Crisis Timeline and Law Enforcement

Our guests describe the parts of the crisis timeline and the role of law enforcement in school safety.

Guests: Chris Melde and Katherine Schweit

Comprehensive School Safety Planning Series Description

In this series, guests describe the importance of having a Comprehensive School Safety Plan, explain different perspectives on school safety, and highlight the connections between school safety strategies.

Other episodes in this series:

• Episode 1: What is School Safety
• Episode 3: Distance Learning, Part 1
• Episode 4: Distance Learning, Part 2
• Episode 5: Restorative Practices, Part 1
• Episode 6: Restorative Practices, Part 2

Episode 2 Transcript

Katherine Schweit: I’d love for more people to spend more time talking to School Resource Officers. They’re in a unique position to be able to move around the school, talk to anyone and do anything at any time of day, but I wonder how many faculty and administrators say more than hello to them, and ask them actually about their job and ask them how they can help, and interact.

Brent Miller: Hello and welcome to Progress Report, a podcast produced by the National Center for School Safety, the STOP School Violence Program National Training and Technical Assistance Center, funded by the Bureau of Justice Assistance. The center is a project of the University of Michigan School of Public Health. Thank you for tuning in to this series, on comprehensive school safety planning. We hope listening helps you recognize the importance of planning, understand the different perspectives on school safety and discover the connections in how various disciplines approach school safety.

In this episode, you’ll hear about the different parts of the crisis timeline and the role of law enforcement in school safety. First is Professor Chris Melde.

Chris Melde: I work in the School of Criminal Justice at Michigan State University, where I focus on issues related to youth violence and school safety, broadly speaking, but particular emphasis is on individuals’ perceptions of crime and victimization risk, as well as the role of street gangs in producing violence.

BM: Could you share a little bit more about what brought you to this field and your journey to where you are now?

CM: Actually, as an undergrad, one of my majors was special education, and so I’ve always been concerned with adolescent development, youth development, and especially within school, related to school. I switched to criminal justice thinking more about safety and protecting others, and so that’s always, I guess, been a particular concern of mine. And so really, as I progressed, it was really a natural fit for me to focus on issues of youth violence and school safety more broadly.

BM: Could you talk a little bit about the intersection of what are known as structural interventions, or “hardening,” and human behaviors, or what is sometimes referred to as “softening”? To those who are listening who might not be familiar, what do those terms refer to? And if you have any specific examples or scenarios that illustrate how they’re both important to school safety, that would be great as well.

CM: Yeah, so first on the soft side, these are ones that we oftentimes don’t think about as school safety, because the soft side of school safety is something that oftentimes just comes naturally, it’s part of the natural school environment. Part of the job of the school is to supervise students and building personnel, school personnel, oftentimes, building personal relationships among school staff, but also with the students. So these are just natural parts of the school environment. But supervision and building those personal relationships that really foster open and clear communication across these stakeholders, those are what we refer to as soft school safety strategies. The common elements of soft strategies that focus on school safety and building a positive school environment, include things like having clear school rules, having clear norms regarding behavior across the school and enforcing those rules in a consistent fashion. You’ll often see, when you walk into a school, a bunch of signage that also reinforces what the school expectations are, what the school rules are. That is the soft side of school safety, it’s building those personal relationships and building those community norms that ensure school safety.

On the flip side, when we talk about hardening strategies or what I would refer to as target hardening strategies, these are those things that you can’t mistake oftentime, as a school safety strategy. So these are things like locks on the front doors, locks on individual classroom doors, the buzzers that have a camera on them at the front door that allow the front office to dictate who gets to come into the facility or not. Things like security guards or School Resource Officers, are also part of that target hardening strategy within a school. But physical school safety or these target hardening measures are also not always so clear-cut. They can include things like numbering both the inside, as well as the outside of doors within a school, numbering the doors, the entry doors on a school. And so oftentimes, people may not notice this, but it’s a really important part of the school safety apparatus, these more physical features of the school. So when you see a school, and on the outside and on the inside, it says on an entry door, “Door number 1,” or, “Door number 8,” that’s really there to help ensure school safety.

