In his September 2009 deposition in the case, Arpaio testified he had never read the complaint in the case, was unfamiliar with the details of the allegations of racial profiling therein, didn't know the content of the 14th Amendment to the U.S. Constitution, and had never read the Department of Justice's guidelines concerning the use of race in investigations, which would have applied to his deputies in the field when they were still operating under a 287(g) program agreement with U.S. Immigration and Customs Enforcement (ICE). He insisted, however, that his deputies didn't profile based on ethnicity or race.