Police brutality

SIGNIFICANCE: Persistent and pervasive patterns of abuse and the enduring obstacles to justice in American policing have contributed to increasing international scrutiny since 1999, when the United States was placed on the Human Rights Watch list of major human rights abusers, along with such countries as Rwanda, Cambodia, and Zimbabwe. Although the impact of cases of police brutality and the disparities in criminal justice in the United States represent substantial threats to institutional legitimacy, it is important to note that the incidence of police use of force has historically been more rare overall given the large numbers of contacts between police and members of the large and diverse American public. By the beginning of the third decade of the twenty-first century, however, public concern about the issue of police brutality had grown amid high-profile cases and calls for systemic police reform.

Article 3 of the United Nations (UN) Code of Conduct for Law-Enforcement Officials states that the legitimate use of force is only that which is “strictly necessary” to subdue persons under the circumstances confronting officers. The UN Basic Principles on the Use of Force and Firearms by Law Enforcement Officials restricts the use of force and firearms to situations in which the “use of force and firearms is unavoidable.” Meanwhile, law-enforcement officials are expected to “exercise restraint in such use and act in proportion to the seriousness of the offense and the legitimate objective to be achieved.” Definitions and justifications for “reasonable” and “necessary” force provided by US law have varied throughout history. The proper use of force by the police maintains the substance of the US Constitution and is fundamental to legitimacy because the police hold a virtual monopoly over the power to exercise lethal force against citizens.

Background

Excessive and lethal force have always been major sources of conflict between members of marginalized racial and ethnic groups and the police in the United States. Despite substantial improvements in race relations, race remains central to police brutality in the United States. A vast body of multidisciplinary literature on the use of force by the police has revealed that members of marginalized racial and ethnic groups face a significantly higher risk than other citizens of becoming victims of police violence, and that members of marginalized racial and ethnic groups are more likely to be incorrectly fired at by police, regardless of the race or ethnicity of the officer. This trend holds true in the US but has also been observed in a number of other countries around the world.

Incidents of police violence against members of marginalized ethnic and religious groups and immigrants have reinforced the public perception that some citizens are subjected to harsher treatment and greater bias than others. Incidents in which real or perceived abuses are made public often spark civil unrest that results in costly and violent uprisings and reinforces public distrust. In 1968, the National Advisory Commission on Civil Disorders , also known as the Kerner Commission, concluded that abusive policing tactics had contributed significantly to the widespread civil disorder of the 1960s.

Later investigatory commissions came to the same conclusions. These include the Christopher Commission, which was appointed to investigate the Los Angeles riots that had followed the acquittal of police officers who had beaten Rodney King; the 1992 St. Clair Commission on excessive force in Boston; and the Mollen Commission on police misconduct in New York. The reports of all these commissions revealed the same patterns that were evident in the Kerner Commission report and reached essentially the same conclusions. Nevertheless, the recommendations made by these commissions largely remained unrealized.

In August 2014, violent protests erupted and continued for days and then months after a White police officer, Darren Wilson, shot and killed an unarmed Black man, Michael Brown, in Ferguson, Missouri, during an altercation related to a recent theft. After more than three months and amid continued verbal and physical protests and unrest in Ferguson, the St. Louis County grand jury decided not to indict Wilson on any charges. The entire country became involved in the emotions and issues raised by the incident, and Wilson ultimately resigned from his position without severance in late November. Additionally, President Barack Obama proposed a new plan to fund a program to institute the use of body cameras for police forces. The subsequent deaths over the next year of a number of young Black men, including Akai Gurley, Tamir Rice, Freddie Gray, and Samuel DuBose, at the hands of police officers generated a continued public outcry. The police shot and killed over 680 people in the United States in 2015; 6 percent of White suspects and 14 percent of Black victims who were shot were unarmed. On average, from 2015 to 2020, 1,769 people a year were injured in police shootings. Of these, 55 percent (979 people) were killed. The majority, 84 percent, were reportedly armed with a firearm or other weapon. A Johns Hopkins study found that welfare check calls were 74 percent more likely to lead to a fatal injury than emergency calls for police to respond when shots had already been fired.

