Erron Anthony Clarke, a Jamaican citizen seeking permanent residency, was detained in a federal courthouse in Central Islip, New York, under conditions described as inhumane. He spent over two days in a cramped cell measuring approximately 6 feet by 6 feet, shared with eight others, while the outside temperature fell to 21 degrees Fahrenheit. The cell lacked adequate heating, and detainees were unable to shower, with lights kept on continuously.

Judge Gary R. Brown, who has nearly 35 years of experience in federal law enforcement and was appointed by President Trump in 2019, issued a critical 24-page opinion regarding Mr. Clarke's treatment. He noted that he had never encountered such conditions in his career and accused Immigration and Customs Enforcement (ICE) of providing false information about Mr. Clarke's arrest. The judge also pointed out that ICE had failed to comply with court orders by not presenting Mr. Clarke for a hearing and not providing photographs of the detention cell, questioning whether the agency should face contempt charges.

This opinion reflects a broader trend, as judges across the United States have increasingly criticized the conditions in federal detention facilities. In August, a federal judge mandated improvements to the holding cells used for migrants at 26 Federal Plaza in New York City. Similarly, a judge in Chicago described the conditions at an ICE facility as "unnecessarily cruel" and imposed restrictions on its operations.