Recommendations

In various sections of this report, we have recommended changes that the City of Joliet and/or JPD need to make to rectify the problems we have identified. Those recommendations and others are collected here. This list is not exhaustive, but the measures described below will move JPD toward policing in a way that both promotes public safety and also respects the Constitution and the law. These changes will also improve the trust and cooperation between JPD and the people it serves. We look forward to working cooperatively with the City and the Department to implement these recommendations.

Overarching Recommendations

• Policies
  1. Revise and implement policies that accurately reflect the conduct expected of officers and provide clear guidance to members. Train members on these policies consistently and hold members accountable for policy violations.
  2. Ensure all policies provide clear guidance so that officers and supervisors can implement key principles. Identify clear standards that supervisors can use to measure and ensure compliance.
  3. Conduct annual policy audits even when relevant law has not changed. Include in that process the divisions or units that are responsible for the policies under review.
  4. Seek input from affected communities and stakeholders in the development and revision of policies.
  5. Adopt policies that embrace best practices, not legal minimums.
  6. Make policies publicly available to the maximum extent consistent with officer and public safety.
• Training
  7. Ensure a departmental training plan is established and followed each year.
  8. Improve the process for assessing training needs within the Department, including remedial training.
  9. Ensure lesson plans are updated and instructors are qualified and effective
  10. Ensure training is rooted in best practices for adult learning, such as drawing on the learner’s existing knowledge base and using scenario-based instruction in addition to classroom lectures.
  11. Ensure that Field Training Officers are properly trained, equipped, supported, and supervised.
• Supervision
  12. Ensure that supervisors receive adequate training tailored to rank and have relevant experience to effectively oversee and guide the officers under their command.
  13. Support supervisors when they issue appropriate training and/or discipline to officers and protect them from any improper interference.
  14. Require supervisors to enforce the expectation that members under their command perform their duties in a manner that complies with federal and state law and JPD policy, especially regarding bias and use of force.
  15. Ensure that supervisors conduct complete, accurate, and thorough reviews of arrests, stops, uses of force (including gun pointing), and overall officer conduct. Ensure reviews include all relevant documents and evidence, including body camera footage, taser report, taser camera footage, and witness statements. This includes reorienting supervisory reviews away from whether officers have properly completed paperwork to substantive evaluation of enforcement activities.
  16. Hold supervisors accountable for conducting thorough reviews that identify tactical errors, training needs, and policy violations.
  17. Require supervisors to hold officers accountable for policy violations and to provide feedback on officer performance, regardless of seniority.
  18. Provide support and resources to supervisors to equip them to respond appropriately to reports of misconduct.
  19. Require supervisors to physically respond to the scene of specific calls or events
  20. Require Investigations supervisors to review cases before they are sent to the State’s Attorney.
  21. Implement a robust and effective Early Intervention System that effectively uses supervisors to identify and prevent potential problems.
• Data/Record Keeping
  22. Improve record keeping throughout the Department so that more and better-quality data is collected and records can easily be used by JPD to evaluate internal practices, trends, patterns, problems, and needs.
  23. Collect and regularly analyze data on all uses of force. Use data to assess force practices, including identifying trends, disparities, and training concerns.
  24. Improve collection and analysis of data related to race and ethnicity to evaluate disparities in enforcement. See more specific recommendation below.
  25. Aggregate information related to officer conduct so that supervisors have a full picture of each officer and can more readily identify issues before they arise.
• Community Trust
  26. Require JPD members to interact with all members of the public in an unbiased and respectful manner, and prohibit taunting, humiliating, or denigrating members of the public.
  27. Hold officers accountable for violations of anti-bias policies, including racist, sexist, or derogatory language, with clear and consistent disciplinary measures.
  28. Seek input from community members on police practices and priorities, and align officer incentives with community-based goals.
  29. Increase transparency and public trust by publicly releasing accurate, de-identified data on complaints, misconduct, and use of force.
  30. Ensure JPD officers have bilingual language skills or access to language as needed.

