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CITY OF SAN BERNARlO - REQUEST FOR OUNCIL ACTION
4
rom: Daniel A. Robbins Subject: Resolution of the City of San
Chief of Police Bernardino adopting the revised �..
ept: Police Police Department's pursuit
policy, SOP Chapter #36,
ate: June 16, 1993 Procedure #3, in accordance with
CVC 17004.7 , Public Ag6ncy
Immunity
ynopsis of Previous Council action:
Resolution #92-452
iecommended motion:
Adopt Resolution.
i'
rLt i 7f�
i- Signatv e
:ontact person: Daniel A. Robbins Phone: 384-5607
supporting data attached: yes Ward:
FUNDING REQUIREMENTS: Amount: NSA Source:
Finance:
Zouncil Notes:
S-5
1 RESOLUTION NO.
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3
4 RESOLUTION OF THE CITY OF SAN BERNARDINO ADOPTING A REVISED
POLICE DEPARTMENT PURSUIT POLICY, SOP CHAPTER #36, PROCEDURE #3,
5 IN ACCORDANCE WITH CVC 17004 . 7.
6 BE IT RESOLVED BY THE MAYOR AND COMMON COUNCIL OF THE CITY
OF SAN BERNARDINO AS FOLLOWS:
7
8 The Mayor and Common Council of the City of San Bernardino
9 has reviewed and adopted the Police Department's pursuit policy,
SOP Chapter #36, Procedure #3, "Vehicular Pursuits" in
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accordance with CVC 17004 .7 "Public Agency Immunity. "
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The Council has reviewed the policy and finds that it
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complies with CVC 17004 . 7 (c) in that the policy provides for
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supervisorial control, a procedure for designating a primary
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pursuit vehicle, for determining the total number of vehicles
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permitted to participate in the pursuit, for coordinating
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operations with other jurisdictions, and guidelines for
17
determining when the interest of public safety and effective law
18
enforcement justify a vehicular pursuit and when a vehicular
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pursuit should not be initiated or should be terminated.
20
21 I HEREBY CERTIFY that the foregoing resolution was duly
adopted by the Mayor and Common Council of the City of San
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� 4
1 RESOLUTION OF THE CITY OF SAN BERNARDINO ADOPTING A REVISED
POLICE DEPARTMENT'S PURSUIT POLICY, SOP CHAPTER #36, PROCEDURE
2 #3 , IN ACCORDANCE WITH CVC 17004 . 7 .
3
4 Bernardino at a meeting thereof, held on the
5 day of 1993 , by the following vote, to wit:
6 COUNCILMEMBERS AYES NAYS ABSTAIN ABSENT
7 NEGRETE
8 CURLIN
9 HERNANDEZ
10 OBERHELMAN
11 OFFICE VACANT
12 POPE-LUDLAM
13 MILLER
14
15 Rachel Clark, City Clerk
16
17 The following resolution is hereby approved this
day of 1993 .
18
19 Tom Minor, Mayor
20 City of San Bernardino
Approved as to form
21 and legal content:
22 JAMES F. PENMAN
23
City Attorney
by• �, -� ���. ,�,
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City Of San Bernardino
San Bernardino Police Department
Interoffice Memorandum
To. Assistant Chief W. Harp
From: Sgt. M. Kinsman��✓
Subject: Revised Vehicular Pursuit Policy
Date: June 16, 1993
Copies:
PROBLEM:
I
Vehicle Code Section 17004 . 7 provides limited liability immunity to a
city which adopts the code's guidelines for police pursuits. The 2nd
and 4th District Courts of Appeal have determined in Payne v. City of
Perris and Colvin v. City of Gardena that pursuit policies based on the
model pursuit policies recommended by the California Police Officers
Association and the California Chiefs and Sheriffs are insufficient.
The recommended guidelines give the pursuing officer "unfettered
discretion" and therefore do not provide a balancing test weighing the
risks to the public against the law enforcement interest in
apprehension. The current vehicular pursuit policy is based on the
CPOA model pursuit policy.
RECOMMENDATION:
1 . Adopt the proposed, revised Vehicular Pursuit policy, Chapter #36,
Procedure #3 .
2 . Submit a proposed resolution to the Mayor and Common Council for
adopting the revised Police Department pursuit policy to obtain
municipal immunity.
FINDINGS :
1 . Vehicle Code Section 17004 . 7 (c) provides immunity for civil
damages - death, personal injury, and property damage - resulting
from a vehicle collision directly related to a police pursuit if
minimum standards are adopted. The minimum standards are
supervisorial control , number of participating police vehicles,
coordination with other agencies, and public safety guidelines for
the initiation and termination of police pursuits.
2 . The 2nd Appellate Court of Appeals in Colvin v City of Gardena
ruled that the city lacked immunity protection under Vehicle Code
17004 . 7 due to the inadequacy of its pursuit policy. The city
Pursuit Staff Study
Page 2
failed to identify specific guidelines for initiating and
discontinuing vehicle pursuits. The court listed these factors to
be considered in terminating a pursuit: vehicular and pedestrian
traffic, roadway and other environmental conditions.
