PREA AUDIT REPORT INTERIM FINALJUVENILE FACILITIESDate of report: July 10, 2017Auditor InformationAuditor name: Adam T. Barnett, Sr.Address: P.O. Box 20381Email: Adam30906@gmail.comTelephone number: 706-550-7978Date of facility visit: May 31 – June 1, 2017Facility InformationFacility name: Sequel TSI Owens Cross RoadsFacility physical address: 318 Hamer Road, Owerns Cross Roads, AL. 35763Facility mailing address: (if different from above) sameFacility telephone number: 256-725-7170The facility is: Federal State County Military Municipal Private for profit Detention Other Private not for profitFacility type: CorrectionalName of facility’s Chief Executive Officer: Bette MooreNumber of staff assigned to the facility in the last 12 months: 53Designed facility capacity: 42Current population of facility: 32Facility security levels/inmate custody levels: MediumAge range of the population: 12 - 18Name of PREA Compliance Manager: Kelsi WallerTitle: PREA Compliance Officer/Quality AssuranceEmail address: Kelsi.Waller@sequelyouthservices.comTelephone number: 256-725-7170 ext 207Agency InformationName of agency: Alabama Department of Youth ServicesGoverning authority or parent agency: (if applicable) Sequel Youth and Family ServicesPhysical address: Click here to enter text.Mailing address: (if different from above) Click here to enter text.Telephone number: Click here to enter text.Agency Chief Executive OfficerName: John StupakTitle: Chief Executive Officer/PresidentEmail address: firstname.lastname@example.orgTelephone number: 215-284-5043Agency-Wide PREA CoordinatorName: Sonya SchierlingTitle: Quality Manager/PREA CoordinatorEmail address: Sonja.email@example.comTelephone number: 941-526-8763PREA Audit Report1
AUDIT FINDINGSNARRATIVEMethodologyThe PREA audit of Sequel TSI Owens, a facility operated by the Sequel Youth and Family Services and contracted by theAlabama Department of Youth Services, was conducted on May 31, 2017. The facility posted the required PREA audit noticeof the upcoming audit sixty days prior to the audit for resident’s confidential communications. As of May 29, 2017, therewere no communications from residents or staff. The Pre-Audit Questionnaire was completed by the facility and sent to theAuditor as required. The PREA Compliance Manager confirmed that all information on the Pre-Audit Questionnaire wasaccurate.The audit process was a team approach. The Audit Team completed a documentation review using the Pre-AuditQuestionnaire, internet search, policies and procedures review, and additional documentation provided via email and flashdrive. The results of the documentation review were shared with the facility prior to and at the site visit. Phoneconversations were conducted and emails were exchanged with the facility.The Audit Team consisted of Adam T. Barnett, Sr., Certified Juvenile and Adult PREA Auditor and Latera Davis (Associate).Mrs. Davis currently works as the Director of Victim and Volunteer Services for the Georgia Department of Juvenile Justice.She is a Licensed Clinical Social Worker, Certified Child Forensic Interviewer, Certified Victim Advocate, Certified Juvenile SexOffender Counselor, and POST Instructor Trainer, as well as a Certified Peer Grant Reviewer for the Department of JusticePrograms.On Wednesday, May 31, 2017 the Facility Program Director met the Auditor at 5:50AM to begin the on-site visit.Welcomes were given by the Facility Acting Program Director and other Direct Care Staff. The PREA Auditor was introducedand the PREA Audit Agenda was reviewed and released. Additional pre-audit information requested weeks prior to on-sitevisit was obtained. The Auditor began the facility tour and Latera Davis began interviewing Direct Care Staff from the thirdshift.Site TourOn the first day of the audit after meeting the Facility Acting Program Director, the PREA Auditor toured the physical plantescorted by the Facility Acting Program Director and the Executive/Regional Director. The Auditor spoke informally with 6staff and 10 residents during the tour which covered housing and common areas of the facility, day areas, classroom areas,shower and toilet areas. The Auditor noted video camera placement throughout the facility and reviewed the videomonitoring setup in the control room areas. Notices of the PREA audit were posted throughout the facility as required by theAuditor and the National PREA Resources guidelines.During the tour of the physical plant, the Auditor observed the location of cameras, staff supervision of residents, living units.The sleeping rooms, toilets and shower were in community areas, placement of posters and PREA informational resources,security monitoring, resident’s movement procedures, and resident’s interaction with staff. The Auditor noted that toilet andshower areas did not completely allow inmates to use the bathroom and shower in complete privacy from other residentsand staff direct viewing. This concern regarding the shower and toilet shower curtains, with additional concerns will bediscussed in the standards details.The Auditor was provided unimpeded access to all parts of the facility and all secure rooms and storage areas in the facility.The laundry room had no blind spots. Residents were fed in their dining area. All office doors in the Administration area didnot have safety windows, however, the facility explain when residents are in a administrative office the doors are open. Thegym and the recreation yard had cameras and residents were well behaved during the tour.PREA Audit Report2
