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DecemOOr4. 201 2

The Honorable Board of Supervfsors
Cou nty of Los Angeles
383 Kennelh Hahn Hall of Admin istration
los Angeles, California 90012
Dear Supervisors:
30-DAY STATUS OF RECOMMENDATIONS MADE BY
THE CITIZENS' COMMISSION ON JAIL VIOLENCE
On October 16, 2012 , the Board requested Ihe Los Angeles County Sheriffs Department
(Department) report back on the status of recommendations made by the Citizens'
Commission on Jail Violence (CCJV), Attached is an update on each recommendation from
Ihe October 15, 201 2, response.
Should you have any questions or require additional infonnation, please contact me or
ASSistant Sheriff Ceci l W. Rhambo, Jr., at (323) 526-5065.

:J! ,7 radziion

0/ 0erV1cf'

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

oWorce' Poley Tn

10115/12 Response:
The Departmem has started the process of restructuring the Use of Force Policy, and
consolidating all Use of Force Policies into a single document
The policy is in its final stages of being incorporated, and has met the scrutiny and approval
of the Office of Independent Review (OIR), Sp&Clal Counsel Merrick Bobb, and force
experts. The new Use of Force Policy will take effect January I , 2013, in order to allow a
reasonable period to train an Department personnel. standardize reporting and investigation
forms. arid set up precise data coding for analysis and early waming.

Update 12104112:
The new Use of Force PoHcy has been finalized and is currently being consoUdated with all
other force policies into a single document entilled: "Force Manual." A training bulletin and
video will be distributed Department wide to assist unit commanders with bnef.ng and
training all personnel regarding the policy changes. The process is scheduled to be
completed by December 31, 2012.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10/15/12 Response:
Currently, the Department requires all personnel to sign that they have read and understand
tile Department's Policy and Ethics Chapters of its Manual of Policy and Procedures. The
Department has prepared a signed admonition form to additionally ensure all personnel
acknowledge in writing that they have read and understand the Department's Use of Force
Policy. This process will be completed by December 31 , 2012.
Update 12104112:
The new Use of Force Policy has been finalized, and is currently being consorKiated with all
other force policies Into a single document entitled: "Force Manual." A training bulletin and
video will be distributed to assist unit commanders with briefing and training all pelSonne1
regarding the policy changes. Unit commanders will ensure all personnel have read and
signed the admonition for acknowledging they have read and understand the policy. The
process is scheduled to be completed by December 31 , 2012.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Response:
The Department is preparing an easy 10 unde~tand tra ining bulletin, to be followed-up with
training conducted by unij training sergeants to ensure all personnel understand how the
Use of Force Policy applies specifICally in Custody, as well as throughout the entire
Department.
Update 12104f12:
The training buUetin and video are being finaHzed, and wi" be distributed to assist unit
commanders with briefing and training all personnel regarding the poHcy changes. The
process is scheduled to be completed by December 31 , 2012.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115/12 Response:
The Department Ilas incorporated the principles contained in tile Force Prevention Policy,
into tile restructured Use of Force Policy. TIlis policy will take effect Jtmullry 1, 201 3.
Additional policies specifically prollibiting inmate retaliation and harassment have also been
incorporated into tile Custody Division Manual.
Update 12104112:
This recommendation wi. be completed upon implementation of the new Use of Force
Policy, effective January 1, 2013.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Response:
While the current Use of Force Policy is based on the ' objectively reasonable" standard. the
Department inserted specifIC language from the Supreme Court c\ecision of Graham v.
Connor, 490 U.S. 386 (1989), into its restructured Use of Force policy (affective January 1.
2013). The S~ualional Use of Force Options Chart is a visual representation of our policies
and training. and also based on Graham v Connor. This visual representation assists our
personnel in understanding what their ' objectively reasonable" fon:e options are. It is used
in conjunction with written policies, verbal training, and dynamic practical application training
scenarios.
Update 12104112:
SpecifIC language from the Supreme Court Decision of Graham v. Connor, 490 U.S. 386
(t989) was inserted into the new Use of Force Policy.
The Department will continue to work with the Implementation Monitor al'ld law enforcement
experts to determine the l'Iecess~y for the Situational Use of Force Options Chart.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

-

, end

10115112 Response:
TIle Department hElli im!erted specific IIIn9uIIge into the restructured Use of Force pobcy to
articulate a strong preference for planned , supeNised. and directed force . More
specifically. the new Preamble to the Department's Use of Force Policy states:

Department members shollid endeavor to de-6sca/ate confrontations fflrough tactical
commllnicatfon. wamings, and other common sense methods preventing tha need to use
force whenever reasonably possible. VV1len force is required. evel}' effort shall be made to
plan. supervise, and dirfJCt fofCfJ in an effort to control confrontations in a calm and
professional manner.
Update 12104112:
This recommelldation will be completed upon implementation of the new Use of fo rce
Policy. effective Janual)' 1, 2013.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Response:
The Department consulted the Department of Justice to ensure compliance with
Department of Mental Health standards. In March 2012, the Department of Justice reported
full compliance by tile Department in its inspection report TIle Department will work witll
mental health experts to develop specific policies, supervision, and training for Ilandling
inmates wiIt1 special needs. Those policies will be implemented concurrent witllthe new
Use of Force Policy (effective January 1, 2013).
Update 12104112:
Please see attached Custody Division Manual policies 5-03/115.00 and 5-041020.00
submitted with this update for policies regarding specia l needs inmates. The policies
regardiog special haodliog for pregnant inmates are a direct reflection of California Penal
Code Sections 6030{f), and 5007.7.

5-03/115.00 PREGNANT INMATES

Upon arrival at a custody housing facility, female inmates shall be screened by medical
personnel and, if requested, provided a pregnancy examination. Inmates who are
deemed by medical staff to be pregnant shall receive the following considerations:
A balanced, nutritious diet approved by a doctor,
Prenatal and postpartum information and healthcare, including, but not
limited to, access to necessary vitamins as recommended by a doctor,
Information pertaining to childbirth education and infant care,
A dental cleaning
Restraining Pregnant Inmates

When security demands require the restraint of a pregnant inmate, while either in a
custody facility or during transportation, the inmate shall be restrained in the least
restrictive manner possible. The method of restraint shall be consistent with the
legitimate security needs of each inmate, as determined by the inmate's criminal history
and propensity for violence or escape.
Labor and Childbirth

Pursuant to California Penal Code Section 6030(f), "... at no time shall a woman who is
in labor be shackled by the wrists, ankles, or both including during transport to a
hospital, during delivery, and while in recovery after giving birth, except as provided in
[Penal Code] Section 5007.7."
In accordance with Penal Code Section 5007.7, an inmate may not be shackled after
they are declared to be in active labor, " ... unless deemed necessary for the safety and
security of the inmate, the staff, and the public."
If security demands dictate that an inmate be shackled while she is in labor, special
consideration shall be made to secure the inmate in the least restrictive manner,
consistent with the legitimate security needs of the inmate, and in a way which will not
interfere with the birthing process or endanger the safety of the inmate or the baby.
As soon as practically possible, the facility watch commander shall be notified about an
inmate who has been shackled while in labor. The details of the incident, including the
reason for restraint, shall be documented in the facility log book.

5-041020.00 JAIL MENTAL EVALUATION TEAM (JMET)
Four Custody Division Jail Mental Evaluation Teams (JMET) address the needs of
mentally ill inmates within the custody of the Los Angeles County Sheriffs Department.
The primary responsibility of the JMET teams is to identify mentally ill inmates who may
be in need of attention to address their special needs.
All inmates in the general population shall have access to Mental Health Services.
Custodial personnel or Medical Services may request evaluations. During routine
working hours access to Mental Health Services will be provided by Jail Mental
Evaluation Team (JMET) members.
Each team consists of one deputy and one mental health clinician. Two North teams
are assigned to, and responsible for, every facility within the Pitchess Detention Center
and are available Monday through Saturday. Two South teams are responsible for the
Century Regional Detention Facility, Twin Towers Correctional Facility, and Men's
Central Jail and are available Monday through Friday. All teams are available during
day-shift hours.
Command and Control
JMET is based at the Twin Towers Correctional Facility (TTCF), and works under the
command of the TTCF Captain. Members report to the TTCF Mental Health Liaison
Lieutenant.
Telephonic notification and written statements of significant incidents; e.g. use of force,
injury to JMET staff members, shall be made and submitted to the TTCF Mental Health
Liaison Lieutenant (or his designee) .
Crisis Situations
During their normal working hours JMET shall be available to watch commanders to
respond to crisis situations and/or tactical situations. Watch commanders may
consider the use of JMET in situations including, but not limited to:
Barricade situations,
Suicidal ideation,
Exhibition of bizarre behavior,
Hunger strike,
Threatening others.
In these circumstances, JMET may act as consultants, or may be used to communicate
with the inmate in an effort to defuse a situation.

JMET Referrals
When a staff member from an affected facility encounters an inmate whom they feel
may need the attention of a mental health clinician, the appropriate Jail Mental
Evaluation Team shall be notified. Each facility shall designate a central point where
staff members can log referrals to the JMET. Members of the JMET shall review the
referral log and interview the inmates in question to assess their mental health needs.
In no way does this preclude any deputy from taking emergent action if they perceive
that an inmate needs immediate attention.
In some cases, JMET may determine the inmate is not suitable to remain in a general
population setting. In such cases, a Behavioral Observation and Mental Health
Referral form shall be completed and arrangements made to transfer the inmate to the
Inmate Reception Center (IRC) for a more intensive medical health evaluation, and
placement in an appropriate level of mental health housing. These may include:
TTCF, Tower I (male inmates),
TTCF, Tower II (female inmates),
TTCF, Medical Services Building (MSB) Forensic In-Patient Program (FIP).
Transportation of an inmate to TTCF mental health housing shall be provided by the
facility from which the inmate is being transported. JMET members may accompany
the transporting facility deputy if it is apparent that the presence of JMET will reduce the
risk of violent or self-injurious behavior on the part of the inmate.
Staff members may refer an inmate to JMET who may not be in need of mental health
housing. In those situations, JMET will determine if further mental health intervention
is needed.
Medical Services
JMET referrals are brought to the originating facility's clinic for evaluation prior to
transfer. JMET referrals shall be prioritized by Medical Services personnel. These
inmates shall be medically cleared to determine if they are appropriate for transfer to
mental health housing at TTCF. JMET shall recommend the appropriate housing
location at TTCF based on their initial assessment of the inmate. The watch
commander, in conjunction with Medical Services personnel, shall make the final
determination for immediate or routine transportation of the inmate. Alternate
transportation shall be arranged if the inmate's condition decompensates and warrants
any urgency as determined by JMET.

NOTE:

It is the intent of this policy that all inmates referred by JMET receive a
medical evaluation prior to their transport to TTCF, however, no inmate
should be unduly delayed in this process. If the watch commander of the
originating facility determines that a medical evaluation will cause an
unnecessary delay in the movement of the inmate, then the watch
commander may authorize the immediate transport of the inmate to the
IRC main clinic, where a medical evaluation shall occur. The name of the
watch commander making this authorization shall be noted on the
Behavioral Observation and Mental Health Referral (BOMHR) form
(SH-J-407).

The medical section of the original Behavioral Observation and Mental Health Referral
(BOMHR) form shall be completed and identified as a JMET referral. The words
"JMET Referral" shall be stamped or handwritten across the top in red ink with the
recommended housing location clearly visible in the upper right hand corner.
The following documents shall be given to the escorting deputy in a sealed envelope
with the name of the facility, the inmate's name, booking number, and the name of the
handling medical staff printed legibly on the outside of the envelope:
Original Behavioral Observation and Mental Health Referral (BOMHR) form,
Medical chart and/or relevant medical documents,
JRC.
Medical Services shall notify the following by facsimile of the Behavioral Observation
and Mental Health Referral (BOMHR) form, to ensure appropriate housing and handling
of the inmate:
Jail Mental Health Services,
IRe Medical Services Clinic.
Facsimile copies of the BOMHR forms sent to the IRC Clinic shall be collected by that
shift's supervising nurse who shall retain them pending the inmate's arrival. The
supervising nurse shall also take delivery of the medical chart when it arrives, and
ensure that the chart is delivered to Health Information Management Services for
appropriate disposition.
Transporting Deputy
The transporting facility deputy shall ensure that the appropriate paperwork
accompanies the inmate to IRC. Upon arrival at IRC, the inmate and paperwork shall
be delivered to the IRC Clinic.

Confidentiality
Custody Division Jail Mental Evaluation Team personnel shall maintain the
confidentiality of all JMET referrals pursuant to Welfare and Institutions Code, Article 7,
section 5328, "Legal and Civil Rights of Persons Involuntarily Detained." Additionally,
all JMET members shall have a signed Oath of Confidentiality on file at Twin Towers
Correctional Facility. This oath mandates that an inmate's mental health history as
well as current information obtained from a JMET contact is considered confidential.

