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January 2011

January 2011
Volume 80
Number 1
United States
Department of Justice
Federal Bureau of Investigation
Washington, DC 20535-0001
Robert S. Mueller III
Contributors’ opinions and statements Features
should not be considered an
endorsement by the FBI for any policy,
program, or service.

The attorney general has determined Workplace Violence Prevention Vigorous prevention programs, timely
that the publication of this periodical
is necessary in the transaction of the
public business required by law. Use
By Stephen J. Romano,
Micòl E. Levi-Minzi, Eugene A.
1 intervention, and appropriate responses
by organizations and their employees
of funds for printing this periodical has will contribute significantly to a safe
been approved by the director of the Rugala, and Vincent B. Van Hasselt
Office of Management and Budget.
and secure work environment.

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The Training Division’s
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Workplace Violence W
orkplace violence, a
complex and wide-

spread issue, has
received increased attention
from the public, mental health
Readiness and Response experts, and law enforcement
professionals.1 The wide range
EUGENE A. RUGALA, and VINCENT B. VAN HASSELT, Ph.D. of acts that fall under this rubric
include all violent behavior and
threats of violence, as well as
any conduct that can result in
injury, damage property, induce
a sense of fear, and otherwise

January 2011 / 1
impede the normal course of According to a Bureau of Labor illustrated in figure 1, the right
work.2 Threats, harassment, Statistics report, 518 homicides end of the spectrum consists
intimidation, bullying, stalking, occurred in the workplace in of such acts as overt violence
intimate partner violence, physi- the United States in 2008.5 Most causing physical harm, nonfatal
cal or sexual assaults, and homi- recently, data revealed that 16 assaults with or without weap-
cides fall within this category.3 percent of workplace fatalities ons, and lethal violence. Mov-
Although a handful of high- resulted from assaultive and vio- ing toward the left end of the
profile incidents (e.g., mass lent acts.6 However, this being spectrum, behaviors become less
shootings at a workplace) have said, most workplace homicides physical and more emotional/
led to increased public aware- take place during robberies or psychological. These include
ness, prevalence rates show that related crimes. Finally, consid- disruptive, aggressive, hostile,
nonfatal workplace violence is ering actual reported workplace or emotionally abusive conduct
a more common phenomenon violence, it is estimated that that interrupts the flow of the
than previously believed. For ex- these events cost the American workplace and causes employ-
ample, a Bureau of Justice Sta- workforce approximately $36 ees concern for their personal
tistics Special Report estimated billion dollars per year.7 safety. Bullying, stalking, and
that approximately 1.7 million Recently, two of the authors, threatening appear on this end of
incidents of workplace violence Rugala and Romano, concep- the spectrum. At the far left end
occurred each year between tualized a workplace violence are behaviors of concern. Ac-
1993 and 1999, with simple and spectrum (adapted from the cording to Rugala and Romano
aggravated assaults comprising American Society for Indus- as well as others, individuals do
the largest portion.4 The same trial Security International) as not “snap” and suddenly become
report revealed that 6 percent a means of understanding and violent without an antecedent
of workplace violence involved categorizing crimes that oc- or perceived provocation.9 In-
rape, sexual assault, or homicide. cur within the workplace.8 As stead, the path to violence is an

Mr. Romano, a retired Ms. Levi-Minzi is a doctoral Mr. Rugala, a retired FBI Dr. Van Hasselt is a
FBI special agent, student at the Center for special agent, is with professor of psychology
operates a consulting/ Psychological Studies, Nova the Center for Personal at Nova Southeastern
training firm in Greenville, Southeastern University, in Protection and Safety in University in Fort Lauderdale,
South Carolina. Fort Lauderdale, Florida. Spokane, Washington. Florida, and a police officer
in Plantation, Florida.

2 / FBI Law Enforcement Bulletin

Behaviors Emotional Acts of Overt Nonfatal
of and Violence or
Concern Psychological Causing Lethal
Behaviors Physical Harm

Figure 1 - Workplace Violence Spectrum

evolutionary one often consist- Prevention helpful. Specific behaviors of

ing of such behaviors of concern Many corporations and orga- concern that should increase
as brooding and odd writings or nizations throughout the United vigilance for coworkers and
drawings. These can be subtle States have instituted programs supervisors include sadness,
indicators of the potential for to help prevent violence in the depression, threats, menacing or
violence and may be unusual or workplace. These efforts can go erratic behavior, aggressive out-
typical for an individual. a long way toward mitigating bursts, references to weaponry,
Several typologies of work- the threat of such occurrences. verbal abuse, inability to handle
place violence behaviors and Although no extant actuarial criticism, hypersensitivity to
events also have emerged over methods for predicting work- perceived slights, and offensive
the past few years.10 Rugala di- place violence exist, employees commentary or jokes referring
vides workplace violence into can take certain actions to re- to violence. These behaviors—
four types, or categories, of acts duce these incidents. First, it is when observed in clusters and
based on the relationship among critical to understand that work- coupled with diminished work
victims, perpetrators, and work place violence does not happen performance (as manifested by
settings (see figure 2).11 Type I at random or “out of the blue.” increased tardiness or absences,
incidents involve offenders who Rather, perpetrators usually poor coworker relations, and
have no relationship with either display some behaviors of con- decreased productivity)—may
the victims or the establishments. cern. Thus, awareness of these suggest a heightened violence
Type II events are those where indicators and the subsequent potential. It must be pointed out,
the offenders currently receive implementation of an action plan however, that no single behavior
services from the facilities (re- to de-escalate potentially violent is more suggestive of violence
tail-, health-, or service-industry situations form essential com- than another. All actions have to
settings) when they commit an ponents of workplace violence be judged in the proper context
act of violence against them. prevention. and in totality to determine the
Type III episodes involve those Behaviors of concern can potential for violence.
current or former employees help workers recognize poten- Not surprisingly, relation-
acting out toward their present tial problems with fellow em- ship problems (e.g., emotional/
or past places of employment. ployees. If a coworker begins psychological or physical abuse,
In Type IV situations, domestic acting differently, determining separation, or divorce) can carry
disputes between an employee the frequency, duration, and in- over from home to the work
and the perpetrator spill over into tensity of the new, and possibly setting.12 Certain signs that may
the workplace. troubling, behavior can prove help determine if a coworker is

January 2011 / 3
experiencing such difficulties Intervention violence, action points should be
include disruptive phone calls Intervention strategies must established as early as possible.
and e-mails, anxiety, poor con- take into account two aspects When an action point has
centration, unexplained bruises of the workplace violence spec- been identified, fellow employ-
or injuries, frequent absences trum: action and flash points. An ees can intervene in a number
and tardiness, use of unplanned action point is the moment when of ways. First, they can talk
personal time, and disruptive an individual recognizes that an with the person and “check in”
visits from current or former employee may be on the path to- to see if everything is all right.
partners. Care must be taken ward committing some type of Allowing people to vent about
when dealing with what can violent act in the workplace and stressful life situations can help
be highly charged situations. subsequently takes action to pre- them release tension.13 This type
Companies may lack the ex- vent it. Action points offer an op- of intervention should be used
pertise to handle these on their portunity for coworkers to inter- cautiously. If the individuals
own and may have to consult vene before a situation becomes display potentially threatening
with experienced professionals. dangerous. Given that human behaviors of concern, vigilant
Finally, all incidents are different behavior is not always predict- coworkers should report these
and must be viewed on their own able and that no absolute way directly to a supervisor. Work-
individual merits. Experience exists to gauge where an indi- ers also can relay information
has shown that no “one size fits vidual may be on the pathway, regarding questionable behav-
all” strategy exists. spectrum, or continuum toward iors to their human resources or

Type of Act Description of Act

Type I Offender has no relationship with the victim or workplace

establishment. In these incidents, the motive most often is
robbery or another type of crime.

Type II Offender currently receives services from the workplace, often

as a customer, client, patient, student, or other type of consumer.

Type III Offender is either a current or former employee who is acting

out toward coworkers, managers, or supervisors.

Type IV Offender is not employed at the workplace, but has a personal

relationship with an employee. Often, these incidents are
due to domestic disagreements between an employee and
the offender.

Figure 2 - Classification of Workplace Violence Acts

4 / FBI Law Enforcement Bulletin

Awareness Prevention
Taking the time to Survival Mind-Set Looking at the
understand the situa- workplace environ-
tion and knowing the ment through the
workplace environ- prism of survival and
ment well enough to asking the what-if
be able to recognize questions to be ready
changes. to do whatever it
Practicing plan either mentally takes to get through
or physically to gain confidence the incident.
and reduce response time.

