JUNE 2019
CITY OF CHICAGO OFFICE OF INSPECTOR GENERAL
REVIEW OF THE CHICAGO POLICE DEPARTMENT'S MANAGEMENT OF SCHOOL RESOURCE OFFICERS FOLLOW-UP INQUIRY
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REPORT OF THE PUBLIC SAFETY SECTION OF THE OFFICE OF INSPECTOR GENERAL
JOSEPH M FERGUSON INSPECTOR GENERAL
CITY OF CHICAGO OFFICE OF INSPECTOR GENERAL 740 NORTH SEDGWICK STREET, SUITE 200 CHICAGO, ILLINOIS 60654 TELEPHONE: (773) 478-7799 FAX (773) 478-3949
JUNE 13, 2019
TO THE MAYOR, CHAIR OF THE COMMITTEE ON PUBLIC SAFETY, CITY COUNCIL, CITY CLERK, CITY TREASURER, AND RESIDENTS OF THE CITY OF CHICAGO:
The City of Chicago Office of Inspector General (OIG) Public Safety Section (PS) has completed a follow-up to its September 2018 review ofthe Chicago Police Department's (CPD or "the Department") management of School Resource Officers (SRO) assigned to Chicago Public Schools (CPS). Based on the Department's responses, OIG concludes that CPD has not fully implemented all of the corrective actions related to the review findings.
OIG's September 2018 review reported that, contrary to national established best practices:
CPD SROs operated in public schools without a CPD-CPS Memorandum of Understanding (MOU) or intergovernmental agreement (dating back to January 1, 2017).
GPD lacked policies or procedures that detailed SRO recruitment, selection, placement, training, roles and responsibilities, and evaluation.
CPD lacked written guidance specifying SRO roles and responsibilities.
CPD lacked sufficient controls, guidance, and standards to evaluate SRO performance.
CPD lacked current rosters of officers working as SROs and the schools to which they were assigned.
Based upon the results ofthe evaluation, OIG recommended that the Department immediately:
1) Work with CPS, juvenile justice entities, and civil rights and community stakeholders to draft and implement an MOU that meets constitutional and statutory civil rights requirements. The MOU should:
State the purpose ofthe SRO partnership;
Outline the roles and responsibilities of CPD, CPS, and schools
Emphasize that SROs should not be involved in routine student disciplinary matters;
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Define what information CPS and CPD will share;
Establish required initial and ongoing training for officers assigned as SROs; and
Establish performance evaluations aligned with SROs' established roles and training that measures SROs' ability to de-escalate situations and use alternatives to arresting students.
Collaborate with CPS, students, families, and community stakeholders to create hiring guidelines for SROs.
Create Department policies and procedures, aligned with best practice and the MOU, that address SRO recruitment, selection, placement, training, roles and responsibilities, and evaluation.
Maintain and regularly update rosters of officers assigned to CPS.
Designate a program coordinator to enhance coordination and accountability.
In response, CPD concurred with many ofthe findings and some ofthe recommendations detailed in the report. CPD's response indicated that by the beginning ofthe 2019-20 school yearthe Department would:
Undertake best efforts to enter into an MOU with CPS that clearly delineates authority and specifies procedures for CPD officer interaction with students while on school grounds;
Develop a policy that defines roles, responsibilities, and appropriate actions of SROs, which will include an express prohibition on the administration of school discipline by CPD officers and provisions for the collection, analysis, and use of data regarding CPD activities in schools;
Develop and implement screening criteria to ensure SROs have the qualifications, skills, and abilities necessary to work safely and effectively with students, parents/guardians, and school personnel; and
Ensure that all SROs receive initial specialized and annual refresher trainings and encourage SROs to exercise discretion to use alternatives to arrest and referral to juvenile court.
OIC acknowledged CPD's expressed commitment to making these necessary reforms. However, the reforms proposed by CPD in its response did not address other crucial areas of concern. Specifically, CPD did not acknowledge or respond to the following recommendations:
To include a broad range of community stakeholders in the creation ofthe MOU;
To create hiring guidelines and include a broad range of community stakeholders in the process;
To state the purpose of the SRO partnership with CPS in the MOU;
To define the data and information that will be shared between CPD and CPS;
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To establish performance evaluations for SROs; and
To maintain and regularly update rosters of SROs.
In February 2019, OIC inquired about the progress the Department was making toward these goals. Based on CPD's response, OIG concludes that the Department has fully implemented one recommendation, has not implemented one recommendation, and three recommendations remain pending. Overall, CPD has failed to undertake action with the immediacy called for by OIG or consonant with the deep community consternation over the method, manner, means and, in some quarters, very existence ofthe program. .
