HomeMy WebLinkAboutItem A: Police Oversight System - Roles and Expectations
ECC
UGENE ITY OUNCIL
AIS
GENDA TEM UMMARY
Work Session: Police Oversight System – Roles and Expectations
Meeting Date: May 18, 2009 Agenda Item Number: A
Department: Central Services/CMO Staff Contact: Sarah Medary
www.eugene-or.gov Contact Telephone Number: 682-6877
ISSUE STATEMENT
The purpose of this work session is to discuss the roles and expectations of the Police Auditor, Civilian
Review Board, and the City Council, related to the police oversight system.
BACKGROUND
In July 2005, the Police Commission presented its final report and recommendations to City Council on
proposed complaint intake and civilian oversight systems (Attachment A). The commission
recommended a hybrid model of Auditor and Civilian Review Board and provided descriptions of the
systems for City Council to consider. The report was accepted, the proposed model was supported, and
a City Charter amendment to authorize the proposal was placed on the November 2005 ballot for voter
consideration and subsequent approval.
In 2006, the City Council hired the first Police Auditor and adopted Ordinance 20374 that provided for
external review of police.
In 2008, City Council placed an amendment to the City Charter on the November ballot that changed the
language that contained the phrases “The city council is authorized to” and “the city council may
authorize” to the mandatory phrase “city council shall….” After the amendment was passed by the
voters, the council appointed a 15-member committee to consider potential necessary revisions to the
related ordinance on police oversight.
Over the next week, the City Council will discuss next steps on how to proceed with implementation of
the recommendations of the Police Auditor Ordinance Review Committee (PAORC) and supervision of
the Police Auditor. The council is also in the process of hiring a new Police Auditor.
In anticipation of these discussions and decisions, City Council has expressed an interest in reviewing
the original materials considered in adopting the hybrid model of oversight and developing a common
understanding and agreement on the related roles and expectations of the Police Auditor, Civilian
Review Board, and the City Council.
COUNCIL OPTIONS
No options are being provided as the work session was proposed as a discussion.
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SUGGESTED MOTION
No motion is suggested as the work session was proposed as a discussion.
ATTACHMENTS
A. Police Commission Report – July 2005
B. Brochure from 2008 Police Auditor Recruitment
FOR MORE INFORMATION
Staff Contact: Sarah Medary, Assistant City Manager
Telephone: 682-6877
Staff E-Mail: sarah.j.medary@ci.eugene.or.us
Z:\CMO\2009 Council Agendas\M090518\S090518A.doc
Police Commission Report to
Eugene City Council:
Police Complaint System and
Civilian Oversight
Recommendations
July 25, 2005
Table of Contents
I. Executive Summary....................................................................................................................1
II. Project Overview.......................................................................................................................2
III. Research and Community Values............................................................................................3
IV. Model Development/Committee Process................................................................................4
V. Proposed Oversight System Description...................................................................................8
Complaint Intake................................................................................................................9
Preliminary Investigation and Complaint Classification..................................................11
Complaint Routing and Possible Outcomes.....................................................................12
Other Intake-Related Recommendations..........................................................................13
Auditor Role in Monitoring Investigations......................................................................17
Civilian Review Board Role.............................................................................................20
Board Membership Recommendations............................................................................22
VI. Oversight Model Frequently Asked Questions......................................................................23
VII. Outstanding Issues and Next Steps......................................................................................25
VIII.Attachments......................................................................................................................28
Police Complaint System and Civilian Oversight Recommendations
I. Executive Summary
Over the past year, the Eugene Police Commission has conducted an extensive review of current practices
for handlingcomplaints against police, including a re-examination of different models of civilian
oversight. Background research for this project included a significant literature review and a consultant
report on civilian oversight modelsin operation nationally. Multiple communityforumswereheld to
seek public input on concerns with the current police complaint system and to compilesuggestions for
improvements. Committees were formed to develop specific recommendations for how complaints are
received, classified, investigated and, once a conclusion is developed, reviewed. The committees
submitted a conceptual oversight model to the Police Commission that instills more robust civilian review
into the complaint process. The conceptual model was revised following additional commission
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discussion and communityinput. On July 25, the resulting recommendations will be presented to City
Council for its consideration. The commission hopes that following the Council work session, it will
continue to refine the oversight model and assist with the development of the ordinance and policies that
will support implementation of the new complaint system.
Values/Outcomes Sought in New Complaint System
Creation of an accessible, safe, impartial and responsive complaintintake system
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Assurance of high quality,thorough and unbiased investigations
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Accountability and fairness for all involved
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Increased transparency in how complaints are handled and dispositions are generated to build
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credibility and trust in thecomplaint system
Identify organizational improvements to enhance the qualityof police services to the public
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Avoid pitfalls encountered in other communitieswhen implementing civilian review
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How Proposal is Different than Current System
Communitymember complaints are lodged with independent auditor’s office
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Investigations are removed from police supervisors and transferred to an expanded investigative
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unit within IA
Full time auditor, independent from the police department,monitors on-going IA investigations
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for quality assurance
Citizen review board oversees the work of the auditor to ensure that investigations are fair
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Options for alternative resolution to complaints are expanded and utilized morefrequently
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Proposed Oversight System Authority (Hybrid Model of Auditor and Civilian Review Board)
Auditor’s office receives complaints, conductspreliminaryinvestigations and classifies how
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cases will be handled
Auditor actively monitors internal investigations, including abilityto participate in interviews,
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require additional investigation, contract with outsideentity to conduct certain investigations and
recommend case dispositions to the Chief of Police
Auditor seeks improvements to police services by identifyingpolicyand training issues
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associated with complaints and reviewing tort and risk claims
Auditor identifies cases for review board to oversee and provides quarterly reports to board on
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complaint processing decisions, investigative findings and case outcomes
Civilian board reviews and comments on investigations sent to it by the auditor,upon request of
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the complainant, or at its discretion, and in specific situations, can require the case to be re-
opened for further investigation
Board monitors the work of the auditor’soffice to ensure that complaint handlingdecisions and
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recommendations to the Chief on case investigations reflect community values
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Police Complaint System and Civilian Oversight Recommendations
II. Project Overview
At the March 11, 2004 Police Commission meeting, Chief Lehner requested that the commission
consider a review of how complaints and internal investigationswere handled by the department.
The Chief was concerned that the department’s current procedures for handling and investigating
complaints did not meet professional standards. The 2004 audit of internal affairs cases
confirmed some of these concerns, specifically identifying deficiencies in the quality and
timeliness of complaint investigations. Several commissioners noted that this project seemed to
fit naturally into the group’son-going discussion of strategies to improve police/community
relations. Furthermore, the commission was highly sensitive to the breach in public trust that
occurred when two former Eugene police officers were convicted for criminal misconduct that
occurred over a period of years while on duty.
The commission decided to take on a review of the police complaint system, adding a re-
examination of civilian oversight models that might be appropriate for Eugene to its effort.
Commissioners agreed that this was a timely and necessary project given that recent events had
cast doubt over the reliability of the current internal affairs procedures to treat all parties
involved in a complaint fairly, and to hold people accountable for inappropriate conduct in a
timely manner. A thorough review of existing policies and procedures, coupled with an
examination of models of civilian oversight, could help rebuild credibility in the department’s
complaint system and improve police/community relations.
In June 2004, the commission developed a work plan for the upcoming year that was devoted
almost entirely to this project. That samemonth, Chief Lehner presented a set of interim
improvements the department’s complaint process in response to the auditor’s report, noting that
more substantive changes would be occur following receipt of the commission’s
recommendations. The commissionrealized that this project would be an undertaking unlike any
of its past efforts, requiring an infusion of resources to meet community expectations for a
thorough and timely review. The commission proposed a 15-month process with the following
main components:
-review current Eugene Police Department (EPD) policies and procedures for
filing complaints and conducting internal investigations;
-examine other models of civilian oversight in place nationally;
-conduct a robust public outreach effort to solicit a broad range of ideas and
suggestions for improvements to the complaint system; and
-develop recommendations to improve the internal affairs process, including
options for incorporating additional civilian oversight in the system and re-
evaluating the commission’s role as a policy review body.
The commission requested contingency funds in the amount of $65,000 to assist in this effort.
The funds were primarily used for additionalstaff support to the project (0.5 FTE) and to
contract with the Police Assessment Resource Center for a report on national models of police
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oversight. On July 28, 2004, the City Council approved the commission’s work plan and
contingency fund request.
