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JOHN L. BURRIS, STATE BAR NO. 69888Law Offices of John L. Burris
Airport Corporate Centre7677 Oakport Road, Suite 1120Oakland, California 94621
Telephone: 510.839.5200
Facsimile: 510.839.3882Attorneys for Plaintiffs
JAMES B. CHANIN, STATE BAR NO. 76043JULIE M. HOUK, STATE BAR NO. 114968
Law Offices of James B. Chanin
3050 Shattuck AvenueBerkeley, California 94705
Telephone: 510.848.4752
Facsimile: 510.848.5819Attorneys for Plaintiffs
(Additional Counsel on Next Page)
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
DELPHINE ALLEN; et al;
Plaintiff,vs.
CITY OF OAKLAND, et al.,
Defendant.
MASTER CASE NO. C-00-4
JOINT STATUS CONFEREN
STATEMENT RE NON-MO
SETTLEMENT ISSUES
Date: March 17, 2011
Time: 10:30 a.m.Courtroom 2, 17TH FLOOR
Honorable Thelton E. Henderso
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GREGORY M. FOX, STATE BAR NO. 070876Bertrand, Fox & Elliot
The Waterfront Building - 2749 Hyde StreetSan Francisco, California 94109Telephone: 415.353.0999Facsimile: 415.353.0990Attorneys for Defendant CITY OF OAKLAND
JOHN A. RUSSO, CITY ATTORNEY, STATE BAR NO. 129729RANDOLPH W. HALL, CHIEF ASSIST. CITY ATTORNEY, STATE BAR NO. 0ROCIO V. FIERRO, SENIOR DEPUTY CITY ATTORNEY, STATE BAR NO. 13
OFFICE OF THE CITY ATTORNEYCITY OF OAKLANDOne Frank H. Ogawa Plaza, Sixth FloorOakland, California 94612Telephone: 510.238.3601Facsimile: 510.238.6500Attorneys for Defendant CITY OF OAKLAND
ROCKNE A. LUCIA, STATE BAR NO. 109349
Rains Lucia Stern, PCAttorneys & Counselors at Law
2300 Contra Costa Boulevard, Suite 230
Pleasant Hill, CA 94523Tel: 925-609-1699
Fax: 925-609-1690
Attorneys for OAKLAND POLICE OFFICERS ASSOCIATION
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PLAINTIFFS CURRENT POSITION
This is a further status conference concerning the progress of the non-mone
the Riders Litigation which was approved by the Court on January 22, 2003.
Plaintiffs attorneys submitted a Case Management Conference Statem
Management Conference that was to be held on December 9, 2010. The Decem
was cancelled by a court order filed on December 8, 2010. Plaintiffs incorporate
their earlier CMC Statement by reference into this Statement.
The Defendants CMC statement in December 2010 had numerous promis
to the effect that the OPD would be in compliance with critical tasks by the end of
2011. The Defendants even stated that the City believes that OPD will have ac
close to achieving substantial compliance by December 31, 2010. (8:11-13). The c
pointed out that:
As this Court has heard so many times before, Defendants believe that theybe in full compliance with the reforms to which they long ago agreed and
long ago orderedSuch rhetoric echoes that which has been repeatedly pre
the Court, including the exact same statementthat compliance will be ac
December 31five years ago
The Defendants empty rhetoric was verified when December 31, 2010 cam
like December 31, 2005) with no substantial compliance having been achieved b
Subsequently, the Independent Monitoring Team (IMT) issued its Fourth Qua
January 27, 2011. The IMT found that OPD was in compliance with 12 (55%
Tasks, in partial compliance with eight Tasks (36%), and not in compliance with o
deferred a compliance determination with one additional Task.
The OPD has not attained full compliance in vital tasks including Task
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regarding compliance issues. The Chief of Police appeared to be leaving for San
not chosen for the job there. He then indicated that he might not be committed to s
Subsequently, he met with the Mayor and decided to continue being Chief of
proposed dramatic changes in the IPAS system which would allow a rebuttal
officers to comments by supervisors. Plaintiffs attorneys strongly disapproved o
sent the Chief a letter which is attached hereto as Exhibit C. On March 7, 2011, th
his order until further notice. Plaintiffs attorneys understand the Chiefs c
supervisors communicate performance related observations to their personnel. Ho
believe that changes proposed by the Chief will accomplish this end and wish to b
proposed changes will not be implemented at a later date.
