HomeMy WebLinkAboutExhibitMEMORANDUM OF UNDERSTANDING
BETWEEN
THE FEDERAL BUREAU OF INVESTIGATION
AND
THE BOCA RATON POLICE DEPARTMENT BOMB SQUAD
THE BROWARD COUNTY SHERIFF'S OFFICE BOMB SQUAD
THE FORT LAUDERDALE POLICE DEPARTMENT BOMB SQUAD
THE MARTIN COUNTY SHERIFF'S OFFICE BOMB SQUAD
THE MIAMI POLICE DEPARTMENT BOMB SQUAD
THE MIAMI-DADE POLICE DEPARTMENT BOMB SQUAD
THE MONROE COUNTY SHERIFF'S OFFICE BOMB SQUAD
THE PALM BEACH COUNTY SHERIFF'S OFFICE BOMB SQUAD
THE PALM BEACH POLICE DEPARTMENT BOMB SQUAD
THE SAINT LUCIE COUNTY SHERIFF'S OFFICE BOMB SQUAD
THE WEST PALM BEACH POLICE DEPARTMENT BOMB SQUAD
MULTI -JURISDICTIONAL RESPONSE TO IMPROVISED EXPLOSIVE DEVICES
This Memorandum of Understanding (MOU) is being executed
between the Miami Division of the Federal Bureau of Investigation
(FBI) and the above named agencies.
1. AUTHORITY
Authority for the FBI to enter into this agreement can be
found at 28 U.S.C. § 533; 42 U.S.C. § 3771; and 28 C.F.R. § 0.85.
2. PURPOSE AND MISSION
The purpose of this MOU is to formalize duties,
responsibilities and procedures to be addressed when a public
safety risk from explosive materials, suspected Improvised
Explosive Device(s) (IED) or other Weapon(s) of Mass Destruction
(WMD) is discovered on a terrorist related or other matter that
the FBI has primary jurisdiction, and the threat(s) from such
devices requires assistance from certified bomb squads from
multiple municipalities. This MOU formalizes the manner in which
non -Federal officers certified as bomb technicians through the
FBI Hazardous Devices School (HDS), assigned to one of the nine
bomb squads within the Miami Division, will have deputized
authority while acting under direction and authority of the FBI.
This MOU is not intended, and should not be construed, to
Page 1 of 9
rd(f)4 �, /«
create any right or benefit, substantive or procedural,
enforceable at law or otherwise by any third party against the
parties, the United States, or the officers, employees, agents,
or other associated personnel thereof.
The mission of the collective participating agencies will be
to share available personnel, equipment, resources and expertise
in the Miami Division of the FBI, to conduct Render Safe
Procedures (RSP) on suspected IEDs and explosive disposal, and in
some instances, investigation of explosive related incidents, as
part of the counterterrorism initiative of the Miami Division of
the FBI.
In the event of a major terrorism attack outside of the
Miami Division,_ by request of another FBI division, under
direction of the Miami Division, this MOU also formalizes the
guidelines under which the Federally deputized members of the
Miami Division bomb squads may be called upon to assist outside
of the Miami Division of the FBI on bomb/explosive related
matters in which the FBI has primary
jurisdiction.
This MOU is not an obligation or commitment of funds, nor a
basis for transfer of funds, but rather is a basic statement of
the understanding between the parties hereto of the tasks and
methods for performing the tasks described herein. Unless
otherwise agreed in writing, each party shall bear its own costs
in relation to this MOU. Expenditures by each party will be
subject to its budgetary processes and to the availability of
funds and resources pursuant to applicable laws, regulations, and
policies. The parties expressly acknowledge that the above
language in no way implies that Congress will appropriate funds
for such expenditures.
3. COMPOSITION
The Miami Division of the FBI will designate Special Agent
Bomb Technician(s)(SABT(s)) within the division to act in support
of this MOU with the participating agencies.
Other participating agencies will designate available
qualified bomb technicians as circumstances and personnel
assignments permit, to support this agreement. When the FBI
requests that a participating agency supply personnel to respond
while under the Federal deputation as outlined in this MOU, each
of the participating agencies reserves the right to refuse
response of their personnel, when other duties prohibit the
response of personnel.
Page 2 of 9
4. DEPUTATIONS/CROSS DESIGNATIONS
Non -Federal officers participating under this MOU will be
sworn in as Special Deputy United States Marshals for purposes of
enforcing United States Code, Title 18. This will provide
authority for the officers to fully participate in all
investigations and respond to bomb or explosive related threats
upon request by the Miami Division of the FBI, anywhere within
the United States. The Miami Division of the FBI would only make
a request for personnel from the participating agencies to
respond outside of the Miami Division when a request is made by
another FBI field division.
These deputations are only in effect when the deputized
officers are requested to respond by the Miami Division of the
FBI, on bombing or explosive related matters in which the FBI has
jurisdiction.
