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
Detroit Field Office
Calhoun County Correctional Facility
Battle Creek, Michigan

December 6 - 8, 2011

FOR INTERNAL USE ONLY. This document may contain sensitive commercial, financial, law
enforcement, management, and employee information. It has been written for the express use of the
Department of Homeland Security to identify and correct management and operational deficiencies. In
reference to ICE Policy 17006.1, issued 09/22/05; any disclosure, dissemination, or reproduction of this
document, or any segments thereof, is prohibited without the approval of the Assistant Director, Office of
Professional Responsibility.

COMPLIANCE INSPECTION
CALHOUN COUNTY CORRECTIONAL FACILITY
DETROIT FIELD OFFICE
TABLE OF CONTENTS
EXECUTIVE SUMMARY ...............................................................................................1
INSPECTION PROCESS
Report Organization.................................................................................................4
Inspection Team Members.......................................................................................4
OPERATIONAL ENVIRONMENT
Internal Relations .....................................................................................................5
Detainee Relations ...................................................................................................5
ICE NATIONAL DETENTION STANDARDS
Detention Standards Reviewed ................................................................................6
Access to Legal Material .........................................................................................7
Admission and Release ............................................................................................8
Detainee Classification System..............................................................................10
Detainee Grievance Procedures ............................................................................11
Detainee Handbook................................................................................................13
Food Service ..........................................................................................................14
Funds and Personal Property .................................................................................16
Staff Detainee Communication .............................................................................17
Use of Force...........................................................................................................19

EXECUTIVE SUMMARY
The Office of Professional Responsibility (OPR), Office of Detention Oversight (ODO) conducted
a Compliance Inspection (CI) of the Calhoun County Correctional Facility (CCCF), Battle Creek,
Michigan, from December 6 to 8, 2011. The facility is owned by Calhoun County and operated by
the Calhoun County Sheriff’s Office, Battle Creek, Michigan. CCCF accommodates ICE
detainees of all classification levels for periods in excess of 72 hours via a Detention Services
Intergovernmental Agreement with the USMS. The facility opened in 1994, and was awarded a
contract in 1999 to house Immigration and Naturalization Service (INS) detainees. The total
number of staff (non-ICE) employed at CCCF is 101. The total inmate capacity is 630, and the
total capacity for ICE detainees is 275. At the time of the inspection, CCCF housed 150 detainees
(140 males and 10 females). All other bed space at CCCF is reserved for the U.S. Marshals
Service and county or municipal inmates. Medical care is provided by Corizon and food service is
provided by Aramark Correctional Services. In March 2010, CCCF received accreditation from
the National Commission on Correctional Health Care.
CCCF compliance with ICE policies and the ICE National Detention Standards (NDS) is the
responsibility of the Office of Enforcement and Removal Operations (ERO) Field Office Director,
Detroit, MI (FOD/Detroit). An Assistant Field Office Director (AFOD) located at the Detroit
Field Office has direct oversight of CCCF. ICE does not have staff permanently assigned to the
facility. A Deportation Officer (DO) and an Immigration Enforcement Agent (IEA) from the
Detroit Field Office conduct scheduled and unscheduled detainee liaison visits to the facility to
address detainee concerns and inquiries. An ERO Detention Service Manager (DSM) conducts
two visits per month to monitor facility compliance with policies and standards.
ODO conducted a Quality Assurance Review (QAR) at CCCF in September 2009. ODO found 90
deficiencies in the following standards: Access to Legal Material, Detainee Grievance Procedures,
Detainee Handbook, Disciplinary Policy, Emergency Plans, Environmental Health and Safety,
Food Service, Funds and Personal Property, Hold Rooms in Detention Facilities, Issuance and
Exchange of Clothing, Bedding, and Towels, Key and Lock Control, Medical Care, Post Orders,
Security Inspections, Special Management Unit (Administrative and Disciplinary), Staff-Detainee
Communication, Terminal Illness, Advance Directives, and Death, Tool Control, and Use of
Force. In November 2010, ODO conducted a Follow-up Inspection at CCCF. ODO found the vast
majority of the identified deficiencies from the previous QAR were corrected; however, repeat
deficiencies were noted in the Food Service and Use of Force areas.
In January 2011, the ERO Detention Standards Compliance Unit (DSCU) contractors, MGT of
America, Inc., conducted an annual inspection of the ICE NDS at CCCF. The facility received an
overall rating of “Acceptable,” and was found to be in compliance with all 38 standards reviewed.
During this CI, ODO reviewed a total of 15 NDS. Five areas were found to be fully compliant: 22
deficiencies were found in the remaining 9 areas: Access to Legal Material (2 deficiencies),
Admission and Release (2), Detainee Grievance System (3), Detainee Handbook (1), Detainee
Classification System (2), Food Service (3), Funds and Personal Property (1), Staff Detainee
Communication (5), and Use of Force (3).
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This report includes descriptions of all the deficiencies and refers to the specific, relevant sections
of the ICE NDS. The report will be provided to ERO to assist in the development of corrective
actions to resolve the 22 identified deficiencies.
Overall, ODO found CCCF in compliance with the areas and standards inspected, including
Medical, Special Management Units and Telephone Access. A majority of the 22 deficiencies
identified were administrative in nature (paperwork, logs, postings, etc.), rather than shortcomings
with respect to practices and procedures. However, ODO identified some deficiencies that are
significant to the well-being and rights of ICE detainees. In particular, the lack of daily searches
for contraband in the food service area and the lack of a pre-employment medical examination for
the department’s supervisor are serious concerns. Additionally, CCCF is failing to maintain a log
of, or tracking system for, detainee grievances, and its staff is not provided with sufficient
guidance with regard to identifying and properly handling emergency grievance instances.
ODO evaluated CCCF’s compliance with the Staff-Detainee Communication standard to assess
communications between ERO, CCCF, and detainees. Generally, healthy and robust
communications among the facility staff, FOD personnel, and the detainee population promotes a
well-run detention environment. At CCCF, the absence of posted schedules for ERO staff visits,
the lack of a tracking system for detainee requests, and the inconsistency in the required 72-hour
response timeframe for detainee requests are all areas in need of immediate resolution.
CCCF does not have a designated area for use as a law library. In lieu of a dedicated law library,
the facility has two computers and a printer on a rolling cart available for use upon request.
Procedures for requesting access and additional time in the law library (beyond the five hours per
week minimum) is not available to detainees.
In the area of Food Service, CCCF is generally in compliance with the NDS; however, ODO found
the Aramark Cook Supervisor, employed at CCCF for more than 60 days, did not complete a preemployment medical examination. Pre-employment medical examinations serve the critical
purpose of ensuring food service workers have no communicable medical conditions. ODO
observed inmate workers being searched when leaving the food service area at the end of each
shift; however, they are not searched when they leave for visits, medical appointments, or other
activities.
CCCF does not videotape calculated use of force incidents with a handheld video camera with
audio capability, as required by the NDS. Additionally, the use of force team technique is not
being used by CCCF when a detainee is forcibly moved and/or restrained during a calculated use
of force. Both requirements are important components in the effort to ensure the well-being of
facility personnel, as well as the overall detainee population.
While ODO did not review the Environmental Health and Safety standard during this inspection,
ODO identified the fact that detainees are being charged for haircuts in the amount of ten dollars
each as an area of concern.

