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Page 2 subject of independent articles4 and city-contracted investigations5 into the practice of badge- bending and private gatherings to mark fatal shootings. LASD deputy gang scandals and lawsuits have been reported on by the press for decades,6 but Los Angeles County elected officials have only recently launched investigations'to intervene in the patterns of serious misconduct by LASD deputy gang members. The City of Santa Ana must not make the same mistake.The recent allegations'of law enforcement gangs within the Santa Ana Police Department (SAPD) must be immediately and independently investigated and publicly reported on. The most assured approach to conducting an independent and thorough investigation into these allegations is for the City of Santa Ana to enact the robust model of civilian oversight as discussed by the City Council Ad Hoc Committee on police oversight. We urge the Mayor and City Council to immediately implement the hybrid investigation-focused and auditor and monitor-focused model of oversight to promptly investigate law enforcement gangs in SAPD. These allegations underline the critical need for the following civilian oversight powers to be urgently enacted. Independent Investigatory Authority It is crucial for the civilian oversight board to be empowered to receive,investigate,make findings, and recommend action regarding all complaints filed against SAPD officers, all allegations of serious misconduct,and all serious use of force incidents. The allegations of sexual misconduct by SAPD officers at Culichi Town restaurant in August 2020 underscores the need for independent investigations.When SAPD officers commit serious misconduct,members of the public must have an impartial and independent investigatory agency to submit complaints and to securely discuss the issues of their complaint. Moreover, independent investigatory authority would provide SAPD officer whistleblowers a meaningful opportunity to submit complaints to an independent investigatory agency,without fear of inaction, retaliation, or harassment. This meaningful opportunity to call out wrongdoing is crucial, particularly as a report on LASD deputy gangs found that"LASD representatives across staff levels described the intrinsic role of supervision as being either complacent or complicit in the formation and persistence of subgroups" and that"`there are disincentives for deputies to report these types of behaviors because of their own involvement,the pressure to not be labeled a`snitch' or `lazy,' or the belief that a deputy should `be tough' and handle it."' The patterns of workplace intimidation and harassment inherent in deputy gangs also highlights the need for Santa Ana's civilian oversight model to exclude current and former law enforcement 4 King, Geoffrey. "Vallejo police bend badges to mark fatal shootings."Open Vallejo,July 28,2020. https://openvallejo.org/2020/07/28/vallejo-police-bend-badge-tips-to-mark-fatal-shootings/ 5 Krans,Brian. "Judge says outside investigation into Vallejo police badge-bending tradition has `no value. Vallejo Sun,March 23,2022. https://www.vallejosun.com/judge-says-outside-investigation-into-vallejo-police- badge-bending-tradition-has-no-value/ 6 Center for Juvenile Law and Policy at LMU Loyola Law School, SO years of Deputy Gangs, 4. 'Tchekmedyian,Alene."L.A. County panel launches investigation into Sheriff's Department`deputy gangs."'Los Angeles Times,March 24,2022. https://www.latimes.com/califomia/stoiy/2022-03-24/civilian-oversight-commisson-del2uty-gangs-investigation 8 Camacho,Ben. "EXCLUSIVE: Santa Ana Police's MET Team Includes Gang-Like Group That Sexually Assaulted a Child."Knock LA,April 22,2022.https://knock-la.com/santa-ana-police-met-gang_/ 9 Peterson et al., Understanding Subgroups Within the Los Angeles County Sheriffs Department, 112-113 AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF SOUTHERN CALIFORNIA