These deputations shall remain in effect for two years, as
long as the participants are assigned duties consistent with the
purposes of this MOU, or until the termination of this MOU,
whichever comes first. Active participants must renew
deputations every two years.
5. INVESTIGATIVE REPORTING PROCEDURES
The agency(s) having primary jurisdiction is responsible for
collection, maintenance, and dissemination of reports and other
documents in conjunction with activities of the participants of
this MOU and in compliance with applicable Federal, state and
local laws. This agreement does not prohibit dissemination by
individual participants of information to other Federal, state or
local law enforcement agencies, as allowed by law to ensure
public safety.
With respect to FBI prepared documents, such must be
prepared and maintained in compliance with applicable Federal law
and Department of Justice (DOJ) policy. Consequently, all
records prepared and shared among participating agencies in
accordance with this MOU may not be released or distributed to
third parties, except as noted above, without the express
permission of the originating agency.
6. OVERTIME REIMBURSEMENT
When personnel from a participating agency respond at the
request of the Miami Division of the FBI under the authority of
this MOU, the participating agency will be reimbursed for
Page 3 of 9
overtime, per diem, and lodging incurred by deputized personnel
acting under this MOU. Overtime will be paid by the FBI in
accordance with a separate Cost Reimbursement Agreement.
7. SUPERVISION AND CONTROL
Overall direction of the responding Hazardous Devices School
(HDS) certified technicians with regards to render -safe
procedures shall be the senior HDS certified technician on scene.
Overall direction of the personnel acting under Federal authority
regarding investigations, shall be the FBI SAC.
Responsibility for conduct, not under the direction of the
FBI, of each participant, both personally and professionally,
shall remain with the respective agency head and each agency
shall be responsible for the actions of their respective
employees;
Each participant will be subject to the personnel rules,
regulations, laws, and policies applicable to those of their
respective agencies.
Each participant will continue to report to his or her
respective agency head for matters not detailed in this MOU
8. EVIDENCE
Participants agree to conform to Federal standards
concerning evidence collection, processing, and storage. The FBI
will maintain evidence collected during investigations conducted
under the authority of this MOU.
9. PROSECUTIONS
Joint bombing/explosives related investigations conducted
under this MOU will conform to the requirements for Federal
prosecution, and will generally be prosecuted in Federal courts.
A determination will be made on a case -by -case basis whether the
prosecution of cases arising under this MOU will be at the State
or Federal level. This determination will be based on the
evidence obtained and a consideration of which level of
prosecution would be of the greatest overall benefit to the
objectives of criminal justice and national security.
Page 4 of 9
10. LIABILITY
Unless specifically addressed by the terms of this MOU, the
parties agree to be responsible for the negligent or wrongful
acts or omissions of their respective employees. Legal
representation by the United States is determined by the
Department of Justice (DOJ) on a case -by -case basis. The FBI
cannot guarantee the United States will provide legal
representation to any Federal or state law enforcement officer or
employee.
Congress has provided that the exclusive remedy for the
negligent or wrongful act or omission of an employee of the
United States government, acting within the scope of his/her
employment, shall be an action against the United States under
the Federal Tort Claims Act (FTCA), 28 U.S.C. Section 1346(b),
and Sections 2671 - 2680.
For the .limited purpose of defending claims arising out of
activity under this MOU, state/local officers who have been
specifically deputized and who are acting within the course and
scope of their official duties and assignments pursuant to this
MOU, may be considered an "employee" of the United States
government as defined in 28 U.S.C. Section 2671. See 5 U.S.C.
Section 3374 (c) (2) .
Under the Federal Employees Liability Reform and Tort
Compensation, Act of 1998 (commonly known as the Westfall Act),
28 U.S.C., Section 2679(b)(1), the Attorney General or his/her
designee may certify that an individual defendant acted within
the scope of his employment at the time of the incident giving
rise to the suit. id., 28 U.S.C. Section 2679(d)(2). The United
States can then be substituted for the employee as the sole
defendant with respect to any tort claims. 28 U.S.C. Section
2679(d)(2). If the United States is substituted as defendant,
the individual employee is thereby protected from suits in
his/her official capacity.
If the Attorney General declines to certify that an employee
was acting within the scope of employment, "the employee may at
any time before trial petition the court to find and certify that
the employee was acting within the scope of his office or
employment." 28 U.S.C. Section 2679(d) (3).
Liability for any negligent or willful acts of participating
agency members, undertaken outside the terms of this MOU, will be
the sole responsibility of the respective employee and agency
involved.
Page 5 of 9
Liability for violations of Federal constitutional law rests
with the individual Federal agent or officer pursuant to Bivens
v. Six Unknown Named Agents of the Federal Bureau of Narcotics,
403 U.S. 388 (1971) or pursuant to 42 U.S.C. Section 1983 for
state officers or cross -deputized Federal officers.