Frustrations regarding perceived incidents of police brutality peaked once more in mid-2020. After nationwide coverage of incidents including the death of Breonna Taylor, an unarmed Black woman who was shot several times and killed by police allegedly using a "no-knock" search warrant inside her home in Louisville, Kentucky, in March, and the death of George Floyd, an unarmed Black man who died in police custody in Minneapolis, Minnesota, in May, large-scale protests broke out in cities throughout the country. A White officer restraining Floyd had knelt on his neck for about nine minutes, even after Floyd had claimed he could not breathe and gone unconscious. Even as the officers at the scene of Floyd's death were subsequently brought up on charges, protests continued in the weeks after his death as activists demanded systemic police reform and some, including representatives of Black Lives Matter, called for shifting funds from police departments to trained social and mental health workers. Activists arguing for such changes also pointed to many reports of police using force against peaceful protesters.

While President Donald Trump signed an executive order in June 2020 that was meant to address an extent of police reform, some commentators and activists argued that the order did not go far enough to effect change. Additional protests erupted in Kenosha, Wisconsin, in August following reports and the releasing of a video showing a Black man, Jacob Blake, being shot in the back seven times by a White police officer. With the officer involved in the shooting claiming that he was acting in self-defense as Blake had allegedly resisted arrest and admitted to possessing a knife, it was announced in January 2021 that the officer was not going to be brought up on charges. By the end of 2020, one of the officers involved in the shooting of Taylor, Brett Hankison, who was reported to have had prior misconduct issues, was fired and indicted on wanton endangerment charges for allegedly indiscriminately firing into the apartment and endangering the lives of her neighbors. In August 2022 Hankison and three other officers involved in Taylor's death were indicted on federal charges, though none had been charged directly with her shooting.

January 2021 additionally saw debates regarding systemic racism in law enforcement, particularly in the context of brutality, when some activists argued that the police response to a large group of rioters, mainly White, who attacked the Capitol building in Washington, DC, on the day of the joint session of Congress held to confirm the results of the 2020 presidential election seemed much less forceful than it had been against people largely peacefully protesting racial injustice on the streets months earlier. Weeks later, the April 2021 fatal traffic stop shooting by a White veteran Minnesota police officer of Daunte Wright, a young, unarmed Black man, once again incited protests and brought further attention to the issue of police use of force and violence, particularly as it occurred during the trial, which had begun in late March, of the officer accused of murder in the Floyd case, Derek Chauvin. Days later, the trial jury found Chauvin guilty on three state charges of murder and manslaughter, and while this verdict was seen as a significant judicial moment, many activists argued that more work needed to be done to improve systems such as policing and ensure police accountability. In early May, yet another rare judicial development related to a case of police use of force occurred that further highlighted the renewed focus on the issue as it was announced that Chauvin and three other former officers—Tou Thao, J. Alexander Keung, and Thomas Lane—who had been present at the scene had also been indicted on federal charges involving unreasonable force and failing both to stop this use of force or provide medical aid to Floyd. That June saw Chauvin receive a sentence in the state case of twenty-two and a half years in prison, and in December he pleaded guilty to the federal charges of civil rights violations. That same month, Kim Potter, the officer who had shot and killed Wright, was found guilty of both first- and second-degree manslaughter following a trial.

In February 2022, a federal jury found Thao, Keung, and Lane guilty of depriving Floyd of his civil rights. The jury decided that Thao and Keung had willfully failed to intervene when Chauvin used unreasonable force. The jury also found that all three former officers had been deliberately indifferent to Floyd's serious medical needs while being restrained in their custody and had willfully failed to give him the first aid that they had been trained to give and that could have saved his life. In May of that year, President Joe Biden, who had been elected in 2020, signed an executive order that insituted a number of police reforms, including the creation of a federal database intended to collect information on police misconduct by federal agencies. Still, despite these incremental steps toward reform, 2022 saw at least 1,176 police killings in the US, making it the deadliest year for police killings since at least 2013. Additionally, in January 2023, another series of nationwide protests broke out following the death of Tyre Nichols, a twenty-nine-year-old Black man who was beaten to death by police officers in Memphis, Tennessee, during a traffic stop. In the aftermath of Nichols's death, five officers involved in his beating were fired and charged with second-degree murder. In June of that year the five officers appeared in court, and by August the local district attorney had dismissed more than thirty criminal cases involving the fired officers due to concerns that these officers could no longer serve as reliable witnesses.

