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Page 3 officers from serving. Members of the public and whistleblower SAPD officers must be assured that the civilian oversight investigative process will not be influenced by the pervasive law enforcement culture of allegiance and "warrior mentality"10 that condones aggressive policing. Moreover, the City of Santa Ana must consider the shortcomings of the investigation into the Vallejo Police Department (Vallejo PD) law enforcement gang. The City of Vallejo contracted with a retired Sonoma County Sheriff to conduct the independent investigation into badge-bending within Vallejo PD.11 During a recent hearing regarding Vallejo PD's use of deadly force, a Solano County Superior Court Judge stated that the independent investigation by the retired Sheriff has "no value" and is"not designed to bring some light"into the practice.12 To date,the City of Vallejo has not made the investigative report public. The City of Santa Ana must not only expedite civilian oversight to investigate law enforcement gangs,but must also ensure the investigatory process has integrity by excluding law enforcement. Regular Public Reporting Santa Ana community members deserve clear answers into the allegations of sexual misconduct surfaced in the Knock LA article. Santa Ana's civilian oversight policy must include the mandate to post on an accessible website all public reports regarding complaint dispositions, investigative findings of fact, and proposed discipline. The disposition of complaints must also be sent directly to civilian complainants. The allegations of SAPD law enforcement gang misconduct must be investigated and transparently reported on. As with the repeated failed attempts by LASD leadership to correct patterns of serious misconduct by LASD gangs over six different sheriff's administrations,13 residents of Santa Ana should not be asked to put blind faith into SAPD's investigation and unsustained misconduct determinations regarding law enforcement gangs. The public must be empowered to access and review independent investigatory reports into law enforcement gang practices within SAPD. Power to Audit Policies and Procedures The civilian oversight board must have the power and authority to conduct independent audits and investigations regarding policies, practices, procedures, customs, and orders of SAPD and to determine whether members of the Police Department are engaging in patterns or practices of constitutional or legal violations,misconduct, or behavior that is problematic with regard to public interaction. Assembly Bill 958 requires law enforcement agencies to have a policy "prohibiting law enforcement gangs and making participation, as specified, in a law enforcement gang grounds for termination" and requires "an agency to disclose an officer's termination for involvement in a law enforcement gang to another law enforcement agency conducting a preemployment background investigation of that officer."14 Given the allegations of law enforcement gangs in SAPD, the City's civilian oversight board must have auditing authority to ensure the City is fully compliant with the new law. 10 Klemko,Robert. "Much of America wants policing to change.But these self-proclaimed experts tell officers they're doing just fine."The Washington Post,January 26,2022. https://www.washingtonpost.com/national- security/2022/01/26/police-training-reform/ 11 Badge-bending is a practice that Vallejo PD officers engaged in for decades,where officers involved in on-duty shootings would bend the tip of their badges to commemorate taking lives. 12 Krans,"Judge says outside investigation into Vallejo police badge-bending tradition has `no value."' 13 Center for Juvenile Law and Policy at LMU Loyola Law School,50 years of Deputy Gangs, 25. 14 Cal.Pen.Code § 13670 AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF SOUTHERN CALIFORNIA