14th Seminannual Report

Case: 1:15-cv-01046-SO Doc #: 524-1 Filed: 04/15/24 1 of 59.
PageID #: 12212
14th Semiannual Report

Written by:
The Independent Monitoring Team
April 2024
Case: 1:15-cv-01046-SO Doc #: 524-1 Filed: 04/15/24 2 of 59. PageID #: 12213
The Independent Monitoring Team
Karl Racine
Monitor Courtney Caruso
Stephanie Yonekura
Deputy Monitor Christine Cole
Assistant Chief
Shunta Boston Dr. Ronnie Dunn
Dr. Randolph Dupont Lisa Fink
Chief Tammy
Melissa Giangrande Hooper (ret.)
Rick Myers Katie O’Brien
Rory Pulvino Victor Ruiz
Captain Scott
Charles R. See Sargeant (ret.)
Abby Wilhelm
Cleveland Police Monitoring Team | 14th Semiannual Report | April2024
Table of Contents
I. Letter from the Monitor ...............................................................................................................1
II. Understanding this Report ...........................................................................................................3
III. Executive Summary......................................................................................................................6
IV. Complete Findings ..................................................................................................................... 13
1. Community Engagement and Building Trust ....................................................................... 13
Areas of Progress .............................................................................................................. 13
Challenges Ahead ............................................................................................................. 13
2. Community and Problem-Oriented Policing ....................................................................... 14
3. Bias-Free Policing .............................................................................................................. 15
4. Use of Force ...................................................................................................................... 16
5. Crisis Intervention ............................................................................................................. 18
6. Search and Seizure ............................................................................................................ 20
7. Accountability ................................................................................................................... 22
8. Transparency and Oversight .............................................................................................. 23
9. Officer Assistance and Support .......................................................................................... 25
10. Supervision ....................................................................................................................... 27
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Cleveland Police Monitoring Team | 14th Semiannual Report | APRIL 2024

11. Outcome Assessments....................................................................................................... 28
V. Appendix ................................................................................................................................... 29
1. Community Engagement and Building Trust ....................................................................... 29
2. Community and Problem-Oriented Policing ....................................................................... 30
3. Bias-Free Policing .............................................................................................................. 31
4. Use of Force ...................................................................................................................... 32
5. Crisis Intervention ............................................................................................................. 36
6. Search and Seizure ............................................................................................................ 39
7. Accountability ................................................................................................................... 40
8. Transparency and Oversight .............................................................................................. 46
9. Officer Assistance and Support .......................................................................................... 48
10. Supervision ....................................................................................................................... 53
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Cleveland Police Monitoring Team | 14th Semiannual Report | April 2024
I. Letter from the Monitor
This 14th Semiannual Report provides the Monitoring Team's view regarding the progress made during
the reporting period: June 2023—December 2023.
Before I begin, I want to share my observation that most of the men and women in uniform I have had
the privilege to work with have demonstrated a commitment to improve the manner in which residents
of Cleveland are policed. Indeed, union leaders with whom the Monitoring Team regularly meets, have
been reasonable and have indicated a willingness to work together towards achieving progress.
The City's leadership would do well to follow suit.
First, the reporting period was unfortunately marked by little progress. In fact, all ratings from the prior
reporting period remain the same with the exception of one downgrade. By any measure, this static
performance—akin to running in place—is insufficient. This is especially so given the urgency that the
Cleveland community understandably demands.
Second, the reporting period was marked by unwarranted delay and denial of access to documents and
databases that the Monitoring Team and Department of Justice (DOJ) need to fulfill their respective
responsibilities under the Consent Decree. The City Law Department first started rolling back the
Monitoring Team and DOJ’s data access in April 2023. Then, in December 2023, the City cited unfounded
reasons for suddenly ceasing all access to documents and databases that are plainly required by the
Consent Decree. It was not until Judge Solomon Oliver Jr. specifically ruled on the issue on March 7,
2024 that the Monitoring Team and the DOJ were able to continue their duties. These delays cost the
City and its taxpayers time, money, and progress in fulfilling the Consent Decree’s mandate that it police
in a constitutional manner.
I implore the City to fully cooperate with the Monitoring Team and DOJ. The alternative—delay and legal
squabbles—takes away from the work that needs to get done. For example, the City has cited numerous
grounds, including lack of resources, for delaying the production of documents and files to the
Community Police Commission (CPC). The Monitor is closely monitoring this issue to report on it in the
next Semiannual Report. How the City proceeds with its responsibilities relative to the CPC will
ultimately demonstrate whether it intends on continuing down a path of resisting or embracing
oversight.
Going forward, the Monitoring Team is preparing to conduct its first formal assessment of three (3)
distinct aspects of the Consent Decree: (1) crisis intervention, (2) search and seizure, and (3) use of
force. Completing these assessments in 2024 will require substantial resources and the full cooperation
of City leaders.
1
The Consent Decree has been ongoing for nearly a decade. Simply put, this City can and should do much
better. The residents of Cleveland deserve no less.
Understandably, these words will be hard for certain leaders within the City to read and come to grips
with. However, the Monitoring Team—representing over 200 collective years of law enforcement,
government, and community engagement experience—has an obligation to report the facts as it sees
them.
Sincerely,
Karl Racine
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II. Understanding this Report

Since the 3rd Semiannual Report, the Monitoring Team has used its Semiannual Reports to present a
summary of the status of the City’s compliance with each of the 340 paragraphs of the Consent Decree.
Although providing “a paragraph-by-paragraph accounting of the general state of the City’s compliance
runs the risk of being an over-simplification,” these summary representations remain useful indicators
for viewing progress over time.1
Therefore, each section of the 14th Semiannual Report summarizes the Monitoring Team’s general
conclusions about compliance status by describing the state of each paragraph listed as one of the
following:
 Non-Compliance: The City and/or Cleveland Division of Police (CDP) has not yet complied with the
relevant provision of the Consent Decree. This includes instances in which the City or CDP’s work
or efforts have begun but cannot yet be certified by the Monitoring Team as compliant with a
material component of the requirement.
 Partial Compliance: The City and/or CDP has made sufficient initial strides or sufficient partial
progress toward a material number of key components of the provision of the Consent Decree—
but has not achieved operational compliance. This includes instances where policies, processes,
protocols, trainings, systems, or the like exist on paper but do not exist or function in day-to-day
practice. It may capture a wide range of compliance states or performance, from the City or CDP
having taken only very limited steps toward operational compliance to being nearly in operational
compliance.
 Operational Compliance: The City and/or CDP has made notable progress to technically comply
with the requirement and/or policy, process, procedure, protocol, training, system, or other
mechanism of the Consent Decree such that it is in existence or practice operationally—but has
not yet demonstrated, or has not yet been able to demonstrate, meaningful adherence to or
effective implementation, including across time, cases, and/or incidents. This includes instances
where a given reform is functioning but has not yet been shown, or an insufficient span of time or
volume of incidents have transpired, to be effectively implemented in a systemic manner.
 General Compliance: The City and/or CDP has complied fully with the requirement and the
requirement has been demonstrated to be meaningfully adhered to and/or effectively
implemented across time, cases, and/or incidents. This includes instances where it can be shown
that the City or CDP has effectively complied with a requirement fully and systemically.
The same caveats that have previously applied to these summary categories remain applicable and are
thus repeated here verbatim. First, “Non-Compliance” or “Partial Compliance” do not automatically
mean that the City or CDP has not made good-faith efforts or commendable strides toward compliance.
It might, instead, signify that initial work has either not yet begun or reached a sufficiently critical point
where progress can be considered to have been made.
1
3rd Semiannual Report at 9.
3
Second, “Partial Compliance” requires more than taking some limited, initial steps toward compliance
with a requirement. It instead requires that the City or CDP have made “sufficient, material progress
toward compliance” that “has graduated from the stages of initial work to more well-developed and
advanced refinement of various reforms.”2
Third, these summary terms do not appear in the Consent Decree. The Monitoring Team employs them
in order to synthesize and summarize the report’s conclusions. Relatedly, compliance with individual
paragraphs of the Consent Decree is necessary for the larger, overall “Substantial and Effective
Compliance” with the whole of the Consent Decree, but it is not the same thing. Ultimately, “Substantial
and Effective Compliance” with the Consent Decree will be reached when “the City either has complied
with all material requirements of this Agreement or has achieved sustained and continuing
improvement in constitutional policing, as demonstrated pursuant to this Agreement’s outcome
measures,”3 “by a preponderance of the evidence.”4
Fourth, the charts within the appendix that summarize progress in each area also condense the
requirements of each paragraph rather than reprinting the entire Consent Decree in the context of this
report. Any imprecision or confusion created by these condensed or summarized requirements is
unintended and, in any event, can be cured with reference to the original language of the Consent
Decree itself.5 Furthermore, the appendix charts primarily cover paragraphs 14 through 340 of the
Consent Decree, but other paragraphs also contain requirements that the City must meet.6
Overall “compliance status” conclusions displayed in tables within the executive summary and the
appendix herein do not replace the more rigorous and comprehensive quantitative and qualitative
assessments of how CDP performs over time:
[T]he Monitoring Team bases its assessments on its current understandings, knowledge, and
information gained through ongoing work and discussion with CDP, the Parties, and other
stakeholders. The assessments are informal to the extent that not all of them are necessarily
informed by the type of exhaustive compliance and outcome measurements that are a critical
component of the Consent Decree—and the summary determinations do not take the place of
these more structured, systemic analyses. The intent is to provide a bottom-line sense of where
CDP is on the road to compliance. Ongoing, rigorous quantitative and qualitative assessments
will provide a more comprehensive picture as work under the Consent Decree proceeds.7
The descriptions of progress contained below should be considered as a synthesis or bottom-line
reporting of substantive discussions from each major Consent Decree area contained within this report.
An additional method for capturing progress is the creation, utilization, and accountability to the
Monitoring Plan, described in ¶ 369, which outlines the work to be done by the Parties within the year.
As is evidenced by the extensive and broad-reaching Consent Decree itself, the City of Cleveland’s
implementation of the Consent Decree and the many action items and projects it encompasses, is a
substantial task. Many areas of the Consent Decree require multiple reporting periods for the City to
achieve—and for the Monitoring Team to confirm and consequently report on—these major milestones.
Therefore, at times this Semiannual Report, as with previous Semiannual Reports, reprints content from
2
3rd Semiannual Report at 10.
3
Dkt. 413-1 ¶ 456 (emphasis added).
4
Id. at ¶ 397.
5
See Id.
6
See 3rd Semiannual Report at 10.
7
Id. at 11.
4
prior Semiannual Reports in instances where there has not been enough material progress to warrant
an update. In such cases, the Monitoring Team is not citing to prior Semiannual Reports in the interest
of readability.
5
III. Executive Summary

Community Engagement and Building Trust
The City appears committed to establishing greater trust with the

community. However, much work remains to engage Cleveland’s
diverse communities, especially those who do not attend
community meetings or otherwise regularly engage with law
enforcement officials. District Policing Committees (DPCs) continue
to meet on a regular basis, but—like broader CDP efforts—lack
consistent attention to ensuring that participants reflect the
diversity of Cleveland at-large. The Monitoring Team notes that the
Community Police Commission (CPC) successfully allocated funding
to support violence reduction efforts, all while maintaining regular
contact with the community. As stated in the 13th Semiannual
Report, operating as a cohesive, collaborative body must continue
to be the priority for the CPC in the months ahead.
Non-Compliance Partial Compliance Operational Compliance General Compliance

¶ 17a, ¶ 17b, ¶ 17c, ¶ 14, ¶ 16,
¶ 18a, ¶ 18b, ¶ 19, ¶ 17d, ¶ 18c, ¶ 23, ¶ 15, ¶ 22
¶ 20, ¶ 21, ¶ 24 ¶ 25, ¶ 26
*** No changes recommended since the 13th Semiannual Report.
Community and Problem-Oriented Policing
There are no significant changes to report in the area of Community

and Problem-Oriented Policing (CPOP). Notably, the City’s updated
CPOP Report for the reporting period covered here does not
warrant an upgrade to the City’s compliance rating at this time. The
Monitoring Team would re-emphasize that the City must provide
evidence of having promoted and relied on community
partnerships in order to see upgrades in its CPOP compliance
ratings.

¶ 27, ¶ 28, ¶ 29,
¶ 30, ¶ 34
¶ 31, ¶ 32, ¶ 33
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Bias-Free Policing
While CDP made incremental progress relative to bias-free policing,

a considerable amount of work remains to be done in this area. CDP
delivered an online and interactive, in-person in-service training
during this reporting period, both of which were infused with bias-
free policing principles. There is, however, evidence that CDP needs
to make additional efforts toward enhancing officers’
internalization or “buy in” of this content. It was also anticipated
that the Supervisory Leadership Training and the revised District
Neighborhood Awareness Training, both of which entail bias-free
policing, would be delivered during this reporting period. They were
not. The Monitoring Team continues to stress the vital need for
compelling evidence of the incorporation of bias-free policing
philosophies and values throughout all aspects of CDP’s
organization and operations.

¶ 35, ¶ 36, ¶ 37,
¶ 43 ¶ 38, ¶ 39, ¶ 40
¶ 41 ¶ 42, ¶ 44
Use of Force
In order for the City to receive an upgrade in its compliance score,

the City must produce specific evidence of progress. With an
interest in supporting and focusing the City’s efforts to achieve
compliance, the Monitoring Team recently scheduled working
groups on specific topics within use of force. The hope is that these
regular meetings will provide opportunities for the City to engage
with DOJ and the Monitoring Team on these issues and receive
support that will enable the City to achieve higher levels of
compliance. The Monitoring Team is working with the Parties to
launch compliance assessments in the next year on use of force
chain of command reviews and the Force Review Board (FRB). The
Monitoring Team also anticipates re-assessing the Force
Investigation Team at some point in the future when a significant
sample of cases can be assessed.

¶ 45, ¶ 48, ¶ 49, ¶ 50,
¶ 122 ¶ 46, ¶ 47, ¶ 111, ¶ 87
¶ 51, ¶ 52, ¶53, ¶ 54,
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¶ 116, ¶ 118, ¶ 120, ¶ 55, ¶ 56, ¶ 57, ¶ 58,
¶ 121, ¶ 125, ¶ 126, ¶ 59, ¶ 60, ¶ 61, ¶ 62,
¶ 128, ¶ 129 ¶ 63, ¶ 64, ¶ 65, ¶ 66,
¶ 67, ¶ 68, ¶ 69, ¶ 70,
¶ 71, ¶ 72, ¶ 73, ¶ 74,
¶ 75, ¶ 76, ¶ 77, ¶ 78,
¶ 79, ¶ 80, ¶ 81, ¶ 82,
¶ 83, ¶ 84, ¶ 85, ¶ 86,
¶ 88, ¶ 89, ¶ 90, ¶ 91,
¶ 92, ¶ 93, ¶ 94, ¶ 95,
¶ 96, ¶ 97, ¶ 98, ¶ 99,
¶ 100, ¶ 101, ¶ 102,
¶ 103, ¶ 104, ¶ 105,
¶ 106, ¶ 107, ¶ 108,
¶ 109, ¶ 110, ¶ 112,
¶ 113, ¶ 114, ¶ 115,
¶ 117, ¶ 123, ¶ 124,
¶ 127, ¶ 130
Crisis Intervention
With respect to crisis intervention, this year has been one of both
progress and change for the City, CDP, and the community-based
Mental Health Response Advisory Committee (MHRAC). The Health
Department worked with CDP to help MHRAC transition into the
role of a more permanent community partner. The City in turn has
demonstrated strong leadership in assisting CDP in making progress
towards compliance. This work has successfully moved CDP to a
position where a compliance assessment is scheduled for the first
half of 2024. Many of the requirements for compliance in this area
are already in place, but the challenge remains in continuing to
grow the consistency with which specialized CIT Officers respond to
crisis events.

