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LEROY D . BA CA.

S H ER IF"F

July 10, 2012

The Honorable Board of Supervisors
County of Los Angeles
383 Kenneth Hahn Hall of Administration
Los Angeles, California 90012
Dear Supervisors:
30-DAY STATUS OF RECOMMENDATIONS MADE IN THE OCTOBER 18, 2011,
BOARD OF SUPERVISORS' MEETING REGARDING THE MERRICK BOBB AND
OFFICE OF INDEPENDENT REVIEW REGARDING THE JAIL SYSTEM
On October 18, 2011, your Board requested that the Los Angeles County Sheriffs
Department (Department) report back on the motion to immediately implement the
recommendations previously made by Special Counsel Merrick Bobb and the Office of
Independent Review. In addition , your Board requested the Department report back on
deputy worn video cameras, the status of the Department's hiring practices, sting
audits, a force rollout team, and the length of time deputies serve in the jails . Attached
is an update on each recommendation from the June 20,2012, response.
Should you have any questions or require additional information, please contact me or
Assistant Sheriff Cecil W. Rhambo , Jr., at (323) 526-5065 .
Sincerely,

EROY D. BACA
SHERIFF

:7! 7rachljon

0/ cSer()i ce

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

COUNTY OF LOS ANGELES - SHERIFF'S DEPARTMENT
The purpose of this document is to provide a status of the recommendations by date
and title, prepared by Special Counsel Merrick Bobb, the Office of Independent Review,
and the Board of Supervisors.

I.

Install surveillance cameras at the Men's Central Jail, the Inmate Reception
Center and the Twin Towers Correctional Facility within 30 days and
develop a plan to purchase and install surveillance cameras at the
remaining jail facilities.
The Department has installed all 705 cameras at Men's Central Jail (MCJ). As of
May 31, 2012, all cameras are online and recording.
The Department is installing cameras at Twin Towers Correctional Facility
(TTCF) and the Inmate Reception Center (IRC). Currently, 615 cameras have
been installed at TTCF (2 recording) and 49 cameras have been installed at IRC
(19 recording).
The attached document (Camera Project Status Report) depicts the
Department's current status on camera installation and the projected total of
cameras.
Data Storage
The video storage servers provide storage of video data. They were received
and installed in December 2011. With existing funds, additional memory has
been added to provide long-term storage of video for 25 months at MCJ and
TTCF. Technicians are analyzing equipment efficiency and quality of resolution
as cameras are added to the servers. Several options regarding video storage
are being considered in order to meet legal and Board approved requirements for
video storage, while also maintaining quality resolution at a reasonable cost.

The network upgrade equipment are servers which send the video feed from the
camera to the archive video server and was installed on April 28, 2012.
Policy
The Department has drafted a new policy regarding video surveillance. The
policy is in the final stages of being reviewed by Department executives and
County Counsel.

Page 1 of 9

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

II.

Eliminate the use of heavy flashlights as batons to subdue inmates.
The Department and the Association for Los Angeles Deputy Sheriffs (ALADS)
came to a mutual agreement regarding the use of flashlights in the jails. The
Sheriff has directed and approved a new policy to limit the size and weight of the
flashlight. The policy specifies that the flashlights shall not weigh more than 16
ounces, and shall not be more than 13 inches in length. Flashlights longer than 6
inches shall be of plastic or nylon composite material only. The Custody Division
Manual (COM) section 3-06/055.20 Flashlights, was published on May 23, 2012.
The Department has not yet received the lightweight battery inserts to make the
current duty issue flashlight in conformance with the new flashlight policy. This
policy effective date will be extended to September 1, 2012, in order to allow
employees a reasonable transition period to acquire a new duty light, or be
issued a lightweight battery insert from the Department.

III.

Eliminate the use of "steel-toe" shoes.
Recommendation implemented.
On October 24, 2011, the Department made revisions to the existing "Footwear"
policy (MPP 3-03/225.00). This policy was published into the Department's
Manual of Policy and Procedures and disseminated to all personnel on
February 12, 2012.
Research of existing personnel showed that Department personnel have never
worn "steel toe" boots in any capacity; however, the Department formally revised
the policy to strictly prohibit any use of "steel toe" boots.

IV.