Defendants progress has been further complicated by efforts by the City
another job and by indications that the current City Manager will be replaced. O
note, the new Mayor appears to be willing to be more active in issues surroundin
and other issues related to the Oakland Police Department. It is too soon to
development will result in significant progress towards the OPD reaching substantia
It has also become apparent that there is tension between the OPD and the I
evident when not a single member of the command staff (Deputy Chief and ab
regularly scheduled exit interview of the IMT. This exit interview is held to in
significant developments that have occurred during the week when the entire IMT s
which only occurs on a quarterly basis.
The IMT has the full support of Plaintiffs attorneys. The current team
working and dedicated to their task. Plaintiffs attorneys have been surprised by th
the OPD and the IMT given the fact that (1) the current IMT (unlike their predecess
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compliance with the MOU.
The OPDs failure to achieve substantial compliance by January 24, substantial compliance will not be attained during the period of the second extensi
January 24, 2012 given the one year of substantial compliance required by the
Plaintiffs attorneys approached the City about a new extension in January 201
commitment from the City that (1) the parties would use their best efforts to
agreement by the March 17, 2011 CMC, and (2) if no significant progress towards
made by March 17, 2011, the parties would be prepared to set a date when any
brought by either Plaintiffs counsel, Defendants counsel, or the IMT pursuant to P
25 and/or 35 of the current MOU. Plaintiffs counsel wanted this commitment
would be afforded the opportunity to prepare and file such a motion while th
jurisdiction under the current MOU.
While plaintiffs counsel have had some productive discussions with the
there is no agreement to extend the MOU at this time and no assurance that such an
obtained. Plaintiffs attorneys proposal for a new MOU would give the Monit
order the OPD to redo investigations, integrity tests and other tasks until they are in
the MOU. The Monitor would also have a much greater presence in Oakland und
The defendants appear to be receptive to plaintiffs attorneys proposal in principle
to commit to any part of it. Instead, they proposed a last minute action plan that
days before this Case Management Conference Statement was due. While laudabl
any plan, will not put the OPD in compliance. Only the OPDs actions, and no
accomplish these tasks.
Plaintiffs attorneys believe that only a new approach will put the OPD into
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this court) over an eight year period, their unwillingness to work with the current
and their failure to commit to a plan to attain compliance in the foreseeable future.DEFENDANT CITY OF OAKLANDS POSITION
Mayor Jean Quan, City Administrator Dan Lindheim and Police Chief Anth
personally committed to a plan of action that will bring OPD into full and final co
NSA/MOU. Based on that commitment by its policy leaders OPD has revie
compliance and non-compliance and prepared the following report to the Court. T
be progress but the pace of compliance must be accelerated. This can onl
compliance is the number one priority for OPD in 2011. The Mayor and Chief of
it the number one priority.
It is clear that prior efforts have not been fully successful and thus a
necessary by the City and OPD. In this status report the City presents a new Actio
approval of Mayor Quan, City Administrator Lindheim and Chief Batts. The City
Action Plan to the plaintiffs attorneys and Chief Warshaw for review and comme
has been approval in concept but final judgment by the Monitor will be bas
performance of OPD implementing the Plan. Given the personal commitmen
Oaklands officials the City has every incentive to achieve compliance this year.
This Action Plan sets forth the criteria for compliance by OPD. Assum
accordance with this Action Plan the City believes all outstanding Tasks will be in
fourth quarter of 2011.The City fully understands that failure presents the risk of
possible appointment of a receiver. More important, the City also understands that
has been a personal disappointment to this Court. That is reason enough for the C
recharge its efforts to perform as promised under past Mayors and Chiefs of Police.
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Given the findings of the Monitor in his Fourth Quarterly Report dated Janu
City agrees with the plaintiffs attorneys that additional time is necessary for OPDreform work it started under the NSA and the MOU.
The parties have been discussing an amendment to the Memorandum
(Amended MOU). The Amended MOU would provide for the Court to continu
jurisdiction of this action for all purposes, consistent with the goal of completin
reform. The Amended MOU would require that the City and OPD continue the
achieving full and sustained compliance with the Reform Tasks not completed und
Initial MOU. The City and OPD believe its now time to focus the compliance
those Tasks that require special attention. A number of other Tasks should be rem
monitoring so economic and human resources may be concentrated on a targeted pla
For example, the Department has achieved substantial compliance for at lea
following Tasks based on the Monitors Fourth Quarterly Report and the OIGs i
inspections. The City and OPD have recommended to the Monitor and plaintiffs
Tasks be therefore removed from the list of actively monitored Tasks effective imm
Task Task Description Date Found in
Compliance
Date Achieved
Sustained Co
2 Timeliness Standards
for IAD investigations
Jun 2009 (First IMT)
(based on Aug-Oct 2008
data)
1st Quarterly Report
(based on Oct-Dec 2
4.7
4.10
Complaints are
reported to IAD on
day of receipt.