The early 2020s saw other notable cases of police brutality occur around the world. For example, in September 2022, the suspicious death of Mahsa Amini, a young Iranian woman who died shortly after she was arrested by Iranian morality police for allegedly not wearing a hijab, triggered massive protests across Iran. The police response to this protest resulted in hundreds of deaths and led to further criticism of Iranian police. France, which had long experienced tension between its national police force and the marginalized communities living in working-class suburbs of Paris, Marseilles, and other major cities, saw massive protests and riots against police brutality in June 2023 after a teenager named Nahel Merzouk was shot and killed by a police officer during a traffic stop in the Parisian suburb of Nanterre. Many observers drew parallels between these protests and earlier protests, particularly a three-week disturbance in 2005, and argued that Merzouk's death was a sign of ongoing issues with policing in France.

Law-enforcement institutions implement their charges through the complex signaling relationships among the various branches of government. Police must try to balance responsiveness to the law, responsiveness to electoral institutions, and responsiveness to the public with the demands of keeping the peace. The impact of “law and order” candidates on both the law and the executive direction of bureaucratic agencies, such as police departments, has been tremendously influential on the history of police brutality. The overt or covert White supremacist beliefs held by some of these figures has also influenced police behavior. For example, President Richard M. Nixon’s White House chief of staff H. R. Haldeman once noted that “President Nixon emphasized that you have to face the fact that the whole problem is really the Blacks. The key is to devise a system that recognizes this without appearing to.” Given the rampant criminality of the Nixon administration itself, political leadership lacking credible commitments to the public perpetuate institutional legacies that define classes of people who are deemed unworthy of protection by the police.

In addition, the “tough on crime” attitude that pervades public opinion is another element that makes it such that those deemed unworthy of constitutional protections are further disadvantaged, as they are perceived to fail to contribute in valuable ways to society. Citizens who are targets of policy are more likely to be victims of police brutality because they are likely to have more interactions with the police. Moreover, they are less likely to have access to avenues of recourse when they are victimized, and they are not likely to be supported by institutions of justice or the public. Consequently, whether the police respond to the law, politics, or the public, police brutality can be understood at least in part as a reflection of the intolerance of American society.

Prevalence

Rates of the use of force by the police vary widely and are significantly impacted by both departmental policies and state laws as well as the compliance of statutes and policies with US Supreme Court guidelines. While the National Conference of State Legislatures reported that at least twenty-two states had enacted laws between 2014 and April 2020 designed to regulate the use of force, and at least sixteen states enacted legislation addressing standards for the use of force between October 2020 and October 2021, many laws remained relatively broad and typically enabled officers judging a safety risk for themselves or others to use lethal force. The Supreme Court’s 1985 ruling in Tennessee v. Garner outlined the boundaries of the police use of force such that permissive statutes, such as the fleeing felon rule, are considered unconstitutional. Garner had been shown to have reduced fatal shootings by the police. However, between that 1985 ruling and 1990, only four states had changed their laws to bring them into compliance with the constitutional rule.

Ultimately, the elemental task of law enforcement, the application of lawful force to protect society, creates a dilemma in which social cohesion is both preserved through and threatened by force. The prevalence of police brutality is profoundly affected by expectations in ways that are self-reinforcing. Given the history of police brutality in the United States and the self-perpetuating nature of reputations, distrust between members of minority communities and the police are not likely to change without changing expectations.

The dilemma of forced peace makes it such that society cannot expect to eliminate all cases of brutality against the public. Therefore, implementing effective analysis of what is reasonable and necessary force and what are credible commitments by the police to all members of society is essential to affecting the prevailing patterns of police brutality. In addition, credibility must be earned and commitments are likely to be tested.

