{"id":1967,"date":"2015-11-11T01:25:39","date_gmt":"2015-11-11T01:25:39","guid":{"rendered":"http:\/\/www.nilc.org\/?page_id=1967"},"modified":"2016-07-12T13:05:55","modified_gmt":"2016-07-12T20:05:55","slug":"scomm-no-rules-of-road-2011-03-0","status":"publish","type":"page","link":"https:\/\/www.nilc.org\/issues\/immigration-enforcement\/scomm-no-rules-of-road-2011-03-0\/","title":{"rendered":"DHS\u2019s \u201cSecure Communities\u201d"},"content":{"rendered":"
MARCH 2011<\/strong><\/p>\n The Secure Communities program is a U.S. Immigration and Customs Enforcement (ICE) program that allows fingerprints of individuals arrested by state and local law enforcement to be sent to the U.S. Department of Homeland Security (DHS) in order to identify persons with an immigration history.\u00a0 Although the program purportedly targets \u201ccriminal aliens\u201d who have been convicted of serious offenses, Secure Communities applies to immigrants regardless of guilt or innocence, how or why they were arrested, and whether their arrests were based on racial or ethnic profiling or were just a pretext for checking immigration status.[1]\u00a0<\/a> ICE has stealthily rolled out Secure Communities, manipulating data and definitions, ignoring flaws fundamental to its structure, and flouting even its own rules in a race to implement the program nationwide.<\/p>\n From the program\u2019s launch in March 2008 until October 2010, ICE characterized the Secure Communities program as being voluntary.\u00a0 During that period, localities believed that the program could not be imposed on them against their will.\u00a0 In an August 17, 2010, memo entitled \u201cSetting the Record Straight,\u201d ICE confirmed the voluntary nature of the program:<\/p>\n If a jurisdiction does not wish to activate on its scheduled date in the Secure Communities deployment plan, it must formally notify its state identification <\/em>bureau and ICE in writing (email, letter or facsimile). Upon receipt of that information, ICE will request a meeting with federal partners, the jurisdiction, and <\/em>the state to discuss any issues and come to a resolution, which may include adjusting the jurisdiction\u2019s activation date in or removing the jurisdiction from <\/em>the deployment plan.<\/em>[2]<\/a><\/p>\n DHS again confirmed the voluntary nature of the program in a letter from Homeland Security Secretary Janet Napolitano to U.S. Representative Zoe Lofgren (D-CA) on September 7, 2010, stating that a jurisdiction choosing not to participate must formally notify ICE and the state identification bureau.[3]<\/a>\u00a0 However, Napolitano directly contradicted herself in a press conference on October 6, 2010, in which she stated that DHS did not \u201cview this as an opt-in, opt-out program.\u201d[4]<\/a>\u00a0 A week before this announcement, the Washington Post<\/em> had quoted an anonymous senior ICE official as stating that, in fact, the so-called opt-out is \u201cnot a realistic possibility \u2014 and never was.\u201d[5]\u00a0<\/a><\/p>\n It is now clear that ICE intentionally misled the public as to the voluntary nature of the program.\u00a0 On February 17, 2011, the Center for Constitutional Rights, the Cardozo School of Law, and the National Day Laborer Organizing Network released excerpts from 15,000 pages of documents received through their Freedom of Information Act (FOIA) lawsuit against ICE.[6]\u00a0<\/a> These documents show that ICE adopted an intentionally misleading definition of \u201cvoluntary\u201d in order to expand implementation of the program before the expected \u201cpushback\u201d from localities.[7]\u00a0<\/a><\/p>\n ICE\u2019s public documents had suggested that ICE was interested in honoring the interests of localities in its implementation of Secure Communities.\u00a0 In the August 17 memo, ICE stated that,<\/p>\n As part of the Secure Communities activation process, ICE conducts outreach to local jurisdictions, <\/em>including providing information about the biometric <\/em>information sharing capability, explaining the benefits of this capability, when they are scheduled for activation, and addressing any concerns they may have.