to order detention.97 This means that the possibility for governmental bias looms large. In 16 States, there is no automatic judicial review of detention. Rather, migrants and asylum seekers must apply to administrative courts for review.98 Both removal and asylum detainees must be kept in specialized facilities, which must be different than those for ordinary prisoners. In a 2014 Court of Justice of the European Union case, the Court ruled that “absence of specialized facilities in one part of Member States’ territory does not justify using prisons, if specialized facilities are available in other part of its territory.”99 Problems arise because there is uncertainty and non-uniformity in the meaning of “specialized facilities.” Despite the ruling, many countries continue to use ordinary prisons to detain migrants. For example, Germany uses prisons, Greece uses police stations, and Austria uses police detention centers.100 States may attempt to disguise such uses of prisons, to which they designate administrative officials or extraordinary prisoners. It is especially important to note that some States do not have the proper capacities and facilities; detention centers tend to be insufficient and cannot be adapted for long-term detention. Pursuant to a report to the EU, detainees are mainly held in specialized facilities. However, such statistics must be read with caution, since they lack academic scope, as they are typically created by each State’s Ministry of Interior without supplemental or external institutional research support.101 Academic scope is significant in providing impartial facts and for avoiding bias from the reporting countries, which could result in skewed, more favorable results. 97 EUROPEAN MIGRATION NETWORK, The Use of Detention and Alternatives to Detention in the Context of Immigration Policies, (2014), 24, accessible at http://ec.europa.eu/dgs/home-affairs/what-wedo/networks/european_migration_network/reports/docs/emnstudies/emn_study_detention_alternatives_to_detention_synthesis_report_en.pdf 98 Id. at 25 99 Case C-474/13, Thi Ly Pham v. Stadt Scheinfurt, Amt fur Meldewesen und Statistik, 2014 E.C.R. 2096. 100 EUROPEAN MIGRATION NETWORK, supra note 99 at 28-9. 101 Izabella Majcher, Immigration detention in Europe: What are the facts? A new European Migration Network Study, EU LAW ANALYSIS (Dec. 24, 2014, 1:27 AM), http://eulawanalysis.blogspot.com/2014/12/immigrationdetention-in-europe-what.html 30