U.S. Department of Homeland Security
Immigration and Customs Enforcement
Office of Professional Responsibility
Inspections and Detention Oversight
Washington, DC 20536-5501

Office of Detention Oversight
Compliance Inspection

Enforcement and Removal Operations
Houston Field Office
Joe Corley Detention Facility
Conroe, Texas

April 9 - 11, 2013

COMPLIANCE INSPECTION
JOE CORLEY DETENTION FACILITY
HOUSTON FIELD OFFICE
TABLE OF CONTENTS
EXECUTIVE SUMMARY ...........................................................................................................1
INSPECTION PROCESS
Report Organization .............................................................................................................6
Inspection Team Members ...................................................................................................6
OPERATIONAL ENVIRONMENT
Internal Relations .................................................................................................................7
Detainee Relations ...............................................................................................................7
ICE PERFORMANCE-BASED NATIONAL DETENTION STANDARDS
Detention Standards Reviewed ............................................................................................8
Admission and Release ........................................................................................................9
Classification System .........................................................................................................10

closely with the ICE contracting officer’s technical representative to align facility policies with
the PBNDS. ICE personnel interact with facility staff and detainees on a daily basis to
proactively identify and resolve compliance issues.
Upon admission, detainees attend a facility orientation, and JCDF management provides
detainees a facility handbook and the ICE National Detainee Handbook, which are both available
in English and Spanish. Detainee property and valuables are inventoried, logged, sealed in
property bags, and placed in a secure storage area. Detainees are provided with appropriate
clothing and free hygiene supplies.
ERO classifies detainees prior to admission to JCDF. Facility staff review and affirm the
classification of arriving detainees using the JCDF classification system. A review of
18 detention files confirmed each contained an ERO classification form, a criminal record, an
Order to Detain/Release Alien, and documentation of a supervisory review. Procedures are in
place for reclassifying detainees housed at JCDF for more than 60 days, when new information
affecting classification levels is received, or following disciplinary action. The JCDF detainee
handbook addresses the classification system and procedures for appealing classification
decisions.
The JCDF detainee handbook is available in all detainee housing units and in the JCDF library.
ODO reviewed 30 detention files and confirmed all detainees signed an acknowledgement
confirming receipt of a facility handbook and the ICE National Detainee Handbook. ODO
confirmed all required content is covered in the JCDF handbook.
Disciplinary policy at JCDF addresses all requirements of the PBNDS. JCDF management has
formulated a graduated severity scale for prohibited acts and disciplinary sanctions, and
encourages informal resolution for minor infractions. Low and moderate level incidents are
reviewed and adjudicated by the Unit Disciplinary Committee; higher level incidents are referred
to the Institution Disciplinary Panel for adjudication.
GEO manages the food service operation at JCDF. Food service staff consists of a food service
manager, a food service production manager, an administrative clerk, and(b)(7)ecook specialists.
Food service staff is supported by a crew of(b)(7)eICE detainee workers. ODO reviewed files for
(b)(7)efood service staff and(b)(7)edetainee workers and verified all received pre-employment medical
clearances. The master cycle and special diet menus are reviewed annually by the food service
supervisor and certified by a registered dietician based on a complete nutritional analysis. The
