In a scathing ruling, a federal judge has ordered that safeguards against what he called "inhumane and unconstitutional” conditions at federal immigration holding cells in Lower Manhattan be made permanent — including limiting the number of detainees that can be held at the site.
The ruling by Judge Lewis A. Kaplan of the U.S. District Court in Manhattan extends rules he first put in place in summer 2025, when the lawsuit regarding conditions at the Jacob K. Javits Federal Building at 26 Federal Plaza was first filed. The rules also include providing immigrant detainees with hygiene products, regular meals, confidential calls with attorneys, and a minimum of 50 square feet of space per detainee.
“By detaining far more persons in the hold rooms than ever was intended and for far longer than ever was intended, ICE objectively deprived detainees of sleep, sanitary living conditions, basic personal hygiene needs, sufficient food and water, and adequate medical care,” Kaplan wrote in a 127-page ruling.
He added, “ICE knew, or should have known, that how it was treating detainees was wrong, yet it continued to do it anyway. It did so to inflict punishment on detainees and induce them to self-deport.”
A spokesperson for the Department of Homeland Security, which oversees ICE and the Manhattan holding cells, issued a statement downplaying Kaplan’s findings that the conditions at the ICE holding rooms were both deplorable and intentional. The statement emphasized that the holding rooms were intended for short-term detention.
The statement said the agency is committed to ensuring the safety and security of detainees. It did not address specific concerns highlighted by the judge.
The ruling is a victory for immigrant rights’ advocates who for months have decried conditions at the ICE holding cells at the 26 Federal Plaza, which has emerged as an epicenter of immigrant enforcement in the city under President Donald Trump’s administration.
In addition to housing the ICE holding cells, the Lower Manhattan building is also home to an immigration court and ICE check-in office where federal officers have increasingly arrested immigrants under Trump’s second presidential term. For days on end, detainees were held in crowded holding rooms, under what Kaplan found were harsh conditions.
The holding cells, built without beds or showers, were once temporary waystations where immigrants would be detained for typically a few hours before being transferred to a more permanent ICE detention center. However, as ICE began arresting a record number of immigrants last summer, there were more detainees than available bed spaces, according to court records, and the agency crammed dozens of people into the cells for days on end.
Kaplan also said ICE employees had attempted to “sanitize the record” of the reality of those conditions. He found that ICE officials repeatedly violated his past orders mandating minimum standards of care at the site — by exceeding capacity restrictions on at least 84 days, failing to provide confidential legal calls, and failing to meet other mandated basic living standards for detainees.
Kaplan’s ruling is the latest in a lawsuit brought over a year ago by immigrants rights’ and civil liberties groups, including the American Civil Liberties Union and the advocacy group Make the Road New York. He wrote that it was necessary to make permanent the minimum standards of care at the facility because it seems unlikely that ICE would start reducing arrests or add more beds in other “appropriate” detention facilities.
ICE arrests in the New York City area surged this summer, according to agency data. Monthly ICE arrests in the region were highest in June 2025, however, shortly after ICE officials began arresting immigrants en masse after exiting their immigration court proceedings. A federal judge in May temporarily blocked that practice.
Harold Solis, co-legal director of Make the Road New York and one of the plaintiff’s attorneys, said the squalid conditions at 26 Federal Plaza are emblematic of the Trump administration’s contempt for the rule of law and hostility toward immigrants.
“We are clear-eyed that these abuses did not occur in isolation,” Solis said in a statement. “They are part of a broader pattern of cruelty and lawlessness that has characterized this administration’s treatment of immigrants over the past year, fueling fear, inflicting profound harm on communities, and undermining the rights and safety of citizens and noncitizens alike.”
Kaplan’s opinion highlighted several individual cases of detainees held in “overcrowded, squalid, and degrading” conditions. Citing the trial record, Kaplan noted that one man was held for nearly three weeks in a room with up to 90 people.
Another spent 19 days in the same clothes without bathing. One woman said guards gave a whole room of women only two menstrual pads. The woman’s clothes were stained with blood when she was on her period.
Others reported a lack of available water. One man described waiting his turn for a guard to squirt water from a bottle into detainees' mouths; another man said guards required them to drink from bathroom sinks because there wasn’t enough bottled water.
And several concerns arose about medical care. At the peak of the overcrowding in early July 2025, the facility held a detainee who tested positive for tuberculosis for six days. Another detainee was held for three days with a large ovarian cyst that an officer reported “could become a life or death emergency if ruptured.”
Kaplan also certified the lawsuit as a class-action claim, allowing the plaintiffs to represent any immigrants currently detained at 26 Federal Plaza or who will be detained there in the future.
“While we applaud the court’s decision to issue permanent protections requiring ICE to improve conditions at 26 Federal Plaza, it shouldn’t take a federal lawsuit to get the government to comply with the law,” said Carmen Iguina Gonzalez, deputy director of immigration detention for the ACLU’s National Prison Project. “As our legal teams have argued before, the conditions at this facility were entirely a crisis of ICE’s own making. We will continue to hold ICE accountable and ensure that people’s rights are upheld.”
