ACLU Connecticut - Earning Trust, 2017
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EARNING TRUST Addressing police misconduct complaints in Connecticut Earning Trust Addressing police misconduct complaints in Connecticut A report of the American Civil Liberties Union of Connecticut Credits The research for this report was conducted by Lillian McKenzie and Rachel Spears under the guidance and supervision of David McGuire and Meghan Smith. The report was compiled, edited, and written by Meghan Smith and David McGuire, with assistance from Dan Barrett. Melvin Medina assisted in the development of the survey tool. American Civil Liberties Union of Connecticut 765 Asylum Avenue Hartford, CT 06105 860.523.9146 email@example.com www.acluct.org EARNING TRUST Addressing police misconduct complaints in Connecticut I. Executive Summary .......................................................................... 1 II. Executive Findings .......................................................................... 3 III. Background...................................................................................... 4 IV. Methodology.................................................................................. 6 V. Detailed Findings Complaint Form Availability................................................................. 7 Complaint Form Protocols .................................................................. 9 Anonymous Complaints ..................................................................... 11 Complaint Policy Transparency ............................................................12 Reaching Departments ....................................................................... 14 Connecticut State Police ..................................................................... 15 VI. Analysis POSTC Complaint Form ....................................................................... 16 POSTC Complaint Policy ....................................................................... 18 VII. Recommendations .............................................................................. 19 Appendix A: Survey Instrument ............................................................... 1A Appendix B: Police Agency Responses ................................................... 1B Appendix C: POSTC Complaint Policy and Form .................................. 1C Appendix D: Connecticut Police Complaint Law .................................. 1D EXECUTIVE SUMMARY All communities deserve police who protect and respect all people. Police deserve to work with and for colleagues who are competent, worthy enforcers of the law and stewards of public resources. Both of these complimentary goals demand strong protocols for meaningfully accepting and addressing complaints alleging police misconduct. Good police complaint protocols ensure public accessibility, prevent intimidation of potential complainants, and facilitate meaningful investigations of misconduct allegations. According to the expertise of civil rights activists, academics, policy experts, community members, and law enforcement agencies,1 best practices for police complaint policies include: accepting all complaints, including those submitted anonymously, online, by mail, or by telephone; making complaint forms and policies easily accessible to the public; and removing barriers to complaint submissions, such as threats of retaliation against complainants or notarization requirements for complainants' statements. Connecticut state law requires all police agencies in the state, including municipal departments, state police troops, and special agencies such as university departments, to adopt or exceed a model complaint policy created by the Police Officer Standards and Training Council (POSTC). In addition, state law requires all police agencies to make their complaint policies publicly available on their websites and at municipal buildings separate from the departments themselves. Meanwhile, POSTC's model policy requires all police employees to accept all complaints, including those submitted anonymously, online, by mail, or by telephone; and prohibits retaliation against complainants and questions about complainants’ immigration statuses during intake. POSTC's policy also created a statewide model complaint form, which POSTC required departments to adopt or exceed and to make available online and at municipal buildings separate from departments themselves. These requirements are not simply suggestions for police agencies to take or leave. They are critically important for building community trust in police, and they carry the weight of the law. During community forums hosted by the ACLU-CT throughout the state, however, we heard from members of the public who described a chilling disregard for these rules among some police agencies. These Connecticut residents expressed concerns regarding notarization requirements, in-person and in-station filing requirements, and lack of access to complaint forms outside of police stations. Seeking to determine whether these frustrations were isolated incidents or indicators of more widespread noncompliance with state law and policy, the American Civil Liberties Union of Connecticut conducted a survey of police agencies throughout the state. Our findings are a troubling confirmation of community members’ concerns. 1. See: The President's Task Force on 21st Century Policing, "Policy and Oversight, Submitted Oral & Written Testimony Received by January 31, 2015," https://cops.usdoj.gov/pdf/taskforce/01-30-2015/Invited_Testimony_January_30.pdf. See Also: The International Association of Chiefs of Police, “Testimony of the International Association of Chiefs of Police, Task Force on 21st Century Policing Listening Session on Police Oversight,” January 30, 2015, http://www.theiacp.org/Portals/0/documents/pdfs/IACPTestimonyListeningSessionPolicyandOversight.pdf. 1 EARNING TRUST Despite reforms, many Connecticut police agencies still make it difficult for members of the public to easily obtain basic, legally required information regarding complaint forms and processes. In some cases, this lack of transparency violates state law, and it could prevent law enforcement agencies from becoming the fair and just entities that communities and police deserve. The problems that we discovered were widespread, and they were not unique to one type of department. The police agencies that exhibited troubling complaint practices serve large and small towns throughout the state. They include state police troops, municipal departments, and special agencies, and they include departments with large and small workforces. Among our findings: • Forty of Connecticut’s law enforcement agencies have not clearly posted either or both their department complaint form or complaint policy online, in direct contravention of state requirements. • Unless pressed further, 43 percent of all agencies surveyed by phone claim that complaint forms are only available at police stations—a violation of state policy. • Many Connecticut police agencies continue to impose barriers to accepting police complaints, such as refusing to accept or actively discouraging anonymous complaints, requiring complainants to submit forms only at police stations, and mandating notarization of complaint forms. • Forty two percent of all agencies surveyed by phone suggested that they are not complying with state law requiring public access to complaint policies. • Many Connecticut police agency representatives surveyed by phone could not answer questions, could not be reached to answer questions, refused to answer questions, provided inaccurate information, or contradicted information posted on departments’ websites. • Sections of POSTC’s model policy and complaint form may exacerbate confusion and undermine the complaint acceptance process in Connecticut. These findings reveal a clear need for additional legislative action, both to make permanent the improvements that Connecticut has made and address areas that continue to hinder police transparency and accountability. The Connecticut General Assembly should adopt legislation that: Establishes meaningful penalties for law enforcement agencies that do not comply with state complaint acceptance and investigation laws; Improves POSTC's existing model complaint policy and adopts that revised version as state law; Creates a standardized complaint form that is compliant with best practices and translated into all commonly-spoken languages in Connecticut, to be used by all law enforcement agencies in the state; Mandates complaint protocol training for all law enforcement agency personnel who interact with the public. Requires law enforcement agencies to track complaint data and to annually report specific complaint information to the Connecticut Office of Policy and Management; Establishing a transparent, accessible police complaint process is just the first step toward creating a truly fair, just, and wise police force in Connecticut—one that lives up to the standards that the public demands and that police departments should expect of themselves. With the right policies and laws in place, Connecticut can create this system. 