Florence Project Six Month Report: Ongoing Complaints and Systemic Issues in Arizona Adult Immigration Detention Centers

Florence Project Six Month Report:
Ongoing Complaints and Systemic Issues in Arizona Adult Immigration Detention Centers 


The Florence Immigrant & Refugee Rights Project (The Florence Project/FIRRP) is a 501(c)(3) non-profit organization that provides free legal and social services to the thousands of adults and children detained in immigration custody in Arizona. The Florence Project was founded in 1989 to provide free legal services to asylum seekers and other migrants in a remote immigration center in Florence, Arizona where there was no meaningful access to counsel. In our more than 30 years of experience, we have expanded significantly, and we now provide free legal and social services to detained adults and unaccompanied children throughout Arizona.  

The expansion of free legal and social services has given the Florence Project the capacity to hear and file complaints to the DHS Office of the Immigration Detention Ombudsman (OIDO), the DHS Office of Civil Rights and Civil Liberties (CRCL), and the DHS Office of the Inspector General (OIG) on behalf of our detained clients. The Florence Project has placed a priority on tracking complaint trends and common issues in detention, especially as they relate to abusive treatment, poor access to healthcare, and failure to accommodate disabilities. Despite numerous complaints to oversight agencies, systemic, inhumane conditions and treatment continue to negatively affect those detained in Arizona detention centers. 

Submitted Complaints from September 2023 to February 2024 

The Florence Project continues to file complaints to the oversight agencies CRCL, OIDO, and OIG. 

This month we sent those agencies a comprehensive complaint letter detailing worsening conditions over the last several months in the Eloy Detention Center (EDC), the Central Arizona Florence Correctional Center (CAFCC), and the Florence Detention Center (FDC). Along with the complaint, we included a letter written by a woman at EDC detailing 35 complaints impacting health and safety, a letter written by a man at CAFCC noting several complaints impacting health and safety, which was signed by an additional 107 men inside the facility, and a letter from a man at FDC detailing his traumatic and abusive experience while detained. 

Detention Conditions  

The Florence Project continues to hear reports and file complaints regarding abhorrent detention conditions, including excessive lockdowns, increased commissary prices of basic necessities, and unsanitary and unhygienic living conditions. 

Excessive Lockdowns 

The Florence Project first filed complaints for two individuals regarding excessive lockdown times around October 2022. Since that time, we have continued to hear reports of excessive lockdowns, which have become worse in recent months, especially around the December holidays and New Year. Many people have reported to the Florence Project that they have been told by staff that the lockdowns are due to severe staffing shortages that cannot seem to be remedied. 

The excessive lockdowns have resulted in numerous violations of ICE’s Performance-Based National Detention Standards (PBNDS), which states, “[i]f outdoor recreation is available at the facility, it shall be offered at a reasonable time of day. Weather permitting, each detainee shall have access for at least one hour per day, five days per week; or, six or more hours per week, at least four days per week,” and “Exercise areas shall offer a variety of fixed and movable equipment.” 

During lockdowns, individuals are held in their cell for hours at a time, without access to recreation, showers, phones, or other sources of entertainment in the common area. We have heard reports from several women in EDC that their pods are sometimes not given recreation for several days. When women are given recreation time, they often only have 30 minutes to an hour per day. Some pods only have access to a small outdoor patio for recreation, where they can walk around but cannot run or play any sports. 

Women in the pods also only have a few hours a day to shower and use the phone. One woman reported that she was not allowed to use the phone to call her Florence Project attorney, who had requested a call on a specific date and time. She was told that she had to wait and was not allowed to call her attorney until the following day. This action violates the ICE PBNDS, which state that “[t]he facility shall provide detainees with reasonable and equitable access to telephones…” and “The facility shall not restrict the number of calls a detainee places to his or her legal representatives or to obtain representation.” 

 Given that there are very few forms of entertainment or social contact that women can have in their cells, excessive lockdowns have resulted in negative mental health consequences for many of the women in EDC. Women have described other women in their pod who spent hours crying and banging on their cells, asking to be let out. 

Unsanitary and Unhygienic Living Conditions 

In both EDC and CAFCC there have been reports from individuals about the unsanitary conditions of the toilets and showers. Showers and toilets are often clogged, resulting in toilets overflowing and people being forced to stand in several inches of stagnant water while showering. The areas smell like feces and sewage water. One woman in EDC noted specifically that the area for new arrivals and transfers is particularly unsanitary, with dried, caked-on feces inside and around the toilets, and women forced to sleep on the dirty floor when they are there for multiple hours or overnight. This violates the ICE PBNDS that state, “[s]pills of blood and body fluids will be cleaned up and the surface decontaminated in such a manner as to minimize the possibility of workers becoming exposed to infectious organism,” and “[w]hen the last detainee has been removed from the hold room, the room shall be given a thorough cleaning and safety inspection.” 