Figure 3 - Survival Mind-Set

security department, ombuds- something.” Employees gener- Survival

man, or employee assistance pro- ally do not want to be viewed An awareness of the work-
gram. Moreover, if employees as undermining their peers and, place violence spectrum, along
feel unable to directly approach therefore, wait until they are cer- with knowledge of prevention
someone about a coworker, they tain that a situation is serious be- and intervention strategies, can
can communicate their concerns fore reporting it. Unfortunately, help increase safety in the work
via an e-mail or text message. at this point, it may be too late. setting. However, advance plan-
Companies have used drop This stresses the importance of ning and preparation for such
boxes, 24-7 tip lines, and ethics awareness on the part of employ- incidents and knowing how to
hotlines to allow employees to ees. Workers must be trained so respond if one occurs are im-
report suspicious behavior while that when behaviors of concern perative for survival. Of equal
maintaining their anonymity. occur, a “red flag” is raised and importance is recognizing the
A “flash point,” the mo- appropriate action taken. In this difference between an active-
ment when workplace violence strategy, awareness + action = shooter scenario and a hostage
occurs, is too late for any type prevention constitutes the key situation because of the different
of preventive strategy and best to prevention. By being aware approaches needed in each set of
avoided by implementing initia- of and acting on behaviors of circumstances.
tives early, once an action point concern, employees can help In a more personal vein,
has been detected. After a flash keep their workplace safe from realizing that the incident may
point, coworkers often indicate violence. Most important, com- end prior to the arrival of law en-
that they were concerned about panies must create a climate of forcement demonstrates the need
the offender but never reported trust within their organizations for workers to take responsibility
their suspicions. Consequent- that allows their employees to for their own lives, in part, by
ly, authorities emphasize that come forward to report troubling developing a survival mind-set,
“if you sense something, say behavior. which involves being ready (both

January 2011 / 5
mentally and physically) for the problem. While some may be prepared for a possible work-
worst-case scenario. While no subtle (e.g., verbal outbursts), place violence incident.
foolproof strategy for surviv- others are more obvious (e.g., The third element of the
ing an active-shooting incident gunshots). survival mind-set involves
exists, this type of mind-set has The second component of rehearsing for an event. This
the three components of aware- the survival mind-set, prepara- may include a mental rehearsal
ness, preparation, and rehearsal tion, entails employees becom- or a walk-through of the work-
which can provide a foundation ing stakeholders in their own place to determine possible exit
for survival (see figure 3).14 safety and security. In particular, routes or hiding places. This
Awareness means understand- they must change how they view can help inoculate employees
ing that workplace violence their work environment and shift against the stress of survival,
can impact anyone, in any work to a what-if way of thinking. For reduce their response time, and
setting, and across all levels of example, workers must consider build confidence in their ability
employment. Further, aware- what they would do if an active to survive. This idea is akin to
ness involves knowing the shooter was in the hallway or that of fire drills and role-play-
work environment well enough lobby of their office building. ing, which involve simulations
to recognize when changes oc- These types of scenarios will of real-world situations to teach
cur that may reflect a potential help them plan and be better new behavioral skills.15 Indeed,
practicing responses in advance
Figure 4 - Untrained and Trained Responses produces a more fluid and rapid
response in the event of a real
Incident of Workplace Violence incident.
Startle and Fear Figure 4 illustrates the dis-
parities in responses between
those who have and those who
have not been trained to deal
Trained Response Untrained Response with these types of stressful
situations. Both groups initially
react by being startled and
Anxious Panic experiencing fear. Then, they
begin to diverge: the untrained
panic, whereas the trained ex-
Recall Disbelief perience controllable anxiety.
From that point on, the trained
group members begin to recall
what they should do next, pre-
Prepare Denial pare, and act. The untrained,
however, experience disbelief
that eventually leads to denial
Commit to Act Helplessness and, ultimately, helplessness.
Knowing how differently the

6 / FBI Law Enforcement Bulletin

groups will react based solely on If escape is not feasible, em- always be possible. The shooter
training underscores the impor- ployees can take other actions. may directly confront workers.
tance of advanced preparation.16 For example, finding a hiding When this occurs, they must
The first response to an ac- place can mean the difference be prepared to know what they
tive-shooter incident is to figure between life and death. If an of- have to do and understand that
out what is occurring. For ex- fice space is available, workers neutralizing the shooter in some
ample, Hollywood has simulated can lock themselves in, barricade manner may be their only way to
gunshots in countless movies the door, and become very quiet survive. This involves behaviors
and television shows; however, so as not to alert the perpetrator. and a mind-set that few people
real gunfire sounds extremely Individuals gathered together ever have to consider. Coming
different. Rapidly assessing the should disperse because it is to terms with what needs to be
situation and evaluating avail- easier to inflict a greater number done and then committing to it

able options constitute the first will prove necessary and likely
steps toward survival. This may mean the difference between life
include evacuating the building; and death.
however, sometimes the only
alternative is concealment. The Awareness means
process of assessing the situation understanding that Active-shooter and hostage
and evaluating options will cycle situations are equally dangerous;
continuously through the minds
workplace violence both present a high risk for in-
of workers over the course of the can impact anyone, jury or death. However, it is im-
event. in any work setting, perative to know the difference
This type of assessment may and across all levels between them (see figure 5).
of employment.

point to the possibility of escape. Ranging from an individual
In that case, employees should to a group, active shooters oper-
leave as quickly as possible, with- ate in close quarters or distant
out seeking approval from others settings, choosing random or
or waiting to collect belongings. specific targets. Hostage takers
Once safe, they should immedi- of casualties when shooting at a also are armed and dangerous
ately contact emergency person- group or cluster of people; there- individuals who may or may
nel. In these situations, phone fore, spreading out will create not use deadly force.17 But, one
lines often become jammed, or confusion and provide fewer tar- main difference is that an active
individuals may think others gets, resulting in fewer victims. shooter may have unrestricted
have contacted authorities when, Another critical action is ongo- access to victims, whereas a
in reality, no one has called for ing communication with fellow hostage taker is restricted either
help. Once connected to an emer- employees. Keeping everyone by choice or the presence of law
gency operator, certain informa- informed of the situation and enforcement. Hostage takers and
tion, if known, should be relayed: helping the injured are important their captives often are contained
description and location of the to surviving an active-shooter in a specific space and surround-
perpetrator, number and types of event. ed by law enforcement until the
weapons used, and an estimate Although escaping or hid- situation is resolved.
of the number of people in the ing from danger are solid sur- Moreover, hostage takers
building. vival strategies, they may not differ in that they subscribe to

January 2011 / 7
Type of Perpetrator Description of Perpetrator

Active Shooter An individual with a firearm who begins shooting in the


Hostage Taker An armed individual who may or may not use deadly force, has
restricted access to victims, and eventually will be contained
with hostages. This type of perpetrator is motivated in one of
two ways.
1. Substantive: Motivated by things the perpetrator cannot
obtain, including money, social or political change, and escape.
These individuals use hostages as pawns to achieve their goals.
2. Expressive: Motivated by a loss, including job or relation-
ship. These individuals act out of emotion and often behave in
senseless, reckless ways with no clear goals.

Figure 5 - Perpetrators

either substantive or expressive situation. Patience on their identity of the perpetrator. Also,
motives.18 Substantive motives part is essential for survival. their only goal is to neutralize
involve money, material items, Some recommended strategies or stabilize the situation. Police
escape, and social or political include remaining calm, fol- officers are taught that hands
change that hostage takers can- lowing directions, and not being kill. Therefore, it is important
not obtain on their own. Perpe- argumentative or irritating to the for victims to raise their arms,
trators with expressive motives perpetrator. Further, it is critical spread their fingers, and drop
are compensating for a loss (e.g., for captives to find a “neutral to the floor while showing that
end of a relationship or job) and ground” where they are neither they do not have any weapons
appear irrational because their too assertive nor too passive with or intention of harming anyone.
actions are emotionally driven. their captor.20 Finally, once they have made
The motives of hostage takers Although negotiating to end contact with officers, survivors
generally do not include harm- the hostage-taking scenario should relay any information
ing captives because this would is preferable, sometimes law that may help, such as how many
completely change the situation enforcement must neutralize shooters were present, identities
and the consequences.19 Those the perpetrator. Police may use and location of them, and weap-
who operate based on substan- SWAT, active-shooter, or rapid- ons used.
tive motives do not want to harm deployment teams.21 If this is the
their captives because they need case, captives should take certain Conclusion
them as pawns to achieve their actions and avoid others to help Workplace violence is a
goals. law enforcement safely and ef- prevalent and complex prob-
It is important for individuals ficiently resolve the situation. lem. While certain high-profile,
held captive to remember that For example, when responding catastrophic incidents have
it will take law enforcement law enforcement officers arrive, drawn the attention of the media
negotiators time to resolve the they are not initially aware of the and the public, numerous events