Each living unit provides basic furnishings, common TV area, showers and toilets located in a community setting. All residentshowers and toilets have shower curtains. The Auditor has concerns regarding the direct viewing by other when residents areshowering or using the toilets. This concern is addressed in standard 115.315.Sampling Interviews and Staff ContactThe audit work plan was discussed, random samples of residents and staff were selected, and specialized staff was identified.Agency and facility staff selected for interviews included:-Sequel Agency PREA Coordinator (Interviewed by Phone)Executive Director/Regional DirectorFacility PREA Compliance ManagerHigher Level Facility Staff (PREA Unannounced Rounds)Lead Medical StaffLead Mental Health StaffHuman Resources AdministratorVolunteerContractorInvestigator (Department of Human Resources)Staff who Conduct PREA ScreeningsStaff who Supervise Inmate Segregated HousingIncident Review MemberStaff Monitoring RetaliationFirst Responder (Non-Security Staff)First Responder (Security)Intake StaffRandom Correctional Officers 1st Shift 5Random Correctional Officers 2nd Shift 4Random Correctional Officers 3rd Shift 3Random Staff Met/PREA During Facility Tour 6New Staff during Orientation 4Fifty-three (53) staff members were employed at the facility as of the May 31, 2017. Thirty (30) staff members were formallyinterviewed, some staff was interviewed twice or more using the Department of Justice audit questions that are included inthe overall staff count; the Auditor interacted with six (6) staff members during the facility tour, and spoke with four (4) newhires during their orientation.Sampling Interviews and Residents ContactFor random resident interviews, the PREA Compliance Manager provided the Auditor with lists of residents organized byhousing unit. The Auditor randomly identified residents according to each housing unit and the staff arranged for thoseresidents to be available for the required interviews.-Random In/mate Interviews 11Disabled – 0Limited English Proficient Inmates (use facility interpreter) - 0Transgender - 0Intersex Inmates - 0Inmates in Segregated Housing - 0Inmates who Reported Sexual Abuse - 1Inmates who Disclosed Prior Sexual Victimization - 1Gay or Bi-Sexual – 0Lesbian or Bi-Sexual - 0Random Residents Met/PREA During Facility Tour 10PREA Audit Report3
On May 31, 2017 the resident census reported the population count was 32 (22 Alabama Department of Youth Services (DYS)youth and 10 Alabama Department of Human Resources (DHS) youth) and the total bed capacity is 42. The age range of thepopulation is 12 to 18. Eleven (11) residents were formally interviewed by the Associate. The Auditor interacted with ten (10)residents during the facility tour.PREA Audit Report4
DESCRIPTION OF FACILITY CHARACTERISTICSThe Sequel Youth and Family Services Mission Statement:“Our mission is to prepare our clients to lead responsible and fulfilling lives by providing mentoring, education, and livingsupport within a safe, structured, dynamic environment – whether on one of our campuses, in the community, or in theirown homes.”The Sequel TSI Owens Mission Statement:“Our mission is to provide a comprehensive educational program that will enable the residents to maximize their potential asthey will have the knowledge to shape the future and become productive citizens who are contributing members of theircommunity and society. To this objective we will follow the defined principles of our beliefs.”Student Profile:ooooooooooFemales, age 12 to 18 years oldFull-scale IQ above 70Impulsive/irresponsible behavioral tendenciesDenies and/or justifies negative behaviorHas problem with anger and aggressionDemonstrates a low degree of empathyLacks self-disciplineExhibits poor coping skillsIs non-compliant with authorityMay have been adjudicated by the Juvenile Justice SystemThe interviewed residents and staff indicated that the Owens facility was a safe place.Facility BackgroundSequel Youth and Family Services is a privately owned company that develops and operates programs for people withbehavioral, emotional, or physical challenges.Sequel TSI Owens was established in 1996 as a residential treatment facility serving females assigned to the program by theAlabama Department of Youth Services, after being adjudicated in the state of Alabama. A separate unit is dedicated toserving females placed by the Alabama Department of Human Resources for intensive care and