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HomeMy WebLinkAbout03-09-1999 Communication STEIN, RUSSELL & PUGH, L.L.P. ATTORNEYS AT LAW IOWA CITY, IOWA 52244 February 26, 1999 Ms. Marian Karr Iowa City Clerk Civic Center 410 E Washington Street Iowa City, IA 52240 RE: Interim Legal Counsel for Police Citizens Review Board Dear Marian: Pursuant to our discussions and discussions with the City Attorney and the Chair of the Police Citizens Review Board we are forwarding this letter of agreement to you concerning the employment of Catherine A. Pugh as interim legal counsel for the Police Citizen Review Board following Doug Russell's departure from the practice of law. We propose that the following terms of employment for Ms. Pugh be approved. 1. Ms. Pugh will assume her duties as interim counsel immediately and shall serve in that capacity for ninety days or until the Police Citizens Review Board retains replacement counsel, whichever period is shorter. Mr. Russell shall terminate his employment as legal counsel for the Police Citizens Review Board no later than March 19, 1999. 2. Mr. Russell and Ms. Pugh shall be paid for all services as legal counsel or interim legal counsel at the rate of $115 per hour. The Police Citizens Review Board shall be given thirty days notlce of any fee increase. Travel time outside the corporate limits of Iowa City, if necessary, shall be billed at the same hourly rate. 3. A monthly statement for services will be submitted to Marian Karr, the Clerk of the City of Iowa City, itemizing in detail all billable time by item, date and time based on tenths of an hour. 4. The minimum billable time for a telephone call is .2 hours. The minimum billable time for preparation of a letter or written document is .25 hours. 5. Each statement for services shall be paid within thirty days of receipt. 6. No retainer fee is required. 7. All attorney expenses for legal counsel work shall be included in the monthly statement for services and payable on the same basis as legal fees. Expenses for travel outside the corporate limits of Iowa City, if necessary, shall be paid according to the usual travel expense policy for city employees. 8. Either Ms. Pugh or the Police Citizens Review Board may terminate the agreement at any time by providing written notice of the termination. 9. We understand City staff is available to assist with photocopying, postage and other clerical duties at the expense of the City of Iowa City. 10. If these terms are acceptable, please have the City Manager sign a copy of this letter and return it to Stein, Russell & Pugh. Thank you for the opportunity to serve as legal counsel to the Police Citizens Review Board. Respectfully, STEIN, RUSSELL & PUGH, LLP. Douglas S. Russell Catherine A. Pugh DSR.kkj C:~SRP'CCRB\KARR.F26 Onthis ! dayof ~ ,1999, the undersigned, on behalf of the City of Iowa City, approves the ferms of employment stated above. Stephen. J(/~,tkins C~ty Manager POLICE CITIZENS REVIEW BOARD A Board of the City of Iowa City 410 East Washington Street Iowa City IA 52240-1826 (319)356-5413 March 10, 1999 DRAFT R. J, Winkelhake, Chief of Police Iowa City Police Department 410 E. Washington Street Iowa City IA 52240 Dear Chief Winkelhake: The members of the Board are looking forward to your attendance at the PCRB Community Forum on Wednesday, April 28, 1999, at 7:00 P.M., at the Broadway Neighborhood Center. With regard to your presentation at the forum, the Board feels you may wish to address police related concerns that are inherent to the neighborhood and what measures the police department is taking to deal with them. These concerns and measures could include, but not necessarily be limited to: types and frequency of crimes, police public relations and prevention programs, or enforcement activities which you believe would be of interest to those citizens living in this area of the city. Because of the nature of your presentation, we expect a question and answer will follow. However, I want to limit your participation to thirty (30) minutes so that the remainder of the time will be available for comments to the Board. If there is any information you would like to appear on the notice for this forum, please feel free to contact me and I will take care of the arrangements. Very truly yours, Leah Cohen, Chair Police Citizens Review Board cc: Steve Atkins, City Manager Eleanor Dilkes, City Attorney POLICE CITIZENS REVIEW BOARD A Board of the City of Iowa City 410 East Washington Street Iowa City IA 52240-1826 (319) 356-5413 March 10, 1999 Ms. Eleanor Dilkes, City Attorney 410 E. Washington Street Iowa City IA 52240 Dear Eleanor: The PCRB would like to extend a very sincere thank you for all your help this past month, We feel comfortable with the Council's decisions and realize