3 . The 4th District Court of Appeals in Payne v City of Perris
identified "broad and amorphous language" found in the guidelines
their pursuit policy when addressing the officers' decision making
process for terminating pursuits. The court determined that the
department's policies failed to articulate or direct the decision
making process concerning whether or not to initiate or terminate
a pursuit.
4 . The contents of the pursuit guidelines for the cities of Perris
and Gardena are similar to the City of San Bernardino's pursuit
guidelines; therefore, are insufficient.
I
5. Richard J. Morillo, Senior Assistant City Attorney has reviewed
I both appellate court decisions and the current police pursuit
guidelines. He has made some recommendations establishing more
specific guidelines to assist the pursuing officer in his/her
decision making process when deciding whether or not to terminate
or initiate a high speed vehicular pursuit.
These recommendations and some documentation guidelines have been
incorporated in the proposed, revised pursuit policy.
ATTACHMENTS
/rm
I
STANDARD OPERATING PROCEDURE CHAPTER #36 PROCEDURE #3
VEHICULAR PURSUITS REVISED 6-16-93
******************************************************************
PURPOSE:
Specific procedures for department personnel involved in any
vehicular pursuits.
POLICY•
A. The essence of a successful pursuit is to apprehend the
violator. It is unwise to take needless chances in an already
dangerous activity. It is far better to either delay the
arrest or abandon the pursuit rather than injure or kill
anyone needlessly, including the police officer.
B. It is our policy to apprehend all persons who are attempting
to evade arrest. However, it must be remembered that the
anticipated results must be worth the risk. Therefore, the
pursuing officer is not to consider that he/she must continue
a pursuit at all costs.
C. The instructions in this SOP are meant primarily for high
speed pursuits. At greatly reduced speeds, it is possible
that good judgment would allow for deviations from these
procedures.
INITIATING, CONTINUING, AND TERMINATING A PURSUIT:
A. The following factors should be considered when determining
whether any pursuit should be initiated, continued, or
terminated.
1 . The seriousness of the originating crime and its
relationship to community safety;
2 . Safety of the public in the area of the pursuit;
3 . Safety of the pursuing officer(s) ;
4 . Volume of vehicular traffic;
5 . Volume of pedestrian traffic;
6 . Location of pursuit;
7 . Speeds involved;
8 . Time of day;
9 . Weather conditions;
STANDARD OPERATING PROCEDURE CHAPTER #36 PROCEDURE #3
VEHICULAR PURSUITS (REVISED) PAGE 2
*******************************************************************
10. Road conditions;
11. Familiarity of the officer and supervisor or watch
commander with the area of pursuit;
12 . Quality of radio communications between pursuing unit(s)
and the dispatcher and supervisor; and
13 . The capability of the police vehicles involved.
B. Once a pursuit is initiated, officers, field supervisors, and
watch commanders should continually question whether the
seriousness of the offense justifies continuing the pursuit.
PURSUING UNITS:
I A. A police unit shall not be engaged in a pursuit unless
equipped with a red light and siren, activated and operating
continuously.
B. In all pursuits, only two units and a supervisor shall be
involved in the pursuit at any time. The watch commander or
field supervisor may approve additional units if necessary.
The lead unit will be considered the primary unit. In the
event the primary unit cannot continue, the secondary unit
shall become the primary unit. Paralleling a pursuit is not
permitted unless approved by the watch commander or field
supervisor. This is not meant to discourage units from taking
positions along or near the pursuit route to relay
information.
C. When a plain unit or motorcycle has initiated a pursuit, it
shall be relieved when the first marked unit can practically
assume the pursuit.
D. Officers in all other units should remain alert to the
pursuit's progress and location, and unless cleared by a
supervisor, shall not become involved in the incident.
E. Non-sworn personnel shall not, at any time, drive any City
vehicle involved in a pursuit.
PURSUIT RADIO PROCEDURE:
A. The pursuing officer(s) shall remain on Channel One unless
directed otherwise.
STANDARD OPERATING PROCEDURE CHAPTER #36
PROCEDURE #3
VEHICULAR PURSUITS (REVISED) PAGE 3
*******************************************************************
B. During the pursuit, the suspect vehicle requires the absolute
attention of the lead or primary unit. Whenever possible, the
unit behind the lead unit shall "call the pursuit" as outlined
under the officer's responsibilities, allowing the lead unit
to give full attention to the suspect vehicle. All units in
the pursuit shall monitor the radio for messages directed to
them. Radios shall be turned up and strict compliance shall
be made with orders given. The use of automatic yelp of the
I siren is discouraged as the high pitch has a tendency to drown
out any incoming message.
