Introduction
Subjecting people to torture is a human rights violation to their right for a life with dignity.[1] International organizations and several sovereign nations advocate against the use of torture for any reason.[2] Article 5 of the UDHR holds that no person shall be subjected to torture.[3] Under international law, a person’s right not to be tortured is absolute and mustn’t be restricted in any way.[4] Torture is the act of purposefully causing severe physical or mental suffering to another person.[5] People engage in methods of torture “as a means of punishment, coercion, and/or to obtain information.”[6] As an absolute right, no means can justify the mistreatment of a person via torture to achieve a political or law enforcement objective.[7]
The Universal Declaration of Human Rights (UDHR) is a document that calls for “fundamental human rights to be universally protected.”[8] The UDHR was created after World War II with the purpose of setting a road map for human rights, freedom, and notions of equality, to which the international community could be in agreement.[9]
Members of the international community, including the United States, adopted the International Covenant on Civil and Political Rights (ICCPR), which concurrently states that no person shall be tortured.[10] The U.S. is obligated to submit a periodic report to the ICCPR committee every four years.[11] The U.S. reports “on the implementation of the rights and obligations enshrined” in the ICCPR.[12] Once the report is submitted, the ICCPR may issue conclusive recommendations that are not legally binding, but nevertheless “place an important moral obligation on the U.S. government” to comply.[13] Therefore, if a state commits an ICCPR violation, the state must rely on the conclusive recommendations “for immediate implementation within one year.”[14] Also, a Special Rapporteur is “appointed for follow-up to concluding observations, and will produce a follow-up progress report” for the ICCPR.[15]
In efforts to address the various interpretations of torture that would allow some nations to continue pursuing such particular methods, the United Nations (UN) established the Convention Against Torture Protocol (CAT) in 1984, which began its implementation in 1987.[16] CAT does not exempt any recourse justification for committing torture and, therefore, prohibits orders from public authority to be used as justifications for torture.[17] The United States’ stance on torture is similar to what the international community abides by prohibiting “torture committed by public officials […] against persons within the public official’s custody or control.”[18] The U.S. signed the CAT protocol in 1988 with reservations.[19] Thus, the U.S. adopted CAT with the reservation that its Articles were “not self-executing, and therefore required domestic implementing legislation.”[20] This condition made CAT “not directly enforceable in U.S. courts, and Congress generally must pass legislation implementing the provision in a domestic statute to make it judicially enforceable.”[21]
However, non-governmental organizations such as Freedom For Immigrants have recently reported that, as of February 2023, undocumented immigrants are tortured by the Office of Immigration and Customs Enforcement (ICE) officials during transfers to distinct detention centers.[22] Unique instances of immigrants’ experiences have been reported about being shackled, beaten, and indefinitely detained throughout their transfer process to different detention centers.[23] Such experiences shed light on how the U.S. abides by prohibiting torture on paper when, in reality, immigration detention centers are being accused of ongoing abuse and torture.[24] Detention centers with notable claims about torture and abuse stem from California’s Otay Mesa Detention Center, Georgia’s Stewart Detention Center, and New Mexico’s Torrance County Detention Facility.[25]
This blog addresses the United States’ ongoing human rights violation of illegal torture against detained immigrants who are under the care of ICE. It examines this agency’s contemporaneous reliance on third-party contractors such as CoreCivic, while immigrants await deportation or have their case heard in court.
