use of force case study

15 use-of-force cases every cop needs to know

“risk comes from not knowing what you’re doing” — warren buffet.

Understanding use of force case law will help you train your officers to act within the confines of the law. Knowing these cases will help train you on how to investigate use of force. Understanding what SCOTUS and lower courts have said will also help you educate the public on exactly what cops are able to do and how that looks.

Here are 15 use-of-force cases that every department and elected official must know, understand, use, and preach. The following are just the names and a quick one-line explanation. Do your homework with a thorough examination of each.

1. Graham v. Connor — This is the essential use of force rubric in the country. 2. Tennessee v. Garner — Addresses deadly force to prevent escape. 3. Terry v. Ohio — Established the legality of so-called “Stop & Frisk” searches. 4. Plakas v. Drinski — No constitutional duty to use lesser force when deadly force is authorized. 5. Pena v. Leombruni — Addresses suspect’s known mental state regarding force. 6. Thompson v. Hubbard — Case where suspect appeared to be drawing a gun and no gun found. 7. Smith v. Freland — Examined policy violation but no violation of Constitutional law. 8. Bush v. City of Tallahassee — Addresses excessive force applied through Graham. 9. Green v. N.J. State Police — Addresses excessive force applied through Graham. 10. Forrett v. Richardson — Unarmed fleeing felon applied through Tennessee v. Garner. 11. Elliot v. Leavitt — Addresses 20/20 hindsight on officer shooting. 12. Brown v. United States — The original (1921) Graham v. Connor style decision. 13. Wardlaw v. Pickett — Punching an approaching verbally argumentative person. 14. City of Canton v. Harris — Addresses liability and “failure to train.” 15. Popow v. Margate — Addresses shooting an innocent person (training).

Don’t Just Train Your Officers — Train Everyone Educating the public on police operations — especially use of force — is going to be the next big thing for quite some time. Furthermore, by understanding this case law we are giving officers an understanding of the legal ground on which they stand so they do not have to be afraid to use it. In today’s climate we’re seeing too many officers not reacting like they should and getting seriously hurt or killed. This trend has recently been coined as “deadly hesitation.”

It’s chalked up to a lack of understanding of the law and a lack of courage on behalf of communities to back their officers. All of this could be fixed by well-informed chiefs, mayors, council members, reporters, and officers.

Do not assume that judges and district attorneys know and understand use of force case law like you do. This is not their fault. It is something they rarely touch. They can prosecute a drunk driver or domestic violence arrest in their sleep but a police shooting rarely (if ever) comes across their desk. Are you a master of every facet of your job?

Don’t let your district attorney base their charging decisions off of a lack of understanding of the law and how it works. You may find it useful to comb through the aforementioned cases with your local DA to help foster an environment of understanding all the way around. I would suggest doing it before an event rather than after.

There are several other important cases out there — the 15 listed above are just a few of the big ones. This is in no way a comprehensive list. If you know of current cases regarding use of force please leave them in the comment section below for all of us to review.

Lieutenant Paul Marik began his career working undercover straight out of the academy. He is currently a Lieutenant Commander with the Pleasant Prairie (WI) Police. Paul has been with the PPPD since 1997 and is the senior trainer for the department. He holds a B.S. and an M.B.A. He is an instructor for Firearms, Defense & Arrest Tactics, Use of Force, Honor Guard and he is a master instructor in Tactical Response and Scenarios. Paul is also a Certified Force Science Analyst. He has investigated several use-of-force situations in southeastern Wisconsin and is an active member of ILEETA.

Do Use of Force Policies Matter in Excessive Force Cases in Federal Court?

• September 8, 2022
• Elias Rodriguez
• Stanford Center for Racial Justice
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The Stanford Center for Racial Justice has begun publishing chapters of our Model Use of Force Policy in beta release. The Model Policy is intended to contribute to the long line of efforts to improve and reform policing and promote practices that will be fair, safe, and equitable for everyone. Below is the first of several essays by our staff examining the role of use of force policies and how they intersect with legal proceedings in a variety of situations. Read Chapter 3 of the Model Policy—Speaking Techniques, Physical Controls, and Personal Body Weapons— here .

On August 24, 2019, a young Black man named Elijah McClain was the victim of a brutal assault by multiple police officers in Aurora, Colorado. He was on his way home from a convenience store, listening to music on his headphones. Following a 911 call by a passing driver who reported McClain as “sketchy,” officers seized McClain based on little more than determining that his actions were “suspicious” and proceeded to inflict pain techniques for 18 minutes— including 15 minutes while McClain was handcuffed. During the assault, officers used two carotid holds— a neck restraint that blocks the carotid arteries’ blood flow to the brain—to McClain’s neck, an armbar hammerlock to his shoulder, and a forceful pain technique which separated McClain’s bicep and tricep muscles. McClain was also later injected with ketamine despite not displaying “any medical conditions that could be treated with ketamine.” On his way to the hospital, McClain went unconscious and died days after the incident.

In August 2020, the family of McClain filed a lawsuit in federal court against the officers and the City of Aurora. The lawsuit claimed the officers violated the Fourth Amendment by depriving McClain of his right to be free from unreasonable seizures—in other words, using excessive force. However, the claim never made it to trial. Before the court could complete the case, the family settled with the city for $15 million.

We discuss below whether the Aurora Police Department’s policies and the officers’ training would have made a difference in holding the officers accountable for McClain’s death had the case gone to trial. We also discuss how SCRJ’s Model Policy would apply to the facts surrounding McClain’s encounter with the Aurora police.

How do federal courts evaluate claims of excessive force?

When reviewing an injured person’s claim of excessive force, federal courts typically seek to answer two main questions: (1) whether the officer acted reasonably ; and (2) whether the officer would have known the officer was acting unreasonably . This approach is known as the qualified immunity standard, and it immunizes officers from monetary liability for using force against individuals. In summary, qualified immunity doctrine protects officers from court proceedings unless the officer violated a clearly established right that every reasonable officer would have known.

Did the officers act reasonably?

Courts analyze the first question by examining the “facts and circumstances” the officer faced “from the perspective of a reasonable officer on the scene, rather than with the 20/20 vision of hindsight.” This is known as the “reasonable officer” standard. The Supreme Court has instructed courts to consider certain factors—such as the severity of the crime, the danger to the officers and public, and the risk of flight or resistance—to evaluate the reasonable officer’s conduct. However, there is a lack of clarity from the Supreme Court and other courts about the details of how courts should conduct the evaluation of the reasonable officer. This lack of clarity contributes to “ haphazard, inconsistent decisions ” where lower courts insert their own ideas of reasonableness instead of looking to definitive evidence of reasonableness—such as the height and weight of an officer, the officer’s level of training and years of experience, or the officer’s compliance with the department’s use of force policies.

A court could allow evidence of the local police agency’s use of force policies and training to help inform whether the officer complied with that policy and/or training—and therefore whether the officer’s actions were reasonable. After all, most organizations expect reasonable employees to follow their employee guidelines. In McClain’s case, the court potentially could have examined the Aurora Police Department’s use of force policy. That policy might have informed officers on how to treat situations like the events that resulted in McClain’s death.

However, some courts do not allow the local agency’s use of force policy into evidence. Additionally, under the Supreme Court “reasonable officer” standard as articulated in Graham v. Connor , some federal courts have ruled that “​​a violation of departmental policy does not equate with constitutional unreasonableness.” And the 10th Circuit Court of Appeal that oversees Colorado federal courts views use of force policies as largely irrelevant to the reasonableness calculation. Consequently, use of force policies may or may not be allowed in federal court to help inform the reasonableness question and—even when allowed into evidence—will likely not determine the ultimate outcome of the question of whether the officer acted reasonably.

Would the officers have known their actions were unreasonable?

The second question requires courts to evaluate whether the officers would have known their actions were unreasonable. Essentially, courts attempt to answer whether the law was sufficiently clear that the alleged conduct was constitutionally unreasonable. If not, the court grants the officer qualified immunity and the case is over, without any trial or accountability for the officer’s actions.

Here too, one would expect a court to look at the local law enforcement agency’s departmental policy and whether the officer knew that—according to the policy—they were acting unreasonably. But courts largely do not utilize use of force policies to establish that officers would have known their actions were unreasonable. Instead, courts usually look at previous court decisions to see whether there was clearly established law concerning the conduct. The Supreme Court has also explained that “[e]ven if an officer acts contrary to [their] training . . . that does not itself negate qualified immunity.” This approach to qualified immunity—reviewing judicial decisions instead of the facts of the case—has been extensively criticized .

Under this part of the qualified immunity analysis, the court examining the McClain family’s claim might have looked at previous excessive force cases in Colorado or other federal courts, instead of reviewing Aurora’s policies, to determine whether the Aurora officers would have known their actions were unreasonable.

The above discussion reveals that use of force policies and violations of those policies are often not examined by federal courts in excessive force lawsuits, and even when the court uses this evidence, the policies will usually not determine the outcome of an officer’s federal civil liability.

Why are use of force policies important?

Use of force policies are important even though they likely will not change the outcome of a federal civil rights claim alleging excessive force. The policies reflect the expectations of police department leadership and the standards to be followed by its well-trained officers. Use of force policies also can help reflect community values for what is reasonable and how a community might expect their police department to use force. For instance, one scholar has recently urged that cities and municipalities should find ways to ensure the public is deeply involved in developing department use of force policies. In turn, use of force policies can improve the perceived legitimacy of the department and create a sense of procedural fairness among those most impacted by policing.

Further, research conducted over the past several decades consistently suggests that more restrictive use of force policies are correlated with reduced police killings—and are not correlated with increases in crime, harm to officers, or other types of negative effects. For example, after Seattle adopted its “necessary” standard , the city reported a significant reduction in the number of force incidents without a decrease in officer or civilian safety. Accordingly, departments can update use of force policies to reflect community values while maintaining the safety of their officers.

Did the Aurora officers violate provisions under the Model Policy?

Our Model Policy aims to provide a tool for local law enforcement agencies to work alongside their community to develop a use of force policy that comprehensively addresses fair, safe, and equitable practices to reduce fatal and non-fatal uses of force.

The officers confronting McClain used a variety of speaking and physical force techniques. Under Chapter 3 of the Model Policy, physical force is an option of “last resort” which officers can use only after exhausting all non-force options and meeting the authorization standards under the Policy. Officers must “de-escalate their use of force as soon as a resisting subject’s behavior no longer justifies the level of force being used.” To de-escalate a situation, officers must first attempt speaking techniques, initially using verbal persuasion, then using verbal commands if verbal persuasion is ineffective. Additionally, before using more severe levels of force, officers must “consider the totality of the circumstances and whether there are factors that might affect a subject’s ability to comply with a verbal command . . . [including] hearing disabilities, language barriers, and/or mental illnesses.”

In the case of McClain, the officers failed to de-escalate the situation. Instead, the officers began their interaction with McClain by resorting to a verbal command—“Hey, stop right there.” Although verbal commands are speaking techniques suggested by the Policy, the officer escalated to using a verbal command rather than using verbal persuasion—a tool of first resort—to gain control of McClain.

After being commanded to stop, McClain told the officers, “I have the right to walk to where I am going.” Immediately after this statement, one officer closed in on McClain and grabbed McClain’s left arm and stated, “I have a right to stop you because you’re being suspicious.” This grabbing of McClain’s arm is defined as a “physical control” under the Model Policy.

