Law Enforcement: Information on Drug-Related Police Corruption (Letter
Report, 05/28/1998, GAO/GGD-98-111).

Recent police corruption cases in several cities have underscored the
link between police corruption and illegal drug activities. This report
studies the impact of drug trafficking on police corruption in large
cities with significant drug problems. Although GAO did not locate any
central data sources that would allow it to reliably estimate the extent
of police corruption or how much corruption is drug-related, the
literature GAO reviewed, along with interviews with officials and
academic experts, provided information on the (1) nature and extent of
known drug-related police corruption in certain large cities; (2)
factors associated with known drug-related police corruption; and (3)
practices that have been recommended or implemented to prevent or detect
drug-related police corruption.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  GGD-98-111
     TITLE:  Law Enforcement: Information on Drug-Related Police
	     Corruption
      DATE:  05/28/1998
   SUBJECT:  Conspiracy
	     Drug trafficking
	     Law enforcement information systems
	     Law enforcement agencies
	     Narcotics
	     Federal/state relations
	     Police
	     Ethical conduct

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GAO/GGD-98-111

Cover
================================================================ COVER

Report to the Honorable
Charles B.  Rangel, House of Representatives

May 1998

LAW ENFORCEMENT - INFORMATION ON
DRUG-RELATED POLICE CORRUPTION

GAO/GGD-98-111

Drug-Related Police Corruption

(182043)

Abbreviations
=============================================================== ABBREV

  BOP - Federal Bureau of Prisons
  DOJ - Department of Justice
  EOUSA - Executive Office for U.S.  Attorneys
  FBI - Federal Bureau of Investigation
  HIDTA - High Intensity Drug Trafficking Area
  IAB - Internal Affairs Bureau
  IACP - International Association of Chiefs of Police
  NIJ - National Institute of Justice
  NYPD - New York City Police Department
  ONDCP - Office of National Drug Control Policy

Letter
=============================================================== LETTER

B-277817

May 28, 1998

The Honorable Charles B.  Rangel
House of Representatives

Dear Mr.  Rangel:

Recent police corruption cases in several cities, including New York,
Chicago, and Philadelphia, highlight the association of police
corruption with illegal drug activities.  You asked us to study the
impact of drug trafficking on the corruption of police in large
cities that have a high incidence of drug trafficking and drug abuse.
As agreed with your office, in conducting our preliminary work, we
sought to identify commission reports and research studies on
drug-related corruption in city police departments, as well as to
identify relevant databases and other pertinent information.

We did not locate any central data sources that would allow us to
reliably estimate the extent of police corruption or how much of
corruption is drug-related.  However, the reports and studies we
reviewed, as well as our interviews with officials and academic
experts, provided descriptive information on the (1) nature and
extent of known drug-related police corruption in certain large
cities; (2) factors associated with known drug-related police
corruption; and (3) practices that have been recommended or
implemented to prevent or detect drug-related police corruption.

We briefed your office on these developments and on the information
we gathered during our preliminary work, and your office asked us to
summarize the results of our work, focusing on these three areas.
This report responds to that request.

To determine what information was available on drug-related police
corruption, we (1) conducted a literature search and review to
identify relevant commission reports, academic studies, symposium
results, and other literature (see bibliography); (2) interviewed
academic experts on police corruption and members and/or staffs of
two anti-police-corruption commissions--one in New York City\1 and
the other in Chicago;\2 (3) interviewed officials with the Department
of Justice (DOJ) and Federal Bureau of Investigation (FBI) in
Washington, D.C., the U.S.  Attorneys' Offices for the Eastern and
Southern Districts of New York, and the Office of National Drug
Control Policy (ONDCP); and (4) contacted international, national,
and state law enforcement associations, including the International
Association of Chiefs of Police (IACP).  In addition, we met with
officials from the New York City Police Department's (NYPD) Internal
Affairs Bureau (IAB) and the current New York City Commission to
Combat Police Corruption.\3

We did our work in Washington, D.C., and New York City, New York,
from August 1997 through April 1998.  The information we provide in
this report is derived from our review of a limited number of
existing reports and studies, as well as interviews with various
officials and academic experts, not from any primary data collection
or analysis undertaken by us.  We did not attempt to verify the
adequacy of the methodologies used to produce the various findings,
nor did we attempt to assess the appropriateness of the conclusions.
Accordingly, our presentation of the findings and conclusions of
these reports and studies should not be construed as our endorsement
of them.  Moreover, we recognize that the policies and practices of
the police departments discussed in the reports and studies may
subsequently have changed.  However, reviewing current policies and
practices in particular departments was beyond the scope of this
report.  Appendix I includes further details on our scope and
methodology.

We provided copies of a draft of this report for a review of the
facts, as presented, to various DOJ units and selected police
organizations and academic experts.  At an exit conference, we
discussed the contents of the draft with DOJ officials, including the
Criminal Division's Deputy Executive Officer and representatives of
the Criminal Division's Public Integrity Section and Narcotic and
Dangerous Drug Section, the Executive Office for U.S.  Attorneys
(EOUSA), and the Bureau of Justice Assistance.  We also contacted the
Chief of the FBI Criminal Investigative Division's Public Corruption
Unit; the Commanding Officer, Office of Chief, NYPD's IAB; the
Director of Research, IACP; Judge Milton Mollen (retired), former
Chairman of the Mollen Commission; and Richard H.  Ward, Professor of
Criminal Justice, University of Illinois at Chicago and Executive
Director for the Chicago Commission.  The various officials and
experts provided technical comments, which have been incorporated in
this report where appropriate.

--------------------
\1 The Commission to Investigate Allegations of Police Corruption and
the Anti-Corruption Procedures of the Police Department, commonly
referred to as the Mollen Commission, was established in July 1992 by
an executive order of New York City Mayor David N.  Dinkins.  The
commission was given a threefold mandate:  (1) to investigate the
nature and extent of corruption in the New York City Police
Department, (2) to evaluate the department's procedures for
preventing and detecting corruption, and (3) to recommend changes and
improvements in those procedures.  The commission issued its report
in July 1994 and was subsequently disbanded.

\2 The Commission on Police Integrity, also referred to as the
Chicago Commission, was appointed on February 7, 1997, by Chicago
Mayor Richard M.  Daley.  The commission's charge was to examine the
root causes of police corruption, to review how other urban police
departments approach the issue, and to propose possible changes to
Chicago Police Department policies and procedures.  The commission
issued its first report in November 1997 and was still active as of
April 1998.

\3 In response to a recommendation of the Mollen Commission, the New
York City Commission to Combat Police Corruption was created on
February 27, 1995, by an executive order of Mayor Rudolph W.
Giuliani.  The New York City Commission was established to monitor
the performance of the NYPD's systems for combatting corruption.
This commission is charged with, among other things, performing
audits, studies, and analyses to assess the quality of these systems.

   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

According to a number of commission reports, academic publications,
and other literature we reviewed and the officials and academic
experts we interviewed, drug-related police corruption differs in a
variety of ways from other types of police corruption.  In addition
to protecting criminals or ignoring their activities, officers
involved in drug-related corruption were more likely to be actively
involved in the commission of a variety of crimes, including stealing
drugs and/or money from drug dealers, selling drugs, and lying under
oath about illegal searches.  Although profit was found to be a
motive common to traditional and drug-related police corruption, New
York City's Mollen Commission identified power and vigilante justice
as two additional motives for drug-related police corruption.  The
most commonly identified pattern of drug-related police corruption
involved small groups of officers who protected and assisted each
other in criminal activities, rather than the traditional patterns of
non-drug-related police corruption that involved just a few isolated
individuals or systemic corruption pervading an entire police
department or precinct.

Regarding the extent of drug-related police corruption, data are not
collected nationally.  Federal agencies either do not maintain data
specifically on drug-related police corruption or maintain data only
on cases in which the respective agency is involved.  Thus, it was
not possible to estimate the overall extent of the problem.  However,
the academic experts and various officials we interviewed, as well as
the commission reports, expressed the view that, by and large, most
police officers are honest.

The FBI provided us with data on FBI-led drug-related corruption
cases involving state and local law enforcement officers.  However,
since the total number of drug-related police corruption cases at all
levels of government is unknown, the proportion constituted by FBI
cases also is unknown.  Data from local sources, if collected, pose
several problems.  For example, drug-related police corruption cases
may not be readily identifiable from the offense charged or
departments may view this information as proprietary or confidential
and may not release it.  Notwithstanding the lack of systematic data,
the commissions and some academic experts described cases of
drug-related police corruption in large cities such as Atlanta,
Chicago, Cleveland, Detroit, Los Angeles, Miami, New Orleans, New
York, and Philadelphia.

Many of our sources consistently reported certain factors to be
associated with drug-related police corruption, although these
factors may also be associated with police corruption in general.
Not every source identified every factor, and the sources differed to
some degree on the emphasis to be placed on a factor.  However, if
all of the factors are considered together, they provide a consistent
framework.  Also, the factors discussed in this report may not
encompass all factors associated with drug-related police corruption,
since the identified factors are based on publicly reported incidents
of drug-related police corruption.