<\/em>[8]<\/a><\/p>\n Given its reluctance to allow communities to opt out, ICE\u2019s statements of outreach are clearly disingenuous.\u00a0 San Francisco and Santa Clara, CA; the District of Columbia; and Arlington, VA, all passed local resolutions seeking to opt out, and ICE entertained their interests in opting out for months before revealing that it had never intended to give them the option.<\/p>\n ICE also has been willing to operate the program in complete secrecy, without a locality even being aware it had been imposed on the community.[9]<\/a>\u00a0 A state\u2019s agreement to participate in the program normally begins with a state investigation bureau\u2019s (SIB\u2019s) signing a memorandum of agreement (MOA) with DHS.\u00a0 However, as revealed by documents received from ICE through a FOIA request by the National Immigration Law Center, ICE agreed to implement Secure Communities in Pennsylvania without having the state sign an MOA.[10]\u00a0<\/a> Moreover, ICE has even backed off from the necessity of a state signing an MOA, stating that the MOA with a state is \u201can unnecessary formality.\u201d[11]<\/a><\/p>\n While states may still be able either to opt out or modify their SIBs\u2019 agreements with DHS, even that possibility is not assured for the future. \u00a0According to ICE\u2019s Secure Communities brochure, the enhanced technology and fingerprint checking is offered by the program through a partnership between DHS and the U.S. Department of Justice (DOJ).[12]<\/a><\/p>\n While states and localities have deliberated over participation in the program, ICE has rolled out the program at breakneck speed.\u00a0 ICE announced the initiation of the Secure Communities program in March 2008, and implementation of the program began in October 2008.\u00a0 As of February 15, 2011, the program was operational in 1,049 jurisdictions in 39 states.[13]\u00a0<\/a> ICE expects to expand the program to all jurisdictions throughout the country by 2013.<\/p>\n The Secure Communities program does not have a statutory mandate, which means that critical oversight of the program has not been required.\u00a0 Meanwhile, Secure Communities is burdensome and costly for police departments.\u00a0 ICE insists that law enforcement agencies (LEAs) \u201cincur little to no cost\u201d due to implementing the program, but police tell a different story.[14]<\/a>\u00a0 According to Sheriff\u2019s Lieutenant Michael Barry in Martin County, FL,<\/p>\n Time is . . . a factor for our staff.\u00a0 Sending I.A.Q.\u2019s [Immigration Alien Queries], waiting for responses, making phone calls to different immigration officials for clarification on detainees [sic] status, gathering additional information for immigration such as photos, booking sheets, fingerprints, and palm prints\u00a0[for Secure Communities] takes away from the deputies [sic] regular duties within the [jail] facility.<\/em>[15]<\/a><\/p>\n Because of the logistics of processing arrestees through Secure Communities, police officers lose time that would otherwise be spent serving and protecting their communities.\u00a0 Local jails also bear the cost of housing arrestees who are held under immigration detainers rather than being released on bond.\u00a0 A detainer is a request from ICE that the arresting agency notify ICE before its release of a noncitizen so that ICE can assume custody.[16]<\/a>\u00a0 The detainer provides the jail with the authority to hold a noncitizen for 48 hours if the person is not already subject to detention.[17]<\/a>\u00a0 For the 48-hour duration of the detainer, the local jail bears the cost of housing the arrestee.\u00a0 Then, when the ICE officer goes to the jail to evaluate whether the arrestee should be taken into ICE custody, the local jail bears the burden and cost of accommodating the ICE officers.\u00a0 Finally, the local jail \u2014 not ICE \u2014 is legally liable if the arrestee is held over the 48-hour period authorized under the detainer,[18]<\/a> or, as has occurred in several locations, if the detainer is mistakenly placed on a citizen.<\/p>\n Secure Communities is an unfunded mandate that makes local law enforcement do the work of federal immigration enforcement and<\/em> bear the costs.