2 EARNING TRUST EXECUTIVE FINDINGS Connecticut law requires all police agencies to post their complaint policies online. Statewide police policy requires all agencies to post complaint forms online and to accept anonymous complaints. But, as of October 2016, this is what 102 police agencies had clearly posted on their websites: Information on Police Agency Websites 40 1 million departments had not clearly posted either or both their complaint form or policy online--a direct violation of state law and policy people living in towns where police departments are not complying with state complaint law or policy The ACLU-CT called 60 police agencies to learn more. Of those 60 agencies: Violations of state law and policy: 43% claimed that complaint forms were only available at police stations 42% suggested that they do not make complaint policies fully available to the public 32% stated or implied that they will not accept anonymous complaints "Where could a complainant find [your complaint] policy?" Police departments are violating state law and policy. In the process, they are undermining public trust in police. The Connecticut General Assembly should solve these problems by: 1 Establishing penalties for police agencies that do not comply with state complaint law 2 Creating a standardized complaint form to be used by all law enforcement agencies in the state 3 3 EARNING TRUST Requiring all law enforcement agencies to track & annually report complaint data BACKGROUND In 2012, the American Civil Liberties Union of Connecticut (ACLU-CT) conducted a statewide survey of police agency procedures for accepting community complaints of police misconduct. That survey discovered widespread resistance and inconsistencies in police agencies’ approaches to accepting complaints, as well as a chasm between Connecticut law enforcement agencies’ protocols and national best practices. Prompted in part by that report, in 2014, the Connecticut General Assembly passed a new law, Public Act No. 14-166, “An Act Concerning Complaints that Allege Misconduct by Law Enforcement Agency Personnel” (Connecticut General Statutes § 7-294bb), to improve the police complaint process. That law, which passed both legislative chambers with broad bipartisan support and without a single opposing vote in the Senate, tasked Connecticut’s Police Officer Standards and Training Council (POSTC) with creating a model complaint policy. It also instructed POSTC to consider creating a model complaint form. Although the law established specific issues for the statewide policy to address, the legislature deferred to POSTC’s judgment regarding how to approach these considerations. The law did, however, require all law enforcement agencies in the state to either adopt or exceed POSTC’s ultimate policy, and to make their policies publicly available online and at a municipal building other than the police department itself. In 2015, POSTC released its guidance. Among other requirements, POSTC's policy mandated departments to: adopt or exceed POSTC's model complaint form; post complaint forms and complaint policies online “where the agency, or the municipality served by the agency, has a website;” and to accept all complaints, including those submitted anonymously or by a third party. POSTC's policy also required all employees to assist people wishing to file complaints, and required all agencies to assign each complaint a tracking number. Echoing state law, POSTC also required departments to adopt or exceed its policy. In a memo dated May 15, 2015, Police Academy Administrator Thomas E. Flaherty notified all of Connecticut’s chief law enforcement officers, training officers, protective services, and resident troopers of POSTC’s new policy and the underlying state law. Copies of the state police complaint law and POSTC's model policy are available in Appendices C and D of this report, respectively. 4 EARNING TRUST Complaint Form Provides space for complainant to describe misconduct allegations Used by public to spur investigations Used by police to investigate complaints and address personnel issues State law required POSTC to consider creating a model form POSTC created model form POSTC policy requires police agencies to adopt or exceed model form POSTC policy states police agencies should make forms available online & at municipal building separate from police department Complaint Policy Outlines police agency protocols for accepting, processing, and investigating complaints Used by police to train personnel Used by public to understand how to file complaints & what to expect during complaint investigations State law required POSTC to create model policy State law required police agencies to adopt or exceed POSTC model policy State law required all departments to make policies available online & at municipal building separate from police department What is POSTC? Connecticut’s Police Officer Standards and Training Council (POSTC) is a seventeen member advisory panel of the Department of Emergency Services and Public Protection. Its mission includes training Connecticut’s police officers, adopting and enforcing professional standards for police officers, and developing and assessing standards for local law enforcement agencies. By design, the majority of POSTC representatives are either current or former members of law enforcement, or individuals like prosecutors or FBI officials, who depend on local law enforcement in order to carry out their work. Members are not elected to their positions but are appointed by the Governor. These reforms were meant to better serve community members and police alike. As the International Association of 1 Police has stated, “a police department must monitor Chiefs of its officer[s’] mistakes and misconduct to protect its interests and reputation.”1Indeed, the state and individual complaint policies were largely created by police; POSTC’s members are mostly law enforcement officials, and Public Act No. 14-166 required each law enforcement agency to adopt or exceed POSTC’s policy after consultation with police union officials. These laws and policies can only affect change, however, when they are implemented and enforced. Understanding this, the ACLU-CT sought to examine how law enforcement agencies have approached new police complaint requirements. To do so, in October 2016, the ACLU-CT conducted a survey of Connecticut police departments. We focused our survey, as we did in 2012, on the crucial first steps in the police complaint process: accepting complaints from civilians. Only after making complaint information easily available and instituting clear policies for accepting complaints can police departments evaluate and address any deficiencies in how they address those complaints. 