The release said: "Notably, in fiscal years 2013 and 2014 the majority of releases of serious criminal offenders were made pursuant to federal court decisions or bond decisions by immigration judges. In a leading court case on immigration detention, Zadvydas v. Davis, the Supreme Court ruled that ICE generally could not detain an individual ordered removed in immigration detention beyond six months, unless the individual would be repatriated in the reasonably foreseeable future. This detention limit can be triggered when a country simply refuses to accept repatriation of its national, irrespective of the individual’s criminal history."
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http://www.politifact.com/texas/statements/2015/aug/28/ted-cruz/ted-cruz-obama-administration-released-104000-crim/