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HomeMy WebLinkAbout03-02-1999 CommunicationFebruary 25, 1999 Douglas S. Russell, Attorney at Law Stein, Russell and Pugh, LLP PO Box 2416 Iowa City, IA 52244 Re: Police Citizens Review Board Dear Doug: CITY OF IOWA CITY HAND DELIVERED Enclosed you will find drafts of the revisions to the PCRB's standard operating procedures and the PCRB ordinance. 1 have not put the changes to the ordinance in ordinance form, but rather, have just redlined the current ordinance as the changes are easier to address that way. The enclosed draft of the SOP concerning summary dismissal does not include an interview of the complainant in executive session. As I told you by phone, because at this stage there will have been no police investigation I am concerned that there is not an exception to the open meetings law that would allow this interview to be held in closed session. Use of Section 21.5(a) in tandem with 22.7(18) (communications not required by law made to a government body when the government body can reasonably believe that the communication would be discouraged if it was subject to public examination) may be applicable in some situations but this would clearly be a case -by -case analysis. For example, if the complainant is speaking to the press it is likely unreasonable to assume they are concerned about the confidentiality of their statement. When we spoke, it was my understanding that you did not think the inability to hold an interview in closed session would be a big problem given that a subcommittee of the Board can simply interview the complainant. With respect to the changes to the ordinance, I have taken the liberty of including a new section on time computation which is based on Iowa Code Section 4.1, subsection 34. It seems to me that this rule will take care of some of the more obvious time issues. Congratulations again on your judicial appointment. Lawyers and litigants of Johnson County are lucky to have you. As we discussed, given your experience with the Board it might be helpful for you to offer your suggestions concerning the qualifications their counsel should possess before your departure. In addition to identifying the substantive areas that are most important, we may want to consider requiring a minimum amount of practice experience. The Council has changed its March 23 meeting to March 30 so I will shoot for putting these revisions on that agenda. I look forward to hearing from you. �V truly yours, yy�l ca-`-Qq'L__ Eleanor M. Dilkes City Attorney Enclosure cc: Marian Karr, City Clerk Sarah Holecek, First Assistant City Attorney RJ Winkelhake, Police Chief Stephen Atkins, City Manager EleanorV Adr2-24.doc 410 EAST WASHINGTON STREET • IOWA CITY. IOWA 52240-1636 •,f519) 556-5000 • FAX (519) 556-5009 BkCEIVED FEB 2 5 1999, CITY OF IOWA CITY IOWA POLICE CITIZENS REVIEW BOARD STANDARD OPERATING PROCEDURES AND GUIDELINES [ Proposed Revisions 2/25/99] The PCRB was established to assure that investigations into claims of police misconduct are conducted in a manner which is fair, thorough and accurate and to assist the Police Chief, the City Manager and the City Council In evaluating the overall performance of the Police Department as a whole by having it review the Police Deportment's investigation into complaints. To achieve these purposes, the PCRB shall comply with Chapter 8 of the Iowa City Code, the Board's By -Laws, and the Police Citizens Review Board's Standard Operating Procedures and Guidelines. PCRB SOP 9198 TABLE OF CONTENTS Page I. Complaint Process.....................................................................................1-2 II. Formal Mediation Guidelines and Procedures ........................................... 2 III. Meetings...................................................................................................3-5 IV. Complaint Review Process.......................................................................5-7 V. Review of Policies, Procedures and Practices of the Iowa City PoliceDepartment.....................................................................................7-8 VI. Annual Report ........................................................................................... 8 VII. General......................................................................................................8-9 VIII. Appendix A. The City Code of Iowa City, Chapter 8, Police Citizens Review Board B. Iowa City Police Citizens Review Board By -Laws C. City of Iowa City Police Citizens Review Board Guidelines and Procedures for Formal Mediation D. Section 21 of The Code of Iowa Official Meetings Open to Public (Open Meetings) E. Section 22 of The Code of Iowa, Examination of Public Records (Open Records) F. Police Citizens Review Board Complaint Form PCRB SOP-9/98 I. Complaint Process In an effort to assure the citizens of Iowa City that the Iowa City Police Department's performance is in keeping with community standards, the PCRB shall review investigations into complaints of police misconduct to insure that such investigations are conducted in a manner which is fair, thorough and accurate. The PCRB shall achieve this by receiving, reviewing and reporting on citizen complaints in accordance with the procedural rules in Chapter 8 of the City Code, following the Police Citizens Review Board By -Laws, Article VIII, and the Board's Standard Operating Procedures and Guidelines. A. Complaints shall be filed in accordance with 8-8-3 C and 8-8-7 A of the City Code of Iowa City. 1. All documents and related materials filed with the Board shall not be returned. 2. Complaints filed in the City Clerk's Office shall be assigned a complaint number consisting of the last two digits of the present year with consecutive numbers, starting with one (1) (e.g. 98-1). The complaint copy sent to Board members shall have all references to police officer names and other identifying information deleted, although the reports of Procedure for complaints subject to summary dismissal 1. A complaint that appears to be untimely filed or a complaint that does not involve the conduct of an Iowa City sworn police officer shall be assigned a number in the ordinary manner as provided in the City Code. 2. A copy of the complaint shall be furnished to the Police Chief or City Manager, with a cover letter indicating that it appears to be an untimely complaint or a complaint that does not involve the conduct of an Iowa City sworn police officer and will be reviewed by the Board at its next regular or special meeting. 3. A copy of the complaint shall be provided to Board members in the next meeting packet; PCRB SOP-81982M - 1 MWI aecision.tne board snau, oy mouon in open session, vote to aetermine whether the complaint will be dismissed under Section 8-8-3 JE)=of the ordinance. The Board shall not discuss the facts or substance of the complaint at said open meeting. 6. If the Board dismisses the complaint the staff shall forward a copy of the decision to the Police Chief or the City manager and also to the complainant. a. The copy going to the Chief or City Manager shall state that the complaint has been dismissed and that a report to the Board by the Chief or City Manager is not required by Chapter 8 of the Code. The Board may request that an investigation be done. b. The copy of the decision sent to the complainant shall include a cover letter advising that although the complaint has been dismissed and will not be reviewed by the PCRB, there is a method for the complainant to file a complaint directly with the Iowa City Police Department that is still available should the complainant wish to pursue the matter. 