Featured Issues

Featured Issue: Immigration Detention and Alternatives to Detention

3/14/25 AILA Doc. No. 24121300. Detention & Bond, Removal & Relief

Update: On March 14, 2025, AILA released a statement in response to the Trump Administration resuming the practice of detaining families pending their court proceedings in the detention facility in Karnes County, TX, and indicating its plans to use a second facility in Dilley, TX, for family detention.

AILA calls on Congress to significantly reduce and phase out the use of immigration detention for immigration enforcement purposes. Detention is costly, leads to inefficiencies in processing cases, and has a long track record of human rights abuses. Community-based case management services and legal representation is more humane and should be offered to noncitizens to support their compliance of immigration obligations.
 


By the Numbers

  • Book Outs/Books In: The Office of Homeland Security Statistics provides data on the number of migrants who are released from CBP custody to proceed with removal cases, transfers to ICE detention, and transfers to Health & Human Services (HHS). It also provides initial book-in data on ICE detention.
  • Detention: For FY2024, Congress has provided funding to detain a daily average of 41,500 noncitizens at a cost of approximately $3.4 billion. During FY2023, Congress provided funding to detain a daily average of 34,000 noncitizens at a cost of approximately $2.9 billion. A December 2024 ICE memo in response to Congressional requests for information noted that increasing detention capacity by more than 60,000 beds will require a funding increase of approximately $3.2 billion dollars.
  • Current Population: Per ICE, on December 8, 2024, there were 39,062 people in custody and on January 22, 2025, there were 39,703. For future data, see bi-weekly data posted on the ICE website under “Fiscal Year 2025 statistics” here.
  • Daily Costs: Projected average daily costs of detaining an adult noncitizen: $164.65. The actual cost of detaining a noncitizen varies based on geographic region, length of detention, facility type, etc. A recent ICE memo in response to the costs of expanding detention noted that they expect a 5% inflationary increase from FY2024 enacted bed costs.
  • Deaths at Adult Detention Centers - AILA supplies a continually updated list of ICE press releases announcing deaths in adult immigration detention. Note: there can be delays in ICE’s reporting of deaths and there have been instances of seriously ill individuals released from ICE custody, whose deaths are not included in this list.
  • ICE Alternatives to Detention: For FY2024, Congress provided approximately $470 million in funding for ICE’s Alternatives to Detention (ADT) program. This is an increase from approximately $443 million in FY2023 in which 194,427 people were enrolled.
  • Daily Costs of ICE ATD: Average daily cost for participants enrolled in ICE’s Intensive Appearance Supervision Program (ISAP): $8.00
  • Community-Based Case Management: The FEMA/CRCL Case Management Pilot Program (CMPP), also known as the “Alternatives to Detention Grant Program,” received $15 million in continued funding for FY2024. Prior to January 20, 2025, it was operating in five cities.
  • Average daily cost of providing case management for individual family members by a community-based organization (2018 pilot): $14.05
  • Legal Representation: There is no right to a government-provided attorney in immigration court and 70 percent of detained persons face proceedings without counsel. There is a pilot program that serves adult individuals with mental disabilities. Congress did not provide any funding for adult legal representation for FY2024.

 


 

AILA’s Recommendations to Congress

  1. Reduce detention funding to at least 25,000 average daily population or less.
  2. Explicitly prohibit detention funding from being used to detain families and children in custodial settings.
  3. Provide continued funding community-based case management programs outside of ICE such as the Case Management Pilot Program (CMPP) operated by the Federal Emergency Management Agency (FEMA) and the Office for Civil Rights and Civil Liberties (CRCL)
  4. Conduct robust oversight of past congressional appropriations transparency requirements and continue to require ICE to disclose and publish information relating to detention contracts, inspection process and reports, detention data, and policies for the alternatives to detention program.

Background

Created in 2002, Immigration & Customs Enforcement (ICE) has over 22,000 full-time employees, with a total annual budget of more than $9 billion. The agency has three core operational directorates: Enforcement and Removal Operations (ERO), Homeland Security Investigations (HSI), and the Office of the Principal Legal Advisor (OPLA). Housed within the Department of Homeland Security, ICE joins Customs & Border Protection (CBP) in making up the nation’s largest police force.