STATUS OF RECOMMENDATIONS REGARDING THE JAil SYSTEM

10115/12 Response:
The Department is currently working with technicians to develop a single, reliable, and
comprehensive dala lracking syslem 10 replace the Personnel Performance Index (PPI) and
Facilities Aulomated Statistical Tracking (FAST) systems.

Update 12104112:
The Department plans 10 upgrade the current PPllo a complelely upgraded system which
wiU provide a comprehensive single solution for tracting aU aspects of Department
personnel performance regardless of assignment. II is estimated the PPI project will cost
approximately $3 million and take approximately 24-36 months for full implementation:
however, funding has not been identified. The new system would provide the functionality
to meet all of the CCJV reconvnendations related to tracking personnel performance.

TIle function of PPI differs from that of FAST. Operations Information Management (OIM),
and Custody Automated Reporting and Tracking System (CARTS). PPI was made solely to
compile and report statistics regarding the performance of Department personnel. FAST,
OIM, and CARTS provide some of those same statistics: however, their main function is to
allow Custody managers to manage events and their workflow. Because personnel
statistics are considered sensitive information, the security of PPI is a great deal more
robust than thaI olthe other systems. Additionalty, edit capabilities are restricted to a small
number of authorized users to ensure the sanctity of personnel information remains intact
and reliable. Based on this reliabil~y, PPI should be the only source of data regarding
personnel performance for reporting purposes. In order to safeguard personnel information
to help ensure ~s continued reliability, ~ is recommended the tracking of workflow, (e.g.
FAST, OIM, CARTS) be kepi separate from that of tracking personnel statistics (PPI).
The Department's plans to upgrade PPI. and its aSSOciated costs, have been fOJwarded to
the County's Chief Information Officer (CIO), and he has preliminarily concurred with the
upgrade proposal. Additionally, the Infonnation Systems Advisory Board (ISAB) has also
been consulted .

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Response:
The Oepartment's long-term plan is to create a new module In the updated Personnel
Performance Index (PPI) dalab<t~ . In order 10 comply irnrrH;(lilllely, 1119 Departmenl is
currently tracking inmate grievances by the names of Department personnel, in the
Facilities Automated Statistical Tracking (FAST) database.

Update 12104/12:
See recommendation 3.8 for status updates on PPI.

STATUS OF RECOMMENDATIONS REGARDING TtIE JAIL SYSTEM

1CV15f12 Ruponse:
The Department has established a process to track and review inmate grievances to identify
potential patterns of conduct by personnel. Special Counsel Menick Bobb urged the
Department to analyze inmate grievances in order to ensure potential problems were
identified. The practice has been incorporated into the regular dutfes of each jail Captain in
order to ensure oversight and early warning to potential problems. Unit commanders are
required to review all staff members' Personnel Performance Index (PPI) and FacUities
Automated Statistical Track~ (FAST) entries to identify possible trends in performance.
This process win also be reviewed by the Custody Division Chief, 6md during Sheriffs
Critical Issues Forums (SCIF).
Update 12104112:
The Department currently has a policy in place to address inmate grievances, which
includes complaints against staff and use offoree incidents. The attached Custody Division
Manual, section 5-12/000.00, mandates that complaints be trac\(ed by a reference number.
Any complaints of allegations of misconduct are forwarded to the unit commander for
investigation and disposition. The attached Custody Division Directive 12-003 states that
personnel identified in an inmate complaint against staff shall be ~sted in the disposition
section of the form, after a supervisor has completed their investigation. Inmate complaints
against staff are accessible in FAST by deputy and inmate names, as weH as reference
number and complaint category.

All inmates confined within the Los Ange les County Jail system have a right to file a
complaint or submit a request for service. No member of the Department shall
discourage, hinder or prohibtt any inmate frOlTl filing a complaint For the purpose of
this policy, the tanns "grievance" and ' complaint" are synonymous.
Responsibilities
It sha~ be the responsibility of all Hne personnel to ensure that Inmate
ReQuestiComplaint Forms (SH-J-420) and medical envelopes are readily available to
all inmates. The supervising line deputy shall check each housing location a minimum
of once per shift to ensure that the forms and medical envelopes are readily available.
The checking and restocking of forms and medical envelopes shall be noted in the
narrative section of the electronic-Uniform Daily Activity Log (a-UDAL). Sergeants
shall note the number of forms retrieved from the romplaint boxes in the designated
section of the e-UDAL.
AI a minimum of once per shift, a sargeant shall remove the forms from the complaint
boxes. review them, confirm Ihe date submitted, ensure the inmate has taken the pink
copy, and that only one issue is addressed per fOITr,. The sergeant shall sort the
forms by category. Basic recuests (defined below) shall be assigned by the sergeant
to a staff member to handle promptly.
All other requests and alt complaints (service, personnel, and Americans with
Disabilities Act (ADA)) shall be assigned a reference number by the sergeant.

The sergeant shail deliver all other requests and service complaints to the watch
sergeant for assignmenUhandling. The sergeant shall immediately deliver personnel
complaints and ADA complaints to the watch commander for review and appropriate
action. The sergeant shaU immediately delive', in person , any sealed medical and
mental health requests and medical related complaints to a medical sergeant.
Emergency Complaints
An inmate may request that a complaint be handled on an emergency basis. An
emergency is defined as an immediate risk of death or injury to the inmate.
Personnel receiving an emergency complaint shall determine If the situation requires
immediate action to protect the life or safety of the inmate and, If so, shall take any
necessary action pending further investigation. Personnel shall immediately notify
their sergeant, who shall initiate the actions necessary to address the situation giving
rise to the emergency. The sergeant shall also notify the watch commander, who
shall make the final determination on whether the complaint is an emergency and, If

so, shall ensure that appropriate action has been taken to resolve the issues giving
rise to the emergency.
The watch commander will further ensure that a written response is provided to the
inmate within five calendar days documenting what action was undertaken to address
the situation which gave rise to the emergency. If the inmate is not satisfied with the
action(s) taken to address the situation, the inmate must submit an appeal of the
Department's action within five calendar days of receipt of the written response. The
watch commander shall make the final determination of the resolution of any appeal
within two calendar days of receipt of the appeal.
If any portion of an inmate complaint is treated as an emergency, but there is another
portion of the complaint that is not deemed to be an emergency, the non-emergent
portion shall be treated as such and the non-emergent portion of the complaint shall
be subject to the general inmate complaint process and deadlines set forth in other
sections of this policy. The portion of the complaint that is deemed to be an
emergency will proceed on the timelines set forth in the preceding paragraph.
Jurisdiction of Complaints

If the complaint or request involves conditions or personnel at another facility, the
facility receiving the form shall facsimile a copy to the concerned facility's unit
commander and mail the original. The concerned facility shall assign the reference
number, and be responsible for completing the request.
Any question of complaint jurisdiction within a jail facility shall be determined by the
unit commander. Any question of jurisdiction within the Custody Division shall be
determined by the Division Chief.
Basic Requests

A basic non-medical or non-mental health request is a request that can be quickly
resolved by a custody assistant, deputy, supervising line deputy or sergeant. This
type of request does not require a reference number. When feasible, the request shall
be handled during the shift in which it is received.
If this is not possible, the watch commander shall be advised and the inmate shall be
notified of the reason for the delay. A complaint involving personnel is not considered
a basic request and shall be handled as set forth below, under "Personnel Complaint."
A basic request may be submitted in any written form.
Requests

All requests other than basic requests must be submitted on the Inmate
Request/Complaint Form. The retrieving sergeant shall assign a reference number to
these requests. Requests shall be handled by established unit procedures.

Requests of a medical or mental health nature shall be submitted by inmates in a
sealed envelope. The sergeant shall immediately deliver, in person, any sealed
medical and mental health requests and medical related complaints to a medical
sergeant.
Complaints (In General)

A sergeant with the rank of sergeant or above shall investigate all complaints within 15
calendar days of the complaint being filed. Upon completion, the handling sergeant
shall complete the "Disposition" section of the Inmate Request/Complaint Form, obtain
the inmate's signature on the white and yellow copies, and provide the yellow copy to
the inmate (See Inmate Complaint Investigation Handbook for instructions on how to
investigate inmate complaints).
If the investigation cannot be completed within 15 calendar days, the handling
sergeant shall notify the assigning watch commander and request an additional 15
calendar days to complete the investigation. Upon approval, the handling sergeant
shall- notify the inmate of this extension.
If, after the extension, the Department has still not completed the investigation, or if an
extension was not approved, the watch commander shall inform the inmate in writing
that the complaint cannot be completed within the requisite time frame and that the
inmate has the right to appeal.
Group Complaints

When individual complaints are submitted by three or more inmates from the same
housing location referencing the same or similar complaints, these complaints shall be
considered group complaints. A single reference number shall be assigned for each
group complaint and applied to each individual complaint form. Each complaint form
submitted shall be handled with written notice to the inmate as provided above.
At no time shall the group complaint procedure be used in regards to personnel
complaints.
ADA Complaints

Inmates may submit ADA complaints on either the "Inmate Request/Complaint Form"
or the "Los Angeles County Sheriff's Department Americans with Disabilities Act
(ADA) Complaint Form". If the inmate uses the "Inmate Request/Complaint Form,"
the "ADA" box on the form should be checked. The posted toll free number may also
be used to file a complaint.
Regardless of the form used, all ADA complaints shall be assigned by the watch
commander to a sergeant to handle as quickly as possible. If the inmate is requesting

a reasonable accommodation that requires the consultation of medical personnel, the
request shall be handed to the appropriate medical personnel. Copies of both
resolved complaints with action taken and unresolved complaints are forwarded by the
facility administration to the Department ADA coordinator.
Complaints of Retaliation

Any allegation of retaliation by an inmate will be objectively and thoroughly
investigated by the Department. Refer to COM section 5-12/005.05, Anti-Retaliation
Policy.
If an inmate submits a complaint alleging retaliation, and such complaint is received by
medical personnel, the Complaint/Request Form shall be immediately hand-delivered
to the watch commander. The allegation will be documented by the watch
commander on a SH-AD-32A, attached to the Request/Complaint Form, and
submitted to the unit commander of the concerned facility for review.
The unit commander shall forward a copy of the SH-AD-32A and attached
Request/Complaint Form to Internal Affairs Bureau, Internal Criminal Investigations
Bureau, and the Office of Independent Review. The Captain of Internal Affairs Bureau
will determine which unit will conduct the investigation.
Personnel Complaints

Personnel complaints shall be immediately delivered by the shift sergeant to the watch
commander to evaluate the nature and seriousness of the complaint, and to assess
the type of response necessary (Le., immediate or routine).
The watch commander shall assign a sergeant to conduct a preliminary inquiry in
order to determine the appropriate method for handling (i.e., handle according to the
inmate complaint investigation process or handle via an administrative or criminal
investigation). A personnel complaint shall not be handled by the staff member
against whom the complaint is directed, and, if possible, not handled by a sergeant
who directly supervises the involved personnel.
Form for Requests and Complaints

If an inmate submits a written request or complaint in some other form, the sergeant
who retrieves it shall return it to the inmate along with a blank Inmate
Request/Complaint Form and provide the inmate the assistance needed to complete
the form. Regardless of the format, all complaints shall be recorded and processed as
described under the section "Complaints (In General)."
Inmates who are unable to complete a written form because of disability, language
barrier, or illiteracy may raise complaints or requests orally, and Department personnel
shall ensure that the complaint or request is documented in writing.

