Enforcement, Detainers

ARCHIVED ISSUE PAGE (LAST UPDATED JUNE 2013)

Challenging the Use of ICE Immigration Detainers

Under 8 CFR. § 287.7, an “authorized immigration officer” may issue Form I-247, Immigration Detainer – Notice of Action, to a law enforcement agency (LEA) that has custody of an alleged noncitizen. A detainer is a request that an LEA notify ICE prior to releasing the individual so that ICE may make arrangements to assume custody within 48 hours after the person would otherwise have been released.

In June 2011, ICE released a new detainer form [1]. According to ICE, the new form more clearly indicates that state and local authorities may not detain an individual for more than 48 hours; that local law enforcement authorities are required to provide arrestees with a copy of the detainer form, which has a phone number to call if the subject of the detainer believes his or her civil rights have been violated; and that ICE has flexibility to issue a detainer contingent on conviction. It remains to be seen whether changes to the form will resolve longstanding problems with detainers that increasingly have resulted in litigation.

Lawsuits generally have challenged local law enforcement authorities’ unlawful practice of holding noncitizens on expired detainers. Below is a non-exhaustive list of cases that have addressed immigration detainer issues.

California

Roy v. Los Angeles County, No. 12-9012 (C.D. Cal. filed October 19, 2012)

Five individuals filed a class action lawsuit against the County of Los Angeles and L.A. County Sheriff for 1) denying bail to thousands of people who want to post bail and have already obtained a court order setting bail purely on the ground that the federal government has placed an "immigration hold" on them; and (2) denying them release from Los Angeles County jail for 48 hours or more on the basis of the immigration hold, even though all charges against them have been dismissed, they have been acquitted of the charge for which they were being held, they were ordered released, or they have served their sentence. The complaint argues that these practices violate state law, as well as the Fourth and Fourteenth Amendments to the U.S. Constitution, and California’s state law analogues (Cal. Constitution, Articles 1, 7, and 13).

Plaintiffs seek injunctive and declaratory relief on behalf of all individuals currently in the custody of and who, in the future, will be in the custody of the defendants on the basis of the immigration hold (Equitable Relief Class). Plaintiffs also seek to bar Defendants from prolonging the detention of members of the class beyond the time that the state law mandates release solely on the basis of an immigration hold not supported by a probable cause determination.

Complaint [2]

Illinois

Jimenez Moreno v. Napolitano, No. 11-05452 (N.D. Ill. filed Aug. 11, 2011)

Two individuals filed a class action lawsuit challenging ICE’s assertion of authority to instruct law enforcement agencies to detain alleged noncitizens for the sole purpose of investigating their immigration status. Plaintiffs allege violations of the Fourth, Fifth and Tenth Amendments, among other claims.

Plaintiffs seek to certify a class consisting of all current and future persons against whom ICE has issued an immigration detainer from the Chicago Area of Responsibility (AOR); where ICE has instructed the LEA to detain an alleged noncitizen for longer than 48 hours; and where ICE has indicated that the basis for continued detention is to investigate the person’s removability. The class does not include noncitizens subject to mandatory detention.

On October 14, the government moved to dismiss. On December 16, 2011, plaintiffs filed an opposition to the motion to dismiss, to which the government filed a response on January 17, 2012. Motions for class certification have been held in abeyance until the court rules on the pending motion to dismiss. Plaintiffs amended their complaint on May 1, 2013, seeking declaratory and injunctive relief under the Administrative Procedures Act, and the Fourth, Fifth and Tenth Amendments for the ongoing violation of their rights, or, in the alternative, habeas corpus relief. ICE responded by denying that the Plaintiff are entitled to such relief. The parties are currently in discovery.

Louisiana

Cacho v. Gusman, No. 11-0225 (E.D. La. filed February 2, 2011)

Two Louisiana residents filed suit to challenge Orleans Parish Sheriff Marlin N. Gusman’s policy and practice of detaining them and other New Orleans residents for indefinite periods without legal authority. The complaint alleges that the sheriff held the plaintiffs for approximately 164 and 91 days after the expiration of their respective ICE detainers, in violation of their Fourth, Fifth, and Fourteenth Amendment rights and that they were falsely and negligently imprisoned in violation of state law. They seek declaratory relief, damages and attorneys’ fees. On May 21, 2012, the court continued plaintiffs Motion to Compel Production without a date because parties reported they were involved in settlement discussions.

