Clark Atlanta University
Riot-Precipitating Police Practices: Attitudes in Urban Ghettos
Author(s): Harlan Hahn and Joe R. Feagin
Source: Phylon (1960-), Vol. 31, No. 2 (2nd Qtr., 1970), pp. 183-193
Published by: Clark Atlanta University
Stable URL: http://www.jstor.org/stable/273723
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By HARLAN HAHN and JOE R. FEAGIN
Riot-Precipitating Police Practices:
Attitudes in Urban Ghettos
PERHAPS the major domestic conflict of the 1960's was produced by
the urban confrontation of predominantly white police forces and
expanding black communities. From an historical legacy of mutual resentment and mistrust, underlying tensions eventually erupted in massive hostilities and riots. Not only were policemen and black ghetto residents principal antagonists in civil disorders, but the animosities between
them also were a significant impetus for violence.
With only a few exceptions, every major incident of urban violence
was triggered by the police. As the President's Commission on Civil Disorders concluded, "Almost invariably the incident that ignites disorder
arises from police action."1 Frequently, the outburts were stimulated by
routine and commonly accepted police practices rather than by gross
instances of injustice. In nearly all cases, however, the particular act of a
policeman which precipitated the disturbance simply sparked a smoldering residue of suspicion that could not have been dampened forever.
Black hostility toward the police became so common and so intense that
the mere presence of a white policeman performing routine duties in the
ghetto, when coupled with other conditions conducive to unrest, often
was sufficient to ignite explosive violence.
Although the relationship between the white police and the black
ghetto had received surprisingly little attention until the outbreak of recent civil disorders, few observers have doubted the existence of a longstanding tradition of criticism and disrespect for the police in the black
communities of the North as well as the South.2 Most studies of Negroes
- in cities that have not experienced riots as well as those that have
erupted into violence - have demonstrated a widespread and volatile reservoir of antipathy toward the police. To cite some illustrative examples: a 1966 Harris survey revealed that 41 percent of Negroes in the
North and West felt local police to be more harmful than helpful in the
cause of Negro rights. Most of the other respondents were uncertain. And
a 1965 Detroit survey disclosed that 58 percent of the Negroes there felt
that law enforcement was not fair. Similarly, a survey after the 1965
Watts riot found that 41 percent of the black residents thought that the
job being done by the police was "not so good" or "poor." Such data are
particularly striking when one considers that a national NORC survey
found 77 percent of the general population evaluating the job police are
Report of The National Advisory Commission on Civil Disorders (Washington: Government
Printing Office, 1968), p. 93.
2Cf. Gunnar Myrdal, An American Dilemma (New York, Paperback, 1964), pp. 540 ff.; and
A. I. Waskow, From Race Riot to Sit-in (Garden City, 1966), pp. 204 ff. and passim.
183
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184
PHYLON
doing in their neighborhoods as "very good" or "pretty good."13
The disapproval of the police expressed by black Americans
requires an improved understanding of the sources of their d
tion if further violence is to be averted. In particular, discus
groes' opinions of the police has revealed an important and pe
lemma that must be resolved before further preventive actio
taken. While Negroes have consistently objected to the petty
and occasional physical brutality of the police, they also have
frequently about the lack of police protection in crime-ridd
neighborhoods. Both the importance of this problem and the
of available data indicate the need to determine the most prevalent
objections to the police voiced in black urban ghettos. Perhaps no group
is more qualified to unravel this apparent inconsistency than black
Americans who have experienced a major riot.
Data for this study were derived primarily from surveys conducted in
riot-torn ghetto neighborhoods shortly after one of the first major disor-
ders (in Bedford-Stuyvesant) and after one of the nation's worst disturbances (in Detroit). The first survey was a "block quota" (modified probability) sample of 200 Negro residents of New York City's Bedford-Stuy-
vesant ghetto interviewed by the National Opinion Research Center
within a few weeks after the 1964 riot.4 The second survey, based on a
stratified quota sample of 307 residents of the Twelfth Street area of Detroit, relied upon similar selection and interviewing procedures and was
conducted within a comparable period of time after the 1967 riot.5 To in8 For summary of these and similar findings, see The President's Commission on Law Enforcement and Administration of Justice, Task Force Report: The Police (Washington: Government Printing Office, 1967), pp. 145-49; Gary T. Marx, Protest and Prejudice (New York,
1967), pp. 36-37; L. Harris and W. Brink, Black and White (New York, 1966-1967), p. 234;
The President's Commission on Law Enforcement and Administration of Justice, The Chal-
lenge of Crime in a Free Society (Washington: Government Printing Office, 1967), p. 99.
