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HomeMy WebLinkAboutStaff Report 2603-6187CITY OF PALO ALTO CITY COUNCIL Special Meeting Monday, June 15, 2026 Council Chambers & Hybrid 5:30 PM     Agenda Item     B.Independent Police Auditor's (IPA) Report of Review of Investigations as of November 2025 and Police Department Use of Force Report for June 1, 2025 – November 30, 2025 City Council Staff Report From: City Manager Report Type: INFORMATION REPORTS Lead Department: City Manager Meeting Date: June 15, 2026 Report #:2603-6187 TITLE Independent Police Auditor's (IPA) Report of Review of Investigations as of November 2025 and Police Department Use of Force Report for June 1, 2025 – November 30, 2025 RECOMMENDATION Staff recommends that the City Council and public receive this informational report with the most recent report from OIR Group attached. BACKGROUND AND ANALYSIS Since 2006, Palo Alto has utilized an Independent Police Auditor (IPA) to conduct secondary review of certain investigations of uniformed Police Department personnel and provide related services. Since the inception of the independent police auditing program, the City has contracted with the Office of Independent Review (OIR Group), to provide these services. The following report transmits the Independent Police Auditor (IPA) Report on Investigations Completed as of November 30, 2025. For reference, the prior IPA report was published November 2025 as an Informational report.1 The Police Department’s website lists all past Independent Police Auditor Reports, here2. Attachment A contains the current IPA report for investigations completed as of November 2025. Per Council direction, the Police Department also shares use of force information through a report provided alongside each IPA report, included here as Attachment B and covers the time period of June – November 2025. The Police Department’s responses to the IPA report recommendations are included here as Attachment C. 1 1 Independent Police Auditor's (IPA) Report of Review of Investigations as of May 2025 and Police Department Use of Force Report for January - May 2025. Link: https://www.paloalto.gov/files/assets/public/v/1/police- department/accountability/ipa-reports/may-2025-independent-police-auditor%E2%80%99s-report-and-papd-use- of-force-report.pdf 2 Palo Alto Police Department Accountability Webpage: https://www.cityofpaloalto.org/Departments/Police/Accountability Independent Police Auditor Reports Webpage: https://www.cityofpaloalto.org/Departments/Police/Accountability/Independent-Police-Auditor Consistent with standing practice, this report is issued as informational for the Council and the public. In light of heavy Council agendas through the end of the fiscal year, staff has not scheduled a study session with OIR Group at this time. Staff will work to schedule an OIR study session with the Council after the Council break. The study session can also include discussion of OIR’s proposed audit scope of work related to Flock cameras. FISCAL/RESOURCE IMPACT STAKEHOLDER ENGAGEMENT ENVIRONMENTAL REVIEW ATTACHMENTS APPROVED BY: INDEPENDENT POLICE AUDITORS’ REPORT Review of Investigations Completed as of 11-30-25 Presented to the Honorable City Council City of Palo Alto 2026 Prepared by: Michael Gennaco and Stephen Connolly Independent Police Auditors for the City of Palo Alto Introduction This is the latest semi-annual report by the Independent Police Auditor for the City of Palo Alto. It primarily covers cases for which the Palo Alto Police Department ("PAPD", or "The Department") completed its internal investigation and review process; it also includes discussions of two older use of force incidents that resulted in injury, became the subject of potential civil litigation, and are now resolved. OIR Group's relationship with the City dates back nearly two decades now ,1 but our current scope of work was established within the last four years. It involves the evaluation of confidential investigative files across a few categories: allegations of misconduct against PAPD officers (whether initiated by the Department itself or a public complaint), physical force incidents involving a certain level of seriousness (including all Taser deployments), and all instances in which one o r more officers point a firearm at a subject. While we do not conduct our own investigations into these matters, our arrangement with the City ensures that we have full access to the Department's own work product, including body-worn camera recordings from involved personal as well as reports, photos, interviews, and other evidentiary materials. This allows us to make informed determinations about the legitimacy and effectiveness of PAPD's processes. In this reporting cycle, we looked at four completed misconduct cases and five force incidents. There were two sustained allegations. The first was for falling below the agency's expected "Standards of Conduct" while remotely viewing a court proceeding. The other, which emerged from the Department's own identification of an ancillary issue during a complaint review, related to the officer's failure to properly notify the driver of the reason for the stop at the outset of the contact. PAPD found that the other allegations covered here were not supported by the evidence. We concurred with each of those findings, and discuss our rationale below. The report also covers five force incidents, three which involved minor injury only and for which the officers' actions were found to be justified. The other two involved, respectively, a broken arm and a bite wound from a police canine that occurred during the apprehension of an assault subject. The force was also deemed "in policy" for these cases – an outcome we agreed with, but with reservations. 1 Based in southern California, OIR Group is a team of police practices experts that has worked in the field of civilian oversight of law enforcement since 2001. It has provided a range of auditing, review, and investigative services for numerous jurisdicti ons in California and in several other states. More information about our work, including dozens of public reports, is available at www.oirgroup.com 3 The four "pointed firearm" cases in this Report's pool were all considered by the Department –and us– as being consistent with policy and training. At the same time, PAPD management continued its practice of using these incidents as opportunities to evaluate performance more broadly, and intervene where individual shortcomings or other issues were noted. The agency's supervisorial assessment of "p -gun" cases is a relatively new responsibility that it has taken on – and not something that is universally tracked in the different jurisdictions with which we are familiar. After some initial challenges in both capturing all the relevant encounters and maximizing the broader benefit of reviewing them, the Department has evolved quite effectively in both areas. While that is a favorable development, some of our encouragement was dampened by noticing that each incident involved at least one lapse in body -worn camera activation by an on-scene officer (though not always the weapon -pointer). We urge the Department to continue its focus on this issue, which we also identified in our last Report. As in the past, the Department continues to be professional and constructive in its approach to our responsibilities. Along with ensuring that we have the materials that we need, responding to the substantive questions that arise during our review cycles, and keeping us apprised of significant developments within the agency on a regular basis, PAPD remains receptive to our feedback in ways that have resulted in demonstrable changes to its operations. We appreciate all of the above. 