8 / FBI Law Enforcement Bulletin

go unreported. Workers should
learn about workplace violence,
recognize the behaviors of con-
cern, and remember that aware-
ness + action = prevention. If an
incident does occur, they should
be able to distinguish a hostage
taker from an active shooter so
that they can determine how to
behave to increase their chances
of survival.
Research has shown that
many of these situations are
over in minutes and law en-
forcement may not arrive in
time. As a result, employees
have to become stakeholders
in their own safety and security
and develop a survival mind-set
© Thinkstock.com
comprised of awareness, prepa-
ration, and rehearsal. Vigorous and Environmental Medicine 3 (2003): 9
J.C. Campbell, ed., Assessing Dan-
prevention programs, timely 775-789. gerousness: Violence by Sexual Offenders,
intervention, and appropriate B. Booth, G. Vecchi, E. Finney, V. Batterers, and Child Abusers (Thousand
Van Hasselt, and S. Romano, “Captive- Oaks, CA: Sage, 1995); and J.R. Meloy,
responses by organizations and Taking Incidents in the Context of Work- Violence Risk and Threat Assessment: A
their employees will contribute place Violence: Descriptive Analysis and Practical Guide for Mental Health and
significantly to a safe and secure Case Examples,” Victims and Offenders 4 Criminal Justice Professionals (San Diego,
work environment. (2009): 76-92. CA: Specialized Training Services, 2000).
4 10
U.S. Department of Justice, Bu- S. Albrecht, Crisis Management for
reau of Justice Statistics, Violence in the Corporate Self-Defense (New York, NY:
Endnotes Workplace, 1993-99 (Washington, DC: Amazon, 1996); R. Denenberg and M.
R. Borum, R. Fein, B. Vossekuil, Government Printing Office, 2001). Braverman, The Violence-Prone Workplace:
and J. Berglund, “Threat Assessment: U.S. Department of Labor, Bureau of A New Approach to Dealing with Hostile,
Defining an Approach for Evaluating Labor Statistics, Fatal Occupational In- Threatening and Uncivil Behavior (Ithaca,
Risk of Targeted Violence,” Behavioral juries from Transportation Incidents and NY: Cornell University Press, 1999); and
Sciences and the Law 17 (1999): 323-337; Homicides (Washington, DC: Govern- G.R. Vanderbos and E.Q. Bulatao, eds.,
E.A. Rugala, U.S. Department of Justice, ment Printing Office, 2008). Violence on the Job: Identifying Risks
Federal Bureau of Investigation, Criti- U.S. Department of Labor, Bureau and Developing Solutions (Washington,
cal Incident Response Group, National of Labor Statistics, Census of Fatal Oc- DC: American Psychological Association,
Center for the Analysis of Violent Crime, cupational Injuries Charts, 1992-2008 1996).
Workplace Violence: Issues in Response (preliminary data) (Washington, DC: E.A. Rugala, Workplace Violence:
(Quantico, VA, 2004); and M.D. Souther- Government Printing Office, 2009). Issues in Response.
7 12
land, P.A. Collins, and K.E. Scarborough, U.S. Department of Justice, Bureau Booth, Vecchi, Finney, Van Hasselt,
Workplace Violence: A Continuum from of Justice Statistics, Violence in the Work- and Romano, “Captive-Taking Incidents
Threat to Death (Cincinnati, OH: Ander- place, 1993-99. in the Context of Workplace Violence:
son, 1997). American Society for Industrial Descriptive Analysis and Case Examples”;
E.A. Rugala and J.R. Fitzgerald, Security, Workplace Violence Prevention and G.M. Vecchi, V.B. Van Hasselt, and S.J.
“Workplace Violence: From Threat to and Response Guideline (Alexandria, VA: Romano, “Crisis (Hostage) Negotiation:
Intervention,” Clinics in Occupational ASIS International, 2005). Current Strategies and Issues in High-Risk

January 2011 / 9
Conflict Resolution,” Aggression and in press); and V.B. Van Hasselt and S.J. Negotiation: Current Strategies and Issues in
Violent Behavior: A Review Journal 10 Romano, “Role-Playing: A Vital Tool in High-Risk Conflict Resolution.”
(2005): 533-551. Crisis Negotiation Skills Training,” FBI G.W. Noesner and J.T. Dolan, “First
R.K. James and B.E. Gilliland, Law Enforcement Bulletin, February 2004, Responder Negotiation Training,” FBI Law En-
Crisis Intervention Strategies, 4th ed. 12-17. forcement Bulletin, August 1992, 1-4; and S.J.
(Belmont, CA: Brooks/Cole, 2001). Van Hasselt and Romano, “Role- Romano and E.A. Rugala, Workplace Violence:
S.J. Romano and E.A. Rugala, Playing: A Vital Tool in Crisis Negotiation Survival Mind-Set (Spokane, WA: Center for
Workplace Violence: Mind-Set of Aware- Skills Training.” Personal Protection and Safety, 2008).
17 19
ness (Spokane, WA: Center for Personal S.J. Romano and M.F. McMann, Romano and Rugala, Workplace Violence:
Protection and Safety, 2008). eds., U.S. Department of Justice, Federal Survival Mind-Set.
15 20
M.E. Levi-Minzi, S.L. Browning, Bureau of Investigation, Critical Incident Ibid.
and V.B. Van Hasselt, “Role-Playing as Response Group, Crisis Negotiation Unit, T.L. Jones, SWAT Leadership and Tacti-
a Measure of Program Effectiveness,” Crisis Negotiations: A Compendium cal Planning: The SWAT Operator’s Guide to
in The Encyclopedia of Peace Psychol- (Quantico, VA, 1997); and Vecchi, Van Law Enforcement (Boulder, CO: Paladin Press,
ogy (New York, NY: Wiley-Blackwell, Hasselt, and Romano, “Crisis (Hostage) 1996).

Notable Speeches

T he FBI Law Enforcement Bulletin seeks transcripts of presentations made by criminal

justice professionals for its Notable Speech department. Anyone who has delivered a
speech recently and would like to share the information with a wider audience may submit a
transcript of the presentation to the Bulletin for consideration.
As with article submissions, the Bulletin staff will edit the speech for length and clarity,
but, realizing that the information was presented orally, maintain as much of the original
flavor as possible. Presenters should submit their transcripts typed and double-spaced on
8 ½- by 11-inch white paper with all pages numbered, along with an electronic version of the
transcript saved on computer disk, or e-mail them. Send the material to: Editor, FBI Law En-
forcement Bulletin, FBI Academy, Outreach and Communications Unit, Quantico, VA 22135,
or to leb@fbiacademy.edu.

10 / FBI Law Enforcement Bulletin

Police Practice

The Child and Family

Leadership Exchange
By Gerald Kelley

P olice departments continually strive to

maintain and improve their relationships
with those they serve. Such positive connections
benefit the community and increase an agency=s
effectiveness. Of Sir Robert Peel=s Nine Prin-
ciples of Policing, five directly mention relation-
ships with the public as essential for law enforce-
ment organizations to perform their duties.2
Similarly, a police agency=s partnerships with
its professional associates are just as crucial for
effectiveness. Collaboration and coordination
among working partners brings about informa-
tion sharing that makes each organization=s deci-
sion making more thorough. This is especially
true of police units that investigate crimes against
juvenilesCin particular, those targeting children.
In Ohio, state law mandates the coordination
of child abuse investigations with the county=s
children=s service agency, as well as with
children=s advocacy centers, whose members
include both public and private organizations.3

To me, teamwork is a lot like being part of

a family. It comes with other obligations,
entanglements, headaches, and quarrels.
But the rewards are worth it.1

- Pat Summit

January 2011 / 11
While these dual investigations by separate entities families.@4 Participants gain an in-depth under-
both are directed at protecting the child, they have standing of the county=s child and family services
different focuses. Law enforcement departments from point of discovery through assessment, legal
want to make an arrest and remove the threat of the intervention, case management, and treatment.
suspect. Social service agencies strive to protect The program incorporates a detailed examination
the well-being of the child and provide assistance of the system=s strengths and weakness and identi-
to the victim and the family. Complications arise fies techniques for cultivating and advocating for
because children=s service agencies follow state- improved services.
mandated time restrictions for the completion and
reporting of their investigations. However, law Structure
enforcement investigations can continue longer CFLE begins with an orientation luncheon,
before a case decision is made, especially if the which gives class members the opportunity to meet
criminal case depends on one another and learn about
DNA or other forensic tests each other=s job and back-

that may take months for ground. A community lead-
completion. The individual ers= reception follows. This
agencies involved do not al- introduces the participants to
ways understand others= time Collaboration and past CFLE graduates, as well
policies and investigative coordination among as local political and business
practices. working partners brings leaders. At the end of the pro-
To provide a mutual un- about information gram, class members partici-
derstanding of the different sharing that makes pate in a graduation ceremony.
roles each organization has in each organization’s A series of individual sessions
the protection of children, the decision making constitute the majority of the
Summit Forum, a collabora- more thorough. 10 months.

tion of local private and gov-
ernment officials, developed Individual Sessions
the 1-day Close Up program, The monthly sessions last
included in the county= s mostly 1 day and are grouped
month-long Child Abuse and Family Awareness into common service-provider categories. Prior to
program. Through the interaction of area profes- each session, class members participate in related
sionals, Close Up illustrated the process of service preclass assignments hosted by the agency provid-
delivery to children and families at risk. Drawing ing the upcoming presentation. This gives each
from the success of the 1-day program and the in- participant firsthand experience with the organiza-
terest of other service providers in involving their tion. After each session, class members evaluate
organizations= processes, the Child and Family the day=s activities and the preclass assignments.
Leadership Exchange (CFLE) began. Each year, the executive committee reviews the
past year=s curriculum and suggests ways to im-
THE PROGRAM prove CFLE using these evaluations as a starting
The mission of the 10-month CFLE is Ato point. Recommendations then are reviewed with
promote excellence in leadership among Sum- each session head, and, if necessary, the program
mit County professionals serving children and is changed for the next year.

12 / FBI Law Enforcement Bulletin

Overnight Retreat
This longest session lasts
a day and a half. Participants
learn about challenges facing the
community in helping families
meet demands posed by societal
changes, how the human ser-
vice system functions to create
a network to help families be-
come whole and complete, and
methods to promote awareness
of issues that interfere with the
well-being of children.
It begins with a discussion,
AThe Challenge of Changing
Times,@ conducted by a panel
consisting of representatives © Thinkstock.com
from children=s service agencies,
job and family service organizations, health de- the criminal justice system and how their investi-
partments, organizations specializing in mental re- gations interconnect.
tardation and development, children=s hospital, the Law enforcement discussions involve the
legal system, police departments, and additional investigative process from assigning the initial
agencies as needed. These entities discuss their case to determining if an arrest is to be made. This
roles in providing community services and the includes a review of past investigations and the
challenges they face in both day-to-day activity problems encountered while conducting them.
and long-term planning. Following the panel dis- Questions asked by members of the class often
cussion, participants cover current issues during begin with AI saw on TV where@ and this leads to
follow-up sessions. Recent topics have included a discussion on admissible evidence, police prac-
bullying and family violence issues. Subjects vary tices, criteria needed before an arrest can be made,
from year to year and reflect both community and elements of a prosecutable case.
and national concerns involving children and
families. Court Involvement
Following the investigative session, the pro-
Investigation gram covers the role of the court. This is not only
and Assessment the criminal court when an arrest has been made
This session shows how agencies involved but also the civil court where custody of the chil-
with investigating child abuse work together. Pre- dren becomes an issue. Representatives from the
class assignments include riding with a uniformed domestic relations, probate, and criminal courts
police officer during a shift, training on a firearms participate in this session.
simulator, and observing as a social worker meets In addition to presentations by each agency,
with a client. A prosecutor and representatives the class tours the various facilities, including the
from the children=s service board, children=s hos- juvenile detention center. The session ends with a
pital, and law enforcement all explain their part in panel discussion and a hypothetical scenario.