Immigration enforcement, including taking noncitizens into custody, is the largest single area of responsibility for ICE. ICE detains noncitizens arrested from the interior of the country and those transferred from the border. Twenty-years ago, the average daily population of detained immigrants was approximately 7,000. During the first Trump Administration, it reached a height of 50,000 average daily population. Regardless of the circumstances of their first encounter with authorities, noncitizens are detained across America in a sprawling network of private and public detention facilities. Most of these facilities operate through contracts between ICE (or, less commonly, the U.S. Marshals Service) and localities for the purposes of detaining noncitizens. In some cases, localities later sub-contract services for operating detention facilities to private prison companies. In other instances, localities reserve space in local, county, or state jails and prisons for the purposes of detaining immigrants. In all cases, localities are financially incentivized to detain individuals to increase profit margins from contracts. One key part of the financial equation is the use of noncitizens to clean and maintain facilities in exchange for $1 a day.

Immigration detention facilities, regardless of the type of contracts, have been the sites of serious and repeated allegations of abuse, including allegations of sexual assault, violations of religious freedom, medical neglect, and the punitive use of solitary confinement. In 2020, the U.S. had the highest number of deaths in ICE adult detention since 2005. Several deaths in custody have been found to have been preventable. Conditions in ICE custody have been described as “barbaric” and “negligent” by DHS experts.

Civil immigration detention works mainly to facilitate deportation. While ICE has the authority to allow most noncitizens to continue with their removal cases on the outside of custody, it often defaults to detention based on alleged “flight risk or threat to public safety.” The vagueness of these concepts frequently works against the liberty interests of noncitizens and there is generally a lack of uniformity when it comes to these discretionary releases. Only a certain portion of the overall noncitizen population must be detained under “mandatory detention” laws and even those individuals may be released based on certain exceptions.

Lastly, because immigration detention is considered “civil,” indigent noncitizens are not generally provided counsel. As a result, representation rates for noncitizens in detention are as low as 14% and directly correlate with the ability to secure release or long-term protection.

 

Reports and Briefings

Government Reports

Legislative and Administrative Advocacy

Browse the Featured Issue: Immigration Detention and Alternatives to Detention collection
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Cases & Decisions, Federal Court Cases

CA2 Finds Detention-Based Habeas Action Qualifies for EAJA Fees

The court held that a habeas petition challenging immigration detention qualifies as a "civil action" for the purposes of EAJA fee recovery and that an interim order of release pending appeal can confer prevailing party status. (Vacchio v. Gonzales, 4/18/05)

4/18/05 AILA Doc. No. 05050413. Detention & Bond, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Finds Denial of Right to Counsel

CA9 found that the IJ violated Petitioner’s right to counsel because he failed to afford him a reasonable time to obtain counsel. It notedthat practical considerations, like detention status and English language ability, should inform the determination. (Biwot v. Gonzales, 4/14/05)

4/14/05 AILA Doc. No. 05050410. Detention & Bond, Removal & Relief

Text of the Civil Liberties Restoration Act of 2005

Text of the Civil Liberties Restoration Act of 2005 (H.R. 1502), introduced by Representative Howard Berman (D-CA) on 4/6/05. The bill seeks to roll back some of the most egregious post-9/11 polices and would secure due process protections and civil liberties for non-citizens in the U.S.

4/6/05 AILA Doc. No. 05040690. Congress, Detention & Bond, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Affirms District Court Jurisdiction Over Bivens Suits; Finds 4th Amendment Violation (Updated 4/10/06)

CA9 held: (1) INA §242 did not preclude a Bivens action for monetary damages; (2) where INS officer had no legal basis to detain Plaintiff pursuant to the expedited removal statute, the officer violated a Fourth Amendment right to be free from unlawful detention. (Sissoko v. USA, 3/16/05)

Federal Agencies, Liaison Minutes

EOIR Responses to AILA's Liaison Questions (3/16/05)

Liaison issues addressed with EOIR included such topics as e-filing, asylum clock issues, application in Immigration Courts of recent circuit court and BIA decisions, FOIA, the new security clearance regulations, among other pressing issues.

