National Data on Police Use of Force 1 National Data on Citizen Complaints about Police Use of Force: Data Quality Concerns and the Potential (Mis)use of Statistical Evidence to Address Police Agency Conduct Matthew J. Hickman* Jane E. Poore [DRAFT VERSION 1/26/15] * This study was funded by a grant from the National Institute of Justice (Award No. 2013-R2-CX-0035). Corresponding author: Matthew J. Hickman, Ph.D., Seattle University, Department of Criminal Justice, 901 12th Ave, Seattle, WA 98122. T: 206296-2484; E: hickmanm@seattleu.edu. National Data on Police Use of Force 2 Abstract National data on citizen complaints about police use of force were collected by the Bureau of Justice Statistics (BJS) in 2003 and 2007. These data are a critical component of the Department of Justice’s overall response to 42 USC 14142, which requires the Attorney General to “acquire data about the use of excessive force by law enforcement officers.” The BJS data have the potential to help support democratic policing, provide useful baseline data on use of force for comparative statistical reporting and research purposes, and enable strong local checks on police abuses, provided that their validity and reliability can be demonstrated. This study sought to assess the validity and reliability of the BJS data. Findings indicate that the BJS data suffer from serious, if not fatal, measurement flaws. The BJS data on citizen complaints do not provide a valid and reliable basis for comparative statistical reporting and research purposes, and should not be relied upon for purposes of litigation. National Data on Police Use of Force 3 National Data on Citizen Complaints about Police Use of Force: Data Quality Concerns and the Potential (Mis)use of Statistical Evidence to Address Police Agency Conduct To truly engage in “democratic policing,” a nation-state must systematically examine law enforcement activity in order to ensure that the democratic ideals of transparency, accountability, and – perhaps most important – fundamental fairness, are reflected in police behavior (Bayley, 2006; Hickman, 2009; Luna, 2000; Sklansky, 2008; Skolnick, 1999). Democratic policing is therefore best viewed as an ongoing process rather than an achievable end in itself. While the U.S. presently employs a broad array of social and economic indicators in order to gauge the overall “health” of the nation, it has a much more limited set of indicators concerning the behavior of the police and the quality of law enforcement. We should seek to develop not only evidence that our police are enforcing the law while obeying the law, but also basic indicators about the quality of police-citizen interactions, the potential role of extralegal factors in policing, and particularly the use of force given its centrality to the police role (Bittner, 1970). National data on public perceptions of police behavior and legitimacy (Tyler, 2002) are also essential to understanding democratic policing. In the wake of recent high-profile incidents (including the cases of Michael Brown in Ferguson, MO, and Eric Garner in New York), it is disturbing and even somewhat hypocritical that the nation known as the leading global advocate of democracy (and democratic policing) actually collects and reports very little of this type of information. As the late Professor and former NYPD Officer James Fyfe (2002: 99) National Data on Police Use of Force 4 remarked, “… we still live in a society in which the best data on police use of force come to us not from the government or from scholars, but from the Washington Post.” Likewise, Robert Kane (2007: 776) has noted that, “… it is both ironic and unacceptable that in American democratic society, the police, which function as the most visible representatives of the crime control bureaucracy, collect data on members of the public in the form of arrest and complaint reports without systematically distributing comprehensive data on their own activities that produced those crime statistics.” These assessments were valid when written, and remain so today. National media reaction to the incidents in Ferguson and New York included some outrage at the fact that we simply do not know how often police in the U.S. use deadly force upon its citizens (e.g., Doyle, 2014; Lowery, 2014), and the U.S. Attorney General also recently expressed dismay over the lack of data on police use of force (Berman, 2015). What do we know about the nature and extent of police use of force in the United States, and how do we know it? In a review of the literature conducted as part of an effort to construct an improved national estimate of police use of nonlethal force, Hickman et al. (2008) found that the majority of studies producing an incident-based rate of police use of force were based on data from a single jurisdiction, and the methods were quite diverse as were the units of analysis. Somewhat unsurprisingly, across 36 studies reporting on the amount of nonlethal force used by the police, rates varied from about a tenth of one percent up to almost 32%. While recognizing the inherent value of a diversity of methodological approaches, Engel (2008) noted that the literature reflects a failure to adequately conceptualize and measure police use of force, and that current National Data on Police Use of Force 5 approaches to understanding force on a national level are not achieving those goals, though some may question whether precision is a worthwhile goal (e.g., see Klinger, 2008; Smith, 2008). The lack of national data and the limited state of knowledge about police use of force is all the more disturbing considering that for the past 20 or more years, the U.S. Attorney General has been legally obligated to produce such information and has failed to make any substantial progress. Section 210402 of the Violent Crime Control and Law Enforcement Act of 1994, codified as 42 USC 14142, requires the Attorney General to “acquire data about the use of excessive force by law enforcement officers” and to “publish an annual summary of the data acquired under this section.” So where are these annual summaries of police use of excessive force? In this study, we focus on a particularly important source of data bearing on democratic policing – citizen’s complaints about police use of force. The Bureau of Justice Statistics (BJS) collected these data from police departments in two waves of their Law Enforcement Management and Administrative Statistics (LEMAS) survey program. The present study sought to address the validity and reliability of these data by examining within-agency change across the two survey waves and attempting