4 Investigations into Allegations of Misconduct Case 1: Concerns about Different Aspects of Detention Factual Overview PAPD received a report of a man intentionally striking a female with his car. An officer responded to the location and began talking to the alleged victim. At that point, the victim identified the subject in a passing car. The officer flagged down the car, the man exited, and the officer requested identification. The man said that he did not speak English and requested a Spanish-speaking officer. The man asked to wait until the Spanish speaking officer arrived before producing identification. The officer then detained the man and placed him into handcuffs. Eventually, the alleged assault could not be established based on the initial investigation, and the man was released at the scene. The case was presented to the District Attorney, who declined to file charges. PAPD Investigation The man filed a complaint against the officer alleging that he was wrongfully treated in the following ways: • Unlawful detention: No legal basis to stop him • Failure to state reason for detention • Inappropriate use of force • Damage to cell phone PAPD assigned an investigator to the complaint, and that person performed a robust investigation. It determined that there was a legal basis to detain the man for a possible assault investigation. The investigation further found that the control holds used by the officer were within policy and that there was no proof that the cell phone had been damaged during the detention.2 PAPD also examined – and refuted – additional complaints by the man: • That the officer lied to the supervisor who had arrived on scene. The investigation revealed that the man was not within earshot when the officer and the supervisor conversed. 2 Despite several efforts at outreach and inquiry with the complainant, the investigator was not able to establish any damage to the cell phone. The man advised that he had shipped the phone to a foreign country for repairs but did not produce any corroborating information. 5 • That the officer refused to move him out of the sun. The body-worn camera evidence revealed that the officer did move the man out of the sun. • That the officer refused to adjust the man’s handcuffs. The body-worn camera shows that the officer did adjust the man’s handcuffs. • That the wait for a supervisor was excessively long. The body-worn camera footage showed the wait was approximately 13 minutes – not the 40 alleged. While the complainant's various assertions of wrongdoing were mostly not substantiated, PAPD found, as alleged, that the officer had failed to provide the man the reason for detaining him. This was in violation of both Department policy and recent state l aw. PAPD's scrutiny of the matter also identified peripheral shortcomings in the officer's performance, which it incorporated into the review. These include a finding that the officer had failed to synch up the personal body-worn camera with the cameras in the patrol vehicle, as required by policy. Finally, PAPD found that the officer performed in a manner inconsistent with best practices and training when moving to detain the man prior to a back-up officer arriving. In response, PAPD recommended that the officer’s supervisor conduct a training debrief on the issues that were found to be out of policy or contrary to training . Documentation of that training was also included in the file. IPA Review IPA reviewed all of the investigative materials developed during PAPD’s investigation and concurred with the findings of PAPD. The investigation and subsequent analysis w ere rigorous. The recent state law referenced is found at Vehicle Code 2806.5. Effective January 1, 2024, the law requires that in most cases: A peace officer making a traffic or pedestrian stop, before asking any questions, shall state the reason for the stop. The officer shall document the reason for the stop on any citation or police report resulting from the stop. Because of the recency of this law, all PAPD officers should be regularly reminded of the need to advise detainees consistent with this new legal requirement that is intended to alleviate concerns about bias-based policing. RECOMMENDATION ONE: PAPD should send out a reminder to all officers reminding them of the need to advise detainees of the reason for any stop. In its review, IPA particularly appreciated PAPD going beyond the four corners of the complainant’s allegations and identifying performance deficiencies based on its review of 6 the incident. As a result, PAPD was able to develop a more robust and effective intervention for the officer to address all of the performance, training, and policy issues. Case 2: Complaint Regarding Disruption of Court Proceeding Factual Overview PAPD was the investigating agency in an alleged homicide/arson case that resulted in a conviction several years ago – only to become the subject of extended appeals and an eventual re-trial. When that second proceeding had reached the point where the jury verdict was being announced, the court afforded certain parties (including some PAPD personnel) the opportunity to observe the outcome remotely. Admonishments to leave cameras and microphones off were included with the emailed link. The verdict turned out to be "Guilty" – at which point both a cheer and a shout of "Screw that guy!" were audible in the courtroom. The judge responded by directing the remote feed to be disconnected. That disruption received media attention in the subsequent covering of the event, which in turn prompted a complaint from a member of the public (who contacted our office in an effort to initiate the process). Aware that the responsible person was a PAPD member, the Department opened an internal investigation into the incident. PAPD Investigation The review was quite straightforward. The facts were not in dispute, and the involved individual (who is a PAPD supervisor) had apologetically contacted an executive manager in the agency to share an online article about the incident within hours of its o ccurrence. It was determined that the supervisor's failure to mute the computer program's microphone feature had been inadvertent. Nonetheless, the Department found that its policy regarding "Standards of Conduct" had been violated. The accompanying memorandum cited the expectation that court proceedings be viewed quietly and with decorum – even in a virtual context. It also discussed the ways in which the episode had distracted from the verdict itself, and had led to an abrupt termination of remote access for numerous interested individuals. These negative impacts reflected poorly on PAPD . IPA Review IPA concurred with the Department's handling of this matter. Though the complaint from the public was an overlapping impetus, it seemed clear that PAPD leadership had already recognized the ways in which the incident merited formal review and accountabili ty. The resulting investigation was efficient and effective – as facilitated by the manner in which the subject supervisor accepted responsibility from the outset. 7 Supervisory Inquiry Investigations Case 1: Allegation of Inappropriate Threat to Arrest Factual Overview PAPD responded to a call from a local convenience store regarding a man who was using the hot water to heat up food he brought from the outside. After a brief conversation with the clerk, the officer identified the man and asked him to go outside the store. The man complied but said that his primary language was Spanish. The officer used the translation service to assist in conversing with the man. During the conversation, the officer repeatedly advised the man that the store was a “private business” and that it had the discretion to remove any patron who it did not want on the premises. The officer further advised the man not to return to the store and if he did, he could be arrested. The conversation ended and the man went on his way. After the incident, the man filed a complaint with PAPD, alleging that the officer had threatened him with arrest for exercising his right to use the store’s hot water. PAPD Review PAPD reviewed the encounter and talked with the involved officer. It found that while the officer mistakenly referred to the convenience store as a “private business ,” the underlying message to the complainant about the ability of store employees to request patrons to leave was correct. PAPD noted that the officer had indeed advised the man that if he returned to the store, he was subject to arrest, but did not view the advisement as a threat or somehow improper. Accordingly, PAPD found that the man’s allegations were without merit. IPA Review IPA reviewed the investigative materials and concurred with PAPD’s findings. The officer’s confusion about “private” and “public” businesses was not material to the larger question of whether the treatment of the complainant was improper. Still, it was appropriately addressed during the initial conversation with the officer and an immediate supervisor. 