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Just as the large number of post-conviction habeas petitions is related to the massive size of the U.S. criminal justice system, as immigration detention has expanded in scope and size over the past several years, habeas petitions challenging that confinement have increased, as well. Immigration detention is at its most massive level ever. At the end of 2018, ICE was holding 47,486 individuals in 215 facilities across the country, about 10% of whom had been detained over six months.
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