Responsible leadership committed to reducing the prevalence of police brutality requires at least the following conditions:

•establishing and using a reputation that reinforces the notion that police protect all members of society

•making it costly to the careers of individual officers to violate their commitments to the public

•investing in incremental changes

•employing mandatory negotiating agents such as external complaint collection and automatic civilian review

The principal of “rule of law” should protect citizens from arbitrary power, and the legitimacy of democratic policing is integrally linked to police compliance with legal standards. The exercise of discretion by the police is fundamental to the duty of police to protect and facilitates their ability to serve the public. Excessive use of force is a federal crime that makes it criminal for an individual acting under the color of the law, including private and contracted security personnel, to deprive any citizens of their civil rights. Concerns about arbitrary police power and racial bias represent a significant threat to the principles of the US Constitution. Therefore, transparency and accountability are essential to the fair and effective pursuit of justice.

Investigation

Addressing brutality is a matter of political will. In many cases, organizations are in place to counter such behavior effectively, but the parties responsible for oversight operate in hostile environments or are themselves unwilling to engage in preventive or retributive actions. Limits on effective oversight and organizational leadership that is designed to protect officers, rather than the public, magnify shortcomings and contribute to a climate wherein officers are aware that punitive actions are unlikely.

There are three primary obstacles to effective oversight: lack of public accountability and transparency, failure to investigate and prosecute incidences of brutality, and obstructionism. The first of the three, lack of accountability and transparency, enables the others. One approach to monitoring police accountability is through internal review, which is a formal bureaucratic process that is often referred to as internal affairs (IA).

Most internal mechanisms designed to investigate incidences of abuse operate with secrecy and often allow officials to refuse to furnish the public with relevant information regarding investigation. This institutional secrecy manifests itself even in cases in which such information is supposed to be publicly available. The provision and availability of data and systematic analysis of the use of force by the police at the local, state, and federal levels rely on voluntary compliance and are inconsistent at best. Furthermore, the data collected by the Federal Bureau of Investigation (FBI) and held by the Department of Justice do not include injuries that fall short of death and also are known to be inaccurate. Therefore, in an effort to rectify the situation, the FBI, along with a group of law-enforcement officials, instituted a pilot study in 2017 designed to evaluate the methodology behind a proposed nationwide database of police use-of-force incidents that result in death or serious bodily injury, which would make the information available for more appropriate and consistent analysis. After approval was given, the FBI officially launched its National Use-of-Force Data Collection and began accepting information in January 2019; however, the FBI did not have authority to require law-enforcement agencies to participate and contribute data at that time. President Biden's 2022 executive order on police reform provided for the creation of a National Law Enforcement Accountability Database. It launched on December 18, 2023.

One of the inherent difficulties in internal monitoring is that the police do not always recognize their own violations. Although departments are required to train their officers to deal with citizen claims regarding brutal treatment, myriad problems pervade the process of compiling information from the public regarding interactions with the police. The vast majority of citizens who feel they have been mistreated by the police do not attempt to address the issue formally, primarily out of fear of retribution. Police efforts to dissuade members of the public from making complaints are widespread and persistent.

Citizens who express interest in filing complaints against police may be threatened with the notorious “trilogy” of disorderly conduct, resisting arrest, and assaulting an officer. Scholar James J. Fyfe has dubbed this phenomenon “contempt of cop,” citing a small percentage of officers who repeatedly file such charges because they are offended by citizens’ demeanor without a legitimate law-enforcement purpose. Complainants may face civil countercharges as well. Since the 1990s, there has been a trend in which police officers have filed suits against plaintiffs and attorneys after unsuccessful litigation, alleging defamation, malicious prosecution, or abuse of process. It should also be kept in mind that police deal regularly with people motivated to make claims against police that might diminish their own culpability.

Civilian review is another approach to oversight that constitutes independent, external review of police activities. Citizen oversight bodies are often created in response to demands for external accountability and take a number of different forms. Because demands for citizen oversight tend to occur in communities in which police use of excessive force is consistently a divisive issue between the police and public, and because of the political bargaining that takes place in the formation of civilian review boards, evidence on the effectiveness of citizen participation in this form is limited. Public participation in this form does, however, afford the police some relief from the occupational demands that characterize police work, in that civilian review can inform police departments and share the responsibility that comes with broadly defined objectives and authority.

