HomeMy WebLinkAboutItem #10 - Discussion ItemJoseph R. Grassie
City Manager
Kenneth I. Harms
Chief of Police
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June 19, 1979
-•-,.1 Internal/External Review
'ENCLOSURES -
FILE, REL 3-3
In response to Mayor Ferre's requests over the last year -and -a
half, and the recent interest in the subject of Police Review
Boards by the media, in the wake of the LeFleure incident, the
Department has been actively reviewing methods used in other
communities to insure proper police conduct and public account-
ability, while at the same time evaluating the effectiveness of
our own procedures. I have in the past taken the position that
a strong internal administrative review is the most effective
and efficient method of processing complaints of police mis-
conduct. I have also publicly taken the position that a tradi-
tional external Civilian Review Board wouldbe inappropriate for
the City of Miami.
Recently, at the request of County Commissioner William Oliver,
in his capacity as council member and at the request of the,Dade
County Commission, the Miami -Dade Criminal Justice Council
conducted an extensive study of these issues, focusing on
citizen complaint review procedures for Criminal Justice agencies
in Dade County. The subsequent staff report on the subject
specifically recommended against the establishment of an external
Civilian Review Board. The staff did, however, indicate that
some form of external review was necessary. The report recom-
mended three alternate models of which the Council chose to
recommend two, along with three additional models that were
independently submitted, for referral to the Dade County Commis-
sion.
At the May 22, 1979 City Commission meeting, Mayor Ferre re-
quested that the Police Department review and report to the
Commission on alternative methods of investigation and review of
citizen complaints. The Mayor further requested that the Depart-
ment analyze the method of processing citizen complaints that has
been established by the Chicago Police Department and advise the
Commission on the desirability of implementing that procedure in
Miami. Mayor Ferre described the Chicago Review procedure as a
Joseph R.'GraSsie
June
Civilian Committee of non -sworn individuals that was also
headed by a civilian administrator who reported to the
Superintendent. He indicated that the committee was made
up of young attorneys who had graduated from local law
schools.
The Mayor explained that the system permitted grass roots
participation through review by two additional boards.
Once the Civilian Review Board makes a recommendation to
the Superintendent, the police organizations have a system
by which they can disagree with that recommendation.. They
can make an independent recommendation. The second board
is an advisory board selected from the community which, if
they disagree with the recommendation of the Civilian Review
Board, can also make an advisory recommendation. The final
decision is then made by the City Administration.
The Mayor felt that this system provided both a professional
inside overview and a non-professional citizen participa-
tion on an advisory basis if they disagree with the conclu-
sions.
In order to evaluate the Chicago Police Department's review
methods, an on -site visit was made by a member of my staff
with the Chicago Police Department and other concerned
Chicago community organizations on June 6, 7 and 8, 1979.
(Attached is the interview schedule outlining the individ-
uals contacted.)
It was found that the Chicago Police Department has a unique
method of conducting internal investigations in that they
have two separate units within the department: the Office of
Professional Standards (O.P.S.) and the Internal Affairs
Divisions (I.A.D.).
The Office of Professional Standards is staffed by civilian
employees of the police department and is limited to
investigating complaints of excessive use of force and par-
ticipating in the investigations of shooting incidents
involving Chicago police officers. The Internal Affairs
Division conducts all other internal investigations or refers
less serious complaints to the employee's commanding officer
for investigation and recommendation.
The focus of the visit was primarily on the activities of the
Office of Professional Standards. This unit is currently
Joseph R. Grassie - 3 June
headed by a civilian attorney, has a staff of 82 -_57 of
which are investigators - and an annual budget of $1.5
million.
The Office of Professional Standards was established in 1974
by the then new Superintendent James Rochford in the wake
of considerable community/police unrest and a scandal which
resulted in the indictment of approximately 70 Chicago
police officers on corruption -related charges. There had
also been an incident in which a Chicago police officer had
shot a juvenile under conditions that seemed unreasonable
and the Internal Affairs Division investigation of the
incident had been severely criticized. These incidents led
to the demotion of the previous superintendent and resulted
in considerable public demand for improvement in the depart-
ment's internal investigations.
It is interesting to note that it was generally accepted,
even within the police department, that the public lacked
confidence in the Internal Affairs Division investigations
of excessive use of force complaints and that this lack of
confidence was justified, in that the Internal Affairs
Division had proved ineffective in conducting these types of
investigations.