One commonly identified factor associated with drug-related
corruption was a police culture that was characterized by a code of
silence, unquestioned loyalty to other officers, and cynicism about
the criminal justice system.  Such characteristics were found not
only to promote police corruption, but to impede efforts to control
and detect it.  A second associated factor was the maturity (e.g.,
age) and education of police officers.  Officers lacking in
experience and some higher education were considered to be more
susceptible to involvement in illicit drug-related activities.

Several of our sources also identified a variety of
management-related factors associated with drug-related corruption.
These factors included ineffective headquarters and field
supervision, the failure of top police officials to promote
integrity, and weaknesses in a police department's internal
investigative structure and practices.  In addition, on-the-job
opportunities to commit illegal acts; inadequate training,
particularly integrity training in the police academies and on the
job; police brutality; and pressures arising from an officer's
personal neighborhood ties were also believed by some sources to be
associated with drug-related police corruption.

Our sources also identified practices that they believed could
prevent or detect drug-related police corruption.  These practices,
although often directed toward combatting police corruption in
general, also were viewed as effective steps toward specifically
addressing drug-related police corruption.  Again, while every source
did not conclude that every practice was effective or suitable for
local conditions, considered together, the practices offer a starting
point for prevention strategies.

Among the prevention practices that our sources identified were (1)
making a commitment to integrity from the top to the bottom of the
police department; (2) changing the police culture; (3) requiring
command accountability (i.e., requiring a commitment to corruption
control throughout the entire department, especially by field
commanders); (4) raising the age and educational requirements and
implementing or improving integrity training in the police academy
for recruits; (5) implementing or improving integrity training and
accountability measures for career officers; (6) establishing an
independent monitor to oversee the police department and its internal
affairs unit; and (7) community policing.\4

The detection practices our sources discussed included integrity
testing,\5 early warning systems to identify potential problem
officers, and proactive investigations of individual officers or
precincts with a high number of corruption complaints.

Lastly, we identified several federal initiatives that were directed
toward assisting state and local governments in preventing and
detecting police corruption.

--------------------
\4 Community policing is an approach by which local police
departments develop strategies to address the causes of and reduce
the fear of crime through problem-solving tactics and
community-police partnerships.  Community policing programs stress
three principles that make these programs different from traditional
law enforcement programs:  (1) prevention, (2) problem solving, and
(3) partnerships.  See Community Policing:  Issues Related to the
Design, Operation, and Management of the Grant Program (GAO/GGD
97-167, Sept.  3, 1997).

\5 Police integrity tests include "stings" designed to determine
whether officers take advantage of opportunities to engage in corrupt
practices that are presented to them by undercover operatives.

   BACKGROUND
------------------------------------------------------------ Letter :2

Police corruption, according to the academic and other literature and
anticorruption commission reports we reviewed, is not a new problem
and dates back to the establishment of the first organized local
police forces.  According to a report by the Knapp Commission,\6 when
the NYPD was established in 1844 as the first municipal police
department in this country, it experienced immediate problems with
extortion and other corrupt activities.  Subsequently, the NYPD has
experienced scandals and investigations approximately every 20
years.\7 As in New York City, corruption has plagued police
departments in many major cities at some point in their history,
including Boston, Chicago, Detroit, Los Angeles, Miami, New Orleans,
and Philadelphia.

While it has been a persistent problem for law enforcement, the
nature of police corruption has varied over time.  Historically,
police corruption involved such low-level and passive activities as
bribery schemes and nonenforcement of the law.  Also, early police
corruption was often depicted as the result of a few dishonest
individuals--commonly referred to as "rotten apples"--in an otherwise
honest department.  However, during the police corruption scandals of
the 1970s and 1980s, the corruption uncovered in several cities was
found to be systemic, rather than attributable to individual
behavior.\8

During the 1970s, New York City's Knapp Commission identified two
general forms of police corruption, which it referred to as
"grass-eaters" or "meat-eaters." According to the Knapp Commission's
report:

     "The overwhelming majority of those [police officers] who do
     take payoffs are `grass-eaters,' who accept gratuities and
     solicit five- and ten- and twenty-dollar payments from
     contractors, tow-truck operators, gamblers, and the like, but do
     not aggressively pursue corruption payments.  `Meat-eaters,'
     probably only a small percentage of the force, spend a good deal
     of their working hours aggressively seeking out situations they
     can exploit for financial gain, including gambling, narcotics,
     and other serious offenses which can yield payments of thousands
     of dollars."\9

The Knapp Commission concluded that, while the meat-eaters receive
the large payoffs and the newspaper coverage, the grass-eaters are
the heart of the problem because their greater numbers make
corruption respectable.\10

Despite this history, disagreement still exists among criminal
justice practitioners, researchers, and the public as to what type of
behavior constitutes police corruption.  Some definitions include
behavior that ranges from brutality to questionable behavior such as
verbal attacks on citizens.  Two key elements of the various
definitions of police corruption, as found in the academic literature
we reviewed, are that the acts involve (1) the "misuse" of the
officer's professional role--"authority" or "official position"--and
(2) the receipt or expected receipt of material rewards or personal
gain.\11

Enforcement of laws against all forms of vice (e.g., gambling,
prostitution, and drugs) reportedly afford opportunities for police
corruption.  However, drug enforcement often exposes police officers
to large amounts of cash and drugs held by individuals who are not
likely to complain about illegal police behavior.  Recent newspaper
accounts, commission reports, academic studies, and other literature
we reviewed suggest that today there are more opportunities than in
the past for drug-related police corruption.

Although the FBI and DOJ have jurisdiction for investigating and
prosecuting public corruption, police corruption is generally
investigated internally by local police departments and/or prosecuted
by local district attorneys.  The FBI, DOJ, and other federal
agencies are involved in only some local public corruption cases,
including police corruption, and the extent of that involvement
varies among cities across the country.

--------------------
\6 Commission to Investigate Allegations of Police Corruption and the
City's Anti-Corruption Procedures (commonly referred to as the Knapp
Commission), The Knapp Commission Report on Police Corruption (New
York:  George Braziller, 1972).

\7 The Knapp Commission Report, pp.  61-64.

\8 T.  Barker, Police Ethics:  Crisis in Law Enforcement
(Springfield, IL:  Charles C.  Thomas, 1996), p.  39.

\9 The Knapp Commission Report, p.  65.

\10 The Knapp Commission Report, p.  4.

\11 H.  Goldstein, Police Corruption:  A Perspective on Its Nature
and Control (Washington, D.C.:  The Police Foundation, 1975), p.  3,
and T.  Barker, R.D.  Hunter, and J.P.  Rush, Police Systems and
Practices:  An Introduction (Englewood Cliffs, NJ:  Prentice Hall
Career and Technology, 1994), p.  213.

   AVAILABLE INFORMATION ON THE
   NATURE AND EXTENT OF DRUG-
   RELATED POLICE CORRUPTION IS
   LIMITED
------------------------------------------------------------ Letter :3

A number of the commission reports, academic publications, and other
literature we reviewed and the officials and academic experts we
interviewed described differences between the nature of drug-related
police corruption and the nature of other types of police corruption;
however, opportunities for financial gain were a key factor in both
forms of corruption.  Unlike other types of corruption, officers
involved in drug-related corruption were found to be actively
committing crimes, not just passively ignoring them or protecting
criminals.  These crimes ranged from stealing drugs and money from
drug dealers to lying under oath about illegal searches.  Usually
these activities were carried out by small groups of officers, rather
than by lone individuals.  Moreover, drug-related police corruption
was not found to be a systemic problem that infected entire
departments or precincts.  Although cases of drug-related police
corruption have been identified in a number of large cities, we found
that only limited data on the extent of the problem were available.

      DIFFERENCES BETWEEN THE
      NATURE OF DRUG-RELATED
      POLICE CORRUPTION AND THE
      NATURE OF OTHER TYPES OF
      POLICE CORRUPTION
---------------------------------------------------------- Letter :3.1

Several of our sources described differences between the types of
illegal activities generally associated with drug-related police
corruption and those associated with other types of police
corruption.  Traditional police corruption usually involved a
mutually beneficial arrangement between criminals and police officers
(e.g., the former offered the latter bribes in exchange for immunity
from arrest).  In contrast, several studies and investigations of
drug-related police corruption found on-duty officers engaged in
serious criminal activities, such as (1) conducting unconstitutional
searches and seizures; (2) stealing money and/or drugs from drug
dealers; (3) selling stolen drugs; (4) protecting drug operations;
(5) providing false testimony; and (6) submitting false crime
reports.  According to NYPD officials, some police officers also
engaged in drug-related crimes while off duty.

The Mollen Commission reported in 1994 that the most prevalent form
of police corruption in New York City was police committing crimes,
especially in connection with the illegal drug trade, whereas the
Knapp Commission reported about 20 years earlier that the prevalent
form of corruption was police taking money to overlook illegal
activities, such as bookmaking.  In summary, the Mollen Commission,
in contrast to the Knapp Commission, found that the meat-eaters, as
opposed to the grass-eaters, had become the rule among corrupt police
officers, rather than the exception.