May 2009 (First IMT)
(based on Jul 2006-Apr
2008 data)
1st Quarterly Report
(based on Oct-Dec 2
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Task Task Description Date Found in
Compliance
Date Achieved
Sustained Co
5.3
5.6
5.12
5.19
5.20
5.21
(based on Oct-Dec 2009
data)
6 Refusal to accept a
citizen complaint
results in discipline
1st Quarterly Report - Apr
2010
(based on Oct-Dec 2009
data)
4th Quarterly Report
(based on July-Sep 2
18.2.
2
Supervisors ensure
witnesses are
identified during arrest
approval
1st
Quarterly Report - Apr
2010
(based on Oct-Dec 2009
data)
4th
Quarterly Report
(based on July-Sep 2
20.3
20.4
20.5
20.6
Span of Control for
Supervisors
1st Quarterly Report - Apr
2010
(based on Oct-Dec 2009
data)
4th Quarterly Report
(based on July-Sep 2
24.2
24.3
24.4
Use of Force reporting Jan 2010 (First IMT)
(based on Data Nov 2007-
April 2009)
4th Quarterly Report
(based on July-Sep 2
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Task Task Description Date Found in
Compliance
Date Achieved
Sustained Co30.2
30.3
Executive Force
Review Boards (Level
1 Force)
1st
Quarterly Report - April
2010
(based on Oct-Dec 2009
data)
4th
Quarterly Report
(based on July-Sep 2
35 Use of Force Reports
Witness
Identification
Jan 2010 (First IMT)
(based on Nov 2007
April 2009 data)
2nd Quarterly Report
(based on Jan-Mar 2
37 Internal Investigations
Retaliation Against
Witnesses
1st Quarterly Report - April
2010
(based on Oct-Dec 2009
data)
4th Quarterly Report
(based on July-Sep 2
43.1.
1
Academy and In-
Service Training
Jul 2009 (First IMT)
Conditional Compliance
3rd
Quarterly Report
(based on Apr-Jun 20
The following Tasks are now in-compliance based on the Monitors Quarter
OIG audits and inspections. OPD expects these tasks will show sustained practice c
necessary one year by December 31, 2011, and thus it has informed plaintiffs co
time these tasks should be removed from the list of tasks subject to active monitorin
or any amended MOU.
Task Task Description Date Found in Date One-Year
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Task Task Description Date Found in
Compliance
Date One-Year
Compliance Will5.5 Commander notified
of complaint
This Task was consistently
in compliance until 4th Qtr.
OPD has implemented
corrective measures and
anticipates compliance in
the 8th Report
(July September 20
5.17 Investigative notes are
permanently
maintained in IAD
case files
4th Quarterly Report
(based on July-Sep 2010
data)
7th Quarterly Report
(based on Apr-Jun 20
7.3 OPD accepts and
investigates
anonymous
complaints
2nd
Quarterly Report Aug
2010
(based on Jan-Mar 2010
data)
5th
Quarterly Report
(based on Oct-Dec 2
16 Supporting the IAD
process
2nd Quarterly Report Aug
2010
(based on Jan-Mar 2010
data)
5th Quarterly Report
(based on Oct-Dec 2
20.1 Sufficient sergeants
assigned to patrol to
allow for 1:8 ratio
3rd Quarterly Report Oct
2010
(based on Apr-Jun 2010
6th Quarterly Report
(based on Jan-Mar 2
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Task Task Description Date Found in
Compliance
Date One-Year
Compliance Will
used data)
25 Use of Force
investigations and
report responsibilities
3rd
Quarterly Report Oct
2010
(based on Apr-Jun 2010
data)
6th
Quarterly Report
(based on Jan-Mar 2
26.1 Force Review Board
Timelines
4th Quarterly Report
(based on July-Sep 2010
data)
7th Quarterly Report
(based on Apr-Jun 20
26.2
26.3
26.4
26.5
26.6
Force Review Boards
(Level 2 Force)
3rd Quarterly Report Oct
2010
(based on Apr-Jun 2010
data)
6th Quarterly Report
(based on Jan-Mar 2
30.1 Executive Force
Review Board
Timelines
4th Quarterly Report
(based on July-Sep 2010
data)
7th Quarterly Report
(based on Apr-Jun 20
33.3 Confidentially
reported misconduct
4th
Quarterly Report
(based on July-Sep 2010
data)
7th
Quarterly Report
(based on Apr-Jun 20
45.4 Consistency of
Discipline
2nd Quarterly Report Aug
2010
5th Quarterly Report
(based on Oct-Dec 2
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Implementation of the Action Plan will divert resources from other law enforcem
currently performing. Thus the City and OPD need clear agreement now by all
Action Plan to avoid future misunderstandings, changes in criteria and delays.
