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Miami Police Department

An Objective and Independent Assessment of

MPD’s Internal Affairs Processes and Procedures


September 14, 2018

Confidential and Proprietary — Prepared for Internal Use

Protecting What Matters®

September 14, 2018

Chief Jorge R. Colina

Miami Police Department
400 NW 2nd Avenue
Miami, Florida 33128

Dear Chief Colina:

We completed our objective and independent assessment of the Miami Police Department’s (MPD)
internal affairs processes and procedures. We commend MPD’s initiative and commitment to validating,
updating and improving its internal affairs practices.

One of the most critical components to successful policing is an agency’s ability to ensure its internal
affairs operations demonstrate best practices in a thorough, fair, objective and timely manner. An agency
displays its commitment to ethics and integrity through its internal affairs practices. We believe every
police department in the United States should work to ensure ethics and integrity in the internal affairs (IA)
unit. An effective internal affairs operation (1) helps reduce complaints against personnel and (2) holds the
personnel accountable for their behaviors through processes that involve rank-and-file staff in the receipt,
response, investigation and adjudication of complaints.

If the MPD implements the recommendations in this report, we believe the Department will have established a
model and roadmap that can guide other similarly sized agencies in their own efforts to improve the operations,
efficiencies and outcomes of their IA units.

This draft report is a confidential and proprietary work document between Hillard Heintze and the MPD. We
are happy to discuss our findings and recommendations in further detail. Thank you for entrusting us with this
critical engagement. It has been an honor to contribute to the mission of the MPD and its commitment to its
personnel, City leaders and the residents of Miami.


Arnette F. Heintze
Chief Executive Officer

312-869-8500 | 30 South Wacker Drive, Suite 1400, Chicago, Illinois 60606
Internal Affairs High-Level Assessment

Table of Contents

EXECUTIVE SUMMARY............................................................................................................................................ 4

Strategic Context: Why Conduct This Assessment Now ......................................................................... 4

Assignment: What You Authorized Us to Do.............................................................................................. 4
Methodology: How We Conducted the Assessment ................................................................................ 4
Experts: The Hillard Heintze Assessment Team ......................................................................................... 6

KEY FINDINGS ............................................................................................................................................................ 7

01 OVERVIEW OF INTERNAL AND EXTERNAL OUTREACH .................................................................. 10

Internal Outreach and Outcomes ............................................................................................................... 10

External Outreach and Outcomes............................................................................................................... 12


Internal Affairs Organizational Structure .................................................................................................. 14

Internal and External Complaint Investigation Process ......................................................................... 14
Written Policies and Procedures ................................................................................................................. 16
Internal Affairs Unit Training ....................................................................................................................... 17
Review and Analysis of a Sampling of Cases from 2015 to 2018 ........................................................ 18


RECOMMENDATIONS .......................................................................................................................................... 24

CONCLUSION AND NEXT STEPS ....................................................................................................................... 27

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Executive Summary


In March 2016, the Department of Justice (DOJ) reached a settlement agreement with the City of
Miami and the Miami Police Department (MPD) to resolve the DOJ’s investigation of officer-involved
shootings. With assistance from Independent Reviewer Jane Castor, the MPD has since implemented
comprehensive reforms to help ensure constitutional policing and support public trust. In January
2018, MPD Assistant Chief Jorge Colina became MPD Police Chief. Chief Colina was the former
commander of the MPD’s Internal Affairs (IA) Unit. With the support of the Independent Reviewer,
Chief Colina identified IA as an area that could benefit from an objective and independent third-party
assessment of processes and practices to ensure alignment with national-level best or emerging
practices. On July 25, 2018, the MPD formally engaged Hillard Heintze to conduct an objective and
independent assessment of its IA processes and procedures.


The scope of this assessment consisted of a high-level review of MPD’s IA policies and practices to
assess efficiencies and identify potential areas for improvement. This included a high-level review of
internal and external complaints and their discipline outcomes to ensure they are handled in a
comprehensive, objective, transparent and timely manner in accordance with the MPD’s policy and
applicable laws. In this report, we provide recommendations to modernize MPD policies and
procedures through the development of transparency and accountability requirements, as well as the
implementation of effective measures that align with best or emerging practices for IA investigations.


Six Key Principles
Emerging from our experiences as leaders in law enforcement and related fields, the Hillard Heintze
methodology is based on the following six strategic principles:
1 Independent and objective analysis
2 Solicitation of multiple perspectives and viewpoints
3 An acute focus on collaboration and partnership
4 An information-driven, decision-making mindset
5 A structured and highly disciplined engagement approach
6 Clear and open lines of communication

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A Systematic Approach
To assess the MPD’s processes and procedures for handling IA cases, the Hillard Heintze assessment
team did the following.
1 Received and reviewed several key documents that guide MPD operations, including sections of
the MPD Policy Manual, to understand the roles and responsibilities for those assigned to the
IA Unit, as well as those of supervisors and command officers required to participate in the
• Reviewed the MPD organizational chart to gain insight into the roles and responsibilities of
supervisors and command officers.
• Conducted a high-level review of existing IA policies, processes and their impact on
achieving organizational performance goals.
2 Interviewed stakeholders within MPD to learn from those with first-hand experience how the
process for handling IA investigations currently functions.
• Identified the tasks individual Department members are responsible for completing and the
effectiveness of the organization as a whole when conducting internal affairs investigations.
• Learned Department members’ perspectives of what worked well with the current IA
investigation process and what they believed needs to be improved.
3 Interviewed external stakeholders to discuss how they feel the MPD handles its IA
investigations, based on their extensive knowledge of the community and relationships with
community members.
• Learned some of the external stakeholders’ perspectives of what worked well with the
current IA investigation process and what concerns they may have.
• Conducted a high-level review of the relationship with external stakeholders who work
directly with Department members in the IA process to determine the quality of their
relationship and its effectiveness within the IA process.
4 Reviewed a random selection of IA investigations from 2015 to 2018 to determine:
• Whether those responsible for investigating complaints against MPD members followed the
policies, procedures and protocols outlined in the current policy manual.
• Whether the quality and comprehensiveness of the intake, investigation and notification
processes were present in the cases reviewed.
• Whether the current IA processes and procedures align with those considered to be best or
emerging practices throughout the country.
• What changes or improvements could be made to the MPD procedures for investigating IA
cases to align with best or emerging practices.