8 Case 2: Various Allegations of Misconduct Related to Arrest Factual Overview The complainant in this case was an adult woman who was arrested for multiple warrants at the end of an encounter with PAPD officers that lasted for several minutes. A few months after the incident, she submitted a written complaint on the Department website, in which she challenged several aspects of the officers' behavior and the consequences of her arrest. (These had included the impounding of her van and the alleged taking of property from it, and the loss of three dogs who were taken by Animal Control .) Officers had originally focused on the woman because of outreach by neighbors, who claimed she was spending time inside a condemned residence and behaving erratically. 3 Officers also learned that an adjoining jurisdiction had issued three warrants for her arrest. When they arrived at the location, they found her inside her van with the dogs – and with a generator running outside and connected to the interior of the van by a hose. Attempts to speak with the woman and get her to emerge of her own volition met with verbal resistance. The Department assigned primary responsibility for communication to a trained negotiator, but this officer's various efforts were unsuccessful. After some minutes had passed, officers removed a plastic covering along the driver's side of the vehicle. This allowed them to speak with the woman more directly; they also noticed a concerning gasoline smell coming from the car as a result of the new op ening. Fire Department personnel were summoned to the scene. After a few more minutes of unsuccessful efforts at dialogue with the highly agitated complainant, officers reached in and physically removed her from the van and took her into custody. She continued to be verbally upset and aggressive, and at one point s pit at one of the officers. She was charged with additional crimes, including cruelty to animals for her apparent mistreatment of the three dogs. Her complaint listed several issues, including an unjustified arrest, inaccurate information on the booking sheet, disregard for her victim's rights, and an improper impound of the vehicle (which she alleged had the collateral consequence s of lost possessions and identity theft). 3 The reported behavior included repetitive screaming and door slamming. 9 PAPD Review The supervisor who reviewed the complaint relied on the body-worn camera recordings of the several officers who responded; this material (in conjunction with the police report and other subsequent documentation) was sufficient to refute the different allegations raised by the woman. The supervisor determined that the officers had addressed the situation appropriately, that some of the specific allegations were in direct conflict with the evidence, and that no misconduct had occurred. IPA Review We concurred with the Department's handling of this case after reviewing the materials in the case file. The complainant's extreme agitation had made it difficult to communicate effectively with her, but the on-scene personnel were patient and persistent in their efforts to do so. The additional adverse consequences of an impounded vehicle and separation from her animals were unfortunate for her but consistent with expected or required protocols. Case 3: Allegations of Handcuffing Injury and Other Misconduct Factual Overview A woman submitted a written complaint to the Department in the aftermath of her arrest for drunk driving. She subsequently came to the police station and provided an interview that tracked the same issues she had raised in her previous correspondence. The woman acknowledged having fault in the underlying incident (a single car traffic collision that was attributed to driving under the influence of alcohol). However, she took exception to several aspects of the officers' handling of the arrest and subsequent investigation at the police station, where she experienced a long delay before providin g a blood sample per her choice. She cited a number of concerns. Some of these related to injury she allegedly suffered as a result of being handcuffed, both originally and during her protracted time cuffed by one wrist to a bench in the Department's processing area. (She submitted phot ographs in support of her claims.) She thought the extended time before the phlebotomist's arrival to test her was a form of mistreatment. She considered the officers to have been overly aggressive at different points in her arrest. She also challenged an aspect of the police report that said she had refused to take an alcohol screening test in the field, and she found the officers' "threats" about taking her to jail to have been inappropriately coercive. The complainant also resented the officers' having recorded her while she was in a vulnerable and emotional state during her time in custody. 10 PAPD Review The Department was able to refute the woman's allegations based on the body -worn camera recordings, which showed the officer's patience and professionalism in dealing with the complainant. Throughout the encounter, she appeared to be operating under the misperception that her cooperation and lack of violent resistance entitled her to a dif ferent standard of treatment than was she was receiving, particularly with regard to being handcuffed. (On the recording, she repeatedly refers to herself as the victim of a "human rights violation."). A distinctive feature of the recording was her rattling of the handcuffs that restrained her, one of which was connected to the bench where she was seated, and the other of which was on her wrist. Apart from the persistence she showed over the course of approximately a half hour, the activity was noteworthy in the context of the wrist injuries she later claimed. Not only had she not complained of pain or tightness when originally cuffed and transported, but at one point she actually slipped out of the lone cuff that connected her to the bench, thus belying the notion that it was injuriously tight. Instead, her own repetitive motions may well have contributed to any discomfort or injury she ultimately asserted in her complaint. As for her other assertions, the recording of her was standard practice (and advisable), the length of processing was fairly standard and largely attributable to the wait for a phlebotomist, and the requirement to sign her citation as a condition of release – or go to jail – was accurately characterized by the officers. She seemed to have a mis-recollection or misunderstanding of the offer to take a test in the field that she had refused (as captured on body-worn camera). In short, none of the allegations of misconduct were substantiated. At the same time, though, reviewers at both the initial supervisor level and then the next - level evaluation both noted performance concerns that warranted – and received – follow- up. These included the failure to take precautionary photographs in response to the woman's initial complaints of pain to her wrists toward the end of her time in custody. The initial search of the woman in the field was also found to have been inadequate. This was revealed most starkly when she produced a phone from her coat pocket while seated on the bench in the processing area, which she then used to record the officers. The relevant officer was counseled about the importance of a thorough search. IPA Review We concurred with the determination that no violations of Department policy had occurred. We also found the additional "issue -spotting" and corrective action to be 11 constructive and worthwhile – a good example of how this process can serve as an opportunity for performance refinements as well as accountability. On the other hand, we found the supervisor's interview of the complainant to be somewhat disappointing. Though the woman had provided a lengthy written articulation of the concerns, the supervisor's approach was to have her itemize them again as the supervisor wrote out a brief summary of each. This seemed inefficient and was less illuminating than reductive – as if the concise note taking was given precedence over gleaning a full version of events through interaction. Moreover, when the woman hesitated over a part of the paperwork that asked whether racial bias was being alleged, the supervisor told her that the investigation would essentially be the same either way. This was seemingly intended to be reassuring as she wavered over the choice, but lent itself to an interpre tation of dismissiveness. Nor was it followed by additional questioning about the basis for the supposed perception of