IACP NATIONAL LAW ENFORCEMENT POLICY CENTER Response To Civil Litigation
IACP NATIONAL LAW ENFORCEMENT POLICY CENTERResponse to Civil LitigationConcepts and Issues PaperOriginally Published: November 1988Revised: October 1996I. INTRODUCTIONA. Purpose of the DocumentThis paper was designed to accompany the ModelPolicy on Response to Civil Litigation developed bythe IACP National Law Enforcement Policy Center.This paper provides essential background material andsupporting documentation to provide greater understandingof the developmental philosophy and implementationrequirements for the model policy. This material will be ofvalue to law enforcement executives in their efforts to tailorthe model to the requirements and circumstances of theircommunity and their law enforcement agency.B. BackgroundTraditionally, law enforcement agencies havemaintained what can best be described as a reactive attitudetowards civil litigation brought against the agency as aresult of law enforcement actions. As in all professions,the tendency has been to focus on what is known best— their own job of enforcing the criminal laws — whileleaving the litigation to the lawyers. As a result, lawenforcement agencies have played a reactive role byconfronting the problem of civil litigation only after acause of action has been filed against the department.The past 25 years have witnessed a virtual explosionof civil litigation aimed at law enforcement agencies.Million-dollar judgments against municipalities and othergovernmental units have become almost common. Suchjudgments have created a veritable insurance crisis forlocal governments that have been forced to either payskyrocketing premiums, provide self-insurance, or joininsurance pools with neighboring vicinities.Some insurance companies have responded by makingmunicipal insurance coverage contingent on a review ofpolicies and procedures for legal and technical soundness.While these are important measures that each lawenforcement agency should initiate to decrease the chancesof being sued, the model policy advocates an even moreaggressive program.Departments must take an active part in reducingthe growth of civil litigation. The focus must be shiftedfrom an exclusive response to the lawsuit alone. First,the department must focus on the law enforcement actionthat allegedly caused a rights violation, and determinehow similar incidents can be prevented or minimized inthe future. This should not be taken to mean that all lawenforcement agencies involved in such litigation are rightsviolators. However, even those agencies that are unjustlyaccused may learn steps to better prove their innocence incourt.Second, after the department has taken active steps to“manage” liability, then it may turn its attention towardthe actual courtroom battle. Again, a proactive stanceis necessary. Police officers are trained in criminal lawyet many continue to ignore or diminish the significanceof civil law. With increased civil litigation exposure,departments need to become familiar with those civil lawsthat are the focus of many large judgments.Some police agencies have operationalized theconcepts of proactive litigation control by establishing aspecial litigation unit that responds exclusively to litigationdemands and those specific incidents that form the basisfor potential litigation. By providing special investigativeand documentation techniques for these incidents, it hasA publication of the IACP National Law Enforcement Policy Center44 Canal Center Plaza, Suite 200, Alexandria, VA 22314This document is the result of work performed by the IACP National Law Enforcement Policy Center. The views and opinions expressed in this document aresanctioned by the center’s advisory board and do not necessarily represent the official position or policies of the International Association of Chiefs of Police.
