Corporate Misconduct Accountability Project
The GEO Group, Inc. · Class Action
GEO Group Forced Immigrant Detainees to Work for $1 Per Day
Private prison company GEO Group systematically exploited hundreds of immigrant detainees at its Washington facility, paying $1 per day for essential labor while pocketing millions in federal contracts. A federal court ruled the practice violated state minimum wage laws.
CRITICAL SEVERITY
TL;DR
GEO Group operated the Northwest ICE Processing Center in Tacoma, Washington under a federal contract worth over $700 million. The company ran a so-called Voluntary Work Program where hundreds of civil immigration detainees performed essential facility operations including cooking, cleaning, laundry, and waste management for $1 per day. A jury awarded over $17 million in back pay to detainees, and the state won nearly $6 million in unjust enrichment. The Ninth Circuit Court of Appeals upheld the verdict, finding GEO violated Washington’s Minimum Wage Act by paying detainees far below the state’s minimum wage while profiting enormously from their labor.
This case exposes how privatized immigration detention creates financial incentives to exploit captive labor.
$700M
Minimum value of GEO’s 10-year federal contract to operate the detention center
$1/day
What GEO paid detainees for essential facility work
$17.3M
Back pay damages awarded to detainee class
$5.95M
Unjust enrichment awarded to Washington State
$16.28/hr
Washington minimum wage GEO refused to pay
200-500
Detainees working in the program daily before lawsuit
$18.6M-$23.5M
GEO’s annual gross profit from managing NWIPC (2010-2018)
The Allegations: A Breakdown
Core Allegations
What GEO Did · 8 points
| 01 | GEO operated a Voluntary Work Program at the Northwest ICE Processing Center in Tacoma where civil immigration detainees performed essential facility operations for $1 per day. Detainees cooked meals for the entire facility, cleaned dormitories and common areas, did laundry for all 1,575 detainees, managed waste, and performed building repairs. | high |
| 02 | GEO relied so heavily on detainee labor that it operated the kitchen with only 13 full-time outside employees while using nearly 100 detainees daily to prepare meals, cook, serve food, and wash dishes. Without detainees, the kitchen staff would have been absolutely unable to meet demand. | high |
| 03 | In the laundry room, one full-time outside employee supervised 12 to 15 detainees processing industrial loads of laundry for the entire facility seven days a week. Detainees cleaned the majority of secured common areas including the kitchen, laundry room, communal bathrooms and showers, and recreational areas. | high |
| 04 | GEO estimated it would need to hire approximately 85 additional full-time outside employees if the work program ended. By using detainee labor at $1 per day instead of paying Washington minimum wage, GEO saved millions of dollars in payroll costs. | high |
| 05 | GEO occasionally increased pay to up to $5 per day when necessary to attract sufficient workers during hunger strikes or disease outbreaks, then always resumed paying $1 per day as soon as practicable. The company never paid detainees Washington’s minimum wage despite their essential role in facility operations. | high |
| 06 | One detainee testified in his deposition about why he participated in the program despite the exploitative pay: I need the money desperately. I have no choice. | high |
| 07 | Between 200 and 500 detainees at NWIPC participated in the work program daily before this lawsuit. GEO operated the program continuously since taking over the facility in 2005, relying on it as a core component of its business model. | high |
| 08 | GEO’s gross profit from managing NWIPC ranged between $18.6 million and $23.5 million per year from 2010 to 2018, with net profit margins of 16 to 19 percent. The company’s profit model depended directly on paying detainees far below market wages. | high |
Regulatory Failures
How the System Enabled This · 6 points
| 01 | GEO’s contract with ICE required the company to comply with all applicable federal, state, and local laws and standards, including labor laws and codes. The contract explicitly stated that if a conflict exists between federal and local standards, the most stringent standard shall apply. | high |
| 02 | Despite this contractual requirement, GEO never complied with Washington’s minimum wage law. ICE played no role in developing or managing the Voluntary Work Program at NWIPC. GEO created job roles and descriptions, set work schedules, provided training, supervised detained workers, and managed payroll. | high |
| 03 | The federal government’s Performance-Based National Detention Standards require contractors to offer voluntary work programs and guarantee monetary compensation of at least $1.00 per day. However, nothing in federal law or GEO’s contract prohibits paying detainees more than $1 per day. | medium |
| 04 | GEO routinely paid detainees up to $5 per day when necessary to attract workers, doing so without any objection from ICE. The government never claimed GEO violated its contract by paying higher wages, and has never objected to contractors paying above the $1 per day minimum. | medium |
| 05 | A former GEO detention officer testified at trial that GEO was free to add fully paid positions to its staff at NWIPC without a contract modification, and that GEO often did so with the understanding that it would not be reimbursed by the federal government for the cost of those additional positions. | medium |