treatment. Sequel TSI Owensis a Medium Risk Secure Facility with 42 beds with 32 licensed by the Alabama Department of Youth Services and 10 bedslicensed by the Alabama Department of Human Resources.Facility AccreditationsThe Owens school program is recognized by the state of Alabama as a state supported school and is accredited by theAdvancEd/SACS-CASI, wherein all teachers hold Alabama teaching certifications.The facility was ACA Accredited, but reported no current ACA accreditations.Security SupervisionDirect Care staff provides security supervision. The security perimeter consists of no wire fences around the facility. A controlcenter in the front lobby monitors all traffic entering and exiting the facility. Numerous cameras control the perimeter andare placed throughout the facility to monitor security. The doors are open by staff with a key. The facility has one entrypoint; the front of the building is where staff and visitors enter. The staff to youth ratios is 1:8 during wake hours and 1:12during sleep hours.PREA Audit Report5
Facility Demographics-The facility’s rated capacity 42Actual population on the first day of the onsite audit 32Number of Females Housed 32 (22 DYS and 10 DHR)Number of males Housed 0Custody/Security Level in the facility MediumGeneral Medical Services On-siteMental Health Services On-siteInvestigation Off-Site (May be conducted by DYS, DHR or Local Law Enforcement)Programming OptionsOwens offered youth two program options:1. Intensive Therapeutic Long-Term Program for Females 13-18 years of age.Owens also provides career/basic living/ life skills education assists us in preparing residents to complete more competentlyand confidently upon completion of the program. This curriculum prepares residents for life outside of secured residentialsettings by teaching specific skills and building self-esteem through a variety of activity.There are also recreational activities, religious, and social services available.PREA Audit Report6
SUMMARY OF AUDIT FINDINGSThe Auditor conducted an exit conference with the agency and facility officials on Monday, May 31, 2017. Agency officials,facility officials, and staff were very open and receptive to an honest discussion regarding areas where PREA complianceneeds to be strengthened. The Facility Program Director began corrective action on each provision immediately. Present atthe exit conference:oooooExecutive Director/Regional AdministratorFacility Acting Program DirectorFacility PREA Compliance ManagerAdam Barnett, AuditorLater Davis, AssociateThe following are concerns shared with the facility:ooUnannounced RoundsShowers and ToiletsSpecific detail about deficiencies and corrective actions regarding these findings appears in the standard-by-standarddiscussions in the main body of the report.The standards are rated as exceed, met, not met, or not applicable. Most standards have between 1 – 15 provisions. Toachieve compliance on any given standard, the facility must achieve 100% compliance with each provision within thestandard. The Auditor used the Department of Justice Final Rule Prisons and Jail PREA Standards published in May 17, 2012.Forty-one (41) Juvenile Standards were audited.The Executive Director/Regional Administrator and the Facility PREA Compliance Manager were very knowledgeable aboutthe PREA requirements and the implementation of processes and systems.Specific detail about deficiencies and corrective actions regarding these findings appears in the standard-by-standarddiscussions in the main body of the report. If the facility completes all concerns within the 45 days before the Auditorreleased the primary report, then the report will be reviewed as the final report.Number of standards exceeded: 0Number of standards met: 38Number of standards not met: 0Number of standards not applicable: 3PREA Audit Report7
Standard 115.311 Zero tolerance of sexual abuse and sexual harassment; PREA Coordinator Exceeds Standard (substantially exceeds requirement of standard) Meets Standard (substantial compliance; complies in all material ways with the standard for therelevant review period) Does Not Meet Standard (requires corrective action)Auditor discussion, including the evidence relied upon in making the compliance or non-compliancedetermination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussionmust also include corrective action recommendations where the facility does not meet standard. Theserecommendations must be included in the Final Report, accompanied by information on specificcorrective actions taken by the facility.This standard directs the agency to adopt a zero tolerance policy for sexual abuse and harassment.Supporting Documents, Interviews and Observations:-Sequel TSI Owens Policy: 13.8.1 Protection from Sexual Abuse and AssaultPREA Written Institutional PlanFacility PREA Compliance Manager Letter – May 12, 2017State of Alabama Department of Youth Services Policy and ProceduresPrison Rape Elimination Act (PREA) Regulatory Guidelines (3-31-2014)Sequel TSI Owens: Pre-Audit Questionnaire (Juvenile Facilities)Agency Organizational ChartOwens Facility Organizational ChartInterviews:o Executive Director/Regional Directoro Agency PREA Coordinatoro Facility PREA Compliance ManagerFindings (By Provisions):(a) The Sequel TSI Owens Policy #13.8.1, Protection from Sexual Abuse and Assault mandates a zero tolerancetoward all forms of sexual abuse and sexual harassment. The policy outlined the agency’s approach to prevent,detect, and respond to sexual abuse and sexual harassment. The agency policy outline is found in section 1 page1. The agency policy clearly defines general definitions and definitions of prohibited behaviors to include sexualabuse and sexual harassments.