Beyond Justice

by Cara Putman

  After driving to the point at which she was sure she’d missed her turn, the GPS barked directions, taking her from the interstate to smaller highways to county roads until she came to a stop in front of an industrial government-issue building. It must have been constructed during the Cold War, a concrete building that rose from the dirt with nothing to distinguish it from a hundred other government buildings—but not here. This one stood alone, with only the Texas desert surrounding it as the county road ran like a ribbon into the distance.

  Hayden pulled into the small parking lot and turned off the car.

  She sat in the car a moment, glancing at the dashboard clock. The drive had eaten up every last second prior to the deposition. Calling Carmen would have to wait. She swallowed around an excessively dry throat and snagged her attaché case. The perfect world of having an hour to review her notes wasn’t happening. Instead, she had to go in there and be brilliant on her prior preparation. If only her butterflies would fly in formation. Well, she’d come too far and spent too much to let the delays stop her from taking the best deposition of her life.

  Lord, help me make the most of this time. Help me ask the right questions.

  Hayden had long believed that if God placed her in a job, He would help her with the day-to-day issues. This was more than asking for guidance and insight as she wrote a brief or searched boxes of discovery. She pulled her attaché case from the backseat and slipped the car keys into an outside pocket.

  When she straightened, she pulled her shoulders back and tipped her chin a bit.

  The double doors led into a facility with cracked white linoleum floors and old plastic chairs whose best days and color selection had been in the sixties. A woman in a security uniform sat behind a high counter, Plexiglas separated her from the lobby. A bank of monitors sat on a counter behind her, and a computer and multi-line phone rested on the desk. The woman’s skin was the color of cinnamon, and a Hispanic lilt accented her voice when she spoke. “May I help you?”

  “Hayden McCarthy. I have a deposition scheduled with the director.”

  The woman looked at her with an expression that Hayden wasn’t sure how to read—half disbelief, half impressed. “May I see your ID?”

  Hayden dug out her driver’s license and bar card and slid them into the drawer the woman pushed out like a bank teller or gas station clerk. She studied the cards, then placed them on a scanner. After she returned them, she picked up the phone and mumbled.

  She gestured toward a set of double doors. “Run your bag through the x-ray machine and pass through the metal detector. Someone will meet you on the other side and escort you.” She slid a visitor badge into the drawer and shoved it to Hayden. “Wear this at all times. We close at five sharp.”

  “Thank you.” Hayden pinned the badge on the lapel of her jacket, then walked through the doors.

  On the other side she submitted to the screenings and was met by a stern-faced, uniformed man. He’d indulged in a few too many bagels, and the stench of his cologne surrounded and gagged her. His salt-and-pepper hair was greased back, and he strutted with one hand on his holster as if she posed a threat.

  “The director’s office is down this hall.”

  “Wait. We’re supposed to have a deposition with a court reporter. In the conference room.”

  “I don’t know nothing about that. You can ask him.” He glanced over his shoulder. “He’s got fifteen minutes tops. Busy man running this place.”

  “I’ll remember that. Thank you.” Hayden strained to hear anything that sounded like the voices of children. Instead she was met with an eerie silence, broken only by her heels clicking against the concrete floor. “Where are the residents?”

  “We’ve got two wings for them. One for the girls, another for the boys. Never the two shall meet.” He laughed, a harsh, grating sound.

  “What do they do?”

  “Do?” He stopped and studied her, his brows knit together and his legs apart. Definite power stance.

  She squared her body to meet his. “Yes, do. You’ve got hundreds of kids. Surely they do something during the day.”

  He snorted and turned back toward the expanse of the hall. “Lady, this is a detention center, not a preschool. They eat, they sleep, they go outside. The rest of the time, they do whatever kids do to entertain themselves.”

  Hayden bit back a retort. Children were children, no matter their circumstances. Each had basic needs that included more than food and water. She’d wager he gave his pooch more affection than these kids received.

  “Here we are.” He stepped to one side and waved her through a doorway.

  Hayden stepped into a suite of offices. A woman looked up and pasted a smile on her bright red lips. Her hair was Texas big, teased on the sides and high. She wore a bold floral dress, slashes of neon color against the gray walls.

  “May I help you?” Her drawl honeyed her words, and her gaze was clear and direct.

  “Hayden McCarthy. I’m here for a deposition with Mr. Snowden.”

  The secretary stood and knocked on a door behind her desk. She opened it and then stuck her head inside. Muffled words filtered out, and she turned around with a tense smile. “Can I get you anything to drink?”

  “Water would be fine. Thank you.”

  “The director will see you now.”

  Hayden followed her into the office. Carlton Snowden didn’t look much like his official bio photo. He had put on a few pounds and lost some hair, but had the same hard eyes and cutting gaze.

  “Ms. McCarthy.” He gestured to a man sitting to the side of the desk, his suit indicating he could be opposing counsel. “This is Jim Beauman with the Department of Justice.”

  The man stood and adjusted the gold frames of his glasses before offering her his hand. “I’m looking forward to our conversation today.”

