The Citizens Police Oversight Commission (CPOC) is proud to announce the release of its Audit Report on the Philadelphia Police Department’s Internal Affairs Division (IAD) investigations of Complaints Against Police (CAPS) in 2024. This comprehensive audit aims to shed light on the police misconduct investigative process, identify areas of strength, highlight opportunities for improvement, and provide recommendations.
CPOC’s Auditing, Policy and Research Division systematically reviewed and assessed IAD investigations for thoroughness, completeness, and objectivity. The report focuses on 357 cases.
Overall Feedback
The report highlights several positive aspects of IAD investigations, including proper subject officer identification, generally unbiased writing in investigative reports, and the obtaining of video evidence within retention periods. Areas of improvement focus on making sure that all allegations made by complainants are addressed in investigative conclusions and the need for standardizing investigation policies to ensure consistency across cases. “Generally, the data in the report demonstrates that IAD is performing well in some aspects of investigations, while also highlighting several key areas for improvement. To best serve the public, we have identified specific concerns, and we are committed to working with IAD leadership to follow up with meaningful solutions,” said Janine Zajac lead writer and the Director of CPOC’s Auditing, Policy, and Research Division.
Recommendations
The reviews detailed in this report resulted in seven concrete policy recommendations from CPOC, aimed at improving the consistency of IAD’s investigations of complaints against police. These recommendations seek to standardize investigative practices where possible, ensuring fairness for both complainants and officers. CPOC looks forward to working with IAD, where appropriate, to develop policies that are responsive to these recommendations.
In the report, CPOC provides seven recommendations. Here are a few featured recommendations:
1. IAD investigators should begin audio and/or video recording all interviews they conduct in their investigations to remove the burden of live transcription and allow for the free flow of information and follow up questions during interviews.
2. IAD does not have a policy related to virtual interviews. CPOC recommends IAD develop a policy related to virtual interviews for civilian complainants and witnesses to increase accessibility and efficiency.
3. IAD should develop a policy to instruct investigators to address violations by police that emerge in the course of an investigation even if they are outside of what is alleged by complainants.
“Through the release of these audit results, CPOC seeks to continue the positive working relationship with IAD and IAD leadership,” said CPOC’s Executive Director Tonya McClary. “There have been observable improvements to IAD investigations since the implementation of live audits, and CPOC remains committed to working alongside the PPD to ensure that police misconduct investigations in Philadelphia uphold the highest standards of thoroughness and impartiality.”
New to the Auditing Process: Live Audits
This is the first report to reflect the new “live audit” system, the result of a partnership established in July 2024 between CPOC and IAD leadership. The revised process requires IAD to send the entire case file for a completed investigation to CPOC for review before the disciplinary process has concluded. In the past, IAD shared only the final report of an investigation (PC memo) and did so after the process had concluded, leaving no opportunity for feedback to inform the case.
• The ability for CPOC staff to make recommendations for changes to an investigation before its closed allows direct oversight of the CAP investigation.
• Of the 357 cases reviewed, 133 were live audits, allowing CPOC to make recommendations before cases were finalized.
• In the 133 live audits, CPOC issued a total of 238 recommendations. Investigators respond to these recommendations, and the Deputy Commissioner overseeing IAD makes the final decision on case updates. IAD fully accepted 66 recommendations, partially accepted 16, and disagreed with 98.
Auditing Standards and Procedures for Complaints Against the Philadelphia Police Department
To learn more about CPOC’s procedures for auditing CAPs, the Auditing Standards and Procedures for Complaints Against the Philadelphia Police Department is available on Phila.gov/CPOC.
About the Citizens Police Oversight Commission
The Citizens Police Oversight Commission (CPOC) is an independent civilian oversight agency designed to advance the just, transparent, and efficient administration of criminal justice in Philadelphia. CPOC is committed to conducting fair and timely investigations into police conduct, enhancing the quality of internal investigations, and fostering community engagement and trust.