BILL ANALYSIS                                                                                                                                                                                                    







                      SENATE COMMITTEE ON PUBLIC SAFETY
                             Senator Mark Leno, Chair                A
                             2009-2010 Regular Session               B

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          AB 1586 (Swanson)                                          6
          As Amended June 9, 2010
          Hearing date:  June 15, 2010
          Public Utilities Code
          SM:dl

                            BART POLICE INDEPENDENT AUDITOR  

                                       HISTORY

          Source:  Bay Area Rapid Transit District Board of Directors

          Prior Legislation: AB 312 (Ammiano) - 2009, died in Assembly  
          Appropriations Committee

          Support: BART Police Managers Association; California  
                   Association of Black Lawyers; City of El Cerrito;  
                   Lakeshore Avenue Baptist Church; Oakland Community  
                   Organizations; Peace Officers Research Association of  
                   California 

          Opposition:None known

          Assembly Floor Vote:  Ayes  67 - Noes  0




                                        KEY ISSUES
           
          SHOULD THE BOARD OF DIRECTORS OF THE BAY AREA RAPID TRANSIT DISTRICT  
          BE AUTHORIZED TO ESTABLISH AN OFFICE OF "INDEPENDENT POLICE AUDITOR"  
          TO INVESTIGATE COMPLAINTS AGAINST DISTRICT POLICE PERSONNEL?












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          SHOULD THE POWERS AND DUTIES OF THE AUDITOR BE DEFINED AS SPECIFIED,  
          IF THE BART BOARD DOES ESTABLISH A POLICE AUDITOR'S OFFICE?


                                          


                                       PURPOSE

          The purpose of this bill is to (1) authorize the Board of  
          Directors of the Bay Area Rapid Transit District (BART) to  
          establish an office of "independent police auditor" to  
          investigate complaints against district police personnel; and  
          (2) require that, if the BART Board does establish a police  
          auditor's office, the powers and duties of the auditor would be  
          as specified.
          
           Existing law  provides for the creation of the San Francisco BART  
          District, comprising the territory lying within the boundaries  
          of the Counties of Alameda, Contra Costa, Marin, San Francisco,  
          and San Mateo.  (Public Utilities Code Section 28600.)  

           Existing law  provides that the board of directors is the  
          legislative body of the district and shall determine all  
          questions of district policy.  (Public Utilities Code Section  
          28762.)  

           Existing law  provides that the district may do any and all  
          things necessary to carry out the purposes of this part.   
          (Public Utilities Code Section 28763.)  

           Existing law  provides that the district is authorized to  
          maintain a police department.  The employees of the district  
          that are appointed as members of such department by the general  
          manager and duly sworn are peace officers; provided that such  
          officers shall not exercise their powers or authority except as  
          specified. The district shall adhere to the standards for  
          recruitment and training of peace officers established by the  
          Commission on Peace Officer Standards and Training, as  












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          specified.  (Public Utilities Code Section 28767.5.)  

           Existing law  provides that the board of directors may contract  
          for or employ any professional services required by the district  
          or for the performance of work or services for the district  
          which, in the board of director's opinion, cannot satisfactorily  
          be performed by the officers or employees of the district.   
          (Public Utilities Code Section 28768.)  

           This bill  would authorize the BART Board to establish an office  
          of "independent police auditor," reporting directly to the  
          Board, to investigate complaints filed against district police  
          personnel.

           This bill  would require that, if the BART Board does establish a  
          police auditor's office, the auditor would have the following  
          powers and duties:
                 To investigate complaints or allegations of on-duty  
               misconduct or off-duty unlawful activity by district police  
               personnel, within the independent police auditor's purview  
               as it is set by the board.
                 To reach independent findings as to the validity of each  
               complaint.
                 To recommend appropriate disciplinary action against  
               district police personnel for those complaints determined  
               to be sustained.

           This bill  provides that the board shall organize, reorganize,  
          and manage the office of the independent police auditor and  
          that, notwithstanding the authority granted the general manager,  
          the board may, by resolution, authorize a citizen review board  
          to participate in recommending appropriate disciplinary action.

           This bill  provides that, if created, the independent police  
          auditor shall prepare, in accordance with the rules of the  
          office, reports of his or her activities as permitted by law. 