been shown that such units can substantially reduce theirinvolvement in civil litigation.While not every department can afford to have sucha specialized unit, almost all can adopt a heightened levelof awareness and develop a more proactive approach bymaking all officers aware of the potential impact of civillitigation and the important role they can play in reducingits incidence and impact.willing to accept minimal documentation withoutlingering doubts. Similarly, more and more municipalinsurance agencies are basing their insurance premiumestimates on the law enforcement agency’s maintenance ofprofessionally sound policy and procedures.The model policy encourages active documentationof all critical incidents by law enforcement agencies asa proactive approach. Documentation of an incidentprovides strong evidence at a later date that no policieswere broken, and gives an accurate record of the events asthey occurred. This type of uniform and comprehensivedocumentation is far more constructive and responsive to apolice agency’s requirement for accountability to the publicand the courts, and this level of effort alone can go a longway in demonstrating good faith in these and other regards.Finally, illegal activity by the department should notbe condoned or hidden. Thus, the model policy approachis to provide an open and active attitude, with dailydocumentation of police activities, especially for thoseincidents that present a high risk for potential liability.C. Focus of Model PolicyLaw enforcement agencies and their attorneys aredivided on how to best approach civil litigation. This splithas been engendered by the litigation-process itself.One strategic approach to litigation is to “hide theball.” Courtroom scrutiny of subpoenaed departmentalpolicies, memoranda, and other special reports has oftenled to liability for the department, where evidence of aviolation of policy, not law, was uncovered. Thus, someagencies and attorneys advise that the best way to combatlitigation is to leave undocumented, or vague, as muchdepartmental policy as possible.While the above strategy may appear attractive, it canalso have disastrous consequences. Failure to provide clearinstruction to staff regarding roles and responsibilities canbe interpreted as deliberate indifference to the protection ofcivil rights in many police-citizen encounters. Moreover, itfails to provide the guidance necessary for the developmentof effective training, supervision, personnel performanceevaluation, and discipline.Lack of documentation can also make the departmentappear as if it is covering up its mistakes. For example, apopular record to be subpoenaed is a citizen’s complaintthat forms the basis for the lawsuit. Where no citizencomplaints are recorded, the plaintiff’s attorney caneffectively skewer the department on insinuations that thedepartment knowingly ignored both citizen complaintsof misconduct and other relevant data that mightreveal the magnitude of the misconduct problem. Thisperception can be made even worse where the departmentdocuments some incidents, but not others. The perceptionof wrongdoing here is underlined by lingering doubtsconcerning the reason for the selectivity.Lack of documentation can be used to imply that thedepartment is negligent in its own procedures. While itmay be uncomfortable to be quizzed on the details of awritten policy, the department looks worse if it is unableto produce any relevant policy. This leaves room forquestions concerning adequate guidance and training ofofficers, departmental condonation of negligent acts, andultimately the negligence of the agency regarding theincident forming the basis for litigation.As courts have become more familiar with lawenforcement procedures, they have also become lessII. AGENCY CIVIL LIABILITYThe increase in civil litigation targeted at lawenforcement agencies and their employees has requiredlaw enforcement executives to become increasinglyconscious of liability. Today’s law enforcement executivemust fully understand numerous legal concepts pertainingto this type of litigation. While municipal liability is anextremely complex and constantly evolving area of thelaw, a brief explanation of its main concepts is appropriate.Civil litigation has also begun to erode the traditionalconfidentiality of internal police records, as more and morecourts have deemed this information imperative to prove acase.The dramatic increase in civil litigation affectinglaw enforcement agencies can be traced to the landmarkSupreme Court decision of Monell v. Department of SocialServices1 in combination with the legal revival of Title 42U.S.C. 1983 as a civil cause of action.This statute, known for brevity’s sake as Sec. 1983,provides as follows:Every person who, under color of any statute,ordinance, regulation, custom or usage, of anystate or territory, or the District of Columbia,subjects, or causes to be subjected, any citizenof the United States or other person within thejurisdiction thereof to the deprivation of anyrights, privileges or immunities secured by theConstitution and law, shall be liable to the partyin an action at law, suit in equity, or other proper12Monell, 463 U.S. 658 (1978).