¶ 132, ¶ 133, ¶ 134,
¶ 131, ¶ 140,
¶ 136, ¶137, ¶ 138,
¶ 135, ¶ 141, ¶ 151, ¶ 142, ¶ 145, ¶ 147,
¶ 139, ¶ 143, ¶ 144,
¶ 152, ¶ 156, ¶ 148, ¶ 149, ¶ 150,
¶ 146, ¶ 153,
¶ 157, ¶ 158, ¶ 159
¶ 154, ¶ 155
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Search and Seizure
Search and seizure progress has disappointingly stalled. Following

a productive data system walkthrough with the Monitor's search
and seizure assessment team, CDP’s data collection team, the City’s
Police Accountability Team (PAT), and experienced sworn
members, the City formally requested that the Monitoring Team
pause its planned search and seizure assessment. In support of its
request for a delay in the planned assessment, the City informed
the Monitoring Team and DOJ that it discovered several material
deficiencies in CDP’s data management system that impaired the
ability of patrol officers to input necessary information about stops,
searches, and seizures and the ability of supervisors to review the
actions of the patrol officers. After careful consideration and
extensive discussions with the Parties, the Monitor decided to
proceed with the assessment on or after June 1, 2024. In the
interim, the City is conducting an internal self-audit on search and
seizure and has pledged to keep the Monitoring Team apprised of
progress.

¶ 160, ¶ 161, ¶ 162,
¶ 163, ¶ 164, ¶ 165,
¶ 166, ¶ 167, ¶ 168, ¶ 173, ¶ 174, ¶ 175
¶ 169, ¶ 170, ¶ 171,
¶ 172
Accountability
The City is required to maintain a disciplinary system that is “fair,

consistent, and provides due process” per ¶ 176. As stated in the
13th Semiannual Report, CDP’s Internal Affairs (IA) continues to
diligently improve upon practices as they work towards compliance
goals. The IA’s relatively new leadership, including the leadership of
Superintendent Viland, delivers a hands-on approach to taking
needed steps to achieve Consent Decree compliance. The
impending finalization and implementation of the IA Manual, as
well as the in-house IA investigator training, will move the City
closer to compliance. The Monitoring Team is hopeful that the
continued improvement efforts being put in place by
Superintendent Viland will warrant upgrades in future reports.
The Office of Professional Standards (OPS) is charged with

investigating all public complaints, except criminal allegations. The
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new OPS Administrator has been making strides to formalize

processes and reduce backlogs. However, OPS has not filed an
annual report since calendar year 2021. OPS must submit an annual
report for the Monitoring Team to have insight into OPS’s self-
evaluation. Further the Administrator was on voluntary leave
during a significant portion of the reporting period, but received
little to no communication regarding OPS processes and progress
during his absence.
The Police Review Board (PRB) reviews OPS investigations and

determines if alleged violations are sustained, and if so, what
appropriate discipline should result. Notably, the PRB has
progressed toward clearing their backlog of cases and should
continue to work to conduct more detailed and documented
deliberations to support its findings. Paragraph 242 of the Consent
Decree requires, among other things, that the PRB submit
recommended discipline which then must “proceed through the
City’s disciplinary process.” The final authority over discipline was
shifted to the CPC pursuant to Charter Section 115-5. The
Monitoring Team has not been informed of any steps the City has
taken to formalize or operationalize changes to its prior process in
light of the shift of authority to the CPC.

¶ 176, ¶ 177, ¶ 179,
¶ 178, ¶ 189, ¶ 190,
¶ 180, ¶ 181, ¶ 182,
¶ 191, ¶ 193, ¶ 195,
¶ 183, ¶ 184, ¶ 185,
¶ 196, ¶ 198, ¶ 203,
¶ 186, ¶ 187, ¶ 188,
¶ 205, ¶ 206, ¶ 208, ¶ 197, ¶ 199, ¶ 202,
¶ 192, ¶ 200,
¶ 209, ¶ 210, ¶ 211, ¶ 207, ¶ 221, ¶ 225,
¶ 194 ¶ 201, ¶ 204, ¶ 214,
¶ 212, ¶ 213, ¶ 216, ¶ 230, ¶ 231, ¶ 235,
¶ 215, ¶ 218, ¶ 219,
¶ 217, ¶ 220, ¶ 224, ¶ 236, ¶ 240, ¶ 247
¶ 222, ¶ 223, ¶ 226,
¶ 228, ¶ 229, ¶ 232,
¶ 227, ¶ 233, ¶ 234,
¶ 238, ¶ 242, ¶ 243,
¶ 237, ¶ 239, ¶ 241,
¶ 246, ¶ 248
¶ 245, ¶ 249
*** Paragraph 194 has been downgraded since the 13th Semiannual Report.
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Transparency and Oversight
The City has three (3) main challenges in this area of work. First, the
City must fill the critically-important position of Inspector General,
which has been vacant since early 2021. Second, the City must
improve the quality of its analysis of the treasure trove of data
available and report on those analyses internally and externally.
Analysis of the extensive data collected by the requirements of ¶
367 would be an important starting point. Finally, the City must
improve the ease of access to information required by ¶ 268. The
Monitoring Team is pleased to learn that command staff is using
data to inform operational and managerial decisions. Additionally,
the City reports that it intends to make data available publicly,
which the Monitoring Team applauds and is eager to see this put
into practice.
¶ 250, ¶ 251, ¶ 252,

¶ 261, ¶ 264, ¶ 266, ¶ 257, ¶ 258, ¶ 260,
¶ 253, ¶ 254, ¶ 255, ¶ 259
¶ 267, ¶ 268 ¶ 262, ¶263
¶ 256, ¶ 265
Officer Assistance and Support
CDP has made significant progress on its overall training program.

Commander Mark Maguth is responsible for leading the training
unit, and he continues to shine in this role. Under his leadership,
the training unit regularly seeks to identify and deploy best
practices, drafts detailed and thoughtful training curricula, and is
open to receiving constructive criticism from DOJ and the
Monitoring Team. CDP’s ongoing work with Polis Solutions, a highly
regarded law enforcement consulting group, is contributing to the
development of curricula inspired by best practices across the
country. We note the observable commitment of the training team
to perform at the highest standard. CDP will need to keep up this
level of rigor, ensuring each Consent Decree paragraph is being
addressed as intended, to achieve compliance on training
requirements.
Regarding equipment and resources, the connection between the City and Public Safety Information
Technology (IT) sections seems strong and effective based on the City IT’s documented efforts to continue
to replace equipment and update technology to ensure an effective police agency.
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Furthermore, the City has adopted new strategies to tackle its long-term recruitment and retention crisis
but can do more to incentivize longer retention among its newest employees. Lastly, there has been too
little progress on employee assistance and performance systems, both of which are critical to providing
CDP employees with the support that they need to fulfill their responsibilities.

¶ 269, ¶ 270, ¶ 271,
¶ 282, ¶ 283, ¶ 284, ¶ 272, ¶ 275, ¶ 276, ¶ 273, ¶ 274, ¶ 289,
¶ 285, ¶ 286, ¶ 287, ¶ 277, ¶ 279, ¶ 280, ¶ 292, ¶ 293, ¶ 295,
¶ 294, ¶ 312, ¶ 313, ¶ 281, ¶ 288, ¶ 290, ¶ 296, ¶ 297, ¶ 298, ¶ 301, ¶ 308
¶ 314, ¶ 315, ¶ 316, ¶ 291, ¶ 299, ¶ 304, ¶ 300, ¶ 302, ¶ 303,
¶ 317, ¶ 318 ¶ 305, ¶ 306, ¶ 309, ¶ 307, ¶ 310, ¶ 319
¶ 311, ¶ 320, ¶ 321
Supervision
First line supervisors remain the primary drivers of meaningful

culture change in police organizations. CDP has developed a new
training to impart improved supervisory skills and policies to
provide expectational clarity for first line supervisors. The
Monitoring Team has observed improvements in supervision
generally as it has reviewed specific incidents and will need to
conduct a more comprehensive review of supervisors’ work to
ensure they are providing and being held accountable for effective
supervision. Regarding the Officer Intervention Program (OIP), CDP
demonstrated some progress toward the end of 2023, but more is
needed to develop and integrate a robust process that not only
complies with the Consent Decree but also serves to support
officers and reduce negative behavioral outcomes. Finally, CDP
submitted revisions of their Wearable Camera System (WCS)
policies that addressed issues regarding supervisory audits of WCS.

¶ 326, ¶ 327, ¶ 328,
¶ 329, ¶ 330, ¶ 331, ¶ 322, ¶ 323, ¶ 324,
¶ 337, ¶ 338, ¶ 340
¶ 332, ¶ 333, ¶ 334, ¶ 325, ¶ 339
¶ 335, ¶ 336
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IV. Complete Findings

1. Community Engagement and Building Trust
Areas of Progress
Community Engagement: CDP continues to demonstrate a commitment to earning trust, cooperation, and
respect from the community. Patrol officers and command staff attend monthly Ward meetings to hear
firsthand about community complaints and offer community members opportunities to participate in
Division-led programs (i.e., Citizens’ Police Academy, District Policing Committee meetings, and other
informal social gatherings with patrol officers around the community). These efforts are consistent with
efforts that the Monitoring Team has reported in previous Semiannual Reports.
CPC: During the reporting period, the CPC successfully allocated funding in the amount of one million
dollars across twenty-six (26) community groups to provide violence reduction programming in Cleveland.
The CPC has continued to sharpen the focus of its work groups to address areas of training, policy
development, equipment acquisition, and deployment. In the 13th Semiannual Report, the Monitoring
Team indicated that Commissioners must become more acquainted with the many laws which govern the
CPC’s work. While there is still much work to be done, the Monitoring Team has observed a concerted
effort on the part of CPC to seek to clarify its internal rules of operation and procedures, all while
maintaining regular contact with the community. For example, the Monitoring Team was pleased to learn
that the CPC met with the Chief of Police in December 2023 and the new Chief in March 2024. Should this
occur on a more routine basis, this will warrant a careful review and consideration of an upgrade for ¶ 16.
Additionally, the CPC met with the Community Police Review Board (CPRB) in February 2024 to identify
greater opportunities for collaboration and coordination. Ensuring that the Monitoring Team is kept
informed as to how the CPC and CPRB are working together to make improvements in CDP’s accountability
and transparency structures will be incredibly important to demonstrate progress towards complying with
¶ 17(d).
DPC: CDP has five (5) DPCs, operating within each District. DPCs are one of the essential ways CDP seeks
to communicate with and engage residents across Cleveland. Through a variety of avenues, i.e.
community service organizations, city safety groups (Fire Department, EMS), and other governmental
bodies, CDP attempts to inform residents about its work, its crime reduction success, and opportunities
for community involvement. CDP continues to build relationships with the Community Relationships
Board (CRB) and the CPC. During the reporting period, the CPC hosted the DPCs at one of its public full
commission meetings where DPCs from each district reported to the community on its work, services,
successes, and challenges within its district. We note that this presentation would have been more
effective had it been co-led with community.
Challenges Ahead
Community Engagement: There is no mechanism by which the City regularly informs the Monitoring Team
as to its community engagement efforts. The Monitoring Team is eager to learn about the strategies the
City is employing to engage members of Cleveland’s diverse communities. From the Monitoring Team’s
observations and independent engagement with the community, it appears that the City is successfully
reaching residents who already have a positive relationship with the law-enforcement community. The
City should also focus its energy on engaging community members who, heretofore, have had less than
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positive, or negative relationships with the police, and those residents who historically have not engaged
with law enforcement. The Monitoring Team suggests prioritizing proactive engagement with young
adults, persons under eighteen (18) years old, as well as persons who have previously been involved in
the criminal justice system. Partnering with social service agencies, recreational centers, job fairs and non-
traditional community organizations who serve lower income populations would result in deeper
engagement with the community.
CPC: The Commission continues to face internal divisions among its members. These divisions lead to
conflicts rendering the body, at times, unable to reach consensus on vital issues. Such divisions have
created barriers to building trust among some members and have continued to distract the CPC from its
important mission. The Commission continues to work on fulfilling its oversight for GPOs, policy review,
and other responsibilities. As stated in the 13th Semiannual Report, working together as a cohesive,
collaborative body must be the priority for the CPC in the next reporting period and will go a long way in
building trust with the community and the institutions it will interface with. We also note that the CPC is
now led by two (2) new co-Chairs and the commission appears to be less fractured than before. There
have been substantial discussions that occurred between the Parties in early 2024 related to CPC’s
document requests that have led to the creation of a CPC working group. However, because those
discussions occurred outside of the reporting period, those will be reported on in the next Semiannual
Report.
DPC: DPC meetings provide important opportunities for CDP to connect and build positive relationships
with community members who do not regularly engage with law-enforcement officials. While DPC
meetings are occurring regularly within each District, there is much work to be done to improve the quality
and inclusivity of those meetings consistent with ¶ 24. The Consent Decree requires that “the [CPC], CDP,
and [Community Relations Board] will develop a mechanism to recruit and expand the membership of the
[DPCs], each of which should include a representative cross-section of community members.” Diversifying
community participation will give CDP a broader understanding of the needs of Cleveland community
members.
2. Community and Problem-Oriented Policing