| 06 | ICE and GEO suspended the Voluntary Work Program at NWIPC on October 28, 2021 during the pendency of this litigation rather than pay Washington’s minimum wage. Hundreds of detainees lost access to the program’s benefits as a result of the district court’s ruling. | high |
Profit Over People
The Business Model · 7 points
| 01 | GEO’s ten-year contract with ICE that began in 2015 awarded the company a minimum of $700 million over ten years. The company’s business model maximized profits by minimizing labor costs through the $1 per day work program. | high |
| 02 | By paying detainees $1 per day instead of Washington’s minimum wage of $16.28 per hour, GEO operated the facility with just a handful of full-time staff hired from the local area, thereby saving millions of dollars that it would otherwise have spent on payroll. | high |
| 03 | The work performed by detainees was not incidental but essential to GEO’s ability to fulfill its contractual obligations to ICE. The contract required GEO to keep NWIPC clean and free of pests, dispose of waste appropriately, provide clean linens and blankets, and serve detainees three nutritious meals daily. | high |
| 04 | During the relevant period, GEO relied heavily on the labor of detained workers to fulfill its contractual duties. Without the help of detainees, the kitchen staff would have been absolutely unable to meet demand, according to trial testimony. | high |
| 05 | The jury awarded $17,287,063.05 in back pay damages to the detainee class for work performed from 2014 through 2021. Divided by seven years, this equals just under $2,500,000 per year in wages GEO withheld. | high |
| 06 | Even after subtracting $2.5 million annually from GEO’s gross profits of $18.6 to $23.5 million per year during 2010-2018, the company would still retain a profit margin of roughly $16 to $21 million per year while complying with the minimum wage law under its current contract. | medium |
| 07 | GEO is a publicly traded private corporation that operates detention and prison facilities for shareholders’ economic gain. The company profits from every cost reduction, creating a direct financial incentive to exploit captive labor. | high |
Worker Exploitation
The Human Cost · 8 points
| 01 | Detainees at NWIPC are civil detainees awaiting administrative review of their immigration status. They are not in criminal proceedings. Some lack legal status in the United States while others are lawful permanent residents with work authorization. | medium |
| 02 | The facility has a maximum capacity of 1,575 detainees. All are held until they are either deported because they have no legal status or released into the United States because they have a legal right to be here. | low |
| 03 | Despite low pay and working conditions, detainees participated in the work program because of the situation in which they had been placed. One detainee testified: I need the money desperately. I have no choice. | high |
| 04 | The work program was labeled voluntary but GEO’s control over essential aspects of detainees’ lives made participation effectively mandatory. Detainees had no realistic alternative to participating if they wanted any income while detained. | high |
| 05 | Detainees who participated could work no more than 8 hours per day and 40 hours per week according to federal detention standards. At $1 per day, a detainee working the maximum 40 hours per week earned just $7 per week, regardless of hours worked. | high |
| 06 | By contrast, if paid Washington’s current minimum wage of $16.28 per hour, a detainee working 8 hours per day would earn $130.24 per day instead of $1. A detainee working 4 hours per day would earn $65.12 instead of $1. | high |
| 07 | The Washington Supreme Court concluded that detainees employed by GEO in the work program were employees within the meaning of Washington’s Minimum Wage Act, and that the law requires GEO to pay Washington’s minimum wage to those detainees. | high |
| 08 | Every day, hundreds of civil detainees at NWIPC worked for GEO performing tasks essential to the operation of the facility. Because of the labor provided to GEO by detained workers, GEO operated its facility with just a handful of full-time staff hired from the local area. | high |
Corporate Accountability Failures
Legal Pushback · 8 points
| 01 | GEO argued that Washington’s Minimum Wage Act violated the doctrine of intergovernmental immunity by treating the federal government differently than the state treats itself. The Ninth Circuit rejected this argument, finding that the law applies equally to all private employers regardless of government affiliation. | medium |
| 02 | GEO claimed it was entitled to derivative sovereign immunity under the government contractor defense. The court rejected this claim, finding that GEO’s contract does not forbid paying Washington’s minimum wage and nothing in the contract dictates the challenged conduct. | medium |
| 03 | GEO argued that federal law preempted Washington’s minimum wage law as applied to immigration detainees. The court found no clear and manifest purpose of Congress to preempt state minimum wage laws from applying to private contractors operating immigration detention facilities. | medium |
