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Item # 22
City of Santa Ana
20 Civic Center Plaza, Santa Ana, CA 92701
Staff Report
October 18, 2022
TOPIC: Police Review Commission Draft Ordinance Discussion
AGENDA TITLE:
Discuss Draft Ordinance Establishing a Police Oversight Commission and Provide
Direction to Staff
RECOMMENDED ACTION
Discuss a draft ordinance establishing a police oversight commission and provide
direction to staff.
DISCUSSION
Timeline
Below is a timeline of activities associated with recent discussions about police
oversight by members of the City Council and Police Oversight Ad Hoc Committee:
June 16, 2020
•Mayor Sarmiento, Mayor Pro Tem Bacerra, and Councilmember Penaloza add a
councilmember requested item to direct staff to research police oversight and
return to the City Council with an informational report.
September 15, 2020
•Staff presents an informational report to the City Council relating to police
oversight. Topics include history of police oversight, overview of models,
subpoena authority, and the Santa Ana Police Department (SAPD)’s complaint
process for allegations of police officer misconduct.
December 15, 2020
•Staff presents an informational report (topics include more details about
subpoena authority, comparative analysis of California cities with police
oversight, and community feedback survey results).
September 7, 2021
•Staff presents an informational report (topics include analysis of Auditor/Monitor
and Investigation-Focused models, examination of Berkeley, Oakland, Riverside,
and Anaheim police oversight mechanisms, and eligibility criteria to serve on a
police oversight board/commission).
Police Review Commission Draft Ordinance Discussion
October 18, 2022
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October 5, 2021
•Mayor Sarmiento appoints Mayor Pro Tem Bacerra, Councilmember Hernandez,
and Councilmember Lopez to the Police Oversight Ad Hoc Committee.
November 2021 - June 2022
•The Police Oversight Ad Hoc Committee meets eight times to study police
oversight in detail and return to the City Council within one year with a
recommendation. The Ad Hoc Committee works on a draft ordinance to establish
a police oversight commission.
July 29, 2022
•The City Council holds a work study session and directs the City Attorney to
prepare an ordinance establishing a police oversight commission.
Draft Ordinance
For discussion only, the City Attorney has prepared a draft ordinance (Exhibit 1)
establishing a police oversight commission. The origin of the ordinance is the working
draft ordinance by the Police Oversight Ad Hoc Committee and staff. Below is a
summary of the provisions of the ordinance:
•Establishes a Police Oversight Commission with an independent Oversight
Director to assist in reviewing the police complaint process and provide a forum
to review, evaluate, and make recommendations about police and public safety.
•Proposes a police oversight model that is a hybrid model consisting of elements
of both the Auditor/Monitor and Investigation-Focused models.
•Consists of seven commissioners appointed by the City Council.
•Requires that each commissioner do the following:
o Take an oath and execute a confidentiality agreement.
o Participate in a ride-along.
o Receive training.
•Requires that the Commission meet within 30 days of all commissioners being
appointed.
•Provides that the City Manager recommend a budget for the Commission as part
of the annual budget process.
•Rules and records are to be developed by the Commission, in consultation with
the Independent Oversight Director and City Manager.
Next Steps
At this time, staff seeks direction from the City Council relating to the draft ordinance.
ENVIRONMENTAL IMPACT
There is no environmental impact associated with this action.
FISCAL IMPACT
There is no fiscal impact associated with this action.
Police Review Commission Draft Ordinance Discussion
October 18, 2022
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EXHIBIT(S)
1. Draft Ordinance (for discussion only)
Submitted By: Kristine Ridge, City Manager
Approved By: Kristine Ridge, City Manager
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ORDINANCE NO. ___
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF SANTA ANA AMENDING
ARTICLE IV OF CHAPTER 2 OF THE SANTA ANA MUNICIPAL CODE TO DELETE
DIVISION 11 AND REPLACE IT WITH A NEW DIVISION 11 FOR THE
ESTABLISHMENT OF A POLICE OVERSIGHT COMMISSION
RECITALS
A. The residents of the City of Santa Ana are concerned about public safety and have
expressed their concern through various means of civil engagement, including
participation in community forums on civilian oversight and widespread protests in 2020
as part of the national movement for racial justice and police accountability.