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Police Complaint System and Civilian Oversight Recommendations
III. Research and Community Values
Even before the work plan was approved, the commission began two efforts to jumpstart the
information gathering phase of the project. An extensive literature review was initiated to collect
current information on best practices and issues surrounding police complaint systems. A binder
of written material on police oversight was compiled and provided to commissioners, including
the 1998 External Review Advisory Committee (ERAC) report. This information was also
posted on-line with links to the material where available, and a binder was placed in the library
to facilitate public access to this information. See Attachment A for the commission’s research
material list.
Also beginning in June 2004, a series of community forums were conducted to solicit public
input on perceived barriers to lodging a complaint against the police, expectations for a model
complaint system, and suggestions for improvements to the process. Specifically, participants
were asked these questions:
What, if anything, would prevent you from filing a complaint with the police
department?
If you have filed a complaint in the past, what was your experience like?
If you have not, what would you expect from the process?
What ways can you think of that would improve the complaint process?
Community members were also encouraged to share comments by email or phone. All
comments were captured, summarized and provided to the commission to help identify the key
issues and community values to be addressed. See AttachmentB for the list of public input
sessions and commentary.
In November, several commissioners attended police in-service training sessions to gather
employees’ perceptions about the current complaint system and ideas for improvements. These
sessions provided useful suggestions and insights from officers and helped assure EPD personnel
that the commission was considering the needs ofboth officers and civilians in its process.
In addition to the public forums, the commissionbegan reviewing existing policies and practices
used in the complaint process. Staff presentations on internal affairs procedures, complaint
investigations, and city disciplinary processes were delivered. Commissioners Bettman and
Laue attended the National Association for Civilian Oversight in Law Enforcement conference to
collect information on different law enforcement complaint processes in place and learn first-
hand about the successes and challenges of these models. The conference also afforded an
opportunity to build relationships and network with others who are involved in this work.
A crucial portion of the background information received was the report “Review of National
Police Oversight Models.” A contract was signed with the Police Assessment Resource Center
(PARC) to conduct a national review of civilian oversight models for jurisdictions that are
comparable to Eugene and to develop recommendations on models that might be a good fit for
our community. Two public presentations of the PARC report were delivered in February 2005.
The report reviewed thirty different oversight systems, grouping them into three broad
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Police Complaint System and Civilian Oversight Recommendations
categories: 1) review and appellate models; 2) investigative and quality assurance models, and
3) evaluative and performance based models. The report was especially useful for comparing
individual elements of the different models when the commission began developing its preferred
oversight system.
Based on the input received and the research conducted, the commission agreed that the
complaint system recommendations should strive for the following outcomes:
respect and protect community members’ rights, civilians and officers alike, in an
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atmosphere that is accessible, safe and fair;
take complaints seriously and provide options for advocate support and alternative
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methods for resolution;
address the issues and reflect the values of this community;
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be impartial, transparent and timely, promoting credibility in the complaint system and
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trust in the police department; and
facilitate continued evaluation of the complaint system and overall department practices
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improve the quality of police services to the community.
IV. Model Development/Committee Process
The commission recognized that, given the magnitude and complexity of the project, a process
adjustment was needed to help it meet its projected timeline without compromising the quality of
work. In December, two committees were convened to develop preliminary recommendations
for how complaints are received and handled (intake process) and how they are resolved and
reviewed (case adjudication and civilian oversight process). The committee process was
intended to facilitate an expeditious yet thorough analysis of these specific segments of the
complaint system as well as expand opportunities for including stakeholders and other
community members in the committees’ deliberations.
Also in December, the commission met with members of Communities United for Better
Policing (CUBP) to discuss how the groups would each proceed in developing recommendations
for civilian review of the police department.The two groups agreed to work collaboratively on
parallel but separate efforts and exchange progress reports and information when appropriate.
CUBP participated in many of the committee meetings, providing insight and perspectives to the
commission as it worked to develop its own oversight model.
In January, a stakeholders email list was developed as a means of providing project information
with a large network of interested parties. The stakeholder list, containing more than 300
addresses, was used to distribute informationon the committee process, as well as to provide
notice of other commission-sponsored events related to the development of the oversight
proposal.
The commission also specifically encouraged the Eugene Police Employees Association (EPEA)
to participate in the process. EPEA representatives attended and provided input at both the
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Police Complaint System and Civilian Oversight Recommendations
committee and commission level. The EPEA’s formal positions on the oversight system are
included as Attachment C.
Complaint Intake Committee
The goal of the Complaint Intake Committee wasto “develop recommendations to improve how
complaints are received and processed to create and accessible, safe, and responsive intake
system that engenders the trust and confidence of all involved and that promotes accountability.”
The committee reviewed three separate models for complaint receipt and handling, and from
these models, developed an intake process that it believed would meet the values described in its
goal statement. The three intake models that were considered are described as follows:
Internal Intake – systems where all complaints regarding police personnel are funneled to
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the police department for processing, although various access points may exist. While
there may be multiple avenues for complainantsto initiate the process, all complaints are
referred to police personnel who are responsible for all case handling decisions
(investigate, dismiss, mediate,etc.). Like most police departments, Eugene currently has
an internal intake system.
Independent Intake – systems where all complaints against police personnel are required
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to be submitted to and processed by an entity outside the police department. This entity
has sole responsibility for complaint intake and categorization decisions, and if not
resolved at intake, assigns the complaint to the investigative unit forfurther processing.
Dual Intake – those systems where complaints may be lodged either with the police
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department or with an independent entity that has responsibility for tracking and
reviewing the complaint. In some systems, the complainant can choose either intake
entity to lodge a complaint. In others, the police department retains responsibility for
intake of internally generated complaints and civilians can choose either venue. Another
variation is where the nature of the complaint, rather than the complainant, determines
which intake system receives the complaint;for example, those where all excessive force
and discrimination complaints are handled by the independent entity. What distinguishes
dual intake systems from the other models is that both entities have complaint decision-
making and tracking responsibilities.
The committee was in agreement that the ability for community members to lodge complaints in
a neutral environment, independent from the police department, was an unqualified requirement
in its proposed model. It initially selected a dual intake model where complainants, both police
and civilians alike, could file a complaint with either the internal affairs or an independent entity,
presumed to be the auditor’s office. This process offered several advantages over the other
models in that it provided options for complainants to self-select the venue they were most
comfortable with and increased intake staff capacity to ensure a timely response to complainants.
The committee acknowledged that for a dual intake system to work well, data sharing and
coordination between internal affairs and the auditor’s office would be a prerequisite.
In sharing its recommended intake model with other commissioners, concerns were raised that
real and/or perceived inconsistencies in complaint handling decisions between the two entities
would be inevitable. The Intake Committee reconsidered its recommendation and revised the
dual model so that the auditor was responsible for complaint classification decisions. At the July
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Police Complaint System and Civilian Oversight Recommendations
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14 meeting, the intake model was revised again, this time directing all civilian complaints to the
auditor’s office for intake, classification, and follow up.
The Intake Committee also developed recommendations on several issues related to complaint
intake and handling decisions, such as whether anonymous complaints should be accepted and
the role of mediation and other alternative resolution options in the process. These
recommendations, along with the latest iteration of the intake model description, are described in
more detail later in this report.
Adjudication/Review Committee
The goals of the Adjudication/Review Committee were to: 1) review existing practices around
case adjudication, discipline decisions, and review/appeal of the adjudication, 2) explore other
processes/models and how civilian oversight fits into those models, and 3) make
recommendations for changes that would promote accountability, thoroughness, timeliness,
integrity, fairness, transparency and consistency. The committee began its task by reviewing the
1998 External Review Advisory Committee (ERAC) report and analyzing broad categories of
civilian complaint review to identify strengthsand weaknesses of each type of system. Three
models were reviewed: Auditor/OmbudsmanOnly; Civilian Review Board; and Hybrid Models
that included both an auditor and review board. The committee agreed early on that it preferred
a hybrid system as advocated by the ERAC, but that its proposal should be more specific about
the auditor and civilian review board’s authority, responsibilities and reporting relationships to
city leadership and other policy bodies.
The committee cited the following benefits of a hybrid system:
it incorporates the advantages of auditor and civilian review board-only models by
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combining increased citizen involvement and professional expertise;
it addresses requests of community and police employees for a fair, transparent and
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credible system;
it provides for more “checks and balances” within the complaint process and of police
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practices in general;
by not just focusing on individual complaints, the auditor is able monitor investigations
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with an eye towards systemic improvements, adding analytical capacity to the
organization;
there is the ability to avoid some of the legal/labor contract issues because the auditor, as
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a city employee, could assume some duties that would otherwise be bargainable if vested
in a citizen board.
