17 minute read

How Police Officers Are Shielded from Accountability

Mia Vuckovich / Political Science 2022

In the wake of George Floyd’s murder in Minneapolis, widespread news coverage and nationwide protests forced the city to act.[1] The four police officers involved were fired and charged, and the city council promised to dismantle the police department.[2][3][4] In June, 71 percent of White Americans said that racism and discrimination were a “big problem.”[5]

But any hopes of meaningful change have since faltered. The council’s pledge to “end policing as we know it” fell Jacob Blake was shot by police in Wisconsin, and a vigilante killed two protesters in the aftermath.[7] In September, a grand jury failed to indict Breonna Taylor’s killers for murder or manslaughter.[8]

This lack of accountability for violent officers is not the result of individual bad actors. Police brutality persists because protections for law enforcement are embedded in legislation, institutions, and the legal system.

THE MYTH OF PROTECTION

Modern policing evolved from systems that promoted the control of Black people and the working class.[9][10] In the South, slave patrols formed to capture slaves attempting to escape. The North wasn’t much better; the first police precincts were established in emerging industrial cities to quell “riots” by exploited factory workers.[11]

These origins show that police have long protected property over human lives. Although Southern slave patrols were abolished along with slavery, they were replaced by police forces designed to control the newly freed Black population.[12] They enforced poll taxes and other

apart.[6] In August, voter suppression

This lack of accountability for violent officers is not the result of individual bad actors. Police brutality persists because protections for law enforcement are embedded in legislation, institutions, and the legal system.

methods. Racist policing and excessive force emerged nationwide to perpetuate White control of political and social systems.[13]

American crimefighting is rooted in societal control, and race determines what counts as crime and gets targeted for oversight. As sociologist Alex Vitale writes, “American crime control policy is structured around the use of punishment to manage the

‘dangerous classes,’

masquerading as a system of justice.”[14] White supremacy is embedded in our law enforcement. Black men are three times more likely than their White counterparts to be killed by police, and Black teens are twenty-one times more likely.[15][16] Our country lacks

effective mechanisms to check and balance a profession created to enforce White supremacy.

However, the attack on Black lives is not simply about failed policing. The idea that police exist to protect us is a myth. The Supreme Court has twice held that the Fourteenth Amendment does not obligate police to protect people from harm.[17][18] Rather, police serve the state to “fabricate social order,” which has always meant maintaining White supremacy. Given this, it’s no surprise that officers nationwide enjoy codified protections.[19]

LAW ENFORCEMENT OFFICERS’ BILLS OF RIGHTS

Many state laws prevent officers from being held responsible for misconduct, including improper use of force. While several of these laws aim to protect officers’ constitutional rights, these affordances are not extended to ordinary citizens. As of 2015, sixteen states have Law Enforcement Officers’ Bills of Rights.[20] While they vary by state, common provisions include:

Departments must notify an officer and their union before pursuing a complaint. Officers get between one and ten days to “cool off” before they have to respond to department questions. Officers must be informed of the complainants and any testimony against them before they are questioned. In some states, officers, unlike complainants, can review footage of an incident.[21] During questioning, investigators cannot harass, threaten, or promise rewards to the officer. Most civilian suspects do not get this privilege.[22] Departments must continue to pay salaries, benefits, and attorney’s fees to suspended officers.

Rights for law enforcement are not inherently wrong, but these provisions are. They enable police officers to act above the law. This power imbalance is especially dangerous when civilians accuse officers of misconduct, as victims face concrete disadvantages.

POLICE UNIONS AND CULTURE

These provisions and the unions that lobby for them reflect a dangerous policing philosophy. In theory, police unions seem like a good thing; officers should be entitled to organize

like any other profession. However, these unions embody regressive policing, protecting cops by sacrificing transparency and accountability.[23]

Union contracts act as a safety net for officers and establish countless privileges, similar to those provided in bills of rights. Per a 2002 report, departments with union contracts were half as likely to validate an excessive force complaint, even though they receive 50 percent more complaints.[24] Furthermore, departments with more protective union contracts are more likely to kill unarmed civilians.[25] These contracts directly hurt Black Americans, who are more likely to suffer from police brutality but are less likely to have their complaints sustained.[26]

Police unions also lobby for legislation that reduces transparency and liability. In New York, officer records are “confidential and not subject to inspection or review” except by court order.[27] Twenty-two other states and Washington, DC, make disciplinary records confidential; fifteen other states severely limit access.[28] Many states wipe records clean after a set period, some as short as six months.[29]