Background
1. System of Detention Centers in the United States.
The U.S. Department of Homeland Security (DHS) oversees ICE, which handles the detention of immigrants who are awaiting deportation or having their immigration case in court.[26] In or around 1988, Congress imposed mandatory detention of noncitizens to prevent their failure to appear at their deportation hearings.[27] Over “two-thirds of the immigrant detainee population [is] held in private detention centers and state and county jails.”[28] In terms of funding, the government pays private contractors to hold immigrants.[29] For instance, in 2012, “ICE was paying private companies $5.1 billion to hold more than 23,000” immigrants in detention facilities.[30] Placing detainees under the care of third-party contractors prevents ICE from directly monitoring “human rights abuses and compliance with US law and policy.”[31] ICE’s number of detentions is influenced by their local quotas, which is a pre-established amount of detentions to fill the facilities’ beds that the agency already has to pay according to its agreements with third-party contractors.[32] This system ensures a profit to private contractors and an incentive for ICE not to cease detentions and, instead, maximize their budget expenditure via taxpayer dollars.[33] The Otay Mesa County Detention Center and Torrance County Detention Facility in California and New Mexico respectively, are 2 of the 350 facilities under ICE’s supervision in the country.[34]
2. New Mexico’s Torrance County Detention Facility
Torrance County Detention Facility (Torrance) is located in Estancia, New Mexico, and detains “people on behalf of both [ICE] and the U.S. Marshals Service [via] CoreCivic, one of the largest for-profit prison companies in the country.”[35] CoreCivic is known by Non-governmental organizations like the ACLU for its safety disregard and retaliation methods whenever detainees object to unsafe conditions such as using pepper spray on protesters indoors.[36] Torrance stands out for its torturous conditions, which have prompted detainees to commit suicide.[37] CoreCivic “currently receives nearly $2 million a month from ICE […] based on the facility’s guaranteed minimum of 505 detained people, though Torrance only had six people in custody at the end of 2022.”[38] Instances of torture and abuse have not deterred contractors like CoreCivic from profiting off individuals who lack the socioeconomic and legal resources to speak up.[39]
3. California’s Otay Mesa County Detention Center
The Otay Mesa County Detention Center (Otay) is located in San Diego, California, and has relied on CoreCivic to manage the facility since 2015.[40] Detainees at Otay have stated how the facility is kept at intensely cold temperatures, causing pain in their bones; there have been inmate deaths and miscarriages because of the poor conditions.[41] Meanwhile, ICE pays “CoreCivic approximately $2.8 million per month to rent bed space.”[42] The population of detainees was “up to 810 as of early January” of 2022.[43] Therefore, an amount exceeding $3,400 has been spent on each person detained at the facility per month, where some have been there for extensively longer periods.[44] Otay reflects the systemic problem in our immigration system by caging immigrants via taxpayer dollars tending to a successful business scheme for private contractors like CoreCivic but a life disruption to immigrants cut away from their families as they await a resolution of their deportation proceedings.
Discussion
1. Past experiences of death and torture
a. Anastasio Hernández Rojas (2010)
Anastasio Hernádez Rojas’ death demystified the claims of abuse and torture that immigrants suffer at the hands of U.S. agents.[45] Anastasio was tortured and killed at the hands of Customs and Border Protection (CBP) and ICE agents.[46] Video footage shows Anastasio lying on the ground, handcuffed, surrounded by over ten agents, being tased and beaten.[47] As a result, he suffered “a heart attack that deprived his brain of oxygen and resulted in brain death.”[48] His autopsy report declared that he suffered “bruises and abrasion on his face and body, five broken ribs, and bleeding into internal organs and neck muscles.”[49] Nonetheless, his death was ruled a homicide.[50] In 2015, the U.S. Department of Justice (DOJ) announced that the government would not “pursue federal criminal civil rights or other federal charges against the federal agents involved.”[51] The DOJ’s independent investigation concluded that Anastasio was creating a struggle by “grappling” and “kicking” the agents, and the proximate cause of his death was his methamphetamine intoxication.[52] Despite international attention, there has been no accountability against the U.S. agents involved in this incident.[53] His death was a result of an evident human rights violation.[54] No immigration status can justify the treatment he received from public officials.[55] Anastasio was dehumanized and tortured.[56] His experience is a shameful illustration of the U.S. immigration system.