Committee members also acknowledged that a hybrid system could pose some challenges in
comparison to the other models:
it may be more complex to implement and there is less chance for a seamless operation;
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there is the possibility of an adversarial relationship between the various oversight
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components, policy bodies and city leadership;
more components add bureaucratic layers and expense to the process;
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complaint resolution is apt to be less timely than in other models.
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Police Complaint System and Civilian Oversight Recommendations
In spite of these challenges, committee membersagreed that community expectations for an
independent, credible complaint process that is accountable to the public would not be met with
just an auditor in place. Similarly, the committee did not believe that a review board alone
would help identify the procedural and training changes that would improve not only the
complaint system, but enhance police services to the public.
With a focus on hybrid oversight models, the committee developed four distinct civilian review
board models and requested City Attorney advice on the legal and employee contract challenges
associated with implementing each variation. Several common characteristics were shared
between all the civilian review board models under consideration:
The review board would be comprised of community volunteers appointed/selected
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by the Mayor and City Council.
Staff support to the board would be provided through a police auditor’s office, which
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at a minimum, reports to the board on complaint trends/statistics and other work
relevant to the auditor’s office. The review board and the auditor would provide
trends and policy information to the Police Commission.
Investigations would normally be conducted by the internal affairs unit and monitored
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by the auditor, although the auditor would have the authority to request additional or
outside investigations.
Final decisions for employee discipline would remain with the Chief of Police.
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A charter amendment would be required to enable the City Council to appoint a
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civilian review board that reviews complaints surrounding employee conduct and to
allow the hiring of an auditor that is answerable to the City Council.
Review board meetings would be open to the public; confidentiality issues should be
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addressed through procedural or contract negotiation avenues.
Of the four models discussed, the committee was least interested in a system that allowed
complainants to appeal the outcome of their investigation to the civilian review board. These
systems posed the most potential for legal and employee contract problems, could become a
costly, adversarial and duplicative quasi-judicial proceeding, and were unlikely to create
improved satisfaction from those involved in the process (appellants, review board members, and
employees alike).
The committee agreed that its preferred options were a:
Bifurcated Investigation Model, where the board would oversee specific cases as they
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were being investigated and with the auditor, would develop findings on those cases
prior to the Chief developing an adjudication; and
Closed Complaint Review, where a complainant can present concerns about the
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outcome of the case to the review board, which will review the file and develop
findings on the case for delivery to the auditor and Chief of Police, but would not
impact the outcome of the investigation.
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Police Complaint System and Civilian Oversight Recommendations
Upon further discussion of the merits of these two models, the committee decided to combine
elements of both options into a new model. This oversight system was presented to the Police
Commission at its May meeting for preliminary discussion and conceptual approval of the hybrid
oversight system. Also in May, committee chairs met with members of CUBP to compare
oversight models. This discussion indicated that the two group’s proposals, while not identical,
were alike in many important aspects.
Once the commission agreed to a hybrid oversight model, research then focused on other
communities with similar systems, particularly Seattle, Portland, and Denver. The Deputy
Director of the Portland Independent Police Review Division and Chair of the Citizen Review
Committee provided an overview of Portland’s system to the commission. In June, Richard
Rosenthal, formerly the Independent Auditor for the City of Portland and recently hired as
Denver’s police monitor, gave his assessment of the commission’s proposed model.
The commission held three meetings in June for deliberation and revisions to the model,
considering further input from City Manager Dennis Taylor (see Attachment D), the City
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Attorney, stakeholder groups, and input received at two public forums. At the June 9 meeting,
the CUBP gave its support to the commission’s draft proposal if the governance of the model
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was under the auspices of the City Council. On June 23 and 28, the commission worked
through the intake system and auditor/review board roles to determine where there was
consensus on the model and identify areas in need of further refinements (see Attachment E for
the commission’s voting record on the substantive portions of the oversight model).
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At the July 14 meeting, the commission held a 30-minute discussion session with CUBP
members to determine how the CUBP would proceed with sharing its proposal and/or comments
on the commission’s oversight model with the Council. A memo from the CUBP regarding the
civilian oversight proposal is included as Attachment F. Also attached is the Human Rights
Commission’s statement of support for the oversight proposal that was read into the record at the
July meeting (see Attachment G).
After the conversation with the CUBP and another discussion with the City Attorney on the
function of the review board, the Police Commission made several adjustments to the model and
voted to forward the oversight recommendations to the City Council for its review. Attachment
H includes the City Attorney’sreview of the oversight modeland specific advice regarding the
function of the review board.
V. Proposed Oversight System Description
In its research of civilian review models, the Police Commission established that police oversight
has evolved from purely citizen volunteer boards charged with reviewing complaints against
police. Civilian review of police now includes a range of different oversight systems with
structural and procedural variations that are unique to each community. The commission agreed
early on that it favored a model that provides for an external review of complaints by
professional staff to ensure competent, thorough, objective and timely investigations. It also
valued models that enabled identification of systemic issues within the police department that
helped generate complaints. Rather than being confined to the review of individual complaints, a
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Police Complaint System and Civilian Oversight Recommendations
model that had strong evaluative capabilities to determine where changes to policy, procedures
and training would improve the overall performance of the department was desired.
The proposed model is a hybrid oversight system that consists of both a full-time professionally-
staffed auditor’s office and a civilian review board. The role of the auditor’s office is to provide
a neutral location to lodge complaints and to actively monitor on-going internal affairs
investigations to ensure objective, thorough and high quality investigations. The auditor
identifies policy, practice and training concerns to promote organizational changes that improve
police services to the community and reduce risk and liability to the city. In addition, a civilian
review board, consisting of five to seven community members, will oversee the work of the
auditor’s office. The role of the review board is to evaluate the case handling decisions and
investigative recommendations of the auditor’s office, and in a set of pre-established
circumstances, assess how complaints are being investigated and responded to. By involving
community members in the review of complaints, the commission sought to increase the
transparency and public understanding of incidents under investigation, and, over time, hoped to
reestablish trust and credibility in the complaint process.
The proposed model is broken down into three main components: 1) complaint intake,
classification and routing decisions, 2) investigation monitoring and adjudication
recommendations, and 3) case review. The auditor and review board’s function in these three
areas are described in more detail below.
Complaint Intake
The success of any complaint system is contingent on an intake process that is easily accessible
and perceived as credible and responsive to the end users. The current police department
complaint intake process is wholly internal,meaning that the police department has sole
responsibility for complaint handling and resolution decisions. In soliciting public input on this
system, people often expressed anxiety that if they complained about a police officer, they would
be subject to some form of retaliation, their concerns wouldn’t be taken seriously, and/or that
nothing would come of their complaint. In response to these concerns, the commission is
recommending that the auditor’s office become the singular intake center for community
member complaints, and that police employees can choose to lodge complaints through either
internal affairs or the auditor’s office. The auditor’s office can also process commendations.
The Police Commission recognizes that designating the auditor’s office as the receptacle for all
community member complaints will require a significant public education process. It
recommends that information on the redesigned complaint process with an accompanying
complaint form is available at multiple locations throughout the community, including
community centers, social service providers and even large retail centers. The brochures should
encourage honest feedback about police conduct and department services and be available in
English and Spanish. The commission is willing to participate as appropriate in developing a
revised complaint intake form and associated information that clearly explains the process,
options for complaint resolution and possible outcomes, and timeline expectations.
The commission also acknowledges that internal procedures for referring community members
to the appropriate entity to take a complaint, answer a question, or access other information
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Police Complaint System and Civilian Oversight Recommendations
about police services will need to be developed. The objective is to assist members of the public
in getting swift resolution to their requests, andto the greatest extent possible, capture and route
complaints about employee conduct to the auditor’s office for documentation and processing.
The commission recommends a policy statement be developed that directs all police employees
to route complaints from community members to the auditor’s office for processing and tracking
purposes. The auditor’s office will be responsible for documenting all contacts and referrals for
statistical reporting purposes.
