§ 2.8 2. Federal and State Prisoners Subject to Removal
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Between 1995 and 2003, the number of federal prison inmates incarcerated for immigration offenses went up nearly 400% from 3,420 to 16,903. Nearly all of these are foreign nationals, most convicted of illegal re-entry after deportation, who can look forward to immigration holds and deportation after completing service of their sentences. Although reliable estimates are difficult to come by, the state prison systems incarcerate more than 200,000 foreign-born offenders who might be subject to removal.
 Harrison & Beck, Prisoners in 2004, Bureau of Justice Statistics Bulletin, p. 10 (October 2005) (NJC 210677).
 Rebecca L. Clark and Scott A. Anderson, Illegal Aliens in Federal, State, and Local Criminal Justice Systems 11, 56 (Urban Institute, NCJ 181049) (June 1999); John Scalia and Marika F.X. Litras, Immigration Offenders in the Federal Criminal Justice System, 2000 at 8 (Bureau of Justice Statistics, NCJ 191745) (23,477 noncitizens charged in federal court for 2000, compared to 63,000 total cases filed); John Scalia, Noncitizens in the Federal Criminal Justice System, 1984-1994, at 10 (Bureau of Justice Statistics Special Report, NCJ 160934) (Aug. 1996); Susan Katzenelson et al., Non-U.S. Citizen Defendants in the Federal Court System, 8 Fed. Sent. Rep. 259 (1996) (24.3% of offenders convicted in federal court in fiscal 1995); U.S. Sentencing Comm’n, supra note 110, at tbl.9 (35.8% of federal prisoners non-citizens in fiscal year 2000). By 2000, the non-citizens accounted for 29% of the federal prison population. Bureau of Justice Statistics, Immigration Offenders in the Federal Criminal Justice System, 2000 at 8 (2002) (NCJ 191745).