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Local police policies: the rules governing officers

Our society erupted in late May and June after the heinous and unprovoked murder of George Floyd at the hands of a Minneapolis police officer, and watched over by three other officers, fostering the Black Lives Matter movement. It seemed like the final straw for a public which had for decades been exposed to police brutality incidents. Yet while monumental societal transformations may seem to appear out of nowhere in reaction to a single incident or deed, tectonic shifts in public attitudes can actually be anticipated, as evidenced by the police departments across the county which years ago began preparing for a reckoning prior to May 25, 2020, incident in Minnesota. These departments' command officers have been proactively reviewing their operating procedures, revising use of force policies, adding bias and de-activation training, and in some cases, seeking out statewide accreditation to meet the highest national and local standards or in some cases establishing the same. That's the conclusion reached by Downtown newsmagazine, which set out to review policies of Oakland County law enforcement agencies – expecting to encounter a wall of resistance when filing Freedom of Information requests with police department's in Birmingham, Bloomfield Township and Bloomfield Hills, police departments in the adjacent communities of Royal Oak, Southfield and West Bloomfield, the Oakland County Sheriff Department and Michigan State Police. Quite the opposite took place, however. Most departments were more than willing to provide department policies and the three local departments even initiated a joint meeting to help discuss their department policies and operating procedures. Only the city of Southfield denied Downtown newsmagazine its Freedom of Information request to review its police department policies, and Southfield Chief Elvin Barren did not return repeated requests for an interview; the city of Royal Oak did not return its policies in time for this article, and Royal Oak Police Chief Cory O'Donohue was out of town and did not return requests for an interview prior to deadline. Aside from having access to department policies, Downtown newsmagazine also learned of a move underfoot to upgrade the overall professional operations of police departments on a statewide basis. “We started back in 2015 as an association, embarking on an accreditation policy,” said Robert Stevenson, executive director of Michigan Association of Chiefs of Police and the former chief of police of the Livonia Police Department. “We have 108 policies that we feel police departments should have and should strive for – and if you hit those, we send in people for two days to verify and then accredit you.” Under the direction of The Law Enforcement Accreditation Commission, the Michigan Association of Chiefs of Police created an accreditation manual, which is now in its fourth edition, as of April 2020. “Accreditation is a progressive and time-proven way of helping law enforcement agencies calculate and improve their overall performances. The foundation of accreditation lies in the adoption of standards containing a clear statement of professional objectives. Participating agencies conduct a thorough self-analysis to determine how existing operations can be adapted to meet these objectives. When the procedures are in place, a team of trained assessors verifies that applicable standards have been successfully implemented,” it states at the beginning of their standards manual. “The Michigan Association of Chiefs of Police (MACP) has pursued the concept and development of a voluntary law enforcement accreditation program for Michigan’s law enforcement agencies. This effort has resulted in the formation of the Michigan Law Enforcement Accreditation Commission (MLEAC), consisting of commissioners appointed by the MACP. Personnel from the MACP provide support services to the commission and to applicant agencies.” Accreditation can cost an agency $1,500 to $6,000, depending on its size and if it is nationally accredited. Annual continuation fees range from $600 to $2,000. Accredited status is granted for three years, with files reviewed on a regular basis in order to make sure there is compliance. “The agency is required to submit an annual report to the Program Director on the anniversary of their accreditation award for the two years between the granting of their accredited status and the next required Commission onsite,” the manual states. MACP's accreditation process for Michigan police agencies is a step ahead of both the national and states' reactions in response to the Floyd murder. President Donald Trump issued an executive order on June 16 designed to guide police reform around the country after weeks of public protests over police killings of unarmed Black Americans, and it recommended creating federal incentives through the U.S. Justice Department for local departments that seek independent credentialing to certify that law enforcement is meeting higher standards for the use of force and de-escalation training. Trump's order would ban the controversial use of choke holds, “except if an officer's life is at risk.” The order also would incentivize local departments to provide experts in mental health, addiction and homelessness as co-responders to “help officers manage these complex encounters,” under the auspices of the U.S. Department of Health and Human Services. Stevenson said accreditation has suddenly “become the big