bias. We did not have the impression that the woman was genuinely interested in asserting biased behavior, and did not see any evidence that would have validated such an assertion. However, the value of objective and rigorous efforts to address any such concerns is obvious, and the Department's review approach fell short here. Additionally, the supervisor responded to some of her points during the interview by explaining how the described behavior was consistent with policy (and therefore not a valid basis for a complaint). This happened to be correct, but the assertions were not well - received, and presumably did little to contribute to the complainant's overall sense that her issues would be assessed with objectivity.4 It should be noted that the supervisor did not appear to be intentionally discouraging or argumentative; instead, the approach simply reflected an understanding of the "mission" that differed from ours – and deviated from the better practice of treating intake as a forum for listening and. thoughtful neutrality. While we support the PAPD's practice of distributing complaint investigation responsi bility throughout the supervisory level, ideally the supervisors will be guided effectively before being asked to carry out these roles. RECOMMENDATION TWO: PAPD should periodically ensure that all supervisors entrusted with conducting complaint investigations are trained in effective techniques for "intake" interviews with complainants. 4 The woman brought up a second incident that she had happened to witness, involving the arrest of a person in the downtown area. The supervisor said he had happened to be there, and found the officers' actions to be completely warranted by the arrestee's behavior. 12 Use of Force Cases Case 1: Control Holds and Takedown Resulting in Head Abrasion Factual Overview PAPD officers responded to a call from a local business requesting that a person who was sleeping outside the entrance be removed from the property. Multiple officers responded and one officer used a foot to nudge the person’s sleeping bag. The man awakened and officers attempted to negotiate with him for multiple minutes to leave voluntarily. The man was slow to respond, argumentative, and complained about his living situation. After nearly seventeen minutes of discussion, Officer 1 told the man that he was going to be placed under arrest and secured his right arm in preparation to handcuff him. Officers 2 and 3 moved to secure the man’s left arm. The three officers wrestled with the man briefly as the man resisted the officers’ efforts to place him in handcuffs. Officer 4 then moved to assist with the process. Once the man was secured, officers observed that he had an abrasion over his eye; this prompted officers to call paramedics to render aid. The man was then transported to the hospital for clearance. The man was booked into jail for trespassing, resisting arrest, and two outstanding warrants. PAPD Review The first level reviewer determined that the use of force was within policy. He noted, however, that Officer 2 used profanity during the encounter when he told the man to “roll up your shit and move along”. The second level reviewer also found that more detail should have been provided in the four officers’ narratives about the arrest and the use of force techniques used. That reviewer also found that Officer 3 should have properly secured the baton back in its scabbard as officers attempted to complete the handcuffing process. Finally, the second reviewer noted that the man claimed on scene that during the use of force, the officers had broken his eyeglasses. The reviewer opined that the officers should have notified a supervisor when the man claimed that they had broken his gl asses. The third level reviewer agreed with the need for the arresting officer to explain in his report why the arrest decision was made when it was. Regarding the baton issue, the reviewer noted that the officer commendably used a baton as leverage to remove the man’s left arm under his body but that it should have placed back in its scabbard instead of on the ground when the officer shifted focus to controlling the man's head. The 13 reviewer noted that the officer's actions had provided an opportunity for a struggling subject to grab an unsecured weapon. The third level reviewer ensured that each of the training points identified resulted in education and briefing for the involved officers. The fact of that training was then documented in the file. IPA Review IPA reviewed the body-worn camera, police reports, and review memoranda . Based on that review, we concurred with the finding that the use of force was within policy. We were particularly impressed with the exactitude of the force review at all levels. Moreover, in the best tradition of law enforcement, PAPD developed robust interventions designed to address performance issues and better prepare its officers for future challenges. PAPD should be credited for its exemplary work in this use of force review . Case 2: Control Holds and Takedown Possibly Resulting in Fractured Wrist Factual Overview PAPD conducted a “bait bike” operation whereby an expensive bicycle owned by the Department is locked and placed in a public location. When the lock is tampered with, it alerts police, who can then respond and detain the thief. In this incident, police did respond and observed the subject on the bike. One officer instructed the subject to stop but he continued to pedal away. A motorcycle officer pursued the subject and was eventually able to direct him to a median whereby he needed to slow. That allowed another officer on foot to grab the subject’s backpack and pull him off of the bicycle. Officers then used control holds to bring the subject’s arms behind his back and successfully handcuff him. After the incident, the subject complained that the officers had “beat” him. He also complained of pain to his forehead. The subject was transported to a local hospital where there was no evidence of injury to his head. The hospital did diagnose a fractured left wrist, however, and placed the subject in a splint. PAPD Review PAPD conducted an extensive review of the incident and determined that the force was within policy. PAPD also determined that the subject’s allegation of excessive force was not corroborated by the body-worn camera footage or other evidence. The Department also attempted to learn whether the wrist injury was caused by the use of force or was pre-existing but could not determinatively resolve that question. 14 The reviewers also noted that the body-worn camera of one involved officer was not activated because it had not been synched it up to the car’s mobile activated video when the officer replaced the battery. PAPD determined that this performance issue would be addressed through training – a decision driven in part by the "trainee" status of the relevant officer. The reviewers also noted that one of the responding officers told the subject to “get into the damn car” while escorting the subject to a patrol car. PAPD indicated it would counsel the officer on the need to remain professional at all times when dealing with the public. IPA Review IPA reviewed all of the investigative materials and concurred with the finding that the force use was within policy. It also found that the body -worn camera evidence refuted the allegation by the subject of excessive force. Again, PAPD’s reviewers are to be commended for identifying the collateral issues discussed above and addressing them through appropriate intervention. Case 3: Complaint of Injury to Head and Wrist while in Custody Factual Overview An adult male prompted a call for service when he was observed slumped over while behind the wheel at a gas pump. Officers responded to the scene and conducted an investigation into possible driving under the influence. The man was contentious and passively aggressive during the initial attempts to assess his condition through field sobriety tests. He also refused to provide a breathalyzer sample, and the officers eventually arrested him and brought him to the police station for a blood test under the authority of a warrant. That process proved to be a challenge, as the man remained uncooperative, argumentative, and recalcitrant. He was handcuffed to a bench, and removing his jacket proved to be a protracted struggle as officers took off one cuff but got no assistance from him. Several officers surrounded the man, and he slid to the ground while yelling about pain in his wrist and continuing to resist. He was ultimately placed in restraints for his own safety and that of the officers. The Department summoned medics to the f acility, but the man initially made no claims of injury and was not cooperative. Once the man was re-secured, he was transported to county jail. However, during intake, he claimed to a nurse that he had been subjected to excessive force, including being thrown to the ground and having his head slammed on the floor. He said he had lost consciousness. Jail staff accordingly declined to accept him until he had been medically cleared. 