The Complaint Action Plan: Responding to Misconduct Allegations in the Aftermath of Civil Unrest

Sydney Roberts

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Oct 13, 2022

Most public safety agencies, civilian police oversight bodies and police internal affairs units across the country were unprepared to ensure a timely response to public complaints in the wake of protests and civil unrest that followed the murder of George Floyd. These bodies lacked sufficient personnel to intake, triage and investigate the sudden barrage of complaints received against law enforcement personnel.

In the first two weeks of protest following the killing of George Floyd, individuals filed more than 400 complaints against Chicago Police Department officers. The Seattle Police Department received more than 19,000 complaints, and the New York City Police Department received more than 700. Such a marked increase of received complaints within a short period could significantly impact the timeliness of complaint investigations.

What Is a Complaint Action Plan?

Public safety agencies can better prepare themselves for a sudden surge in public complaints by creating a complaint action plan that outlines the agency’s response, transparency and engagement efforts. The plan should ensure a timely and transparent response to complaints and include community outreach and engagement.

Such a plan could be a standalone document constructed by a law enforcement agency’s internal affairs unit or a civilian police oversight body. Alternatively, the plan could be integrated into a larger emergency operations, critical incident, or crisis response plan. Having an action plan to handle police misconduct complaints ensures accountability.

Four Key Aspects of a Complaint Action Plan

On-Call Team. The complaint intake process must be sufficiently resilient to ensure consistency, timeliness and comprehensiveness at all times. Establishing an on-call team to manage and triage incoming complaints during mass gatherings, large events and periods of civil unrest will ensure stability should you encounter a sudden surge of complaints. The on-call team begins preliminary investigative work, including:

  • Conducting complainant and witness interviews
  • Reviewing video evidence
  • Canvassing the incident scene and social media sites
  • Collecting other pertinent evidence

Agencies should identify key triage factors in advance, such as:

  • Seriousness of the complaint and injury, if applicable
  • Presence of actionable evidence
  • Cooperation of the victim, complainant or witness
  • Possibility of criminal charges against the officer

Complaint Dashboard. To avoid compromising a subsequent investigation, the investigating agency must be transparent in the complaint information received and provide assurance that action is being taken to ensure accountability. A police complaint dashboard – specifically one that displays complaint data related to the event sparking the increase in complaints – provides transparency to the public. Dashboard data should include, but not be limited to:

  • Nature of the complaint
  • Date and location of the incident
  • Demographic information for the involved officer, complainant or victim
  • Officer rank
  • Complaint resolution

Media Engagement. Public safety agencies should proactively leverage media outlets, including social media, to acknowledge that they have received complaints. Agencies should affirm that all complaints will be subject to review and investigation. These efforts and accountability increase transparency regarding the handling of police complaints.

Community Outreach. The willingness of the community to actively partner in crime prevention and detection hinges on its trust and confidence in policing institutions and their willingness to hold themselves accountable. Direct engagement with community residents and stakeholders is a critical step in building public confidence. Agencies must inform the community about the police oversight and accountability system, engage in an open dialogue about the complaint data, and encourage community members to file complaints.

Community outreach provides agencies the opportunity to hear about community members’ experiences with the police, barriers and fears with regard to filing complaints, and their perspectives on appropriate outcomes. These outreach efforts must include two-way conversations and should occur along with the broad dissemination of information about police misconduct.

Ensure Integrity and Accountability in the Complaint Process

The integrity of the police oversight and accountability system relies on timeliness, transparency and community engagement. Adherence to these principles is critical when an increase in received complaints is likely. Public safety agencies that incorporate a complaint action plan are best positioned to ensure their investigations align with best practices. Moreover, by developing such a plan, your agency’s commitment to accountability is reinforced with the public.

Jensen Hughes’ team of law enforcement consultants has planned, led and implemented many of the most comprehensive transformation initiatives over the past three decades. Learn more about how we can help your law enforcement agency provide greater transparency and regain or deepen your community’s trust.

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About the author

Sydney R. Roberts, JD
A proven leader in police accountability, Sydney has provided insight and guidance on civil and human rights matters impacting law enforcement, including illegal search and seizure, denial of counsel and officer-involved shootings.