3/16/05 AILA Doc. No. 05051268. Admissions & Border, Asylum, Detention & Bond, Removal & Relief
Federal Agencies, Liaison Minutes

ICE Liaison Minutes (3/16/05)

The liaison minutes record the discussions with ICE regarding such topics as stipulated removal orders, automatic stay provisions, the new EOIR security clearance regulations, Operation Compliance, file sharing, alternatives to detention, among other issues.

3/16/05 AILA Doc. No. 05051766. Detention & Bond, Removal & Relief
Media Tools

AILA Issue Packet on Unaccompanied Children

Bipartisan legislation introduced in the 109th Congress would provide guidelines for the detention, care, and placement of unaccompanied children. This packet will help you advocate for the Unaccompanied Alien Child Protection Act of 2005 (S. 119).

Media Tools

AILA Issue Packet on REAL ID Act

Many of the troubling anti-immigrant provisions that were stripped from the intelligence reform bill have resurfaced as part of the REAL ID Act (H.R. 418). This packet will assist you in opposing the REAL ID Act.

3/9/05 AILA Doc. No. 05031062. Asylum, Detention & Bond, Removal & Relief
Federal Agencies, Agency Memos & Announcements

Cerda Memo: Guidance on ICE Release Gratuity Program for Release Following Long-Term Immigration Detention

This ICE memo from February 18, 2005, provides guidance on implementation of the release gratuity program for qualified non-citizens eligible for release following long-term immigration detention.

2/18/05 AILA Doc. No. 09121563. Detention & Bond, Removal & Relief
Federal Agencies, Agency Memos & Announcements

DHS Releases FY2006 Budget Request

The DHS's FY2006 budget proposal requests $1,854 billion (an increase of $79 million from FY2005), including $80 million in discretionary funding, and $1,774 billon in mandatory funding generated from fee revenues.

2/8/05 AILA Doc. No. 05020879. Detention & Bond, Removal & Relief
Federal Agencies, FR Regulations & Notices

EOIR Interim Rule on Background and Security Investigations

EOIR's interim rule makes significant changes affecting granting of relief in removal proceedings pending security investigations, and consequences of respondents’ failure to comply. Comments are due 4/1/05. (70 FR 4743, 1/31/05)

1/31/05 AILA Doc. No. 05012861. Detention & Bond, Removal & Relief
Federal Agencies, Liaison Minutes

State Bar of Texas Meeting Minutes (1/28/05)

The 1/28/05 minutes from the last quarterly meeting of the State Bar of Texas, Committee on Laws Relating to Immigration & Nationality, address a variety of issues, including DORA, backlogs, and pro bono representation.

1/28/05 AILA Doc. No. 05031512. Detention & Bond, Removal & Relief
Federal Agencies, Agency Memos & Announcements

Cerda Memo on Post-Order Custody Review after Clark v. Martinez

A 1/21/05 memo from Victor Cerda, Acting Director, Office of Detention and Removal Operations, ICE, provides interim guidance on post-order custody reviews following the Supreme Court's decision in Clark v. Martinez.

1/21/05 AILA Doc. No. 09022075. Detention & Bond, Removal & Relief
Cases & Decisions, Federal Court Cases

Analysis of Supreme Court Decision Holding that Inadmissible Aliens May Not Be Detained Indefinitely

The Supreme Court held that its decision in Zadvydas v. Davis, finding indefinite detention unconstitutional, applies to non-admitted foreign nationals. (Clark v. Martinez, 1/12/05)

1/12/05 AILA Doc. No. 05011461. Detention & Bond, Removal & Relief
Federal Agencies, Agency Memos & Announcements

ICE Re-Circulates Guidance on ICE Transportation, Detention, and Processing Requirements

ICE re-circulated a 10/18/04 memo titled “Detention Prioritization and Notice to Appear Documentary Requirements” and outlined how the guidance should be used to assist ICE officials while conducting immigration enforcement operations.