| 04 | The dissenting judge argued that Washington violated the Supremacy Clause by treating NWIPC worse than state-run detention facilities, which are exempt from the minimum wage law. The majority held that the relevant comparison is between private facilities, not between private and government-run facilities. | low |
| 05 | The United States filed an amicus brief supporting GEO, arguing that applying the minimum wage law would interfere with federal immigration operations. The court rejected this argument, noting that increased costs alone do not violate intergovernmental immunity. | medium |
| 06 | After hearing oral argument, the Ninth Circuit certified three questions to the Washington Supreme Court about state law. The Washington Supreme Court answered that detainees are employees under the Minimum Wage Act and that the law applies to work performed by detainees in private detention facilities regardless of government contracts. | medium |
| 07 | The consolidated actions were filed in 2017. A jury trial resulted in a verdict of $17,287,063.05 in back pay damages to the detainee class. After a bench trial, the district court awarded $5,950,340.00 in unjust enrichment to Washington State. | high |
| 08 | The district court enjoined GEO from employing detainees without paying Washington’s minimum wage. The Ninth Circuit affirmed the judgment in full on January 16, 2025, nearly eight years after the lawsuits were filed. | medium |
The Bottom Line
What This Means · 6 points
| 01 | The Ninth Circuit held that application of Washington’s Minimum Wage Act to civil detainees held in GEO’s privately operated federal detention center does not violate the doctrine of intergovernmental immunity. States may enforce generally applicable minimum wage laws against private contractors even when those contractors work for the federal government. | high |
| 02 | The court held that Washington’s Minimum Wage Act is not preempted by federal law. The federal government’s decision to set a $1 per day minimum for detainee work programs does not prohibit private contractors from paying more, and nothing in federal law caps the wages contractors may pay. | high |
| 03 | GEO’s contract with ICE explicitly requires the company to comply with all applicable state labor laws and codes, including minimum wage laws. The contract does not exclude minimum wage laws from this requirement and provides that when conflicts exist between federal and local standards, the most stringent standard shall apply. | high |
| 04 | The case demonstrates how privatized immigration detention creates financial incentives to exploit captive labor. When private companies profit from every dollar saved on operations, detained people become cost variables rather than human beings with rights. | high |
| 05 | The court’s ruling delivers some measure of restitution to exploited workers, but the broader system that allowed this abuse for years remains intact. Private prison companies continue to operate immigration detention facilities across the country under similar contracts. | high |
| 06 | The dissent argued that applying the minimum wage law would create dramatic distinctions in allowances applicable to detainees based on the location of their detention, potentially undermining the Voluntary Work Program nationwide. The majority found these concerns speculative and rejected them. | low |
Timeline of Events
2005
GEO Group begins operating the Northwest ICE Processing Center in Tacoma, Washington under federal contract and immediately implements a work program paying detainees $1 per day
2010-2018
GEO’s gross profit from managing NWIPC ranges between $18.6 million and $23.5 million per year with net profit margins of 16-19 percent
2014-2021
Period covered by back pay damages award for minimum wage violations
2015
GEO’s current ten-year contract with ICE begins, worth a minimum of $700 million over the contract period
2017
Class of detainees and Washington State file separate lawsuits against GEO in federal district court alleging violations of Washington’s Minimum Wage Act; district court consolidates the actions
August 2019
United States files statement of interest in district court arguing that basic constitutional principles prevent Washington from interfering with federal government activities
2021
Jury awards $17,287,063.05 in back pay damages to detainee class; district court awards $5,950,340.00 in unjust enrichment to Washington State after bench trial
October 28, 2021
District court enjoins GEO from continuing the Voluntary Work Program without paying Washington minimum wage; GEO and ICE suspend the program entirely rather than comply
2021-2022
GEO appeals to Ninth Circuit Court of Appeals
October 6, 2022
Ninth Circuit hears oral argument on GEO’s appeal
2023
Ninth Circuit certifies three questions of Washington state law to Washington Supreme Court
2023
Washington Supreme Court answers certified questions, holding that detainees are employees under state law and the Minimum Wage Act applies to private detention facilities regardless of government contracts
February 21, 2024
United States files amicus brief in Ninth Circuit maintaining its position that applying the Minimum Wage Act violates intergovernmental immunity and is preempted by federal law
January 16, 2025
Ninth Circuit issues opinion affirming district court judgment in full, rejecting all of GEO’s arguments on appeal
Direct Quotes from the Legal Record
QUOTE 1
Detainee testimony on coercion
workers
“I need the money desperately. I have no choice.”