1. Once the pursued vehicle is observed and followed by the
helicopter, pursuing units shall remain in a Code 3
operation, decreasing speed; however, remaining close
enough to effect an arrest at the termination of the
pursuit. The aircraft is responsible for coordinating
the ground units.
PURSUING OFFICER'S RESPONSIBILITY:
A. The initiating pursuit unit shall indicate:
1 . The known law violation or reason for the pursuit.
2 . Description of the fleeing vehicle and suspects.
3 . Location and direction of travel as changes take place.
4 . Any other information which is necessary to ensure
effective pursuit tactics.
5 . Report known or probable wants on the fleeing vehicle
and/or occupants.
a. If a license number is relayed, the dispatcher
shall determine registration/criminal want
information and relay same to pursuing officers as
soon as practical .
COMMUNICATIONS RESPONSIBILITY:
A. Inform other field units, a field supervisor, the watch
commander, and helicopter when a pursuit is initiated.
B. Shall relay to monitoring units:
1 . Clear the air for emergency traffic, 10-3
STANDARD OPERATING PROCEDURE CHAPTER #36 PROCEDURE #3
VEHICULAR PURSUITS (REVISED) PAGE 4
2 . The direction of travel.
3 . Street traveled upon.
4 . The last intersection passed.
5. Any changes in direction of travel.
6. The reason for the pursuit.
7 . A complete description of the vehicle being pursued and
the number of occupants.
8 . A registration check on the pursued vehicle license (if
available) .
C. Notify affected agencies and specify if assistance is or is
not requested for the pursuit unit.
D. Provide back-up units as requested.
SUPERVISORY RESPONSIBILITY:
A. Upon being notified of the pursuit, the field supervisor will
assure himself of the following:
1. No more units than required or necessary are involved.
2 . Available equipment is utilized.
3 . Affected agencies are notified.
4 . The field sergeant (watch commander in the absence of a
field sergeant) is responsible for the pursuit activities
as outlined and has the authority to cancel a pursuit at
any time it becomes necessary.
5 . A supervisor shall proceed to the pursuit termination
point to provide guidance and necessary supervision.
6 . The supervisor(s) involved shall provide a report in
writing to division commander; a critique and analysis of
the pursuit. The supervisor shall complete a Highway
Patrol Pursuit Report (CHP 187) and submit the report to
the Traffic Bureau.
PURSUITS INTO OTHER JURISDICTIONS:
0
STANDARD OPERATING PROCEDURE CHAPTER #36 PROCEDURE #3
VEHICULAR PURSUITS (REVISED) PAGE 5
A. Should the decision be made to continue the pursuit out of the
City of San Bernardino, the affected jurisdiction shall be
notified without delay. They will be advised of the location,
direction of travel and the cause or violation of law of the
pursued vehicle. Their assistance may be requested to have a
marked unit intercept and assume calling the pursuit from the
secondary position.
B. If the pursuit is assumed by another agency, the initiating
officer will drop out of the pursuit; however, will proceed to
the termination point to provide information which may be
required for the arrest.
PURSUITS INTO SAN BERNARDINO BY OTHER JURISDICTIONS:
A. San Bernardino Police officers shall not join the pursuit
unless specifically requested to do so by the pursuing
jurisdiction and approved by the watch commander or sergeant.
1. San Bernardino Police officers will not join a pursuit on
the freeways crossing San Bernardino by another
jurisdiction. Officers may be assigned to stand by in
the area of off-ramps, should the suspect vehicle enter
surface streets. Stand by on on-ramps shall not occur.
2 . When a pursuit leaves the city, the San Bernardino
officers will terminate their involvement unless directed
otherwise.
3 . When approval is given to assist another agency in the
pursuit, San Bernardino officers shall not "take over" or
become the primary unit of the pursuit, unless the
pursuing agency is incapable of continuing the pursuit.
The San Bernardino officer's responsibility is to "call
the pursuit" and aid in coordination where possible.
4 . No San Bernardino police unit shall join in any pursuit
for any reason when there are three (3) or more police
units already in the pursuit unless there is supervisory
approval .
PURSUIT TACTICS :
A. During a pursuit the involved officers should continually
evaluate the status of the pursuit and should continually
question whether the seriousness of the violation warrants the
continuation of the pursuit.
STANDARD OPERATING PROCEDURE CHAPTER #36 PROCELURE #3
VEHICULAR PURSUITS (REVISED) PAGE 6
*******************************************************************
1. At either the officer's or supervisor's discretion, the
pursuit may be terminated at any time.
B. The unit behind the suspect vehicle shall never be passed by
another unit unless the lead unit approves the maneuver.
C. All units while in pursuit, whether the vehicle in front of
the unit is a police vehicle or the suspect vehicle, shall
space themselves at a distance to ensure proper braking and
reaction time in the event the lead vehicle slows, stops, or
makes any other moves.
