AuthorTitleCitationSummaryYear
Major ReAnne R. Wentz "EQUALITY OF TREATMENT": HOW SERVICE MEMBERS OF COLOR ARE DISPROPORTIONATELY IMPACTED BY THE MILITARY LAW ENFORCEMENT'S TITLING PROCESS 230 Military Law Review 307 (2023) The inequality experienced today is part of the legacy of our nation's past. It is also, more specifically, the harvest of the military's own history of racial exclusion, followed by racial segregation and discrimination. It is, as well, intimately linked to and reinforced by social conditions existing in the larger society. White and non-white... 2023
Mackenzie Boyer "I CAN'T BREATHE": HOW RECORDING THE POLICE CAN SAVE A LIFE AND THE JUSTICE SYSTEM 29 Widener Law Review 241 (2023) 9 minutes, and 29 seconds--the excruciating length of time during which George Floyd cried out I can't breathe twenty-eight times as he was slowly dying at the hands, or knees rather, of law enforcement. I can't breathe-- George Floyd's last three words, each cry for help more faint than the last, as he gradually lost consciousness, and... 2023
Marcia M. Ziegler 32 SHOTS IN THE DARK: HOW LOCAL GOVERNMENTS CAN INCREASE POLICE ACCOUNTABILITY WHEN STATES REFUSE TO 74 Mercer Law Review 1155 (Spring, 2023) On March 13, 2020, Breonna Taylor was shot to death in her apartment hallway by police officers executing a search warrant. The warrant was based on a false affidavit, the executing officers acted criminally on scene, and in the aftermath, detectives spread misinformation about the case on social media. While there was some limited accountability... 2023
  A Commentary on Qualified Immunity in the Aftermath of City of Tahlequah v. Bond 59 Criminal Law Bulletin 2 (59-SEP Trial 18) Delores D. Jones-Brown earned a J.D. and a Ph.D. in criminal justice from Rutgers University. She is retired from the Department of Law, Police Science, and Criminal Justice Administration at John Jay College of Criminal Justice, City University of New York (CUNY). She was the founding director of the John Jay College Center on Race, Crime, and... 2023
Sydney Baker , Kamar Y. Tazi , Emily Haney-Caron A CRITICAL DISCUSSION OF YOUTH MIRANDA WAIVERS, RACIAL INEQUITY, AND PROPOSED POLICY REFORMS 29 Psychology, Public Policy, and Law 320 (August, 2023) Courts often assume that youth and adult suspects are equally capable of making decisions about whether to talk to police officers--decisions that carry serious long-term consequences. In Miranda v. Arizona, the Supreme Court ruled that prior to custodial interrogation, police officers must remind suspects of their rights to silence and legal... 2023
Ryan D. King , Besiki L. Kutateladze A HIGHER BAR: INSTITUTIONAL IMPEDIMENTS TO HATE CRIME PROSECUTION 57 Law and Society Review 489 (December, 2023) Why are hate crime cases so rarely prosecuted? Most states and the federal government have hate crime laws on their books, yet available data indicate few prosecutions in most jurisdictions. Drawing on case files and interviews with police and prosecutors in one jurisdiction, three institutional impediments to hate crime prosecution are identified:... 2023
Garanique Williams A MEANS TO AN END: A WAY TO CURB BIAS-BASED POLICING IN NEW YORK CITY 2023 Cardozo Law Review de novo 90 (2023) C1-2Table of Contents Introduction. 91 I. Background. 95 A. Explaining the New York City Housing Authority (NYCHA). 95 B. The Rise of Police Service Areas (PSAs). 96 C. The Problem with PSAs. 98 D. Section 14-151 of the Administrative Code's Offered Protections to Bias-Based Profiling. 101 E. The Constitutional Protections to the Problem of... 2023
Simone Drake , Katrina Lee , Kevin Passino , Hugo Gonzalez Villasanti A MULTIDISCIPLINARY APPROACH TO IMPROVING POLICE INTERACTIONS WITH BLACK CIVILIANS 38 Ohio State Journal on Dispute Resolution 717 (2023) I. Introduction II. Historical Overview A. Race and Policing B. Police Training III. Project Design A. Informed by a Multidisciplinary Team B. Software Development IV. Future Directions V. Conclusion Over-use of force by law enforcement officers in the United States persists, along with a resulting state of crisis in Black communities. Massive... 2023
