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October 23,2012

The Honorable Board of Supervisors
County of Los Angeles
383 Kenneth Hahn Hall of Admir'lislration
Los Angeles, California 90012
Dear Supervisors:

30·DAY STATUS OF RECOMMENDATIONS MADE IN THE OCTOBER 18, 2011,
BOARD OF SUPERVISORS' MEETING REGARDING THE MERRICK BOBB AND
OFFICE OF INDEPENDENT REVIEW REGARDING THE JAIL SYSTEM
On October 18, 2011, the Board requested thai the Los Angeles County Sheriffs
Department (Department) report back on the motion to immediately implement the
recommendations previously made by Special Counsel Merrick Bobb and the Office of
Independent Review (OIR). In addition, the Board requested the Department report back
on deputy worn video cameras, the status of the Department's hiring practices, sting
audits, a force rollout team, and the length of time deputies serve in the jails Attached is
an update on each recommendation from the September 18, 2012, response.
Should you have any questions or require additional information , please contact me or
Assistant Sheriff Cecil W. Rhambo, Jr., at (323) 526-5065
Sincerely,

LEROY D. BA
SHERIFF

,'7/ JradHioIl oj ()(,Toir:e

RECOMM ENDATIONS BY MERRICK BOSB AND OFFICE OF INDEPENDENT REVIEW
REGARDING THE JAIL SYSTEM

COUNTY OF LOS ANGELES - SHERIFF'S DEPARTMENT

The purpose of this document is to provide a status of the recommendations by dale
and title, prepared by Special Counsel Merrick Bobb, the Office of Independent Review,
and the Board of Supervisors.

I.

Install surveillance cameras at the Men's Central Jail, the Inmate Reception
Center and the Twin Towers Correctional Facility within 30 days and
develop a plan to purchase and install surveillance cameras at the
remaining jail facilities,
The Deparlment has installed all 705 cameras at Men's Central Jail (MCJ). As of
May 31,2012, all cameras are online and recording.
The Deparlment is installing cameras at Twin Towers Correctional Facility
(TTCF) and the Inmate Reception Center (lRC). CutTently, 673 cameras have
been installed at rTCF (87 recording) and 66 cameras have been installed at
IRC (33 recording).
The attached document (Camera Project Status Reporl) depicts the
Department's current status on camera installation and the projected total of

cameras.
Data Storage
The servers and storage equipment, together, provide storage of video footage
They were deployed the first quarter of 2012. Additional hard drives and storage
ellclosures have been deployed to provide long-tenn storage of the video
footage. Technicians are analyzing equipment efficiency and storage capacity as
cameres are added to the storage system. Options regarding the expansion of
video storage have been considered in order to meet legal and Board approved
requirements for archived video. while ensuring quality resolution at various
frame rates.
The network upgrade for MCJ was completed at the end of April 2012. The
installation of the servers and storage equipment was completed at the end of
May 2012. The network upgrade for all of rTCF and IRe is currently underway
alld is scheduled to be completed in November, 2012. The remaillillg cameras
for TTCF and IRC are scheduled to be brought on line in December, 2012

Page 1 of 9

RECOMMENDATIONS BY MERRICK BOBB AND OFFICE OF INDEPENDENT REVIEW
REGARDING THE JAIL SYSTEM

Po/icv
The Sheriffs Department has implemented new policies to propmfy inspect and
secure all equipment associated with the video surveillance system. The
Department is finalizing its policies regarding the review of video recordings
involving a use of force. Personnel are required to write their report prior to
viewing any video recording of force incidents.

II.

Eliminate the use of heavy flashlights as batons to subdue inmates.
Recommendation implemented - Effective September 1. 2012
The Sheriff has directed and approved a new policy to limit the size and weight of
the flashlight. The policy specifies that the flashlights shall not weigh more than
16 ounces, and shall not be more than 13 inches in length. Flashlights longer
than 6 inches sl1all be of plastic or nylon composite ma/erial only The Custody
Division Manual (COM) section 3-06/055.20 Flashlights, was published on
May 23, 2012. The policy was implemented on September 1, 2012. in order to
provide a reasonable period of time to acquire policy conforming flashlights.
In August, 2012, all custody assistants were issued a new high quality flashlight
made of durable lightweight composite material, approximately 13 inches in
length All deputies were provided a light weight battery sleeve to bring their
current duty"issued flashlights into compliance with the new policy

III.