b. Rolando (2019)
Rolando’s case was far from humane treatment.[57] He was a Guatemalan asylum seeker who survived a gunshot wound to the head but was suffering headaches and sporadic bleeding.[58] After requesting asylum at the San Ysidro border, Rolando was taken to “solitary confinement and [was jailed] […] for months at the Otay Mesa detention center.”[59] There, he scarcely got any medical attention, and was often “bleeding from his eyes, ears and nose […] [and] he would lose consciousness.”[60] Otay managed to offer him “only ibuprofen to treat the immense pain caused by the gunshot wound.”[61] According to ICE’s medical records, Otay’s ER doctor believed that Rolando could have had a brain hemorrhage as a result of the gunshot wound.[62] Rolando migrated from Guatemala after his father was killed for being a member of the pro-indigenous movement, which led to his gunshot wound as a death threat.[63] The Guatemalan police did not help Rolando and, in fear, he sought to migrate to the U.S.[64] Rolando’s experience was torturous and should not be the treatment that asylum seekers receive when they are already escaping from a violent environment with no protections.[65]
c. Erik Mercado (2023)
Erik Mercado is a very recent example of an immigrant detained by ICE and placed under the care of a CoreCivic in March 2021.[66] He claimed to have been tortured by agents as retaliation for denouncing the inhuman conditions of the facilities.[67] Mercado claimed that ICE retaliated against him for almost two years by (1) being in solitary confinement, (2) suffering medical neglect, and (3) transferred by plane to a different center, which is deemed as a retaliatory punishment because it isolates the detainee from his network within the facility and their families.[68] Mercado’s transfer process raises serious questions since he traveled to a different facility with shackles on his waist and legs without access to a restroom.[69] He suffered a ‘circular transfer’ meaning he was transferred several times between the same number of facilities under conditions that “could amount to torture.”[70] Mercado has been detained and circularly transferred from Otay to Nevada for over three years.[71] On August 11, 2023, U.S. District Court Judge Cristina D. Silva partially granted Mercado’s Petition for Writ of Habeas Corpus, ordering ICE to schedule a bond hearing within 21 days of her Order, or Mercado will be released.[72] Mercado was able to take a further step in his deportation proceedings after being detained for nearly three years in various facilities.[73] He was confined as a prisoner and silenced for speaking up on behalf of himself and his fellow detainees.[74] His case is one of the many lives that have been confined at the hands of private contractors such as CoreCivic.
2. Backlogged Courts Benefit Industrial Detention Complex Centers
Deportation proceedings are currently delayed because the immigration courts must address the 1.3 million case backlog, increasing the average wait time to over four years to achieve a resolution.[75] For instance, Ohio’s number of pending immigration cases as of the fiscal year 2023 is at a record high of 22,322.[76] On one hand, immigrants are detained indefinitely until their deportation proceedings culminate.[77] Alternatively, having the judiciary in pursuit of catching up with this backlog may not provide immigrants with the utmost fairness and impartiality if the judges’ main goal is to eliminate the backlog.[78] The goal may be “just finishing a certain number of digits per day” and meeting the daily quota of pending cases.[79] The Biden administration has hired over 200 immigration judges to increase the courts’ efficiency by resolving more cases annually.[80] The above fails to suggest a solution to the indefinite detention of immigrants under the presumed care of ICE and CoreCivic.[81] On the contrary, the government’s stance remains a matter of numbers.[82] The federal government argues that undocumented individuals, or non-citizens, are not protected under the Constitution and “are entitled only to those rights expressly provided by statute.”[83] Therefore, their indefinite detention absent a court hearing is not a constitutional law violation.[84] However, torture claims arise during their detention period.[85] The Biden administration should (1) increase the number of judges sitting in ongoing immigration cases and (2) increase the quality of the immigration system by deprivatizing detention centers to humanize the proceedings as a least prison-like structure.
Conclusion
Privatization of the detention centers dehumanizes immigrant folks. Their presence becomes a quota, and their advocacy becomes a restraint to ICE and private contractors like CoreCivic to handle them how they best see fit.[86] Removal proceedings do not have fixed timelines for immigrants to have their cases heard in front of a judge, which gives ICE and DHS enough leeway to detain them indefinitely.[87] What was once a method to ascertain a migrant’s presence in the courtroom has become a method of torture and abuse in their search for a better life.[88] No agents have been held accountable for the death of Anastasio, nor have ICE and CoreCivics taken responsibility for Rolando’s excruciating suffering while having a potential brain hemorrhage.[89] Circular transfers and retaliatory torture by government contractors reflect a poor adherence to the international and domestic laws that the U.S. has abided to follow.[90] The U.S. must cease using third-party contractors who profit from government contracts. So long as immigrants continue to be detained and confined in unsafe environments under DHS’ awareness, the U.S. is violating the human rights of these immigrants not to be tortured. Their immigrant status should not deem them less worthy of life, dignity, and respect.
[1] Equality and Human Rights Commission, Article 3: Freedom from torture and inhuman or degrading treatment, Sept. 20, 2023, https://www.equalityhumanrights.com/en/human-rights-act/article-3-freedom-torture-and-inhuman
-or-degrading-treatment, (last visited Sept. 13, 2023).