to validate data for agencies reporting extreme changes, as well as attempting to validate data for a random sample of agencies. We begin with a review of the literature on national-level data about police use of force, and specifically citizen complaints (including sub-national data). We then turn to our study methodology, the results, and a discussion of the findings and their importance for policy and practice. National Data on Police Use of Force 6 Literature Review National-level Data on Use of Force The principal federal response to the use of force data collection requirement mentioned earlier (42 USC 14142), and the only systematic, national-level data collection on police-citizen interactions at present, is the Police Public Contact Survey (PPCS) administered by BJS. The PPCS is a supplement to the National Crime Victimization Survey (NCVS), and the goal is to provide national estimates of the incidence and prevalence of citizen contacts with the police. The PPCS also seeks to describe the nature of those contacts, including whether the police used or threatened the use of force, the specific actions they took, as well as any potentially provoking citizen behaviors. The PPCS has been administered every three years since 1999. The NCVS-based sample for the 2011 PPCS (the most recent at the time of writing) included 62,280 persons age 16 or older, with completed interviews for 49,246 persons. The sample is weighted to represent a national estimate of 241 million persons age 16 or older. The 2002 BJS Survey of Inmates in Local Jails (SILJ) also provided some information about police use of force, although BJS has never analyzed or reported on these data. The SILJ is a computer-assisted personal interview conducted with a nationally representative sample of jail inmates, and covering a broad range of topics (for details see James, 2004). Importantly, the SILJ contained items that parallel those included in the PPCS; thus, jail inmates are asked about the use or threat of force experienced at the time of their arrest. Analysis of the inmate data demonstrates that the National Data on Police Use of Force 7 PPCS underestimates force due to the exclusion of the recently incarcerated (the PPCS accounts for about 87% of the total force incidents derived from both sources), and that the inmate sample is more likely to experience force, a much higher level of force, and is more likely to report injury from force (Hickman et al., 2008). However, demographic characteristics are substantively similar across the two data sources: males, blacks, and youth are more likely to experience force. The BJS Deaths in Custody Reporting Program (DCRP) has provided national data on arrest-related deaths. DCRP data on law enforcement homicides (both justifiable and unjustifiable) are substantively similar to those obtained by the FBI’s Supplemental Homicide Reports (SHR); specifically, 97% of law enforcement homicides involved a male subject, the average age was 33 years, more than 80% were killed by a handgun, and about 30% involved a black subject (Mumola, 2007). The DCRP data indicate that about 56% of all arrest-related deaths involved a minority subject (suicide is the only category of arrest-related deaths in which whites are the majority) (Mumola, 2007). Finally, the BJS LEMAS survey, which is presently the most systematic and comprehensive source of national data on law enforcement personnel, expenditures and pay, operations, equipment, and policies and procedures, also has collected data om use of force. The LEMAS surveys have been conducted roughly every three years since 1987, and provide national estimates for all state and local law enforcement agencies based on a representative sample of about 3,000 agencies. In the 2003 and 2007 iterations of LEMAS, data were collected on formal citizen complaints about police use of force. The LEMAS data provide information on the volume and rate of complaints as National Data on Police Use of Force 8 well as complaint dispositions. Importantly, the LEMAS platform can also be used in conjunction with other data (such as Census Bureau data) to explore issues such as minority representation and structural correlates of citizen complaints (Hickman & Piquero, 1999). The LEMAS complaints data have also found diverse application in the field, including being used to establish “baselines” for larger police departments in their annual reports, as well as in Monell litigation involving police departments. We will return to these issues later in the paper. The LEMAS questions on citizen complaints were motivated in part by Fyfe’s (2002) paper on the lack of data on the use of deadly force (which was part of a larger National Academy of Sciences panel focused on BJS police data series), and in consultation with Fyfe and other scholars engaged in the study of police use of force, it became clear that one viable option was to harness the LEMAS survey for these purposes. These discussions led to the development of items that were incorporated into the 2003 LEMAS survey instrument for the purpose of collecting official departmental data on citizen complaints about police use of force. These data were collected from large agencies (those with 100 or more officers) as an initial effort that could potentially lead to broader or more detailed use of force data collection. This initial foray was successful in that it provided evidence that police departments were, if nothing else, at least generally willing and able to provide this type of information. The 2007 LEMAS data (referencing calendar year 2006 complaints data) were expanded beyond large agencies to include sampled smaller agencies. However, the complaints data were restricted to include the total received, pending, sustained, or National Data on Police Use of Force 9 having some other, non-specified disposition. This is unfortunate given that there is substantial interest in both the academic and practitioner communities regarding unfounded complaints in particular, but it is also recognized that omnibus surveys often have to sacrifice detail for broad scope. The 2006 complaints data were never reported on by BJS. LEMAS data were not collected as scheduled for 2010, and the 2012 collection is being processed as of this writing. Citizen Complaints The academic literature on citizen complaints can be organized in terms of studies about the receipt and processing of complaints (Brandl et al., 2001; Dugan & Breda, 1991; Griswold, 1994; Hassell & Archbold, 2010; Hickman et al., 2000; Hickman, 2006; Hudson, 1970; Independent Commission on the Los Angeles Police Department, 1991; Lersch & Mieczkowski, 1996; Liederbach et al., 2007; Littlejohn, 1981; Pate & Fridell, 1993; Wagner, 1980a, 1980b; Worrall, 2002), the characteristics of officers who are the subjects of complaints (Brandl et al., 2001; Harris, 2009, 2001; Hassell & Archbold, 2010; Hickman et al., 2000; Lersch & Mieczkowski, 1996, 2000; Liederbach et al., 2007; Pate & Fridell, 1993; Wagner, 1980a), and the characteristics of complainants (Hudson, 1970; Lersch & Mieczkowski, 1996; Liederbach et al., 2007; Pate & Fridell, 1993; Wagner, 1980b). There is also literature focused on the structural correlates of complaint volumes and dispositions, such as agency organizational characteristics, the presence of external review entities, agency policies and procedures, and community demographics (Brandl, 2001; Cao, 1999; Cao et al., 2000; Griswold, 1994; Hassell & Archbold, 2010; National Data on Police Use of Force 10 Hickman et al., 2000; Hickman 2006; Hickman & Piquero, 1999; Lawton et al., 2001; Lersch, 1998; Lersch & Mieczkowski, 1996, 2000; Shjarback, forthcoming; Walker et al., 2001; Worden et al., 2013; Worrall, 2002). Finally, there are at least two nationallevel data collection efforts (Hickman, 2006; Pate & Fridell, 1993). One of the challenges in synthesizing this literature is that police complaint processes are somewhat idiosyncratic, owing to different intake processes, unique codes of conduct, varying types and layers of decision making processes, different degrees of internal and external review, as well as differing policies and procedures, some of which are negotiated with collective bargaining units. Despite historic attempts by Presidential Commissions, the International Association of Chiefs of Police (IACP), and others during the 1970’s to encourage some degree of standardization and consistency as part of the process of formalizing police complaints and disciplinary systems, much of the idiosyncrasy that remains is tied to the individual department histories and traditions. Nevertheless, the available literature on complaint processing indicates that, in general: • • • • • • A relatively small proportion of officers are responsible for a large proportion of complaints, but this has generally been linked to arrest activity and other measures of productivity; On-view incidents and more “proactive” policing assignments may be more likely to lead to complaints than dispatched calls; Minority citizens complain in numbers disproportionately greater than their representation in the population served, and this is particularly true for black citizens; Minority officers are disproportionately the subject of citizen complaints, as well as internal (police-initiated) complaints; There is wide variation in sustain rates across agencies, some of which is attributable to structural differences, but also to idiosyncrasies in the processing of complaints; In general, sustain rates are lower for physical force complaints as compared to other types of complaints; National Data on Police Use of Force 11 • Internal (police-initiated) complaints tend to have higher sustain rates than citizen complaints. The idiosyncrasies in complaint processing noted above should give rise to concern over national level data collection efforts. This is not to say that such efforts should not be undertaken; rather, a careful program of research and development is needed in order to understand whether the data can be collected, and with what degree of validity and reliability. Probably the first national-level study of citizen complaints was conducted by Pate & Fridell (1993) for the Police Foundation. Their study focused on police use of force broadly (including agency policies and procedures, training, official reports, citizen complaints, and so forth), and collected data via an establishment survey of 1,111 agencies. 840 agencies provided data on citizen complaints about police use of force. Collectively, they reported 15,608 complaints during 1991, with rates of complaint varying by size and type of agency. Pate & Fridell (1993, p. 95) reported that minorities composed 48.4% of the population served and 58.6% of those filing complaints of excessive force among 215 city police departments. Blacks, in particular, were overrepresented, composing 21.4% of the population served but 42.3% of those filing complaints. Sustained complaints also varied by race of complainant, with black complainants accounting for 27.3% of sustained complaints. In terms of officer characteristics, black officers comprised 13.3% of sworn officers in city police departments, and 12.5% of those with citizen complaints of excessive force (in contrast, Hispanic and “other” officers were overrepresented in complaints). However, black National Data on Police Use of Force 12 officers were disproportionately represented in sustained complaints (17.3%) compared to other race/ethnicity categories. The 2003 LEMAS complaints data are referenced to calendar year 2002, and provide interesting data for researchers and for police departments. For example, large municipal police departments received a total of 22,238 citizen complaints about police use of force during 2002, corresponding to overall rates of 45 force complaints per agency, 9.5 per 100 full-time sworn officers, and 2.4 per 10,000 residents (Hickman, 2006). Eight percent of these complaints were officially sustained, meaning there was sufficient evidence to justify disciplinary action against the subject officer(s). Other dispositions included: not sustained (37%), meaning that there was insufficient evidence to prove the allegation; unfounded (25%), meaning that the complaint was not based on facts, or the reported incident did not occur; exonerated (21%), meaning that the incident occurred, but the officer’s action was deemed lawful and proper; and 9% had some other disposition, such as the complaint being withdrawn. As previously mentioned, BJS collected a second wave in 2007 (referenced to calendar year 2006) but never reported on them. Validity Concerns One commonly expressed concern about the LEMAS program is that BJS should invest more in validation research. There are of course data quality checks in place to ensure that survey responses are internally consistent, and substantial differences in quantitative data from previous iterations (primarily among large agencies) are normally National Data on Police Use of Force 13 both automatically and manually checked. Yet these checks are no match for true validation studies that assess the degree to which the data reported by agencies in LEMAS reflects reality based on some external criterion. Walker & Katz (1995) examined bias crime units in 16 municipal police departments in the central region of the U.S. These 16 agencies were selected in part because they had reported having a bias crime unit on the 1990 LEMAS survey. Walker & Katz conducted telephone interviews with the officers in charge of the bias crime units in those agencies. However, they found that only four of these agencies actually had such a unit, six other agencies had designated officers in other units to handle the bias crime function as needed, and the remainder had no unit, designated officers, or special procedures for bias crimes. Some scholars have raised concerns about the LEMAS agency and employee counts (Maguire et al., 1998; Uchida & King, 2002). Maguire et al. (1998), for example, noted discrepancies between the number of agencies and officers enumerated across the UCR, LEMAS, and data collected by the Office of Community-Oriented Policing Services, suggesting that LEMAS substantially undercounted agencies and officers in the mid-1990’s. Langworthy (2002) raised concerns about the reliability of data items pertaining to the number of patrol beats, as well as low item response rates for calls for service data. LEMAS suffers from the common problems of self-administered questionnaires (such as memory, socially desirable responding, fatigue, indifference) but also those relatively unique to establishment surveys, such as inadequate record keeping or the National Data on Police Use of Force 14 “force fitting” of agency records to match the criteria of survey items, and error attributable to an individual’s response to less quantitative items on behalf of the organization. BJS invests in pre-testing instrumentation, generally combined with focus groups comprised of law enforcement representatives (the Police Executive Research Forum was especially helpful in this regard when that organization was collecting LEMAS data for BJS, ensuring that the providers – who are also in many cases the end users – of the data understood and could provide the data being requested as well as weigh-in on the utility of the data). BJS has largely relied on the research community for assessments of validity and reliability, and BJS both learns from and responds to this research. For example, in direct response to Walker and Katz (1995), BJS modified LEMAS survey items concerning special units to incorporate expanded response options that did not force an agency into an “either-or” situation. The present study is in the same spirit and tradition of reliance on the research community for assistance in establishing data quality. The next section discusses the study methodology, and is followed by the results and a discussion of the findings. Methodology The study reported here included three phases: (1) merging the 2002 and 2006 complaints data (from the 2003 and 2007 waves of LEMAS data) for large municipal police departments and conducting basic descriptive analyses of those data; (2) assessing the reliability of the complaints data by conducting a within-agency comparison of the National Data on Police Use of Force 15 two years of data; and (3) assessment of the validity of the data using a subsample of agencies for external validation. The merging process was complicated by the fact that the agency ID fields designed by the Census Bureau and in use for several prior waves of the LEMAS survey were not used by the data collection agent in the 2007 LEMAS survey. However, data for large municipal police agencies (i.e., self-representing agencies) were successfully merged at the agency level. The study was necessarily limited to large agencies because the 2002 complaints data were collected only for these agencies whereas the 2006 data were expanded into the LEMAS sample of non self-representing agencies. Following the merging of the two waves of data, the within-agency changes across the two time points were calculated. We used a distributional rationale for identifying relatively large changes from 2002 to 2006 in both the volume of complaints and sustained complaints, as well as rates (per 100 officers). Where very large changes were observed, we attempted to explain those changes using publically available reports (such as police department annual reports to the public), any publically accessible records and/or data, as well as direct contacts with agency personnel via telephone, mail, or electronic inquiry. This approach primarily addresses reliability (the within-agency distributional difference across the two waves serves as a reasonable indicator), but also addresses validity in the assessment of the underlying reasons for substantial changes. In the third phase, a simple random sample of 100 agencies was selected for external validation of complaints data using publically available reports, records and/or data, as well as direct contacts with agency personnel via telephone, mail, or electronic National Data on Police Use of Force 16 inquiry. A key outcome is the proportion of sampled agencies for which complaints data reported to LEMAS corresponded with the external criterion, within an acceptable range (allowing that some minor differences may be expected if an agency had a large number of cases pending disposition at the time they reported data to LEMAS, and a lag between that point in time and external measures such as annual reports). Results Descriptive Analysis of Merged Waves of LEMAS data Because BJS never reported on the 2006 complaints data, and we are unaware of any other published analyses of these data, we begin by providing descriptive statistics for the merged data. While there were 496 agencies reporting complaints data in 2002, when the waves of LEMAS were merged, we found that a total of 417 agencies had reported complaints data for both 2002 and 2006. Among these 417 agencies, there was an overall increase in the total number of complaints about police use of force from 17,300 complaints in 2002, to 20,330 complaints in 2006 (Table 1). There were also increases in the overall rate of force complaints per 100 officers, per 100 officers responding to calls for service, and per 10,000 residents served. *** Insert Table 1 about here *** Overall, the change in the number of use of force complaints from 2002 to 2006 (3,030) amounts to a 17.5% increase, ranging from a 9.6% increase among agencies having 250-499 officers, up to a 55.6% increase among agencies having 100-249 officers (Table 2). While there was an overall increase in the number of full-time sworn officers National Data on Police Use of Force 17 during the same time period, there was a slight decrease in the number of