Among other things, while CPD has ensured that the roster of officers assigned to schools is regularly updated, it has not adopted OIG's recommendation for an SRO program coordinator. CPD is still working towards the implementation of an MOU, SRO policies, procedures, and hiring guidelines, all of which require collaboration with CPS, parents, students, and various community stakeholders.
We thank the staff and leadership of CPD for their cooperation and their responsiveness to our follow-up inquiries.
Respectfully,
Joseph Lipari
Deputy Inspector General, Public Safety City of Chicago
Mark Flessner, Corporation Counsel, City of Chicago
Dana O'Malley, General Counsel, Chicago Police Department
Maggie Hickey, Independent Consent Decree Monitor
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OIC FILE # 19-0273
CPD'S MANACEMENTOF SCHOOL RESOURCE OFFICERS FOLLOW-UP INQUIRY JUNE 13, 2019
FOLLOW-UP RESULTS
In February 2019, OIG followed up on a September 2018 review ofthe Chicago Police Department's (CPD or "the Department") management of School Resource Officers (SRO). Below, is a summary of OIG's 2018 review recommendations associated with the findings and the status ofthe corrective actionsthe Department has taken.
Our follow-up inquiry did not observe or test any implemented procedures reported by the Department. We are solely reporting on the development and adoption of policies and procedures as reported by CPD; thus, we make no determination as to their effectiveness, which would require an evaluation with full testing. However, if the corrective actions that are pending are fully implemented by CPD, this will address the core concerns raised in the original review.
OIG uses four categories to describe the Status of Corrective Action:
IMPLEMENTED - The department has implemented actions that may reasonably be expected to resolve the core findings noted in the original evaluation.
PARTIALLY IMPLEMENTED - The department has implemented actions in response to the audit, but the actions do not fully address the findings raised in the original evaluation.
PENDING IMPLEMENTATION - The department has initiated action plans that, if fully implemented, may reasonably be expected to resolve the core findings ofthe original evaluation. However, the department has not completed implementation.
NOT IMPLEMENTED - The department has not initiated or implemented any actions responsive to OIG's findings.
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OIG FILE # 19-0273
CPD'S MANAGEMENT OF SCHOOL RESOURCE OFFICERS FOLLOW-UP INQUIRY
CPD should immediately work with CPS, juvenile justice entities, and civil rights and community stakeholders to draft and implement an MOU that meets constitutional and statutory civil rights requirements. The MOU should:
State the purpose ofthe SRO partnership;
Outline the roles and responsibilities of CPD, CPS, and schools;
Emphasize that SROs should not be involved in routine student disciplinary matters;
Define what information CPS and CPD will share;
Establish required initial and ongoing training for officers assigned as SROs; and
Establish performance evaluations aligned with SROs' established roles and training that measure SROs' ability to de-escalate situation and use alternatives to arresting students.
STATUS OF CORRECTIVE ACTION: PENDING IMPLEMENTATION
In response to OIG's follow-up inquiry, CPD stated that it is committed to working with CPS leadership to draft and implement a new MOU before the start ofthe 2019-2020 school year. CPD's timetable disregards OIG's urging to act on the findings and recommendations immediately. Since the publication of OIG's original review, an entire additional school year has transpired without an agreement in place to govern the placement and operation of SROs in Chicago Public Schools. The Department has stated that it plans to present a draft ofthe agreement to the Chicago Board of Education prior to its adoption by CPD and CPS. The Department has indicated it will undertake best efforts to enter into a MOU that clearly defines:
' 1. The duties, responsibilities, and appropriate actions of officers assigned as SROs;
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OIG FILE # 19-0273
CPD'S MANAGEMENT OF SCHOOL RESOURCE OFFICERS FOLLOW-UP INQUIRY
Selection criteria for officers assigned as SROs;
The initial and refresher training requirements for officers assigned as SROs; and
The collection, analysis, and use of data regarding CPD activities in CPS schools.
CPD and CPS leadership identified the following issues that will be addressed in the new MOU:
SRO familiarity with the CPS Student Code of Conduct and CPS disciplinary procedures;
SRO responsibility to respond immediately to calls for service involving emergency situations;
SROs' ability to coordinate with school administration and CPS safety and security personnel in problem-solving activities;
Ensuring that police action by SROs should minimize any disruption to the school's normal operation; and
Initiating an SRO prohibition on intervening in routine student disciplinary matters.