Use of Force

31. Ensure that policies, training, and accountability practices emphasize the sanctity of all human life and treating all people with dignity and respect as a core principle for all police interactions
32. Provide clear definitions and consistent guidance for the circumstances under which force is authorized.
33. Update use of force policies and training to emphasize that force should be proportional to the circumstances, with particular attention to tactics like taser use and head strikes.
34. Train officers to understand that resorting to force early in an encounter is not a form of de-escalation. Require officer documentation of use of force with sufficient detail to determine whether each use of force complied with JPD policies.
35. Rename the form used to report uses of force from “Defensive Action Report” to “Use of Force Report.”
36. Ensure policies include clear limits on when officers can draw, exhibit, or point their firearms, and require appropriate documentation with justifications any time an officer points their firearm at someone.
37. Ensure supervisory force investigations are thorough.
38. Require on-scene supervisory approval prior to breaking a car window for extraction, absent exigent circumstances.
39. Prohibit the use of taser on a person in an elevated position.
40. Provide sufficient scenario-based training and support to ensure officers and supervisors understand and can consistently apply JPD policies, including strategies for safely resolving encounters. Ensure policies and training incentivize and support officers to create time to safely resolve encounters.
41. Ensure officers are held accountable for failing to intervene to stop force that violates policy when they have a realistic opportunity to do so.
42. Ensure officers are held accountable for failing to report use of force policy violations.
43. Provide training for supervisors to ensure they can identify and analyze problematic force and tactics and can provide guidance and direction to officers whose conduct is problematic.
44. Hold supervisors accountable for identifying, documenting, and correcting violations of force policies and deviations from training, including ensuring that subordinates report all uses of force that are required to be reported by policy.
45. Prohibit peers and involved supervisors from conducting supervisory review of force.
46. Prohibit union members from serving on the force review panels.
47. Require force review panels to provide a substantive analysis of policy compliance (including particular consideration specific to populations such as youth or people with behavioral health disabilities) and training needs for each use of force reviewed, including all notes or memoranda on their deliberations.
48. Increase the scope of supervisory review and force review panels to include evaluation of whether supervisory review at a lower level was sufficient.

Crisis Intervention

49. Update policies regarding officers’ interactions with people with behavioral health disabilities, including its use of force policies and “Mental Health Subjects” policy. As with all policies, revisions should reflect best practices.
50. Continue to train officers to identify people in crisis and to utilize de-escalation tactics that enhance the safety of all present.
51. Ensure a fully CIT-trained officer (i.e., one who has completed the 40-hour training) is available to respond to any call involving someone with a behavioral health disability during all shifts in all districts.
52. Continue efforts to secure specialized dispatcher training and consider pairing with other agencies to do so.
53. Train and instruct dispatchers to dispatch fully CIT-trained officers to calls involving someone with a behavioral health disability. This requires keeping dispatchers informed about which officers are fully CIT-trained.
54. Involve community partners and community members—especially those with lived experience—in developing policies and delivering training to ensure they meet the needs of the Joliet community
55. Designate a supervisor to serve as a CIT Coordinator^[1] to develop and implement revised policies and trainings and to coordinate the Department’s crisis intervention response, including overseeing CIT-certified officers
56. Improve collection and analysis of data related to calls and outcomes involving individuals who may have a behavioral health disability.^[2]
57. Conduct thorough reviews of incidents involving individuals who may have a behavioral health disability and the actions taken, both to ensure compliance with policy and to inform and improve policies, training, and tactics
58. Review uses of force involving individuals with a behavioral health disability for compliance with CIT policy in addition to use of force policy.
59. Continue efforts to develop cross-agency resources for responding to people in crisis.
60. Ensure all Department members receive annual scenario-based training on mental health topics.