officers responding to calls for service. Populations served increased 2.8% overall. The corresponding rates of complaint on an officer and resident basis increased overall among agencies in all size categories. *** Insert Table 2 about here *** We also examined complaints that were officially sustained. Among the 417 agencies, there was an overall increase in the total number of sustained complaints from 1,240 complaints in 2002, to 1,863 complaints in 2006 (Table 3). Two agencies did not report sustained complaints in 2006. Overall, the change in the number of sustained use of force complaints from 2002 to 2006 amounts to a 50.2% increase, with wide variation from 5.8% among agencies having 250-499 officers, up to 171.4% among agencies having 100-249 officers. *** Insert Table 3 about here *** Complaint sustain rates (i.e., the percentage of complaints that are sustained) were also explored. We first subtracted any complaints that were still pending a final disposition from the total number of complaints in the denominator. Overall, the sustain rate increased slightly, from 7.8% in 2002 to 9.7% in 2006. *** Insert Table 4 about here *** Analysis of Within-Agency Change We next examined the distribution of within-agency changes in the raw number of complaints across the two waves. Central tendency and dispersion statistics for the raw National Data on Police Use of Force 18 change in complaints from 2002 to 2006, by size of agency, are provided in Table 5. As can be seen, there are some extreme changes in all size categories, ranging overall from a decline of about 1,000 complaints to an increase of more than 3,000 complaints among the largest agencies. We focused on those agencies having the most extreme changes in total complaints (i.e., changes above the 90th percentile or below the 10th percentile) within categories of agency size. As previously mentioned, we attempted to explain those changes using publically available reports, records and/or data, as well as direct contacts with agencies. When we were able to directly verify the data reported for 2002 and 2006 we noted the verification numbers. More commonly, agency personnel estimated based upon their knowledge of current and historical complaint processing. We also noted the “nature of the problem” when there were discrepancies. Below we provide some case examples of specific agencies that highlight some common problems encountered, as well as the impact on overall figures in LEMAS. *** Insert Table 5 about here *** Agencies having 1,000 or more officers Among the largest agencies (those with 1,000 or more officers), six had what could be characterized as extreme changes relative to other agencies in the same size category. Erroneous data for these six agencies alone inflate the total number of complaints about police use of force reported in 2002 LEMAS data by an estimated 4,351 complaints, or 25% of the total 17,300 complaints for all agencies that reported in both National Data on Police Use of Force 19 waves of the data collection, and by 38% for agencies within the same size category. For 2006, the inflation is an estimated 4,854 complaints, or 24% of the total 20,330 reported. The largest raw increase in complaints among this agency size group was reported by the New York City Police Department (an increase of 3,213 complaints, or 72%, from 2002 to 2006). However, in comparing the reported figures for the NYPD in LEMAS with available data reported by the NYC CCRB, it is apparent that the LEMAS figures do not reflect the total number of complaints about police use of force. The NYC CCRB reports 4,612 complaints in 2002, and 7,669 complaints in 2006, involving Force, Abuse of Authority, Discourtesy, and Offensive Language (FADO). The figures reported in LEMAS are 4,450 and 7,663, for 2002 and 2006, respectively, suggesting that the NYPD likely reported the total FADO complaints from the CCRB in the LEMAS survey. The NYC CCRB reports that 2,336 complaints had at least one force allegation in 2002, and this increased to 4,159 in 2006 (an increase of 1,823 complaints, or 78%). This provides a good example of the “total vs. subset problem” (providing the total number of complaints rather than the requested subset of force complaints) and it also sheds light on the potential “cases vs. allegations problem” (complaint cases vs. allegations within complaint cases). The largest raw decrease in complaints among this agency size group was reported by the Detroit Police Department (a decrease of 1,012 complaints, or 86%, from 1,172 reported in the 2002 LEMAS to 160 reported in 2006). Communication with the Detroit Board of Police Commissioners confirms that the 1,172 figure for 2002 is approximately the total number of citizen complaints or allegations in that year (their National Data on Police Use of Force 20 records show 1,113 total complaints, and 1,154 total allegations in 2002, 160 of which were force allegations), while the 160 figure for 2006 is the accurate total use of force allegations in that year; thus there were 160 force related allegations in both years. This is an example of the “total vs. subset” problem in 2002, and the “cases vs. allegations” problem in both 2002 and 2006. This inflation will of course influence the overall rates on an agency, officer, and population basis, as well as the rates within the agency size group. For example, within the “1,000 or more” full-time sworn size group for 2002, the rates of force complaint would be revised from 357 per agency to 221; from 10.5 per 100 full-time sworn to 6.5; from 18.0 per 100 full-time sworn responding to calls for service to 11.1; and from 3.30 per 10,000 population to 2.04. Within this size group for 2006, the rates of force complaint would be revised from 397 per agency to 245; from 11.7 per 100 full-time sworn to 7.2; from 20.3 per 100 full-time sworn responding to calls for service to 12.6; and from 3.59 per 10,000 population to 2.22 (see Table 6). *** Insert Table 6 about here *** Agencies having 500-999 officers The largest raw increase in complaints among agencies of this size group was reported by the Oakland (CA) Police Department (901 complaints, or an increase of 570%). In comparing the reported figures for Oakland with available data from that agency’s Internal Affairs Division, it is apparent that the 2006 LEMAS figures for Oakland do not reflect the total number of complaints about police use of force. The National Data on Police Use of Force 21 LEMAS data indicate 158 complaints about use of force in 2002, and 1,059 such complaints in 2006. Annual reports from Oakland’s Internal Affairs Division indicate 