EAST HAVEN DEPARTMENT OF POLICE SERVICES 471 NORTH HIGH STREET EAST HAVEN, CONNECTICUT 06512

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1 East Haven Police Department Settlement Agreement Eighteen Month Compliance Report Pursuant to the requirements of the Settlement Agreement (SA) between the Town of East Haven, East Haven Police Department (EHPD), and the United States Department of Justice (DOJ); this report is submitted as record of compliance with the eighteen month requirements as indicated in the SA. The SA requires that the EHPD maintain and demonstrate continued compliance with the following: 1. EHPD shall review each policy or procedure related to this Agreement 180 days after it is implemented, and annually thereafter, to ensure that the policy or procedure provides effective direction to EHPD personnel and remains consistent with the Agreement, professional police practices, and current law, including incorporating mechanisms to promote and measure accountability and community engagement. EHPD also shall review policies and procedures as necessary upon notice of a policy deficiency during audits or reviews. Within 60 days of that review EHPD shall revise the policy or procedure and consult with the Joint Compliance Expert (JCE) and DOJ. DOJ and the Joint Compliance Expert shall provide the same review and approval of revised policies and procedures as with the initial policies and procedures to ensure consistency with this Agreement. 2. EHPD shall review and revise its Code of Conduct within 180 days of the Effective Date, and annually thereafter, to: a) describe with specificity permitted and prohibited officer conduct; b) be consistent with the requirements of professional police practice and this Agreement; and EHPD 18 Month Compliance Report Page 1 of 5 July 1, 2014

2 c) have an absolute requirement of officer honesty and make termination the default penalty for dishonesty. 3. Within 30 days after issuing a policy or procedure pursuant to this Agreement, EHPD shall ensure that all relevant EHPD personnel have received, read, and understand their responsibilities pursuant to the policy or procedure, including the requirement that each officer or employee report violations of policy; that supervisors of all ranks shall be held accountable for identifying and responding to policy or procedure violations by personnel under their command; and that personnel will be held accountable for policy and procedure violations. EHPD shall document that each relevant EHPD officer or other employee has received, read, and sufficiently understands the policy. Training beyond roll-call or similar training will be necessary for many new policies to ensure officers understand and can perform their duties pursuant to the policy. 4. Within twelve months of the Effective Date, EHPD shall develop and implement an EHPD-specific system to accurately evaluate officer performance in areas related to integrity, community policing, and critical police functions on both an ongoing and annual basis that comports with professional police practices and the requirements of this Agreement. As part of this program, EHPD shall establish a formalized system documenting annual performance evaluations of each officer by the officer s direct supervisor which shall include assessment of: a) community engagement and communication with the public; b) use of community-policing and problem-solving strategies; c) civilian commendations and complaints; d) disciplinary actions; EHPD 18 Month Compliance Report Page 2 of 5 July 1, 2014

3 e) compliance with policies on usage of sick leave and other leave; f) compliance with policies on secondary employment; g) safety (e.g., POST officer safety standards and vehicle operations); h) training; i) report-writing; and j) decision-making skills. In compliance with SA Paragraph 13 (Page 9) and SA Paragraph 25 (Page 11), the EHPD conducted one to two training sessions on the policies and procedures manual with all sworn and non-sworn employees during the months of January 2014 and February Generally all sworn employees received two training sessions and non-sworn employees received one training session. The first session addressed all policies that took effect on February 1, The second session addressed all policies that took effect on March 1, All of the sessions had a positive impact in that they enabled proper review with all employees to ensure that their questions were answered and they were made aware of the basis for enacting some policies and the expectations of the department regarding compliance. All employees were provided all policies before the training sessions and were given sufficient time to review the policies prior to attending the training sessions. At the completion of the training sessions and/or prior to the effective date of the policies, employees were required to sign off having receiving and understanding each policy through the Power DMS policy management system. The training sessions were designed to assist employees in understanding the policies, and afforded them a level of comfort moving forward with the new policies and procedure manual. At the completion of the training sessions on the policies and procedures manual, the EHPD proceeded to conduct an additional review of the entire manual. Some of the issues raised were brought up by employees during training and some were noted administratively by the command staff. Based on this review, the EHPD determined that a total of 46 policies and procedures needed revisions to help the EHPD function better both operationally and administratively. Furthermore, it EHPD 18 Month Compliance Report Page 3 of 5 July 1, 2014

4 is expected that the revisions will help with ensuring that the EHPD maintains compliance with the SA. The 46 policies and procedures requiring revision were submitted to the DOJ and the JCE for review on April 11, As of the date of this report, the EHPD has received final review of these policies from the DOJ. The EHPD intends on submitting the revisions to the Board of Police Commissioners in July In addition, the EHPD submitted two new policies and two revisions to existing policies that address body worn cameras and the Secure Communities Program. These policies have been reviewed, approved, and returned by the DOJ and the JCE. All four of these policies have been also approved by the East Haven Board of Police Commissioners and will be in effect on or before July 1, In compliance with SA Paragraph 22 (Page 11), the EHPD reviewed and revised the Code of Conduct with an updated version issued on December 11, 2013 and effective March 1, This updated version rescinded the initial version that became effective on September 30, The updated version was among numerous other policies and procedures that were reviewed and approved by the DOJ and JCE during the fall of Furthermore, the EHPD submitted additional revisions to the Code of Conduct as part of the 46 policies and procedures submitted for review on April 11, In compliance with SA Paragraph 166 (Page 166), the East Haven Board of Police Commissioners, after review by the DOJ and JCE, approved Policies and Procedures # Performance Evaluations in order to specifically address this requirement. This policy was also reviewed and approved by the executive board of the collective bargaining group, and took effect on June 15, This policy directly calls for annual performance evaluations on an employee s anniversary date. Due to its effective date, the performance evaluations for approximately the next 12 months may only be partial reviews depending upon an employee s anniversary date. Employees have reviewed and signed off on this policy through the Power DMS system. Employees have also received individualized and/or roll call training and supervisors have and/or will also receive training on the completion of the performance evaluation forms. EHPD 18 Month Compliance Report Page 4 of 5 July 1, 2014

5 In compliance with SA Paragraph 69 (Page 20), the semi-annual Stop and Search Analysis Report for January 1, 2014 through June 30, 2014 will be completed and submitted to the DOJ and the JCE in early July In addition to this compliance report, supplemental compliance reports will also be submitted by the EHPD s Community Liaison Officer and Language Assistance Coordinator, Training Supervisor, and Professional Standards Officer. These reports will address areas such as community outreach and language assistance activities, training that has been provided and/or will be provided in the coming months, and an analysis of complaints, administrative investigations, internal investigations, and uses of force. Their reports will cover the period from January 2014 to June Please see the supplemental reports for further details. All general provisions of the SA that do not specifically address a date or time period have been sustaining compliance as required. There are no issues or matters to report by the EHPD that deviate from continued compliance with the SA. This report is being simultaneously submitted to both the DOJ and JCE for review and comment. Any further supporting documentation to ensure compliance is available for inspection if requested. Respectfully Submitted, Edward R. Lennon Jr. Deputy East Haven Police Department Compliance Coordinator DOJ SA EHPD 18 Month Compliance Report Page 5 of 5 July 1, 2014