Here’s an example of a scenario where numbering doors is extremely important. There may be a medical episode or there might be a violence episode within a school environment, where you have people on the inside of the school, who reach out to first responders, who reach out to police and ambulance through maybe a 911 call, to let people know that there’s been an incident in the school. But in some schools, students or staff may refer to particular areas of a school as a particular wing, or there’s been an incident in Mrs. Thomas’s classroom, but people on the outside and first responders on the outside, have no idea where Mr. Thomas’s room is. So really with no effort, within a school, you can make a decision to when you refer to particular rooms or particular sections of the schools or particular doors, to create a norm where you refer to doors or sections of schools with numbers, so that somebody on the inside could say, “There’s been an incident next to door number two,” and in that regard, first responders can plan for that, and there’s also very visual markers of where door number two is, for the school, so that a first responder when responding to that situation, can go directly to that door or to the correct side of the building.

In more serious terms, if there was a school shooting or something like that, the same, really, rules apply where you don’t have miscommunication between people on the inside and people on the outside, about where particular doors are. I know people sometimes refer to doors as being on the west wing or the south wing or the east wing, and I can tell you, when people refer to directions, I’m oftentimes really confused ’cause I don’t pay… I don’t think that way. And so, something as clear or as simple as just numbering doors on both the exterior and interior, really helps, because people on the interior can use that signage as well, to communicate clearly.

BM: Yeah, that seems like a great example of that intersection of both sets of strategies, because on the internal culture side, it’s… We’re all referring to these rooms by their number and we’re getting used to that, and so, in the case of an emergency, we’d be ready with that information, we would just know, that’s room number two, but that’s also easily accessible to an outsider. So someone who’s an emergency responder coming in, it’s just a very straightforward way of figuring out, “Okay, where do I need to go? Who do I need to help?” So thank you for sharing that. Yeah, I wouldn’t have thought of room numbers as being important, and it sounds like they really could be, in a crisis.

So speaking of folks who might have to respond to something from outside the school, that’s going on inside the school, could you tell me a little bit from your perspective, about the law enforcement point of view, on different parts of this crisis timeline? When I say that, I’m referring to prevention, crisis management and post-crisis. I think there are other terms that it might encapsulate, but I’m really curious about the law enforcement perspective on that.

CM: Absolutely. Law enforcement is tasked to do a lot of jobs in society, and so they have a lot of different roles, and not every law enforcement community and not every school community uses law enforcement in the same way. But they can play a role across all the parts of the crisis timeline, including prevention. A number of schools, a lot of schools across the country, utilize law enforcement as part of a prevention strategy, and so, they can be a part of what we refer to as that soft side of crime prevention, and that a number of SROs may be on campus on a daily basis or a few times a week, some of them may be tasked with delivering parts of different curriculum. That might have to do with things like crime prevention, school safety, drug prevention.

A classic example would be the D.A.R.E. officer who’s in school quite frequently to deliver that program. So law enforcement oftentimes, in that role, in the prevention role, are oftentimes really trying to open up lines of communication between students and law enforcement, to get students to feel comfortable with law enforcement and to improve attitudes towards the police, things like that. But from a prevention standpoint, law enforcement oftentimes plays a deterrent role as well, and these are both on school campuses where they might in the morning or in the afternoon, really be helping to offer as a gatekeeper and monitoring the flow of people in and out of a building, but also at school events, at football games and basketball games, things like that, you’ll oftentimes see police there. And part of that is simply deterrence.

From a crisis management standpoint, that’s where we really see the role of law enforcement is in its traditional sense, in the sense of responding to calls for service and managing particular safety situations, and really, that is the role of law enforcement within our communities more broadly. So that’s oftentimes what we think about as the role of law enforcement, they’re trying to mitigate a threat to ensure public safety, they’re conducting investigations, things like that. But another critical aspect of law enforcement is also post-crisis, because we look to law enforcement to communicate why an incident may have occurred and whether an incident might occur again in that same location.

In a crisis, we oftentimes… What you’ll find is, people are gonna be leery about going back to that school environment, especially if they don’t have any information. And so, law enforcement oftentimes is our… Is looked upon to be a communicator about the threat, about whether the threat has been mitigated and the safety concerns that people may have in going back to school. And so they really play a part across this entire crisis timeline, and we look to law enforcement oftentimes to ensure that schools are kept safe.

BM: That’s something I hadn’t realized until you mentioned it, but when there is a crisis that occurs in a school, oftentimes, the first people to speak about it are law enforcement officials. A lot of folks listening are either maybe interested in developing a comprehensive school safety plan, or are potentially already working on one. So I’m wondering if you have any advice that you’d give folks, who are just starting out, and then maybe folks who are already in the thick of it.

CM: Absolutely. So one, there’s a lot of excellent resources on implementing comprehensive school safety plans within schools. These include the effective use of those physical safety measures that we talked about previously, as well as those that incorporate the softer side, the social measures that create a positive school environment. One thing that I would recommend schools consider, is incorporating what we refer to as Crime Prevention Through Environmental Design. You’ll often hear this referred to as CPTED, because this literature really is very intentional and about how it marries the soft and hard dimensions of school safety, really looking to reduce the opportunities and the likelihood of problematic behaviors. There’s also a growing literature on training in restorative practices, as well as training in the role of SROs in schools. Learning from mistakes of how SROs have been incorporated in the past and learning about effective planning for when schools want to include an SRO is to recognize some of the potential harms that could come about or really unintended consequences of an SRO, and any negative consequence that they could have on school.

And so, just as an example there, one of the issues that has been noted about SROs is the likelihood of formal sanctioning for what otherwise would have been a typical school incident. So if there’s a conflict in school and an SRO is involved, there’s the potential that you may have an arrest record or there might be the potential for an SRO to intervene in ways that other students elsewhere in schools that don’t have SROs or an incident that otherwise, before the SRO arrived, would have been handled informally.

And so really, this upfront work in understanding the role of SRO’s, understanding the roles of restorative practices, those are coming much more to the fore, and there’s a lot of resources on the most effective use of these different resources within schools.

BM: For folks who are sort of in the middle of working on things, is there anything else you’d like to share for them, as they are making progress on their school safety planning?

CM: Yeah. So one of the critical things about coming up with a comprehensive school safety plan, one of the… A bit of advice that I would offer is, be intentional about understanding the nature of your school safety issues, take an inventory, the types of data your school collects, that can help to pinpoint the times, places and actors that lead to the most problems. Talk to all your school stakeholders, to gain an understanding of the safety concerns they have and that they have or have experienced, or even that they’ve heard about. You can triangulate across all these sources of information to be sure that your plan can effectively address the most pressing issues in the school. Not all stakeholders will agree where the problems are… What the problems are, where they’re located, or even what times of day are most problematic. But collecting systematic data and understanding the types of data that you’re using in consideration of your comprehensive school safety plan, is important.

For example, where do issues occur before school? Where do issues occur during the school day? What about immediately after school? Are there patterns in the data that you’re already collecting or that you have access to, that can shed light onto those problems? Is there something about the physical location that creates the problem? Is there something about the social dynamics of the school that leads to the conflict? And can simple changes and procedures reduce the threat of those social conflicts occurring? Can simple changes to school practices eliminate the opportunity for conflicts? Other things to look at is, do problems occur in particular classrooms, among particular cohorts or grades of students? And are there differences across these factors that could really lead to different remediation strategies or targeted remediation strategies, that would reduce the overall rates of harm or misbehavior that are occurring?

And so really, in sum, if you’re confident in the nature of the problems, you’re gonna be more confident in the solutions to those problems. And so, taking the time to really gather as much information, where you can be confident that you’re addressing the harms that are there, and the problems that are occurring in your school, the better. On the flip side of that, there are times when individual teachers, individual staff members, may have their own ideas about what problems are in school, but again, not everybody may agree. And so, if everybody is trying to address problems that they think are the most pressing, you really then fail to have that comprehensive strategy, where people have a really good understanding of what’s going on, and that oftentimes might lead then to ineffective strategies being put in place, because it’s not really targeting the problems that are there.

BM: Well, Chris, I really appreciate you taking the time to talk to me today. And well, have a great rest of your day and thanks again.

CM: You too. Thanks Brent.

BM: Take care.

That was Chris Melde, a professor in the School of Criminal Justice, at Michigan State University. Next is Katherine Schweit, an attorney, a former FBI agent and journalist.

KS: As an FBI agent, I worked on national security matters like 9/11 and bank robberies and espionage cases like every FBI agent works, and when the Sandy Hook shooting occurred in December of 2012, there were 20 children killed and six staff, female staff at the school, plus the shooter’s mother, and suddenly, the world was aware of this horrible situation that we had, about how safe are our schools when we send our children there. I think we always worry about that, but I think, after Sandy Hook, everybody was so traumatized by the death of those children and how quickly it occurred and what police could have done, that I became part of the then Vice President Biden’s White House team, that was working on how to look for ways to improve school safety and train students and faculty. It just became kind of a permanent full-time job, and so I shifted from national security and all I did was school safety matters, business safety matters, and I became the FBI’s lead in all things, active shooter and mass shooter.

So I think that when you talk about school safety, and I think if you start from the position of school safety is everybody’s job, even the students, so school safety is everybody’s job, everybody has a role in prevention, everybody has a role in response, everybody has a role in recovery. For law enforcement, prevention is in some ways, kind of the trickiest part, because in the response and recovery, that’s what people see, you see it in the movies, and you see it on television, you see it in your neighborhood, when an ambulance arrives, when a fire truck arrives, when a police officer arrives and the lights are flashing on your cars, and I’ve certainly, as an FBI agent, spent plenty of time moving to the scene with lights and sirens, running and getting to the scene and I know my job when I get there, I know whether I need to pull my gun out or whether I need to handcuff somebody, and the firefighter knows whether they need to start dropping hoses at the fire hydrant down the road.

People, I think, are more familiar with the law enforcement role in response and recovery. I think it’s the role in prevention that is so important right now, to targeted violence, to school safety, because the law enforcement response sometimes, in general, I think the public thinks, “Oh if we call the police, they can prevent this.” But law enforcement, whether they’re federal, state, local or tribal law enforcement, have limited authority when it comes to situations. So from a prevention standpoint, law enforcement is just a part of it. Law enforcement might be one of the last who actually knows that something bad is gonna happen.

So the prevention part of it, even though law enforcement is key because they can intercede and they can make arrests, the prevention part of it, is so dependent on see something, say something, it’s so dependent on the public taking responsibility, and I think this is, and particularly for me, one of my causes. I have a book that I wrote, that is exactly about that, is that the public has to take responsibility for this, and the book is called Stop the Killing, that’s exactly what it’s about. It’s that everybody has to be part of it, but law enforcement can’t be the answer to prevention.

I work all in this space, and I hear… I have conversations with people all the time, and I think it’s very easy for people to say to me, I hear all the time, “Well, you can’t prevent it ’cause you can’t predict it,” and, “You don’t know what’s coming,” and, “There isn’t anything I could do about it.” That’s really the wrong way to think about it, because all of prevention, all of response and recovery, requires pre-planning. Think about the Emergency Operations Plan in your business or in your school building. There’s an Emergency Operations Plan that’s out there. When’s the last time anybody looked at it? It’s a binder, in the old days, it was a binder or paper sitting in some three-ring binder, sitting on somebody’s shelf with dust on it, and today, that same crazy three-ring binder document is now electronic and nobody accesses it, and it’s in some electronic file someplace in some HR or you don’t really know where. My advice is, look that up and see what your role is and see what your responsibilities are on that, because that pre-planning, whether it’s for prevention response or recovery, is there, it can be done. What are the phone numbers to call and who are the people in the neighborhood who can help you, where can you have your business… Whether it’s school or another business, where can that move to, temporarily.

I worked a couple of cases in Wisconsin, as an agent, we had bomb threats called into a school. The school was evacuated down the road to the high school, and then the high school had bomb threats called in to it, so then those kids… The high school kids and the middle school kids who were there, had to evacuate to a third location. You gotta plan, you gotta plan for contingencies, and I think sometimes, that you think, “Oh, something… I don’t know what will happen and I’ll respond to it when I do.” No, you can plan for almost anything, you just have to think about it ahead of time, tabletop it, have a discussion about it.

BM: From your perspective, what does great coordination look like? Specifically, who’s involved? What are some things that are happening?

KS: Oh, that’s a great question, because I think that people have a tendency to put coordination and planning and preparation at the very bottom of their list. I’m gonna do what I need to do today. Say, if you’re an administrator, you have three phone calls that you don’t necessarily wanna make and two meetings that you don’t wanna attend, but you do it anyway because it’s your job, and you attend those meetings and then you have to document it and you write those things up, and then still on your to-do list is, “I really should look at that Emergency Operations Plan. I really should take the opportunity to meet the School Resource Officer, and I really should take the opportunity to come up with a list of things that maybe I can talk to the faculty about, in our next staff meeting, that have to do with school safety,” and that’s always at the bottom of your to-do list. And then you always feel like it’s not really actually your job as an administrator, because that’s really the job of the facilities person or the SRO.

When you asked about the role, I think that everybody stovepipes their role and that’s very common. Your job, you get paid to do your job, and you don’t necessarily get paid to support other people’s jobs. But in order to have good planning and preparation, you have to support other people’s jobs. When the SRO says, “I’d like an opportunity to meet with you,” you need to step up and make that opportunity happen. When the faculty member says, “There’s no window coverings on my windows, and the school has been open for two years now,” you need to say, “Hey, what do we need to do, to get this taken care of?” You need to take responsibility for things that maybe you don’t necessarily see as in your lane by supporting the people who have it in their lane.

I also think that it’s really important to spend time one-on-one with each other, chatting with each other, table-topping. And by table topping, I mean sit around a table. One of the simplest things you can do is, say, for instance, at a school, at a faculty meeting or administrative meeting, take the opportunity to talk specifically about what you’re concerned about. Ask people, “What do you worry the most about, when you come to the school? What do you worry the most about, when you’re leaving school?” If you don’t talk to each other, and I know that sounds kind of commonplace, but you won’t really understand what the role of somebody else is. In my consulting work, I find a lot of times that I’ll talk to somebody and say, “What will you do in this situation?” and they’ll say, “I will do A, B and C.” And when they explain what A, B and C is, sometimes they can’t do those, they don’t have the phone numbers to make the calls, or at that somebody else’s responsibility, or they say, “I don’t do that, because that’s Joe’s job.” And then I go to Joe and Joe says, “I don’t do that, ’cause that’s Sally’s job.” So communicating allows you to know who has what role during an emergency.

BM: Is there anything else you wanna speak to, with regard to training or how training supports this coordination and this prevention?

KS: Yeah, I’d just love to put a bow on the fact that training is a non-stop situation. If you view training as a one event, one hour check-a box, because there’s some state statute that requires you to have that type of training, or the school board has approved that type of training and you view training as a check box, one hour thing, you may as well not do it at all. Training is something that should be done on a regular basis. I know, one of the companies that I’ve worked with, has a policy of, before every meeting they talk for five minutes about security matters, and I think it’s just brilliant, it’s just… They make one little point about security matters, and that also takes a little pre-planning, little pre-planning in the school situation.

Maybe the SRO comes up with a list of 20 security items that are just a couple of minutes, to talk about where the exits are, where to look for the Emergency Operations Plans, what to do if there is a concern about a student who might want to self-harm and other things like that, what do you do if the system’s locked, the alarms go off, the water systems fail, or the water… Or the fire suppression systems go off, what are those safety factors that you can tell your faculty and staff, in a non-emergency time, which is five minutes at the beginning of a meeting. It’s just a great example of it. But training is a constant thing. I say that as a law enforcement officer who carried gun for all those years, if I just viewed my training as the one time that I go to qualify, and in fact, the FBI qualifies four times a year, but a lot of law enforcement agencies might qualify one time a year, if that’s the only time you ever pick up your gun and shoot, you’re not gonna be very good at it. Training is more than that.

BM: You’ve mentioned School Resource Officers a few times, and I was wondering if there’s anything you think is important for folks, who maybe are just starting out with a School Resource Officer, maybe who are interested, if there’s anything you think they should know about an SRO. And then I also know you’re working on a project with the National Center for School Safety, that I would also love to hear about.

KS: SROs are just Police Officers, and a lot of people see them that way, and they say, “Well, the Police Officers know a lot of things and they have their own job and then I have my own job,” instead of realizing that a School Resource Officer is one more adult member of the team, in a school, who brings just different skill sets, just like it takes a math teacher and it takes a Science teacher, and it takes an English teacher to teach students, it takes all those different faculty members, including the School Resource Officer, to bring about school safety and for the students and the administrators and the faculty. So I think School Resource Officers are often not really used as well as they could be because they’re just viewed potentially as… Or I fear they would be viewed as disciplinarians alone, when in fact, they’re a role model for students, and they should be one of the many role models in a school, to show students how you can be successful adults, follow the rules, if you’re talking about elementary school kids, or not being afraid, if you’re talking about high school kids.

Right now, a lot of people are struggling with the role of law enforcement and pretty similar to what I saw, when I was growing up in the 60s and the 70s, and the more that you take the roles away and you talk to each other as people, the easier it is to break down some of those struggles and the barriers about fear and, “Are you gonna do this to me? And I’m afraid to come and talk to you?” particularly with a high school child. You have a high schooler who might know things and they’re afraid to come and talk to the police about it, because they don’t know what the police will do to them. That’s important, to recognize that, as SROs and tackle that head on. The SROs are the adults, they need to tackle that head on.

I’m working… My company is working with the National Center for School Safety, we’re putting together half a dozen digital shorts and supporting materials that come behind them, so that we have an opportunity to kind of provide micro-training, not only for law enforcement who might be in the schools, like School Resource Officers, or those who might interact within a school, so any law enforcement, but then also, I think that they’ll cross over… This is what I was talking about earlier, about crossing over on roles. We hope that the digital shorts will be as valuable to administrators and to school counselors, to teachers, to see how the students might see things or how an SRO might see things.

So the shorts are designed to help train and educate the School Resource Officers in specific things, with regard to kids. So for example, some of the subject areas are, “What is the teen brain like and how does it develop?” Even though you think that’s complicated, you might think that’s complicated, we do it in three minutes, we can say, and something that a SRO or a faculty member can watch on their phone, listen to, with their earbuds in their ears, three minutes of, “Hey, this is… Teen’s brains are different, they’re developing in a different way, and here are some ways that you can deal with them.” So each digital short is set up to say, “Here’s a situation you might not be familiar with, because these are younger people than you usually deal with, and here are some good ways that we can help, we’d recommend, based on experts… Based on experts, how we’d recommend that you interact with these teens.”

But hopefully, the digital shorts will provide an opportunity for the SROs to learn better how to understand and support students who have perhaps cultural differences, look differently, sound differently, act differently, eat differently, they have mental health issues, they might have developmental challenges, and with the SRO being more aware of these, if they don’t have exposure to them, we hope that this will allow them to resolve issues that might come up in the school, where faculty are reaching out to them to say, “Hey, we have this student. There’s this problem. Can you help us?”

But also a second part to that, we want the digital shorts not just to educate the School Resource Officers and other adults in how to interact with teenagers, essentially, and young people, but also we want the digital shorts to show the School Resource Officers, their responsibility to be part of the learning environment in the schools and how they can bring what they have, as law enforcement officers, to the table to help these young people grow up in a strong environment, not an environment where they might be bullied because they’re different, not an environment where they’re scared because they don’t know how to react to law enforcement, not in an environment where they fear that they don’t have a reason to live, and so they become suicidal. So we think that law enforcement can provide a very strong support system, just like counselors in the school and faculty and staff can.

BM: Thank you so much, Kate. Is there anything else you’d like to share with our listeners?

KS: No, I just wish everybody a great school year. I think we’re in for good, positive things to come.

BM: Our guests in this episode discussed the phases of the crisis timeline and the difference between structural interventions or hardening strategies, and human behavioral interventions or softening strategies. They also shared their thoughts on collaboration with law enforcement and the role that School Resource Officers can play in protecting schools. If you’d like to learn more that may help in your context, you can check out the following freely available resource from the National Center for School Safety. The video, School Safety and Crime Prevention Through Environmental Design, in which Christine Kofsky discusses the benefits of CPTED, the six components that make it up, and key findings from school principals, who implement CPTED strategies.

Thank you for tuning in to this episode. For more information about the National Center for School Safety, visit our website, nc2s.org. You can also check us out on Twitter and Facebook. This episode of Progress Report was produced by the National Center for School Safety, at the University of Michigan, School of Public Health. Additional resources and information can be found in the show notes. And music is thanks to Makaih Beats.

This project was supported by cooperative agreement Number 2019-YS-BX-K001, awarded by the Bureau of Justice Assistance. The Bureau of Justice Assistance is a component of the US Department of Justice’s Office of Justice programs, which also includes the Bureau of Justice Statistics, the National Institute of Justice, the Office of Juvenile Justice and Delinquency Prevention, The Office For Victims of Crime and the Office of Sex Offender Sentencing, Monitoring, Apprehending, Registering and Tracking. Points of view or opinions in this document, are those of the author and do not necessarily represent the official position or policies of the US Department of Justice.