                    RECEIVERSHIP/OVERCROWDING CRISIS AGGRAVATION
          












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          The severe prison overcrowding problem California has  
          experienced for the last several years has not been solved.  In  
          December of 2006 plaintiffs in two federal lawsuits against the  
          Department of Corrections and Rehabilitation sought a  
          court-ordered limit on the prison population pursuant to the  
          federal Prison Litigation Reform Act.  On January 12, 2010, a  
          federal three-judge panel issued an order requiring the state to  
          reduce its inmate population to 137.5 percent of design capacity  
          -- a reduction of roughly 40,000 inmates -- within two years.   
          In a prior, related 184-page Opinion and Order dated August 4,  
          2009, that court stated in part:

               "California's correctional system is in a tailspin,"  
               the state's independent oversight agency has reported.  
               . . .  (Jan. 2007 Little Hoover Commission Report,  
               "Solving California's Corrections Crisis: Time Is  
               Running Out").  Tough-on-crime politics have increased  
               the population of California's prisons dramatically  
               while making necessary reforms impossible. . . .  As a  
               result, the state's prisons have become places "of  
               extreme peril to the safety of persons" they house, .  
               . .  (Governor Schwarzenegger's Oct. 4, 2006 Prison  
               Overcrowding State of Emergency Declaration), while  
               contributing little to the safety of California's  
               residents, . . . .   California "spends more on  
               corrections than most countries in the world," but the  
               state "reaps fewer public safety benefits." . . .  .   
               Although California's existing prison system serves  
               neither the public nor the inmates well, the state has  
               for years been unable or unwilling to implement the  
               reforms necessary to reverse its continuing  
               deterioration.  (Some citations omitted.)

               . . .

               The massive 750% increase in the California prison  
               population since the mid-1970s is the result of  
               political decisions made over three decades, including  
               the shift to inflexible determinate sentencing and the  
               passage of harsh mandatory minimum and three-strikes  












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               laws, as well as the state's counterproductive parole  
               system.  Unfortunately, as California's prison  
               population has grown, California's political  
               decision-makers have failed to provide the resources  
               and facilities required to meet the additional need  
               for space and for other necessities of prison  
               existence.  Likewise, although state-appointed experts  
               have repeatedly provided numerous methods by which the  
               state could safely reduce its prison population, their  
               recommendations have been ignored, underfunded, or  
               postponed indefinitely.  The convergence of  
               tough-on-crime policies and an unwillingness to expend  
               the necessary funds to support the population growth  
               has brought California's prisons to the breaking  
               point.  The state of emergency declared by Governor  
               Schwarzenegger almost three years ago continues to  
               this day, California's prisons remain severely  
               overcrowded, and inmates in the California prison  
               system continue to languish without constitutionally  
               adequate medical and mental health care.<1>

          The court stayed implementation of its January 12, 2010 ruling  
          pending the state's appeal of the decision to the U.S. Supreme  
          Court.  That appeal, and the final outcome of this litigation,  
          is not anticipated until later this year or 2011.

           This bill  does not appear to aggravate the prison overcrowding  
          crisis described above.


                                      COMMENTS

          1.  Need for This Bill  
          ---------------------------
          <1>   Three Judge Court Opinion and Order, Coleman v.  
          Schwarzenegger, Plata v. Schwarzenegger, in the United States  
          District Courts for the Eastern District of California and the  
          Northern District of California United States District Court  
          composed of three judges pursuant to Section 2284, Title 28  
          United States Code (August 4, 2009).












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          According to the author:

               This legislation is necessary to give the public a  
               role in the disciplinary process for unlawful and  
               unprofessional conduct by BART police officials, which  
               will prevent incidents like the Oscar Grant killing.

          2.  Background: The Killing of Oscar Grant and The Meyers Nave  
          Report  

          In the aftermath of the shooting death of Oscar Grant by a BART  
          police officer on New Years Day 2009, the BART board  
          commissioned the Meyers Nave law firm to conduct an independent  
          investigation of BART police practices on that occasion.  The  
          report found "the tactics of BART PD at the field level were  
          seriously deficient."  The report contained numerous  
          recommendations for improving BART Police practices.  These  
          included the handling of complaints against BART Police  
          personnel and outside oversight of complaints against BART  
          Police personnel:  

               XI.  DUTY TO REPORT
               
               BART PD should require officers to report their own  
               use of force, as well as that observed of others.  The  
               tightly confined definition of a reportable use of  
               force now required may contribute to not reporting all  
               force used.  BART police policy should be amended to  
               specifically include a statement that officers have a  
               duty to report all pertinent facts known to them,  
               including potential uses of force by their peers.   
               Further, failure to report misconduct should itself be  
               viewed as serious misconduct by BART PD.

               XII.  PERSONNEL COMPLAINT INVESTIGATIONS

               BART PD's substandard practices/procedures for the use  
               of force investigations and personnel complaint  
               investigations may have contributed to the outcomes of  












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               the New Year's Day incident.  If all BART PD officers  
               knew that BART PD would relentlessly investigate use  
               of force incidents, including pulling of video and  
               canvassing the scene, it is doubtful that BART PD  
               officers would use force when it is not reasonable to  
               do so.  There were no rigorous institutional reporting  
               mechanisms to require reporting and officers are left  
               to their own devices and reporting thresholds.  And,  
               there are no obvious consequences for under-reporting  
               the use of force.