Similar to the Police Commission, the review board will be an access point to the City and serve
a public education and outreachfunction to community membersregarding the police complaint
system. As such, the board can receive and forward complaint information to the auditor’s office
for processing. The review board can also provide a forum to gather community member
concerns about an event where police actions generate considerable public concern. The board’s
function is not to investigate the incident,but to collect public comments, help educate
community members on the complaint process, and in the event that officers’ conduct is
investigated, ensure that the original complaints brought to the board’s attention were addressed
through the ensuing investigation.
There are some situations where a community member has concerns about a police incident and
utilizes redress options other than the complaint process. The commission believes that the
auditor’s office should be able to review and potentially initiate a complaint investigation in
specific situations where community members have clearly expressed concern about police
practices absent the established complaint process, i.e., filing of a tort or risk claim, holding a
press conference, etc.
The Police Commission acknowledges that some portion of community contacts to intake staff
will not necessarily be complaints, but will be questions about police practices or referrals to
other agencies for assistance with a problem. The commission recommends that issues that can
be easily resolved to the person’s satisfaction at intake are documented via a “Contact Log” and
closed. A community contact appropriate for thecontact log has been preliminarily defined as
“questions about police policies and practices, referrals to other agencies/resources, and dispute
of facts where the contact is satisfactorily resolved at intake.” All other issues will be treated as
complaints and handled as described in the next section.
In its redesign of the complaint intake process, the commission agreed that a classification
system was necessary to facilitate efficient use of resources, timely response to complainants and
meet customer service expectations. It is recognized that any intake system will require a certain
level of judgment and flexibility to most appropriately address each concern. While there is
discretion built into the system to enable staffto exercise sound decision-making, there are also
checks and balances in place to ensure that thesedecisions reflect the values established for the
complaint system. In monitoring the work of the auditor’s office, the review board will
periodically evaluate the complaint intake and classification system to ensure that the goals of an
accessible, neutral, and responsive intake process are being met. A review of the number and
types of contacts made to intake, case handling decisions, utilization of alternative resolution
options, and other outcome measures will be conducted, and any recommendations for
procedural improvements will be forwarded to the appropriate policy body.
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Police Complaint System and Civilian Oversight Recommendations
Preliminary Investigation and Complaint Classification
Internal affairs statistics over the past several years show that the office responds to over 300
citizen contacts a year. These contacts range from simple requests for information to allegations
of criminal misconduct against police officers.As such, the department has used two broad
categories of complaints to distinguish cases that require a full investigation from other contacts:
allegations and inquiries. Complaint categorization has both procedural and public perception
implications. Procedurally, how a complaint is classified affects the level and type of
investigation conducted, disposition outcomes, timeline for completion, and record retention
requirements. In terms of public perception, the department’s internal categorization process has
been criticized as being biased, inconsistent and dismissive of valid concerns. Alternately, some
police employees have voiced frustration that the department’s intake system creates an open
door policy for frivolous complaints that redirects sergeants’ attention from supervising
employees to conducting pointless investigations. Clearly, this was an area ripe for change.
The Police Commission believes that all complaintsshould be treated with due diligence, but has
found that to make the most efficient use of resources, facilitate a timely response to
complainants, and offer multiple options for complaint resolution, a categorization system is
necessary. To ensure that the basis for classification decisions is independent, consistent and
transparent, the commission recommends that the authority for categorizing complaints rest with
the auditor’s office. A basic process description follows, but more formalized procedures should
be established to provide clear, standardized practices.
The auditor’s office will be responsible for conducting a preliminary investigation of all
complaints to determine how the issue is best handled. Vesting the authority to classify
complaints with the auditor’s office is intended to reassure the community that these decisions
will be informed, professional judgments that consider how to achieve the best resolution to an
issue, and are not formed on the perceived credibility of the complainant. For consistency, the
auditor should classify both internally generated and community-based complaints. To enable
the auditor to conduct a preliminary investigation into the involved incident requires that the
auditor have access to law enforcement databases.
The auditor will classify complaints into two categories: service complaints and allegations of
misconduct. A service complaint will include concerns about police officer performance or
demeanor, customer service and/or level of police service complaints, or complaints where the
person is dissatisfied with current procedures or in disagreement with established police policies.
The complainant does not allege behavior that would constitute a policy violation. Service
complaints, in large part, will replace the category of complaints currentlytreated as “inquiries.”
The formal definition of a service complaint will need to be developed and incorporated into
police department policy. An allegation of misconduct will be those complaints that, if true,
would be a violation of department policy, a violation of a person’s civil rights, or a criminal
offense. Both service complaints and allegations of misconduct will be further categorized by
type for statistical tracking purposes and to allow trends analysis on the nature of the complaints
received.
11
Police Complaint System and Civilian Oversight Recommendations
Complaint Routing and Possible Outcomes
The Police Commission has found that issues involving employee performance are often most
appropriately addressed by the supervisor. This encourages a learning environment for the
employee and retains supervisory involvement in employee development and initial corrective
action. Service complaints provide for resolution of complaints without a time-intensive, formal
investigation and enable supervisors to address “minor” performance and demeanor issues
through management intervention techniques (training, coaching, etc.). If the auditor classifies
the contact as a service complaint, a variety of outcomes are available to the complainant,
including notification to the supervisor, alternative resolution options, or referral to supervisor
for follow-up investigation. If misconduct is discovered through supervisor follow-up on a
service complaint, the complaint will be reclassified as a misconduct allegation.
Complaints categorized by the auditor as misconductallegations will be routed to internal affairs
for investigation. The Police Commission recommends that supervisors no longer investigate
complaints about their subordinates and that instead, internal affairs is restructured into a
specialized investigative unit that will conduct the majorityof complaint investigations.
If the complainant alleges behavior that would be a criminal offense, the auditor will route the
case to the Chief of Police for review and a decision to involve the District Attorney.
Both service complaints and misconduct allegations may be appropriate for alternative
resolution, depending in part on the type of complaint and the employee’s past history. The
auditor’s office will be responsible for identifying cases that are most appropriate for alternative
resolution options. More information and refinements on the alternative resolution process will
be developed as part of the commission-sponsored Mediation and Advocacy Task Team.
Timely notification on the receipt and disposition of complaints will be the responsibility of the
auditor’s office. If a case is dismissed, the auditor will inform the complainant for the basis of
the dismissal. If the case will proceed to a formal investigation, the auditor’s office will notify
the complainant and explain or provide information on process expectations, options and
timeline. A final disposition letter will be generated after case adjudication clearly explaining
the outcome of the case and the basis for the decision. The commission recognizes that while
increased transparency and understanding of the complaint process is an overarching goal, public
records constraints and confidentiality issues need further discussion and resolution.
The auditor’s office will maintain a robust case-tracking database documenting the receipt, status
and disposition of all complaints. The database should be shared with Internal Affairs as both
entities will have responsibility for tracking cases. If policy or training deficiencies are noted
through the review/investigation of a complaint, these would be documented as an outcome of
the complaint. Timelines for complaint notification, classification and routing decisions,
investigation, and case disposition will need to be developed.Adherence to the established
timelines will be one of the outcome measurestracked and reported by the auditor’s office.
Attachment I is a flow chart that illustrates how a community complaint will move through the
proposed model.
12
Police Complaint System and Civilian Oversight Recommendations
Other Intake-Related Recommendations
Staffing and Physical Location of the Auditor’s Office
The intake model as described will require additional staffing to be successful. This includes, at
a minimum, an auditor and requisite staff (approximately 3 FTE) and additional investigative
capacity in the internal affairs unit. The commission recommends that physical location of the
auditor’s office be separate from the police department but in close proximity to facilitate a close
working relationship with others involved in the complaint process.
Anonymous and Third Party Complaints
Currently, the Eugene Police Department has a practice of accepting anonymous and third party
complaints on a case-by-case basis, but there are no formal, documented procedures in place. In
general, anonymous and third party complaintscan only be investigated if there is enough
credible and specific information provided to identify the incident/personnel involved. For
clarification, it was agreed that third party complaints include both those submitted by a witness
to the incident (can be either an involved party or not), or by a person who is did not witness the
event but is bringing the complaint forward on behalf of another person based on information
relayed to his/her. In the latter case, the third party may be a parent or an advocate, for example.
Noting that anonymous and third-party complaintscan serve an importantrole in the complaint
process and can offer a sense of safety to complainants who are fearful of coming forward, the
following is recommended:
The police department should have a formal policy of accepting both anonymous and
o
third party complaints.