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ODO found the medical care at CCCF to be well-managed. CCCF has a fully functioning medical
unit to address detainee health care and a clinic that is adequately staffed to meet detainee health
needs. ODO verified intake screenings, physical examinations, medications, treatments for special
and chronic needs, and follow-up care are provided in accordance with the standard. Detainee sick
call requests are reviewed and triaged in a timely manner. ODO also verified medical transfer
summaries were included in all 14 of the records reviewed for detainees being transferred from
CCCF.
ICE detainees have access to television, outdoor recreation, local newspapers, mail, and
commissary purchases. CCCF also offers religious services, as well as vocational and educational
programs.
This report includes descriptions of all the deficiencies and refers to the specific, relevant NDS.
The report will be provided to ERO to develop corrective actions to resolve the 22 deficiencies.

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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 (NDS) or the ICE
Performance Based National Detention Standards (PBNDS), as applicable. The NDS apply to
CCCF. In addition, ODO may focus its inspection based on detention management information
provided by ERO Headquarters (HQ) and ERO field offices, and on issues of high priority or
interest to ICE executive management
ODO reviewed the processes employed at CCCF to determine compliance with current policies
and detention standards. Prior to and during the inspection, ODO collected and analyzed relevant
allegations and detainee information from multiple ICE databases, including the Joint Integrity
Case Management System (JICMS) and the ENFORCE Alien Booking Module (EABM) and
Alien Removal Module (EARM). ODO also gathered facility facts and inspection-related
information from ERO HQ staff to prepare for the site visit at CCCF.

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 NDS 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 classifies program issues into one of two categories: deficiencies and areas of concern.
Specific deficiencies and areas of concern are identified in bold with sequential numbers in this
report. OPR defines a deficiency as a violation of written policy that can be specifically linked to
the NDS, or to ICE policy or operational procedure. OPR defines an area of concern as something
that may lead to or risk a violation of the NDS or 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, Office of Detention Oversight.