specific instance.4 Policy need not be written to hold thecity liable. Where a law enforcement agency, through longpractice, has done something in a certain way, a customhas arisen. Liability may be based on this custom, even ifwritten procedures would have prohibited such actions.Finally, municipal policy may be expressed throughtraining, supervision, and discipline. A municipalitymay incur Sec. 1983 liability for negligence in training,supervision, or inadequate discipline.5Establishment of a municipal policy of negligenttraining sufficient to hold the municipality liable underSec. 1983 was addressed by the Supreme Court in Cityof Canton v. Harris.6 A city may be held liable forconstitutional violations caused by its failure to adequatelytrain employees where the failure to train amounts to “adeliberate indifference to the rights of persons with whomthe police come into contact.”7 A municipal policy wouldnot be established solely on the basis that one officer wasinadequately trained, or that some better type of trainingcould have been used that would have eliminated theactions that caused the injury.proceeding for redress.”While Sec. 1983 does not create any substantiverights, it provides a means for individuals to gain redressfrom the governmental unit and the government officialswho have used their position of authority to deprive theindividual of a federally protected right. For example, theConstitution guarantees each individual the right to be freefrom unreasonable searches and seizures. Where a lawenforcement officer makes an unlawful arrest, a deprivationof that constitutional right has occurred. The subject ofthe unlawful arrest may seek damages for this violation ofrights through use of the federal courts under Sec. 1983.Thus, Sec. 1983 provides a broad vehicle forlitigating the spectrum of rights guaranteed by the federalConstitution and statutes.When discussing governmental liability, it should beclarified at this point that the law enforcement agency isan arm of the city or county for which it is authorized toact. Thus, where the executive promulgates policy for hisofficers, it is generally attributable to the city.Traditionally, governmental bodies have been immunefrom liability. The Monell case began the process of liftingthis immunity, holding that a municipality could be heldliable in certain instances for an employee’s actions.Since Monell, several Supreme Court cases haveclarified and created guidelines on when a municipalitymay be held liable under Sec. 1983. Most importantly,the city or village may not automatically be held liable forthe employee’s actions, using the common-law doctrine ofrespondeat superior. To be held liable, the city or policedepartment must have promulgated some policy or heldto some custom of operation that the officer act upon, andthat caused the rights violations.2 For example, where alaw enforcement agency has a policy that violates federalguidelines on use of force, and an officer injures a personwhile following that policy, the city may be held liable.Thus, for a city to be held liable, the city itself must havecontributed to the rights violation.Neither the parameters for what constitutes a “policy”nor clearly defined guidelines pertaining to whichgovernmental employees may set official policy forSec. 1983 purposes have been clearly established by theSupreme Court. However, a few broad principles havebeen formulated.First, policy makers are government officials whosedecisions or choices for action may fairly be said torepresent final, official municipal policy.3 Second, policymay include rules of general applicability and conduct,and decisions by policy makers that will be applied to oneIII. FRAMEWORK OF THE POLICYThe model policy is set up to provide a proactiveapproach to civil litigation through a two-prongedapproach. First, the department should target those areasthat generate the most amount of litigation, and addressthem through strengthened procedures. Second, the modelpolicy addresses the control of documents flowing fromcivil litigation in the form of subpoenas and requests fordiscovery.A. Recognition of Incidents Producing LitigationSome of the more prevalent law enforcementprocedures forming the basis for both Title 42 USC 1983and state law actions are vehicular pursuit, uses of deadlyand non-deadly force, and searches and seizures. Whilethis fact should come as no surprise, the truly importantaspect of this statement is the recognition that departmentscan manage better by focusing more strongly on thoselaw enforcement actions that cause the greatest number ofproblems. Agencies can begin this process by selectingthose policies and procedures that are employed mostfrequently by police officers and that have the greatestpotential for litigation.The model policy targets five types of law enforcementactions that continuously appear as the basis for civil4Pembaur v. City of Cincinnati, 475 U.S. 469, 106 S. Ct. 1292 (1986).City of 0klahoma City v. Tuttle, 471 U.S. 808, 105 S. Ct. 2427(1985).52Id.63Id.7357 U.S. Law Week 4263 (1989).Id. at 4271.