January 2011 / 13
Family Support Services were helped and what problems they encountered
The objective of this session is to promote during the process.
awareness of the range of resources and services
available in the community. Preclass assignments Leadership and Important Decisions
include visiting the agencies, giving class members During this session, the class travels to the
an opportunity to both observe the organization and state capital and meets with government leaders.
ask questions concerning its operation. Represen- Participants review a proposed law that involves
tatives participating include those from the areas children and families and question the state rep-
of mental retardation and development, housing, resentatives about it. This includes whether they
and health care, as well as the Urban League. At support the law or not and why. If available, the
the suggestion of past class class observes hearings on the
members, participants also bill that they reviewed.

include representatives from
the metro transit authority, Close Up and Prevention
which provides clients with- …working together
out available transportation The last session focuses on
as a team can make an emerging area of concern
a way to get to scheduled the task of providing
appointments. for professionals serving chil-
better service to the dren and families and discusses
Media Relations Day community’s children available programs. Topics
This event brings in and families easier. vary from year to year, and

members from the local the answers to the problems
print and broadcast me- are not always what the class
dia. They explain how the expects. It highlights what the
media interacts with com- professionals face in making
munity agencies and keeps decisions that have lasting ef-
the public informed of available services or the fects on the involved individuals and community
lack thereof. Discussions have included the First services. Last year=s topic, date rape, produced
Amendment and the role of the media in the com- many questions and varying viewpoints.
munity. At the end of the session, class members
are Ainterviewed@ by a local TV reporter so they FEEDBACK
can experience the receiving end of the camera. Since the CFLE began, over 375 participants
from 28 agencies have completed the program.
Treatment Services It certainly seems to cultivate excellence among
Follow-up treatment is very important for Summit County professionals and provide a sense
victims. In this session, representatives from the of cooperation among the various organizations.
Child Guidance and Family Solutions and the One attendee said, AMeeting and interacting with
Community Health Center, both based in Akron, others in similar fields provided me with many
explain the services they provide in both group and different perspectives of addressing similar prob-
individual sessions. If available, clients of one of lems.@ Another stated, AI have already used the
the services address the class and explain how they contacts I made in assisting me in my work.@ A

14 / FBI Law Enforcement Bulletin

third participant declared about newfound knowl- protection professionals can improve the services
edge of other agencies, AI have learned so much they provide to the individuals they serve.
that will forever change my view of their work.@
Pat Summit and Sally Jenkins, Reach for the Summit (New
Throughout the year, the Child and Family York, NY: Broadway Books, 1998).
Leadership Exchange stresses that working togeth- 2
er as a team can make the task of providing better (accessed June 11, 2010)
Ohio Revised Code: 2151.42.1 (D)(1) and 2151.42.1 (F)(1):
service to the community=s children and families Reporting Child Abuse or Neglect; and Ohio Revised Code:
easier. It recognizes the problems that individual 2151.42.1 (D)(2)(b): Reporting Child Abuse or Neglect.
organizations have with outside collaboration, 4
such as agency-specific policies, procedures, and ChildFamilyLeadershipExchange/tabid/84/Default.aspx
interpretation of laws. The program works to iden- (accessed June 11, 2010)
tify, address, and overcome these issues or at least
Lieutenant Kelley is the unit commander for the Juvenile
have one agency understand another=s point of Bureau of the Akron, Ohio, Police Department.
view. By working together, the community=s child

The Bulletin’s
E-mail Address
© Digital Vision

T he FBI Law Enforcement Bul-

letin staff invites you to commu-
nicate with us via e-mail. Our e-mail
address is leb@fbiacademy.edu.
We would like to know your
thoughts on contemporary law en-
forcement issues. We welcome your
comments, questions, and suggestions
about the magazine. Please include
your name, title, and agency on all
e-mail messages.
Also, the Bulletin is available for
viewing or downloading on a number
of computer services, as well as the
FBI’s home page. The home page
address is http://www.fbi.gov.

January 2011 / 15
Safeguard Spotlight

Responding to a Child Predator’s Suicide

W hen officers investigating cases that

expose them to child pornography
and child exploitation materials experience
• Following a subject suicide, it is accept-
able and possibly appreciated to ask
people about their thoughts and feelings.
the suicide of a subject, what “typical” or Talking about suicide is not taboo; it actu-
“normal” responses might they have? In fact, ally can give individuals an opportunity
investigators have a wide range of reactions in to share their perspectives. During assess-
these instances. ments, USU personnel have spoken to
The FBI’s Undercover Safeguard Unit officers who previously had not discussed
(USU) has found that the more face-to-face their reactions; doing so gave them relief.
contact officers had with the subject, the more Nonprofessionals should speak and listen
potential conflict may characterize their re- to their colleagues about their reactions to
sponse to the suicide. USU personnel currently suicide.
are researching this trend. • If people cheer upon learning of a sui-
Investigators may fall back on their sense cide, it is appropriate to point out that not
of just anger because of the egregious nature everyone responds the same way. Provid-
of child predatory acts. These officers may ing tangible rules pertaining to behavior
hear about a subject suicide and consider it a during critical times actually may relieve
tangible end to an overwhelmingly rampant some discomfort, particularly when
and potentially vicious crime. people are unsure about what to say or do
Considering the wide range of possible in the midst of a suicide.
reactions, how might a supervisor or team
member respond to a group of investigators? • Public displays of the subject suicide,
USU personnel offer some constructive steps such as posting pictures of the deceased
worthy of consideration. individual or a “predator suicide list” on
• Before a subject suicide, educate and talk the office wall, can make some people
to your team members about the diversity uncomfortable in the workplace. Such
of reactions they may encounter. During, actions also can give the impression to the
perhaps, a staff meeting, ask them how public that the agency encourages subject
they might expect to react or how they suicide. Further, imagine a family member
have responded in the past. Emphasize of the subject entering the office and see-
that it is normal for people to not know ing such displays; remember, they also are
how to react in unusual circumstances— victims.
the suicide of a child predator certainly • Find appropriate ways for you and your
fits this category. team to control anger. Encourage peer

16 / FBI Law Enforcement Bulletin

discussion and provide team-building time Contact USU if you have questions about
and excursions. These cases make many of- debriefings following a subject suicide. We
ficers feel primarily shock and anger. While can assist you or refer you to someone else
investigators may compartmentalize such who can help. Unit personnel can provide
feelings, anger still is a normal response to education about the psychological impact of
extreme human violation and, perhaps, even working these cases.
necessary for officers to continue prosecuting
these charges. However, personnel must fun-
nel this anger in constructive ways. Perhaps,
provide investigators an as-needed break. Dr. Nicole Cruz of the FBI’s Undercover Safeguard
Sometimes, “dark” humor helps to detoxify Unit (USU) prepared this Safeguard Spotlight. USU
provides guidance and support for personnel exposed
exposure to horrific activity; however, al- to child pornography and child exploitation materials.
though normal, it also may signify a need for The unit can be contacted at 202-324-3000.
more ways to ventilate.

“One less child predator in the world....”

“I know that I’m not responsible, but, somehow,
I feel somewhat responsible.”
“What about all the time I put into this case…
all for nothing….”
“That poor family....”
“I’ve never been traumatized by the images, but
I was traumatized by this.”
“I never signed on to do this type of work and
see someone die like that....”
“Everyone is happy about it, but I talked to the
guy and I feel upset. I have no one to talk to
about it....”
“He got off easy.”

January 2011 / 17

Strategies for Curbing

Organizational Politics
By Tracey G. Gove, M.P.A.

© Thinkstock.com

U ndoubtedly, police work involves danger.

While law enforcement officers are highly
trained and well equipped to meet the challenges
Detective Lieutenant Gove
of the West Hartford,
Connecticut, Police
they face on the street, a hidden danger lies within Department is an adjunct
the police organization itself. Though this danger faculty member at
Manchester Community
may remain largely unseen and ignored, it deeply College in Connecticut.
entrenches itself within the agency’s culture and
daily operations. This foe, which lurks below the
surface of most workplaces, is a complex and sin-
ister web known as “office politics.” Left unabated,
such political games destroy employee morale and
sap an agency’s time and resources. Fortunately,
law enforcement officers and supervisors can take
steps to minimize these negative effects.