[2] Rebecca Evans, The Ethics of Torture: Definitions, History, and Institutions, INTERNATIONAL STUDIES ASSOCIATION AND OXFORD UNIVERSITY PRESS, (Jan. 30, 2020), https://oxfordre.com/internationalstudies /display/10.1093/acrefore/9780190846626.001.0001/acrefore-9780190846626-e-326 (last visited Sept. 29, 2023).
[3] Universal Declaration of Human Rights, United Nations, https://www.un.org/en/about-us/universal-declaration-of-human-rights, (last visited Sept. 12, 2023).
[4] The Human Rights Fact Sheet, Office of the United Nations High Commissioner for Human Rights, (May 2002), at 3, https://www.ohchr.org/sites/default/files/Documents/Publications/FactSheet4rev.1en.pdf (last visited Oct. 11, 2023).
[5] Equality and Human Rights Commission, supra note 1.
[6] Shannon C. Houck & Meredith A. Repke, When and why we torture: A review of psychology research, 3 Translational Issues in Psychological Science 272, 273 (2017).
[7] Equality and Human Rights Commission, supra note 1.
[8] UNITED NATIONS HUMAN RIGHTS, https://www.ohchr.org/en/universal-declaration-of-human-rights (last visited Sept. 12, 2023).
[9] What is the Universal Declaration of Human Rights and Why Was it Created?, Amnesty International, https://www.amnesty.org/en/what-we-do/universal-declaration-of-human-rights/ (last visited Sept. 29, 2023).
[10] General Assembly Resolution 2200A (XXI): International Covenant on Civil and Political Rights, United Nations Human Rights, Article 7, https://www.ohchr.org/en/instruments-mechanisms/instruments/international-covenant-civil-and-political-rights#:~:text=the%20present%20Covenant.-,Article%207,to%20medical%20or%20scientific%20experimentation., (last visited Oct. 11, 2023).
[11] FAQ: The Covenant on Civil & Political Rights (ICCPR), American Civil Liberties Union, (July 11, 2013), https://www.aclu.org/documents/faq-covenant-civil-political-rights-iccpr#:~:text=Countries%20that%20have%20ratified%20the%20ICCPR%20are%20obliged%20to%20report,and%20is%20usually%20live%20streamed (last visited Sept. 30, 2023).
[12] Fifth Periodic Report by the United States of America Under the International Covenant on Civil and Political Rights, U.S. Department of State, https://www.state.gov/fifth-periodic-report-by-the-united-states-of-america-under-the-international-covenant-on-civil-and-political-rights/ (last visited Sept. 30, 2023).
[13] American Civil Liberties Union, supra note 11.
[14] Human Rights Committee, INTERNATIONAL JUSTICE RESOURCE CENTER, https://ijrcenter.org/un-treaty- bodies/human-rights-committee/#State_Reporting (last visited Sept. 30, 2023).
[15] Id.
[16] United Nations Treaty Collection, 9. Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, United Nations Treaty Collection Depositary (1984), https://treaties.un.org/Pages/ViewDetails.aspx?src=TREATY&mtdsg_no=IV-9&chapter=4&clang=_en (last visited Sept. 12, 2023).
[17] Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, United Nations, Dec. 10, 1984, at 2, https://treaties.un.org/doc/Treaties/1987/06/19870626%2002-38%20AM/Ch_IV_9p.pdf (last visited Sept. 29, 2023).
[18] 20. Torture (18 U.S.C. 2340A), U.S. Department of Justice Archives, https://www.justice.gov/archives/jm/criminal-resource-manual-20-torture-18-usc-2340a (last visited Sept. 12, 2023).
[19] Michael J. Garcia, The U.N. Convention Against Torture: Overview of U.S. Implementation Policy Concerning the Removal of Aliens, CRC Report for Congress, CRS-4, (2006) https://trac.syr.edu/immigration/library/P1339.pdf (last visited Sept. 12, 2023).
[20] Id.
[21] ArtII.S2.C2.1.4 Self-Executing and Non-Self-Executing Treaties, Cornell Law School, https://www.law.cornell.edu/constitution-conan/article-2/section-2/clause-2/self-executing-and-non-self-executing-treaties (last visited Sept. 30, 2023).
[22] ‘Trafficked & Tortured’: Scale of ICE Detention Transfer Operations Mapped in New Report, FREEDOM FOR IMMIGRANTS, (Feb. 16, 2023), https://www.freedomforimmigrants.org/news/trafficked-and-tortured-press-release (last visited Sept. 12, 2023).