We employed rigorous mixed methodologies, where applicable and feasible, at a high level. We relied
on a collection of qualitative data, such as observational and interview-based information, as well as
quantitative data, including random reviews of IA cases. Both sets of data were analyzed and
evaluated to make the best possible high-level assessment.

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Hillard Heintze is one of this nation’s foremost privately held strategic advisory firms specializing in
independent ethics, integrity and oversight services — with a special focus on federal, state and local
law enforcement agencies, including police departments, sheriff’s departments and IA bureaus. We
provide strategic thought leadership, trusted counsel and implementation services that help leading
organizations target and achieve strategic and transformational levels of excellence in law
enforcement, security and investigations. We supported the MPD through the Hillard Heintze Law
Enforcement Consulting Practice. Individually, our staff members have been responsible for leading
the significant transformation of many major city police departments and law enforcement agencies.

Kenneth A. Bouche, Chief Operating Officer

Over nearly two decades, Ken Bouche has established a career as an executive
leader and senior advisor at the forefront of applying best practices in management,
government, technology and information sharing to law enforcement, homeland
security and justice communities. Today he serves as Hillard Heintze’s Chief
Operating Officer, overseeing the day-to-day activities of the firm and the
alignment of its resources, expertise and capabilities. Ken dedicated 23 years to the
Illinois State Police where he led operations in Northern Illinois including the development of
community policing, violence reduction and public integrity programs. As Colonel and CIO, Ken was
responsible for modernizing the agency’s technology, data and intelligence-led policing functions. He
recently served as Chief of Police in Schaumburg, Illinois for one year following Hillard Heintze’s
assessment of the Village’s police department. Ken holds a Master of Public Administration from the
University of Illinois at Chicago and a B.A. from Northeastern Illinois University.

Rob Davis, Senior Vice President, Law Enforcement Consulting

Rob Davis is a highly regarded and innovative national leader in policing and public
safety. Rob served in a variety of capacities during his 30-year career with the San
Jose Police Department, including as the Chief of Police for seven years. During his
time as chief, he also served as the President of the Major Cities Chiefs Association.
He provided consulting services for the U.S. State Department, traveling on
numerous occasions to Central and South America to provide training in community
policing methods addressing gang prevention, intervention and suppression. Since retiring from San
Jose, Davis has been involved in numerous assessments of police departments across the nation. He
also has over 4,000 hours of experience delivering law enforcement training throughout California.

Christi L. Gullion, Vice President, Law Enforcement Consulting

Christi Gullion is a highly accomplished expert in police monitoring, oversight and
reform and the introduction of strategic internal and external risk management
practices to public and private sector organizations. Recently, she led or participated
as a subject matter expert in the assessments and collaborative reform initiatives for
Baltimore, Maryland; Calexico, California; Milwaukee, Wisconsin; Commerce City,
Colorado; Memphis, Tennessee; Beloit, Wisconsin and the University of Rhode
Island Public Safety Department, providing subject matter expertise in use of force, internal affairs,
accountability and early intervention system analysis. Her experiences have made her an expert at
assessing culture in law enforcement agencies.

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Key Findings

Key Finding #1: The MPD is a professional agency led and represented by many highly capable
individuals who recognize and support the Department’s commitments to its many constituencies.
Although we did not assess all MPD operations, it was evident while interacting with MPD leadership
and members that the staff is talented and dedicated and strives to serve those who live and work in
the City of Miami in the professional manner the community expects and deserves.

Key Finding #2: The IA leadership and personnel are hard working, supportive of each other and
open to recommendations for improvement.
Based on interviews with IA leadership and personnel, it was clear that they had a positive attitude
regarding all efforts to improve their operations, were supportive of their colleagues, and despite their
full workload, strive to get their work done efficiently and effectively. In addition, the IA Unit staff as a
whole were open, receptive and transparent in this IA review process, in that they were willing to
discuss areas they could improve and make changes for the betterment of their department.

Key Finding #3: Although the staffing and workload ratio for the IA Unit is appropriate, reassessing
and reassigning some duties may be needed.
The Department usually receives approximately 200 formal complaints each year, but that number is
increasing in 2018. The staffing levels appear to be appropriate, as the IA Unit’s 12 investigators are
responsible for an average of fewer than two formal complaints each month. However, the IA
lieutenant is currently handling both the administrative and the operational duties of the IA Unit due
to an administrative lieutenant vacancy. In addition, the IA Unit handles additional MPD duties that are
typically the responsibility of other units in similarly sized law enforcement agencies. Such duties
include lower-level external complaint investigations typically handled by a supervisor in a patrol
district, and monitoring the Florida Department of Law Enforcement on criminal investigations of
officer-involved shootings, while also conducting the administrative investigations of those incidents,
if necessary.

Key Finding #4: IA staff members are often called upon to conduct criminal investigations that should
be handled by the appropriate members of the Criminal Investigations Division (CID).
Of particular concern is that the MPD IA Unit is often assigned the responsibility of conducting the
initial criminal investigations of some cases involving Department personnel, such as domestic violence
cases. It is not considered a best practice for IA Unit staff to conduct both the criminal and
administrative investigations of Department personnel. This is because information gathered from an
administrative investigation could find its way into the criminal investigation and taint it, potentially
jeopardizing any subsequent criminal prosecution.

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IA Unit staff should monitor criminal investigations conducted by CID personnel routinely assigned to
investigate such criminal cases. As such, a criminal investigation involving an MPD member should be
handled in the same manner as it would for non-MPD personnel, meaning by detectives who would
handle the investigation if the suspect were not an MPD member. IA Unit staff should then initiate an
official administrative investigation once the criminal investigation or proceedings are concluded.

Key Finding #5: IA case investigations have significantly improved over time.
We found significant improvements in the quality, consistency and thoroughness of IA case
investigations between those conducted in 2015 and those investigated in 2017. We discovered even
greater improvements in the 2018 IA cases. Such improvements include, but are not limited to, a
completed checklist kept within the file for consistency in the investigative process; higher quality
interviews conducted without leading questions; interviews conducted for all appropriate persons; and
greater articulation of the basis for the cases’ adjudication.

Key Finding #6: The MPD should develop a disciplinary policy including a disciplinary matrix or
disciplinary guidelines to ensure consistency, appropriateness and transparency in the disciplinary
The MPD currently lacks a disciplinary policy, matrix or guidelines that would assist MPD leadership in
determining disciplinary decisions to help ensure that consistent, fair and progressive discipline is
provided in all IA misconduct cases where appropriate. A disciplinary policy would also ensure that the
process is transparent for all Department personnel.