7. If the Board determines the complaint shall not be dismissed, it shall so advise the Police Chief or City Manager so they may continue their investigation and make their required report to the PCRB. C. Amendments to a complaint must be in written form. D. The complainant may withdraw the complaint at any time prior to the Board's issuance of its report to City Council.. It. Formal Mediation Guidelines and Procedures Formal mediation is the responsibility of the PCRB and is offered as a method to facilitate a successful resolution of the issues involved in a complaint. The PCRB shall accomplish this responsibility by complying with 8-8-2 H. 8-8-4 and 8-8-7 of the City Code and the PCRB Guidelines and Procedures for Formal Mediation, approved by the City Council on March 10, 1998 and made a part hereof. III. Meetings PCRB SOP-9=2f - 2 Regular meetings shall be held monthly. Special meetings may be called by the Chair as needed. The Board shall comply with Article V of the PCRB By -Laws and the PCRB Standard Operating Procedures and Guidelines. A. Meeting packets shall be distributed to Board members at least two (2) days prior to a meeting when possible. B. Place of Posting Notices and Agendas. 1. Follow requirements of Section 21.4, The Code of Iowa. 2. The City of Iowa City provides the Notice Bulletin Board in the lobby of the Civic Center; notice of a meeting will also be distributed in media boxes located in the Civic Center. C. Consent Calendar shall include: 1. Minutes of the last meeting(s); 2. Correspondence and/or memoranda directed to the PCRB (not complaint -related). Staff shall be given directions based on Board discussion as to whether staff shall respond or whether Board members shall respond, with copies furnished to the Board. D. Time for open public discussion shall be made available at all open meetings as provided by the PCRB By -Laws, Article V, Section 6. E. Time for "Board Information" and "Staff Information" shall be made available at all meetings. F. Decisions made in executive session shall be ratified in open session. G. Taped minutes of open meetings shall be kept thirty (30) days from acceptance and approval of minutes. H. Taped minutes of executive meetings shall be kept for one year from the date of the meeting. To the extent practicable, legal counsel for the PCRB shall attend all meetings of the Board. J. Electronic Participation 1. Follow the requirements of Section 21.8, The Code of Iowa for "electronic meetings.". "Electronic meetings" as defined in this section presumes electronic participation is necessary for a quorum. 2. Electronic participation in meetings. A member may participate by electronic means when the member's presence is not necessary for a quorum, and said member shall have all rights as if participating in person.. PCRB SOP-9/882M - 3 1 K. Quorum and Voting Requirements 1. Quorum. See By -Laws V.2. 2. Voting. See By -Laws V. 10. 3. Voting to close a session. See Section 21.5, The Code of Iowa. L. Iowa Open Records Law 1. The Board must follow all the requirements of Chapter 22, The Code of Iowa, Examination of Public Records (Open Records). This means every person has the right to examine and copy the public records of the PCRB pursuant to that Chapter. 2. The lawful custodian of the PCRB public records is the City Clerk of Iowa City. If the City Clerk requires legal counsel concerning whether a document is public or confidential, she shall notify both the City Attorney's Office and counsel to the PCRB of the request. 3. All records of the Board shall be public except as specifically provided for in Chapter 22, The Code and in the PCRB By -Laws. 4. Confidentiality of complaints, reports of investigations, statements and other documents or records obtained in investigation of any complaint. See By -Laws VI1.1(a). 5. Confidentiality of the minutes and tape recordings or closed sessions. See By -Laws VI1.1(b). 6. Confidentiality of mediation matters. See By -Laws VII.1(d). 7. Confidentiality of information protected by the Iowa Open Records Law or the Iowa Open Meetings Law. See By -Laws VII.1(c). M. Iowa Open Meetings Law. The Board must follow all the requirements of Chapter 21, The Code of Iowa, Official Meetings Open to Public (Open Meetings). N. Conflicts of Interest and Ex Parte Contacts 1. Conflicts of Interest. See By -Laws V.9. 2. Ex Parte Contacts. See By -Laws, V.8. IV. Complaint Review Process The Board shall review all Police Chiefs reports and City Manager's reports concerning complaints utilizing Sections 8-8-6, 8-8-7 and 8-8-8 of the City Code and the PCRB Standard Operating Procedures and Guidelines. PCRB SOP 8/882M - 4 1 A. Review of Police Chiefs report or City Manager's report. Follow 8-8-7 B of the City Code. Select a level of review as outlined in 8-8-7 B. 1 (a)-(f) of the City Code. The Board shall notify the Complainant and the Police Chief, or the City Manager if the complaint is against the Chief, of the selected level of review. The Chief shall notify the officer of the selected level of review. C. Request for an extension of time to file PCRB public report. Refer to 8-8-7 B.6 of the City Code. D. The PCRB shall not issue a public report critical of a police officer until after a name -clearing hearing has been held or waived by the police officer. Refer to Section 8-8-7 B.4 of the City Code. E. Name -clearing hearing procedure 1. If the Board determines that the comments or findings contained in its proposed report will be critical of the conduct of a sworn police officer, it must offer the officer a name -clearing hearing prior to the issuance of the Board's report to Council. 2. The Board shall select a proposed date for the name -clearing hearing. 3. Written notice of the date, time and place of the name -clearing hearing shall be given to the officer no less than ten working days prior to the date set for hearing. The notice to the officer should be transmitted via the Chief of Police. The notice to the officer shall provide a written response form for the officer to demand or waive the name -clearing hearing. Said written response form shall also allow the police officer to state whether he or she requests an open or closed session. 4. If the officer provides a written waiver of the name -clearing hearing prior to the date set for hearing, the hearing shall not be held. 5. If the officer does not respond to the notice prior to the time of the hearing, the hearing shall be convened. If the officer does not appear, the hearing shall be terminated. 6. If the officer demands a hearing or appears at the hearing, the Board will first determine whether the hearing shall be open or closed. If the officer requests a closed session, the Board shall close the session pursuant to motion specifically identifying Section 21.5(1)(i) and 21.5(1)(a) of the Iowa Code as the basis for closure. If the officer does not request a closed session the session shall be open except where closure is appropriate pursuant to Section 21.5(1)(a). 7. At the hearing the Board shall advise the officer of the Board's proposed criticism(s) and evidence supporting the same. The officer shall be given the opportunity to be heard and to present additional evidence, including the testimony of witnesses. 8. If, subsequent to a name -clearing hearing or waiver of a name -clearing hearing by the officer, the Board changes its level of review, it shall issue a new written notice pursuant to subparagraph B. hereof. If, following said change, the proposed report is critical of the PCRB SOP-91992M - 5 1 sworn officer's conduct, the Board shall offer another name -clearing hearing to the officer pursuant to the name -clearing hearing procedures herein. 9. The complainant shall not receive a notice of, or have the right to participate in, a name - clearing hearing. F. Report Writing — Follow 8-8-7 of the City Code 1. The Chair shall appoint a committee to prepare draft reports. The committee may request assistance from staff as needed. 2. When possible, a draft report shall be included in the agenda packet prior to the meeting at which it is discussed. 3. Draft reports shall be discussed in executive session and finalized by the full Board. 4. Draft reports shall be confidential. 