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
2,076 - 2,100 of 2,120 collection items
Federal Agencies, Agency Memos & Announcements

ICE’s Detention Operations Manual (2000)

A 2000 version of ICE’s Detention Operations Manual.

9/1/00 AILA Doc. No. 17031430. Detention & Bond, Removal & Relief
Federal Agencies, FR Regulations & Notices

INS Proposed Regulation on Indefinite Detention

INS proposed rule for review process governing detention of persons ordered removed but whose removal has not been effected within 90 days. Comments are due by 7/31/00. (65 FR 40540, 6/30/00)

6/30/00 AILA Doc. No. 00063001. Detention & Bond, Removal & Relief
Federal Agencies, Liaison Minutes

INS Enforcement Liaison Minutes (6/2/00)

Topics covered in a liaison meeting between AILA and INS Enforcement included prosecutorial discretion, problems with district offices ignoring G-28s, ASC processing for expiring green cards, and NAFTA adjudication issues.

Federal Agencies, Agency Memos & Announcements

INS Interpretation of Detention & Release Provisions

INS General Counsel addresses the circumstances under which non-criminal, criminal and 'terrorist' aliens subject to final removal orders should be detained. The impact of delay of removal periods is among the topics discussed.

3/16/00 AILA Doc. No. 00051001. Detention & Bond, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Upholds Decision to Detain Respondent Post-Order

The BIA upheld the district director’s determination to continue post-deportation order detention, after holding that it had jurisdiction over the respondent’s appeal, and that the respondent was eligible for release under INA §241(a)(6). (Matter of Saelee, 2/25/00)

2/25/00 AILA Doc. No. 00032478. Detention & Bond, Removal & Relief
Federal Agencies, Practice Resources

INS General Counsel List of Resolved Issues

The INS General Counsel has provided a list of 21 issues that have been resolved through AILA liaison. Among other things, various unlawful presence and 245(i) questions are addressed.

EOIR Report: Evaluation of the Rights Presentation

During FY1998, the EOIR funded a short-term pilot project designed to augment the due process information detainees receive from immigration judges. Three nonprofit organizations provided daily “rights presentations” to INS detainees. This report provides a summary of the evaluation findings.

11/30/99 AILA Doc. No. 17060162. Detention & Bond, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA on Transition Period Custody Rules

The BIA held that INA 236(c) does not apply to aliens whose most recent release from custody by an authority other than the INS occurred prior to the expiration of the Transition Period Custody Rules. (Matter of Adeniji, 11/3/99)

11/3/99 AILA Doc. No. 99120676. Detention & Bond, Removal & Relief
Cases & Decisions, AAO Cases

AAO Declares Bond Breached When Subject Failed to Appear

AAO dismissed the obligor’s appeal, upholding the breach of a $3,500 delivery bond after the obligor failed to present the bonded alien for removal.

8/30/99 AILA Doc. No. 00011472. Detention & Bond, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA on Mandatory Detention of LPRs

The BIA held that an LPR will not be considered "properly included" in a mandatory detention category when the IJ or the BIA finds that it is substantially unlikely that the INS will prevail on a charge of removability. (Matter of Joseph, 5/28/99)

5/28/99 AILA Doc. No. 99060240. Detention & Bond, Removal & Relief
Federal Agencies, Agency Memos & Announcements

EOIR Memo on Electronic I-830

EOIR memorandum 99-4 announcing that EOIR has agreed to accept the electronic transmittal of Form I-830, Notice to EOIR: Alien Address, effective 5/1/99, formalizing the use of e-mail to notify the immigration courts and BIA of any change in an individual’s custody status while a case is pending.

4/30/99 AILA Doc. No. 99043099. Detention & Bond, Removal & Relief
Federal Agencies, Agency Memos & Announcements

New Mandatory Review Policy For INS Long-Term Detainees

INS April 30, 1999, Statement by Commissioner Meissner on INS policy for mandatory review of long-term detainees.