Plaintiff’s Complaint [9]

Pennsylvania

Galarza v. Lehigh County, No. 12-3991 (3d Cir. filed Nov. 19, 2010)

A U.S. citizen filed suit against individual ICE officers, local law enforcement officers, the City of Allentown, Lehigh County, and various city and county officials, alleging that he was unlawfully held for three days on an immigration detainer. The complaint alleges, among other things, that defendants violated the plaintiff’s Fourth, Fifth, and Fourteenth Amendment rights when they, issued a detainer without probable cause that plaintiff was an “alien” subject to detention and removal and based solely on plaintiff's Hispanic ethnicity. Plaintiff seeks damages and attorneys’ fees.

On April 6, 2011, plaintiff filed an Amended Complaint and on April 25, 2011, Lehigh County, the City of Allentown, and individual defendants filed motions to dismiss. On August 3, 2011, plaintiff filed a related lawsuit against the United States under the Federal Tort Claims Act for false arrest, false imprisonment, and negligence. On November 4, 2011, the two cases were consolidated under 10-6815. On March 30, 2012, the court issued an order granting in part and denying in part defendants’ motions to dismiss. The court ruled, inter alia, not to dismiss equal protection and Fourth Amendment claims against several defendants. Mr. Galarza settled his claims against the individual defendants, the City of Allentown, and the United States and the district court issued a final order dismissing the case as to all defendants on September 19, 2012.

On March 19, 2013, Plaintiff appealed the March 30, 2012 order and opinion of the court granting Lehigh County’s Motion to Dismiss. Plaintiff argued that 1) the district court erred in dismissing Plaintiff Ernesto Galarza’s Fourth Amendment claim against Defendant Lehigh County where, pursuant to the County’s policy and practice, County officials imprisoned Plaintiff, a U.S. citizen, for three days solely because he was named on a federal immigration “detainer” form, even though the form did not purport to be supported, and was in fact unsupported, by probable cause; and 2) the district court erred in dismissing Plaintiff’s Fourteenth Amendment due process claim against Defendant Lehigh County where the County did not notify Plaintiff of the reason for his detention and denied him an opportunity to respond or contest the validity of the detainer. Lehigh County responded by arguing that it had adopted a policy of following established federal law as it pertains to immigration detainers and that plaintiff failed to establish that the County’s policy of detaining individuals pursuant to immigration detainers caused a deprivation of Plaintiff’s constitutional rights.

Rhode Island

Morales v. Chadbourne, No. 12-0301 (D.R.I. filed April 24, 2012)

A naturalized U.S. citizen who was erroneously detained by Rhode Island law enforcement officials on immigration detainers—twice—filed a lawsuit against federal and state defendants, alleging violations of her Fourth Amendment and due process rights and her rights under state law.

Plaintiff asks to court to, inter alia, 1) issue permanent injunctions against ICE defendants, prohibiting them from issuing detainers against plaintiff in the future, or otherwise causing her to be illegally detained as an alleged deportable “alien”; 2) issue permanent injunctions against Rhode Island Defendants, prohibiting them from detaining plaintiff on the basis of an immigration detainer; 3) issue a declaration that ICE Defendants violated the Constitution and federal law; 4) issue a declaration that Rhode Island defendants violated the Constitution; 5) award compensatory and punitive damages against all individual Defendants in their capacities for violations of federal and state law; and 6) award compensatory damages against the United States under the FTCA.

Amended Complaint [16]

Utah

Uroza v. Salt Lake County, No. 11-0713 (D. Utah. filed Aug. 5, 2011)

A college student brought suit against the county and its employees challenging the county’s policy and practice of holding certain individuals beyond the 48-hour period permitted by an immigration detainer in violation of the Fourth, Fifth, and Fourteenth Amendments and the state constitution. After posting bond, plaintiff was held in county jail pursuant to an ice detainer for an additional 39 days. He seeks declaratory judgment, compensatory damages, and attorneys’ fees.

Defendants answered the complaint on August 29, 2011. On March 26, 2012, plaintiffs filed an amended complaint, and on April 23, 2012, the defendants answered the amended complaint. On June 11, 2012, the federal defendants filed a motion to dismiss.