The types of reported drug-related corruption engaged in by police
officers, as well as the types of police corruption tolerated,
differed among cities and even differed among precincts within the
same city.  Several academic experts, as well as officials in New
York City, indicated that the levels of acceptance for different
types of offenses committed in connection with drug enforcement
activities varied, and that the perceived line between corrupt and
acceptable police behavior was not fixed.  For example, some of these
sources suggested that an officer might view stealing money from a
drug dealer as acceptable behavior, while the officer would draw the
line at stealing and selling drugs.  Over time, behavior, such as
dealing in illegal drugs, which was previously viewed as unacceptable
by even corrupt officers might become acceptable or at least
tolerated.  However, our sources also indicated that formerly
acceptable behavior, such as lying under oath, might become
unacceptable.  In addition, certain sources suggested that in one
department, officers might be more likely to report drug-related
corruption but not acts of brutality; while in another department,
the reverse might be the norm.

As in the case of other types of police corruption, a primary
reported motive for drug-related police corruption was financial
gain, but profit was not the only motive identified.  The Mollen
Commission identified three motivating factors for corruption:  (1)
profit, (2) power, and (3) perceived "street" law enforcement ends.
The commission further explained that while corrupt police officers
usually raided drug locations for profit, they sometimes carried out
raids because they (1) wanted to show that they were in control of
the precinct's "crime-ridden streets," (2) wanted to feel the "power"
and "thrill" of their badges and uniforms, or (3) believed that
vigilante justice was the way to punish those who might otherwise go
unpunished.  Similarly, some of the officials we interviewed
suggested such motives as job cynicism due to the perception that the
revolving door of justice lets criminals go free, or officers'
dissatisfaction with how they were viewed and treated by the people
in the community.

Our sources also identified differences between the pattern of
drug-related police corruption and patterns of other types of police
corruption.  The commissions and academic experts reported that
drug-related police corruption typically involved small groups of
officers.  For example, the Mollen Commission described these groups,
such as those found in New York City's 73rd precinct case,\12

as "crews" akin to street gangs.  Similarly, the Chicago Commission
reported that the officers they surveyed characterized corruption as
isolated in small groups.  In other cities, identified drug-related
police corruption cases usually involved from 9 to 30 officers often
working together, not individuals or entire departments.
Drug-related police corruption usually did not involve such
non-drug-related patterns as (1) just a few isolated individuals
within a department who engaged in illegal acts or (2) low-level
corruption pervading entire departments or precincts.

The commission reports, as well as several federal and New York City
officials and academic experts we interviewed, generally described
drug-related police corruption as being organized differently from
the corruption of earlier eras; however, these sources varied in
their characterization of the new organizational forms.  For example,
in describing New York City's 30th precinct case,\13 a DOJ official
said that, although numerous officers were involved, it was not one
large enterprise.  Rather, officers moved in and out of groups,
depending on how opportunities presented themselves.  The Mollen
Commission compared the "standardized and hierarchical--almost
bureaucratic" organizational forms of traditional corruption with the
street-gang-like structure of the drug-related crews, which were
"small, loyal, flexible, fast moving and often hard hitting." The
commission also noted that, in some cases, there were explicit
agreements or pacts between officers to help ensure that officers
observing criminal behavior would not report this behavior.

The information sources used in this report generally concurred in
their description of the nature of drug-related police corruption.
However, since these sources' observations were based on publicly
identified cases of such corruption, which may not be representative
of all drug-related police corruption cases, these observations may
not completely portray the nature of the problem.

--------------------
\12 The Mollen Commission reported that in New York City's 73rd
precinct between 1988 and 1992, a tightly knit group of 8 to 10
officers who worked together on steady tours of duty routinely
conducted unlawful raids on drug locations while on duty.

\13 During the course of its investigation in 1993, the Mollen
Commission uncovered allegations of corruption against several
officers in New York City's 30th precinct (Manhattan).  The
commission brought this information to the attention of city and
federal officials.  The U.S.  Attorney for the Southern District of
New York investigated the allegations with the commission; NYPD's
IAB; and, subsequently, the local district attorney's office.
Ultimately, 30 officers were convicted of primarily drug-related
offenses.  An additional officer was acquitted, but the officer was
later found guilty of administrative charges and was fired by the
NYPD.

      EXTENT OF DRUG-RELATED
      POLICE CORRUPTION IS UNKNOWN
---------------------------------------------------------- Letter :3.2

We did not locate any centralized, systematically gathered,
nationwide source of data that could be used to estimate the extent
of the problem nationally.  Some data on drug-related police
corruption were available from federal agencies, such as the FBI, and
local agencies.  These data usually included only information about
cases in which the reporting organization had been involved or were
of limited use because of inconsistencies or anomalies in the
data-gathering and tabulating methodologies.  However, our sources
provided accounts of some drug-related police corruption cases in
several large cities.

         LACK OF CENTRALIZED,
         SYSTEMATICALLY GATHERED
         DATA TO ESTIMATE EXTENT
         OF PROBLEM NATIONALLY
-------------------------------------------------------- Letter :3.2.1

During our review, we were unable to identify nationwide data sources
for quantifiable information on the extent of drug-related police
corruption.  In this regard, we contacted appropriate DOJ agencies,
including the National Institute of Justice (NIJ), the Bureau of
Justice Statistics, the Criminal Division's Public Integrity Section
and Narcotic and Dangerous Drug Section, the FBI's Public Corruption
Unit, and the Federal Bureau of Prisons (BOP); national and state
police organizations; and academic experts in the field of police
research.  However, various acedemic experts and officials we
interviewed and the commission reports reviewed expressed the view
that, by and large, most police officers are honest.

         SOME DATA PROVIDED BY
         FEDERAL ORGANIZATIONS
         INVOLVED IN CORRUPTION
         INVESTIGATIONS
-------------------------------------------------------- Letter :3.2.2

Although we could not locate any databases from which to estimate the
extent of drug-related police corruption, DOJ agencies provided us
with some data.  DOJ investigative and prosecutorial agencies,
including the FBI's Public Corruption Unit, EOUSA, the U.S.
Attorneys' Offices in the Southern and Eastern District of New York,
and the Criminal Division's Public Integrity Section,\14 had data on
the number of corruption cases in which they were involved.  BOP
maintained some data on former law enforcement officers in federal
correctional facilities.  NIJ provided us with information on two
NIJ-sponsored police integrity studies.  However, officials indicated
that NIJ did not collect or maintain quantitative data.

The FBI provided us with data on the number of drug-related
corruption cases involving state and local law enforcement, between
fiscal years 1993 and 1997, in which it was the lead law enforcement
investigative organization.\15 (See app.  II for a comparison of
total and drug-related FBI-led law enforcement corruption
cases/convictions for fiscal years 1993-97.) An official in the FBI's
Public Corruption Unit told us that the FBI has jurisdiction in local
police corruption cases (i.e., when an officer is alleged to have
abused his or her official capacity to advance a criminal cause).
However, this official also indicated that the FBI usually only
investigates local police corruption matters when (1) "systemic"
corruption problems were identified but were not being addressed by
local officials, (2) no one was designated at the local level to
investigate allegations of corruption, (3) the police department's
internal investigative bureau was unwilling or unable to investigate
itself, or (4) a police department or local government requested an
FBI investigation.  These situations generally involved small police
departments with 20 or fewer officers.  Frequently, according to the
official, the FBI provided the local police department with the
resources, expertise, and required technology to conduct the
investigation.

Because the FBI is selective in the drug-related police corruption
cases it handles, for the reasons discussed above and because of
resource constraints, these cases may not be representative of the
nature, geographic distribution, or other characteristics of
drug-related police corruption cases.  Moreover, the number of cases
handled by the FBI may not be indicative of the total number of
drug-related police corruption cases occurring in cities across the
country.

The DOJ Criminal Division's Public Integrity Section provided us with
data, reported annually, on public corruption cases handled (1)
solely by the Section, (2) by the Section in conjunction with a U.S.
Attorney's Office, or (3) solely by a U.S.  Attorney's Office.\16

These data included public corruption cases involving illegal drug
activities.  However, not all cases involving such activities by
public officials are handled as public corruption violations and,
therefore, would not be included in the database.  Furthermore, these
data were not categorized by the type of officials committing the
corruption (e.g., an elected political official or a police officer)
but by the level of government--federal, state, or local--at which
the corruption occurred.  Therefore, these data indicated the number
of federal prosecutions of corrupt local officials, but not the
number of police officers prosecuted.