buzzword, but we currently have 24 departments that are accredited and another 30 or so in the process. Another 200 (agencies) have come to us to learn about it or get started.” In the state of Michigan, there are 401 municipal police agencies and another 83 sheriff departments. Stevenson said the Michigan Law Enforcement Accreditation Commission has now added two spots on the board for sheriffs' representations from Michigan Sheriffs' Association. Participation in accreditation at this point is voluntary. Each of the points in the president's order are already specified in the state accreditation standards. Of the 24 accredited agencies, which range across the state, they include the Auburn Hills Police Department, Battle Creek Police Department, Bloomfield Hills Public Safety Department, Bloomfield Township Police Department, East Grand Rapids Department of Public Safety, Farmington Police Department, Farmington Hills Police Department, Grand Blanc Township Police Department, Howell Police Department, Livonia Police Department, Marquette Police Department, Marshall Police Department, Meridian Township Police Department, Midland Police Department, Mott Community College Department of Public Safety, Northville Township Police Department, Novi Police Department, Port Huron Police Department, Portage Department of Public Safety, Rockford Department of Public Safety, Roseville Police Department, University of Michigan Flint Police Department, White Lake Township Police Department and Wyandotte Police Department. Of the 30 departments undergoing accreditation, Birmingham Police Department, Chesterfield Township Police Department, Clawson Police Department, Dearborn Police Department, Dearborn Heights Police Department, Ferndale Police Department, Grand Rapids Police Department, Monroe Police Department, Plymouth Township Police Department, Romulus Police Department, Sterling Heights Police Department, Warren Police Department and Ypsilanti Police Department are all at various points in working towards certification. Stevenson emphasized accreditation is not simple – nor should it be. The standards and manual for accreditation are on the group's website, allowing both agencies and the public the ability to preview and assess necessary standards – and what police departments must be working towards and maintaining. “It's why Bloomfield Hills and Bloomfield Township are so proud of their accreditation. They're ahead of the curve,” he pointed out. “Accreditation, for all three departments (Birmingham, Bloomfield Hills and Bloomfield Township), before George Floyd – we decided to take the dive,” said Birmingham Police Chief Mark Clemence. “What it allows is, before with policies they were subtly addressed, but now they're spelled out. Birmingham, Bloomfield Hills and Bloomfield Township – we want to be ahead of the curve. The (Birmingham) City Commission funded the cost of accreditation in last year's budget.” “Only four percent of the departments' in the state are accredited,” pointed out Bloomfield Township Police Chief Phil Langmeyer. “You'll find with the accreditation process that national standards are the right way to do things. We always prohibited choke holds. Well, okay, we're going to spell it out. It's the right way to do it. This is where to go to stay in our profession.” “It's reviewed annually, and there has to be a buy-in by every officer,” said Bloomfield Hills Public Safety Chief Noel Clason. “The whole department has to meet these – every officer, every dispatcher is tested on these – and exceed them on every item. It's much more stringent than the state requirement for mental health and for all new hires.” Included in the standards and mandates are very specified use of force policies, duty to intervene, which Stevenson said is “number two – it was always important, long before the incident in Minneapolis. Officers should know to intervene. Besides, there are laws if they don't. There can be malfeasance, malpractice and even manslaughter (charges). We've thought for years about them. Your use of force policies should reinforce them.” “Law enforcement officers are held to higher standards,” Langmeyer said. Of the George Floyd incident and video, he said, “To watch that as an officer was appalling.” Clemence said he couldn't watch the whole video. “It made me sick,” he said. “Bias-based policing is prohibited,” Stevenson said, having put it in writing long before the recent Black Lives Matter movement. “We've been very proactive. The things people are talking about now, we've been advocating for four years. There's training – and then there's retraining. You have to have retraining at least once every three years. These are best practices of what every department needs to be doing – at least. “A lot of things they're talking about are already there,” he said. “We've been blowing that horn for four years. As a profession, we've been helping our departments for years. “When they say the police needs to reform, I say we're always reforming,” Stevenson said. “What we did two years ago is not what we're doing today. And what we'll be doing two years from now will hopefully be different, regardless if they pass a law.” Setting uniform standards and policies for departments is a good idea, according Scott Wolfe, associate professor in the School of Criminal Justice at Michigan State University. He noted that nationwide, there are 18,000 agencies, with each needing to develop policies and follow standards. “Most agencies have really good policies that are up to national standards,” Wolfe