Key Finding #7: The MPD needs to review and revise its IA Section’s Standard Operating Procedures
(SOP) Manual.
MPD’s IA Section’s SOP Manual, which includes the policies and procedures for handling IA
complaints, needs to be reviewed and revised to incorporate relevant best practices or emerging best
practices. Discontinued practices are still listed in the manual, and it contains a large amount of
information that could be streamlined or serve as stand-alone documents.

Key Finding #8: Training for IA personnel should be completed prior to full-time assignment when
MPD personnel assigned to the IA Unit attend outside IA training. However, this training typically does
not occur until after the employees have been assigned to the IA Unit on a full-time basis, which can
sometimes be quite a while after their initial assignments. This creates a gap between when an employee
begins working on IA cases and when he or she undergoes the training.

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Key Finding #9: IA investigations can be further improved regarding consistency, thoroughness,
timeliness and quality.
Our review of the random series of IA investigations handled from 2015 to 2017 indicated IA
investigations could be further improved in terms of consistency and completeness of the
investigative process and objectivity of the interviews and documentation articulating the reasoning
behind disposition determination or disciplinary recommendations.

Key Finding #10: The IA Unit currently does not conduct periodic reviews or audits of IA
investigations and disciplinary outcomes discipline.
The MPD currently does not have a process for conducting routine audits of the cases it investigates.
This represents a missed opportunity to identify the strengths and weaknesses of the IA Unit’s
investigative processes and to identify how disciplinary outcomes are determined, thus limiting MPD’s
ability to identify patterns and trends in areas that could be improved within policy, training, or
practices and procedures and accountability.

Key Finding #11: MPD does not appear to be using its IA Pro and Blue Team Systems to the fullest
extent possible.
During interviews and casual conversations with MPD and other external personnel, we noted MPD
personnel and the IA Unit are not fully utilizing the IA Pro and Blue Team systems. They do not use IA
Pro to track the case timeline and status, instead tracking it manually on a case-tracking log. Although
some personnel track this information in IA Pro, others do not. In addition, we observed other
indications that IA case files are sometimes not entered into IA Pro until the case has been closed.
MPD and the IA Unit should recognize that when fully utilized, IA Pro and Blue Team can assist to
lighten their workload and allow for better tracking and case management.

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01 Overview of Internal and External Outreach


To conduct a high-level assessment of the MPD’s IA processes and procedures, we conducted select
in-person interviews with members of MPD’s IA Unit responsible for conducting IA investigations,
including IA leadership, supervisors and investigators. In addition, we conducted select in-person
interviews with Department leadership and first-line supervisors we chose to interview to determine
their perspectives on the IA process.

We worked with Assistant Chief Manuel Morales, Major Armando Aguilar and Major Jesus Ibalmea to
organize these select interviews, which occurred over a three-day period. The focus of the interviews
was to understand the Department, the IA Unit and individuals’ perspectives of the IA investigation
process. The following represents a synopsis of the themes and individual concerns revealed during
the interviews.

Efficiency and Timeliness of IA Unit

Some interviewees questioned the IA Unit’s efficiency and timeliness, given the sufficient amount of
staff and reasonable caseload that the IA Unit maintains. They expressed that not every IA case is
complex, and although a 180-day requirement exists for any external complaint investigation initiated,
many cases approach or go beyond this time limit, but should not.

Electronic Maintenance of IA Process

A consensus among the interviewees noted that although the IA Unit was moving toward making the
investigative process electronic, it is currently a hybrid electronic and paper process, with an emphasis
on being paper-based. The IA Unit inputs some information into IA Pro, which is an automated
software program specifically designed to help IA units mange investigations and caseloads. However,
much of the investigators’ work is still on paper.

Case Tracking and Management

Some interviewees indicated that the IA Unit members are not using the IA Pro case management
system to the best of their ability. IA Pro can track the IA cases’ timelines and case statuses, but the
Unit does not use all of IA Pro’s capabilities to do this. Although some IA members track their cases in
IA Pro, some manually track their cases on a paper log. Some mentioned that the IA Unit still meets on
a monthly basis to discuss case statuses, rather than using IA Pro to track cases and their assignment,
timeliness and status, among other information, so these valuable meetings can focus on discussions
of the investigations themselves. If IA Pro was appropriately used for case tracking and management,
some said real-time caseload issues could be identified and reviewed by leadership to understand
immediate staffing and resource needs and to see trends or patterns during case investigations and
their outcomes.

Case Investigation
Some interviewees mentioned that if a complainant was not cooperative, IA may not continue to
investigate the case and instead close it rather than interview other witnesses, attempt to obtain

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videos or take other actions. Although at times IA cannot conduct further investigations without the
cooperation of complainants, our case review indicated opportunities to pursue an investigation often
emerged or were evident and yet IA closed the cases, rather than continue an investigation if
information indicated misconduct could have occurred.

Disciplinary Protocols
Most of those interviewed acknowledged that the MPD has some disciplinary outcomes listed in its
policies for at-fault vehicle accidents, but the Department does not have a disciplinary matrix or
disciplinary guidelines for other sustained misconduct offenses. Interviewees generally agreed that
discipline was not always consistent among officers or progressive for individual officers. For example,
for some, but not all, sustained IA cases, the Department conducted a review of previous cases with
similar allegations to determine whether consistent, progressive and appropriate disciplinary outcomes
occurred and were documented. Interviewees acknowledged that no periodic review or audit for
trends or patterns of disciplinary outcomes regularly occur.

Timeliness of Discipline Outcome

We observed a consensus among interviewees that after a case investigation has been completed,
Department members can be notified that discipline will be handed out. However, they are often not
notified of the specific disciplinary outcome for an unreasonably long time, sometimes up to six

IA Duties
Some interviewees expressed concern about how the IA Unit investigates all cases no matter the level
of complexity. Interviewees indicated that in the past, lower-level case allegations were handled at the
shift-level by supervisors, but currently every type of external and internal complaint — no matter the
seriousness of the allegation — is handled by the IA Unit. Interviewees also expressed concern that in
addition to handling every case, the IA Unit was also responsible for monitoring the criminal
investigation by the Florida Department of Law Enforcement for handling the administrative
investigation of any officer-involved shooting. In many agencies of similar size, this responsibility is
given to the CID unit handling non-department member-involved shootings, such as a homicide unit,
even if no homicide occurred during the officer-involved shooting. This is typically done because of
the homicide investigators’ and the associated crime scene analysts’ expertise working cases involving
shootings. The responsibility of IA staff typically would be only to monitor the investigation
undertaken by the CID staff of the shooting. Given this, interviewees were concerned that the MPD’s
IA Unit was handling substantially more duties than other similar-sized agencies’ IA units, and that
handling some of these duties are not considered a best practice for IA personnel.

