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 Houston Field Office
Joe Corley Detention Facility
Conroe, Texas

July 21–23, 2015

 

COMPLIANCE INSPECTION
for the
JOE CORLEY DETENTION FACILITY
CONROE, TEXAS
TABLE OF CONTENTS

EXECUTIVE SUMMARY
Overall Findings...................................................................................................................2
Findings by Performance-Based National Detention Standards (PBNDS) 2011 Major
Categories ............................................................................................................................3
INSPECTION PROCESS .............................................................................................................4
DETAINEE RELATIONS ............................................................................................................5
INSPECTION FINDINGS
SAFETY
Environmental Health and Safety ........................................................................................6
SECURITY
Funds and Personal Property ...............................................................................................6
Special Management Units ..................................................................................................6
Use of Force and Restraints .................................................................................................7
CARE
Medical Care ........................................................................................................................7
Significant Self-Harm and Suicide Prevention and Intervention .........................................8

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*

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INSPECTION TEAM MEMBERS

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

Office of Detention Oversight
July 2015
OPR 201507644

Lead Inspections and Compliance Specialist
ODO
Inspections and Compliance Specialist
ODO
Contractor
Creative Corrections
Contractor
Creative Corrections
Contractor
Creative Corrections
Contractor
Creative Corrections
Contractor
Creative Corrections
Contractor
Creative Corrections
1

Joe Corley Detention Facility
ERO Houston

 

EXECUTIVE SUMMARY
The Office of Detention Oversight (ODO) conducted a compliance inspection of Joe Corley
Detention Facility (JCDF) in Conroe, Texas, from July 21 to 23, 2015. 1 JCDF opened in 2008
and is owned and operated by the GEO Group, Inc. (GEO). The Office of Enforcement and
Removal Operations (ERO) began housing detainees at JCDF in 2008 pursuant to an
Intergovernmental Service Agreement (IGSA), under the oversight of ERO’s Field Office
Director (FOD) in Houston, Texas.
ERO staff members, including a
Quantity
Detention Service Manager, are Capacity and Population Statistics
assigned to the facility. A GEO ICE Detainee Bed Capacity2
1,050
Warden is responsible for oversight Average ICE Detainee Population3
649
of daily facility operations and is
Male Detainee Population (as of 07/21/2015)
799
supported by (b)(7)e personnel. GEO
Female
Detainee
Population
(as
of
07/21/2015)
0
provides food and medical services.
The facility is accredited by the American Correctional Association and National Commission on
Correctional Health Care.

OVERALL FINDINGS

Inspection Results
Compared

In June 2014, ODO conducted an
inspection of JCDF under the Standards Reviewed
Performance-Based
National
Detention Standards (PBNDS) 2011, Deficient Standards
reviewing the facility’s compliance Overall Number of
with 11 standards and finding the Deficiencies
Deficient Priority
facility compliant with three Components
standards. There were a total of 19
deficiencies in the remaining eight Corrective Actions Initiated
standards; eight of those deficiencies relate to priority components.

FY 2014
(2011 PBNDS)

FY2015
(2011 PBNDS)

11

16

8

6

19

9

8

2

0

6

In July 2015, ODO conducted an inspection of JCDF under the PBNDS 2011, reviewing the
facility in accordance with the requirements of 16 standards and finding the facility compliant
with ten standards. ODO found nine deficiencies under the remaining six standards; two of those
deficiencies relate to priority components.4 Finally, ODO identified six opportunities where the
facility initiated corrective action during the course of the inspection.5

                                                            
1

Male detainees with low, medium and high security classification levels are detained at SDC for longer than 72
hours.
2
 Data Source: ERO Facility List Report as of July 27, 2015. 
3
 Ibid. 
4
Deficient priority components were found in the following standard: Medical Care (2).
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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Joe Corley Detention Facility
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FINDINGS BY PBNDS 2011 MAJOR CATEGORIES
PBNDS 2011 STANDARDS INSPECTED6

DEFICIENCIES

Part 1 - Safety
1.2 - Environmental Health and Safety
Sub-Total

1
1

Part 2 - Security
2.1 - Admission and Release
2.2 - Custody Classification System
2.5 - Funds and Personal Property
2.11 - Sexual Abuse and Assault Prevention and Intervention
2.12 - Special Management Units
2.13 - Staff-Detainee Communication
2.15 - Use of Force and Restraints
Sub-Total