18 / FBI Law Enforcement Bulletin

Office politics often are easier to recognize Law enforcement agencies are especially sus-
than to describe. The general term politics simply ceptible to the influence of internal political games.
describes a competition for power, but office poli- As highly structured organizations, agencies’ strict
tics involves those who seek power at the expense hierarchy of titles and ranks allows employees
of others, with an “I win, you lose” attitude. Office at all levels to exercise authority. These factors,
politics are behaviors that maximize self-interest coupled with the competitive, type-A personalities
and conflict with the collective goals and interests of many law enforcement professionals, inevitably
of others.1 create a highly charged political environment.
These divisive behaviors take many forms. At
its worst, office politics manifest as outright ma- Strategies for Officers
nipulation and sabotage for the sake of one’s own In law enforcement organizations, internal
upward mobility, power, or success. These tactics politics often affect officers more than anyone else.
function as a means to win the regard of superiors While the political games of peers and immediate
or key decision makers, both in and outside of the supervisors impact officers directly, the byprod-
agency. Instead of honest, professionally built re- ucts of upper-echelon political drama may trickle
lationships, office politicians down to the agency’s lower
build relationships through levels as well. Strategies

deceit and chicanery. exist that can help officers
More often, though, avoid becoming personally
workplace politics take the Left unabated, entangled in the political
more subtle forms of mali- such political games web.
cious gossip, rumors, or Long hours at work with
criticism through which the
destroy employee little activity often lead offi-
office politician controls the morale and sap an cers to share many personal
flow of information. For ex- agency’s time and thoughts and ideas. Officers
ample, office politicians may resources. should remember that a co-

spread nuggets of bad infor- worker can and likely will
mation that discredit and ruin repeat whatever they say,
the reputation of a coworker, so they should not reveal
or they might exploit the anything sensitive. Also, of-
weaknesses of others to make them appear less ficers should not repeat anything that a coworker
competent. With these tactics, office politicians tells them in confidence as this can and surely will
aim to undermine coworkers whom they perceive cause negative repercussions in the future.
as threats to success. When officers strive for a special assignment,
Employees play political games regardless of promotion, or just a successful, enjoyable career,
their education, intelligence, or position of author- they must rely on personal merit alone. To reach
ity. Intelligent, confident people who will do any- their professional goals, officers need not resort
thing to climb the promotional ladder often adopt to politicking; instead, they should improve them-
such tactics; or, those who perceive themselves selves professionally through higher education,
as less competent may resort to political games to specialized training, and simple hard work. If
compensate for their shortcomings. officers set goals and couple them with appropriate

January 2011 / 19
strategies, they always will outperform those who in the workplace causes long-term complications
rely on political maneuvers. Additionally, if of- when grievances are repeated.
ficers dedicate their time toward their professional
development, they will have less time to worry Approaches for
about the ambitions of others.2 Supervisory Personnel
Officers should not rationalize, either internally Because of their managerial position, supervi-
or externally, any negative behaviors that they ex- sors play a pivotal role in curbing workplace poli-
hibit in pursuit of their goals. Officers might think tics; unfortunately, supervisors may exacerbate the
“everyone does it” or “they did not deserve that problem if they engage in political behavior them-
promotion,” but these are only weak attempts to selves. Supervisors can take steps to minimize
justify improper and even unconscionable behav- political maneuvering in their offices.
ior.3 Humans can rationalize • They should keep an eye
just about anything, but, out for political behavior
in the end, political games not only in others but also
most likely will hurt only the in themselves. Supervisors
player’s career. are only human and, thus,
Officers need to develop may feel tempted to play the
emotional and social intel- political game when they
ligence by building healthy might benefit personally.
relationships at all levels Such behavior, however,
within their organization. will destroy trust and weak-
This opens lines of commu- en employee performance.4
nication and prevents mis- Unfortunately, a political
understandings about the be- web often is so subtle and
haviors and actions of others. complex that it can ensnare
Similarly, officers should pay supervisors before they ever
proper courtesy and respect © Thinkstock.com realize it exists.5 To escape
to all coworkers and not align this trap, supervisors should
with cliques or social groups. Networking, while keep their antenna tuned to both the inter-
important, need not exclude others. nal workings of their agency and their own
When officers make personal complaints, they behavior.
should follow proper procedures and handle them
• Supervisors should pay attention to the infor-
through the appropriate chain of command. Ide- mal leaders and power players among their
ally, officers should express their grievances to subordinates. Officers become leaders not just
a spouse or trusted friend outside of the agency. through formal promotion; certain frontline
Often, however, fellow law enforcement officers officers attract and keep a loyal following
more easily relate to job frustrations because they of peers. If the formal hierarchy acts as the
understand the unique characteristics of police skeleton of an organization, these informal
work. If officers confide in a fellow law enforce- networks function as the central nervous
ment professional, they should carefully choose a system.6 If supervisors want to successfully
select few confidants whom they trust to keep their navigate this political environment, they must
concerns in confidence. If not, unchecked venting keep abreast of the informal power networks

20 / FBI Law Enforcement Bulletin

that build it. Supervisors can gain insight to • Instead of involving themselves in the
this complex web of relationships if they ob- political arena, supervisors should develop
serve and study the workplace interactions of their managerial skills and encourage open
their coworkers. and transparent communication from their
• Upper-level administrators should ensure that subordinates. Effective communication
their agencies maintain a zero-tolerance policy eliminates the deadly grapevine and rumor
that clearly prohibits unnecessary criticism mill; otherwise, communication voids will
and disparaging comments, as well as mali- be filled with any available information
cious gossip, rumors, and other disinformation. regardless of its accuracy. Poor commu-
Agencies must not only maintain a written nication, even unintentional, facilitates a
policy but also strictly enforce it at all levels destructive political culture.9
in the agency. Supervisors should not gossip • Supervisors must coach, mentor, and set
or talk about coworkers behind their backs, goals with their subordinates. A manager’s
especially in front of day-to-day duties in-
subordinates. clude more than extin-

• Supervisors should guishing “fires” that
examine how they erupt; they also should
measure success among Supervisors should work closely with per-
their subordinates to en- sonnel on their profes-
examine how they sional development.
sure that their standards measure success among
do not reward political This type of leader-
behavior. If supervi-
their subordinates ship lessens the risk of
sors bestow promotions to ensure that their employees resorting to
and plumb assignments standards do not reward deceptive practices to
based on personal rela- political behavior. accelerate their careers.

tionships or favor, then All of these proposed
they encourage a highly strategies to counter of-
political environment. fice politics are mostly
Promotions and desir- informal approaches. At
able assignments only should go to workers times, however, organizational politicking rises
who possess a relevant track record of success to a level that requires more formal action (e.g.,
and the requisite skills for the new position.8 if an employee violates a zero-tolerance policy).
• Similarly, upper-level administrators should In these instances, supervisors should discipline
analyze their agency’s rewards and recognition employees according to their organization’s
process. To ensure fairness and supplant hid- standards, and officers should report misbehav-
den agendas, supervisors should apply objec- ior through the official complaint process. Ad-
tive standards toward their recognition criteria. ditionally, both supervisors and officers should
Law enforcement organizations must design consider using their union, human resources
their recognition process so that supervisors department, or state labor board; each mediates
only reward their employees based on objec- a variety of disputes, complaints, and discrimi-
tive criteria rather than as a personal favor. nation issues.

January 2011 / 21
Conclusion Endnotes
Law enforcement organizations must certify Eran Vigoda-Gadot, “Leadership Style, Organizational Politics,
and Employees’ Performance: An Empirical Examination of Two Com-
that their culture, policies, and operations discour- peting Models,” Personnel Review 36, no. 5 (2007): 661-683.
age an excessively political environment—a task, 2
Biagio W. Sciacca, “Don’t Turn Your Back on Organizational
no doubt easier said than done. Agency leaders Politics,” Pennsylvania CPA Journal (Fall 2004).
should remember that above all, employees want 4
“Coping with Office Politics,” http://www.bnet.com/article/
their organizations to operate fairly. Objective coping-with-office-politics/57033?tag=mantle_skin;content
standards for assignments and promotions, trans- (accessed November 17, 2010).
parent communication, and opportunities for pro- Scott J. Harr and Karen M. Hess, Careers in Criminal Justice and
Related Fields: From Internship to Promotion (Belmont, CA: Wads-
fessional development all foster an environment worth Cengage Learning, 2006).
where political maneuvers do not replace hard 6
David Krackhardt and Jeffrey R. Hanson, “Informal Networks:
work, honesty, and accomplishment. Law enforce- The Company Behind the Chart,” Harvard Business Review, July-
August 1993.
ment officers already have inherently dangerous 7
Louellen Essex and Mitchell Kusy, “Playing the ‘Office Politics’
jobs, and an agency’s internal politics need not Game,” Training + Development, March 2008, 76-79.
cause officers more stress than the conditions on 8
“Coping with Office Politics.”
the street. “Coping with Office Politics.”

FBI Law Enforcement Bulletin

Author Guidelines
Length: Manuscripts should contain 2,000 consideration by other magazines. Because it
to 3,500 words (8 to 14 pages, double-spaced) is a government publication, the Bulletin can-
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study several issues of the magazine and con-
Format: Authors should submit three
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lications/leb/leb.htm for the expanded author
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Criteria: The Bulletin judges articles on a publication date for accepted articles, which
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It generally does not publish articles on simi- Bulletin, FBI Academy, Outreach and Com-
lar topics within a 12-month period or accept munications Unit, Quantico, VA 22135, or to
those previously published or currently under leb@fbiacademy.edu.