15 Officers brought him to the hospital, where he was evaluated, treated and then approved for release to jail custody.5 He was charged with both DUI and resisting. PAPD supervisors, who had been present during the efforts to obtain a blood sample, had taken the position that officers had not used anything more than "controlling force," which would not ordinarily initiate the agency's full -scale review protocol for a force incident (or fall within the established scope of work for evaluation by the Independent Police Auditor). The hospital trip, in conjunction with the man's assertions, had moved the encounter into a different category, and the full review was conducted. This included an interview of the man by a superviso r as well as assessment of extensive other evidence, including body-worn camera recordings, photos, and reports from several involved officers. The Department found no support for the man's contentions of excessive force or other mistreatment. On the contrary, the officers had been notably patient and professional in dealing with the man's persistent lack of cooperation. The recordings established that no slamming or loss of consciousness had occurred, and that pain to the man's wrist was attributable to his own resistance while handcuffed. PAPD determined that the force was reasonable, and the officers' actions were consistent with policy. IPA Review We concurred with the Department's assessment of this incident. There were multiple officers (and supervisors) involved in the effort to obtain a blood sample and then restrain the man for transport. The process was awkward at times as they transitioned away from the bench to the ground and struggled to overcome a large person's lack of cooperation. It was clear from the videos that the subject did not lose consciousness, and his repeated references to his wrist and hand were not only difficult to distinguish from his other efforts to distract and prolong, but were also related to his own straining against the handcuffing process. The officers remained controlled throughout the lengthy encounter. It also was a sound decision to forego the blood draw in light of the overall circumstances and the difficulties the man was presenting. While agreeing with the PAPD findings here, we also note that the supervisor's attempt to interview the man for purposes of the force review fell short of the ideal in a couple of ways. The first was a lack of focus on the man's allegations regarding head trauma and loss of consciousness. (Instead, the supervisor's questioning was limited to the wrist injury issue.) The supervisor also appeared to lose patience with the man toward the end of the conversation, as the subject's obfuscation and contentiousn ess continued. While 5 Medical staff did not observe significant injury; he was given an ice pack for a sore wrist. 16 this was understandable, the simple goal of providing the subject with an opportunity to tell his or her version of events without challenge or "cross-examination" should remain the Department's focus in this situation. RECOMMENDATION THREE: PAPD should devote renewed attention to the training of supervisors in appropriate interview techniques with the subject of a use of force. Case 4: Control Hold Resulting in Broken Arm Factual Background Officers were dispatched to a local eatery after two women went into the men’s bathroom and, after being advised to use the women’s bathroom instead, got into a verbal confrontation with the manager. Employees then called 911, indicating that it appeared as if the women were intoxicated. Two officers responded to the location and found the two women arguing with the restaurant manager. The officers separated the manager from the two women and endeavored to get them outside of the business. Officer 1 then grabbed one of the women’s left wrist while Officer 2 grabbed her right wrist. The woman pulled away, causing Officer 1 to momentarily lose control of the woman’s wrist. Officer 2 continued to hold onto her and pushed the woman against the wall, at which time both officers heard a “pop” sound.6 Officers immediately radioed paramedics to respond, completed the handcuffing process, and escorted the woman out of the restaurant. The second woman was also handcuffed and removed from the restaurant without incident. Paramedics arrived and transported the injured woman to the hospital where x -rays showed that she had suffered a fractured humerus bone. The other woman was booked at County jail for trespassing and being drunk in public. The injured woman was cited for similar charges (and a resisting arrest charge) but released to the hospital for continued treatment of her injured arm. PAPD Review 6 The supervisor who reviewed the use of force incorrectly stated that Officer 1 did not know the woman was injured during the handcuffing process because the woman made other statements without any further complaint of pain. Officer 1’s supplemental police report, included a description of hearing a distinct “popping noise” as Officer 2 applied pressure to the woman’s arm and that Officer 2 immediately called paramedics for a suspected “broken arm." This self - documentation indicated that Officer 1 had in f act been aware of a concern. 17 PAPD conducted a use of force investigation and found the force used by the officers “in policy.” The supervisor who reviewed the force also commented positively about the responding officers’ de-escalation efforts, calling those efforts “empathetic.” This assertion was supported by observations that the officers spoke calmly and in a relaxed manner and gave multiple warnings to the women before going hands on. The supervisor also, and creditably, identified a failure on behalf of the first responding officer to “test record” body-worn camera equipment prior to shift and provided counseling to the officer about that oversight. The supervisor identified one training issue relating to a conversation picked up when the non-injured woman was being transported to the jail. Apparently, the woman had been able to use her I-Watch to communicate with another person during the transport. In another positive example of additional follow-up, the supervisor sent an email to shift officers advising them of the potential security issues that an unsecured I-Watch might present and advised officers to remove them from an arrestee prior to trans port. IPA Review IPA reviewed the investigative materials and body-worn camera footage of the incident. IPA agreed that the force used was consistent with Department policy and appreciated the performance issues identified by the supervisor. However, as explained below, we did not agree that the officers used empathetic and effective de-escalation techniques at the onset of the incident. Officers’ Communication Tactics A review of the body-worn camera showed that the officer who responded first to the incident, upon receiving the radio transmission about the nature of the call and then while responding to the call, commented aloud: “starting off solid with a couple ‘drunkeys’”. This sarcastic reference displayed a sub-optimal attitude before even arriving at the call.7 When that officer arrived in the restroom hallway area, one of the women asked the officer to relax, which led to this response: “No, you’re going to relax”. As the women continued to talk, the officer interrupted her and said: “Listen to me”. Almost imm ediately the officer told the women, “You have two options: go to jail or get your stuff and leave.” The officer then told them repeatedly to "stop talking and leave?” The officer then said, “Do you understand the words coming out of my mouth,” and when one of the women tried to again explain her account responded by saying, “I don’t care”. 