said. “Agencies need to look to national standards for best practices. National agencies that disseminate their best practices are best to follow their lead, because with 18,000 agencies, not every policy fits every one. Follow the guidelines, but it's not a good idea to have a one-size-fits-all.” On June 29, Governor Gretchen Whitmer unveiled plans for a four-part plan to reform policing in Michigan. Her plan calls for bans on choke holds; further limits on the use of no-knock warrants; incentives for law enforcement agencies to hire/retain officers where they live; call on an arm of the department of health and human services to recommend best practices to police responding to calls involving people who are mentally ill; and promotion of programs to improve relationships between police, communities and community leaders. She would also like legislators to send her a bill which would classify “false, racially-motivated 911 calls” as hate crimes. “All Michiganders, no matter their community or the color of their skin, deserve equal treatment under the law,” Whitmer said in a news release. She said she would also support legislation for the formation to require an independent investigation of all police shootings or use of force that results in the death of an unarmed civilian. State Sen. Ruth Johnson (R-Groveland Township) has proposed legislation which would require law enforcement agencies to punish officers who fail to intervene when a colleague breaks the law. “It's a good time to listen,” noted West Bloomfield Chief of Police Michael Patton. “We treat people with dignity here. The police department is listening. “It's a noble profession – yes, it has its challenges, and there are some who should never have gone into it,” Patton said tactfully, referencing Minneapolis Officer Derek Chauvin, as well as others accused and/or convicted of wrongs against suspects or civilians. “It's a service job. I tell everyone – from the moment you walk in the door, it's no longer about you. “(Minneapolis) makes us think also...are there people like that here? Are there people like that who could lose their temper and use excessive force? Is it a lack of training? I know in West Bloomfield it didn't happen,” he said. “We train officers to be flexible, to speak in a more officious manner in daily events… If I believe an officer has malice in their heart, I'll make sure they don't wear the badge anymore.” Oakland County Sheriff Michael Bouchard concurs. “Yes, there are bad police officers, and they need to be held accountable. If they're evil, we don't want them, like any other professions,” he said. “There are 800,000 police officers – if there are 80 bad officers, they make it to the news. I'm not minimizing it, but we have to highlight the good.” He noted “there are state laws preventing us from doing more…especially with background checks. We're prevented from giving polygraph tests. It's one more thing that can go deeper, ask more questions on psychological and behavior issues. When I was becoming a police officer (in the 1970s), I took a polygraph test. We'd like to do psychological testing. We'd like to be able to review social media. We'd like it required of them to give us their social media and their passwords – because someone might have a secret account and be saying terrible things. That's a ticking time bomb. “We want people who are coming in to serve their communities, who want to make a difference at often what is the worst time in someone's life,” Bouchard continued. “It's an opportunity for you to help them at that time. We don't want someone coming in on a power trip.” Patton said he believes in, and tries to guide his department, by Sir Robert Peel's three core ideas. In 1829, Peel established the London Metropolitan Police Force and became known as the “Father of Modern Policing.” Peel and his commissioners established a list of three core ideas and nine policing principles that are still considered the bedrock of today's law enforcement. Of the core ideas, the first is the goal is preventing crime, not catching criminals. “An effective police department doesn't have high arrest stats; its community has low crime rates.” The second goal emphasizes the key to preventing crime is earning public support. “They will only accept this responsibility if the community supports and trusts the police.” The third goal is that the police earn public support “by respecting community hiring officers who represent and understand the community, and using force only as a last resort.” A force representative of the community, along with enlightened leadership, ranks high in the prescription for a successful police force promoted by professor Robert Sedler of Wayne State University Law School who has a long history studying law enforcement and the community it serves “In 1974, only 17 percent of officers in the Detroit Police Department were Black, and only five percent of the captains and lieutenants were. When Coleman Young came in, he started affirmative action, hiring a Black officer for every White officer. The Detroit Police Officers Association challenged it in court, and I wrote the Friend of the Court brief,” Sedler said. “Eventually, the police department got it right, especially under chief Craig. With all of the recent protests, you're not seeing the looting and rioting in Detroit like in (some) other cities. “While Trump and others blame it on rogue cops, I think it starts at the top. When officers use excessive force, they seem to know they can get away with it, from leadership and from