Areas of Progress
In the 13th Semiannual Report, the Monitoring Team favorably noted that the City had sought technical
assistance from DOJ’s Office of Community Oriented Policing Services (COPS) to improve its CPOP efforts.
The Monitoring Team was pleased to learn that the City has continued to seek CPOP technical assistance,
both through partnering with the Collaborative Reform Initiative Technical Assistance Center (CRI-TAC)
and attending the 31st Problem-Oriented Policing Conference. The Monitoring Team is cautiously
optimistic that improvement in CPOP is near. These activities demonstrate that the City is listening to the
Monitoring Team’s constructive criticism and taking action. Taking initiative to learn about CPOP
principles is important and commendable. The Monitoring Team looks forward to being kept apprised of
how the City seeks to incorporate the lessons learned from these experiences.
Challenges Ahead
In the 13th Semiannual report, the Monitoring Team reported a downgrade in compliance for ¶ 30 due to
poor delivery of CPOP training that omitted significant portions of the curriculum approved by the
Monitoring Team. This compliance rating will remain until the Monitoring Team observes and the City
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delivers high-quality training consistent with the approved curriculum. Additionally, in order to move
towards operational compliance in ¶ 31 and ¶ 32, the City must provide evidence that it is maintaining
collaborative partnerships. The Monitoring Team stated in the 12th Semiannual Report and 13th
Semiannual Report that the City has not provided any description of how it has partnered or developed
relationships with community groups or leaders. In November, the City provided the Monitoring Team
with a list of meetings conducted by the CPOP Review Committee, but these did not demonstrate or
outline any CPOP-related strategies. For this reason, the Monitoring Team would re-emphasize in this 14th
Semiannual Report that the City must provide evidence of having promoted and relied on community
partnerships.
The City has also not progressed as it relates to ¶ 33 and ¶ 34. This lack of progress can be attributable to
the City’s 2022 CPOP Report falling short of Consent Decree requirements. To reach compliance, the City
needs to be responsive to comments and feedback provided by the DOJ and the Monitoring Team. The
Monitoring Team dedicated significant subject matter expertise, time, and—in turn—City resources, to
provide meaningful feedback that would help the City move forward. Unfortunately, that feedback was
only superficially addressed or ignored all together. The City’s updated CPOP Report drafts continue to be
deficient.
3. Bias-Free Policing
Areas of Progress
During this reporting period, the Monitoring Team received, reviewed, and observed CDP’s Session III in-
service training, which utilized integrated reality-based scenarios that included use of force, search and
seizure, and bias-free policing content. Two (2) members of the Monitoring Team observed two (2) of the
three (3) Session III in-service modules in December. Prior to attending the in-person training session,
officers were required to take an online training that included content on bias-free policing concepts.
During the in-person training, bias-free policing was properly contextualized within the framework of
procedural justice, with the trainer explicitly addressing principles like dignity and respect, voice,
transparency, and trustworthiness.
Challenges Ahead
Despite the inclusion of procedural justice principles in the training, the Monitoring Team observers noted
that participants struggled to recall these principles during scenario debriefings. It is recommended that
instructors consider employing a mnemonic device, like DRVTT (Dignity and Respect, Voice, Transparency,
and Trustworthiness), to aid officers in memorizing and better understanding these principles.
As highlighted in the 13th Semiannual Report, CDP collaborated with a contractor to develop in-service
Supervisory Leadership Training incorporating bias-free policing. This training was postponed and has not
yet been rescheduled to the Monitor’s knowledge. In early 2022, CDP conducted District Neighborhood
Awareness Trainings to address bias-free policing requirements. While the curriculum was sound,
Monitoring Team observers noted that its delivery lacked content covering recent critical incidents
involving excessive and deadly force by CDP officers, despite that content being included in the
curriculum. Substantive feedback from the Monitoring Team and the DOJ prompted the development of
the District Neighborhood Awareness Refresher training, which was to be distributed to all officers
through the CDP’s Learning Management System (LMS) to supplement the initial training and ensure all
officers received the comprehensive curriculum. The revised training has yet to be administered, as the
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Training Section awaits renewal of the software contract needed to make the necessary changes in the
LMS.
The Monitoring Team re-emphasizes the imperative for clear evidence of the integration of bias-free
policing philosophies and values across all facets of CDP’s community interactions and policing practices.
This integration should be reflected in the comprehensive analysis of data covering all CDP activities,
including the use of force, arrests, motor vehicle and investigatory stops, and misconduct complaints
alleging discrimination on the basis of race, ethnicity, gender, disability, sexual orientation, or gender
identity. This information should be published annually in a publicly accessible report, as specified in ¶
265 of the Consent Decree.
Furthermore, the Consent Decree requires that bias-free policing and equal protection permeate all
aspects of CDP’s organizational operations, including recruitment and hiring, unit assignments,
promotions, performance evaluations, resource deployments, accountability systems, among others. We
encourage CDP to provide the Monitoring Team with specific evidence that the culture change envisioned
by bias-free policing and equal treatment under law is taking root. At various points in the past, the City
has been unwilling to engage with the Monitoring Team regarding promotions in order for the Monitoring
Team to assess, among other things, whether bias-free and equal protection principles are embedded
through CDP personnel processes. For example, starting on March 23, 2022, the Monitoring Team asked
for the City’s then-current promotions-related materials (forms, evaluations, tests, etc.) which the City
uses in its promotions process. The Monitoring Team followed up on at least eight (8) occasions
thereafter, via email and during meetings, requesting this information, with the most recent request sent
on April 11, 2023. To date, the Monitoring Team has not received these materials, and therefore is not
able to provide technical assistance nor assess compliance on these requirements. Furthermore, while
some headway was made on the subject of evaluations on this topic, that effort has been stalled for some
time. The Monitoring Team stands ready to assist the City in reaching this important objective.
4. Use of Force
Areas of Progress
In the last quarter of 2023, reports written by the Monitoring Team on the chain of command review of
CDP’s use of force cases were filed for each of the four (4) quarters of calendar year 2022. The Monitoring
Team is in discussion with the Parties on the next phase of assessment of the chain of command reviews
for uses of force. The most critical aspects of the use of force – necessity, objective reasonableness,
proportionality, and use of de-escalation – are generally in line with expectations and when not, are
generally detected by the chain of command reviews. In recent months, there has been effort to
demonstrate that supervisors are connecting the collection of data with operational personnel. The
December 2023 CDP Stat Meeting brought district commanders in to describe how they use the data in
their operational capacity. Recent conversations that included operational personnel in plans for the
upcoming compliance assessments have been advantageous. Continued efforts on the part of the City to
link operational and data personnel will strengthen the importance and role of data in use of force
specifically and constitutional policing generally.
Even before the Monitoring Team’s Force Investigation Team (FIT) assessment was delivered and filed in
October 2023, the Internal Affairs (IA) Superintendent instituted changes to comply with policy and the
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Consent Decree addressing concerns surrounding the timeliness of notifications, administrative hearings,
and other issues identified by the FIT assessment.8
FIT leadership also implemented the necessary procedures, per the FIT Manual, requiring administratively
compelled interviews be scheduled and completed within seventy-two (72) hours, as required by the FIT
Manual.
Per ¶ 121, when FIT is deployed, a preliminary report must be presented to the Chief or the Chief’s
designee no later than twenty-four (24) hours after learning of the use of force. The Monitoring Team’s
last assessment noted that this notification was not consistently being made within twenty-four (24)
hours. FIT leadership reports that it now consistently makes such notifications, per the FIT Manual.
Paragraph 122 requires the completion of FIT Investigations within sixty (60) days unless there was an
authorized extension. While the Monitoring Team’s FIT assessment found cases completed beyond sixty
(60) days, it was not able to determine whether an extension was requested and approved. FIT leadership
reports that these procedures have been updated and now documentation of extensions are maintained
in the IAPro file.
CDP also reports that in August 2023, FIT specific training was provided to the members of FIT for their
annual training. The attention to detail and process by the IA Superintendent to improve FIT’s operations
is laudable and critical to efforts to achieve compliance in this area. Another FIT assessment will be
required to confirm the implementation of these improvements and whether they have been successful.
Additionally, the CDP has developed routines for the FRB, with planned meetings quarterly and adding
more as needed. In 2023, the FRB met eight (8) times to review all Level 3 cases and samples of Level 2
cases. With the creation of a working group, the Monitoring Team hopes that frequent and consistent
feedback and communication with FRB leadership can advance its progress even further. The Monitoring
Team is pleased to see a degree of openness to these exchanges to further strengthen the practices
around the FRB, its training, and the analysis of available data.
Challenges Ahead
The challenges set forth in the 13th Semiannual Report in the area of use of force remain the same. The
practices and policies are in place, and there is consensus that the policies are generally followed. Yet the
Monitoring Team further expects the City to show that it has created processes that allow it to identify
issues arising from IA/CPC/FRB review that have training or policy or supervisory implications and to
document and report on how the Division responds to those issues and then continuously assesses its
responses. The aforementioned working groups, through direct and respectful conversation and the
presentation of intermediate deliverables by the City, will help the City improve and move toward
assessments to occur in 2024.
The chain of command reviews of use of force continue to take longer than expected and longer than is
useful for effective accountability and management. Consent Decree ¶ 102 contemplates a review within
seventy-two (72) hours for each rank level after five (5) days for the immediate supervisory review (¶ 94,
¶ 100). The entire process now takes longer than that roughly twenty (20) day period. The Monitoring
Team appreciates that using data, CDP is looking more closely at the time to completion. Additional
8
Dkt. #490-1, Filed October 24, 2023.
17
focused attention on those metrics is important for the officers, management, and members of the
community who may be the subject of inappropriate uses of force.
During this rating period, the FIT leadership reports that it has made corrections since the Monitoring
Team’s last assessment, through training, procedures, and documentation. Another FIT assessment will
be required to confirm the implementation of these changes and whether they have been successful. The
Monitoring Team is aware that few FIT cases have occurred since its last assessment (which is very positive
for the City). Yet the Monitoring Team encourages the FIT to ensure these updated procedures are
ingrained for each FIT case so that once the Monitoring Team does conduct a future FIT assessment, it
will see that these procedures are sustained in FIT’s practices.
In accordance with ¶ 125, the voting members of the FRB are required to have regular updates on legal
issues, policy, and curriculum on use of force. Because of the nature of the FRB as an internal
accountability mechanism designed for critical self-review and analysis, the Monitoring Team expects to
see the training include details of the ethos and philosophy of the FRB so that all voting members have a
detailed understanding of their role and expectations as well as the FRB’s value to the organization. The
FRB is distinct from a use of force review – it is an opportunity for reflection and discussion beyond the
actual use of force; an examination of decision making, an interrogation of tactics and response; and an
assessment of the City’s adherence to policies. CDP has assembled a wide-ranging group to improve on
its draft FRB training curriculum and has made this a priority for 2024.
After three (3) years of operation, the FRB must spend time assessing its own work and effectiveness and
ensuring that referrals it made are acted on in both timely and impactful ways. While recent use of force
reports provide data on the number of cases and the types of referrals made, a more comprehensive
review by the FRB to understand its efficacy and influence is warranted. The analysis described in ¶ 129,
combined with work done by the Data Collection Analyst Coordinator to comply with ¶ 261 and ¶ 266, is
necessary to achieve a higher level of compliance. As stated in the 13th Semiannual report, “the
Monitoring Team further expects the FRB to review the results of its work and ensure the referrals to the
other units of the CDP were acted upon. It would be instructive for the FRB to review its work on an annual
basis and compare findings to prior years to assess FRB impact.”9
5. Crisis Intervention
Areas of Progress
The Crisis Intervention Program aims to promote community solutions that assist individuals in crisis
through effective problem solving and sustainable change.10 MHRAC is a community vehicle for partnering
with the CDP to implement this goal. This year, MHRAC demonstrated strength and autonomy through a
period of change, moving it toward a clear path for sustainability. Under the leadership of the City of
Cleveland’s Health Department, MHRAC ratified bylaws that will govern the organization. The Health
Department also brought in new members and created two new subcommittees. The Youth
Subcommittee has the potential to build on CDP’s innovative Youth Policy to make a difference in the lives
9
Semiannual report at 22.
10
See ¶ 131 of the Consent Decree.
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of Cleveland’s residents.11 The second subcommittee, Data and Growth, makes use of data-informed
outcomes to analyze crisis events and improve outcomes.
During the reporting period, MHRAC and CDP leveraged the strengths of the MHRAC Training
Subcommittee to maintain critical in-service training and curriculum work for all officers. They also revised
curricula for dispatcher training as well as the 40-hour training for specialized Crisis Intervention Team
(CIT) officers. Additionally, MHRAC’s Training Subcommittee identified a strategy for coordinating the
development of new curriculum across a range of stakeholders, including the CDP CIT Program, the CDP
Training Section, the CPC Training Committee, the DOJ, and the Monitoring Team. This strategy is paying
dividends and has the potential to serve as a model of cooperation across other subject areas of the
Consent Decree. These changes have also brought in new membership, which in turn energizes the
MHRAC.
The City’s Police Accountability Team (PAT) and CDP have also demonstrated skill and commitment to
compliance in this area by organizing and leading the Crisis Intervention Program working group, which
meets monthly. This group is led by CDP’s Crisis Intervention Coordinator and includes members of the
DOJ, the Monitoring Team, the Health Department, the City Law Department, the Alcohol, Drug and
Mental Health Service Board of Cuyahoga County (ADAMHS Board), and CDP. The working group focuses
on establishing compliance with the terms of the Consent Decree, and ensuring cohesion where areas of
compliance intersect with and involve multiple agencies and stakeholders. The City’s leadership has
formalized this group into a self-sufficient entity. Most recently, the group worked together to achieve
consensus with respect to the Monitoring Team’s methodology for assessing outcomes in this area.
Accordingly, the Monitoring Team’s assessment will begin during the next reporting period.
Finally, during the reporting period, CDP revised its Specialized Crisis Intervention Plan. The revised plan
includes call volume information and a plan for recruitment of specialized CIT officers. It also proactively
anticipates barriers and identifies potential solutions. Overall, the City, CDP, and the Health Department
have demonstrated strong leadership in this area that is necessary for continued progress with respect to
Consent Decree compliance.
Challenges Ahead
Despite CDP’s progress, the challenges in this area remain twofold. First, the City and CDP must continue
to demonstrate to the public the City’s progress and accomplishments in this area. It is difficult to create
newfound confidence in the police response to individuals involved in a behavioral crisis. The Monitoring
Team encourages the City to build out its CPOP practices in order to support the efforts being made with
respect to crisis intervention, and continue to show the community firsthand the progress being made.
Results from the upcoming Crisis Intervention Assessment—which will demonstrate the progress made
over seven (7) years of work designed to improve behavioral crisis events—will also aid in public
perception. Of course, the Monitoring Team will report on areas on improvement as well, but recognizes
that positive informal feedback from involved community members has been encouraging and
assessment results will aid in demonstrating progress made to date.
Second, CDP must ensure consistent implementation with policies governing on-scene leadership during
crisis events. It is important that efforts to expand the recruitment of CIT officers continue to be successful
11
See Case Western Reserve University Schubert Center for Child Studies “Youth and Policing: A Look at
Cleveland’s New Child Policy.”
19
and that supervisors be held accountable for following the crisis intervention policy. These efforts are key
to ensuring CIT officers are being called to crisis events whenever possible and consistent with CDP policy.
Finally, the Monitoring Team notes that it is critical for officers to have the ability to access community
resources. Officers should continue to make use of de-escalation techniques and to show empathy,
concern, and respect for those in crisis, but available resources, especially late at night, are necessary for
encouraging officers to take additional time to find meaningful options for individuals in need of care. The
Health Department is currently exploring the Care Response model (a community response to crisis
intervention that prioritizes the health of the person experiencing a crisis). This is encouraging and could
make greater use of the 988 behavioral health crisis services phone number. A broader range of
community services is desirable and will provide officers with the ability to access services beyond arrest
or mental health involuntary commitment to a hospital emergency room.
6. Search and Seizure