5. Final Public Reports shall be reviewed by legal counsel to the PCRB before being submitted to the City Council. G. Final PCRB Public Reports shall be distributed according to 8-8-7 B.3 of the City Code. The copy sent to the City Council shall be accompanied by the minutes of the meeting which approved it and be sent to the City Clerk for inclusion in the next Council agenda packet. H. Once the Public Report is sent to designated parties, the complaint file is closed and is taken to the City Clerk's Office for retention. V. Identification of Officers Vl. Review of Policies, Procedures and Practices of the Iowa City Police Department As stated in the City Code, 8-8-7 C(3), and Article 11 of the PCRB By -Laws, and using the PCRB Standard Operating Procedures and Guidelines, the Board shall, from time to time, report to the City Council on policies, procedures and practices of the Iowa City Police Department, including recommended changes, if appropriate. A. Policy -review discussions shall be held at regular meetings, when possible. PCRB SOP-"82/99 - 6 1 B. When citizens have a concern about police procedures or practices, but there is no allegation of individual officer misconduct, there may be an issue of policy. Any citizen or Board member may raise an issue at a PCRB meeting. C. The Board encourages signed written correspondence from citizens but will accept anonymous correspondence concerning policies, procedures, and practices of the Iowa City Police Department. VII. Annual Report The PCRB shall maintain a central registry of all formal complaints against sworn police officers and shall provide an annual report to the City Council which will give the City Council sufficient information to assess the overall performance of the Iowa City Police Department. 8-8-2 M and 8-8-7 C.2 of the City Code, Article VII1.5 of the PCRB By - Laws, and the PCRB Standard Operating Procedures and Guidelines A. The annual report shall include information required by Chapter 8 of the City Code. B. The PCRB's annual report may also include recommendations to amend the Ordinance. Vlll. General A. The lawful custodian of the PCRB records and the central depository for all information is the City Clerk's Office of the City of Iowa City. B. The Chair is the official spokesperson for the PCRB. C. When legal counsel and/or staff are contacted on PCRB business, they shall report that information to the Chair and to each other. D. Contacts between a Board member and the Police Chief and/or City Manager shall be in the form of written communication when possible. E. Requests for information from the Board to the Police Chief or City Manager shall be in writing. F. The PCRB administrative assistant shall provide to the Board a monthly "PCRB Office Contacts Report," stating the number of telephone calls and in -office contacts which come directly to the PCRB office, the general substance of such contacts, and their disposition. G. Voice Mail telephone messages to the PCRB office from citizens shall not be retained nor will messages be transcribed unless there are extenuating circumstances on a case -by -case basis determined by legal counsel for the PCRB and the City Attorney's Office. H. The Board shall utilize its own letterhead stationery. e1eanor\perbgde2.doc 8-8-3: DEFINITION OF COMPLAINT; COMPLAINT PROCESS IN GENERAL: D. All complaints must be filed with either the Board or the Iowa City Police Department within sixty (60) ninety.JaUdays of the alleged misconduct. E. Only those complaints which do not involve the conduct of an Iowa City sworn police officer or are not filed within sixty -(&A) Lllr days of the alleged misconduct may be subject to summary dismissal by the Board. (Ord 97-3792, 7-15-1997) 8-8-6: POLICE CHIEF'$ REPORT TO THE BOARD: CITY MANAGER'S REPORT TO THE BOARD: E. The Police Chief's report to the Board shall be completed within-0;i41y438) uinf . 229) calendar days after complaint is filed. The Board may grant extensions from the deadline for good cause shown. 8-8-7: DUTIES OF THE BOARD; COMPLAINT REVIEW AND GENERAL DUTIES: B. Review of Police Chiefs Report or City Manager's Report: 6. The Board's report to the City Council shall be completed within th4ty-(3p)-lp five. (4acalendar days of receipt of the Chiefs or City Manager's report. The City Council may grant requests for extensions to this deadline upon good cause shown. D-5-11:TI.ME OMPU.LA-RON I rgaNdn:mm4xYllyuusµn rAx: City of Iowa City MEMORANDUM Date: February 23, 1999 To: City Council From: Mayor Re: Police Citizens Review Board Our recent discussions with the PCRB have given me reason to reassess the purpose for which they were set up and to evaluate, in my own judgment, how they are doing. As we all remember, the Board was established to review complaints filed against the police and determine the validity of these complaints. To date these evaluations have proven what many of us already suspected, that we have a competent and professional police department. I have been particularly impressed with the thoroughness of their deliberations and their efforts to protect the identity of the officers involved. In this regard, I am particularly curious as to why they feel it is necessary to track an officer's identity before they resolve the complaint. It would appear that the same purpose could be served by revealing the identity after resolution of the complaint. I have asked the chairperson of the board to elaborate in writing why they feel so strongly about this. I indicated my agreement to allow this information for several reasons. First, I feel that we as a Council have set up this board for a specific purpose. Although I do not understand why prior identification is necessary, I feel we should respect their wishes until such time as their procedures prove to be unfair or arbitrary. Second, their actions to date relative to protecting an officer's identity have convinced me of their honesty and sincerity. Third, even if their actions prove not to be impartial, they have no authority other than to recommend to the Chief and the Council. Fourth, our refusal to allow their request will be viewed by those who are critical of the Police Department as an effort on the part of the Council to prevent them from doing what they were set up to do. I believe we need to take a more constructive view of this board. In most cities that have such a board, they end up being proof positive of the quality of their police departments. Our board is finding the same thing right here in Iowa City. Their job is just as much to affirm the quality of our police, as it is to point out its weaknesses. To date, their reports have confirmed our belief that we have a fine police department. We need to realize that the PCRB can be a valuable tool for the Council and the Chief to show the dedication of our police force in serving the public. Our failure to support the PCRB gives the public, whether right or wrong, a reason to suspect our motives. While this board is indeed an arm of the Council and, as with any board, should be monitored closely, we should either support them or reevaluate their importance to the community. cc: �CRB Eleanor Dilkes, City Attorney wunciNnemos\PCRB.doc POLICE CITIZENS REVIEW BOARD A Board of the City of Iowa City 410 East Washington Street Iowa City IA 52240-1826 (319)356-5413 February 25,1999 Mayor Ernest W. Lehman Iowa City Civic Center 410 East Washington Street Iowa City IA 52240 RE: Police Citizens Review Board Dear Mayor: COPY You contacted me on Friday, February 12, 1999, and requested a letter of clarification concerning the request of the Police Citizens Review Board to have officer identifying numbers for a particular complaint before the Board deliberates on that complaint. We understand from our joint meeting with the City Council on February I Vh that the Council agrees we should receive identifying numbers and that when we should receive those numbers is the sole remaining issue. The Board continues to