4 The following is the description of the sample design given by Paul B. Sheatsley, National
Opinion Research Center Survey Research Director:
Fifty blocks were chosen at random and four respondents were assigned in each
block. On the basis of Census data, 89 men were assigned, and 111 women. Of the
women, 52 had to be employed, 59 not employed. Of the men, 24 had to be aged
18-29, the others 30 or older.
Interviewers were instructed to start at the eighth dwelling unit from the Northwest corner of the block, proceeding clockwise, and to call there and at each
successive dwelling unit seeking men and women to fill their quotas on that block.
If no one was at home or there was no one in the household who met their quota
requirements, they went on to the next dwelling unit. When their quota of four
was properly filled, they started on another block.
All persons 18 years of age or older were eligible for interview, provided they
resided in the dwelling unit. No more than one person was interviewed in any
household. The quota controls insured a proper representation of men and women
and that there would be sufficient employed females and younger males-the most
common biases of the usual quota sample. Although race was not specified, all
respondents were Negro. All interviewers too were Negro.
Thus the sample is best described as a modified probability sample or a quota sample.
5 The sampling process in the Detroit survey was nearly identical to that in the Bedford-
Stuyvesant study with the following major exceptions: All blocks in the Twelfth Street
neighborhood were stratified arbitrarily on the basis of a composite index of socioeconomic
status derived from projections based on statistics for the value of owner-occupied dwelling
units, mean rent, and substandard or dilapidated dwelling units from the city block statistics
of the 1960 census of housing. Blocks were chosen randomly within each statum, and interviewers were assigned to the blocks. Quota assignments were made for age and race, and
eligibility for the survey was established at 21 rather than 18 years of age. The racial characteristics of interviewers and respondents were matched. Interviewing was performed by the
Market Opinion Research Corporation, which conducts the Detroit News polls, under an
agreement with the senior author. We would like to acknowledge our appreciation to the
University of Michigan for the support which made this study possible and to the National
Opinion Research Center for making the Bedford-Stuyvesant data available to us.
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RIOT-PRECIPITATING POLICE PRACTICES
185
crease the comparability of the two surveys, 37 white resp
eliminated from the reports of the Detroit study.
Since most people normally act on the basis of what they
the facts, rather than on what actually may be true, ghet
opinions about police conduct should be of special relevanc
tempts to improve police practices or to avoid additional disorders.
Focusing primarily on surveys in Bedford-Stuyvesant and the Twelfth
Street neighborhood in Detroit, this analysis will examine the collective
sentiments of ghetto residents about police conduct in ghetto areas. The
general mood of the black community doubtless has a decisive influence
in creating the underlying conditions for the outbreak of violence.
Although police practices per se are usually the exclusive focus of
public discussion, they are clearly part of a larger white-controlled legal
and juridical system ostensibly charged with dispensing equality and justice to ghetto residents. One might well anticipate the distrust of Negroes
of a legal system whose norms and rules they have had little part in
framing.
Substantial support for this expectation was found in the results of
the 1967 Detroit survey. A staggering 92 percent of the Negro respondents
there did not believe "most of the laws on the books are fair to all people"; an even larger percentage thought there was general inequality in
law enforcement. Fewer than one in twenty agreed that "laws are enforced equally." Few felt judges to be completely honest: only one in
twenty-five felt judges were "honest all the time." Likewise, few felt Detroit policemen to be "honest all the time": only one in twenty. Respon-
dents with a conventional faith in the fairness of the law and its adminis-
trators, therefore, constituted a small minority in the ghetto. An overwhelming proportion of the residents were convinced that injustice pervaded the entire legal system.
Pervasive hostility of blacks to the overarching, white-created and
white-dominated legal system may well have contributed to the recent
outbreaks of violence, but it is difficult to measure the total impact of
this hostility or to alter it. From this perspective, it matters little how po-
lice have conducted themselves in black neighborhoods. If the rejection
of the entire white-controlled law enforcement system, as personified by
the police, was a primary impetus for ghetto riots, white America may
well have to suffer for centuries of denial and neglect. A massive constitutional revision of the entire legal system may be necessary to grant
black Americans legal equality and legal justice.