(b) The Sequel TSI has established a full time position for an agency wide PREA Coordinator. Agency designates anupper level PREA Coordinator for the company who has sufficient time and authority to develop, implement andoversee all Sequel TSI efforts to comply with the PREA Standards in all of its facilities. The agency operates morethan one facility; each of Sequel TSI facilities are required to designate a PREA Compliance Manager withsufficient time and authority to coordinate the facility’s efforts to comply with the PREA Standards.(c) The Owens facility has a designated PREA Compliance Manager. An interview indicated that he has a great dealof correctional experience and sufficient time and authority to coordinate the facility’s effort to comply with thePREA Standards.Corrective Action and Verification: NonePREA Audit Report8
Standard 115.312 Contracting with other entities for the confinement of residents Exceeds Standard (substantially exceeds requirement of standard) Meets Standard (substantial compliance; complies in all material ways with the standard for therelevant review period) Does Not Meet Standard (requires corrective action)Auditor discussion, including the evidence relied upon in making the compliance or non-compliancedetermination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussionmust also include corrective action recommendations where the facility does not meet standard. Theserecommendations must be included in the Final Report, accompanied by information on specificcorrective actions taken by the facility.This standard directs the agency who has facilities for the housing of residents at other locations.This standard is rated non-applicable.Supporting Documents, Interviews and Observations:-Sequel TSI Owens Policy: 13.8.1 Protection from Sexual Abuse and AssaultState of Alabama Department of Youth Services Policy and ProceduresPrison Rape Elimination Act (PREA) Regulatory Guidelines (3-31-2014)Sequel TSI Owens: Pre-Audit Questionnaire (Juvenile Facilities)Professional Service Contract between Alabama Department of Youth Services and Sequel TSI of Alabama, LLC.Alabama Contract Review ReportInterviews:o Executive Director/Regional Directoro Agency PREA Coordinatoro Facility PREA Compliance ManagerFindings (By Provisions):(a) The Sequel TSI Family and Youth Services is the private agency that has authority with direct responsibility for theoperation of Owens location that confines residents. Therefore, the Sequel TSI Owens does not have authority tocontract with other entities for the confinement of residents. Interviews with the Facility PREA ComplianceManager and the Executive Director/Regional Director indicated that the facility does not and has not contractedany other entity for the confinement of residents.A review of the Pre-Audit Questionnaire, and confirmed by staff interviews, showed that there were zero contractsfor the confinement of residents that the facility entered or renewed with private entities or other governmentagencies since the last PREA audit.Corrective Action and Verification: NoneStandard 115.313 Supervision and monitoring Exceeds Standard (substantially exceeds requirement of standard) Meets Standard (substantial compliance; complies in all material ways with the standard for therelevant review period)PREA Audit Report9
Does Not Meet Standard (requires corrective action) Auditor discussion, including the evidence relied upon in making the compliance or non-compliancedetermination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussionmust also include corrective action recommendations where the facility does not meet standard. Theserecommendations must be included in the Final Report, accompanied by information on specificcorrective actions taken by the facility.This standard directs the facility in how to monitor and supervise residents as it relates to PREA.Supporting Documents, Interviews and Observations:-Sequel TSI Owens Policy: 13.8.1 Protection from Sexual Abuse and AssaultPREA Written Institutional PlanSequel TSI Owens Policy: 3000.23 Resident ObservationVariable Staffing Plan (DYS and DHR Combined)State of Alabama Department of Youth Services Policy and ProceduresPrison Rape Elimination Act (PREA) Regulatory Guidelines (3-31-2014)Sequel