litigation for consideration. However, these areas aregeneralized from the experiences of many law enforcementagencies. Police agencies should examine their ownlocal situations to determine if this pattern holds true forthem or whether other issue areas should be targeted forconsideration. Moreover, law enforcement agencies shouldcontinually monitor citizen complaints, officer disciplinaryreports, and legal actions filed against the agency, amongother similar matters, to determine if new areas of policeoperations deserve closer scrutiny.1. Uses of force. Law enforcement powers include theright to use force in order to gain compliance or to preserveorder. Each day, an officer may use force several timeswithout consciously identifying it as such. While some lawenforcement personnel equate a use of force with the useof deadly force only, the definition is much broader. Useof force runs the gamut of physical coercion from a gentlenudge or a firm “come-along hold” to the use of a firearm.Use of force also extends to indirect coercive activitiesbeyond physical contact between the officer and thesuspect. Use of a cruiser to ram a car, or to force it off theroad, will be considered a use of force. Recently, muchattention has been focused on the use-of-force potentialof canine units. The use of OC spray, a Taser, or otherindirect means of gaining compliance or controlling asuspect should be recognized as an element of force.While these examples are not an all-inclusive list ofwhat constitutes a use of force, they serve to illustrate thefact that a broad range of daily law enforcement actionsmay constitute a use of force. Thus, while shootingincidents may not occur daily, many other uses of force areavailable to serve as the basis for a civil rights suit do.Force incidents prove attractive fodder for the mediaand attorneys. It is only natural that some persons whohave been involuntarily directed to follow a police officer’sorder will automatically claim that excessive force wasused. Unfortunately, abuses of police authority by a few inthe past have produced a presumption that those practicescontinue to occur by all law enforcement officers in thepresent.Given the high profile of use-of-force incidents,law enforcement agencies should follow the specialinvestigative and documentation procedures outlined in themodel policy. (See also IACP National Law EnforcementPolicy Center Model Use of Force Policy.) An importantfirst step will include recognizing the full continuum of useof force. Training of officers and supervisors should beinitiated to reinforce thinking about uses of force on thiscontinuum, and special documentation needs.An indispensable first step in the documentationprocess involves developing departmental policy andprocedures on force reporting. Agencies must be clear asto what types of actions their officers are required to reportand how this reporting should take place. The Model Policyon Use of Force Reporting developed by the Policy Centerin 1996 is a recommended approach to meeting this need.2. Vehicular pursuit. The model policy targetsvehicular pursuits resulting in personal injury or propertydamage as high-liability risk incidents.Clearly, most law enforcement agencies recognize thedanger to the public and the officer in high-speed pursuits.Many departments have formulated pursuit policies thatrequire an officer to consider a broad range of criticalfactors before initiating pursuit, such as weather conditionsand the potential for serious injury and damage if thepursuit is continued, not only to the officer and perpetrator,but to innocent bystanders and surrounding property. (Seethe Policy Center’s Model Policy on Vehicular Pursuit.)As vehicular pursuits have been held in certaininstances to be uses of force and seizures, they provideample bases for the constitutional torts under Section1983 used in civil litigation. Given the frequency ofdifferent types of vehicular activity by law enforcementofficers, these incidents merit special procedural attentionand documentation. Some states mandate reporting ofvehicular pursuits on a statewide level. Agencies in suchstates therefore habitually collect information in this area.Most agencies in states that do not have such requirementswill have to develop reporting protocols and procedures tomeet this information and monitoring requirement.3. Searches and seizures. The complexity of FourthAmendment case law causes searches and seizures to beanother area of potential litigation. Warrantless searchesor seizures are particularly vulnerable, as the courtmust determine whether the circumstances that wouldpermit a warrantless search/seizure were present in eachparticular case. This has become a serious problem inmany jurisdictions with regard to warrantless vehiclesearches involved in drug investigations and seizures.While suppression of evidence is the main remedy at acriminal trial for an illegal search or seizure, concurrentcivil actions for a civil rights violation under Section 1983are increasingly being filed in order to additionally seeka monetary remedy for the illegal search/seizure. (See theModel Policy on Executing Search Warrants.)4. Failure to take law enforcement action. Severaljurisdictions have experienced a surge of civil actionsbased on a citizen’s charge that an officer should havetaken, but failed to take, a specific law enforcement actionthat would have protected the person. The FourteenthAmendment due-process clause does not impose onstates and municipalities a duty to protect specificindividuals from the harmful acts of others, unless theperson has involuntarily been taken into custody.8 Thus,De Shaney v. Winnebago County Dept. of Social Services, 489 U.S.189,109 S. Cf. 998 (1989)84