Plaintiff’s Complaint [17]
Memorandum of Law in Support of Federal Defendants' Motion to Dismiss [18] [18]

Closed Cases

California

Comm. for Immigr. Rights of Sonoma County v. County of Sonoma, No. 08-4220 (N.D. Cal. filed Sept. 8, 2008) (CASE CLOSED)

An immigrant rights organization and three individual plaintiffs filed suit against ICE and the County of Sonoma (County) to challenge their policies of arresting and detaining individuals suspected of immigration violations. The complaint alleges, among other things, that ICE agents and Sonoma County police officers use race as a motivating factor for traffic stops and other detentions; stop, interrogate, search and arrest persons without adequate justification; and hold individuals in the County jail without any lawful basis for detention. Plaintiffs allege violations of their constitutional rights under the Fourth, Fourteenth and Fifth Amendments and violations of federal and state law. Plaintiffs seek declaratory and injunctive relief, damages and attorneys’ fees.

On July 28, 2009, the district court granted in part and denied in part defendants’ motions to dismiss and granted plaintiffs leave to amend their complaint. On September 14, 2009, plaintiffs filed an amended complaint. In a March 10, 2010 order, the district court again granted in part and denied in part defendants’ motions to dismiss. The court found ICE’s use of detainers lawful because “the plain language of § 287.7 authorizes, and does not preclude, the issuance of immigration detainers for individuals who are not already in arrest.” However, the court refused to dismiss plaintiffs’ constitutional claims.

The parties initiated settlement negotiations, and at a mandatory settlement conference on March 4, 2011, individual plaintiffs and the federal defendants finalized a settlement agreement. On May 25, 2011, all plaintiffs reached a global settlement agreement in principle with the County defendants, and on June 1, 2011, plaintiff Committee for Immigrant Rights for Sonoma County (CIRSC) ratified the agreement in principle.

The district court issued an opinion on June 16, 2011, affirming the denial of plaintiffs’ motion for a global protective order that would have precluded the use of other immigration status-related information outside the context of the litigation. The court ordered the parties to resume meet and confer negotiations regarding the form of a general protective order governing discovery in the action.

On July 22, 2011, and August 25, 2011, and December 12, 2011 the court stipulated to the dismissal of all plaintiffs’ claims against all defendants pursuant to the parties’ settlement agreements.

Colorado

Quezada v. Mink, No. 10-0879 (D. Co. filed Apr. 21, 2010) (CASE CLOSED)

A Colorado resident brought suit against Jefferson County Sheriff Ted Mink alleging that the sheriff illegally detained him for 47 days on an expired ICE detainer. In his Third Amended Complaint filed on December 16, 2010, Quezada included individual ICE employees and the United States as defendants. Plaintiff Quezada alleged violations of the Fourth and Fourteenth Amendments as well as false imprisonment and negligence claims.

On May 13, 2011, the Court dismissed all claims against the United States of America. On June 3, 2011, plaintiff Quezada and defendant Mink entered into a voluntary settlement fully resolving the dispute and stipulated to dismissal of the action, with prejudice, and with no award of fees or costs to either party.

Connecticut

Brizuela v. Feliciano, No. 12-0226 (D. Conn. filed Feb. 13, 2012) (CASE CLOSED)

A Connecticut resident, represented by students in Yale Law School’s immigration clinic, filed a representative habeas petition and class action complaint challenging the Connecticut Department of Corrections’ practice of holding individuals after their lawful state custody has expired solely on the basis of an immigration detainer. The suit was filed on behalf of the petitioner and all similarly situated individuals currently in custody of, and in future custody of, the Connecticut Department of Corrections. The suit alleges violations of the Fourth, Tenth, and Fourteenth Amendments and seeks declaratory and injunctive relief. Petitioner also filed a motion for class certification or representative habeas action on February 13, 2012. In light of DHS’ imminent plan to activate Secure Communities in Connecticut, on February 22, 2012, Petitioner filed a motion seeking the court to order Respondents to show cause why the writ should not issue and why declarative and injunctive relief should not be granted. On March 21, 2012, plaintiffs moved to certify the constitutional challenge to the Attorney General. After the lawsuit was filed, the Department of Corrections implemented new policies regarding the detention of individuals pursuant to ICE detainers. The parties reached a settlement agreement on February 19, 2013, which outlined new Department of Corrections policies requiring ICE to 1) issue a Notice of ICE detainer and Rights to the inmate; 2) hold an ICE detainee only if he/she is subject to a prior order of removal or meets one of the dangerousness criteria; 3) detain an individual who is not subject to a prior order of removal and meets none of the dangerousness criteria only in rare circumstances; 4) track each ICE detainee and record data related to all persons against whom immigration detainers are lodged; 5) and conduct periodic audits of all facilities where ICE detainees are held for compliance with the procedures set forth in the settlement. The Settlement Agreement will terminate and no longer be enforceable on February 2, 2017.