167 for 2003 (the earliest year for which data were available), and 247 in 2006. The larger number for 2006 likely reflects the total number of all citizen complaints received in that year (reported in annual reports as 1,008), another example of the “total vs. subset problem.” The largest raw decrease in complaints in this agency size group was reported by the Albuquerque Police Department (from 364 in 2002, to 69 in 2006, or a decrease of 81%). The department was unable to confirm the LEMAS data, and they have been under investigation by the DOJ civil right division, with a recent findings letter dated April, 2014. A recent annual report indicates about 130 total complaints during a 6 month period. An older report by the Police Assessment Resource Center (PARC) indicates approximately 200 complaints per year from 1999 – 2001, and 21 allegations of excessive force in citizen complaints for 2000; 48 allegations in 2001. The 364 in 2002 is likely a total number for both internal investigations and external complaints (allegations), while the 69 in 2006 is possibly the correct external allegations of use of force. Inaccurate data for agencies reporting extreme changes in this size category inflate the total number of complaints about police use of force reported in 2002 LEMAS data by an estimated 375 complaints, and for 2006, the inflation is an estimated 942 complaints. Within the “500 to 999” full-time sworn size group for 2002, the rates of force complaint would be revised from 64 per agency to 51; from 9.2 per 100 full-time National Data on Police Use of Force 22 sworn to 7.4; from 15.0 per 100 full-time sworn responding to calls for service to 12.0; and from 2.04 per 10,000 population to 1.64. For 2006, the rates of force complaint would be revised from 78 per agency to 47; from 10.9 per 100 full-time sworn to 6.6; from 19.0 per 100 full-time sworn responding to calls for service to 11.4; and from 2.44 per 10,000 population to 1.46 (see Table 6). Agencies having 250-499 officers The Professional Standards Bureau (PSB) for the police department in Dayton, OH indicated that they had a 4-year records retention policy and that searches of paper records for 2002 and 2006 would not produce anything. A legacy computer system was able to pull some electronic data for 2006, and they reported a total of 57 citizen complaints in 2006. PSB personnel suggested that the 24 complaints about police use of force reported in LEMAS for 2006 could be accurate. With regard to the 2002 data, PSB personnel indicated that the LEMAS figure (91) was more consistent with the total officer-reported uses of force. For example, in 2006, there were 72 total officer-reported uses of force. Inaccurate data for these agencies inflate the total number of complaints about police use of force reported in 2002 LEMAS data by an estimated 620 complaints, and for 2006, the inflation is an estimated 809 complaints. Within the “250 to 499” full-time sworn size group for 2002, the rates of force complaint would be revised from 25 per agency to 17; from 7.5 per 100 full-time sworn to 5.1; from 11.6 per 100 full-time sworn responding to calls for service to 7.9; and from 1.56 per 10,000 population to 1.06. For National Data on Police Use of Force 23 2006, the rates of force complaint would be revised from 28 per agency to 17; from 7.9 per 100 full-time sworn to 4.9; from 12.3 per 100 full-time sworn responding to calls for service to 7.6; and from 1.65 per 10,000 population to 1.02 (see Table 6). Agencies having 100-249 officers Within this agency size group it was much more challenging to validate data, but there were many examples of erratic reporting, such as for the police departments in Wilmington, NC (18 complaints in 2002, but 223 in 2006) and Warner Robbins, GA (66 complaints in 2002, but just 5 in 2006). Inaccurate data for these agencies are conservatively estimated to inflate the total number of complaints about police use of force reported in 2002 LEMAS data by 273 complaints, and for 2006, the inflation is an estimated 1,140 complaints. Within the “100 to 249” full-time sworn size group for 2002, the rates of force complaint would be revised from 7 per agency to 6; from 4.9 per 100 full-time sworn to 4.2; from 7.6 per 100 full-time sworn responding to calls for service to 6.6; and from 0.87 per 10,000 population to 0.75. For 2006, the rates of force complaint would be revised from 11 per agency to 7; from 7.3 per 100 full-time sworn to 4.7; from 11.5 per 100 full-time sworn responding to calls for service to 7.4; and from 1.32 per 10,000 population to 0.84 (see Table 6). The net effect for the BJS complaints data is substantial inflation in both the 2002 and 2006 waves. For 2002, the rates of force complaint would be revised from 41 per agency to 28; from 8.8 per 100 full-time sworn to 5.9; from 14.4 per 100 full-time sworn National Data on Police Use of Force 24 responding to calls for service to 9.8; and from 2.17 per 10,000 population to 1.47. For 2006, the rates of force complaint would be revised from 49 per agency to 30; from 10.1 per 100 full-time sworn to 6.3; from 17.0 per 100 full-time sworn responding to calls for service to 10.5; and from 2.48 per 10,000 population to 1.54 (see Table 6). Random Sample for External Validation Focusing only on those agencies having relatively extreme within-agency changes will of course mask more subtle inaccurate variations in reported data for other agencies. For this reason, we selected a random sample of 100 agencies for validation. Of the 100 agencies contacted, 39 were actually able to fulfill our data request. Twenty-seven agencies reported that they purged their records due to record retention laws, or citizen complaints were not recorded during the years investigated. Despite extensive follow-up, 31 agencies were unable to fulfill our request during the study period because of limited resources and/or backlogs of public data requests, or agencies were simply non responsive to correspondence attempted by electronic inquiry, mail, or telephone contact. Finally, three of the 100 agencies explicitly refused to participate in the study. Among agencies able to provide data, the data received only rarely matched the data reported in LEMAS. In fact, only three of the 39 agencies reported complaints data that matched LEMAS data for both years; another ten reported data that matched one of the two years. Sixteen of the remaining 26 agencies reported data that were either 50% higher or lower than the data reported in LEMAS, ranging from an under-count of 89 to an over-count of 82. The net effect was inflation in both years (119 