master menu is a 42-day cycle that includes a minimum of two hot meals per day. Religious
diets are approved by the Major, in consultation with a volunteer chaplain, and medical diets are
provided when ordered by the medical unit. All areas of the food service operation are clean and
well organized.
The property storage area at JCDF is monitored 24 hours a day via closed circuit video cameras.
JCDF conducts weekly audits of detainee property, which exceed the PBNDS requirement for
quarterly audits. These audits are documented on a facility-generated property form.
Informal and formal grievance procedures are covered in the facility handbook. The JCDF
grievance policy is comprehensive and addresses all requirements of the PBNDS, including
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appeal procedures. Detainees may contact ICE directly if they are dissatisfied with a grievance
decision or an appeal response at the facility level.
The Executive Secretary is the designated grievance coordinator and maintains a grievance log to
document and track formal and informal grievances submitted by ICE detainees. The grievance
log for the 12 months preceding this CI reflected no formal detainee grievances. A total of
32 informal grievances were documented on the log, and ODO verified all responses to
grievances were timely. The categories of the informal grievances were as follows: 12 regarding
medical appointments (five from the same detainee), five related to photocopies and free mailing
privileges, three regarding property, and two related to laundry services. The remaining
grievances were miscellaneous and unrelated. There were no grievances alleging staff
misconduct. The grievance log documented informal resolutions of all 32 grievances. ODO
identified no trends or patterns.
JCDF has a dedicated law library with five computers, one typewriter, a copy machine/printer,
and adequate furnishings. All computers are equipped with the most recent version of
LexisNexis software. Library hours are posted in the library and in each detainee housing unit.
This information is also provided in the facility handbook. Detainees have document copying
privileges and sufficient opportunities to prepare legal documentation. A JCDF staff member
oversees the library and assists detainees as needed. Detainees can make private, unmonitored
telephone calls for legal purposes.
The medical clinic, which is operated by GEO, has 24-hour nursing coverage. The Clinical
Medical Authority is a physician who has provided services at JCDF for one year and has prior
experience with the Texas Department of Corrections. The Clinical Medical Authority examines
between 15 and 30 patients each day. Additional staff includes a dentist, a dental assistant, (b)(7)e
registered nurses,(b)(7)elicensed vocational nurses, (b)(7)epharmacy technician (b)(7)e certified
medication assistants, and(b)(7)e medical records technicians. The Clinical Medical Authority
stated lack of a mid-level provider is an issue. The current staffing plan does not include a
position for a nurse practitioner or a physician assistant. At the time of the review, there were
vacancies for a director of nursing, a registered nurse, a licensed vocational nurse, and a licensed
psychology counselor. ODO confirmed training files contain all required documentation, and all
credentials are primary source verified. Physical examinations are conducted by an
appropriately-trained registered nurse. In all 30 records reviewed by ODO, a hands-on physical
examination and a dental screening were completed within the 14-day timeframe prescribed by
the PBNDS.
Detainees are screened for tuberculosis at intake via a chest x-ray. Documentation of necessary
screening was confirmed during the medical record review. ODO found the infection control
program at JCDF addresses all PBNDS-mandated subject matters.
Nurses collect and date-stamp sick call requests during visits to the housing units, which occur
twice daily. The triage nurse determines if a medical need is emergent, routine, or requires only
a written response. ODO confirmed sick call requests are triaged in a timely manner, and nonemergency physician appointments are scheduled appropriately.