22 / FBI Law Enforcement Bulletin

Leadership Spotlight

Changing Roles

A bout a year ago, I began accom-

panying my mom to one of her
weekly evening activity groups. It seemed
to support her, and to be a chauffeur. I am
Anita’s daughter.
In most aspects of our lives, our roles
like a perfect way to spend more time with change far more often than every 25 years.
her, which is an increasingly more pre- Sometimes, however, it may take us nearly
cious commodity as we both grow older. that long to realize that we no longer are
What it has become, however, is an amaz- serving or leading others in the way they
ing experience in changing roles. need. Our subordinates may not have need-
When I was ed our direction
young, my mom for a long time,
supported me but they may be
in everything I hungering for
did. The entity our support. Our
of “Deborah’s superiors may
Mom” would be looking to us
wait day after day to pick me up from for more leadership and guidance than they
after-school activities. She was my Girl did in the past. Our colleagues may be fol-
Scout troop leader for several years. Debo- lowing our example and leadership, unbe-
rah’s mom would deliver forgotten reports knownst to us.
and chaperon field trips. Deborah’s mom Wise leaders should try not only to be
was a cheerleader and champion, confi- flexible in the roles they play but also be
dant and counselor, and, like all parents, sensitive to when those roles change. As
chauffeur. She was an essential part of leaders, sometimes our roles and respon-
who I was becoming. sibilities are obvious; sometimes, they are
Twenty-five years later, the roles have subtle and slight. All of these roles are es-
reversed. Hardly anyone in my mom’s ac- sential. And, while it is important to be the
tivity group knows my name. I am Anita’s mom, it is an honor to be the daughter.
daughter. My mom is the center of atten-
tion. Her skills and expertise are coveted
and shared. The adventures of learning Deborah Southard of the Leadership
Development Unit at the FBI Academy
new things and meeting new people are prepared this Leadership Spotlight.
hers. I am there just to spend time with her,

January 2011 / 23
Legal Digest

Off-Duty Officers
and Firearms

© Thinkstock.com

eople generally recog- expected to provide a calming 2004 (LEOSA) allows officers
nize law enforcement presence. This is true when they to carry concealed weapons not
officers by their marked are on duty, but does this extend only in their jurisdictions but in
cruisers and uniforms, which to off-duty hours when there are all 50 states, and the territories
include the display of symbols no outward signs of authority? of the United States, provided
of authority—a badge and a The U.S. Congress has certain conditions are met.1 This
gun. The public expects officers determined that in a post-9/11 article will explore LEOSA,
to be comfortable carrying a world, the public is better address federal statutory limita-
sidearm and to exercise preci- served when off-duty officers tions regarding firearms pos-
sion and sound judgment when are in a position to effectively session, and summarize a short
using it. Officers are respon- respond in the face of a threat. legal history of the Second
sible for ensuring the safety and To this end, the Law Enforce- Amendment concerning the
protection of citizens and, thus, ment Officers Safety Act of right to bear arms.2

24 / FBI Law Enforcement Bulletin

THE SECOND advised that these men would Heller, a special police offi-
AMENDMENT commonly provide their own cer in the District of Columbia,
The Second Amendment to customary arms when called to was denied a license to register
the Bill of Rights was ratified service.9 The Court, thus, up- a handgun for self-protection in
on December 15, 1791. It reads, held the ban of weapons having his home even though he pos-
“(a) well regulated Militia, no connection to the militia or sessed one for his job. Citing
being necessary to the security to the common defense. the Second Amendment, Hel-
of a free State, the right of the From 1939 until recently, ler filed suit in federal district
people to keep and bear Arms, the Supreme Court steered clear court challenging the city’s gun
shall not be infringed.”3 History of much of the debate regard- laws. This challenge was re-
shows, however, that this simple ing the meaning of the Second jected and Heller appealed. The
amendment is anything but. Amendment. In 2008, the Court D.C. Circuit Court reversed the
Over the years, much debate offered guidance as to the district court’s decision, hold-
has centered on whether the meaning of the Second Amend- ing that an individual has a right
right referred to in the Second ment in Heller v. District of under the Second Amendment
Amendment is an individual or Columbia.10 The Supreme Court to possess firearms and that the
a state right.4 held that the District of Colum- city’s gun laws infringed upon
In 1939, the U.S. Supreme bia’s ban on handguns and oper- that right. The U.S. Supreme
Court offered some insight as able firearms in the home was Court affirmed the decision and
to the context of the Second unconstitutional. However, the discussed the extent of the right
Amendment in deciding United Court did note that the Second to bear arms.
States v. Miller.5 The case Amendment does not allow an The Court declared that an
involved the interstate transpor- unfettered right to possess all “inherent right to self-defense”
tation of an unregistered short- kinds of firearms or permit all is central to the Second Amend-
barreled shotgun in violation persons to possess them. ment and that a total ban on an
of the National Firearms Act
of 1934.6 The Court decided
that the Second Amendment’s

“obvious purpose was to assure
the continuation and render pos-
sible the effectiveness of mili- …law enforcement
tia forces.”7 The Court further officers retain
stated that only weapons with a their identity, training,
“reasonable relationship to the experience, and dedication
preservation or efficiency of a to the safety and welfare of
well regulated militia” would the community regardless
come under the Second Amend- of whether they are
on duty….

ment definition of arms.8 Ex-
plaining that the militia meant
“all males physically capable
of acting in concert for the Special Agent Bulzomi is a legal instructor at the FBI Academy.
common defense,” the Court

January 2011 / 25
entire class of firearms essen- Amendments to the U.S. Con- deeply rooted in the nation’s
tially serving as Americans’ stitution. The plaintiffs contend- history and tradition. As such,
first choice for self-defense ed that the Court’s decision in it is a “central component” to
of “the home, where the need Heller14 should be applied to the the Second Amendment right
for defense of self, family, and states through the Fourteenth to bear arms to include the
property is most acute” is an Amendment’s Due Process protection of one’s home, self,
impermissible infringement Clause—interpreted by the family, and property, a right
upon one’s right to keep and Supreme Court as allowing the protected from infringement by
bear arms.11 The Court clari- Court to incorporate provisions the federal government, as well
fied, however, that this right of the Bill of Rights and apply as from the states. The Court re-
is not absolute. Further, the them to the states. According to versed the court of appeals and
Court provided a nonexhaustive the Court, the issue is “whether remanded the case for further
list of “presumptively lawful the particular Bill of Rights proceedings.

regulatory measures,” including Today, not only police of-
restricting felons and mentally ficers but virtually all Ameri-
ill persons from possessing cans may possess a handgun
firearms, restricting the car- for home protection. As noted
rying of firearms into schools in Heller,18 this may be limited
and government buildings, and as a result of reasonable restric-
imposing conditions or quali-
LEOSA applies tions, such as mental instabil-
fications concerning the sale to qualified active ity and felony convictions. In
of commercial firearms.12 The duty and retired addition, local and state restric-
Court concluded by ordering the officers. tions concerning the storage and

District of Columbia to allow number of handguns still may
Heller to register his handgun be lawful. However, any restric-
and to issue him a license to tions that appear so restrictive
carry it in his home. as to circumvent this individual
As the District of Columbia right to bear arms likely will be
is a federal enclave and not a guarantee is fundamental to our deemed unconstitutional.
state, the decision only impacts scheme of ordered liberty and
the federal government. Howev- system of justice”15 or, in other FEDERAL STATUTES
er, this past term in McDonald words, “deeply rooted in this In 1968, Congress enacted
v. City of Chicago,13 the Su- Nation’s history and tradition.”16 the Federal Gun Control Act,19
preme Court addressed the role The Court stated that its deci- prohibiting convicted felons
of the Second Amendment with sion in Heller17 was clear on from possessing a firearm.
respect to state gun control. this point. Since the passage of this act,
In McDonald, the ban on Self-defense is a basic right Congress has enacted additional
handguns by the city of Chicago recognized by various legal pieces of legislation to further
and one of its suburbs, the systems throughout the ages. restrict firearm possession. Two
Village of Oak Park, Illinois, More important, individual self- of these acts in particular—the
was challenged as violating defense is a fundamental right Lautenberg Amendment20 and
the Second and Fourteenth from an American perspective, the Brady Handgun Violence

26 / FBI Law Enforcement Bulletin

Prevention Act—could affect
law enforcement officers and
their employers.21
The Lautenberg Amendment
Enacted in 1996, the Lau-
tenberg Amendment creates a
prohibited-possessor status for
persons convicted of a mis-
demeanor crime of domestic
violence.22 There is a statutory
stipulation that the convicted
individual had legal counsel
or knowingly, voluntarily, and
intelligently waived it. If the
conviction is set aside, it does
not automatically mean that the © Thinkstock.com
prohibited-possessor status also
is set aside. If the judge’s order
contains restrictions on firearms offense to be a crime that spe- The U.S. District Court for
possession, the prohibited-pos- cifically included the domestic the Northern District of West
sessor status continues.23 The relationship as an element to Virginia denied the motion to
act permits an individual who is the underlying crime would dismiss the indictment. Hayes
a prohibited possessor to peti- have limited the reach of the then entered a conditional guilty
tion to the U.S. attorney general statute. plea and appealed the denial.
for relief. If the relief is denied, In Hayes, police officers The U.S. Court of Appeals for
the act allows for judicial re- responded to a 911 call of do- the Fourth Circuit reversed
view of the denial.24 mestic violence. They arrived the district court, agreeing
In United States v. Hayes,25 at the home of Ronald Hayes, with Hayes that the underlying
the Supreme Court held that the obtained his consent to search charge was not a qualifying
statutory predicate requiring a his home, and discovered predicate offense because it
“misdemeanor crime of dom- a rifle, as well as two other did not designate a domestic
estic violence” does not have firearms. Hayes was indicted relationship as an element to
to include a crime establishing on three charges of possession the crime. The U.S. Supreme
a specified domestic relation- of firearms after having been Court agreed to hear the case
ship.26 In other words, the previously convicted of a and reversed the Fourth Circuit
statutory predicate is satisfied misdemeanor crime of domes- decision.
as long as it involves a misde- tic violence against his wife. The Supreme Court held
meanor crime of violence and He contested the indictment that the government need only
the victim is a person who has on the basis that battery was show beyond a reasonable
a qualifying domestic relation- not a predicate offense under doubt that the victim of domes-
ship. To require the predicate the Lautenberg Amendment. tic violence was the defendant’s