your support was necessary to reach these goals. The Board will continue to monitor and make suggestions as we feel necessary. This first year and a half has been a learning process for all of us. Your insights have helped make it possible for us to fulfill our duties under the ordinance. We thank you for your confidence and support. Sincerely, Leah Cohen, Chair Police Citizens Review Bpard cc: Steve Atkins, City Manager Ernie Lehman, Mayor R. J. Winkelhake, Chief of Police CITY OF IOWA CITY IOWA POLICE CITIZENS REVIEW BOARD STANDARD OPERATING PROCEDURES AND GUIDELINES [ Proposed Revisions 3~5~99] 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 achiet/e 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 9/98 TABLE OF CONTENTS Page I. Complaint Process ..................................................................................... 1-2 Il. Formal Mediation Guidelines and Procedures ........................................... 2 II1. Meetings ................................................................................................... 3-4 IV. Complaint Review Process ....................................................................... 4-6 V. Identification of Officers ................................................................................ 6 VI. Review of Policies, Procedures and Practices of the Iowa City Police Department ..................................................................................... 6-7 VI. Annual Report ........................................................................................... 7 VII. General ...................................................................................................... 7-8 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, althou.~h the reports of the Police Chief and Cit.v Manager shall identify the officers b.v number as set forth in Section V of these procedures.= i~). complaints subject to summary dismissal Procedure for 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; 4. The Board shall determine whether additional information is necessary, to assess whether the complaint should be summarily dismissed and. if additional information is necessary., the method b,v which such information will be obtained. The methods available include an interview PCRB 8OP-~21~9 - 1 of the complainant by a subcommittee of the Board. a request to the complainant for fi written submission on the issue presented and an investigation b.v the Board. but shall not include an invitation to the complainant to address the PCRB at a public meetin.a or an interview of the complainant at a public meetin.a. ............... ~ ............. on the Board's determination that additional information is not necessa~ to determine whether the complaint should be summaril.v dismissed or. upon completion of the investig~tiQn determined necessfiry to make such decision.the Board shall, by motion in open session, vote to determine whether the complaint will be dismissed under Section 8-8-3 ~E__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 repeal 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.. II. 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. PCRB SOP-9/98.2/99 - 2 III. Meetings 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. I. 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 PCRB SOP--9/,g82/99 - 3 quorum, and said member shall have all rights as if participating in person.. 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 Vll.l(a). 5. Confidentiality of the minutes and tape recordings or closed sessions. See By-Laws Vii, 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 VIl.l(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. PCRB SOP-9/982/99 - 4 I ' IV. Complaint Review Process The Board shall review all Police Chief's 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. A. Review of Police Chief's report or City Manager's report. Follow 8-8-7 B of the City Code. B. 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). PCRB SOP 9!982/99 - 5 I ' 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 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 1, The reports of the Police Chief and the City Manager to the Board will identify, the officers with unique identifiers, i.e. same number for same officer from one complaint to the next. but not by name. In its public reports, however, the Board shall not use the same number for the same officer from one report to the next. in order to guard against inadvertent identification of the officer to the public by the Board. The Board reserves the right, however, to identify, the officer in a ~;u~;tained complaint pursuant to Section 8-8-7(B) of the City Code and may obtain the officer's name from the City Clerk for this purpose. 