Sarah E. Burns, Sarah S. Wheeler A REVIEW AND LOOK AHEAD AT CRIMINALIZING PREGNANCY IN THE NAME OF THE STATE INTEREST IN FETAL LIFE 76 SMU Law Review 369 (Spring, 2023) Across the United States, and especially in communities that are highly policed and in places hostile to abortion, pregnant people are dying, suffering, being separated from their children and families, and going to jail and prison in purported service of the state interest in fetal life recognized in Roe v. Wade and expanded in Planned Parenthood... 2023
Matthew Sweat A SQUARE DOUBLE HELIX IN A ROUND HOLE: FORENSIC GENETIC GENEALOGY SEARCHES AND THE FOURTH AMENDMENT 39 Georgia State University Law Review 605 (Winter, 2023) A forensic genetic genealogy search (FGGS) involves law enforcement's use of consumer DNA databases to generate leads to solve cold cases. As a result of more modern technological processes, the DNA profiles kept in consumer databases are far more revealing than the DNA profiles stored in the FBI's Combined DNA Index System (CODIS). Accordingly,... 2023
Samantha Buckingham ABOLISHING JUVENILE INTERROGATION 101 North Carolina Law Review 1015 (May, 2023) Rehabilitation is a paramount consideration in abolishing police interrogation of youth. Interrogation is one of the first interactions young people have with the criminal legal system. Unfortunately, the most common methods of interrogation are coercive rather than consensual. Youth are uniquely vulnerable to coercive methods, especially in... 2023
Josephine Ross ABOLISHING POLICE CONSENT SEARCHES THROUGH LEGISLATION: LESSONS FROM SCOTLAND 72 American University Law Review 2017 (August, 2023) Why have U.S. civil rights organizations omitted the abolition of consent searches from the panoply of recommended police reforms? As over 90% of all searches of cars and pedestrians in the United States are based on consent, this begs the question. The Supreme Court created the consent loophole so that police who lacked probable cause could... 2023
Allegra McLeod ABOLITION AND ENVIRONMENTAL JUSTICE 69 UCLA Law Review 1536 (September, 2023) During the coronavirus pandemic, movements for penal abolition and racial justice achieved dramatic growth and increased visibility. While much public discussion of abolition has centered on the call to divest from criminal law enforcement, contemporary abolitionists also understand public safety in terms of building new life-sustaining... 2023
Brandon Hasbrouck ALLOW ME TO TRANSFORM: A BLACK GUY'S GUIDE TO A NEW CONSTITUTION 121 Michigan Law Review 883 (April, 2023) Allow Me to Retort: a Black Guy's Guide to the Constitution. By Elie Mystal. New York: The New Press. 2022. Pp. 270. Cloth, $25.10; paper, $17.66. What happens to a dream deferred? --Langston Hughes Constitutional law seeps into our daily lives in America. Whether it's a state legislature taking another shot at undermining civil rights or a police... 2023
Elliott Averett AN UNQUALIFIED DEFENSE OF QUALIFIED IMMUNITY 21 Georgetown Journal of Law & Public Policy 241 (Winter, 2023) A policeman's lot is not so unhappy that he must choose between being charged with dereliction of duty if he does not arrest when he has probable cause and being mulcted in damages if he does. --Chief Justice Earl Warren This Note argues that, rather than being eliminated, qualified immunity should be strengthened in the face of a nationwide... 2023
Chi Adanna Mgbako, Nate Johnson, Vivienne Bang Brown, Megan Cheah, Kimya Zahedi ANTI-CARCERAL HUMAN RIGHTS ADVOCACY 26 University of Pennsylvania Journal of Law and Social Change 173 (2023) Abstract. The theory of carceral abolition entered the mainstream during the 2020 global protests for Black lives. Abolition calls for divestment from carceral institutions like police and prisons in favor of the expansion of social and economic programs that ensure public safety and nurture community well-being. Although there is little... 2023
Jeffrey Fagan , Lila J.E. Nojima ARE POLICE OFFICERS BAYESIANS? POLICE UPDATING IN INVESTIGATIVE STOPS 113 Journal of Criminal Law and Criminology 593 (Summer, 2023) Theories of rational behavior assume that actors make decisions where the benefits of their acts exceed their costs or losses. If those expected costs and benefits change over time, the behavior will change accordingly as actors learn and internalize the parameters of success and failure. In the context of proactive policing, police stops that... 2023