Revise the Policy on Head Strikes with Impact Weapons to forbid all head
strikes, including, but not limited to, head strikes against fixed objects
such as floors, walls or jail bars, unless the standard for lethal force has
been met.
Recommendation implemented.
On October 10, 2011, the Sheriff initiated a "Force Prevention" policy (COM 302/035.00) which provides direction for personnel relating to respect based
treatment of incarcerated individuals. This policy was published into the Custody
Division Manual and disseminated to all custody assigned personnel on
November 8, 2011. The policy was then discussed with the ALADS working
group in which revisions were made. The revised Force Prevention policy was
republished and redistributed to all personnel in the jails on March 19, 2012.
Page 2 of 9

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

On October 26, 2011, the Department made additions to the existing
"Unreasonable Force" (MPP 3-01/025.10) policy and the "Activation of
Force/Shooting Response Teams" (MPP 5-09/434.05) to strictly prohibit head
strikes against a hard object. Unless otherwise handled by the Internal Affairs
Bureau (lAB), the Custody Force Response Team (CFRT) responds to all force
incidents where any head strike occurs, whether the strike is initiated by
personnel, or by contact with floors, walls or other hard objects. The
"Unreasonable Force" and "Activation of Force/Shooting Response Teams"
policies were published into the Department's Manual of Policy and Procedures
and disseminated to all personnel on February 13, 2012.

V.

Rotate jail deputies between floors at Men's Central Jail and other jail
facilities at no less than six-month intervals.
Recommendation implemented.
In January 2011, Men's Central Jail began rotating their staff no less than every
six months. After consulting with ALADS, a new Custody Directive "Mandatory
Rotation of Line Personnel in Custody" (12-001) was published and disseminated
to all custody personnel on February 17, 2012, mandating the rotation of all
Custody line personnel every six months.

VI.

Enforce the Anti-Retaliation Policy to prevent Sheriff's deputies from
retaliating against inmates speaking with legal representatives or inmate
advocacy groups or for expressing dissatisfaction with jail conditions.
Recommendation implemented.
In August 2011, the Department made revisions to the existing "Treatment of
Inmates" (CDM 5-12/005.00) policy to prevent deputies from retaliating against
inmates. All staff assigned to Custody Division were provided a formal briefing
on the revisions to the policy. The briefing began August 4, 2011, and continued
for a two-week period. In addition, the Department redistributed the policy on
October 25, 2011, for another two-week recurring briefing to ensure each staff
member was fully aware of the expectations of the policy and mandated quarterly
recurring briefings be conducted.
The Department made additional revisions to the existing "Treatment of Inmates"
policy in order to separate and create specific orders relating to retaliation
against inmates. The Custody Division Manual, "Anti-Retaliation Policy" (CDM 512/005.05) mandates that all complaints of retaliation are forwarded to lAB; the
captain of lAB will determine which unit will conduct the investigation. This
Page 3 of 9

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

revised version of the "Treatment of Inmates" policy and the new "Anti-Retaliation
Policy" were published and disseminated to all custody personnel on
February 27, 2012. ·

VII.

Interviews of inmates who make claims of excessive force should not be
conducted by, or in the presence of, the deputies or their supervising
sergeant involved in the alleged use of force.
Recommendation implemented.
On October, 26, 2011, the Department made revisions to the existing "Use of
Force Reporting and Review Procedures" (MPP 5-09/430.00) policy ensuring
privacy during force interviews. This policy was published in the Department's
Manual of Policy and Procedures and disseminated to all personnel on
February 13, 2012.

VIII.

Interviews of inmates alleging use of force and any witnesses must occur
as soon as feasibly possible, but no later than 48 hours of the incident.
Recommendation implemented.
On October, 26, 2011, the Department made revisions to the existing "Use of
Force Reporting and Review Procedures" (MPP 5-09/430.00) policy directing
supervisors to immediately conduct interviews. As noted in VII, this policy was
published in the Department's Manual of Policy and Procedures and
disseminated to all personnel on February 13, 2012.

IX.

Develop a prioritization process for Use of Force Investigations to ensure
that the most severe incidents are completed within 30 days and that all
others are completed within 60 to 90 days.
Recommendation implemented.
The Department developed a CFRT Directive (11-005) that established new
criteria for force review in the jails. This ensures that significant force cases, not
handled by lAB, are externally evaluated and completed within 30 days. At that
time, they are reviewed by the newly formed Custody Force Review Committee
(CFRC), which consists of three commanders. The last CFRC was conducted on
June 19, 2012, and included oversight by the Office of Independent Review
(OIR). The next CFRC is scheduled for July 10, 2012.

Page 4 of 9

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

The Department continues to process the most severe incidents as lAB
investigations, which are generally completed within 90 days unless unexpected
circumstances arise.
The CFRT Directive was published and disseminated to all custody personnel on
November 7, 2011. The aforementioned CFRT Directive was revised and
published as a Custody Division Policy on May 23, 2012. The CFRC policy was
published and disseminated to all custody personnel on April 16, 2012.

X.