1. The International Association of Chiefs of Police, “Building Trust Between the Police and the Citizens They Serve ,” http://www.theiacp.org/portals/0/pdfs/buildingtrust.pdf 5 EARNING TRUST METHODOLOGY As a first step, the ACLU-CT visited the Connecticut state police website, as well as the websites of all Connecticut law enforcement agencies required to report traffic stop data under the Alvin W. Penn Racial Profiling Prohibition Act. Surveyors then assessed which sites included clearly posted, easily available complaint policies and/or complaint forms, as required by state law and POSTC policy, respectively. These criteria excluded some agencies in small towns that are supervised by resident state troopers and local officers, as well as some specialized agencies. That screening process showed that 40 percent of these agencies were not complying with state law or POSTC’s posting requirements: 16 departments had clearly posted a complaint form, but not a complaint policy; three had clearly posted a policy but no form; and 21 had clearly posted neither the form nor the policy. One agency website yielded an ongoing error message, and its municipal website included neither a clearly posted form nor policy. The majority of agencies that failed to clearly post either or both the complaint form and policy were in southwestern Connecticut—11 were in New Haven County, and 12 were in Fairfield County. In addition, most municipal departments that failed to clearly post either or both the form or policy serve towns with mid-to-large populations. Based upon the Connecticut Department of Public Health’s 2015 population estimates, 26 departments that failed to clearly post either or both the form or policy serve towns that are among the 75 largest cities in Connecticut. Combined, the municipal departments that failed to clearly post either or both their complaint policies or forms serve a population of nearly one million people (953,837), and the non-compliant universities together serve more than 10,000 students (10,982). The Metropolitan Transportation Authority, meanwhile, states on its website that it serves a population of more than 14 million people. Following this initial screening process, we selected agencies for in depth telephone interviews. The goal of this survey was to examine police agencies’ compliance with state law and policy regarding police complaints. We therefore turned our attention to the 40 police agencies that were missing one or both the complaint form and policy, as well as the agency that had neither a functional website nor a municipal page containing that information. Due to the size and scope of the jurisdictions they serve, we also included the state’s twelve police troops and the municipal departments of the state’s ten most populous cities, provided they were not already slated for follow-up. While these criteria limited the scope of our survey, we believed that this mixture of compliant and non-compliant departments would provide a representative sample of law enforcement agencies for the purposes of our research. Ultimately, these criteria narrowed the pool of agencies for telephone surveys to 60: 45 municipal police departments, two universities, the Metropolitan Transportation Authority, and 12 state police trooper barracks. To complete these telephone surveys, two trained ACLU-CT volunteers, who varied in age and ethnic background, called all 60 agencies’ non-emergency numbers. Volunteers called on two consecutive days in October 2016, during the normal business hours of 9 a.m. through 5 p.m. Callers began by informing the agency representatives that their calls were for a research project, and that they were not seeking to file a complaint. They proceeded by asking eight questions from a script (the survey instrument is available in Appendix A). In order to double-check the initial screening process, that script included an opportunity for agencies to help callers find complaint forms and policies online. Following each call, volunteers noted the call length, number of holds and transfers, whether the call required navigation through automated messages or voicemails, and the general demeanor of agency representatives. The ACLU-CT’s survey and this subsequent report were not meant to entrap law enforcement agencies, nor was our survey meant to be scientific or comprehensive in its examination of the police complaint process. Rather, our goal was to better understand the current status of the initial steps in the police complaint process in Connecticut, in light of changes to state law. A detailed summary of findings for each survey question follows. A chart outlining survey responses is available in Appendix B. 6 EARNING TRUST COMPLAINT FORM AVAILABILITY Unless pressed further, 43 percent of all agencies surveyed claimed that complaint forms were only available at police stations. POSTC’s complaint policy requires all police agencies to either adopt or improve upon its model form and to make their complaint forms available in a municipal building separate from the police department. The policy also states that agencies “should” place these forms on their websites. Survey question: Is there a form to fill out? Volunteers therefore began their scripts by asking if agencies had complaint forms. Nearly two-thirds of agencies surveyed (65 percent, or 39 agencies total) stated that they did. Two agency representatives stated “I believe so,” one said “probably,” one said “come in [to the station],” and one did not know. Southington responded that there was not a form and that someone would need to come in to the station; Weston stated that there was not a form and that someone would need to either come in or call the station; Thomaston answered that there was not a form and that someone would need to submit a complaint by writing. Survey question: Where can someone filing a complaint find the form? Would they have to come into the police station, or is there somewhere else they can pick it up? The survey next asked where someone could find the agency's police complaint form. In direct violation of POSTC requirements, 43 percent of agencies surveyed (26 total) responded only that it was available at the station/barracks. Two agencies with clearly posted online forms responded only that the complaint form was available online. Two other agencies said that a form was available at the station or over the phone; three replied that it was available at the station or by mail; one answered that it was available at the station and “maybe the town hall.” Survey question: Is the form available online? Volunteers then asked agencies if the forms were available online. This direct question offered agencies a second opportunity to clarify whether they were compliant with POSTC policy. It is unclear, however, whether a typical caller would ask about complaint form availability with this level of specificity, or if callers would instead have more general inquiries about where to find complaint forms. In response to this direct question, less than one third of agencies (17 total) stated that the form was available online. Meanwhile, in violation of POSTC’s policy, thirty percent of agencies surveyed indicated that their forms were either not yet or not at all available online (Ansonia, Bridgeport, Clinton, Metropolitan Transportation Authority, New Britain, Norwalk, Norwich, Plymouth, Seymour, Southington, Suffield, Thomaston, Weston, Windsor, and Wolcott). Of these, Thomaston and Weston had indicated earlier that they did not have a form at all. 7 EARNING TRUST Troublingly, seven departments that stated that they did not have forms available online (Bridgeport, Clinton, New Britain, Norwalk, Norwich, Plymouth, and Putnam) did in fact have forms available on their websites. Similarly, volunteers were unable to locate Orange’s complaint form online, despite the agency’s assertion that the form was available there. These discrepancies suggest that representatives were either uncertain of complaint protocols or attempting to mislead callers. Regardless of the root causes, each disparity between a department's website and its representative's response raises serious concerns about whether potential complainants would also receive misinformation, which could lead to complainants becoming confused or discouraged. Ten department representatives did not know the answer to this question. Included in these ten is Middletown, where a representative initially responded, “I don’t think so. I don’t look at our website,” but later went online with the caller to find the form on the agency’s page. A representative for Western Connecticut State University, which did have a form available online, responded: “I don't know. I should know this." 8 EARNING TRUST 20 15 10 5 on ly In -s ta tio n "P re fe r" st at io n St at io n op tio na l More than one in ten agencies surveyed require complaint forms to be notarized. Nearly one in four requires complainants to submit complaints at police stations. Un su re 0 De pe nd s COMPLAINT FORM PROTOCOLS Does a complainant have to come into the station to submit a complaint form? On the issue of notarization, the POSTC policy sends mixed signals. While the policy does not use the word “notarization,” it does say that departments “may” place complainants “under oath,” and that complainants may be “requested to sign the complaint after reading or having it read to them [sic] the warning for perjury or false statement.” If a complainant does not sign under oath, POSTC says, departments may “note” the refusal on the complaint. In keeping with this policy, POSTC’s standardized complaint form includes space for a notarized signature, next to language warning complainants that they may be arrested if their statements prove false. As the U.S. Department of Justice