While the interrelations certainly are complex, it is doubtful that the
injustice of the entire legal system could have played a part in precipitating a riot had not that injustice been reflected graphically and directly in
police practices and thus reinforced in the minds of those who have long
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186
PHYLON
considered themselves oppressed. People are seldom moved to
solely by abstract ideas that are not translated into everyday
ences. It is likely that hostility of Negroes toward white aut
been kindled by abrasive contacts with ghetto police.
Again, evidence for this proposition was found in the surve
Twelfth Street area of Detroit. Table 1 records perceptions of
ple in the neighborhood were treated by the police" before t
started. A clear majority felt that police treatment of local re
fore the riot had been "not good" or "poor." This was a somew
proportion of negative sentiments than that disclosed by the r
a similar question after the 1965 Watts riot.6 The results in D
cated that animosity toward the police before the riot may w
been a major factor in provoking the violence. At the very l
judgments expressed by Detroit Negroes demonstrated that,
role objections to the police may have played in fomenting t
the hostility of ghetto residents is not founded solely upon
proval of abstract white authority. Such hostility is also based
cific criticisms of interactions with local police.
TABLE 1
EVALUATIONS OF POLICE TREATMENT BEFORETHE HRIOT
IN DETROIT, 1967
Number of Respondents Percentage
Very
Good
Good
84
19
7
31
Not
Good
62
23
Poor
85
32
Don't
Know
18
7
Total
268
Despite
100
the
police
spawn
many
ghett
respondents
trouble?"
An
ponses
were
proportions
ries.
Clearly
the
particul
riot
or
the
p
though
the
was
somewh
riots
elsewh
A
study
in
W
John F. Kraft, Inc., "The Attitudes of Negroes in Various Cities" in "Federal Role in Urban
Affairs," Hearings before the Subcommittee on Government Operations, U. S. Senate, 89th
Congress, 2nd session, August 31-September 1, 1966, Part 6, p. 1393.
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RIOT-PRECIPITATING POLICE PRACTICES
187
TABLE 2
ASSESSMENTS OF BLAME FOR THE BEDFORD-STUYVESANT
RIOT, 1964
Number of Percentage of
Respondents Respondents
Police (in general or in particular) 59 30
Negroes (leaders, organizations) 43 22
White people, officials 35 18
Delinquents, criminals 26 13
Young
people
22
11
Agitators, extremists 5 3
Miscellaneous, vague 16 8
Don't know, no answer 34 17
Total (Multiple answers allowed) 240 122
dents (compared to only 2 percent of the wh
police mistreatment was a basic cause of the
sponsored by the Detroit Urban League, whic
uate 23 possible causes of the riot, found tha
the most emphasis.8 While a substantial pro
Bedford-Stuyvesant were also critical of othe
black communities, the cumulative evidence f
cates that major urban riots frequently have
dents on police behavior.
Perhaps the most popular phrase for prot
practices has been the cry of police brutality
Stuyvesant were asked to estimate the exten
area; the distribution of responses to this qu
About one half of the sample said that there
tality in their area; only one in three was willin
TABLE 3
APPRAISALS OF POLICE BRUTALITY IN
BEDFORD-STUYVESANT, 1964
Number of
Extent of Police Brutality Respondents Percentage
A
A
lot
37
little
None
Don't
19
59
63
Know
30
32
41
200
21
102
T. M. Tomlinson and David O. Sears, Negro Attitudes Toward the Riot (Los Angeles: UCLA
Institute of Government and Public Affairs, 1967), p. 13.
8 Detroit News, August 20, 1967. In a Congressional Quarterly survey of congressmen, 44 percent of the Northern Democrats interviewed said that poor police-community relations were
of great importance as a cause of riots. Congressional Quarterly Report, September 8, 1967.