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All detainees, including those housed in the special management unit, are allowed one hour of
outdoor recreation each day, seven days a week. A full-time recreation officer is responsible for
the development and oversight of the recreation program at JCDF. The facility has three
recreation areas with access to fresh air and sunlight. Handballs, soccer balls, basketballs, and
basketball hoops are available for detainee use. Housing unit dayrooms provide detainees with
opportunities for television viewing and playing board games.
The facility has a designated Sexual Abuse and Assault Prevention and Intervention (SAAPI)
Coordinator and a Sexual Abuse Response Team (SART). The members of the SART include
the SAAPI Coordinator, the Major, the Health Services Administrator, the mental health
professional, and the Facility Administrator or designee. ODO confirmed JCDF policies are
comprehensive and address the requirements of the PBNDS. Staff and detainees are instructed
regarding reporting procedures for sexual abuse and assault. These procedures address
notification through the JCDF chain of command, which includes the shift supervisor, the Major,
and the Facility Administrator. Notification of ICE and local law enforcement is also required,
and medical examinations are mandatory. ODO confirmed there have been no reported incidents
of sexual abuse or assault to date at JCDF.
ODO reviewed(b)(7)e andomly-selected staff training records and verified completion of SAAPI
pre-service training and annual refresher training. ODO verified the SAAPI training program
addresses all required elements, including mandated procedures for handling any reports or
observations concerning possible sexual assault.
Through observation of admission and orientation processing, ODO confirmed JCDF
management provides a presentation to all detainees regarding SAAPI, including a
familiarization with the zero tolerance policy, definitions of sexual abuse and assault, prevention
and intervention, self-protection, reporting, treatment, and counseling. Detainees are also
informed of the SAAPI program via the detainee handbook, brochures, and postings in housing
units, hallways, the medical department, and the intake screening area. All presentations and
written notifications are provided in English and Spanish, and are translated for other significant
non-English speaking segments of the detainee population.
JCDF segregation policies address all requirements of the PBNDS. ODO confirmed the special
management unit is well lit, temperature-appropriate, and sanitary. ODO verified medical,
custody, and administrative personnel visit the special management unit as required by the
PBNDS. There were no ICE detainees housed in the special management unit during the
inspection.
The JCDF staff-detainee communication policy allows detainees to have informal and
unrestricted access and interaction with ERO and facility staff. ERO visitation schedules are
conspicuously posted in all detainee housing units. ODO reviewed the Facility Liaison Visit
Checklists from January 2012 to April 2013, and confirmed ERO officers conduct scheduled and
unscheduled visits multiple times each week to interact with detainees, address questions or
concerns, and monitor the living conditions in the housing units. Detainee request forms, printed
in English and Spanish, are readily available in each housing unit. From January 2012 to the
date of this CI, the facility received and processed more than 4,308 formal and informal requests
from detainees. ODO reviewed 30 randomly-selected formal requests submitted by detainees
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during this time period, and confirmed all 30 requests were documented and recorded in the
electronic request log, detainees were provided a timely response, and a copy of each request
was placed in the individual detention file.
JCDF has three designated suicide watch cells. The cells are monitored via closed circuit
cameras, and are clean and absent of items that can facilitate a suicide. ODO confirmed facility
policy addresses all requirements of the PBNDS. JCDF reported there have been no suicide
attempts; however, five suicide watches occurred during the 12 months preceding this CI. ODO
reviewed the medical file of one detainee who was placed on suicide watch and confirmed
suicide watch management was consistent with the PBNDS and facility policy. Examination of
training records for(b)(7)erandomly-selected custody staff and all medical personnel confirmed
completion of suicide prevention and intervention training as part of orientation and during
annual refresher training.
Detainees have reasonable and equitable access to telephones at JCDF. The facility provides a
total of 240 telephones for detainee use. The ratio of one telephone for every 3.5 detainees far
exceeds the PBNDS requirement of one telephone for every 25 detainees. Notification that calls
are subject to monitoring and procedures for obtaining unmonitored legal calls are provided in
the detainee handbook and posted near telephones in the housing units. Detainees are allowed to
place free calls to consulates, the DHS Office of Inspector General Hotline, and pro bono legal
service providers. An on-site review of ICE logbooks and telephone serviceability reports
confirmed all telephones are inspected for functionality daily by facility staff and weekly by ICE
staff.
JCDF has a comprehensive use of force policy addressing all requirements of the PBNDS. ODO
reviewed(b)(7)erandomly-selected staff training records and verified training in confrontation
avoidance, use of force, cell extraction, application of restraints, use of video recording
equipment, and oleoresin capsicum (OC) spray. ODO confirmed there were no calculated and
four immediate use of force incidents involving ICE detainees during the 12 months preceding
this CI. ODO reviewed the written documentation and video recordings of the four immediate
use of force incidents and verified compliance with facility policy and the PBNDS.