IA Unit’s Handling of Criminal Investigations

Our assessment revealed that IA staff members are called upon at times to conduct the initial criminal
investigation of Department member-involved cases. This could include domestic violence or sexual
assault cases. This is not considered a best practice because criminal investigations involving
department personnel and any corresponding administrative investigations should be separated. This
is done to ensure that information that may come out of an administrative investigation, which could
include compelled statements, does not cross over into criminal investigations where constitutional
rights against self-incrimination are at stake. By having IA staff conduct both cases, the firewalls

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between information learned from the administrative investigation could spill over into the criminal
one. Should information from an administrative interview inappropriately be shared in the criminal
investigation, it could jeopardize a prosecutor’s ability to successfully prosecute the criminal case. As
such, the responsibility to handle the criminal cases they have been given is yet another factor that
plays a role in the length of time it takes the IA Unit to complete its investigations.

Most state statutes mandate IA investigations be completed within a certain period. In Florida, they
must be completed within 180 days of a complaint being filed. These mandated periods for
administrative investigations typically are tolled during the associated criminal investigations. The
administrative investigation should then only begin after all criminal investigations or proceedings are
concluded. This is done in part to allow for the separation of the two types of investigations. However,
this does not prevent a designated IA Unit member from monitoring the criminal investigation on
behalf of the Chief of Police to ensure proper investigative steps are being taken.

MPD’s Early Intervention System (EIS) Protocols and Processes

Although we did not specifically review MPD’s EIS, our discussions revealed that the current EIS and
the process surrounding it may not be aligned with national best or promising practices. This was
revealed in the discussions surrounding the EIS performance indicators; thresholds; alert notifications,
including how they are handled, documented and reviewed by managers; and the lack of periodic
review of the EIS process. Having an appropriate and efficient EIS can assist in identifying at-risk
behavior before employee misconduct occurs that may require an internal IA investigation. Because of
this, an assessment of MPD’s EIS for areas of improvement would be beneficial.


Police departments that implement the most effective processes for handling complaints against
members typically require close coordination between IA unit members responsible for handling
personnel complaints and other department stakeholders who play a role in the IA process. This is
because these entities must coordinate to ensure compliance with the specific requirements outlined
in Florida law, the Police Officer Bill of Rights (POBOR) laws and the City’s own policies. As the
Fraternal Order of Police (FOP) represents MPD officers, sergeants, lieutenants and captains it also
plays a major role in the MPD IA process.

In addition, a Civilian Investigation Panel (CIP) was established in 2002 based on a vote of referendum
in the City of Miami. The CIP reviews all MPD IA cases after they are closed and then provides a
memo of its findings and recommendations for the MPD’s consideration.

Because of the close coordination between the MPD and these entities when handling misconduct
allegations against Department personnel, we interviewed select members of these organizations.
These interviewees were asked about the level of cooperation that currently exists between them and
IA personnel while handling these complaints and their views of the IA process itself. The following
information represents the highlights of what we learned during these interviews.

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Good Relationship between IA Unit and Involved Organizations

We observed a consensus among interviewees that a good relationship and rapport exists between IA
and the FOP. They noted these entities are able to schedule and reschedule as needed and work well
together. We also observed agreement during interviews that, generally, there is mutual respect
between IA and the CIP. They understand each other’s purpose and believe that each entity is striving
for thoroughness, consistency and quality in investigations.

IA Unit’s Investigative Process

Some interviewees expressed concern with the IA Unit not documenting why case investigations go
over the 180-day required time limit. A few interviewees understood that this lack of adherence to the
180-day time limit may be based on State Attorney’s Office needs, but also acknowledged that the IA
Unit does not routinely track cases’ progress or document the reasons behind the delays. Interviewees
were also concerned that a subject member often receives no notice of the initial complaint
investigation. The officer may only be notified when an interview may be required. Additionally,
interviewees mentioned that IA investigators were not regularly looking for or at body-worn camera
footage, but noted IA personnel’s efforts to do so have been better in recent months.

Consistency in Classifications and Outcomes

Some interviewees expressed concerns that the findings adjudicated for cases involving line-level
personnel are at times harsher than those given to front-line supervisors or managers for similar
offenses. Another concern was that IA classifications are unclear at times and should be clarified or
eliminated. For example, officers’ behaviors could be classified as either improper procedure or neglect
of duty, which can be confusing and therefore lead to inconsistency in the classification of IA cases.

Delegation of Duties
Many interviewees recognized that strong, quality leadership exists within the IA Unit, but mentioned
the IA leadership being overwhelmed at times in their workload due to a lack of delegation.
Specifically, interviewees were concerned that IA leadership handles too many responsibilities and
oversight, and suggested that the sergeants should oversee the detectives and hold them accountable,
and that in turn sergeants should be held accountable by the lieutenants. Interviewees believed
individuals other than IA leadership should handle training and other similar responsibilities.

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02 Current Policies and Procedures for Handling Complaints


The MPD IA Unit is currently composed of a major who oversees the Unit, one lieutenant who is
responsible for coordinating the intake and investigation of complaints against Department members,
and one lieutenant who is responsible for coordinating the initiation and investigation of the cases for
the proactive Public and Anti-Corruption Unit. Both lieutenants report directly to the major, who
reports directly to the chief. Seven sergeants and five detectives report to the IA lieutenant. Sergeants
investigate the higher-level cases and oversee the detectives, and the detectives investigate the
lower-level cases that were previously sent out to the shift supervisors. One of these detectives also
serves as the complaint intake coordinator. In addition to these sergeants and detectives, the IA Unit
has five civilian personnel.

Four sergeants and 11 detectives are under the Public and Anti-Corruption lieutenant. One of these
sergeants and two of these detectives are currently assigned to task forces working with the Federal
Bureau of Investigation (FBI) and the State Attorney’s Office. In total, 32 personnel are under the
command of the major of this IA Unit, including those who handle the IA cases and the Public and
Anti-Corruption cases.