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PHYLON
188
brutality at all. These findings are remarkably similar to respon
identical question asked both in Harlem in 1964, which disclosed
percent thought there was at least some police brutality in the area, and
in Watts in 1965, which revealed that 47 percent believed in the existence
of brutality. In both surveys more than a third of the respondents were
undecided about the question.9 In striking contrast, a Gallup poll indicated that only 7 percent of white males believed that there was police
brutality in their areas.10
While the issue of "police brutality" has produced major differences
between Negroes and whites, survey data also have revealed a diversity
of opinion within the black community on this critical issue. Perhaps this
division has been promoted by the ambiguity of the phrase police brutal-
ity. Ghetto residents may have been "brutalized" in many ways, including the use of excessive force, harassment, the lack of protection from
crime, and a failure to serve the community. A UCLA survey of Watts
residents after the 1965 riot asked about six forms of police brutality,
such as lack of respect, insulting language, rousting and frisking, the use
of unnecessary force in arrests, and beating up suspects in custody. A
high percentage of residents believed that such practices existed in the
area, ranging from 65 percent for beating up suspects to 72 percent for
rousting and frisking. Moreover, from 21 percent (on beating up a suspect) to 41 percent (on rousting and frisking) alleged that they had seen
it happen; and from 4 percent (on beating up a suspect) to 23 percent (on
insulting language) stated that it had happened to them. These data, together with data from observational studies of police in the field, indicate
that there are some firm empirical grounds for the allegations of police
malpractices.1' Furthermore, a larger group of Watts residents expressed
a belief that some specific type of police misconduct had occurred in the
area than were willing to admit the existence of police brutality. For
many respondents, the phrase police brutality may have implied images
of gross physical harm to innocent persons of which they were frankly
unaware; yet other persons might have interpreted police brutality to include less severe and more common types of police misbehavior. As a result, the controversy over police brutality probably has contributed little
to the identification of specific police practices that may provoke explosive hostility in ghetto neighborhoods.
In addition to direct violations of civil liberties that are difficult to
measure or evaluate, ghetto residents have been subjected to other forms
of mistreatment by police, such as inadequate protection and services,
that provoke strong resentment. The Bedford-Stuyvesant survey asked
9 Kraft, op. cit., pp. 1389, 1400.
"o Cited in the President's Commission on Law Enforcement and Administration of Justice,
Task Force Report: The Police, p. 148.
nWalter J. Raine, "The Perception of Police Brutality in South Central Los Angeles" (Los
Angeles: UCLA Institute of Government and Public Affairs, 1967), pp. 6-8. For observer
reports of police brutality, see Albert J. Reiss, "How Common is Police Brutality?" Trans/
action, V (July-August, 1968),10-20.
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RIOT-PRECIPITATING POLICE PRACTICES
189
residents to rate police performance before the riot on a num
pects, including courtesy, responding to calls, patrolling the a
number of police assigned to the area in normal times. Respo
question are recorded in Table 4. A minority of the Bedfordresidents rated police activities in the area as either "good" o
in any respect. This finding contrasts strikingly with a 1965 Gal
which revealed that 70 percent of the public had a "great deal
for their police, and with an NORC survey which found that 77
the public rated the police protection they received as "pret
"very good."l2 A majority of the Bedford-Stuyvesant responde
cent, considered the local police "just fair" or "bad" on cour
more important perhaps, dissatisfaction with the police incre
sponding to calls, patrolling the area, and the number of po
signed to the area before the riot. Comparatively, the fewe
judgments were expressed about police courtesy. Nearly two
the respondents saw a need for improvement in the amount
police protection they received.
TABLE 4
RATINGS OF POLICE PRACTICES IN BEDFORD-STUYVESANT,
1964*
(N--200)
Percentage Rating Police As
Practices Excellent Good Just Fair Bad Don't Know Total
Courtesy 6 29 37 19 11 102
Responding to Calls 4 24 32 28 13 101
Patrolling the Area 2 24 39 28 9 102
Number of Police
Assigned to Area
in
Normal
Times
2
19
42
25
13
101
*Question: "Now I have some questions about the police force around here, in general, before
this recent trouble. How would you rate the police on . . . "
Although such ratings of specific police practices were doubtle
clouded by pervasive negative sentiments about law enforcement acti
ties in general, many ghetto residents were very critical of specific po
protective practices in the ghetto, practices relatively unrelated to
more publicized issue of police brutality. Most of the members of t
black community that had experienced a riot seemed to be asking fo
more and better police protection and service, not less. These data ar
corroborated by the findings of the Kerner Report; its summary commen
is that its "surveys have reported that Negroes in Harlem and South C
tral Los Angeles mention inadequate protection more often than brut
ity or harassment as a reason for their resentment toward the police."13
2 Cited in the President's Commission on Law Enforcement and Administration of Justice,
Task Force Report:The Police, p. 145.