B. High-Risk Incident Proceduresa municipality could incur Section 1983 liability whereofficials take no steps to prevent harm to their prisoners.Aside from this specific situation, the question ofwhether a law enforcement officer owes a duty to protectspecific individuals from harm is controlled by state law.Generally, law enforcement officers are considered to owea duty only to the public to exercise their law enforcementpowers. Most jurisdictions hold that there is “no duty” toprotect any specific person, unless a specific duty has beenauthorized by law. For example, once a perpetrator is takeninto police custody, the officer does have a duty to protectthe life of that perpetrator. Failure to take action to protectthat individual would be a breach of duty, and give rise to acause of action. Unless a duty to take action is specificallyestablished, these jurisdictions would hold that an officerhas no duty to protect particular individuals. However,once an officer undertakes to protect an individual, theofficer must continue to do so, and any negligence in suchprotection will give rise to a cause of action.By contrast, some jurisdictions do not follow the “noduty” rule, and hold that officers do have a mandatory dutyto protect specific individuals.Directly related to this issue, however, is that ofliability for failure to act based on an individual’s race,religion, or similar criteria. If a police agency followseither a written policy or unwritten custom of failing toprotect certain classes of citizens based on their gender orrace, for example, the agency is dramatically increasingthe likelihood of a liability suit under Section 1983 for aviolation of the equal-protection clause.This issue has become evident not just with regard torace or religion but with regard to gender in the context ofdomestic violence cases. A police agency becomes liableunder the Civil Rights Act if the police follow a formalpolicy or informal custom of providing less protection towomen or to married persons than they would provideto males or to people who are unmarried. Under theseconditions, a pattern of discriminatory service delivery maybe established.5. Rendering medical assistance. Law enforcementofficers have a duty to ensure that medical assistance isprovided to those in their custody. This duty would extendboth to the arresting officer and jail personnel. As theprisoner cannot voluntarily care for his medical needswhile in custody, the government must provide accessto special medications, medical procedures, emergencytreatment, or first aid for both injuries received prior to andduring the arrest incident, and for already existing medicalproblems, such as diabetes.Closely related, and an active subject area for civillitigation, is providing psychological assistance toprisoners, which has been brought on by an increasednumber of jail suicides.The model policy requires officers to follow certainspecial procedures when involved in an incident that wouldbe considered a high-liability risk incident. While some ofthese procedures are specific to a particular incident, suchas the special report required after a high-speed pursuit,most are generally applicable.Not every high-risk incident will produce civillitigation. Certain scenarios, such as firearms dischargesresulting in death, often end up the focus of litigation,and officers will almost automatically provide careful andthorough documentation of events. As there is no wayof knowing which incident will later erupt into a lawsuit,supervisors and officers should treat all high-risk incidentsas if they will go to court. This extra early preparation maysave time and money at the onset of litigation.The key focus for the officer is to begin a processof detailed documentation of the events surroundingthe incident. All officers involved in these incidentsare required to submit a fully detailed memorandumconcerning the incident to their supervisor by the end oftheir shift.The officer should begin on the scene, while hismemory is fresh, to note all relevant information, no matterhow obscure, such as weather conditions that obscuredvisibility, broken street lamps, and crowd conditions.A supervisor should immediately be summoned to thescene, and a thorough processing of the scene for evidenceshould be conducted according to departmental procedures.Color photographs and videotapes can be a valuabletool in preserving an exact record of the scene and thewitnesses. Often, officers do not have time to note all thepeople on the scene or at the perimeter. Photographs canlater be used to retrace the event and identify all possiblewitnesses.There has been a recent increase in state legal actionsagainst law enforcement agencies for false arrest and falseimprisonment. A similar problem of law enforcementactions undertaken based on mistaken facts often arisesduring residential searches, where the search warrantprovides an ambiguous or vague description of theresidence to be searched. The model policy requiresthat a supervisor conduct an independent review of allrelevant facts prior to the search in order to eliminate suchincidents.The booking process should also be used to discernthe mental and physical status of the suspect. The bookingofficer should document whether the officer gave thesuspect any first aid, or transported the suspect to thehospital for medical attention prior to arrival for booking.The suspect should be questioned as to whether medicalattention is currently needed, or whether he has any specialmedical problems that will need attention while he is in5