believe that it is important that it receive the identifying numbers of all officers involved in a PCRB complaint, and information about which previous PCRB complaints named that officer or officers, before it deliberates on the Chief's (or City Manager's) report. The purpose of the information is twofold. First, it allows the Board to track the behavior of particular officers over the entire period of the Board's existence. Second, it allows the Board to use the information to assist in its review of the Chief's (or City Manager's) determinations regarding the credibility of a particular officer, where appropriate and relevant to a pending complaint. The first function may be served by giving the Board the identifying number after the complaint has been decided upon. The second function may be served only if the information is received before the Board deliberates on a pending complaint. In reviewing a report on a citizen complaint, the Board's only role is to review the reasonableness of the determinations made by the Chief of Police (or the City Manager). Imagine a situation in which a complainant's version of the story and the officer's version of the story differ substantially. In reviewing the report prepared on such a complaint, the Board must decide whether the Chief s decision to credit one version over the other was reasonable. In making that assessment, information about the participants --the officer as well as the complainant — is clearly relevant. The Chief certainly knows the officer's history; the Board must have information about the officer's prior involvement to make a fair assessment of the Chief s (or City Manager's) review of the matter. Mayor Ernest Lehman Page 2 The information requested is, in itself, neutral. The fad that an officer was named in a previous complaint will not prejudice the Board for or against the officer, and the resolution of a prior complaint might reflect positively as well as negatively on an officer's truthfulness. Nor is the information requested so the Board may draw the impermissible inference that an officer complained against in a prior instance is more likely to have committed misconduct. The Board appreciates the airing of the Council's concerns about the proper and improper use of the identifying number of an officer. The Board and the City Attorney are working out guideline language for a new SOP to address the Council's concerns on this issue. Nonetheless, the Board strongly believes that as long as the City Council keeps the Board in existence, it must trust the Board to operate within its standard operating procedures with all relevant information that may properly affect its decisions. The PCRB was conceived as a response to a community tragedy. Its still -evolving role reflects the importance of protecting the rights of individual officers as well as the community's need for effective police oversight. That balance is reflected in the statutory responsibilities imposed on the PCRB by the City Council. While they confirm the City's commitment to external accountability for the Iowa City Police Department, they also reflect stringent limits on the Board's authority. The Board recognizes the judicious balance incorporated in the PCRB ordinance and has, in turn, sought to be balanced and judicious in its approach to its work. Consistent with this approach, one of the Board's first unanimous decisions was that we did not wish to know the identity of officers, but would be satisfied to work with a system of unique but anonymous identifiers of the Chiefs own devising. We continue to be willing to work with staff to resolve whatever problems arise with implementing this system. A board like the PCRB can never please everybody. We will be viewed, depending on one's politics and predisposition, as essential to the function of the community or an intrusive annoyance, as having too much power or too little, as presuming and doing too much or showing too little effect. We are prepared to live with that, but feel the need to stress the importance of maintaining the balance that is built into the ordinance. That balance requires that the Board be provided with the information it needs — including the identifying numbers of officers named in complaints — so that it may fulfill its duties under the ordinance and make fully informed decisions. Respectfully, /S/ Leah Cohen, Chair Police Citizens Review Board POLICE CITIZENS REVIEW BOARD A Board of the City of Iowa City 410 East Washington Street Iowa City IA 52240-1826 (319)356-5413 February 25, 1999 R. J. Winkelhake, Chief of Police Iowa City Police Department 410 E. Washington Street Iowa City IA 52240 Dear Chief Winkelhake: kC ��' I (a pY This is to confirm our telephone conversation of February 24 acknowledging your availability to make a presentation on the Special Crimes Action Team at the PCRB Community Forum on Wednesday, April 28, 1999, at 7:00 P.M., at the Broadway Neighborhood Center. If there is any information you would like to appear on the notice for this forum relating to your presentation, please let me know. I will keep you advised as plans are made. Thank you for your continuing cooperation and assistance. Sincerely, Sandra Bauer, Assistant Police Citizens Review Board cc: Board members I/ Douglas Russell City Council Eleanor Dilkes MEMORANDUM POLICE CITIZENS REVIEW BOARD A Board of the City of Iowa City 410 East Washington Street Iowa City IA 52240-1826 (319)356.5413 TO: Eleanor Dilkes, City Attorney v O1py FROM: Sandy Bauer, Assistant to the PCRB RE: Complaint Forms DATE: February 25, 1999 Attached is the draft of the information sheet for the Police Department complaint form and the PCRB complaint form. Would you please review and forward any comments to the Board. . Thank you for your continuing assistance in these matters. cc: Board members Doug Russell You want to file a complaint about an Iowa City police officer. Which complaint form should you use? There are two kinds of complaint forms. The form you choose determines how your complaint will be handled. 1. Iowa City Police Department Complaint Form If you use the Police Department form, your complaint will be investigated by the Iowa City Police Department. You will be notified about the outcome of the investigation. Police Department investigations are handled internally. This kind of investigation usually takes from xx to xx months. [This section may need to be expanded by the CityAttorneyd 2. Police Citizens Review Board (PCRB) Complaint Form If you use the PCRB form, your complaint will be investigated by the Iowa City Police Department. But, as soon as you file your form, the PCRB will receive a copy of it, so they know your complaint is being investigated. When the Police Department has finished its investigation, the Police Chief will prepare a written report for the PCRB. The PCRB will study the report to decide whether they agree with the Chief's findings. The Board may also conduct its own investigation of your complaint before preparing its own report for the City Council. You will be notified of the outcome of the PCRB's review. The PCRB handles its work with complaints confidentially and does not release the names of citizens or police officers. However, the media may report information about PCRB decisions. This kind of investigation, including the time required by the Police Department and the time required by the PCRB, usually takes between xx and xx months. If you have questions about choosing a form, contact the Police Department (356-5275) or the PCRB Office (356-5413) B-8-1 CHAPTER POLICE CITIZENS' REVIEW BOARD SECTION: 8-8- 1: Creation Of A Police Citizens' Review Board 8-8- 2: Intent, Goals And Guiding Principles 8-8- 3: Definition Of Complaint; Complaint Process In General 8-8- 4: Formal Mediation 8-8- 5: Police Department And Police Chief Investigatory Duties; City Manager Investigatory Duties 8-8- 6: Police Chief's Report To The Board; City Manager's Report