The recent announcement of Dr. Schriro's departure from the newly created office of DHS Office of Detention Policy and Planning should concern all stakeholders and organizations in the area of immigration detention. DHS-ICE has expressly stated that the purpose of the office is to "plan and design a civil detention system tailored to ICE's needs." The Smart and Tough Enforcement of Immigration Laws Backgrounder expressly elaborate's DHS-ICE's goals to include ensuring that "those individuals pending removal or adjudication of their case shall be provided a safe environment in compliance with detention standards that is respectful of civil rights and civil liberties." The idea: DHS-ICE should deploy existing constitutional and human rights standards to ensure an effective transformation to a "truly civil" model for immigrant detention, and guide the activities of the new responsibilities and offices created as part of the reforms (ODPP, ODO and DRO).
At a minimum, should include the following (each of these suggestions is linked to a human right standard that the US has endorsed via treaty):
-Ensure that detention is done in accordance with law and is not arbitrary (see International Covenant on Civil and Political Rights, Article 9).
-Ensure that detainees are treated with respect for the inherent dignity of the human person (see International Covenant on Civil and Political rights, Article 10(1))
-End the practice of racial discrimination by ensuring that the letter of the Convention Against Racial Discimination's General Comment 30 (on Discrimination Against Non-Citizens) is followed.
-Standardize processes for the parole of asylum seekers who have passed credible fear interviews, and carefully evaluate the claims of any immigrant detainee who expresses fear of return. (Convention Against Torture and Refugee Convention).
Some concrete ways to promote these goals:
1. Facilities that should never rely on local manuals in mixed facilities (ones that house both criminal and civil immigration detainees) that do not comply or reflect the basic DHS detention center requirements. Such guides not only confuse detainees, but they directly contradict the idea of a civil detention process because they may provide inaccurate information regarding options for bond and reinforce the idea that their civil detention is analogous or similar to the detention of criminal detainees.
2. Respecting the inherent dignity of the person encompasses many issues including: a) the need to implement procedures that will promote an awareness of the standards and the rights of detainees from the moment they arrive at any particular facility. All facilities should have orientations that explain the nature of their detention, explain their rights while they are detained, provide a clear and detailed explanation of grievance procedures, immediately upon entry. b) provide more oversight for decisions regarding the provision of medical care and basic toiletries and necessities to immigrant detainees. c) examine the irony and reform the work system in place in immigrant detention facilities - it is not clear that the practice of paying immigrant detainee $1/day in a country that does not recognize their right to work for any form of labor is appropriate.
3. provide uniform standards across jurisdictions regarding how decisions regarding the parole of asylum seekers are made. While currently this is an area that lies in the discretion of District Directors, the deprivation of liberty should be justified and fully explained and done so in a uniform manner across jurisdictions - especially since all District Directors are to apply 8 CFR212.5(b) and show urgent humanitarian reasons or significant public benefit to the release. All should have to explain the basis of their decision in detail.
4. Provide more oversight and clarify the roles of responsibilities of deportation officers at all stages of the deportation process. All deportation officers should be required to update each of their clients in a predictable and regular manner and should be required to effectively communicate with detainees in a language that a detainee can understand or have access to language lines of other tools to facilitate communication. Other detainees should not be relied upon as translators given the importance of having the detainee fully understand the implications of cooperating/not cooperating with DOs at every stage of the deportation process. DHS should formally adopt a position on the responsibility of contractors with IGSAs to provide translators during the grievance process - especially since the DHS standards encourage that the initial stage of the grievance be informal and oral. Further DHS should formally adopt a policy regarding Title VI and language interpreters.
5. Provide better protections for the right of family association. No family member should have to fear visitations to a DHS facility; there are already enough barriers facing family members that wish to visit facilities and/or establish minimum contact with a relative who is detained. At a minimum, the practice of asking general visitors to state their immigration status should be ended, and detainees should have the ability to place free calls to loved ones and to attorneys. This will also ensure that any facility loses any incentive to prolong unnecessarily the detention of any individual seeking to be reunited with their family.
6. End the practice of locating detention centers in remote areas. While related to the comment above on family rights, this practice also directly impacts the right and ability of immigrant detainees to seek and obtain counsel for immigration matters and to address civil liberties violations (such as indefinite/prolonged/unlawful detention).
This final comment is not based on human rights standards: save costs to the American taxpayer by aggressively pursuing alternatives to detention and supervised release options. Where the detention may cost $95/day and many alternatives to release only cost $12/day, these suggestions are mere common sense.
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Why the contribution is important
This is important because the transformation of immigrant detention from a patchwork of contract facilities (many of which are mixed facilities that engage in the detention of civil immigrant detention and the detention of criminals) lies at the heart of the proposed immigrant detention reforms to reform detention to make it reflect a civil, not criminal, form of detention. Given the current patchwork of facilities that detain immgrants in the US, and the existence of human rights treaties that directly address aspects of immigration detention, this idea seeks to serve as a means to suggest how many of the deep constitutional and human rights commitments already adhered to by the United States can serve to inform the reform of the practice of immigration detention.
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