The increased relative risk to members of marginalized racial and ethnic groups and the relative inability of personnel diversity to affect police killings make external institutional checks on authority an investment rather than a cost. A considerable amount of scandal that can undermine legitimacy arises from incidents in which police officers kill suspects. Departments spend a substantial amount of time and resources dealing with situations in which lethal force is used. Additionally, officers involved in killings often experience trauma that necessitates counseling services to deal with situations in which they have used lethal force, they may have their careers interrupted, and their reputations can be damaged by such incidents. Instituting structural mechanisms that influence the likelihood of excessive or deadly force also means that officers will not have to experience this form of violence either.

Prosecution

There are essentially two paths to exacting justice for unlawful use of force by the police: criminal and civil prosecution. Criminal prosecution may occur at the local, state, and federal levels. At the local level, prosecutors can bring criminal charges against officers under state laws regarding such violent offenses as assault, battery, murder, and rape. Some states have laws that specifically address excessive police force. Federal prosecutors also have the authority to bring charges against officers under relevant federal laws, and federal and state grand juries also have the power to investigate and indict officers for the alleged criminal use of force.

Criminal prosecution is an extremely limited mechanism of accountability. Judges and juries tend to afford considerable deference to police testimony, making conviction incredibly difficult and ultimately making successful prosecution less likely. In addition, criminal prosecution does not address the systematic organizational, leadership, political, and policy problems that contribute to the abuse of power by officers.

Most states do not compile data on rates of prosecution, conviction, and sentencing, but there is substantial evidence for concluding that criminal prosecution for police use of excessive force is extremely rare. The lack of support by public officials, the need for good working relationships between police and prosecutors, and the low probability of conviction contribute to a reluctance to bring charges against officers. There are also few referrals from internal affairs. Moreover, the standard of proof that requires prosecutors to demonstrate that officers had “specific intent” to deprive citizens of their civil rights represents a significant obstacle to convictions.

Civil liability is another potential vehicle for achieving justice in cases of police brutality, though a legally challenging one. The necessary elements of proof and legal standards vary widely from state to state. In the twenty-first century, police officers in most US jurisdictions enjoyed the benefit of qualified immunity, a legal principle that protects individual police officers from liability in civil cases against misconduct they committed on the job. Although the law permits plaintiffs to recover both monetary damages and equitable relief, civil suits alleging excessive force are exceedingly difficult to win. On the other hand, the amounts awarded in civil cases of excessive force have risen steadily since the 1970s, and large settlements for police brutality have strained the resources of some city governments, who typically must foot the bill for any settlement paid out. Nevertheless, potential financial burdens have not served as effective deterrents to excessive force, primarily because civil suits provide little incentive for individual officers to cease using excessive force. Civil suits also fail to influence systemic change in organizational culture, departmental policies, unfair institutional structures, and patterns of political bias.

Punishment

The avenues for addressing police brutality include, but are not necessarily limited to, criminal conviction, civil litigation leading to job loss, early warning systems that expect supervisors to impose penalties for misuse of power, exacting additional education and training requirements for officers exhibiting contempt, and victim-offender mediation. The reality, however, is that none of these avenues is regularly or consistently utilized.

Institutional bias within police departments often favors officers and can include such protections as police officer bills of rights. Although most bureaucrats are required to give up some of their individual civil liberties for the privilege of government work, strong police unions and professional associations afford exceptions for the police. Exceptions for officers allow for the purging of instances of abuse from officers’ personnel files and negotiated contracts that can prevent the disciplining and dismissal of officers when appropriate. Moreover, because police officers rely on one another for their own personal physical safety, the use of lethal force to protect fellow officers is central to cohesion among officers. Finally, the high degree of isolation inherent in police work contributes further to the organizational culture known as the “blue wall of silence.” All these factors insulate the police from both necessary and unnecessary punitive measures.