Discriminatory Policing

61. Revise policy on discriminatory policing to accurately reflect the law and to be more comprehensive of the variety of conduct that constitutes biased policing.
    • As with all policies, train all members regularly.
    • Engage meaningfully with the Joliet community and seek input from communities that are affected by biased policing in the development and revision of the policy and training.
62. Improve documentation of all stops (including pedestrian stops), frisks, and searches, requiring officers to document, at a minimum, the race of the person stopped and the reasonable suspicion (based on articulated facts) or probable cause that supports the relevant enforcement activity. Require supervisors to review this documentation to ensure compliance with law and policy.
63. Regularly analyze data on stops, citations, frisks, searches, arrests, uses of force, and other enforcement activities. Where the analysis shows disparities in enforcement, attempt to determine why the disparities exist and take steps toward eliminating unjustified racial disparities—such as by redeploying officers or re-prioritizing enforcement objectives.
64. Train supervisors to recognize, monitor for, and respond to biased policing.
    • Require supervisory review of officers’ enforcement activities to include review for indications of bias.
    • Hold supervisors accountable for identifying and addressing bias.
    • Provide supervisors with tools necessary to effectively monitor and review, and to help guide officers away from biased conduct.
65. Collect accurate data on complaints of biased policing, even if not sustained, and use this data to assess patterns.
66. Ensure allegations of racial bias are fully investigated and that officers are held accountable for violations. Report sustained allegations to prosecutors as required under Brady and Giglio.
67. Revise gang database policies and practices. This includes conducting a review of the utility and procedural fairness of its database, purging records for individuals whose information has been improperly maintained, and coming into compliance with federal requirements and standards.
68. Provide annual high quality training on fair and impartial policing that is clearly supported by JPD leadership.

Gender Bias

69. Revise the Department’s domestic violence policy to require (1) thorough investigation of domestic violence incidents, (2) strangulation and lethality assessments, and (3) primary aggressor determinations where appropriate.
70. Ensure Department members comply with the sexual assault policy, including by using trauma-informed practices in interactions with victims, including trauma-informed interviews of victims.
71. Provide thorough training to all sworn personnel in responding to gender-based violence.
    • For detectives and Internal Affairs investigators, this should include training in trauma-informed interviewing, up-to-date investigation techniques relevant to gender-based crimes, and a more comprehensive understanding of victims’ responses to sexual assault and domestic violence.
72. Designate specific detectives to handle domestic violence investigations and provide them with advanced training.
73. Ensure the Department has enough detectives to handle the gender-based violence caseload.
74. Track arrest warrants issued in domestic violence and sexual assault cases and the time it takes from warrant to arrest.
75. Provide high quality training to recognize and mitigate bias against women, especially survivors of gender-based violence.

Accountability

76. Revise complaint intake procedures and public-facing information to simplify and facilitate community member complaints, including requiring Department members to accept, document, and notify Internal Affairs about all complaints of misconduct.
77. Prohibit officers from discouraging complaints by members of the public.
78. Respond to all complaints as required by policy, and not as desired by complainant
79. Ensure that department members are trained on their duty to report misconduct and to cooperate with administrative investigations, and are held accountable for failing to do so.
80. Provide clear guidelines for complaint classification to ensure that serious misconduct is adequately investigated and disciplined, including:
    • Classifying complaints based on the nature of the allegations rather than on anticipated outcomes
    • Completing investigations even in cases where complainants do not participate in the investigation
81. Implement procedures for thorough, objective, and timely investigations, including:
    • Setting appropriate timeliness benchmarks and ensuring adherence to those benchmarks.
    • Ensuring that investigators obtain all available, relevant evidence and conduct thorough and impartial interviews.
    • Establishing standards for objective and unbiased review of evidence, including in credibility determinations, and the documentation of this review.
82. Implement procedures for ensuring fair, proportionate, and consistent discipline including the proper tracking and analysis of remedial training and enhanced supervisor oversight.
83. Provide sufficient training and oversight for Department members responsible for ensuring accountability.
84. Comply with best practices in hiring and promotion processes, including by rejecting candidates with problematic backgrounds and disciplinary histories.
85. Ensure that BOFPC members receive relevant training on police policies and best practices such as statutory powers of police, automatic disqualifiers from JPD employment, an Officer’s Oath of Office, JPD’s disciplinary process, and DEI related concerns.
86. Collect and analyze data about misconduct allegations to identify and correct problems in the Department.