B. There have been publicized allegations of excessive force, unnecessary use of force,
abuse of authority, and bribery committed by Santa Ana Police Officers which erodes
public trust in law enforcement and the community, the Police Department and the City
Council are committed to working together to build trust and improve public safety.
C. The City of Santa Ana has settled numerous lawsuits concerning allegations against
police officers and the Santa Ana Police Department (Department or Police Department)
and the settlements are reported to have cost the City an estimated $24 million and the
City Council is committed to exploring ways to reduce liability through improvements in
police operations.
D. The establishment of the Santa Ana Police Oversight Commission will support
democratic governance and will lead to an even more professional, well-managed,
ethical, and highly functioning Police Department.
E. Santa Ana residents and the City Council desire a highly resourced and effective
Oversight Commission to improve law enforcement operations and build community trust.
F. The Santa Ana City Council is committed to providing the resources needed to properly
investigate allegations of abusive police practices, police misconduct, officer-involved
shootings, and other serious uses of force and thereby determines it is necessary to
ensure the people who conduct investigations have the requisite expertise, establish the
credibility of the investigations, and inspire the community’s confidence in their quality
and independence.
G. Pursuant to the City of Santa Ana City Charter Section 700, the City Council may
provide for the organization, conduct, and operation of offices, departments, and other
agencies set forth in the Charter and may provide for the creation of additional
departments, divisions, offices, and agencies and for their alteration or abolition, for their
assignment and reassignment to departments, and for the number, titles, qualifications,
powers, duties, and compensation of all officers and employees.
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H. Pursuant to City Charter Section 700, the City Council by ordinance may assign
additional functions or duties to offices, departments, or other agencies or create
additional offices or departments.
I. Pursuant to City Charter Section 900 the City Council may establish appointive boards
and commissions by ordinance and shall specify in such ordinance the powers and duties
of the boards and commissions.
THE CITY COUNCIL OF THE CITY OF SANTA ANA DOES HEREBY ORDAIN
AS FOLLOWS:
SECTION 1. Article IV of Chapter 2 of the Santa Ana Municipal Code is hereby
amended by deleting the existing Division 11 in its entirely and replacing it to read as follows: :
CHAPTER 2
ARTICLE IV
DIVISION 11 – POLICE OVERSIGHT COMMISSION
2-616. Establishment and Purpose.
There is hereby established a Police Oversight Commission (hereinafter referred
to as the “Commission”). The purpose of the Commission shall be to improve
transparency, increase the accountability of and public confidence in the Santa Ana
Police Department, provide for an Independent Oversight Director to assist in reviewing
the police complaint process and provide a forum to review and evaluate and make
recommendations about police and public safety.
2-617. Police Oversight Commission Membership and Term
The Commission shall consist of seven (7) members to be appointed by the city
council from the residents of the city.
The city council shall appoint members who are fair and impartial and represent
diverse social, economic and political interests. The city council shall consider the
career and life experiences of Commission applicants and appoint people whose
experiences will most benefit the Commission’s ability to carry out its duties and
responsibilities and build trust with the community. The City Clerk shall prepare
application forms requiring applicants to provide information demonstrating that they
meet qualification requirements set forth in Section 2-618.
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2-618. Qualifications of Commissioners
Qualifications of Commissioners.
(a) All members of the Commission shall reside in the City of Santa Ana.
(b) Elected or appointed officers and employees serving the City shall not be
eligible for appointment to the Commission.
(c) Any person who is an employee of any federal, state, county or city
governmental entity or agency or any member of the employee’s immediate family shall
not be eligible for appointment to the Commission unless at least five (5) years has
passed from the date of their separation from the governmental entity with which they
were previously employed. “Immediate family” as used herein shall be defined as the
spouse, registered domestic partner, or dependent children of the government
employee. This prohibition excludes any person who is an employee of any college or
university, (member of academia) and any person employed by a non-profit
organization.
(d) Practicing attorneys who handle, or are members of firms or entities that
currently handle, criminal or civil matters involving the Santa Ana Police Department are
ineligible to serve on the Commission.