Anonymous complaints should be documentedand investigated until they either meet a
o
lack of credibility threshold or investigativeleads are exhausted. It is acknowledged that
complaints alleging more serious misconduct or criminal behavior will be allocated more
investigative resources than other anonymous complaints. It is also recognized that the
chances for successful resolution of anonymouscomplaints are low, particularly if the
investigator cannot contact the complainantfor additional information, and that these
cases may be closed after a preliminary investigation due to insufficient evidence or
information.
In addition to accepting anonymous complaints, the department should allow
o
complainants to request that their personal information be kept confidential from named
employees if an investigation ensues.
The policy should acknowledge the acceptance of two categories of third party
o
complaints:
Those with a reasonably direct relationship to the incident, such as a witness or
person with professional or organizational knowledge of incident (supervisor,
other employee).
Advocates or others with a special relationship to complainant (e.g., parent
assisting a minor child who was directly affected, advocates for persons with
disabilities, mental health issues, non-citizens or persons with language barriers).
13
Police Complaint System and Civilian Oversight Recommendations
Whenever possible, the department will encourage the complainant to contact the person
o
directly involved in the incident to participate in the investigation to verify/clarify and
provide additional information relevant to the complaint.
Intake personnel have a responsibility to advise complainants of the availability of
o
advocates, particularly in cases where juveniles or other vulnerable populations may be
involved in a formal investigative process. The actual role of advocates should be
addressed as part of the redesign of the mediation program.
Requesting Sworn Statements
One of the objectives of the redesigned intakeprocess is to encourage honest feedback from
community members about police employee performance and quickly correct misconduct once
identified. The commission recognizes that malicious complaints do occur, and that these often
result in serious personal and professional hardship to involved officers. Spurious complaints
also take a toll on agency resources and employeemorale. However, it is also recognized that
requiring all complainants to sign a sworn statement attesting to the truthfulness of their
complaint could be perceived as an obstacle to accessing the complaint system and act as a
deterrent in reporting actual police misconduct. The following recommendations attempt to
balance values around enhancing the accessibility and safety of the complaint intake process
with setting a clear expectation for truthfulness and accountability for all:
Sworn statements will not be required as part of the complaint intake process.
o
If upon review of the complaint, it is determined that criminal behavior is alleged and the
o
allegation passes an initial credibility test to warrant further investigation, a signed
statement from the complainant will be taken during a follow-up interview.
The statement developed should use language that is neutral and non-threatening.
o
Any requirement for a sworn statement should be clearly articulated in all public
o
information on the complaint process and described in a way that is factual and
encouraging of participation.
All cases where sworn statements are collected will be documented for review and trends
o
analysis.
Refusal to sign a sworn statement will not be the sole basis for discontinuing an
o
investigation.
Complaint Dismissal
A more formalized process for when complaints can be dismissed may alleviate community
concerns that complaints are not being handled consistently or fairly and will help standardize
procedures. The following are guidelines to be refined at a later date for situations where complaints
could be dismissed so that procedures are clear to the public and intake and investigation resources
are used wisely. It should be noted that these procedures indicate areas where complaints may be
justifiably dismissed, but do not limit the auditor’s discretion in making such decisions.
Document all complaints received and if dismissed, why they were dismissed.
o
14
Police Complaint System and Civilian Oversight Recommendations
Justification for dismissal
o
-Acknowledging that timeliness of the complaint is important, as memory diminishes
over time and witnesses and evidence maybe more difficult to locate/uncover, a
timeline for complaint acceptance should be established. A six month timeframe is
recommended, as it would be consistent with the retention timefor dispatch tapes and
any video recordings taken. The procedures allow, but do not require, the intake
entity to dismiss complaints involvingincidents more than six months old.
Exceptions to the timeline should be included, such as delays due to advice to first
resolve a criminal case, hospitalization, or incarceration. No specific deadline for
complaints alleging serious criminal conduct should be in place.
-If the complaint is about an employee who does not work for the City, the complaint
can be declined as outside the jurisdiction of the auditor’s office and the complainant
referred to the appropriate entity;
-If upon review of the complaint it is determined that the substance of the complaint is
solely to contest the enforcement action taken (not the manner in which it was taken)
the complaint may be dismissed and the complainant directed to the appropriate
remedy or channel for that grievance, e.g., municipal court to contest traffic citation;
Complaints that are closed due to insufficient information should be flagged as such in the
o
final case disposition.
Warrant/Records Checks
Some community members have expressed concern that the practice of running a records check
on complainants, which not only provides basic incident information but also indicates whether a
person has an outstanding warrant, could have a chilling effect on the complaint process and
prevent people with old or active criminal histories from coming forward with complaints.
Further, it was feared that reviewing a complainant’s record would have a prejudicial impact on
the process, i.e., people with more police contacts would not be given as much credibility as
others. It should be noted that a records check is a query of the local law enforcement database
to show the number and types of police contacts, and includes notification of any outstanding
warrants (state and national). This differs from a “background check” which is a more extensive
search of a person’s law enforcement record, any resulting court proceedings and sanctions,
credit checks, employment history, etc.
By moving the preliminary investigation and classification of complaints under the auspices of
the auditor’s office, the commission hopes to ameliorate some of the issues associated with law
enforcement databases queries which inextricably determine the information necessary to
process the complaint and indicate the existence of outstanding warrants. Unlike a police
department employee, auditor’s office staff would not be obligated to act on an outstanding
warrant, but could instead encourage community members to responsibly take care of court
orders. The following process is recommended.
Records/warrant checks should not be conducted on a routine basis as part of complaint
o
intake as this can be a deterrent to potential complainants.
The auditor’s office will have the responsibility to screen and conduct a preliminary
o
investigation of complaints forclassification purposes. As part of this process, intake
15
Police Complaint System and Civilian Oversight Recommendations
personnel may need to run a records check to identify involved personnel and gather
other incident information necessary for the complaint categorization. If an outstanding
warrant is discovered during this process,intake personnel will have the discretion to
notify the complainant of this fact so that the warrant can be resolved without risk of
arrest. In situations where the complaintis of a serious nature, the fact that an
outstanding warrant exists will not delay processing the complaint. Similarly, if an
outstanding warrant for certain crimes (e.g., a violent felony) is discovered, intake staff
will notify police of this fact when appropriate. Procedures will be developed to provide
guidance for when intake staff should take more direct action on an outstanding warrant.
The Police Commission recognizes that records checks are a routine portion of all police
o
investigations, including internal investigations. However, as only a subset of all
complaints will require a formal investigation, removing a records check from the initial
complaint intake process significantly reduces the risk that filing a complaint will trigger
an arrest. Since a records check will occur if the complaint proceeds to the investigation
phase, public information on the complaint process should explain that as part of
investigating the complaint, any outstanding warrants will be identified. The language
should encourage people who are concerned about the possibility of an outstanding
warrant to access the auditor’s office to filea complaint and/or to clear their warrants
with the Court before filing a complaint.The actual language selected should attempt to
balance transparency with other values such as neutrality, open access, safety and
accountability.
Alternative Resolution to Complaints
The commission believes that a successful mediation program should be an integral part of the
redesigned complaint process. As such, commissioners have expressed a commitment to
modernize and expand the current program to ensure complainants are informed of the complaint
resolution options available to them and to maximize opportunities for alternative resolution.
Over the years, the department has worked with the Human Rights Program to develop a
mediation and advocacy program that has had a number of successes and is not significantly
different in its function than the model programsexamined nationally. However, there is a sense
that the existing program has not reached its potential and after several years in effect, may
benefit from an evaluation.
The commission supports the current practices of offering formal mediations, facilitated
conversations, and/or advocacy support for certain complaints to promote understanding of
interactions and promote respectful communication and accountability for each person’s actions.
The commission agreed at its May 12, 2005, meeting to appoint a task force of Police
Commission, Human Rights Commission, and community stakeholders to look at current
practices and make proposals regarding the enhancing the role of mediation and advocacy in the
complaint process. Specifically, the task team will determine which entity should manage the
mediation program and coordinate actual mediations, whether mediators should be hired on
contract, whether mediation should preclude the use of the regular complaint process, and how
community advocates may best be utilized in the process. The task teamwill include interested
commission members, HRC staff and volunteers, and other key stakeholders, such as
Community Mediation Services.