               Personnel complaints should be examined and used as a  
               risk management tool to not only review the actions of  
               the officers, but the policies of the BART PD.   
               Further, the pattern of conduct by police officers  
               should be examined in the adjudication of any  
               personnel complaint.  Officers' conduct over a period  
               of time will provide BART PD with a very strong sense  
               of training needs and possibly, the decision to retain  
               an employee.

               XIII.  TRANSPARENCY AND ACCOUNTABILITY

               The reporting requirements and quality of the reports  
               by BART PD with respect to force and misconduct do not  
               invite transparency.  An independent evaluator would  
               have noticed these deficiencies and changes could have  
               been made before this incident occurred.  The lack of  
               significant reporting of use of force incidents, lack  
               of critical analysis in personnel complaints, limited  
               reporting requirements, no on-scene investigations,  
               etc. contributed to the events on the morning of  
               January 1, 2009.  Best practices require other  
               actions.

               BART should consider retaining a reputable auditing or  
               oversight firm, with experience in police matters, to  
               conduct ongoing, meaningful audits and evaluations of  
               BART PD.  These audits and reports should be  
               considered for availability to the public.  












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               The greater the degree of transparency by BART PD, the  
               better the agency will become.  External audits and  
               the responses to those audits are the basis for steady  
               improvement that all police agencies desire.  While  
               the process is often difficult and burdensome, the  
               fruit of such efforts will be worth it.  The public  
               will have a greater sense of comfort in the BART PD  
               and the agency will constantly evolve toward  
               excellence.  If BART opts to develop a review  
               committee to oversee BART PD policy, the committee  
               must be highly versed in police issues and be free to  
               act as independently as is reasonably possible.  Such  
               committees should be fully versed in the use of force  
               issues such as Graham v. Connor and understand that  
               policing is a very inexact craft practiced under  
               rapidly changing and often escalating and chaotic  
               circumstances.(Public Report, Review of BART PD  
               Policies, Practices and Procedures Re: New Year's Day  
               2009.  Meyers Nave, August 11, 2009, pages 6-7.   
                http://bart.gov/docs/Meyers_Nave_Public_Report.pdf  )

          3.  What This Bill Would Do  

          AB 1586 would authorize the BART board to "establish an office  
          of independent police auditor, reporting directly to the board,  
          to investigate complaints filed by members of the public against  
          district police officers."  It would not require establishment  
          of the auditor but rather permit the BART board to create it, if  
          the board so chooses.  If the board does choose to create such  
          an auditor's office, the bill states that the powers and duties  
          of the auditor shall be:

                 To investigate complaints or allegations of on-duty  
               misconduct or off-duty unlawful activity by district police  
               personnel, within the independent police auditor's purview  
               as it is set by the board.
                 To reach independent findings as to the validity of each  
               complaint.
                 To recommend appropriate disciplinary action against  












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               district police personnel for those complaints determined  
               to be sustained.

          This bill also states that the board may authorize a citizen  
          review board to participate in recommending appropriate  
          disciplinary action.  

          The BART board has informed Committee staff that it has already  
          approved a "BART Citizen's Oversight Model" and awaits the  
          authorization that this bill would confer to implement that  
          model.  This bill simply authorizes the BART board to appoint an  
          independent police auditor who would report directly to the  
          board.  

          AB 1586 enumerates the duties that any such auditor would have,  
          if one is appointed, and limits the auditor's scope to  
          investigation of complaints involving on-duty misconduct or  
          off-duty unlawful activity.  Therefore, a complaint involving a  
          BART officer's conduct while off-duty would not fall within the  
          auditor's purview if it did not rise to the level of illegal  
          activity.  

          SHOULD THE BART BOARD HAVE THE AUTHORITY TO CREATE AN  
          INDEPENDENT POLICE AUDITOR?

          SHOULD THE INDEPENDENT AUDITOR BE AUTHORIZED TO REVIEW  
          COMPLAINTS REGARDING OFF-DUTY MISCONDUCT NOT AMOUNTING TO A  
          CRIME?



          4.  Argument in Support  

          The Peace Officers Research Association of California states:

               Our organization supports this legislation, which will  
               allow the BART Board of Directors to create a third  
               party review system, a model similar to the Citizen  
               Review Programs that have been working successfully in  
               various cities, such as Berkeley and Oakland.  In  












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               these systems, the Civilian Review Board or Commission  
               independently investigates complaints against officers  
               and makes recommendations to the City Administrator.   
               This bill will give BART the authority to create a  
               system wherein an Auditor and/or Commission would have  
               investigatory powers over complaints against officers  
               and would report those findings and recommendations to  
               the General Manager of the BART Board.  Under this  
               type of system, the General Manager would have the  
               full and final authority regarding those  
               recommendations and the imposition of employee  
               discipline.  It is important to note that the General  
               Manager works at the will of the Board, ensuring that  
               the Board would still have its continued input into  
               employer-employee relations.  


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