[23] Trafficked & Tortured: Mapping ICE Transfers, Freedom for Immigrants, (2022), at 30-31, https://static1.squarespace.com/static/5a33042eb078691c386e7bce/t/63ed9236ee82156a4608eba2/1676513859587/FInal+Report_FFI_T%26T_021523.pdf (last visited Sept 12, 2023).
[24] Spencer Woodman, Lawsuit Alleges ‘Brutal Conditions’ in US Immigration Detention Centers, ICIJ, (Aug. 27, 2019), https://www.icij.org/investigations/solitary-voices/lawsuit-alleges-brutal-conditions-in-us-immig ration-detention-centers/ (last visited Sept. 13, 2023).
[25] Maurizio Guerrero, Torture with impunity runs rampant in ICE facilities, PRISM, (June 15, 2023), https://prismreports.org/2023/06/15/torture-rampant-ice-facilities/ (last visited Sept. 13, 2023).
[26] Fact Sheet: Immigration Detention in the United States, NATIONAL IMMIGRATION FORUM, https://immigrationforum.org/article/fact-sheet-immigration-detention-in-the-united-states/ (last visited Sept. 13, 2023).
[27] Carolina Rizzo, Catch and Detain: The Detention Bed Quota and the United States’ Overreliance on Detention as a Tool for the Enforcement of Immigration Laws, 27 Harvard Journal of Hispanic Policy 39, 40-41, 44. (2014/2015).
[28] Id. at 44.
[29] Id. at 42.
[30] Id. at 45.
[31] Id.
[32] Detention Quotas, Detention Watch Network, https://www.detentionwatchnetwork.org/issues/detention-quotas#:~:text=Local%20quotas%2C%20referred%20to%20as%20guaranteed%20minimums%20in,many%20people%20are%20detained%20to%20fill%20these%20beds (last visited Sept. 13, 2023).
[33] Id.
[34] NATIONAL IMMIGRATION FORUM, supra note 26.
[35] Leonardo Castañeda, ‘They Treat Us Like We’re Animals:’ Inside Torrance County’s Troubled Detention Center, ACLU of New Mexico, (Aug. 8, 2022), https://www.aclu-nm.org/en/news/they-treat-us-were-animals-inside-torrance-countys-troubled-detention-center (last visited Sept. 13, 2023).
[36] Id.
[37] Death of Brazilian Migrant in ICE Custody Predictable and Preventable Result of ICE and CoreCivic Abuse, Neglect and Dangerous Conditions at Torrance County Detention Facility, Innovation law Lab, (Aug. 27, 2022), https://innovationlawlab.org/press-releases/death-of-brazilian-in-torrance/ (last visited Sept. 1, 2023).
[38] Guerrero, supra note 25.
[39] Castañeda, supra note 35.
[40] CoreCivic, Otay Mesa Detention Center, https://www.corecivic.com/facilities/otay-mesa-detention-center (last visited Sept. 14, 2023).
[41] Kate Swanson, Silent Killing: The Inhumanity of U.S. Immigration Detention, 18 Journal of Latin American Geography 176, 177 (2019).
[42] Id. at 184.
[43] Sofía Mejías-Pascoe, COVID Cases Among Migrants at Otay Mesa Facility Soar to Highest Level Yet, TIMES of San Diego, (Jan. 19, 2022), https://timesofsandiego.com/politics/2022/01/19/covid-19-cases-at-otay-mesa-detention- center-soar-to-highest-count-yet-amid-outbreaks-in-other-border-detention-facilities/ (last visited Oct. 1, 2023).
[44] Id.
[45] Kate Morrissey, International tribunal takes case for border death lawsuit, The San Diego Union-Tribune, (May 18, 2017), https://www.sandiegouniontribune.com/news/immigration/sd-me-hernandez-rojas-20170518-story.html (last visited Oct. 11, 2023).
[46] Id.
[47] Id.
[48] Christina Jo Pérez, Performing the State’s Desire: The Border Industrial Complex and the Murder of Anastasio Hernández Rojas, 43 Frontiers: A Journal of Women Studies 93, 95 (2022).
[49] Alliance San Diego, 12 Years in Search of Justice for Anastasio Hernández Rojas, (Feb. 4, 2021), https://www.alliancesd.org/the_anastasio_hernandez_rojas_case_timeline (last visited Sept. 1, 2023).
[50] Id.