Late Submissions

Complaints submitted 15 calendar days after the event upon which the complaint is
based shall be considered late and denied. These complaints will receive a
disposition code of 50 and closed. Personnel complaints shall not be considered late if
the last event complained of occurred within 15 calendar days of the submission date.
If the date of submission comes into question, the assigned sergeant shall review the
e-UDAL and confirm that the forms had been retrieved on a daily basis. If the forms
were not collected daily, an adjustment shall be made to allow for the 15 calendar
days.
Personnel complaints submitted 15 calendar days or more after the event upon which
the complaint is based will be considered late and denied. Late complaints will be
closed in F.A.S.T. with a code 50; however, they shall be thoroughly investigated.
The inmate shall be notified that the complaint was submitted late and denied, but that
the Department will nonetheless conduct an investigation and take appropriate action
in response to the complaint. The decision to conduct any investigation after the
expiration of the 15 calendar day deadline shall not invalidate the denial of an untimely
complaint or confer any rights on the involved inmate.
Resolution of the Complaint

Once the results of the complaint investigation have been determined, the assigned
sergeant shall complete the "Disposition" section on the Inmate Request/Complaint
Form. A written response shall be delivered to the inmate generally within 15 calendar
days after the submission of the complaint. A written response shall be provided for
any approval or denial of a complaint. This requirement shall be satisfied by providing
the inmate a copy of the final disposition of the Inmate Request/Complaint Form.
Inmates shall sign the original or facsimile copy (if forwarded from another unit) of the
Inmate Request/Complaint Form to document receipt of the written response as stated
in Title 15 Section 1073, "Inmate Grievance Procedure." However, if the complaint
was previously addressed as the result of a court order or other governmental referral,
it is not mandatory to summon the inmate for his/her signature.
For complaints relating to inmates that have been released after the submission of a
complaint, the assigned sergeant shall note in the "Disposition" section that the inmate
has been released. A copy of the disposition should be forwarded to the released
inmate's listed mailing address. Once the investigation has been completed and
signed by the inmate (if applicable), the Inmate Request/Complaint Form shall be
placed into the facility's Inmate Request/Complaint Coordinator's in-box for further
processing.
NOTE: The Inmate Request/Complaint Coordinator shall ensure that the receipt of the
written response is properly entered in the F.A.S.T. system. The Inmate Complaint

Disposition Data shaU be completed on the back of the Inmate Request/Complaint
Form.
Complaints From Released Inmates

Inmate complaints received from persons who have been released from custody shall
be processed on an Inmate Request/Complaint Form (not a Watch Commander
Service Comment Report form) pursuant to Manual of Policy and Procedures, section
3-04/010.05, "Procedures for Department Service Review." Complaints submitted from
form~r inmates shall be subject to the same guidelines, requirements and procedures
as a complaint submitted by an inmate in custody.
Referred Inmate Complaints

In the event an inmate is unable to submit a complaint, a complaint may be submitted
by a non-involved party (i.e., an inmate's friend, relative, etc.) on behalf of the inmate.
Referred inmate complaints shall be processed pursuant to Custody Division Manual
section, 5-12/020.00, "Referred Inmate Complaints." Referred inmate complaints shall
be subject to the same guidelines, requirements and procedures as a complaint
submitted by an inmate in custody.
Conflict Resolution

Sergeants are encouraged to offer the inmate a "Conflict Resolution Meeting" with the
employee(s) they are complaining about. A "Conflict Resolution Meeting" between an
inmate and personnel is voluntary, and shall be conducted by a sergeant. The
purpose of a "Conflict Resolution Meeting" is to further the Department's ongoing effort
to encourage respect-based interaction with inmates. Even if the inmate's complaint
against personnel is unfounded, a "Conflict Resolution Meeting" may serve as a
learning experience for the inmate and personnel.
Certain inmate complaints where there is an indication of significant misconduct are
not suitable for conflict resolution, such as excessive force, retaliation, or criminal
misconduct. Sergeants should use good judgment in determining whether a "Conflict
Resolution Meeting" is appropriate for the circumstances.
Dispositions

Findings resulting from an investigation in response to an inmate complaint depend on
whether the complaint is against personnel or a service complaint.
Service complaints shall be resolved with one of the following dispositions:
•
•

Founded. Further action taken (investigation establishes that the complaint is
true and that a sergeant has taken appropriate action to remedy the matter),
Unfounded. No further action (investigation clearly establishes that the
complaint is not true and no further Department action is necessary),

•

Unresolved (Investigation fails to resolve the complaint, and there is no .
preponderance of the evidence to either affirm or refute the inmate's complaint.
It is within the sergeant's discretion to determine whether any action is
necessary or appropriate to address the source of the inmate's complaint).

Inmate complaints against personnel shall be resolved with one of the following
dispositions:
•
•
•

•
•

Exoneration (Employee was clearly not involved or incident could not have
occurred),
Employee Conduct Appears Reasonable (The employee's conduct appeared to
be in compliance with procedures, policies, guidelines or training),
Appears Employee Conduct Could Have Been Better (The employee's conduct
was in compliance with procedures, policies and guidelines. The complaint
could have been mitigated if the employee had employed tactical
communication principles or common sense),
Employee Conduct Should Have Been Different (The employee's conduct was
not in compliance with established procedures, policies, guidelines or training),
Unable to Make a Determination (There is insufficient information to assess the
employee's alleged conduct or to identify the employee involved).

Should the inmate complaint investigation result in a disposition that the employee's
conduct should have been different, the unit commander shall determine the following
course of action:
•
•

Train, counsel, and/or mentor the employee,
Initiate an administrative or criminal investigation, as appropriate.

Refer to Complaints Against Personnel below for further details about what should be
communicated to the complaining inmate.
Appeal Process for Complaints

Appeals by inmates must be submitted within seven calendar days of receiving the
written disposition regarding their complaint, or it will be denied. Appeals shall be
submitted on the appropriate appeal form. Inmates who are unable to complete a
written form because of disability, language barrier, or illiteracy may raise complaints
or requests orally, and Department personnel shall assist these inmates in completing
the written form.
The appropriate sergeant, an individual different from the initial reviewer (watch
commander, medical sergeant, mental health sergeant, or food production sergeant)
shall make the final determination of the resolution for the appeal. Inmates shall be
advised, in writing, of the disposition of their appeal within 15 calendar days after the
submission of the appeal.

If the Department fails to notify the inmate of the disposition. of the appeal within 15
calendar days, the inmate's appeal shall be considered denied. The unit commander
or his designee, shall review all inmate complaint appeals to ensure a thorough
investigation has been conducted and the appropriate disposition has been rendered.

Handling Dispositions of Personnel Complaints
The results of an investigation pertaining to an inmate complaint against personnel
shall not be disclosed in any form, induding written reRponReR to inmate r.omplaintR.
The reviewing sergeant shall advise the inmate, in writing, of the disposition of a
complaint against any personnel or any results of inquiries pertaining to personnel
conduct. The information disclosed to the inmate shall be limited to the following
information:
•
•
•

Acknowledgment of the complaint,
Statement that the investigation was completed,
Assurance that the appropriate administrative action has been taken (for
complaints that have been resolved as "Employee Conduct Should Have Been
Different. H).

Note: For the other personnel complaint dispositions, the disclosure shall be limited to
the following response: "Your complaint has been thoroughly investigated; however,
we were unable to substantiate that (employee's name) violated any of our
Department policies and procedures."
When an inquiry into the conduct of any personnel results in the initiation of a unit
level administrative investigation, an lAB investigation, or an ICIB investigation, the
sergeant conducting the inquiry into the inmate complaint shall complete the
"Disposition" section of the Inmate Request/Complaint Form, indicating the disposition
as "Unit Level Investigation," "Internal Affairs Bureau Investigation," or "ICIB
Investigation. "

Retention of Original Inmate Complaints
Pursuant to Custody Division Manual section 4-13/000.00, "Retention of Records,"
custody facilities shall retain all inmate complaints for five years. Additionally, all
inmate requests requiring a reference number shall be retained for five years.

Extensions
The unit commander, or his/her designee, may extend time deadlines for the
submission or disposition of a complaint or appeal in the event of an emergency
situation or when there is an extended disruption of normal facility operations.

Los Angeles County Sheriff's Department

CUSTODY DIVISION DIRECTIVE
Custody Support Services

CUSTODY DIVISION DIRECTIVE: 12-003
ISSUED FOR:

DATE: JULY 25,2012

CUSTODY DIVISION
INMATE COMPLAINTS AGAINST STAFF

PURPOSE
The purpose of this directive is to establish procedures regarding data collected from the
Inmate Complaint/Service Request Forms (SH-J-420) involving Department personnel.
The Facility Automated Statistical Tracking System (F.A.S.T.) was designed to capture
basic data from inmate complaints. In order to assist the Discovery Unit with Pitchess
Motions, F.A.S.T. has now been modified to enable statistical coordinators to enter the
names of personnel involved in complaints against staff.
POLICY AND PROCEDURES
Effective immediately, personnel identified through the inquiry of a complaint classified as
"Complaint Against Staff', shall be listed in the Disposition Section of the Inmate
Complaint/Service Request Form (SH-J-420). Those personnel named in the inmate
narrative section of the complaint shall not be entered into F.A.S.T. unless verified by the
supervisor assigned to the review.
Unit statistical coordinators shall enter the employee numbers and names of all personnel
listed in the Disposition Section into the Inmate Complaint Module within one business
day, in accordance with Custody Division Manual section 4-01/025.00, Inmate Assault
and Force Reporting in F.A.S.T.
Once the information is entered into F.A.S.T., unit commanders are capable of running a
report of those personnel identified in inmate complaints. Unit commanders or above will
be the only ones authorized to run this report for their unit or bureau. Any use of this
information for counseling, discipline or mentoring purposes shall only be done after a
thorough review of the facts surrounding each complaint.
RETENTION
Inmate complaints are to be retained for a period of 5 years in compliance with section 413/000.00 Retention of Records of the Custody Division Manual.

Originally Issued: 712512012
Revised:
Latest Revision:

PAGE 1 OF2

INMATE COMPLAINTS AGAINST STAFF

COD: 12-003

The policies and procedures outlined in this directive shall remain in effect until the
Custody Division Manual is revised and/or this directive is rescinded.
Questions regarding
Support Services,

. directive should be directed by email or phone to Custody
Incent E. Callier at (213) 893-5102.

APPROVED: ~~~~~~~~~~______

ARY:oam

Originally Issued: 7125/2012
Revised:
Latest Revision:

PAGE 2 OF2

STATUS OF RECOMMENDAT IONS REGAR DING THE JAIL SYSTEM

1Q11!V12 Response:
The Dcpartmenl has established direct daily reporting procedures for force incidents, to
identify potential patterns of conduct by pe rso nnel. The process was initially established
through the Commanders Management Task Force. and lias been incorporated into the
regular duties of Custody Division in order to ensure oversight and ear1y warn ing to potential
problems.
Update 12104112:
Custody Division faciHties report all uses of force incidents to Custody Support Services
(CSS) on a daily basis. AU incidents are eKamined regarding their tactics , location. time of
occurrence, and personnel involved , for any patterns or issues. All use of force data is
reviewed with the Sheriff and Chief every week. In addition, each facility Captain is req uired
to submit a monthly analysis oftheir use offorce incidents to CSS. where each Incident is
analyzed for hislorical data, plior use of force incidents. m~igating circumstances , and any
training issues. This information is then compiled and reported to Custody Division each
month. Custody Division reports the findings of any issues, trends, or concerns to the
Sheriff.

STATUS OF RECOMMENDATIONS REGARDING THE JAil SYSTEM

10115112 Response:
The Department's Custody Division and the Commanders Management Task Force have
received valuable input from numerous correctional agencies throughout the Nation
regarding the effectiveness of body scanners. The Department has conducted product
analysis and pricing and is in the process of purchasing the body scanners. Your Board win
be required to approve the purchase based on existing County protocols.
Update 12104112:
Currently, ttJe Department does not have any body scanners; however, we are currently in
the procurement process with Internal Services Department to purchase 20 units. The
Board approved this purchase with mOllies identified frorn the Over Detention Settlement
lawsuit. The e'3timated cost per unit is $175,000 to $220,000, with an estimated
maintenance cost of 12 percent.
The proposed scanners will be deployed as follows:

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Response:
I have personally reflected on my shortcomings in managing Custody Division. I took
immediate action to correct the situation, and personally evaluated all of the jaH facilities to
verify areas of concern through direct interaction w!th personnel and inmates. I created the
Commanders Management Task Force to inspect every aspect of jail operatiorls, and
ensure prompt aetiorl arid follow-up. I insisted all personnel cooperate with all oversight and
critique, and encouraged cooperation with the Commission's investigation, even when the
information was not favorable to the Department.
Update 12104112;
I meet with Custody Division executives on a weekly basis to monitor the Division's overall
use of force , participation in the Education Based Incarceration program, inmate complaint
levels, inmate population issues, as well as other custody relsled topics .

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Response:
I agree with the Commission's assessment. but am also bound by adherence to laws,
policies, and procedures when it comes to matters of formal discipHne. I value and respect
tOO Commission's input regarding leadership and accountability, and have ordered formal
administrative investigations to determine if there is a factual basis for formal discipline.
I understand the Commission's point regarding the difference between evidence of
misconduct, and not getting the job done. I agree that in several instances my senior
management failed to keep me informed. or did not perform to my expectations. All of this
will be taken into evidence-based consideration at the culmination of the formal
investigations, but the outcome win not be influenced by personal or political motrvations of
an}'Qne.
Update 12104112:

The administrative investigations are ongoing.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

"",ty ,y CU8fod¥

'----- -- -- -

~ or hl diacfpftl&/y

10115112 Response:
I have restructured the chain of command. The new Assistant Shertff over Custody Division
will report directly to me. Furthermore, I have restructured Intemal Affairs Bureau (lAB) and
Internal Criminal Investigations Bureaus (ICIS) directly under the Division Chief (currently
Chief Roberta Abner), who will report directly to me.