Police unions frequently oppose the creation of civilian review boards and move to weaken established ones.[30] Often, review boards simply gather evidence and cannot give recommendations or discipline officers. Some union contracts mandate internal review boards, which support their own and often allow officers to resign before an investigation. [31] In 2010, David Cornelius Smith died in Minnesota after an officer kneeled on his neck for four minutes while another straddled his legs; after an internal review, the officers faced no discipline.[32]

When an officer is accused of misconduct, unions can help them appeal the decision to an independent arbitrator. In Minnesota, almost half of terminated officers are reinstated on appeal. This rate is similar to that of other unions, but the way in which appeals are handled poses an issue.[33]

Rather than assessing the misconduct and reason for termination, arbitrators look at the circumstances, such as the officer’s record and what kind of discipline was imposed in similar situations. They also focus on whether the department had a specific policy or training in place regarding the circumstances. For arbitrators, this system ensures due process; however, it goes beyond preserving legal rights. It excuses and perpetuates misconduct.[34]

Although police unions originated with the same desires as other organized labor forces— reasonable hours, better working conditions, fair pay—they are still a part of historically unjust policing. They reinforce White supremacy in criminal justice and have deadly consequences for Black communities. Furthermore, these unions appoint White leaders who “consistently take stances against the safety and rights of Black Americans,” even as law enforcement becomes more racially diverse.[35]

Union lobbying encourages the “blue wall of silence”—the informal rules that cause cops to ignore each other's misconduct.[36] This culture prevents police departments from disciplining officers and discourages officers from holding each other accountable.

In Baltimore, after Joe Crystal reported fellow officers for excessive force, he stopped receiving backup and had a dead rat left on his windshield.[37] He was told by his supervisor to “keep a lid on it” and was turned away by his union leader. Crystal’s story reflects the “blood in, blood out” culture that makes it impossible for law enforcement to report misconduct. Even after officers retire, they are still expected to abide by this code. Ex-officers face backlash for testifying against current ones. This culture reflects the corruption and lack of transparency within policing institutions.[38]

QUALIFIED IMMUNITY

Even if a victim overcomes these legislative and institutional challenges, the legal system still poses several obstacles. Long-established Supreme Court precedent makes it difficult to convict an officer of excessive force.

In 1967, the Supreme Court established qualified immunity to protect government officials in cases of minor infractions.[39] It was intended for civil servants acting in good faith who thought they were following the rules. However, Harlow v. Fitzgerald dismissed the good-faith requirement in 1982, paving the way for the expansion of qualified immunity.[40]

Qualified immunity shields police officers from lawsuits unless they violate a “clearly established” right. To win, victims must find another case with the exact circumstances that sets a precedent for wrongdoing. This standard creates an endless cycle of failed accountability.[41]

Traditionally, qualified immunity cases were always two-pronged. The judge would assess whether an officer used excessive force, then determine if they violated a “clearly established” right.[42] However, in the 2009 decision Pearson v. Callahan, the Supreme Court allowed judges to bypass the question of excessive force. This ruling makes it easier for judges to dismiss suits and further shelters officers from punishment.[43]

Qualified immunity also discourages claims from being brought at all. Lawyers typically take excessive force cases on a forfee basis, meaning they are paid only if their client wins.[44] Because so many cases are dismissed on the grounds of qualified immunity, lawyers have less incentive to take on these suits, and victims have a harder time finding representation.

OBJECTIVE REASONABLENESS

Excessive force claims are also held to an “objective reasonableness” standard, which the Supreme Court established in 1989 in Graham v. Connor. [45] Graham suffered several injuries after being restrained and thrown against a car by police while experiencing a diabetic insulin reaction. When he asked the officers to look in his wallet for a diabetic decal, an officer replied, “I’ve seen a lot of people with sugar diabetes that never acted like this. Ain’t nothing wrong with the motherfucker but drunk. Lock the son of a bitch up.”[46]

Before this case, Johnson v. Glick held that excessive force required an officer to use force “maliciously and sadistically for the very purpose of causing harm.”[47] In contrast, Graham held that the jury should consider excessive force “from the perspective of a reasonable officer on the scene, rather than with the 20/20 vision of hindsight.” When Graham’s case was remanded to the lower court, the jury used this new framework to side with the officer.[48]