💡 This quote shows the coercive nature of the supposedly voluntary work program and how detainees had no real choice but to work for exploitative wages
QUOTE 2
GEO’s dependence on detainee labor
allegations
“Without the help of detainees, the kitchen staff would have been ‘absolutely’ unable to meet demand.”
💡 GEO’s own testimony admitted that the facility could not function without detainee labor, proving this was not a voluntary benefit but essential to operations
QUOTE 3
GEO’s contract requirements
regulatory
“GEO’s contract with ICE requires GEO to comply with ‘all applicable federal, state, and local laws and standards,’ including ‘labor laws and codes.'”
💡 The contract explicitly required GEO to follow state minimum wage laws, undermining the company’s claims that federal law prohibited compliance
QUOTE 4
Most stringent standard applies
regulatory
“if ‘a conflict exist[s] between [federal and local] standards, the most stringent standard shall apply.'”
💡 The contract required GEO to apply whichever wage standard was higher between federal and state law, meaning Washington’s minimum wage should have applied all along
QUOTE 5
GEO’s profit from the facility
profit
“Between 2010 and 2018, GEO’s gross profit from managing the NWIPC ranged between $18.6 million and $23.5 million per year, with general net profit margins of 16 to 19 percent.”
💡 These figures show GEO made enormous profits from the detention center while paying detainees poverty wages, demonstrating the exploitation was financially motivated
QUOTE 6
GEO’s cost savings from underpayment
profit
“Because of the labor provided to GEO by the detained workers employed under this program, GEO operated its facility with just a handful of full-time staff hired from the local area, thereby saving millions of dollars that it would otherwise have spent on payroll.”
💡 The court explicitly found that GEO’s business model depended on underpaying detainees to avoid hiring adequately paid staff
QUOTE 7
Scale of detainee labor
allegations
“Every day, hundreds of civil detainees at the NWIPC worked for GEO, performing tasks essential to the operation of the facility.”
💡 This was not a small-scale program but a systematic exploitation affecting hundreds of detainees daily performing essential work
QUOTE 8
Number of additional staff needed
allegations
“GEO estimated that if the VWP at the NWIPC ended, it would have to hire approximately 85 additional full-time outside employees.”
💡 GEO’s own estimate reveals the massive scale of work performed by underpaid detainees, equivalent to 85 full-time positions
QUOTE 9
Washington Supreme Court holding
accountability
“the MWA government institutions exception ‘does not apply to detained workers in private detention facilities regardless of whether the private entity that owns and operates the facility contracts with the state or federal government.'”
💡 The state’s highest court definitively ruled that private detention facilities like GEO’s must pay minimum wage regardless of government contracts
QUOTE 10
Ninth Circuit majority holding
conclusion
“We hold that the application of Washington’s MWA to civil detainees held in GEO’s privately operated federal detention center does not violate the doctrine of intergovernmental immunity.”
💡 The federal appeals court confirmed that states can enforce minimum wage laws against private prison companies even when they contract with the federal government
QUOTE 11
No federal prohibition on higher wages
regulatory
“Nothing in GEO’s contract with ICE or in the PBNDS provides that GEO may not compensate civil detainees at rates higher than $1.00 per day.”
💡 Federal standards set a floor, not a ceiling, meaning GEO was always free to pay minimum wage but chose not to maximize profits
QUOTE 12
GEO’s practice of paying more when needed
regulatory
“GEO has routinely paid detainees up to $5 per day when necessary to attract sufficient workers. GEO has done so without any objection from ICE.”
💡 GEO’s own practice proves it could legally pay more than $1 per day, undermining its claims that federal law prohibited compliance with state minimum wage
QUOTE 13
Purpose of federal work program
regulatory
“Section 5.8 states that the purpose of the VWP is to provide detainees ‘opportunities to work and earn money while confined, subject to the number of work opportunities available and within the constraints of the safety, security and good order of the facility.'”