16
Police Complaint System and Civilian Oversight Recommendations
In the interim, the commission recommends the following improvements:
Reconsider and develop more specific definitions of “mediation” and “facilitated
o
conversation”
Formalize procedures for which types of complaints can be mediated and who
o
decides which complaints are appropriate for alternative resolution
Develop procedures for how advocates are involved in complaint intake, investigation
o
and alternative resolution options
Improve data collection and tracking of mediations/facilitated conversations so that
o
the number and types of complaints that were resolved through alternative resolution
processes and how successful those efforts were can be evaluated
Integrate alternative resolution options into the complaint process (promote/share info
o
about mediation and advocacy options, etc.) and increase publicity and outreach for
mediation both internally and to the public.
Auditor Role in Monitoring Investigations
Investigation Assignment
The auditor’s office screens and classifies complaints to determine if the issue is a misconduct
allegation that will require an internal investigation. The Police Commission believes that there
is certain subset of internal investigations that, due to the nature of the complaint, are of high
public interest and require the utmost scrutiny to ensure a fair and credible outcome. The auditor
will identify these complaints as “community impact cases,” which will include, at a minimum,
excessive force, violation of constitutional rights, and bias/disparate treatment allegations. The
review process for “community impact” cases is discussed later in this report.
In the preliminary review of an allegation of misconduct, the auditor maydecide that to reduce
the potential for real or perceived bias, the investigation should be conducted by an external
entity. In authorizing the auditor to require external investigations, the commission recommends
that criteria are developed to guide the auditor in making such decisions and that a source of
trained, outside investigators is identified.
Allegations that involve possible criminal offenses will be routedto the Chief of Police with a
recommendation for District Attorney involvement. The auditor will not be directly involved in
any criminal investigations but will have access to the case files relevant to the administrative
portion of the allegation and as part of his/her role in systemic review.
The auditor will route all other allegations, including “community impact cases”, to the internal
affairs unit for investigation.
Case Monitoring
The auditor will actively monitor on-going investigations to ensure a thorough, objective, and
timely process and a high quality end product. This requires that the auditor have unfettered
access to all relevant investigative materials, an authority which the commission believes should
17
Police Complaint System and Civilian Oversight Recommendations
be specified by ordinance. The Police Commission recognizes that the auditor’s level of
involvement in a specific case will depend on the type of allegation. For instance, internally-
generated investigations that involve employee performance issues may not merit the same
attention and resources as other cases, but these decisions need to be made on a case-by-case
basis.
In the course of monitoring an open investigation, the auditor may sit-in on and participate in
investigative interviews involving employees, complainants and/or witnesses. A policy statement
may be necessary to clarify that employees are required to cooperate fully with the investigative
process and the auditor as part of that process.
In his/her review of an investigation, the auditor may require additional investigation by internal
affairs staff to ensure that, to the extent feasible, all relevant investigative leads were explored and
the facts of the case have been fully established. Additionally, if while monitoring a case, the
auditor believes that the standards for a high quality investigation are not being met, the auditor can
contract with an outside entity to assume the investigation.
Adjudication Recommendations
Once the investigative portion of the complaintreview is complete, all case materials will be
provided to the auditor. The auditor will make every reasonable effort to contact the complainant to
let him/her know that the investigation is complete, summarize the case findings, and determine if
the complainant has any additional information to share relevant to the case. One of the objectives
of this contact is to promotea better understanding of the process and options available to the
complainant, including possible involvement of the review board once the case is closed. Also, if
new information is provided during this contact, the auditor can then direct further investigation.
If the auditor is satisfied that the investigation is complete at this point, s/he will meet with the
involved employee’s supervisor to develop a case adjudication recommendation that will then be
forwarded up the chain of command to the Chief of Police. Any disagreements on the adjudication
recommendation between the auditor and the command staff will be documented and forwarded to
the Chief. Final adjudication and discipline decisions rest with the Chief of Police.
An associated effort pertaining to case adjudications was to review the existing disposition terms
and determine if other adjudication types and/or names would help complainants better
understand the outcome of their complaint. It is important to note that these terms apply only to
complaints that have undergone an investigation; these definitions do not apply to complaint
outcomes that, after being classified, are processed without a formal investigation. The revised
adjudications being recommended are as follows:
1) Sustained
: The complainant’s allegation(s) were determined to be a violation of EPD’s
policies, rules, and/or procedures and, by a preponderance of the evidence, the employee(s)
involved committed the violation as alleged.
1
2) Insufficient Evidence
: The chain of command was unable to determine, by a
preponderance of the evidence, whether or not a violation of EPD’s policies, rules, and/or
procedures occurred.
1
Replaces “Not Sustained”
18
Police Complaint System and Civilian Oversight Recommendations
3) Unfounded.
:The claim is unsubstantiatedIt wasdetermined by a preponderance of the
evidence that the employee(s)involved did not engage in the behavior as alleged by the
complainant.
2
4) Within Policy
: It was determined, by a preponderance of the evidence, that the behavior
of the employee(s) involved did occur but was consistent with EPD policies, rules, practices
and/or procedures.
5) Mediated
:During the process of an investigation, it was determined that the case would
likely be more successfully resolved through mediation; all parties agreed to mediate the
complaint and the mediation process was completed.
6) Inactive
:The investigation cannot proceed forward without additional information. The
investigation may be reactivated upon the discovery of new, substantive information or
evidence.
7)Administratively Closed:
The investigation is closed prior to reaching a conclusion. For
instance, the complainant does not provide the information needed or refuses to cooperate
with the investigation.
Systemic Review
One of the primary strengths of the auditor modelas proposed is to afford additional analytical
capacity that is not merely focused on individual complaints but strives towards systemic evaluation
of the complaint process and departmental practices in general. In furtherance of this objective, the
commission recommends that the auditor:
be summoned to the scene of critical incidents to enable first-hand knowledge of high
o
profile events should a complaint ensue;
participate in deadly force review boards (contingent on the result of SB301)
o
review risk/tort claims and develop risk/liability reduction plans
o
The City Manager’s contracted annual audit of closed internal affairs investigations would no
longer be necessary if the auditor model proposed is implemented.
The commission has found through its research that the ability to influence police policy is one
of the strongest accountability measures. Whilethis authority may be vested in either the
auditor’s office or the review board, experience nationally has indicated that the volume of
complaint investigations tends to diminish thecapacity to conduct thorough policy reviews. As
such, the Police Commission recommends that it is retained as the department’s policy review
body and that the auditor is charged with reporting any policy issues to the commission.
The auditor’s office will also develop an annual report of its workload, case handling and
investigative recommendations and suggestions for procedural improvements. The report may
also evaluate discipline decisions for consistency across personnel and relevant to specific
violations. The annual report should highlight any situations where the auditor recommended
actions that were not supported by the Chief of Police and how those disagreements were
resolved. The annual report should also enable both the review board and City Council to assess
the performance of the auditor’s office to ensure that it is functioning as intended.
2
Replaces “Exonerated”
19
Police Complaint System and Civilian Oversight Recommendations
Civilian Review Board Role
Individual Case Review
A fundamental responsibility of the review board is to oversee the work of the auditor’s office
and, from a civilian perspective, ensure that the case recommendations developed promote high
quality, objective investigations. The board’s oversight function can occur in two ways. First,
the auditor’s office will develop quarterly reportsfor board review that document the auditor’s
case handling decisions, input on investigations, adjudication recommendations, and
identification of departmental procedure and/or training issues.The board may also participate
with the auditor in more specific, periodic evaluations of the complaint system. These may
include satisfaction surveys from complainants and other involved parties, case handling audits,
and investigation trends analysis, etc.
Secondly, the board can review closed investigations upon request of the complainant, at its own
discretion through a majority vote of board members, or by the auditor’s recommendation.
Additional criteria to guide board decisions to accept or decline the review request should be
developed. For example, can police employees request the board review a case or should they be
required to use the established grievance procedures? The closed case review is prospective in
nature, the focus of which is to establish if the complaint system worked as intended in that
particular case and to develop recommendations for process improvements. The board’s case
findings will be provided to the auditor and Chief of Police.
If the board agrees to a closed case review, it will be provided access to the full investigative file
so that it can make a reasoned judgment about the quality of the investigation and the rationale
for the case disposition. To enable more transparency into the process, actual discussion of the
closed case will occur in a public meeting. A case summary that redacts identifying information
will be provided at the meeting to protect confidentiality of involved employees. More formal
procedures for closed case reviews in a public setting will need to be developed (i.e., auditor/lead
investigator reporting requirements, questions and comment period, public input, etc.).