"S Report of the National Advisory Commission on Civil Disorders, p. 161.
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190
PHYLON
Some observers have noted that lower-class neighborhoods w
crime rates, regardless of their racial characteristics, always
ceived less protection than the middle- or upper-class section
Thus some might argue that the complaint by Negroes of
protection and services is actually a class, not a racial, complai
ghetto residents in fact perceive differentials in police protect
cial or socioeconomic terms? An opportunity to partially exp
question was provided by a series of inquiries in the Detroit s
asked the respondents to compare the police protection receiv
sons (with race unspecified) crudely differentiated into two
omic levels: renters and homeowners. Then they were also ask
pare the protection received by Negroes and whites of roughl
socioeconomic level (homeowners). The results are presented
A substantial majority, 61 percent, of these Negro responden
that police protection was about the same for renters and ho
However, on the question with a crude class control, well ove
served that white homeowners got more protection than Ne
owners. Although a number of the respondents acknowledged
ference in police protection, a substantially larger proportion
likely to perceive discrimination in racial terms than in class t
TABLE 5
PERCEPTIONS OF SOCIOECONOMIC AND RACIAL DIFFERENCES
IN POLICE PROTECTION IN DETROIT, 1967
Homeowners Versus Renters: Number of Respondents Percentage
Renters get more protection 5 1
Homeowners get more protection 84 31
Protection
Don't
about
the
know/no
same
166
answer
TOTAL
270
61
16
6
99
White Homeowners Versus Negro Homeowners:
Negroes get more protection 7 3
Whites get more protection 151 56
Protection
about
Don't
the
same
know
TOTAL
270
103
38
9
3
100
In
addition,
88
ghetto
in
Detroi
the
way
they
tr
viously
inhabite
groes
have
come
shaped
by
direc
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RIOT-PRECIPITATING POLICE PRACTICES
191
ances about the inadequacy of protection, therefore, have probably
yielded a deeper sense of hostility and resentment than is (or was) prevalent among other slum dwellers. Although police administrators sometimes explain inadequate ghetto police coverage in socioeconomic terms,
black ghetto residents tend to perceive the same lack of protection in ra-
cial terms.
In another sense, however, criticisms by Negroes of police protection
might have been anticipated. A survey in Washington found, for example, that Negroes expressed much more anxiety about crime than did
whites.14 And a nationwide NORC survey revealed that Negroes were
more likely than whites to report that they had been victims of serious
crimes, particularly burglary, robbery, assault, and rape.15 In addition,
several observation studies have indicated that black ghettos received less
police protection than other sections of urban areas. In Hartford, Connecticut, fewer daytime patrolmen were assigned to a black ghetto than
to white neighborhoods of similar size, even though ghetto citizens summoned police much more often because of criminal acts; in Cleveland, policemen took almost four times longer to respond to burglarly reports
from the Negro district than from any other section of the city.16
The apparent demand for increased police protection and services coupled with frequent criticisms of excessive police force, discourtesy, and
harassment may seem to reflect a contradiction in the sentiments of the
black community. However, this seeming discrepancy can be resolved by
examining modern law enforcement policies in most urban ghettos. As
urban police departments have become increasingly professionalized,
they have sought to reduce serious offenses in high-crime areas, particularly black ghettos, by instituting a policy of preventive patrolling.l7 Such
a procedure, as the President's Crime Commission has noted, "often involves aggressive action on the part of the police in stopping persons
using the streets in high-crime areas and in making searches of both persons and vehicles."18 Thus many ghetto residents have had (or have seen)
disturbing encounters with patrolmen who were searching for suspects in
major crimes, such as homicides, serious assaults, and large thefts from
(usually white) businesses, many of which have taken place in other
areas of the city; or who at the behest of white authorities were attempting to suppress ghetto vices such as gambling, narcotics, the numbers
4 Cited in the President's Commission on Law Enforcement and Administration of Justice,
The Challenge of Crime in a Free Society, p. 50.
1 Phil Ennis, Criminal Victimization in the United States (Washington: U. S. Government
Printing Office, 1967).