12/04112 Update:
Please see the attached organizational charts submitted with this update renecting past,
curren!. and proposed hierarchies as they relate to all oftfle CCJV recommendations.

FORMER DEPARTMENT ORGANIZATION CHART

[

Sheriff

-

)

Undersheriff
Admlnl.tnttv. Service. Ofvl.,on

I

~

Assistant Sheriff

Assistant Sheriff

Field Operations Region I

Leadership and Training
Division

Field Operations Region II

Court Service. Division
,

Field OperaUons Region III

Technical Services Division

Detective Division

Custody Division

Homeland Security Division

CURRENT DEPARTMENT ORGANIZATION CHART

Sheriff
Undersheriff
Admlnl.tnttv. s.rvteM OMsion

I

I

Assistant Sheriff

Assistant Sheriff

Field Operations Region I

l •• d.,..hlp and Training
Division

~

Field Operations Region II

Court Services Divis ion

Field Operations Region III

Technical Services Division

Detective Division

Custody Division

Homeland Security Division

.

.

,

PROPOSED DEPARTMENT ORGANIZATION CHART

Sheriff

[

Undersheriff

1

Admini!ltrative Services Division

Assistant Sheriff

Assistant Sheriff

Assistant Sheriff

Proposed
I

Field Operations Region I

[

Leade~hip

and Training
Division

Field Operations Region 11

Court Services Division

Field Operations Region III

Technical Services Division

Detective Division

Homeland Security Division

Custody Division

1

Investigations Division
Proposed

LEADERSHIP AND TRAINING DIVISION
CURRENT DIVISION ORGANIZATION CHART

leadership and Training
Division

-

Commander

r-

Commander

RbkManav-nent
Bu....u

Tr1Iining Bu.... u

Ex.c::utiw Foretl

STAR Unit

Committee

Employ•• Support
Servlc•• BUAlIU

Sure,u of Labor
R,lltlonl
Penon.,.1 .nd Bude-t

~'Ilew

Intern •• Crlmlnl'
Inv"tlgetlone Bu,..,u
,

,

l"tlrlUll Arrllr. Bur.. u ,

LEADERSHIP AND TRAINING DIVISION
PROPOSED DIVISION ORGANIZATION CHART

Leadership and Training
Division

-

Commander

Commander

'nllnlng Burelu

Rl.k Management

STAR Unit

El(ecutlv8 Fon:e Review

Employ. . SUPFKJrt

Service, Bur.lu
Burnu 0' Labor
Relatlona
Penonne/and Budget

Bur•• u

CommlU..

~

INVESTIGATIONS DIVISION
PROPOSED DIVISION ORGANIZATION CHART

Investigations Division
Funded Chief

Internal Affairs Bureau

Internal Criminal
Investigations Bureau
.

.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Response:
I agree and have advocated such a proposal in the past The Department is currently
ordinanced for a third Assistant Sheriff posHion, but requires additional funding from the
Board of Supervisors, Additionally, the Department merged Correctional Services and
Custody Operations into a consolidated command, under Custody Division (currently Chief
Alex Vim) .
Update 12104112:
On November " 2012, the Department submitted a funding request to the Chief Executive
Office (CEO) for this recommendation. The Oepartment is working w~h the Department of
Human Resources (OHR) on the hiring process. I have already approved a recruitment
announcement, which is posted on the DHR website, and I anticipate the selection process
to be completed by the end of the year. Please see attached recruitment announcement
submitted with this update.

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STATUS OF RECOMMENDATIONS REGARDING THE JAil SYSTEM

10/15/12 Response:
The Deptlrtment agrees that the new Assistant Sheriff over Custody should possess
experience in managing a large corrections facility or department. As a Correctional
Commissioner for the State of California, I understand and appreciate the specialized
knowledge and skills required for running such a large jail population.

Update 12104112:
See recommendation 4.4 for status updates on the hir'"9 process.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Response:
The Department agrees that the Assistant Sheriff for Custody should report directly to the
Sheriff. Since the inception of the Commission, I have required the Assistant SheriTf to
report directly to me, in addition to weekly !;cheduJed executive meeting!; known as the
Sheriff's Executive Planning Council (EPC). consisting of ali senior managers attha rank of
Division Chief and above.
Update 12104112:
See recommendation 4.4 for organizational charts associated with all CCJV
recommendations .

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

not be 8 p9fmanent pBrt ofC1l1tOdy

10/15/12 Response:
The Department agrees that th e Commander Management Task Force (CMTF) should nol
be a pennanent part of Custody management. I ha'le directed lhe CMTF to incorporate its
jail refonns inlo the regular duties of the Custody Division command . I have kept the CMTF
intact as an immediate. short-term solution 10 identify and address deficiencies in all jail
operations. AI the culmination of the Commission's Final Report and Recommendations.
lhe CMTF wHI conduct an out-tmefing with Custody Division to ensure all ofthe jail reforms
will remain a permanent solution 10 improve jail operations.

STATUS Of RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Response:
I agree that I must regularly and vigilantly monitQr the Department's use of force in the jails.
The Commanders Management Task force has developed a thorough, clear, accurate, and
prompt force reporting procedure, which includes daily force numbers and charts. This
process has kept me and senior managers aware of force trends, and ensures a prompt
response to significant use of force incidents. This format will be passed on to Custody
Division at an oul briefing. and will continue with the new Assistant Sheriff over Custody.

Update 12104112:
I continue 10 monitor the use of force in the jails by meeting with Custody Division managers
OIl a weekly basis.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Rfi/sponsfi/:
The Department appreciates thai tile Commission recognizes Sheriff's Crttlcallssues
Forums (SCIF) are currently condllCled in Custody DMsion. The Department is commined
to continuing SCIF's and open forums to provide additional quality control, oversight and
review throughout the Department.

Update 12104112:
In the past, Custody Division has held SCIF presentations on an annual basis. Beginning in
September, Custody Division began to hold these large, division-wide meetings on a biannual basis to examine the previous six-month and one-year periods. In addition, the
Division holds smaller meetings on a monthly basis to insure thai concerns are examined
and corrective action is taken when appropriate.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Response:
The Department agrees thai senior management personnel need to be more visible and
engaged in Custody. From the onset of the jail allegations, I visited every jail facility til1\l
directed ail senior managers to do the same. I designated Commander Paul Pietrantooi to
serve as a Personnel Performance Commander, to specifically walk through jail facilities,
both announced and unannounced, to identify and address deficiencies. In addijion to
infOflTlal walks through jaillacilities, I have required unit commanders to report back and
account for the frequency of their interactioo on jail floors at "Inmate Town Hail Meetings,"
as well as regular attendance at staff briefings and ·spot check" inspections.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Response:
The Department .....ilt be requesting funding for additional staffing required to 8ddll~!;!;
operational needs of larger untts.

Update 1210"'12:
The Department is in the process of conductlng a comprehenSive assessment of the
operations staff for the eight custodia l facUities . The assessment win compare each facil~y
and establish a model for allocating administrative staff based on individual facility needs
The Department anticipates the assessment of each jail facility .....mbe completed within 60
days.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Response:
The Department agrees and will be seeking funding to create an internal Audit and
Inspections Division. The Commanders Management Task Force has already mel with the
Commission and the Los Angeles Police Department to explore the creation of an internal
Audit and Inspections Division. A pmposal to create the Sheriff's Inspectional Services
Command (ISC) has been prepared. but requires funding from your Board.
Update 12104112:
On November I , 2012, the Department submitted a funding request to the Chief Executive
Officer (CEO) and has been engaged in discussions of the proposed staffing levels.
The goal of the ISC is to identify and address potential deficiencies within the Department
through audits, inspections, reviews, mentorship, and open forums with personnel at Oil
ranks. The focus of the ISC is to ensure prompt and effective action to strengthen our level
of service, while reducing the Department's exposure to lililbility. The Inspectlonal Un~'s
scope will encompass four main areas:
•
•
•
•

Internal Command Inspections
Independent Aud~s, Inspections. and Review
Disciplinary Review
Accountability and Maintenance

Currently, Department's inspections are conducted by individuals throughout the
Department as a collateral assignment. The Department is proposing to follow the de1lign
olLAPD's Audit and Inspection Division so that all audits and inspections are centralized
within one unit: therefore, creatiflg accountability at all ranks.
This new unit will be taSked with inspecting and auditing all of the various units within the
Department. The Department has consulted witil members of the LAPD to gain insight into
the challenges and successes of their Aud~ and Inspections Division. In addition, the
Department has also consulted with the Auditor Controller's office for additional guidance.
There are approximately 70 different units that would benard from this inspectiOn IiInd audit
process. It is estimated that each audit would take approximately 3G-120 days to complete.
The Department is currently reviewing each unit and conducting a risk assessment to
determine the priorfty of inspections.
The Department is discussing proposed initial staffIng levels with the CEO. Once the unit is
established for a period of time, the Department will be better able to determine the
optimum staffing level needed to achieve an appropriate schedule of audits.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115/12 Response:
The Department has already prepared a policy consistent with the Commission's
recommendations. The policy is in its final stagll'lS or review.

Update 12104112:
The Department is conrerring with County Counsel on the proposed policy.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 RespOn$fl:
The Department has re-established participation wHh the NaHonallnslHute of Corrections,
National Jail Exchange (Large Jail Network), The next fonnal conference will be held March
2013, in Aurora, Colorado, A Custody commander will be designated as tile liaison, to
participate and report back regarding best practices and information to me and at Custody
Division staff meetings,
The Department is also involved with the American Jail AssocialiOn and the Southern
California Jail Manager's Association , In addition, the Department has recently initiated a
Force Consortium with other local agencies,

Update 12104/12:
The Large Jail Network is designed for executive level participation, Department members
are scheduled to attend the next meeting in the spring of 2013, AddHionally, the
Department has organized a consortium comprised of the nine southern Califomia sheriffs
departments, which will examine use of force issues, policy, training, and management
methodology, The goal is to examine and establish. some best practices in these areas.
The first session of the consortium is scheduled for February 5, 2013.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Response:
The Department will continue to expand Education Based Incarceration (EBI), Inmate Town
Hall Meetings, and other efforts emphasizing respect for, engagement of, and
communication with Inmates. The Department appreciates that the Commission also
understands the value of progressive programs thai encourage respect based Interaction
between staff and inmates. To date, there have been more than 6,500 participants of EBI.
Over the past year. combined attendances at regularly scheduled Inmate Town Hall
Meetings have increased to more Ihan 50.000.

Update 12104112:
It is the responsibility of each custody facility unit commander or their designee to facilitate
Town Hall meetings. Every facility conducts a Town Hall meeting for each housing area at
~st once a month. Prior to the commencement of a Town Hall meeting. a survey is
provided to each inmate in attendance and is collected by the staff at the end of each
meeting. If there are specifIC complaints regarding a quality of life issue, they are entered
into the Town Hall Meeting TraCker. AU issues derived from Ihe Town HaH meetings are
addressed within seven days from the date of the meeting.
The information provided in the Town Hall Meeting Tracker is audited on a weekly basis by
staff membef'll from the EBI Bureau. Each faciljty entry Is reviewed for the thoroughness
and to ensure Ihat the inmate concerns have been addressed. A report of the top five
concerns is generated and provided to each facility captain for review.
Since October 2011, there have been 1,572 Town Hall meetings conducted, and 57,«9
inmates in attendance.
The Department also provides all inmates the opportunity to submit complaints. outside of
the Town Hall meeting forums. Each housing area has a supply of Inmate Complaint Forms
available for the inmate to obtain. The inmate can complete the complaint form , retain the
pink copy, and place the complaint in a locked Inmate Complaint Form box, which is
collected at leas! once per shift by the floor sergeant.
The sergeant and medical personnel review all collected complaints. All complaints
pertaining to medical requests are collected by medical staff. entered into the tracking
system by Medical Services Bureau. and handled to conclusion.
AU other complaints are handled by the floor sergeant. Complaints that are easy to resolve,
such as linen, clothing, care packets, etc.. are immediately handled by the sergeant.
Complaints that require additional research are logged into the tracking system,
disseminated to the appropriate handling entity, and completed as soon as possible. The

STATUS OF RECOMMENDATIONS REGARDING THE JAil SYSTEM
yellow copy of the complaint with the complaint disposition is returned to the inmate. The
disposition of the complaint is entered into the tracking system.
The Commission recommends that the Department continues to implement reforms that
emphasize the respect for and communication with inmates. The Department's EBI Bureau
has been established to focus on education within the custodial environment and provide
the inmates in our custody the ability to fully capitalize upon the rehabilitative programs and
the Department's concurrent efforts to reduce recidivism.
Principles of Education-Based Incarceration:
Assess and evaluate the educational and trade skills of all inmates.
• Develop a learning environment to educate inmates.
• Develop and implement an automated case management information system.
• Strengthen and systemize our partnership with California Department of Corrections
and Rehabilitation.
• Develop a structured curriculum.
• Transform the cultural mentality of residents in the communities at large and those
housed in our care to support and embrace the principles of EBI.
Under the command of a captain, the EBI Bureau is comprised of several sub-units that
address the educational needs of inmates beginning at the first point of contact when they
are arrested and information is entered into our booking system, to a point post-release
when they are involved in our post-release educational programs.
In the past, the Department's vocational programs did not have an educational component.
Our experience has shown that participation in life skills, decision-making, parenting,
personal relations, and spiritual growth programs provide the life-changing skills needed to
succeed outside of the custodial environment. EBI provides the following inmate programs:
Programs Offered
• Personal Development
• Leadership
• Decision Making
• Critical Thinking
• Relationships
• Conflict Management
• Employment
• Time Management
• Budget Management
• Understanding and Coping with Stress
• Vocational Programming
• General Educational Development (G.E.D.)
• Parenting
• Substance Abuse
• Moral Resonation Therapy

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM
•
•

Anger Management
Communication Skills

The Department's ultimate goal is to transform the culture of the custody facilities and
provide a safe, secure learning environment for our personnel and the inmates. To date,
there have been more than 7,000 participants in ESI.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115/12 Re$ponse:
The Department teaches de-escalation techniques in the Academy. The Department hes
incorporated the Force Prevention Policy into the Academy and Jail Operations training
curriculum. Force Prevention will also be included throughout the entire Department in the
restructured Use of Force Policy (effective January 1. 2013).