Graham did little to clarify what “reasonable officer” meant. Furthermore, it caused police departments to create equally vague standards. A 2019 study found that use-offorce policies in the seventy-five largest US cities regularly fail to provide meaningful instruction on when and how to use force. Only 31 percent of policies require officers to exhaust alternatives before using deadly force, and only 17 percent instruct officers to use force that is proportional to a person’s resistance. Nonetheless, all of these policies cite Graham’s “reasonable officer” standard.[49]

Qualified immunity and objective reasonableness are only the beginning of legal protections for cops. Most police officers benefit from an American predisposition to side with law enforcement.[50] Grand juries are often reluctant to indict them.[51] Prosecutors and judges are inclined to dismiss misconduct cases.[52] When cases do go to trial, juries are unlikely to convict. From January 2005 to April 2017, only 35 percent of arrested officers were convicted, about half the civilian conviction rate.[53]

WHERE DO WE GO FROM HERE?

These issues are only the tip of the iceberg; there are countless other faults within our criminal justice system that protect law enforcement and hurt their victims, especially low-income people and people of color.

Reforms targeting these issues will not undo centuries of enduring, systemic racism. They are ineffective and fail to improve trust in law enforcement. policing is rooted in racist slave and property control systems. Its focus has always been property, not serving communities. The concept of “procedural justice”—that if police apply the law in an unbiased and procedurally proper way, public trust will increase and fewer violent confrontations will occur—is a fallacy.

Modern law enforcement has failed, and we can no longer afford to fund failure. We must reject intensive over-policing and invest in policies that improve public safety and promote

racial justice. Over the past forty years, the scope of policing has vastly expanded to encompass homelessness, untreated mental illness, and youth

Modern violence; consequently, policing

The concept of “procedural justice” —that if police apply the law in an unbiased and procedurally proper way, public trust will increase and fewer violent confrontations will occur—is a fallacy.

of these issues has intensified. Policing and criminalization cannot solve social issues.[56]

It’s time to reconsider the role of the police and establish new institutions that strengthen communities. American policing costs around $115 billion annually; in Los Angeles, it costs about one-sixth of the city’s budget.[57]

[58] Budgets should be reallocated to economic initiatives that address racial segregation and reduce the need for police. This means investing in affordable housing, training mental health professionals to respond to corresponding 911 calls, and funding educational services so that they no longer depend on property taxes.[59]

Most cities already have organizations or programs that attempt to address these issues; they are just drastically underfunded. [60] Reallocating policing budgets would boost these initiatives. Furthermore, advocacy groups nationwide have developed proposals and strategies for their respective areas.

In Durham, North Carolina, Durham Beyond Policing proposed a Community-Led Safety and Wellness Task Force to maintain public safety and develop “viable structural alternatives to policing and incarceration.”[61] In Eugene, Oregon, the CAHOOTS program provides crisis intervention through 911 dispatchers.[62] In Chicago, the Black Youth Project has developed an “Agenda to Build Black Futures,” which provides economic and social reforms to address structural racism. These organizations provide starting points for any city looking to rethink its approach to public safety.[63]

This isn’t a case of “a few bad apples.” This isn’t a case of good cops and bad cops. Policing is broken, racist, and oppressive. It does not hold officers accountable for their actions, and it never will.