Areas of Progress
During the reporting period, search and seizure has unfortunately stagnated. The search and seizure
compliance efforts have been beset with a series of starts and stops. During this reporting period, the
search and seizure working group, mentioned in the 13th Semiannual Report, convened twice. The first
meeting served as an introductory conversation, and the second meeting, in early November, involved a
walkthrough of the Monitoring Team’s search and seizure assessment tool with the Monitoring Team. The
purpose of the walkthrough was to identify data sources and demonstrate where information that would
be reviewed and assessed by the Monitoring Team could be found. The City provided a detailed
presentation that will inform the Monitoring Team’s assessment process. This second meeting was
productive and insightful.
Challenges Ahead
Although informative, the second meeting revealed that the Monitoring Team would face difficulty
accessing data needed for supervisory and command level reviews. As a result, questions arose about the
CDP’s implementation of certain aspects of the supervisory review process required by the Consent
Decree. On November 29, 2023, after digging deeper into the data accessibility questions raised, the PAT
formally requested a delay of the Monitoring Team’s planned search and seizure assessment. The PAT
informed the Monitoring Team that CDP intends to conduct a comprehensive self-audit of the search and
seizure protocols, administrative review processes, and data collection and management systems. The
City further indicated that the self-audit will utilize an eight-step process, comprised of both qualitative
and quantitative research methods, and will take approximately three (3) to six (6) months to complete.
The City promised that it would make its findings available to the public when complete. The City may also
require additional time to implement the necessary corrective actions.
On December 19, 2023, the PAT requested to meet with the Monitoring Team and DOJ to discuss
deficiencies identified in the data caused by technological glitches in the Brazos system (which is used to
record and track stop, search, and seizure data). During the meeting, the PAT reported that it had
identified the following three (3) sources of deficiencies in the data:
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1. Between June 1 – 30, 2023, the narrative text box in which officers enter justification for the
stop (i.e., probable cause or reasonable suspicion analysis) was not available on the stop form.
Seventy-four (74) forms were affected by this issue during this time period.
2. Since November 1, 2023, CDP has been unable to enter new officers into the Brazos system,
which in turn means those officers have been unable to complete the stop forms. This issue has
persisted for newly hired cadets, lateral hires, and officers that have been rehired by CDP.
3. A group of supervisors are unable to approve the stop forms as required by the Consent Decree.
There are currently 620 stop forms pending supervisor approval.
PAT informs us that it is working closely with the Public Safety Division’s Office of Information Technology
(“IT Division”) in an effort to resolve these issues. The IT Division reported it has requested a root cause
analysis of each problem as well as a comprehensive report from the vendor to assess the scope and
magnitude of the deficiencies and to reconcile and rectify the discrepancies in the data.
After extensive deliberations with the Parties and among the Monitoring Team, the Monitor decided to
proceed with the search and seizure assessment in 2024, but will allow CDP time to complete its self-
audit. Accordingly, the Monitoring Team’s assessment is set to commence on or before June 1, 2024. The
Monitor further notes that the Brazos System issues discussed above concern 2023 data. As reported in
the 13th Semiannual Report, the Monitoring Team is looking to conduct an assessment on 2022 data,
which does not appear to have been affected by the Brazos issued discussed above. However, as of April
8, 2024, the City has not yet delivered its annual report analyzing stop forms from 2022. Weighing these
factors, initiating the assessment after June 1, 2024 will ensure the Monitoring Team can review the City’s
analysis and reports and the City can complete its self-audit prior to commencement of the assessment.
It is worth noting that the Monitoring Team had been prepared to conduct this assessment in 2023, which
would have allowed for the City to have feedback on its more recent data. Now that the Monitoring Team
is conducting this assessment in June 2024, the data is roughly two (2) years old.
The most significant challenge to providing a rating on search and seizure has been the City’s failure to
provide the Monitoring Team and DOJ access to its databases for nearly a year. This culminated in the City
formally terminating the Monitoring Team and DOJ’s access to critical data and systems beginning
December 29, 2023 – alleging concerns that such access may violate Ohio State Law. For more than eight
(8) years, the City has provided the Monitoring Team and DOJ access to CDP documents and databases as
required by the Consent Decree, including IAPro, Blue Team, Evidence.com, Brazos, and CDP’s Records
Management System. However, due to a recent decision by the City Law Department, the Monitoring
Team and DOJ were denied access to information and systems needed in order complete their
responsibilities under the Consent Decree. Specifically the Monitoring Team and DOJ were denied access
to body-worn camera footage; incident reports; use of force reports; taser deployment information; stop,
search, and arrest reports; supervisor review of stop, search, arrest, and use of force reports; complaints;
and IAPro files. While the City has claimed that it appreciates the importance of the Monitoring Team and
DOJ receiving access to core documents, its action have not been consistent with its words. The City’s
actions caused the Court to hold a hearing to consider DOJ’s motion to enforce the Consent Decree that
was based on the City’s refusal to provide the Monitoring Team and DOJ access to its systems and data.
The Court agreed with DOJ and ordered the City to provide access.
Over the course of the next reporting period, the Monitoring Team looks forward to receiving the internal
audit reports from PAT, bi-weekly updates on resolution of the IT issues, assurances as to the integrity
21
and reliability of the stop data being collected, and the 2022 search and seizure report which was expected
at the end of quarter four (4) 2023. And, importantly, the Monitoring Team looks forward to regaining
access to necessary databases and systems. This information is critical to assessing CDP’s compliance with
search and seizure provisions of the Consent Decree.
7. Accountability
Areas of Progress
Internal Affairs: The IA team reports that it is close to finalizing a draft training with an outside vendor to
ensure all IA investigators have received adequate initial training, per ¶ 180. They expect to have a draft
to the Training Review Committee, Monitoring Team, and DOJ by mid-February. Upon approval, all IA
team members will be provided this same training.
During this reporting period, IA reports that its investigators attended a one-and-a-half-hour webinar from
an outside vendor regarding developing a timeline for use-of-force incidents. They also report that a
different vendor presented a full day’s training on 1st Amendment, Social Media, Use of Force, Qualified
Immunity, and Civil Liability Legal updates, attended by IA investigators and investigators from other units.
However, these trainings were not vetted through the Training Section, nor were the Monitoring Team or
the DOJ informed about the trainings beforehand, given the opportunity to review the curricula, or given
the chance to observe the in-person training. Per the Consent Decree, the Commander of the Training
Section is responsible for reviewing all training received by CDP’s members for consistency, quality,
accuracy, currency, completeness, compliance with law and policy, and effectiveness of the teaching
modality. In addition, to the extent that CDP would like to apply training toward Consent Decree
compliance, CDP must inform the Monitoring Team and DOJ about it beforehand to allow the team to
review the curriculum and/or observe the training delivery. The IA team indicated plans to host a training
in February on Human Factors and Interviewing for Use of Force investigations from an outside vendor.
While the Monitoring Team has been provided with the initial course plan, the training must be vetted
through the Training Section, and the Monitoring Team and DOJ must be given the opportunity to observe
the training delivery.
The IA team is to be commended for working to expedite the completion of the IA Manual. It was
approved by the Monitoring Team and DOJ on February 12, 2024 (outside of the reporting period).
Lastly, IA leadership reports that it held a full unit meeting during this period to cover how to properly
enter allegations into IAPro, with the goal of having consistent reporting related to allegations.
Office of Professional Standards: No progress to report.
Police Review Board: No progress to report.
Discipline: During this reporting period, CDP spent time collaborating with the Monitoring Team and DOJ
on updating its disciplinary matrix, the title of which CDP has now changed to “Corrective Action
Guidance.” The Monitoring Team feels optimistic that this will be finalized in the next reporting period.
Challenges Ahead
Internal Affairs: IA will need to ensure that its IAPro data is consistent as supervisors work to follow the
procedures required for entering allegations correctly.
22
Additionally, as the IA Manual update is completed, IA will continue to face the challenge of implementing
its requirements with fidelity to ensure timely investigations of all internal allegations of officer
misconduct that comport with ¶¶ 182-187 of the Consent Decree. Since some internal investigations are
delegated to other units, IA leadership will also be challenged with overseeing the completeness and
timeliness of all delegated investigations. Ultimately, the Monitoring Team will need to conduct an
assessment of IA’s work to be able to determine whether it will move toward Operational Compliance on
many paragraphs of this section.
Office of Professional Standards: In the last reporting period, ¶ 194 was moved from Non-Compliance to
Partial Compliance with the hiring of a new Administrator. However, complaints regarding the
Administrator’s leadership style and his leave of absence, which began during the period covered by this
report, jeopardize compliance with this paragraph. The Monitoring Team notes that it received the City’s
annual report required by ¶ 215 (on analysis required by ¶ 214) in February 2024. We had not previously
received a report since 2021. Because this report was received outside of the reporting period, it will be
addressed in the next Semiannual Report. Between November 27, 2023 and January 3, 2024, the OPS
Administrator took voluntary leave. He returned in a limited capacity—without full access to the materials
needed to fulfill the duties of his role—from January 3, 2023 to February 27, 2024. The Monitoring Team
was notified when the Administrator went on voluntary leave, but received little to no communication
regarding OPS processes and progress during his absence. Regularly scheduled OPS working group
meetings that occur every two weeks were canceled during the Administrator’s voluntary leave and did
not resume until March 21, 2024. The Monitoring Team had no visibility into the skills, expertise, or
experience of the interim Administrator, nor did the Monitoring Team have visibility into how the City
determined who would serve as interim Administrator. It is for all of these reasons that the City has been
downgraded for ¶ 194.
Police Review Board: Overall timelines, particularly waiting for the Chief or Director’s final decisions,
continue to extend beyond reasonable lengths. The City must provide updated documentation to advance
compliance in several paragraphs pertaining to PRB. Further, the Monitoring Team has not received a PRB
manual from the City since it provided comments in October 2022—more than a year ago.
Discipline: Monitoring Team members have spent substantial time this reporting period reviewing
disposition letters from disciplinary hearings. Ultimately, a discipline assessment will allow the Monitoring
Team to determine whether discipline is being applied consistently, fairly, and per the matrix, but the
Monitoring Team will first seek to have discussions with CDP’s Chief and the City’s Public Safety Director
to discuss more recent disciplinary decisions and better understand their decision-making processes prior
to initiating such an assessment in the future.
8. Transparency and Oversight

Areas of Progress
While the City has not yet filled the position of Inspector General (IG), vacant since early 2021, the
Monitoring Team recognizes and applauds the City’s reconsideration of its plan to expand the IG position
to include all City Public Safety agencies. A joint filing to amend the Consent Decree consistent with this
expanded role was filed on January 12, 2024. We are eager to see the position posted and filled. It is
imperative that the City work with focused attention and employ creative mechanisms to recruit, hire,
and retain an IG. Over the last eight (8) years the position was filled for less than 1.5 years.
23
The Monitoring Team notes the improvement in the manner in which street-level supervisors and district
commanders are using data. There have been meetings with the Data Team and command staff personnel
to demonstrate that supervisors are connecting the collection of data with needs and strategies of
operational personnel. The December 2023 CDP Stat Meeting brought district commanders in to describe
how they use the data in their managerial capacity. Additionally, recent conversations included
operational personnel in the plans for the upcoming compliance assessments. Continued efforts on the
part of the City to link operational and data personnel will strengthen the importance and role of data in
constitutional policing.
Increased transparency of data seems to be on the horizon as a City initiative. Mayor Bibb has announced
an open data initiative through the newly created Office of Urban Analytics and Innovation (Urban AI).
According to the Urban AI website, the section will include an Urban Data Lab and a section that will
“establish a culture of continuous improvement.”12 When the Monitoring Team recommended the City
post and share the raw data prepared by the CDP data team in response to ¶ 367, they elected to do so
on the forthcoming Urban AI space. The Monitoring Team very much looks forward to that reality.
In recent months the Parties, with the Monitoring Team, have discussed the expectations around reports
relative to ¶¶ 257-268. There will be ongoing conversations in that regard.
Challenges Ahead
The City created and experienced protracted delays and changes to plans around the IG position. This
important position remains vacant and the progress to fill this position seems slow. All paragraphs, ¶¶
250-256, that relate to the IG remain in non-compliance.
CDP identified irregularities with the Brazos reporting system in its capture of detailed information in the
area of stops and searches. Brazos is on the online reporting solution for these types of activities in
accordance with ¶ 260. CDP and the PAT are working closely with the City IT Department and the Brazos
help desk to remedy the issue. The issue was identified in early November, and the Monitoring Team was
briefed in December. It is imperative that personnel in CDP understand the urgency of some data
collection efforts and invoke senior assistance more urgently.
For increased compliance to be achieved with ¶¶ 261- 263, the City must demonstrate there are job
requirements or a standard operating procedure for the Data Analysis and Collection Coordinator to
conduct the routine tasks of those paragraphs.
¶¶ 264-266 require extensive reporting and analyses. Over time, the Monitoring Team has reviewed
reports and find they generally lack the expected level of analysis. After extensive conversation with CDP
and PAT in the latter part of 2023, it is clear that additional conversation is required for clarity on the
number and types of reports required by these paragraphs. The Monitoring Team looks forward to
ongoing conversations and responding to proposals by the City to achieve a greater level of compliance
with these paragraphs. There is agreement and recognition that the current systems of data collection
can be cumbersome not only for officers but also for the necessary level of quality assurance for reliable
reporting by the Data Team. It is gratifying to learn from the City IT Department that there are
conversations with outside entities that could address that reality in the near term.
12
https://www.clevelandohio.gov/city-hall/office-mayor/urban-ai
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Paragraphs 267 and 268 relate to sharing data with the public and essentially requires the CPC to be
engaged in that process. The Monitoring Team is unaware of the extent to which the Data Team liaises
with the CPC to increase the reach of their hard work. There continue to be challenges with ease with
which users can easily locate specific information relative to policies on the City of Cleveland websites.
There is a table of contents and specific areas. However, to effectively search policies, the user must have
a detailed knowledge of CDP and the language of CDP. Using the search tool does not bring the user to a
specific page or policy, making all policies difficult to find, access, and review. Reorganizing the website in
a way that makes it easier for members of the public, and likely members of CDP, to find what they need
should be established as a task for the coming year. Not only does ¶ 268 require the posting of policies
and procedures, but also requires training plans, community policing initiatives, community meeting
schedules, budget, and internal audit reports on its website. It is not evident where members of the public
should go for these items. When one searches for “community policing meetings” or “district policing
meetings,” nothing relevant appears in the search bar.
9. Officer Assistance and Support