According to a BOP official, the BOP database identifies "special
supervision cases," which include former law enforcement officers who
have been convicted of various offenses, including drug-related
corruption, and incarcerated in federal correctional facilities.  He
said that this category of cases could include some state and local
police officers, but these officers could not be identified.  In
addition, the official indicated that this category could be analyzed
by offense code to determine whether the offender's current
conviction was drug-related.  However, he noted that drug-related
corruption cases could not be identified for two reasons.  First, the
database does not distinguish between drug-related corruption
convictions and other drug-related convictions.  Second, some
officers involved in drug-related police corruption may have pled
guilty to non-drug-related offenses, such as conspiracy; therefore,
these officers would not be identified in the database as having been
convicted of a drug-related offense, including police corruption.
Thus, it was not possible to determine from the BOP database the
number of state and local police officers who were incarcerated in
the federal system for drug-related corruption.

Officials from the U.S.  Attorneys' Offices for the Eastern and
Southern Districts of New York told us that they maintained
information on the drug-related police corruption cases they handled,
but that most drug-related police corruption cases in New York City
were investigated by the NYPD's IAB and prosecuted by the local
district attorneys.  According to these officials, their offices
become involved in a police corruption case when the case (1) is
egregious and warrants federal involvement--that is, it is
precinctwide or large in scope; (2) is generated by their offices;
(3) is brought to them by the NYPD's IAB; (4) is
cross-jurisdictional--crosses city or state boundaries; or (5) is a
case closed by NYPD's IAB or local authorities that a U.S.  Attorney
decided to review.  According to the Eastern District official, that
district handled five or fewer cases of police corruption each year.
The Southern District official indicated that that district was
involved in a small number of police corruption cases referred to it
by the NYPD's IAB, and that it also conducted numerous
investigations, every year, of police corruption allegations made to
the office.  Both districts participated in the prosecutions of
drug-related corruption cases uncovered during the Mollen Commission
investigation.

--------------------
\14 DOJ's Public Integrity Section collected information from U.S.
Attorneys' Offices across the country.

\15 The FBI reported that it investigates public corruption,
including drug-related police corruption, under the following
statutes:  18 U.S.C.  ï¿½371, Conspiracy to commit an offense; 21
U.S.C.  ï¿½841, Possession with intent to distribute drugs; 18 U.S.C.
ï¿½1951, Interference with commerce by threats or violence (Hobbs Act);
18 U.S.C.  ï¿½1952, Interstate Transportation and Racketeering; 18
U.S.C.  ï¿½ï¿½1961-68, Racketeer Influence and Corrupt Organization
(RICO) provisions; and 18 U.S.C.  ï¿½924(c), Carrying dangerous weapons
in conjunction with committing a crime of violence or a
drug-trafficking related crime.

\16 Report to Congress on the Activities and Operations of the Public
Integrity Section for 1995, Department of Justice, Criminal Division,
Public Integrity Section:  Washington, D.C.  This report states that
it is prepared pursuant to Section 529 of the Ethics in Government
Act of 1978 (P.L.  95-521).  Part II of the report details the cases
prosecuted by the Public Integrity Section; Part III presents data
that are based on the Section's annual nationwide survey of U.S.
Attorneys.

         LOCAL POLICE DEPARTMENT
         DATA REPORTED TO BE
         INCOMPLETE OR
         NONCOMPARABLE
-------------------------------------------------------- Letter :3.2.3

Academic experts and various U.S.  Attorney and FBI officials
indicated that the primary repository for any data on drug-related
police corruption was at the local level, particularly the internal
affairs section of local police departments.  However, they cautioned
that obtaining, analyzing, and trying to create a national database
on police corruption from local data sources may present several
problems.

First, data from local agencies may not be readily accessible because
internal affairs units may view the data as proprietary or
confidential.  Second, drug-related police corruption cases may not
be readily identifiable as such.  For example, an officer
investigated for such corruption may be charged with perjury, rather
than a drug-related offense.  Third, available data provided by local
officials may not be verifiable because of the lack of access to case
files.  Even if the files were available, academic experts we
interviewed believed that other files concealing allegations of
corruption might exist in some police departments.  Fourth, available
data reflect who has been caught, identified, and recorded, but not
necessarily all of those officers who have engaged in drug-related
police corruption.  Fifth, local information may not be available
from a single source, since cases of drug-related police corruption
may be handled administratively by the police department, prosecuted
by the local district attorney, or prosecuted by the local U.S.
Attorney's Office.

Finally, available data are not likely to be comparable across police
departments because of variations in the definition and handling of
drug-related police corruption cases, as well as differences in data
collection methods.  One researcher characterized local police
department corruption data as measures of a department's energy for
investigating and its ability to measure corruption, not as reliable
indicators of trends in the overall level of corruption in a
department.

         SOURCES IDENTIFIED SOME
         CASES OF DRUG-RELATED
         POLICE CORRUPTION
-------------------------------------------------------- Letter :3.2.4

Our sources did identify examples of publicly disclosed cases of
drug-related police corruption in several cities during the past
decade.  The Mollen Commission investigated and uncovered
drug-related police corruption in New York City.  The Chicago
Commission described identified cases of drug-related police
corruption in Chicago, New York City, Philadelphia, Miami, New
Orleans, Los Angeles, and Detroit.  In addition, we identified
accounts of drug-related police corruption in Atlanta and Cleveland.
(App.  III contains a synopsis of drug-related cases in several
cities.)

However, since the publicized cases only provided information about
those officers convicted of identified drug-related corruption
offenses in cities where the problem had been reported, these
individuals and cities may not be representative of officers who
commit such offenses or of the locations where such crimes are
committed.  From the case information available, no conclusions can
be drawn about (1) which types of officers are involved in
drug-related corruption; (2) the extent of drug-related police
corruption within cities where it has been identified; or (3) the
incidence of drug-related police corruption in cities across the
country.

   SOURCES IDENTIFIED VARIOUS
   FACTORS ASSOCIATED WITH DRUG-
   RELATED POLICE CORRUPTION
------------------------------------------------------------ Letter :4

The commission reports, much of the academic and other literature we
reviewed, and officials and academic experts we interviewed,
identified a variety of factors as being associated with drug-related
as well as other types of police corruption.  These factors included
(1) opportunities to commit illegal acts or crimes on the job--for
example, the availability of large sums of money; (2) the
maturity-level (age) and education-level of the officer; (3)
inadequate training, particularly integrity training, in the police
academies and on the job; (4) a police culture that supported or
ignored corruption; (5) ineffective headquarters and field
supervision; (6) management's failure to enforce a code of integrity;
(7) weaknesses in a police department's internal investigative
structure and practices; (8) involvement in police brutality; and (9)
pressures arising from an officer's personal neighborhood ties.

Our sources did not rank the factors according to their impact on
drug-related police corruption; therefore, we had no basis on which
to assess their relative importance.  Moreover, since these factors
were only associated with identified drug-related police corruption
cases that have been publicly disclosed, they may not be all
inclusive or necessarily representative of the universe of
drug-related police corruption cases.  Also, to our knowledge, no
systematic studies of the causal link of these factors to
drug-related police corruption have been undertaken.

      OPPORTUNITIES TO COMMIT
      ILLEGAL ACTS OR CRIMES ON
      THE JOB
---------------------------------------------------------- Letter :4.1

Our sources described police recruits, generally, as individuals who
had become police officers for the right reasons.  They also said
that once on the job, however, officers working in precincts with a
high level of drug activity may be confronted with opportunities to
commit illegal acts or crimes, such taking large sums of money from
drug dealers, who are generally reluctant to complain about thefts by
police officers.  Without support and experience, these temptations
are hard for some officers to resist.  Moreover, federal officials,
academic experts, and the commission reports described how some
police officers who engaged in illicit drug-related activities were
able, through a "de-sensitizing" or rationalization process, to
justify their behavior on the basis of, for example, the notion that
they were only harming or disrupting illegal drug dealers.

Academic sources and DOJ Criminal Division Public Integrity Section
officials suggested that police officers working in certain
situations, such as in undercover operations, could be more
vulnerable to involvement in illegal drug-related activities.  For
example, the nature of undercover work generally places an officer in
a criminal environment conducive to corruption.  In addition, these
federal officials opined that corruption was more likely to result
from day-to-day contacts between police officers and informants.
Academic and other sources also suggested that special drug
investigation units with low levels of supervision were also
considered to be high-risk environments for drug-related corruption.

      MATURITY- AND
      EDUCATION-LEVEL OF THE
      OFFICER
---------------------------------------------------------- Letter :4.2

The commission reports we reviewed and various officials and academic
experts we interviewed indicated that certain recruitment policies,
such as lower age and education requirements, might be related to
incidents of police corruption.  An official in the U.S.  Attorney's
Office of the Southern District of New York and academic experts
indicated that in New York City and Chicago, for example, most of the
officers involved in recent drug-related corruption cases would not
have been hired under previous higher age and education criteria.

Moreover, rapid recruitment initiatives to meet major, time-critical
hiring demands appeared to be associated with episodes of
drug-related police corruption in some cities.  For example, police
departments in Miami and Washington, D.C., went through major hiring
initiatives during the 1980s, and these departments subsequently
experienced corruption problems.  Academic sources and some federal
officials suggested that, for various reasons, including inadequate
screening (e.g., inadequate or incomplete background checks), such
rapid recruitment initiatives might have permitted the hiring of
recruits who might not otherwise have been hired.