7 While this made a disappointing impression, it should be noted that the officer was alone at the time of the recorded comment. 18 After the injured woman was handcuffed, she cried “ow!” and then advised the second arriving officer that her arm hurt. Officer 2 responded: “I know it hurts because you are moving so much.”8 In addition to the actual words articulated, the overall tone of the officers and Officer 1’s sudden ultimatum to them after a very short amount of engagement was disquieting. The abrupt repeated warnings of arrest were not effective and came across as impatience. While inebriated persons can present a challenge to officers who endeavor to reason with them, the two women were not aggressive or physically threatening to the officers. Slowing down the encounter and displaying effective communication strate gies to achieve compliance could well have resulted in the officers not needing to use force and a more successful resolution. And, though not egregious, the officers' approach also did not seem affirmation-worthy – which made the supervisory review disappointing. Securing an Injured Person The control holds used in this case are one of the lowest levels of force used by officers and almost never result in serious injury. This incident, however, is testament to the reality that every “hands on” encounter has the potential to be physically im pactful. In this case, the officers were immediately aware that the woman had been injured as the officers continued to complete the handcuff process. Yet the officers completed the handcuffing even though the woman had been injured, and then blamed her for the pain that she subsequently suffered. One issue that was not considered was whether officers should continue to secure a person who has been obviously injured by the use of force. Perhaps the appropriate tactical approach is to complete the process so that the person can be secured, but that process should be undertaken particularly carefully. RECOMMENDATION FOUR: PAPD should advise its supervisors that when reviewing force incidents, they should consider whether taking time and deploying different (and truly empathetic) strategies could have reduced the need to use force. RECOMMENDATION FIVE: PAPD should consider whether additional training would be beneficial on how to address arrestees who are injured as a result of a use of force but not yet secured. 8 As noted above, the supervisor incorrectly wrote in the analysis that the woman did not complain of the injury until after she was escorted from the restaurant. 19 Case 5: Canine Bite of Assault/Hate Crime Suspect Factual Overview This incident originated as a call for service regarding a street fight in the early morning hours. Arriving officers ascertained that an individual had been knocked unconscious and had been the subject of homophobic slurs. They located the subject they believed was responsible for the crime, but he ignored officer commands and then ran from the scene. Within minutes, officers located the man in the outer stairwell of an apartment building. He was seemingly trying to hide there. But when officers blocked the lone entryway at ground level, he was effectively trapped. He ignored multiple commands to surrender, and a “contact team” of several officers was formed to take him into custody. That task was complicated, however, by the features of the location. The man (who seemed physically fit and had just been involved in an alleged assault) had the higher ground, and the stairwell was somewhat narrow and inherently precarious. This meant that for the officers to go “hands on,” or to use other less lethal force options such as the Taser, involved a higher risk factor than usual. One of the responding officers was accompanied as usual by a police service dog, and the decision was made to bring the leashed dog to the bottom of the stairs in hopes of encouraging the man to surrender peacefully in lieu of a possible bite. The man app eared at the first landing area and tried to engage in dialogue as the dog barked repeatedly. Meanwhile, the man was given repeated commands, warned about the potential for a dog bite, and implored to surrender. He was not cooperative, insisting to the o fficers that he was innocent and making other non-productive statements. Eventually, a supervisor on scene made the decision in conjunction with the K -9 officer to send the dog up the flight of stairs in order to engage the man, at which point the additio nal officers rushed up the stairs and got him handcuffed. The dog bit the man’s leg and held the bite for several seconds, with the handling officer eventually standing over them to monitor the arrest and then call the dog off. The man received several puncture wounds/lacerations to his lower leg. Officers treated him at the scene, and then medics transported him to the hospital for further intervention. He was eventually cleared for booking in the jail. 20 PAPD Review and Outcome The supervisor who was at the scene and helped make the decision to deploy the canine (and who ultimately participated actively in the handcuffing of the man)9 was the person who completed the supervisory review of the incident. The supervisor interviewed the subject at the hospital,10 evaluated the reports of participating officers, reviewed the body- worn camera recordings, and made a methodical effort to apply the relevant policy standards to the facts of the case. The result was a determination that the decision to use the dog, and the force that ensued, was appropriate and within policy in light of the prevailing circumstances. The supervisor’s lengthy memorandum was reviewed by a second level of review, who reached the same conclusions regarding law and policy. IPA Review We found much of the supervisor’s comprehensive memorandum to be persuasive. We also concur with the conclusion that the dog bite was a justified tactic to achieve the apprehension of a non-cooperative, physically able subject who was wanted for a serious crime and situated in a tactically challenging location. At the same time, we make note of one procedural issue and one substantive one. First, while we understand the natural inclination to have the involved supervisor take responsibility for the review process, and while the second-level review adds a level of detached scrutiny, the reality of the process here was that the supervisor 's decision- making became a subject of self-assessment. The favorable conclusion happens to be a view we shared. Ideally, though, a supervisory review is handled by an individual at a greater remove from the underlying events. RECOMMENDATION SIX: The Department should assign canine force reviews to supervisors who were not directly involved in/responsible for the specific decisions that precipitated the force. As a substantive matter, our own review of the body-worn camera recording raised questions about the efficacy of the dog’s immediate presence when efforts are being made to achieve a peaceful resolution with a “trapped” subject. On the one hand, the 9 We make separate note in this report of the advisability of supervisors refraining from physical engagement where practicable. Here, multiple officers were staged, and the supervisor may have been more effective by maintaining an “arm’s length” overview of the force usage. 10 The subject made a number of statements; these varied considerably in their relevance and lucidity. But he did assert that he had offered to come down the stairs if the dog went away, and that he had not been directed to come down or warned before the bite occurred. Some of these assertions were belied by the video evidence . 