INSPECTION TEAM MEMBERS

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

Management and Program Analyst (Team Leader)
Special Agent
Detention and Deportation Officer
Contract Inspector
Contract Inspector
Contract Inspector

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ODO, Headquarters
ODO, Headquarters
ODO, Headquarters
Creative Correction
Creative Correction
Creative Correction

Calhoun County Correctional Facility
ERO Detroit, MI

OPERATIONAL ENVIRONMENT
INTERNAL RELATIONS
ODO interviewed ICE and CCCF supervisory personnel, including the Jail Administrator and the
AFOD. ODO also interviewed a Supervisory Immigration Enforcement Agent (SIEA), an IEA
and several CCCF Correctional Officers (CO). During the interviews, all personnel stated the
working relationship between CCCF and ERO is professional and mutually beneficial, and morale
is good amongst HDC and ERO officers.
ERO personnel stated they have sufficient resources to carry out their duties and responsibilities at
CCCF. Scheduled and unscheduled visits to the facility by ERO management personnel occur six
to seven times per year. DOs and IEAs visit the CCCF housing units three times each week to
address detainee concerns and to respond to detainee written requests.

DETAINEE RELATIONS
ODO randomly-selected and interviewed 10 male and 5 female ICE detainees to assess the
overall living and detention conditions at CCCF. ODO received no complaints concerning
access to legal materials, issuance and replenishment of hygiene supplies, sending and receiving
mail, recreation, visitation, religious service, the grievance process, or medical care. All
expressed satisfaction with the quality of the food; however, three detainees stated the food
portions were too small. All expressed that the CCCF is professional and detainees are treated
with dignity and respect.
Detainees stated they see ICE officers three or four times a week. All stated they are familiar with
the procedures for contacting their respective DO, pro bono legal services, and consular offices
All males stated that they are being charged ten dollars per haircut at the barber shop. ODO
verified this with CCCF staff. Funds are deducted from detainee accounts. Two detainees stated
the facility did not make reasonable accommodations for religious holiday food menus. All stated
they received handbooks.

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ICE NATIONAL DETENTION STANDARDS
ODO reviewed a total of 15 NDS and found HDC fully compliant with the following 6 standards:
Detainee Transfers
Medical Care
Telephone Access
Special Management Unit (Administrative Segregation)
Special Management Unit (Disciplinary Segregation)
Suicide Prevention and Intervention
As these six standards were compliant at the time of the review, a synopsis for these areas was not
prepared for this report.
ODO found deficiencies in the following nine areas:
Access to Legal Material
Admission and Release
Detainee Classification System
Detainee Grievance Procedures
Detainee Handbook
Food Service
Funds and Personal Property
Staff-Detainee Communication
Use of Force
Findings for each of these standards are presented in the remainder of this report.

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ACCESS TO LEGAL MATERIAL (ALM)
ODO reviewed the Access to Legal Material standard at CCCF to determine if detainees have
access to a law library, legal materials, courts, counsel, and equipment to facilitate the preparation
of legal documents, in accordance with the ICE NDS. ODO reviewed policies, interviewed facility
staff, and assessed equipment used by detainees to access legal materials.
The facility does not have a designated area for use as a law library (Deficiency ALM-1). In lieu
of a dedicated law library, the facility has a separate small-sized room with a stationary computer
available for use. Additionally, two computers and printers on rolling carts are available for use in
the housing areas, upon request. Detainees also have applicable supplies available for use when
the carts are present in the housing areas. ODO acknowledges the efforts of CCCF to provide
access to legal materials within the housing units; however, the facility does not have a law library
located in a designated room within the facility, as per the ICE NDS (Deficiency ALM-1). This
deficiency was cited during the September 2009 ODO QAR.
Upon admission, CCCF provides detainees with a facility-specific handbook that should inform
detainees about the availability of legal materials and the procedures for requesting access. The
handbook does not inform detainees of the scheduled hours of access, or the procedures for
requesting additional time to access legal materials, requesting legal reference materials not
maintained in the library, or notifying a designated employee that legal material or equipment is
missing or damaged (Deficiency ALM-2), nor is this information posted.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY ALM-1
In accordance with the ICE NDS, Access to Legal Material, section (III) (A), the FOD must
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.
DEFICIENCY ALM-2
In accordance with the ICE NDS, Access to Legal Material, section (III)(Q), the FOD must ensure
the detainee handbook or equivalent shall provide detainees with the rules and procedures
governing access to legal materials, including the following information: 1. that a law library is
available for detainee use; 2. the scheduled hours of access to the law library; 3. the procedure for
requesting access to the law library; 4. the procedure for requesting additional time in the law
library (beyond the 5 hours per week minimum); 5. the procedure for requesting legal reference
materials not maintained in the law library; and 6. the procedure for notifying a designated
employee that library material is missing or damaged. These policies and procedures shall also be
posted in the law library along with a list of the law library’s holdings.

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ADMISSION AND RELEASE (AR)
ODO reviewed the Admission and Release NDS at CCCF to determine whether procedures are in
place to protect the health, safety, security and welfare of each person during the admission and
release process. ODO interviewed staff and detainees, and reviewed policies and procedures, the
detainee handbook, and detention files.
ODO observed CCCF intake procedures during the admission of ICE detainees to the facility,
including the creation of detention files by facility staff. ODO reviewed 20 randomly-selected
detention files to determine if required detainee-related documents were present and properly
completed. All files were in good order and did contain required documents, including Forms I203/203a, Order to Detain or Release, authorizing the detention and release of detainees; however,
upon arrival, detainees are not accompanied with Form I-213, Record of Deportable/Inadmissible
Alien. (Deficiency AR-1). The I-213 is an essential ICE document from which facilities are able
to properly classify incoming detainees.
During intake processing, all property accompanying the detainee is taken, catalogued, and
appropriately placed in detainee property bags. ODO also observed CCCF officers conducting
thorough interviews of detainees upon admission. Additionally, facility medical staff conduct
detailed medical screenings of all ICE detainees.
CCCF staff stated that visual searches and pat-downs of ICE detainees are conducted by officers of
the same gender. During the inspection, ODO determined that the facility does not conduct stripsearches of detainees upon admission. CCCF policy does allow officers to conduct strip-searches
with supervisory approval, if reasonable suspicion exists that a detainee may have concealed
contraband on their person. Interviews with detainees and facility personnel, in conjunction with
detention file reviews, confirm that strip-searches are not being conducted at CCCF.
During the admissions process, CCCF personnel provide detainees with orientation briefings
regarding the rules and regulations of the facility. CCCF makes use of a video presentation to
supplement the material provided in the facility handbook. The CCCF written orientation policy
and procedures have not been approved by ERO personnel, as required (Deficiency AR-2). To be
certain that ICE detainees are provided with a thorough orientation by each IGSA facility, the
respective FOD office must approve all applicable procedures.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY AR-1
In accordance with the ICE NDS, Admission and Release, section (III)(B), the FOD must ensure
admission staff will use the documentation accompanying each new arrival for identification and
classification purposes. If the classification officers are not ICE employees, ICE will provide only
the information needed for classification-processing. Under no circumstances shall non-ICE
personnel have access to the detainee’s A-file.

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DEFICIENCY AR-2
In accordance with the ICE NDS, Admission and Release, section (III)(B), the FOD must ensure
all facilities shall have a medium to provide ICE detainees an orientation to the facility. In IGSAs
the ICE office of jurisdiction shall approve all orientation procedures.

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DETAINEE CLASSIFICATION SYSTEM (DCS)
ODO reviewed the Detainee Classification System standard at CCCF to determine if there is a
formal classification process for managing and separating detainees based on verifiable and
documented data. ODO reviewed policies, the facility handbook, and 15 detainee classification
files. ODO also interviewed a classification officer and a supervisor assigned to classify detainees
upon arrival.
The facility holds ICE detainees of all classification levels. CCCF staff advised that ERO does not
consistently provide sufficient documentation to assist in the detainee classification process. ODO
reviewed 15 randomly-selected detention files. Eight files did not contain sufficient data,
including Forms I-213 and I-203/203a (Deficiency DCS-1). The seven remaining files did
contain the appropriate documents from which to properly classify detainees.
During the review of the CCCF handbook, ODO noted the classification section does not include
an explanation of the classification levels, including the conditions and restrictions applicable to
each. Additionally, the handbook does not state the procedures by which a detainee may appeal
his or her classification (Deficiency DCS-2). The two above-mentioned requirements have been
developed to help ensure proper classification for the overall well-being of detainees, as well as the
safety of facility staff and visitors.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DCS-1
In accordance with the ICE NDS, Detainee Classification System, section (III)(A)(1), the FOD
must ensure all detainees are classified upon arrival, before being admitted into the general
population. ICE will provide CDFs and IGSA facilities with the data they need from each
detainee’s file to complete the classification process. All officers assigned to classification duties
shall be trained in the facility’s classification process.
DEFICIENCY DCS-2
In accordance with the ICE NDS, Detainee Classification System, section (III)(I), the FOD must
ensure the detainee handbook’s section on classification will include the following:
1. An explanation of the classification levels, with the conditions and restrictions applicable to
each.
2. The procedures by which a detainee may appeal his/her classification.

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DETAINEE GRIEVANCE PROCEDURES (DGP)
ODO reviewed the Detainee Grievance Procedures standard at CCCF to determine whether a
process to submit formal or emergency grievances exists, and responses are provided in a timely
manner, without fear of reprisal. In addition, ODO reviewed the standard to determine whether
detainees have an opportunity to appeal responses and whether accurate records are maintained.
ODO interviewed ERO officials, CCCF officials, and detainees; and reviewed facility records,
policies, and procedures.
CCCF has written policies and procedures for detainees to submit informal and formal grievances.
Assistance with the filing of grievances is available, if needed, through language services and/or
facility personnel who are able to translate for detainees. While the facility encourages informal
grievance resolution at the lowest possible level, detainees may initiate the formal grievance
process by writing their grievance on a request form. Formal grievances are reviewed by the
CCCF grievance officer and copies are maintained in the respective detention files, as required;
however, the facility is not maintaining a detainee grievance log (Deficiency DGP-1).
Additionally, resolved informal or oral grievances that are not being documented and placed in
detention files, as required (Deficiency DGP-2).
ODO apprised CCCF personnel of the importance of maintaining an official grievance log of all
formal grievances and documenting and placing the results of all informally resolved grievances in
detention files. All formal and informal detainee concerns or complaints must be recorded and
properly filed to ensure the information is shared between ICE and detention facility personnel.
The ICE Detainee Grievance Procedure standard requires the implementation of proper procedures
to identify and handle emergency grievances. A review of CCCF Policy J160.1 “Inmate Rights”
indicates CCCF has not developed detailed written procedures for handling emergency detainee
grievances (Deficiency DGP-3). In addition to creating specific guidance and procedures, ODO
recommends CCCF provide training to its personnel on these procedures to ensure that emergency
grievances are properly identified and addressed in an expeditious and thorough manner.
All grievance-related deficiencies were discussed with CCCF and ERO staff during the review and
at the closeout briefing.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DGP-1
In accordance with the ICE NDS, Detainee Grievance Procedures, section (III)(E), the FOD must
ensure each facility devise a method for documenting detainee grievances. At a minimum, the
facility will maintain a detainee grievance log.
DEFICIENCY DGP-2
In accordance with the ICE NDS, Detainee Grievance Procedures, section (III)(A)(1), the FOD
must ensure the detainee is free to bypass or terminate the informal grievance process, and proceed
directly to the formal grievance stage. If an oral grievance is resolved to the detainee's satisfaction
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at any level of review, the staff member need not provide the detainee written confirmation of the
outcome; however, the staff member will document the results for the record and place his/her
report in the detainee’s detention file.
DEFICIENCY DGP-3
In accordance with the ICE NDS, Detainee Grievance Procedures, section (III)(F), the FOD must
ensure each facility shall implement procedures for identifying and handling an emergency
grievance. An emergency grievance involves an immediate threat to a detainee's safety or welfare.
Once the receiving staff member approached by a detainee determines that he/she is in fact raising
an issue requiring urgent attention, emergency grievance procedures will apply.

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DETAINEE HANDBOOK (DH)
ODO reviewed the Detainee Handbook standard at CCCF to determine if the facility provides each
detainee with a handbook, written in English and any other languages spoken by a significant
number of detainees housed at the facility. ODO reviewed the detainee handbook to ensure it
describes the facility’s rules and sanctions, disciplinary system, mail and visiting procedures,
grievance system, services, programs, and medical care, in accordance with the ICE NDS. ODO
also interviewed staff and reviewed the facility’s local detainee handbook.
CCCF detainee handbooks are available in both English and Spanish. A majority of the detainee
population at CCCF are from Central and South America; Spanish-speaking countries. ODO
confirmed that a sufficient number of handbooks are available in Spanish and are distributed
properly. CCCF staff informed ODO that in accordance with local policy, detainees are provided
verbal and video orientations that include references to the handbook. Subsequently, detainees are
required to sign for the handbook and a receipt is generated. All detainees stated that they were
issued a facility detainee handbook. CCCF last revised its handbook in January 2011.
During the review, ODO discovered the CCCF detainee handbook does not provide any
information concerning law library use in accordance with the NDS (Deficiency DH-1). ODO
recommends this missing information be inserted during the annual handbook revision. Other
handbook omissions are reported under the relevant standards as Deficiencies ALM-2, DCS-2,
and F&PP-1.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DH-1
In accordance with the ICE NDS, Detainee Handbook, section (III)(B), the FOD must ensure the
handbook will briefly describe individual programs and services and associated rules. Among
others, these include recreation, visitation, education, voluntary work, telephone use,
correspondence, library use, and the canteen/commissary. The overview will also cover medical
policy (sick-cell); facility-issued items, e.g., clothing, bedding, etc.; access to personal property;
and meal service.

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FOOD SERVICE (FS)
ODO reviewed the Food Service NDS at CCCF to determine if detainees are provided with a
nutritious and balanced diet, in a sanitary manner. ODO reviewed policies and documentation,
interviewed staff, observed meal service and tray delivery, and inspected food storage and
preparation areas.
All work associated with the preparation and service of meals is performed by contractor Aramark
Correctional Services, Inc. The facility has a satellite system meal service. No ICE detainees
work in the food service department. ODO verified inspections are conducted as required and
temperature logs are maintained. The master menu was certified by a licensed dietician.
Sanitation in the food service areas was good and equipment was found to be in working order.
Documentation was produced verifying the food service operation was last inspected by the
Calhoun County Public Health Department on September 2, 2011.
Daily searches of food service work areas are not conducted as standard operating procedure.
ODO was informed food service staff does not conduct searches on any regular basis, and security
staff performs shakedowns in the area only twice a month (Deficiency FS-1). ODO also notes
inmate workers are only searched at the end of their shift; they are not searched if they leave the
kitchen during their shift for visits, medical appointments, or for other reasons. This deficiency
was cited during the ODO 2009 QAR and again in the 2010 Follow-Up Inspection. Regular
searches of the food service area and workers ensure contraband is not removed from the kitchen.
ODO verified all inmate workers have received medical clearances to work in the food service
department; however, an Aramark Cook Supervisor employed at CCCF for more than 60 days did
not undergo a pre-employment medical examination (Deficiency FS-2). Pre-employment medical
examinations serve the critical purpose of ensuring food service workers have no communicable
medical conditions.
In its inspection of storage areas, ODO found food items stored on shelving with the required sixinch clearance from the floor; however, the items were stored against the walls (Deficiency FS-3).
The standard requires a two-inch clearance from walls to prevent possible contamination by
vermin.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY FS-1
In accordance with the ICE NDS, Food Service, section (III)(B)(5), the FOD must ensure all
facilities establish daily searches (shakedowns) of work areas (trash, etc.) as standard operating
procedures, paying particular attention to trash receptacles. Also required are searches of detainees
leaving certain work areas (e.g., bakery, vegetable preparation, dining room, warehouse).
DEFICIENCY FS-2
In accordance with the ICE NDS, Food Service, section (III)(H)(3)(a), the FOD must ensure all
food service personnel (both staff and detainee) receive a pre-employment medical examination.
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DEFICIENCY FS-3
In accordance with the ICE NDS, Food Service, section (III)(J)(3)(d)(e), the FOD must ensure all
products are stored at least six inches from the floor and sufficiently far from walls to facilitate
pest control measures. Food items are to be stored at least two inches from the walls and at least
six inches above the floor.

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ERO Detroit, MI

FUNDS AND PERSONAL PROPERTY (F&PP)
ODO reviewed the Funds and Personal Property NDS at CCCF to determine if controls are in
place to inventory, issue receipts for, store, and safeguard detainees’ personal property. ODO
reviewed policies and procedures, and interviewed staff.
CCCF’s funds and personal property policy and procedures provide for the accounting, inventory,
and safeguarding of detainee property from the time of admission until the time of release. Funds
and valuables are properly inventoried and logged by the facility’s supervisory staff. The safe and
the large-valuables locker are maintained in the shift supervisor’s office, as required by the NDS.
Detainees and/or family members are able to deposit funds into individual accounts for
commissary privileges. The CCCF detainee handbook has policies and procedures concerning
personal property; however, the facility does not have a policy for storing or mailing property not
allowed in the detainee’s possession (F&PP-1). To ensure accountability of all detainee property,
the process must be articulated clearly and transparently in the facility handbook.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY F&PP-1
In accordance with the ICE NDS, Funds and Personal Property, section (III)(J)(3), the FOD must
ensure the facility’s detainee handbook or equivalent notifies detainees of facility policies and
procedures concerning personal property including:
3). The rules for storing or mailing property not allowed in their possession.

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December 2011
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Calhoun County Correctional Facility
ERO Detroit, MI

STAFF-DETAINEE COMMUNICATION (SDC)
ODO reviewed the Staff-Detainee Communication standard at CCCF to determine if procedures
are in place to allow formal and informal contact between detainees and key ICE and facility staff;
and if ICE detainees are able to submit written requests to ICE staff and receive timely responses
in accordance with the ICE NDS. ODO interviewed staff and detainees, and reviewed policies and
procedures, request logs, and detention files.
Detention facilities are required to document unannounced visits by ICE personnel to detainee
living areas. ODO conducted interviews of CCCF and ICE staff to assess compliance with the
standard. The review confirmed ERO management personnel, including the AFOD, are
conducting unannounced and unscheduled visits to the facility; however, the facility is not
maintaining a record of those visits (Deficiency SDC-1). Additionally, ERO officers are required
to perform weekly facility visits, and must document their observations. The ICE Change Notice
National Detention Standards, Staff/Detainee Communication Model Protocol, dated June 15,
2007, specifies guidelines for detention facility liaison visits. ODO confirmed ICE officers are
conducting visits to the facility and are completing the required facility liaison checklist. As with
the unannounced ICE management visits to the facility, a log is not being used at CCCF for
recording informal communications between ICE officers and detainees (Deficiency SDC-2). The
lack of proper documentation is particularly concerning to ODO, especially in light of the previous
OPR inspection conducted in 2009 that cited the same deficiencies.
According to ICE and CCCF personnel, Tuesdays and Thursdays are designated days for
scheduled contact visits for ERO officers to communicate with detainees. ERO staff visited the
facility during the ODO compliance inspection, but the official visitation schedule was not posted
in the detainee living areas, as required by the NDS (Deficiency SDC-3). It is important that the
visitation schedules of ERO officers be conspicuously posted in the facility so detainees are aware
of opportunities to ask questions of, or address concerns to, ERO officers.
Detainees are able to write and submit requests to ICE through CCCF officers. Request forms are
scanned and transmitted via e-mail to ICE for review and response. ODO reviewed the detainee
request process to ensure detainees receive responses from ICE within the required 72-hour
window, as per the NDS. ODO found that requests are received from detainees and transmitted to
ICE, typically on the same day; however, responses from ERO are not consistently received by
CCCF within 72 hours of transmission (Deficiency SCD-4). Additionally, CCCF does not
maintain a log to track the complete detainee request process, as required (Deficiency SDC-5).
CCCF relies strictly on the electronic mail system and its sent and received archives for the
tracking of detainee requests. ODO recommends that CCCF immediately establish a computerbased or paper log to track the requests in detail, as required by the ICE NDS.
During the review and closeout, ODO discussed the above-cited deficiencies with CCCF and ERO
staff to highlight the importance of detailed record-keeping in this area. ODO has repeatedly
observed that facilities with well-managed staff-detainee communications are typically less likely
to experience serious detention-related issues and events as those with poor communication
capabilities and oversight.
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December 2011
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Calhoun County Correctional Facility
ERO Detroit, MI

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY SDC-1
In accordance with the ICE NDS, Staff-Detainee Communication, section (III)(A)(1), the FOD
must ensure policies and procedures shall be in place to ensure and document that the ICE Officer
in Charge, the Assistant Officer in Charge, and designated department heads conduct regular
unannounced (not scheduled) visits to the facility’s living and activity areas to encourage informal
communication between staff and detainees, and informally observe living and working
conditions. Each facility shall develop a method to document the unannounced visits, and ICE will
document visits to IGSAs.
DEFICIENCY SDC-2
In accordance with the Change Notice Staff/Detainee Communication Model Protocol, dated June
15, 2007, section (F)(2), the FOD must provide the Jail Liaison Officer with a logbook to maintain
at the facility to log their visits, names and alien registration numbers of detainees informally
interviewed and any unscheduled communications with detainees, along with any concerns or
comments.
DEFICIENCY SDC-3
In accordance with the ICE NDS, Staff-Detainee Communication, section (III)(A)(2)(b), the FOD
shall devise a written schedule and procedure for weekly detainee visits by District ICE detention
and deportation staff. The ICE officer will also visit the facility’s Special Management Units
(SMU) to interview any ICE detainees housed there, monitor housing conditions, review
detainees’ classification and basis for placement in the SMU, and review all records in this regard.
Written schedules shall be developed and posted in the detainee living areas and other areas with
detainee access. The ICE Field Office Director shall have specific procedures for documenting the
visit. IGSAs with larger populations should be visited more often if necessary.
DEFICIENCY SDC-4
In accordance with the ICE NDS, Staff-Detainee Communication, section (III)(B)(1)(b), the FOD
must ensure, in IGSAs without ICE presence on-site, the detainee requests shall be forwarded to
the ICE office of jurisdiction within 72 hours and answered as soon as possible and practicable, but
not later than within 72 hours from receiving the request. If it is apparent that the request is
serious in nature, procedures shall be in place for an expedited review and response to the request.
DEFICIENCY SDC-5
In accordance with the ICE NDS, Staff-Detainee Communication, section (III)(B)(2), the FOD
must ensure all requests are recorded in a logbook specifically designed for that purpose. In
IGSAs, the date the request was forwarded to ICE, and the date it was returned shall also be
recorded.

