DHS also appears to recognize the political costs of collecting DNA from people outside the criminal justice system. In a March 22, 2010 letter from DHS Secretary Napolitano to Attorney General Holder, Napolitano sought an exemption to DNA collection from juveniles under 18. Hidden text within one of the documents1 recognizes that collecting DNA from juveniles could increase “ICE's exposure to criticism” and notes:

[t]here is a high likelihood that ICE would face litigation and other opposition from community and nongovernmental organizations (NGOs) if ICE were to sample all juvenile detainees.




And according to the Council for Responsible Genetics, twenty-eight states already collect DNA from juvenile offenders, as well.