The Office of Professional Standards became operational in
1974, headed by a troika of civilian attorneys: one white,
one black and one Latin. However, this proved unworkable
and James Casey, the white attorney, subsequently became the
head of the program. Civilian investigators are hired and
trained at the Police Academy though they do not attend the
same classes as the Chicago Police Department's officers.
An attempt is made to insure an ethnic and racial mix in the
investigative staff, which is generally made up of young,
recent college graduates. The investigators are paid
salaries equal to that of police investigators, which is
higher than that of starting Chicago police officers. The
Office of Professional Standards investigators are not sworn
police officers and do not carry weapons.
The purpose of O.P.S. was to improve public credibility
because it was perceived that I.A.D. was not trusted by the
community. The program, after initially experiencing con-
siderable problems, seems to have become generally accepted
and is meeting this objective. Both Police Department
Joseph R. Grassie
representatives and community organizations
with its operation.
There are, however, several significant drawbacks that must
be considered in evaluating the advisability of implementing
such a program in the City of Miami. Principal among these
is the fact that the program is expensive; the quality of
investigations is inconsistent and generally lower than the
quality of I.A.D. investigations; the investigations take
considerably longer to be completed; and O.P.S. investigators
need closer supervision than do police investigators. An
additional negative aspect of the program is that it tends to
significantly increase the number of complaints lodged
against officers, with the increased complaints being generally
of a more frivolous nature.
The Chicago Police Department, however, apparently feels that
added cost and the reduced quality of investigations were
worth trading off in order to insulate the Department from
controversial situations.
It is important to note that the Chicago Police Department is
not unionized and that there is no appeal outside of the
Department for disciplinary action of less than six days
suspension.
This is important because the majority of the disciplinary
action taken by the Department, as a result of O.P.S.
investigations, fall within the six -day -no -outside -appeal
period. Thus the majority of O.P.S. sustained complaints are
not subject to external review in the form of an employee
appeal.
In the Chicago Police disciplinary process, the employee may
have disciplinary action reviewed by a departmental board
that can make recommendations to the Superintendent. Any
disciplinary action of six days to thirty days suspension
may be appealed to the Police Board which is similar to the
Miami Civil Service Board with respect to disciplinary
matters, except that its decision is binding and final unless
the employee appeals to the Circuit Court for relief. Dis-
ciplinary action in excess of thirty days suspension or for
termination, must be approved by the Police Board which makes
the final decision, which is also appealable to the Courts.
June 19,, 1979
appear satisfied`
Joseph R. Grassie
A. comparison of the overall complaint review procedures of
the City of. Chicago and the City of Miami indicates many
similarities.
At the investigative level, Chicago's O.P.S. and Miami's
I.S. are different in that the Commander and investigators
of I.S. are sworn personnel rather than civilian employees
and I.S. conducts a wider range of investigations. However;
both units report directly to the Police Department's top
administrator.
In both departments the employee may appeal recommended
disciplinary action to an internal department review board
which may make an alternative non -binding recommendation to
the Department head. All disciplinary action taken against
Miami Police Officers (other than a written reprimand) may
be further appealed to the Civil Service Board. In Chicago,
only disciplinary action in excess of five days may be
appealed to the City's Police Board while disciplinary action
of more than thirty days must be approved by the Police
Board.
The Chicago Board is similar to Miami's Civil Service Board,
but as indicated, it has a more limited jurisdiction on
disciplinary matters. However, the Police Board also has
several other functions. These include approving the Police
Department's budget, reviewing departmental policy and
recommending candidates to the Mayor for the position of
Superintendent.
The O.P.S. had a complaint sustained rate of 6.84% for 1978
while the City of Miami Police Department's I.S. had a
sustained rate of 13.72% for the same period.
It is important that certain misconceptions about the Chicago
Police Department's Office of Professional Standards and its
disciplinary system be clarified. The O.P.S. is not a
committee or board but rather a part of the Chicago Police
Department's organizational structure that employs non -sworn
investigators to conduct investigations of allegations of
excessive use of force by police officers. These investi-
gations are conducted in much the same manner as the Miami
Police Department's Internal Security Unit conducts similar
types of investigations. The non -sworn employees working in
O.P.S. are not attorneys. However, the head of O.P.S.,
James Casey, is an attorney and a former Federal prosecutor.
