HomeMy WebLinkAboutStaff Report 14472
City of Palo Alto (ID # 14472)
City Council Staff Report
Meeting Date: 6/20/2022 Report Type: Information Reports
City of Palo Alto Page 1
Title: Police Response to OIR Report
From: City Manager
Lead Department: Police
Recommendation
This is an informational report, and no Council action is required.
Background
Since 2006, OIR Group has been contracted by the City of Palo Alto to act as an Independent
Police Auditor (IPA). The IPA provides an independent review of qualifying administrative
investigations and public complaints investigated by the Palo Alto Police Department, publishes
a bi-annual report reviewing those investigations, and gives recommendations on ways to
improve investigative processes and department practices.
On February 14, 2022, the IPA presented the December 2020-2021 report to the Council.
On March 14, 2022, Council requested the Department prepare written responses to the IPA
recommendations. In the future, Department responses will be published as an addendum to
the IPA report. For the December 2020-2021 report, which has already been published, the
Department is providing these responses as an informational item to the Council.
Discussion
The Department reviewed the IPA recommendations in detail and consulted with the IPA and
appropriate staff members about them. In most cases, the Department agreed with the IPA’s
recommendations and modified existing policies or procedures accordingly. The Department
addresses its responses to each of the IPA recommendations in the attached document. In the
interest of public awareness, the Department publishes an updated version of its policy manual
on the Department’s website on a quarterly basis. The next quarterly publication is scheduled
to occur in August 2022.
Attachments:
• PAPD Response to Dec 2020-2021 IPA Recommendations
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DATE: MAY 26, 2022
TO: ED SHIKADA, CITY COUNCIL
FROM: ASSITANT CHIEF ANDREW BINDER
SUBJECT: POLICE DEPARTMENT RESPONSE TO DEC 2020-2021 IPA RECOMMENDATIONS
RECOMMENDATION ONE: PAPD should go beyond a “letter of the law” assessment when evaluating an
allegation that an officer used his discretion in a retaliatory or otherwise improper fashion.
The Department agrees that if there is an allegation an officer used their discretion in a retaliatory or
otherwise improper fashion, the Department should interview the officer to determine intent and
rationale for the officer’s actions instead of solely relying on the “letter of the law” to reach a conclusion
on the officer’s conduct.
RECOMMENDATION TWO: PAPD should address allegations of officer misconduct in straightforward and
timely ways, apart from concerns about parallel proceedings that may involve some of the same
concerns.
The Department agrees with this recommendation and has revised its administrative procedures to
reflect the Department’s commitment and expectation for the prompt resolution of all administrative
matters while remaining mindful of parallel court proceedings.
RECOMMENDATION THREE: PAPD should prioritize the timely resolution of cases, and should hold
managers accountable as needed to ensure that this occurs.
The Department agrees with this recommendation and will continue to balance the prioritization of the
timely resolution of administrative cases with other critical department operations as personnel capacity
allows.
RECOMMENDATION FOUR: PAPD should advise its members of the apparent need to obtain a blood
draw in order to support a successful prosecution and consider changing policy to require it in cases
involving suspected driving while intoxicated (marijuana or other drugs).
The Department agrees with advising its officers of the importance in obtaining a blood sample or other
biological (urine) sample when it can be lawfully obtained in support of a successful prosecution. This has
been accomplished via a department training memorandum.
RECOMMENDATION FIVE: PAPD should ensure, through documentation, that any recommended verbal
counseling does in fact occur.
The Department agrees with this recommendation and has created an Administrative Investigation
Disposition memorandum which documents departmental action taken as part of an administrative
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investigation. This memorandum is provided to the involved officer and retained in the administrative
case file once the investigation has been completed.
RECOMMENDATION SIX: PAPD should determine how a body-worn camera should be placed that would
still successfully video events when wearing a traffic vest and import that knowledge to the involved
officer and the Department as a whole.
The Department agrees with this recommendation and has revised the Police Policy Manual to address
its expectations for wearing body-worn cameras in conjunction with other articles of clothing so that it is
able to successfully capture events.
RECOMMENDATION SEVEN: The Department should assign two investigators to key interviews in its
internal affairs cases, and at a minimum should ensure such staffing for the interview of the subject
employee.
The Department agrees with this recommendation and has revised its administrative procedures to
ensure that two investigators be assigned to key interviews. Although it was not the case for all
interviews related to the reviewed investigation, the Department’s typical practice has always been to
assign two investigators to such interviews.
RECOMMENDATION EIGHT: PAPD should revise its force review protocols to instruct supervisors that
when an initial attempt at a subject interview is not productive as a result of an observed physical or
mental condition, the reviewer should attempt to re-interview the subject at a later, more favorable
time, or document why such an attempt was not made.
