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Timothy P. Fox (CA Bar 157750) [email protected] Elizabeth Jordan* [email protected] CIVIL RIGHTS EDUCATION and ENFORCEMENT

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Timothy P. Fox (CA Bar 157750) Tfox@Creeclaw.Org Elizabeth Jordan* Ejordan@Creeclaw.Org CIVIL RIGHTS EDUCATION and ENFORCEMENT Case 5:19-cv-01546 Document 1 Filed 08/19/19 Page 1 of 210 Page ID #:1 1 Timothy P. Fox (CA Bar 157750) [email protected] 2 Elizabeth Jordan* [email protected] 3 CIVIL RIGHTS EDUCATION AND ENFORCEMENT CENTER 4 104 Broadway, Suite 400 Denver, CO 80203 5 Tel: (303) 757-7901 6 Fax: (303) 872-9072 7 Stuart Seaborn (CA Bar 198590) [email protected] 8 Melissa Riess (CA Bar 295959) [email protected] Lisa Graybill* 9 Monica Porter (CA Bar 311974) [email protected] [email protected] Jared Davidson* 10 Jessica Agatstein (CA Bar 319817) [email protected] 11 [email protected] Jeremy Jong* DISABILITY RIGHTS ADVOCATES [email protected] 12 2001 Center Street, 4th Floor SOUTHERN POVERTY LAW Berkeley, California 94704 CENTER 13 Tel: (510) 665-8644 201 St. Charles Avenue, Suite 2000 Fax: (510) 665-8511 New Orleans, Louisiana 70170 14 Tel: (504) 486-8982 William F. Alderman (CA Bar 47381) Fax: (504) 486-8947 15 [email protected] Jake Routhier (CA Bar 324452) Elissa Johnson* 16 [email protected] [email protected] 17 ORRICK, HERRINGTON & SOUTHERN POVERTY LAW SUTCLIFFE LLP CENTER 18 405 Howard Street 150 E. Ponce de Leon Ave., Ste. 340 San Francisco, CA 94105 Decatur, GA 30030 19 Tel: (415) 773-5700 Tel: (404) 521-6700 Fax: (415) 773-5759 Fax: (404) 221-5857 20 Attorneys for Plaintiffs (continued on next page) 21 22 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 23 EASTERN DIVISION – RIVERSIDE 24 Case No. 19-cv-01546 25 FAOUR ABDALLAH FRAIHAT; MARCO MONTOYA AMAYA; CLASS ACTION 26 RAUL ALCOCER CHAVEZ; JOSE 27 SEGOVIA BENITEZ; HAMIDA ALI; Complaint for Declaratory and MELVIN MURILLO HERNANDEZ; Injunctive Relief for Violations of the 28 JIMMY SUDNEY; JOSÉ BACA Due Process Clause of the Fifth Case 5:19-cv-01546 Document 1 Filed 08/19/19 Page 2 of 210 Page ID #:2 1 HERNÁNDEZ; EDILBERTO Amendment and Section 504 of the 2 GARCÍA GUERRERO; MARTIN Rehabilitation Act, 29 U.S.C. § 794, MUÑOZ; LUIS MANUEL et. seq. 3 RODRIGUEZ DELGADILLO; 4 RUBEN DARÍO MENCÍAS SOTO; ALEX HERNANDEZ; 5 ARISTOTELES SANCHEZ 6 MARTINEZ; and SERGIO SALAZAR ARTAGA; on behalf of themselves and 7 all those similarly situated; INLAND 8 COALITION FOR IMMIGRANT JUSTICE, an organization; and AL 9 OTRO LADO, an organization, 10 Plaintiffs, 11 v. 12 13 U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT; 14 U.S. DEPARTMENT OF 15 HOMELAND SECURITY; KEVIN MCALEENAN, in his official 16 capacity as Acting Secretary, U.S. 17 Department of Homeland Security; MATTHEW T. ALBENCE, in his 18 official capacity as Acting Director, 19 U.S. Immigration and Customs Enforcement; 20 DEREK N. BRENNER, in his official 21 capacity as Deputy Director, U.S. Immigration and Customs 22 Enforcement; TIMOTHY S. 23 ROBBINS, in his official capacity as Acting Executive Associate Director, 24 Enforcement and Removal Operations; 25 TAE JOHNSON, in his official capacity as Assistant Director of 26 Custody Management, Enforcement 27 and Removal Operations; STEWART D. SMITH, in his official capacity as 28 Assistant Director, Immigration and Case 5:19-cv-01546 Document 1 Filed 08/19/19 Page 3 of 210 Page ID #:3 1 Customs Enforcement Health Service 2 Corps; JACKI BECKER KLOPP, in her official capacity as Assistant 3 Director of Operations Support, 4 Enforcement and Removal Operations; and DAVID P. PEKOSKE, in his 5 official capacity as Senior Official 6 Performing Duties of the Deputy Secretary, Department of Homeland 7 Security, 8 Defendants. 9 Mark Mermelstein (CA Bar 208005) 10 [email protected] ORRICK, HERRINGTON & SUTCLIFFE LLP 11 777 South Figueroa Street, Suite 3200 12 Los Angeles, CA 90017 Tel: (213) 629-2020 13 Fax: (213) 612-2499 14 Christina Brandt-Young* [email protected] 15 DISABILITY RIGHTS ADVOCATES 655 Third Avenue, 14th Floor 16 New York, NY 10017 Tel: (212) 644-8644 17 Fax: (212) 644-8636 18 Maia Fleischman* 19 [email protected] SOUTHERN POVERTY LAW CENTER 20 4700 Biscayne Blvd., Ste 760 Miami, FL 33137 21 Tel: (305) 537-0589 Fax: (786) 237-2949 22 Attorneys for Plaintiffs (continued from previous page) 23 *Pro Hac Vice Application Forthcoming 24 25 26 27 28 Case 5:19-cv-01546 Document 1 Filed 08/19/19 Page 4 of 210 Page ID #:4 1 TABLE OF CONTENTS 2 GLOSSARY OF TERMS ........................................................................................ iv 3 INTRODUCTION .................................................................................................... 1 4 PARTIES ................................................................................................................... 8 5 I. Plaintiffs ............................................................................................................ 