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INSPECTION PROCESS
ODO inspections evaluate the welfare, safety, and living conditions of detainees. ODO primarily
focuses on areas of noncompliance with the ICE National Detention Standards or the ICE
PBNDS, as applicable. The PBNDS apply to JCDF. In addition, ODO may focus its inspection
based on detention management information provided by the ERO Headquarters and ERO field
offices, and to issues of high priority or interest to ICE executive management.
ODO reviewed the processes employed at JCDF to determine compliance with current policies
and detention standards. Prior to the inspection, ODO collected and analyzed relevant
allegations and detainee information from multiple ICE databases, including the Joint Integrity
Case Management System, the ENFORCE Alien Booking Module, and the ENFORCE Alien
Removal Module. ODO also gathered facility facts and inspection-related information from
ERO Headquarters staff to prepare for the site visit at JCDF.

REPORT ORGANIZATION
This report documents inspection results, serves as an official record, and is intended to provide
ICE and detention facility management with a comprehensive evaluation of compliance with
policies and detention standards. It summarizes those PBNDS that ODO found deficient in at
least one aspect of the standard. ODO reports convey information to best enable prompt
corrective actions and to assist in the on-going process of incorporating best practices in
nationwide detention facility operations.
OPR defines a deficiency as a violation of written policy that can be specifically linked to the
PBNDS, ICE policy, or operational procedure. When possible, the report includes contextual
and quantitative information relevant to the cited standard. Deficiencies are highlighted in bold
throughout the report and are encoded sequentially according to a detention standard designator.
Comments and questions regarding the report findings should be forwarded to the Deputy
Division Director, OPR ODO.

INSPECTION TEAM MEMBERS

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

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

6

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

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OPERATIONAL ENVIRONMENT
INTERNAL RELATIONS
ODO interviewed the Warden, the Assistant Warden, an Assistant Field Office Director, and a
Supervisory Detention and Deportation Officer. During interviews, all personnel stated the
working relationship between JCDF and ICE personnel is excellent. JCDF and ERO
management stated morale is high, and working conditions are adequate to accomplish all
required duties.
The Warden and Assistant Warden stated staffing is adequate at JCDF to manage and handle the
current detainee population at the facility. The Warden and Assistant Warden stated ERO
officers visit the housing units multiple times each week to communicate with ICE detainees and
address issues or concerns.

DETAINEE RELATIONS
ODO interviewed 30 randomly-selected detainees to assess the overall living and detention
conditions at the facility. ODO received no complaints concerning access to legal materials,
issuance and replenishment of hygiene supplies, sending and receiving mail, recreation,
visitation, receipt of the detainee handbook, the grievance process, or access to medical care. All
detainees interviewed were satisfied with the telephone service, but felt the cost per minute was
expensive. All detainees stated they are able to contact consular officials, attorneys, and the
DHS Office of Inspector General.
Detainees expressed satisfaction with the level of interaction with ICE staff during weekly
scheduled and unscheduled visits.

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ICE PERFORMANCE-BASED
NATIONAL DETENTION STANDARDS
ODO reviewed a total of 16 PBNDS and found JCDF fully compliant with the following
standards:
Detainee Handbook
Disciplinary System
Food Service
Funds and Personal Property
Grievance System
Law Libraries and Legal Material
Medical Care
Recreation
Sexual Abuse and Assault Prevention and Intervention
Special Management Units
Staff-Detainee Communication
Suicide Prevention and Intervention
Telephone Access
Use of Force and Restraints
As these 14 standards were compliant at the time of the review, a synopsis for these standards
was not prepared for this report.
ODO found deficiencies in the following two standards:
Admission and Release
Classification System
Findings for each of these standards are presented in the remainder of this report.

