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Sir Robert Peel’s 9 Principles of Policing – Principle #4

I am writing a series of articles where I discuss Sir Robert Peel’s 9 Principles of Policing.  I believe these principles are as important today for law enforcement leaders as the day Peel penned them.

Click here to read my introduction to the topic and discussion of Principle #1.   Click here to read about Principle #2.  Click here to read about Principle #3.

Today, my focus is on Principle #4.

Principle #4

To recognise always that the extent to which the co-operation of the public can be secured diminishes proportionately the necessity of the use of physical force and compulsion for achieving police objectives.

In today’s context, most people would read Principle #4 and agree with it immediately.  If we take a look back in time, that view may not always have been the case.  However, Principle #4 expresses a timeless truth that is still relevant today as it was in 1829.

Law enforcement needs the willing cooperation of the public to do their job effectively.  We can’t use force to compel them to comply.

The use of force by police officers is a necessary part of their job.  However, that use of force must be reasonable, appropriate, and delivered fairly and impartially.  Otherwise, law enforcement will not have the willing cooperation of the public.

If the public refuses to cooperate or only cooperates through coercion or compulsion, chaos may soon follow.     

Historical Perspective

In 1829 and the ensuing years, policing was much different than it is today.  And I don’t mean that in a good way.

There was no such thing as a professional police officer.  Your ability to get a job in law enforcement was dependent on who you knew rather than your ability to do the job.  The technology was non-existent.  For the most part, training was non-existent. 

Instead, police officers relied upon the use of brute force to do their jobs.  If brute force didn’t work, they relied upon the weapons of the day. 

A New York Times editorial, Police with Pistols, published on November 15, 1858, expressed dismay when the police shot and killed a fleeing suspect. 

“The pistols are not used in self-defense, – but to stop the men who are running away.  They are considered substitutes for swift feet and long arms.  Now, we doubt the propriety of employing them for such a purpose.  A Policeman has no right to shoot a man for running away from him.  But what right have Policemen to carry revolvers at all?  We doubt very much the policy of arming our Policemen with revolvers.” 

This trend continued into the 20th century, where law enforcement continued to do their job with little regard for the people they served.

Wickersham Commission

In 1929, President Herbert Hoover appointed the National Commission on Law Observance and Enforcement, also known as the Wickersham Commission.  This commission conducted the first comprehensive study of crime and law enforcement in U.S. history, primarily driven by prohibition.

The findings of the Wickersham Commission were published in 1931 and 1932 in fourteen different volumes.  The volume titled Lawlessness in Law Enforcement shocked the nation.  This volume indicted the illegal actions of law enforcement, particularly as it related to the widespread use of the “third degree” by police officers who willfully inflicted pain and suffering on suspects. [i]  The report described many other types of brutality as well.

As a side note, the volume titled Police promoted the idea of hiring more professional police departments, staffed with highly qualified and trained officers who were insulated from political pressures. 

Ironically, the commission reported the chief evil as the short term of service of the police chief.

Kerner Commission

In 1967, President Johnson appointed the Commission on Law Enforcement and the Administration of Justice, also known as the Kerner Commission.  The President charged this commission with looking into the civil unrest and riots, which began in 1965.

The findings of the commission, the Kerner Report, were released in 1968.  The commission criticized the federal and state governments for failed education, housing, and social-services policies. [ii]  These failures led to riots across the country.

The commission also issued a report entitled, “The Challenge of Crime in a Free Society.”  The report generally criticized the police for their over response to many of the riots, which led to the death of many rioters. [iii]

Among several hundred recommendations, the Kerner Commission called for improved training and professionalization for law enforcement, recommended that the police and communities work together, and that law enforcement radically changes their administrative practices, and the way personnel is selected. [iv]

In the years following the release of the findings of the Kerner Commission, several new programs were started, including the Bureau of Justice Assistance, National Crime Victimization Survey, 9-1-1, Law Enforcement Assistance Program, Community Oriented Policing Services, National Institute of Justice, and the Office of Justice Programs.

Case Law

In 1973, Johnson v. Glick, decided by the Second Circuit Court of Appeals, set the standard for the use of force by establishing the Johnson v. Glick test for pre-trial detainees.  The court had to look at four parts. 

  1. The need for the application of force.
  2. The relationship between the need and the amount of force that was used.
  3. The extent of injury inflicted.
  4. Whether force was applied in a good faith effort to maintain or restore discipline or maliciously and sadistically for the very purpose of causing harm. [v]

The Johnson v. Glick ruling was followed by the Tennessee v. Garner case decided by the Supreme Court in 1985. 

In Tennessee v. Garner, the US Supreme Court ruled that laws that authorized the police to use deadly force on fleeing felons, who were non-violent, violate the Fourth Amendment. [vi]  Before the Garner ruling, most jurisdictions considered the use of deadly force to apprehend someone for any felony legitimate.

In May of 1989, the US Supreme Court unanimously found in Graham v. Connor that the Johnson v. Glick standard for excessive force no longer applies as it relates to the Fourteenth or Eighth Amendment.  The court found that the intent of the officer wasn’t what mattered.  Instead, the objective factors of the case are the only relevant factors when evaluating claims of excessive force. [vii]

Furthermore, the court found that any claims of excessive force must be examined through the eyes of how another objectively reasonable police officer in the same situation would have acted. 

Lastly, the court decided that the following factors must be considered when determining if an officer’s use of force was excessive:

  1. The severity of the crime at issue;
  2. Whether the suspect poses an immediate threat to the safety of the officers or others; and
  3. Whether (the suspect) is actively resisting arrest or attempting to evade arrest by flight.