To The Board 8-8- 7: Duties Of The Board; Complaint Review And General Duties 8-8- 8: Board Composition; Limited Powers Of The Board 8-8- 9: Police Officer's And Complainant's Rights Preserved 8-8-10: Sunset Clause 8-8-1: CREATION OF A POLICE CITIZENS' REVIEW BOARD: As permitted under Iowa's home rule au- thority, the City hereby creates a Police Citizens' Review Board, to be hereafter referred to as the "Board", subject to the duties and limited powers set forth herein. (Ord. 97-3792, 7-15-1997) 8-8-2: INTENT, GOALS AND GUID- ING PRINCIPLES: A. Investigations into claims of inappro- priate conduct by sworn police officers 8-8-2 will be conducted in a manner which is fair, thorough, and accurate. B. An annual reporting system regarding complaints against sworn police offi- cers will be established to give the City Council sufficient information to assess the overall performance of the Iowa City Police Department in these matters. C. The Board will: 1.Oversee a monitoring system for tracking receipt of complaints lodged against sworn police officers; 2. Provide oversight of police investi- gations through review of such investi- gations; (Ord. 97-3792, 7-15-1997) 3. Provide the opportunity for a hear- ing to the police officer if the Board's findings on the complaint are critical of the police officer, as required by constitutional law, and give the police officer the opportunity to present testi- mony and evidence; (Ord. 98-3865, 12-15-1998) 4. Issue a final public report on each complaint to the City Council which sets forth factual findings and a writ- ten conclusion which explains why and the extent to which the complaint is either "sustained" or "not sus- tained". D. The Board shall have no authority over police disciplinary matters be- 299 Iowa City 8-8-2 cause only the Police Chief or City Manager may impose discipline under Iowa law. E. No findings in the Board's report shall be used in any other legal proceeding. F. The Board shall only review the con- duct of sworn police officers and shall only act in a civil, not criminal, capaci- ty. The Board is not intended to be a court of law, a tort claim process or other litigation process. No action of the Board shall be deemed to diminish or limit the right of any person to file a claim or a lawsuit against the City. G. A complaint may be filed by any per- son with personal knowledge of an incident. "Personal knowledge" means the complainant was directly involved in the incident or witnessed the inci- dent. If the person with personal knowledge is underage or otherwise unable to complete a complaint form, the complaint may be filed by such person's designated representative. The City Manager, the Police Chief, the City Council, or the Board may file a complaint based upon a reasonable belief that police misconduct has oc- curred regardless of personal knowl- edge. H. In order to assure that people feel confident in the complaint process, nonpolice City staff shall be available at a public location other than the Police Department to receive com- plaints, although complaints may also be filed at the Police Department. Formal mediation shall be available to the complainant(s) and the police officer(s) at any time during the pro- cess. [:11.1% I. The Board shall not interfere with or diminish the legal rights of sworn police officers, including those rights protected under the union contract, Civil Service Commission, and State and Federal law. Similarly, the Board shall respect the rights of privacy and freedom from defamation shared by complainants and witnesses, as well as those same rights enjoyed by po- lice officers under the law. J. The City Council finds that internal accountability within the Police De- partment is a valid legislative purpose, and one method of accomplishing such internal accountability is to have the police do their own investigations into claims of inappropriate police conduct. If a complaint is asserted against the Police Chief, the City Manager will investigate the claim and report to the Board and the City Coun- cil. K. Investigation of all formal complaints is a mandatory duty of the Police Chief, and a report of each complaint investigation shall be given to the Board. Such reports to the Board shall include the factual findings of the Police Chief as well as a written con- clusion explaining why and the extent to which a complaint is either "sus- tained" or "not sustained". However, such reports shall not include disci- pline or other personnel matters. If the Police Chief and the City Manager find the police officer's actions constitute misconduct and discipline is imposed by the Police Chief or City Manager, the internal affairs investigation may become a public record to be released 299 Iowa City l by the City Attorney to the extent provided by law. L. In order to assure external account- B. ability of the actions of the Police Department, all formal complaint in- vestigations shall be reviewed by the Board and reported to the City Coun- cil. M. External accountability will further be provided by the Board's maintenance of a central registry of all formal com- plaints. In addition to the central regis- try, the Board shall provide an annual report to the City Council, which report shall be public and shall set forth the general types and numbers of com- plaints, how they were resolved, de- mographic information, and recom- mendations as to how the Police De- partment may improve its community relations or be more responsive to community needs. N. The Board shall have oversight au- thority to review police practices, procedures, and written policies as those practices and procedures relate to the Police Department's perfor- mance as a whole, and shall report same to the City Council, including any recommended changes. (Ord. 97-3792, 7-15-1997) 8-8-3: DEFINITION OF COMPLAINT; COMPLAINT PROCESS IN GENERAL: A. A "complaint" is an allegation of mis- conduct lodged against a sworn police officer ("police officer" or "officer") employed by the Iowa City Police Department, where the complained -of activity occurred while the officer was LIM acting in the capacity of a sworn po- lice officer. Any person with personal knowledge of the alleged police misconduct may file a complaint with the Board or with the Iowa City Police Department. In order to have "personal knowledge", the complainant must have been di- rectly involved in the incident or wit- nessed the incident. If the person with personal knowledge is underage or otherwise unable to complete a com- plaint form, the complaint may be filed by such person's designated repre- sentative. The City Manager, the Po- lice Chief, the City Council or the Board itself may file a complaint based on a reasonable belief that police misconduct has occurred re- gardless of personal knowledge. The person or official filing the complaint may hereafter be referred to as the "complainant". C. All complaints filed with the Board or the Iowa City Police Department shall be in writing and on forms provided by the Board. Complaint forms shall be available to the public in easily acces- sible locations, and nonpolice staff shall be available to receive the com- plaint forms. Assistance may be avail- able to complete the form as designat- ed by the Board. D. All complaints must be filed with either the Board or the Iowa City Police Department within sixty (60) days of the alleged misconduct. E. Only those complaints which do not involve the conduct of an Iowa City sworn police officer or are not filed within sixty (60) days of the alleged misconduct may be subject to summa- 997 Iowa City DMI ry dismissal by the Board. (Ord. 97-3792, 7-15-1997) 8-8-4: FORMAL MEDIATION: A. Formal mediation shall be the respon- sibility of the Board, and shall be available to the complainant(s) and police officer(s) at any stage of the process upon consent of all involved parties and as provided by the Board. Upon the filing of a complaint, all complainants shall