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ADMISSION AND RELEASE (A&R)
ODO reviewed the Admission and Release standard at JCDF to determine if procedures are in
place to protect the health, safety, security and welfare of each person during the admission and
release process, in accordance with the ICE PBNDS. ODO reviewed policies, procedures, and
detention files, interviewed facility staff and detainees, and observed the admission and release
process.
Upon arrival at JCDF, detainees are searched, photographed, fingerprinted, medically screened,
and provided an identification card and a wristband verifying the identity and classification level
of each detainee. JCDF management provides a facility orientation, as well as a facility
handbook and an ICE National Detainee Handbook provided in English and Spanish. Detainees
view the ICE “Know Your Rights” video and a JCDF facility orientation video. JCDF staff
creates a detention file for each detainee admitted to the facility.
Detainee property is inventoried and logged during the intake process. Property items are
documented on a personal property form attached to the property bag. Valuables and personal
property are appropriately stored in a secure area that is monitored 24 hours a day via closed
circuit video cameras. JCDF conducts weekly audits of detainee property, which exceeds the
PBNDS requirement for quarterly audits. Access to the property room is properly regulated.
ODO reviewed 20 detention files and confirmed all files contained a classification form, proof of
hygiene items issued, and a signed receipt for the facility handbook and the ICE National
Detainee Handbook. Detainees are provided with appropriate clothing and free hygiene supplies.
Prior to release, detainees are fingerprinted, sign a receipt for valuables and personal property,
and surrender facility-issued clothing and bedding.
During this CI, ODO observed unattended, unsecured alien files on a table in the intake/release
processing area, in close proximity to detainees being processed for release (Deficiency AR-1).
Exclusive access by ICE staff to alien files, which are internal ICE records, prevents the loss of
documents from within those files. ODO brought the unattended files to the attention of ICE
management, and immediate action was taken to secure the files in a locked container.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY AR-1
In accordance with the ICE PBNDS, Admission and Release, section (V)(D), the FOD must
ensure, under no circumstances may non-ICE/DRO personnel have access to the detainee’s
A-file.

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CLASSIFICATION SYSTEM (CS)
ODO reviewed the Classification System standard at JCDF to determine if there is a formal
classification process for managing and separating detainees based on verifiable and documented
data, in accordance with the ICE PBNDS. ODO interviewed staff, and reviewed policy, the
housing roster, and detainee files.
ERO classifies detainees prior to admission to JCDF. Upon arrival, facility staff review and
affirm the classification using the JCDF classification system. ODO determined the JCDF
system conforms to the ERO system. Review of 18 detention files confirmed each file contained
an ERO classification form, a criminal record, an Order to Detain/Release Alien, and
documentation of a supervisory review. Procedures are in place for reclassifying detainees
housed at JCDF for more than 60 days, when new information affecting classification levels is
received, or following disciplinary action.
The JCDF detainee handbook addresses the classification system and procedures for appealing
classification decisions. ODO interviewed eight Level III detainees, six Level II detainees, and
three Level I detainees. All stated they were aware of the classification and appeal process.
A review of training records for (b)(7)e taff members confirmed completion of training in the
classification system. ODO interviewed JCDF and ICE personnel who oversee classification and
confirmed all demonstrated a full understanding of classification procedures. Based on a review
of the grievance log and interviews of classification staff, ODO confirmed there were no
grievances or appeals related to classification.
ODO confirmed Level I and Level III detainees are not co-located within housing units;
however, ODO observed Level I and Level III detainees commingled outside of a housing unit
(Deficiency CS-1). ODO noted six unrestrained detainees being escorted to a consular telephone
conference: three in red uniforms signifying a Level III classification, and three in blue uniforms
signifying a Level I classification. ODO verified the classification levels of each detainee by
examining identification cards. While touring the admissions area of the facility, ODO observed
a Level III detainee in a holding cell with a Level I detainee. Both situations were immediately
brought to the attention of facility management and ERO staff, and necessary actions were taken
to separate the detainees. To ensure detainee safety, it is critical Level I and Level III detainees
are separated at all times. Commingling detainees with violent criminal histories and detainees
with non-violent criminal histories could result in a life-safety issue.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY CS-1
In accordance with ICE PBNDS, Classification System, section (V)(F)(3), the FOD must ensure
Level 3 detainees may not be co-mingled with Level 1 detainees.

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