January 2011 / 27
current or former spouse or in agency, or political subdivision LEOSA already was recognized
some way related to the defen- thereof or for military training among a number of states. 31
dant. The Court stated, “but that or competitions.”29 The extent That is, law enforcement offi-
relationship, while it must be of this exception and whether it cers retain their identity, train-
established, need not be de- applies to individuals has yet to ing, experience, and dedication
nominated as an element of the be fully determined. As with the to the safety and welfare of
predicate offense.”27 prohibited-possessor status cre- the community regardless of
Aside from the obvious ated by the Lautenberg Amend- whether they are on duty in
suitability issues raised by the ment, the provision in the Brady their employer’s jurisdiction,
underlying conduct engaged statute also could impact the going home to another com-
in by the applicant or officer, ability of an officer to carry a munity, or merely traveling for
which should be considered by firearm. leisure purposes. However, the

the agency, Hayes may impact act creates a limited privilege
hiring and retaining officers to carry concealed weapons for
by law enforcement agencies. law enforcement officers, not a
For example, if a misdemeanor right to bear arms.
conviction pertaining to a crime LEOSA allows Qualification
of violence surfaces during the qualified officers to Under LEOSA
investigation, the department protect themselves,
must determine whether the LEOSA applies to qualified
crime involved someone who
their families, and active duty and retired offi-
had a domestic relationship with the community by cers.32 Qualification under LEO-
the applicant or officer. being armed while SA requires employment by or
off duty.

retirement from a local, state, or
The Brady Handgun federal law enforcement agency
Violence Prevention Act as someone charged with the
The Brady Handgun ability to investigate, prosecute,
Violence Prevention Act also and arrest people for viola-
creates a prohibited-possessor LAW ENFORCEMENT tions of law.33 If an agency has
status upon a finding based on OFFICERS SAFETY firearms proficiency standards,
reasonable cause to believe, ACT OF 2004 the officer must meet them to
after a hearing with notice and On July 22, 2004, President qualify to carry under this act.34
an opportunity to participate, George W. Bush signed into law The statute also prohibits car-
that an individual is a “cred- H.R. 218, the Law Enforcement rying firearms when under the
ible threat” to the safety of Officers Safety Act (LEOSA),30 influence of alcohol or any in-
an intimate partner or child.28 which created a general nation- toxicating or hallucinatory sub-
An exception to the act exists wide recognition that the public stance.35 If a current or retired
whereby the prohibited pos- is better served by allowing law officer is prohibited by federal
sessor status does not extend enforcement officers to carry law from possessing a firearm,
to the “United States or any their firearms outside of their ju- they are not qualified to carry
department or agency thereof risdictions whether they are on one under this legislation.36 It
or any state or department, or off duty. The theory behind also is important to note that if

28 / FBI Law Enforcement Bulletin

an officer is under a disciplinary carry concealed weapons within person raising the defense is,
action that may result in sus- 12 months of the issuing date of in fact, a qualified officer under
pension or termination by their the identification.44 LEOSA and was carrying the
agency, they are not qualified to LEOSA does not give required identification at the
carry under this act.37 qualified officers any special time of the alleged violation.
Qualified retired officers enforcement or arrest authority This means that the act will
must have retired in good or immunity. It merely allows not keep officers from being
standing for reasons other than them to carry concealed weap- arrested. However, LEOSA will
mental instability and served at ons. If these weapons are used, stand as a defense at a hearing
least an aggregate of 15 years.38 there is no special protection as to the legality of the arrest if
However, if the retirement was from arrest. Qualified officers the arrestee is, in fact, a quali-
due to a service-related disabil- may find themselves acting only fied officer with the requisite
ity, the officer need only have identification.
completed the probationary pe-
Limitations of LEOSA
riod to qualify under this act.39
Retired officers also must have Type of Firearm
a nonforfeitable right to benefits LEOSA allows qualify-
under their agency’s retirement ing officers to carry concealed
plan.40 At personal expense, the firearms, but, at the same time,
retired officer must meet the limits what qualifies as a fire-
state standard for firearms quali- arm. The act’s definition of fire-
fication required for active law arms does not include machine
enforcement officers.41 guns, silencers, or explosive or
Qualified active duty and destructive devices.45
retired officers must have pho-
tographic identification issued State Limitations on
by the agency they work for © iStockphoto.com Carrying in Certain
or retired from.42 Retired of- Locations
ficers’ identification must have under the authority of a citizen’s Limitations also exist as
some indication that they have arrest or self-defense claim or to where a concealed firearm
been tested or have otherwise under authority established by may be carried. LEOSA ex-
been determined by the issuing the state. empts qualified officers from
agency to meet the standards Qualified officers may use state laws limiting or prohibit-
active officers must meet to LEOSA only as an affirmative ing the carrying of concealed
carry concealed weapons.43 Re- defense if prosecuted. An weapons.46 However, LEOSA
tired officers do have the option affirmative defense requires does not supersede state laws
of possessing the photographic that the finder of fact, the judge, permitting private property
identification with a certifica- must make a determination owners from limiting or prohib-
tion from the state, rather than of whether the person raising iting the carrying of concealed
their former agency, that they the defense is eligible to do weapons on their property.47
have met the state’s require- so. To be eligible, the judge This would include public bars,
ments for active duty officers to must have determined that the private clubs, and places, such

January 2011 / 29
as amusement parks. Nor does policies. Some agencies have subject to reasonable restric-
the act circumvent any state continued to enforce such tions. LEOSA, as noted above,
laws prohibiting carrying policies. Arguably, because does not confer a right to bear
concealed weapons on state or LEOSA explicitly overrides arms. The act merely confers
local government property.48 state law provisions (except a limited immunity from state
Possible examples would be those addressing state facilities and local laws dealing with
courthouses, schools, or parks. and property), and the head of concealed firearms and does
an executive agency is given not supersede any federal laws
Federal Limitations power by way of state law, or regulations. Some jurisdic-
on Carrying in Certain it would appear that LEOSA tions outlaw the open display
Locations would override off duty restric- and carrying of firearms; how-
Federal laws or regulations tion policies. However, agencies ever, LEOSA does not allow
are not superseded by LEOSA. with such a policy and officers officers to carry firearms other

Qualified officers may not car- than concealed. The authoriza-
ry concealed weapons onto air- tion to carry concealed is not
craft under the act. They also accompanied by any grant of
cannot carry firearms into fed- extraterritorial arrest powers.
eral buildings or onto federal Qualified officers must be aware
property. However, in Febru- The authorization of the laws of the state in which
ary 2010, a federal statute took to carry concealed they are carrying concealed
effect authorizing individuals is not accompanied weapons, satisfy qualification
to carry concealed weapons by any grant of standards, and carry proper
into national parks if they extraterritorial arrest identification.
have complied with the carry powers. The world changed on

concealed rules of the state or September 11, 2001. Through
states in which the park is lo- LEOSA, Congress reacted to
cated.49 Of course, this federal this new age of terrorism, ac-
statute will not change the fact cepting the fact that America
that it is unlawful to carry a never has faced a greater need
firearm into federal buildings, working within these agencies to have additional watchful
even in a national park.50 This should seek guidance and eyes on the streets of its cit-
would include facilities, such clarification in regard to the ies, towns, and rural areas.
as visitor’s centers, museums, legality of such policies. These eyes possess the training,
and restrooms. skills, and resources neces-
CONCLUSION sary to stop rapidly evolving
Internal Policies In recent opinions, the U.S. situations before they become
It is unclear whether Supreme Court has clarified disasters. They also provide an
LEOSA overrides an agency’s what previously was unclear instantaneous, no-cost benefit
ability to limit an officer’s for hundreds of years, that the to the country by simply allow-
authority to carry a personally Second Amendment does confer ing trustworthy officers to carry
owned handgun off duty as a right to bear arms for purposes concealed weapons while off
part of off-duty restriction of self-defense in the home, duty.