unions,” he said. “It's the leadership and the unions, and the policies they create and enforce. You need cameras, you don't use choke holds, and you don't use facial recognition. In my view it depends on the policies put into effect by the department and it needs support from the community. It took a long time, and a lot of litigation, but now you have a Detroit police force that has the support of the community.” “The most egregious thing is we've had deaths where officers are standing by watching (criminal acts) happen,” said Samuel Walker, professor emeritus, School of Criminology at University of Nebraska Omaha. He noted the Minneapolis Police Department had a “duty to intervene” policy in effect for several years, and yet three younger officers were standing by, watching and not intervening. “The question is, did they not know the policy? Did they not read it? Did they not have any in-service training? Did they not train with any sergeants? Where was the chief – was he not making sure it was in effect?” asked Walker. “George Floyd should be alive if the chief had done his job.” Essential to prevent another incident – anywhere, in any community – is training, training, and more training. Ongoing training is part of all policies Downtown newsmagazine reviewed and was stressed by command officers in interviews – training is now part of their DNA, with critical directions now no longer left to assumption, intuition or changes of leadership. For those looking to become a police officer in Birmingham, Bloomfield Hills and/or Bloomfield Township, a recruit must have completed a four-year college in any major, or an associate degree in criminal justice. Bloomfield Hills Chief Clason noted many officers have masters degrees as they continue to put themselves through higher education. “They're often the guys we promote,” he said. Then, for every potential applicant at every local agency comes the real training – at the police academy. “To be certified, they have to complete the Michigan Commission of Law Enforcement Standards (MCOLES) academy for 17 weeks,” said Bloomfield Township Chief Langmeyer. “But you have to get a job within 12 months of completion. If you don't, you're no longer certifiable. Once we hire someone, with us, there's another 17 weeks, minimum, of field training with an officer looking over their shoulder, and then one-year of probation. That, and then there's continuing education. There are things we each mandate and trainings they go to outside. There's an amazing amount of training throughout their entire career.” For example, Langmeyer said, MCOLES only mandates one training in firearms per year, but in Bloomfield Township they do three others. Birmingham and Bloomfield Hills do as well. “You have to train for every single situation because it will happen here – it just won't happen as often as it does in Detroit or Pontiac,” Birmingham Chief Clemence pointed out. In West Bloomfield, Patton said they require a two-year college degree prior to training at the MCOLES police academy. “We would like to have people of diverse backgrounds who don't have a law enforcement degree,” Patton said. If they like what they see, “We will sponsor them through the academy, as a professional stepping stone. We get to see their work ethic. It's not an automatic that they'll get a spot with us. It's very competitive, and we can be very selective.” While the West Bloomfield Police Department currently has two Black police officers and “a fair number of female officers,” he said hiring minorities is a “challenge.” But he emphasizes it's a noble profession. To become a Michigan State Police officer, a college degree is not required. A candidate must be at least 21 years old, have a high school degree or GED, “although a high school degree helps for promotion,” said Michigan State Police First Lieutenant Mike Shaw, public information officer for Wayne, Oakland and Macomb counties. “They then must go through our live-in academy in Lansing (Monday through Friday). Even if they've been a local officer, they have to go through our academy.” While it varies, the most recent class was 26 weeks, Shaw said. What about the image of the “macho” warrior police officer? Is that ingrained and perpetuated at training academies? “It is a military model for training. We are a paramilitary organization,” Shaw said. “We rank, we salute officers, and at the beginning, we march. But as we go along (in training), we want them to think on their own, make split-second, good decisions, use other recruits – use their peers, to make decisions. By the time they're done, the recruits are running that school.” While training is rigorous and strict, the emphasis on being a “warrior” is no longer the acceptable standard, Shaw and other law enforcement officers said. “Warriors – no. We want to be part of the community. I live and vote in the community,” Shaw said. “It's not a warrior mentality. Part of law enforcement is writing tickets, slowing people down, fighting crime – but the other part is being a role model, a member of the community. It's getting out and being a leader in the community. “For new recruits, we teach conflict resolution,” he said. “Ethics, interpersonal connection, de-escalation, is all built right into our training. Our biggest use of force or our tool is our mouth, because if something goes wrong, it's because we're not communicating well. A lot of times, in any part of life, you're going to get people to do things if you communicate well.” “It's more of a guardian outlook than warrior, but that comes from