4/30/99 AILA Doc. No. 99050459. Detention & Bond, Removal & Relief
Cases & Decisions, Federal Court Cases

District Court Can Review Detention Claim

Review of claims regarding INS's use of ex parte secret evidence must be sought in the appeals court after the issuance of a final order, but under IIRIRA's transitional regime, habeas jurisdiction exists in district court to review the detention-related claims. (Haddam v. Reno, 4/28/99)

4/28/99 AILA Doc. No. 99042890. Detention & Bond, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA on Mandatory Detention and Effect of Filing EOIR-43

The BIA held that the filing of Form EOIR-43 by the INS automatically stays an IJ's order releasing an alien who is charged under INA 236(c)(1), even where the IJ terminated proceedings after finding the alien is not subject to 236(c)(1). (Matter of Joseph, 4/23/99)

4/23/99 AILA Doc. No. 99050456. Detention & Bond, Removal & Relief
AILA Public Statements, Correspondence

AILA Letter on AEDPA Section 440(d)

Letter from AILA to Attorney General Reno urging her to take immediate action in light of the recent U.S. Supreme Court decision (on March 8, 1999) declining review of lower court decisions which diverged from the opinion in Matter of Soriano with regards to AEDPA Section 440(d).

4/15/99 AILA Doc. No. 99042159. Detention & Bond, Removal & Relief
Federal Agencies, Practice Resources

Draft INS Memo on Access to Legal Representation

A 3/1/99 draft INS memo regarding detainee access to legal representation.

3/1/99 AILA Doc. No. 99031780. Detention & Bond, Removal & Relief
Federal Agencies, Agency Memos & Announcements

INS Advises on Detention Procedures

A 2/3/99 memo from Michael Pearson, Executive Associate Commissioner (INS) clarifying the authority of District Directors to make release decisions and emphasizing the need to provide a review of administratively final order detention cases.

2/3/99 AILA Doc. No. 99030580. Detention & Bond, Removal & Relief

Human Rights Watch Report on Detention of Unaccompanied Minors

A 12/22/98 Human Rights Watch report finds that the INS violated the rights of unaccompanied children in its custody.

Federal Agencies, Agency Memos & Announcements

INS Memo with New Detention Guidelines

A 10/7/98 memo from Michael Pearson, Executive Associate Commissioner (INS) providing instructions on the application of the new detention guidelines.

10/7/98 AILA Doc. No. 98100791. Detention & Bond, Removal & Relief
Cases & Decisions, Federal Court Cases

District Court Rules on Motion in Case Involving Detainee Mistreatment

The government's motion to dismiss was granted in part and dismissed in part in a case brought by asylum seekers alleging mistreatment while being detained in an Elizabeth, New Jersey immigration detention facility. (Jama v. INS, 10/1/98)

10/1/98 AILA Doc. No. 98100159. Detention & Bond, Removal & Relief
Cases & Decisions, Federal Court Cases

CA2 Finds Habeas Jurisdiction for Aliens “in Custody”

The court held that the federal courts have jurisdiction under 28 USC §2241 to grant writs of habeas corpus to aliens when those aliens are “in custody in violation of the Constitution or laws or treaties of the United States.” (Henderson v. INS, 9/18/98)

9/18/98 AILA Doc. No. 98092880. Detention & Bond, Removal & Relief
Federal Agencies, FR Regulations & Notices

INS Proposed Rule on Juvenile Processing after Flores v. Reno

INS proposed rule to establish the procedures for processing juveniles in Service custody. The new rule sets guidelines for the release of juveniles from custody and the detention of unreleased juveniles in state-licensed programs and detention facilities. (63 FR 39759, 7/24/98)

Federal Agencies, FR Regulations & Notices

DOJ Final Rule on Criminal Detention under IIRAIRA

DOJ final rule amending the regulations of the INS and the EOIR to establish a regulatory framework for the detention of criminal aliens pursuant to the Transition Period Custody Rules set forth in IIRIRA. Effective 6/18/98. (63 FR 27441, 5/19/98)

5/19/98 AILA Doc. No. 98051958. Crimes, Detention & Bond, Removal & Relief
Federal Agencies, Liaison Minutes

EOIR Liaison Meeting Minutes (4/30/98)

EOIR liaison minutes from an April 30, 1998 liaison meeting between AILA and the Executive Office for Immigration Review (EOIR), topics include NACARA/suspension issues, detention and bond, asylum, attorney conduct, and process issues.

Cases & Decisions, Federal Court Cases

Court Dismisses Bond Redetermination Case for Failure to Exhaust

The court dismissed the habeas petition without prejudice to give the BIA the opportunity to rule on the government's appeal of the IJ's decision that Petitioner was entitled to a bond redetermination hearing. (Thompson v. INS, 4/3/98)

4/3/98 AILA Doc. No. 98040358. Detention & Bond, Removal & Relief