<\/p>\n From its inception, Secure Communities was touted as a program intended to target \u201cthe worst of the worst.\u201d[19]\u00a0<\/a> ICE\u2019s Secure Communities brochure states that ICE prioritizes \u201cthe most dangerous and violent offenders.\u201d[20]\u00a0<\/a> In practice, however, Secure Communities does not do that.\u00a0 The use of preconviction fingerprint-scanning to identify persons who have a history of contact with the immigration system could never serve that purpose because a preconviction fingerprinting system is a broad dragnet that catches mostly noncriminals and low-level offenders.\u00a0 The dragnet also ensnares lawful permanent residents who may or may not be deportable and even citizens who are not deportable under any circumstances.<\/p>\n Despite various iterations of priorities and risk-based levels,[21]<\/a> ICE has failed in practice to prioritize the most dangerous, convicted, criminal immigrants for deportation.\u00a0 ICE claims that it operates the program according to a risk-based approach intended \u201cto identify aliens charged with or convicted of a serious criminal offense and incarcerated in jails and prisons throughout the United States,\u201d in accordance with a hierarchy of prioritized levels.[22]<\/a>\u00a0 However, ICE has created no mechanism to ensure that Level 1 offenders who have been convicted of crimes are prioritized for removal.\u00a0 On the contrary, ICE uses the mechanism of the detainer to ensure that all arrestees are channeled into the immigration enforcement system, regardless of their criminal history.\u00a0 After an immigration \u201chit,\u201d ICE places a detainer on the arrestee without consideration of its priorities and regardless of whether he or she is a dangerous, high-priority criminal.<\/p>\n In November 2009, ICE announced that during the first year of the program it had identified 110,000 criminal aliens through Secure Communities.\u00a0 Shortly thereafter, ICE corrected its press release to say that it had identified more than 111,000 aliens \u201ccharged with or convicted of crimes.\u201d[23]<\/a>\u00a0 Initially, ICE considered anyone \u201cidentified\u201d by Secure Communities a \u201ccriminal alien.\u201d\u00a0 Only after the numbers were challenged did ICE specify that these were actually not all \u201ccriminals.\u201d\u00a0 In fact, by ICE\u2019s own numbers, less than 10 percent of those identified were charged with or convicted of the prioritized Level 1 offenses, and 5 percent were U.S. citizens.<\/p>\n Data obtained through the FOIA lawsuit filed by the Center for Constitutional Rights, the Cardozo School of Law, and the National Day Laborer Organizing Network shows that 79 percent of individuals deported through Secure Communities between October 2008 and June 2010 were either noncriminals or were picked up for low-level offenses such as traffic violations.[24]<\/a>\u00a0 As of November 2010, this percentage remained relatively unchanged.[25]<\/a>\u00a0 Since the program\u2019s inception, it has failed to target violent and dangerous criminals and has instead cast a net over noncriminals and low-level offenders.<\/p>\n ICE has also deliberately manipulated data.\u00a0 According to purportedly cumulative data collected by ICE between April and June 2010, the actual number of noncriminals deported in many Secure Communities jurisdictions inexplicably decreased<\/em>.<\/a>[26]\u00a0<\/a> Here are some examples of decreases in the number of noncriminal Secure Communities deportees between April and July 2010:<\/p>\n This cumulative data was summed, month by month.\u00a0 ICE must answer how cumulative numbers can decrease.\u00a0 Perhaps the decrease represents a shift in the way ICE was categorizing \u201cnoncriminals\u201d \u2014 arguably for the sake of making it appear that ICE was deporting more \u201ccriminals.\u201d\u00a0 Regardless, ICE does not appear to be subject to basic laws of mathematics.<\/p>\n Implementation of Secure Communities has been marked by lack of transparency and accountability. \u00a0ICE has imposed Secure Communities in 39 states without a congressional mandate and without promulgating regulations through a process that would allow public input.