Addressing police brutality requires an understanding of the character of the law, the history of disparities in criminal justice in the United States, and the fundamentally paradoxical nature of police work. Justice is an abstract idea that is never perfectly actualized from all possible perspectives. Punitive measures are not only extremely unlikely, but also are often unsatisfactory and insufficient means for restorative justice. Punitive measures do not prevent police brutality in the future, nor do they provide any means for re-establishing the trust that underlies the authority of the state, the legitimacy of police power, and mutually beneficial community relations.

Criticism of Generalized Complaints of Police Brutality

During the ongoing debate over police brutality and excessive use of force, some, including those working in law enforcement, continued to emphasize that when considering how much contact the police has with the public, incidents of brutality remained rare overall, and that generalizing the problem from one of individual officers to the whole profession of policing could have adverse consequences. Such arguments often cited links between broad criticism and reformation efforts and the potential for demoralization and increased fear experienced by law enforcement workers as well as greater community relations strains and a reduction in active policing. Police officers needed to be able to face the inherent dangers of their job, they asserted, to effectively combat crime.

Bibliography

Andone, Dakin. "Federal Grand Jury Indicts Four Former Minneapolis Police Officers in George Floyd's Death." CNN, 8 May 2021, www.cnn.com/2021/05/07/us/federal-indictment-george-floyd-officers/index.html. Accessed 17 May 2021.

Bacon, John. "Brooklyn Center Officer Faces Hearing in Shooting of Daunte Wright; City Approves Sweeping Changes in Policing." USA Today, 17 May 2021, www.usatoday.com/story/news/nation/2021/05/17/daunte-wright-shooting-ex-officer-court-manslaughter-charge/5121798001/. Accessed 17 May 2021.

Balko, Radley. Rise of the Warrior Cop: The Militarization of America's Police Forces. PublicAffairs, 2013.

Bruer, Wesley. "DOJ to Enable Nationwide Collection of Use-of-Force Data." CNN, 13 Oct. 2016, www.cnn.com/2016/10/13/politics/police-force-justice-department-loretta-lynch/index.html. Accessed 29 Jan. 2018.

Ceron, Ella. “Last Year Was Deadliest Year on Record for Police Violence in the US.” Bloomberg, 6 Jan. 2023, www.bloomberg.com/news/articles/2023-01-06/police-killed-1-176-people-in-2022-most-ever-in-the-us#xj4y7vzkg. Accessed 22 Sep. 2023.

Chaney, Cassandra, and Ray Robertson. "Racism and Police Brutality in America." Journal of African American Studies, vol. 17, no. 4, 2013, 480–505.

"Fatal Force." The Washington Post, 26 Jan. 2022, www.washingtonpost.com/graphics/investigations/police-shootings-database/. Accessed 26 Jan. 2022.

Greenwald, Anthony G., Mark A. Oakes, and Hunter G. Hoffman. “Targets of Discrimination: Effects of Race on Responses to Weapons Holders.” Journal of Experimental Social Psychology, vol. 39, 2003, 399–405.

Greve, Joan E. “What is the George Floyd Justice in Policing Act and is It Likely to Pass?” The Guardian, 6 Feb. 2023, www.theguardian.com/us-news/2023/feb/06/george-floyd-justice-in-policing-act-explainer-tyre-nichols. Accessed 6 Mar. 2023.

Harrell, Erika, and Elizabeth Davis. Contacts between Police and the Public, 2018—Statistical Tables. Bureau of Justice Statistics, Dec. 2020, bjs.ojp.gov/library/publications/contacts-between-police-and-public-2018-statistical-tables. Accessed 14 Apr. 2021.

Human Rights Watch. Shielded from Justice: Police Brutality and Accountability in the United States. Human Rights Watch, 1998.

Howard, Lauren C., et al. "Young Adults' Distress About Police Brutality Following the Death of George Floyd." Youth & Society, vol. 55, no. 6, 2023, pp. 1173-1190. DOI: 10.1177/0044118X221087282. Accessed 8 July 2024.

"Law Enforcement Legislation: Significant Trends." NCSL, 20 Oct. 2021, www.ncsl.org/research/civil-and-criminal-justice/law-enforcement-legislation-significant-trends-2021.aspx. Accessed 26 Jan. 2022.