Typically, the 1,200-member Department receives approximately 200 formal complaints each year,
although that number has increased slightly in 2018. As such, the staffing level appears to be
appropriate, as the IA Unit’s 12 investigators (seven detectives and five sergeants) would be
responsible each month for an average of fewer than two formal complaints. There is a vacancy in the
IA administrative lieutenant position, and as such, the IA lieutenant is currently handling both the
administrative and operational duties of the IA Unit. In addition, the IA Unit is handling additional
duties that are usually handled by other units, as previously noted, which is putting a strain on the IA
Unit’s current productivity. Given the supervisory authority given to the rank of major, the IA Unit
Major has the ability to move within supervisory and command circles to secure the tools and
resources needed to accomplish IA tasks, such as moving investigators from the Public and Anti-
Corruption Unit side to assist the IA investigations when needed.


Under the current IA investigation process, the MPD receives and processes complaints in one of
three ways.
1 The IA Unit receives the complaint second-hand from another Department member, who
received the complaint from the complainant. The other Department member would have
completed the complaint form (R.F. 121) and written a brief summary on the back. The IA Unit
receives any primary investigation information and physical evidence that has been gathered,
and takes responsibility for the completion of the investigation.
2 The IA Unit’s complaint intake coordinator receives a complaint directly from a complainant.
The IA Unit performs almost all of the investigative tasks necessary to investigate and guide the
case through the internal review process.

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3 The IA Unit receives the complaint by mail, email,

phone, fax or anonymously. The IA Unit attempts to KEY DEFINITIONS
contact complainants by phone and/or certified mail
Formal Discipline
to come to the IA Unit to provide a sworn, recorded
statement or to meet the complainants at their Discipline given to a subject
convenience, if necessary. The IA Unit performs member in a sustained
almost all of the investigative tasks necessary to misconduct complaint that
investigate and guide the cases through the internal consists of a written reprimand,
review process. suspension without pay,
disciplinary transfer, demotion,
The Department currently does not accept complaints or termination from
arising out of the following. employment.

• Traffic summons issuance or arrest situation wherein Informal Discipline

the only disputed information are the facts of the
Discipline given to a subject
incident, summons and arrest.
member that consists of verbal
• Outstanding debts, divorce disputes and other civil- counseling, training,
related matters. documented oral counseling, the
issuance of a performance
Instead, the Department logs these complaints that are not improvement plan (PIP), or any
accepted on the complaint log. In addition, the Department combination of these.
makes a distinction between what they define as legitimate
complaints, and those that are considered not legitimate
are labeled “N” for non-complaint and are logged in the computerized system for future reference.

When investigating complaints, the IA investigator is responsible for all facets of the investigation,
including the following.
• Making personal contact with the complainants, witnesses and Department employees involved
in the complaint.
• Conducting interviews, gathering evidence and obtaining formal statements from the
complainants, witnesses and Department employees involved.
• Ensuring the complainants made proper identification of City employees involved in the
complaint, when possible.
• Collecting all documents and reports which have been generated on incidents related to a
complaint investigation.
• Recording all conversations and statements.
• Gathering all physical evidence that may relate to the case.
• Completing a report outlining the facts about the case and the specific sections of the law or
Department policy the subject member is alleged to have violated.

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• Forwarding this report to the lieutenant of the IA Unit, who reviews and then forwards to the IA
Major for final review and recommendations. If sustained, it then is forwarded to the Deputy
Chief and then the Chief for the final decisions on discipline. The Chief makes a final
determination on discipline to be applied in a sustained complaint.
• Ensuring all of the appropriate reports and evidence are gathered and stored in the IA Unit in
compliance with the records retention requirements of the State of Florida and the City of


The MPD has an IA SOP Manual that includes some written policies and procedures that guide the
work of the IA Section, including the IA Unit and the Public and Anti-Corruption Unit. This IA SOP
outlines requirements for accepting, investigating, reviewing and tracking complaints as well as the
duties and responsibilities of its members.

This IA Section SOP provides general requirements to guide the work of those involved in providing IA
intake and investigations and public safety services, including the following.
• Purpose and scope regarding the mission, goals and objectives of the IA Section, including
internal and external safeguards and requirements.
• Expectations for the type of work members complete while on duty.
• Responsibilities of supervisors and managers to ensure they provide proper supervision and
oversight of their subordinates, for which they may be held accountable.
• General policies and procedures for how employees should treat other Department members,
City personnel and members of the public.
• General policies and procedures for the complaint process, including intake, investigation,
review, and case tracking and management.
• Forms regarding the complaint intake and investigation process, including types of findings
available for adjudication.

Based on our review of the manual, we believe the essential components of IA policies and procedures
are included. The inclusion of a mission statement is progressive and should be commended,
particularly because it includes internal and external goals and objectives. However, many policies and
procedures for IA investigations that have been developed by other progressive agencies are not

For example, some requirements and procedures within this manual do not necessarily align with what
many consider national best or emerging practices. We identified the following.
• The manual discusses unaccepted complaints based on particular exceptions as described
above. Although it is required that any unaccepted complaints be documented on the complaint
log, the investigator must interpret whether one of these exceptions exists. For example, one of
the exceptions is if a traffic summons issuance or arrest situation only involves the dispute of

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the facts of the incident. Depending on the situation, the determination could vary depending
on the MPD employee who is involved with the complaint intake. MPD personnel are able to
use their own discretion as to whether to accept a complaint. In addition, it gives personnel the
discretion to talk a complainant out of filing a complaint. Consideration should be given to
requiring notification to a supervisor if and when this occurs.
• The manual stipulates that a complaint “determined not to be a legitimate complaint” is to be
logged as “N” for non-complaint. The language surrounding whether a complaint is “legitimate”
should be reconsidered because although some complaints do not require further investigation
based on their merits, saying a complaint is not “legitimate” can be viewed as invalidating the
process or not hearing the community member nor taking their complaints seriously. In addition,
the term non-complaint should also be reconsidered, as many agencies are now using the term
“inquiry” for such complaints, which is more aligned with the tenets of procedural justice.
• The manual outlines that complaints minor in nature can be identified as “S” cases, 1 investigated
by the unit commander of that employee and returned to IA Section within 90 days. This was a
previous practice, as now all cases are investigated by the IA Unit. The MPD should consider
going back to this practice and require all “S” cases be ultimately reviewed by IA Unit after
completion, or update the IA Section manual to outline the current practice.
• The manual requires notification of the accused employee prior to the interview, but some
notifications occur months after the investigation is initiated. The MPD should consider
requiring employees be notified in writing immediately when a complaint is received in the
interest of transparency.
• The manual is large at 181 pages. It should be reviewed for opportunities to streamline
requirements, parse out critical policies as standalone documents, and revise or eliminate
practices and procedures that are no longer used or necessary.