TSI Owens: Pre-Audit Questionnaire (Juvenile Facilities)Sequel TSI Owens Administrative Site Visit: Unannounced RoundsFacility Staff Work SchedulesDaily Population ReportsFacility Vulnerability AssessmentsFacility RosterPREA Form 115.113 Supervisory Monitoring LogAnnual Review of Staffing Assessment (DYS 115.332)Interviews:o Executive Director/Regional Directoro Agency PREA Coordinatoro Facility PREA Compliance Managero Higher Level Facility StaffFindings (By Provisions):(a) The Owens Facility develops, documents, and makes its best efforts to comply on a regular basis with a staffingplan that provides for adequate levels of staffing, and uses video monitoring to protect residents against abuse. Aninterview with the Executive Director indicated that the facility takes into consideration the 11 requirements instandard 115.13 (a) – 1: Generally accepted detention and correctional practices;Any judicial findings of inadequacy;Any findings of inadequacies from Federal Investigative agencies;Any findings of inadequacy from internal and external oversight bodies;All components of the resident population;The composition of the resident populationThe number and placement of supervisory staff; institution programs occurring on a particular shift;Any applicable State or Local Laws, Regulations or Standards;The prevalence of substantiated or unsubstantiated incidents of sexual abuse; andAny other relevant factors.(b) An interview with the Executive Director revealed each time the staffing plan is not complied with, the facilitydocuments and justifies all deviations from the staffing plan. Cameras are strategically located to supplementPREA Audit Report10
staffing and to enhance supervision of residents. There are approximately 11 plus cameras deployed. Theauditor is not going to provide further information related to these because of security concerns; however,observations made during the tour confirmed this facility has a considerable number of cameras strategicallylocated throughout the facility supplementing supervision inside the facility fence and outside.The Owens Facility has cameras installed. Cameras have been placed in all housing units, common areas andhallways. Cameras can be viewed in the control center.(c) The Sequel TSI Owens policy and the interview with the Facility PREA Compliance Manager revealed that atleast annually, in collaboration with the PREA Coordinator, the facility reviews the staffing plan to see whetheradjustments are needed in: The staffing plan;The deployment of monitoring technology orThe allocation of agency/facility resources to commit to the staffing plan to ensure compliance.The Executive Director and PREA Compliance Manager, in interviews, confirmed the process for conductingannual reviews. A review of the Pre-Audit Questionnaire and confirmed by staff interviews, the average dailynumber of residents on which the staffing plan was predicated is 42 beds.(d) Interviews with the Facility Management Team and documentation reviewed revealed that the intermediatelevel and/or higher level staff conduct unannounced rounds to identify and deter staff sexual abuse and sexualharassment. Sequel TSI Owens policy requires unannounced rounds to be performed on all shifts and all areasof the facility occupied by residents.When announced rounds are being conducted, the Sequel TSI Owens policy directs staff not to alert other staff.Interviews with some intermediate level staff indicated that unannounced rounds occur on all shifts throughoutthe facility to include housing units, kitchen, booking, laundry, and any area where residents have access to.The facility provided documentation to confirm unannounced rounds are being conducted. Unannounced roundsare documented using the Administrative Site Visit: Unannounced Rounds form. The documentation reviewedfrom the Administrative Site Visit: Unannounced Rounds form needs more detail.Corrective Action and Verification:Concern #1: A review of the Administrative Site Visit: Unannounced Rounds documentation need more details covering theactions of the rounds.The PREA Compliance Manager and Facility Program Director corrected this concerns by issuing a directive to all staffconducting unannounced PREA rounds to details in documenting such rounds.Standard 115.315 Limits to cross-gender viewing and searches Exceeds Standard (substantially exceeds requirement of standard) Meets Standard (substantial compliance; complies in all material ways with the standard for therelevant review period) Does Not Meet Standard (requires corrective action)Auditor discussion, including the evidence relied upon in making the compliance or non-compliancedetermination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussionPREA Audit Report11