success must be clear and definite; there is no longer time to leave any element o
uncertain or unclear.
If the Monitor disagrees with some of the elements of the Action Plan;
suggestions on how compliance must be achieved, then the City requests that the
writing what specific or general actions are necessary for compliance for the R
Tasks. The City and OPD will review the Monitors compliance recommendatio
them assuming they comport with the economic and human resources available to
and OPD disagree with a recommendation then it will meet and confer with
plaintiffs counsel on a reasonable resolution. If the parties and the Monitor are un
reasonable resolution then either party and/or the Monitor may motion the cou
resolving the dispute so the Action Plan may be approved and implemented forthwit
The initial meet and confer between the parties and the Monitor has
However the parties and the Monitor have not had a face to face meeting to reach
Action Plan.. The parties and the Monitor have therefore agreed to meet in perso
conference on March 17 in court to complete the meet and confer on the Actio
consensus agreement that same day. If the parties need the guidance of the Court t
since we will all be present in court. The City is optimistic that this meeting will le
Action Plan so that it can begin to implement it without further delay.
Once the Action Plan has been approved and implemented the City and OP
Monitor review each Task for compliance. OPD will also meet and confer w
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recommendations and reasonable time to fix the deficiencies before issuing a form
compliance or partial compliance. If OPD is unable to resolve the problem the
proceed to issue a finding of non-compliance. If a dispute continues regarding the
party or the Monitor may motion the Court for a decision resolving the dispute.
Given the leadership and commitment of the Mayor and Chief of Police th
new Action Plan, once modified and/or approved by the Monitor, will lead t
compliance and one year practice compliance within the year of 2012. The Cit
plaintiffs attorneys that if the meet and confer process on an extension does not re
application for an Amended Memorandum of Understanding by June 1, 2011 than
motion the court for a hearing to resolve the matter with a hearing date of Mond
2011.
POSITIONOFINTERVENOR:OAKLANDPOLICEOFFICERSASSO
The Oakland Police Officers Association (OPOA, intervener) contin
parties in an effort to fully implement the Negotiated Settlement Agreement (NS
since the last CMC, the OPOA has attended numerous formal and informal meetin
Department representatives, and City personnel in order to facilitate NSA complianc
There have been a number of issues which have surfaced since the last
generated discussion and debate. Aside from the OPOAs stated concern over civi
Internal Affairs function at OPD, which is specifically set forth in correspondence
City Administrator Dan Lindheim dated February 16, 2011, none have appea
obstacles for further NSA compliance. The OPOA has had a number of discussio
concerning civilianization. At this point in time, the OPOA is not aware of any fo
efforts to civilianize Internal Affairs. The OPOAs stated concerns rest in part
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process of compliance and will continue to do so.
Finally, the OPOA is aware of the fact that other issues have been deb
several months, and it is unclear as to whether any of those issues will caus
implementation of the NSA.
Dated: March 10, 2011
/s/
JOHN L. BURRIS
Attorney for Plaintiffs
Dated: March 10, 2011
/s/
JAMES B. CHANINAttorney for Plaintiffs
Dated: March 10, 2011
/s/
GREGORY M. FOXAttorney for the Defendant
Dated: March 10, 2011
/s/
Rocio V. FierroAttorney for the Defendant
Dated: March 10, 2011
/s/
Rockne A. Lucia Jr.
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ATTORNEY ATTESTATION
I hereby attest that I have received telephonic or email authorization for any
indicated by a conformed signature (/s/) within this E-filed document.
Dated: March 10, 2011 /s/GREGORY M. FOX
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