U.S. Department of Homeland Security

Immigration and Customs Enforcement
Office of Professional Responsibility
Inspections and Detention Oversight Division
Washington, DC 20536-5501

Office of Detention Oversight
Compliance Inspection

Enforcement and Removal Operations
ERO Chicago Field Office
Monroe County Detention Dormitory
Monroe, Michigan

May 5–7, 2015

COMPLIANCE INSPECTION
for the
MONROE COUNTY DETENTION DORMITORY
MONROE, MICHIGAN
TABLE OF CONTENTS
EXECUTIVE SUMMARY
Overall Findings...................................................................................................................2
Findings by National Detention Standards (NDS) 2000 Major Categories .........................3
INSPECTION PROCESS .............................................................................................................4
DETAINEE RELATIONS ............................................................................................................5
INSPECTION FINDINGS
DETAINEE SERVICES
Detainee Classification System............................................................................................6
Detainee Grievance Procedures ...........................................................................................6
Food Service ........................................................................................................................6
Funds and Personal Property ...............................................................................................7
Staff-Detainee Communication ...........................................................................................7
SECURITY AND CONTROL
Use of Force .........................................................................................................................7

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INSPECTION TEAM MEMBERS

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

Office of Detention Oversight
May 2015
OPR 201505510

ODO
Lead Inspections and Compliance Specialist
Inspections and Compliance Specialist
ODO
Contractor
Creative Corrections
Creative Corrections
Contractor
Contractor
Creative Corrections
Contractor
Creative Corrections
Contractor
Creative Corrections

1

Monroe County Detention Dormitory
ERO Detroit

EXECUTIVE SUMMARY
The Office of Detention Oversight (ODO) conducted a compliance inspection of the Monroe
County Detention Dormitory (MCDD) in Monroe, Michigan, from May 5 to 7, 2015. 1 MCDD
opened in 2000 and is owned by Monroe County and operated by the Monroe County Sheriff’s
Office. Enforcement and Removal Operations (ERO) began housing detainees at MCDD in
2000 pursuant to an Intergovernmental Service Agreement (IGSA), under the oversight of
ERO’s Field Office Director (FOD) in Detroit, Michigan.
ERO staff members are assigned to
Capacity and Population Statistics
Quantity
the facility, and a Detention Services
Manager is assigned to the facility on ICE Detainee Bed Capacity 2
80
a part-time basis. An MCDD Major Average ICE Detainee Population 3
51
is responsible for oversight of daily Male Detainee Population (as of 05/05/2015)
39
facility operations and is supported
Female Detainee Population (as of 05/05/15)
0
by (b)(7)e personnel.
MCDD staff
provides food services and Advanced Correctional Healthcare provides medical services. The
facility holds no accreditation. The facility is not contractually obligated to comply with the ICE
Performance-Based National Detention Standards 2011, Sexual Abuse and Assault Prevention
and Intervention (SAAPI) standard but made efforts to comply. 4

OVERALL FINDINGS
In February 2011, ODO conducted
an inspection of MCDD under the
National
Detention
Standards
(NDS) 2000, reviewing the
facility’s compliance with 25
standards and finding the facility
compliant with nine standards.
There were a total of 54 deficiencies
in the remaining 16 standards.

Inspection Results
Compared

FY 2011
(NDS 2000)

FY2015
(NDS 2000)

Standards Reviewed

25

15

Deficient Standards
Overall Number of
Deficiencies
Deficient Priority
Components

16

6

54

9

N/A

N/A

0

1

Corrective Action

In FY2015, ODO evaluated MCDD’s compliance with the NDS 2000, reviewing the facility’s
compliance with 15 standards and finding the facility compliant with nine standards. ODO
found nine deficiencies in the remaining six standards. Finally, ODO identified one opportunity
where the facility initiated corrective action during the course of the inspection. 5

1

Male and female detainees of security classification level I through III are detained at the facility for periods in
excess of 72 hours.
2
Data Source: ERO Facility List Report as of May 4, 2015.
3
Ibid.
4
MCDD has a policy addressing Prison Rape Elimination Act (PREA) Compliance, J-101, dated December 1, 2013.
MCDD has a stated zero tolerance for incidence of rape, sexual assault or sexual misconduct.
5
Corrective actions, where immediately implemented, best practices and ODO recommendations, as applicable,
have been identified in the Inspection Findings section and annotated with a “C”, “BP” or “R”, respectively.