be informed that formal mediation is available. A com- plainant may also meet informally with the police officer and the watch com- mander of the police officer if the complainant wishes to do so. B. If a complaint is successfully mediat- ed, the terms of the mediation agree- ment shall be set forth in writing, and shall be kept confidential to the extent allowed by law; but the status of set- tlement shall be maintained in the Board's central registry for reporting in the Board's annual report. There shall be no retaliation against police offi- cers who choose not to mediate. (Ord. 97-3792, 7-15-1997) 8-8-5: POLICE DEPARTMENT AND POLICE CHIEF INVESTIGATO- RY DUTIES; CITY MANAGER INVESTI- GATORY DUTIES: A. Complaints: The Police Department shall forward copies of all complaints received to the Board. If the complaint concerns the Police Chief, a copy of the complaint shall also be forwarded to the City Manager. B. Investigation: It shall be the mandato- ry duty of the Police Chief to do the following: 997 Iowa City 1. Prior to investigation of any com- plaint, the Police Chief shall first give Garrity and Gardner advice to all po- lice officers implicated in the com- plaint, as required by constitutional law. This means the officer cannot be required to waive the officer's consti- tutional right against self-incrimination. However, the officer may be required to answer questions during the inves- tigation as a condition of the officer's employment, but any admissions made by the officer cannot be used against the officer in a criminal pro- ceeding. 2. Notify the complainant and the police officer who is the subject of the complaint that formal mediation is available at any time during the Police Department's investigation and the Board's review. The Police Chief may also notify the complainant that the complainant may meet informally with the police officer and the watch com- mander of the police officer if the complainant wishes to do so. 3. Assign the complaint to designated investigators within the Police Depart- ment for investigation into the factual allegations of the complaint. 4. The complainant shall be inter- viewed by the Police Department and shall be entitled to have a neutral City staff person or some other person chosen by the complainant present during the interview. The police officer is entitled to have a union steward present during any interviews. FEW 5. Investigators will prepare and for- ward a report of their investigation to the Police Chief, and shall make de- tailed findings of fact as to the allega- tions in the complaint, and shall also set forth a written conclusion which explains why and the extent to which the complaint is either "sustained" or "not sustained". C. Legal Advice: If litigation, including criminal charges, relating to the matter of the complaint is commenced or is being contemplated by or against any party to the complaint, the Police Department, the Police Chief and/or the Board shall consult with the City Attorney and/or the Board's own attor- ney on a case -by -case basis, to deter- mine whether and how the investiga- tion of the complaint should proceed. D. Complaints Against Police Chief: If a complaint is filed concerning the Po- lice Chief's conduct, the City Manager shall investigate or cause an investi- gation to be completed. E. Disciplinary Action: Nothing in this Chapter shall prevent the Police Chief or the City Manager from taking disci- plinary action prior to the Board's review of the complaint. (Ord. 97-3792, 7-15-1997) 8-8-6: POLICE CHIEF'S REPORT TO THE BOARD; CITY MAN- AGER'S REPORT TO THE BOARD; A. The Police Chief shall receive the designated investigators' report within the time frame indicated by the Police Chief. The Police Chief shall conduct a review of the investigators' report, and may do any or all of the following: 2W. conduct interviews or request the police investigators to conduct addi- tional investigations; request addition- al information, or that additional ques- tions be asked; interview or direct that other persons or witnesses be inter- viewed; request that other documents be reviewed and/or retrieved; and any other investigative matters the Police Chief deems appropriate. B. The Police Chief will consult with the City Personnel Administrator and the City Attorney prior to finalizing the Police Chief's report to the Board, and shall then forward this report to the Board, which shall include the follow- ing: 1. Detailed written findings of fact concerning the allegations in the com- plaint; 2. A written conclusion which explains why and the extent to which the com- plaint is either "sustained" or "not sustained"; and 3. Recommended remedial actions, if any, including amending current poli- cies or adopting new policies. C. The Police Chief's report to the Board shall not include discipline or person- nel matters. D. A copy of the Police Chief's report to the Board shall be given to the police officer, the complainant, and the City Manager. If the complaint concerns the Police Chief, copies of the City Manager's report to the Board shall be given to the Police Chief, the com- plainant, and the City Council. 997 Iowa City 8-8-6 8-8-7 E. The Police Chief's report to the Board a. On the record with no additional shall be completed within thirty (30) investigation; calendar days after complaint is filed. The Board may grant extensions from b. Interview/meet with complainant; this deadline for good cause shown. c.Interview/meet with named offi- F. All investigations shall be performed cer(s) and other officers; in a manner designed to produce a minimum of inconvenience and em- d. Request additional investigation barrassment to all parties -including by the Police Chief or City Manager, the complainant, the police officer, or request police assistance in the and other witnesses. Board's own investigation; G. If a complaint is filed concerning the e. Performance by Board of its own Police Chief, the City Manager's re- additional investigation; port shall include the same findings of fact and conclusions as required for f. Hire independent investigators. the Police Chief's report to the Board. (Ord. 97-3792, 7-15-1997) 2. The Board shall apply a "reason- able basis" standard of review when reviewing the Police Chief's or City 8-8-7: DUTIES OF THE BOARD; Manager's report. This requires the COMPLAINT REVIEW AND Board to give deference to the Police GENERAL DUTIES: Chief's or City Manager's report be- cause of the Police Chief's and City A. Complaints: The Board shall forward Manager's respective professional copies of all complaints received to expertise. The Board may recommend the Police Chief for investigation; or that the Police Chief or City Manager where the complaint concerns the reverse or modify their findings only if: Police Chief, forward a copy of the complaint to the City Manager for a. The findings are unsupported by investigation. substantial evidence; B. Review Of Police Chief's Report Or b. The findings are unreasonable, City Manager's Report: arbitrary or capricious; or 1. The Board shall review all Police c. The findings are contrary to a Chief's reports and City Manager's Police Department policy or practice, reports concerning complaints. The or any Federal, State, or local law. Board shall decide, on a simple major- ity vote, the level of review to give When collecting arid reviewing addi- each Police Chief's or City Manager's tional evidence, the Board shall rely report, and the Board may select any on evidence which reasonably prudent or all of the following levels of review: persons are accustomed to rely upon in the conduct of their serious affairs. 