6 Cited in Report of the National Advisory Commission on Civil Disorders, pp. 161-62; cf.
"Program budgeting for police departments," The Yale Law Journal, LXXVI (March, 1967),
822, 828.
7 This interpretation is compatible with the excellent analysis by Robert M. Fogelson, "From
Resentment to Confrontation: The Police, the Negroes, and the Outbreak of the NineteenSixties Riots," Political Science Quarterly, LXXXIII (June, 1968), 217-47.
8 President's Commission on Law Enforcement and Administration of Justice, Task Force
Report: The Police, p. 23.
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192
PHYLON
game, and prostitution.l9 In addition, the least competent and most
prejudiced patrolmen often are put on phetto patrol. Given such police
practices, it is not surprising that ghetto residents have complained of
police harassment and even police brutality. In the words of the President's Crime Commission: "it is also apparent, however, that aggressive
preventive patrol contributes to the antagonism of minority groups
whose members are subjected to it. A basic issue, never dealt with explicitly by the police, is whether... the gain in enforcement outweighs
the cost of community alienation."20
Aggressive preventive patrolling, with its frequent field interrogations and vice raids, thus leads to alienation of ghetto residents and complaints of harassments and brutality. But such patrolling also seems to
have another negative, if somewhat more indirect, impact on ghetto residents' view of their police protection. Since the volume of crime in the ci-
ties has nearly always exceeded the resources of the police, law enforcement officials apparently have devoted minimal attention to the many re-
ports by ghetto residents of what police consider minor crimes - burglaries involving small amounts of money, vandalism, breaking and entering, noisy parties, and the like. Moreover, police response to reports even
of major crimes all too frequently seems slow and lethargic - particularly in the case of intraracial crimes committed within the ghetto itself.
Preoccupation with preventive patrolling seems to result in neglect of ordinary police services. The net effect of such a preventive patrolling policy, despite police intentions to improve their assistance to crime-ridden
ghettos, has been to reinforce rather than change pervasive beliefs in the
injustice of the law enforcement system.
Although some survey data indicate that most ghetto residents share a
pervasive belief in the injustice and inequality of the existing legal and
juridical system, the findings of several studies clearly suggest that dissatisfaction with the police is not based solely on abstract dogmas about
alien white authority. This resentment has been reinforced by numerous
hostile and abrasive encounters with the police.
Available data indicate that residents of large urban ghettos which
have experienced riots are critical of police treatment of black citizens
and that many of them blame urban disorders in large measure on the
police. Moreover, the Bedford-Stuyvesant, Harlem, and Watts data
clearly indicate that a near-majority of ghetto residents believe in the existence of at least some police brutality, a somewhat ambiguous term for
1 A certain preoccupation with vice in the ghetto, "crimes without victims," can be seen in
data on 1958 gambling arrests in Los Angeles; according to one authority, 86 percent of all
police arrests for gambling were of Negroes. Yet whites totalled only 8 percent of those
arrested. Ed Cray, The Big Blue Line (New York, 1967), p. 183.
"President's Commission on Law Enforcement and Administration of Justice, Task Force
Report: The Police, p. 23.
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RIOT-PRECIPITATING POLICE PRACTICES
193
such police practices as unnecessary rousting and frisking, i
guage, and the use of unnecessary force in making arrests.
Yet the data also indicate that ghetto residents see themse
tims of another, less publicized form of discrimination: inad
protection and services. In Bedford-Stuyvesant, criticisms o
bility of police protection were slightly more common than
police discourtesy. The residents of most urban ghettos app
improved regular police services in their neighborhoods and
tention to their calls; in Hartford and Cleveland police atten
from the ghettos has been found to lag behind responses to
white areas.
In large measure, the apparent discrepancy between complaints about
police brutality and the inadequacy of protection may have resulted from
the modern policy of aggressive preventive patrolling, which has not only
increased hostile encounters between the public and the police but also
has allowed minor crimes to be overshadowed by major offenses. Police
patrolling always has been a problem in lower-class urban neighbor-
hoods, but the legacy of discrimination seemingly has prompted Negroes
to interpret the conflict in racial rather than social or economic terms.
A thorough examination of this tactic of aggressive preventive patrolling, together with an intensive investigation of the unequal distribution
of police resources, seem to demand high priority from city officials,
given the increasing gravity of the American racial situation and the
prospects for intensified urban violence of the kind frequently generated
in the past by police practices.
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