      INADEQUATE POLICE ACADEMY
      AND ON-THE-JOB TRAINING
---------------------------------------------------------- Letter :4.3

Inadequate training, particularly integrity training, in the police
academies and especially on the job, was identified as another factor
associated with drug-related corruption.  According to a member of
the Mollen Commission we interviewed, before the establishment of the
commission and the implementation of its recommendations, the NYPD's
integrity training consisted of the message "don't get caught."
Moreover, the Mollen Commission found that the NYPD police academy's
integrity training at that time was based on the types of corruption
uncovered by the Knapp Commission, such as gambling and vice rackets.
The Mollen Commission concluded that this training not only had
little relevance to the temptations confronted by police officers
about 20 years later, but the training sent a message of departmental
disinterest in integrity matters.\17 Asserting that the real test of
the effectiveness of the Chicago Police Department's training
strategies comes when new police officers are assigned to districts
and begin to face the challenges inherent in their work, the Chicago
Commission found that the department could do a better job in this
crucial area.

--------------------
\17 NYPD officials told us that the integrity training program
subsequently had been changed, and they provided us with a copy of
the student training guide.

      POLICE CULTURE THAT
      SUPPORTED OR IGNORED
      CORRUPTION
---------------------------------------------------------- Letter :4.4

The relationship between police culture and police corruption,
including drug-related police corruption, was a recurring theme
articulated by our various sources.  They generally concurred that
although police culture may be positive (i.e., supportive of
integrity), a negative culture (i.e., one that supported or generally
ignored corruption) was a key factor associated with drug-related
police corruption.  Among the attitudes and values identified as
characteristics of a police culture that supported corruption were
the following:  (1) a code of silence with grave consequences for
those violating it; (2) loyalty to other officers above all else; (3)
police cynicism or disillusionment about their jobs, the criminal
justice system, and public support for those who performed properly;
and (4) indoctrination on the job as to what is acceptable
behavior--for example, ignoring corruption.  The Mollen Commission
concluded that such aspects of a police culture primarily facilitated
corruption by (1) setting the standard that nothing was more
important than the loyalty of officers to each other (e.g., not
stopping even the most serious forms of corruption) and (2) thwarting
efforts to control corruption, thereby leading officers to cover up
for other officers' crimes.

The literature we reviewed and some academic experts suggested that
the relationship between culture and corruption is complex.  For
example, one expert asserted that police behavior was affected by
three levels of culture:  (1) the culture of the police profession in
general, (2) the culture of a particular police department, and (3)
the culture of the city.  He also suggested that the code of silence
may be a characteristic that is common to the culture of police
departments in general, while attitudes toward brutality or stealing
illegal drugs may be more a part of a particular police department's
culture.  The literature indicates that tolerance of corruption
varies among cities and even within a city, over time.  In addition,
the previous discussion on the lack of integrity training suggests an
acculturational process, whereby new officers learn the
rationalizations and accepted behaviors from more experienced
officers.

      INEFFECTIVE HEADQUARTERS AND
      FIELD SUPERVISION
---------------------------------------------------------- Letter :4.5

At the systemic level, the commission reports identified poor or
inadequate supervision in police departments from the top down--at
headquarters and in the field--as a factor associated with
corruption.  For example, the Mollen Commission found a widespread
breakdown in field supervision in the NYPD.  The commission asserted
that this breakdown fueled and protected the police corruption they
observed, and it primarily blamed NYPD's management for the poor
state of police supervision.  The Chicago Commission found the
Chicago Police Department lacking in supervisory accountability and
emphasized the importance of the supervisory role of sergeant to an
effective police organization.

      MANAGEMENT'S FAILURE TO
      ENFORCE A CODE OF INTEGRITY
---------------------------------------------------------- Letter :4.6

Various sources acknowledged the critical role of department
management in promoting ethics and integrity and the serious
consequences of management's failure to provide such leadership.
Although major police departments historically have distributed rules
and guidelines proscribing unethical and potentially corruptive
conduct, an article from a recent symposium sponsored by the FBI and
Major City Chiefs Administrators concluded that these guidelines may
be confusing or misleading, and consequently can contribute to
corruption.\18 Moreover, in some departments, operational goals
conflict with written policies.  For example, a police department may
have rules, which are consistently enforced through disciplinary
actions, against accepting gratuities from the business community
with corresponding sanctions, but the chief and other high-ranking
commanders may be the guests of these same business representatives
at their country clubs.  Also, police organizations have generally
claimed the privilege of self-regulation.  The Mollen Commission
concluded that the failure of NYPD's corruption controls reflected
the inevitable consequence of allowing the police to "police
themselves."

--------------------
\18 Alfred E.  James and Charles V.  Campisi, "Organizational Culture
and Values," Maintaining Integrity in Law Enforcement Organizations:
Selected Readings, Major City Chiefs Administrators and National
Executive Institute Associates (Quantico, VA:  FBI Academy, January
1994), p.  30.

      WEAKNESSES IN A POLICE
      DEPARTMENT'S INTERNAL
      INVESTIGATIVE AREAS
---------------------------------------------------------- Letter :4.7

Our sources identified problems in a police department's internal
investigative structure and practices as another aspect of inadequate
management associated with drug-related police corruption.
Corruption control was negatively affected by such factors as the
lack of respect for internal affairs units; flaws in investigative
techniques; the lack of resources; inadequately skilled internal
affairs staff; the lack of autonomy of the internal affairs bureau;
and the minimizing or concealing of police corruption incidents
(e.g., by putting allegations of police corruption in a special file
rather than initiating an investigation).  By 1992, according to the
Mollen Commission, NYPD's corruption control system had collapsed,
but no one in the department had the incentive to fix what was
broken.  Also, the Chicago Commission reported hearing evidence of
substantial delays in addressing the corruption in one district.  At
the same time, however, the commission asserted that the Chicago
Police Department's leadership, particularly its Internal Affairs
Division, should be given some credit for taking a proactive role in
exposing recent police corruption scandals.

Our literature review and expert interviews indicated that cities
varied in the structures, procedures, and practices employed to
identify and investigate corruption.  For example, New York used
field associates--line officers recruited to report covertly to the
internal affairs unit on any misconduct or illicit activities that
they observed while at work--but other cities did not.

      POLICE BRUTALITY
---------------------------------------------------------- Letter :4.8

Among other factors that the commission reports and several academic
experts we interviewed found could be associated with drug-related
police corruption was police brutality.  In Chicago, for example, one
researcher found that, while not all officers involved in police
brutality were also engaged in drug-related police corruption, a
number of police officers involved in drug-related corruption also
had histories of the use of excessive force.  The Mollen Commission
reported a similar finding.  DOJ public integrity officials suggested
that, if there is a violation of the civil rights of a drug dealer,
little support for the dealer would come from other police officers;
rather, the code of silence would likely be invoked, creating an
environment supportive of corruption.

      PRESSURES FROM AN OFFICER'S
      PERSONAL NEIGHBORHOOD TIES
---------------------------------------------------------- Letter :4.9

Still another factor associated with drug-related police corruption
and identified during our review was pressure arising from an
officer's personal neighborhood ties.  That is, some sources
indicated that neighborhood ties to friends, family members, or even
associates, for example in gang-plagued areas, might make it
difficult for officers raised in those communities to avoid
situations that promote corrupt behavior.  Alternatively, however,
some sources suggested that neighborhood ties might deter corruption
because officers would have a stake in the community.

   SOURCES IDENTIFIED SOME
   PRACTICES THAT MIGHT PREVENT
   AND DETECT DRUG-RELATED POLICE
   CORRUPTION
------------------------------------------------------------ Letter :5

The commission reports and many of the academic and other
publications we reviewed and the officials and academic experts we
interviewed identified and/or recommended various practices to
prevent and detect drug-related police corruption.  We did not
evaluate and do not necessarily endorse these practices.  Although
these practices generally are said to address the previously
discussed factors that are associated with drug-related police
corruption, the practices may also combat other types of corruption.

The prevention practices that were identified included (1) making a
commitment to integrity from the top to the bottom of the department,
(2) changing the police culture, (3) requiring command
accountability, (4) raising the age and educational requirements and
implementing or improving integrity training in the police academy
for recruits, (5) implementing or improving integrity training and
accountability measures for career officers, (6) establishing an
independent monitor to oversee the police department and its internal
affairs unit, and (7) community policing.

Among the detection practices recommended and/or implemented were
integrity testing, early warning systems to detect potential problem
officers, and proactive investigations of individual officers or
precincts with a high number of corruption-related complaints.
Several factors, such as available resources or the culture of the
department, affected the appropriateness or implementation of these
practices in particular cities.  While some departments were already
implementing some of the recommended prevention and/or detection
practices, a recommendation usually was based on the perceived merits
of the practice, which were grounded in policing experience, rather
than a formal evaluation of that practice.

In addition, we identified several federal initiatives that were
directed toward assisting state and local governments in preventing
police corruption.