997 Iowa City 8-8-7 3. At the conclusion of the Board's review, the Board shall issue a public report to the City Council concerning the complaint investigation. Such public report shall include detailed findings of fact concerning the com- plaint, together with a clearly articulat- ed conclusion which explains why and the extent to which the complaint is "sustained" or "not sustained". This public report shall not include the names of the complainant or the po- lice officers unless the complaint is sustained. In addition, this public report shall not include any discipline or personnel matters, although the Board may comment generally as to whether the Board believes discipline is appropriate without commenting on the extent or form of the discipline. A copy of this public report to the City Council shall be given to the com- plainant, the police officer, the Police Chief and the City Manager. (Ord. 97-3792, 7-15-1997) 4. The Board shall not issue a report which is critical of the sworn police officer's conduct until after a "name - clearing hearing" has been held, con- sistent with constitutional due process law. The Board shall give notice of such hearing to the police officer so that the officer may testify before the Board and present additional relevant evidence. The Board shall be respon- sible for protection of all State and Federal rights enjoyed by the officer. The officer may waive the right to this hearing upon written waiver submitted to the Board. (Ord. 98-3865, 12-15-1998) 5. If the Board's report is not critical of the officer's conduct, the Board is not required by law to offer a hearing to lM the officer, but the Board may hold hearings as deemed appropriate by the Board. 6. The Board's report to the City Council shall be completed within thirty (30) calendar days of receipt of the Chief's or City Manager's report. The City Council may grant requests for extensions to this deadline upon good cause shown. 7. Nothing in this Chapter shall in any way impede or interfere with the Po- lice Chief's and the City Manager's lawful ability to perform their person- nel supervisory duties over sworn police officers, including the ability to impose discipline as deemed appropri- ate by the Police Chief or City Manag- er. 8. No findings or report submitted to the Board or prepared by the Board shall be used in any other proceed- ings. C. General Powers And Duties: The Board shall also carry out the follow- ing duties: 1. Maintain a central registry of com- plaints. 2. Collect data and do an annual re- port to the City Council which shall be public and shall set forth the general types and numbers of complaints, disposition of the complaints, the discipline which was imposed, if any, and demographic information. This annual report shall not include the names of the complainants or officers involved in complaints which were not sustained, and shall otherwise be in a form which protects the confidentiality M Iowa City 8-8-7 of the parties while providing the pub- lic with information on the overall performance of the Police Depart- ment. The Board's annual report may also include recommended changes in police practices, policies or proce- dures. 3. In addition to the annual report, the Board shall, from time to time, report to the City Council on police practices, procedures and policies, including recommended changes, if appropriate. 4. The Board shall adopt procedural rules and bylaws governing the Board's activities, including the receipt and processing of complaints, and such procedural rules and bylaws shall be approved by the City Council. (Ord. 97-3792, 7-15-1997) 8-8-8: BOARD COMPOSITION; LIM- ITED POWERS OF THE BOARD: A. Board Composition: 1. The Board shall consist of five (5) members appointed by the City Coun- cil, who shall be Iowa City eligible electors and shall serve without com- pensation. The City Council shall strive to appoint members who repre- sent the diversity of the community. Appointments to the Board shall in- clude one current or former "peace officer" as that term is defined by State law. The City Council reserves the right to waive the residency re- quirement for good cause shown. The City Council also reserves the right, for good cause shown, to waive the requirement that the Board include one current or former peace officer. am 2. Following final adoption and publi- cation of this Ordinance, the City Council shall appoint members to the Board for staggered terms. All ap- pointments shall be for a four (4) year term, except for the initial appoint- ments which shall be as follows: a. One person appointed for a two (2)year term. b. Two (2) persons appointed for three (3) year terms. c. Two (2) persons appointed for four (4) year terms. 3. Training shall be available to all Board members to enable them to perform the duties imposed herein, including training on Iowa's public records and open meetings laws. B. Limited Powers: The Board shall have the following limited powers: 299 Iowa City 1.On its own motion, by a simple majority vote of all members of the Board, the Board may file a complaint. 2. The Board shall decide the level of review to give the Police Chief's or City Manager's report by a simple majority vote of all members of the Board. 3. The Board has no power to review police officer personnel records or disciplinary matters except to the extent such matters are made public by the City Attorney. 4. The Board has only limited civil, administrative review powers, and has no power or authority over criminal matters. The Board is not a court of I law, and is not intended to substitute as a tort claims procedure or as litiga- tion against the City. 5. If criminal charges are brought or are being considered against a partic- ular police officer(s), the Board's re- view or investigation may proceed with interviewing other officers or witnesses, or collecting documents, as appropriate. Any statements given by an officer who is subject to criminal investigation cannot later be used against the officer in a criminal pro- ceeding, as provided under the Fifth Amendment to the U.S. Constitution, unless such constitutional right is waived. 6. The Board may obtain outside counsel and independent investigators in order to carry out the Board's du- ties. 7. The Board may hold general infor- mational hearings concerning Police Department practices, procedures or written policies, and such hearings will be public. The Board shall then report the results of such general informa- tional hearings to the City Council, as the Board deems appropriate. (Ord. 97-3792, 7-15-1997) 8-8-9: POLICE OFFICER'S AND COMPLAINANT'S RIGHTS PRESERVED: A. All rights enjoyed by sworn police officers employed by the City are preserved in this Chapter, and nothing herein is intended to waive, diminish or interfere with any such rights pro- tected by the union contract, Iowa's Civil Service Commission laws and other applicable State and Federal laws. B. All common law rights enjoyed by complainants and police officers, such as privacy and freedom from defama- tion, shall be protected during the process set out in this Chapter, and it shall be the Board's duty to protect said rights. C. Notwithstanding the above provisions, no Board member shall be liable to any person for damages or equitable relief by reason of any investigation or recommendation or report made by either a Board member or by the Board itself. (Ord. 97-3792, 7-15-1997) 8-8-10: SUNSET CLAUSE: This Chapter shall be automatically repealed on August 1, 2001, unless reenacted by City Council. (Ord. 97-3792, 7-15-1997) 997 Iowa City Legal Counsel for PCRB After passage of the PCRB ordinance the following steps were taken to retain legal counsel: 1) CA sent a letter to Johnson County and Linn County Bar Associations on July 301h (copy attached) outlining the position as we saw it then, offering more information if requested, and asking resumes be submitted to the CA with a deadline of 30 days (August 26). 2) As in all cases where an outside attorney is being retained to represent City employees or body due to a conflict of interest, the City Attorney establishes minimum qualifications. After the deadline passe(the City Attorney reviewed the applicants for minimum qualifications and forwarded all applicants to the PCRB. 3) There was no job description per se, nor was any ad placed in local newspapers. 