must also include corrective action recommendations where the facility does not meet standard. Theserecommendations must be included in the Final Report, accompanied by information on specificcorrective actions taken by the facility.This standard directs the facility about how it treats transgendered and intersex residents in regards to cross-gender stripsearches or cross-gender body cavity searches.Supporting Documents, Interviews and Observations:-Sequel TSI Owens Policy,13.8.1 Protection from Sexual Abuse and AssaultSequel TSI Owens Policy, 3000.8 Control of ContrabandSequel TSI Owens Policy, 3003.46 Staff Conduct with DYS Students of the Opposite SexSequel TSI Owens Policy, 9.10 SearchesIn-Service Staff Training RosterPrison Rape Elimination Act (PREA) Power PointPREA Written Institutional PlanState of Alabama Department of Youth Services Policy and ProceduresPrison Rape Elimination Act (PREA) Regulatory Guidelines (3-31-2014)Sequel TSI Owens: Pre-Audit Questionnaire (Juvenile Facilities)PREA Form 115.315 Cross Gender Strip SearchesPREA Form 115.315 Cross Gender Pat-Down SearchesShift Duty AssignmentsMedical Reports (Medical Examination of Transgender or Intersex Juvenile)Interviews:o Executive Director/Regional Directoro Agency PREA Coordinatoro Facility PREA Compliance Managero Random Officerso Non-Medical Staff Cross Gender Searches (Officer)o Random ResidentsFindings (By Provisions):(a) The Sequel TSI Owens policy directs staff not to conduct cross-gender strip searches or cross-gender visual bodycavity searches (meaning a search of the anal or genital opening) except in exigent circumstances or whenperformed by medical practitioners. Documentation review indicated that Owens reports no exigentcircumstances for this audit period. The facility maintains a log book to document when exigent circumstancesoccur. The facility’s search policy prohibits female staff from conducting strip searches or cross-gender visualbody cavity searches except in exigent circumstances or when performed by authorized medical personnel.Facility documentation also indicated that no female staff member has been authorized to conduct the abovesearches within the PREA audit period. Interviewed staff related female staff does not conduct cross-gender patsearches on male residents. Interviews with residents confirmed that none of them had been strip searched by afemale officer.(b) Staff interviews and facility documentation indicated that all cross-gender strip searches and cross-gendervisual body cavity searches will be documented. The facility houses female residents only.(c) The Sequel Youth and Family Service policy, requires Owens to implement policies and procedures that enableresidents to shower and perform bodily functions and change clothing without non-medical staff of the oppositegender viewing the breasts, buttocks or genitalia, except in exigent circumstances or when such viewing inincidental to routine cell or bed checks. Interviewed residents stated they are never naked in full view of staff andare provided privacy while changing clothes, showering and using the restroom.PREA Audit Report12
(d) According to staff interviews and documentation review, the facility has housed zero transgender residents withinthe past 12 months. Sequel Youth and Family Services directs staff not to search or physically examine atransgender or intersex resident for the sole purpose of determining the resident’s genital status. If the resident’sgenital status is unknown, the facility may determine during conversations with the resident, by reviewing medicalrecords, or, if necessary, by learning that information as part of a broader medical examination conducted inprivate by a medical practitioner.(e) The staff received training on how to conduct cross-gender pat-down searches, and searches of transgender andintersex residents, in a professional and respectful manner, and in the least intrusive manner possible, consistentwith security needs. The facility provided samples of documentation to confirm staff has received and receivesearch training consistent with the Sequel Youth and Family Services policy. The PREA Compliance Managerconfirmed there have been no cross-gender strips or visual body cavity searches conducted within the auditedcycle.A review of the Pre-Audit Questionnaire, and confirmed by staff interview, showed that in the past 12 months therewere zero cross-gender strip and visual body cavity searches of residents.Overall Interview Results:Twelve (12) security staff, representing staff from all three shifts, was interviewed. One hundred percent (100%) ofstaff interviewed indicated that cross-gender pat searches were not conducted. While they are not prohibited, suchsearches would only occur in exigent circumstances. None of the interviewed staff could recall a circumstance thatwarranted a cross-gender pat down search. One hundred percent (100%) of the interviewed staff stated
Facility type: Correctional Detention Other Name of facility’s Chief Executive Officer: Bette Moore Number of staff assigned to the facility in the last 12 months: 53 Designed facility capacity: 42 Current population of facility: 32 Facility security levels/inmate cu
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