Mattresses and uniforms are old and falling apart. One woman in EDC reported that in December the unit manager told her that all of the mattresses that needed to be replaced but they have yet to be replaced. The dryer does not properly dry clothes, so towels and uniforms are often given back to people still damp and smelling of mildew. Women have reported that undergarments are also worn out and often returned damp, prompting concerns for yeast infections and other types of infections. This violates the ICE PBNDS. which states, “[t]he facility shall have a policy and procedure for the regular issuance and exchange of clothing bedding, linens, and towels,” “At no cost to the detainee, all new detainees shall be issued clean, indoor/outdoor, temperature-appropriate, presentable clothing during in-processing…Additional clothing shall be issued as necessary for changing weather conditions, or as seasonally appropriate,” and “Detainees shall be provided with clean clothing, linens, and towels on a regular basis to ensure proper hygiene. Socks and undergarments will be exchanged daily, outer garments at least twice weekly and sheets, towels, and pillowcases at least weekly.”  

At both EDC and CAFCC we have heard reports that entire pods are forced to share one nail clipper, which has prompted concerns of passing skin infections or blood-borne infections if someone cuts their skin. 

Inhumane Treatment 

Individuals in FCC and EDC have reported inhumane treatment, particularly concerning lack of clothes in extreme temperatures and excessive wait times for court. 

Several articles of clothing and hygiene are not provided in EDC. During the cold months, sweatshirts and sweatshirts can only be bought from commissary, a violation of the PBNDS’s requirements that weather-appropriate clothing be issued “at no cost to the detainee.” Waterproof jackets are also not provided, and individuals are forced to walk from building to building in the rain with no ability to dry off. People arriving at EDC are also not issued deodorant, which must be bought from commissary. Clients have reported consistent “shake downs” at EDC, where guards search through the individuals’ cells and count their bras, underwear, flip flops, shirts, etc. 

At CAFCC there have also been reports that individuals are only allowed to wear their jackets in their housing unit and cannot wear them while waiting in holding cells or on the bus for court or while in the medical or visitation areas. CAFCC also does not provide any thermal shirs or sweatshirts, which are only available for purchase from the commissary. Despite the heat during the summer, the winter months, especially late at night and early in the morning when people are brough to court, can dip below freezing.  

At CAFCC individuals who have court at 8:30am and 2:30pm are woken up between 1:30am and 2:30am and placed in holding cells. Individuals are not allowed to bring their jackets despite cold temperatures outside and in the holding cells. They have their hands and feet cuffed until about 5:00am when they are taken to the Florence Detention Center (FDC) for their court hearings. Once they arrive at FDC, they are forced to wait on the bus without jackets, still with their hands and feet cuffed, for about another hour. As previously stated, temperatures in the early mornings in the winter can dip below freezing. Once inside, everyone must wait in another holding cell without jackets at FDC both before and after their court hearings. Everyone is then brought back to FCD between 5:00pm and 7:00pm. Many individuals have reported that, because they are woken up so early and wait so long in extreme conditions, they are at a point of exhaustion by the time they get to their court hearing. This violates the ICE PBNDS’s policy on “Use of Four- or Five-Point Restraints,” which prohibits cuffing for extended periods of time. 

The Florence Project has confirmed that commissary prices in EDC have gone up significantly including prices for snacks, that many people rely on due to the innutritious diet. One woman in EDC reported that she was informed by staff that commissary prices went up to pay for broken items, such as televisions, in the detention center. 

Delays or Denials of Disability Accommodations and Medical Equipment

The Florence Project continues to see delays and obstacles for individuals who need glasses and confusion regarding when and how someone can get medical equipment. 

The Florence Project filed a comprehensive complaint for Ms. M to assist in accessing glasses after four months of detention. Ms. M was detained in EDC with contacts and forced to wear the same pair for several months before receiving glasses. Ms. M asked medical staff repeatedly for glasses and extra contacts, noting that she was experiencing eye pain from wearing the same pair of contacts and washing them only in water. After about a month, Ms. M was finally povided with contact solution to wash her contacts, but she was only provided open cups to wash them in, not a closed, sanitary contact case.  

Ms. M was informed by medical staff that her family could send her contacts, in accordance with facility policy, or they could order and send her glasses from a specific manufacturer, but they could not send her glasses from home. However, she was told that the facility would not provide her with glasses, contacts, or an optometry appointment. Her family did not have the financial means to buy and send her more contacts or buy her new glasses from the specific manufacturer. Eventually, one of her contacts ripped and for months she wore only one contact lens.  