During our interviews with former and the current IA leadership and investigators, we learned many
investigators were recently assigned to the IA Unit and they are still learning the IA intake and
investigative process. Specifically, a large number of IA personnel were promoted out of the IA Unit in
2014, and the IA Unit subsequently lost the institutional knowledge held by those employees. Some
personnel returned to the IA Unit in 2016, but many of the new investigators have no previous IA

The IA Unit Lieutenant would like to incorporate a more formal onboarding program into IA for new
investigators, especially given some of the new investigators’ lack of knowledge base. Currently, as
part of an informal onboarding process, the new IA investigators are provided an overview of MPD

Cases minor in nature (e.g. improper demeanor, discourtesy, failure to give a name upon request, tardiness, driving
complaints) may be identified as “S” cases. During interviews with MPD personnel, they indicated the term “S” case was
used because these cases were previously forwarded to the “shift-level” supervisor or commander to investigate.

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and IA polices and processes and POBOR during their first two days. They then shadow a Complaint
Intake Officer to understand the interaction process with the public and the IA Pro software where
the complaint is inputted. The sergeants and detectives are sent for a weeklong IA training by an
outside agency, but this often cannot happen right away and these personnel are learning on-the-job
until such training is available and received. An additional method of training is having sergeants
mentor the detectives, but given that the sergeants are also sometimes new and learning, this can be a

We observed that the IA command staff was supportive, respectful and understanding of the learning
curve and challenges their IA supervisors and investigators are currently experiencing. We commend
the IA lieutenant for the plan to incorporate a formal onboarding program for new investigators. We
also commend the IA Unit’s current efforts at the informal onboarding process staff has implemented
to date.


We conducted a thorough review of the written policies and procedures the MPD IA Unit uses to
receive, investigate and process complaints against members. We also interviewed the IA major, IA
lieutenant, additional MPD command staff, and IA supervisory and investigative personnel. Based on
this information, we conducted a random sampling of IA cases handled during 2015 to 2017. We
included additional cases investigated in 2018 to compare any changes or improvements to date. The
purposes of the sampling were to assess the degree to which the IA Unit followed the Department’s
policies and procedures and to assess whether the investigations were handled in a thorough, fair,
objective and consistent manner for both the complainant and the subject member.

After assigning a number to each individual IA case number for each year, a random number generator
selected the IA cases to be reviewed. Given the high-level nature of this assessment, we conducted a
review of at least eight cases from each year from 2015 and 2017, and four cases from 2018. The
following table represents the number of cases selected for review for each year.

Table 1: Cases Selected for Review by Year

Year Number of Cases Reviewed Number of Cases Percentage of Cases Reviewed

2015 8 245 3

2016 9 210 4

2017 8 19 4

2018 4 N/A N/A

The random selection of cases yielded a wide variety of different types of complaints, summarized by
the following table.

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Table 2: Types of Complaints

Year Internal or External Complaint Complaint Allegation Finding

2015 External Abuse of Treatment Substantiated

2015 External Discourtesy Cleared

2015 External Discourtesy Withdrawn

2015 External False Arrest Inconclusive

2015 External Harassment Non-Complaint

2015 External Improper Procedure Cleared

2015 External Improper Procedure Substantiated

2015 External Improper Procedure Inconclusive

2016 External Misconduct Substantiated

2016 External Biased Based Profiling Non-Complaint

2016 External Discourtesy Inconclusive

2016 External Discourtesy Inconclusive

2016 External False Arrest Inconclusive

2016 External Harassment Inconclusive

2016 Internal Improper Procedure Substantiated

2016 External Improper Procedure Filed

2016 External Improper Procedure Non-Complaint

2017 External Misconduct Unsupported

2017 External Abusive Treatment Non-Complaint

2017 External Biased Based Profiling Non-Complaint

2017 External Discourtesy Substantiated

2017 External Excessive Force Pending – Open


2017 External False Arrest Non-Complaint

2017 External Improper Procedure Withdrawn

2017 External Misconduct Sustained

2018 External False Arrest Non-Complaint

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2018 External Improper Procedure Non-Complaint

2018 Internal Misconduct Sustained

2018 External Neglect of Duty Not Sustained

Described below are some highlights of the randomly sampled IA cases for 2015 to 2018. In the
majority of the IA cases we assessed, the following steps were handled routinely, according to the
Department’s policies and protocols.
• Significant improvements in the quality of the investigations were shown over time in the 2015
to 2017 IA cases, and most significantly in the recent 2018 IA cases.
• In late 2017, the IA Unit changed its dispositions to reflect dispositions consistent with national
standards including sustained, not sustained, exonerated, unsupported and withdrawn.
• Proper steps were taken to receive the complaints from external complainants.
• The IA Unit provided the subject members they interviewed the appropriate information to
comply with government codes, POBOR and FOP requirements, using appropriate forms to
guide them in this process.
• The IA Unit allowed subject members to have appropriate representation when desired during
an interview, including a representative from the FOP or a FOP attorney.
• Closure Letters were issued to the complainants and subject members for completed cases.

The following are issues identified during our assessment of the IA cases. These demonstrate the
instances in which (1) some investigative steps were not handled as well as they could have been, (2)
errors were made during the investigative process, or (3) the key components of an effective
investigation were not included in the process: 2
• Some cases did not include or complete a checklist in the investigator’s case folder, which
signaled potential inconsistencies in the process.
• Some investigators only conducted interviews of the complainant, civilian witnesses, subject
officers and witness officers who were on site at IA offices, and did not canvass the area where
the precipitating incident occurred for other potential civilian witnesses or surveillance videos,
nor obtain potentially relevant arrest, incident and property reports.
• We sometimes observed a lack of articulation of the reason for the non-complaint adjudication,
whether it was a decision by the State Attorney’s Office (SAO) or if there was simply no
violation and why not. Even if there is no need for further investigation, this reasoning needs to
be articulated.

Each of the bullets does not represent a separate case. Rather, it represents a number of the issues identified could have
been from various cases.