The Model Policy allows officers to use physical controls with an individual—such as wrist locks, twist locks, or arm bars. However, before officers use physical controls, officers must use speaking techniques to gain control of an individual, and the force must be authorized under the policy. If speaking techniques fail, an officer may use physical controls if the individual’s “physical actions become actively resistant to a point that prevents an officer from making an arrest,” or if the officer believes they are “necessary to prevent imminent bodily harm to the officer, the [individual], or another person and that belief is consistent with available information.”

The officer’s arm grabbing violated the Model Policy because the officers would first be required to use speaking techniques and McClain’s “physical actions” were not “actively resistant” to a point that would prevent arrest.

Notably, after the arm grab, McClain pleaded to the officers that he was “an introvert,” to “please respect his boundaries,” and that he was “wearing his headphones . . . trying to stop his music to hear [the officers’] command.” This suggests that the totality of the circumstances, including the “factor that might affect [McClain’s] ability to comply with a verbal command” would not support the arm grab, much less any escalation in force.

Yet, the officers continued to escalate the amount of force applied, including the use of tactics that are considered personal body weapons. The Model Policy defines personal body weapons as the “use of the officer’s body parts . . . by means of kinetic energy transfers (impacts) to gain control of a subject.” Officers may not use personal body weapons—such as palm heel strikes, common fist strikes, elbow strikes, and front and rear takedowns—unless the officer, after first using speaking techniques and physical controls, is unable to take control of the individual and “the [individual’s] physical actions become actively resistant to the point that they pose a substantial risk of causing imminent bodily harm.”

After the initial arm grab by one officer, a second officer grabbed McClain’s other arm. “Stop tensing up,” the officers ordered McClain. McClain continued to plead with the officers to “Please leave [me] alone.” At this point in the interaction, one armed officer used a speaking technique and two officers used a physical control to take McClain under their control. The record does not show any facts to support the notion that McClain’s “physical actions [became] actively resistant to the point that [McClain] pose[d] a substantial risk of causing imminent bodily harm.”

The available information to the officers came from a nearby motorist’s call to 911 dispatch; the caller stated McClain was acting “sketchy,” had a ski mask on, was making “signs with his hands,” and did not appear to be armed. Additionally, the officers’ own perception indicated that McClain was holding a single shopping bag and did not appear armed. Despite there being no available information indicating it was necessary to prevent imminent bodily harm, the officers escalated this situation even further by first frog marching McClain to a wall, then applying a carotid hold to block blood supply to McClain’s brain, and finally tackling McClain to the ground. These actions would be violations under the Model Policy.

The officers had no information that McClain was at risk of performing actions that caused any imminent bodily harm. McClain’s mere “hesitancy . . . in following [the officers] commands” did not justify the use of physical controls or personal body weapons. Instead, the officers should have “de-escalate[d] their use of force” because McClain’s actions and the officers’ knowledge of the situation “no longer justifie[d] the level of force being used.”

There was some information reported that an officer claimed McClain reached for an officer’s gun while officers had a hold of McClain’s arms—and after officers had frog marched McClain to a grassy area. This statement has been heavily disputed by McClain’s family because of the inconsistency with which officers recounted the details, as well as a statement by an officer that he “did not feel any contact with his service weapon.”

After being taken to the ground, the officers continued to inflict physical compliance techniques and eventually paramedics injected ketamine into McClain’s body. McClain later died.

Do use of force policies matter?

Would the Model Policy have had an effect on the officers’ behavior had the Aurora Police Department implemented it prior to this case? Written rules alone are insufficient to assure proper conduct—and factors such as training, experience, and police culture can influence individual officer behavior. Further, the limited influence that use of force policies have on an officer’s federal civil liability also raises questions about the role of providing clear standards on the use of force.

We believe clear standards are essential. The standards provide a baseline reflecting the expectations of the department and the community. They also are a basis for training and a source of ongoing reference for officers who want to refresh their understanding of what is expected of them. Policies also ultimately help shape what a reasonable officer can and should do in a variety of circumstances.

Whether using our Model Policy or similar guidelines, police agencies and communities should work together to form a common understanding of their visions for public safety. These visions should be shaped by information police agencies learn from the most successful police departments across the nation and informed by dialogue with members of communities who are most impacted by policing. While much more is needed to improve public safety, a police department’s use of force policy which considers fair, safe, and equitable values, leading practices, and community voices is essential to achieving fair, safe, and equitable outcomes.

Disclaimer: The facts cited above were assumed to be true based upon allegations in the federal civil complaint in the McClain case, as well as public news sources, and have not been evaluated for accuracy. The above analysis reflects the opinions of our staff and is intended for educational purposes and policy discussions.

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Split-Second Decisions: How a Supreme Court Case Shaped Modern Policing

Officers using deadly force rely on a legal doctrine set forth decades ago. Now, the movement launched by the death of George Floyd is trying to change that standard.

By David D. Kirkpatrick

In case after case, it took only a split second for an officer to pull the trigger.

Adam Toledo, a 13-year-old in Chicago, had tossed away a handgun and begun raising his hands. Ma’Khia Bryant, a 16-year-old in Columbus, Ohio, lunged with a knife at another teenager. Tyrell Wilson, a 33-year-old mentally ill homeless man in Danville, Calif., had a knife in hand when he shouted “Kill me” at an approaching deputy sheriff.

All three were among more than 100 people shot and killed by the police over the previous six weeks.

The officers’ justification for the use of lethal force in each instance differs with the circumstances. But as in almost every other recent case involving questions of police use of force, law enforcement officials defending the officers are relying on a doctrine set forth by the Supreme Court three decades ago and now deeply ingrained in police culture: that judges and juries should not second-guess officers’ split-second decisions, no matter how unnecessary a killing may appear in hindsight.

Now, the national movement launched by the death of George Floyd, emboldened by an officer’s conviction last week for his murder, is pushing to change that standard.

While most agree that officers must sometimes use deadly force to protect themselves or others, many criminologists say the wide latitude under the rule is an obstacle to reducing the number of police killings, and lawmakers in Congress and many states have begun seeking tighter restrictions.

The number of people killed by the police in the United States — consistently about 1,000 a year — is far higher than in other developed countries. A disproportionate number of the shootings are by white police officers against people of color , as in the cases of Adam Toledo, Ma’Khia Bryant and Tyrell Wilson. And many experts say the split-second standard is partly to blame for that death toll.

“I am convinced that is the No. 1 cause,” said Lawrence W. Sherman, an American criminologist with experience in the police departments of New York and Minneapolis who is now an emeritus professor at the University of Cambridge.

“It puts the United States into an extreme exceptionalism in allowing killings that would be prosecuted as murder elsewhere, like the U.K.,” he added.

Lawyers for police unions argue that the rate of police killings in the United States reflects a higher level of civilian violence because of greater gun ownership and a flimsier social safety net than in other wealthy countries. They say the split-second decision standard is essential to keeping officers and the public safe.

“If the officer doesn’t act, there’s a strong probability that an individual will be killed,” said Larry James, general counsel for the Fraternal Order of Police, pointing to the recent shooting of the 16-year-old in Columbus.

“The officer is duty-bound to take that action to protect the life of another citizen or him or herself — that is the standard that police should be judged by, not Monday morning quarterbacking,” he added.

Until the mid-1980s, policies on the use of force varied widely across the states. Some allowed deadly action against any fleeing suspect of a felony, even if the suspect posed no imminent threat.

That changed in 1985. The Supreme Court ruled in Tennessee v. Garner that police could shoot only if they had probable cause to believe that a fleeing suspect posed a significant threat of injury or death to an officer or others. The number of police killings steadily declined over the next four years, studies show.

But in 1989, a more conservative court took a different approach in the ruling of Graham v. Connor, establishing the precedent that dominates today.

The case was brought by Dethorne Graham, a Black man the police had stopped in Charlotte, N.C., on suspicion of shoplifting because he had hurried in and out of a convenience store.

Mr. Graham, a diabetic desperate for orange juice to avoid a seizure from low blood sugar, told the police that he had rushed out of the store because of a long checkout line. But as he staggered and briefly passed out, officers assumed he was drunk and forced him into tight handcuffs, leaving him with a broken foot, cuts on his wrists, bruises on his forehead and an injury to his shoulder.

The Supreme Court sent the case back to a lower court, finding that the police needed only to meet the standard of what a reasonable officer might do. The criteria for “reasonable,” the high court said, should include special accommodations for the pressures of police work.

“The calculus of reasonableness must embody allowance for the fact that police officers are often forced to make split-second judgments — in circumstances that are tense, uncertain and rapidly evolving — about the amount of force that is necessary in a particular situation,” Chief Justice William H. Rehnquist wrote in the majority opinion.

“‘Not every push or shove’” was improper “even if it may later seem unnecessary in the peace of a judge’s chambers,” the chief justice wrote, quoting an earlier ruling. The lower court ultimately ruled in favor of the police.

The Supreme Court opinion did not explicitly address lethal force and defined only the rights of a suspect, not the restrictions a state could impose on law enforcement.

But state legislatures and judges, often sympathetic to the police, largely adopted the question of what would be reasonable to an officer making a split-second judgment as the test for assessing any police use of force, whether deadly or not.

Graham v. Connor became “the lodestar” and “created this impression that almost nothing is out of bounds,” said Barry Friedman, a law professor at New York University and the director of its Policing Project, which has drafted a model statute to regulate the police use of force.

The same standard also became embedded in the training and practices of American police — “part of law enforcement DNA, often unnoticed as it works in the background to determine our actions,” a magazine for police officers declared in a 2014 article about the ruling.

“A generation of officers has been trained in the case’s practical meaning and has spent decades applying it to every use-of-force decision,” the article said.

It was published in response to a wave of protests over allegations of excessive force in the fatal shooting of Michael Brown, a Black man in Ferguson, Mo. In part because he claimed he had made a split-second decision about his self-defense, the officer who killed Mr. Brown never faced charges.

Many critics say the standard’s narrow focus on the moment an officer pulls the trigger obscures questions about the many choices that led up to the confrontation, noted Rachel Harmon, an authority on police law at the University of Virginia. For example, she said, did the officer rush recklessly into danger or take steps to defuse the situation?

The same standard may also make it more difficult to combat racial bias in the use of lethal force, even though Black suspects are more than twice as likely as people of other races to be killed by the police, said Jeffrey Fagan , a law professor at Columbia.

“All an officer has to say is, ‘I feared for my life’ — those are the magic words,” he said. But the statistics strongly suggest that the “police are more likely to form that sense of imminent danger when confronting a Black person than a white person.”

Mr. Chauvin was convicted in part because he could not claim that Mr. Floyd’s suffocation was a split-second decision. But critics of the split-second standard cite a litany of police shootings of innocent Black people. In 2014, Cleveland police officers screeched their cruiser to a halt just a few feet from Tamir Rice , a Black 12-year-old playing in a park with a toy replica gun, and within two seconds had shot him because they deemed him a threat. He died the next day.

The next year, a police officer in a suburb of Minnesota pulled over Philando Castile, a 32-year-old Black man driving with his girlfriend and daughter. The officer shot him five times at close range, killing him in the seat of his parked car, out of a mistaken fear that he might have been reaching for a gun.