Sec. 2-618. – Commissioner confidentiality and training
(a) Prior to attending his or her first Commission meeting, each Commissioner
shall take an oath and execute a confidentiality agreement stating that they will not
divulge confidential information, including identities of witnesses and contents of
confidential testimony and documents, either during their term of office or thereafter to
ensure that private personnel information and other information subject to state law
protections is not released or shared
(b) No later than 90 days after appointment, each member shall:
1. Participate in a ride-along with the Santa Ana Police Department and every
six (6) months thereafter; and
2. Receive training in relevant subject matters, including but not limited to the
police department’s operations, policies, practices, procedures related to: internal affairs
investigations, authorized uses of force including the use of deadly force, control
devices and techniques, uses of conducted energy devices, handcuffing and restraints,
detention and arrest of persons, search and seizure of persons and property, and
vehicle pursuits well as the duties, responsibilities, procedures, and requirements
associated with all ranks and assignments facilitated by the [Independent
Inspector/Director
3. All training shall be predominantly obtained from independent, third-party
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bodies or institutions that have experience with internal affairs of police departments
and civilian review investigations and audits.
4. Attend training sessions sponsored by the National Association for Civilian
Oversight of Law Enforcement or similar entities, or through presentations provided on
topics including, at a minimum, constitutional rights and civil liberties, fundamentals of
procedure, evidence, and due process, procedural rights and confidentialities afforded
to police officers by California law (including, but not limited to, Government Code
Section 3300 et seq. and Penal Code Sections 832.7 and 832.8 and Evidence Code
Sections 1040-1043, state use of force standards, police union contract, labor rights, in-
person Implicit Bias training, and best practices for conducting investigations.
Sec. 2-620. - Meetings.
The Commission shall hold its first meeting within thirty (30) days after all of its
members have been appointed. At such meeting, the Commission shall fix the time and
place of regularly scheduled meetings which shall not meet less than once each month.
The Police Chief or their designee or other person directed by the City Manager shall
attend all regular and special meetings of the Commission and provide regular staff
support to the Commission.
Sec. 2-621. - Powers and duties of the Police Oversight
Commission.
To effectuate its purpose, the Commission shall:
(a) Review and evaluate the policies, practices and procedures contained in the Santa
Ana Police Department policies manual and develop programs and strategies to
promote positive police community relations and make appropriate recommendations to
the City Manager and the City Council. Within thirty (30) days after receiving such
recommendations the City Manager shall submit a response to the Commission. If the
Commission is dissatisfied with the response, the Commission may submit its
recommendations to the City Council. The City Manager may extend for an additional
thirty (30) days the time periods in which they are required to submit their responses to
the Commission by giving the Commission written notice of such extension.
MENU ITEMS FOR SECTION (b) [There may be other suggested options upon
discussion]:
(b) Receive, hear and review misconduct complaints against Santa Ana police officers
alleging the use of force that result in great bodily injury, discrimination, officer veracity,
sexual harassment, and/or sexual assault by on-duty Santa Ana police officers.
OR
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(b) Hear and review misconduct complaints against Santa Ana police officers where the
allegation involves the use of force that resulted in great bodily injury, discrimination,
officer veracity, sexual harassment, and/or sexual assault if the Department’s Internal
Affairs investigation results in a finding of “unfounded”, “exonerated” or “not sustained”
and thereafter by unanimous vote, recommend Oversight Director conduct independent
investigation;
OR
(b) Receive and review all findings from Internal Affairs stemming from misconduct
complaints against Santa Ana police officers where the allegation involves the use of
force that result in great bodily injury, discrimination, officer veracity, sexual harassment,
and/or sexual assault.
(1) All complaints to be reviewed by the Commission must be addressed to the
Commission and must be in writing on forms supplied by the Commission and shall be
signed by the complainant. Anonymous complaints will not be accepted.
(2) A copy of each complaint filed for Commission review shall immediately be
forwarded to the members of the Commission, the Independent Oversight Director, the
City Manager and the Chief of Police.
(3) No complaint shall be accepted, reviewed or investigated by the Commission or the
Independent Oversight Director if it is not filed with the Commission within one hundred
and twenty (120) days of the alleged misconduct by the Santa Ana Police Officer.