the department,” said Clemence. “That's the Birmingham or Bloomfield way.” “The leadership has to set the tone,” Langmeyer concurred. “Our officers don't think of themselves as warriors, though they sometimes have to be.” “This isn't the Vietnam-era cops that now grew up,” said Clason. “These younger cops grew up in diverse high schools. They're young and have a different attitude.” Implicit bias training has been part of training for both recruits and seasoned troopers since 2016, with retraining occurring for all MSP officers in 2019. “We require seven hours of continuing education every two years on whatever a trooper wants,” Shaw said, in addition to all annual mandatory training, which includes firing a weapon three times a year, defensive tactics, proper pursuit training and hazardous materials training. In June, the Michigan Senate approved legislation sponsored by state Sen. Jeff Irwin (D-Ann Arbor) that would require police officers to complete training on de-escalation techniques, implicit bias, procedural justice and mental health resources. At the Birmingham City Commission in late June, a request from Clemence for a proposal for bias awareness and sensitivity training that will cover how biases impact decision, perceptions and interactions was unanimously approved. The controversial use of choke holds is something already spelled out in Bloomfield Hills, Bloomfield Township, Birmingham, West Bloomfield, Oakland County Sheriff and Michigan State Police policies – and in all cases, it is prohibited, unless the life of the officer or a civilian is threatened. Bouchard said their defensive tactics program is based on threat pattern recognition use of force standard, Michigan Edition, “which does not utilize or allow chokeholds or strangleholds. After applying handcuffs and once the incident is under control, deputies shall ensure that the subject is placed and remains in an upright or side position that will prevent positional asphyxiation, in accordance with training.” De-escalation is required, he said, and training is done for all deputies. Bouchard said groups of deputies are trained every Wednesday at their facilities. “I've been trying to build a state-of-the-art facility for years. I would like $5 million in allocations from the state legislature and the feds. We're the only one in the county to have a training unit – and they do a great job, but if we had a facility we could push them so if they make a mistake, it's done there, so when a split-second decision is made, they're ready,” Bouchard said, noting it would provide a facility for training for local agencies as well. As for the issue of regulating the use of force, all department policies review by Downtown newsmagazine addressed the issue. “It is the policy of the Bloomfield Hills Public Safety Department that officers use only the force necessary to effectively bring an incident under control, while protecting the lives of the officer and others. The use of force must be objectively reasonable in effecting the lawful arrest, and/or in the lawful performance of duty,” the township's policy reads. “Deadly force Targets: Head/Neck/Throat and Clavicle: Impact weapon strikes to these areas shall not be used unless the officer is justified in using deadly force. These striking points have high implications for creating severe injury in the forms of great bodily harm or death.” Bloomfield Township's Use of Less Lethal Force Policies and Procedures spells out “objectively reasonable use of force,” with severity of crime, whether the suspect poses an immediate threat to the safety of officers and others, and whether the suspect is actively resisting arrest or attempting to evade arrest by flight.” Verbal commands are preferred, but when ineffective it notes that an officer may escalate to control methods that may involve the use of physical force, including strikes, kicks, pressure point tactics, take downs, joint locks, handcuffing, Taser, chemical agent, impact weapon, such as a baton, or lethal force. It states “Officers will receive de-escalation training annually,” along with lethal force training, Taser re-certification, and physical control techniques and handcuffing training, which is conducted twice a year. “The use of unreasonable, unnecessary force, and/or the failure to provide proper medical treatment following the use of force, shall, in every case, result in certain and severe disciplinary action against those who use or fail to intervene in cases of suspected excessive force by another officer, or fail to provide for the care of persons in custody. The use of a carotid neck restraint is prohibited except in a deadly force encounter,” states the Birmingham Use of Force directive. The West Bloomfield Police Department, similar to Birmingham, Bloomfield Hills and Bloomfield Township, approves, trains and issues its officers Tasers, collapsible batons and aerosol subject restraint – chemical or pepper spray, which is considered intermediate tools. “Officers shall not use deadly force to effect the arrest of or stop a suspect fleeing from a misdemeanor crime, or to stop a suspect who has escaped from custody after having been arrested or convicted for a misdemeanor crime,” West Bloomfield's policy continues. If an officer does something egregious on duty, “All members of the force have a duty to intervene, and they have a duty to report,” said West Bloomfield's Patton. “Even if they see something later. We've always had that.” President Trump's recent executive order mandates the justice department develop and