Use of Litigation Data in Risk Management Strategies for the Chicago Police Department

The Office of Inspector General’s (OIG) Public Safety section has completed an inquiry regarding the Department of Law (DOL) and the Chicago Police Department’s (CPD) collection of data related to lawsuits involving CPD and its members. This inquiry was conducted pursuant to Municipal Code of Chicago (MCC) § 2-56-230(e), which includes among the Public Safety section’s powers and duties to “review, audit and analyze civil judgments and settlements of claims against members of the Police Department, and to issue recommendations based on its findings to inform and improve or correct deficiencies in the conduct, or operation of the Police Department.” OIG reviewed requests made by DOL to the Office of the Comptroller for the payment of settlements and judgments of CPD-involved cases from January 1, 2017 through December 31, 2020. Based on this review, OIG calculates that the City spent over $250 million on judgments and settlements during the period of analysis. Through its analysis, OIG has identified shortcomings related to the collection and management of litigation data involving CPD. These shortcomings limit the City’s ability to understand areas of litigation risk to the City and to implement responsive improvements to CPD’s operations and policies. In conducting its inquiry, OIG interviewed personnel from the Office of Risk Management, DOL, and CPD, and reviewed data from DOL. OIG was unable to conduct an in-depth analysis of data from individual lawsuits because of limitations in the quality and quantity of data collected by DOL.

Subject matter experts recommend law enforcement agencies implement risk programs to identify and mitigate risk areas, and many police departments in large jurisdictions use such programs. The collection and analysis of litigation data is a critical component of such risk management programs. Litigation data should be used to analyze trends, inform early intervention systems and specific administrative investigations, and help identify gaps in administrative investigation processes. However, CPD is poorly positioned to perform these functions due to the City’s current litigation data collection and management practices.

Specifically, OIG identified two areas where the City’s current practices limit its ability to perform these functions: (1) DOL does not collect litigation data at a sufficient level of detail, and (2) DOL is unable to merge its litigation data with CPD’s related data (e.g., use of force reports and arrest reports) to expand potential avenues of analysis. As a result, the City of Chicago is failing to capitalize on opportunities to manage risks arising from CPD’s operations.

To meet best practices, OIG makes four recommendations. First, DOL, the City’s Office of Risk Management, and CPD’s Risk Management Unit should better coordinate to align goals and procedures to determine how to best collect litigation data, including to identify an effective means of merging DOL data with CPD data. Second, these agencies should coordinate to implement industry best practices as they determine what data should be collected. Third, DOL should develop policies, procedures, and training to inform and regulate the collection of litigation data across its divisions and staff. Such a policy should require the collection of data necessary to meet the goals of CPD and the City’s risk management programs, and also include mechanisms to ensure that DOL personnel are complying with the policy. Lastly, as DOL works to upgrade its case management system, it should coordinate with the Office of Risk Management and CPD’s Risk Management Unit to ensure that each entity’s information systems, data collection, and analysis tools are compatible.