[1] “George Floyd Protests: Peaceful Weekend Across U.S.” Accessed November 9, 2020. https://www.wsj.com/livecoverage/protests-george-floyd-death-2020-06-06. [2] Campbell, Josh, Sara Sidner, and Eric Levenson. “All Four Former Officers Involved in George Floyd's Killing Now Face Charges,” June 4, 2020. https://www.cnn.com/2020/06/03/us/george-floyd-officers-charges/index.html. [3] Brittany Shammas, Kim Bellware. “Murder Charges Filed against All Four Officers in George Floyd's Death as Protests against Biased Policing Continue,” June 4, 2020. https://www.washingtonpost.com/nation/2020/06/03/george-floyd-police-officers-charges/. [4] Andone, Dakin, and Josh Campbell. “Minneapolis City Council Members Intend to Defund and Dismantle the City's Police Department,” June 8, 2020. https://www.cnn.com/2020/06/07/us/george-floyd-protests-sunday/index.html. [5] Taylor, Keeanga-Yamahtta, and Alexis Okeowo. “We Should Still Defund the Police,” August 14, 2020. https://www.newyorker.com/news/our-columnists/defund-the-police. [6] Herndon, Astead W. “How a Pledge to Dismantle the Minneapolis Police Collapsed,” September 26, 2020. https://www.nytimes. com/2020/09/26/us/politics/minneapolis-defund-police.html. [7] Allam, Hannah. “Vigilante? Militia? Confusion And Politics Shape How Shooting Suspect Is Labeled.” NPR. NPR, August 28, 2020. https://www.npr.org/2020/08/28/907130558/ vigilante-militia-confusion-and-politics-shape-how-shooting-suspect-is-labeled. [8] Packer, ZZ, and Jelani Cobb. “The Empty Facts of the Breonna Taylor Decision.” The New Yorker, September 27, 2020. https://www.newyorker.com/culture/ cultural-comment/the-empty-facts-of-the-breonna-taylor-decision. [9] Fountain, Ben. “Slavery and the Origins of the American Police State.” Medium. GEN, May 29, 2020. https://gen.medium.com/slavery-and-the-origins-of-the-americanpolice-state-ec318f5ff05b. [10] Mitrani , Sam. “The Police Were Created to Control Working Class and Poor People, Not 'Serve and Protect'.” In These Times, January 6, 2016. https://inthesetimes.com/working/entry/17505/police_and_poor_ people. [11] Jabali, Malaika. “If You're Surprised by How the Police Are Acting, You Don't Understand US History.” The Guardian. Guardian News and Media, June 5, 2020. https://www.theguardian.com/commentisfree/2020/jun/05/ police-us-history-reform-violence-oppression. [12] Alexander, Michelle. The New Jim Crow: Mass Incarceration in the Age of Colourblindness. UK: Penguin Books, 2019. [13] Vitale, Alex S. The End of Policing. London: Verso, 2018. [14] The End of Policing. [15] Edwards, Frank, Michael H. Esposito, and Hedwig Lee. “Risk of Police-Involved Death by Race/Ethnicity and Place, United States, 2012–2018.” American Journal of Public Health 108, no. 9 (2018): 1241–48. https://doi. org/10.2105/ajph.2018.304559. [16] Flatow, Nicole. “Report: Black Male Teens Are 21 Times More Likely To Be Killed By Cops Than White Ones.” ThinkProgress, October 10, 2014. https://archive.thinkprogress.org/report-black-male-teens-are21-times-more-likely-to-be-killed-by-cops-than-white-ones-72fb08a1dbda/. [17] “DeShaney v. Winnebago County Department of Social Services.” Oyez. Accessed November 9, 2020. https://www.oyez.org/cases/1988/87-154. [18] “Castle Rock v. Gonzales.” Oyez. Accessed November 9, 2020. https://www.oyez.org/cases/2004/04-278. [19] Neocleous, Mark. The Fabrication of Social Order: A Critical Theory of Police Power. LONDON; STERLING, VIRGINIA: Pluto Press, 2000. Accessed November 9, 2020. doi:10.2307/j.ctt18fs9s7. [20] Hager, Eli. “Blue Shield.” The Marshall Project. The Marshall Project, April 27, 2015. https://www.themarshallproject.org/2015/04/27/blue-shield. [21] Netflix. 2019. “The Broken Policing System | Patriot Act with Hasan Minhaj | Netflix.” Youtube. https://www.youtube.com/watch?v=km4uCOAzrbM. [22] Najdowski, Cynthia J., and Catherine L. Bonventre. “Deception in the Interrogation Room.” Monitor on Psychology. American Psychological Association, May 2014. https://www.apa.org/monitor/2014/05/jn. [23] Butler, Paul. “Why the Fraternal Order of Police Must Go.” The Marshall Project. The Marshall Project, October 12, 2017. https://www.themarshallproject. org/2017/10/11/why-the-fraternal-order-of-police-must-go. [24] Bureau of Justice Statistics and Matthew J. Hickman. 