has explained, however, notarization requirements, particularly when paired with threats of prosecution, can have a chilling effect on the public's willingness and ability to file police complaints. Survey question: Does a citizen complaint need to be notarized to be accepted? We therefore asked agencies if a complaint form needed to be notarized in order for the agency to accept it. Troublingly, eight departments (Ansonia, Eastern Connecticut State University, Plainville, Plymouth, Seymore, Thomaston, Trumbull, and Windsor) stated outright that they require notarization. One third of agencies surveyed (20 total) said no, but their clarifications at times suggested otherwise. Middletown, for instance, encouragingly said that it did not require notarization, but disappointingly said that complainants would need to "swear to it [a complaint]" and "then we sign." Similarly, Redding and Clinton indicated that they did not require notarization, but that complainants would need to deliver a sworn statement to be "signed in front of an officer" (Redding) or that they took the signatures of the complainant and department employee receiving the complaint (Clinton). Groton stated that notarization was required "sometimes at some departments." The agency's representative went on to say that he did not believe the department required notarization, but that a complainant "must sign that it's the truth." Guilford said that it did not require notarization, but that a complaint would be "more credible" if notarized. It therefore appears as if some departments that technically do not mandate notarization may still impose onerous signature requirements on complainants. 9 EARNING TRUST Notarization Is: Verification by a Notary Public that someone's signature is genuine, a document is real, and that the signatory acted without duress or intimidation A known obstacle for people wishing to file police complaints Is Not: Proof that a statement is true Necessary in police complaint intake Other agencies did not provide a clear "yes" or "no" response when asked about notarization, but strongly suggested that they required it. Bridgeport, for instance, responded that a "sergeant signs off" on complaints. Norwich asserted: "get [the form], fill it out, and we will sign." Three [New Canaan, Stamford, and] asserted that it "depends." Stamford noted that "depending on severity, you have to sign a written statement." Survey question: Does a complainant have to come into the station to submit the form? Volunteers next asked if complaints must be filed at the department’s station. Encouragingly, fourteen agencies stated that someone did not need to submit a complaint at the station, although one (Weston) later indicated that the agency “like[s] to handle [complaints] in person.” In violation of the statewide model policy, however, more departments (28 percent, or 17 total) stated either that complainants must submit forms at the station (Ansonia, Bridgeport, Clinton, New Britain, New Canaan, Norwalk, Norwich, Seymour, Southington, Stamford, Suffield, Thomaston, Trumbull, Willimantic, and Windsor) or that they “would prefer” in-station complaints (Eastern Connecticut State University and Plainville). Eastern Connecticut State University’s representative elaborated that the agency “would like them to, because we don’t want a false complaint. [Complainants] must swear it’s the truth.” Norwich stated: “You have to come in and get it. You have to turn it in to a supervisor anyway.” Norwalk reiterated that it did not use complaint forms by stating that someone would need to come in to the station, as “we don’t give out forms.” Similarly, Southington required complainants to come in to the station, as it did not have forms. "We don't give out [complaint] forms." - Norwalk Police Department "The use of a standardized form to record complaints shall be implemented..." - Police Officer Standards and Training Council, Mandatory Uniform Policy "I don't try to tell people to go online and file complaints against me." - Bristol Police Department "All employees will assist those who express a desire to lodge complaints against any member of the agency. This includes ... providing complaint form(s) and/or complaint filing information and/or giving instructions as to where the complaint forms may be obtained." - Police Officer Standards and Training Council, Mandatory Uniform Policy Two agencies (Bristol and Guilford) were unsure whether they required in-station complaints. Bristol’s uncertainty, however, seemed to indicate uncooperativeness, as the agency representative stated: “I don’t try to tell people to go online and file complaints against me.” The Connecticut State Police centralized public information officer responded that the state police do “not always” require complainants to submit complaints in-barracks. Survey question: (If no in-station filing requirement) Is there another way? Could they mail or email it? Of the departments that did not require in-station submissions, only one (Western Connecticut State University) indicated that someone could file a complaint via any avenue (as it stated, a complainant could use “anything you want” to file, including mail and email). Seven departments (Groton Long Point, Guilford, Orange, Plainville, Putnam, Thomaston, and Wolcott) said that someone could submit a complaint by mail, and two (the Metropolitan Transportation Authority and Stamford) said that someone could submit by phone. Redding stated that someone could submit by mail or phone; three departments (Hartford, Middletown, and Plymouth) stated that someone could submit via mail or email; and three (Danielsonbased Troop D, North Haven, and Weston), stated that someone could submit online, although Weston, as discussed earlier, stated that it would prefer to handle complaints in-person. "You have to come in and get it." - Norwich Police Department "The complaint policy and forms should be made available online." - Police Officer Standards and Training Council, Mandatory Uniform Policy 10 EARNING TRUST ANONYMOUS COMPLAINTS In violation of state policy, at least 14 agencies will not accept anonymous complaints. Additional agencies surveyed may accept, but not honor, anonymous complaints. "What's the point, you know?" - Bridgeport Police Department "Then it's not a complaint." - Norwich Police Department "At some point, it's not taken with much heart." - Bristol Police Department In keeping with national law enforcement best practices, Connecticut’s state model policy requires departments to accept anonymous complaints of police misconduct. Survey question: Could someone fill out the form anonymously? Seventeen agencies surveyed said that someone could anonymously file a complaint and did not suggest otherwise. Nearly one quarter of all agencies surveyed (14 total), however, either directly or indirectly contravened state policy requiring acceptance of anonymous complaints. Nine stated outright that they would not accept anonymous complaints (Bethel, Bridgeport, Clinton, New Britain, New Haven, Norwalk, Norwich, Thomaston, and Willimantic). For example, Norwich replied, “No, then it’s not a complaint.” Bridgeport responded, “No, what’s the point, you know?” Five agencies surveyed suggested that anonymous complaints would not be taken seriously or as seriously as other complaints (Bristol, Groton Long Point, Orange, Plymouth, and Western Connecticut State University). Bristol, for instance, stated that someone could submit anonymously, “but at some point it’s not taken with much heart.” Groton Long Point stated that it would accept anonymous complaints, but that an anonymous complaint “lacks substance.” Plymouth’s representative answered that there was “nothing to follow up on” with an anonymous complaint, then stated: “I've never filled one out or looked at one, so I don't know." Orange said that it would accept anonymous complaints, but that they would have a “different weight.” Stamford responded that “it depends.” The same department requested our volunteer’s full name and responded “that’s it?” when she provided her first, casting doubt as to whether complainants’ anonymity would be respected. On the issue of accepting anonymous complaints, Connecticut’s state policy is unequivocal: police departments must accept all complaints, anonymous or otherwise. Departmental uncertainty or blatant disregard for this requirement is therefore cause for alarm. It is also particularly concerning that even large departments with clearly posted forms and policies online, such as Norwalk and New Haven, suggested that they