The Chicago Police Department is not unionized and does
not have a procedure where police organizations review
disciplinary action and make recommendations to the
Superintendent. The department does, however, have an
internal department review board to which employees may
appeal disciplinary action prior to review by the Superin-
tendent. This board is similar to the Miami Police Depart-
ment's Disciplinary Review Board (D.D.R.H.). Furthermore,
Chicago does not have a Community Advisory Board that
reviews citizens' complaints and makes recommendations to
the City Administration. The City of Chicago does have a
Police Board that has jurisdiction to hear appeals by
employees of disciplinary action of six days suspension or
more and which must approve all disciplinary action. of
thirty days or more. The Police Board's action is not
advisory but rather final unless overturned by the courts
upon an employee's appeal.
As previously indicated, the Staff of the Miami -Dade Crim-
inal Justice Council conducted an in-depth study of
external review procedures used in other communities. At
its June 4, 1979 meeting the Council referred five external
review models to the County Commission and recommended that
the Commission select from those models the features they
felt most suited for Dade County.
The following is a summary and comparison of the models
that the Council recommended.
OMBUDSMAN
The Ombudsman is an independent governmental official who
receives complaints against government agencies and offi-
cials, who investigates and who makes recommendations to
remedy the complaints. He does not replace or displace
existing remedial machinery, but would supplement and re-
inforce the existing political, administrative and legal
processes of control.
CRIMINAL JUSTICE REVIEW PANEL
This panel will act in an advisory capacity to the County
Manager and the Director of the Public Safety Department,
and to the City Managers or Mayors and Police Chiefs from
Dade's twenty-six municipalities. It will have two (2)
major functions: (1) to review and provide input on
10101111
criminal justicepoliciesand procedures that affect Dade's
citizenry; and (2) to, ensure the integrity of the various
criminal justice internal review systems through an after -
the -fact review of citizen complaints, where the citizen
is dissatisfied with the internal review findings.
GELBER PLAN
The Citizens' Review Board is
group. The goal of the Board
trate the secrecy of internal
the law enforcement sector of
grievance machinery.
an advisory, counseling, referral
is to provide a process to pene-
investigations and to deprive
complete domination over the
Upon receiving a complaint, the Board will direct the staff
to gather all available information, counsel and refer the
complainant to the appropriate agency and assist in obtain-
ing a lawyer where required. If necessary, they will
accompany the individual to the appropriate agency to assist
in the filing of the request for an official investigation.
HARDIN PLAN
This plan creates a board known as The Police -Civilian
Appeals Board. It consists of five members appointed by
the Commission. The duties of the Board are to hear
complaints by citizens who are not satisfied with the
results of the Police Internal Review process. They will
hear complainants and any witnesses the complainants or
any other party may wish to present.
Upon hearing all witnesses and the police position, the
Board will vote yes or no on the question of referring the
case to the Manager's Office for additional review. The
recommendation is not legally binding.
COMMUNITY APPEALS BOARD
The Community Appeals Board investigates, conducts hearings
and makes recommendations to the Chief Administrator of
the appropriate City or County regarding complaints or
grievances made by any person against any employee of the
Public Safety Department or any municipal police department
in Dade County. The Community Appeals Board does not
exercise jurisdiction until the appropriate police depart-
ment has completed its investigation. If the Community
i
Joseph R. Grassie
June 19, 1979
Appeals Board determines that the police department is, not
properly handling the case, then the Board may investigate
prior to the termination of the investigation by that
police department.
The Board has full authority to require testimony under
oath and to subpoena witnesses and to obtain relevant
dnucments.
The Board consists of seven members appointed by the County
Commission for three years:'
OMBUDSMAN
401
CRIMINAL JUSTICE
REVIEW PANEL
CRIMINAL JUSTICE COUNCIL
STAFF
ENDORSEMENTS
AMERICAN BAR ASS 0 TION/
C.J.C. STAFF
COST
Oversees existing complaint
processes to insure proper
consideration of complaint.
Any act or failure ;to act
by any agency,, official 6
public employee (except
courts, .legislative, chief
executive); multi-
jurisdictional:
Subpoena powers, access`
to all public records
and confidential files
relevant to investigation.
Complaint received at
Ombudsman office, then
forwarded to existing
complainant review
mechanism of agency
complained about.
Ombudsman appointed,by;::
executive 6 confirmed
by legislative body;
Ombudsman has freedom to
choose own staff.
At least 5 years; removal
for cause only by
legislative body.
$175,000 per year.
Review 6 provide input on
Criminal Justice policies
6 procedures 6 insures
integrity of the various
Criminal Justice Review
Systems.