Eliminate the use of "steel-toe" shoes.
Recommendation implemented.
On October 24. 2011, the Department made revisions to the existing "Footwearpolicy (MPP 3-03/225.00). This policy was published into the Department's
Manual of Policy and Procedures and disseminated to all personnel on
febll)ary 10, 2012.
Research of existing personnel showed that Department personnel have never
worn 'steel toe' boots in any capacity: however. the Department formally revised
the policy to strictly prohibit any use of 'steel toe" boots.

IV.

Revise the Policy on Head Strikes with Impact Weapons to forbid all head
strikes. including, but not limited to, head strikes against fixed objects
such as floors, walls or jail bars, unless the standard for lethal force has
been met.
Recommendation implemented.
Page2of9

RECOMMENDATIONS BY MERRICK BOBB AND OFFICE OF INDEPENDENT REVIEW
REGARDING THE JAIL SYSTEM

On October 10, 2011, the Sheriff initiated a "Force Prevention " policy (COM 3021035,00) which provides direction for personnel relating to respect based
treatment of incarcerated individuals, This policy was published into the Custody
Division Manual and disseminated to all custody assigned personnel on
November 8, 2011. The policy was then discussed with the ALADS working
group in which revisions were made. The revised Force Prevention policy was
republished and rodistributed to all personnel in the jails on March 19. 2012.
On October 26, 2011, the Department made additions to the existing
"Unreasonable Force" (MPP 3-01/025.10) policy and the "Activation of
ForcelShooting Response Teams" (MPP 5-09/434.05) 10 slricrly prohibit head
strikes against a hard object. Unless otherwise handled by the Internal Affairs
Bureau (lAB), the Custody Force Response Team (CFRT) responds to all force
incidents where any head strike occurs, whether the strike is initiated by
personnel, or by contact with floors, walls or other hard objects. The
'Unreasonable Force" and "Activation of ForcelShooting Response Teams"
policies were published into the Department's Manual of Policy and Procedures
and disseminated to al/ personnel on February 13, 2012.

V.

Rotate jail deputies between floors at Men's Central Jail and other jail
facilities at no less than six-month intervals.
Recommendation implemented partially.
In January 20", Men's Central Jail began rotating their staff no less than every
six months. After consulting with ALADS, a new Custody Directive "Mandatory
Rotation of Line Personnel in Custody" (12-001) was published and disseminated
to all custody personnel on February 17, 2012, mandating the rotation of all
Custody line personnel every six months within their assigned facility. All
facilities (MCJ, TrCF, IRC, CRDF, MLDC, and all PDe facilities) began rotating
personnel every six months effective February 17, 2012. The Department is
currently assessing the feasibility of rotating deputies amongst proximate custody
facilities_ There are several logistical, scheduling. and labor issues that need to
be overcome before this could be accomplished.

VI.

Enforce the Anti-Retaliation Policy to prevent SherifFs deputies from
retaliating against inmates speaking with legal representatives or inmate
advocacy groups or for expressing dissatisfaction with jail conditions.
Recommendation implemented.
In August 2011, the Department made revisions to the existing "Treatment of
Inmates" (CDM 5-12/005.00) policy to prevent deputies from retaliating againsl
Page30f9

RECOMMENDATIONS BY MERRICK BOBB AND OFFICE OF INDEPENDENT REVIEW
REGARDING THE JAIL SYSTEM

inmates. All staff assigned to Custody Division were provided a fennal briefing
on the revisions to the policy. The briefing began August 4,2011, and continued
for a two-week period. In addition, the Department redistributed tile policy on
October 25, 2011, for another two-week recurring briefing to ensure each staff
member was fully aware of the expectations of the policy and mandated quarterly
recuning briefings be conducted,
The Department made additional revisions to the existing "Treatment of Inmates"
policy in order to separate and create specific orders relating to retaliation
against inmates. The Custody Division Manual, "Anti-Retaliation Policy" (COM 5121005.05) mandates that all complaints of retaliation are forwarded to lAB; the
captain of lAB will determine which unit will conduct the investigation This
revised version of the "Treatment of Inmates· policy and the new "Anti-Retaliation
Policy' were published and disseminated to all custody personnel on
Febmary 27, 2012. In response to further discussions with the ACLU, the
Department is reexamining the current policies

VII.