will not accept anonymous complaints. "Anonymous and third party complaints will be accepted." -Police Officer Standards and Training Council, Mandatory Uniform Policy 11 EARNING TRUST COMPLAINT POLICY TRANSPARENCY Where could a complainant find [your complaint] policy? Ask supervisor 5% Not Public 12% Forty two percent of surveyed agencies' responses contravened state law requiring public, online access to complaint policies. Upon Request 5% In-station 5% Don't know 12% FOI 13% No Response 38% "Can't reveal" 2% Online 8% State law stipulates, and POSTC’s policy reiterates, that police agencies must post complaint policies on their websites, or on the corresponding municipal website if a department does not have its own. In addition, state law and POSTC’s policy require departments to make their complaint policies available at municipal buildings other than those housing police stations. These complaint policies, which are supposed to outline agencies' protocols for accepting and investigating complaints, are separate from the forms used to file complaints. Volunteers therefore asked each department if it had a written policy regarding complaints, and where to find those policies. Survey question: Do you have a written policy about citizen complaints and the complaint investigation process? In response to the survey question regarding whether the department had a written complaint policy, 45 percent of agencies surveyed (27 total) asserted that they had written policies. In addition, Suffield and Thomaston were unsure but stated that they believed there was a policy, and New Haven’s representative was unaware of a policy but stated that the department had procedures. Six departments did not know if they had policies. Survey question: Where could a complainant find that policy? Agencies’ responses were more troubling, however, when asked about public access to complaint policies. State law is unequivocal: each agency must post its complaint policy on its website or on a municipal website, in addition in addition to making the policy available at a municipal building other than the police department. Out of all agencies surveyed, only six mentioned online access: Middletown, New Canaan (which was “pretty sure” it was online), North Haven, Woodbridge, the centralized state police public information officer, and Groton Long Point (whose representative was unsure if the policy was online yet, but said that a member of the public “could be provided with a copy no problem”). Groton Long Point’s representative was correct—its policy was not available online. Neither, however, were North Haven or Woodbridge’s policies, despite their assertions to the contrary. Forty two percent of all agencies surveyed (25 departments total) responded in ways that contravene state law. Three departments (Seymour, West Haven, and Winchester-Winsted) indicated only that their policies were available upon request. Five (Plymouth, Putnam, Clinton, Hartford, and Trumbull) stated that a member of the public would need to go into the station or ask a manager for a copy. Later, Hartford’s 12 EARNING TRUST representative stated that “a lot of policies are not” online, then directed the caller to a brochure on the department’s website. While directing the caller, the Hartford representative noted that the department was required to file a yearly report regarding complaints, due to a settlement in a civil rights lawsuit. Danielson-based Troop D stated that the policy was at the barracks, but the agency representative was unsure whether it was public information. Bethany-based Troop I stated that it could “not reveal that information,” but that the caller could call central barracks. New Haven's representative, who earlier stated that he did not believe the department had a complaint policy, asserted that he did not believe the policy was online. The department policy, however, was online. Of the 25 agencies that responded in ways that contravened state law, fourteen (23 percent of all agencies surveyed) indicated that their policies were either completely unavailable to the public or available through a freedom of information (FOI) request. Six agency representatives asserted that their department complaint policies were completely inaccessible for members of the public: Ansonia, Bridgeport, Bristol, the Metropolitan Transportation Authority, Orange, and Stamford. Stamford’s website, however, does include its policy. There was also a disturbing trend of departments citing FOI laws when asked about access to complaint policies. Eight departments (Eastern Connecticut State University, Guilford, Norwich, Plainville, Suffield, Western Connecticut State University, Windsor, and Wolcott) mentioned FOI requests when asked about access to complaint policies. As Wolcott stated, “it’s internal,” and therefore “available [via] freedom of information.” Or, as Guilford stated, in a response that demonstrates a complete misunderstanding of the complaint process and a disturbing attitude toward members of the public, the department’s policy is available via FOI request because, “It’s not all public. We don’t want the bad guys to know how we operate.” Few everyday members of the public are aware of FOI laws, let alone able or willing to navigate the FOI request process. An available-by-FOI-only policy violates state law and creates unnecessary impediments to transparency. "It's not all public. We don't want the bad guys to know how we operate." - Guilford Police Department "Each law enforcement agency shall make its policy available to the public and shall ensure that: A) Copies of the policy are available at the town hall or another municipal building...other than a municipal building in which the law enforcement agency is located, and B) the policy is available on the law enforcement agency's Internet web site or the Internet web site of the municipality served by the law enforcement agency." - Connecticut General Statutes § 7-294bb 13 EARNING TRUST REACHING DEPARTMENTS HOLD TIMES, TRANSFERS, AND AUTOMATED SYSTEMS Only two agencies include “filing a complaint” as an option in their automated answering systems. In an effort to gain a clear understanding of the initial police complaint process, during telephone surveys, volunteers recorded the time that it took to reach an agency representative, as well as the length of each phone call. Lengthy wait times or complicated telephone systems—or, on the other end of the spectrum, abrupt hang-ups or dropped calls—can create barriers to filing complaints. In the cases of 36 agencies, volunteers were able to reach a person immediately (in five seconds or less) or in one minute one second or less. Volunteers were able to reach 14 agencies’ representatives within two minutes. Outliers included: Hartford, where it took the caller eight minutes and 50 seconds to reach a person; Middlebury, where a volunteer was unable to reach a person for three minutes; Stamford, where it took four minutes to reach a person; and Danbury, where it took five minutes and 43 seconds for the caller to reach a person. Slightly more than half (32) of the law enforcement agencies surveyed used automated systems, which volunteers navigated in order to complete their calls. Only two agencies’ automated systems (Middlebury and Willimantic) included filing a complaint as an option for callers. Twenty-seven agencies placed volunteers on hold at least once, with most hold times lasting less than two minutes. Outliers in this area included: Plainville and Stamford, which kept volunteers on hold for three minutes each; Suffield, which placed the caller on hold for three minutes and 30 seconds; and Guilford, which placed the caller on hold once for one minute and a second time for three minutes. Hartford placed the caller on hold twice, once for three minutes and 33 seconds, and once for four minutes and 31 seconds. Similarly, Danbury placed volunteers on hold four times: twice during the initial call, and twice during the follow-up call, with waits ranging from nine seconds to one minute and 25 seconds. Trumbull utilized its hold system more than any other department, as it placed volunteers on hold six times, with waits ranging from 41 seconds to one minute and 37 seconds. Thirteen agencies transferred calls straight to voicemail boxes, which required follow-up calls. Nine of these (Monroe, Naugatuck, New Milford, Newtown, North Branford, Ridgefield, Rocky Hill, Waterbury, Waterford) also forwarded the follow-up caller to voicemail. AGENCIES FROM WHICH CALLERS COULD NOT OR DID NOT GATHER INFORMATION Callers were unable