D. Employing lawful intervention when involved in pursuits:
1. Officers shall refrain from employing intervention
tactics when involved in a misdemeanor violation pursuit.
a. During pursuits, the preservation of human life,
especially innocent citizens from imminent great
bodily harm or death, shall be a primary motivating
factor.
b. Officers shall not discharge a firearm at or from a
moving vehicle except as the ultimate measure of
self defense or defense of another when the suspect
is using deadly force by means other than the
vehicle.
C. Barricading a roadway must be considered as a force
likely to result in death. Officers shall not
barricade a roadway to apprehend a suspect.
"Rolling" roadblocks are also prohibited, unless
specifically approved or requested by a supervisor.
2 . Intervention techniques may be employed only when all
other reasonable options have been exhausted and when a
felony is involved.
3 . A field supervisor or watch commander must first approve
such action and will designate which of the units
involved will perform the intervention.
a. It will become the designated officer's decision as
to when and where to conduct the intervention.
b. All other units involved should be warned prior to
implementing the intervention and they should
STANDARD OPERATING PROCEDURE CHAPTER #36 PROCEDURE #3
VEHICULAR PURSUITS (REVISED) PAGE 7
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adjust their driving tactics appropriately.
Officers should not attempt to intervene with a
vehicle traveling over 35 mph.
4 . It is important for the officers and supervisors involved
to remember that lawful intervention equates to that
amount of force which may cause injury and/or death, and
careful consideration should be given prior to
implementing intervention.
E. Officers not assigned shall not respond, loiter, or drive by
the termination site of any pursuit.
1. Upon the termination of the pursuit, the station
commander or sergeant shall assign units that are to
remain outside the city limits of San Bernardino if the
termination is in another jurisdiction and their presence
or assistance is requested.
F. Lawful intervention reporting:
1 . Per Section 2 . 1. 32 of the collision manual, lawful
intervention is not a reportable traffic collision.
2 . For reporting purposes, a collision investigation will be
conducted on all interventions where a police unit was
used to intervene with the suspect vehicle. The face
page of the investigation should be marked as "In House
Only" . ID shall be called to the scene for photographs.
If the action results in injury or death, the traffic
investigator and Risk Management will be notified.
* Risk Management will be notified for 'damage only'
accidents also.
VEHICLES INVOLVED IN PURSUITS :
A. If bottomed-out during a pursuit, routinely deadline the
vehicle at City Yards for inspection for possible damage,
notify supervisor and leave necessary documentation.
B. If vehicle does not suffer damage, still leave a vehicle
repair slip indicating vehicle was involved in pursuit, so
that preventative maintenance by City Yards may be scheduled.
STANDARD OPERATING PROCEDURE CHAPTER #36 PROCEMME #3
VEHICULAR PURSUITS (REVISED) PAGE 8
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FORCED VEHICLE STOPS (LEGAL INTERVENTION) :
A. The decision to attempt a forcible stop shall be based on
careful consideration of all facts apparent to the officer.
B. A forcible stop of a pursued vehicle may be undertaken only
under the following circumstances:
1. When the officer has reason to believe that the continued
movement of the pursued vehicle would place others in
imminent danger of great bodily harm or death AND
2 . When the apparent risk of harm to a person or persons
other than the occupant of the pursued vehicle is so
great as to outweigh the apparent risk of harm involved
in making the forcible stop AND
3 . After all other reasonable means of apprehension have
been considered and rejected as impractical such as
continue to follow, call for support, call for other
department and/or allied agency assistance.
C. An occupied privately-owned vehicle shall not be used to
forcibly stop another vehicle.
I
D. The following tactics may be used to stop a pursued vehicle.
The selection of the best method in each circumstance should
be preceded by an evaluation of all factors surrounding the
individual event. The method used should offer the greatest
probability of success with the least likelihood of injury to
the general public, the officer, and the suspect.
1 . Channelization - Officers may deliberately direct a
vehicle into a given path or location (i.e. , unpaved
roadway, dead-end road, etc. ) by using stationary objects
(pylons, barricades, vehicles) placed in the current path
of the pursued vehicle.
2 . Rolling Roadblocks - Officers may elect to use rolling
roadblocks with the concurrence of a supervisor. The use
of rolling roadblocks must be weighed against the
potential risks presented by continuing the pursuit.
3 . Ramming - Officers, as a last resort, may elect to use a
deliberate collision between a patrol vehicle and the
pursued vehicle to terminate a pursuit. Use of a vehicle
not equipped with a push bumper is discouraged. A
STANDARD OPERATING PROCEDURE CHAPTER #36 PROCEDURE #3
VEHICULAR PURSUITS (REVISED) PAGE 9
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supervisor's permission should be obtained prior to the
ramming. The guidelines below shall be followed:
a. Motorcycles:
1) Officers shall not ram motorcycles or similar
vehicles except:
a) When necessary in defense of the
officer's life or life of another or
b) During the actual commission of an
assault with a deadly weapon with a
vehicle or
C) When necessary to prevent the escape of a
person whom the officer reasonably
believes has committed a felony through
the use or threatened use of deadly force
or
d) When necessary to apprehend a person who
has committed an assault with a deadly
weapon with a vehicle which the officer
reasonably believes has resulted in
serious injury or death.
b. Vehicles other than motorcycles
1) To assure an officer is not left in a
vulnerable position, consideration should be
given to the final resting place of the patrol
car and its proximity to the violator's
vehicle prior to ramming.