2006. “Citizen Complaints about Police Use of Force.” Law Enforcement Management and Administrative Statistics, (June). NCJ 210296. https://www.bjs.gov/content/pub/pdf/ccpuf.pdf. [25] Rad, Abdul. “Police Institutions and Police Abuse: Evidence from the US.” SSRN Electronic Journal, 2018. https://doi.org/10.2139/ssrn.3246419. [26] Friedman, Lawrence M. Fisher, George. Crime Conundrum: Essay on Criminal Justice. S.1.:Routledge, 2020. [27] Henning, A. “A Guide to 50-a, the Most Contentious State Law on the Books.” CSNY, October 18, 2019. https://www.cityandstateny.com/articles/policy/ criminal-justice/reformers-look-to-repeal-or-reform-50a.html. [28] Lopez, German. “How to Reform American Police, According to Experts.” Vox. Vox, June 1, 2020. https://www.vox.com/2020/6/1/21277013/police-reform-policies-systemic-racism-george-floyd. [29] Reports, Special. “Special Report: Police Union Contracts Offer Shield of Protection.” Reuters. Thomson Reuters, January 13, 2017. https://www.reuters.com/investigates/special-report/usa-police-unions/. [30] Dewan, Shaila, and Serge F. Kovaleski. “Thousands of Complaints Do Little to Change Police Ways.” The New York Times. The New York Times, May 30, 2020. https://www.nytimes.com/2020/05/30/us/derek-chauvin-george-floyd.html. [31] Nolan, Thomas. “Behind the Blue Wall of Silence.” Men and Masculinities 12, no. 2 (2009): 250–57. https://doi.org/10.1177/1097184x09334700. [32] Matos, Alejandra, and Randy Furst. “Minneapolis Cops Rarely Disciplined in Big-Payout Cases.” Star Tribune. Star Tribune, June 3, 2013. https://www.startribune.com/minneapolis-cops-rarely-disciplined-in-big-payout-cases/209811991/. [33] Gottfried, Mara H., and Sarah Horner. “How Often Do Arbitrators Reinstate Fired Cops? Just under Half the Time.” Twin Cities. Twin Cities, June 22, 2019. https://www.twincities.com/2019/06/23/how-often-do-arbitrators-reinstate-fired-cops-just-under-half-the-time/. [34] “How Often Do Arbitrators Reinstate Fired Cops? Just under Half the Time.” [35] Butler, Paul. “Why the Fraternal Order of Police Must Go.” The Marshall Project. The Marshall Project, October 12, 2017. https://www.themarshallproject.org/2017/10/11/why-the-fraternal-order-of-police-must-go. [36] Johnson, Olivia. Blue Wall of Silence: Perceptions of the Influence of Training on Law. Universal Publishers, 2010. [37] Murdock, Sebastian. “'Rat Cop' Joe Crystal Shunned From Baltimore Police Department After Reporting Officer Brutality.” HuffPost. HuffPost, December 7, 2017. https://www.huffpost.com/entry/baltimore-joe-crystal_n_7582374. [38] Hayden, Philip. “Why an Ex-FBI Agent Decided to Break through the Blue Wall of Silence.” USA Today. Gannett Satellite Information Network, February 1, 2019. https://www.usatoday.com/story/opinion/policing/2019/01/31/blue-wall-of-silence-policing-the-usa-cops-community/2604929002/. [39] “Pierson v. Ray - 386 U.S. 547, 87 S. Ct. 1213 (1967).” Community. Accessed November 9, 2020. https://www.lexisnexis.com/community/casebrief/p/casebrief-pierson-v-ray. [40] “Harlow v. Fitzgerald - 457 U.S. 800, 102 S. Ct. 2727 (1982).” Community. Accessed November 9, 2020. https://www.lexisnexis.com/ community/casebrief/p/casebrief-harlow-v-fitzgerald. [41] Finn, Tyler. “Qualified Immunity Formalism: ‘clearly Established Law’ And The Right To Record Police Activity.” Columbia Law Review. Accessed November 9, 2020. https://columbialawreview.org/content/qualified-immunity-formalism-clearly-established-law-and-the-right-to-record-police-activity/. [42] “Qualified Immunity Formalism: ‘clearly Established Law’ And The Right To Record Police Activity.” [43] “Pearson v. Callahan - 555 U.S. 223, 129 S. Ct. 808 (2009).” LexisNexis. Accessed November 9, 