In 2018, the police raced to a street corner in the Crown Heights section of Brooklyn to investigate reports of a possible gunman, and moments later shot and killed Saheed Vassell , a 34-year-old mentally ill Black man who was well known around the neighborhood. He had been pointing a piece of pipe they mistook for a weapon.

The officer who shot Mr. Castile was acquitted of manslaughter . The officers in the other cases were not charged. The cities where Tamir Rice and Mr. Castile were killed paid millions of dollars to settle civil claims.

The split-second standard “has become a way to insulate officers from any critical review,” said Seth Stoughton, a professor at the University of South Carolina School of Law. A former policeman in Tallahassee, Fla., he testified as an expert witness in the trial of Derek Chauvin, the officer who killed Mr. Floyd.

Now, after the uproar over the Floyd killing, many state and federal lawmakers are trying to impose new restrictions on the use of force. A Maryland law passed this month over the objections of the governor requires that any such actions must be “necessary and proportional” to prevent “an imminent threat of physical injury” or to achieve “a legitimate law enforcement objective.” It specifies a prison sentence of up to 10 years for any officer who causes injury or death by violating those rules.

California, Illinois and other state legislatures have debated similar measures, and the House of Representatives last year passed its own bill raising standards for the use of force and requiring attempts at de-escalation.

Some police advocates argue that the new rules could violate officers’ right to defend themselves.

“With the benefit and luxury of hindsight and time and tranquillity, you could get any kind of use-of-force or police-practices expert or even an attorney to say that there was something else that an officer could have done,” said David Mastagni, a California lawyer for police unions who has helped lobby in Sacramento against such restrictions. “Then the officer is stripped retroactively of the right to self-defense.”

But Mr. James, general counsel of the Fraternal Order of Police, brushed off all the efforts at legislation and said he was not worried. Even if states or Congress pass stricter standards “that trump Graham v. Connor,” he said much would depend on whether judges continue to instruct juries, as they often have since the ruling, about the inherent risks of second-guessing an officer’s split-second decision.

An earlier version of this article misstated the year that Tamir Rice was shot and killed by the Cleveland police. It was 2014, not 2015.

How we handle corrections

David D. Kirkpatrick is a national correspondent based in New York and the author of “Into the Hands of the Soldiers: Freedom and Chaos in Egypt and the Middle East.“ In 2020 he shared a Pulitzer Prize for reporting on covert Russian interference in other governments and as the Cairo bureau chief from 2011 to 2015 he led coverage of the Arab Spring uprisings. More about David D. Kirkpatrick

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Criminal Justice Collaborative

Study: body-worn camera research shows drop in police use of force.

Cheryl Corley

Police officer David Moore is pictured wearing a body camera in Ipswich, Mass., on Dec. 1, 2020. The city was among 25 statewide awarded grants to purchase body-worn cameras for videotaping interactions with the public. A new study says the benefits to society and police departments outweigh the costs of the cameras. Boston Globe/Boston Globe via Getty Images hide caption

Police officer David Moore is pictured wearing a body camera in Ipswich, Mass., on Dec. 1, 2020. The city was among 25 statewide awarded grants to purchase body-worn cameras for videotaping interactions with the public. A new study says the benefits to society and police departments outweigh the costs of the cameras.

One of the most powerful examples of the significance of police body-worn cameras played out in a Minneapolis court room during the trial of Derek Chauvin, the former police officer convicted of murder and manslaughter in the killing of George Floyd. The video collected from the body worn cameras of the police officers involved in Floyd's arrest showed his death from a variety of angles and prosecution and defense attorneys used the video extensively as they argued the case.

Across the country, police departments are increasingly using body-worn cameras to better monitor what officers are doing out in the field with the hope that they will reduce the prevalence of misconduct and improve fairness in policing. Still, there's been a lot of uncertainty over whether the technology is actually helpful. In addition, local governments and police departments that have not integrated the technology as part of their policing practice often cite cost as a barrier.

America Reckons With Racial Injustice

Police bodycam video shows george floyd's distress during fatal arrest.

Now, in one of the latest studies about the equipment, a team of public safety experts and world economists say body-worn cameras are both beneficial and cost effective. They outline their reasoning in a research paper released recently by the University of Chicago Crime Lab and the Council on Criminal Justice's Task Force on Policing. The report is an update of a variety of studies of body-worn cameras and it also compares the cost of the technology to the dollar value of the benefits that may come as a result.

Professor Jens Ludwig, head of the Crime Lab, says the findings show the key benefit of body-worn cameras is the reduced use of police force. For example, among the police departments studied, complaints against police dropped by 17% and the use of force by police, during fatal and non-fatal encounters, fell by nearly 10%.

"That's hopeful but not a panacea," Ludwig says. "Body-worn cameras are a useful part of the response but not a solution by themselves. Body-worn cameras are not going to solve the problem of the enormous gap we see in police use of force in the U.S. against Black versus white Americans. "

Even so, New York University Professor Morgan Williams Jr. says "integrating the technology into policing practices can be an important step towards making policing fairer and more accountable."

Live Updates: Protests For Racial Justice

Police bodycam transcripts: george floyd pleaded 20 times that he couldn't breathe.

In 2013, about a third of local law enforcement agencies, used some form of body-worn camera technology. By 2016, the number had grown to nearly 50%. While law enforcement often cites finances as a barrier to adopting body-worn cameras, the researchers say the benefits to society and police departments outweigh the costs of the cameras.

The pricetag for police bodycams can be several thousands of dollars per officer since costs include purchasing and maintaining the equipment, paying for storing the enormous amount of information the cameras can collect, and training officers. On the other hand, the study asserts that the dollar value of body-worn camera benefits — the estimated savings generated by a reduction of citizen complaints and averted use of force incidents — along with the cost reductions that could come from fewer investigations, is significant. The study estimates the ratio of the value of the benefits compared to the cost of body-worn cameras at 5 to 1 and well above an estimated 2 to 1 cost-benefit of hiring more police.

"If you are a local government looking at adopting the cost, from your narrow green eyeshade bottom line, the technology probably pays for itself," Ludwig says. "And the benefits to the public are a huge win and easily outweigh the cost."

The study notes, however, that the research developed so far about body-worn cameras is limited since results are based on data from police departments that were the first to adopt the new technology. It could also be, says Ludwig, that body-worn cameras and the impact they have on policing will be different as people figure out better ways to use the technology.

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Graham v. Connor, 490 U.S. 386 (1989)

A claim of excessive force by law enforcement during an arrest, stop, or other seizure of an individual is subject to the objective reasonableness standard of the Fourth Amendment, rather than a substantive due process standard under the Fourteenth Amendment. In other words, the facts and circumstances related to the use of force should drive the analysis, rather than any improper intent or motivation by the officer who used force.

When a diabetic patient began to experience an insulin reaction, he asked a friend to drive him to a convenience store to buy orange juice. Since the store was crowded when he arrived, the patient felt that he would not get the orange juice in time and asked his friend to drive him to another individual's house. A police officer noticed the patient leaving the store soon after he entered it and followed the friend's car. The officer eventually stopped the vehicle and ordered the patient and the friend to wait while he investigated what happened in the store. Other police officers handcuffed the patient after arriving at the scene, while failing to investigate or address his medical condition. The patient was injured during these events, but the original officer released him after some time had passed when he found out that no crime had occurred in the store.

• William Hubbs Rehnquist (Author)
• Byron Raymond White
• John Paul Stevens
• Sandra Day O'Connor
• Antonin Scalia
• Anthony M. Kennedy
• Harry Andrew Blackmun
• William Joseph Brennan, Jr.
• Thurgood Marshall

Writing for a unanimous Court, Rehnquist ruled that an analysis of an excessive force claim should consider whether the search or seizure was objectively reasonable, based on how a reasonable police officer would have handled the same situation. The specific intent of the individual police officer who executed the search or seizure should not matter. While improper intentions do not make a reasonable use of force unconstitutional, good intentions do not shield an officer from liability if their use of force was objectively unreasonable. Thus, the Supreme Court rejected both the decisions of lower courts that had relied on the 14th Amendment and arguments that the Eighth Amendment prohibition on cruel and unusual punishment should apply. (An Eighth Amendment standard also would be subjective.) In deciding whether an officer used excessive force in a certain situation, a court should consider similar factors to those described in the earlier decision of Tennessee v. Garner. These include the severity of the crime, any threat posed by the individual to the safety of officers or other people, and whether the individual is trying to flee or resist arrest.

This case helped shape police procedures for stops that involve the use of force. An officer cannot justify these actions based on a hunch or by showing that they acted in good faith. Instead, they must carefully articulate facts and events that made their use of force objectively reasonable under the circumstances.

U.S. Supreme Court

Graham v. Connor

No. 87-6571

Argued February 21, 1989

Decided May 15, 1989

490 U.S. 386

Petitioner Graham, a diabetic, asked his friend, Berry, to drive him to a convenience store to purchase orange juice to counteract the onset of an insulin reaction. Upon entering the store and seeing the number of people ahead of him, Graham hurried out and asked Berry to drive him to a friend's house instead. Respondent Connor, a city police officer, became suspicious after seeing Graham hastily enter and leave the store, followed Berry's car, and made an investigative stop, ordering the pair to wait while he found out what had happened in the store. Respondent backup police officers arrived on the scene, handcuffed Graham, and ignored or rebuffed attempts to explain and treat Graham's condition. During the encounter, Graham sustained multiple injuries. He was released when Conner learned that nothing had happened in the store. Graham filed suit in the District Court under 42 U.S.C. § 1983 against respondents, alleging that they had used excessive force in making the stop, in violation of "rights secured to him under the Fourteenth Amendment to the United States Constitution and 42 U.S.C. § 1983." The District Court granted respondents' motion for a directed verdict at the close of Graham's evidence, applying a four-factor test for determining when excessive use of force gives rise to a § 1983 cause of action, which inquires, inter alia, whether the force was applied in a good faith effort to maintain and restore discipline or maliciously and sadistically for the very purpose of causing harm. Johnson v. Glick, 481 F.2d 1028. The Court of Appeals affirmed, endorsing this test as generally applicable to all claims of constitutionally excessive force brought against government officials, rejecting Graham's argument that it was error to require him to prove that the allegedly excessive force was applied maliciously and sadistically to cause harm, and holding that a reasonable jury applying the Johnson v. Glick test to his evidence could not find that the force applied was constitutionally excessive.

Held: All claims that law enforcement officials have used excessive force -- deadly or not -- in the course of an arrest, investigatory stop, or other "seizure" of a free citizen are properly analyzed under the Fourth Amendment's "objective reasonableness" standard, rather than under a substantive due process standard. Pp. 490 U. S. 392 -399.

(a) The notion that all excessive force claims brought under § 1983 are governed by a single generic standard is rejected. Instead, courts must identify the specific constitutional right allegedly infringed by the challenged application of force, and then judge the claim by reference to the specific constitutional standard which governs that right. Pp. 490 U. S. 393 -394.

(b) Claims that law enforcement officials have used excessive force in the course of an arrest, investigatory stop, or other "seizure" of a free citizen are most properly characterized as invoking the protections of the Fourth Amendment, which guarantees citizens the right "to be secure in their persons . . . against unreasonable seizures," and must be judged by reference to the Fourth Amendment's "reasonableness" standard. Pp. 490 U. S. 394 -395.

(c) The Fourth Amendment "reasonableness" inquiry is whether the officers' actions are "objectively reasonable" in light of the facts and circumstances confronting them, without regard to their underlying intent or motivation. The "reasonableness" of a particular use of force must be judged from the perspective of a reasonable officer on the scene, and its calculus must embody an allowance for the fact that police officers are often forced to make split-second decisions about the amount of force necessary in a particular situation. Pp. 490 U. S. 396 -397.

(d) The Johnson v. Glick test applied by the courts below is incompatible with a proper Fourth Amendment analysis. The suggestion that the test's "malicious and sadistic" inquiry is merely another way of describing conduct that is objectively unreasonable under the circumstances is rejected. Also rejected is the conclusion that, because individual officers' subjective motivations are of central importance in deciding whether force used against a convicted prisoner violates the Eighth Amendment, it cannot be reversible error to inquire into them in deciding whether force used against a suspect or arrestee violates the Fourth Amendment. The Eighth Amendment terms "cruel" and "punishment" clearly suggest some inquiry into subjective state of mind, whereas the Fourth Amendment term "unreasonable" does not. Moreover, the less protective Eighth Amendment standard applies only after the State has complied with the constitutional guarantees traditionally associated with criminal prosecutions. Pp. 490 U. S. 397 -399.

827 F.2d 945, vacated and remanded.

REHNQUIST, C.J., delivered the opinion of the Court, in which WHITE, STEVENS, O'CONNOR, SCALIA, and KENNEDY, JJ., joined. BLACKMUN, J., filed an opinion concurring in part and concurring in the judgment, in which BRENNAN and MARSHALL, JJ., joined, post, p. 490 U. S. 399 .

Page 490 U. S. 388

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Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.

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Overview of Police Use of Force

Broadly speaking, the use of force by law enforcement officers becomes necessary and is permitted under specific circumstances, such as in self-defense or in defense of another individual or group.

There is no single, universally agreed-upon definition of use of force. The International Association of Chiefs of Police has described use of force as the "amount of effort required by police to compel compliance by an unwilling subject" [1] .

Officers receive guidance from their individual agencies, but no universal set of rules governs when officers should use force and how much.

Context counts. No two situations are the same, nor are any two officers. In a potentially threatening situation, an officer will quickly tailor a response and apply force, if necessary. Situational awareness is essential, and officers are trained to judge when a crisis requires the use of force to regain control of a situation. In most cases, time becomes the key variable in determining when an officer chooses to use force.

Amount of Force Used

Law enforcement officers should use only the amount of force necessary to mitigate an incident, make an arrest, or protect themselves or others from harm. The levels, or continuum, of force police use include basic verbal and physical restraint, less-lethal force , and lethal force.

Learn more about the use-of-force continuum .

The level of force an officer uses varies based on the situation. Because of this variation, guidelines for the use of force are based on many factors, including the officer’s level of training or experience.

An officer’s goal is to regain control as soon as possible while protecting the community. Use of force is an officer’s last option — a necessary course of action to restore safety in a community when other practices are ineffective.

Injuries may occur in any use-of-force incident, and police should ensure that those injured receive medical aid and that the family of any injured person is notified.

Excessive force. The frequency of police use-of-force events that may be defined as justified or excessive is difficult to estimate [2] . There has been no national database of officer-involved shootings or incidents in which police use excessive force. On January 1, 2019 the FBI launched  a national use-of-force data collection .

[note 1] International Association of the Chiefs of Police, Police Use of Force in America, 2001 , Alexandria, Virginia, 2001.

[note 2] Alpert, Geoffrey P., and Roger G. Dunham, 2004. Understanding Police Use of Force: Officers, Suspects, and Reciprocity, New York: Cambridge University Press, 2004.

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Use of Force

As part of the Violent Crime Control and Law Enforcement Act of 1994, Congress obligated the Attorney General to “ acquire data about the use of excessive force by law enforcement officers,” and “publish an annual summary of the data acquired” (see 34 U.S.C. §   12602 ).

In 1995, the National Institute of Justice (NIJ) and BJS convened a Police Use of Force Workshop to discuss the associated data collection requirements of the Act. Challenges collecting valid and reliable of use of force statistics were discussed, including the specific identification and collection of excessive force data. Two data collection streams were developed from this effort: BJS and NIJ sponsored the  International Association of Chiefs of Police National Use of Force Database Center  (which produced the report, Police Use of Force in America, 2001 ) and BJS's Police-Public Contact Survey (PPCS).

• Police-Public Contact Survey (PPCS) The PPCS is a national survey of the nature and characteristics of citizen contacts with law enforcement. Data are collected from a nationally representative sample of residents age 16 or older, and include information on contacts with law enforcement such as traffic stops, arrests, handcuffing, and incidents of law enforcement use of force.

Since 1995, BJS and other Department of Justice agencies have engaged in efforts to capture a broader understanding of law enforcement use of force. This includes the following projects:

Arrest-Related Deaths (ARD) program

From 2003 to 2012, BJS collected a national census of information on persons who died either during the process of an arrest or while in the custody of state or local law enforcement personnel. Data collected included information on the decedent's demographic characteristics, the manner and cause of death, the law enforcement agency involved with the death, and circumstances of the incident such as weapon use and alleged criminal behavior of the decedent. While the collection continued through early 2013, published data are currently available through 2009.

In 2014, Congress passed the Death in Custody Reporting Act (DCRA) of 2013. The DCRA specifies that states are responsible for reporting information to the Attorney General on deaths in custody, which includes deaths during the process of arrest. This law includes potential sanctions for non-reporting states of up to 10% of their Byrne Justice Assistance Grant (JAG) funds. Because BJS’s statutory authority precludes its data from being used for anything other than statistical or research purposes, the Department of Justice has determined that data-collection responsibilities for DCRA reside with the Bureau of Justice Assistance. 

See Arrest-Related Deaths for more information.

• Law Enforcement Management and Administrative Statistics (LEMAS)

The LEMAS survey collects data from a nationally representative sample of state and local law enforcement agencies on personnel, pay and benefits, budgets, record and information management systems, and community policing. Since 1987, LEMAS has asked agencies about the existence of their use of force policies as well as use of lethal and less-lethal weapons. Across select LEMAS iterations, agencies have been asked about numerous topics related to the use of force, including: investigation policies pertaining to citizen complaints of excessive force; the annual number of citizen complaints received, including the number sustained; the number of internally generated use of force incidents and reports; documentation policies regarding force incidents; and the authority and role of citizen complaint review boards.

See Law Enforcement Management and Administrative Statistics  for more information.

• Survey of Inmates in Local Jails (SILJ)

The SILJ provides information collected from a nationally representative sample of inmates in local jails on individual characteristics of jail inmates, including current offenses and detention status, characteristics of victims, criminal histories, family background, and gun possession and use. In 2002, inmates were asked about their experience with law enforcement at the time of their arrest and the types of force used (if any) against them.

See Survey of Inmates in Local Jails for more information.

FBI’s National Use of Force Data Collection

The FBI created the National Use of Force Data Collection in 2015 to provide nationwide statistics on law enforcement use of force incidents. The data collection includes national level statistics on law enforcement use of force incidents and basic information on the circumstances, subjects, and officers involved. This data collection offers insight rather than information on specific incidents; and does not assess or report whether officers followed their department’s policy or acted lawfully.

See FBI Use of Force for more information.

FBI's Supplementary Homicide Reports (SHR)

The FBI's SHR are a part of the Uniform Crime Reporting (UCR) Program. The UCR provides aggregate annual counts of the number of homicides occurring in the United States. The SHR data provide additional details about each homicide incident, including the jurisdiction, month, year, victim and offender demographic characteristics, weapon, the circumstances surrounding the incident (e.g., argument, robbery, gang-related), and the relationship between the victim and offender, if known. In addition to incident-specific information on murder and nonnegligent homicides that come to the attention of the law enforcement, SHR collect data on justifiable homicides. The FBI publishes data on justifiable homicides by a law enforcement officer each year through the annual Crime in the United States publication (CIUS).

See The Nation's Two Measures of Homicide  ( July 2014, NCJ 247060)  for more information on the FBI Supplementary Homicide Reports.

FBI's Law Enforcement Officers Killed and Assaulted (LEOKA)

The FBI's LEOKA collection annually gathers information on the number of law enforcement officers killed, feloniously or accidentally, and the number of officers assaulted while performing their duties. Data is collected through the UCR Program for city, university and college, county, state, tribal, and federal agencies. The FBI publishes LEOKA data each year through CIUS.

See FBI LEOKA for more information.

Police Data Initiative (PDI)

The PDI is a law enforcement community of practice that includes leading law enforcement agencies, technologists, and researchers. Numerous law enforcement agencies have submitted use-of-force incident data to the PDI. The PDI was developed by the Office of Community Oriented Policing Services (COPS Office) and is maintained by additional partners, including the National Police Foundation.

See Police Data Initiative for more information.

Other Souces of Use of Force Data

The Centers for Disease Control and Prevention (CDC) also collects national data pertaining to lethal and nonlethal injuries inflicted through legal intervention, which are defined as injuries inflicted by the law enforcement or other law-enforcing agents, including military on duty, in the course of arresting or attempting to arrest lawbreakers, suppressing disturbances, maintaining order, and other legal actions. Lethal incidents are captured through the  National Vital Statistics System (NVSS), Fatal Injury Reports , and nonlethal injuries are captured through the National Electronic Injury Surveillance System - All Injury Program (NEISS-AIP) , a data collection co-sponsored by the CDC and the Consumer Product Safety Commission .

The CDC has been expanding its efforts to capture more information surrounding the circumstances of violent deaths through the  National Violent Death Reporting System (NVDRS) . While the NVDRS has received support from all 50 states (including the District of Columbia and Puerto Rico), the most recent compiled data are not nationally representative. Data for all three databases can be accessed from the  Web-based Injury Statistics Query and Reporting System (WISQARS) .

Data Collections

Recent publications.

• Local Police Departments, Procedures, Policies, and Technology, 2020 – Statistical Tables
• Sheriffs’ Offices, Procedures, Policies, and Technology, 2020 – Statistical Tables
• Contacts Between Police and the Public, 2020

How many persons have contact with the police in a given year?

During 2020, an estimated 53.8 million U.S. residents age 16 or older, or 21% of the population, had one or more contacts with police. This includes contacts initiated by the police, contacts initiated by residents, and traffic accidents. See  Contacts Between Police and the Public, 2020 .

How many persons had contact with police in 2020?

In 2020, about 53.8 million persons age 16 or older had one or more contacts with police during the prior 12 months. An estimated 25.5 million experienced contact initiated by police, nearly 30.0 million initiated contact with police, and 7.8 million reported police contact as the result of a traffic accident. About 16.7 million persons reported being pulled over as the driver in a traffic stop, compared to about 16.2 million persons  reporting a crime, disturbance, or suspicious activity to police. See  Contacts Between Police and the Public, 2020 .

Does the ARD program include deaths resulting from any use of force by state or local law enforcement personnel?

Yes. The ARD collection includes all deaths that result from any use of force by law enforcement officers, regardless of whether the officer intended the use of force to be lethal. To resolve an incident, law enforcement officers are authorized to use force in an escalating series of actions. The amount of force used ranges from the mere presence of an officer to the use of lethal force.

Most law enforcement agencies have policies that guide the appropriate level of force for a given situation. Law enforcement personnel are trained to only use lethal force when an arrest subject poses a serious threat to the officer or another individual and an arrest would be imminent. The threshold of criminal behavior to prompt an arrest is far lower than the threshold to prompt the use of lethal force.

Terms & Definitions

Deadly or lethal force, excessive use of force, non-deadly or less-lethal force, use of excessive force, use of force.

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The Structure and Delivery of Police Use of Force Training: A German Case Study

• Original Article
• Open access
• Published: 17 May 2021
• Volume 7 , pages 87–112, ( 2022 )

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• Mario S. Staller   ORCID: orcid.org/0000-0002-8608-9098 1 ,
• Swen Koerner 2 ,
• Valentina Heil 3 ,
• Isabel Klemmer 1 ,
• Andrew Abraham 4 &
• Jamie Poolton 4  

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The current study aims to investigate the current structure and delivery of police recruit training. Using a case study approach, we systematically observed a semester of police training that consisted of 30 h with a specific focus on police use of force training. Field notes and time-on-task data was analysed using an inductive approach. The results revealed, first, a lack of constructive alignment of the training modules and learning tasks within the training settings. Second, an adherence to traditional linear approaches to training resulting in high amounts of augmented instruction and feedback and a one-size-fits all approach to technical and tactical behaviour. Third, a non-efficient use of available training time with low amounts of engagement in representatively designed tasks that stimulated problem-solving processes. Based on these results we suggest that there is a need: (a) for police trainers and curriculum designers to align the objectives, practice structure and delivery of police training with the needs of police officers in the field (e.g. conflict resolution); (b) for police trainers to employ more learner-centred pedagogical approaches that account for individual action capabilities and resources, and allow for high amounts of training time with representatively designed training tasks; and (c) for senior managers of overall police training decision-makers to provide the necessary trainer education, in order to furnish trainers with the knowledge and tools to appropriately plan, deliver and reflect upon their practice in keeping with concept of constructive alignment.

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1 Introduction

Generating and applying the best available evidence to police policy, practice and decision-making is an integral constituent in the process towards the professionalisation of the police (Brown et al. 2018 ; Mitchell and Lewis 2017 ). However, in the context of police training, research has indicated that practice based on tradition rather than empirical evidence is common (Basham 2014 ; Birzer 2003 ; Cushion 2020 ). At the same time, research findings have brought into question the effectiveness of police training in conveying the skills needed for conflict management (Jager et al. 2013 ; Renden et al. 2015a ). This has led to efforts to show how empirical evidence might inform the content and delivery of police training on order to further professionalize practice within this domain (Körner and Staller 2018 ). Researchers in the field of coaching and education have proposed constructive alignment as one way of drawing in empirical findings in a structured and coherent way (Abraham et al. 2015 ; Biggs 1996 ; Loughlin et al. 2020 ). Constructive alignment can be operationalised at a macro programme level and at a micro session delivery level. Figure 1 displays a schematic of how constructive alignment operates at a programme level.

(Adapted from Abraham et al. 2015 )

A schematic of the process to develop a constructively aligned programme

This process offers a guide to programme designers to match and align all elements of design, planning, delivery, assessment with the overarching reality-informed learning outcomes (Abraham et al. 2015 ; Muir et al. 2015 ). In addition to this programme level view on constructive alignment, a sessional level view also exists (see Fig. 2 ). Here, alignment is considered in terms of the connectivity between session outcomes and overall outcomes, and then in terms of the connectivity between desired session outcomes, task/practice design, coach/trainer behaviour and learner engagement. Instructor expertise and effectiveness is evaluated with reference to what they do and their capacity to rationalise why this is constructively aligned. Ultimately, the point of constructive alignment is to facilitate the development of desired skills and, where relevant, the transfer of skills from a training setting to a real-life setting (Loughlin et al. 2020 ).

Session constructive alignment (Adapted from Abraham et al. 2015 )

Our focus in this paper is on police use of force training and its constituent components (e.g. firearms training, arrest and self-defence training, etc.) rather than the whole programme of police development. Concerning training programmes for coping with physical conflict situations, empirical studies have begun to paint a picture of the range of skills needed to deal with such situations (Preddy et al. 2019b ; Rajakaruna et al. 2017 ) and to different formats of delivery (Renden et al. 2016 ). Yet, besides analysis of police self-defence and arrest training (Cushion 2020 ), there is no known holistic account of the delivery of police training. In order to fill this gap, this paper aims to evaluate the delivery of police training by taking a snap shot of practice in a German police force and drawing on the concept of constructive alignment as a framework for evaluation.

In keeping with this view, it is of concern that research has indicated that skills learned in police training do not necessarily transfer to the criterion environment of dealing with violent encounters (Jager et al. 2013 ; Renden et al. 2015a ). Proposals to tackle this observed lack of transfer, regularly include improving organizational structures to provide more training time (Buttle 2007 ; Jager et al. 2013 ; Renden et al. 2015a ); revising what is taught (Renden et al. 2015a ; Renden et al. 2016 ) and how it is taught (Cushion 2020 ; Körner and Staller 2018 ; Nota and Huhta 2019 ; Staller and Zaiser 2015 ). Research so far has mostly investigated the structure and delivery of police training by interviewing trainee officers (Buttle 2007 ; Rajakaruna et al. 2017 ) and trainers (Körner et al. 2019 ; Preddy et al. 2019b ). Only recently did Cushion ( 2020 ) provide empirical evidence about the actual delivery of police training. Using a case study approach and employing participant observation, interviews and time-on-task analysis, Cushion participated and observed three, two-day courses of officers’ safety training in the UK. The study showed that practice activities were delivered in a disjointed fashion and were not representatively designed. This adds empirical evidence to the notion that police training methods regularly seem to employ an instructor-centric linear teaching model (Birzer 2003 ; Werth 2011 ). This approach is characterized by having defined the relevant conditions and stimuli under which the learner has to perform, and comparing the performance of the learner with a clear description of criteria by which the behaviour will be judged acceptable (Elias and Merriam 2005 ). The underlying assumption of linear teaching is that skills can be isolated and built part by part in preparation for the criterion environment. The focus in this process is on a specific technique and sequence of movements, which must be copied from the trainer’s model and reproduced in the event of an emergency (Körner and Staller 2018 ). For example, Cushion ( 2020 ) observed that police trainers delivering officer safety training drew heavily from a manual of arrest and self-defence techniques to design their programme. Advantages of linear approaches include accelerated acquisition of isolated skills in low-stress and low variance environments, which is accompanied by the learner (and teachers) subjective conviction of technique mastery (Abraham and Collins 2011 ). However, such learning environments (low-stress, low-variance) do not usually align to the specific situational parameters of conflict situations in the policing context (Jager et al. 2013 ; Renden et al. 2015a ) which should characterise the learning outcomes of police training (Cushion 2020 ; Rajakaruna et al. 2017 ). More representative task design in this context should consist of two components: (a) functionality of the task; and (b) action fidelity (Pinder et al. 2011 ). While the functionality of a training activity enables the trainee to experience the pressure conditions and constraints of the task expected in the criterion context, action fidelity refers to the learner being afforded the full range of responses available in the field. The core element of representativeness is the relationship between perceptual-cognitive, motor and emotional conditions (Broadbent et al. 2015 ; Headrick et al. 2015 ; Staller et al. 2017a , b ) and which seem to be underrepresented in police training (Cushion 2020 ; Körner et al. 2019 ).

Another drawback of the linear approach to learning often lies in limiting the amount of time that learners are actually engaged in practice, due to the adherence to blocked practice drills with augmented coach instruction and feedback (Curtner-Smith et al. 2001 ; Renshaw and Moy 2018 ). In the context of police training, Cushion ( 2020 ) noted that the available training time was not maximised. Over the three courses observed participants spent 54.1% of the training time being passive, while the coach(es) demonstrated, briefed the learners and gave feedback. After taking into account all activities in which participants observed others or worked as a simulator, the time spent motorically engaged in subject matter-related tasks was between 20 and 30%. Time-on-task is a necessary factor for the mastering of skills (Ericsson 2016 ) and considered a process indicator for learning (Mars 2006 ). However, it is acknowledged that activity alone is not enough. Learners need to be engaged and invested in the task at hand (Christenson et al. 2012 ) to advance the rate of learning. As such, police training needs to engage police recruits in well-designed learning activities (Cushion 2020 ; Staller and Zaiser 2015 ). Taken together, linear approaches to training may come at the expense of the representative design of the training tasks and the low time-on-task of the learner.

Although the literature is critical of the structure and delivery of police training, empirical investigation of how training is actually delivered is limited to the perspective of the trainees (learners) and coaches (trainers) (i.e. Preddy et al. 2019a ; Rajakaruna et al. 2017 and to a specific component of police training (i.e., officer safety training, Cushion 2020 ). Furthermore, when generalising the findings of police training it is important to be cognisant of differences in national socio-economic context. With these limitations in mind, the current study utilised a case study approach employing participant observation to investigate the structure and delivery of police training in Germany and how it is configured to deliver its outcomes.

A case study methodology was implemented employing participant observation to systematically garner enough information about police training to effectively understand how it was delivered (Cushion 2020 ; Thomas 2011 ) Participant observation is a frequently applied field strategy in learning settings (Patton 1990 ) and is deemed appropriate for case study designs where the phenomenon under investigation is observable in the natural environment, suitable information can be collected via this means, and the boundaries of investigation are open-ended (Jorgensen 2015 ). Ethical approval for the study was obtained by the Ethics Committee of the German Sports University of Cologne.

2.1 Data Collection

Data collection was conducted at a police academy in Hesse, Germany. A study section with 5 full days of police use of force training provided the analytical frame of the study with the object being the process of training (Thomas 2011 ). The study section was part of the second year of the recruits’ training and contained 30 h of police training and instruction with one weekly training day dispersed over 5 consecutive weeks. The study section was embedded between two sections of practical training out in the field at a functioning police department. A curriculum of the to be learned skills and competencies provided the framework for the police training. In general, the goal of police education at the University of Applied Sciences of Police and Public Administration is to develop the competencies needed for fulfilling the tasks of policing (Hessisches Ministerium des Innern und für Sport 2016 ). The stated learning outcomes and curriculum for police use of force training are to develop recruits’ individual self-defence concept and being able to apply the learned technical and tactical skills in scenario-based exercises (Hessische Hochschule für Polizei und Verwaltung 2016 ). During the 5 training days, aspects of self-defence, restraint and control, shooting and tactical training were covered.

A class of 24 recruits and their trainers were observed during training sessions. The group of 24 was split in two for most sessions; in total 25 trainer-recruit delivery sessions were observed (see Fig. 3 ). Participants of police training were informed about the observation in advance of the sessions taking place and provided their informed consent. Several individuals were absent over the course of the study causing attendance rates to differ in each training session. The number of coaches also differed depending on the training days and the delivered content. The ratio of coaches-to-recruits varied over the five days from 2:7 (day 5; firearms training) to 1:24 (day 1; self-defence, arrest and control training). The variation in numbers are outlined in Fig. 1 .

Structure of observed training days with additional information regarding content, training facility, number of coaches, participants and observing researchers, respectively

Four researchers (MS, SK, VH, IK) monitored the training as observer participants. Three researchers (MS, SK, IK) had more than 10 years of experience in teaching self-defence and combat related training programmes. All researchers took extensive field notes in addition to a “time-on-task” analysis.

In order to account for the microstructure of the training, a time-on-task analysis (Cushion 2020 ) was employed. For this purpose, the timing, content and duration of each training element was. In keeping with the sessional basis of constructive alignment researchers paid specific attention to what the tasks participants were engaging with (e.g., training activities, listening, pairs, groups, alone) and what coaches were doing (e.g., demonstrating, giving instruction). Session objectives were drawn from the learning outcomes noted in the introduction. This enabled the recording of the type and the duration of each element along with the pedagogy employed by the coaches.

The microstructure of each session was noted at 15 s intervals. Additionally, for every interval researchers noted what the learners were doing and how the specific training activity was set up. This included information about group size (e.g., one learner and three simulators) and a precise description of the exercise.

2.2 Data Analysis

Following the data collection phase, curriculum, session plans, field notes and time-on-task analysis were compared between the two observers within a team. Differences in the raw data were resolved by discussing the issues in question until agreement about the observation was achieved. The analytic process consisted of two distinct phases and followed the protocol employed by Cushion ( 2020 ). First, the collected raw data (field notes, time-on-task analysis) was broken down into “meaning units” that conveyed one idea or a related set of observations. All field notes were examined line-by-line as well as data concerning the time frame of each activity within training sessions. Second, meaning units identified were grouped together to organise common meaning units into lower-order themes. A further level of interpretation compared lower-order themes to organise them into larger more inclusive higher-order themes.

Concerning the time-on-task analysis, an inductive approach was employed, utilising the process of abstraction to reduce and group the raw data. the inductive approach resulted in two themes relating to the training activities that were carried out. First, practice activities that focused on reproducing the behaviour demonstrated and instructed by the coach. These activities were concerned with “how” to perform a specific technical or tactical skill and involved no decision concerning “what” skill to use. Second, “problem solving” activities included practice that aimed at solving a given task under certain constraints involving “what”—and “how”-decisions. In order to account for training activities with different level of participation and different roles (observer, simulator, player), a player-index was used to calculate net training time from total training time within a specific activity. The player-index was based on the group size and number of individuals that performed as a player and of those who performed as simulators or observers. For example, when a training activity consisted of 4 recruits, comprising 1 player and 3 simulators, a player index of 1:4 was noted. Net training time was then calculated by multiplying total training time for this activity with the player index. If the recorded training time for this activity was 4 min, a net training time of 1 min was calculated (4 min × 1/4 = 1 min).

The higher and lower order themes that emerged from the data analysis are presented in Table 1 . The higher order themes are presented in subsequent paragraphs.

3.1 Structure of Police Training

On a macrolevel, training was divided into the three different training settings of self-defence and arrest training, firearms training and tactical training. The total time-on-task analysis showed that recruits spent the most time participating in tactical training and the least training time on firearms training (see Table 2 ).

On a microlevel, cumulatively recruits engaged in almost 9 ½ hours ( M  = 09:29:00) of practice activities directly related to developing their technical and problem-solving skills. Of this time, short of 4 h ( M  = 03:52:28) was spent as a player (net training time) reproducing techniques and tactics that were demonstrated by the coaches ( M  = 02:28:24) or problem solving ( M  = 01:24:04). The percentage of time-on-task as a player (net training time) in each training setting was largest for self-defence and arrest training ( M  = 23.13%) and at similar levels for firearms ( M  = 15.04%) and tactical ( M  = 13.89%) training.

Net training time, spent in training activities including problem solving accounted for on average of 6.37% in self-defence and arrest training, 0.00% in firearms training and 7.77% in tactical training. Coach Delivered Information activities accounted for nearly 9 h ( M  = 08:51:00) of training time with Instruction ( M  = 13.62%) and Feedback ( M  = 11.54%) the main activities (see Table 3 ).

Concerning the time spent in different training sessions, results revealed that most total training time was spent in tactical training ( M  = 11:31:20). However, the net training time of each participant in tactical training was less ( M  = 01:35:47) than in self-defence, arrest and control training ( M  = 01:50:56), but more than in firearms training ( M  = 00:25:55).

3.2 Content and Delivery

The analysis of the curriculum and the session plans and the observation of training yielded two main findings. First, there was a prominent focus on the management of conflict by the means of force. Only one brief simulation in the five training days aimed at resolving a conflict by communicative means. Second, there was a lack of connection between the different modules of police training, namely self-defence and arrest training, firearms training and tactical training. At a macrolevel, the modules appeared disjointed, in the sense that one element did not inform or was not deliberately integrated within another. At a microlevel, there appeared a disconnect in the topics (skills) covered within a single training session. An example was observed in self-defence and arrest training:

The training goes from defending against grabs to the wrist, to applying arm bars, joint locks and handcuffing. In the end, the recruits had to do a relay race with a partner, where they had to handcuff a person who was already stood against the wall. (Field notes, day 5, self-defence and arrest training)

3.3 Lack of Representative Task Design

A prominent feature of the police training observed was the lack of representativeness. A common observation was that simulators in training tasks lacked the presentation of valid information for the learner to act upon. Especially in activities involving the delivery of blows and strikes, simulators seemed afraid of what the player (key learner) was about to do. As a result, attacks on the learner were slow and nonaggressive:

Recruits have to stop a charging attacker and to perform a takedown and to arrest the person. The simulators do not attack properly and players perform the technique at the wrong distance. Another technique would be more appropriate at this “wrong distance”. It looks like a choreography. The simulator did not resist and helped the learner by going down even if the technique was performed at the wrong distance. (Field notes, day 2, self-defence and arrest training)

As illustrated, such activities mostly resulted in non-representative interactions, which lacked valid feedback for the learner. The coaches did not explicitly instruct the simulator about how to act or intervene during the activity to adapt or optimise the simulator behaviour. There were a lot of training tasks that lacked representativeness by design of the training task:

Teams of five competed against each other in a relay race. Four recruits laid on the floor, their hand behind their backs. One recruit had to handcuff everyone - and releasing the handcuffs before handcuffing the next partner. The partners on the ground helped the recruit who was working, because every team wanted to be the fastest team. Each round lasted for approx. 2 minutes. So every recruits laid down 4 times for 2 minutes and worked once for 2 minutes. They all laughed and had a lot of fun during this exercise. (Field notes, day 5, self-defence and arrest training).

In this example, the task itself was designed in a non-representative way, with five recruits lying next to each other waiting for being handcuffed. Learners rushed from one person to another order to be the fastest team. As such, recruits were not able to perform the behaviour as it would be needed in the field. This lack of action fidelity could also be observed in firearms training. For example, recruits were tasked with math problems before shooting.

Participants were in ready position and had to shoot the target the coach was calling out. Targets were geometrical objects with numbers in it. The coach said: “yellow 1” or “blue 3”. Recruits shoot two rounds at the specified target. In the next exercise the coach set a calculation task: “Square root of 9” – Recruits had to shoot a the “3”. All shooting tasks did not involve a representative stimulus. (Field notes, day 3, firearms training)

In the field, like in this practice activity, police officers have to react to specific information sources, however, the information is context specific, unlike this activity. In tactical training, paper targets were used to represent suspects in a “enter and search” practice activity.

In tactical training recruits were presented with a scenario (possible burglary in progress), which they (teams of two) had to respond to. The two recruits had to enter safely the premises and search for the suspect. The coaches hid paper targets (picturing a man holding a gun) in the apartment. Recruits had to talk to the paper targets (e.g. “Drop your gun!”). After the scenario the two recruits talked among themselves. [Recruit A] said: “That was good. We have to do this more often”. [Recruit B] answered: “I find it difficult to practice with those paper targets. They don’t react”. (Field notes, day 5, tactical training)

Furthermore, due to official restrictions on tactical training involving simulators with guns, recruits knew in advance that coaches would not shoot at them, making the scenario predictable and likely reducing the anxiety levels within learners (Nieuwenhuys et al. 2012 ). As such, the task was less representative.

One team was performing a scenario (entering a building after a potential burglary); the others observed. One recruit said “Nobody is shooting at you” (the coaches are not allowed to shoot at the recruits in that kind of training); The other recruit replied: “Then it’s not that bad”. (Field notes, day 4, tactical training)

Performance of recruits also varied between isolated technical training activities compared to those that allowed for the integration of information and action. Whereas recruits seemed to perform quite well during technical training—that is, they applied the technique according to the instruction and feedback of the coach—they were not able to apply the trained technique to a more representative setting later in training. Instead, the recruits found different individual solutions to the problem set:

Recruits were taught a controlling technique on the ground. After 15 minutes of technical training with corrections from the coach, recruits should team up and fight against each other with one being the suspect and the other being the officer trying to control and arrest the partner. Recruits were not able to apply the taught technique. Every recruit tried different solutions to control the opponent. Some succeeded, some not. But nobody maintained the shown position longer than a few seconds. (Field notes, day 3, self-defence and arrest training)

4 Discussion

The current study fits into efforts to professionalize police training in Germany (Körner et al. 2018 ). With a focus of these efforts to provide evidence for the reflection of current practices, the aim of this body of work is to provide empirical evidence about the actual delivery of police training and how it is configured to deliver its outcomes. The observation and the data analysis provided insights into the actual practice of police training in a German law enforcement agency. Similar to the themes presented in the results section, the discussion will focus on (a) the structure and delivery of police training, (b) the level of representativeness in police training.

4.1 The Structure and Delivery of Police Training

The macrostructure of police training seems to lack a consistent rationale that is grounded in functional skill development and constructively aligned with the objective of developing competent police officers. Furthermore, police training seems to adhere to a traditional, linear structure both on a macro- (isolated training elements) and a micro-level (isolated techniques and tactics). Finally, the current microstructure of police training provides recruits with a relatively small percentage of training time actually engaged in practice focused activities, especially involving problem-solving skills.

4.1.1 Lack of a Consistent Rationale for the Structure of Police Training

The overall structure of police training is built around providing solutions to conflict situation problems. For the solving of operational problems with weapons, recruits engage in firearms training. In order to be able to solve conflict without the use of weapons, recruits participate in self-defence and arrest training. The integration of these elements can sometimes be seen in tactical training, when scenarios are employed as training activities. However, often the focus of such sessions is not firearms and/or self-defence, but the teaching of tactical behaviour like situational awareness and the enter and searching of apartments. This structure around solutions of conflict situations can be found in other states at a national level (Hochschule der Sächsischen Polizei 2016 ; Hochschule des Bundes für öffentliche Verwaltung 2015 ) as well as in other countries at an international level (Cushion 2020 ; Renden et al. 2015b ). This is problematic, insofar that (a) tasks are isolated from the context in which they occur and (b) taught content may not be aligned with the needs of the learners and their working context.

Decontextualizing practice in order to develop understanding and rules how to solve specific problems is useful on a temporary basis (Price et al. 2019 ). However, the lack of context may lead to the practice of disintegrated, “off-the-shelf” solutions (Cushion 2020 ) and the lack of functional task alignment (i.e. learners do not act on the actual information that is present in the field) when designing representative learning tasks (Pinder et al. 2011 ). As such, it may be advisable to structure the training content around problems, like citizen-police interaction, terror intervention or domestic violence interventions instead of physical coercion, de-escalation or the use of firearms. Focusing on problems instead of distinct solutions (e.g. use of force, arrest techniques, de-escalation) would allow learners to use their individual capabilities and conflict resolutions strategies (Körner and Staller 2018 ; Rutter 2020 ). This approach is supported by data from scenario training in police agencies, where the same problems are solved differently by men and women according to their own capabilities (Jaeckle et al. 2019 ). A problem-based approach would also compliment the ecological dynamics perspective advocating the developing of skills based on the action capabilities of the performer and the task at hand (Seifert et al. 2019 ).

The type and characteristics of the problems set should be based on a need analysis of the taught officers, which may vary depending on the specific context they will operate in. In keeping with box 1 in Fig. 1 , constructive alignment of the learning program should be based around intended learning objectives that have been informed by the demands of the working context to be entered and the needs of the recruits relative to those demands. This becomes the basis for designing long-, medium-, and short-term plans that will enable these objectives to be achieved and that provide a key reference point from which police trainers and decision-makers can monitor and adjust the effectiveness of their programs, plans and delivery (Abraham et al. 2015 ). Our interpretation of the course curriculum and our practice observations suggest that the macrostructure of the programme was not obviously guided by a clear view of what recruits should be expected to cope with at this point in their training. Instead, a specific set of skills was selected seemingly on received wisdom. Such an approach appears to limit the curriculum designers and coaches’ perspective of police training. Coping with operational situations—which are often conflictual in nature (Ellrich and Baier 2016 ; Hine et al. 2016 )—demands more than the use of use of force, tactical behaviour and shooting skills (Todak and James 2018 ; Todak and White 2019 ; Zaiser and Staller 2015 ). Communication and de-escalation skills were not part of the police training in the study section observed. The lack of training activities focusing on communication and de-escalation skills has been criticized by trainees of Australian police forces (Rajakaruna et al. 2017 ). As such, police training would benefit from more clearly aligning the structure of the programme and its delivery with the intended outcome of police recruits being able to cope with conflict.

4.1.2 Traditional, Linear Structure and Delivery of Police Training

It appears that underlying the structure of police training (macrostructure) and the delivery of training (microstructure) is a traditional, linear and reproductive approach to skill acquisition. In this case study, police training was structured at a macro-level into three isolated parts or “modules”: self-defence and arrest training, firearms training and tactical training Footnote 1 (Hessische Hochschule für Polizei und Verwaltung 2016 ). In the domain of policing this siloed approach is known as the applied learning model (Adang 2011 ), which is common in police educational settings in Germany (Hochschule der Sächsischen Polizei 2016 ; Hochschule des Bundes für öffentliche Verwaltung 2015 ). Skills are first practiced in isolated (technical) modules before they are integrated in a scenario training consisting of interactive simulations between learners (players) and role-players (simulators). In the current study, interactive scenario training was carried out during tactical training; however, beyond these examples, representative simulations were scarce. Instead, training was heavily focused on training isolated techniques in a reproductive manner.

The performance difference of recruits in isolated training tasks compared to representatively designed tasks, showed that recruits were not able to apply the formerly learned skills in contextualised environments. This is in line with predictions from both naturalistic decision making (NDM) and ecological dynamics’ interpretations of human performance (Seifert et al. 2019 ). In short, the lack of functional coupling and integration of the different elements (perception, cognition and action, brain and body, use of force and de-escalation) that are needed in order to solve conflicts (Rutter 2020 ) will inevitably limit the transfer of skills to practice. The approach of isolating modules (firearms training, self-defense and arrest training, tactical training, de-escalation) that are later put together (as a whole) is based on the assumption of “modularity”, which is a characterizing feature of the traditional linear approach to learning. The assumption is that isolated processes (e.g., techniques) can be decoupled from the action in the performance context and effectively integrated back into the whole system to advance performance ((Renshaw et al. 2019 ). However, this assumption is not supported by other theoretical rationales, like the NDM and ecological dynamic frameworks (Ashford et al. 2020 ; Correia et al. 2018 ; Renshaw et al. 2019 ; Seifert et al. 2019 ) which argue that skills are best developed in context.

At a micro-level the results also showed evidence of a traditional linear learning model. These linear models of learning are characterised by: (a) “ideal models” and the existence of single solutions of skills-to-be-learnt (Moy et al. 2016 ; Orth et al. 2018 ; Seifert et al. 2019 ); (b) ideal techniques are demonstrated by the coach and repeated by learners in isolated drills before put into application within the performance context (Metzler 2017 ; Moy et al. 2014 2016 ); (c) complex skills are split into smaller parts (Metzler 2017 ); (d) training consists of highly structured teaching sequences (Moy et al. 2016 ); and (e) detailed prescriptive instructions and corrective verbal feedback provision by the coach (Correia et al. 2018 ). Highly structured sequences were observed in the current study, especially in the training of self-defence and arrest, and firearms. Furthermore, detailed descriptive and prescriptive instructions, as well as corrective feedback were given regularly by the coaches. These findings are consistent with those from studies of police educational settings in general (Shipton 2012 ; Werth 2011 ) and police training in particular (Cushion 2020 ), which also found a high prevalence of teacher-centred linear approaches to learning.

Furthermore, the current curriculum emphasises the existence of ideal models of technical and tactical behaviour in specific situations. As such, the curricular structure suggests a one-size-fits all approach. All recruits, irrespective of their body composition and action capabilities, were expected to learn certain self-defence and arrest techniques. The assumption that one movement pattern acts as an optimal template for all learners has been rejected on an empirical basis (Chow et al. 2009 ; Schöllhorn 1999 ; Schöllhorn et al. 2012 ). Hence, this traditional linear approach lacks in providing the learners with opportunities to develop their individual strategies for dealing with conflict situations. This problem has been addressed recently (Körner and Staller 2018 ; Rutter 2020 ; Staller and Körner 2019b ), by advocating a more goal-oriented approach to conflict situations, which emphasises the discovery of individualised solutions to problems faced according to the learner’s action capabilities and prerequisites. Despite for the most part adopting a linear, there were examples of coaches, especially in self-defence and arrest training and firearms training, attempting to deliver goal-directed tasks that were constrained to guide the practice of context-specific functional solutions.

4.1.3 Low Amount of Qualitative Time-on-Task

In the current case study, a relatively low amount of qualitative time-on-task was observed ( M  = 40.82% total activities with practice focus). This is in line with results from Cushion ( 2020 ), who also found that officers spent less than 50% of the training time actively engaged in a task. Since time-on-task is a necessary factor for the mastering of skills (Ericsson 2016 ) and considered as a process indicator for learning (Mars 2006 ) police training would benefit from increasing the time-on-task of the learners.

However, practice per se is not predictive of learning efficacy, since the quality of practice task also plays a fundamental role concerning skill development (Correia et al. 2018 ). With regards to quality, two aspects have to be considered. First, the amount of practice time, where the learner actually is able to act upon the environmental constraints; that is, the amount of practice time when the learner has the role of the player (and not the simulator). Second, the amount of training time spent engaging in representative simulations; that is, training tasks that incorporate high levels of functionality and action fidelity. As such, training tasks focusing on the technical reproduction of a certain behaviour could be deemed as low-quality interactions. In the current study, time-on-task involving partner interactions that satisfy these two desirable criteria (player-status and no technical reproduction) was approximately 6% of total training time. Since claims for optimizing police training regularly include the call for more training time (Jager et al. 2013 ; Renden et al. 2015a ), the current results would suggest first optimizing the available training time by developing high quality training tasks (simulations). Tackling this issue would require dealing with two aspects. First, to reduce the high amounts of time recruits spent passive, and second, to optimize the partner interactions in a way that representative simulations can take throughout the learning programme rather than just at the end as is common in a traditional modular approach (Staller and Körner 2019a ).

4.1.4 Representative Learning Design in Police Training

The results indicated that the levels of representativeness differed across the different training settings. In firearms training, representativeness was lacking by design due to the necessary safety constraints of live fire shooting (Adang 2011 ; Staller et al. 2017a , b ). Instead, numbers, static images or coach instructions served as non-representative cues for initiating a shooting response. In self-defence and arrest training, it was observed that many exercises contained no functional coupling between the information presented and the action of the learner. For example, a training activity was observed which had recruits lying on the ground waiting to get handcuffed rather than talking or taking them down. Moreover, it was observed that recruits acting as attacking simulators charged slowly towards learners, which in turn performed their defending behaviour at a distance, where they did not reach the attacker. However, the attacking partner reacted to the defending behaviour like it was the right distance. The need for recruits to literally act as simulators meant that learners were responding to information that was not likely representative of the information presented by a civilian in the field. This stresses the importance of ensuring optimal partner interaction by developing partners as good simulators by introducing roles and responsibilities of good training partners (Staller and Körner 2018 ). There is empirical evidence that recruits acting as simulators elicits positive learning effects (Sjöberg et al. 2016 ), providing an additional argument for shifting the simulator role away from the coaches as the sole simulator.

It was found that tactical training was most representative of the criterion environment when recruits had the opportunity to solve problems posed using scenario training. However, after the coaches gave, often large amounts of, corrective feedback, recruits repeated the same scenario, which now lacked the unpredictability and surprise of the first training experience. Such observations indicate that scenario training is not representative by design per se and as such may not be capable of fostering “realism” in training as advocated by the literature (Adang 2011 ; Murray 2004 ). Analysing training tasks alongside the framework of representative learning design may prove the more functional alternative in ensuring skill transfer (Krause et al. 2017 ). Hence the simulations should be representatively designed regardless of their complexity (regular partner interaction vs. high-end scenario training). Practitioners and researchers alike may consider high quality partner interactions as a quality criterion for police training (Staller and Körner 2019a ).

It appears that the modularized organizational structure of police training as well as the linear oriented microstructure is geared towards what is regularly called “realistic scenario trainings” (Andersen et al. 2016 ; Sjöberg and Karp 2012 ). However, the amounts of training time spent as learners in such tasks was low. Long waiting times seem to have costs concerning valuable training time-on-task. Also, the motivation of learners seems to be negatively affected by long waiting times (Staller et al. 2021 ). Due to high numbers of recruits compared to the low numbers of coaches that are available, a sustainable solution for this problem may lie in rendering partner interactions with peers as “mini” scenarios, being highly representative simulations that get more and more complex over time and are dependent on the resources that are available.

4.2 Limitations

Case study methodology has inherent weaknesses. The current case took place at a specific time period in the education of young police officers, in a specific training institute with a specific focus on police use of force training. Therefore, the results cannot be readily generalised to police training in other law enforcement agencies at a national or international level. As such, further observations of police training for different populations (recruits, regular officers, specialized teams, etc.) in different settings (agencies, states, countries) with different trainers are needed to get a fuller picture of the practice of police training. That being said, since police institutions in Germany have been reluctant of providing access in order to research coaching in police training (Staller and Körner 2019b ), the current case study for the first time provides insights into such programs and may serve as a catalyst for further research into the structure and delivery of police training.

5 Conclusion and Practical Implications

The current study aimed to shed light on the structure and delivery of police training in Germany and how it is configured to deliver its outcomes. The key point of reference being programme and sessional constructive alignment.

From a macro programme perspective, our study suggested that problems existed in learning outcome design and subsequent programme design. We noted a lack of realism in connecting the learning outcomes around what recruits were expected to overcome and the demands of the role they would fulfil in the field. At face value the outcomes of having a self-defence concept and being able to apply the learned technical and tactical skills in scenario-based exercises make intuitive sense. However, we suggest they lack important context and aligned perceptual, cognitive and motor skills. For example, the skill of recognising, communicating and de-escalating with a capacity to adapt behaviour seems to be underrepresented within existing training programmes. Drawing on these ideas, an alternative outcome could read: the recruit will be able to recognise and respond to potential threats of violence in different contexts through means of negotiation and/or physical use of force. In keeping with constructive alignment, such an outcome would give clearer guidance on how this would be assessed, how tasks might be designed and how modules could be connected.

Given the problem of a lack of constructive alignment at a programme level, it is not surprising that we observed a lack of constructive alignment at a sessional level in the training modules. In particular, an adherence to traditional linear approaches to training with high amounts of augmented instruction and feedback was generally observed. This approach typically offers a one-size-fits all approach to technical and tactical behaviour in specific situations, which is at odds with being able to resolve conflictual situations in police-citizen interactions. As such, training programmes and activates could be structured and designed to develop a broader skill set for coping with conflict in the field at the expense of technical training of distinct techniques. We do not completely discount the role of repetitive drills, rather we would suggest that if they are used it is within a spiral curriculum (Harden and Stamper 1999 ) that layers and returns to the necessary concepts in different contexts. By structuring police training in this spiral fashion, where the main concepts are learned in an iterative and progressive fashion, skill development of police officers could take place on a much more individual level by maintaining the demands posed by the field at each skill level.

Finally, our data suggests that available training time in police training seems not be used efficiently. Active time-on-task, especially engagement in representatively designed tasks, involving problem-solving capabilities was low given that the police literature advocates representatively and interactively designed training tasks as the gold standard for training (Nota and Huhta 2019 ; Staller and Körner 2019a ). Again, this may well be explained by a lack of constructive alignment in the programme, which limits up front planning as there is a lack of a clear learning outcome and, therefore, a clear view on how to achieve that outcome. We noted, in the course of this data collection that police trainers were afforded only a limited amount of time to plan and reflect. While this needs further investigation, a lack of planning time along with a programme that is not constructively aligned could explain much of the issues we have identified here. We are aware that the results here are critical of the trainers we have observed; however, these trainers were experienced and open to observation. We suggest the issues identified are more about limits in original design than in trainer capacity. However, in order to achieve transformations in coach delivery, coach development in police training should expose police trainers to alternative contemporary pedagogical approaches to skill learning. This should include first-hand experience of and reflection on the pedagogical tools available to coaches and the teaching of the learning theories underpinning the pedagogy. Likewise, traditional pedagogies and their genesis within the knowledge structure of the coach should be reflected upon, in order to check and challenge current practice (Cushion 2020 ; Hoy and Murphy 2001 ).

The de-escalation and communications module is not part of police training, instead the subject of Psychology is in charge of teaching the recruits these skills (Hessische Hochschule für Polizei und Verwaltung 2016 ).

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All authors substantially contributed to the current study and the final manuscript. The study was designed by MS, AA and SK. Data was collected and analysed by MS, SK, VH, IK. MS wrote the first draft of the manuscript. SK, AA and JP provided substantial feedback to the manuscript and helped to reach the manuscript reach its final form.

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Staller, M.S., Koerner, S., Heil, V. et al. The Structure and Delivery of Police Use of Force Training: A German Case Study. Eur J Secur Res 7 , 87–112 (2022). https://doi.org/10.1007/s41125-021-00073-5

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Facebook account takeovers are targeting people you know, turning friendship into fraud

Go public finds dozens of instances of the same scam running rampant on the site.

Social Sharing

For three days, Lesa Lowery says she could do nothing but watch as a fraudster impersonated her on Facebook, swindling her friends out of thousands of dollars for goods that didn't exist.

The entire time Meta — the company behind the social media site that has billions of users worldwide — ignored the crime.

"I just felt helpless," said Lowery, who told Go Public her account was taken over by the fraudster in early March. "I literally sat there and cried," she said.

"I felt really bad for everybody whose money was taken." She'd connected with hundreds of people on Facebook, many of whom she'd lost touch with in person.

• Got a story you want investigated? Contact Rosa and the Go Public team

A Go Public investigation found Lowery is one of many being targeted by a scam the social media giant is allowing to run rampant on its site.

Here's how it works: After locking a user out of their account, the scammers begin impersonating the user and claiming an elderly parent has moved into long-term care and that they are selling off some belongings.

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"It was a multitude of really good things — hot tubs, trucks, tractors and all these people were messaging," Lowery, from Sussex, N.B., said of the post on her Facebook page.

She could see the posts offering items for sale, but wasn't able to access the direct messages people were sending the scammer.

It's called an account takeover. Once the account is hijacked, the attacker can post publicly and access the victim's contacts and private messages.

It's just one example of big social media players, including Meta, making billions from users while failing "to protect them in such a basic way," said cybercrime expert Claudiu Popa, author of The Canadian Cyberfraud Handbook and a cybersecurity expert who advises government and companies.

Meta — which also owns Instagram, Messenger, Threads and WhatsApp — made about $185 billion Cdn in revenue last year, a 16 per cent year-over-year increase, according to its 2023 annual report.

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"There is no customer service," Popa said. "And as a result, what starts as a small issue is exacerbated into a massive identity theft or identity fraud."

In an email to Go Public, Meta said it has "over 15,000 reviewers across the globe review potential violations on Facebook and Instagram," noting that they receive "in-depth training."

But it didn't say why its systems are failing to catch the retirement home scam that's all over the site.

Read Meta's response to Go Public here.

'Embarrassed that I had fallen for it'

In Lowery's case, the scammer accessed her account after sending an email that looked like it was from Facebook.

It said her account had been compromised and that she needed to change her password. When she clicked the link in the email, she was asked to input her old password and choose a new one.

Now armed with her password, the fraudster was able to access Lowery's account and take it over, locking her out.

When she was finally able to regain access to her account days later, Lowery found that her online friends had been swindled out of a combined $2,500 in the form of deposits for the items they thought they were buying.

Lowery says several of her friends reported the crime to Facebook as it was happening, but Meta did nothing to stop it.

When they tried to post warnings on the page itself, the scammer would delete the warnings and block them. Lowery's former neighbour, Carol Stevens, lost $250.

The two hadn't seen each other for years after Stevens moved away, but they kept in touch through Facebook.

"I never felt pressured. I never got the feeling that I had to be rushed to put a deposit down," Stevens said about her online conversations with the fraudster.

"I would not have fallen for it, except that I thought it was my friend Lesa and she's the most honest, trustworthy person I know."

Stevens intended to buy more, but was tipped off to the scam when the bank receipt she got from the first e-transfer she sent on Mar. 6 had a name on it that she didn't recognize.

"I felt embarrassed that I had fallen for it," said Stevens, who reported the crime to the Canadian Anti-Fraud Centre (CAFC).

"I didn't realize that someone could take over a page … and then pretend they were them in a chat on Messenger."

Go Public confronts scammer

More than 16,000 Canadians reported being victims of cyber fraud in 2023, totalling almost $429 million in losses according to the CAFC.

The highest fraud losses on record, according to the organization. And that's just the tip of the iceberg. According to the CAFC website, only an estimated five to 10 per cent of fraud is ever reported.

Go Public found dozens of other fraudulent posts on Facebook using the same scam to trick users out of money by making them think they're dealing with trusted friends.

Many of the posts use the same wording and even the same photos. Posing as a customer, Go Public contacted several of the scammers behind the fraudulent posts, asking to buy generators that were posted for sale between $800 and $1,500.

One responded within minutes, impersonating the Facebook account owner for about an hour while negotiating the price, and even offering to deliver the item.

The fraudster asked for a $300 deposit to be sent through online payment service PayPal. 

When Go Public revealed we were investigating Facebook frauds and asked why they were scamming people and if Meta had ever shut them down, the fraudster replied with a smirking emoji.

AI fuelling fraud

Cybercrime expert Popa says scammers are using artificial intelligence-powered servers to identify potential victims and their email addresses, and to create emails that are specific to the social media sites people use, or the businesses they engage with.

"If you've got the right logos and the right username … people are more likely to click and get infected and get defrauded," he said, noting that AI can also be used to match someone's writing style and tone.

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A U.K.-based tech market research agency, Sapio Research, surveyed more than 600 senior cybersecurity experts from U.S. companies last year.

The majority saw an increase in cyberattacks in the past year, and 85 per cent of those believe those attacks were likely powered by AI.

Regulation needed: expert

In March, a group of 41 U.S. state attorneys general demanded that Meta provide support for users after a "dramatic and persistent spike" in complaints about account takeovers, exactly what happened to Lowery.

They noted Meta's massive layoff of around 11,000 employees in November 2022, which reportedly focused on the "security and privacy and integrity sector."

Meta responded to the group, saying it's taking steps to address account takeovers. But it's not clear what those steps are.

Meta announced layoffs of another 10,000 employees in March 2023. When Go Public asked if all the layoffs impacted the company's ability to respond to fraud, Meta did not answer the question.

Instead, the company said, "To detect malicious activity and help protect people … we also constantly improve our detection, enforcement and support systems."

Expert shares advice on avoiding common scams

Popa says regulations are needed for organizations like Meta that collect sensitive data, and he says companies should be required to have customer service in place to deal with fraud quickly.

"Whether it's human or an AI, the organizations need to respond to people's actual needs," he said.

Go Public asked Public Safety Minister Dominic LeBlanc and Public Safety Canada if regulations are being considered. They didn't answer the question.

Until that happens, Popa offers this advice for staying safe online:

• Create shortcuts to your favourite sites and always use them to access your top sites and accounts, so you never have to depend on links from emails that could easily be fake.
• Never reuse passwords and always use two-factor authentication. "Convenience is the opposite of security," he said.

A Facebook hack cost her friends thousands. The company did nothing to stop it.

As for Lowery, she was only able to get back into her account days later, when Facebook asked her to confirm her identity by uploading a photo and official identification — in her case a passport.

Both Lowery and Stevens say Meta should be doing a better job of responding to fraud on its platform.

"When Facebook first came out, it was a great way for people to keep in touch with people. It wasn't a multitude of ads and scams," Lowery said. "They should start taking control of that."

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She says she can't help but blame herself for falling for the scam, but knows she's one of many that get sucked in.

"I always thought I was so Facebook savvy, you know, that would never happen to me," she said. "But it's so easy."

Lowery has since shut down the account the scammer used and opened a new one that only includes friends she keeps in touch with outside of Facebook.

She and Stevens reported what happened to New Brunswick RCMP and the Canadian Anti-Fraud Centre, but haven't heard anything since.

Submit your story ideas

Go Public is an investigative news segment on CBC-TV, radio and the web.

We tell your stories, shed light on wrongdoing and hold the powers that be accountable.

If you have a story in the public interest, or if you're an insider with information, contact  [email protected]  with your name, contact information and a brief summary. All emails are confidential until you decide to Go Public.

Read more stories  by Go Public.

Read about our hosts.

ABOUT THE AUTHOR

Rosa Marchitelli is a national award winner for her investigative work. As co-host of the CBC News segment Go Public, she has a reputation for asking tough questions and holding companies and individuals to account. Rosa's work is seen across CBC News platforms.

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