2) Ramming should not occur when the pursued
vehicle is traveling in excess of 35 mph.
4 . Boxing In - The use of boxing in as a technique for
terminating pursuits is discouraged. Under ordinary
circumstances, the potential hazard outweighs the chance
for a successful stop of a violator and therefore should
only be used at slow speeds or where the obvious risks
can be eliminated or appreciably reduced.
5 . Use of Firearms - Officers may use firearms only as a
0
STANDARD OPERATING PROCEDURE CHAPTER #36 PROCEMM #3
VEHICULAR PURSUITS (REVISED) PAGE 10
*******************************************************************
last resort and shall be governed by Department Policy,
Chapter 37 regarding use of weapons.
E. A supervisor shall evaluate all forced vehicle stops and
complete an interoffice memo to the appropriate division
commander.
I
C I T Y O F S A N B E R N A R D I N O
INTEROFFICE MEMORANDUM
TO: Dan A. Robbins, Chief of Police
Victor Lorch, Director of Risk Management
FROM: Richard J. Morillo
Sr. Assistant City Attorney
DATE: June 9, 1993
RE: Review of Police Department Pursuit Policy
COPIES: James F. Penman, Sgt. Michael Kinsman
IWe have undertaken a review of the pursuit policy of the San
Bernardino Police Department ( SOP Manual, Chapter 36, Procedure #3)
in light of recent court decisions interpreting Vehicle Code
517004. 7. We conclude the present policy is deficient in failing
to provide guidelines for initiating or terminating pursuits, and
that the policy requires clarification as to designating the "lead
vehicle. " Suggested revisions are attached.
Background
Vehicle Code 517004.7 confers limited immunity from liability
on a City which adopts guidelines for police pursuits. The
immunity only extends to potential liability for injuries or death
or property damage "resulting from the collision of a vehicle being
operated by an actual or suspected violator of the law who is
being, has been or believes he or she is being or has been pursued
by a peace officer employed by a public entity in a motor vehicle. "
In other words, the immunity applies only to injuries caused by the
suspect/violator ' s vehicle. No immunity is conferred by this
statute for injuries caused by a City vehicle involved in a
pursuit . ' Subsection ( c ) of Vehicle Code 517004. 7 sets forth four
criteria that must be satisfied for a policy to confer immunity:
" If the public entity has adopted a policy for the safe
conduct of vehicular pursuits by peace officers, it shall
meet all of the following minimum standards:
'Under Vehicle Code §17004, public employees are immune from
personal liability for injury, death or property damage occurring
" .chile responding to an emergency call or when in the immediate
pursuit of an actual or suspected violator of the law . . . " This
immunity is absolute and does not depend upon the adoption of a
pursuit policy.
TO: Dan A. Robbins, Chief of Police
Victor Lorch, Director of Risk Management
FROM: Richard J. Morillo, Sr. Assistant City Attorney
DATE: June 9, 1993
RE: Review of Police Department Pursuit Policy Page 2
( 1 ) It provides that, if available, there be supervisory
control of the pursuit.
( 2 ) It provides procedures for designating the primary
pursuit vehicle and for determining the total number of
vehicles to be permitted to participate at one time in
the pursuit.
( 3 ) It provides procedures for coordinating operations
with other jurisdictions.
( 4 ) It provides guidelines for determining when the
interests of public safety and effective law enforcement
justify a vehicular pursuit and when a vehicular pursuit
should not be initiated or should be terminated. "
Present San Bernardino Police Department Policy
The complete present San Bernardino policy is attached hereto
as Exhibit A. Relevant provisions include the following:
"WHEN PURSUITS MAY BE INITIATED:
Pursuits may be initiated when an officer has reasonable
cause to stop a vehicle and the driver fails to stop as
required by law.
"WHEN TO DISCONTINUE A PURSUIT:
Officer should consider discontinuing a pursuit when it
poses a serious and unreasonable risk of harm to the
pursuing officer or to the public, balanced against the
seriousness of the violations. "
"PURSUIT UNITS :
A. A police unit shall not be engaged in a pursuit
unless equipped with a red light and siren, activated and
operating continuously.
B . In all pursuits, only two units shall be involved in
the pursuit at any time. The station commander or field
supervisor may approve additional units, if necessary.
