Philip L. Torrey, Immigration Detention’s Unfounded Bed Mandate, 15-04 Immigr. Briefings 1 (2015).
Abstract: This article (1) reviews the history of the immigration bed mandate (or bed quota) from 2009 to present, (2) discusses its inconsistent interpretation by the U.S. Department of Homeland Security, and (3) offers reasons why the bed mandate is both constitutionally questionable and bad policy.