Interviews of inmates who make claims of excessive force should not be
conducted by, or in the presence of, the deputies or their supervising
sergeant involved in the alleged use of force_
Recommendation implemented
On October, 26, 2011, the Department made revisions to the existing 'Use of
Force Reporting and Review Procedures" (MPP 5-091430.00) policy ensuring
privacy during force interviews, This policy was published in the Department's
Manual of Policy and Procedures and disseminated to all personnel on
February 13, 2012.

VIII.

Interviews of inmates alleging use of force and any witnesses must occur
as soon as feasibly possible, but no later than 48 hours of the incident.
Recommendation implemented.
On October, 26, 2011, the Department made revisions to the existing 'Use of
Force Reporting and Review Procedures' (MPP 5-091430.00) policy directing
supeNisors to immediately conduct interviews. As noted in VII, this policy was
published in the Department's Manual of Policy and Procedures and
disseminated to all personnel Oil February 13, 2012.

IX.

Develop a prioritization process for Use of Force Investigations to ensure
that the most severe incidents are completed within 30 days and that all
others are completed within 60 to 90 days.
Page4of9

RECOMMENDATIONS BY MERRICK BOBB AND OFFICE OF INDEPENDENT REVIEW
REGARDING THE JAIL SYSTEM

Recommendation implemented.
The Department developed the CFRT to ensure that significant force cases. not
handled by lAB, are externally evaluated and completed within 30 days. Upon
completion, they are reviewed by the newly formed Custody Force Review
Committee (CFRC), which consisfs offhree commanders. The last CFRC was
conducted on October 16,2012, and included oversight by Ihe OIR The next
CFRC is scheduled for November 6, 2012. To date, the CFRC has reviewed 51
cases Of those, 5 have been referred to lAB and none have been referred to
ICIB.
The Department continues to process the most severe incidents as lAB
investigations, which are generally completed within 90 days unless unexpected
circumstances arise.
The CFRT Directive was published and disseminaled 10 all custody personnel on
November 7, 2011. The aforementioned CFRT Directive was revised and
published as a Custody Division Policy on May 23, 2012. The CFRC policy was
publish6d and disseminated to all custody personnel on April 16, 2012.

X.

Develop a plan for more intense supervision that requires jail sergeants to
directly supervise jail deputies, including walking the row of jail cells and
floors and responding as soon as possible to any notification of interaction
where force is being used on an inmate.
Recommendation Implemented at MC),
On October 27, 2011. the Department delivered a letter to the Chief Executive
Officer requesting additional supervisory staff in the jails. However, the
Department felt it was imperative to immediately increase staffing at MCJ.
Effective November 6, 2011, 19 sergeants wern added to MCJ's current staffing
to ensure the appropriate supervision was in place. These items were removed
from other critical areas within the Department and deployed to cover both Day
and PM shifts. Funding for Ihese items was requested in a letter to the CEO on
October 26, 2011, however to dale the request has gone unfulfilled. There are
now 2 sergeants assigned to 2000, 3000, 4000, SOOO, and 9000 floors, and a {ul/time sergeant is dedicated to 170011750. All sergeants were briefed on the
expectations to be visible and actively monitoring activity on Ihe floor at aI/ times.
In addition, the Department has completed "duty statements· for all cuslody
personnel to ensure they have a full understanding of the expectations of their
assignment.

Page50f9

RECOMMENDATIONS BY MERRICK BOBB AND OFFICE OF INDEPENDENT REVI EW
REGARDING THE JAIL SYSTEM

XI.

Immediately mandate that all custody medical personnel report all
suspicious injuries of inmates to the Internal Affairs Bureau or the captain
of the jail facility where the inmate is housed.
Recommendation implementoo.
On October 26. 2011, the Deparlment's Medical SelVices Bureau revised the
"InjUly/lllness Report-Inmate" policy (M206.09) to include a provision requiring
medical slaff to advise the facility watch commander in the event an inmate
reports/al/eges that their injurifJs are the result of force used by a Department
employee. This policy was disseminated to all medical personnel on
October 26, 2011.