1/11/05 AILA Doc. No. 18042300. Detention & Bond, Removal & Relief
Federal Agencies, Agency Memos & Announcements

ICE Memorandum on Orders of Supervision

A 11/12/2004 memorandum from Victor X. Cerda, Acting Director, ICE Detention and Removal Operations, standardizes the reporting requirements for individuals released under an order of supervision or released on recognizance.

11/12/04 AILA Doc. No. 10072768. Detention & Bond, Removal & Relief
AILA Public Statements, Correspondence

Sign-On Letter to Members of Congress Regarding H.R. 10

A letter from AILA and other interested organizations to Members of Congress asking that they reject the divisive immigration provisions of the House-passed 9/11 Recommendations Implementation Act (H.R. 10).

10/19/04 AILA Doc. No. 04101866. Asylum, Detention & Bond, Expedited Removal, Removal & Relief
Federal Agencies, Agency Memos & Announcements

DHS Memo on Detention Prioritization and NTA Documentary Requirements

DHS 10/18/04 memorandum from DHS undersecretary Asa Hutchinson providing priorities for the detention of people and outlining documentary requirements which must be met when transferring people to ICE custody for removal proceedings. Courtesy of Peter D. Williamson.

10/18/04 AILA Doc. No. 04101840. Detention & Bond, Removal & Relief

White House Letter Fails to Adequately Support Deletion of Harmful Immigration Provisions in HR 10

Letter from the White House to House & Senate intelligence reform bill conferees, dated 10/18/04, fails to adequately call for the deletion of all the harmful immigration provisions contained in the House-passed measure (H.R. 10).

10/18/04 AILA Doc. No. 04102062. Congress, Detention & Bond, Removal & Relief

Final Text of H.R. 10 as Passed by the House

Text of the 9/11 Recommendations Implementation Act as passed by the House on October 8, 2004.

10/8/04 AILA Doc. No. 04101364. Admissions & Border, Congress, Detention & Bond, Removal & Relief
Federal Agencies, Agency Memos & Announcements

Statement of Administration Policy on 9/11 Recommendations

The Administration’s statement expresses, among other things, opposition to the overbroad expansion of expedited removal authorities contained in H.R. 10 as well as the overbroad alien identification standards proposed by the bill that are unrelated to security concerns.

10/7/04 AILA Doc. No. 04100864. Detention & Bond, Removal & Relief

BIA Finds Pro Bono Project Very Successful at Meeting Original Goals

The BIA issued a program review report, finding that its Pro Bono Project, which recently completed its third year of operation, has been very successful in meeting its original goals. The report concludes with a few suggestions to continuously review and evaluate the BIA Pro Bono Project.

10/1/04 AILA Doc. No. 18041842. Detention & Bond, Removal & Relief
Federal Agencies, Liaison Minutes

EOIR Responses to AILA's Liaison Questions (9/30/04)

Liaison issues addressed with EOIR included local court rules, payment of fees, St. Cyr relief, publication of decisions, prima facie removability, judicial performance, video hearings, venue changes, "front desking", FOIA, impact of ICE's detention program, and EOIR's pro bono program.

9/30/04 AILA Doc. No. 04110113. Asylum, Crimes, Detention & Bond, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Affirms Dismissal of Post-Removal Detention Habeas Petitions Filed Before the 90-Day Removal Period Expired (Updated 11/8/04)

The court held that habeas petitioners whose removal is not reasonably foreseeable cannot raise a colorable due process claim for release until the 90-day removal period has expired. (Khoutesouvan et al. v. Morones, 10/27/04)

9/13/04 AILA Doc. No. 04100572. Detention & Bond, Removal & Relief
AILA Public Statements, Memo & Regulatory Comments

AILA/AILF Comments on the DHS/DOJ Joint Proposed Rule Regarding Execution of Removal Orders

AILA and AILF oppose the DHS/DOJ joint proposed regulations to remove the requirement that acceptance by a country is not required for removal to that country, and that "country" does not require the existence or functionality of a government.

8/18/04 AILA Doc. No. 04081960. Detention & Bond, Removal & Relief