Florida

Bernabe v. Kronberg, No. 10-22829 (S.D. Fla. filed Aug. 5, 2010) (CASE CLOSED)

An individual held on an expired ICE detainer filed a habeas petition alleging that the sheriff’s office had unlawfully detained him in excess of 48 hours. Following his transfer to ICE custody, the plaintiff amended his petition to state that his continued detention violated his Fourth, Tenth, and Fourteenth Amendment rights.

On September 19, 2010, the court dismissed the case after receiving petitioner’s status report indicating that he had been released from custody. The stipulated dismissal stated that the Miami Dade County Department of Corrections had issued a new written directive that “all relevant detainees be released, consistent with their interpretation of the federal guideline, and not be held longer than 48 hours.”

Plaintiff’s Amended Complaint [33]
Sept. 17, 2010 Status Report [34]

Florida Immigration Coalition v. Palm Beach County Sheriff, No. 09-81280 (S.D. Fla. filed Sept. 3, 2009) (CASE CLOSED)

Three Florida immigrant rights organizations and an individual plaintiff filed a habeas petition and complaint seeking to enjoin the policies and practices of the defendant, Palm Beach County Sheriff, that result in confinement of pre-trial detainees for longer than the statutorily permitted 48 hours. The individual plaintiff was held by the Palm Beach County sheriff for more than five months. The complaint alleged that the defendant’s policies of not releasing individuals subject to an ICE detainer on bond and holding individuals subject to detainers for longer than 48 hours violated plaintiffs’ rights under the Fourteenth and Fourth Amendments.

The court granted the defendant’s motion for summary judgment on October 28, 2010 and ordered the case closed. Plaintiffs appealed the case to the Eleventh Circuit and the court later granted plaintiffs’ motion to dismiss the appeal voluntarily with prejudice.

Plaintiff’s Complaint [35]
Defendant’s Motion for Summary Judgment [36]
Order on Motion for Summary Judgment [37]

Cote v. Lubins, No. 09-0091 (M.D. Fla. filed Feb. 23, 2009) (CASE CLOSED)

A Florida resident filed a habeas petition challenging her detention at the Lake County Jail where she had been held for one week without charges and without the opportunity to be heard. The complaint alleged, among other things, that the plaintiff’s arrest without a warrant and her detention without charges or a hearing violated her rights under the Fourth and Fourteenth Amendments. Plaintiff further alleged that Form I-247 did not authorize her detention.

On February 23, 2009, the same day plaintiff filed her complaint, the court issued an Order to Show Cause. The following day, respondents transferred the plaintiff to ICE custody. ICE released the plaintiff on March 5, 2009. The district court granted the plaintiff’s motion to voluntarily dismiss her habeas petition on March 25, 2009.

Emergency Petition for Writ of Habeas Corpus [38]

Indiana

Jimenez v. United States, No. 11-1582 (S.D. Ind. filed Nov. 30, 2011) (CASE CLOSED)

A U.S. Citizen who was unlawfully held for three days pursuant to an ICE detainer and denied bond filed suit against unknown individual ICE officers and the United States. The complaint alleges violations of plaintiff’s Fourth Amendment rights and includes claims under the Federal Tort Claims Act for negligence, false imprisonment, and other torts. The plaintiff seeks compensatory damages and other proper relief.

On February 27, 2012, defendants filed an answer to the complaint. On April 24, 2012, all parties stipulated to dismissal based on settlement of the claim.

Plaintiff’s Complaint [39]

Melendrez Rivas v. Martin, No. 10-0197 (N.D. Ind. filed June 16, 2010) (CASE CLOSED)

An individual filed suit against the LaGrange County Sheriff and jail administrators for holding her on an ICE detainer for ten days after she posted bond. The complaint alleged that Rivas’ detention violated her rights under the Fifth and Fourteenth Amendments. She is seeking injunctive relief, damages and attorneys’ fees.