The Department agrees with this recommendation and has revised the Police Policy Manual to ensure
investigators attempt to re-interview a subject if the initial attempt to interview is not productive or
document why such an attempt was not made.
RECOMMENDATION NINE: PAPD should develop protocols to ensure that body-worn camera evidence
of any reportable force be reviewed by the supervisor assigned the force review close in time to the
date of the incident.
The Department agrees with this recommendation and has revised the Police Policy Manual to ensure
body-worn camera evidence of any reportable force as part of a force review is reviewed by a supervisor
or manager close in a timely manner.
RECOMMENDATION TEN: PAPD should ensure that in force cases for which there is a seeming
discrepancy in the evidence (as in gaps between officer versions, or between reports and body-worn
camera footage), the review is elevated to a formal internal affairs investigation.
The Department agrees with this recommendation. In the reviewed investigation, the Department did
not find any apparent discrepancy and the video evidence was comprehensive, so no further
investigation was deemed necessary.
RECOMMENDATION ELEVEN: PAPD should revise its protocols to ensure that PAPD personnel assigned
to administrative investigations attempt to interview all civilian victims and witnesses, even when they
are represented by counsel.
The Department agrees with this recommendation and has revised its administrative procedures to
ensure that administrative investigators attempt to interview civilian victims and witnesses, even when
represented by counsel and if no interview occurs, provide an explanation as to why.
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RECOMMENDATION TWELVE: PAPD should advise those assigned to conduct internal investigations that
witness officers to any force incident should be interviewed, if possible, even if they are employed by
another police agency.
The Department agrees that in situations in which a force incident occurs relevant witness officers should
be interviewed when feasible but recognizes that, in some cases, comprehensive video evidence may
obviate the need to interview all officers present.
RECOMMENDATION THIRTEEN: During internal investigations into uses of force, PAPD should retrieve
and review any body-worn cameras of other agency witness officers.
The Department agrees that as part of an administrative force investigation, supervisors should attempt
to obtain and review body-worn camera footage of non-PAPD witness officers and has revised the Police
Policy Manual.
RECOMMENDATION FOURTEEN: Per its stated intent, PAPD should modify its policy requiring officers to
contact residents of yards prior to searching, ensuring that specific questions are asked about potential
individuals in the back yard, the Department’s intent to deploy a K-9, an advisement to residents to stay
inside during the search, and a follow up contact when the search has been completed.
The Department agrees that, when time and circumstances allow, officers should contact residents of
yards prior to searching, ensuring that specific questions are asked about potential individuals in the
back yard, the Department’s intent to deploy a K-9, an advisement to residents to stay inside during the
search, and a follow up contact when the search has been completed and has revised the Police Policy
Manual to reflect this.
RECOMMENDATION FIFTEEN: The K-9 handler and PAPD cover officer should be counseled on the
importance of identifying themselves as police officers during any attempts at apprehension.
The Department agrees with this recommendation and has revised the Police Policy Manual to expressly
reflect the Department’s existing expectation for officers to identify themselves prior to the use of force.
RECOMMENDATION SIXTEEN: PAPD should revise policy to ensure that any post-incident interview of a
person subjected to a K-9 deployment be handled by a supervisor.
Department policy already provides that any post-incident administrative interview of a person subjected
to a K-9 deployment be handled by a supervisor. Consistent with best practices, the Department will
continue to allow the investigating officer to conduct post-incident interviews of a person subjected to a
K-9 deployment in a professional manner unless circumstances provide that such interview is best
handled by a supervisor.
RECOMMENDATION SEVENTEEN: PAPD should advise all members of the K-9 program (including the
involved officer in this incident) that even when formal announcements are not practicable, officers
should provide a modified warning so that the subject and other potential uninvolved individuals are
advised of the impending intent to deploy the police dog.
The Department agrees that when formal announcements are not practical, officers should provide a
modified warning of the impending intent to deploy the police dog once circumstances make it feasible
to do so. This has been addressed in the Police Policy Manual.
RECOMMENDATION EIGHTEEN: PAPD should follow through where possible on obtaining relevant
photographs of injuries and medical records in force cases resulting in hospital visits.
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The Department agrees with this recommendation and has revised the Police Policy Manual to ensure
that officers should follow through where possible on obtaining relevant photographs of injuries and
attempt to obtain medical records in force cases resulting in hospital visits.
RECOMMENDATION NINETEEN: PAPD supervisors should refrain from going beyond the involved
officer’s own claims in justifying force through the listing of possible threat-based rationales.
The Department agrees with this recommendation and has revised is administrative procedures to reflect
the refrain of supervisory actions beyond the officer’s own claims in justifying force.