\u00a0 ICE has simply announced the progam\u2019s \u201crules\u201d on its website and then changed them repeatedly and without prior notice.<\/p>\n Nor is ICE governed by rules or requirements regarding its collection and release of Secure Communities\u2013related data.\u00a0 Only through FOIA requests has the public gained any sense of who ICE is channeling into removal proceedings through Secure Communities.\u00a0 But even here ICE makes up the rules as it goes along.\u00a0 Syracuse University\u2019s Transactional Records Access Clearinghouse (TRAC), which collects and catalogs anonymous statistical data about the arrests, detentions, charges, and removal activities of ICE, was notified by ICE in October 2010 that certain information historically submitted to TRAC was now \u201cunavailable.\u201d[27]<\/a>\u00a0 ICE touts its success in removing criminal aliens, so the requested information is certainly available.\u00a0 It appears, therefore, that ICE has exempted itself from disclosure laws that govern all federal agencies.<\/p>\n For all the problems associated with the program, Secure Communities offers a meager, hidden complaint procedure with no meaningful redress.\u00a0 Rather, ICE\u2019s main Secure Communities webpage directs persons who locate its \u201cCivil Rights and Civil Liberties\u201d link[28]<\/a> to the DHS Office of Civil Rights and Civil Liberties (OCRCL) website for purposes of filing complaints.[29]<\/a>\u00a0 The program\u2019s complaint procedure assumes that a person whose rights have been violated knows about Secure Communities, knows that his or her rights were violated as a direct result of the program, has computer and Internet access, locates the Secure Communities webpage within ICE\u2019s website, reads English, and already knows that OCRCL is responsible for keeping Secure Communities accountable.\u00a0 And the complaint procedure assumes that such a person is willing to file a complaint even though the complaint will not necessarily be kept confidential within DHS, such that the complainant may be subject to retaliation.<\/p>\n Finally, serious questions remain as to how far-reaching the fingerprint-sharing between DHS and DOJ will be.\u00a0 Will the fingerprints of teachers applying for jobs be checked against DHS databases?\u00a0 Will the fingerprints of immigrant attorneys who wish to take the bar examination be stored in case they later have contact with the police?\u00a0 Will mobile fingerprint scanners be used to match fingerprints against DHS databases, so that taking a person into custody will not even be required? \u00a0From launch to implementation and from implementation to rights violations, the Secure Communities program operates without rules.<\/p>\n <\/a>[1] For background information on Secure Communities, see Overview of the Key ICE ACCESS Programs<\/em> (National Immigration Law Center, Nov. 2009), www.nilc.org\/immlawpolicy\/LocalLaw\/ice-access-2009-11-05.pdf; see also More Questions than Answers about the Secure Communities Program<\/em> (NILC, Mar. 2009), www.nilc.org\/immlawpolicy\/LocalLaw\/secure-communities-2009-03-23.pdf. Memorandum for All ICE Employees from John Morton, Assistant Secretary for U.S. Immigration and Customs Enforcement, Subject: \u201cCivil Immigration Enforcement: Priorities for the Apprehension, Detention, and Removal of Aliens,\u201d June, 30, 2010, www.ice.gov\/doclib\/detention-reform\/pdf\/civil_enforcement_priorities.pdf. [vc_row el_class=”holder” css=”.vc_custom_1444345515294{margin-top: -100px !important;}”][vc_column][vc_row_inner][vc_column_inner][vc_empty_space height=”0px”][\/vc_column_inner][\/vc_row_inner][vc_row_inner][vc_column_inner width=”3\/4″][vc_column_text] DHS\u2019s \u201cSecure Communities\u201d: No Rules of the Road MARCH 2011 The Secure Communities program is a U.S. Immigration and Customs Enforcement (ICE) program that allows fingerprints of individuals arrested by state and local law enforcement to be sent to the U.S. Department of Homeland Security (DHS) in order […]<\/p>\n","protected":false},"author":3,"featured_media":0,"parent":600,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"inline_featured_image":false,"footnotes":""},"_links":{"self":[{"href":"https:\/\/www.nilc.org\/wp-json\/wp\/v2\/pages\/1967"}],"collection":[{"href":"https:\/\/www.nilc.org\/wp-json\/wp\/v2\/pages"}],"about":[{"href":"https:\/\/www.nilc.org\/wp-json\/wp\/v2\/types\/page"}],"author":[{"embeddable":true,"href":"https:\/\/www.nilc.org\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/www.nilc.org\/wp-json\/wp\/v2\/comments?post=1967"}],"version-history":[{"count":9,"href":"https:\/\/www.nilc.org\/wp-json\/wp\/v2\/pages\/1967\/revisions"}],"predecessor-version":[{"id":9043,"href":"https:\/\/www.nilc.org\/wp-json\/wp\/v2\/pages\/1967\/revisions\/9043"}],"up":[{"embeddable":true,"href":"https:\/\/www.nilc.org\/wp-json\/wp\/v2\/pages\/600"}],"wp:attachment":[{"href":"https:\/\/www.nilc.org\/wp-json\/wp\/v2\/media?parent=1967"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}DHS is imposing Secure Communities on localities nationwide despite earlier insistence that the program was voluntary.<\/h3>\n
Secure Communities is an unfunded mandate that local communities enforce federal immigration law.<\/h3>\n
The Secure Communities program targets everyone<\/em> who has ever had any dealings with the immigration system \u2014 not a prioritized set of dangerous criminals.<\/h3>\n
\n
The Secure Communities program operates in a rule-free environment.<\/h3>\n
\n\u00a0Notes:<\/h4>\n
\n<\/a>[2] Secure Communities: Setting the Record Straight<\/em> (U.S. Immigration and Customs Enforcement, Aug. 17, 2010), available at www.nilc.org\/immlawpolicy\/LocalLaw\/ice-scomm-setting-record-straight-2010-08-17.pdf, p. 6.
\n<\/a>[3] Letter from Janet Napolitano, Sec\u2019y, U.S. Dept. of Homeland Security, to Rep. Zoe Lofgren, U.S. House of Rep. (Sept. 8, 2010).
\n<\/a>[4] See related press release, \u201cSecretary Napolitano Announces Record-Breaking Immigration Enforcement Statistics Achieved Under the Obama Administration,\u201d Oct. 5, 2010, www.ice.gov\/pi\/nr\/1010\/101006washingtondc2.htm.
\n<\/a>[5] Shankar Vedantam, \u201cLocal Jurisdictions Find They Can\u2019t Opt Out of Federal Immigration Enforcement Program,\u201d Washington Post,<\/em> Sept. 30, 2010, www.washingtonpost.com\/wp-dyn\/content\/article\/2010\/09\/30\/AR2010093007225.html.
\n<\/a>[6] Preliminary Briefing Guide: Newly Released Documents Chronicle Agency\u2019s Deception about Opting-out of \u201cSecure Communities\u201d Program<\/em> (Center for Constitutional Rights, National Day Laborer Organizing Network, Cardozo School of Law, Feb. 17, 2011), http:\/\/uncoverthetruth.org\/wp-content\/uploads\/Uncover-the-Truth-FOIA-Briefing-Guide-2-17-111.pdf.\u00a0<\/em>
\n<\/a>[7] See id.<\/em>, citing an email message from Randi Greenberg, Secure Communities Program Outreach and Communication Director, to various ICE officials, Aug. 26, 2009, Subject: SC Guidance Voluntary\/Mandatory Question, ICE FOIA 10-2674.00018-0001832 (\u201cThe SC initiative will remain voluntary at both the State and Local level. \u00a0Once activated, 30-days written notice will be required in order to suspend or terminate the information-sharing. \u00a0Until such time as localities begin to push back on participation, we will continue with this current line of thinking.\u201d) See also an email message from Dan Cadman, ICE, to Marc Rapp, Acting Director, Secure Communities, ICE Nov. 9-Nov. 12, 2010, Subject: Strategy for Difficult Interoperability Deployment Locales, ICE FOIA 10-2674.001811-1812. \u00a0In response to an inquiry from an ICE official about what \u201cvoluntary participation\u201d and \u201copting out\u201d of Secure Communities mean, Marc Rapp, Acting Director of Secure Communities, says: \u00a0\u201cSC defines voluntary strictly as the ability to receive the immigration response. \u00a0If the local jurisdiction elects not to receive the immigration response they will not be routed back. \u00a0This does not invalidate the requirement for CJIS to deploy interoperability by 2013. \u00a0Id. \u00a0As you know certain jurisdictions have not been overly receptive to attending our outreach meetings and some states are even hesitant to sign the MOA. \u00a0It is these locations that the strategy needs to address.\u201d \u00a0All documents obtained through the Freedom of Information Act lawsuit NDLON et al. v. ICE<\/em>, 10-CV-3488, are available at http:\/\/ndlon.org\/feb\/.