XII.

Report back on the role of the new jail commanders and how they will be
used to reduce jail violence.
As reporled to the Board on November 1,2011.

Since the implementation of efforts by the Commander Management Task Force
(CMTF) to reduce jail violence and associated use of force incidents, totel
significant uses of forw continue to decline, Two documents are allached
relating to force incidents in the jails.
Force Used by Month - Significant force vs. Less significant force
Force Year to Date - 2007 to 2012
The jail commanders continue to work with eacll custody unit to accomplish the
goals set forlh by the Sheriff.
The jail commanders oversee the op€rations of the CMTF. comprised of five
commanders, eight lieutenanls, eight sergeants, and four support slaff. The
IifJutenants, sergeants, and support staff are all items that were removed from
critical units within the Department and deployed to this task force.
The CMTF Mission is 10 assess and transform the culture of the custody facilities
in order to provide a safe, secure learning environment for our Department
pfJrsonnel and the inmates placed in the Department's care, The CMTF's
purpose is to empower Department personnel to provide a level of
professionalism and selVe the needs of inmates consistent with the Department's
"Core Valuas.·
The CMTF's responsibilities and goals include promoting community trust,
reducing jail violence by changing Ihe deputy culture of the custody environment,
Page6of9

RECOMMENDATIONS BY MERRICK BOBS AND OFFICE OF INDEPENDENT REVIEW
REGARDING THE JAIL SYSTEM

encouraging respect baSfJd communications with inmates, reviewing and
implementing new training for staff assigned to the j ails, preparing and raws/ng
all directNes/policies necessal}' to implement SpeclBl Counsel Marrick BobblOlR
recommendations, analyzing force incidents and developing and implemanting a
clJs/odial career path.
The CMTF and ClJstody SlJpport Services have been working col/aboratively to
fulfill recommen dation requests made by the American Civil Uberlies Union
(ACLU) , Special (;()unsel Merrick 8obb, the OIR, 11nd the Los Angeles County
Board of Supervisors, which P6rlain to the Jaifs.
The eight CMTF lieutenants worl< directly in accomplishing the goals set forth by
the Sheriff and commanders. The eight CMTF SBfge8fltS are comprised as 8 jaJI
force ·roIJ..out~ team (CFRT) who oversee, mentor and reV/8W al/ slgniflCant force
cases It!at maet a particular criterion, yet do not rise to the !evel of an lAB
investigation.

XIII.

Sheriff to work with the Chief Executive Office to immediately study the
feasibility of purchasing officer worn video cameras for all custody
personnel to use, to Identify potontlal funding for this purpose, and
develop appropriate policies and procedures for the use of theso cameras.
Policies should include a requirement that custody personnel record all
interactions with inmates, Including TItle 15 checks, any movement
tflroughout the jail facilities and any use of force. Each fal1unt to record or
Immediately report any use of force against inmates must bo approprial~y
disciplined.
The Department conducted 8 six month "Proof of ConcepF in order 10 determine
Whether there is a precfical use for P6rsonal Video Recording Devic6s (PVRD) In
ClJstody Operations Div/slOfls.
The Department recsived and issued 30 PVRO's for the pilot program. Tile
CM TF drafted a guideline, and conducted training for the voluntser deputies
inVOlved in the program. The PVRO's were worn by deputies interacting with
Inmates at MCJ and TTCF. The Department conducted testing of PVRD models
from two different manuf8Cfurars. The pilot program, which began on February
26, 201 2, was completed on August 3, 2012. The Department provklfKi the
Board with 8 preliminary mport on the pi/oI program Oll Sapfember 18. 2012.
The Department is CUfTfinlly conducting further enalysis on the technology and
related costs.

PSSl6 7 of 9

RECOMMENDAn ONS BY MERRICK BOBB AND OFFICE OF INDEPENDENT REVIEW
REGARDING THE JAIL SYSTEM

XIV.

Consider the feasibility of targeted and random undercover .tlng
operations performed in cu.tody facilities to ensure deputies are working
w1thin polfcy.
As reported in closed seSSIOn.
The Sheriff discussed this motion during the November 1, 2011, clos9d S6SSK)Il
meeting.

XV.