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• We often observed inconsistencies in names, dates, race or ethnicity, and facts and findings
within an individual case file, such as on the complaint form, investigation summary report,
complaint letters and arrest, incident and property reports. Although these inconsistencies did
not affect the outcome of these investigations, such errors should rarely occur. If IA
investigators use templates to type such documents, they should be cautious of these errors
because it affects both internal and external perception of quality and effort given to the
• When an IA investigation resulted in discipline, there often was no documentation that the
officer’s previous complaint or discipline history was reviewed, nor any articulation or
justification for determining the particular discipline, which calls into question the
implementation of progressive discipline.
• Some interviews were not in IA Pro or the case file, and the IA staff had to find them in their
computer hard drives, on their server or on the physical CDs where the investigators kept the
• In some cases in which the complainant withdrew the complainant, the investigation did not
move forward even when a few preliminary steps could have been done to determine if there
was any issue of concern. We observed instances where an officer or civilian could have been
interviewed or a surveillance video or body-worn camera video could have been obtained and
reviewed. These materials could provide an opportunity to improve policy or training, or
develop officers’ performance in the field for actions that were at a minimum not procedurally
just or at a maximum were actions that require corrective action.
• Investigators asked leading questions in some of the interviews from the earlier 2015 IA cases.
We determined that the investigators asking these leading questions in these 2015 cases are no
longer with the MPD.
• Of the cases that included arrest reports, some of these field reports demonstrated challenges
with articulating or omitting on-scene actions, grammar and spelling, and documenting all
officers that were on scene.
• We observed limited instances in which body-worn cameras were available but were not
searched for by the investigator to see if they were available.
• We observed IA cases where an officer may have not broken MPD policy, but their actions
could have been more procedurally just toward the complainant. Such actions may have had a
negative impact on the Department’s ability to build community trust and relationships. These
include instances where the officer could have initially articulated the reason for the stop or
encounter to a driver or pedestrian, provided the officer’s name and badge number, or
articulated next steps and why throughout the course of an incident when possible so that
community members are informed.

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• In some cases investigated by field supervisors, we noted a glaring lack of interview skills,
whether intentional or not. The questions the field supervisors posed to subject members
lacked the significant probative quality one would expect from an interviewer committed to fact
finding. For example, simply asking a subject member whether he or she used any profanity
against a complainant, receiving an answer of “no,” and then moving on without asking any
other questions calls into question the quality of the interview and the interviewer’s skills or
professionalism. While some could argue that this is why only IA investigators should conduct
IA investigations, we believe it is more important that all supervisors recognize the importance
of the IA process and be trained to handle interviews appropriately.

Although we identified instances in which aspects of the investigation could have been handled better
or indicated a potential need for MPD to update its policies and procedures, if MPD acknowledges this
report’s findings and recommendations and the IA Section continues to move forward, MPD can have
an IA Section that is recognized as a model agency nationwide

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03 Comparison of MPD’s Policies and Procedures to

Other Agencies

Based on the interviews with MPD employees and external stakeholders, as well as our analysis of
recent IA investigations, we evaluated MPD’s current policies and procedures regarding complaints
against Department members or policies. We believe they meet minimum standards compared to
other law enforcement agencies. However, the Department has missed some opportunities for MPD
management to improve its IA investigations processes to be more thorough, fair, objective and
consistent for all parties involved. These opportunities include, but are not limited to, the following.
• Training for Investigators: Although not always feasible, the IA Unit should make every effort to
send its new investigators to receive IA training either prior to beginning work in the IA Unit or
shortly thereafter. This would help minimize the amount of on-the-job training the new
investigators have to endure and assist the IA sergeants in mentoring these new investigators
beyond just initial investigative knowledge.
• Training for Supervisors: The Department could provide additional formal training regarding the
roles and responsibilities of field supervisors and command officers to handle complaints
effectively. This would help the supervisors and command officers proactively manage their
subordinates’ work performance to prevent or address behaviors that could lead to misconduct.
This would also be beneficial if the MPD decides to go back to the practice of having lower-
level cases investigated by the supervisors in their respective units and forwarded to IA for
• Increased Transparency: The MPD should reinforce the IA investigations processes and create
as much transparency as possible when conducting IA investigations. This could (1) increase the
quality of the investigations, and (2) instill greater confidence and credibility that any
disciplinary measures taken against a Department member are fair and objective.
• Assessment of Using the IA Pro and Blue Team Systems: Given the challenges identified with
the IA Unit’s case management efforts and its tracking of the status of IA investigations —
including monitoring case status and complaint trends and patterns — the Department could
improve its IA process and case tracking and management by conducting an assessment of the
use and management of its IA Pro and Blue Team systems. This would assist the MPD in
identifying areas of improvement in these two systems, which directly affect the IA process.
• Assessment of EIS: Establishing an appropriate and efficient EIS has produced great benefits in
other law enforcement agencies. An EIS can identify at-risk behavior that has been shown to
lead to employee misconduct and assist supervisors in intervening and preventing their
subordinates from engaging in potential misconduct in the future. Conducting an assessment of
the Department’s EIS would be a great step toward ensuring the use and management of this
program is appropriate and efficient, meets MPD’s needs and maintains its purpose. An
assessment could include a review of the appropriate performance indicators that should be
part of an EIS, establishing thresholds that should be used and how alert notifications are
handled, as well as identifying mechanisms for conducting periodic reviews of such

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Internal Affairs Policies and Training

1.1 Update MPD’s IA Section SOP Manual, including the policies and procedures, for
handling IA complaints to incorporate relevant best practices or emerging best practices.

1.2 Conduct a review of MPD’s policies and procedures to determine how to incorporate
internal and external procedural justice throughout the department. .

1.3 Eliminate the exceptions for accepting a complaint and require acceptance of all
complaints so they document whether a subsequent investigation is required.

1.4 Eliminate any use of the wording that defines a complaint as not being legitimate. Such a
term is not good for community transparency and external procedural justice when MPD
should accept and address all complaints. “No Further Action Needed” or “Inquiry” could
be considered when describing why a complaint will not be investigated.

1.5 Review and revise the IA SOP Manual for opportunities to streamline requirements, parse
out critical policies as stand-alone documents, and revise or eliminate practices and
procedures that are no longer used or necessary.

1.6 Develop and implement a discipline matrix or disciplinary guidelines based upon
progressive discipline so there is fairness and transparency in the disciplinary process and
consistency when determining discipline for sustained misconduct cases.

1.7 Make every effort to send new investigators out to receive IA training either prior to
beginning work with the IA Unit or shortly thereafter to minimize the amount of on-the-
job training.