\n<\/a>[8] Secure Communities: Setting the Record Straight<\/em>, supra<\/em> note 2, p. 6.
\n<\/a>[9] See Melissa Keaney, \u201cSmoke and Mirrors: FOIA Reveals ICE Deception in Secure Communities Program,\u201d Immigration Impact,<\/em> Sept. 1, 2010, http:\/\/immigrationimpact.com\/2010\/09\/01\/smoke-and-mirrors-foia-reveals-ice-deception-in-secure-communities-program\/.
\n<\/a>[10] See Secure Communities Weekly Executive Report: Dec. 15-19, 2008 <\/em>(Secure Communities, U.S. Immigration and Customs Enforcement), available at http:\/\/immigrationimpact.com\/upload\/docs\/Secure%20Communities.pdf.
\n<\/a>[11] Maria Sacchetti, \u201cU.S. Pushes State to Join Security Plan,\u201d Boston Globe<\/em>, Oct. 6, 2010,\u00a0 www.boston.com\/news\/local\/massachusetts\/articles\/2010\/10\/06\/us_asks_mass_police_to_join_ice_plan\/.
\n<\/em><\/a>[12] www.ice.gov\/doclib\/secure_communities\/pdf\/sc_brochure_508.pdf.
\n<\/a>[13] Activated Jurisdictions<\/em> (Secure Communities, U.S. Immigration and Customs Enforcement, Mar. 1, 2011), www.ice.gov\/doclib\/secure-communities\/pdf\/sc-activated.pdf.
\n<\/a>[14] \u201cBenefitting Law Enforcement throughout the United States\u201d (undated 1-pg. flyer published by Secure Communities, U.S. Immigration and Customs Enforcement), www.ice.gov\/doclib\/secure-communities\/pdf\/lea-benefits.pdf.
\n<\/a>[15]\u00a0Memo from Lt. Michael Barry, Martin County, FL, Sheriff\u2019s Office, to Major Steve Chase, Re: Immigration Procedures, Feb. 28, 2008, available at www.fiacfla.org\/Quote%201%20-%20Martin%20County%20Memo.pdf, p. 2.
\n<\/a>[16] 8 CFR 287.7(a).
\n<\/a>[17] 8 CFR 287.7(d).
\n<\/a>[18] Cacho et al. v. Gusman<\/em>, No. 11 Civ. 225 (E.D. La. filed Feb. 2, 2011) (civil rights action for damages based on violation of the 48-hour time period); \u00a0Quezeda v. Mink et al.<\/em>, No. 10 Civ. 879 (D. Colo. Dec. 12, 2010) (same); Florida Immigrant Coalition et al. v. Bradshaw<\/em>, No. 9 Civ. 81280 (S.D. Fla. filed Sept. 3, 2009) (same); Ramos-Macario v. Jones et al.<\/em>, No. 10 Civ. 813 (M.D. Tenn. filed Sept. 28, 2010) (same); Rivas v. Martin et al.<\/em>, No. 10 Civ. 197 (N.D. Ind. filed June 16, 2010) (same).
\n<\/a>[19] ICE Fiscal Year 2008 Annual Report<\/em> (U.S. Immigration and Customs Enforcement, undated), www.ice.gov\/doclib\/news\/library\/reports\/annual-report\/2008annual-report.pdf, p. 5.