complaints in 2002, National Data on Police Use of Force 25 or 19% of the total complaints reported by these agencies; and 64 complaints in 2006, or 10% of the total reported by these agencies). Discussion The problems encountered in this study of citizen complaints point to serious measurement concerns. Agencies in 2002 were asked to “Enter the current dispositions for all formal citizen complaints received during 2002 regarding use of force” and were provided with response blanks to report the total number of complaints, as well as those that were unfounded, exonerated, not sustained, sustained, pending, or had some other disposition. In 2006, agencies were asked about complaints using the exact same wording; however the response categories were limited to total, sustained, pending, or other disposition. Clearly, the item wording is not sufficiently precise, or is not being interpreted and used by respondents as intended, to yield valid and reliable measurement. The types of problems we encountered are listed below, with some agencies having one or more of the listed problems, in one or both years of reported data: • • • • • • Reporting total citizen complaints rather than the subset involving use of force; Combining citizen complaints with internal complaints; Combining or replacing citizen complaints with officer reported uses of force; Reporting total force allegations within complaint cases, rather than cases involving any force allegation; Reporting total complaints investigated, rather than complaints received; Undetected data entry error (either agency or data collection agent). In sum, the findings of this study indicate that the LEMAS data on citizen complaints about police use of force suffer from serious, if not fatal, measurement flaws. National Data on Police Use of Force 26 The LEMAS data on citizen complaints do not provide a valid and reliable basis for comparative statistical reporting and research purposes, and should not be used for these purposes. The LEMAS data also should not be relied upon for purposes of litigation involving the conduct of law enforcement agencies. Recent Monell litigation points to increasing reliance upon on statistical evidence of police organizational wrongdoing (Futterman et al., 2008). Plaintiffs must show that they suffered a deprivation of their Constitutional rights, that it was caused by some policy or custom of the city to act or fail to act, and the action or failure to act was a result of “deliberate indifference” to the plaintiff’s rights. Increasingly, lawyers are turning to statistical arguments in support of a policy or custom and/or in support of arguments about deliberate indifference. The City of Chicago recently experienced a wave of litigation in this style using the BJS complaints data, where it was argued that since their complaint sustain rate was lower than the baseline in the BJS data, the City was not adequately policing itself, and this contributed to an environment in which officers acted with impunity. The present study shows that the BJS data do not provide a valid and reliable basis for this kind of comparative analysis. With the passage of the 1994 Violent Crime Control and Law Enforcement Act, the U.S. Department of Justice was granted authority to pursue civil litigation against police departments that display a “pattern or practice” of Constitutional violations, including use of excessive force (42 USC 14141). This is an important and powerful mechanism, and a necessary check on police behavior that helps to ensure that the police are held accountable to the public. But there is no clear context for these investigations, National Data on Police Use of Force 27 and it remains unclear what constitutes a pattern or practice of use of excessive force. As previously noted, the same Act legally required the Attorney General to collect and publish annual summaries of data on use of excessive force (42 USC 14142). Perhaps the intent of this pair of statutes was to enable the rational investigation of police use of force, as the data collected under 14142 could provide an empirical basis for pattern or practice investigations carried-out under section 14141. However, in the findings letter issued following their recent investigation of the Albuquerque Police Department, the Civil Rights Division opines that the law does not require statistical evidence or a specific number of incidents or acts in order to find a pattern or practice of use of excessive force. Yet, they noted in their investigation that fatal police shootings were statistically high for a city of that size. In the roughly twenty years since the passage of the 1994 Crime Act, there has been little significant progress toward the annual reporting requirement. Absent substantial political will and resources, it may be that the Federal government will simply not be the leader on national data collection regarding police use of force. A strict reading of 42 USC 14142 reveals no requirement that the Federal government take the lead role, or any particular role, in the design or execution of primary data collection on police use of excessive force. The U.S. Attorney General could satisfy the requirement by compiling and reporting on various government sponsored and non-government initiated efforts. Perhaps privately funded, citizen-led, or other grassroots efforts will lead the way on national data collection. For example, the Cato Institute’s National Police Misconduct National Data on Police Use of Force 28 Statistics and Reporting Project (www.policemisconduct.net) is based upon media reports of police misconduct incidents. In their latest annual statistical report (2010), they reported tracking 4,861 incidents involving 6,613 officers; about one quarter of the officers were involved in excessive force reports. The NPMSRP misconduct data were recently used as the dependent variable in an agency-level analysis reported by Eitle et al. (2014). Conclusion The results of this study suggest that much work remains to be done on collecting national data about police use of force both in general and specifically with regard to citizen’s complaints. Lest we seem overly critical of the federal efforts, it is important to also note that the President has empaneled a Task Force on 21st Century Policing, and that panel has already held hearings and may soon issue findings as this is being written. The Task Force is likely to take-up the issue of national data on police use of force in their future meetings. For its part, BJS is already planning a meeting in April, 2015, that will once again bring academics, police practitioners, and others together to assist in determining what types of data should be collected and how best to proceed. It is somewhat disheartening that it takes high profile incidents like those in Ferguson, MO, and New York to motivate political leadership on these issues, but it is critical to maintain the pressure and momentum if the legally mandated goal of annual national statistics on police use of excessive force is to be satisfied. National Data on Police Use of Force 29 BJS has discontinued the collection of citizen complaints data in LEMAS. This is perhaps unfortunate from a research and development perspective, since the collection of these data could be improved with additional work. 