21 obvious “intimidation factor” and prospect of a bite could be motivating in a way that preempts the need for force to be used at all. (Officers sometimes “arc” a Taser in order to achieve the same effect – a valid tactic.) However, (and as in this case), the incessant barking has as much potential to be agitating or destabilizing in a way that complicates the situation.11 Here, the man’s comments were sometimes drowned out by the dog, and officers gave conflicting commands (“Get on the ground!” vs. “Come down the stairs!”) in a way that suggested that they too were responding in an elevated fashion. While every situation is different, we encourage PAPD to consider a flexible approach to providing a window for additional communication that is not compromised by the dog’s loud, aggressive presence. RECOMMENDATION SEVEN: The Department should evaluate different approaches to utilizing the canine when further negotiation or communication with a resistant subject has the potential to be undermined by the dog’s presence. We also note that the duration of the bite was approximately 36 seconds. The subject was continuing to struggle during that time (including with the dog), and the handler removed the canine promptly once the man was handcuffed, but the presence of the other officers on the landing arguably reduced the necessity for continued engagement. The Department’s “Canines” policy states as follows: when “the handler believes the suspect no longer poses a threat, the handler “should promptly command the canine to release the suspect.” The question here, then, is at what point the subject was no lo nger a “threat” that necessitated the dog’s ongoing involvement. The handler’s judgment here seems to have been predicated on the moment of successful handcuffing. This seems reasonable to us in the context of this event. Still, minimizing the “bite tim e” should be a priority that we hope PAPD will continue to emphasize in training and future deployments. We also take this opportunity to note that the years that have passed since this incident have seen relevant updates to policy, procedure, and training. The Department has not had a bite incident since 2021, and believes that its current program is both an asset to public safety and a reflection of understandable concerns about the risks associated with police dogs. 11 Interestingly, the current PAPD policy on canine use now includes a reference to quieting the dog after a warning is issued, to allow for any verbal response by the subject to be audible. Though the officers were already engaged in direct verbal contact with the man in this case, the chance for more clear communication might still have been beneficial. We consider this update to policy to have been a prudent one. 22 "Pointed Firearm" Incidents PAPD provided us with review materials regarding four different incidents that had involved the pointing of a gun as part of enforcement actions. The Department's protocol for these matters begins with an acknowledgement by the relevant officer or officers, as documented in the police report for the larger incident. The context for the gun-pointing is then assessed by a first-level supervisor in a formal memo, based in part on body-worn camera recordings of the specific moment or moments in question. (Often, clips from multiple officers are included in the package and show the pointing from different perspectives.) The supervisor determines whethe r the pointing was justified by the circumstances and otherwise consistent with training and expectations. That evaluation is then reviewed at two additional rank levels, which ensures thorough scrutiny and sometimes leads to additional insights. Importantly, and as the product of refinements in the system over time, those insights can include peripheral issues that may not even be related to the weapon -pointing itself, but are nonetheless worth addressing – and might never have been noticed if not for the incident receiving automatic review. We have long encouraged PAPD (and other agencies) to maximize the learning opportunities and performance enhancements that are provided alongside more specific accountability mechanisms, and the Department's movement in this direction has been commendable. Below is a summary of the context for the deployments, along with the Department's supervisory assessment of each. 1. Officers responded to a call for service from a homeowner who requested a welfare check from a non-relative resident who was behaving erratically and, at times, threateningly. (The homeowner had allowed the person to stay about a month previously, in sympathy for that person's lack of a stable place to live.) Two experienced officers and a trainee were first on scene, and noticed the subject – an adult female – taking action to avoid them. The woman was soon spotted on the roof of the residence holding (but not pointing) what initially appeared to be a rifle that officers later learned was a BB gun. The officers retreated, regrouped, and put a plan together to contact the woman. During this interval, they also learned that she had an open arrest warrant. After unavailing efforts to reach her by phone and loudspeaker, they formed an entry team and proceeded into the residence. One officer briefly pointed his firearm at an elderly male resident of 23 the house upon unexpectedly encountering him, but quickly realized the man was not a threat and lowered his weapon. Officers eventually located the woman in the backyard, apparently trying to climb over a wooden fence that was several feet tall. The woman remained stationary, with her back to the officers and her arms draped over the fence in a way that left them uncertain as to whether she was armed. Two officers pointed their weapons at her to provide lethal cover as other team members gave commands, moved closer, and eventually got her into handcuffs without further incident. She was booked into jail on the basis o f her previous warrant. The supervisory review affirmed the legitimacy of the officers' three separate instances of weapon pointing in the context of their efforts to safely locate and detain the woman. One member of the arrest team was later found to be missing body -worn camera video. The issue was explored, and it was established that the relevant officer was appropriately equipped and had tested the camera when responding to the call, but it did not w ork when he attempted to activate it at the scene. Because he had reported issues with the camera (and in the larger context of faulty performance with a system that has since been replaced12), the Department did not find this gap to be blameworthy. He was not one of the two weapon-pointers, and other recordings captured the key events comprehensively. 2. Officers investigating a commercial burglary in the early morning hours noted a potential suspect car that later fled from the area at high speed. A tracking dart assisted in locating the vehicle, and officers performed a "high risk traffic stop" to engage with the suspect and take him into custody. During the initial moments of the stop, and prior to the su spect's ultimate compliance, one officer used a firearm's mounted light twice to briefly illuminate the interior of the vehicle. The officer's written report noted that the intention was not to point at the driver, but that the path of the muzzle may have crossed that person's body at some point. Clips from camera recordings captured the relevant movements, which appeared consistent with the officer's description. The pointing was found to be consistent with policy. During the review process, it was determined that one of the involved officers had not properly synced the body-worn camera to the patrol car recording system, which resulted in a failure to activate. This was documented and addressed. Reviewers also took the 12 We discussed this equipment-based concern in our last semi-annual audit report. 24 opportunity to counsel one of the officers on report-writing, based on vagueness in the description of taking the suspect into custody. 3. Officers disrupted a car burglary in progress, and the two subjects fled on foot in different directions. During the subsequent search, a team of officers located one of the subjects hiding in a backyard. One officer briefly pointed a firearm at the subj ect while giving commands, which were followed right away and preceded a handcuffing that occurred without incident. The gun-pointing was found to be consistent with policy. Meanwhile, it was noted that a different officer had failed to initiate a body-worn camera recording of the event, and was counseled appropriately. 