  “It’s a deposition. As I agreed to Monday with your pit bull of an attorney.”

  “Sure, sure. She’s sick, so you get me. We’re waiting on the court reporter.” The attorney grinned at her and then at Director Snowden. “People get lost coming out here.”

  “It’s true.” The director nodded as if following a script. “The wide open spaces confuse folks.”

  “I’ll call her.” Hayden pulled out her phone and checked for messages. Seeing none, she placed the call. “Hi, this is Hayden McCarthy. We’re expecting you at the juvenile detention center for the deposition.”

  “I’m on my way. Strangest thing, but I came out of lunch and had a flat tire.” The woman huffed a frazzled breath. “I’m never late, but I didn’t anticipate this.”

  Hayden stifled a sigh of her own. “When do you think you’ll arrive?”

  “I’ll be there in an hour.”

  “See you then.” Hayden hung up and turned to the men. “She’ll be here in an hour.” She kept the information about the flat to herself.

  “Now wait a minute. I only have an hour.”

  “The agreement was for up to six hours of deposition. Maybe we could make use of the time by having a tour.”

  “Is this true?” Director Snowden looked at the government attorney.

  Beauman shot his shirt cuffs, then pasted on a smile. “Yes, it is.”

  Snowden’s assistant bustled in with a chilled bottle of water, which Hayden accepted with quiet thanks.

  “If we had anything on this young man, we’d be happy to provide it after the proper FOIA request was made.” Mr. Beauman’s smile got smarmier. “However, there isn’t much to give.”

  Hayden shifted against the chair but kept her own smile in place. “I can’t imagine any child in this facility doesn’t have a file filled with information. Even that would put his mother at ease.”

  The need for justice burned through her, and she itched to serve the revised complaint here and now. Watch the smug expression slide from the man’s face with the realization that she was very serious about pursuing Miguel’s murder. She restrained herself because if she presented it now,
the conversation was over. She had to bide her time, learn what she could, and then launch the official process.

  “I’m sure you can spare time for a quick tour while we wait, Mr. Snowden, since opposing counsel is here.”

  Snowden steepled his fingers under his chin and studied her. She willed him to understand how determined she was. A flash of communication passed between the men and she waited for the result. Finally he nodded.

  “A tour won’t hurt anything and could prove you’re on a ghost hunt.” He stood and gestured for her to do the same. “Ladies first.”

  CHAPTER 32

  Any time Hayden saw something to explore, Snowden physically pointed her in another direction. When he didn’t, Beauman did. The places they showed her were corridors of narrow, cell-like rooms. Bunk beds were crammed into them, topped with navy comforters and basic pillows. In the hallways there were stations of bookcases, puzzles, and random toys, but no children.

  Finally she couldn’t hold her question in any longer. “Where are the children?”

  “Here and there. A few groups are outside for fresh air and exercise. Another group is having medical checks. We keep them active and healthy for their stay. One illness can spread through a facility in no time.”

  That wasn’t the impression the guard had given her, but she kept that to herself. Snowden led her down another sterile hallway and around a corner, down some stairs, and into a security center.

  “This is where our guards monitor 24/7. The best defense is a good offense, so we stay alert for trouble and catch its inception rather than let it spread. Kids from rival gangs are here, so we keep a close eye on them.”

  Hayden’s gaze roamed the bank of monitors. “Are these the only monitors?”

  “Ma’am?” His sugary southern sweetness about made her gag.

  “Do you have more cameras monitored elsewhere?”

  One of the guards cleared his throat, and Mr. Snowden glared at him. “The only thing not visible here is the sleeping quarters.”

  “I see that. Are those monitored?”

  “Not during a time like this when most are empty.”

  “But there are cameras in the rooms?”

  “Sure.”

  “Are those records somewhere?”

  “I’m not sure why you’re asking.” Yet his shifty gaze told her he’d figured it out.

  “If Miguel Rodriguez was killed in his room, then video captured his murderer.” Someone had seen the last page of the boy’s life.

  “Now look. Nobody was killed here. A few may have died, but from illness or an injury they arrived with.”

  Beauman stepped between them. “We should see if the court reporter is ready.”

  Hayden wanted to protest, but restrained herself. Snowden might not realize he’d opened a line of questioning for the deposition, but Beauman understood. She needed Snowden’s answers captured by the court reporter while he was under oath. Then the answers could be used in court to prevent him from changing his testimony later.

  The walk back to the office was quiet while Hayden took in everything and memorized what she saw. Snowden’s assistant stood as soon as they entered her space.

  “The woman set up in your office. I hope that’s all right, sir.”

  “Fine.” Snowden walked past her and opened the door to his office. “Please bring four bottles of water.”

  “Right away.”

  The stenographer’s equipment was stationed on the edge of Snowden’s desk. Ten years ago that would have been a machine to type on; now it was a digital recorder with an attached microphone.

  The court reporter looked about fifty and wore bling-y jeans and a cardigan set. Her cat’s eye glasses caused her eyes to look big and curious. “I’m ready whenever y’all are.” She reached for a White Castle cup and slurped through the straw. “I’ll run a test and get started.”