(4) All Commission discussions with the Independent Oversight Director concerning
alleged misconduct of any Santa Ana police officer shall be held in closed session. At
least ten (10) days' advance written notice of the date of the meeting in which a specific
officer will be discussed in closed session shall be given to the complainant and the
named police officer and their legal counsel, if known to the Commission.
(c) Receive and discuss reports from the Independent Oversight Director on all
incidents of the following:
(1) officer-involved shootings, (discharge of a firearm at a person by a Santa Ana peace
officer) that results in death;
(2) in-custody deaths;
(3) uses of force by a Santa Ana police officer that result in great bodily injury of a
person.
(d) Direct the Independent Oversight Director to independently investigate a complaint
of police misconduct as set forth in subsection (b) as authorized by this Division 11 or
the City Council provides authorization pursuant to Santa Ana City Charter Section
1100.
(1) The Independent Oversight Director shall investigate timely complaints as soon as
possible. Pursuant to Santa Ana City Charter Section 1100, the City Council hereby
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authorizes the Independent Oversight Director to subpoena witnesses for the
investigation. At the conclusion of the investigation, the Independent Oversight
Director shall submit a report with findings and recommendations, either orally or in
writing, to the Commission.
(2) Upon receipt of the Independent Oversight Director’s report, the Commission may:
(i) Direct the Independent Oversight Director to investigate the complaint further;
(ii) Forward the Commission's findings and recommendations concerning the
complaint to the City Manager based upon the Independent Oversight Director’s report.
(e) Authorize the Independent Oversight Director to audit complaint files and review
policies to ensure best practices are implemented.
(f) Advise the Mayor, City Council, City Manager, and Police Chief on community
relations issues involving the Santa Ana Police Department.
(g) Review any Memorandum of Understanding (MOU) between the City and the Santa
Ana Police Officers Association or the City and the Santa Ana Police Management
Association and provide suggestions and recommendations concerning negotiations to
the City Manager and the City Council.
(h) Conduct public meetings to educate the community on the purpose of the Police
Oversight Commission and provide a forum for discussions about police policies,
practices and procedures.
(i) Prepare and submit an annual report to the City Council concerning the
Commission’s activities, findings and recommendations.
a) The number of investigations initiated during the annual reporting period and
data summarizing the nature of the alleged or actual underlying conduct;
b) The number of investigations concluded during the reporting period, and, of
those investigations, the number that took more than six months to conclude and data
summarizing the nature of the alleged or actual underlying conduct;
c) The number of investigations pending as of the end of the reporting period and
data summarizing the nature of the alleged or actual underlying conduct;
d) The number of complaints not sustained during the reporting period and data
summarizing the nature of the alleged or actual underlying conduct;
e) The number of complaints sustained during the reporting period and data
summarizing the nature of the alleged or actual underlying conduct;
f) The number of complaints filed against each police officer in each police
department during the reporting and data summarizing the nature of the alleged or
actual underlying conduct;
g) The number of complaints referred to other agencies during the reporting
period and the identity of such other agencies and data regarding summarizing the
nature of the alleged or actual underlying conduct.
(j) Perform such other duties as requested by the City Council.
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Sec. 2-622. – Appointment and role of an Independent Oversight Director
(a) The City Council does hereby authorize the appointment of an Independent
Oversight Director (referred to as Oversight Director in this Section) pursuant to City
Charter Section 1100 and in accordance with this Section 1100 shall appoint the
Oversight Director. The Oversight Director may be engaged through a professional
services agreement or may be hired as a City employee at the discretion of the City
Council.
(b) The Oversight Director shall assist the Commission in performing its duties and
exercising its powers.
(c) The Oversight Director shall, in accordance with this division, when directed by the
Commission after receiving a complaint covered by this division, conduct investigations
of complaints from members of the public alleging: the use of unreasonable force,
discrimination, lack of officer veracity, sexual harassment, and/or sexual assault by on-
duty police officers of the Santa Ana Police Department and all incidents involving the
discharge of a firearm at a person by a Santa Ana police officer, and/or when death or
serious bodily injury results from direct police action. In addition to conducting
investigations related to complaints, the Oversight Director shall also have the
independent authority to periodically request and review general citizen complaints and
"use of force" reports or other pertinent documents maintained by, or available to, the
Chief of Police to determine whether death or serious bodily injury has been caused by
direct police action. No investigations shall be commenced on any incidents that
occurred prior to the effective date of the Ordinance adopting this division.