Eang L. Ngov ASYMMETRIES, NORM MATCHING, AND THE PURSUIT OF EQUITY BETWEEN THE POLICE AND THE PUBLIC 60 American Criminal Law Review 231 (Spring, 2023) Concerns about police abuse and overcriminalization are on the forefront of public conscientiousness. In spite of the Black Lives Matter movement and calls for police reform, law enforcement officials enjoy a variety of criminal procedure loopholes and double standards, which the United States Supreme Court has ratified through its creation of the... 2023
Ronald J. Coleman BIG DATA POLICING CAPACITY MEASUREMENT 53 New Mexico Law Review 305 (Summer, 2023) Big data, algorithms, and computing technologies are revolutionizing policing. Cell phone data. Transportation data. Purchasing data. Social media and internet data. Facial recognition and biometric data. Use of these and other forms of data to investigate, and even predict, criminal activity is law enforcement's presumptive future. Indeed, law... 2023
Michael Z. Green BLACK AND BLUE POLICE ARBITRATION REFORMS 84 Ohio State Law Journal 243 (2023) The racial justice protests that engulfed the country after seeing a video of the appalling killing of a Black male, George Floyd, by a Minnesota police officer in 2020 has led to a tremendous number of questions about dealing with racial issues in policing. Similar concerns arose a little more than fifty years ago when police unions gained power... 2023
Ayesha Bell Hardaway BLACK AND BLUE: THE INTRACTABLE PRESENCE OF RACE IN AMERICAN POLICING 73 Case Western Reserve Law Review 607 (Spring, 2023) The Racial Reckoning of 2020 ignited a national conversation about the myriad structural flaws in our policing systems. This was not the first time. Modern America has experienced several waves of national discussions about policing. The first sustained wave began during the 1950s and ran through the 1960s, with Black activists and their allies... 2023
Norrinda Brown BLACK LIBERTY IN EMERGENCY 118 Northwestern University Law Review 689 (2023) Abstract--COVID-19 pandemic orders were weaponized by state and local governments in Black neighborhoods, often through violent acts of the police. This revealed an intersection of three centuries-old patterns--criminalizing Black movement, quarantining racial minorities in public health crises, and segregation. The geographic borders of the most... 2023
Chaz Arnett BLACK LIVES MONITORED 69 UCLA Law Review 1384 (September, 2023) The police killing of George Floyd added fuel to the simmering flames of racial injustice in America following a string of similarly violent executions during a global pandemic that disproportionately ravaged the health and economic security of Black families and communities. The confluence of these painful realities exposed deep vulnerabilities... 2023
Charelle Lett BLACK WOMEN VICTIMS OF POLICE BRUTALITY AND THE SILENCING OF THEIR STORIES 30 UCLA Journal of Gender & Law 131 (Summer, 2023) C1-2Table of Contents Introduction. 132 I. Brief History of State Sanctioned Violence Against Black People in the United States. 132 A. Slave Patrols as the Foundation of Modern Policing. 132 B. The Lynching Period and Law Enforcement's Involvement. 134 C. Historical Account of the Criminalization of Black Activism. 136 1. Second Red Scare. 136 2.... 2023
Kendra Albert, Avatara Smith-Carrington BOMB BODY POLITICS: ON THE TSA'S ALGORITHIMIC POLICING OF GENDER 33 University of Florida Journal of Law and Public Policy 213 (Spring, 2023) Long before modern discussions of algorithmic policing, the Department of Homeland Security was using sexist and racist algorithms to determine which individuals to subject to additional screening. The algorithms are built into the Transportation Safety Administration's advanced imaging technology, and they are used to justify the systems of... 2023
Jenna Prochaska BREAKING FREE FROM "CRIME-FREE": STATE-LEVEL RESPONSES TO HARMFUL HOUSING ORDINANCES 27 Lewis & Clark Law Review 259 (2023) Municipalities throughout the country enforce broad and harmful crime-free housing and nuisance property ordinances (CFNOs)--local laws that encourage landlords to evict or exclude tenants from housing opportunities based on their contact with the criminal legal system or calls for police help. There is little evidence that CFNOs are effective at... 2023
Mackenzie Philbrick BUDGETING FOR EXONEREE COMPENSATION: INDEMNIFYING EXONEREES NOT OFFICIALS TO DETER FUTURE WRONGFUL CONVICTIONS 50 Fordham Urban Law Journal 797 (April, 2023) As survivors of state harm, exonerees are often woefully undercompensated compared to present jury awards for wrongful incarceration. Furthermore, by precluding exonerees who have falsely confessed or pled guilty from receiving state compensation, lawmakers squander an opportunity to increase police accountability going forward, further stacking... 2023
Sandy Hudson BUILDING A WORLD WITHOUT POLICE 69 UCLA Law Review 1646 (September, 2023) L1-2TABLE OF CONTENTS Introduction. 1648 I. Reform: A Project of Repeated Failure. 1653 II. Safety & Security as the Goal. 1660 III. The New Future. 1670 Conclusion. 1677 2023
Jared Joseph , Bill McCarthy CALIFORNIA CIVIL ASSET FORFEITURE AND THE POLICING OF MINORITY RESIDENTS 48 Law and Social Inquiry 1138 (November, 2023) In Who Are the Criminals?, John Hagan argues that legislators use crisis framing to influence how the general public thinks about crime. President Ronald Reagan used reports of a drug use epidemic fueled by organized crime as part of his crisis framing. In 1984, he signed the Comprehensive Crime Control Act (CCCA) as part of his war on drugs.... 2023
Quinlan Cummings CALLING OFFICER HESTER PRYNNE! THE PROMISES AND PITFALLS OF EMPLOYING PUBLIC SHAME AS A DETERRENT FOR POLICE MISCONDUCT 60 American Criminal Law Review 179 (Winter, 2023) I literally could not put my phone down. Whether I got shot or not, this needed to be documented. Those words were spoken by the bystander who used their smartphone to capture the moment that police in Austin, Texas opened fire on peaceful protestors seeking medical assistance for 20-year-old Justin Howell. An officer had shot Howell in the back... 2023
Edward R. Maguire , Shawn L. Hill , Howard Giles CAUGHT IN THE MIDDLE: ACCOMMODATIVE DILEMMAS IN POLICE--COMMUNITY RELATIONS 29 Psychology, Public Policy, and Law 486 (November, 2023) Police reform movements often focus on improving relationships between police and the public. These relationships are a primary focus of community policing and procedural justice, two major reform efforts in policing worldwide over the past 3 decades. Reform movements that seek to improve relationships between police and the public rely, in part,... 2023
Jonathan Jackson , Tasseli McKay , Leonidas Cheliotis , Ben Bradford , Adam Fine , Rick Trinkner CENTERING RACE IN PROCEDURAL JUSTICE THEORY: STRUCTURAL RACISM AND THE UNDER- AND OVERPOLICING OF BLACK COMMUNITIES 47 Law and Human Behavior 68 (February, 2023) Objective: We assessed the factors that legitimized the police in the United States at an important moment of history, just after the police killing of George Floyd in 2020. We also evaluated one way of incorporating perceptions of systemic racism into procedural justice theory. Hypotheses: We tested two primary hypotheses. The first hypothesis was... 2023
André Douglas Pond Cummings , Kalvin Graham CLAIM DENIED - ACCESS DENIED: THE BLACK WALL STREET INSURANCE GRIFT 35 Saint Thomas Law Review 101 (Spring, 2023) The subject of Corporate Reparations has gained noteworthy momentum in recent years. The murder of George Floyd at the hands of former police officer Derek Chauvin in 2020 galvanized major United States corporate leadership into thinking about and committing to playing a sizeable role in ending systemic racism and bringing economic equality and... 2023
Catherine L. Fisk COLLECTIVE BARGAINING AND THE TRANSFORMATION OF POLICE 69 Wayne Law Review 1 (Spring, 2023) I. Introduction. 1 II. Police Abuse and the Question of Managerial Failure. 6 III. The Controversy Over Police Unions and Violence: Collective Action, Contract, Culture, or Something Else?. 12 IV. Whither Police Labor Relations Reform. 15 V. Conclusion. 29 2023