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May 2015
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Monroe County Detention Dormitory
ERO Detroit

FINDINGS BY NDS 2000 MAJOR CATEGORIES
NDS 2000 STANDARDS INSPECTED 6

DEFICIENCIES

Part 1 – Detainee Services
1. - Access to Legal Material
2. - Admission and Release
4. - Detainee Classification System
5. - Detainee Grievance Procedures
6. - Detainee Handbook
7. - Food Service
8. - Funds and Personal Property
15. - Staff-Detainee Communication
16. - Telephone Access
Sub-Total

0
0
2
1
0
3
1
1
0
8

Part 2 – Security and Control
7. - Environmental Health and Safety
13 - Special Management Unit (Administrative)
14. - Special Management Unit (Disciplinary)
17. - Use of Force
Sub-Total

0
0
0
1
1

Part 3 – Health Services
2. - Medical Care
3. - Suicide Prevention and Intervention
Sub-Total

0
0
0

Total Deficiencies

6

9

For greater detail on ODO’s findings, see the Inspection Findings section of this report.

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May 2015
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Monroe County Detention Dormitory
ERO Detroit

INSPECTION PROCESS
Every fiscal year, the Office of Detention Oversight (ODO), a unit within U.S. Immigration and
Customs Enforcement’s (ICE) Office of Professional Responsibility (OPR), conducts
compliance inspections at detention facilities in which detainees are accommodated for periods
in excess of 72 hours and with an average daily population greater than ten to determine
compliance with the applicable ICE National Detention Standards (NDS) 2000, the PerformanceBased National Detention Standards (PBNDS) 2008 or 2011.
During the compliance inspection, ODO reviews each facility’s compliance with those detention
standards that directly affect detainee health, safety, and/or well-being. 7 Any violation of written
policy specifically linked to ICE detention standards, other policies, or operational procedures
that ODO identifies is noted as a deficiency. ODO will highlight any deficiencies found
involving those standards that ICE has designated with either the PBNDS 2008 or 2011 to be
“priority components.” 8 ICE considers those components to be of critical importance, given
their impact on facility security and/or the health and safety, legal rights, and quality of life of
detainees in ICE custody.
Immediately following an inspection, ODO hosts a closeout briefing in person with both facility
and ERO field office management to discuss their preliminary findings, which are summarized
and provided to ERO in a preliminary findings report. Thereafter, ODO provides ERO with a
final compliance inspection report to: (i) assist ERO in working with the facility to develop a
corrective action plan to resolve identified deficiencies; and (ii) provide senior ICE and ERO
leadership with an independent assessment of the overall state of ICE detention facilities. The
reports enable senior agency leadership to make decisions on the most appropriate actions for
individual detention facilities nationwide.

7
8

ODO reviews the facility’s compliance with selected standards in their entirety.
Priority components have not been identified for the NDS 2000.

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May 2015
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Monroe County Detention Dormitory
ERO Detroit

DETAINEE RELATIONS
ODO interviewed 25 detainees, who volunteered to participate. None of the detainees made
allegations of mistreatment, abuse, or discrimination. The majority of detainees reported being
satisfied with facility services, with the exception of the complaints below:
•

Food Service: Eight detainees alleged the food portions were small.
o

•

Action Taken: Food service staff notified ODO that the facility’s menus are
certified by a registered dietician and prepared in accordance with the standard.
ODO observed a lunch meal and found the food portions to be in accordance with
the menu.

Medical Care: Two detainees alleged they had issues with medical care. One detainee
alleged he is diabetic, and there were too many carbohydrates in his special diet tray.
One detainee inquired about having a tooth extracted.
o

Action Taken: The facility medical staff reviewed the medical file of the detainee
alleging there are too many carbohydrates in his special diet tray and coordinated
with the facility food service to have the detainee placed on an American Diabetic
Association approved diet before the completion of the inspection. ODO
reviewed the medical file of the detainee that inquired about having a tooth
extracted, and found he was scheduled for a follow-up appointment with the
medical staff about the tooth after the completion of the inspection. Facility
medical staff followed-up with the detainee during the inspection.