Since Graham v. Conner, the US Supreme Court and other courts have made additional rulings related to the use of force, but Graham v. Conner is still the standard today, or at least for now.

Ferguson

On August 9, 2014, Officer Darren Wilson shot and killed an unarmed 18 yr old African American man, Michael Brown, after he attacked Officer Wilson in Ferguson, Missouri.  This police use of force, more than any other in recent history, sparked outrage and led to protests across the United States and throughout the world.

Even though the Department of Justice cleared Darren Wilson and corroborated his account of what happened, the incident still stands as a watermark of the public’s tolerance or intolerance of police use of force, especially force the public deems unjustified. [viii]

This shift of the public’s perception of the legitimacy of police use of force was altered forever as a result of this incident. 

Social Media and Technology

Social media played a big role in the aftermath and perception of the legitimacy of Darren Wilson’s use of force against Michael Brown even though no video of the actual shooting existed.  That hasn’t always been the case.

Long before modern technology existed, information about police use of force traveled by mouth.  As technology improved, word traveled faster via various modes of transportation.  Later on, the printed word shined a light on police use of force.  Eventually, the television brought this topic into the homes of citizens.  Of course, the videotape of the Rodney King beating brought excessive police use of force to the attention of the nation like no other previous incident.

Over the next few decades, the police began to record themselves with in-car cameras. Smartphone technology provided the means for everyone to have a camera in their hands at all times, and body-worn cameras became a necessary tool in every police officer’s toolbox.

In the Ferguson case, thousands and thousands of tweets were posted, establishing the narrative about what happened and the perceived illegitimacy of the police use of force during the incident. 

Unfortunately, the first Press Conference held by the Ferguson Police Department was not until almost 24 hours after the incident.  By then, the accepted narrative of what happened was spreading across the United States, and the predictable resistance of the police had begun. 

Many citizens were no longer willing to cooperate as police officers attempted to carry out their responsibilities.

Lessons for Today

Law enforcement must understand the relationship between the police using physical force versus the need to have the willing cooperation of the public.  This relationship matters because law enforcement cannot effectively do their job without the willing cooperation of the public.

Police will never be able to use force as a motivator to gain the willing cooperation of citizens.

The more force is used by the police, the less the public is willing to cooperate.  In fact, just the perception of the police using too much force leads to a lack of willing cooperation.

Since Ferguson, there has been a shift throughout the country to usurp the findings of the US Supreme Court ruling in Graham vs. Conner.  There have been many voices across the nation wanting to hold law enforcement to a higher standard.  Suffice it to say there has been a move to judge police use of force cases from the perspective of officer created jeopardy.  In other words, did the police officer’s pre-use of force conduct lead to what would otherwise be a justified use of force?  Different Court of Appeals has begun to use this standard when reviewing police use of force cases.  [ix]  There have been several court cases across this country on this issue.

Also, there has been a move to change state law to restrict and/or change the way law enforcement uses force and the situations where it is used.  Many states have made changes to laws related to police use of force.  Also, many police departments have made extensive changes to their policies.

In California, new state law changed the standard for police to use force from “reasonable” to “necessary.”  [x] 

The Camden County Police Department changed its policy and limits police use of force only as a “last resort.”  [xi]

While many changes are appropriate and necessary, there is a danger that some changes may make police officers less safe. 

Conclusion

A lot has changed since Sir Robert Peel developed this principle.  Few people would argue about the progress law enforcement has made in the last 190 years.  Police officers today are better trained, better educated, more professional and I would argue they demonstrate much more restraint when it comes to using force than in Peel’s day.  Yet, law enforcement is probably under the most scrutiny ever when it comes to police use of force.

The widespread use of social media, the proliferation of smartphones with video cameras, the use of body-worn cameras by law enforcement and the litigious nature of society have all contributed to a belief that excessive use of force by the police is a serious problem.

Of course, any excessive use of force is wrong, and those officers responsible should be held accountable.  Still, the majority of the millions of police encounters or arrests happen with no police use of force.

It is evident, though, that law enforcement must be proactive to combat both the rare instances of police officers using excessive force and the perception that police officers use excessive force frequently.

Law enforcement must develop strong policies when it comes to police use of force, accompanied by great training and a thorough review of each use of force incident.  Besides, law enforcement must treat people fairly and respectfully in their encounters to help gain the willing cooperation of the public. 


[i] https://law.jrank.org/pages/11309/Wickersham-Commission.html

[ii] https://en.wikipedia.org/wiki/Kerner_Commission

[iii] https://www.smithsonianmag.com/smithsonian-institution/1968-kerner-commission-got-it-right-nobody-listened-180968318/

[iv] https://www.npr.org/2017/10/06/542487124/president-johnson-s-crime-commission-report-50-years-later

[v] https://daiglelawgroup.com/wp-content/uploads/2016/10/Teaching-the-New-Consitutional-Pre-Trial-Detainee-Standard.pdf

[vi] https://scholarlycommons.law.northwestern.edu/cgi/viewcontent.cgi?article=6811&context=jclc

[vii] https://www.thoughtco.com/graham-v-connor-court-case-4172484

[viii] https://www.nytimes.com/2015/03/05/us/darren-wilson-is-cleared-of-rights-violations-in-ferguson-shooting.html

[ix] https://www.llrmi.com/articles/legal_update/2017_supreme_court_mendez/

[x] https://www.usatoday.com/story/news/nation/2019/08/20/california-new-police-use-force-law-significant-change/2068263001/

[xi] https://www.policeone.com/law-enforcement-policies/articles/nj-police-launch-strict-last-resort-use-of-force-policy-uHgrmit5mgTNWifn/

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