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Recommendations to Improve and Inform CPD’s Internal Affairs Investigations

February 14, 2019

Summary

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

Executive Summary

BIA is charged with investigating, documenting, and reviewing allegations of misconduct by CPD members. It investigates allegations including, but not limited to criminal misconduct, operational violations, theft of money or property, planting of drugs, substance abuse, residency violations, and medical role abuse.

Among the rules and standards governing the conduct of BIA’s investigations are those found in CPD’s General and Special Orders, and CPD members’ collective bargaining agreements. At present, BIA uses the Citizen and Law Enforcement Analysis and Reporting (CLEAR) system to manage its investigations and accompanying records. CPD is currently in the process of building a new case management system (CMS).

OIG’s recommendations, as shared with CPD on November 27, 2018, are as follows:

  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 S08-0l-Ol 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 11.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.

 

Recommendations to Improve and Inform CPD’s Internal Affairs Investigations - publication cover