On March 18, 2011, the district court denied defendants’ motion to dismiss for failure to state a claim, finding that plaintiff had sufficiently stated a claim for violation of her due process rights. On September 1, 2011, the parties stipulated to dismissal with prejudice of all claims against the defendant. The case was formally dismissed on September 6, 2011.

Louisiana

Ocampo v. Gusman, No. 10-4309 (E.D. La. filed Nov. 12, 2010) (CASE CLOSED)

An individual filed a habeas petition challenging his 95-day detention in Orleans Parish Prison, pursuant to an immigration detainer. The petitioner alleged violations of his Fourth, Fifth, and Fourteenth Amendment Rights. In addition to habeas relief, the petitioner requested declaratory relief and attorneys fees. The petitioner simultaneously filed a motion for a temporary restraining order requesting the court to 1) enter an order declaring that transfer subject to an expired detainer would be unlawful; and 2) restrain respondents from any lawful but discretionary transfer to ICE custody during the pendency of his writ petition. The court granted the petitioner habeas relief on November 15, 2010, ordering his immediate release.

Missouri

Keil v. Triveline, No. 09-3417 (W.D. Mo. filed Nov. 6, 2009) appeal docketed, No. 11-1647 (8th Cir., Mar. 24, 2011)(CASE CLOSED)

A U.S. citizen sued individual ICE officers and a Department of State official alleging that they violated his Fourth and Fifth Amendment rights by unlawfully arresting and holding him in a county jail pursuant to an ICE detainer. He sought damages and attorneys’ fees.

On January 6, 2011, the district court granted defendants’ motions for summary judgment, finding, among other things, that plaintiff’s Fourth Amendment claim failed because defendants had probable cause to arrest plaintiff for falsely claiming U.S. citizenship and misusing a U.S. passport. The court also found that the plaintiff could not state a Fourth Amendment claim based on the defendants’ issuance of a detainer, as there was no evidence that the detainer had served as a basis for the plaintiff’s arrest.

Plaintiff filed a notice of appeal to the U.S. Court of Appeals for the Eighth Circuit in March 2011. Oral argument took place on September 22, 2011. The Eighth Circuit affirmed the lower court decision in an opinion dated November 21, 2011, finding that the immigration agents had at least arguable probable cause to arrest Keil for one or more violations of federal law.

Plaintiff’s Complaint [46]
Order on Defendants’ Motion for Summary Judgment [47]
Appellant’s Opening Brief [48]
Appellee’s Opposition [49]
Appellant’s Reply Brief [50]
Eighth Circuit Decision [51]

New York

Harvey v. City of New York, No. 07-0343 (E.D.N.Y. filed Jan. 16, 2007) (CASE CLOSED)

A pro se plaintiff filed suit against the City of New York and employees of the Department of Corrections after he was twice held at Rikers Island pursuant to ICE detainers for a total of more than 140 days. An amended complaint was filed by plaintiff’s legal representatives on October 30, 2008 alleging violations of plaintiff’s First, Fourth, Fifth, Sixth, and Fourteenth Amendment rights and federal law. The complaint sought damages, injunctive relief, and attorneys’ fees.

Defendant City of New York filed an answer to the third amended complaint on December 22, 2008. The parties settled the case for $145,000 and the case was dismissed on June 12, 2009.

Pennsylvania

Urbina v. Rustin, No. 08-0979 (W.D. Pa. filed July 11, 2008) (CASE CLOSED)

Two individuals filed a habeas petition and class action suit against the Warden of Allegheny County Jail challenging their continued detention pursuant to ICE detainers and alleging violations of the Fourteenth Amendment. The District Court issued an order to show cause on July 14, 2008. The United States responded to the habeas petition and show cause order on July 21, 2008, arguing that the adult and minor plaintiffs were in the lawful custody of ICE and HHS Unaccompanied Children’s Services, respectively, and were not at present being held under an immigration detainer. Plaintiffs filed a motion for class certification on July 23, 2008, seeking to certify a class consisting of all who are or will be detained in the Allegheny County Jail based solely on an immigration detainer and without the opportunity to object to their detention. The same day, the district court denied the habeas petition as moot, dismissed the action, and denied the motion for class certification because ICE had assumed custody of both petitioners.