Areas of Progress
Training: Commander Mark Maguth of the Training Section has aggressively pushed for all training
curriculum development and instructor assessments to come through the CDP’s Training Section in an
attempt to hold all training to CDP’s standards. While there has been progress in these efforts to comply
with ¶¶ 275 and 280, the Monitoring Team is still seeing evidence that certain trainings have not been
reviewed by the Training Section as needed. The Monitoring Team continues to urge CDP toward
compliance on this requirement by requiring all trainings be reviewed, coordinated, and approved by the
Training Section.
In addition, it appears that other lesson plans are regularly being reviewed by the Training Review
Committee, including representation from the CPC, which is a positive step toward their more substantive
involvement in training development.
On December 16, 2023, the CDP and CPC partnered to provide an experiential presentation to the
community of some of CDP’s training, allowing the community to participate in select training scenarios.
The presentation was very informative, and the community was engaged and pleased with the
opportunity to observe and participate in CDP-created simulations and training scenarios.
During this reporting period, the Monitoring Team reviewed multiple training documents, to include a
District Awareness Refresher course, an interactive reality-based training covering many Consent Decree
topics, and CDP’s 2024 Needs Assessment and Training Plan. In addition, during this period the Monitoring
Team observed Session III of CDP’s in-service training. The Monitoring Team believes that this training
reflected a holistic approach to combining hands-on scenarios with multiple learning objectives on search
and seizure, de-escalation and use of force, bias-free policing, and crisis intervention, among others.
Equipment: The City’s IT Department is increasingly connected to daily operational needs of the CDP. City
IT has been involved in meetings with the Monitoring Team, CDP operations personnel, the PAT, and the
Data Team, discussing emerging issues around record collection and retention. In July 2023, the City
established a Police IT Board that meets with Public Safety IT on a biweekly basis. Also importantly,
consistent with ¶ 294, City IT met with the CPC for the first time on January 4, 2024 (after the reporting
period). The City IT Department continues to follow the expectation of ¶¶ 291-298 with its annual
25
assessment, planning, and appropriation process. The replacement plan for equipment purchased is
followed and as new technologies emerge, City IT and Public Safety IT make improvements. In-car dash
cameras have been installed in one hundred twenty-five (125) vehicles, and the remaining one hundred
seventy-five (175) will be completed by the end of June 2024. Other upgrades and updates in portable
radios, IAPro, along with the PC refresh and in-car modem refresh are or will be completed in the next
few months. The City appropriated additional funds to support the hiring of eight (8) additional staff to
further support the increasing and ongoing IT needs. City IT reports exploring what could be significant
improvements to the Computer Aided Dispatch and Records Management Systems. Such changes would
limit redundant entry and improve workflows significantly.
Recruitment and Retention: With near historic staff shortages caused by voluntary departures and
retirements and the national crisis in recruiting police officers experienced across the nation, the
Recruitment and Retention Section at the Department Public Safety (DPS), along with the PAT, have
embarked on novel approaches. With support from the Administration, the City revised its recruitment
strategy to conduct a weekend-long recruitment effort affording candidates a one-stop experience to
apply and participate in the preliminary testing center. The weekend event produced over six hundred
(600) interested persons and yielded approximately three hundred (300) pre-qualified recruits. To
generate further interest within the public, the City changed the maximum age, implemented hiring
bonuses, emphasized changes in the collective bargaining agreement, increased wages for existing
officers, and instituted shift changes. All this incentivized new applicants and prior CDP officers to express
interest. It is hoped that the CDP can host sufficient academy classes in 2024 to field up to one hundred
fifty (150) new officers.
Since the 2022 compliance assessment of ¶¶ 308-311 by the Monitoring Team, CDP requested some
technical assistance and made changes to its processes and record keeping. These policies appear to be
promising. A subsequent assessment was neither requested nor conducted.
Challenges Ahead
Training: CDP delayed its Supervisor Training, which is now scheduled for the next reporting period. The
Monitoring Team looks forward to observing the in-person portion of the training. A persistent challenge
is that the Training Division needs to make certain that participants are engaged in the training program,
for example, by ensuring that participants are alert, non-disruptive, and not distracted by personal mobile
devices. Thus, not only is the training material important, but so too is the effectiveness of the training
delivery. In addition, CDP must continue to ensure that all trainings provided to CDP officers are vetted by
the Training Section to ensure the quality of training is up to par with what has become CDP’s standard
in-house training quality. The Monitoring Team continues to eagerly await an updated version of the FRB
Training, which it last saw in February of 2023 and which required significant upgrades. In addition, CDP
has been working for some time on updating their Field Training Program, but the Monitoring Team has
yet to review an updated version. While the Monitoring Team acknowledges that the workload of the
Training Section is heavy, CDP must continue to stay apace, and keep the Monitoring Team apprised of its
work, to ensure that it is fulfilling its duties under the Consent Decree.
CPC’s review of training materials has been a critical focal point of recent conversations and is expected
to be discussed in the next Semiannual Report.
Recruitment and Retention: Voluntary terminations, both retirements and departures, continue to
outnumber new hires. While the Recruitment and Retention Section endeavors to conduct exit surveys of
26
all personnel who leave, based on shared reports, the exit surveys capture only a small percentage of
those who leave. DPS needs to establish systems to strengthen the necessary communication and
connections between CDP’s Human Resources and the DPS’s Recruitment and Retention Section to
improve the data collection from those leaving in ways that might inform management on retention
strategies. The survey results that were shared with the Monitoring Team show there remain issues within
the control of management – specific plans to address them should be made.
As described above, the recruitment fair held on a December weekend was very impressive and produced
record numbers of applicants. Numbers alone should not drive the effort. Paragraph 304 directs the
recruitment plan to “include specific strategies for attracting a diverse group of applicants….” The
Monitoring Team has not seen a plan that connects specific strategies to specific goals. It would also be
helpful for the plan to articulate the goals the CDP wants to meet such as gender parity in the CDP, a
percent of Spanish speakers, or other demographic or skill based on analysis of the current composition
of personnel. The Recruitment Plans demonstrate that those in the DPS Recruitment and Retention
Section have deep connections to segments of the Cleveland community such as local media,
neighborhood-based gathering places, and more. The Monitoring Team is not aware of the degree to
which the Recruitment and Retention Section engages with the CPC in accordance with ¶ 305.
Among the concerns the initial assessment of background investigations (¶¶ 308-311) revealed was the
finding that there does not appear to be objective criteria for the ultimate selection of those recruits who
are hired. With the successful recruitment effort this winter and the large number of anticipated recruits
that effort will produce, CDP leadership and the DPS are urged to create assessment criteria and to
document decisions around the selection process.
Employee Assistance: In the last six (6) months, the City has failed to provide the Monitoring Team any
evidence of its efforts to provide mental health and other support to its law enforcement personnel. It
has been many months since a revised policy was reviewed, and it is unclear at this time if there is an
active policy or operations manual for Employee Assistance.
Performance & Promotions: There appears to have been no effort or activity to address the non-
compliance of ¶¶ 312-318 which concern performance evaluation process. A performance evaluation
policy and matrix being drafted in previous reporting periods did not appear to progress, to the
Monitoring Team’s knowledge, during this period. Similarly, as previously reported, the Monitoring Team
made several efforts in the past to engage the City in collaborative discussions around promotions to
better understand the City’s compliance with these paragraphs. The City remains unresponsive to the
Monitoring Team’s various past requests for documentation and additional working sessions.
10. Supervision
Areas of Progress
The approved curriculum for Supervisor Training reflects an emphasis on supervisor intervention and
oversight. The Monitoring Team looks forward to the opportunity to observe the delivery of this training.
After a period of inactivity, in late 2023, CDP presented an update of their work on its Officer Intervention
Program (OIP) that included their current research of OIPs in other jurisdictions that they intend to review
for possible integration into their program. The presentation also included a demonstration of the Power
BI dashboards that will be used for tracking of officers who trigger the system.
27
CDP submitted comprehensive policy revisions on their WCS for review by the Monitoring Team and DOJ.
The revisions address the previously identified issues regarding supervisory audits and include a
requirement for command reviews to ensure supervisory accountability. Once approved and
implemented, CDP should re-acquire a higher level of compliance on ¶ 329. The Monitoring Team looks
forward to reviewing these enhanced supervisory and command audits and CDP’s assessment of those
audits.
Challenges Ahead
The Monitoring Team will need to have a fuller picture of whether supervisors are achieving their
requirements for close and effective supervision (¶ 322), and whether CDP is in fact holding officers
directly accountable for the quality and effectiveness of their supervision (¶ 325). CDP should identify
metrics for holding supervisors accountable and document ongoing supervisory performance to show
progress toward compliance. The Monitoring Team will continue to gain insight into supervisory
performance through its topic-specific assessments on use of force, search & seizure, and accountability.
The presentation of CDP’s aspirations regarding OIP was helpful and it appeared that some progress is
being made. However, CDP stated that they were still in “data collection mode,” and has yet to establish
a timeline for deliverables related to the OIP Consent Decree requirements. Further, the Power BI
dashboards are not yet accessible to supervisors for tracking of their officers nor has the draft OIP policy
(and its accompanying procedural manual) been completed to provide sufficient guidance to ensure the
program is properly implemented. The Monitoring Team would like to see CDP prioritize this area in the
next assessment period. A robust OIP should be viewed as an integral part of achieving and maintaining a
healthy workforce.
11. Outcome Assessments
CDP has continued to compile its data for the outcome assessment chart. The Monitoring
Team has advised CDP to post this data on its website and make the data publicly available. The City
recently informed the Monitoring Team that they plan to do so as part of their Urban AI initiative
mentioned above. The Monitoring Team is greatly interested in this Initiative becoming a reality, as this
trove of data can be used for many purposes, including to advance the narrative about change in
the Cleveland community. CDP data show positive changes have occurred over the consent decree years
– and it has earned the right to celebrate those changes – but they have not yet taken the opportunity to
dynamically share them to inform the public and help researchers. The Monitoring Team encourages the
City to take every opportunity to use the outcome measures data to demonstrate its changes over time
and to allow the public to see for itself, by way of the data, the positive impact of these changes.
28
V. Appendix
1. Community Engagement and Building Trust
PARAGRAPH # DESCRIPTION STATUS OF COMPLIANCE
CDP crea on of “formal and informal mechanisms
14 that facilitate ongoing communica on between CDP PARTIAL COMPLIANCE
and the many Cleveland communi es it serves.”
Crea on of CPC to make recommenda ons, work
with Cleveland communi es to develop
15 recommenda ons, and “report to the City and GENERAL COMPLIANCE
community as a whole and to provide
transparency” on reforms.
CPC members “will be appointed and vacancies will
be filled in accordance with the City’s Charter”; and
16 PARTIAL COMPLIANCE
periodic mee ngs with Chief of Police to “provide
recommenda ons.”
“[H]old public mee ngs across the City, complete
an assessment of CDP’s bias-free policing policies,
17(a) NON-COMPLIANCE
prac ces, and training, and make
recommenda ons.”
“[A]ssist as appropriate in . . . development of
17(b) training related to bias-free policing and cultural NON-COMPLIANCE
competency.”
“[O]n an ongoing basis, assess CDP’s community
ac vi es” and “make recommenda ons” related to
17(c) NON-COMPLIANCE
“community engagement” and “community
confidence.”
“[O]n an ongoing basis, review CDP’s civilian
oversight structure to determine if there are
17(d) PARTIAL COMPLIANCE
changes it recommends for improving CDP’s
accountability and transparency.”
“[R]eview and comment on CDP’s policies and
18(a) prac ces related to use of force, search and seizure, NON-COMPLIANCE
and data collec on and reten on.”
[R]eview and comment on CDP’s implementa on
18(b) of ini a ve, programs, and ac vi es that are NON-COMPLIANCE
intended to support reform.”
“[H]old public mee ngs to discuss the Monitor’s
18(c) reports and to receive community feedback PARTIAL COMPLIANCE
concerning CDP’s compliance with this Agreement.”
“The City will provide access to all informa on
requested by the Commission related to its
19 NON-COMPLIANCE
mandate, authority, and du es unless it is legally
restricted.”
CPC “will issue [at least annual] reports,” which the
20 NON-COMPLIANCE
“City will post . . . to the City’s website.”
29

“The City will consider and mely respond in wri ng
to the Commission’s recommenda ons for
21 NON-COMPLIANCE
improvements,” which “will be posted to the City’s
website.”
CPC budget listed as “separate line item” to ensure
22 GENERAL COMPLIANCE
“sufficient independence and resources.”
Facilita on of “regular communica on and
coopera on between CDP and community leaders
at the local level,” with District Policing Commi ees
mee ng “at minimum, every quarter.”
CPC, CDP, and Community Rela ons Board (“CRB”)
will “develop a mechanism to recruit and expand”
24 Commi ee membership.” CDP “will work with NON-COMPLIANCE
[Community Police] Commission to select officers
for each District Policing Commi ee.”
CDP “will work closely with District Policing
Commi ees to iden fy strategies to address crime
and safety issues in their District,” considering and
addressing iden fied priori es.
“At least annually, each District Policing Commi ee
will present its iden fied strategies, concerns, and
recommenda ons” to the CPC, with CDP officer
who is Commi ee member presen ng to CPC
“CDP’s assessment of ways to address” the
recommenda ons.”
2. Community and Problem-Oriented Policing

Implementa on of “comprehensive and
27 integrated community and problem-oriented PARTIAL COMPLIANCE
policing model” by the City.
Ensuring that “mission statement reflects
[the Division’s] commitment to community-
oriented policing” / “integrat[ing] community
and problem-oriented policing principles into
its management, policies and procedures,
recruitment, training, personnel evalua ons,
resource deployment, tac cs, and
accountability systems.”
Ensuring “that officers are familiar with the

geographic areas they serve,” “engage in
29 problem iden fica on,” and “work PARTIAL COMPLIANCE
proac vely . . . to address quality of life
issues.”
30

Ini al and annual in-service community and
problem-oriented policing training “adequate
30 NON-COMPLIANCE
in quality, quan ty, type, and scope” that
addresses specifically iden fied areas.
Maintenance of “collabora ve partnerships
with a broad spectrum of community
31 groups,” including CDP mee ngs with PARTIAL COMPLIANCE
community organiza ons and District Policing
Commi ees.
CDP “meet[ing] with members of the
community in each District on a monthly
basis and “solic[ita on of] par cipa on from
32 a broad cross-sec on of community members PARTIAL COMPLIANCE
in each District” to “iden fy problems and
other areas of concern . . . and discuss
responses and solu ons.”
Development and implementa on of
“systems to monitor officer outreach to the
community” that CDP “will use . . . to analyze
. . . whether officers are partnering with a
broad cross-sec on of community members
to develop and implement coopera ve
strategies that build mutual respect and
iden fy and solve problems.”
“At least annually, CDP will present the
results” of paragraph 33 analysis “broken out
by District in a publicly-available community
34 NON-COMPLIANCE
policing report” that describes problems,
solu ons, and obstacles. Report provided to
Commission and posted on CDP website.
3. Bias-Free Policing
Delivery of “police services with the goal of ensuring
35 that they are equitable, respec ul, and free of PARTIAL COMPLIANCE
unlawful bias,” among other things.
“CDP will integrate bias-free policing principles into
its management, policies and procedures, job
36 descrip ons, recruitment, training, personnel PARTIAL COMPLIANCE
evalua ons, resource deployment, tac cs, and
accountability systems.”
CDP will ensure that it “administer[s] all ac vi es
37 without discrimina on” on basis of various PARTIAL COMPLIANCE
protected classes
“CDP will develop a bias-free policing policy”
38 incorpora ng CPC recommenda ons “that provides OPERATIONAL COMPLIANCE
clear guidance to officers”
31