Update 12104112:
Currently, the Academy curriculum provides a totai of 80 hours of instruction on the
Department's Use of Force policy, Defensive Tactics, and Persons with Disabilities.
The Use of Force Learning Domain curriculum includes 12 hours of the following:
• Introduction to Use of Force
• Force Options
• Use of Deadly Force
• Documenting Use of Force
• Concept of Control in Use of Force
The Defensive Tactics Learning Domain curriculum includes 60 hours of the following:
• Principles of Defensive Tactics
• Person Searches
• Controlling Force: Control Holds and Take-down Techniques
• Carotid Restraint Control Holds
• Restraint Devices
• Firearm Retention and Takeaways
• Use of Impact Weapons
• Transporting Prisoners
The Persons with Disabilities learning Domain cuniculum includes six hours of the
following:
• Disability Laws
• Developmental Disabilities
• Physical Disabilities
• MentallUness
The Department's Jail Operations training curriculum includes 32 hours of Use of Force
policy IiInd force prevention , An additional 8 hour block of instl1Jction on values based
decision-making, respect-based communication, and how to deal with inmates was added
to the curriculum, which inclUdes scenarios covering recalcitrant inmetes and force
prevention policies. The Department has conducted recurrent briefings at each facility to

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM
ensure Custody Division employees have been briefed and adhere to the Force Prevention
policy.
Due to the fact that the mentally impaired population has increased, the Department felt a
need to enhance training in this area to potentially lessen force incidents with mentally
impaired inmates. For years, employees received four hours of training on how to cope with
mentally-impaired inmates in Jail Operations training which was taught by the Department
of Mental Health. The Jail Operations curriculum has expanded by an additional six hours
of training taught by the Jail Mental Evaluation Team (JMET).
JMET consists of a team of deputies who are classified as subject matter experts
specifically trained to handle mentally disturbed persons. JMET is partnered with a
Psychiatric Social Worker II to assist in de-escalating conflicts and ultimately reducing the
potential of force incidents. The JMET training staff receives 32 hours of training per year.
The training consists of the following:
•
•
•
•
•
•
•
•

Introduction to Mental Illness including signs and symptoms
Identification and types of mental illness and co-occurring disorders
Crisis Intervention
Suicide Prevention and Identification
Pacific Clinic's conferences once a year on mental illness
Mental Illness and Law Enforcement Systems (MILES) conference once per year
Mental Evaluation Team (patrol) ride-a longs
Patton and Metropolitan Hospital tours.

The primary responsibility of JMET is to identify mentally-ill inmates who are in need of
additional attention to address their special needs. JMET responds directly to the housing
areas for any requests by staff, which may include, but are not limited to individual
assessments (completed twice a week to evaluate care and any unmet needs in general
population), provide intervention services, transportation to clinics, and assist in crisis
situations {jail extractions, attempt suicides, hunger strikes, etc.}.
Effective January 1,2013, the Force Prevention policy will be mandated throughout the
Department in the new Use of Force policy.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115/12 RNpcmse:
The Department has added two additional weeks at the end of the Academy to enhance Its
ethics training and guidance. More specificaHy, recruits will be taught the principles of
Constitutional Jailing, Constitutional Policing, and Procedural Justice. This will be
reinforced during Custody Division training, as well as Department-wide training, through
the Deputy leadership Instilllte. Furthermore, personnel will not only learn Our Core
Values, blJl. be held accountable for Polk:y and Ethics violations in conflict with Our Core
Values.
Update 12104112:
Please see the attached flow chart depicting the additional training added to the academy
and jail specific classes.

Lo~'

Angeles County S heriff's Depllrtment

Training Mandate for New Recruits Within the Department
Deputy Sheriff

(-'

DePT1:th.erlff

.(

1

.-

LASD Academy

•

j
--

....

Jail Operations

,-

On the Job Training
at Facility wn:O .

Custody
Leadership

" .....

,......

~

(111 WMb E1f/aJJoN No....."", 1ft)

TO lillaf38
WeeI!s

at

Training

.

PINS. ,.,., to pilQl 3 to vI_ thl speclffc 'mining provided to Me" InllnH,

Custody ASSIstant

LASD Academy

On the Job Training

••

Los A ngeles County Sher{fJ'~'lJepartmen'

Training Mandate for New Deputy Sheriff Trainees
Dl:!puty Sheriff ' _ _ _ _ _ _.... \

Tf.in..

'

Pm-Employment Rflquiromflnls
Entry Leval Examination
Backgrounds
VPAT~

POST and ~ StMdMfIs

LASD AC.ldemy
16 W...~.r

• POST Certified Learning
Domains
• Report O#iling
• DepartmfJfIt Ethics and
standards
• CORE Volues
• S/I'flSS Mgt/Alcohol
Awamness
• Respecf Based LeaOOrship
• Crlb(;ai Decision Ma~i/Jg
• Frn/emization
• Museum of T%r<J1ll;{}
• TaclicBVPIlYSICill Trainillg
• PIlysicaJ Fttneu I &fJfCiI;e
• Introdudioll /0 Luu than

Leillal Oavice.t

• Mse'-' a.n.ww I

Ted!r..,.,.,

R8.ttnItI1
Alt*~ c....

"'"

,......

J.l1I OpaT.ltlonl!

f-------->\ Custody L eaders hip f--- - - ,
2 W""ks

Sheriff &. OSJ M llndlltet

SheriftMandates

• Inmaw Cullurnt Tmining
• Gang ID 6. Classifiea/ion
• Conlnlband end EvidallCB
• Custody Specific Report Writing
• Department Ethics and Standards
• CORE Va lues

Custody Lffaoorship Skills
Cognitlvfl Communicetkm
Valued Communication
Force Incident Video Review
FOTC6 PlllvBntion
Americans with Disabilitl6s Act
Constitutional JII~ng

•
•

•
•
•
•
• 08slruclM> CliqUflS
• Di$tributlOn of Commissary 6.
Silpplies
• EmlflV'MCY Pr'OC8d;Jros
• Scenaoo TffJln~
08mOfls/rlJ1ion

Custody Facillry
Traini"g

" .....

• TI1CtIcttI Commune.oons
• GIlMOdy SptICIIk: Pana/ eoc.t.II...
• Corje., StaftAN,. & ~

Ooet/i..,

•

EBI Orientation 6.
Forc;e Prevelltion
Facil/fy Specific Unit Orders,
Policies 6. Procedures
Facility SpecifIC Emergency

",_w
• FirJI R8$p0nS$ '

"""

Turnout

Los Angeles County Sherif/'s Dtpartttftmi

Training Mandate for New Custody Assistant Trainees

•

• Repott ~DI9

• o.p.rtmefII EJhk;s and SbtIxlfHds
• CORE V8ktes
. Fotce~

• " " ' _ u(ToItNanctJ
• Shss MgtIAJmhoIA _ _ ~
• Rtnped &JI:ld ~
• Fmlem/zation

• CrfbctII DedJ"iQn Ma/Iing

.1&1/ Cullody Specific Tmlning
• Management oIll)111alo Worl<ar3
• Deslr!JCJlva Cliques
• DI~ribution of Commissary &

Suppl;u

Prrtetlc.1 Appllc.Uon & r ,.'nlng
Vnd .. Culf0s&' [Mlnq QfffcfC

ESt Ori>tnttJtion & F(IJ'(I/lltJrizarion
Fotr;.

Pr.venloon

FIICHy $p«1fJ, U,ti/ OrI:Mrs.
PoIdtI, & PmoedunJS

II: ~""-" __ E _

::." ' _ '• • T",",,",

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10/11j/12 Response:
The Department has drafted a proposal for a "Dual Track. Career Path" (DTCP). The
proposal centers on staffing the jails with personnel who are better suited in skills,
personalities, and desire to serve permanently in 8 Custody assignment. The proposal
would also benefit those deputies who choose to serve in patrol, since they would not be
required to serve a long tenure in the jails, unless they specifICally desired to do so.
The proposal was presented to the Board of Supervisors' PubHc Safety CARs meeting on
Febfl.l8ry 8, 2012. The proposal is curren1jy being considered by the employee associations
(ALADS and PPOA), and is subject to additional reform based on the best interest of the
public, the Department, and its employees.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115/12 RNpOllse:
I have directed that aH jail captains regularly attend and conduct Inmate Town Hall
Meetings, tiS well as become directly engaged with staff, inmates, and independent
oversight at each facility. This directive has been followed up with an accounting for the
frequency of captain and supervisory tlttendance at Inmate Town Hall Meetings, training,
and briefing.
The information will be permanently reviewed by the Custody Division chief and the
assistant sheriff over Custody.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 RfJspon~e:
Law enforcement officers must be Ileld to tile Ilfgllest standard of honesty and integrity, and
tllat standard must be continually communicated. Tile Department will continue to
empllasize tile principles clearly stated in Our Core Values, as well as reinforce Ille
Department's "zero-tolerance" for disllonesty. To accomplisll this, the Department will
require all unit commanders to conduct in-service br~fings rtlminding personnel of tile
Discipline Schedule lor Disllonesty. To ensure this is accomplislled in a timely manner,
tllese briefings will be conducted in concurrence witll the signed admonition lor tile
restructured Use of Force Policy, to be completed by December 31. 2012.

Update 12104112:
Tile Discipline Guidelines Ilave been revised and submitted for approval. Employee unions
wiH be notified and provided an opportunity to respond.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Response:
The Department and has already implemented a Mandatory Rotation Directive.
Impiemented on February 17, 2012, the Directive provides a reasonable exception for
·positions that require additklnal training or experience that may affect the effectiveness of
their command. These key positions shall be reported annually to the chief of Custooy
Division:
To ensure compliance with this Directive, unit commanders are required to retain their
rotation records for at \east two years.
Update 12104112:
The Sheriff's Department will work with the Implementation Monitor to assemble a working
group of personnel to pilot rotations within and among proximate facilities to asses!> the
viability of impiementing such a policy. In order to ensure cooperation from the employee
union!>, participation in the pilot program win be voluntary.

STATUS OF RECOMMENDATIONS REGARDING THE JAil SYSTEM

1W15112 Response:
As the CommiSsion points out ir1 its FtrJal Report, the Department cannot prohibit
discretionary decisions with personnello associale with each other, but il wiH remain vigilant
to prohibit the use of Department resources and time in any actillily contrary to the
Department's Mission and Core Values. This will be accomplished by ensuring supervisors
and managers are continually monitoring the workplace, and documenting activities in
conflict with the Department's Mission and Core Values. The Department will also
incorporate a forma l lecture during the extended Jail Operations and Ethics Training ,
specifICally discouraging participation ir1 destructive cliques. Additionally, "spot checks· and
inspections will be conducted by senior managers and by the Inspectional Services
Command (ISCl currently being proposed.
The Commission's concerns regarding visible tattoos associated with deputy cliques is
addressed Ihrough a clear policy, summari1.:ed by this excerpt from Manual of Policy and
Procedures Section 3-01/050.80: "While on duty and Wfjaring any D&parlr1lflllt-approved
uniform or appropriate business attire, members are prohibited from exhibiting any tattoo,
branding. Of"other form of body art thaI may O!i seM by another persOfl."