maintain a database of bad cops – to track when officers have been terminated or decertified, have been criminally convicted for on-duty conduct or faced civil judgments for improper use of force. The problem of bad, or “rogue” cops jumping from department to department has ceased to be an issue, Michigan Association of Chiefs of Police Stevenson said, since 2018, when Public Act 128 went into effect to stop cops jumping departments without their knowledge of problem issues. PA 128 requires a law enforcement agency who is hiring a current or previously licensed law enforcement officer to request and review the reasons for, and circumstances under which an applicant left employment with a previous law enforcement agency. It also requires an agency receiving a request to disclose this information. The act provides for liability protection from such disclosures for the previous agency and allows an applicant due process to object to information with an explanation. “Prior (to PA 128), you could only have name, date of hire and date of release,” Stevenson said, recalling his days as chief of police in Livonia. “Many city HR departments would only release that information, so when you'd to go hire someone, it was possible to not know what you were getting, because HR departments would seal their files. PA 128 resolved that.” Hiring someone from out of state can still pose an issue, so without a national database, departments still hire at their own risk. Body worn cameras are also being addressed by local departments. Birmingham will have the addition of body worn cameras in the near future to aid their officers, joining local departments such as Royal Oak, Ferndale and Northville. They're a tool Bloomfield Township is starting to look at, but Bloomfield Hills and the Oakland County Sheriff's office are not. All three local departments, along with West Bloomfield and the state police, have in-dash car cameras. “I've got mixed feelings because of transparency,” Bloomfield Hills Chief Clason said. Clemence said a 2017 Michigan law, PA 85, Law Enforcement Body-Worn Camera Privacy Act, protects crime victims and establishes that body-worn camera recordings would be exempt from disclosure under the Freedom of Information Act (FOIA), except under certain circumstances. For West Bloomfield Chief Patton, “We are pricing out body cameras, but they are costly. It's not an insignificant cost. But, if not now, when? I don't anticipate any resistance or reluctance from our township board.” While Bouchard claims he's a “fan” of body cameras, he asserted “the legislature won't do what is necessary to make it a good program. We wanted to have it for police accountability and have it exempt from FOIA, just to have it triggered for internal misconduct investigations, to keep it for police accountability. We see some things we can't release – medical, personal situations. We see people's worst moments, so the body cameras see those worst moments.” He also said the storage requirement is oppressive. “We'd have to have people go through what was and wasn't admissible, and that would be millions of dollars,” he said. As for the national rallying cry by some critics to defund the police – the movement receives no local law enforcement or academic support. Wayne State Law's Sedler said, “The slogan 'defund the police' is really not helpful. You're talking about reform and restructuring policing. You talk about the best way to deal with domestic violence incidents, for example, maybe you need police and social workers. You need to talk about restructuring and it's going to be city by city, community by community.” “Disbanding a police department, getting rid of them, is actually very common. But creating a new one is very rare,” said Bill King, professor of criminal justice, Boise State University. “It's never because there's too much crime. Most police agencies get disbanded because they're small, not a lot of crime, and often rural. That's often when a sheriff's department comes in. In urban and suburban situations, in Ohio, which I studied between 1970 and 1999, of 115 disbanded agencies, one-half were because of their budget; about one-third were because of police misbehavior – cops doing something criminal and getting arrested; and the rest were generally government merger, like a township police department and village police department. “Disbanding is rarely racial – it's financial,” he emphasized. “If it's about police misconduct and the community is upset and diverse; it could be a way of hitting the reset button.” He said in a 2015 national study, 54 police agencies are disbanded across the United States each year. “Do there need to be changes in policing? Absolutely,” said Shaw of the Michigan State Police. “Yelling at each other doesn't get you there.” Bloomfield Township's Langmeyer said defunding isn't the answer, but rather a need to figure out how to fund in different ways, notably to have officers better trained to help the mentally ill. He said they are looking at creating crisis intervention teams. “We have officers trained in that,” he said. “It needs to be multi-jurisdictional.” “We need partnerships with hospitalizations, social workers, intake specialists, mental health experts,” Clemence of Birmingham said. “Police work is so much more than policing. There are avenues to add, in mental health and others. Police is the first avenue. Could additional resources be added? I wouldn't want to slide out a social worker without a police officer first.”

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