Lawson, Tamara F. "Powerless against Police Brutality: A Felon's Story." St. Thomas Law Review, vol. 25, no. 2, 2013, pp. 218–43.

Lingan, John. "Copping To It." Pacific Standard, vol. 8, no. 6, 2015, pp. 18–9.

Méheut, Constant, and Catherine Porter. "Riots in France Highlight a Vicious Cycle Between Police and Minorities." The New York Times, 17 July 2023, www.nytimes.com/2023/07/17/world/europe/france-riots-police-poor.html. Accessed 22 Sep. 2023.

Morales, Christina. "What We Know about the Shooting of Jacob Blake." The New York Times, 5 Jan. 2021, www.nytimes.com/article/jacob-blake-shooting-kenosha.html. Accessed 21 Jan. 2021.

National Research Council. Fairness and Effectiveness in Policing: The Evidence. National Academies, 2003.

Nuwer, Rachel. "When Cops Lose Control." Scientific American Mind, vol. 26, no. 6, 2015, pp. 44–51.

Office of Public Affairs. US Dept. of Justice. "Three Former Minneapolis Police Officers Convicted of Federal Civil Rights Violations for Death of George Floyd." Press Release 22-165. The United States Department of Justice, 24 Feb. 2022, www.justice.gov/opa/pr/three-former-minneapolis-police-officers-convicted-federal-civil-rights-violations-death. Accessed 17 Mar. 2022.

Ostrom, Elinor, R. Parks, and Gordon Whitaker. Patterns of Metropolitan Policing. Praeger, 1978.

Prosecuting Police Misconduct: Reflections on the Role of the U.S. Civil Rights Division. Vera Inst. of Justice, 1998.

Rojas, Rick, and Richard Fausset. "Police Killings Prompt Reassessment of Laws Allowing Deadly Force." The New York Times, 14 June 2020, www.nytimes.com/2020/06/14/us/rayshard-brooks-Garrett-Rolfe-atlanta.html. Accessed 18 June 2020.

Rosenfield, Nate, Brian Howey, and Jerry Mitchell. "'Did You Tase Him in the Face!?' Inside 'Goon Squad' Deputies' Group Chat." The New York Times, 12 June 2024, www.nytimes.com/2024/05/29/us/mississippi-sheriffs-goon-squad-whatsapp.html. Accessed 8 July 2024.

Sanchez, Ray, et al. "Ex-officer Kim Potter Found Guilty of Two Counts of Manslaughter for Fatally Shooting Daunte Wright." CNN, 23 Dec. 2021, www.cnn.com/2021/12/23/us/kim-potter-trial-thursday/index.html. Accessed 26 Jan. 2022.

Skolnick, Jerome H., and James J. Fyfe. Above the Law: Police and Excessive Use of Force. Free, 1993.

Smith, Rogers. Civic Ideals: Conflicting Visions of Citizenship in U.S. History. Yale UP, 1997.

"Study of Fatal and Nonfatal Shootings by Police Reveals Racial Disparities, Dispatch Risks." Johns Hopkins Bloomberg School of Public Health, 15 Mar. 2024, publichealth.jhu.edu/2024/study-of-fatal-and-nonfatal-shootings-by-police-reveals-racial-disparities-dispatch-risks. Accessed 8 July 2024.

Sullivan, John, et al. "Nationwide, Police Shot and Killed Nearly 1,000 People in 2017." The Washington Post, 6 Jan. 2018, www.washingtonpost.com/investigations/nationwide-police-shot-and-killed-nearly-1000-people-in-2017/2018/01/04/4eed5f34-e4e9-11e7-ab50-621fe0588340‗story.html?utm‗term=.9d23b328e2c5. Accessed 29 Jan. 2018.

Tennenbaum, A. N. “The Influence of the Garner Decision on Police Use of Lethal Force.” Journal of Criminal Law and Criminology , vol. 85, 1994, pp. 241–60.

"US Data on Police Shootings and Violence." Law Enforcement Epidemiology Project, 2024, policeepi.uic.edu/u-s-data-on-police-shootings-and-violence/. Accessed 8 July 2024.

Walker, Samuel. Police Accountability: The Role of Citizen Oversight. Wadsworth, 2001.