Update 12104112:
Effective October 22. 2012, with Jail Operations Class #390, Ihe Department incorporated a
formal lecture specifically discouraging participation in destructive c~ques.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Response:
The Department agrees in concept. It is my desire to create a fully staffed Custody Training
Bureau under the leadership of the Custody Dlvision Chief or the newly appointed Custody
Division Assistant Sheriff position. in an effort to fulfill the Commission's training mandates_
To accomplish this task the appropriate fuooing is necessary from the Chief Executive
OffICer (CEO). The American Civil Liberties Union (AC lU) concurs with this configuration
In addition, the Department has submitted the Dual Track Career Path (DTCP) proposal to
the CEO for approval. The DTCP will permit non-patrol trained deputy sheriffs assigned to
Custody Division the opportunity to promote within Custody Division to the rank of Division
Chief. The DTCP will also allow deputy sheriffs the flexibility to se~t a career path in
Custody Division or Field OperationsJDetectives. The DTCP will provide value and a career
path for personnel assigned to Custody Division.

Update 12104112:
The Department is In the process of revising its supervisory selection process for newly
promoted supervisors. Historically. the Department pennttted each custody captain to
select their top two choices. then anowed Field Operations, Courts Services and Detective
Divisions to select their supervisors with Custody Division receiving the remaining
supervisors. As we mova forward, Custody Division will have an equal voice In the
selection of newly promoted supervisors. This will be accomplished by pennitting Custody
Division to immediately select a replacement if a vacancy is identified instead of waiting untH
other divisio ns fill their vacancies with Custody Division receiving the last selections_
The Department's policy and practice allows custody sergeants to promote to the rank of
custody lieutenant without having to transfer to field operations first. The perception,
however. is the Department does not practice this policy. The Department will ensure
supervisory personnel are aware thai they can , and will , be promoted in Custody Division
without having to transfer to Fiekl Operations Division first.
In addition, the Department has submitted the DTCP proposal to the CEO for approval. The
DTCP will pennit non-patrol trained deputy sheriffs assigned to Custody Division the
opportunity to promote within Custody Division to the rank of Division Chief. The DTCP will
also allow deputy sheriffs the flexibility to select a career path in Custody Division or Field
Operations/Detectives. The DTCP wiM provide value and a career path for personnel
assigned to Custody Division_

STATUS OF RECOMMENDATIONS REGARDING THE JAil SYSTEM

10116/12 Re5ponse:
The Department's Personnel Administration Bureau has forecasted a consistent hiring
strategy for the next five years based upon the Department's current financial allocations.
However, if the Chief Executive Officer (CEO) implements a fiscal reduction in the
Department's budget, the hiring strategy will require adjustments according to financial
restraints.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Ruponse:
I have mandated an additional two-week ctJslody specific training cuniculum for new
deputies: this curriculum is in addition 10 !he two-week Jail Operations class. Under Ihe
Departmenfs currenllraining mandates, following this classroom curriculum, deputies musl
complete an additional 12 week training course under the supervision of an experienced
and well respected cuslody training officer at their respective facilities. Therefore, the
custody training for new deputies actually tolals 16 weeks.
In addition to the 16 weeks noted above, the Department is increasing specific facility
training from 12 weeks to 16 weeks. This will enhance tile actual custody training for new
deputies to a total of 20 weeks.
The Department is also increasing training for custody supervisors from 8 hours to 40
hours.
Furthermore, it is my desire to create a fully staffed Custody Training Bureau under the
leadership of the Custody Division Chief or the newly appointed Custody Division Assistant
Sheriff position. To accomplish this task Ihe appropriate funding is necessary from your
Board. The American Civil Liberties Union 'ACLU" concurs with this configurallon .
Update 12104112:
The Department agrees in concept with Ihe CCJV recommendation regarding tile inception
of a Custody Training Bureau (CTB): however, we feel the best practice would be to adhere
to the industry standard, and assign the CTB within the command structure of the Custody
Operations Division The Department has met with members of tile American Civil Liberties
Union (ACLU) who concurred with this configuration.
The Department's view is shared by experts cited in the CCJV reporl that "corrections is its
own separate profession" and, "Patrol and jail work are two very different disciplines· The
commafld structure of Custody Operations Division, overseen by Ihe Custody assistant
sheriff wi ll ensure that custody is not unnecessarily influenced by field operations.
The Slate of Califomia utilizes two separate and unrelated entities to oversee law
enforcement training : the California 'Commission on Peace Officer Standards and Training"
(POST) is responsible for the certifICation and recurrent training of police officers, while Ihe
' California Department of Corrections and Rehabilitation - Standards and Training for
Corrections' oversee the training of local and Slate oorrectional officers throughout the
State.
Wrth respect to "significantly more custody specific training" - new deputies wiH receive an
additional two weeks of custody train ing. specific to the correctional environment. The

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM
curriculum is in addition to the two-week Jail Operations class. Under the Department's
current training mandates, following this classroom curriculum, deputies must complete an
additional 12 week training course under the supervision of an experienced and well
respected custody training officer at their respective facilities. Therefore, the custody
training for new deputies total 16 weeks.
Recently, the Department has increased specific facility training from 12 weeks to 16
weeks. This has expanded the actual custody training for new deputies to a total of 20
weeks, which exceeds regional sheriffs departments in Southern California.
The following Southern California sheriffs departments were surveyed. The listed agencies
each utilize a specific custody training bureau, under the command of their respective
correctional operation divisions, which instruct custody orientation and mandated recurrent
training.
Sheriffs Department
Los Angeles County
Imperial County
Kem County
Orange County
San Bernardino County

Custody Training for New Deputies
20 Weeks
12 Weeks
6 Weeks
4 Weeks
6 Weeks

The following agencies' field and custody training units are combined with subject matter
experts assigned respectively to field and custody operations.
Sheriffs Department
Riverside County
Santa Barbara County
Ventura County

Custody Training for New Deputies
8 Weeks
16 Weeks
4 Weeks

POST mandates two hours of custody specific training in the Basic POST Certified
Academy. The table below shows the current custody specific academy training and
academy attrition rates for Southern California agencies.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

Sheriff's Department
Los Angeles County
Imperial County
Kern County
Orange County
Riverside County
San Bernardino County
Santa Barbara County
Ventura County

Basic Academy Custody Training
18 Week Academy - 4 Hours Custody
9 Week Correctional Academy
14 Week Correctional Academy
26 Week Academy - 4 Hours Custody
9 Week Correctional Academy
23 Week Academy - 4 Hours Custody
4 Week Correctional Academy
3 Week Correctional Academy

Academy Attrition Rates
18%
33%
15%
17% _.",
20%
10%
0%
30%

Custody supervisor training has increased from 24 hours to 40 hours, effective October
2012.
See recommendation 5.2 for status updates in regards to training for mentally ill inmates
The Department is working with the CEO to identify funding for the proposed CTB.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Response:
All custody facility Un~ Commanders are required to schedule face-to-face meetings wi\t1
custody personnel prior to the end of their probationary period. Outlined in this meeting,
Unit Commanders are mandated to discuss the following topics; Department's Core Values,
Department's MissKm Statement. Constitutional Jailing, Procedural Justice, and their
probationary evaluation to ensure personnel fully grasp the Importance of their career
responsibilities. A checklist form outlining the respective topics will be included in the
probationary training packet.
UpdOllte 12104112:
On October 15, 2012,the Department implemented a new Custody Division Directive, 12005. to address the concerns of the CCJV. The directive established procedures regarding
the documentation of Ihe probationary period with aU new custody personnel.
Custody Division unit commanders are required to schedule face-ta-face meetings with
custody personnel prior to the end oftheir probationary period. Outlined in this meeting,
unit commanders are mandated to discuss the following topics; Department's Core Values,
Department's Mission Statement, Constrtutional Jailing, Procedural Justice, and their
p-robationary evaluation to ensure personnel fully grasp the importance of their career
responsibilities.
A checklist outlining the respective topics will be included in the probationary training
packet. A copy of the directive is attaChed with this status update.
The CCJV expressed concem the Department was not adequately vetting probationary
personnel during the probationary period who may present disciplirlary problems to the
Department in the fulure. The CCJV stated the industry standard probationary employee
attrition rate was between 10 and 25 percent. The Department contacted the below
indicated agencies to capture their probationary period attrition rate from 2010 to 2012.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM
See recommendation 6.3 for the academy attrition rate for the aforementioned sheriff's
departments.
The Department believes the CCJV most likely merged the academy and probationary
attrition rates of the law enforcement agencies they contacted to formulate their conclusion.

Los Angeles County Sheriff's Department

CUSTODY DIVISION DIRECTIVE
Custody Support Services

CUSTODY DIRECTNE: 12·005
ISSUED FOR:

DATE: OCTOBER 15, 2012

CUSTODY DMSION
PROBATIONARY PERiOD FOR CUSTODY PERSONNEL

PURpoSE
The purpose of this directfve is to establish procedures regarding documenting the

probationary period of custody personnel.
POLICY AND PROCEDURES

The Commander Management Task Force (CMTF) researched the protocol for newly
assigned custody personnel who successfully complete the probationary period.
Currently, the respective training sergeant from each facility meets with probationary
personnel and provides a detailed assessment of the employee's performance. This is

memorialized ., a probationary evaluatkm, which signifies the end of the probationary
period.
The Citizens' Commission on Jail ViOlence (CC.N) recommended the Department
implement a meaningful probationary period for custody personnel. The Oepartment
agrees with the recommendation.
The CMTF recommend altering the current procedures and implementing a
consequential probationary period. The facility training protocol will remain in-tact;
hoWeIIer, at the completion of the employee's sixth month of a66ignment, the shift
sergeant shall conduct an assessment of the employee's performance, Which will be
documenled In II memorandum. If the employee 's performance is substandard, the
sergeant and the shifllieutenant will request remediation with the approval of the Un~
Commander. If the Unit Commander determines that the employee's performance is not
sat~factory, then normal protocols to address their failure to complete the probationary
period will be followed . Upon successful completion oftha remediation, the sergeant or
lieutenant Shall document the necessary information in a memorafldum.

~"'GE'

rl2

PROBATIONARY PERIOD FOR CUSTODY PERSONNEL

COD: 12.005

Prior to the employee's one year anniversary the Unit Commander or designee shall
schedule a face-to-face meeting to discuss the following topics:
• Core Values
• . Mission Statement
• Constitutional Jailing
• Procedural Justice
• Probationary Evaluation
A checklist form outlining the respective topics must be included in the probationary
training packet. If the Unit Commander or the designee is satisfied with the employee's
responses, the Unit Commander shall draft a memorandum to memorialize the
employee's successful completion of the probationary period.
RETENTION
The policies and procedures outlined in this directive shall remain in effect until the
Custody Division Manual is revised and/or this directive is rescinded.
Questions regarding this directive should be directed by email or phone to Custody
Support Services, Lt. Vincent E. Callier at (213) 893-5102.

ARY:mda

Originally Issued: 10115/2012
Revised:
Latest Revision:

PAGE2of2

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Response:
The Department has submitted a request to the Chief Executive Officer (CEO) for 10
lieutenants and 101 sergeants to be added to Custody Division.
Update 12104112:
The cuITent number of superviso~ in Custody Division is critically low, Administrative
burdens on the current supervisors diminish their ability to actively supervise the line staff.
Custody Division unit commanders were requested to conduct a supervisory assessment 01
their respective facility and provide a suitable number of lieutenants aTld sergeants that they
deemed critically necessary, in order to fulfill the obligations olltleir responsibiliHes. These
additionally requested items would be deployed directly to the fine positions. covering a 24hour operation, throughout Custody Division as follows:
Facility
Men's Central Jail
Twin Towe~ Correctional Facility
Century Regional Detention Facility
North County Correctional Facility
PDC East Facility
PDC South Facility
PDC North Facility
Inmate Reception Center
Mire Loma Detention Center
Trensportation Services
Totals

Lieutenant

Sergeant

1
1

20
21
7

o

o
o
o
o
o

o
o
2

14

6
9
5
10
6
3
101

In order to accomplish this goal, the Department has submitted an appropriate funding
request to the CEO for 2 lieutenants and 101 sergeants to be added to Custody Division.
The Department's original response requested ten lieutenants. That response included
funding for eight add~ional Risk Management lieutenants, at each custody facility to relieve
line lieutenants of the administrative burden caused by the overload of paperwol1l. The
request for Ihose eight items is now covered solely in Recommendation 7.6 .
The number of supervisors requested is critically necessary; nevertheless, the funding
request does not provide Custody Division with an ideal supervisory staffing model. Active
supervision, in the appropriate ratios, can make a significant impact on incidents of jail
violence.

