How DHS Creates Ethical Dilemmas for Emergency Managers
The most critical ethics issue facing emergency managers today is the misuse of emergency management resources by the Department of Homeland Security, particularly ICE, to support the administration’s anti-immigration policy. By involving emergency managers in roles that violate our ethical standards, DHS has diminished public trust for the emergency management community.
The most egregious misuse of emergency management resources was the creation and operation of the detention center commonly called Alligator Alcatraz by the Florida Department of Emergency Management (FDEM). FDEM managed the construction, daily operations, and vendor contracting for the facility.
The use of emergency management resources to support immigration is not without precedent. In April 1980 economic and social conditions resulted in a vast migration of Cubans to the United States. Cuba allowed anyone who wished to leave to do so, and the United States granted temporary status to the refugees. Local governments were quickly overwhelmed, and President Jimmy Carter declared a state of emergency under the Disaster Relief Act of 1974. The Federal Emergency Management Agency (FEMA) was the lead agency responsible for coordinating the on-scene federal humanitarian and operational response. FEMA opened and operated major refugee resettlements and housing camps across the country to handle the massive influx of over 125,000 migrants. These included facilities at Eglin Air Force Base (Florida), Fort Chaffee (Arkansas), Fort McCoy (Wisconsin), and Fort Indiantown Gap (Pennsylvania).
Compare this humanitarian response with the conditions in Alligator Alcatraz which was funded by FEMA funds diverted from Shelter and Services Program. The September 11, 2026, Inspector General Report, titled Unannounced Inspection of ICE’s Florida Soft-Sided Facility (“Alligator Alcatraz”) in Ochopee, Florida, identified six key findings:
Key Finding 1: FSSF Did not Comply with Environmental Health and Safety Standards
Key Finding 2: FSSF Did not Comply with Special Management Units (SMU) Standards
Key Finding 3: FSSF Did not Comply with Medical Standards Related to Withdrawal Monitoring
Key Finding 4: FSSF Did not Comply with Food Service Standards
Key Finding 5: FSSF Did not Comply with Personal Hygiene Standards
Key Finding 6: FSSF Did not Comply with Recreation Standards
In summary, the IG found, “staff could not clearly identify which detention standards they used for holding detainees on immigration-related charges… the facility complied with Intake and Use of Force standards but did not comply with standards…”
A report by Amnesty International, titled Torture and Enforced Disappearances in the Sunshine State: Human Rights Violations At “Alligator Alcatraz” and Krome in Florida, details numerous civil rights violations and concluded: “Amnesty International considers that detention conditions at both facilities amount to cruel, inhuman and degrading treatment. The use of prolonged solitary confinement…amount to torture or other ill-treatment.”
Efforts to hold the Director of FDEM accountable for the conditions at Alligator Alcatraz under a code of ethics were stymied because the Director was not bound by a specific code of ethics, as he is not a member of the International Association of Emergency Manager and no longer holds a certification from that body.
This is only the most highly visible example of ethics violations of the misuse of emergency management resources. What has been quietly happening behind the scenes is even worse.
You may recall that at the beginning of the current administration, FEMA had identified a shortfall of 35% of the personnel it needed. In response, the administration began planning not to reinforce FEMA but to decrease the workforce by 50%. The initial target was Cadre of On-Call Response/Recovery (CORE) employees. To effect this reduction, DHS removed FEMA’s authority to extend CORE contracts.
DHS eventually offered new contracts to former CORE employees, but the contracts came with a catch. The employees had to agree to be detailed to ICE. According to an investigative report by the subcommittee on Economic Development, Public Buildings and Emergency Management, titled Stretched Thin: The Erosion of FEMA’s Core Mission Under DHS: How the Department of Homeland Security Diverted Federal Emergency Management Agency Resources to Support Immigration Enforcement and The Consequences for America’s Disaster Readiness, “FEMA personnel were directed to perform functions, including operational planning for arrests, raids and patrols; processing and logistics for detained noncitizens; recruiting and onboarding ICE officers; and day-to-day management of immigration detention facilities…One witness described FEMA as the “operational backbone” of the enforcement campaign, stating, ‘ICE could not have done this work without FEMA.’” The use of emergency management personnel for these purposes is not what we do and a clear violation of our mandate to help those in need.
The good news is that United States District Court for Northern District of California has ruled that DHS violated the Post-Katrina Emergency Management Reform Act of 2006 (PKEMR). PKEMR made FEMA a distinct entity within DHS and transferred all functions, including personnel, to FEMA. This provides the opportunity for FEMA to reclaim responsibility for its personnel management. Unfortunately, the court did not provide any form of compensation because situations have changed since the lawsuit was filed. DHS and the plaintiffs have until October 9 to meet and confer and report back to the court. It is also well to remember that FEMA was under no obligation to reduce staffing but chose to do so according to the court findings. While this is a slight glimmer of hope, at will depend on FEMA’s leadership.