August 18, 2022 IJJC Compliance Committee Meeting


Illinois Juvenile Justice Commission Compliance Committee Members and Staff. The public is welcome to attend.


August 18, 2022 Time: 1:00pm


Video Conference Information:


  1. Welcome, Introductions & Roll Call
  2. Compliance Manual Submission Updates
  3. Compliance Determination Discussion
    1. Jail Removal Violations
  4. Implementation of Compliance Strategies
    1. Local Jail Removal
    2. Compliance Manual and Policies
  5. New Business
  6. Public Comment
  7. Adjourn


  1. Welcome, Introductions & Roll Call
    Chairman Rick Velasquez called the meeting to order at 1 p.m. and invited Executive Director Andrea Hall to call roll.
    Roll Call: Bob Bowen, Lisa Jacobs, Rick Velasquez, Ebonie Epinger, Andrea Hall, Sav Felix, Peg Robertson, Tobata Richardson, Dan Hunt, Julie Biehl
    Staff: Seth El-Jamal
    Introductions-Drea Hall
    Open Roll call, no action to be taken.
  2. Compliance manual update
    Review compliance monitoring strategies in lieu of being out of compliance
    Executive Director Andrea Hall gave a brief update on the compliance manual approval process from OJJDP. The manual was submitted ahead of the deadline. OJJDP responded with edits that needed to be addressed. After edits were completed, the manual was accepted and approved by OJJDP on August 12th. Recognition was specifically given to Lisa Jacobs and the Loyola team of pre-law interns who did a great deal of work to complete the manual. Co-Chair Lisa Jacobs thanked Bob Bowen for his support. Lisa also thanked Executive Director Andrea Hall for her increased support and work with OJJDP. The implementation phase will now begin.
  3. Compliance determination discussion
    Executive Director Andrea Hall gave a brief update on the status of compliance determination. The IJJC Title II application has been submitted but the IJJC did not meet the de minimis numbers for 2022 Compliance. Andrea Hall stated Illinois was over the minimum number of allowed violations by twice the amount and therefore, will be officially out of compliance in the near future. She also stated that after Sept 1, 2022, Illinois will receive official notice of their compliance status and funding for the next year.
    Chairman Rick Velasquez asked how the non-compliance status will affect funding for 2022.
    Andrea Hall responded that there are currently 19 grantees through Title II funding. The Commission will have to reduce contracts for Title II for the larger contracts as a result of being out of compliance.
    Rick Velasquez stated the Compliance Committee will continue to be an important element in making sure that the new compliance strategy is progressing, "Our work has just begun".
    Andrea Hall added that some states might be out of compliance due to the changes in the monitoring universe including possibly California and Nevada. Many states do not know how they would implement new compliance strategies and therefore might withdraw from Title II funding as a result.
    Peg Robertson stated that she would be curious to see if OJJDP will change their definitions due to the fact several states could be out of compliance.
    Lisa Jacobs stated that the nomenclature "jail removal" is misleading. We all agree that we want no youth in county jails, but the problem is not in county jails. The major problem is police facilities. The point is conflating custody definitions is inaccurate and it needs to be communicated differently.
    Bob Bowen stated that inspectors call him. In the last three years he has had 5 youth in jails that have been brought to his attention.
    Lisa Jacobs stated that youth are at highest risk for abuse in jails and wondered if OJJDP is considering separating jails and lockups.
    Lisa also suggested this list as the main items to strategize around.
    1. Violations are not happening in jails; they are happening in police lockups.
    2. Laws are not in alignment.
    3. When does the clock start and stop? When does is a youth considered incarcerated? At what point does the clock stop as it relates to when a youth is sent home or to a detention center?
    4. We know from data that violations are occurring in Chicago "hot spot" districts. We're not sure that districts even know the OJJDP requirement. Make sure that CPD knows the standards.
    5. Can we investigate and find out why districts are out of compliance. (Staffing issues, pandemic related, etc.)
    6. Should we be changing the Illinois statute to match the federal statute?

    Rick Velasquez stated that he did not believe there has been adequate effort to provide local districts feedback, to make sure that they are aware of the issue. The IJJC's work with detention centers has shown that when you begin showing the data, they are willing to engage. The power of information and relationship building is critical in the process.
    Bob Bowen stated that the Illinois Chief of Police Association has a new Executive Director. Kenny Winslow is a former Chief of the Springfield Police Department. This might be the time to build a relationship with him to begin a new conversation about compliance challenges statewide. His colleagues speak highly of him.
    Tobara Richardson stated that she has identified Ashly Wright as a potential resource. Ms. Wright has worked with previous and current Attorney Generals. Tobara tated that if there is something to address, it could be added to the IJJC list of items to bring to her attention. Tobara asked the Commission to brief her office about the statute and the issue. She also stated that if the compliance issue can be packaged in a brief set of statements, it could be communicated clearly. Lastly, she stated that she doesn't make any final decisions but could support the process and build the relationship.
    Bob Bowen reminded the Commission that changing the rules on compliance violations relative to jail removal will be a legislative fight. He stated that he believed in the idea of making statutes consistent across the board and would be beneficial for the Department of Corrections. The police chiefs see the flexibility of the current 16 hours as a benefit.
    Andrea Hall explained that one of the IJJC interns suggested establishing a city ordinance that aligns with the Federal statute, working with Mayor Lightfoot stating that CPD cannot hold youth longer than 6 hours.
    Bob Bowen stated that the problem with the 6-hour rule is that municipalities must rely on probation officers to arrive at a facility within the 6-hour time period and they cannot.
    Lisa Jacobs stated that the Commission should divide the current challenges into three areas of work. These are listed below

    1.  Addressing cook county/ CPD- this is where most of the violations occur.
    2. Identify and categorize the monitoring universe STATE-WIDE and build a more functional monitoring strategy.
    3. Generalized work and build communication materials (ICOY) and TTA programs.
      Lisa Jacobs asked Tobara Richardson if the AG Office has all the background on jail removal issues? She suggested that the Commission work to draft briefing materials for this issue. Tobara agreed with this suggestion.
      Julie Biehl stated that there are people who have been negotiating with the city of Chicago that could provide intel in the conversations around policing. This is an issue for the Inspector General and noted they have been doing a lot of engagement with CPD. Lastly, she referenced Katie Culleeny, who used to as a resource as she is working in a Juvenile Justice role in the mayor's office.
      Andrea Hall recounted a meeting in May with Jaren Smith, the new CPD Juvenile Commander. The Commander stated he is aware of the 6-hour rule and said the reason youth are being held longer is because of the higher charges necessitate more time to investigate. Staffing issues were referenced as a reason for the delays but the Commander Smith would not verify that as the cause.
      Rick Velasquez stated that the data shows most violations are about 1-2 hours over the 6-hour rule. These are not egregious violations. Commander Smith gave the IJJC permission to work with the detectives, his team, and other juvenile officers around the city. Commander Smith is not surprised by the data and is also interested in ideas around deflections and diversion. He was intrigued by the different practices in other districts and wondered why it was not happening here. He wants that to be something we head toward.
      Lisa Jacobs suggested to create a Compliance workgroup to build briefing materials for legislators and stakeholders.
      Rick Velasquez stated that he would like to begin a conversation about how JAMIS data is gathered, scrubbed, and disseminated so the IJJC can consider how to improve that methodology. Bob Bowen agreed and stated that he would like to involve his administrative assistant in the process.
  4. Compliance Manual and Policies
    Due to time constraints, did not discuss.
  5. New Business
    None noted.
  6. Public Comment
    None noted.
  7. Adjourn
    Meeting adjourned at 2:00pm.