      PRACTICES TO PREVENT
      DRUG-RELATED POLICE
      CORRUPTION
---------------------------------------------------------- Letter :5.1

Our various sources identified and/or recommended practices to
prevent police corruption in general and drug-related police
corruption in particular.  Although some practices, such as making a
commitment to integrity, were generally recommended, the merits of
other practices, such as establishing an independent monitor to
oversee the police department and its internal affairs unit, were the
subject of some disagreement and debate.

Focusing on a positive approach to preventing police corruption,
commission reports and a recent NIJ symposium emphasized the
importance of police departmental leadership in instilling a
commitment to integrity.  According to the Mollen Commission, such a
commitment cannot be just an abstract value statement but must be
reflected in the actions of the Police Commissioner, the department's
top commanders, and the field supervisors who shape the attitudes of
the rank and file.  The message must be sent throughout the
department that corruption will not be tolerated.  Similarly, the
Chicago Commission asserted that supervisors must constantly
reinforce the value statement and code of ethics through example and
through a system of rewards for proper behavior.  The NIJ symposium
underscored the importance of developing a "healthy" police
organization to reinforce and maintain the good character and
constructive motivations of individuals who join law enforcement.

Our various sources generally concluded that instilling a commitment
to integrity and developing a healthy police organizational
environment required changes in the police culture.  Even though
police culture was identified as a negative factor associated with
drug-related police corruption, a positive police culture, supportive
of integrity and commitment, was also identified as a factor that
could prevent such behavior.  For example, the police culture of the
San Diego Police Department, a department reportedly not experiencing
drug-related police corruption, was characterized by one source as
discouraging an officer from taking anything except his or her
paycheck.  Among the aspects of a positive police culture that the
sources identified were loyalty to the department's integrity, rather
than loyalty to corrupt colleagues; positive peer pressure,
supportive of integrity, that helped the department to regulate
itself; pride in the organization; and positive incentives for
reporting corruption.

The commissions, in particular, emphasized command accountability
(i.e., requiring a commitment to corruption control throughout the
entire department, especially by field commanders) as a key component
of a department's anticorruption strategy.  The Mollen Commission
concluded that command accountability was the cornerstone of a
department's anticorruption strategy.  Similarly, the Chicago
Commission affirmed its belief in the principle of supervisor
accountability and asserted that supervisors who did not know of or
did nothing to stop wrongdoing in their command should be
disciplined.  Moreover, the commission recommended a meaningful
ethics training component and a probationary period for new
supervisors.

Our sources recommended several recruiting practices to help prevent
police corruption.  These practices included (1) better candidate
screening, for example, completion of background checks; (2) raising
the age of recruits; (3) raising educational standards, for example,
requiring at least some college education; (4) incorporating
integrity training into police academy curricula; (5) reviewing
police officers' integrity as part of probationary period
evaluations; and (6) extending the probationary period.  Some of
these recommendations emphasized selection of those candidates with
the maturity to deal with the temptations and pressures presented by
modern policing, particularly in neighborhoods with high levels of
drug-related activities.  Generally, some college or military
experience was considered an indicator of maturity because it
provided an opportunity for prospective candidates to live away from
home and establish a work record.  However, the commission reports,
studies, and experts often differed regarding the specific age and
educational requirements recommended (e.g., 22 or 23 years old and 2
or 4 years of college).

Our sources stressed that, since drug-related police corruption and
the influences of a negative police culture continue to confront
officers during their careers, prevention activities should continue
beyond the police academy.  The prevention practices that our sources
advocated included (1) integrity training as part of the continuing
education of officers, (2) the inclusion of integrity assessments in
in-service evaluations, and (3) a consideration of integrity
assessments when determining promotions.  In addition, DOJ public
integrity officials suggested rotational assignments, that is, moving
officers to different precincts as a means to remove local police
officers from the pressures of personal ties in their own communities
that provide opportunities for corruption.  This is a practice
generally followed by some federal law enforcement agencies.

To ensure the accountability of police departments to the public, one
approach our sources recommended was external oversight of police
departments, particularly their internal affairs bureaus, by an
independent review board or commission, special prosecutor, or
inspector general.  The Mollen Commission recommended an independent
oversight commission with (1) a small permanent staff; (2) the
ability and authority to bring on additional staff, as needed, from
law enforcement agencies, such as the FBI and Drug Enforcement
Administration; and (3) subpoena power to enable the commission to
carry out its own investigations.  Subsequently, the Commission to
Combat Police Corruption was established by the current New York City
Mayor to oversee the NYPD's implementation of its anticorruption
systems and controls.  However, according to commission officials and
documents, the commission has no independent subpoena power or
authority to conduct its own independent investigations.  According
to various sources, because police departments historically have been
self-regulating, some departments may oppose proposals for
independent review mechanisms, particularly with independent
investigative authority, as recommended by the Mollen Commission.
NYPD officials told us they did not oppose the creation of an
independent commission, but opposed its having independent
investigative authority because it duplicated the authority of local
district attorneys and federal agencies.

Among the new approaches to local law enforcement being implemented
in numerous cities is community policing.  We found differences of
opinion among our sources regarding the effectiveness of community
policing in preventing police corruption.  The Chicago Commission
reported anecdotal evidence suggesting some connection between
building community relations and a reduction in aggressive forms of
police corruption.  The commission concluded that once the community
is exposed to positive reform and gang and drug violence are reduced
it is no longer fertile ground for police corruption.  Nevertheless,
the Mollen Commission, noting the concern of many in law enforcement
that the close relationship between officers and citizens required
for successful community policing may also increase opportunities for
police corruption, concluded that "the value of the [community
policing] program to effective law enforcement and its commensurate
benefits to the community far outweigh[ed] the risks involved."

      PRACTICES TO DETECT
      DRUG-RELATED POLICE
      CORRUPTION
---------------------------------------------------------- Letter :5.2

Our various sources also identified and/or recommended several
practices to detect police corruption in general and drug-related
police corruption in particular.  As with police corruption
prevention practices, we found differences of opinion among our
sources regarding the effectiveness of particular practices.

A recurring theme among the officials we interviewed was that
departments should apply their drug enforcement investigative
techniques to investigations of drug-related police corruption.  For
example, investigators might employ such techniques as (1) placing
officers suspected of being involved in illicit drug-related
activities under surveillance, (2) getting drug dealers and corrupt
officers to testify against other dealers or traffickers or other
corrupt officers, or (3) debriefing arrested drug dealers to obtain
information on police corruption.  New York City officials
recommended that police departments engage in proactive
investigations of areas showing a high concentration of drug-related
corruption complaints against police officers.  NYPD officials told
us that the department was using pin-mapping to track precincts with
high levels of corruption complaints.  This technique is typically
used to identify high crime areas by putting pins on a map where
crimes have occurred.

Some departments, such as the NYPD, used and recommended integrity
testing to detect drug-related police corruption.  According to NYPD
officials and documents, the IAB conducted both targeted integrity
testing, which is directed at officers suspected of involvement in
corrupt activities (about 25 percent of the total tests conducted),
and random integrity testing, which is directed at precincts or duty
shifts that might be prone to corruption based on statistical data.
Generally, NYPD's targeted integrity testing is more sophisticated
and might involve setting up a sting.  For example, as part of a
sting operation, undercover officers might pose as a married couple
involved in the local drug trade.  The operation would then be
videotaped to determine whether the targeted officer(s) would commit
corrupt acts, such as buying drugs from the couple.

Academic experts we interviewed indicated that police departments
disagreed about the cost-effectiveness of integrity testing,
particularly random testing, in terms of the number of prosecutions
it is likely to generate.  Chicago Commission staff indicated that
several commission members were concerned that integrity testing
might (1) constitute entrapment, (2) have a deleterious effect on the
morale of the department, and (3) involve the inefficient use of
resources.  NYPD officials, in contrast, told us that integrity
testing often helped convince corrupt officers to cooperate with the
investigation and identify other corrupt officers.  However, a study
of New York's random integrity-testing program, carried out by KPMG
Peat Marwick LLP for the New York City Commission to Combat Police
Corruption, found that, although random integrity testing was not an
effective tool for identifying and weeding out corrupt police or
serving as a barometer of corruption in the department, it can be
useful for identifying patrol officer training needs.  The KPMG study
did not attempt to determine whether the program had a deterrent
effect or met its objective of creating a sense of IAB's
"omnipresence" (i.e., to have each officer believe that each
assignment might be an integrity test).  NYPD officials told us that,
on the basis of another consultant study, they found that officers
believed many more random integrity tests were being conducted than
actually were, and that the program was having a deterrent effect.

Our sources also indicated that many police departments have some
type of early warning system consisting of identified factors, or
patterns of behavior, that may indicate a corruption problem.  Some
systems are less formal in terms of the criteria used to select
potentially corrupt officers to be targeted for observation, while
other systems have a formal set of criteria for selecting such
officers.  Moreover, the factors a police department looks at may
also vary.  Factors relating to an officer that might be monitored
include standard of living, indebtedness, type of car driven, and the
number of complaints lodged against him or her.  Also, how
departments address findings may differ.  For example, a potentially
problem officer may be sent back to the academy for training or to an
employee assistance program.  The Chicago Commission also highlighted
the need for computerized resources to support such systems to allow
for the analysis of data indicative of potential misconduct,
including corruption.