(d) The Oversight Director shall conduct all audits and investigations in a fair,
objective, impartial and ethical manner, and shall comply with the Public Safety Officers
Procedural Bill of Rights (Government Code Sections 3300, et seq.) in interviewing
police officers. The Oversight Director shall prepare a written report of each
investigation that will constitute the public record and may discuss confidential or
privileged information with the Commission in a properly notice closed session. Report
shall comply with the provisions of Penal Code Sections 832.5 and 832.7 and Evidence
Code Sections 1043 and 1046. After review by the Commission the public record of the
investigation shall be posted on the public website for the Commission within thirty (30)
days. All disclosures of investigations conducted by the Oversight Director shall
comply with California Penal Code Sections 832.5 and 832.7 and California Evidence
Code Sections 1043 and 1046, as amended from time to time. The Oversight Director
may discuss findings with the Commission and/or the public in strict compliance with
California Penal Code Sections 832.5 and 832.7 and California Government Code
Sections 3300, et seq.
(e) The City Manager or their designee shall assist with advertising the position of
Oversight Director and shall prepare the necessary documents to engage the Oversight
Director. The City Council shall review all qualifying applications and select no more
than three applicants to interview for the role of Oversight Director. The Commission
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shall be permitted the opportunity to review the top three applicants and recommend a
candidate to the City Council. The Oversight Director shall, pursuant to Charter
Section 1100, report directly to the City Council.
Sec. 2-623. – Budget and Support for Commission and Independent
Oversight Director
The City Manager shall make a recommendation to Council, as part of the annual City
budget to fund the Commission and any additional labor, consulting, equipment, training
or materials necessary for the Commission and the Independent Oversight Director to
carry out the duties and exercise the powers set forth in this division.
Sec. 2-624. - Rules and records.
The Commission shall, in consultation with the Independent Oversight Director
and the City Manager develop rules for the transaction of business of the Commission,
which rules shall, among other things, include the manner of calling and giving notice of
special meetings and hearings and the appointment and powers of ad hoc and standing
subcommittees. Said subcommittees may be formed to work on various topics within
the scope of police activities. The City Council shall adopt the rules for the transaction of
business of the Commission. The Commission shall also keep records of its
resolutions, rules, transactions, motions, orders, findings, recommendations and
determinations. Except for those items made confidential by California Penal Code
Sections 832.5 and 832.7, the records of the Commission shall be open to the public.
2-625. Severability.
Should any provision of this division, or its application to any person or
circumstance, be determined by a court of competent jurisdiction to be unlawful,
unenforceable or otherwise void, that determination shall have no effect on any other
provision of this division or Chapter or the application of this division or Chapter to any
other person or circumstance and, to that end, the provisions hereof are severable.
SECTION 3. Section 2-325 of Article IV of Chapter 2 of the Santa Ana Municipal
Code is hereby amended to add a subsection (i) to read as follows:
Sec-2-235.-Compensation for members of boards, commissions.
(i) Police Oversight Commission. Each Commissioner shall receive $50 per
meeting with no more than four (4) compensated meetings per month.
SECTION 4. The City Clerk shall attest and certify to the passage and adoption of
this Ordinance, and shall cause same to be posted as required by law and this Ordinance
shall take effect thirty (30) days after its final adoption.
SECTION 5. If any section, subsection, sentence clause or phrase or word of this
Ordinance is for any reason held to be invalid or unconstitutional by a decision of any
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court of competent jurisdiction or preempted by state legislation, such decision or
legislation shall not affect the validity of the remaining portions of this Ordinance. The City
Council of the City of Santa Ana hereby declares that it would have passed this Ordinance
and each and every section, subsection, sentence clause or phrase or word not declared
invalid or unconstitutional without regard to any such decision or preemptive legislation.