Recommendations to Inform and Improve CPD’S Internal Affairs Investigations

The Public Safety Section (PS) of the City of Chicago Office of Inspector General (OIG) conducts, on an ongoing basis, reviews of individual closed disciplinary investigations conducted by the Civilian Office of Police Accountability (COPA) and the Chicago Police Department’s (CPD) Bureau of Internal Affairs (BIA). In the process of reviewing BIA investigations, OIG identified five recommendations to inform and improve future investigations:

  1. CPD members assigned to investigate complaints should ensure that, whenever appropriate, case files include an Initiation Report. If there is no Initiation Report, investigators should consider explaining the origin of a complaint in their summary report or summary report digest. The consistent inclusion of information about the origin of a complaint would provide improved context for judging misconduct and determining outcomes.
  2. Where a disciplinary investigation is related in some way to a criminal proceeding, the assigned investigator should periodically document the status of those proceedings in a To From report, rather than simply documenting the fact that the criminal proceedings remain pending. Doing so might serve to better explain any delays in the administrative investigation caused by the pendency of related criminal matters.
  3. In order to protect and promote timeliness in its investigations, BIA should take steps to avoid assigning an investigation to an investigator who is on a lengthy leave of absence or furlough, and should consider reassigning an investigator’s cases, as appropriate, at the beginning of a lengthy leave of absence or furlough.
  4. If a BIA supervisor reviews an investigation for approval and decides to return it to the assigned investigator, the supervisor’s reason for doing so should be documented. This would create a more complete case record and might prevent the same issue in an investigation from being raised at multiple review points.
  5. Special Order S08-01-01 sets out, in part, steps BIA investigators must take in attempting to contact complainants. To ensure that complaints of police misconduct are appropriately received and investigated, BIA investigators should, at a minimum, follow each requirement of Section II.F of that order. Before approving the closure of an investigation for lack of complainant contact or lack of a sworn affidavit, BIA supervisors should verify full compliance with the provisions of that section.

In response, CPD outlined the process by which complaints come from various sources to BIA for investigation, and affirmed that it is BIA’s practice to document the source of a civilian complaint if it is received without an Initiation Report. With respect to OIG’s remaining four recommendations, CPD noted that its new CMS would provide additional opportunities for assuring compliance and quality.