Develop a plan for more intense supervision that requires jail sergeants to
directly supervise jail deputies, including walking the row of jail cells and
floors and responding as soon as possible to any notification of interaction
where force is being used on an inmate.
Recommendation Implemented at MCJ.
On October 27, 2011, the Department delivered a letter to the Chief Executive
Officer requesting additional supervisory staff in the jails. However, the
Department felt it was imperative to immediately increase staffing at MCJ.
Effective November 6, 2011, 19 sergeants were added to MCJ's current staffing
to ensure the appropriate supervision was in place. These items were removed
from other critical areas within the Department and deployed to cover both Day
and PM shifts. There are now 2 sergeants assigned to 2000, 3000, 4000, 5000,
and 9000 floors, and a full-time sergeant is dedicated to 1700/1750. All
sergeants were briefed on the expectations to be visible and actively monitoring
activity on the floor at all times. In addition, the Department is working on "duty
statements" for all custody personnel to ensure they have a full understanding of
the expectations of their assignment.

XI.

Immediately mandate that all custody medical personnel report all
suspicious injuries of inmates to the Internal Affairs Bureau or the captain
of the jail facility where the inmate is housed.
Recommendation implemented.
On October 26, 2011, the Department's Medical Services Bureau revised the
"Injury/Illness Report - Inmate" policy (M206. 09) to include a provision requiring
medical staff to advise the facility watch commander in the event an inmate
reports/alleges that their injuries are the result of force used by a Department
employee. This policy was disseminated to all medical personnel on
October 26, 2011.
Page 5 of 9

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

XII.

Report back on the role of the new jail commanders and how they will be
used to reduce jail violence.
As reported to the Board on November 1,2011.
Since the implementation of efforts by the CMTF to reduce jail violence and
associated use of force incidents, total significant uses of force continue to
decline. Two documents are attached relating to force incidents in the jails:
Force Used by Month - Significant force vs. Less significant force
Force Year to Date - 2007 to 2012
The jail commanders continue to work with each custody unit to accomplish the
goals set forth by the Sheriff.
The jail commanders oversee the operations of the CMTF, comprised of five
commanders, eight lieutenants, eight sergeants, and four support staff. The
lieutenants, sergeants, and support staff are all items that were removed from
critical units within the Department and deployed to this task force.
The CMTF Mission is to assess and transform the culture of the custody facilities
in order to provide a safe, secure learning environment for our Department
personnel and the inmates placed in the Department's care. The CMTF's
purpose is to empower Department personnel to provide a level of
professionalism and serve the needs of inmates consistent with the Department's
"Core Values."
The CMTF's responsibilities and goals include promoting community trust,
reducing jail violence by changing the deputy culture of the custody environment,
encouraging respect based communications with inmates, reviewing and
implementing new training for staff assigned to the jails, preparing and revising
all directives/policies necessary to implement Special Counsel Merrick Bobb/OIR
recommendations, analyzing force incidents and developing and implementing a
custodial career path.
The CMTF and Custody Support Services have been working collaboratively to
fulfill recommendation requests made by the American Civil Liberties Union
(ACLU), Special Counsel Merrick Bobb, the OIR and the Los Angeles County
Board of Supervisors, which pertain to the Jails (recommendations attached).

Page 6 of 9

RECOMMENDATIONS BY MERRICK BOBB AND OFFICE OF INDEPENDENT REVIEW
REGARDING THE JAil SYSTEM
Below is a summary of the current overall status of all recommendations made
since 1994:

Agency

Implemented'

AClU

27
94

-----

Not
ImDlemented
2

In Process

6

3

Totals
Recommendatio l1!.......
32

75

2

17
6

119

01R
60S

6

0

2

6

Totals

202

12

30

244

Bobb

85

The eight CMTF lieutenants work directly in accomplishing the goals set forth by
the Sheriff and commanders. The eight CMTF sergeants are comprised as a jail
force "roll-out" team (CFRT) who oversee, mentor and review all significant force
cases that meet a particular criterion, yet do not rise to the level of an lAB
investigation .

XIII,

Sheriff to work with the Chief Executive Office to immediately study the
feasibility of purchasing officer worn video cameras for all custody
personnel to use, to identify potential funding for this purpose, and
develop appropriate policies and procedures for the use of these cameras.
Policies should include a requirement that custody personnel record all
interactions with inmates, including Title 15 checks, any movement
throughout the jail facilities and any use of force. Each failure to record or
immediately report any use of force against inmates must be appropriately
disciplined.

As reported to the Board on March 13, 2012.
The Department is conducting a six month "Proof of Concept" in order to
determine whether there is a practical use for Personal Video Recording Devices
(PVRD) in Custody Operations Divisions.
The Deparlment has received and issued 30 PVRD's, for the pilot program. The
CMTF drafted a guideline, and conducted training for the volunteer deputies
involved in the program. The pilot program began on February 26,2012, and will
be re-evaluated in six months. The PVRD's are wom by deputies interacting with
inmates at MCJ and TTCF. The Deparlment has conducted testing with three
different models of PVRD's_

Page 7 019

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

XIV.

