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27 S. Cal. Rev. L. & Soc. Just. 113 (2018)
Under ICE: The Bed Quota and Political Rhetoric in American Immigration Detention

handle is hein.journals/scws27 and id is 139 raw text is: 












   UNDER ICE: THE 'BED QUOTA' AND

   POLITICAL RHETORIC IN AMERICAN

            IMMIGRANT DETENTION


                   ARIANA SAI~UDO-KRETZMANN*

         They should call this place the jail of broken dreams.

                  - Nilson Flores, detainee at Stewart Detention Center'

         Detention of a migrant should be a matter of last resort. It
  should be an exception, not the rule. The thought that someone who is
  expressing fear of being killed in his home country, that we would put
  that person in a jail-like setting, is the first sort of assumption that I
  would really question.

                                 - Grace Meng, Human Rights Watch2

                      TABLE OF CONTENTS

I. IN TR O D U C TIO N   ............................................................................... 114
II. A GENERAL AND HISTORICAL OVERVIEW OF
      IMMIGRANT DETENTION ...................................................... 115
      A . THE B ED  Q UOTA  ...................................................................... 115



* University of Southern California, Gould School of Law, Class of 2018; B.A. Political Science
and English, 2014, Boston College. I am thankful to Professors Emily Ryo, Niels Frenzen, and
Jean Reisz for their helpful guidance.
I Jerome Socolovsky, Critics of US Immigrant Detention Center Go In to Support Detainees,
VOICE OF AMERICA NEWS (Oct. 6, 2014, 7:10 PM), https://www.voanews.com/a/2474723.html
(providing relevant video footage at 0:25-0:29).
2 The Strange Death of Jose de Jesus, NPR'S LATINO USA (July 22, 2016) (37:41-38:02; 38:06-
38:19), https://www.npr.org/2017/09/08/546821261/the-strange-death-of-jos-de-jes-s-part-2.

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