In the course of meeting the goals of a new MOU, CPD reports that it has begun the process of meeting with various community stakeholders, students, families, school personnel, and officers assigned as SROs. More specifically, the Department stated that "CPD members have hosted several meetings with CPS officials since 2018 and are currently in the process of scheduling additional meetings in the coming weeks."1
1 Members of OIG's Public Safety Section attended a community event on SROs hosted by CPD on May 6, 2019 The event was held at Paul Laurence Dunbar College Preparatory School To the extent it is representative of a larger community engagement process for input regarding a new CPD-CPS MOU, the event may not have been sufficiently open to assure the input of the broad and diverse array of community stakeholder viewpoints and experiences, nor sufficiently advertised or transparent to satisfy community interest, as expressed to OIG by numerous institutional and community stakeholders
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OIC FILE # 19-0273
CPD'S MANAGEMENTOF SCHOOL RESOURCE OFFICERS FOLLOW-UP INQUIRY
CPD should collaborate with CPS, students, families, and community stakeholders to create hiring guidelines for SROs.
STATUS OF CORRECTIVE ACTION: PENDING IMPLEMENTATION
CPD stated that it is in the process of creating a revised SRO screening and selection policy that will outline SRO qualifications, selection, placement, and evaluation and satisfy the requirement of the consent decree. Currently, district commanders are charged with individually selecting officers to serve as SROs.
CPD stated that, "in developing screening and selection policy, CPD members within the Office ofthe Superintendent in conjunction with CPS officials, hosted or are scheduled to host community engagement meetings at the following schools: (1) Back of the Yards College Preparatory High School; (2) Chicago Vocational Career Academy High School; (3) John Marshall Metropolitan High School; (4) Sullivan High School; and (5) William Jones College Preparatory High School." CPD indicated that during these community meetings they "met with representatives of the following CPS stakeholder groups: (1) students; (2) families; (3) school personnel; (4) community stakeholders; and (5) officers assigned as SROs". At these meetings, CPD reports that screening criteria and minimum qualifications for SROs were discussed at length.
CPD should create Department policies and procedures, aligned with best practices and the RECOMMENDATION: MOU, that address SRO recruitment, selection,
placement, training, roles and responsibilities, and evaluation.
STATUS OF CORRECTIVE ACTION: PENDING IMPLEMENTATION
CPD stated that it is involved in ongoing conversations with CPS to create policies and procedures regarding SRO recruitment, selection, placement, training, roles and responsibilities, and evaluations to satisfy the consent
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OIG FILE # 19-0273
CPD'S MANAGEMENT OF SCHOOL RESOURCE OFFICERS FOLLOW-UP INQUIRY
decree. According to CPD, over the past three years the Department has participated in meetings hosted byCOFI (Community Organizing and Family Issues) to have ongoing conversations about the relationships that exist between students and officers. Additionally, the Department stated that CPD's Education and Training Division is working with the National Association of School Resource Officers to develop a new training curriculum for officers assigned as SROs that will reflect national best practices.
CPD should maintain and regularly update rosters of officers assigned to CPS.
STATUS OF CORRECTIVE ACTION: IMPLEMENTED
CPD stated that certain members within the Bureau of Patrol have been tasked with updating the roster of SROs before the start ofthe new school year and in January of the following year. CPD supplied OIG with an updated roster of SROs assigned to schools as of January 2019. According to this roster, there are 176 police officers serving as SROs in 75 schools and 22 school sergeants that supervise the assigned SROs.
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CPD should designate a program coordinator to enhance coordination and accountability.
STATUS OF CORRECTIVE ACTION: NOT IMPLEMENTED
CPD stated that due to the constraints of collective bargaining agreements with respective unions it has not established an SRO program coordinator position. The Department noted that it will continue to work towards determining if a program coordinator is necessary as it develops its SRO policies. OIG urges the City Council Committee on Public Safety to probe this asserted constraint, among other topics, in a hearing regarding OIG's SRO findings and recommendations.
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MISSION
The City of Chicago Office of Inspector General (OIG) is an independent, nonpartisan oversight agency whose mission is to promote economy, efficiency, effectiveness, and integrity in the administration of programs and operations of City government. OIG achieves this mission through,
administrative and criminal investigations by its Investigations Section;
performance audits of City programs and operations by its Audit and Program Review Section;
inspections, evaluations and reviews of City police and police accountability programs, operations, and policies by its Public Safety Section; and
compliance audit and monitoring of City hiring and employment activities by its Hiring Oversight Unit.
From these activities, OIG issues reports of findings and disciplinary and other recommendations,
to assure that City officials, employees, and vendors are held accountable for violations of laws and policies;
to improve the efficiency and cost-effectiveness of government operations; and
to prevent, detect, identify, expose, and eliminate waste, inefficiency, misconduct, fraud, corruption, and abuse of public authority and resources.
AUTHORITY
OIG's authority to produce reports of its findings and recommendations is established in the City of Chicago Municipal Code ยงยง 2-56-030(d), -035(c), -110, -230, and 240.
Cover image courtesy of Creative Commons.
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