2020. https://www.lexisnexis.com/community/casebrief/p/casebrief-pearson-v-callahan. [44] Ali, Amir H., Emily Clark, Kelly Hayes, Gabe Newland, and Matt Henry. “Qualified Immunity: Explained.” The Appeal, June 20, 2019. https://theappeal.org/qualified-immunity-explained/. [45] “Graham v. Connor - 490 U.S. 386, 109 S. Ct. 1865 (1989).” LexisNexis. Accessed November 9, 2020. https:// www.lexisnexis.com/community/casebrief/p/casebrief-graham-v-connor. [46] Daley, Jim, Kiran Misra, Raven Geary, Lucia Geng, Jonathan Ballew, and Mateo Zapata. “Supreme Court of the Youth / Police Project in Graham v. Connor.” South Side Weekly, July 30, 2019. https://southsideweekly.com/supreme-court-youth-police-project-graham-v-connor/. [47] “Johnson v. Glick.” Casetext. June 29, 1973. https://casetext.com/case/johnson-v-glick. [48] Obasogie, Osagie K. “The Bad-Apple Myth of Policing.” The Atlantic. Atlantic Media Company, June 16, 2020. https://www.theatlantic.com/politics/archive/2019/08/how-courts-judge-police-use-force/594832/. [49] Obasogie, Osagie K., and Zachary Newman. “The Endogenous Fourth Amendment: An Empirical Assessment Of How Police Understandings Of Excessive Force Become Constitutional Law.” Cornell Law Review 104, no. 1281 (n.d.): 1281–1336. [50] “The Endogenous Fourth Amendment: An Empirical Assessment Of How Police Understandings Of Excessive Force Become Constitutional Law.” [51] Lopez, German. “Grand Juries Usually Don't Indict Police Officers. Should They Be Changed?” Vox. Vox, December 31, 2014. https:// www.vox.com/2014/12/31/7468775/grand-jury. [52] Ross, Janell. “Police Officers Convicted for Fatal Shootings Are the Exception, Not the Rule.” NBCNews.com. NBCUniversal News Group, March 14, 2019. https://www.nbcnews.com/news/ nbcblk/police-officers-convicted-fatal-shootings-are-exception-not-rule-n982741. [53] Park, Madison. “Police Shootings: Trials, Convictions Are Rare for Officers.” CNN. Cable News Network, October 3, 2018. https://www.cnn.com/2017/05/18/ us/police-involved-shooting-cases/index.html. [54] Nesvet, Matthew. “My Year As A New Orleans Consent Decree Insider.” My Year As A New Orleans Consent Decree Insider, July 30, 2019. https://theappeal.org/my-year-as-a-new-orleansconsent-decree-insider/. [55] Jannetta, Jesse, Sino Esthappan, Jocelyn Fontaine, Mathew Lynch, and Nancy La Vigne. “Learning to Build Police-Community Trust.” Urban, August 2019. https://www.urban.org/sites/default/files/publication/100705/learning_to_build_police-community_trust_3.pdf. [56] Donnella, Leah. 2020. “How Much Do We Need The Police?” NPR. https://www.npr.org/sections/codeswitch/2020/06/03/457251670/how-much-do-we-need-the-police. [57] Levin, Sam. “What Does 'Defund the Police' Mean? The Rallying Cry Sweeping the US – Explained.” The Guardian. Guardian News and Media, June 6, 2020. https://www.theguardian.com/us-news/2020/jun/05/defunding-the-police-us-whatdoes-it-mean. [58] “LA City Council Slashes LAPD Funding By $150M.” CBS Los Angeles. CBS Los Angeles, July 1, 2020. https://losangeles.cbslocal.com/2020/07/01/la-city-council-could-slash-lapd-funding-by-150m-as-it-finalizes-new-budget-wednesday/. [59] Lopez, Christy. “Opinion | Defund the Police? Here's What That Really Means.” The Washington Post. WP Company, July 6, 2020. https://www.washingtonpost.com/opinions/2020/06/07/ defund-police-heres-what-that-really-means/. [60] Donnella, Leah. 2020. “How Much Do We Need The Police?” NPR. https://www.npr.org/sections/codeswitch/2020/06/03/457251670/how-much-do-we-need-the-police. [61] Durham Beyond Policing Coalition. N.D. “Proposal For A Community-led Safety And Wellness Task Force.” Accessed November 9, 2020. https://durhambeyondpolicing.org/wp-content/uploads/2019/07/Durham-Beyond-Policing-Budget-Proposal-2019-2020. pdf. [62] “CAHOOTS.” White Bird Clinic, July 31, 2020. https://whitebirdclinic.org/cahoots/. [63] “SOLUTIONS.” Agendatobuild. Accessed November 9, 2020. https://www.agendatobuildblackfutures.com/solutions.

This article is from: