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Assault and Battery: Chemical (Pepper Spray (OC), Tear Gas and Chemical Agents)

     An arrestee claimed that an officer used excessive force in arresting him, including the use of pepper spray. The officer, during a traffic stop of the plaintiff, suspected that he might be wanted for a criminal offense. The arrestee claimed that the officer struck him several times with a flashlight after he slipped on a patch of ice, jumped on him after he began to run and fell to the ground, used pepper spray against him after he had already been subdued and handcuffed, and ignored his protests that he was in pain in forcibly moving him from the ground to a police vehicle. Because it was disputed whether the officer used the pepper spray on the arrestee before or after he was handcuffed, the excessive force claim concerning the use of the pepper spray survived summary judgment. Tracy v. Freshwater, #08-1769, 2010 U.S. App. Lexis 21238 (2nd Cir.).

Assault and Battery: Handcuffs

****Editor's Case Alert****

     National Guardsmen helping police officers with post-hurricane law enforcement stopped a motorist for speeding. He made three phone calls from the scene, one to police, to complain that Guardsmen had used a racial slur against him, one to his wife, an attorney, and one to his insurance company. His wife witnessed him being handcuffed when she arrived. A federal appeals court ruled that there was probable cause to stop the motorist, and that handcuffing him, without more, did not constitute an excessive use of force, even if they were allegedly adjusted too tight. Lockett v. City of New Orleans, #09-30712, 2010 U.S. App. Lexis 9261 (5th Cir.).

    A motorist was stopped for speeding and then arrested on an outstanding warrant, over her protests that the record of the warrant was mistaken. The bench warrant for an alleged probation violation had, in fact, been requested to be recalled, but the court had not yet entered the order. The arrestee was then handcuffed and shackled to a wall at the county station for most of the twelve and one-half hours she spent in custody while waiting for city police to come get her.

     She claimed that she suffered various physical and mental injuries as a consequence. A diabetic, she was allegedly denied permission to get her insulin from her vehicle, and allegedly told that she would be fine without it for a day. The trial court granted summary judgment to the defendant officer on her excessive force claim arising from her handcuffing. The appeals court upheld this result, finding that the plaintiff, although an innocent and wronged party, failed to show that the arresting officer committed a due process violation.

     He was not to blame for the majority of her ordeal, as he had only been on duty for four and a half hours of the time she remained handcuffed. As to the appropriate legal standard under the Maryland state Constitution for excessive force claims for force used by officers on a person in custody following a valid arrest, the court ruled that it was whether the force used amounted to punishment, rather than whether the force used shocks the conscience.

     The actions of the county police indicated that they had no intention to punish the plaintiff. They thought that she would only be shackled for a short time, they offered her food and drink, and they permitted her to use the bathroom. Smith v. Bortner, #2667, 2010 Md. App. Lexis 112.

Assault and Battery: Physical

     An officer believed that a motorcycle rider had committed a number of relatively minor infractions (failing to wear a helmet while driving a motorcycle and failing to stop when signaled by police). These infractions did not justify the force allegedly used by the officer in tackling the plaintiff from his motorcycle and slamming him into the pavement, so that the officer used excessive force and was not entitled to qualified immunity. The appeals court upheld a jury verdict for the plaintiff of $2,500 on both federal civil rights and state law assault and battery claims. Raiche v. Pietroski, #09-1910 2010 U.S. App. Lexis 21977 (1st Cir.).

     A motorist led state troopers on a 50-mile high-speed chase, culminating in his arrest. He sued, claiming that the troopers had used excessive force against him, and then unduly delayed his receipt of needed medical care. A federal appeals court upheld the trial court's grant of qualified immunity to the troopers, finding, on the basis of videotapes of the incident, that one trooper's actions in apprehending the plaintiff had been objectively reasonable, and that the tapes did not support the motorist's claim that the trooper beat a restrained cooperating suspect. Additionally, medical records did not show that the few minutes of delay before receiving medical treatment had caused any substantial harm. Borneman v. Rozier, #10-6045, 2010 U.S. App. Lexis 21316 (Unpub. 10th Cir.).

Assault and Battery: Tasers

****Editor's Case Alert****

     Police responded to a call from a woman's husband, reporting that she had stormed out of the house after a domestic dispute, having tried to put him in a closet, and had taken a kitchen knife with her. She was later observed walking back towards the home, and did not appear to be holding the knife. One of the officers tried to approach her, but she veered off the walkway towards the front door, walking quickly, but not running. The officer discharged his Taser into her back without warning when her feet were on the front steps of her home, and she went rigid, spun around, and struck her head on the concrete steps, suffering a traumatic brain injury.

     While Tasers may not constitute deadly force, the appeals court noted, their use clearly "seizes" a suspect in an abrupt and violent manner. The officer was not entitled to qualified immunity for using it against the woman who allegedly did not pose an immediate threat to the officer or anyone else. The appeals court held that a reasonable jury could conclude that, at the time the officer used the Taser, the plaintiff was not "fleeing," but only quickly walking to her own home, where the officer could easily arrest her if he wanted to. Cavanaugh v. Woods Cross City, #10-4017, 2010 U.S. App. Lexis 2290 (10th Cir.).

Attorneys' Fees: For Plaintiff

     Nonprofit associations consisting of day laborers and agencies working with them challenged a municipality's enforcement of restrictions on soliciting work on public sidewalks. They objected to actions of sheriff's deputies in "running" day laborers looking for work off the public sidewalks at several intersections. One plaintiff later reached a settlement with the municipality. The trial court then denied a motion by another plaintiff seeking an award of attorneys' fees. This plaintiff association, which failed to assert any facts to support its claim that it was forced to divert resources to aid another association because of the actions of the defendants was not entitled to such fees, as it failed to establish its standing as an injured party, and was dismissed as a party. A second plaintiff association, however, achieved prevailing party status through its settlement agreement, which was judicially enforceable, and was entitled to an award of attorneys' fees. La Asociacion de Trabajadores de Lake Forest v. Lake Forest, #08-56564, 2010 U.S. App. Lexis 21959 (9th Cir.).

Dogs

     A federal appeals court has held that a police dog's action in leaping into a car, which was left open by a motorist, was based on "pure instinct" that drugs would be found there and did not constitute a violation of the motorist's Fourth Amendment rights. The dog, once inside, alerted to the areas of the passenger seat and glove box. Evidence including cocaine and cash subsequently found in the glove compartment when officers then conducted a search did not need to be suppressed. While the ruling occurred in a criminal case, the same reasoning would apply in a federal civil rights lawsuit concerning similar facts.

     The appeals court, after reviewing a video of the incident involving the drug-sniffing dog, rejected the motorist's claim that the officer who was handling the dog had encouraged it to leap into the car. Prior caselaw has held that an interior sniff of a vehicle may be a 4th Amendment violation if the officer facilitates or encourages the dog's entry into a car. In this case, the dog's interior sniffs, "as a natural migration from his initial exterior sniffs, did not constitute a search requiring a warrant or probable cause." United States v. Pierce, #09-3865, 2010 U.S. App. Lexis 20212 (3rd Cir.).

False Arrest/Imprisonment: No Warrant

     When an officer responded to a burglar alarm at a house, he observed that a basement window appeared to have been pried open. The front door was open, and several items were on the porch. The officer observed a man inside the house going through some papers. He was the son of the woman who owned the house, was there alone, and admitted that he did not know how to turn off the alarm. He became "confrontational" when the officer asked him to exit the premises, he tried to head butt the officer, and he was placed under arrest for disorderly conduct, a charge he pled no contest to.

     His mother subsequently indicated that he had her permission to remove items from the house. The next day, he returned to the police station to file a complaint about his arrest. The sergeant taking his statement ran his driver's license and learned that it had been suspended, and wrote him a citation for driving with a suspended license, as he had driven to the station. He sued, asserting claims for false arrest, excessive force, and illegal search in running his driver's license.

     A federal appeals court found that the officer had probable cause to arrest the plaintiff at his mother's house and reason to believe that he was committing a crime being in the house, which was not his. There was no evidence that he suffered any injury from any force the arresting officer used, and he had attempted to head butt the officer. A claim of malicious prosecution was meritless in light of his plea of no contest to the disorderly conduct charge. Running of his license after he furnished it as identification did not constitute an unlawful search. Crock v. Pennsylvania, #10-2001, 2010 U.S. App. Lexis 21625 (Unpub. 3rd Cir.).

     A Florida officer believed that he saw cannabis in a man's mouth, and that the suspect was resisting him by chewing and swallowing what he believed was evidence of a crime. The officer therefore arrested him for violation of a state statute prohibiting obstruction or resistance of an officer performing his legal duty. Under the circumstances, the officer had arguable probable cause to make the arrest and was therefore entitled to qualified immunity on false arrest and malicious prosecution claims.

    The appeals court also held that the defendant officers were entitled to qualified immunity on an excessive force claim, as one officer's efforts to stop the arrestee from swallowing the supposed cannabis, and the other officer's use of a Taser against the arrestee did not violate the plaintiff's clearly established rights. The officers believed the suspect was attempting to destroy evidence, and that he was resisting orders and attempting to flee or resist arrest by jumping in his car. It would "not be clear to every reasonable officer that the force used was excessive under the circumstances." German v. Sosa, #10-10443, 2010 U.S. App. Lexis 21026 (Unpub. 11th Cir.).

     When it was undisputed that a pedestrian was neither on the sidewalk nor in a crosswalk when he entered a "parking turnout" on a street, officers had at least a reasonable belief that they had probable cause to arrest him for jaywalking, so that they were entitled to qualified immunity on his false arrest claim. An excessive force claim lacked merit when all that happened was that an officer had allegedly swung his baton at the arrestee without actually touching him. Burdett v. Reynoso, #08-15159, 2010 U.S. App. Lexis 21018 (Unpub. 9th Cir.).

     Officers had probable cause to arrest a man based on the "indicia of controlled substance use" that he exhibited, and were therefore entitled to qualified immunity on his false arrest and false imprisonment claims. The arrestee also asserted a claim that the defendants had failed to produce and disclose exculpatory evidence in his case. But this claim was barred under Heck v. Humphrey, #93-6188, 512 U.S. 477 (1994), as success on this claim would imply the invalidity of his conviction, which had not been overturned on appeal or otherwise set aside.

     The plaintiff also failed to provide support for his claims that the officers acted with racial animus in arresting him, that they tampered with their recordings of his arrest, or that they used excessive force against him. Because the arrest was supported by probable cause, the officers were entitled to qualified immunity even if the arrestee could make out a viable First Amendment retaliation claim, because "the right of an individual to be free of police action motivated by retaliatory animus" despite the existence of probable cause was not clearly established as of 2006, the date of the incident. Ra El v. Crain, #08-56122, 2010 U.S. App. Lexis 20536 (Unpub. 9th Cir.).

False Arrest/Imprisonment: Warrant

     Even after making changes in an arrest warrant affidavit to correct what the arrestee claimed was false and omitted information, there was still probable cause to support the plaintiff's arrest for arson of a furniture store, which resulted in $2.8 million in damages. The suggested changes did not support the conclusion that "a neutral magistrate would not have issued the warrant" had these changes been known.

     The omitted facts included descriptions of suspects in four previous dumpster fires behind the store, none of whom matched the arrestee, and the store owner's "demonstrably false" statement that she had seen him "gloating" at the crime scene sometime after the fire. The fact remained that gasoline containing bottles which had been placed on a table inside the window of the store contained numerous gasoline soaked pieces of mail addressed to the arrestee or his wife over a five year period of time, which the arrestee could not explain, and there were also facts about a dispute he had with the store owner. The fact that juries in two trials of the arson case were not able to reach a unanimous verdict against the arrestee did not alter the fact that there had been probable cause for his arrest. Smith v. Almada, #09-55334, 2010 U.S. App. Lexis 21496 (9th Cir.).

     Before officers executed an arrest warrant against a man for unpaid child support, they confirmed the warrant's validity. The warrant, however, had actually been quashed in a "minute entry" by the court, but no record of that order had yet reached the sheriff's office, so the warrant's validity was confirmed. The officers proceeded with the arrest, despite the arrestee's protests that the warrant had been quashed. He was not released until the next day. Upholding summary judgment for the officers, the court ruled that unless the warrant was invalid on its face, the defendants had no duty under the Constitution to independently attempt to determine its validity. Reasonable officers could disagree on whether they were required to investigate further when confronted by the arrestee's claim that he had a certified copy of the minute entry quashing the warrant. Ochser v. Funk, #1 CA-CV 09-0141, 2010 Ariz. App. Lexis 156.

Firearms Related: Intentional Use

     A woman posed a significant threat to officers and others who might be hit by the police car which she put in rear gear while handcuffed with her hands behind her back after being arrested on a drug charge and placed in the front passenger seat of the vehicle, which had the engine running. An officer was entitled to qualified immunity for shooting her. She admittedly was in a moving vehicle that she could not control, and even if the officer would have been able to side-step the car by the time he fired, as the plaintiff's experts argued, his action, as an attempt to stop the car, was still justified by the threat to others present. Olseth v. Larson, #10-4015, 2010 U.S. App. Lexis 20305 (Unpub. 10th Cr.).

     A woman's disturbed son, who had murdered his wife years ago, stopped taking his medication, obtained a gun, and threatened to kidnap certain family members. Officers seeking to have him committed went to his apartment, and his mother tried to get him to come out, but instead he started shooting. The plan of extraction developed by a police investigator had involved the mother knocking on the front door while officers remained in front of the house, but out of sight of the son. Both the mother and her son were shot and killed during the ensuing gun battle.

     The decedents' estates and family members sued, claiming that the officers were responsible for the deaths under a "state-created danger" theory of liability. The officers were entitled to qualified immunity because the state-created danger theory was not clearly established in the 5th Circuit at the time of the incident. Judgment was also entered for the city, as the plaintiffs did not successfully create an issue of fact as to whether the city's review of the officers' conduct violated department rules in a manner that rose to the level of "ratification" so that the city would be liable for the officers' conduct. Saenz v. City of McAllen, #09-41072, 2010 U.S. App. Lexis 20464 (Unpub. 5th Cir.).

First Amendment

     A political action committee was opposed to increased municipal taxes and spending, and involved in building opposition to the City Council's authority to implement an automated photo-monitoring program to enforce traffic regulations. The group and one of its members sued the City of Cincinnati, contending that a regulation governing access to the interior spaces of city hall violated their First Amendment rights to express their opinions and was void for vagueness. Upholding a trial court's preliminary injunction against the regulation, a federal appeals court agreed that the plaintiffs had shown that there was a substantial likelihood that they would prevail on the merits of their claims.

     The group had twice tried and failed to gain access to the interior stairs and the lobby of city hall to hold a press conference and rally advocating its views. The city barred most private business enterprises or solicitations in city buildings, while providing for exceptions with specific approval when judged to be "in the public interest," such as the United Way campaign. As a practice, the city only approved activities inside city buildings that had a sponsor such as a city department or council member.

     In this manner, the city had allowed, inside city hall, rallies by a group supporting increased taxes for local schools, and for a group urging a local newspaper to stop accepting ads for adult entertainment. The regulation gave city departments and officials complete discretion as to whether a proposed rally or display in city hall would be in the "public interest," and requires groups to collaborate with public officials in order to avail themselves of the opportunity to conduct expressive activities inside city hall, the court found. Miller v. City of Cincinnati, #08-4679, 2010 U.S. App. Lexis 19820 (6th Cir.).

     A federal appeals court has ruled that a city's attempt to totally ban tattoo parlors violated the First Amendment. The court concluded that “the tattoo itself, the process of tattooing, and even the business of tattooing are … purely expressive activity fully protected by the First Amendment.” The court also ruled that a total ban was not a reasonable time, place, or manner regulation "because it is substantially broader than necessary to achieve the city's significant health and safety interests and because it entirely forecloses a unique and important method of expression." Anderson v. City of Hermosa Beach, #08-56914, 2010 U.S. App. Lexis 18838 (9th Cir.). Editor's Note: a good number of prior court decisions have upheld such bans against First Amendment challenges. The court in Anderson cited six such prior cases, two from federal trial courts, and four from state appellate courts, while stating that "we respectfully disagree."

Malicious Prosecution

     An arrestee claimed that a grand jury indictment that resulted in her arrest was "tainted" by the actions of a justice of the peace/county judge and a police chief. The plaintiff claimed that the judge sexually assaulted her, and then, to try to discredit her, he conspired with the police chief to have her prosecuted for extortion. The problem with this claim, a federal appeals court found, was that there was no competent summary judgment evidence that the extortion claim was false, since the plaintiff had not filed a sworn statement to that effect with the trial court.

     While a district attorney did file an affidavit stating that his investigation had uncovered no evidence of extortion, his statement did not assert that the extortion claim was false. There was also no evidence from which it could be inferred that the police chief knew that the judge's accusations were false, and the judge did not testify before the grand jury that indicted the plaintiff. The plaintiff, therefore, failed to establish a violation of her constitutional rights, so summary judgment was properly entered for the defendants, including the city, the county, the judge, and the chief of police. Espinosa v. Zamora, #10-40190, 2010 U.S. App. Lexis 21573 (Unpub. 5th Cir.).

     A motorist was arrested by a city police officer for DUI, and a court, acting on the motorist's petition to rescind the statutory summary suspension of his driver's license, ruled that the officer had probable cause to make the arrest for alcohol-impaired driving. The motorist subsequently sued the officer and the employing city for malicious prosecution. The Illinois Supreme Court has overturned rulings by the trial and intermediate appeals court which rejected his malicious prosecution claim on the reasoning that he was collaterally estopped from relitigating the validity of probable cause because of the probable cause determination in the license suspension proceeding.

     If the lower court's reasoning were upheld, the Illinois Supreme Court commented, there would be a need to conduct "full-blown" hearings on probable cause at statutory summary suspension proceedings, which would conflict with the desirable goal of conducting "swift hearings" focused on the sole purpose of whether there were grounds to rescind the summary suspension of a motorist's driving privileges. Hurlbert v. Charles, #109041, 2010 Ill. Lexis 1064.

Parking Tickets and Traffic Offenses

     Motorists in Cleveland, Ohio sued the city, challenging the decision to enforce a traffic camera ordinance, which involves taking pictures of motorists who run red lights at certain locations, against drivers who lease, and do not own, their cars. They argued that such enforcement of traffic citations against them amounted to an unconstitutional taking of property without just compensation, in light of the fact that the ordinance did not originally provide for liability on the part of lessees. The ordinance was subsequently amended to provide for lessee liability. The lawsuit involved citations the city enforced against lessees prior to the amendment of the ordinance.

     A federal appeals court ruled that the plaintiffs had failed to assert a constitutional claim under the Takings Clause of the U.S. or Ohio Constitution, since the ordinance in question did not aim at the seizure of or "otherwise impair" an "identifiable" fund of money. The court did, however, order further proceedings on the plaintiffs' claim that such enforcement of the traffic camera ordinance unjustly enriched the city in violation of state law, which the trial court had not analyzed. McCarthy v. City of Cleveland, #09-4149, 2010 U.S. App. Lexis 23203 (6th Cir.).

Public Protection: Accident/Crime Victims

     An officer who served as a crash investigator was dispatched to the scene of an accident that took place between a female motorist and a male motorcycle rider. The officer, who observed the motorcycle rider lying face down after having been thrown and landing head first on the street, believed that he was dead. Other officers were already on the scene. He later claimed that the female motorist, while "a little shaken up," had told him that she was not injured. He handed back her driver's license, registration, and insurance card, and suggested that she could leave her disabled car at the parking lot of a nearby gas station, which she did. The officer returned to his vehicle to complete paperwork, and did not inquire as to how the motorist was getting home or offer to assist her in doing so.

     The elderly female motorist declined an offer from the gas station attendant to drive her home if she would wait there until closing time, and she stated that she could walk home. As she attempted to do so, she was struck by a hit and run driver as she crossed a street, suffering serious injuries, and was hospitalized for various surgeries and treatments until she died. A lawsuit against the township and officer contended that they were responsible for her injuries at the hands of the hit and run driver by "abandoning" her at the scene of the first accident. The trial court and intermediate appeals court entered summary judgment for the defendants, finding them immune from liability for the officer's performance of discretionary acts at the scene of the first accident.

      The courts rejected an argument that the officer negligently performed ministerial duties in connection with the accident, for which state law does not provide immunity, since the female motorist had not asked him to provide aid. This was also not a case in which the motorist was plainly incapacitated, so that even if the officer was not exercising discretion, there was no evidence that he "negligently performed a ministerial task." Pappas v. Union Township, #A-5850-08T2, 2010 N.J. Super. Unpub. Lexis 2054 (A.D.).

Release Agreements

     A man claimed that a number of police officers assaulted him in his home, and that a second group of officers, also present, failed to intervene to stop the unjustified use of force, which he contended constituted gross negligence. Claims against the second group of officers were settled for a total of $25,000, and a signed release agreement was entered into which stated that it covered the discharge of "all other persons" from the plaintiff's claims.

     The first group of officers, who were alleged to have assaulted the plaintiff, argued that the release covered claims against them as well as against the second group of officers, despite the fact that they had not signed it, paid nothing under it, and were represented by separate counsel and insurance companies. An intermediate Michigan appeals court upheld these officers' interpretation.

     The Michigan Supreme Court has now reversed, and in so doing overturned a prior state court decision barring the use of testimony and other extrinsic evidence outside of the language of a release when an unnamed party asserts third-party beneficiary rights based on broad language in a liability release, and when there is an ambiguity as to the intended scope of the coverage of the release. The plaintiff's intent, it was argued, had been to only settle with the second group of officers. Further proceedings were ordered on this issue. Shay v. Aldrich, #138908, 2010 Mich. Lexis 1700.

Search and Seizure: Search Warrant

     A homeowner claimed that police unlawfully searched his home and seized marijuana plants found there without probable cause, doing so by misleading a magistrate into issuing a search warrant for the premises. This was allegedly accomplished by misstating the plaintiff's criminal history.

     Rejecting this argument, and upholding summary judgment for the state trooper who obtained the search warrant, a federal appeals court held that even if the plaintiff's criminal history was misrepresented in the affidavit for the search warrant, the other information in the affidavit sufficed to supply probable cause since there was information from the DEA that the plaintiff had received marijuana cultivation products shipments, and the trooper himself stated that he found marijuana cigarette remnants in the plaintiff's trash in close proximity to items of his mail. Parkey v. Sample, #09-3966, 2010 U.S. App. Lexis 22113 (6th Cir.).

Search and Seizure: Vehicle

     A federal appeals court has ruled that police must obtain a warrant before using Global Positioning System (GPS) devices to monitor vehicles and their locations. The court reasoned that the use of such devices constitutes a seizure under the Fourth Amendment because "prolonged GPS monitoring reveals an intimate picture of the subject's life that he expects no one to have."

     Evidence obtained by the GPS device was the result of tracking the location and speed of a suspect's vehicle around the clock for 28 days, and the transmission of data to law enforcement agents who placed the device on the vehicle. While the decision came in a criminal appeal, the reasoning would also apply in a federal civil rights case contending that the placement of such a device on a car without a warrant violates the Fourth Amendment. U.S. v. Maynard, #08-3030, 615 F.3d 544 (D.C. Cir. 2010).

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      Body Armor: "Bulletproof Vest Partnership Initiative" presents information on the Bulletproof Vest Partnership Program. This program is designed to provide critical resources to state, local, and tribal jurisdictions for the sole purpose of purchasing bullet-resistant body armor for sworn law enforcement officers. (BJA)

     Drugs: The Office of National Drug Control Policy has added two new fact sheets to its Web site: "Marijuana: Know the Facts" and "Marijuana Legalization: A Bad Idea."

     Gun Violence: Ten national law enforcement organizations have started a partnership focusing on effective strategies to address gun violence, calling the problem a "crisis" and "unacceptable." The National Law Enforcement Partnership to Prevent Gun Violence was launched at the 2010 International Association of Chiefs of Police convention. The groups said that 100,000 Americans or killed or injured with firearms every year. In 2008, 34 officers were killed in the line of duty with firearms. So far this year, there have been 43 such deaths. Other groups involved in addition to the IACP itself include the National Association of Women Law Enforcement Executives, Police Executive Research Forum, Police Foundation, Major Cities Chiefs Association, National Organization of Black Law Enforcement Executives, International Association of Campus Law Enforcement Administrators, Commission on Accreditation for Law Enforcement Agencies, National Sheriffs' Association, and Hispanic American Police Command Officers Association.

     Identity Theft: "Expanding Services To Reach Victims of Identity Theft and Financial Fraud" (NCJ 230590) offers practical tools to prepare victim service providers to help victims of identity theft and financial fraud. This publication includes information about developing case protocols, training staff, and staging campaigns; it also provides self-help materials to enable victims to become better self-advocates.

    Social Media: The International Association of Chiefs of Police, in partnership with the U.S. Justice Department's Bureau of Justice Assistance, has launched the IACP Center for Social Media, a project to build the capacity of law enforcement to use social media to help prevent and solve crimes, strengthen police-community relations, recruit employees, and enhance services. The new website www.IACPsocialmedia.org includes free resources such as a model policy, fact sheets, case studies and instructional tutorials.

     Statistics: "Background Checks for Firearm Transfers, 2009 - Statistical Tables" (NCJ 231679) provides the number of firearm transaction applications checked by state points of contact and local agencies, the number of applications denied and the reasons for denial, and estimates of applications and denials conducted by each type of approval system. (BJS).

     Tasers: Canada has adopted new national guidelines for Taser use by law enforcement.

    • Abbreviations of Law Reports, laws and agencies used in our publications.

     • AELE's list of recently-noted civil liability law resources.