The Florence Project tried to assist Ms. M to figure out how she could order and receive new glasses. The Florence Project legal team emailed her ICE Deportation Officer who responded, “IHSC [ICE Health Service Corps] does not have a facility policy for medical equipment being sent in – please contact Core Civic.” However, when Ms. M asked the CoreCivic staff in her housing unit, she was told that CoreCivic also does not have a policy for sending medical equipment from home, and they advised her to again ask ICE. Ms. M suffered from a visual impairment unnecessarily for months as a direct result of this lack of clear policy and failure to account for her visual impairment and accommodate her medical needs appropriately. 

In October 2023 the Florence Project worked with a community group to buy new glasses for Ms. M from the specified manufacturer. We then filed a complaint on her behalf, requesting, first, that she be allowed her glasses when they were sent to her through the mail and, second, requesting written policies from ICE and/or CoreCivic regarding sending medical equipment to those detained at EDC. Ms. M was given her glasses that were sent to her. However, to date we have not received any written policies or clarification regarding sending medical equipment.  

The Florence Project has also continued to hear and report that people in EDC and CAFCC do not have access to other basic medical equipment, such as dentures. 

One man in CAFCC also reported that there is only 1 shower that complies with the Americans with Disabilities Act (ADA) for people with disabilities in his pod but that the shower is broken, meaning individuals with accessibility issues cannot use any shower with accommodations. This issue has been ongoing at CAFCC for several years. In 2019 the Florence Project assisted an individual in CAFCC with cerebral palsy, who reported that the only ADA accessible shower in his pod was broken. He requested a shower chair multiple times over several months before finally being provided one. 

Discrimination and Intimidation

Women detained at EDC have reported that their toilets in their cells are very close to the cell door and anyone who walks by, including male guards, can see them using the toilet. This violates ICE PBNDS stating, “Detainees shall be provided with a reasonably private bathing and toileting environment in accordance with safety and security needs. Detainees shall be able to shower, perform bodily functions, and change clothing without being viewed by staff of the opposite gender…”    

One woman also reported that individuals in EDC are strip searched after social visits that allow physical contact. She noted that they were forced to sign a document agreeing to the strip searches and were told that, if they did not sign the document, all future visits would be denied. This violates ICE PBNDS that state, “[s]taff shall not routinely require a detainee to remove clothing or require a detainee to expose private parts of his or her body to search for contraband,” and “[f]Facilities may perform a strip search when an articulable and reasonable suspicion exists that contraband is concealed on the detainee’s person.” Blanket strip search policies fail to meet the requirement of specific and articulable reasonable suspicion.  

There have also been reports from CAFCC and EDC regarding incidents of retaliation and threats of segregation for filing complaints or voicing concerns. One man in FDC reported that the guards in FDC threaten and intimidate detainees and have told him specifically that they will do everything they can to make sure he loses his asylum case. This violates ICE PBNDS’s ban on harassment, which states that, “[s]taff will not harass, discipline, punish, disclose sensitive information about, or otherwise retaliate against a detainee lodging a complaint.” We were also informed in CAFCC that one man was threatened with segregation for helping multiple, non-English speaking men file complaints about construction causing issues in their pod. 

Specialty Medical Care 

The Florence Project continues to hear reports and file complaints of egregious delays or denials in specialty medical care.  

In a recent compliant filed by the Florence Project, we noted the chronic back, shoulder, neck, and arm pain that a man in CAFCC had been experiencing for over two and a half years after a fall at another ICE detention facility. The pain resulted in limited mobility of his right arm and weakness in his legs. Despite multiple sick calls and grievances filed by our client, he did not receive any specialty care to address his limited mobility or chronic pain. In April 2023, he was told he was referred for a neurosurgery consultation for possible surgery but, after 10 months, he still has not seen a specialist. 


Excessive Use of Segregation and Suicide Watch 

We continue to hear reports from EDC and CAFCC regarding overuse of segregation, particularly for suicide watch and mental health observation. Individuals have been left in segregation in CAFCC for weeks or months at a time due to a serious mental illness. 

The Florence Project filed complaints for two women who believed they were wrongly placed on suicide watch, with no clothes other than a “suicide smock.” In one complaint we filed, a woman reported that she was struggling with her mental health but was not suicidal. She noted that medical staff told her if she went to suicide watch she would get a nice, comfortable, quiet room where she could relax, so she agreed. She was then placed in handcuffs, stripped, put in a suicide smock, and placed on suicide watch for three days. The complaint noted that she expressed trauma after being placed on suicide watch that made her more uncomfortable in detention and afraid to express any other mental health concerns. 