2. An allegation of misconduct or previous allegation of misconduct against an officer is not and shall not be used by the Board as evidence of misconduct. PCRB SOP-8,~82/99 - 6 I VI. 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. 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. PCRB SOP-9/982/99 - 7 Vlh 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 VIII.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. VIII. 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. eleanor~pcrbgde2.doc · PCRB SOP-g/g82/99 - 8 I ' 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 ~!×~' (~0) ninety !90) 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 =!×t;.' (60) nine~ (90) 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'S REPORT TO THE BOARD: CITY MANAGER'S REPORT TO THE BOARD: E. The Police Chief's report to the Board shall be completed within. !h!.~.~' (30) nine~ (90) 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 Chief's Report or City Manager's Report: 6. The Board's report to the City Council shall be completed within *.hi~, (30) forty- fiv~ (4§) 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. 8-8-11 :TIME COMPUTATION In computin.a time under this Chapter. the first da.v shall be excluded and the last included. unless the last falls on a Sunday. in which case the time prescribed shall be extended so as to include the whole of the following Monday. However. when the last day for the filing of a complaint or the completion of a report falls on a Saturday or Sunday. or a day on which the office of the City Clerk of the Ci~ of Iowa Ci.ty is closed due to a Ci.ty holiday, the time shall be extended to include the next day on which the office of the Clerk is open to receive the filing of a complaint or the report. Lega ~elea nor~pcrb\prosrev.doc March 5, 1999 DouglasS. Russell CITY OF I0 WA CITY Attorney at Law Stein, Russell & Pugh, LLP P.O. Box 2416 Iowa City, IA 52244 P,e: Police Citizens Review Board [)ear Doug: I understand from your recent phone call that the proposed revisions to the Board's SOPs that I sent you under cover of February 15, 1999 are acceptable to the Board with two exceptions. First, in light of the provisions regarding redaction of the officers' names from complaints, the Board wishes to have written assurance that it will have access to the police officer's name for the purpose of naming an officer in a sustained complaint pursuant to Section 8-8-7(B) of the City Code. Enclosed you will find a further revision to the SOPs. Section V now states that the Board may obtain the officer's name from the City Clerk for this purpose. With respect to guidelines for release of a name in a sustained complaint, I understand that you will read the Hawk Eye case and we can discuss it on Monday. As I told you by phone, however, I believe that the changes to the SOPs and ordinance should be put in place now rather than waiting for a discussion and codification of such guidelines. I suspect that this discussion would delay and complicate the changes to the SOPs and ordinance that were discussed and tentatively approved by Council at its recent work session. I look forward to hearing from you on Monday. Eleanor M. Dilkes City Attorney Enclosure cc: Marian K. Kerr, City Clerk Sarah Holecek, First Assistant City Attorney R.J. Winkelhake, Police Chief Steve Atkins, City Manager elea no r'tltr',r u ss el 5.d cc CITY OF IOWA CITY IOWA POLICE CITIZENS REVIEW BOARD STANDARD OPERATING PROCEDURES AND GUIDELINES [ Proposed Revisions 3/5/99] The PCRB was established to assure that investigations into c/aims of police misconduct are conducted in a manner which is fair, thorough and accurate and to assist the Po/ice Chief, the City Manager and the City Council in evaluating the overall performance of the Po/ice 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 9/98 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 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, _ldentificatiQn of Officers 1, The reports of the Police Chief and the City Manager to the Board will identify the officers with unique identifiers, i.e. same number for same officer from one comDlaint to the next. but not by name. In its public reports, however, the Board shs!l not use the same number for the same officer from one report to the next. ¢¢¢¢J in order to guard a.dainst inadvertent identification of the officer to the public b.v. the Board, The Board reserves the right, however, to identify the officer in a ~,~ sustained complaint pursuant to Section 8-8-7(B) of the City Code and may obtain the officer's name from the City Clerk for this purpose. _2. An allegation Of misconduct or previous allegation of misconduct against an officer is not and shall not be used by the Board as evidence of misconduct. PCRB SOP-g/OS~{/9~- 6 I