In addition, according to our sources, drug use was a reported
concern and drug testing--whether targeted or random--was a practice
employed by some police departments to detect drug use, although such
use was not necessarily found to be an indicator of drug corruption.
However, how departments treated positive test results varied.  For
example, in Chicago, drug use is treated as a medical problem.  In
New York City, according to NYPD officials, an officer who (1) fails
a drug screening test; (2) is found in possession of illegal drugs;
or (3) refuses to take a drug screening test is dismissed.  In either
case, positive drug test results are typically not treated as a
crime.

Particularly in larger police departments, special internal affairs
units may be responsible for implementing detection practices, such
as those identified in this report.  Both the Mollen Commission and
Chicago Commission reports emphasized the need for police department
internal affairs units to have high-quality staff and sufficient
resources to carry out investigations.  However, the Mollen
Commission also emphasized that the NYPD's IAB had to first establish
its credibility if it were to fight corruption effectively.

Our sources also identified variations among cities in the prevention
or detection practices recommended and implemented.  According to
academic experts, possible explanations for these differences
included the (1) availability of resources; (2) strength of and
opposition from police unions; (3) police culture; and (4) form of
city government (e.g., mayor-council or city manager).

      FEDERAL INITIATIVES TO
      PROMOTE THE PREVENTION AND
      DETECTION OF DRUG-RELATED
      POLICE CORRUPTION
---------------------------------------------------------- Letter :5.3

During our review, we also identified federal efforts to assist local
law enforcement in preventing and detecting drug-related police
corruption.  According to FBI Public Corruption Unit officials, in
addition to leading or providing assistance to state and local
officials on law enforcement corruption investigations, the FBI is
working on a proposal with the IACP and National Sheriffs'
Association to proactively address systemic corruption in law
enforcement.  By using covert investigative techniques, identifying
causal factors, and developing and promoting the implementation of
internal control models in concert with the law enforcement
community, the FBI hopes to assist local law enforcement
organizations in preventing and detecting corruption.  In addition,
the officials told us that the FBI assists local organizations by
providing training in corruption prevention and detection techniques.

In July 1996, NIJ and the Office of Community Oriented Policing
Services sponsored a symposium on police integrity.  Attendees at the
conference, which provided a forum for the discussion of policing
issues such as corruption, included law enforcement executives,
researchers, police officers, labor organizations, community and
political leadership, and related disciplines.  The symposium
achieved consensus, and made short- and long-term recommendations, on
a number of issues.  The recommendations included (1) continued
dialogue at a level closer to the practitioners, through additional
national or regional meetings at which information could be collected
and shared; (2) national workshops inviting representatives from
leading police development programs throughout the country (e.g., the
FBI National Executive Institute) to discuss infusing integrity and
ethics throughout the curriculums for greater effectiveness in police
leadership development programs; (3) the development and
implementation of a national "teach the teachers" program to create a
corps of instructors versed in ethical theory and practice in police
services; and (4) assessment of entry-level screening and hiring
processes to determine if they are reliable predictors of ethical
behavior.

Further information on the practices for preventing and detecting
police corruption recommended appear in the DOJ publication, Police
Integrity:  Public Service With Honor.  Presently, NIJ is also
sponsoring studies on police misconduct and police integrity.

Finally, the 1998 National Drug Control Strategy,\19 prepared by
ONDCP, discusses additional federal programs that assist state and
local law enforcement or deal with public corruption.  DOJ's Edward
Byrne Memorial State and Local Law Enforcement Assistance Program
provides support to state and local law enforcement organizations in
the form of grants that can be used to, among other things, improve
the investigation and prosecution of drug-related public corruption
crime.  Organized Crime Drug Enforcement Task Forces, which were
established in 1982 and typically consist of members of 11 federal
agencies and state and local law enforcement organizations, have
public corruption as 1 of their targeted activities.  Moreover,
through ONDCP's High Intensity Drug Trafficking Area (HIDTA)\20
Program, federal, state, and local law enforcement agencies undertake
cooperative investigations that could involve drug-related activities
by police officers.  ONDCP officials told us that, while ONDCP
presently has no strategic initiatives that directly address
drug-related police corruption, they are likely to consider
specifically addressing this issue in the future.

--------------------
\19 The National Drug Control Strategy, 1998:  A Ten Year Plan
(Washington, D.C.:  Office of National Drug Control Policy, 1998),
pp.  35 and 36.

\20 HIDTAs are regions with critical drug-trafficking problems that
harmfully affect other areas of the United States.  The ONDCP
Director, in consultation with the Attorney General, heads of drug
control agencies, and governors, designates the HIDTA locations, of
which there are currently 17.  HIDTAs, among other things, facilitate
cooperative investigations, intelligence sharing, and joint
operations against trafficking organizations.  Federal resources
support these initiatives.

---------------------------------------------------------- Letter :5.4

As agreed with your office, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days
from the date of this letter.  At that time, we will send copies of
this report to the Chairmen and Ranking Minority Members of the
congressional committees with jurisdiction over drug control and
criminal justice issues; the Attorney General and heads of Justice's
law enforcement agencies; the Secretary of the Treasury and heads of
Treasury's law enforcement agencies; the Director of ONDCP; and the
heads of nongovernmental organizations and associations representing
law enforcement interests, such as the IACP, that we contacted during
our work.  Copies will also be made available to others upon request.

The major contributors to this report are listed in appendix IV.  If
you have any questions about this report, please call me on (202)
512-8777.

Sincerely yours,

Richard M.  Stana
Associate Director
Administration of Justice Issues

OBJECTIVES, SCOPE, AND METHODOLOGY
=========================================================== Appendix I

Congressman Charles B.  Rangel requested that we conduct a study on
the impact of drug trafficking on the corruption of police in large
cities having a high incidence of drug trafficking and abuse.  In
conducting our preliminary work, we sought to identify commission
reports and research studies on drug-related police corruption, as
well as relevant databases and other pertinent information.  However,
we could not identify any central data sources to quantify the extent
of drug-related police corruption and the linkage between illegal
drugs and corruption.  Therefore, we agreed to provide descriptive
information on the (1) nature and extent of drug-related police
corruption in certain large cities, (2) factors associated with
drug-related police corruption, and (3) practices that have been
recommended or implemented to prevent or detect drug-related police
corruption.

To address our three objectives, we conducted an extensive literature
search, using automated information services, such as the National
Criminal Justice Reference Service and Westlaw, to identify relevant
academic publications, symposium reports, and reports issued by city
police commissions established to investigate and propose methods for
countering police corruption.  The number and scope of the reports
and studies we identified were limited, and the results they provided
may not be entirely reliable, nor generalizable.  The studies and
reports identified and used in the preparation of this report are
listed in the bibliography.

We interviewed officials with the Department of Justice's (DOJ)
Bureau of Justice Statistics, Bureau of Justice Assistance, Criminal
Division's Public Integrity Section and Narcotic and Dangerous Drug
Section, National Institute of Justice, Executive Office for U.S.
Attorneys; the Federal Bureau of Prisons; and the Federal Bureau of
Investigation's (FBI) Public Corruption Unit.  We also contacted the
Office of National Drug Control Policy.  In addition, we contacted
several international, national, and state law enforcement
associations to determine whether they could identify any related
studies and provide us with additional information sources.  These
associations included the Fraternal Order of Police, International
Association of Chiefs of Police (IACP), National Organization for
Black Law Enforcement Executives, National District Attorneys
Association, National Association of Police Organizations, National
Sheriffs' Association, Police Executive Research Forum, and Police
Foundation.  We also discussed the issues with a number of academic
experts in police research.

We conducted our fieldwork in New York City, where we met with
officials from the New York City Police Department's (NYPD) Internal
Affairs Bureau (IAB), U.S.  Attorneys' Offices for the Eastern and
Southern Districts of New York, the current City of New York
Commission to Combat Police Corruption, and officials associated with
New York City's former Commission to Investigate Allegations of
Police Corruption and the Anti-Corruption Procedures of the Police
Department, commonly referred to as the Mollen Commission.  We also
interviewed representatives of the current City of Chicago Commission
on Police Integrity and contacted the current City of Philadelphia
Police Corruption Task Force, which is presently conducting its
study.

Regarding our first objective, we obtained some descriptive
information on the nature of drug-related police corruption from the
Mollen Commission and Chicago Commission reports and our interviews
with officials from the FBI and the U.S.  Attorneys' Offices in the
Eastern and Southern Districts of New York.  We also obtained
information from academic reports and studies from our literature
search and by discussing the issues with academic experts.  These
sources provided descriptive information about drug-related police
corruption.  However, since these observations were based on a
limited number of publicly disclosed, large-city, drug-related police
corruption cases, this information may not accurately portray or be
representative of the nature of such corruption in all large-city
cases.