Both state and Federal officers enjoy qualified immunity from
suit for constitutional torts, "insofar as their conduct does not
violate clearly established statutory or constitutional rights of
which a reasonable person would have known." Harlow v.
Fitzgerald, 457 U.S. 800 (1982).
Participating agency personnel may request representation by
the U. S. Department of Justice for civil suits against them in
their individual capacities for actions taken within the scope of
employment, if and when civil actions are levied against them,
pursuant to 28 C.F.R. Sections 50.15, 50.16.
An employee may be provided representation "when the actions
for which representation is requested reasonably appear to have
been performed within the scope of the employee's employment and
the Attorney General, or his/her designee, determines that
providing representation would otherwise be in the interest of
the United States." 28 C.F.R. Section 50.15(a).
Deputized personnel's written request for representation
should be directed to the Attorney General and provided to the
Chief Division Counsel (CDC) of the Miami FBI. The CDC will then
forward the representation request to the FBI's office of General
Counsel (OGC) together with a letterhead memorandum concerning
the factual basis for the lawsuit. FBI/OGC will then forward the
request to the Civil Division of DOJ together with an agency
recommendation concerning scope of employment and Department
representation. 28 C.F.R. Section 50.15 (a)(3).
If deputized personnel are found to be liable for a
constitutional tort, he/she may request indemnification from DOJ
to satisfy an adverse judgement rendered against the employee in
his/her individual capacity. 28 C.F.R. Section 50.15 (c)(4).
The criteria for payment are substantially similar to those used
to determine whether a Federal employee is entitled to DOJ
representation under 28 C.F.R. Section 50.15(a).
Determinations concerning legal representation and
indemnification by the United States are discretionary and are
made by the DOJ on a case -by -case basis. The FBI cannot guarantee
that the United States will provide legal representation, legal
defense, or indemnification to any federal or state employee
Page 6 of 9
detailed to any of the participating agency members, and nothing
in this Article shall be deemed to create any legal right on the
part of any participating agency member.
11. TRAINING
An additional goal of this agreement will be to facilitate
co -training ventures among participants to ensure continuity of
responses to incidents involving threats to public safety.
Participants of this agreement will meet routinely, as
mutually agreed, to discuss and establish training activities and
venues, as well as other mutual concerns.
12. MEDIA
All media releases and statements related to activities
under the purview of this MOU will be mutually agreed upon and
jointly handled according to FBI and participating agency
guidelines.
13. DURATION
The term of this MOU is for five years, renewable upon
written agreement by the participating agencies. Any
participating agency may withdraw from the MOU at any time by
providing written notification to the Miami FBI at least 30 days
prior to withdrawal.
14. MODIFICATIONS
This agreement may be modified at any time by written
consent of all involved agencies. Modifications of this MOU
shall have no force and effect unless such modifications are
reduced to writing and signed by an authorized representative of
each participating agency.
15. SETTLEMENT OF DISPUTES
Disagreements between the participants arising. under or
relating to this MOU will be resolved only by consultation
between the participants and will not be referred to a court of
law or to any other person or entity for settlement. The final
authority to resolve any disputes will be the SAC of the Miami
FBI.
Page 7 of 9
FBI/ Contracting CY ficer
16. CONCLUSION
Nothing in this MOU is intended to create additional
liabilities on the part of any participating agency, nor does
this MOU change or modify other formal or informal agreements
with any of the participating agencies.
Signed and agreed to by:
im�\1V ) . WOY'
athan I. Solomon
Special Agent in Charge, FBI Miami
ti 1 1/Z />a.'
Maury V. Taylor
Contracting Offfooi
ftiorel BtueMM O
Daniel Alexander
Chief of Police, Boca Ratdn Police Department
Al Lamberti
Sheriff, Broward County Sheriff's Office
Bruce G. Roberts
Chief of Police, Fort Lauderdale Police Department
Robert L. Crowder
Sheriff, Martin County Sheriff's Office
Page 8 of 9
John Timoney
Chief of Police, Miami Police Department
Robert Parker
Director, Miami -Dade Police Department
Richard D. Roth
Sheriff, Monroe County Sheriff's Office
Ric L. Bradshaw
Sheriff, Palm Beach County Sheriff's Office
Michael S. Reiter
Chief of Police, Palm Beach Police Department
Ken J. Mascara
Sheriff, St. Lucie County Sheriff's Office
Allan Orthman
Captain, West Palm Beach Police Department
Page 9 of 9
CITY OF MIAMI, a municipal
Corporation of the State of Florida
ATTEST:
PRISCILLA THOMPSON PEDRO G. HERNANDEZ
CITY CLERK CITY MANAGER
APPROVED AS TO INSURANCE APPROVED AS TO FORM AND
REQUIREMENTS: CORRECTNESS:
LEEANN BREHM JULIE O. BRU
RISK MANAGEMENT CITY ATTORNEY