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December 2011
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Calhoun County Correctional Facility
ERO Detroit, MI

USE OF FORCE (UOF)
ODO reviewed the Use of Force NDS at CCCF to determine if necessary use of force is utilized
only after all reasonable efforts have been exhausted to gain control of a subject, while protecting
and ensuring the safety of detainees, staff and others, preventing serious property damage, and
ensuring the security and orderly operation of the facility, in accordance with the ICE NDS. ODO
interviewed staff and reviewed local policies, training records, use of force documentation, and
surveillance video recordings of two use of force incidents. ODO toured the facility, inspected
security equipment, and reviewed local policies, use of force documentation, and training records.
ODO was informed there have been five incidents involving use of force and application of
restraints on detainees in the past year. The facility’s stock of non-lethal weapons consist of
batons, OC Spray, and tasers. Use of tasers on detainees is expressly prohibited by facility policy.
CCCF policy states that the use and level of physical force is dependent upon the officer’s
perception of resistance and danger posed by that resistance. It divides force in terms of that
which is necessary to gain control of detainee’s resistance into five categories: Officer
Presence/Verbal Direction, Compliance Controls, Physical Controls, Intermediate Controls, and
Deadly Force Response. The policy does not distinguish between situations necessitating
immediate use of force from those in which there is no immediate threat to the detainee or others,
allowing assessment and possible resolution without resorting to force. In addition, the policy
does not require documentation by way of videotape. Although fixed, digital security cameras are
located throughout the facility, they have limited range and do not have audio capability. ODO’s
review of two video recordings of force incidents confirmed there were blind areas that the
cameras are incapable of capturing. Though a handheld video camera is maintained in the
supervisor’s office, it is not used to record use of force incidents, as required by the NDS
(Deficiency UOF-1).
CCCF does not have a designated use of force team. When an incident occurs, a request for
assistance is transmitted by radio, and any available personnel are expected to respond.
Responding staff are not trained in, and do not follow, the use of force team techniques, including:
team composition, supervisory roles and the video recording of incidents (Deficiency UOF-2).
Recording calculated use of force incidents is required per the NDS. Specifically, the NDS
requires information, such as, but not limited to, the introduction and preamble by the use of force
team leader noting the facility name, location, date, and time, and the faces of all participating
team members, must be audio and visually recorded. Use of a portable camera will enable CCCF
staff to record, for example, close-up footage of the detainee’s body during medical examination in
order to document the presence or absence of injuries.
Additionally, team safeguards are not in place to prevent injury and exposure to communicable
disease (Deficiency UOF-3). Training and the use of protective gear is critically important to
ensure the welfare of staff and the detainee population.

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Calhoun County Correctional Facility
ERO Detroit, MI

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY UOF-1
In accordance with the ICE NDS, Use of Force, section (III)(A)(2)(a)(b), the FOD must ensure, if
a detainee is in an isolated location (e.g., a locked cell, a range) where there is no immediate threat
to the detainee or others, the officer(s) takes the time to assess the possibility of resolving the
situation without resorting to force. The calculated use of force is feasible in most cases.
Calculated use of force is appropriate when the detainee is in a cell or other area with a securable
door or grill, even if the detainee is verbalizing threats or brandishing a weapon, provided staff
sees no immediate danger of the detainee causing harm. The calculated use of force affords staff
time to strategize, resolving situations in the least confrontational manner. Incidents of use of
force shall be documented and forwarded to ICE for review. The videotaping of all calculated uses
of force is required.
DEFICIENCY UOF-2
In accordance with the ICE NDS, Use of Force, section (III)(A)(4)(a-l), the FOD must ensure,
when a detainee must be forcibly moved and/or restrained during a calculated use of force, the useof-force team technique applies.
DEFICIENCY UOF-3
In accordance with the ICE NDS, Use of Force, section (III)(D), the FOD must ensure use-of-force
team safeguards are in place to prevent injury and exposure to communicable disease. Use-ofForce team members and others participating in calculated uses of force shall wear protective gear.
If the circumstances of an immediate use-of-force incident permit, staff will obtain and use
appropriate protective equipment (helmets with face shields, gloves, pads, etc.) before intervening.  

Office of Detention Oversight
December 2011
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Calhoun County Correctional Facility
ERO Detroit, MI