To determine the extent of drug-related police corruption in large
cities and the extent of any link between drug trafficking and police
corruption, we attempted during our preliminary work to identify a
central repository or collection point for relevant quantitative
data.  DOJ component agencies, law enforcement organizations, and
academic experts could not identify any such central repository.  The
FBI was able to provide us with limited data on FBI-led drug-related
law enforcement corruption cases.  We have used these data to show
the extent of the FBI's involvement in drug-related law enforcement
corruption investigations.  However, they do not reflect the overall
extent of drug-related police corruption.  Moreover, we did not
independently verify the accuracy of the data provided by the FBI.

Regarding our second objective, to determine the factors associated
with drug-related police corruption, we reviewed the Mollen
Commission and Chicago Commission reports.  Moreover, we reviewed
academic studies identified during our literature search and obtained
the views of several academic experts.  We also included those
factors identified by officials during our interviews with the NYPD's
IAB, the DOJ Criminal Division's Public Integrity Section and
Narcotic and Dangerous Drugs Section, and the U.S.  Attorneys'
Offices in New York City.  The same factors were often identified
independently by several different sources.

Regarding our third objective, to determine some of the practices
recommended or adopted by city police departments to prevent and/or
detect drug-related police corruption, as well as police corruption
in general, we reviewed and summarized the findings and
recommendations of the Mollen Commission and Chicago Commission
reports; observations from academic sources; and information provided
by federal law enforcement officials, the NYPD's IAB, and the New
York City Commission to Combat Police Corruption.  We also discussed
this topic with academic experts.  Moreover, we obtained information
from the FBI on its proposed joint initiative with the IACP and
National Sheriffs' Association to develop internal control models to
prevent and detect police corruption.

It is important to emphasize that we derived the information
presented in this report from our review of a limited number of
existing reports and studies and interviews with federal and local
law enforcement officials and academic experts.  We did not undertake
any primary data collection and analysis.  We found only a limited
number of studies and reports, which were carried out in a small
number of large American cities.  The results of these studies may
not be entirely reliable or generalizable.  We did not attempt to
verify the adequacy of the methodologies used to produce the various
findings, nor did we attempt to assess the appropriateness of the
conclusions or recommendations.  Accordingly, our presentation of
reported findings and conclusions should not be viewed as our
endorsement of them.  Moreover, although we recognize that the
policies and practices of the police departments discussed in the
reports and studies may subsequently have changed, reviewing current
policies and practices in particular departments was beyond the scope
of this report.

FBI-LED STATE AND LOCAL LAW
ENFORCEMENT CORRUPTION CASES
OPENED AND OFFICERS CONVICTED,
FISCAL YEARS 1993-97
========================================================== Appendix II

                               Table II.1

                FBI-Led Law Enforcement Corruption Cases
                      Opened, Fiscal Years 1993-97

                                                         Percentage of
                                   Total      Number of   cases opened
                              corruption   drug-related       that are
Fiscal year                 cases opened   cases opened   drug-related
-------------------------  -------------  -------------  -------------
1993                                 186             61             33
1994                                 185             85             46
1995                                 210             77             37
1996                                 183             85             46
1997                                 190             92             48
----------------------------------------------------------------------
Note:  According to an FBI Public Corruption Unit official, although
the FBI was the lead investigative agency in these cases, a
significant number of the cases involved the participation of other
federal, state, and/or local law enforcement organizations.

Source:  Public Corruption Unit, Criminal Investigative Division,
FBI.

                               Table II.2

                 Officers Convicted as a Result of FBI-
                     Led Law Enforcement Corruption
                  Investigations, Fiscal Years 1993-97

                                              Number of  Percentage of
                               Total law       officers       officers
                             enforcement  convicted for  convicted for
                                officers   drug-related   drug-related
Fiscal year                  convicted\a       offenses       offenses
-------------------------  -------------  -------------  -------------
1993                                 129             59             46
1994                                 143             72             50
1995                                 135             77             57
1996                                  83             38             46
1997                                 150             79             53
----------------------------------------------------------------------
Note:  According to an FBI Public Corruption Unit official, although
the FBI was the lead investigative agency in these cases, a
significant number of the cases involved the participation of other
federal, state, and/or local law enforcement organizations.

\a Because cases may remain open for a number of years, convictions
in a given year may relate to cases opened in previous years.

Source:  Public Corruption Unit, Criminal Investigative Division,
FBI.

EXAMPLES OF PUBLICLY DISCLOSED
INVESTIGATIONS OF DRUG-RELATED
POLICE CORRUPTION IN LARGE CITIES
BETWEEN 1988 AND 1998
========================================================= Appendix III

City                Example of publicly disclosed investigations
------------------  --------------------------------------------------
Atlanta             In 1995, six police officers were convicted of or
                    pleaded guilty to federal corruption charges
                    stemming from an FBI undercover sting. Five other
                    officers were suspended but not charged.

Chicago             (1) Seven officers of the Tactical Unit of the
                    15th District were indicted in December 1996 on
                    federal charges for allegedly using their
                    positions, skills, and experiences as police
                    officers to rob and extort money and narcotics
                    from drug dealers on Chicago's west side.

                    (2) Stings conducted by the Police Department's
                    Internal Affairs Division and the FBI led to the
                    arrest in 1997 of three 6th District tactical
                    officers for conspiracy to commit robbery and
                    sales of illegally confiscated narcotics.

Cleveland           As a result of an FBI undercover operation, 44
                    police, sheriff's department, and corrections
                    officers from 5 law enforcement agencies were
                    charged in January 1998 with taking money to
                    protect cocaine trafficking operations in
                    Cleveland and northern Ohio. Eight of the officers
                    had pled guilty as of April 10, 1998.

Detroit             As a result of an FBI undercover operation, nine
                    officers were charged in 1991 with conspiracy to
                    aid and abet the distribution of cocaine,
                    attempted money laundering, and other charges.

Los Angeles         As a result of an FBI undercover operation, 27
                    Sheriff's deputies and 1 police officer had been
                    convicted by 1994 for skimming millions of dollars
                    of drug money, while members of an elite narcotics
                    unit.

Miami               The Miami Police Department experienced a series
                    of drug-related cases during the late 1980s, which
                    resulted in the arrest, suspension, or punishment
                    of more than 100 officers.

New Orleans         For 6 months in 1994, New Orleans police officers
                    protected a cocaine supply warehouse containing
                    286 pounds of cocaine. As the result of an FBI
                    undercover investigation, 11 officers, who were
                    paid nearly $100,000 by undercover agents, were
                    convicted. Two more officers are under indictment
                    and are scheduled to stand trial at the end of
                    April 1998. The undercover part of the
                    investigation was terminated when a witness was
                    killed under orders of a New Orleans police
                    officer.

New York            (1) Six police officers from two Brooklyn
                    precincts were arrested in 1992 by Suffolk County,
                    Long Island, police and charged with narcotics
                    crimes arising from their association with a
                    Suffolk County drug ring.

                    (2) Between 1992 and 1996, federal and city
                    investigations and prosecutions led to the
                    conviction of 30 officers in Manhattan's 30th
                    precinct for primarily narcotics-related offenses.
                    An additional officer was acquitted, but later
                    found guilty of administrative charges and fired
                    by the New York City Police Department.

Philadelphia        Since 1995, 10 police officers from Philadelphia's
                    39th District have been charged with planting
                    drugs on suspects, shaking down drug dealers for
                    hundreds of thousands of dollars, and breaking
                    into homes to steal drugs and cash.

Savannah            As a result of an FBI undercover operation, 10
                    officers were convicted in 1994 for protecting
                    drug dealers. Officers took guns and drugs from
                    drug dealers on the street and sold them to
                    undercover agents portraying drug dealers.

Washington, D.C.    As a result of an FBI undercover operation, 12
                    officers were arrested and convicted in 1994 for
                    protecting an undercover agent portraying a drug
                    dealer who was transporting hundreds of kilos of
                    cocaine into Washington, D.C.
----------------------------------------------------------------------
Sources:  Chicago Commission on Police Integrity (Chicago, Detroit,
Los Angeles, Miami, and Philadelphia examples); Commission to
Investigate Allegations of Police Corruption and the Anti-Corruption
Procedures of the Police Department (New York example); and Public
Corruption Unit, Criminal Investigations Division, FBI (Atlanta,
Cleveland, Detroit, Los Angeles, New Orleans, Savannah, and
Washington, D.C., examples).

MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix IV

GENERAL GOVERNMENT DIVISION,
WASHINGTON, D.C.

Daniel C.  Harris, Assistant Director
Michael G.  Kassack, Evaluator-in-Charge
Barbara A.  Stolz, Senior Evaluator
Douglas M.  Sloane, Supervisory Social Science Analyst
David P.  Alexander, Senior Social Science Analyst
Michael H.  Little, Communications Analyst
Michelle D.  Wiggins, Issue Area Assistant

OFFICE OF THE GENERAL COUNSEL,
WASHINGTON, D.C.

Geoffrey R.  Hamilton, Senior Attorney

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