Petition for Writ of Habeas Corpus [54]

Tennessee

Ramos-Macario v. Jones, No. 10-0813 (M.D. Tenn. filed Aug. 30, 2010) (CASE CLOSED)

A Tennessee resident brought a class action lawsuit against the Rutherford County Sheriff's Office, the Rutherford County Sheriff, and other individual employees of the Sheriff’s Office- alleging he was unlawfully detained for four months pursuant to an ICE detainer after he was otherwise eligible for release. He alleges, among other things, that his illegal seizure and prolonged detention violated his constitutional rights and state law. He seeks to represent a class that includes prisoners of Rutherford County Jail who were detained unlawfully pursuant to detainers. Plaintiff seeks declaratory and injunctive relief, damages and attorneys’ fees.

On March 3, 2011, the court dismissed Ramos-Macario’s federal and state law claims against Sheriff Jones and one of his chief deputies. The court denied defendants’ motions to dismiss in all other respects and denied their motion for summary judgment. On March 17, 2011, defendants answered plaintiff’s amended complaint.

The parties have reached a provisional settlement agreement and are awaiting court approval of portions of the agreement. On April 20, 2012, all parties moved to voluntarily dismiss the suit.

Washington

Castillo v. Swarski, No. 08-5653 (W.D. Wa. filed Nov. 13, 2008) (CASE CLOSED)

A U.S. Citizen and army veteran brought suit against individual ICE officers alleging he was unlawfully detained, interrogated, and imprisoned for seven and a half months pursuant to an ICE detainer before he was unlawfully ordered removed. The complaint alleged violations of plaintiff’s Fourth and Fifth Amendment rights and sought compensatory damages, punitive damages, and attorneys’ fees.

Defendants filed a motion to dismiss plaintiffs’ amended complaint or in the alternative, for summary judgment on October 2, 2009. The District Court granted defendant’s motion to dismiss with respect to one defendant, but denied it with respect to the other defendants on December 10, 2009. Defendants filed a notice of appeal on January 11, 2010.

The parties settled the case for $400,000 and received a letter of apology from the U.S. Attorney’s Office in Seattle, Washington. The case was dismissed on December 28, 2010.

[60]

RESOURCES

Defeating ICE Hold Requests (2012) [61]. -- Washington Defender Association, Immigrant Legal Resource Center, National Immigration Project of the National Lawyers Guild, National Immigration Law Center, and Immigrant Defense Project.

Appendix 1: General and county specific fact sheets and questions for a first meeting with public officials [62]
Appendix 2: Sample requests for information to police, jails, and ICE under state and federal freedom of information laws [63]
Appendix 3: Legal and policy documents on ICE detainers/hold requests [64]
Appendix 4: Letters from public officials on detainer policies [65]
Appendix 5: Talking points, messaging and discussion points, and editorials [66]
Appendix 6: Legislation and administrative policies relating to ICE hold requests/Detainers [67]

Legal Action Center, Response to the Department of Homeland Security’s request or comments in connection with a review of existing regulations [68]: Docket No. DHS-2011-0015 - Reducing Regulatory Burden; Retrospective Review Under Executive Order 13563, 76 Fed. Reg. 13526 (Mar. 14, 2011) (submitted April 13, 2011).

NGO Comments on Proposed Detainer Guidance [69] (Oct. 5, 2010).

Immigration Policy Center, The Secure Communities Program: Unanswered Questions and Continuing Concerns [70] (Updated Nov. 2010).

Immigration Policy Center, ICE’s Enforcement Priorities and the Factors that Undermine Them [71] (Nov. 2010).

Detention Watch Network, Immigrant Defense Project, Immigrant Legal Resource Center, Washington Defender Association’s Immigration Project, National Immigration Project of National Lawyers Guild, National Immigration Law Center, Rights Working Group, A Dangerous Merger: ICE Enforcement Programs in the Criminal Justice System [72] (March 2010).

Immigration Policy Center, Immigration Detainers: A Comprehensive Look [73] (Feb, 17, 2010).

National Immigration Project, Washington Defender Association, Immigrant Legal Resource Center, Understanding Immigration Detainers: An Overview for State Defense Counsel [74] (March 2011).

Erich C. Straub, Davorin J. Odrcic and Steve Laxton, Immigration Detainers and Unlawful Detention: A Guide for Criminal Attorneys [75] (Jan. 2011).

Washington Defender Association’s Immigration Project, Understanding Immigration Detainers: A Basic Primer for Defense Counsel [76] (Spring 2010).