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Police employee data: Elements and validity. Justice Research & Policy, 4:11-19. Wagner, A. (1980a). Citizen complaints against the police: the complainant. Journal of Police Science and Administration, 8, 247-252. ---. (1980b). Citizen complaints against the police: the accused officer. Journal of Police Science and Administration, 8, 373-377. Walker, S., & C. Katz. (1995). Less than meets the eye: Police department bias-crime units. American Journal of Police, 14:29-48. Worrall, J. (2002). If you build it, they will come: Consequences of improved citizen complaint review procedures. Crime & Delinquency, 48, 355-379. National Data on Police Use of Force 35 Table 1. Citizen complaints about police use of force, 2002 and 2006, by number of full-time sworn (agencies reporting in both waves only) 2002 Full time sworn Number of agencies Number of FTS FTS responding to CFS Population 2003 Total complaints Complaints per agency Per 100 FTS Per 100 FTS CFS Per 10,000 pop Total 417 197,671 119,790 79,677,197 17,300 41 8.8 14.4 2.17 1,000 or more 500 – 999 250 – 499 100 – 249 32 30 76 279 109,255 20,816 25,783 41,817 63,632 12,761 16,663 26,734 34,622,295 9,372,281 12,353,960 23,328,661 11,424 1,912 1,930 2,034 357 64 25 7 10.5 9.2 7.5 4.9 18.0 15.0 11.6 7.6 3.30 2.04 1.56 0.87 Number of FTS FTS responding to CFS Per 100 FTS Per 100 FTS CFS 200,457 119,525 2006 Full time sworn Total Number of agencies 417 Population 2007 Total complaints 81,936,925 1,000 or more 32 108,580 62,457 35,393,317 500 – 999 30 21,505 12,348 9,644,348 250 – 499 76 26,853 17,198 12,839,674 100 – 249 279 43,519 27,522 24,059,586 Note: Full-time sworn categories for 2006 are based upon 2003 LEMAS designation. Complaints per agency Per 10,000 pop 20,330 49 10.1 17.0 2.48 12,698 2,351 2,116 3,165 397 78 28 11 11.7 10.9 7.9 7.3 20.3 19.0 12.3 11.5 3.59 2.44 1.65 1.32 National Data on Police Use of Force 36 Table 2. Percentage change in personnel, population served, and numbers and rates of use of force complaints, 2002-2006 Full time sworn Number of FTS FTS responding to CFS Population Total complaints Complaints per agency Per 100 FTS Per 100 FTS CFS Per 10,000 pop Total 1.4% -0.2% 2.8% 17.5% 17.5% 15.9% 17.8% 14.3% 1,000 or more 500 - 999 250 - 499 100 - 249 -0.6 3.3 4.2 4.1 -1.8 -3.2 3.2 2.9 2.2 2.9 3.9 3.1 11.2 23.0 9.6 55.6 11.2 23.0 9.6 55.6 11.8 19.0 5.3 49.5 13.2 27.1 6.2 51.1 8.7 19.5 5.5 50.9 National Data on Police Use of Force 37 Table 3. Sustained complaints, 2002 and 2006 - agencies reporting 2006 data only 2002 Full time sworn Total 1,000 or more 500 - 999 250 - 499 100 - 249 2006 Full time sworn Total Total sustained complaints Complaints per agency Per 100 FTS Per 100 FTS CFS Per 10,000 pop 1,240 3 0.6 1.0 0.16 612 193 274 161 19 6 4 1 0.6 0.9 1.1 0.4 1.0 1.5 1.6 0.6 0.18 0.21 0.22 0.07 Total sustained complaints 1,863 Complaints per agency Per 100 FTS 4 Per 100 FTS CFS 0.9 Per 10,000 pop 1.6 1,000 or more 845 27 0.8 1.4 500 - 999 291 10 1.4 2.4 250 - 499 290 4 1.1 1.7 100 - 249 437 2 1.0 1.6 Note: Full-time sworn categories for 2006 are based upon 2003 LEMAS designation. Two agencies did not report sustained complaints in 2006. 0.23 0.24 0.30 0.23 0.18 National Data on Police Use of Force 38 Table 4. Complaint sustain rates, 2002 and 2006 2002 Total complaints Total pending Total sustained complaints Sustain rate Total 17,300 1,334 1,240 7.8 1,000 or more 500 - 999 250 - 499 100 - 249 11,424 1,912 1,930 2,034 1,028 130 114 62 612 193 274 161 5.9 10.8 15.1 8.2 Total complaints Total pending Total sustained complaints Sustain rate 20,330 1,054 1,863 9.7 Full time sworn 2006 Full time sworn Total 1,000 or more 12,698 315 845 6.8 500 - 999 2,351 450 291 15.3 250 - 499 2,116 116 290 14.5 100 - 249 3,165 173 437 14.6 Note: Full-time sworn categories for 2006 are based upon 2003 LEMAS designation. Two agencies did not report sustained or pending complaints in 2006. National Data on Police Use of Force 39 Table 5. Descriptive statistics for raw change in total complaints, 2002-2006, by number of full-time sworn Full time sworn Agencies Mean Median SD Min 10 25 Percentiles 50 75 90 Max Total 417 7 0 183 -1012 -19 -5 0 4 28 3213 1,000 or more 500 – 999 250 – 499 100 – 249 32 30 76 279 40 15 2 4 -35 -2.5 -1 0 636 184 54 24.5 -1012 -295 -200 -61 -217 -104 -24 -7 -99 -16 -10 -3 -35 -2.5 -1 0 9 15.5 10 4 324 105 38 15 3213 901 229 205 National Data on Police Use of Force 40 Table 6. Revisions to 2002 and 2006 complaints data when extreme agencies are corrected (corrected figures in parentheses) 2002 Number of FTS FTS responding to CFS 417 197,671 119,790 79,677,197 1,000 or more 32 109,255 63,632 34,622,295 500 - 999 30 20,816 12,761 9,372,281 250 - 499 76 25,783 16,663 12,353,960 100 - 249 279 41,817 26,734 23,328,661 Number of FTS FTS responding to CFS 417 200,457 119,525 81,936,925 1,000 or more 32 108,580 62,457 35,393,317 500 - 999 30 21,505 12,348 9,644,348 250 - 499 76 26,853 17,198 12,839,674 100 - 249 279 43,519 27,522 24,059,586 Number of agencies Full time sworn Total 2006 Full time sworn Total Number of agencies Population 2003 Population 2007 Note: Full-time sworn categories for 2006 are based upon 2003 LEMAS designation. Total complaints 17,300 (11,681) 11,424 (7,073) 1,912 (1,537) 1,930 (1,310) 2,034 (1,761) Complaints per agency Per 100 FTS 8.8 (5.9) 10.5 (6.5) 9.2 (7.4) 7.5 (5.1) 4.9 (4.2) Per 100 FTS CFS 14.4 (9.8) 18.0 (11.1) 15.0 (12.0) 11.6 (7.9) 7.6 (6.6) Per 10,000 pop 2.17 (1.47) 3.30 (2.04) 2.04 (1.64) 1.56 (1.06) 0.87 (0.75) Total complaints 20,330 (12,585) 12,698 (7,844) 2,351 (1,409) 2,116 (1,307) 3,165 (2,025) Complaints per agency Per 100 FTS 10.1 (6.3) 11.7 (7.2) 10.9 (6.6) 7.9 (4.9) 7.3 (4.7) Per 100 FTS CFS 17.0 (10.5) 20.3 (12.6) 19.0 (11.4) 12.3 (7.6) 11.5 (7.4) Per 10,000 pop 2.48 (1.54) 3.59 (2.22) 2.44 (1.46) 1.65 (1.02) 1.32 (0.84) 41 (28) 357 (221) 64 (51) 25 (17) 7 (6) 49 (30) 397 (245) 78 (47) 28 (17) 11 (7)