Comsider a " roll-out team " to Investigate when there Is a use offoree in a
custody facility.
Recommendation implemented.
Beginning November 2011, the Department created the CFRT, comprised of
eight sergeants and a lieu/enant, who are tasked with responding to selected
custody facility force inckienls,
The CMTF created set criteria thel mandate facility walch commanders to
contact the CFRT and request a response. The CFRT sergeant will oversee and
assist in rile force documentatIOn for the facility. In the course of reviewing the
Incident. the CFRT sergeant shal! give specific direction to rile handling
superviSf)(" If any policy vioJatlOns are discovered, the CFRT will immediately
essume responsibility of the fOrc6 investigation and inffiate an lAB mvesligalion.

AN incidems requiring e CFRT response WI/I be reviewtJd by a newly formed
CFRC comprised of throe commanders essigned to Custody Division. The

too

CFRC has
authority to order eddilional investigation, make
f9C0mmendations, or request an lAB investigation iflhare appears to ~ 8
possible violation of Department policy. Smce Inception (November. 2011), the
CF RT has been notified/consulted on 182 incidents and has responded to 97
incidents. Year to date In 2012, the CFRT has been l1olified/consulted on 154
incidents and has respcmded 85 limes. The remaining cases that the CFRT did
not respond to did not meet the CFRT response criteria.

XVI.

Report back in 30 days on the hiring standards for deputy sheriffs and how
they changed during the last hiring push.
Recommendation completed· a full report on the hiring standards was provided
in the November 1, 2011, letter.

Page 8 019

RECOMM ENDATIONS BY MERRICK BOBB AND OFFICE OF INDEPENDENT REVIEW
REGARDING THE JAIL SYSTEM

XVII.

Consider a two-track career path for deputies, patrol deputies and custody
deputies.
Feasibility study is ongoing.
On December 16, 2011 , the Department concluded en extensive two-month
study which analyzed different methods of implementing a two-track career path
within the Department. These study results have been presented to the CEO,
ALADS, PPOA, and the Public Safety Cluster Agenda Review meeting on
February 8. 2012.
The Department formed a subject mailer expert working group to update the
current sergeant and lieutenant classifications for the Dual Track Career Path
proposal. and is also working with the CEOs Classification Unit regarding its
implementation. The Department continues to conduct informational meetings
conceming the proposal with the CEO. ALADS, and PPOA.

XVIII.

Review existing policy of assigning new deputies to custody functions,
specifically, the length of time spent in custody and the hiring trend as its
primary determining factor, and revise the policy to reduce the length of
time deputies serve in custody.
On October 28. 2011, the Department authorized custody personnel to initiate
extensions if they desire to remain in their current assignment. As of
October 12, 2012. 490 dep(lties have taken advantage of this offer, which will
ultimately cause a reduction of time that deputies will serve in a custody
assignment.
As noted in the above item, recommendations for a two-track career path were
presented to the CEO, ALADS, Professional Peace Officers Association. and the
Public Safety CAR meeting on February 8,2012, which will reduce the length of
time deputies, selVe in custody.

Page90f9

CAMERA PROJECT STATUS REPORT

10/15/2012
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LOS ANGELES COUNTY SHERIFF'S DEPARTMENT
FORCE USED YTD 2007-2012

120

100
2012

80

2011

2010
2009

60

2008
2007
40

20

0
Jan

Feb

Mar

Apr

May

Jun

Jul

Aug

Sep

Oct

Nov

Dec

2012
2007
2008
2009
2010
2011
Total
Total
Total
Total
Total
Total
Incidents Incidents Incidents Incidents Incidents Incidents
Jan
96
110
98
49
62
33
Feb
84
76
83
51
62
49
Mar
100
77
90
81
48
46
Apr
75
69
80
71
37
47
May
101
79
85
70
60
27
Jun
91
85
93
71
54
34
Jul
82
77
84
63
56
36
Aug
98
96
114
67
44
43
Sep
89
94
80
56
55
41
Oct
105
73
89
52
35
16
Nov
94
78
75
52
43
Dec
99
66
85
58
30
Grand Total
1114
980
1056
741
586
372
Percentage Difference
-12.03%
7.76% -29.83% -20.92% -24.70%
Month

2012 Numbers reflect the difference between the same time span from 2011.

*Totals presented are as of 10/13/2012