See the tables below for Department supervisory staffing levels Department wide, in
Custody Division. and proposed for Custody Division.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

Ca tain to Lieutenant
Lieutenant to Se eant
Se eant to De

Ca tain to Lieutenant
Lieutenant to Sergeant
Se eanllo De
Se eanllo De u I CA

1:6

1:3
1:6

1:7

1:3
1:12
1:17

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Response:
The Departrmmt ha5 changed its procedures which previously mandated that depllliea
transfer to patrol, by currently allowing unlimited annual extensions in Custody Division.
Deputy personnel who do not desire to transfer to patrol are afforded the option 10 subm~
annual extensions to Custody Division Headquarters. Upon approval of Iheir request.
deputies are permitted to remain in Custody Division In time. this policy change will
significantly reduce the length of time in Custody Division for sworn personnel who desire to
transfer to Patrol.
If the Dual Track Career Path (DTCP) is approved by the Board, deputies who do not have
an interest in patrol will be excluded from submitting patro l transfer requests .
The Department is in the final stages of conducting an assessment and evaluation of duty
statements from each position at every custody facility to determine which job classification
(sworn p9lSQnnel or custody assistant) is best suited to handle the functional operation of
thai particular position.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Respollse:
As stated in the response sedion of recommendation 6.6. the Department is conducting an
assessment of positions within Custody Division. Preliminary information has shown that
the line personnel positions in Custody Division are substantially understaffed. If the
Department can maintain its current comp~ment of sworn personnel and increase ils
compliment of custody assistants by approximately 160 positions. this would enhance the
level of service in our jail facilities and afford the Department the resources to provide our
inmates with the opportunity for additional programming. It has been documented through
the Rehabilitation surveys, which are issued at every Town Hall meeting. that our Inmate's
second highest request is additional iIlmate programming.
Update 12104112:
The Department is in the final stages of conducting an assessment and evaluation of duty
statements from each position at every custody facility to determine which job classifications
(sworn personnel or custody assistant) are best suited to handle the functional operation of
that particular position.
The Department's current Custody Division personnel staffing model is comprised of 68
percent deputy sheriffs and 32 percent custody assistants. An assessment of all positions
in Custody Division was completed , which showed that the Division was understaffed. Unit
commanders were requested to provide an efficient personnel staffing model to manage the
variol.Js responsibilities encumbered by their respective facilities. As depicted in the table
below, the unit commanders requested a total of 173 additional personnel items (130
deputy sheriffs and 43 custody assistants).
After a review of the personnel request and duty statements, the Department proposed the
additional personnel items be filled with 160 custody assistant items. If the Department
maintained its current compliment of sworn personnel and increased its compliment of
custody assistants by approximately 160 positions, the staffing model would renect 65
percent deputy sheriffs and 35 percent custody assistants. This is the maximum
compliment of custody assistants as agreed upon in a Memorandum of Understanding
(MOU) with the Association for Los Angeles Deputy Sheriffs (ALADS).

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM
The table below depicts the Department's current staffing levels for deputy sheriffs and
custody assistants, and the deployment of the proposed 160 custody assistants.

Facility
Men's Central Jail
Twin Towers Correctional Facility
Century Regional Detention Facility
North County Correctional Facility
PDC East Facility
PDC South Facility
PDC North Facility
Inmate Reception Center
Total:

Deputy
568
466
233
271
129
164
144
251

CA
164
277
151
79
59
78
67
186

2,226

1,061

14
19
5
55

Proposed
CA
15
25
20
17
14
19
5
45

173

160

Captain's
Request
10
30
23

17

The Department has submitted the appropriate funding request for 160 custody assistant
positions to the Chief Executive Officer (CEO).
The Department is currently asseSSing if the percentage of custody assistants could be
increased without jeopardizing jail security and safety. If this assessment indicates an
increased percentage of custody assistants is feasible, then the Department would confer
with the unions about possible changes to the MOU.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10/15/12 Response:
Pursuant to Special Counsel Merrick Bobb 's recommendation, the Department recently
implemented mandatory rotations in Custody Division within each facility. The Department
Is evaluating the recommendation of implementing a sensible, but steadfast policy of
rotations of personnel among proximate facilities. The Department is assessing the
probability of employee union issues, the impact on affected personnel, and the best
practices for the overall health of the Depiirtment.
Update 12104112:
The Sheriff's Depiirtment will work with the Implementation Monitor to assemble a working
group of personnel to pilot rotations within and among proximate facHit~s to assess the
viability of implementing such 8 poliCY. In order to ensure cooperation from the employee
unions, participation in the pilot program wiU be voluntary.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Re$ponse:
The Department [r:; reviewing the Mission Statement and will make the appropriate changea
to reflect the importance of Custody Division.
Update 12104/12:
The Department has developed a working group to review the current Mission Statement.
The focus of the working group is to make appropriate changes to reflee! the importance of
Custody Division and a custody career palh.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

;--_~_CUsIody ~~
_

_

':'
.__...
_ · _- _

_

}ai_l ---'1

_

1W15112 Response:
As previously mentioned, if approved by your Board, the implementation of the Dual Track
Career Path (OTCP) will fulfill this recommendation .
Update 12/04112:
The CCJV illustrated a program similar to the San ~iego County Sheriff's Department'~
(SOSD) two-tier system with a custody specific 16 week training academy and specific
custody deputy designation as a recommended alternative to the Department's current
personnel model. During the Department's assessment of the SOSO pen>onnel structure,
members of their department provided candid opinions regarding shortcomings of their
model:
•
•

•

•
•

The two academy model created a caste system at the onset of a deputy's career.
Shortly after the creation of the ·specific deputy designation,· detention deputies
initiated a class-action lawsuit for pay parity and attempted to separate from the
deputy union, a situation that was settled in arbitration.
As a resuft of the parity arbitration, a 5-10 percent pay differential was established.
which nullified operational cost savings, one of the main reasons for the two-tier
system.
DlJe to the established caste system, hostilities often occur between patrol and
detention deputies.
During the recent San Diego County wildfires, their department was unable to
address field force deployment needs. Their departmenltook the risk of liability
assigning detention deputies to handle patrol posts, even though they were not
patrol certified .

During the Department's DTCP feasibility assessment, the prior Modified Deputy Program
(MOP) was reevaluated. The MOP was previously terminated because it was ineffective
and detrimental to the employee and the overall Department. The operation of the
"Modified Deputy Academy" created a third job ctassiflcation within the Custody Operations
Division and increased operational costs over time.
Concerns with the MDP included:
•
•
•
•

Two separate academies created a caste system.
Operational costs to add a modified academy would double the current Acedemy
budget.
It was anticipated that custody assistants would initiate a lawsuit for pay parity as
occurred in San Diego, minimizing any potentia l cost savings.
Field force deployment would be unsustainable.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM
•

A survey of "Modified Deputies" indicated that the overwhelming majority found the
program to be detrimental to their career. They felt it created a caste system in
which they were openly disparaged.

The DTCP analysis proved it to be a more advantageous option that will enhance the
careers of sworn personnel with additional career freedom, flexibility, and promotional
opportunities. The DTCP attributes, when fully implemented, include:
•
•
•
•
•
•
•

Recruitment, hiring and training will remain unchanged.
Sworn personnel are provided the flexibility to select a career in custody without
transferring to Field Operations Division.
Personnel can promote within Custody Division up to the rank of division chief.
The custody environment will experience an increase in its value.
The program is cost neutral.
In the long term the DTCP is projected to provide a cost savings, as non-patrol
supervisors will receive five percent less in salary~
The paradigm shift in the Department's culture will not c~eate a caste system.

If approved by the Board and the CEO, the implementation of the DTCP will fulfill this
recommendation.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Response:
The Department will need to expand tile number of Internal Affairs Bureau (lAB)
investigators. Tile Commanders Management Task Force has already met with
Commission members to explore comparable systemic changes implemented by the Los
Angeles Police Department (LAPD) in response to a 2001 Federal consent decree. Based
on knowledge gained from our research , the Department is prepared to take the following
steps consistent with the Commission's recommendations:

1. Seek funding to expand the number of lAB investigators.
2. Ensure that all uses of force that re5ult in injulies more than "redness, swelling or
bruising," or complaints of paifl regarding the "head, neck, or spine" would be
reviewed and , if necessary, investigated by lAB or Internal Criminallnvestlgations
Bureau (ICIB).
3. Ensure an other uses of force investigated at the unit level come under the OYefSight
and review of lAB and the Office of Independent Review (OIR), or the new Office of
Inspector General (DIG) if approved by the Board .
Require all supervisors investigating cases involving injuries to seek out evidence from
medical staff, including medical record,., statement from personnel who witnessed injuries
and photographs of injuries. (Medical personnel should also be asked to document that
information in their own records).
Update 12104J12:
Many of the changes regarding the cr~eria for lAB investigations are contingent upon tile
amount of funding provided by the Board. The Department will continue to work with the
Implementation Monitor to ensure compliance with the inlent of the recommendation.

STATUS OF RECOMMENDATIONS REGARDING THE JAil SYSTEM

10/15112 RespomJe:
The Department agrees the Custody Force Review Committee (CFRC) should continue to
monitor Force Packages for trends. concerns. and the performance of supervisors. The
CFRC exhaustively reviews and scrutinizes significant force cases not rising to the ievel of
an lAB investigation. If the Department is able to expand staffing for lAB invesUgators.
more 01 these significant force cases will be scrutinized during Executive Force Review
Committee (EFRC) as recommended by the Commission. In the interim. CFRC will
continue to scrutini~e these force cases, and monitor for trends, concerns, and the
performance of supervisors.
Update 12104112:
The commanders who comprise the CFRC, along with the Custody Training Bureau and
representatives from the Office of Independent Review. thoroughly examine the quality of
each force package, focusing on the application of force. tactics, actions of supervision. and
the overall qualdy of the investigation. Corrective actiQn is routinely sought via directed
training Qf fQrmal administrative investigation. During a CFRC sessiQn. handling
supervisors of each force Incident are present to respond directly to questions regarding
their decision making and performance. Recommendations are tracked for trends in
performance or behavior.

STATUS OF RECOMMENDATIONS REGARDING THE JAil SYSTEM

10115112 Response:
The Department has Incorporated a policy consistent with the Commission's
recommendation . The restructured Use of Force policy specif/Els that personnel are
required to provide a timely written report of force incidents prior to reviewing video footage
Since the new Use of Force policy will not be effective until January 1, 2013, Custody
Division immediiitely implemented a Division Directive requiring compliance with the same
standards regarding the review 01 video footage (effective September 27, 2012).

Update 12104112:
This recommendation wiU be comp~ted upon implementation of the new Use 01 Force
Policy, effective January 1, 2013.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10/15/12 Response:
The Department will revise its policy to expand its "no huddling" practJce for all signifICant
force . The Department will monitor and review significant force incidents to ensure
compliance with the policy.
Update 12104112:
The new force policy will require that for force incidents handled by Internal Affairs Bureau.
deputies who use force and those who witness force will not be allowed to communicate
with each other untillhey have prepared their report or have been intelViewed by
investigators. The policy will be effective January- , . 2013.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

Division undsr e Chlefwtm I¥OCIId r&pOIt

1(1115112 Response:
r have restructured the Leadership and Training Division 10 have operational command of
Internal Affairs Bureau (lAB) and Intemal Criminal Investigations Bureau (tCIB).
In order to move lAB and ICIB under a separate and independent Investigations Divf$ion,
the Department requires funding for an additional chief position. Consistent with the
Commission's remarks, the Sheriff is not opposed to considering the appointment of a
sworn or nOll-sworn Chief of Investigations from outside the Department, if the person
fXISSl:lsses the knowledge , expertise. and skills required . The Sherfff would conSider a
farmer judge. judicial commissioner, or retired professional expelienced in evaluating facts
and evidence.
Update 12104112:
Currently, one cl1ief oversees the Leadership and Training Division which consists of lAB,
ICIS, Risk Management Bureau, Training Bureau, The Success Through Awareness
Resistance (STAR) Unit, Employees Support Service Bureau, and the Bureau of Labor
Relations and Comp~ance_
Under the proposed recommendation, this Division would be bifurcated. A new Division
named Intemallnvestigations Division would be created. A proposed chief position would
direct the new Division whiCh would be tasked with the responsibilities of lAB and ICIB. The
remaining units would remain within the Leadership and Training Division. The Internal
Investigations Division chief would report directly to the Sheriff. This would send a clear
message that disciplinary investigations and allegations of misconduct investigations are a
top priority for the Department.
Consistent with the remarks of the CCN, I agree with the recommendations and am
considering the appointment of either a sworn or non-sworn Chief of Investigations from
outside the Department. I am seeking a candidate with expertise as a prosecutor or an
investigator.
The Department is working with the Chief Executive OffICer (CEO) to identify funding for this
recommendaboll_
See recommendation 4.6 status update for organizational charts related to all CCJV
recommendations.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

I

...,~ I,IIIMPLEMENTEDI
II!
~ valued wsla#f&d byp8l5Ofll7&/ that OM d9ttWaJy cenyout

_tf1fJ B6fIOItIvSllnd ~nt work oftflnt bun/au.