Consider the feasibility of targeted and random undercover sting
operations performed in custody facilities to ensure deputies are working
within policy.
As reported in closed session.
The Sheriff discussed this motion during the November 1, 2011, closed session
meeting.

XV.

Consider a "roll-out team" to investigate when there is a use of force in a
custody facility.
Recommendation implemented.
Beginning November 2011, the Department created the CFRT, comprised of
eight sergeants and a lieutenant, who are tasked with responding to selected
custody facility force incidents.
The CMTF created a set criteria that mandate facility watch commanders to
contact the CFRT and request a response. The CFRT sergeant will oversee and
assist in the force documentation for the facility. In the course of reviewing the
incident, the CFRT sergeant shall give specific direction to the handling
supervisor. If any policy violations are discovered, the CFRT will immediately
assume responsibility of the force investigation and initiate an lAB investigation.
All incidents requiring a CFRT response will be reviewed by a newly formed
CFRC comprised of three commanders assigned to Custody Division. The
CFRC has the authority to order additional investigation, make
recommendations, or request an lAB investigation if there appears to be a
possible violation of Department policy. Since the implementation of the CFRT,
they have responded to 70 incidents as of July 2, 2012.

XVI.

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

XVII.

Consider a two-track career path for deputies, patrol deputies and custody
deputies.
Feasibility study is ongoing.
Page 8 of 9

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

On December 16, 2011 , the CMTF concluded an extensive two-month study
which analyzed different methods of implementing a two-track career path within
the Department. Study results and CMTF recommendations have been
presented to the Chief Executive Office (CEO), ALADS, PPOA, and the Public
Safety Cluster Agenda Review meeting on February 8, 2012.
The Department formed a subject matter expert working group to update the
current sergeant and lieutenant classifications for the Dual Track Career Path
proposal, and is also working with the CEOs Classification Unit regarding its
implementation. The CMTF continues to conduct informational meetings
conceming the proposal with the Chief Executive Office (CEO), ALADS, and
PPOA.

XVIII.

Review existing policy of assigning new deputies to custody functions,
specifically, the length of time spent in custody and the hiring trend as its
primary determining factor, and revise the policy to reduce the length of
time deputies serve in custody.
On October 28, 2011 , the Department authorized custody personnel to initiate
extensions if they desire to remain in their current assignment. As of July 5,
2012, 406 deputies have taken advantage of this offer, which will ultimately
cause a reduction of time that deputies will serve in a custody assignment.
As noted in the above item, recommendations for a two-track career path were
presented to the CEO, ALADS, Professional Peace Officers Association, and the
Public Safety CARs meeting on February 8, 2012, which will reduce the length of
time deputies, serve in custody.

Page 9 of 9

CAMERA PROJECT STATUS REPORT
6/18/2012

MCJ

ITC'

,

II
,

*

~

~

~

lOS ANGElES COUNTY SHERIFF'S DEPARTMENT

Force By Month 2011

- - - -- -- - - - - - -- -----r

100

19,000

90

17,000
80
70

.

::c

________~..__..__~~------------------------------------------{

...c

60

13,000

I

l
14
11,000 !

~ 50

=

i

~

15,ooo ~

.

40

'ii
Q
30 +-----------~~------------------~.-------~~----------------~~~-l 9,ooo

i

20

!
7,000

10
~--+ 5,000

Jan 11

Feb 11

Mar 11

Apr 11

May 11

Jun 11

Julll

--Significant

Aug 11

Sep 11

Oet 11

- - -less Significant

Nov 11

Dec 11

- Combined

Jan 12

Feb 12

Mar 12

Apr 12

May 12

~u ne

12

~ D IP

eportable force is less significant when it is limited to any of the following and there is no injury or complaint of pain nor any indication of misconduct:
Searching and handcuffing techniques resisted by the suspect,
Department-approved control holds, come-along, or take down,
Use of Oleoresin Capsicum spray, Freeze +P or Deep Freeze aerosols, or Oleoresin Capsicum powder from a Pepperball projectile when the suspect
is not struck by a Pepperball projectile.
eportable force is significant when it involves any of the following:
Suspect injury resulting from use of force,
Complaint of pain or injury resulting from use of force,
Indication or allegation of misconduct in the application of force,
Any application of force that is greater than a Department-approved control hold, come-along, or take down. This includes the activation of the
electronic immobilization belt or the use of the Total Appendage Restraint Procedure (TARP).

·Total$ P'~s~l!t~d a~ as 0107/05/2012

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

_lCCC

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.

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