TO: Dan A. Robbins, Chief of Police
Victor Lorch, Director of Risk Management
FROM: Richard J. Morillo, Sr. Assistant City Attorney
DATE: June 9, 1993
RE: Review of Police Department Pursuit Policy Page 3
"PURSUIT RADIO PROCEDURE:
B. During the pursuit, the suspect vehicle requires the
absolute attention of the lead or primary unit. Whenever
possible, the unit behind the lead unit shall 'call the
pursuit' , as outlined under the officer's
responsibilities, allowing the lead unit to give full
attention to the suspect vehicle. . . .
1 . Once the pursued vehicle is observed and followed by
the helicopter, pursuing units shall remain in a Code 3
operation, decreasing speed, however, remaining close
enough to effect an arrest at the termination of the
pursuit.
2. The aircraft then becomes the pursuing unit and is
responsible for coordinating the ground units.
Payne v. City of Perris
In Payne v. City of Perris ( 1993) 12 Cal.App.4th 1738, the
Fourth District Court of Appeal held that Perris ' pursuit policy
failed to confer immunity because it was not specific enough in
providing guidelines on when pursuits should be initiated or
discontinued. The opinion does not indicate what Perris' policy
said about initiating pursuits, except that it was similar to the
City of Gardena ' s policy that was found to be deficient in Colvin
v. City of Gardena ( 1992 ) 11 Ca1 .App. 4th 1270, discussed below. On
terminating pursuits, the Perris policy provided:
"Officers should consider discontinuing a pursuit when it
poses a serious and unreasonable risk of harm to the
pursuing officer or to the public, balanced against the
seriousness of the violation( s ) . Justification to
continue a pursuit will be based on what reasonably
appears to be the facts know or perceived by the
officer. "
Colvin v.City of Gardena
In Colvin v. City of Gardena, supra, the Court held that
Gardena ' s pursuit policy failed to meet the criteria of Vehicle
Code 517004 . 7 in four respects. One of them -- limiting the number
of vehicles in a pursuit -- is not a deficiency in San Bernardino' s
policy, and thus will not be discussed. The other problems were
TO: Dan A. Robbins, Chief of Police
Victor Lorch, Director of Risk Management
FROM: Richard J. Morillo, Sr. Assistant City Attorney
DATE: June 9, 1993
RE: Review of Police Department Pursuit Policy Page 4
the following:
1. Initiation of pursuits:
Gardena' s policy stated:
"Pursuits may be initiated when an officer has
reasonable cause to stop a vehicle and the driver fails
to stop as required by law. " (This is identical to San
Bernardino' s policy. )
The Court found this insufficient because the Vehicle Code
contemplates "guidelines for determining when the interest of
public safety and effective law enforcement justify a vehicular
pursuit and when a vehicular pursuit should not be initiated. " A
policy which simply authorized a pursuit in all instances fell
short of this subjective.
2 . Termination of pursuits:
I
Gardena' s policy provided:
"Justification to continue a pursuit will be based
on what reasonably appears to be the facts known or
perceived by the officer. Officers should consider
discontinuing a pursuit when it poses a serious and
unreasonable risk of harm to the pursuing officer or to
the public balanced against the seriousness of the
violations, or when directed to do so by a supervisor. "
As the Court did in Payne, supra, the Colvin court found that
this standard vested too much discretion in the pursuing officer.
3 . Primary Vehicle:
Gardena ' s policy contained no mechanism for designating the
"primary vehicle" , although it did spell out specific
responsibilities for the different vehicles involved. The court
deemed it inadequate.
Discussion
Putting all of these together, it is clear that San
Bernardino ' s policy needs revision in three aspects in order to
take advantage of the immunity conferred by Vehicle Code § 17004. 7 .
The provisions for initiating and discontinuing pursuits are
insufficient and must be revised. Additionally, the mechanism for
TO: Dan A. Robbins, Chief of Police
Victor Lorch, Director of Risk Management
FROM: Richard J. Morillo, Sr. Assistant City Attorney
DATE: June 9, 1993
RE: Review of Police Department Pursuit Policy Page 5
designating the "primary" pursuit vehicle should be clarified. It
appears that the "lead" vehicle is the intended "primary" vehicle,
but the policy could be more specific.
Drafting An Adequate Policy
The only case to uphold pursuit guidelines under Vehicle Code
§17004.7 is Weiner v. City of San Diego ( 1991 ) 229 Ca1.App.3d 1203.
For reference, a copy of San Diego' s pursuit policy, as appended to
the court' s decision in Colvin, supra, is attached hereto as
Exhibit B.
1 . Initiation of Pursuits:
The City of San Diego policy upheld in Weiner provided:
"An officer may initiate a pursuit under the following
conditions:
a. When a known wanted felon is in the vehicle.
b. When the occupant( s) of the vehicle have
committed a crime in the officers' presence.