Develop bias-free policing and procedural jus ce
training “adequate in quality, quan ty, scope, and
39-40 OPERATIONAL COMPLIANCE
type” covering specific areas within 18 months of
the Effec ve Date.
Supervisor training on bias-free policing and
procedural jus ce issues covering specific areas
Annual in-service training on bias-free policing
“adequate in quality, quan ty, type, and scope”
Analysis of paragraph 265 data (“including use of
force, arrests, motor vehicle and inves gatory
43 NON-COMPLIANCE
stops, and misconduct complaints alleging
discrimina on”)
Considera on of “bias-free policing and equal
44 protec on” principles in hiring, unit assignment, PARTIAL COMPLIANCE
promo on, and performance assessments.
4. Use of Force
“CDP will revise, develop, and implement force
policies, training, supervision, and accountability
systems with the goal of ensuring that force”
45 complies with the Cons tu on, federal law, and the OPERATIONAL COMPLIANCE
Consent Decree “and that any use of unreasonable
force is promptly iden fied and responded to
appropriately.”
“The City will implement the terms of this
Agreement with the goal of ensuring that use of
force by CDP officers . . . will comply” with at least
twelve major, listed principles.
Division “will ensure that the [use of force] incident
47 is accurately and properly reported, documented, PARTIAL COMPLIANCE
and inves gated.”
“CDP will track and analyze officers’ uses of force to
hold officers accountable for unreasonable uses of
48 OPERATIONAL COMPLIANCE
force; to guide training and policy; and to iden fy
poor tac cs and emerging trends.”
Development of use of force policies “that comply
with applicable law[,] . . . are adequate to achieve
the goals described in paragraph 45,” and “specify
that unreasonable use of force will subject officers
to the disciplinary process, possible criminal
prosecu on, and/or possible civil liability.”
“CDP’s policies will address the use and deployment
50 of its authorized force techniques, technologies, OPERATIONAL COMPLIANCE
and weapons.”
Weapon-specific policies “will include training and
cer fica on requirements that each officer must
32

meet before being permi ed to carry and use the
authorized weapon.”
“No officer will carry any weapon that is not
authorized or approved by CDP.”
“Prior to the use of any approved weapon, the
officer, when possible and appropriate, will
53 communicate to the subject and other officers that OPERATIONAL COMPLIANCE
the use of weapon is imminent, and allow the
subject an opportunity to comply.”
“The City will implement policies” for firearms,
54-83 ECWs (Tasers), and OC (pepper) spray that comply OPERATIONAL COMPLIANCE
with a host of specific, expressly listed provisions.
CDP “will provide all current officers use of force
training that is adequate in quality, quan ty, scope,
and type and that includes” a number of specific,
expressly listed elements.
CDP “will provide the use of force training described
in paragraph 84 to all new officers.”
“CDP will provide all officers with annual use of
86 force in-service training that is adequate in quality, OPERATIONAL COMPLIANCE
quan ty, type, and scope.”
“CDP will develop and implement a single, uniform
repor ng system pursuant to a Use of Force
repor ng policy” that complies with the force Level
categoriza on set forth in the paragraph.
Requiring “[a]ll officers using or observing force” to
complete a Use of Force Report including a number
of specific features and avoiding “conclusory
statements, ‘boilerplate’, or ‘canned’ language.”
“Officers will be subject to the disciplinary process
89 for material omissions or misrepresenta ons in OPERATIONAL COMPLIANCE
their Use of Force Reports.”
“Officers who use or observe force and fail to report
it will be subject to the disciplinary process, up to
and including termina on, regardless of whether
the force was reasonable.”
Requirement to “no fy . . . supervisors . . . as soon
as prac cal following any use of force” and if
becoming aware of “an allega on of unreasonable
or unreported force by another officer.”
92 “Use of Force Reports will be maintained centrally.” OPERATIONAL COMPLIANCE
“A supervisor who was involved in a use of force,
including by par cipa ng in or ordering the force
93 under inves ga on, will not inves gate the incident OPERATIONAL COMPLIANCE
or review the Use of Force Reports for approval or
disapproval.”
Se ng specific requirements rela ng to the
inves ga on of low-level, Level 1 force.
33

Se ng specific requirements rela ng to the
inves ga on by supervisors and/or CDP chain of
command for inves ga on and review of Level 2
force.
“CDP may refer criminal inves ga ons of uses of
110 force to an independent and highly competent OPERATIONAL COMPLIANCE
agency outside CDP.”
Crea on and design of dedicated Force
Inves ga on Team (FIT) that “will conduct
administra ve inves ga ons . . . and criminal
inves ga ons” of serious force, “force involving
poten al criminal conduct,” in-custody deaths, and
cases assigned to it by the Chief.
112 Composi on of FIT Team. OPERATIONAL COMPLIANCE
“FIT members will receive FIT-specific training that
is adequate in quality, quan ty, scope, and type” on
a host of specific, expressly-listed topics both
ini ally and annually therea er.
“CDP will iden fy, assign, and train personnel for
114 the FIT to fulfill the requirements of this OPERATIONAL COMPLIANCE
Agreement.”
Response of FIT to use of force scenes. FIT
no fica on of prosecutor’s office. No fica on of
115 designated outside agency to conduct criminal OPERATIONAL COMPLIANCE
inves ga on if City elects to use external agency for
such inves ga ons.
“CDP will develop and implement polices to ensure
that, where an outside agency conducts the
criminal inves ga on, FIT conducts a concurrent
and thorough administra ve inves ga on.”
Memorandum of understanding required between
117 CDP and outside agency containing specific, OPERATIONAL COMPLIANCE
expressly-listed provisions.
Se ng forth various, specific, and expressly-listed
responsibili es of FIT during its inves ga ons.
119 N/A N/A
Providing for delay of compelled interview if “case
has the poten al to proceed criminally” but
otherwise requiring that “[n]o other part of the
inves ga on . . . be held in abeyance” unless
“specifically authorized by the Chief” in consulta on
with inves ga ng agency and prosecutor’s office.
Requiring comple on of preliminary report
presented to Chief or Chief’s designee “as soon as
possible, but absent exigent circumstances, no later
than 24 hours a er learning of the use of force.”
34

Comple on of inves ga on within 60 days.
Prepara on of FIT inves ga on report. Review of
FIT inves ga ve report by head of Internal Affairs
122 NON-COMPLIANCE
who “will approve or disapprove FIT’s
recommenda ons, or request . . . addi onal
inves ga on.”
Revision of FIT Manual to ensure “consisten[cy]
123 with the force principles” and several specific, OPERATIONAL COMPLIANCE
expressly-listed provisions.
“The City will develop and implement a Force
Review Board “to serve as a quality control
mechanism for uses of force and force
inves ga ons, and to appraise use of force
incidents from a tac cs, training, policy, and agency
improvement perspec ve.”
Requiring “training on legal updates, updates on
125 CDP’s policies, and CDP training curriculum related PARTIAL COMPLIANCE
to the use of force” for each member.
Manda ng “comprehensive and reliable reviews of
inves ga ons within 90 days of submission to the
FRB,” and encompassing officer’s decision-making
at the moment force was used as well asl “the
circumstances leading up to the use of force,
tac cal decisions, informa on sharing and
communica on, adequacy of supervision,
equipment, training, CDP’s medical response, when
applicable, and any commendable ac ons” and
ac ons and inac ons of all involved members.
Descrip on of reviews, which will: ensure objec ve
and complete inves ga ons and findings supported
by preponderance of the evidence; be presented by
the inves gator or District representa ve (for
supervisors); review wri en records and discuss the
case with the presenter; order addi onal
inves ga on when needed; determine whether the
case raises concerns about policing, training,
equipment, supervision, medical response,
communica on, or tac cs and referral to
appropriate unit; recommending non-disciplinary
ac on; and documen ng FRB findings and
recommenda ons within 15 days of each
presenta on.
“The FRB will assess the quality of the
inves ga ons,” including whether they are
“objec ve and comprehensive and
128 recommenda ons are supported by a PARTIAL COMPLIANCE
preponderance of evidence. The FRB will iden fy
and document any deficiencies that indicate a need
for correc ve ac on”
35

“Annually, the FRB will examine the data related to
use of force” provided by the DACC per ¶261 (and
in conjunc on with ¶266) “to detect any pa erns,
trends, and training deficiencies and make
recommenda ons for correc on as appropriate”
and will provide the analysis to the Monitor.
The FRB will work with the DACC to “develop a
tracking system to ensure that each of its
recommenda ons has been forwarded to the
130 appropriate personnel. The Chief or his or her OPERATIONAL COMPLIANCE
designee will ensure that the FRB’s
recommenda ons, including non-disciplinary
correc ve ac on, are implemented as appropriate.”
5. Crisis Intervention
“CDP will build upon and improve its Crisis
Interven on Program” in furtherance of four
specific, expressly-listed goals, which “will provide
131 a forum for effec ve problem solving regarding OPERATIONAL COMPLIANCE
the interac on between the criminal jus ce and
mental health system and create a context for
sustainable change.”
Establishment of Mental Health Response
Advisory Commi ee (the “Advisory Commi ee”)
“to foster rela onships and build support between
132 the police, community, and mental health GENERAL COMPLIANCE
providers and to help iden fy problems and
develop solu ons designed to improve outcomes
for individuals in crisis.”
133 Composi on of Advisory Commi ee. GENERAL COMPLIANCE
“The Advisory Commi ee will meet regularly and
provide guidance to assist CDP in improving,
expanding, and sustaining its Crisis Interven on
Program.”
Advisory Commi ee will conduct an annual
“analysis of crisis interven on incidents to
determine whether CDP has enough specialized
CIT officers, whether it is deploying those officers
effec vely, and whether specialized CIT officers”
and communica ons “are appropriately
responding to people in crisis,” and will also
“recommend appropriate changes.”
“The Advisory Commi ee’s reports and
recommenda ons will be provided” to CPC, “be
publicly available, and will be posted on the City’s
website.”
36

CDP will designate a Crisis Interven on
137 Coordinator for specific, expressly-iden fied GENERAL COMPLIANCE
purposes.
“Coordinator will develop and maintain
partnerships with program stakeholders and serve
as point of contact” and “resource” for other
stakeholders.
“Coordinator will par cipate in the Advisory

Commi ee and on a regular basis solicit feedback
from the mental health community and
specialized CIT officers, call-takers, and
dispatchers regarding the efficacy of CDP’s Crisis
Interven on Program.”
“Coordinator will be responsible for coordina ng

implementa on of the changes and
recommenda ons made by the Advisory
Commi ee, as appropriate.”
“Coordinator will be responsible for ensuring the
selec on of appropriate candidates for
141 designa on as specialized CIT officers” and “to PARTIAL COMPLIANCE
ensure that officers, call-takers, and dispatchers
are appropriately responding to CIT-related calls.”
“Coordinator will create ways to recognize and
142 honor specialized CIT officers, call-takers, and OPERATIONAL COMPLIANCE
dispatchers.”
Ini al and annual crisis interven on training to all
143 officers and recruits that is “adequate in quality, GENERAL COMPLIANCE
quan ty, type, and scope.”
Ini al and annual crisis interven on training for
dispatchers and call-takers.
“The City will provide enhanced specialized
training in responding to individuals in crisis to
145 certain officers (‘specialized CIT officers’),” who OPERATIONAL COMPLIANCE
will be “called upon to respond to incidents or
calls involving individuals in crisis.”
Outlining various requirements for the “enhanced
146 training” for specialized CIT officers of “at least 40 GENERAL COMPLIANCE
hours.”
Outlining various requirements for the “enhanced
147 training” for specialized CIT officers of “at least 40 OPERATIONAL COMPLIANCE
hours.”
Designa on of specialized CIT officers, per specific,
expressly-listed requirements.
“Supervisors will iden fy and encourage qualified
149 officers across all shi s and all Districts to serve as OPERATIONAL COMPLIANCE
specialized officers.”
37

“All Field Training Officers” (“FTO”s) “will receive
the enhanced specialized crisis interven on
training described in paragraph 146,” though FTOs
will “not be designated as a specialized CIT officer”
unless they volunteer and have been selected to
do so.
“Specialized CIT officers who are dispatched to an

incident involving an individual in crisis will have
primary responsibility for the scene,” with
supervisors “seek[ing] the input of a specialized
CIT officer . . . where it is reasonable for them to
do so.”
“[T]he Coordinator will develop an effec ve

specialized crisis interven on plan . . . to ensure
that a specialized CIT officer is available to
respond to all calls and incidents that appear to
involve an individual in crisis” that includes
various, specific, expressly-iden fied
requirements. The City “will use its best efforts to
ensure that a specialized CIT officer responds to all
calls and incidents that appear to involve an
individual in crisis.”
City “will consider” crisis intervention program
153 assessment by Ohio Criminal Justice Coordinating GENERAL COMPLIANCE
Center of Excellence.
CDP “will revise its policies to make clear that a
crisis intervention response may be necessary
even in situations where there has been an
apparent law violation.”
CDP “will revise its current crisis intervention
policy to ensure that specialized CIT officers have
155 appropriate discretion to direct individuals . . . to GENERAL COMPLIANCE
the health care system, rather than the judicial
system . . . where it is appropriate to do so.”
CDP policies and procedures will ensure that
“specialized CIT officers . . . must be dispatched to
all calls or incidents that appear to involve an
156 individual in crisis.” CDP must “track incidents in PARTIAL COMPLIANCE
which a specialized officer was not dispatched to
such calls” and “identify any barriers” to ensuring
dispatch of specialized CIT officer to such calls.
“CDP will track calls and incidents involving
157 individuals in crisis by gathering, at a minimum,” OPERATIONAL COMPLIANCE
specific, expressly-identified data.
38

Public reporting of paragraph 157 data and
provision to Advisory Committee.
“The City will utilize” paragraph 157 data “to
identify training needs and develop case studies
and teaching scenarios” for training and other
expressly-identified systemic purposes.
6. Search and Seizure

“CDP will revise, develop, and implement search
and seizure policies that comply with applicable
law, . . . include the requirements below,” and
conform to expressly-iden fied principles.
Policy requirements for officers for stops,
161-165 PARTIAL COMPLIANCE
searches, and deten ons
“Officers will immediately no fy a supervisor
when effectua ng a custodial arrest for
obstruc ng official business, resis ng arrest, or
assault on an officer and no other substan ve
viola on is alleged,” and “the supervisor will
respond to the scene.”
“Officers will not use ‘canned’ or conclusory
language without suppor ng detail in documents
or reports documen ng inves gatory stops,
searches, or arrests.”
“Officers will ar culate the jus fica on for an
inves gatory stop, search, or arrest in a specific
and clear manner in their reports.” CDP “will train
officers” on documen ng stops. “Supervisors will
review all documenta on of inves gatory stops,
searches, and arrests.”
Supervisor will review of “each arrest report by
officers under their command,” with supervisors
reviewing reports for specific, expressly-iden fied
deficiencies.
Supervisory review of inves gatory stops,
170-172 PARTIAL COMPLIANCE
searches, and arrests.
Provision of “ini al training that is adequate in
quality, quan ty, scope, and type on inves gatory
stops, searches, and arrests, including the
173 requirements” of the Consent Decree that “will OPERATIONAL COMPLIANCE
address the requirements of Fourth Amendment
and related law, CDP policies,” and specific,
expressly-iden fied topics.
Provision of “annual search and seizure in-service
training that is adequate in quality, quan ty, type,
39

and scope” incorpora ng specific, expressly-
iden fied topics.
7. Accountability
The City and CDP will ensure that all allega ons of
officer misconduct, whether internally discovered
or alleged by a civilian, are fully, fairly, and
efficiently inves gated; that all inves ga ve
176 findings are supported by a preponderance of the PARTIAL COMPLIANCE
evidence and documented in wri ng; and that all
officers who commit misconduct are held
accountable pursuant to a disciplinary system that
is fair, consistent, and provides due process.”
“Internal Affairs will conduct objec ve,
comprehensive, and mely inves ga ons of all
internal allega ons,” with “findings . . . based on
the preponderance of the evidence standard” that
must “be clearly delineated in policies, training,
and procedures and accompanied by detailed
examples to ensure proper applica on by
inves gators.”
“Internal Affairs will be headed by a qualified
178 civilian” who “will report directly to the Chief of OPERATIONAL COMPLIANCE
Police.
179 Qualifica ons for IA inves gators. PARTIAL COMPLIANCE
Ini al training for IA inves gators “that is
adequate in quality, quan ty, scope, and type on
conduc ng misconduct inves ga ons” that
addresses specific, expressly- iden fied topics.
“[A]nnual training” for IA inves gators “that is
adequate in quality, quan ty, type and scope”
“In each inves ga on, Internal Affairs will collect
and consider” all evidence. “[N]o automa c
preference for an officer’s statement over a non-
officer’s statement.” No disregard of a “witnesses’
182 statement solely because of” connec on to the PARTIAL COMPLIANCE
complainant or criminal history. IA inves gators
must “make all reasonable efforts to resolve
material inconsistencies between witness
statements.”
IA “will evaluate all relevant police ac vity and any