4) PCRB interviewed all applicants and followed interview format for everyone interviewed (copy attached). 5) PCRB decided to offer position and City negotiated and entered into the contract. (Contract signed September 24; Board approved October 2) Issues this time to be resolved: Time line? Job description/simple paragraph of minimum qualifications. CA suggested Doug may wish to identify areas that are important, i.e. minimum practice experience, or criminal law experience. Recruitment area? Letter? From whom? Attachments or offer to send upon request? Update that to offer SOP's; mediation procedure; by-laws? Ads? Interview format Legalcoadoc July 30, 1997 JOHN S ALLEN 398 BOYD LAW BLDG IOWA CITY IA 52242 Re: Iowa City Police Citizens Review Board (PCRB) Dear Member of the Johnson County Bar Association: 111' 'i5' CITY OF IOWA CITY The purpose of this letter is to obtain preliminary information from attorneys who are interested in serving as legal counsel to the newly -formed Police Citizens Review Board ("PCRB"). The Iowa City City Council gave final consideration to the ordinance establishing the PCRB on July 15, 1997 and the ordinance became effective upon publication on July 23, 1997. Board members will be appointed at the Council's meeting on August 26, 1997. If you would like a copy of the ordinance, please contact my office and we will send you one. City staff is currently in the process of establishing staff support for the PCRB. Due to potential conflicts of interest the City Attorney's office will not represent the PCRB. Because we are chartering new territory with the PCRB it is difficult to imagine all the legal issues that may arise. However, one can anticipate that counsel will review the bylaws and complaint form and assist the PCRB with issues concerning the Iowa Open Meetings and Open Records laws, personnel and confidentiality, police policy and procedure and use of force. If you are interested in being considered as counsel for the PCRB, please submit the following information to me no later than August 26, 1997: 1. Resume and/or summary of your education, work experience and any other experience that particularly qualifies you to represent the PCRB. 2. Current hourly rate. Rates are subject to negotiation. 3. Identify any potential conflicts of interest you may have in representing the PCRB. Retention of counsel will be one of the first Items on the PCRB's agenda when it meets following appointment of members on August 26, 1997. The Board will choose its own attorney with assistance from City staff. The budget for the PCRB will include attorney's fees. Although the fee structure has not yet been determined, City staff anticipates a guaranteed monthly retainer amount with payment at an hourly rate for any hours in excess of the retained number of hours. If you have any questions please feel free to contact me or Assistant City Attorney Dennis Mitchell. Very truly yours, Eleanor M. Dilkes Acting City Attorney cc: City Council Steve Atkins, City Manager Marian Karr, City Clerk eleanor/E r/a0omey. mrg 610 EAST WASHINGTON STREET • IOWA CITY. IOWA 52240.1936, (519) 356-5000, FAX (519) 556-5009 0 a ao 70 Q807 July 30, 1997 MEMBERS OF LINN COUNTY BAR ASSOC C/O KAREN VOLZ - PRESIDENT PO BOX 50762 I CEDAR RAPIDS IA 52407-5062 Re: Iowa City Police Citizens Review Board (PCRB) CITY OF IOWA CITY Dear Member of the Linn County Bar Association: The purpose of this letter is to obtain preliminary information from attorneys who are interested in serving as legal counsel to the newly -formed Police Citizens Review Board ("PCRB"). The Iowa City City Council gave final consideration to the ordinance establishing the PCRB on July 15, 1997 and the ordinance became effective upon publication on July 23, 1997. Board members will be appointed at the Council's meeting on August 26, 1997. If you would like a copy of the ordinance, please contact my office and we will send you one. City staff is currently in the process of establishing staff support for the PCRB. Due to potential conflicts of interest the City Attorney's office will not represent the PCRB. Because we are chartering new territory with the PCRB it is difficult to imagine all the legal issues that may arise. However, one can anticipate that counsel will review the bylaws and complaint form and assist the PCRB with issues concerning the Iowa Open Meetings and Open Records laws, personnel and confidentiality, police policy and procedure and use of force. If you are interested in being considered as counsel for the PCRB, please submit the following information to me no later than August 26, 1997: 1. Resume and/or summary of your education, work experience and any other experience that particularly qualifies you to represent the PCRB. 2. Current hourly rate. Rates are subject to negotiation. 3. Identify any potential conflicts of interest you may have in representing the PCRB. Retention of counsel will be one of the first items on the PCRB's agenda when it meets following appointment of members on August 26, 1997. The Board will choose Its own attorney with assistance from City staff. The budget for the PCRB will include attorney's fees. Although the fee structure has not yet been determined, City staff anticipates a guaranteed monthly retainer amount with payment at an hourly rate for any hours in excess of the retained number of hours. If you have any questions please feel free to contact me or Assistant City Attorney Dennis Mitchell. Very truly yours, &,gym. G� Eleanor M. Dilkes Acting City Attorney cc: City Council Steve Atkins, City Manager Marian Karr, City Clerk eleanorAtr/attomey.mq 610 EAST WASNINOTON STREET • IOWA CITY. IOWA 32240.1826 • (710) 356-5000 • FAX (110) 356-3009 aFo4:0 1. What are your reasons for applying for this position? 2. Have you thought about what issues are likely to arise from work with the PCRB? What is your expertise in dealing with these issues? - Open meetings and Open Records Law - Civil Service system - criminal defense and privilege - hiring and firing - conflict of interest 3. What would you do if the Board is not responsive to your advice? 4. If there were a breach of confidentiality by a Board member, what would you do as counsel? 5. What do you see as your role and time commitment for this position? STEIN, RUSSELL & PUGH, L.L.P. ATTORNEYS AT LAW ENGLERT BUILDING P. O. BOX 2416 IOWA CITY, IOWA 5=" L. JAY STEIN DOUGLAS S. RUSSELL CATHERINE A. PUGH' 'ALSO ADMITTED IN ILLINOIS Ms. Leah Cohen Chair, Police Citizen Review Board 410 E. Washington Street Iowa City, Iowa 52240 Dear Leah: FAX (319) 351-6409 TELEPHONE February 26, 1999 (319) 351.5610 As you are aware, I was appointed District Court Judge by Governor Vilsack on February 24, 1999. Pursuant to the Rules of Iowa Supreme Court I am required to leave the private practice of law within thirty (30) days. My present schedule will have me leaving the practice by March 19th. As we have discussed, my partner, Catherine A. Pugh, has agreed to serve as interim legal counsel for the Board at the Board's request. The City Attorney and the City Clerk are in agreement that she may serve in this capacity. I have the highest confidence in Catherine's ability as an attorney. I have forwarded a letter of agreement concerning the terms of Catherine's employment to the City Clerk. I anticipate that Catherine and I will both attend the meetings on March 2nd and 9th and that after the meeting on March 9th I will cease serving as your legal counsel. I want you and the Board members and the City staff to know that I was honored to be selected to serve as your legal counsel and I have enjoyed working with you all. It is a privilege to serve with such a capable, hardworking and sensible group of people. I will miss you all. Respectfully, STEIN, U7 & PUGH, L.L.P. Douglas S. Russell DSR.gIg C: \S R P\D O U G \P C R B. F 26