The board, in turn, will develop and present an annual report to the Mayor and City Council
evaluating the auditor’s work, assessing whether the auditor’s office is functioning as intended,
and recommending improvements to current policies and procedures. The report will also note
concerns about complaint investigations and/or the adjudication recommendation made by the
auditor, which may precipitate policy and practice changes as directed by the Council and/or
indicate deficiencies in performance expectations within the auditor’s office.
Community Impact Cases
The commission had a thorough discussion on the function of the review board as it related to
monitoring “community impact cases.” The commission had considered a model where the
board had access to these cases prior to the adjudication decision so that its comments and
recommendations could be formulated and shared before the outcome of the case was decided.
However, upon City Attorney review of this process, the commission recognized several
significant risks with the proposal:
20
Police Complaint System and Civilian Oversight Recommendations
Board members would have access to case information that, if purposely or inadvertently
o
released to others, can breach the integrity of the investigation;
For the board to have a meaningful discussion on an open case while protecting
o
confidential information, it would need to meet in executive session, which compromises
the transparency of the board’s deliberations and actions;
Even if conducted in executive session, board members’ actions and statements directly
o
and indirectly related to the case can be called into question in an arbitration setting. It
will be more difficult for the city to sustaindiscipline because it will have to prove that
the board’s involvement (or individual member’s actions) did not influence the Chief’s
adjudication decision.
The commission reconsidered this model in light of these issues and approved a substitute
process whereby the review board would have access to closed investigations, but have the
authority to re-open the investigation with cause. It was agreed that the alternative proposal
mitigated some of the most serious issues without compromising the impact of the board in these
high profile cases. The review board’s function in community impact cases is described below.
Investigations that meet the pre-determinedcriteria for a community impact case will be
provided to the board upon adjudication of the complaint, but prior to a discipline decision if the
case is sustained. The board would receive both sustained and un-sustained community impact
case investigations. As a starting point, community impact cases will include allegations of
excessive force, bias/disparate treatment and allegations that involve violation of constitutional
rights. A formalized definition will need to be developed as a matter of policy.
The board would have full access to all investigative materials related to these cases, in a non-
3
public setting, in preparation for discussion of the case in a public meeting. The board will then
convene to discuss the quality of the investigation and the outcomeof the case with the
auditor/lead investigator, and based on its discussions, could:
-Concur with the adjudication; and/or
-Develop findings regarding possible improvements about the investigative
process, complaint handling practices, and/or other police procedures relevant to
that case; and/or
-Find that there were deficiencies in the investigation that impacted the outcome of
the case, or that the adjudication was not supported by the facts in the case, and
vote to re-open the case to examine those areas.
Unless the board votes to re-open the investigation, if the complaint was sustained, the case
would proceed to the discipline phase. If the board requires further investigation, the auditor
would report back to the board on the outcome of any additional investigation and whether the
adjudication was modified. The board would have access to that portion of the investigation
after it was completed and can develop a final set of findings on the entire case at that point.
The complainant would not be able to request any further review of “community impact” cases.
However, complainants will still be able to request the board to conduct a prospective review of
3
Cases where the complaint is sustained couldnotbereviewed in a public meeting under the currentEPEA
contractual agreement.
21
Police Complaint System and Civilian Oversight Recommendations
other types of closed cases. It will be the auditor’s responsibility to alert complainants that their
case will be automatically reviewed by the board as a matter of policy for community impact
cases, and will notify complainants of their ability to request review by the board in other types
of cases.
Board Membership Recommendations
The commission strongly believes that the success of the proposed model rests in large part on
the quality of community volunteers that serve on the board. A high level of integrity and
discipline will be required, as will the ability to review cases impartially, acting primarily as fact
finders. The commission has developed the following board membership and selection process
parameters:
A smaller board size comprised of 5-7 members is recommended to maintain a highly
o
effective and qualified membership. The existing enabling ordinance for the Police
Commission already provides that one member of the review board is appointed to serve as a
member of the commission to facilitate information exchange.
Members should serve 4-year staggered terms, with a two-term limit (some members
o
preferred 3-year terms).
Members must be age 18 or olderand must meet residency requirements (residency within
o
the urban growth boundary and city limits were both discussed, but a decision on which
requirement was preferred was not reached).
Real and perceived impartiality is critical to the credibility of the board. As such, city
o
employees are not allowed to serve, nor should direct family members of police employees.
Those with felony convictions should also be prohibited from serving on the board.
Additional recommendations for background qualifications, skills and training requirements
will be developed once the function of the board and its reporting relationships are decided.
Selection of members should strive to be reflective of the community, but should not be
o
based on representing a particular constituency (council wards, special interest groups,
neighborhoods, etc.). Instead, members should be selected based on a demonstrated ability
to be fair and impartial.
The Mayor should develop and oversee the selection process, possibly in consultation with
o
the auditor, so that it includes broad community participation in application screening
process. The community panel would review applications and select a slate of candidates for
City Council’s consideration. However in making the board appointments, Council may
select an applicant outside the selection panel’s recommended candidate pool.
Procedures for removal of members after appointment should be developed.
o
The commission agreed that to protect the board from outside influence, the Chief should not
o
serve in an ex-officio capacity on the board, nor should any city officials have specific
nominating authority for board members.
22
Police Complaint System and Civilian Oversight Recommendations
VI. Oversight Model Frequently Asked Questions
1.What is a hybrid police oversight system and why was it selected?
A hybrid system combines two distinct components into one system. In this case, the two
components are a professional police auditor and a civilian review board. The commission is
recommending a hybrid system of civilian oversight to build on the strengths of each
component to best meet the community’s expectations. The full time auditor monitors
investigations for quality assurance and identifies systemic changes needed to improve the
overall performance of the organization. The civilian review board creates opportunities for
community members to review and comment on how the department investigates and
responds to complaints, promoting a fair and transparent process.
2.Whatmakes this model independent of the police department?
To ensure structural independence of the oversight system, the commission recommends that
the auditor be hired and report to the City Council, and that the City Council, with
community input, appoints the review board members. The auditor’s office will provide the
staff support to the review board. So while the auditor and his/her staff are city employees,
they will not be employed by the police department, physically located in the police
department, or supervised by the Police Chief.
3.How does this model assure that all complaints are handled appropriatelyand that
complainants are protected from retaliation?
The intake and classification of complaints, which determines how a complaint is handled,
will no longer occur within the police department. Instead, based on clear protocols, the
auditor’s office will decide how a complaint would be classified. The review board will
monitor these decisions through review of quarterly reports. In addition, the ability to lodge
complaints in the auditor’s office is intended to provide a safe and neutral environment for
complaint intake. People who are still anxious about the possibility of some form of
retribution for filing a complaint may choose to lodge their concerns anonymously.
Anonymous complaints will be taken seriouslyand will be classified. However, the auditor
will not be able to conduct follow-up communications with an anonymous complainant.
4.Why does this system still allow police to investigate police?
One of the fundamental values for the complaintsystem is the desire that investigations are
impartial, thorough and fair. Misconduct investigations, which carry the possibility for
discipline up to and including employee termination, must meet rigorous standards for
objectivity and integrity. The outcome must be based on a preponderance of evidence. For
these reasons, the commission believes that the investigations should be conducted by trained
professionals, but monitored for quality assurance by an outside, independent civilian
employee, i.e., the auditor. To help protect these investigations fromreal or perceived bias,
the commission is also recommending that the involved employee’s supervisor no longer
conduct internal investigations. Instead, the internal affairs unit should be restructured so
that it has the capacity to conduct investigations of employee misconduct.
23
Police Complaint System and Civilian Oversight Recommendations
5.Who decides the outcome of my case and what if I disagree?
In an effort to achieve the best possible outcome, the proposed oversight system offers
multiple resolution options. In reviewing your complaint, the auditor will determine if your
case should be handled at the line supervisor level, is appropriate for alternative resolution, or
requires a misconduct investigation. If an internal investigation is required, the auditor will
monitor the case and develop an adjudication recommendation. Ultimately, the Chief of
Police will determine the disposition of internal investigations and if the allegation is
sustained, what level of discipline is warranted. If you disagree with the outcome, you can
request that the review board take another look at your case to ensure that the investigation
was thorough and fair and that the adjudication decision was consistent with the facts of the
case.
6.Isn’t subpoena power necessary to compel police officers to provide information needed by
the board to review my case?
The review board will have access to the full investigative file, which will include taped
interviews with the involved officers. Therefore, the commission determined that compelling
testimony was unnecessary to access the information needed to review an investigation.
7.How do I know what type of discipline occurred in my case?
You will be notified of the adjudication decision and if discipline will be imposed. However,
the type of discipline cannot be disclosed. Oregon public records law dictate that employee
discipline records be treated confidentially and are not open to the public. The auditor will
develop an annual report that will show the number and type of allegations investigated, the
adjudication decisions, and type of discipline rendered. In this way, the public will have
access to statistical information that explains the outcome of investigations and meets
confidentiality requirements.
8.Does this model require a vote to implement?
An amendment to the existing city charter will be required to enable the City Council to hire
the auditor and appoint review board members. City charter amendments require an
affirmative vote of the public. However, if the charter amendment vote fails, the model can
be implemented under the City Manager’s purview with largely the same role and
responsibilities.
9.How much will thissystemcost?
Once the oversight model is finalized, a budget will be developed that includes staffing for
the auditor’s office (approximately 3 FTE).Other costs associated with the model’s
implementation include additional investigativecapacity in the internal affairs unit, and
training and other requisite support for the board to operate effectively.
10.Will the police union oppose a civilian oversight system in Eugene?
The Eugene Police Employees Association (EPEA) has voiced support for additional
oversight that is accountable to the public and respectful of the rights of police officers. The
EPEA has a responsibility to ensure that the due process rights of its membership are
24
Police Complaint System and Civilian Oversight Recommendations
protected in any new system that is implemented. In the commission’s proposed model,
there are several elements that will require negotiation with the union to enable the
contractual changes necessary to implement the system.
11.How will members of the review board be selected to ensure broad community
representation?
The police commission believes that the reviewboard’s success lies in its ability to be
impartial. To achieve this, the review board membership should reflect the community, but
not be appointed to represent any particular constituency or organization. The commission
has suggested a selection process that involves a Mayor-appointed community panel that will
screen applications using a set of standard criteria, and forward a pool of candidates for City
Council consideration. If the charter amendment passes, the City Council will ultimately
make the review board member selection decisions.
12.How will we know if the oversightsystem is effective?
Experience in other communities indicates that civilian oversight systems are continually
evolving as direct experience grows and national best practices are established. A robust
database will be developed as part of the system to enable tracking and analysis of
complaints as they move through the system. The commission plans to evaluate the
complaint system six months and a year after implementation to determine where
improvements are needed. This may include both a review of the data collected and
satisfaction surveys of people involved in the system (review board members, police
employees, complainants, etc.).
VII. Outstanding Issues and Next Steps
Jurisdiction of Oversight Model
One of the overarching, but unresolved, issues surrounding the oversight proposal is a
determination of which police department employees would be subject to the new procedures.
There are several key issues to consider when making a decision regarding the scope of authority
for the oversight system. The unique role and broad authority police officers have, which in turn
has the most potential for abuse of power and community impact, is the primary impetus for
additional civilian oversight. It is this role that distinguishes police officers from other city
employees. Therefore, an oversight system that applies to sworn officers only would be a
reasonable and practical delineation, and not inconsistent with the direction taken in other
communities.
However, another underlying principle is the desire to facilitate systemic change in the police
organization. Limiting the scope of authority for both the auditor and the board to reviews of
sworn employees may counteract this objective. Other key considerations include:
Providing a consistent process across employees who work in the same units or have
o
the same job functions within the city;
Applying oversight resources where they will be most effective;
o
25
Police Complaint System and Civilian Oversight Recommendations
Creating a system that is not overly confusing to the public or procedurally
o
complicated to maintain; and
Developing a system that has credibility to employees and the public.
o
rd
The commission discussed this issue at its June 23 meeting and considered five options for
determining which employees the oversight system had jurisdiction over. It narrowed the
options to the following two categories for City Council consideration.
Categories of Employees Covered Considerations
1) All EPD employeesSimplicity and consistency in procedures
within the department; however, it would
create inconsistency among AFSCME
represented employees and non-sworn, non-
represented employees City-wide; requires
negotiation with two bargaining units.
2) Auditor’s role would include complaint Maintains consistent, simple process for intake
intake for all EPD employees, access to all and allows the auditorto be aware of and
EPD records and ability to monitor all identify issues regarding investigation of all
investigations; review board’s authority is employees; targets oversight resources on
sworn employees. Board would be kept complaints that normally have highest liability
apprised of all complaints through auditor’s and community interest.
quarterly reports.
Governance Issues
Another key decision point for the Council’s consideration is whether it will seek voter approval
for a charter amendment to implement the model as proposed by the commission, and if so, the
timing for the election. The commission considered the following points when deciding whether
the oversight bodies should report directly to the City Council:
Costs and timing constraints to enable a November 2005 ballot initiative
o
Uncertainty of the election results may delay model implementation
o
Structural independence for the auditor maybe necessary to make decisions that may
o
not be otherwise supported by city management
Review board will become a governing body per the public records law and subject to
o
open meetings requirements; other legal and contractual issues
Model may have more credibility with the public, but is not likely to gain the support
o
of the police union
More potential for politicizing the complaint process if oversight entities report to
o
elected officials
Tangential issues associated with modifying the current city manager/council form of
o
government
The commission agreed that the credibility of the oversight system required that it have structural
independence and voted unanimously to recommend that the City Council hire the auditor and
appoint the citizen review board.
26
Police Complaint System and Civilian Oversight Recommendations
Next Steps
The Police Commission’s report is intended to be a comprehensive description of its proposed
complaint system. However, as a conceptualmodel, the commission recognizes that multiple
procedural refinements will be necessary prior to implementation.
One area that will need considerable attention is the design of a robust data collection and case
tracking/reporting system that can be utilized by boththe auditor’soffice and the internal affairs unit to
This database should support a rigorous initial assessment
flag personnel, policy and training issues.
and continual evaluation to identify where adjustments are needed so that the complaint system
maintains relevance to current needs and expectations and meets established outcomes for
effectiveness. Complaint records retention procedures should be reconsidered as part of the
system design.
The commission also recommendsthat the data collection and reporting system be designed to
facilitate the seamless integration of an early intervention system in the future. The
implementation of a formal early warning system to identify officers who may need intervention
and assistance is one that the commission believes holds promise and is related, but adjunct, to
the immediate revisions to the complaint process. This is a topic that merits a thoughtful and
collaborative process that involves police department managers, human resources staff and the
EPEA, and could be included as a project in a future police commission work plan.
The Police Commission’s proposed oversight model mitigates many of the major legal and
contractual obstacles that would have required resolution prior to implementation. Nonetheless,
if the Council moves forward with the model as proposed, there are issues that will require
negotiation with the EPEA, revolving mainly around maintaining confidentiality of records and
public meetings.
Other outstanding issues identified at this time that the Police Commission can address, if
requested, include:
Whether the board should have the ability to audit a random selection of closed cases in
o
addition to those that are brought before it by the complainant?
Better defining the relationship between the review board, the auditor and the Police
o
Commission, i.e., does the role of the commission alter in any significant way?
Hiring decisions around the auditor position including:
o
should the auditor be hired as an at-will employee?
o
should there be specific removal procedures to protect him/her from unpopular
o
decisions (i.e., requiring a super-majority vote of council?)
should the auditor be hired prior to finalizing the enabling ordinance and policies
o
so that s/he can assist in formulating the operating procedures for the auditor’s
office and review board?
Should the commission participate in developing the hiring process and criteria
o
for selection of the auditor?
To what extent should the commission be involved in the design of a system evaluation
o
tool and actual assessment of the oversight system after implementation?
27
Police Complaint System and Civilian Oversight Recommendations
Upon review and discussion of the recommendations contained in this report, the commission is
happy to assist in resolving these and other outstanding issues with the input and direction from
City Council.
VIII. Attachments
Attachment A. Police Complaint System and Civilian Oversight Project: Commission Research
Material List
Attachment B. ComplaintProcess Public Forum Summary
Attachment C. July 12, 2004 and May 10, 2005 Memos to Police Commission from EPEA
President Willy Edewaard
Attachment D. May 17, 2005 Memo to Police Commission from City Manager Dennis Taylor
on Proposed Oversight System
Attachment E: Police Commission OversightSystem Decision Points: Commissioner Voting
Record
Attachment F. July 21, 2005 Memo to Police Commission from Communities United for Better
Policing
Attachment G. July 14 Memo to Police Commission from Human Rights Commission
Attachment H. June 7 and July 8 Memo to Police Commission from City Attorney Sharon
Rudnick
Attachment I: Police Oversight Model Flow Chart for Community Concerns
28
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