C . When the officer has an articulable reason for
wanting to stop the vehicle. "
In Colvin, the court noted that San Diego' s policy was more
specific than Gardena' s insofar as it provided for the initiation
of a pursuit when a known wanted felon is in the vehicle or the
occupants of the vehicle have committed a crime in the officer' s
presence . It stopped short of endorsing it, however, probably
because the "articulable reason" standard vests too much discretion
in the pursuing officer.
In Payne, the court quoted from the pursuit policy of the City
of Bellevue, Washington, not as an example of an adequate policy,
but to demonstrate that such policies could be adopted without
unduly hampering law enforcement. The Bellevue, Washington policy
calls for consideration of the following factors with respect to
the initiation, continuation and termination of pursuits:
" ( 1 ) the seriousness of the originating crime and
its relationship to community safety;
( 2 ) safety of the public in the area of pursuit;
TO: Dan A. Robbins, Chief of Police
Victor Lorch, Director of Risk Management
FROM: Richard J. Morillo, Sr. Assistant City Attorney
DATE: June 9, 1993
RE: Review of Police Department Pursuit Policy Page 6
( 3 ) safety of the pursuing officer( s) ;
(4) volume of vehicular traffic;
( 5 ) volume of pedestrian traffic;
( 6) location of pursuit;
( 7 ) speeds involved;
( 8 ) time of day;
( 9 ) weather conditions;
( 10 ) road conditions;
( 11 ) familiarity of the officer and supervisor or
commander with the area of pursuit;
( 12 ) quality of radio communications between
pursuing unit( s ) and the dispatcher and supervisor; and
( 13 ) the capability of the police vehicles
involved. "
The Payne court also quoted from the model policy of the
° National Law Enforcement Policy Center:
"The pursuing officer shall consider the following
factors in determining whether to initiate a pursuit:
( 1 ) The performance capabilities of the policy
vehicle;
( 2 ) The condition of the road surface upon which
the pursuit is being conducted;
( 3 ) The amount of vehicular and pedestrian traffic
in the area; and
( 4 ) Weather conditions. "
Bellevue ' s policy is to be commended because all of the criteria
seem to be common-sense factors, although it may focus too much on
safety and not enough on necessity. We believe the model policy
quoted in Payne is deficient, in that it has no regard for the
seriousness of the offense for which the suspect is being pursued.
TO: Dan A. Robbins, Chief of Police
Victor Lorch, Director of Risk Management
FROM: Richard J. Morillo, Sr. Assistant City Attorney
DATE: June 9, 1993
RE: Review of Police Department Pursuit Policy Page 7
2. Termination of Pursuits:
The following passage from Colvin is worth quoting at length
insofar as the court contrasted Gardena' s inadequate policy with
the policies of several other jurisdictions:
"In addition to failing to set forth guidelines for
initiating a pursuit, the City' s policy lacks any
guidelines for discontinuing a pursuit. The City' s
policy merely directs officers to engage in a
cost/benefit analysis and to discontinue a pursuit
whenever the risk of harm to the officer or to the public
outweighs the seriousness of the violations. However,
there are no guidelines to assist the officer in
balancing risks and benefits. Consequently, this element
of the City' s policy is purely conclusionary.
"In contrast, the San Diego policy sets forth the
following factors an officer should consider in
determining whether a pursuit should be terminated:
vehicular traffic, pedestrian, roadway and environmental
conditions; the violation for which the suspect is
wanted; whether the suspect is known to be a juvenile;
and, whether the suspect has been identified to the point
that later apprehension can be accomplished.
"Also, in this regard, San Francisco' s policy states
a pursuit should be discontinued when an unreasonable
danger exists to the officers or others. Its guidelines
go on to state: 'An unreasonable danger exists when
speeds dangerously exceed the normal flow of traffic or
when vehicular or pedestrian traffic necessitates
dangerous maneuvering exceeding the performance
capabilities of the vehicle or driver, or when the reason
for apprehending the pursued vehicle clearly is
outweighed by the risk of harm imposed on the person or
property of the officers or others if the pursuit is
continued. '
"Also by comparison, the policy of the County of Los
Angeles directs a pursuit to be discontinued inter alia,
' [ a] fter a reasonably short distance when the only known
reason for the pursuit is traffic violations or other
misdemeanors, or known or suspected GTA [grand theft
auto] suspects ' or when the pursuit is as a result of
action by another police department traversing the
County' s jurisdiction and the County' s assistance is no
TO: Dan A. Robbins, Chief of Police
Victor Lorch, Director of Risk Management
FROM: Richard J. Morillo, Sr. Assistant City Attorney
DATE: June 9, 1993
RE: Review of Police Department Pursuit Policy Page 8
longer needed.