[51] Federal Officials Close the Investigation into the Death of Anastasio Hernandez-Rojas, U.S. Department of Justice Office of Public Affairs, (Nov. 6, 2015), https://www.justice.gov/opa/pr/federal-officials-close-investigation-death-anastasio-hernandez-rojas (last visited Sept. 1, 2023).
[52] Id.
[53] Id.
[54] Morrissey, supra note 45.
[55] Office of the United Nations High Commissioner for Human Rights, supra note 4 at 3.
[56] Jo Pérez, supra note 48 at 95.
[57] Sam Levin, This asylum seeker was shot in the head. ICE jailed him and gave him ibuprofen, The Guardian, (Oct. 9, 2019), https://www.theguardian.com/us-news/2019/oct/08/us-immigration-ice-asylum-seeker-detention-rolando (last visited Sept. 1, 2023).
[58] Id.
[59] Id.
[60] Id.
[61] Nicole Einbinder, ICE reportedly gave an asylum-seeker at a detention center ibuprofen after he was shot in the head, INSIDER, (Oct. 10, 2019), https://www.insider.com/ice-asylum-seeker-ibuprofen-shot-head-detention-center- immigration-2019-10 (last visited Oct. 11, 2023).
[62] Id.
[63] Levin, supra note 57.
[64] Id.
[65] Einbinder, supra note 61.
[66] Erik Mercado & Ramon Dominguez Gonzalez, Opinion: Our fight for freedom is a fight for humanity, The San Diego Union-Tribune, (Oct. 17, 2022), https://www.sandiegouniontribune.com/opinion/commentary/story/2022-10-17/commentary-immigration-detention-freedom-fight (last visited Sept. 29, 2023).
[67] Guerrero, supra note 25.
[68] Id.
[69] Kate Morrissey, ICE detainees allege retaliation for speaking about medical conditions at Otay Mesa center, Los Angeles Times, (Mar. 4, 2023), https://www.latimes.com/california/story/2023-03-04/ice-detainees-allege-retaliation-after-speaking-out-about-medical-conditions-at-otay-mesa-detention-center (last visited Sept. 1, 2023).
[70] Id.
[71] Arechiga v. Archambeault & Bernacke, No. 2:23-cv-00600-CDS-VCF, ECF No. 23, at *1:10-11, (Casetext, D. Nev. 2023).
[72] Id.
[73] Id.
[74] Guerrero, supra note 25.
[75] AILA Doc. No. 21050334, Featured Issue: Immigration Court Backlog and Reprioritization, American Immigration Lawyers Association, (Aug. 18, 2023), https://www.aila.org/library/featured-issue-immigration-court-backlog (last visited Nov. 16, 2023).
[76] Historical Immigration Court Backlog Tool, TRAC Reports, Inc., (2023), https://trac.syr.edu/phptools /immigration/court_backlog/ (last visited Sept. 14, 2023).
[77] Madeleine Carlisle & Jasmine Aguilera, Supreme Court Rules Thousands of Immigrants Can Be Detained Indefinitely, TIME, (June 13, 2022), https://time.com/6187133/supreme-court-immigrants-bond-hearings/ (last visited Sept., 29, 2023).
[78] AILA Doc. No. 21021232, Policy Brief: Why President Biden Needs to Make Immediate Changes to Rehabilitate the Immigration Courts, (Feb. 12, 2021), https://www.aila.org/library/policy-brief-why-president-biden-needs-to-make (last visited Nov. 16, 2023).
[79] Zolan Kanno-Youngs, Backlogged Court and Years of Delays Await Many Migrants, The New York Times, (May 13, 2023), https://www.nytimes.com/2023/05/12/us/politics/immigration-courts-delays-migrants-title-42.html (last visited Nov. 16, 2023).
[80] Id.
[81] Freedom for Immigrants, supra note 23 at 30-31.
[82] Detention Watch Network, supra note 32.
[83] No. 2:23-cv-00600-CDS-VCF, supra note 71 at 1:17-19.
[84] Id.
[85] Freedom for Immigrants, supra note 23 at 30-31.
[86] Guerrero, supra note 25.
[87] Madeleine Carlisle & Jasmine Aguilera, supra note 77.
[88] Rizzo, supra note 27 at 41.
[89] U.S. Department of Justice Office of Public Affairs, supra note 51.
[90] American Civil Liberties Union, supra note 11.