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May 2015
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Monroe County Detention Dormitory
ERO Detroit

INSPECTION FINDINGS
DETAINEE SERVICES
DETAINEE CLASSIFICATION SYSTEM (DCS)
ODO’s review of 20 randomly selected detention files and an interview with staff confirmed,
there is no supervisory review of the assigned classification level (Deficiency DCS-1 9).
ODO’s review of 20 randomly selected detention files found documentation of the detainees’
classification assignments were not included (Deficiency DCS-2 10). MCDD classification staff
stated the classification information is maintained in the facility computer system only.
DETAINEE GRIEVANCE PROCEDURES (DGP)
A review of the facility handbook reveals the handbook does not notify detainees of available
assistance in preparing a grievance, does not provide the policy prohibiting staff from retaliating
against detainees for filing grievances or provide the opportunity to file a complaint about officer
misconduct directly with the Justice Department (Deficiency DGP-1 11).
FOOD SERVICE (FS)
A review of the training curriculum found the training program for food service staff does not
cover the NDS (Deficiency FS-1 12).
ODO observed the carts containing food trays were not inspected before they were transported
out of the food service area and were not secured with locking devices (Deficiency FS-2 13).
Corrective Action: The facility initiated corrective action during the review by installing
locking devices on each cart (C-1).
9

“The first-line supervisor will review and approve each detainee's classification.” See ICE NDS 2000, Standard,
Detainee Classification System, Section (III)(A)(3).
10
“The officer will place all original paperwork relating to the detainee's assessment and classification in his/her Afile (right side), with a copy placed in the detention file.” See ICE NDS 2000, Standard, Detainee Classification
System, Section (III)(B).
11
“The grievance section of the detainee handbook will provide notice of the following: The procedures for filing a
grievance and appeal, including the availability of assistance in preparing a grievance. The policy prohibiting staff
from harassing, disciplining, punishing or otherwise retaliating against any detainee for filing a grievance. The
opportunity to file a complaint about officer misconduct directly with the Justice Department by calling 1-800-8694499 or by writing to: Department of Justice P.O. Box 27606 Washington, DC 20038-7606” See ICE NDS 2000,
Standard, Detainee Grievance Procedures, Section (III)(G)(2), (5) and (6).
12
“The facility training officer will devise and provide appropriate training to all food service personnel in detainee
custodial issues. Among other things, this training will cover INS’s detention standards.” See ICE NDS 2000,
Standard, Food Service, Section (III)(B)(1).
13
“Food will be delivered from one place to another in covered containers. These may be individual containers, such
as pots with lids, or larger conveyances that can move objects in bulk, such as enclosed, satellite-feeding carts. Food
carts must have locking devices. A member of the food service staff will oversee the loading of satellite-feeding
carts. Staff shall inspect and secure all food carts before allowing their removal from the food service area.” See
ICE NDS 2000, Standard, Food Service, Section (III)(C)(2)(g) and (i).

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Monroe County Detention Dormitory
ERO Detroit

ODO inspected the sack meals provided to detainees being transported. The meals contained
one cheese sandwich, a bag of potato chips, cookies, and a piece of fruit. The meals did not
contain a second sandwich with meat (Deficiency FS-3 14).
FUNDS AND PERSONAL PROPERTY (F&PP)
A review of the facility handbook reveals the handbook does not explain how to obtain personal
identity documentation, such as a copy of their passport, birth certificate, etc. (Deficiency
F&PP-1 15).
STAFF-DETAINEE COMMUNICATION (SDC)
A review of the facility handbook reveals the handbook does not state that the detainee has the
opportunity to submit written questions, requests, or concerns to ERO staff and the procedures
for doing so, including the availability of assistance in preparing the request (Deficiency SDC1 16).

SECURITY AND CONTROL
USE OF FORCE (UOF)
ODO interviewed staff and reviewed training files and determined the facility staff is not trained
in the use-of-force team technique (Deficiency UOF-1 17).

14

“Each sack shall contain at least two sandwiches per meal, of which at least one will be meat (non-pork).” See
ICE NDS 2000, Standard, Food Service, Section (III)(G)(6)(c).
15
“The detainee handbook or equivalent shall notify the detainees of facility policies and procedures concerning
personal property, including: That, upon request, they will be provided an INS-certified copy of any identity
document (passport, birth certificate, etc.) placed in their A-files.” See ICE NDS 2000, Standard, Funds and
Personal Property, Section (III)(J)(2).
16
“The handbook shall state that the detainee has the opportunity to submit written questions, requests, or concerns
to ICE staff and the procedures for doing so, including the availability of assistance in preparing the request.” See
ICE NDS 2000, Standard, Staff-Detainee Communication, Section (III)(B)(3).
17
“Staff shall be trained in the use-of-force team technique in sufficient numbers for teams to be quickly convened
on all shifts in different locations throughout the facility.” See ICE NDS 2000, Standard, Use of Force, Section
(III)(A)(4)(b).

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May 2015
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Monroe County Detention Dormitory
ERO Detroit