1.8 Ensure that all current investigators receive training on interview techniques and avoid
using leading questions during interviews.

1.9 Provide additional formal training regarding the roles and responsibilities of supervisors
and command officers to help them proactively manage their subordinates’ work
performance and prevent or address behaviors that could lead to misconduct.

1.10 Reinforce the IA investigations processes with MPD personnel and create as much
transparency as possible when conducting IA investigations. This includes helping
supervisors understand the importance of asking appropriate probative questions when
called upon to conduct interviews regarding complaints.

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Procedures for Handling Internal Affairs Complaint Intake and Investigations

2.1 Revisit the practice of having lower-level “S” cases investigated by the unit commander
of that employee and then returned to the IA Unit within 90 days for their review. If this
practice is not revisited, update the IA Section manual to outline the current practice.

2.2 Require initial notification in writing to the accused employee when a complaint is
received rather than waiting until an interview of that employee is required. This will help
satisfy the interest of transparency in the process in addition to the conclusion letter
provided to the employee.

2.3 Include a checklist in each case folder and complete this checklist for all IA cases
investigated to ensure quality, consistency and fairness.

2.4 Ensure that, when appropriate, arrest, incident and property reports are obtained and
physical areas of the incident are canvassed for other civilian witnesses or surveillance
videos to reveal other potentially relevant evidence during IA investigations.

2.5 Ensure that if templates for complainant letters or investigative summaries are used by IA
investigators that all information is correct for that particular case file.

2.6 Consider whether preliminary investigative steps are warranted, even in cases in which
the complainant withdrew the complainant. Such proactive steps may lead the MPD to
improve its officers or update its policies, training or practices and procedures rather than
waiting for a reactive moment to do so.

2.7 Ensure that all IA cases, not just sustained ones, articulate the reason for their
adjudication or why no further action was taken after the preliminary review.

2.8 Ensure that all IA cases articulate in writing the reason for the disciplinary action
implemented and is included in the IA file, and that the narrative clearly identifies the
review of the employee’s past history and the progressive discipline considered, thereby
helping to ensure discipline adheres to the standards of progressive discipline and that
the discipline is thorough, fair, objective, and consistent.

2.9 Move toward having all IA investigative files and components electronically entered,
uploaded and stored. Although IA is currently making this transition, this should be a
consistent and permanent practice.

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Internal Affairs Oversight and Accountability

3.1 Ensure that the first-line supervisors in their respective units review all arrest reports for
quality, including spelling, grammar and thoroughness, and that they include all personnel
on scene, actions taken and articulation of actions.

3.2 Ensure that IA investigators are automatically conducting a query for body-worn camera
video footage in every case to review such footage for corroborating statements of any
and all parties.

3.3 Include a review of the aforementioned findings and recommendations in supervisors’

oversight of an IA case investigation to ensure appropriate, thorough and quality
investigations are conducted.

3.4 Consider relieving the IA Unit from handling any future criminal investigations. Instead,
assign these cases to the appropriate CID Unit to avoid any conflict between the
investigation of a criminal case and its subsequent administrative investigation. The IA
Unit should continue monitoring such criminal investigations on behalf of the Chief of
Police to ensure they are being handled appropriately. This would also allow IA Unit
personnel to focus on their own investigative caseload.

3.5 Consider assigning the investigation of all officer-involved shootings to the appropriate
CID Unit rather than the IA Unit, ensuring that those most adept at handling the
investigation of shooting incidents and crime scene analysis conduct the investigations.
Having the IA Unit conduct these investigations is a heavy lift for an IA Unit and does not
provide the independence needed for the administrative investigation.

3.6 Conduct a quarterly audit of all IA case investigations and their disciplinary outcomes to
identify patterns and trends of areas that could be improved within policy, training, or
practices and procedures, and to help ensure accountability.

3.7 Conduct an assessment of Department members’ use of the IA Pro and Blue Team
Systems. This should include an assessment of both the broader MPD team and the IA
Unit’s use of the IA case management and tracking practices for IA investigations,
including the case assignment, timeliness, status, and any emerging trends and patterns
that could be reviewed.

3.8 Conduct an assessment of MPD’s EIS to ensure the appropriate and efficient use and
management of the system and to help identify at-risk behavior prior to employee
misconduct. This would include identifying the appropriateness of the performance
indicators, thresholds and handling of the alert notifications, as well as conducting a
periodic review of such notifications and their documentation.

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Conclusion and Next Steps

We are enthusiastic about the MPD Internal Affairs Unit’s path forward. As of the date of this report,
the Major and Lieutenant have the capabilities to serve as change agents for the Department.
Additionally, the men and women of the MPD IA Unit are committed to the agency, to one another
and to the community they serve – as are MPD leadership and personnel with whom we interacted.

Among its other strengths, the MPD IA Unit has an effective baseline of leadership and committed
investigators. With critical improvements in several areas, they can serve as innovators for writing
policies, mentoring personnel and further committing to the improvement of the internal affairs intake
and investigation processes and their disciplinary outcomes.

As the MPD leadership, and specifically the IA Unit, enters the next phase of this effort to improve the
department’s IA processes, and as they begin implementing the recommendations in this report,
leadership should consider creating a strategic roadmap to address the following priorities.
1 Reassess and reassign some of the IA Unit’s duties as appropriate.
2 Review and develop, or revise written policies and procedures including the IA Section SOP
Manual, a disciplinary policy and a disciplinary matrix or guidelines.
3 Identify ways to provide training to investigators prior to their assignment.
4 Continue to strengthen the quality and timeliness of the IA investigations.
5 Conduct periodic reviews or audits of IA investigations and discipline for improvement and
6 Use the IA Pro and Blue Team systems to their fullest for case management and tracking.
7 Evaluate the early intervention system and its process.

Addressing the areas outlined in this report will be critical for the MPD, the IA Unit and the community.
As mentioned above, a deeper review of the other areas within the MPD – including IA Pro and Blue
Team, and EIS utilization and processes – would further help the Department move toward becoming a
progressive agency. We are available to work closely with the MPD and the IA Unit to implement our
recommendations. In addition, we would be willing to conduct the deeper evaluation of the other areas
within the Department as mentioned.

If the MPD accepts and implements the recommendations outlined this report, it will help advance the
IA Unit and its processes, help the Department to conform to meet community expectations, improve
policing services, assist the Department in retaining its quality IA Unit personnel, and potentially serve
as a model for law enforcement agencies across the country.

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