30 / FBI Law Enforcement Bulletin

Law enforcement of- exercising what Presser and the others See Title 18 U.S.C. § 925 (a)(1).
ficers know that criminals are claimed was their right to bear arms. The Title 18 U.S.C. § 926 (B) and (C).
Court decided that the states, unlike the All 50 states exempt their own on-duty
never off duty. LEOSA also federal government, were free to regulate police officers from statutes governing the
is premised on the notion that the right to keep and bear arms. The Court right to carry concealed weapons. A major-
officers are vulnerable off duty. also emphasized that the Second Amend- ity of states allow within their borders other
Criminals sometimes target ment protects only a legitimate reserve states’ peace officers to carry concealed
them, as well as their families, militia meant to serve the states and the weapons if on official business. Kansas,
federal government. The Court cautioned, Michigan, Minnesota, Pennsylvania, Wyo-
for harm; these individuals also however, that the states cannot disarm the ming, and Vermont allow on- and off-duty
know that off-duty officers may people so as to deny the United States this out-of-state officers to carry concealed
be unarmed. LEOSA allows military resource regardless of the Second weapons. California, Connecticut, Dela-
qualified officers to protect Amendment. ware, Florida, Idaho, Indiana, Maryland,
307 U.S. 174 (1939). Mississippi, Nevada, New York, Oregon,
themselves, their families, and 6
Id. at 175-76, (National Firearms Act, Vermont, and Wyoming allow carry-con-
the community by being armed Pub. L. No. 90-618, 48 Stat. 1236 (1934) cealed permits or rights for retired officers.
while off duty. (codified as amended in scattered sections 32
Title 18 U.S.C. § 926B (qualified law
of 28 U.S.C.) was the first federal regula- enforcement officers) and § 926C (qualified
tion of private firearms). retired law enforcement officers).
Endnotes 7
Id. at 178. 33
Id.; and Id. at Sec. 926B(1) and
1 8
Title 18 U.S.C. § 926 B and C. Id. 926C(1).
2 9 34
U.S. Constitution, amend. II. Id. at 179-80. Id. at § 926B (C)(4).
3 10 35
Id. 128 S. Ct. 2783 (2008). Id. at § 926B (C)(5) and 926C (C)(6).
4 11 36
In 1875, the U.S. Supreme Court in Id. at 2817-18. Id. at § 926B (C)(6) and 926C (C)(7).
12 37
United States v. Cruikshank, 92 U.S. 542, Id. at 2816-17. Id. at § 926B (C)(3).
13 38
dismissed an indictment for two individu- 130 S. Ct. 3020 (2010). Id. at § 926C (c)(3)(A).
14 39
als charged with denying freemen their 128 S. Ct. 2783 (2008). Id. at § 926C (c)(3)(B).
15 40
Second Amendment right to keep and Id. at 3034. Id. at § 926C (c)(4).
16 41
“bear arms for a lawful purpose.” The Id. Id. at § 926C (c)(5).
17 42
Court advised that citizens must look 128 S. Ct. 2783 (2008). Id. at § 926B(d) and § 926C(d)(1).
18 43
to the state’s police power for protec- Id. Id. at § 926C(d)(1).
19 44
tion against other parties infringing upon Pub. L. No. 90-618 (1968), codified Id. at § 926C(d)(2)(A) and (B).
their right to bear arms as the amendment in chapter 44 of Title 18 of the U.S. Code. Id. at § 926B(e)(1)-(3) and § 926C(e)
wording “shall not be infringed…means Title 18 U.S.C. § 922. (1)-(3).
21 46
no more than it shall not be infringed by The short title of the 1993 amend- Id. at § 926B(a) and § 926C(a).
Congress, and has no other effect than to ment, which included amendment to § Id. at § 926B(b)(1) and § 926C(b)(1).
restrict the powers of the national govern- 922 and 924. Id. at § 926B(b)(2) and § 926C(b)(2).
22 49
ment.” The Court concluded that under the The Lautenberg Amendment See Title 36 U.S.C. § 2.4.
laws of the United States there were no ap- contains § 922(d)(9) and (g)(9), passed See Title 18 U.S.C. § 930, Possession
plicable federal charges in the indictment. in 1996, which was part of the Omnibus of Firearms and Dangerous Weapons in
The Court continued along this trail Consolidated Appropriations Act of 1997. Federal Facilities.
of precedent that the Second Amendment This act was challenged in United States
limits only the federal government when v. Hayes, 129 S. Ct. 1079 (2009), without Law enforcement officers of other than
it upheld a state prohibition against par- success. federal jurisdiction who are interested
ticipation in an unauthorized militia in the See Title 18 § 921 (33)(B)(ii). in this article should consult their legal
1886 case Presser v. Illinois,116 U.S. 252 See Title 18 U.S.C. § 925 (c). advisors. Some police procedures ruled
(1886). Presser was an unlicensed militia- 129 S. Ct 1079 (2009). permissible under federal constitutional
man who, along with 400 others, marched Id. at 1090. law are of questionable legality under
through the streets of Chicago with swords Id. at 1088. state law or are not permitted at all.
and rifles in violation of Illinois state law, See Title 18 U.S.C. § 922 (g)(g).

January 2011 / 31
Bulletin Report

Reentry Housing Options

The Bureau of Justice Assistance has sponsored Reentry Housing Options:
The Policymakers’ Guide to provide practical steps that lawmakers and others
can take to increase public safety through better access to affordable housing for
individuals released to the community. In most jurisdictions, people returning
from incarceration find accessible and affordable housing in short supply. They
often face additional challenges unique to individuals with a criminal history that
make it even more difficult to obtain suitable housing.
Historically, the national debate on housing for people returning from
prison or jail has been considered within broader discussions of affordable
housing. However, as the number of formerly incarcerated individuals has sky-
rocketed over the past few decades, widespread concern has developed about
how to provide them with housing in ways that promote public safety. The
high cost associated with not doing so for the growing reentry population has
become apparent, prompting many jurisdictions across the country to look for in-
novative approaches to increase affordable housing capacity for newly released
Without a stable residence, these people can find it nearly impossible to re-
connect positively to a community. Significant costs to public safety in the form
of increased crime and victimization can occur. Moreover, when newly released
individuals lack stable housing and fail to maintain steady employment, children
and others who depend on them for support are adversely affected.
The guide begins with a short narrative on housing options and a chart that
profiles six alternatives for reentry housing. Then, the document goes on to ex-
amine three distinct approaches (greater access, increased housing stock, revital-
ized neighborhoods) to enhance the availability of these housing options, giving
examples of how a particular jurisdiction has put each of the three into action.
The three jurisdiction examples help illustrate a cross-section of the categories
of housing and the types of tactics available to policymakers wishing to increase
the reentry housing stock in their jurisdiction. Moreover, the examples were se-
lected because of the broad applicability of their methods to other jurisdictions
faced with similar affordable housing shortages for individuals returning from
prison and jail.
Reentry Housing Options: The Policymakers’ Guide (NCJ 230589) can be
obtained by accessing the National Criminal Justice Reference Service’s Web
site, http://www.ncjrs.gov.

32 / FBI Law Enforcement Bulletin

Bulletin Notes
Law enforcement officers are challenged daily in the performance of their duties; they face each
challenge freely and unselfishly while answering the call to duty. In certain instances, their actions
warrant special attention from their respective departments. The Bulletin also wants to recognize
those situations that transcend the normal rigors of the law enforcement profession.

Officer Scott Oak of the West Richland, Washington, Police Department

witnessed an unfortunate sight on his way to work in his patrol car. The
officer observed a two-vehicle collision after which the cars quickly burst
into flames. As he ran to the scene, Officer Oak was told that a child was
trapped inside one of the burning vehicles. The officer delved through the
smoke- and flame-filled vehicle three different times to free the child. When
Officer Oak finally managed to extract the child from the mangled car, the
vehicle exploded and knocked both him and the victim to the ground, but
the officer quickly recovered and performed CPR. Officer Oak suffered
Officer Oak
burns on his arms and smoke inhalation injuries to his lungs as a result of
his heroic rescue.

One morning in May 2009 at Atascadero State Hospital in Atascadero,

California, Chief Larry Holt and Lieutenant David Landrum of the Depart-
ment of Police Services were traveling from a meeting when they responded
to an emergency call for a collision between a single vehicle and a tree.
Upon their arrival at the scene, Lieutenant Landrum ran to the car while
Chief Holt accessed a fire extinguisher and first aid kit. In the automobile,
Lieutenant Landrum found the semiconscious, incoherent driver behind the
wheel, as an engine fire caused by a broken fuel line quickly approached
the driver’s seat. Even though the driver outweighed Lieutenant Landrum
Lieutenant Landrum
by over 100 pounds, the lieutenant managed to free him from the vehicle
and transport him to a safe
location until paramedics arrived. The victim
Nominations for the Bulletin Notes should be based
of the accident suffered multiple fractured ribs on either the rescue of one or more citizens or arrest(s)
and lacerations, but his injuries may have been made at unusual risk to an officer’s safety. Submissions
fatal if Lieutenant Landrum had not swiftly re- should include a short write-up (maximum of 250 words),
a separate photograph of each nominee, and a letter
moved him from the burning vehicle. from the department’s ranking officer endorsing the
nomination. Submissions can be mailed to the Editor,
FBI Law Enforcement Bulletin, FBI Academy, Outreach
and Communications Unit, Quantico, VA 22135 or
e-mailed to leb@fbiacademy.edu.
U.S. Department of Justice Periodicals
Federal Bureau of Investigation Postage and Fees Paid
Federal Bureau of Investigation
FBI Law Enforcement Bulletin ISSN 0014-5688
935 Pennsylvania Avenue, N.W.
Washington, DC 20535-0001

Official Business
Penalty for Private Use $300

Patch Call

The Estes Park, Colorado, Police Department The patch of the Dixon, Illinois, Police De-
patch highlights the town’s location as the gate- partment represents several aspects of the town’s
way to the 265,000–acre Rocky Mountain Na- history. Across the top, a white arch symbolizes
tional Park. Each summer the park receives over 3 Dixon’s War Memorial Arch, and white letters
million visitors who tour the majestic and rugged state the town’s founding year of 1830. The patch’s
mountain peaks and valleys. The patch features border proudly highlights Dixon as the hometown
one of the area’s most abundant wildlife species, of 40th President Ronald Reagan. Finally, the cen-
the 5-point bull elk, with snow-capped Rocky ter graphics display the American and Illinois State
Mountains in the background and the Colorado flags beneath the bald eagle, honoring the state and
State seal in the foreground. nation that the department serves.