183 evidence of poten al misconduct uncovered PARTIAL COMPLIANCE
during the course of the inves ga on.”
40

IA will not consider guilty plea or verdict as
“determina ve of whether a CDP officer engaged
in misconduct” or jus fica on for “discon nuing
the inves ga on.”
IA “will complete its administra ve inves ga ons
185 within 30 days from the date it learns of the PARTIAL COMPLIANCE
alleged misconduct.”
186-187 IA inves ga ve report requirements. PARTIAL COMPLIANCE
Forwarding of completed IA inves ga ons “to the
officers’ supervisors, the Training Review
188 Commi ee, the Force Review Board, the Officer PARTIAL COMPLIANCE
Interven on Program, and the Data Collec on and
Analysis Coordinator.”
“CDP will require any CDP employee who observes
or becomes aware of any” poten al misconduct to
“report the incident to a supervisor or directly to”
IA.
“CDP will develop a system that allows officers to
190 confiden ally and anonymously report poten al OPERATIONAL COMPLIANCE
misconduct by other officers.”
“CDP will expressly prohibit all forms of
retalia on, discouragement, in mida on,
coercion, or adverse ac on, against any person,
civilian or officer, who reports misconduct, makes
a misconduct complaint, or cooperates with an
inves ga on of misconduct.”
“Officers who retaliate . . . will be subject to the
disciplinary process.”
OPS inves gates “all complaints of misconduct it
receives” and will confer with IA “to develop
policies and procedures for handling ma ers over
which they both have inves ga ve jurisdic on.”
“The City will ensure that OPS is led by an
administrator with the skills, exper se, and
experience to effec vely manage the intake,
tracking, mely, and objec ve inves ga on of
194 NON-COMPLIANCE
complaints”; implement PRB training; “assess
OPS’s equipment and staffing needs”; and
“develop and implement performance standards
for OPS.”
Ini al training for OPS inves gators “adequate in
195-196 quality, quan ty, scope, and type,” including OPERATONAL COMPLIANCE
specific, expressly-listed topics.
“OPS Inves gators will not be current members of
197 the CDP, and no CDP personnel will have any GENERAL COMPLIANCE
ac ve role in OPS’s opera ons.”
“The City will ensure that the lawyer represen ng
198 OPS does not have any actual or apparent conflicts OPERATIONAL COMPLIANCE
of interest.”
41

“OPS will have its own budget, separate from . . .
the Department of Public Safety” that “affords
199 sufficient independence and resources, including GENERAL COMPLIANCE
sufficient staff and training to meet the terms of
this Agreement.”
Development and implementa on of OPS
200 opera ons manual “made available to the public” PARTIAL COMPLIANCE
that covers specific, expressly-listed topics.
Development and implementa on of “a program
to promote awareness through the Cleveland
community about the process for filing complaints
with OPS.”
“CDP and the City will work with the police unions
. . . to allow civilian complaints to be submi ed to
OPS verbally or in wri ng; in person, by phone, or
202 on line; by a complainant, someone ac ng on his GENERAL COMPLIANCE
or her behalf, or anonymously; and with or
without a signature from the complainant,” with
all “complaints documented in wri ng.”
CDP will post and maintain by the intake window
at CDP headquarters and all District headquarters
203 a permanent placard describing the civilian OPERATIONAL COMPLIANCE
complaint process” and containing specific,
expressly-listed informa on.
“CDP will provide training that is adequate in
quality, quan ty, scope, and type to all police
204 personnel, including dispatchers, to properly PARTIAL COMPLIANCE
handle complaint intake, including” with respect
to specific, expressly-listed topics.
CDP officers “carry complaint forms in their CDP
vehicles,” which officers must provide “upon
request.” Supervisors will be dispatched to scene
205 when an individual wants to make a complaint, OPERATIONAL COMPLIANCE
with the supervisor providing a copy of completed
complaint form “or a blank form to be completed
later by the individual.”
“The City and OPS will make complaint forms and
other materials outlining the complaint process
206 and OPS’s contact informa on available at OPERATIONAL COMPLIANCE
loca ons” including a number of specific,
expressly-listed loca ons.
“OPS’s complaint form will not contain any

language that could reasonably be construed as
207 discouraging the filing of a complaint, including GENERAL COMPLIANCE
warnings about the poten al criminal
consequences for filing false complaints.”
42

Availability of complaint forms in English and
Spanish. “OPS will make every effort to ensure
that complainants who speak other languages . . .
can file complaints in their preferred language.”
“City will ensure that civilian complaints submi ed
through other exis ng systems, including the
209 Mayor’s Ac on Center and the Department Ac on OPERATIONAL COMPLIANCE
Center, are immediately forwarded to OPS for
inves ga on.”
“OPS will establish a centralized electronic
numbering and tracking system for all
complaints,” which “will maintain accurate and
reliable data regarding the number, nature, and
210 status of all complaints . . . including inves ga on OPERATIONAL COMPLIANCE
meliness and no fica on of the interim status
and final disposi on of the complaint.” It “will be
used to monitor and maintain appropriate
caseloads for OPS inves gators.”
Biased policing tracked as a separate category of
complaint that “are captured and tracked
appropriately, even if the complainant does not so
label the allega on.”
“[A]llega ons of unlawful inves gatory stops,
212 searches, or arrests” tracked as a separate OPERATIONAL COMPLIANCE
category of complaints.
“[A]llega ons of excessive use of force” tracked as
separate category of complaints.
“OPS will conduct regular assessments of the
214 types of complaints being received to iden fy and PARTIAL COMPLIANCE
assess poten al problema c pa erns and trends.”
“OPS will produce, at least annually, a public
report summarizing complaint trends, including”
215 PARTIAL COMPLAINCE
with respect several specific, expressly-iden fied
areas.
Assignment of complaints to Standard and
Complex inves gatory tracks.
Dismissal and/or administra ve dismissal of
complaint inves ga ons.
“The City will ensure that inves ga ons of
complaints are as thorough as necessary to reach
reliable and complete findings that are supported
by the preponderance of the evidence.”
“CDP will ensure that OPS has mely access to all
reports related to the incident . . ,” and authority
of OPS “to conduct addi onal inves ga on” of any
complaint of police misconduct when CDP
inves ga on has already taken place rela ng to
the incident.
43

“OPS inves gators will a empt to interview each
complainant in person” and record the interview.
“The Chief will order officers who witnessed or
par cipate in an incident that is the subject of an
221 OPS complaint to cooperate with the OPS GENERAL COMPLIANCE
inves ga on,” including by responding to wri en
ques ons or si ng for an in-person interview.
“OPS inves gators will have access to any relevant
222 disciplinary informa on in the record of an officer PARTIAL COMPLIANCE
who is the subject of a current inves ga on.”
“OPS will consider all relevant evidence,” with no
preferences for par cular witness’s statements,
including of officer over a non-officer, or because
223 of connec on to complainant or criminal history. PARTIAL COMPLIANCE
“OPS will make all reasonable efforts to resolve
material inconsistencies between witness
statements.”
224 OPS findings categories. OPERATIONAL COMPLIANCE
“OPS will document in wri ng the inves ga on of
each complaint, including all inves gatory steps
225 taken, and OPS’s findings and conclusions,” which GENERAL COMPLIANCE
must “be supported by a preponderance of the
evidence.
“In addition to determining whether an officer
committed the conduct alleged in the complaint
and whether it violated policy, OPS may consider
whether: (a) the police action was in compliance
with training and legal standards; (b) the incident
226 indicates a need for additional training, PARTIAL COMPLIANCE
counseling, or other corrective measures; and (c)
the incident suggests that CDP should revise its
policies, strategies, tactics, or training. OPS may
include recommendations on these topics in its
investigation.”
“OPS will forward all inves ga ons and its wri en
conclusions to PRB in sufficient me for PRB to
227 consider them no later than the second regularly PARTIAL COMPLIANCE
scheduled PRB mee ng following comple on of
the inves ga on.”
“OPS will send periodic wri en updates” to the
228 complainant at specific, expressly- iden fied OPERATIONAL COMPLIANCE
junctures.
“[A] complainant may contact OPS at any me to
determine the status of his/her complaint.”
“Mayor will work with the City Council to develop
an ordinance to place a Charter Amendment on
the ballot” addressing PRB composi on and
appointment process.
44

“PRB members will not be current or former
members of the CDP.”
“PRB will have its own budget,” overseen by OPS
Administrator and separate from Department of
Public Safety, that “affords sufficient
independence and resources.”
Ini al training for PRB members “that is adequate
233-234 in quality, quan ty, scope, and type” and that PARTIAL COMPLIANCE
covers specific, expressly-iden fied topics.
PRB mee ngs open to the public and posted in
235 advance, with “case presenta ons and PRB votes” GENERAL COMPLIANCE
occurring during “open session.”
“OPS inves gators will a end PRB mee ngs at
which their inves ga ons are being considered
236 and present their findings . . . . ” PRB may “ask the GENERAL COMPLIANCE
inves gator to conduct further inves ga on” as
necessary.
“PRB recommended disposi ons will be based on
a preponderance of the evidence. For each case,
PRB shall set forth its conclusion and an
237 explana on of its reasons and suppor ng PARTIAL COMPLIANCE
evidence in wri ng, including, when applicable,
the jus fica on for depar ng from OPS’s
recommended disposi on.”
“In cases where PRB is recommending a sustained
disposi on, in whole or in part, PRB will include a
recommenda on as to disciplinary or non-
disciplinary correc ve ac on.”
[Timely] forwarding of PRB recommenda ons to
Chief of Police and Director of Public Safety.
“The Chief of CDP will issue a General Police Order
that requires officers to (a) cooperate with the
Internal Affairs and OPS inves gators; and (b)
submit all relevant evidence to the inves gators
such that it is available for considera on by
Internal Affairs or PRB.”
Disciplinary hearing requirement, with officer
given “opportunity to tes fy” and suspension of
241 hearing if “officer provides new or addi onal PARTIAL COMPLIANCE
evidence at hearing,” with ma er “returned to IA
or PRB for considera on.”
Disciplinary recommenda ons by PRB to proceed
through the City’s disciplinary process. Wri en
jus fica on by Chief or Director of their
disagreement with PRB’s recommenda ons.
“CDP will track the number of instances in which
the Chief or the Director of Public Safety rejects, in
whole or in part, PRB’s recommended
disposi on.”
45

“The City will ensure that discipline for sustained
allega ons of misconduct comports with due
process, and is consistently applied, fair, and
based on the nature of the allega on, and that
mi ga ng and aggrava ng factors are iden fied
and consistently applied and documented.”
“[T]he City will review its current matrix and will
seek to amend it” “to ensure consistency” and
inclusion of a number of specific, expressly-
iden fied features.
“All disciplinary decisions will be documented in
wri ng.”
“[T]he City will provide its disciplinary matrix to
248 the PRB, Commission, the Police Inspector OPERATIONAL COMPLIANCE
General, and the police unions for comment.”
“CDP will work with the unions to allow for
249 sustained disciplinary findings to stay in an PARTIAL COMPLIANCE
officer’s record for ten years.”
8. Transparency and Oversight

“The City will hire an individual or individuals with
significant experience in law enforcement prac ces
and civil rights law to serve as a Police Inspector
250 NON-COMPLIANCE
General” (“IG”). City must seek CPC’s “input in
developing minimum qualifica ons and experience”
for IG.
IG work in Office of Mayor but report to Chief of
251 NON-COMPLIANCE
Police.
252 IG “will not be a current or former employee of CDP.” NON-COMPLIANCE
253 Du es and authority of IG. NON-COMPLIANCE
Budget of IG must be “a separate line item” in City
255 budget and “afford[] sufficient independence and NON-COMPLIANCE
resources” to comply with Consent Decree.
IG “will have access to all documents and data
256 necessary to perform the above func ons, including NON-COMPLIANCE
any raw data.”
“CDP will collect and maintain all data and records
necessary to accurately evaluate its use of force
prac ces and search and seizure prac ces and
facilitate transparency and, as permi ed by law,
broad access to informa on related to CDP’s decision
making and ac vi es. To achieve this outcome, CDP
will designate an individual or individuals as the ‘Data
Collec on and Analysis Coordinator.’”
Coordinator “will ensure the collec on and tracking
of all documents related to uses of force and
46

allega ons of misconduct and related materials,”
including specific, expressly-listed materials and
informa on.
Coordinator “will ensure the crea on and
maintenance of a reliable and accurate electronic
259 system to track all data derived from force-related GENERAL COMPLIANCE
documents,” including specific, expressly-iden fied
data.
Coordinator “will ensure the crea on and
maintenance of a reliable and accurate electronic
system to track data on all vehicle stops,
260 inves gatory stops, and searches, whether or not OPERATIONAL COMPLIANCE
they result in an arrest or issuance of a summons or
cita on.” The system must conform to a number of
specific, expressly-iden fied requirements.
Coordinator must “rou ne[ly] report[] . . . relevant
data to the Chief of Police, FRB, Training Review
Commi ee, OPS, the [Community Police]
Commission, and the Police Inspector General.”
Coordinator “responsible for the annual assessment
262 of forms and data collec on systems to improve the OPERATIONAL COMPLIANCE
accuracy and reliability of data collec on.”
Coordinator “will develop a protocol to accurately
analyze the data collected and allow for” various
outcome measurements, “subject to the review and
approval of the Monitor and DOJ.”
Annually, “CDP will conduct an assessment and issue
a report summarizing its inves gatory stop, search,
and arrest data” that addresses various specific,
expressly-iden fied topics.
Annually, “CDP will conduct an assessment and issue
a report of all ac vi es, including use of force,
arrests, motor vehicles and inves gatory stops, and
misconduct complaints alleging discrimina on, to
265 determine whether CDP’s ac vi es are applied or NON-COMPLIANCE
administered in a way that discriminates against
individuals on the basis of race” or other listed
prohibited classes or characteris cs, and that
addresses various specific, expressly-iden fied topics.
266 Annual analysis of “prior year’s force” data with FRB. PARTIAL COMPLIANCE
“[A]ll CDP audits, reports, and outcome analyses
267 related to the implementa on” of the Consent PARTIAL COMPLIANCE
Decree will be public.
“CDP will post its policies and procedures, training
plans, community policing ini a ves, community
mee ng schedules, budgets, and internal audit
reports on its website.”
47
9. Officer Assistance and Support