4. Officers spotted a vehicle that had been identified by a witness as being involved in a residential burglary; the occupants of the same car were about to leave the scene of a second burglary when officers arrived. In an effort to stop the car from leaving , one officer hurriedly pointed a firearm at the driver and other occupants while giving commands and attempting to open the car door. Meanwhile, a supervisor had engaged on the passenger side. The driver ignored the commands and instead drove away within seconds. The supervisory review affirmed the legitimacy of the weapon -pointing as a response to the circumstances. However, the review also noted two points for follow -up: the failure of the pointing officer to record the incident with body-worn camera, and the potential "crossfire" danger created by the positioning of the supervisor opposite the pointed weapon. Both of these issues were addressed. IPA Review We concurred with the Department's findings as to the reasonableness of each instance of gun-pointing. The small number of cases from the review period, and the controlled and limited nature of each deployment that did occur, are a reflection of the officers' apparent recognition that the tactic has significance as an exercise of authority and should be utilized accordingly. We also commend the agency for embracing this relatively new category of reviewable event as an occasion for holistic, constructive assessment of officer performance. Supplemental issues were identified and resolved in each of the four cases. Unfortunately, several of those issues related to a recurring problem: namely, a failure to activate body-worn cameras. It should be noted that these lapses did not appear to be intentional; nor were they especially costly in these incidents as "lost evidence" (given the presence of other officers and car cameras that captured relevant events). Still the 25 prevalence – and persistence – of this particular shortcoming clearly merits ongoing attention from the Department. RECOMMENDATION EIGHT: PAPD should continue to work with its officers to ensure that recording equipment is functioning properly, and that lapses in compliance with activation policy are met with appropriate accountability. 1 | P a g e DATE: MARCH 17, 2026 TO: HONORABLE CITY COUNCIL FROM: ACTING POLICE CHIEF JAMES REIFSCHNEIDER SUBJECT: USE OF FORCE SUPPLEMENT TO IPA REPORT This memorandum responds to the City Council’s November 2020 direction to provide use of force summary data (which encompasses all use of force incidents in which a “Supervisor’s Report on Use of Force” has been completed by the Police Department) as an attachment to each Independent Police Auditor (IPA) report. Policy Manual §300 (“Use of Force”) requires that all uses of force by Police Department members “be documented promptly, completely, and accurately in an appropriate report.”1 The policy also requires that, under certain circumstances, a “Supervisor’s Report on Use of Force” also be completed by the supervisor, and routed for approval through the chain of command up to and including the Police Chief. Most commonly, a “Supervisor’s Report on Use of Force” is completed after an officer uses some form of force that results in a visible or apparent physical injury to a subject or the subject complains of pain or alleges they were injured. Consistent with the IPA’s expanded scope of administrative review established by the City Council in November 2020, the Department forwards the following types of use of force cases to the IPA for review and recommendations: all cases where a subject’s injuries necessitate any treatment beyond minor medical treatment in the field, and all cases where an officer uses a baton, chemical agent, TASER, less lethal projectile, canine, or firearm. The IPA’s scope of administrative review was further-expanded in July 2021 to include cases when a firearm is pointed at a subject. Consistent with the practice established in the May 2023 iteration of this memorandum, the Department is choosing to release the race of the recipient(s) of any force used. This summary covers the period of June 1, 2025 thru November 30, 2025. Use of Force Cases From June 1, 2025 thru November 30, 2025, the Police Department responded to approximately 23,000 calls for service and effected nearly 900 arrests. During that time, there were 8 cases where 1 The Palo Alto Police Department Policy Manual is updated quarterly and posted online at https://www.paloalto.gov/Departments/Police/Public-Information-Portal/Police-Policy-Manual 2 | P a g e force requiring a “Supervisor’s Report on Use of Force” was used, 2 of which fell within the IPA’s scope of administrative review. The IPA’s review of 1 of these cases appears in the current IPA report; the other will appear in a future IPA report. The current IPA report, covering administrative investigations completed as of November 30, 2025, includes a review of 5 use of force incidents, 4 of which occurred prior to June 1, 2025. In their review of these incidents, the IPA concurred with the Department’s finding that the force employed was justified by the circumstances and consistent with policy. The race of the subject upon whom force was used was Hispanic (2), Black (2), and White (1). June 2025 thru November 2025 Use of Force Summary Type of Force Number of Cases Status of IPA Review Physical Strength 8 1 completed; 1 pending review; 6 outside scope Chemical Agent 0 TASER 0 Baton 0 Less-Lethal Projectile 0 Canine 0 Firearm 0 Firearm Pointed at Person Cases From June 1, 2025 thru November 30, 2025, officers pointed a firearm at a person on 9 occasions. Three of these cases appear in the current IPA report; the remaining 6 will appear in a future IPA report. The current IPA report includes a review of 4 total incidents during which officers pointed a firearm at a person, each of which occurred between February, 24, 2025 and August 27, 2025. In their review of these 4 incidents, the IPA concurred in each case with the Department’s finding that the pointing of the firearm was justified by the circumstances and consistent with policy. In the 4 incidents described in the current IPA report, the races of the subjects at whom a firearm was pointed was White (1), Asian (1), Hispanic (2), and Unknown (1). 1 | P a g e DATE: TO: FROM: MARCH 17, 2026 HONORABLE CITY COUNCIL ACTING POLICE CHIEF JAMES REIFSCHNEIDER RECOMMENDATION #1: PAPD should send out a reminder to all officers reminding them of the need to advise detainees of the reason for any stop. The Department agrees and has issued this reminder. RECOMMENDATION #2: PAPD should periodically ensure that all supervisors entrusted with conducting complaint investigations are trained in effective techniques for "intake" interviews with complainants. The Department agrees and will include instructions during a quarterly Supervisor’s meeting. RECOMMENDATION #3: PAPD should devote renewed attention to the training of supervisors in appropriate interview techniques with the subject of a use of force. The Department agrees and has already identified this as an area with room for improvement. As a result, the Department provided an instructional block of training on this topic to all supervisors and managers at a meeting on November 6, 2025. RECOMMENDATION #4: PAPD should advise its supervisors that when reviewing force incidents, they should consider whether taking time and deploying different (and truly empathetic) strategies could have reduced the need to use force. The Department agrees and will reemphasize this aspect during this year’s biennial Use of Force training. RECOMMENDATION #5: PAPD should consider whether additional training would be beneficial on how to address arrestees who are injured as a result of a use of force but not yet secured. The Department agrees and has requested that the manager and supervisors of the Department’s defensive tactics training team explore options for this. 2 | P a g e RECOMMENDATION #6: The Department should assign canine force reviews to supervisors who were not directly involved in/responsible for the specific decisions that precipitated the force. The Department agrees that where feasible, a canine force review should be assigned to a supervisor who was not directly involved in/responsible for the specific decisions that precipitated the force. RECOMMENDATION #7: The Department should evaluate different approaches to utilizing the canine when further negotiation or communication with a resistant subject has the potential to be undermined by the dog’s presence. The Department agrees and changed the canine policy accordingly in 2022 as a result of reviewing the 2021 incident that prompted this recommendation. RECOMMENDATION #8: PAPD should continue to work with its officers to ensure that recording equipment is functioning properly, and that lapses in compliance with activation policy are met with appropriate accountability. The Department agrees. This is an ongoing point of emphasis for field personnel in 2026. The Department will continue to hold personnel accountable as appropriate for policy non- compliance in this area.