Rebecca L. Fix , Jeffrey Aaron , Sheldon Greenberg COMMUNITY CRIME, POVERTY, AND PROPORTION OF BLACK RESIDENTS INFLUENCE POLICE DESCRIPTIONS OF ADOLESCENTS 47 Law and Human Behavior 12 (February, 2023) Objective: Our study examined officers' attitudes and perceptions of adolescents in general (and challenges in policing adolescents) and the degree to which community variables affect those perceptions. Hypotheses: Our examinations of officers' descriptions of adolescents and challenges in policing adolescents were exploratory. We hypothesized that... 2023
Sean J. McKinley, Edelyn Verona, Department of Psychology, University of South Florida COOL UNDER FIRE: PSYCHOPATHIC PERSONALITY TRAITS AND DECISION MAKING IN LAW-ENFORCEMENT-ORIENTED POPULATIONS 47 Law and Human Behavior 591 (October, 2023) Objective: Compared with other jobs, the law enforcement profession is a high-stakes occupation that has the potential to greatly impact public safety, and officers must face daily dangers not experienced in other professions. Previous research indicates that many law enforcement officers exhibit varying degrees of psychopathic traits, which... 2023
Marty Berger , David A. Sklansky CRIME, COMMUNITY, AND THE SHADOW OF THE VIRTUAL 2023 University of Illinois Law Review 1607 (2023) As reformers and abolitionists spar over the future of law enforcement, both camps urge giving the community a weightier say in defining public safety priorities. Regardless of whether police departments should be further revamped or instead defunded, a key task will be determining how to grapple with the complicated, heterogeneous nature of... 2023
Margareth Etienne , Richard McAdams CRIMINOGENIC RISKS OF INTERROGATION 98 Indiana Law Journal 1031 (Spring, 2023) In the United States, moral minimization is a pervasive police interrogation tactic in which the detective minimizes the moral seriousness and harm of the offense, suggesting that anyone would have done the same thing under the circumstances, and casting blame away from the offender and onto the victim or society. The goal of these minimizations is... 2023
Juliet P. Stumpf CRIMMIGRATION AND THE LEGITIMACY OF IMMIGRATION LAW 65 Arizona Law Review 113 (Spring, 2023) Crimmigration law--the intersection of immigration and criminal law--with its emphasis on immigration enforcement, has been central in discussions over political compromise on immigration reform. Yet crimmigration law's singular approach to interior immigration and criminal law enforcement threatens to undermine public faith in the legitimacy of... 2023
Jennifer M. Page, University of Zurich, jennifer.page@uzh.ch DEFENSIVE KILLING BY POLICE 24 Journal of Ethics & Social Philosophy 315 (April, 2023) All self-defense is undertaken under uncertain circumstances. If amid a violent encounter, someone pulls out and unlocks a gun, takes aim, and begins to squeeze the trigger, it is always possible for the gun to jam or be out of bullets. However, some self-defense scenarios are far more uncertain, where a person has not revealed a clear intent to... 2023
Jerron R. Wheeler, Esq. DEFUNDING C.O.P.S.: CONDITIONING FEDERAL FUNDING TO STATE AND LOCAL LAW ENFORCEMENT AGENCIES UPON THE IMPLEMENTATION OF A PROGRAM THAT SCREENS ITS CURRENT AND FUTURE OFFICERS FOR WHITE SUPREMACIST AFFILIATIONS 23 University of Maryland Law Journal of Race, Religion, Gender and Class 1 (Spring, 2023) I. Introduction. 1 II. White Supremacy in Policing. 4 III. Congress' Spending Clause Power. 10 IV. Proposed Screening Program. 13 V. Conclusion. 18 2023
Allison R. Cross , Kelsey E. Tom , Danielle Wallace , Rick Trinkner , Adam D. Fine DID GEORGE FLOYD'S MURDER SHAPE THE PUBLIC'S FELT OBLIGATION TO OBEY THE POLICE? 47 Law and Human Behavior 510 (August, 2023) Objective: Our goal in the present study was to use longitudinal data to assess how normative (i.e., consensually motivated) and instrumental (i.e., coercively motivated) obligation to obey police changed after police murdered George Floyd and whether these changes differed by political ideology. Hypotheses: Using procedural justice theory, we... 2023