, ___ _ "" ___ _

Chief Abner

10115112 Response:
The Department wln continue to make It clear Ihat Intema! Affairs Bureau (lAB) persormel
are valued investigators. This will be accomplished through continuing to promote qualified
personnel from the ranks of lAB. Caplain Alicia Ault is an example of many experienced
lAB investigators recently promoted. The Sheriff's Department also recognizes that
promotion is only one method of developing a cadre of quality irwestigators . since the
promotional process must fOllow strict Civil Service rules .

j

I

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Response:
The Department will increase penalties lor proven acls of excessive force and dishonesty.
The increases will be renected in the revised Discipline Guidelines to show ' zero tolerance:
includin!l termination and possible prosecution.

Update 12JD4I12:
The Discipline Guidelines have been revised and submitted for approval. Employee unions
wi" be notified and provided an opportunity to respond.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 RNpOnse:
Most units currently must create a designated Risk Manager from existing personnel in
order to vigilantly track lind monitor use of force in~estigations, for thoroughness,
timeliness, quality contrOl, patterns, potentialliabilmes, and other factors.

Risk Management positions are sometimes not filled in order to fin essential front ~ne posts.
This is made more difficult with mandatory budget reductions.
Update 12104112:
The Department has requested eight additional lieutenants to assist in relieving further
administrative burdens of existing line lieutenants. These lieutenants would be assigned to
the following facilities: Century Regional Detention Facility, NoM County Correctional
Facility, PDC East facility, PDC South Facility, PDC North Facility, Inmate Reception
Center, Mira Loma Detention Center, and Transportation Services. Men's Central Jail and
Twin Towers Correctional Facility already have Risk Management Lieutenants in place.
The Risk Management lieutenant would ensure the quality control of use of force
investigations, inmate complaints, civW claims, lawsuits, and other risk management
concerns determined by the Unit Commander. The timeliness and thoroughness of
investigations is necessary to ensure proper accountability and reduce civ~ liability.
The qualifICations of the Risk Management lieutenant require law enforcement experience
as well as extensive institutional knowledge of the Sheriffs Department, policies, tactics,
judicial procedures, and administrative investigations. In addition, this position would be
almost exclusively interacting with various line lieutenants and sergeants, thus requiring the
level of responsibility associated with the rank of lielltenant.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM
.. i

10115112 Response:
The Department agrees that force investigations shoukl not be conducted by deputies'
immediate supervisors, particularly when the leadership or involvement of the supervisor
couk! be in question.
The Department has worked with the Office of Independent Review (OIR), and Special
Counsel Merrick Bobb to develop policy to ensure thai supervisors involved in a use of forcEI
incident shall not conduct the investigation. Additionalty, any case where supervision is in
question will be reviewed by both the watch commander and unit commander.
Update 12104112:

Strlct compliance with the recommendation would require significant funding to ensure force
investigations are not conducted by deputies' immediate supervisors. The Department will
continue to work with the Implementation Monitor to develop viable solutions, and ensure
compliance with the intent of the recommendation.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Response:
The Department will develop procedures to prohibit Capteins from ct1enging charges,
reducing discipline, or holding penalties in abeyance for discipline involving use of force,
dishonesty, or failure to report force incidents. Such changes will require consultation with
the employee associations (ALADS and PPOA). The Department will keep the Board
updated about the status of this recommendation

Update 12104112:
The Department is consulting with County Counset

on this recommendahon .

STATUS OF RECOMMENDATIONS REGARDING THE JAil SYSTEM

1011!S112 Response:
The Department agrees that off-duty misconduct should be vigorously investigated and
diSCiplined when founded. 1 he Department will ensure oversight and review through the
new inspectional process and Case Review, where applicable.

STATUS OF RECOMMENDATIONS REGll.RDING THE JAIL SYSTEM

10/15/12 Response:
The Commission accuriltely reports that current Department policies rsqu illl Ule completion
of force reviews and administratrve investigations in an appropriate time trame, In order to
do a beller job at enforcing those policies, the Sheriffs Department has implemented
captain and commarlder duty statements. specifically identifying their duty to ensure
objective find timely review of force investigations.
Th~ policy provides the clarity of specific job functions to hold deficient performers
accountable for their faikJres, without excuse or claim of ignorance, This clarity in
expectations iii not only reinforced through the chain of command, but at the annual
'Captain's College" and 'Commarlders College" training seminar conducted by Department
seniof management.

Update 12104112:
The Department is currently implementing a database known as Operations Information
Management (OIM) within Custody Division. OIM is in use within other units of the
Department and il is anticipated the implementation phase. barring any unforeseen
cirCl.lmstances, will be the first week Of Aprit2013, OIM will enable custody managers to
assign and track force reviews and investigiltions_ Concurrently, the Custody Automation
Reporting and Traclling System (CARTS) is being buiH which will. once implemented.
replace all functionality of Facilities Automated Statistical Tracking (FASn and OIM.
Because the DIM database is already in use, the Department will incur ooly licensing fees in
order to implement OIM. The implementation of CARTS will be compleled by June 2014.
OIM is only considered a temporary solution to capture data until a more reliable and
comprehensi~e system, (CARTS) can be developed. DIM is not based 011 enterprise level
architecture and is not slJitable for the quanlity of data to be used as a long term solution.
Licensing fees lor DIM is approximately $30,000.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10/15/12 Response:
The Department's long-term plan is to create a new module in the updated Personnel
Performance Illdex (PPI) database. In order to comply immediately, the Department is
currently tracking inmate grievances, by the names of Department per.oonnel, in the
Facilities Automated Statistical Tracking (FASn database.
Consistent with the Commission's recommendations, the information can be used to identify
potential pattems of conduct by personnel. The process has been incorporated into the
regular duties of each jail captain in order to ensure orersight and early waming to potential
problems.

Update 12104112:
See recommendation 3.8 for status updates on PPI.

STATUS OF RECOMMENDATIONS REGARDING THE JAil SYSTEM

10115112 ReapontJe:
The Department agrees that the Inmate grievance process should be Improved, with added
checks and oversights, The Department has worked with the American Civil liberties Union
(AClU), Office of Independent Review (OIR), and Special Counsel Merrick Bobb to create
an inmate grievance form and poliCies acceptable to all parties. The process was
presented in Federal Court and the Department has been utilizing the established form and
procedures,
The Department also implemented its own "Anti-Retaliation Policy" (Custody Division
Manual Section 5-12/005 .05) to ensure inmates were not discouraged from filing inmate
grievances.
Updllte 12104112:
This recommendation includes several components:
•

•
•

Each complaint form Should be serialtzed and should be placed into two separate
boxes - one for the Department and one for an outside oversight entity (e.g.
AClU or Inspector General)
The complairlt shoUld not be investigated by the involved deputy's supervising
sergeant
Internal Affairs Bureau (lAB) should investigate any cases in which there is
retaliation against an inmate.

Comp/clin( Forms and Separate Boxes
This recommendation would require the department to reprinl the current Inmate
Complaint FOllns as well as change the design procedure to address how to include
sequential numbers for tracking on the forms.
Preliminary cost estimates to add an addnional fourt h page (outside oversight entity
copy). and create envelopes for inmates to place in our existing Iockboxes or to mail
directly to the outside entity, replicating the new medical complaint process format, is
$164,000 to produce 1 million new forms and envelopes. It is anticipated that this supply
would last approximately six 10 eight months.
In addition,the Department would be required to install about 450 additional lock boxes
throughout the Jail system for the outside entity copies of the forms . The Department
estimates the cost of the additional lock boxes to be approximately $22,500. This would
be the least expensive option, but it comes with some undesirable consequences .
The new proposed sequential forms would require accountability by each facility.
Accountability would require personnel to pass out forms only when requested by an

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM
inmate. Personnel would also have to log each form and serial number in order to track
and maintain a record. The Department would no longer be able to leave the Inmate
Complaint/Request forms unsecured for inmates to retrieve at their leisure as the
serialized forms would require tracking. This contradicts requests by inmate advocate
groups that have requested that inmates have easy access to forms without having to
ask a deputy for them.
The additional lock boxes would require the outside oversight entity to go inside security
at each of the facilities, on a daily basis, to service the 450 lock boxes.
A viable alternative solution would be to implement an automated inmate complaint
program utilizing iPad kiosks. This would be an automated system which does not
require any type of paper forms. It would no longer require sergeants to collect the
forms each shift. All complaints would be sent electronically to the appropriate unit or
person in real time. The electronic complaints would be serialized and traceable.
A pilot program for Twin Towers is estimated to cost the department approximately
$493,469 and will take about six months to develop. The cost for this type of system is
higher initially, but it comes with some tremendous advantages.
The inmate's complaint is sent immediately, in real time, to the outside oversight entity
and to the appropriate custody personnel for investigation and resolution. The complaint
is logged and tracked without any involvement by security deputies. The outside
oversight entity does not need to physically walk throughout each custody facility on a
daily basis to collect inmate complaints from lock boxes.
The "Department has consulted with Merrick Bobb, the ACLU, and OIR. All of them support
the use of electronic forms as long as inmates have easy access to the kiosks from their
living quarters. The Department will discuss this option with the implementation monitor.
Complaint Investigations
The Department, when feasible, will have a sergeant from another part of the facility
investigate a complaint. There are times, however, when this in not feasible. The
Department has instituted mandatory job rotations at all Custody facilities. This means, as
time goes on, every sergeant will have supervised every deputy at some point or another.
Also, there are some instances, at some facilities, in which there is no other sergeant onduty to investigate the complaint other than the supervising sergeant or the watch sergeant,
who effectively supervises the entire shift.
Anti-Retaliation
The Department has implemented an Anti-Retaliation policy that requires the complaint to
be documented and sent to lAB. The captain of lAB is responsible for determining who will
conduct the investigation of the complaint.

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Responu:
The Departmenl agrees Ihallhe use of lapel cameras, more commonly known as a
Personal Video Recording Device (PVRDj, should be broadened.
The Department is ill its final phase of piloting and evaluating PVRDs for use in the jails.
There are some technical limitations of the devices. but the Department is working with
several vendon:; to address these limitat;ofls H1 artier to deploy the PVRDs. Since the
Department is expanding high definition fixed video surveillance throughout its jail facililies,
PVRDs will be utilized during high-risk escorts. significant incidents, or other notable duties
with the need for a video record of the incident.
Update 12104112:
The Department completed a comprehensive study that was delivered to the Board on
November 2, 2012. The Department is working with the Chief Executive Officer (CEO) to
identrfy rul'\ding for this recommendatiol'\.

STATUS OF RECOMMENDATIONS REGARDING THE JAil SYSTEM

10/15/12 Response:
I agree and proposed a similar concept to your Board in 1999. The Department will support
the Soard's efforts 10 increase oversight and accountability in the jails through the Oflic~ of
Inspector Genera l (OIG),

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

10115112 Response:
The Department agrees to report regularly to yo ur Board on use of force and the status of
Custody reform recommendations. I respect the Board's role of ensuring proper oversig ht
of all County Departments, and wi ll continue to provide reports showing use of force
statistics, or any other data the Board feels helpful to ensure proper oversight and review.
I will continue to make myself available to the Board to present the ongoing status of jail
reforms, and anything relating to the Department. I, along with the assistant sheriff for
Custody, will continue to update the Board regarding jail reforms with support
documentation reflecting implementation steps and status.
The Department appreciates the Commission's recognition that the Board should use its
budgetary and oversight authority to ensure that any funds allocated by the Board to the
Department to implement recomme ndations and reforms are used for their intended
purposes.

STATUS OF RECOMMENDATIONS REGARDING THE JAil SYSTEM

10115112 Response:
The Department agrees that the OffICe of Independenl Review (GIR) should be given the
resources necessary to add a staff position to ensure that tile procedures and dispositions
of all force incidents handled at the unit level are fair and thorough .
The Department will work with OIR to facilitate such oversight should the Board decide to
fund the recommendation .

STATUS OF RECOMMENDATIONS REGARDING THE JAIL SYSTEM

1W15112 Response:
The Department agrees that the Office of Inspector General (DIG), if created by your Board,
should review the Depanmenl's data for IrelOs, spikes, and patterl'lS in the jaHs. The
Departrm:lnt will funy cooperate and work directly with the DIG to provide all that is needed
to facilitate such analysis.