0
0
1
0
1
0
2
4

Part 4 - Care
4.1 - Food Service
4.3 - Medical Care
4.4 - Medical Care (Women)
4.6 - Significant Self-Harm and Suicide Prevention and Intervention
Sub-Total

0
3
0
1
4

Part 5 - Activities
5.6 - Telephone Access
Sub-Total

0
0

Part 6 - Justice
6.1 - Detainee Handbook
6.2 - Grievance System
6.3 - Law Libraries and Legal Materials
Sub-Total

0
0
0
0

Total Deficiencies

9

                                                            
6

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

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July 2015
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Joe Corley Detention Facility
ERO Houston

 

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, ICE 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 Priority components have been selected from across a range of detention
standards based on 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. 

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July 2015
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Joe Corley Detention Facility
ERO Houston

 

DETAINEE RELATIONS
ODO interviewed 40 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:


Detainee Handbook: Five detainees alleged they have not received the ICE National
Detainee Handbook, and three detainees alleged they have not received the facility
handbook.
o Action Taken: ODO reviewed each detainee’s detention files and observed signed
acknowledgment forms that they received the ICE National Detainee Handbook
and facility handbook during admission into the facility.



Funds and Personal Property: A detainee alleged they received a photo copy of a check
from a staff member for $100.00 dollars. The detainee alleges the money has not been
deposited into their commissary account.
o Action Taken: ODO was informed by staff the photo copy of the check was given
to the detainee in error. The check was meant for another detainee with a similar
name. Facility staff followed up with the detainee and explained the error.



Medical Care: Two detainees alleged they were not receiving adequate medical attention.
One detainee alleged he was not receiving appropriate medication for headaches. One
detainee alleged he had pain from the upper stomach area to his kidney. The detainee
further alleged he was supposed to have had a urine test but to date had not been
scheduled for the test.
o Action Taken:
Medical services notified ODO, the detainee with the allegation of not receiving
medication for headaches, was seen and provided the appropriate medication.
ODO reviewed the detainee’s medical record and verified the detainee was
provided medication for his headache. The detainee was referred to the medical
staff for further review. Medical services notified ODO, the detainee with the
allegation of stomach pain, was seen twice during the inspection, and a urine
sample was collected for analysis. The detainee was referred to the medical staff
for further review.

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July 2015
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Joe Corley Detention Facility
ERO Houston

 

INSPECTION FINDINGS
SAFETY
ENVIRONMENTAL HEALTH AND SAFETY (EH&S)
ODO reviewed the Fire Drill Evaluation forms provided by the facility safety manager showing
that fire drills are completed and emergency keys were drawn; however, the emergency key
drills were not timed (Deficiency EH&S-19).
Corrective Action:
Corrective action was initiated during the inspection by
modification of the facility Fire Drill Evaluation form to include this requirement (C-1).

SECURITY
FUNDS AND PERSONAL PROPERTY (F&PP)
ODO reviewed the facility handbook and found the handbook provides procedures for reporting
lost or damaged property; however, the handbook does not explain how to obtain personal
identity documents from ERO (Deficiency F&PP-110).
Corrective Action:
Corrective action was initiated during the inspection by
modification of the detainee handbook (C-2).
SPECIAL MANAGEMENT UNIT (SMU)
A review of policies governing segregation and the operation of the SMU confirmed it does not
provide written procedures for the review of the detainee’s status while in disciplinary
segregation (Deficiency SMU-111).
Corrective Action:
The facility initiated corrective action during the inspection by
modifying the policy to include the procedures for the review of the detainee’s status
while in disciplinary segregation (C-3).

                                                            
9

“Emergency-key drills shall be included in each fire drill, and timed.” See ICE PBNDS 2011, Standard 1.2,
Environmental Health and Safety, Section (V)(C)(4)(c).
10
 “The detainee handbook or equivalent shall notify the detainees of facility policies and procedures related to
personal property, including that, upon request, they shall be provided an ICE/ERO- certified copy of any identity
document (e.g., passport, birth certificate), which shall then be placed in their A-files;” See ICE PBNDS 2011,
Standard 2.5, Funds and Personal Property, Section (V)(C)(2).
11
“All facilities shall implement written procedures for the regular review of all disciplinary segregation cases...”
See ICE PBNDS 2011, Standard 2.12, Special Management Units, Section (V)(B)(3). 

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July 2015
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Joe Corley Detention Facility
ERO Houston

 

USE OF FORCE AND RESTRAINTS (UOF&R)
Three use-of-force incidents occurred in the twelve months prior to the inspection. ODO
reviewed the after-action review reports and found that required reviews were not completed
within two working days as required by the standard (Deficiency UOF&R-112).
Corrective Action:
The facility initiated corrective action during the inspection by
adding a section in the policy and procedures requiring shift supervisors to complete the
after action review by the end of the shift on which the use-of-force occurred (C-4).
ODO also found the facility administrator did not report the findings and conclusions as to the
appropriateness of the force used to the FOD (Deficiency UOF&R-213).
Corrective Action:
The facility initiated corrective action during the inspection by
adding a section in the policy and procedures requiring the Warden or Assistant Warden
to submit their findings to the Assistant Field Officer Director before the close of
business on the second day after the use-of-force occurred (C-5).

CARE
MEDICAL CARE (MC)
ODO reviewed 32 detainee health records and determined that in four cases the 14 day health
assessments were completed after 14 days. In three other cases, ODO was unable to determine
when the health assessments were completed as there was no date on the health assessment
forms (Deficiency MC-114).
The ODO medical record review identified six cases in which detainees were referred for mental
health evaluation. In one of the six cases, the evaluation was not completed within 72 hours as
required by the standard, and in another case the evaluation was not completed at all (Deficiency
MC-215).
                                                            
12

“The after-action review team shall complete and submit its after-action review report to the facility administrator
within two workdays of the detainee’s release from restraints. The facility administrator shall review and sign the
report, acknowledging its finding that the use of force was appropriate or inappropriate.” See ICE PBNDS 2011,
Standard 2.15, Use of Force and Restraints, Section (V)(P)(4).
13
“Within two workdays of the after-action review team’s submission of its determination, the facility administrator
shall report with the details and findings of appropriate or inappropriate use of force, by memorandum, to the Field
Office Director and whether he/she concurs with the finding.” See ICE PBNDS 2011, Standard 2.15, Use of Force
and Restraints, Section (V)(P)(5).
14
“Each facility’s health care provider shall conduct a comprehensive health assessment, including a physical
examination and mental health screening, on each detainee within 14 days of the detainee’s arrival unless more
immediate attention is required due to an acute or identifiable chronic condition.” See ICE PBNDS 2011, Standard
4.3, Medical Care, Section (V)(L). This is a priority component.
15
“Based on intake screening, the comprehensive health assessment, medical documentation, or subsequent
observation by detention staff or medical personnel, any detainee referred for mental health treatment shall receive
an evaluation by a qualified licensed mental health professional as medically indicated no later than 72 hours after
the referral, or sooner if necessary.” See ICE PBNDS 2011, Standard 4.3, Medical Care, Section (V)(N)(3). This is
a priority component.

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July 2015
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Joe Corley Detention Facility
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The record review of 12 detainees who reported taking medications on arrival found that in three
cases the detainees did not receive ordered medications for two to four days after admission
(Deficiency MC-316).
SIGNIFICANT SELF-HARM AND SUICIDE PREVENTION AND INTERVENTION
(SS-H& SP&I)
ODO reviewed a detainee’s record and found while on suicide watch the detainee was not reevaluated on a daily basis in accordance with the standard (Deficiency SS-H, SP&I-117).
Corrective Action:
The facility initiated corrective action during the inspection by
arranging for weekend coverage by mental health professionals so reassessments are
completed daily (C-6).

                                                            
16

“Each detention facility shall have and comply with written policy and procedures for the management of
pharmaceuticals, to include documentation of accountability for administering or distributing medications in a
timely manner, and according to licensed provider orders.” See ICE PBNDS 2011, Standard 4.3, Medical Care,
Section (V)(G)(12).
17
“Detainees placed on suicide watch shall be re-evaluated by appropriately trained and qualified medical staff on a
daily basis, with this re-evaluation documented in the detainee’s medical record.” See ICE PBNDS 2011, Standard
4.6, Significant Self-Harm and Suicide Prevention and Intervention, Section (V)(D).

Office of Detention Oversight
July 2015
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Joe Corley Detention Facility
ERO Houston