At EDC many women have noted their fear to talk with the mental health professionals due to concerns that any mention of mental health symptoms will result in placement on suicide watch. This use of suicide watch violates ICE’s PBNDS, which contemplate and prohibit this exact scenario, stating that, “[d]eprivations and restrictions placed on suicidal detainees must be kept at a minimum. Suicidal detainees may be discouraged from expressing their intentions if the consequences of reporting those intentions result in punitive treatment. Placing suicidal detainees in conditions of confinement that are worse than those experienced by detainees in the general population may result in the detainee not discussing his or her suicidal intentions and falsely showing an appearance of a swift recovery.” 

Responses from CRCL and OIDO

The Florence Project recognizes and appreciates that hard work of CRCL and OIDO to address people’s concerns on the ground inside detention centers with OIDO case managers and in making policy recommendations to ICE.  

While OIDO has addressed complaints in the detention center for some of our clients, some complaints remain outside of OIDO’s ability to address at the ground level in individual detention centers. For instance, excessive lockdowns routinely evade review and redress by OIDO because the widespread use of lockdowns relate to ICE and CoreCivic policy and individual OIDO case managers lack authority to modify broader ICE or prison policies in a manner to remedy the individuals’ complaints.  While OIDO does theoretically have authority to make broader policy recommendations, we have not yet received any responses from OIDO regarding policy recommendations based on our numerous complaints.  

Additionally, we continue to see many of the same types and patterns of complaints repeatedly from many different individuals, even after one person’s complaint may have been addressed, with little to no indication from OIDO about how it plans to more systematically address and prevent such patterns and practices.  In some cases, we have had the same issue reappear for the same individual after it was allegedly “resolved.” For example, we filed two complaints for an individual in FCC with hypertension who was not receiving a diet for health. Despite two separate complaints filed to OIDO, he continued to express that he was not always given a proper diet for health. In other cases, OIDO has marked a complaint as “resolved” when the resolution was only that the individual experiencing the abusive or problematic practice was deported before the issue could be fixed. In one such case, we filed a complaint for a man in CAFCC with diabetes and neuropathic pain who was ordered orthopedic shoes and compression socks from medical staff but never received them in the facility. Before he was provided any assistance from OIDO in accessing these accommodations he was transferred to EDC and shortly after was deported. Likewise, OIDO has not provided information regarding how it tracks such complaint patterns or how it plans to address them through policy recommendations or otherwise.  

CRCL has responded to some of our complaints, noting that they would forward the complaint to OIG for possible further investigation. If OIG declines to investigate, CRCL may then open their own investigation. However, all OIG investigations are private, so we are unaware of how many, if any, of the complaints filed by the Florence Project have been investigated by OIG. 

We received notice from CRCL that in the last half of 2023, they opened investigations into at least nine of our complaints filed in 2023 and 2024. In January 2024 we received notice from CRCL that based on a complaint we filed in February 2023, “CRCL will be issuing recommendations to ICE regarding the provision of eyeglasses to individuals with vision impairments at the CAFCC.” We have yet to see any such recommendations or be informed of any policy with regard to the provision of eyeglasses in the facility. In September 2023, CRCL responded to a complaint we filed in May 2023 informing us that CRCL, “intends to issue recommendations to ICE regarding the provision of shoes to individuals with disabilities who require specialized footwear.” Again, we have not seen nor are aware of any recommendations or changes in policy on this matter.  

While we acknowledge that OIDO has assisted multiple people with their individual complaints and that CRCL has investigated complaints at EDC and CAFCC, reports from our clients establish that conditions are worsening. We are concerned about the deteriorating conditions and ICE and CoreCivic’s apparent lack of concern for people’s well-being. We are also concerned that many of these issues cannot be addressed because of the extreme level of understaffing that has been an ongoing problem for years, specifically since the COVID-19 pandemic. 


Over the past several months we have noticed even more widespread discontent among individuals in detention. Many have expressed fear to speak out against the multiple injustices they are facing. 

We have also noticed several similarities between Arizona’s ICE detention centers and other detention centers that have been forced to close because of multiple abuses and violations of ICE’s standards. EDC and CAFCC suffer from many of the same problems that are noted in the OIG reports from the Torrance Correction Center, such as severe staffing shortages and unsanitary sinks and toilets. EDC and CAFCC also have the same pervasive problems as Adelanto ICE Processing Center, such as delayed and inadequate medical care, and failure to provide basic dental care, unnecessary tooth extractions, etc. There are also several identical issues in the Arizona detention centers that were found in the CRCL 2017 investigation of Adelanto, such as verbal disrespect and harassment by staff and retaliation for voicing grievances. We ask for urgent action to reduce detainee populations at these dangerous facilities, and ultimately close them. 

While CRCL has issued some recommendations and OIDO has resolved some individual complaints, the systemic abuses persist. The Florence Project will continue to document and monitor the inhumane treatment inflicted upon those detained. As one woman in EDC stated, “ICE should not be profiting from people’s pain and suffering.”