8 6 II. Defendants ....................................................................................................... 29 7 JURISDICTION ..................................................................................................... 32 8 VENUE .................................................................................................................... 32 9 FACTUAL ALLEGATIONS ................................................................................. 32 10 III. Defendants Subject Thousands of Civil Detainees to Punitive Conditions Despite the Availability of Alternatives ......................................................... 32 11 IV. Defendants are Responsible for Selecting, Contracting, and Monitoring 12 Conditions in Detention Facilities ................................................................. 41 13 V. Multiple Government Entities, Including DHS Itself, Have Concluded That Defendants Are Not Adequately Monitoring and Overseeing Detention 14 Facilities ......................................................................................................... 47 15 VI. As a Result of Defendants’ Failure to Monitor and Oversee Medical and 16 Mental Health Care at Detention Facilities, Conditions in Those Facilities Constitute Punishment and Expose Plaintiffs and Class Members to 17 Substantial Risk of Serious Harm .................................................................. 62 18 A. Defendants Systemically Fail to Ensure That Detained Individuals 19 Receive Timely Medical and Mental Health Care ..................................... 63 20 B. Defendants Systemically Fail to Ensure Timely Access to Medically Necessary Specialty and Chronic Care ...................................................... 72 21 C. Defendants Systemically Fail to Ensure That Care is Provided by 22 Trained or Qualified Personnel .................................................................. 84 23 D. Defendants Systemically Fail to Ensure Detained Individuals Receive Timely Emergency Health Care ................................................................. 92 24 E. Defendants Systemically Fail to Ensure Adequate Physical and Mental 25 Health Intake Screening ........................................................................... 101 26 F. Defendants Systemically Fail to Ensure Adequate Staffing of Medical 27 and Mental Health Care ............................................................................ 108 28 COMPLAINT - i - CASE NO. ______________ Case 5:19-cv-01546 Document 1 Filed 08/19/19 Page 5 of 210 Page ID #:5 1 G. Defendants Systemically Fail to Ensure Adequate Mental Health Care .............................................................................................. 120 2 H. Defendants Systemically Fail to Ensure the Adequacy of Medical 3 Records and Documentation. ................................................................... 126 4 VII. As a Result of Defendants’ Failure to Monitor and Oversee Segregation Practices at Detention Facilities, Conditions in Those Facilities Constitute 5 Punishment and Subject Plaintiffs in Segregation and Members of the 6 Segregation Subclass to Violations of the Fifth Amendment................... 130 7 A. Defendants Violate the Fifth Amendment by Failing to Ensure That Civil Detainees in Segregation Are Not Subjected to Punitive Conditions 8 of Confinement ......................................................................................... 132 9 Defendants Subject Plaintiffs to a Substantial Risk of Serious 10 Harm Through Their Failure to Monitor and Prevent Needless and Arbitrary Segregation ....................................................... 138 11 Defendants Fail to Monitor and Oversee Segregation Practices 12 on a Systemic Scale ................................................................. 150 13 VIII. As a Result of Defendants’ Failure to Monitor and Oversee Disability- Related Practices in Detention Facilities, Plaintiffs with Disabilities and 14 Members of the Disability Subclass Are Subjected to Violations of the 15 Fifth Amendment and Section 504 of the Rehabilitation Act .................. 157 16 A. Section 504 of the Rehabilitation Act Prohibits Discrimination on the Basis of Disability by Executive Agencies .............................................. 157 17 Defendants Exercise Centralized Control Regarding Conditions 18 Impacting Persons with Disabilities at Detention Facilities 19 Nationwide ............................................................................... 159 20 Defendants Systemically Fail to Ensure Access to ICE Programs and Services for Detained Individuals with Disabilities. ........ 160 21 Defendants Systemically Fail to Ensure Adequate Screening to 22 Identify, Track, and Accommodate Detained Individuals with 23 Disabilities ..............................................................................
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