jail. The transporting officer should provide informationwhether the suspect ever lost consciousness or complainedof chest pains, dizziness, nausea, or lightheadedness duringarrest or while being transported. Where a neck restrainthold has been used, these symptoms can mean that thesuspect is in physical trouble.A color booking photo of the prisoner should be takento document both injuries and lack of injuries. This canbe used to dispel claims by a prisoner that injuries werereceived by jail officials or the arresting officers.Finally, to help eliminate jail suicides, the bookingofficer should document any information that suggestspsychological instability and seek psychological counselingfor the prisoner. Where drugs are suspected to be the causeof such instability or are causing ultra-aggressive behavior,drug counselors should be consulted.the officer appear and feel like a wrongdoer. Thus, someattempts should be made to circumvent this problem. Theofficer should be reminded that any internal investigationsare standard procedure, and that a full review of theincident is designed as a protective measure.The officer should be reminded that he is not requiredto discuss the incident with reporters, or any attorneysnot associated with the case unless subpoenaed to testify.Comments made after an incident are admissible evidencein court. The officer may be feeling vulnerable after anincident, and confused as to whether he acted properly.The persons who should listen to those doubts are thedepartment psychologist or chaplain, not the plaintiff’sattorney.Arrangements generally must be made for thelegal defense of any officers named in civil litigation asdefendants with the department for actions arising outof their employment. Usually, municipal attorneys orattorneys hired by the governmental entity will act as theofficer’s legal counsel. Where there is some doubt as tothe propriety of the officer’s actions, and the department isarguing that they have no liability for the officer’s acts, aconflict of interest arises for the department’s legal counsel.Counsel cannot assert that the officer acted improperlyand defend the officer at the same time. Thus, officersare generally required in these situations to seek separatecounsel. Retention of legal counsel, whether private orthrough the department, should be discussed early in theprocess with the involved officers.C. Post-Incident ProceduresThe model policy requires officers involved in a highrisk incident to submit a detailed report to their supervisorbefore concluding their tour of duty. The supervisoris initially responsible for ensuring that this report is ameaningful documentation of the incident. The supervisorshould ensure that the report includes the names of allofficers, suspects, and witnesses involved; any injuriessustained; a complete explanation of what happened; andany statements given on the scene. This will provide theagency’s chief executive with the full details required todiscuss the incident with the press should that be necessary.The model policy suggests that the chief submit amemorandum concerning the incident to departmentlegal counsel as soon as possible, and meet to discuss theincident. This is a proactive damage-control measure.Should the incident result in litigation, legal counsel willneed to be informed of all details of the incident. Thus, thelaw enforcement agency should work with legal counselto assess each incident beforehand. The agency shouldbe prepared to discuss both the correct and potentiallyincorrect measures the officers or department took duringthe incident. Department legal counsel may also be ableto provide the department with direction as to the types ofinformation and documents to be gathered in preparationfor trial.The status of an officer involved in high-profileincidents is often overlooked by departments. Evenwhere an initial assessment of the officer’s actionsshows they were correct, an air of impropriety remains.While accident review boards, use-of-force hearings, orother internal investigations may be standard operatingprocedure, these procedures often leave the officer feelingcastigated by the department. Media coverage of highprofile incidents may, as a result of a lack of accurateinformation, misrepresent the officer’s actions and makeD. Record RetentionTwo factors important to managing civil litigation ina proactive manner are organization and analysis. Theseare especially important in the intelligent management andstorage of departmental records and records pertaining
The increase in civil litigation targeted at law enforcement agencies and their employees has required law enforcement executives to become increasingly conscious of liability. Today's law enforcement executive must fully understand numerous legal concepts pertaining to this type of litigation. While municipal liability is an
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