Any case where complain-
ant appeals findings of
internal review system
6 other areas of crit-
ical concern to the
community; multi -
jurisdictional.
Created by County
Ordinance -advisory
authority; no
subpoena powers.
County Manager
Receives complainant's
appeal of internal re-
view findings; reviews
adequacy 6 accuracy of
internal review pro-
cedures.
11 specified community
agencies each designate
1 member to panel -
appointment ratified by
County Manager 6 County
Commission. Panel has
5 member staff.
$125,000 per year.
GELBER PLAN
COMM ITY
APPEALOARD
DR. SEYMOUR GELBER
ilieRDIN PLAN
ROBERT A. HARDIN
COMMUNITY
RELATIONS BOARD
Advises, counsels, makes
referral for Complainants,
monitors police', agency's.
investigations,',expresses
public approval or disap-
proval where appropriate,
makes recommendations.
Citizen's complaint(s)_.
against law enforcement
agencies.
Advisory; no subpoena
powers.
Staff responsible to
County Manager - Board
responsible to County
Commission
Receives citizens'
complaints h provides
support assistance
to complainant.
Minimum 5 citizens from
5 specified community
agencies, plus optional
citizens -at -large; 1 or
2 professional staffers
hired by County
Manager.
Board members:
volunteers:
Staff: full-time employed
by County.
Supplements existing
control processes by
producing avenue or appeal
of internal review
finding.
Complaints by citizen(s)
not satisfied with re-
sults of police internal
review process.
Advisory; can recommend
review by City.
Manager of case.
City Commission
Public hearing 6 re-
viewing of facts; all
participants appear
voluntarily.
Each City/County
Commissioner appoints
1 member to Board.
Unpaid volunteers,
staggered terms.
Investigates 6 conducts
hearings, makes recom
mendations regarding,
complaints.
All complaints or
grievances against ``
any employee of: the
PSD or;muni"cipal
department.
Created pursuant to
Dade County Charter;.
full power to sub-
poena & require
testimony under oath.
County Commission,
No jurisdiction until
appropriate police
agency has completed
investigation of com-
plaint --exception is
when CAB determines
police agency is not
properly handling
investigation, then
CAB may proceed to
investigate.
7 members appointed
by County Commissioners;
Board has working
staff.
3 years staggered
terms; unpaid -
volunteers.
1
All of the plans recommended by the Council appear to have
both positive and negative aspects. It is axiomatic that,
for anyform of external review to be successful, it must
be tailored to the community it is to serve. Another pre-
requisite to success is that the model be accepted by those
it will affect.
I recommend that the City Administration be charged with the
responsibility of forming a committee to review all pertinent
material relating to this issue and to report its recommenda-
tions within thirty to sixty days. This committee should have
two primary objectives: First, it should assess the community's
need in this area and should determine if the Department's
internal review function should be supplemented with other
procedures.
Second, if the Committee determines that there is a need for
additional community input in the present system, it should
assess the recommendations made by the Council along with any
other information that may be available, and it should recom-
mend to the City Commission the form of community participation
that will best meet the needs of the citizens of the City of
Miami.
KIH :mm/rch
Wednesday,' June 6
Interview Schedule -
Chicago.Trip
1979
Sergeant Floyd Turner
Commander
Jim Casey
Dennis Nowickie
Joseph Haughey`
Thursday, June 7, 1979.
Robert Howard
Jim Burns
Edmund Brooks
Julius McMillan
Werner Petterson:
Dick Salem
Steve. Sheller
Joseph Gomez
Friday, June 8, 1979
William Geller
Janice Linn
Jim Casey
Joseph Dileonardi
Dick
Brzeezek
Chicago Police Department-
Youth Division
former IAD Investigator
Chicago Police Department
Commander, Youth Division
Chicago Police Department -
OPS Commander
Chicago Police Department -
Legal Advisor
Better Government Association
Chicago Human Relations``
Commission
Department of Justice
Community Relations Service'
Chicago Crime Commission
Chicago Alliance of Business -
former OPS Investigator
Law Enforcement Study Grou
Chicago Police Department -
OPS Commander
Chicago Police Department - Deputy
Superintendent Bureau of Inv. Serv.
Chicago Police Department - Exec.
Assistant to the Superintendent
Dennis Nowickie
Chicago Police Department` -
Youth Division
Chicago Police Department
Division
Commander
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