law enforcement, complaints, police officers, municipal liability, complaint review, deliberate indifferrence standard


This article briefly describe the emerging professionalism of law enforcement and, within this context, discuss the risks and benefits associated with current models for receiving and reviewing citizen complaints against police officers. Part IV discusses courts' application of the deliberate indifference standard to claims that a citizen complaint procedure is inadequate and summarizes litigation in several small and large communities employing the various models for complaint review. Additionally, Part IV examines the issues of proof raised in Canton and reinforced in Brown. The Article divides the cases by the models employed; however, the potential deficiencies in any model and the issues of proof suggested by the Court in Brown find substantial commonality regardless of the model a municipality adopts. Part V summarizes some of the judicially-dictated minimum standards by which towns and cities should assess their own complaint review procedure.



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