💡 Federal detention standards frame the work program as a benefit for detainees, but GEO turned it into a profit mechanism through systematic underpayment
QUOTE 14
Impact of court ruling
accountability
“In response, rather than pay Washington’s minimum wage to the detained workers, GEO, with the approval of ICE, suspended the VWP at the NWIPC during the pendency of this litigation.”
💡 Rather than comply with the minimum wage law, GEO eliminated the program entirely, showing its true priority was profit over providing benefits to detainees
QUOTE 15
US government position
accountability
“Appearing as amicus, the government argues that direct-regulation intergovernmental immunity applies here because ‘[t]here can be no dispute that if the federal government operated the detention facility and implemented the Voluntary Work Program directly, principles of intergovernmental immunity would bar application of state minimum wage laws to detainees.'”
💡 The US government defended GEO’s exploitation, revealing how federal policy enables private prison companies to profit from underpaid captive labor
Frequently Asked Questions
What did GEO Group do wrong?
GEO operated an immigration detention center in Tacoma, Washington where it paid hundreds of civil detainees only $1 per day to perform essential facility operations including cooking, cleaning, laundry, and waste management. These detainees did work that would have required GEO to hire approximately 85 additional full-time employees at market wages. A court found this violated Washington’s minimum wage law, which required payment of $16.28 per hour.
How much did GEO profit from this scheme?
GEO’s gross profit from managing the detention center ranged between $18.6 million and $23.5 million per year from 2010 to 2018, with net profit margins of 16-19 percent. The company’s ten-year contract with Immigration and Customs Enforcement was worth a minimum of $700 million. By paying detainees $1 per day instead of minimum wage, GEO saved millions in labor costs that went directly to corporate profits.
Was the work program really voluntary?
The program was labeled voluntary, but evidence showed detainees had no real choice. One detainee testified: I need the money desperately. I have no choice. Detainees are held in closed facilities with no other way to earn money for basic needs like phone calls to family. Between 200 and 500 detainees participated daily before the lawsuit, showing how many felt compelled to work for exploitative wages.
What happened to the detainees who sued?
A jury awarded the class of detainees $17,287,063.05 in back pay for wages GEO should have paid them under Washington’s minimum wage law. The court also awarded Washington State $5,950,340.00 in unjust enrichment. However, GEO appealed and has not yet paid these amounts as of January 2025. Meanwhile, GEO suspended the work program entirely in October 2021 rather than pay minimum wage.
Did the federal government know about this?
Yes. Immigration and Customs Enforcement contracted with GEO to operate the facility and approved the work program. GEO’s contract explicitly required compliance with state labor laws. When detainees sued, the United States filed briefs defending GEO and arguing that state minimum wage laws should not apply. The federal government sided with the private prison company against exploited workers.
Is this still happening at other detention centers?
The court’s ruling only directly affects the Tacoma facility. However, GEO and other private prison companies operate immigration detention centers across the country under similar contracts with similar work programs. Unless other states bring enforcement actions or Congress changes federal law, this exploitation likely continues elsewhere.
Why did it take so long to resolve this case?
The lawsuits were filed in 2017. After trials in 2021, GEO appealed. The Ninth Circuit heard arguments in October 2022 but then certified questions to the Washington Supreme Court, which took time to answer. The Ninth Circuit did not issue its final opinion until January 16, 2025, nearly eight years after the lawsuits began. During this entire time, detainees have had no work program at all because GEO suspended it.
Can GEO appeal further?
GEO can petition the Ninth Circuit for rehearing en banc or petition the US Supreme Court for review. Given that the United States filed briefs supporting GEO’s position, further appeals are likely. This means detainees may wait even longer to receive the back pay they are owed.
What can I do about this?
Contact your members of Congress and demand they end federal contracts with private prison companies that exploit detainee labor. Support organizations that provide legal aid to detained immigrants. Advocate for state and federal minimum wage laws that explicitly cover all detained workers regardless of immigration status. Push for transparency requirements that force private prison companies to publicly disclose labor practices and wages.
Are private prisons legal?
Yes, private companies operating prisons and detention centers under government contracts is legal in the United States. The federal government and many states contract with private companies like GEO Group and CoreCivic to operate facilities. However, this case shows how privatization creates incentives to maximize profit by minimizing costs, often through exploitation of captive populations who have no power to refuse.
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