to reach 12 agencies. As in our 2012 report, some law enforcement agencies were unable to provide volunteers with answers, directed the volunteers to voicemail boxes, ended the call abruptly or rushed the volunteer off of the phone, or hung up. At times, this resulted in callers being able to gather partial, but not complete, survey responses from certain departments. In other instances, callers were unable to reach a person at all. In each of these situations, volunteers attempted to reach the agency a second time. 14 EARNING TRUST Agencies reached by phone after first or second attempt: Ultimately, there were 12 agencies from which we could not collect telephone survey data, because our callers were unable to obtain Unreachable 20% answers during either of their attempts to gather information: Brookfield, Danbury, Middlebury, Monroe, Naugatuck, New Milford, Newtown, Ridgefield, Rocky Hill, Waterbury, Waterford, and West Haven. This is the second time that Monroe proved inaccessible, as ACLU-CT surveyors were also unable to gather information from the department in 2012. The absence of information from these agencies is itself cause for alarm, as it suggests that concerned residents would be similarly frustrated in attempts to learn how to file complaints. Indeed, there is anecdotal Reached evidence from Waterbury to support this assessment. During public 80% forums, the ACLU-CT heard from Waterbury residents who had encountered difficulty navigating the department’s complaint process. During our first call to Waterbury, our volunteer was transferred to the front desk, which transferred her elsewhere, upon which she was disconnected. She called the community relations department, which told her to call internal affairs to speak with a sergeant. She called the sergeant and encountered his voicemail. In our second attempt to contact Waterbury, our volunteer called the front desk, which transferred her to the voicemail of a lieutenant in the internal affairs department. She attempted to call him a second time and again only reached his voicemail. As discussed in the methodology section of this report, our telephone survey was limited to 60 law enforcement agencies, which we selected in order to create a representative sample of police practices throughout the state. We selected some of these agencies, such as state police departments and large municipal departments, solely based on the sizes of their populations served, as their websites showed that they had clearly posted both their complaint forms and policies online, in accordance with state law and policy. Even some of these agencies, however, contravened state law in their telephone survey responses. This raises serious questions about practices at other agencies that are complying with website posting requirements but were not selected for telephone survey calls. Future studies would likely benefit from including these agencies, in order to gain a broader understanding of police complaint practices throughout the state. 15 EARNING TRUST CONNECTICUT STATE POLICE State police showed signs of improvement, but lack consistency in responses to questions about the complaint process. We have included state police responses throughout the detailed findings of this report. Due to the scope of the state police system in Connecticut, however, it is worth describing some key findings regarding state police as a group. When surveyed by the ACLU-CT in 2012, state police were particularly hostile and uncooperative. In this area, state police showed signs of improvement. As in 2012, however, callers encountered inconsistencies and contradictions between state police troops’ survey answers. Encouragingly, the vast majority of state police troops directed callers to dial the centralized state police public information officer at some point during the telephone survey. Two, however (Bethany-based Troop I and Danielson-based Troop D), did not. In addition, the points at which state police troops redirected callers varied. Furthermore, some state police representatives responded to survey questions with answers reflecting state law and POSTC’s model policy, but there was not uniformity between barracks on this point. For example, Montville-based Troop E told the surveyor that a complainant would need to travel to the police barracks in order to file a complaint, while all other troops either instructed the caller to dial the centralized public information officer or stated that there was a complaint form available. 15 EARNING TRUST POSTC COMPLAINT FORM "Some disincentives to reporting complaints are inherent within complaint forms themselves." -International Chiefs of Police Association The POSTC “uniform civilian complaint report” form is not compliant with best practices and may undermine the complaint process in Connecticut. As the purpose of this report was to gain insight regarding the initial steps of the police complaint process in Connecticut, the ACLU-CT also analyzed POSTC’s uniform “civilian complaint report,” the form that the council created to complement its complaint policy. In addition to simply accessing information regarding how to file a complaint, these forms are often one of the first entry points to the complaint process. What we discovered was disturbing. POSTC’s model complaint form may sow confusion among police and members of the public alike, and it includes sections that may impede acceptance or reception of complaints. Our assessment reveals three key ways in which POSTC’s model form does not adopt best practices: 1 • The form includes sections for complainants to provide their names, contact information, and dates of birth. In a requirement with dubious utility for investigating complaints but a clear risk of intimidating complainants, the form also includes space for complainants to provide their employers’ names, addresses, and contact information. It does not indicate that complainants are allowed to anonymously file complaints, and it does not clearly state that contact information is optional. POSTC’s own model policy, appropriately and in keeping with national best practice, requires all law enforcement agencies to accept all complaints, including those made anonymously. A form that omits this critical fact therefore seems to contradict POSTC's own policy. • The form includes space for a complainants’ signature, paired with a threat of prosecution. This section asks for complainants’ signatures, in order to attest that: “I understand that making a false statement intended to mislead a law enforcement officer in his official function is a violation of Connecticut General Statute 53a-157b and could result in my arrest and being fined and/or imprisoned.” There are two problems with this language. First, a signature is, by definition, a record of a person’s name, yet POSTC’s own policy allows complainants to file anonymously. The complaint form’s signature section does not note that the signature is optional, and therefore seems to contradict POSTC’s own anonymity rules. Second, mentions of prison and fines can intimidate complainants and discourage complaints, and they are not in keeping with law enforcement experts’ best practices. As the U.S. Department of Justice has stated, threats of prosecution are “a well-known deterrent to filing a complaint.” 2 1. For best practice recommendations, see: The International Association of Chiefs of Police, “Testimony of the International Association of Chiefs of Police, Task Force on 21st Century Policing Listening Session on Police Oversight,” January 30, 2015, http://www.theiacp.org/Portals/0/documents/pdfs/IACPTestimonyListeningSessionPolicyandOversight.pdf. 2. U.S. Department of Justice Civil Rights Division, “Investigation of the East Haven Police Department,” December 19, 2011, https://www.justice.gov/sites/default/files/crt/legacy/2011/12/19/easthaven_findletter_12-19-11.pdf. 16 EARNING TRUST • Third, the form includes a section for a notary’s signature. Similarly to threats of prosecution, this notary signature requirement is a recognized impediment to police complaint filings. As the International Chiefs of Police Association has noted, notarization requirements, particularly when combined with threats of prosecution, frequently appear in “inadequate” police complaint processes: “Some disincentives to reporting complaints are inherent within complaint forms themselves. For instance, language on complaint forms sometimes stipulates that a civilian complaint will not be accepted unless notarized. When followed by language stating that knowingly making false, untrue, or malicious complaints will be subject to 3 criminal prosecution, some would-be complainants may be intimidated.” POSTC’s form should not replicate these inadequacies. 3. See supra note 1, The International Association of Chiefs of Police, “Testimony of the International Association of Chiefs of Police, Task Force on 21st Century Policing Listening Session on Police Oversight.” 17 EARNING TRUST POSTC COMPLAINT POLICY The POSTC model complaint policy includes language that may subvert the complaint process in Connecticut. POSTC’s model complaint policy incorporates many national recommendations for receiving and accepting complaints. Its language regarding accepting all complaints in all formats, barring retaliation against undocumented immigrant complainants, and requiring police departments to make complaint forms and policies accessible to the public, for instance, are all acceptable. Our assessment, however, reveals two key areas in which POSTC's model complaint policy falls short: • POSTC’s policy only requires “supervisory personnel” to attend “periodic refresher training, as determined by the department” regarding complaint protocols. This top-down approach ignores the fact that all employees who interact with the public should be prepared to accept complaints. It also is not working. As demonstrated by survey responses, some agency employees are clearly confused or uncertain about complaint protocols. A training policy that leads one agency representative to say, “I don’t know. I should know this,” is clearly a policy that shortchanges both department personnel and members of the public alike. Every law enforcement agency in the state should therefore ensure that every employee who interacts with the public receives annual training regarding accepting and handling police complaints. • As outlined earlier in this report, POSTC’s policy includes language that allows departments to require complainants to sign written statements under oath and after threats of arrest or imprisonment. As discussed in the complaint form section of this report, threats of prosecution and notarization and signature requirements are known deterrents to complaint filings. Connecticut’s complaint policy should therefore explicitly ban, not allow, these practices. 18 EARNING TRUST RECOMMENDATIONS The Connecticut General Assembly took the right step by passing legislation to establish the minimum requirements for accepting and receiving police complaints in Connecticut. Our survey, however, reveals that some police departments have not taken that mandate seriously, and that the state still has significant work to do. To address these concerns, the Connecticut General Assembly should do five things: 1. Establish meaningful penalties for police agencies that do not comply with state complaint laws. Police agencies' widespread lack of compliance with existing complaint law and policy only underscores that police cannot consistently police themselves in this area. In order to spur and maintain compliance, the state legislature should ensure enforcement. If a department fails to substantially comply with complaint laws, the state should levy a penalty, in the form of the withholding of state funds from the police department or the Department of Emergency Services and Public Protection. This practice has precedent in state law; the Alvin W. Penn Racial Profiling Prohibition Act adopted the same enforcement mechanism for police agencies’ reporting of traffic stop data, and it has proven effective. 2. Establish an improved statewide, uniform complaint policy as state law. Police agencies have policy guidance to create meaningful mechanisms for accepting and receiving complaints. Yet as this survey shows, many have failed to do so. To illuminate legislative intent, create uniformity among agencies, and ensure that there is no wrong door for anyone wishing to file a complaint, the Connecticut General Assembly should adopt a statewide complaint policy, based on POSTC’s current model but revised to eliminate problematic language, into legislation. 3. Require law enforcement agencies to track and publicly report complaint data. It should not take an ACLU survey to uncover police complaint information. Transparency regarding complaints can help departments and the public to identify and address issues, and it can build community trust in police. At minimum, police agencies in the state should therefore report the following information to the Office of Policy and Management each year: tracking numbers for every complaint received, the nature of the alleged misconduct that prompted each complaint, the outcomes of each complaint investigation, the dates when each complaint was filed, and the dates when each complaint investigation was resolved. As the International Association of Chiefs of Police has noted, “many agencies have become more open and transparent in their efforts to share data with the public,” including data regarding “their receiving, processing, and disposing of citizen-generated complaints.”1There is precedent for this type of data sharing in Connecticut; both the Alvin W. Penn Racial Profiling Prohibition Act and a 2014 state law governing police use of Tasers require law enforcement agencies to submit reports to the state Office of Policy and Management. This reporting, as the International Association of Chiefs of Police has explained, can improve “community trust and can help initiate and inform joint problem-solving strategies.” 2 1. International Association of Chiefs of Police, "Protecting Civil Rights: A Leadership Guide for State, Local, and Tribal Law Enforcement," September 2006, http://www.iacp.org/portals/0/pdfs/PCR_LdrshpGde_Part1.pdf 2. Supra note 1, International Association of Chiefs of Police, "Protecting Civil Rights: A Leadership Guide for State, Local, and Tribal Law Enforcement." 19 EARNING TRUST 4. Replace the existing complaint form, created by POSTC, with a standardized form that is compliant with best practices. In 2014, the legislature tasked POSTC, an unelected and majority law enforcement council, with creating the statewide model complaint policy and form. This extreme deference should not happen again. POSTC’s policy and form include problematic language that could subvert the complaint process. In addition, police agencies are not uniformly complying even with POSTC’s requirements. Establishing a meaningful police complaint process therefore requires the strength of legislative action. Just like any other publicly funded agency, police departments should expect oversight from the government, and the legislature should be up to the task. To address disparities in how police departments accept and receive complaints and to facilitate reporting by departments, the legislature should create a uniform complaint form for all departments to adopt. This will create a level playing field among all police departments in the state, as well as ensure that there is no wrong door for any person seeking to file a complaint. To fix existing language that could intimidate and deter potential complainants, this new form should: make clear that anonymous complaints are accepted and that all complainant contact information and names are voluntary; eliminate requests for complainants’ employers’ contact information; remove all references to notarization; eradicate signature requirements; and do away with references to prosecution. The legislature should further require these forms to be available at a centralized online location, as well as on all police agency websites and at municipal buildings separate from police departments themselves. While POSTC’s model form is available in English and Spanish, the ultimate statewide complaint form should be posted in these and the other most commonly-spoken languages in Connecticut, in accordance with U.S. Census data. 5. Mandate complaint protocol training for all police agency personnel who interact with the public. According to POSTC's model policy, all police agency personnel, including non-uniformed civilian employees, must accept complaints. At the same time, however, POSTC’s policy only requires “supervisory personnel” to attend “periodic refresher training, as determined by the department” regarding complaint protocols. This top-down approach to training ignores the fact that “all agency personnel,” not just supervisors, should be able to competently accept complaints. It also is not working. As demonstrated by many agency responses, some law enforcement employees are clearly confused and uncertain about complaint protocols. To address this problem, every police agency in the state should therefore ensure that every employee receives annual training regarding accepting and handling complaints. 20 EARNING TRUST APPENDIX A Police Complaint Telephone Survey ACLU-CT Survey: Police Accountability and Internal Affairs Practices Overview Goals: The ACLU-CT is conducting a series of tests to determine how well police departments comply with Public Act No. 14-166. Our goals are to assess (1) how easy it is for an average citizen to get information about filing a complaint against a police officer, (2) how well employees of the police departments who interact with the public know their own procedures about filing police complaints, (3) how police complaints can be filed, and (4) what kind 1. Erect meaningful penalties for police agencies that do not comply with state complaint laws. of restrictions exist on who can file a police complaint, and (5) the availability of police complaint forms and policies. General Caller Instructions: Callers will be calling police departments across the state of Connecticut to ask specific questions regarding the departments’ Internal Affairs policies. Callers will be calling to inquire about the procedure for filing a complaint against a police officer. It is extremely important that callers do not suggest that an actual incident occurred or provide any fictional details about an alleged incident. Providing false information to the police could result in charges for false reporting. Callers must follow the script (below) as closely as possible and record their answers in the spaces below. Calls must be made from the ACLU-CT office during office hours (9:00 am – 5:00 pm). To reiterate, it is not our intent to trick or entrap police departments or officers. We are trying to determine what information is provided to an individual inquiring about the internal affairs complaint process. Call Instructions: 1. Please look over the script and familiarize yourself with the questions you will be asking. 2. Dial *67 in front of the police department’s number in order remain anonymous. 3. Remember, you are requesting information about how to file a complaint against a police officer. 4. You have absolutely no information about the incident or even whether an incident occurred. You only want to know about the process of filing a complaint. If they won’t give you any information without details of the incident, note this. 5. If asked, you do not feel comfortable giving any information including your name. If the officer pressures you, ask why they want your name and record his/her answer. 6. Please stick to the script! Only ask the exact questions in the script. Never change the wording. If the officer cannot answer a question please ask if there is someone you can speak with that can help you. 7. Please do not ask leading questions. You should only repeat the exact questions and should not initiate other questions. Feel free to repeat questions as many times as you feel you need, but you are not trying to entrap the officer. Our goal is to simply understand what information the average person would receive when asking about making a complaint. 8. Please be specific when documenting answers on the attached form. Please do not wait to fill out the form until after you have completed the call. 9. You MUST complete the entire form (or if questions could not be answered, please note this and why). Be sure to include the information about the department and the length of your call. Also, please keep track of the process of getting the correct person on the line to answer your questions. 10. If after three questions it becomes clear that the person who answered the phone cannot answer the questions, request to speak with a community relations officer. 1A EARNING TRUST APPENDIX A Department Information Department Name: Telephone Number: _*67 ____________________________________________ Date/Time of phone call **WHEN CALLING, REMEMBER TO DIAL *67 BEFORE DIALING** 1. Erect meaningful penalties for police agencies that do not comply with state complaint laws. Script/Questions Before speaking with someone: How long did it take to reach someone who could help you? ______ Did you have to navigate an automated system to reach someone?________ Did the automated system have an option for filing a complaint?__________ Were you put on hold?_____ How many times?____ How long?_____ How many times were you transferred? _____________ Were you ever sent to voicemail? _______________ Once someone is on the phone: Hi, I am calling because I am doing a research project and am trying to get information about how to file a complaint against a police officer. I don’t know anything about this sort of thing, so I was hoping you could help me. 1. Is there a form to fill out? 2. Where can someone filing a complaint find the form? Would they have to come into the police station or is there somewhere else they can pick it up? 3. Is the form available online? a. (If yes) Okay, I’m on your website now, can you help me find it? **If at this point, it becomes clear that the officer who answered the phone cannot answer these questions, ask to speak with a community relations officer or someone from Internal Affairs. 4. Does a citizen complaint need to be notarized to be accepted? 2A EARNING TRUST APPENDIX A 5. Does a complainant have to come into the station to submit the form? a. (If no) Is there another way? Could they mail or email it? 6. Could someone fill out the form anonymously? 7. Do you have a written policy about citizen complaints and the complaint investigation process? 8. Where could a complainant find that policy? meaningful penalties forit?police a.1. IsErect it online? Can you help me find agencies that do not comply with state complaint laws. After the call, evaluate the officer's demeanor: _____Friendly & helpful _____Reserved yet helpful _____Defensive & mildly hostile _____Hostile & uncooperative _____N/A or couldn’t evaluate 3A EARNING TRUST APPENDIX B 1. Erect meaningful penalties for police agencies that do not comply with state complaint laws. 1B EARNING TRUST APPENDIX B 1. Erect meaningful penalties for police agencies that do not comply with state complaint laws. 2B EARNING TRUST APPENDIX B 1. Erect meaningful penalties for police agencies that do not comply with state complaint laws. 3B EARNING TRUST APPENDIX B 1. Erect meaningful penalties for police agencies that do not comply with state complaint laws. 4B EARNING TRUST APPENDIX B 1. Erect meaningful penalties for police agencies that do not comply with state complaint laws. 5B EARNING TRUST APPENDIX C 1. Erect meaningful penalties for police agencies that do not comply with state complaint laws. 1C EARNING TRUST APPENDIX C 1. Erect meaningful penalties for police agencies that do not comply with state complaint laws. 2C EARNING TRUST APPENDIX C 1. Erect meaningful penalties for police agencies that do not comply with state complaint laws. 3C EARNING TRUST APPENDIX C 1. Erect meaningful penalties for police agencies that do not comply with state complaint laws. 4C EARNING TRUST APPENDIX C 1. Erect meaningful penalties for police agencies that do not comply with state complaint laws. 5C EARNING TRUST APPENDIX C 1. Erect meaningful penalties for police agencies that do not comply with state complaint laws. 6C EARNING TRUST APPENDIX C 1. Erect meaningful penalties for police agencies that do not comply with state complaint laws. 7C EARNING TRUST APPENDIX C 1. Erect meaningful penalties for police agencies that do not comply with state complaint laws. 8C EARNING TRUST APPENDIX C 1. Erect meaningful penalties for police agencies that do not comply with state complaint laws. 9C EARNING TRUST APPENDIX C 1. Erect meaningful penalties for police agencies that do not comply with state complaint laws. 10C EARNING TRUST APPENDIX C 1. Erect meaningful penalties for police agencies that do not comply with state complaint laws. 11C EARNING TRUST APPENDIX C 1. Erect meaningful penalties for police agencies that do not comply with state complaint laws. 12C EARNING TRUST APPENDIX C 1. Erect meaningful penalties for police agencies that do not comply with state complaint laws. 13C EARNING TRUST APPENDIX C 1. Erect meaningful penalties for police agencies that do not comply with state complaint laws. 14C EARNING TRUST APPENDIX D 1. Erect meaningful penalties for police agencies that do not comply with state complaint laws. 1D EARNING TRUST APPENDIX D 1. Erect meaningful penalties for police agencies that do not comply with state complaint laws. 2D EARNING TRUST