  “Thanks.” Hayden slipped her attaché case from her shoulder, grateful to set it down. She sank onto the chair closest to the court reporter and pulled legal pads covered with notes from the bag. When she had arranged them in order on her lap, she glanced at the gentlemen. “Ready when you are.”

  Beauman considered her pile of legal pads. “Exactly how long do you expect this deposition to last?”

  “That all depends on the director.” She turned a sweet smile on him. “If he answers my questions it shouldn’t take more than a couple hours.” Neither needed to know there was only one question on each page with a couple blank pads on the bottom.

  “We’ll see.” With that he settled against the chair and crossed one leg over a knee. While he might look relaxed and bored, Hayden knew he would pounce the moment he thought she’d gone too far. He waved to the court reporter. “Let’s roll.”

  “Yes sir.” The woman pressed a button on the impossibly small recorder. Then she looked at Snowden. “If you would say something.” She watched a reading as he counted from one to five. Then she turned to Hayden. “It’s your turn.”

  Hayden grimaced at the microphone. She never really knew what to say without sounding slightly ridiculous. A mic check at church could be a Bible verse, but here? “I can’t wait to ask all my questions.”

  Snowden’s skin paled, and she wondered what he was afraid she’d ask. She wanted to find that question and nail him.

  “We’re good.” The court reporter turned to Snowden. “Sir, I need to swear you in. Please raise your right hand. Do you promise the testimony you are about to give is true, so help you God?”

  He nodded with a sharp jerk of his chin.

  “You need to speak your answer, sir.”

  “Yes.”

  “Your witness.” The court reporter sat back, and Hayden leaned forward.

  Hayden tried to tilt the notepads away from Beauman’s line of sight. “Please state your name and address for the record.”

  She quickly led him through routine questions. The key was to be friendly and keep an open face so the witness slowly forgot he should be guarded. She wanted him in a rhythm so Beauman had nothing to object to and questions and answers would flow in a dance of words. As she ticked through his education and job history, the director’s shoulders relaxed and his hand quit drumming the table. He leaned back in his chair and gazed at her as if wondering if this was the best she could do.

  Then they reached his work history at the detention center.

  “How long have you worked here?”

  “Two years.”

  She made a notation. “Have you always worked as the director?”

  “I started as the assistant and moved into the director role a year ago.”

  “What does your job consist of?”

  “I am responsible for ensuring that the children in our custody are well cared for while here.”

  “What does ‘well cared for’ mean?”

  “I don’t understand.” His back stiffened away from the chair.

  “How do you define ‘well cared for’?”

  “Getting all my wards through the day successfully.”

  “So no injuries?”

  “Yes.”

  “No deaths?”

  “Of course.” He turned to Beauman, who stayed silent.

  “Definitely no murders?”

  “Yes.”

  She jotted a note, letting his answer linger. “Who is your boss?”

  “Ultimately the governor.”

  “This is a state agency?”

  “Operating under contract with Immigration and Customs.”

  “Whom do you report to? The governor of Texas? Or the director of ICE?”

  “Both . . . I guess.”

  “Please don’t guess. Simply answer to the best of your knowledge.”

  The director sputtered a moment and looked at Beauman. The government attorney didn’t flinch as he straightened the cuff on his pant leg. “Answer the question.”

  The director huffed out a breath. “Both.”

  “Who funds this facility?”

 
“Both.”

  “In what ways?”

  “We receive block grants from the federal government and a per diem from the state.”

  “Which is the larger source of income?”

  “I’d have to check.”

  “All right.” She made a notation, then turned to Beauman. “Please make a note to provide the documentation. A formal request will follow.”

  Beauman nodded, but didn’t write anything down. This would be a good test of how he’d cooperate. Hayden paused and considered whether she had enough to establish that the federal government shared responsibility for the facility. From Snowden’s testimony, it was at least partly culpable. She’d tug that string more, but direct him to another area first. Let him think he was off the hook.

  She moved him through the process they used when checking in new detainees and checking them out. “What do you document in the children’s files?”

  “Anything of note.”

  “Give me some examples.”

  “Medical needs. If the guards have to intervene in a situation. Those situations.”

  “So if there was an assault, it would be documented?”

  “Yes.”

  “An injury requiring medical care?”

  “Yes.”

  “What if someone was stabbed with a knife?”

  He hesitated a beat. “Yes, if it required medical intervention.”

  “But not if it didn’t?”

  “Not likely. We have too many residents to track every situation.”

  “So if a child in your care was stabbed by another resident, that might not be noted.”

  “Not if medical care wasn’t needed.”

  “So if someone were killed, it wouldn’t be documented?”

  “I didn’t say that.”

  Mr. Beauman leaned forward. “I think that’s enough on this line of questioning.”

  She smiled sweetly at him. “I’ve only begun. Thank you.” She noted how both men bristled when she poked here. They were trying to create the illusion that nothing was in Miguel’s file. She could lay a foundation for how ridiculous that was. “So if a child died of natural causes and medical care wasn’t provided, would anything be noted?”