"Further, the policies of the City of San Francisco
and the County of Los Angeles both emphasize the
immediate apprehension of the violator is 'never more
important than the safety' of innocent persons or the
officers themselves. Similarly, the San Diego policy
directs the officers to ' continually question whether the
seriousness of the offense justifies continuing the
pursuit' and cautions that a pursuit should be continued
only ' as long as it is safe to do so. "' Id. at 1284-
1285. —
In Payne, the model policy of the National Law Enforcement
Policy Center stated as follows with respect to termination of
pursuits:
"Pursuit shall be immediately terminated in any of
the following circumstances:
( 1 ) Weather or traffic conditions substantially
increase the danger of pursuit beyond the worth of
apprehending the suspect;
( 2 ) The distance between the pursuit and fleeing
vehicles is so great that further pursuit is futile; or
( 3 ) The danger posed by continued pursuit to the
public, the officers or the suspect is greater than the
value of apprehending the suspect( s) . "
Again, we find the model policy deficient. Bellevue' s policy
( which covers both initiation and termination of pursuits) has
practical appeal, as does San Diego' s (with the exception of the
factor which reads "suspect is known to be a juvenile, " ) .
3 . Designating Primary Vehicle:
The court in Colvin quoted or paraphrased the policies of
several other jurisdictions and contrasting their policies to
Gardena ' s with respect to designating the primary pursuit vehicle
and limiting the number of vehicles involved in a pursuit:
" In contrast, the policy of the City of Los Angeles
states the initial pursuing unit shall be designated the
primary pursuit vehicle, and that in the event the
primary unit cannot continue as the primary unit, the
TO: Dan A. Robbins, Chief of Police
Victor Lorch, Director of Risk Management
FROM: Richard J. Morillo, Sr. Assistant City Attorney
DATE: June 9, 1993
RE: Review of Police Department Pursuit Policy Page 9
secondary unit shall become the primary unit.
"Similarly, San Diego' s policy provides, in relevant
part, that in the event another unit becomes better
positioned to provide cover for the chase unit, then that
unit shall become the primary assisting unit and the
former assisting unit shall cease any violation of
traffic laws.
"The policy of the City of Los Angeles further
states, inter alia: 'Number of police units
participating. The initial pursuing police unit (primary
unit ) and back-up police unit ( secondary unit) shall be
the only units to pursue the suspect vehicle' . . .
"Likewise, the policy of the County of Los Angles
provides ' [t]he active pursuit shall normally consist of
no more than three units; the primary unit; and two back-
up units, ' unless more assistance is specifically
requested. " Id. at 1286.
It is mentioned, in the case of San Bernardino' s existing
policy there appears to be a simple assumption that the lead unit
in a pursuit is the "primary unit. " The change that needs to be
made is to specifically provide that this is so.
Recommendation
We recommend the department replace the separate policy
statements on initiating and terminating pursuits with a single
statement covering their initiation, continuation and termination.
The recommended SOP revision attached hereto is modeled after the
Bellevue, Washington, policy, with the addition of language from
San Diego ' s as to the need to "continually question whether the
seriousness of the offense justifies continuing the pursuit . . . "
We also recommend the statement in paragraph B under the
heading "PURSUIT UNITS" be amended to incorporate the language from
the LAPD policy, so that paragraph B will read as follows:
" In all pursuits, only two units shall be involved
in the pursuit at any time. The station commander or
field supervisor may approve additional units, if
necessary. The initial pursuing unit shall be the
primary pursuit vehicle. In the event the primary unit
cannot continue as the primary unit, the secondary unit
shall become the primary unit. "
TO: Dan A. Robbins, Chief of Police
Victor Lorch, Director of Risk Management
FROM: Richard J. Morillo, Sr. Assistant City Attorney
DATE: June 9, 1993
RE: Review of Police Department Pursuit Policy Page 10
This concludes our comments. If you have any questions about
the foregoing, please feel free to call.
RJM:ms[robbinsl .mem]
Attachments
RECOMMENDED REVISION TO SAN BERNARDINO POLICE
DEPARTMENT PURSUIT POLICY (SOP Ch. 36, Procedure #3)
Delete material under headings "WHEN PURSUITS MAY BE
INITIATED" and "WHEN TO DISCONTINUE A PURSUIT" and substitute the
following:
"INITIATING, CONTINUING AND TERMINATING A PURSUIT:
A. The following factors should be considered when
determining whether any pursuit should be initiated, continued or
terminated:
( 1 ) the seriousness of the originating crime and its
relationship to community safety;
( 2 ) safety of the public in the area of pursuit;
( 3 ) safety of the pursuing officer( s) ;
( 4 ) volume of vehicular traffic;
( 5 ) volume of pedestrian traffic;
( 6 ) location of pursuit;
( 7 ) speeds involved;
( 8 ) time of day;
( 9 ) weather conditions;
( 10 ) road conditions;
( 11 ) familiarity of the officer and supervisor or
commander with the area of pursuit;
( 12 ) quality of radio communications between pursuing
unit( s ) and the dispatcher and supervisor; and
( 13 ) the capability of the police vehicles involved.
B . Once a pursuit is initiated, officers, field supervisors
and station commanders should continually question whether the
seriousness of the offense justifies continuing the pursuit. "