Report 2021-105 Recommendation 63 Responses

Report 2021-105: Law Enforcement Departments Have Not Adequately Guarded Against Biased Conduct (Release Date: April 2022)

Recommendation #63 To: Stockton Police Department

To ensure that it adequately investigates possible biased conduct and implements effective corrective actions, Stockton Police should ensure that by January 2023 it has formalized policies - such as through discipline matrices or broader discipline guidelines - specifying options for corrective actions beyond punitive discipline that are designed to change officer behaviors associated with biased conduct. The department should require that, when appropriate, these corrective actions—such as training and education—be part of the discipline that officers receive when they are found to have engaged in biased conduct.

Annual Follow-Up Agency Response From April 2026

Previously implemented.

Status: Fully Implemented

SPD formalized a range of corrective actions designed to change officer behavior associated with biased conduct.

Policies and Procedures Implemented

Policy 1009 - Personnel Complaints

Requires supervisors to consider corrective actions such as:

- Targeted training

- Coaching

- Counseling

- Performance improvement plans

- Increased supervisory monitoring

Policy 1028 - Early Warning System

Ensures early, non punitive interventions for flagged employees.

Policy 1045 - Performance Tracking

Supports identification of training needs and behavioral trends.

Training Used as Corrective Measures

- Procedural Justice

- Beyond Bias

- Why'd You Stop Me?

- ICAT

- POST Supervisor and Management Schools

California State Auditor's Assessment of Annual Follow-Up Status: Pending

The policies Stockton cites in its response are not in alignment with the recommendation. Specifically, the recommendation was for Stockton to specify precise non-punitive measures that will be considered options for changing officer behavior and require that officers found to have acted in a biased manner receive training and education. Stockton's policies do not feature these elements.


Annual Follow-Up Agency Response From March 2025

Previously implemented. Noted in previous report.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Stockton asserts that it has already implemented this recommendation. It provided no additional documentation to change our previous assessment.


Annual Follow-Up Agency Response From October 2023

When Bias investigations conclude, the Department will review the potential related training and education available and consider it for the discipline recommended. To include training and/or education as part of the discipline received, has been a practice at the Stockton Police Department.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Stockton PD reported to us that it does not have a policy that specifies options for corrective actions beyond punitive discipline.


All Recommendations in 2021-105

Agency responses received are posted verbatim.