\n<\/a>[20] \u201cSecure Communities: A Modernized Approach to Identifying and Removing Criminal Aliens\u201d (2-pg. brochure published by Secure Communities, U.S. Immigration and Customs Enforcement, Jan. 2010), www.ice.gov\/doclib\/secure-communities\/pdf\/sc-brochure.pdf.
\n<\/a>[21] On June 30, 2010, ICE published the following updated hierarchy:<\/p>\n<\/div>\n\n
\n[Emphasis added, clarifying notes omitted.]<\/li>\n<\/ul>\n
\n<\/a>[22] \u201cMemorandum of Agreement between U.S. Department of Homeland Security Immigration and Customs Enforcement and [State Identification Bureau]\u201d (prototype memo, undated), www.ice.gov\/doclib\/foia\/secure_communities\/securecommunitiesmoatemplate.pdf.
\n<\/a>[23] \u201cSecretary Napolitano and ICE Assistant Secretary Morton Announce That the Secure Communities Initiative Identified More Than 111,000 Aliens Charged with or Convicted of Crimes in Its First Year,\u201d U.S. Immigration and Customs Enforcement press release, Nov. 12, 2009, www.ice.gov\/news\/releases\/0911\/091112washington.htm.\u00a0 When it was first issued, however, this press release\u2019s headline was \u201cSecretary Napolitano and ICE Assistant Secretary Morton Announce That the Secure Communities Initiative Identified More Than 110,000 Criminal Aliens in Its First Year.\u201d
\n<\/a>[24] Briefing Guide to Secure Communities, ICE’s Controversial Immigration Program: New Statistics and Information Reveal Disturbing Trends and Leave Crucial Questions Unanswered<\/em> (Center for Constitutional Rights, National Day Laborer Organizing Network, Cardozo School of Law, Aug. 2, 2010), http:\/\/ccrjustice.org\/files\/Secure%20Communities%20Fact%20Sheet%20Briefing%20guide%20%208-2-2010%20Production.pdf.pdf.
\n<\/a>[25] Secure Communities: IDENT\/IAFIS Interoperability Monthly Statistics through November 30, 2010<\/em> (U.S. Immigration and Customs Enforcement, Dec. 13, 2010), www.ice.gov\/doclib\/foia\/secure_communities\/nationwide_interoperability_conviction-nov10.pdf. Low-level offenders include ICE Levels 2 and 3.\u00a0 As of Nov. 2010, 77 percent of those deported were noncriminals and low-level offenders.
\n<\/a>[26] Immigration and Customs Enforcement (ICE) Agency\u2019s Spin Cannot Obscure the Truth about the \u201cSecure Communities\u201d Program: Rights Groups\u2019 Advocacy Leads to Critical ICE Admissions and Breakthroughs Related to the Flawed Program<\/em> (Center for Constitutional Rights, National Day Laborer Organizing Network, Cardozo School of Law, Sept. 1, 2010), www.ccrjustice.org\/files\/CCR%20NDLON%20Cardozo%20Response%20to%20ICE%20Spin%209-1-10%20FINAL.pdf.
\n<\/a>[27] \u201cICE Declares That Key Data It Holds Are \u2018Unavailable\u2019: Unlawful Denial of Records Blocks Public Understanding of Immigration Enforcement,\u201d Transactional Records Access Clearinghouse news release, Oct. 4, 2010, http:\/\/trac.syr.edu\/foia\/ice\/20101004\/.
\n<\/a>[28] See www.ice.gov\/secure_communities\/, bottom of the webpage.
\n<\/a>[29] See www.dhs.gov\/xabout\/structure\/crcl.shtm.<\/p>\n<\/div>\n<\/div>\n[\/vc_column_text][\/vc_column_inner][vc_column_inner width=”1\/4″][vc_widget_sidebar sidebar_id=”sidebar-1″][\/vc_column_inner][\/vc_row_inner][\/vc_column][\/vc_row]\n<\/div>","protected":false},"excerpt":{"rendered":"