“The City will ensure that officers receive
adequate training to understand: (a) how to police
effec vely and safely in accordance with CDP
policy; [and] (b) the requirements of this
Agreement, Ohio law, and the Cons tu on and
laws of the United States,” including in the areas
of “procedural jus ce, bias-free policing, and
community policing.”
“CDP will expand the scope and membership of
the Training Review Commi ee.”
“[T]he Training Review Commi ee will develop a
wri en training plan for CDP’s recruit academy,
271-272 proba onary field training, and in-service training” PARTIAL COMPLIANCE
that addresses a host of specific, expressly-
iden fied issues.
“The Training Plan and schedule will be
273 implemented once any objec ons have been OPERATIONAL COMPLIANCE
resolved” on a yearly basis.
“The City, including the Training Review
Commi ee, will annually review and update CDP’s
training plan” by “conduct[ing] a needs OPERATIONAL COMPLIANCE
274
assessment” that addresses a number of specific,
expressly-iden fied data and informa on on real-
world trends, needs, policy, and law.
“CDP’s Commander responsible for training” will
be in charge of “all CDP training.”
“CDP will designate a single training coordinator in
each District. The Commander responsible for
training will establish and maintain
276 communica ons with each District training PARTIAL COMPLIANCE
coordinator to ensure that all officers complete
training as required and that documenta on of
training is provided to the” training Commander.
“CDP will develop recruit academy and in-service
277 curricula that comport with” the Training Plan and PARTIAL COMPLIANCE
Consent Decree requirements.
“For all other substan ve updates or revisions to
policy or procedure, the City will ensure and
document that all relevant CDP personnel have
279 received and read the policy or procedure. PARTIAL COMPLIANCE
No fica on of each revision or update will include
the ra onale for policy changes and the difference
between the old and updated policy.”
Training Commander reviews all training
280 materials; ensures that they use “a variety of adult PARTIAL COMPLIANCE
learning techniques, scenario-based training, and
48

problem-solving prac ces”; and “ensure that all
curricula, lesson plans, instructor’s qualifica ons,
and tes ng materials are reviewed by the Training
Review Commi ee.”
“CDP will ensure that instructors are qualified and
281 use only curricula and lesson plans that have been PARTIAL COMPLIANCE
approved by the” Training Commander.
“CDP will revise, as necessary, its field training
program for graduates of the police academy to
282 NON-COMPLIANCE
comport with” the Training Plan and Consent
Decree.
“The field training program will incorporate
283 community and problem-oriented policing NON-COMPLIANCE
principles, and problem-based learning methods.”
Review and revision of Field Training Officer
(“FTO”) “par cipa on policy to establish and
284 implement a program that effec vely a racts the NON-COMPLIANCE
best FTO candidates” and “revise eligibility
criteria” for FTOs.
New FTOs and Field Training Sergeants must
“receive ini al and in-service training that is
adequate in quality, quan ty, scope, and type, and
285 NON-COMPLIANCE
that addresses” a number of specific, expressly-
listed topics and conforms to a number of
addi onal features or requirements.
“CDP will create a mechanism for recruits to
provide confiden al feedback regarding the
quality of their field training,” and the Division
286 NON-COMPLIANCE
“will document its response, including the
ra onale behind any responsive ac on taken or
decision to take no ac on.”
“The City and the Training Review Commi ee will,
on an annual basis, analyze all aspects of CDP’s
FTO program,” “consider emerging na onal
287 policing prac ces in this area,” and “recommend, NON-COMPLIANCE
and CDP will ins tute, appropriate changes to
policies, procedures, and training related to its
FTO program.”
“CDP will document all training provided to or
received by CDP officers,” with officers “sign[ing]
an acknowledgement of a endance or digitally
acknowledge[ing] comple on of each training
course,” which “will be maintained in a format
that allows for analysis by training type, training
date, training source, and by individual officer
name.”
“CDP will develop and implement a system that
will allow the Training Sec on to electronically
49

track, maintain, and produce complete and
accurate records of current curricula, lesson plans,
training delivered, and other training materials in
a centralized electronic file system.”
“The City will develop and implement
accountability measures . . . to ensure that all
officers successfully complete all required training
programs in a mely manner.”
“The City will implement” paragraphs regarding
equipment and resources in order to allow
291 implementa on of the Consent Decree “and to PARTIAL COMPLIANCE
allow officers to perform their jobs safely,
effec vely, and efficiently.”
“CDP will complete a comprehensive equipment
and resource study to assess its current needs and
priori es,” and it “will develop an effec ve,
comprehensive Equipment and Resource Plan that
is consistent with its mission and that will allow it
to sa sfy the requirements of this Agreement.”
“CDP’s Equipment and Resource Plan will provide

for necessary equipment including, at least” “an
adequate number of computers”; “an adequate
number of operable and safe zone cars”; “zone
cards with reliable, func oning computers that
provide officers with up-to-date technology”
including computer-aided dispatch, the records
293 management system, and various core law OPERATIONAL COMPLIANCE
enforcement systems; and “zone cars equipped
with first-aid kits.” “This plan also will ensure that
CDP properly maintains and seeks to con nuously
improve upon exis ng equipment and technology;
and is appropriately iden fying equipment needs
and seeking to u lize, as appropriate, emerging
technologies.”
“CDP will ac vely seek input and feedback from

the Commission, patrol officers, and supervisors
294 NON-COMPLIANCE
regarding resource alloca on, equipment needs,
and technological improvements.”
“City and CDP” must “us[e] best efforts to
295 implement the Equipment and Resource Plan as OPERATIONAL COMPLIANCE
required.”
“CDP will . . . implement an effec ve, centralized
records management system.”
“CDP will u lize a department-wide e-mail system
297 to improve communica on and informa on OPERATIONAL COMPLIANCE
sharing.”
50

“CDP will employ informa on technology
professionals who are trained to conduct crime
and intelligence analysis, who are capable of
troubleshoo ng and maintaining informa on
technology systems and who can iden fy and
suggest appropriate technological advancements.”
“CDP will implement an effec ve employee
assistance program that provides officers ready
299 access to the mental health and support resources PARTIAL COMPLIANCE
necessary to facilitate effec ve and cons tu onal
policing.”
“The City will review and revise . . . its recruitment
and hiring program to ensure that CDP
successfully a racts and hires a diverse group of
qualified individuals.”
“The Mayor will work with the City Council to
develop an ordinance to place a Charter
Amendment on the ballot that would give the
appoin ng authority greater flexibility in the
selec on of candidates from the cer fied eligibility
list for the CDP.”
“CDP will develop a recruitment policy and a
strategic recruitment plan that includes clear
goals, objec ves, and ac on steps for a rac ng
qualified applicants from a broad cross-sec on of
the community” and meets certain specific,
expressly-listed requirements.
“The City will implement the recruitment plan
303 within 60 days of it being approved by the OPERATIONAL COMPLIANCE
Monitor.”
“CDP’s recruitment plan will include specific

strategies for a rac ng a diverse group of
applicants,” including officers with various,
specific, expressly-listed skills and backgrounds.
“In developing and implemen ng its recruitment

plan, CDP will consult with the [Community Police]
305 Commission and other community stakeholders PARTIAL COMPLIANCE
on strategies to a ract a diverse pool of
applicants.”
“[O]bjec ve system for hiring and selec ng
306 recruits” that “employs reliable and valid selec on PARTIAL COMPLIANCE
criteria.”
“CDP will report annually to the public its
recrui ng ac vi es and outcomes,” which will
include informa on on various, expressly-listed
areas.
51

“[A]ll candidates for sworn personnel posi ons”
will have “psychological and medical examina on”
and be subject to “drug tes ng.” Exis ng officers
receive “random drug tes ng.”
“CDP will conduct thorough, objec ve, and mely
background inves ga ons of candidates for sworn
posi ons” that cover various, expressly-listed
topics.
“CDP will request to review personnel files from
candidates’ previous employment and, where
310 possible, will speak with the candidate’s OPERATIONAL COMPLIANCE
supervisor(s)” and maintain any “salient
informa on . . . in candidate’s file.”
“If a candidate has previous law enforcement
experience, CDP will complete a thorough,
311 objec ve, and mely pre-employment PARTIAL COMPLIANCE
inves ga on” addressing various expressly-
iden fied things.
“CDP will ensure that officers who police
professionally and effec vely are recognized
through the performance evalua on process” and
312 “are iden fied and receive appropriate NON-COMPLIANCE
considera on for performance.” Likewise, “poor
performance” must be “reflected in officer
evalua ons.”
“The City will develop and implement fair and
consistent prac ces to accurately evaluate officer
313 performance in areas related to integrity, NON-COMPLIANCE
community policing, and cri cal police func ons,
on both an ongoing and annual basis.”
CDP will use “a formalized system documen ng
the annual performance evalua ons of each
officer by the officer’s direct supervisor,” including
314–315 an assessment of several expressly-listed areas. NON-COMPLIANCE
“Supervisors will meet with the employee whose
performance is being evaluated to discuss the
evalua on.”
“CDP will hold supervisors of all ranks accountable
316 for conduc ng mely, accurate, and complete NON-COMPLIANCE
performance evalua ons of their subordinates.”
“The City will develop and implement fair and
consistent promo on prac ces that comport with
317 the requirements of this Agreement and result in NON-COMPLIANCE
the promo on of officers who are effec ve and
professional.”
In considering promo on, “appoin ng authority
318 NON-COMPLIANCE
will consider” specific, expressly- listed “factors.”
“CDP will complete a comprehensive staffing study
to assess the appropriate number of sworn and
52

civilian personnel to perform the func ons
necessary for CDP to fulfill its mission and sa sfy
the requirements of the” Consent Decree. / “CDP
will develop an effec ve, comprehensive Staffing
Plan that is consistent with its mission, including
community and problem-oriented policing, and
that will allow CDP to meet the requirements of”
the Consent Decree.
320 Requirements of CDP Staffing Plan. PARTIAL COMPLIANCE
“The City and CDP will employ best efforts to
321 implement the Staffing Plan over the period of PARTIAL COMPLIANCE
me set forth in the approved plan.”
10. Supervision
“CDP will ensure that first line supervisors provide
322 close and effec ve supervision of officers” in a PARTIAL COMPLIANCE
number of express, specifically-iden fied ways.
“CDP will develop and implement supervisory
training for all new and current supervisors” that is
323 “adequate in quality, quan ty, type, and scope, and PARTIAL COMPLIANCE
will include” a number of specific, expressly-listed
topics.
“Therea er all sworn supervisors will receive
adequate in-service management training.”
“CDP will hold supervisors directly accountable for
the quality and effec veness of their supervision,
325 including whether supervisors iden fy and PARTIAL COMPLIANCE
effec vely respond to misconduct and ensure that
officers effec vely engage with the community.”
CDP “will create a plan to modify its Officer
Interven on Program (‘OIP’) to enhance its
326 effec veness as a management tool to promote NON-COMPLIANCE
supervisory awareness and proac ve iden fica on
of poten ally problema c behavior among officers.
“CDP supervisors will regularly use OIP data to
327 evaluate the performance of CDP officers across all NON-COMPLIANCE
ranks, units, and shi s.”
“The OIP will include a computerized rela onal
database that will be used to collect, maintain,
328 NON-COMPLIANCE
integrate, and retrieve data department-wide” in a
number of specific, expressly-iden fied areas.
“CDP will set threshold levels for each OIP indicator
that will trigger a formal review, and the thresholds
329 NON-COMPLIANCE
will allow for peer-group comparisons between
officers with similar assignments and du es.”
330-336 Addi onal express requirements of OIP. NON-COMPLIANCE
53

“If CDP chooses to use body worn cameras, CDP
will provide clear guidance and training on their
use, and will implement protocols for tes ng
337 equipment and preserva on of recordings to foster OPERATIONAL COMPLIANCE
transparency, increase accountability, and build
trust, while protec ng the privacy rights of
individuals.”
“Supervisors will review recordings related to any
incident involving at least a Level 2 or 3 use of force;
injuries to officers; and in conjunc on with any
other supervisory inves ga on.”
“Supervisors will conduct adequate random and
directed audits of body worn camera recordings”
339 and “incorporate the knowledge gained from this PARTIAL COMPLIANCE
review into their ongoing evalua on and
supervision of officers.”
“Officers will be subject to the disciplinary process
for inten onal or otherwise unjus fied failure to
ac vate body worn cameras in viola on of CDP
policy.”
54
Cleveland Police Monitoring Team | 14th Semiannual Report | April2024
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Case: 1:15-cv-01046-SO Doc #: 524-1 Filed: 04/15/24 1 of 59.

14th Semiannual Report

The Independent Monitoring Team

Dr. Randolph Dupont Lisa Fink

Rick Myers Katie O’Brien

Rory Pulvino Victor Ruiz

Areas of Progress .............................................................................................................. 27

I. Letter from the Monitor

The City's leadership would do well to follow suit.

II. Understanding this Report

III. Executive Summary

The City appears committed to establishing greater trust with the

Non-Compliance Partial Compliance Operational Compliance General Compliance

*** No changes recommended since the 13th Semiannual Report.

Community and Problem-Oriented Policing

There are no significant changes to report in the area of Community

Non-Compliance Partial Compliance Operational Compliance General Compliance

*** No changes recommended since the 13th Semiannual Report.

While CDP made incremental progress relative to bias-free policing,

Non-Compliance Partial Compliance Operational Compliance General Compliance

*** No changes recommended since the 13th Semiannual Report.

In order for the City to receive an upgrade in its compliance score,

Non-Compliance Partial Compliance Operational Compliance General Compliance

Non-Compliance Partial Compliance Operational Compliance General Compliance

*** No changes recommended since the 13th Semiannual Report.

Non-Compliance Partial Compliance Operational Compliance General Compliance

Search and Seizure

Search and seizure progress has disappointingly stalled. Following

Non-Compliance Partial Compliance Operational Compliance General Compliance

*** No changes recommended since the 13th Semiannual Report.

The City is required to maintain a disciplinary system that is “fair,

The Office of Professional Standards (OPS) is charged with

new OPS Administrator has been making strides to formalize

The Police Review Board (PRB) reviews OPS investigations and

Non-Compliance Partial Compliance Operational Compliance General Compliance

Transparency and Oversight

Non-Compliance Partial Compliance Operational Compliance General Compliance

¶ 250, ¶ 251, ¶ 252,

*** No changes recommended since the 13th Semiannual Report.

Officer Assistance and Support

CDP has made significant progress on its overall training program.

Non-Compliance Partial Compliance Operational Compliance General Compliance

*** No changes recommended since the 13th Semiannual Report.

First line supervisors remain the primary drivers of meaningful

Non-Compliance Partial Compliance Operational Compliance General Compliance

*** No changes recommended since the 13th Semiannual Report.

IV. Complete Findings

2. Community and Problem-Oriented Policing

6. Search and Seizure

Office of Professional Standards: No progress to report.

Police Review Board: No progress to report.

8. Transparency and Oversight

9. Officer Assistance and Support

11. Outcome Assessments

PARAGRAPH # DESCRIPTION STATUS OF COMPLIANCE

2. Community and Problem-Oriented Policing

Ensuring “that oﬃcers are familiar with the

PARAGRAPH # DESCRIPTION STATUS OF COMPLIANCE

PARAGRAPH # DESCRIPTION STATUS OF COMPLIANCE

PARAGRAPH # DESCRIPTION STATUS OF COMPLIANCE