Darren Byler DIGITAL TURBAN-HEAD: RACIAL LEARNING AND POLICING MUSLIMS IN NORTHWEST CHINA 46 PoLAR: Political and Legal Anthropology Review 121 (May, 2023) What do you think of our turban-heads' (women de chantou)? the taxi driver wondered, nodding out the window at a Uyghur pedestrian. I stared at him blankly. Not waiting for my response, he continued, wanting to get my thoughts on how the United States's war in Iraq was going. He had heard that it was going to affect the oil prices. It was 2010,... 2023
Cynthia Godsoe DISRUPTING CARCERAL LOGIC IN FAMILY POLICING 121 Michigan Law Review 939 (April, 2023) Torn Apart: How the Child Welfare System Destroys Black Families--and How Abolition Can Build a Safer World. By Dorothy Roberts. New York: Basic Books. 2022. Pp. 11, 303. $32. Among a growing consensus that the criminal legal system is oversized, racist, and ineffective at preventing harm, the child welfare/family-policing system continues to be... 2023
Daina Strub Kabitz ENGAGING IN EQUITY-CENTERED POLICYMAKING: STATE-LEVEL RACIAL EQUITY IMPACT ASSESSMENT TRENDS, LESSONS LEARNED, AND FUTURE DIRECTIONS 49 Mitchell Hamline Law Review 645 (June, 2023) I. Introduction. 646 II. Background. 647 III. Racial Equity Impact Assessments: Detailed Examples. 651 A. Criminal Justice Focused REIAs: Iowa's Correctional Impact Statement. 651 B. Generally Applicable REIAs: Colorado's Demographic Note. 654 C. Emerging REIA Trends at the Local Level: New York City's Racial Equity Report. 656 IV. Racial Equity... 2023
Randall E. Ravitz ENSURING JUSTICE, EQUITY, AND ACCOUNTABILITY THROUGH THE NEW MASSACHUSETTS PEACE OFFICER STANDARDS AND TRAINING (POST) COMMISSION 67-WTR Boston Bar Journal 16 (Winter, 2023) Events in 2020 focused public attention squarely on the practices of law enforcement and issues of racial justice. Responding to calls for action, the Massachusetts Legislature passed, and Governor Charles D. Baker signed, An Act Relative to Justice, Equity and Accountability in Law Enforcement in the Commonwealth. The legislation changed the rules... 2023
Seema Kakade ENVIRONMENTAL EVIDENCE 94 University of Colorado Law Review 757 (Summer, 2023) The voices of impacted people are some of the most important when trying to make improvements to social justice in a variety of contexts, including criminal policing, housing, and health care. After all, the people with on-the-ground experience know what is likely to truly effectuate change in their community, and what is not. Yet, such lived... 2023
Jennifer T. Perillo, Rochelle B. Sykes, Sean A. Bennett, Margaret C. Reardon, Department of Psychology, Indiana University of Pennsylvania EXAMINING THE CONSEQUENCES OF DEHUMANIZATION AND ADULTIFICATION IN JUSTIFICATION OF POLICE USE OF FORCE AGAINST BLACK GIRLS AND BOYS 47 Law and Human Behavior 36 (February, 2023) Objective: Given the greater contact that Black youth have with the legal system compared with White youth, it is important to consider the differential ways that police use of force against these youth is perceived. Black youth may be at greater risk than White youth for animalistic (being seen as animal-like) and mechanistic (being seen as... 2023
Michael Gentithes EXIGENCIES, NOT EXCEPTIONS: HOW TO RETURN WARRANT EXCEPTIONS TO THEIR ROOTS 25 University of Pennsylvania Journal of Constitutional Law 60 (March, 2023) When a police officer interacts with an individual, the encounter is subject to myriad exceptions to the Fourth Amendment's warrant requirement that lack a coherent justifying theory. For instance, officers can warrantlessly search if an automobile was involved in the interaction, an arrest occurred, or a protective sweep was necessary to prevent a... 2023
Amy C. Watson , Taleed El-Sabawi EXPANSION OF THE POLICE ROLE IN RESPONDING TO MENTAL HEALTH CRISES OVER THE PAST FIFTY YEARS: DRIVING FACTORS, RACE INEQUITIES AND THE NEED TO REBALANCE ROLES 86 Law and Contemporary Problems 1 (2023) Tragic police shootings of people experiencing mental health crises, along with recognition of the overrepresentation of people with serious mental illnesses in the criminal legal system, have garnered several decades of research and policy attention. Substantial resources have been focused on improving law enforcement's ability to safely provide... 2023
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