured or no
longer contagious. The facility does not have an infirmary.
Detainees who are HIV positive are not generally segregated from the inmate
population. Their HIV status is kept confidential. If the detainee is being treated by an
outside HIV clinic, he or she is generally permitted to visit the clinic. 55
D.

Refusal of Treatment and Hunger Strikes

A detainee may refuse to take medications up to three times if the medicine is
not critical. After three refusals, the doctor’s involvement is required in ensuring the
health of the detainee. The detainee will be counseled about their refusal to take
medication and, ultimately, the doctor at the facility will determine whether a detainee
who refuses medical care can be housed safely at the facility. All refusals are
documented in the detainee’s medical record. 56
There are no formal procedures for hunger strikes, other than monitoring the
detainee’s vital signs. Officers are required to report any detainees who are not eating.
Officer b6, b7C explained that she has seen persons within the facility who may not eat
the food given at meal times, but who would instead eat food purchased at the
commissary. 57
IX.

Religious Issues

The Santa Ana Facility has a group Bible study twice a week and a Muslim
prayer group meets on Fridays. The facility has a chaplain and one detainee explained
that a Muslim religious figure once visited the facility regularly, but does not visit any
more. Meals which accommodate detainees’ religious beliefs are provided upon

53

Mr.

b6

and Ms.

54

Mr.

b6

notes of detainee interviews.

55

Ms.

56

Ms.

57

Ms.

b6

notes of interviews with detainees.

notes.
b6

notes.
notes.

10

request. 58
According to the Detainees, they are permitted to keep a Bible or Koran, but no
other personal belongings. 59 The Detainee Handbook provides that a detainee “may
request . . . authorization for items not listed [in the handbook] by submitting an Inmate
Request Form to the Security Supervisor.” 60 It was not clear whether, in practice, the
Santa Ana Facility permits detainees to retain religious items.
X.

Other Issues
A.

Lack of Detainee Contact with INS Representatives

INS Detainees at the Santa Ana Facility have experienced difficulty contacting
INS representatives to discuss their immigration status. Officer b6, b7C explained
that an INS representative was supposed to visit the Santa Ana Facility every Thursday,
but that no one from the INS had come to the facility since late August. Detainees may
request to meet with their deportation officer, but deportation officers rarely come to the
Santa Ana Facility to meet with detainees. 61 One detainee indicated that he submitted a
request to meet with his INS counselor over four months ago, but has still not met with
him. Even when INS representatives do come, they typically do not bring detainee files
and are unprepared to discuss the detainee’s immigration status. According to
detainees, deportation officers typically come to the Santa Ana Facility merely to make
an appearance, but are of little assistance. 62
B.

Grievance and Disciplinary Procedures

When a detainee has a complaint, he or she may fill out an “Inmate Grievance
Form” (see “Attachment I”) and submit it to the Module Officer. If the detainee is not
satisfied with the Module Officer’s response, he or she may submit the grievance form
to the Module Officer’s superior. Officer b6, b7C also explained that different Module
Officers are on duty at different times. Thus, when a detainee has a complaint directed
at a Module Officer, the detainee has the opportunity to submit the grievance form to a
different officer when the first officer is off duty. 63
The Detainee Handbook sets forth a non-exclusive list of behaviors classified as
minor and major disciplinary violations. The consequences for disciplinary violations
are described as follows:
58

Mr.

notes.
b6

59

b6
Mr.
notes of interviews with detainees. On the other hand, Ms.
notes of her interview
with a detainee indicate that certain items, such as crosses and angels, are permitted to remain in
detainees’ possession.

60

See Detainee Handbook, (May 1, 2002) at 14. The “Inmate’s Request Form” is attached hereto as
“Attachment H.”

61

Mr.

62

Mr.

63

Mr.

notes.
b6

and Ms.

b6

notes of interviews with detainees.

notes.

11

1.
2.
3.
4.
5.
6.
7.

Verbal warning
Loss of privileges
Extra work privileges
Removal from work detail
Disciplinary isolation
Forfeiture of good time and/or work time
Criminal charges 64

The handbook fails to outline (1) which penalties correspond to which violations or (2)
what disciplinary procedures, if any, are in place. Notably, the “Inmate Grievance
Form” appears to have a box to be checked if a detainee has a disciplinary complaint.
However, the delegation did not notice the facility’s disciplinary policies posted
anywhere in the facility.
C.

Detainee Work Program

The Santa Ana Facility has a work program, though one detainee indicated that
work programs are not available to non-criminals. 65 Other detainees indicated that they
are required to clean and perform other “janitorial services” in their housing module
without pay. If they refuse, they are put in “lock down.” 66
D.

Personal Item Retention

As noted above, the Detainee Handbook sets forth a list of “authorized items”
detainees may keep in their cell. 67 Detainees may store as many items in their cell as
their jail issued property bins will hold. The Detainee Handbook further states that
certain “daily used items” may be stored neatly on the desktop and/or bookshelf within
the cell.
E.

Dietary Requirements

Detainee meals are provided by Aramark Corporation. The diet provided by
Aramark Corporation includes approximately 3100-3200 calories per day and is
determined by certified dieticians. Detainees can and do request accommodations for
religious and ethnic diet requirements. 68 Coffee and juice is also available in the
housing module.

64

See Detainee Handbook, (May 1, 2002) at 11.

65

Ms.

66

Ms.

67

See Detainee Handbook, (May 1, 2002) at 13.

68

Mr.

b6
b6

b6

notes of interview with detainee.
and Ms.

b6

notes of interview with

notes of interviews with detainees.
b6

food services manager with Aramark Corporation.

12

XI.

Conclusion

Overall, the staff at the Santa Ana Facility was very cooperative and the facility
was a very clean and well-maintained state-of-the-art facility. For the most part,
detainees represented that the staff is generally respectful toward them. As Ms.
b6
explained, the INS detainees at this facility are better off in many ways than
their counterparts at other nearby INS facilities.
However, perhaps due to the nature of the I.G.S.A. arrangement with the INS,
the policies and procedures at the Santa Ana Facility did not seem to be informed by the
INS Detention Standards in several respects. There is significant room for
improvement, particularly with respect to detainee access to legal resources and
receiving telephone messages. There also appears to be a consistent problem with the
availability of INS representatives to speak with Santa Ana detainees.
These failings seem to have more to do with failings of the INS than the facility
staff. For instance, the lack of detainee contact with INS officials, the lack of a "1-800"
number, and the failures in connection with medical transportation are INS
responsibilities. The Santa Ana staff seemed willing to accommodate the needs of INS
detainees ― Ms. b6, b7C explained that she is trying to gather enough INS detainees to
fill the popular computer class and is willing to make any required legal materials
available to detainees ― but it does not appear that the INS has adequately informed the
Santa Ana staff of these standards and made the appropriate materials and resources
available.

13