Legal Assistant Personal Injury

Also by Angela J. Davis

Arbitrary Justice: The Power of the American Prosecutor

Criminal Law

(author, with Katheryn Russell-Brown)

Trial Stories

(coeditor, with Michael E. Tigar)

Basic Criminal Procedure

(coauthor, with Stephen A. Saltzburg and Daniel J. Capra) Compilation copyright © 2017 by Angela J. Davis

Introduction copyright © 2017 by Angela J. Davis

All rights reserved. Published in the United States by Pantheon Books, a division of Penguin Random House LLC, New York, and distributed in Canada by Random House of Canada, a division of Penguin Random House Canada Limited, Toronto. Pantheon Books and colophon are registered trademarks of Penguin Random House LLC. Library of Congress Cataloging-in-Publication Data Names: Davis, Angela J., [date] editor.

Title: Policing the black man : arrest, prosecution, and imprisonment / edited and with an introduction by Angela J. Davis.

Description: First edition. New York : Pantheon Books, a division of Penguin Random House LLC [2017]. Includes bibliographical references and index. Identifiers: LCCN 201-***-**** (print). LCCN 201-***-**** (ebook). ISBN 978**********

(hardcover : alk. paper). ISBN 978********** (e-book). Subjects: LCSH: Discrimination in criminal justice administration—United States. African American criminals.

Classification: LCC HV9950 P64 2017 (print). LCC HV9950 (ebook). DDC 364.3/496073— dc23.

LC record available at lccn.loc.gov/ 201-***-****

Ebook ISBN 978**********

www.pantheonbooks.com

Cover design by Oliver Munday

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Contents

Cover

Also by Angela J. Davis

Title Page

Copyright

Dedication

Acknowledgments

Introduction: Angela J. Davis

A Presumption of Guilt: The Legacy of America’s History of Racial Injustice

Bryan Stevenson

The Endurance of Racial Disparity in the Criminal Justice System Marc Mauer

Boys to Men: The Role of Policing in the Socialization of Black Boys

Kristin Henning

Racial Profiling: The Law, the Policy, and the Practice Renée McDonald Hutchins

Making Implicit Bias Explicit: Black Men and the Police Katheryn Russell-Brown

Policing: A Model for the Twenty-first Century

Tracy Meares and Tom Tyler

The Prosecution of Black Men:

Angela J. Davis

The Grand Jury and Police Violence Against Black Men Roger A. Fairfax, Jr.

Elected Prosecutors and Police Accountability

Ronald F. Wright

Do Black Lives Matter to the Courts?

Jin Hee Lee and Sherrilyn A. Ifill

Poverty, Violence, and Black Incarceration

Jeremy Travis and Bruce Western

Contributor Acknowledgments

A Note About the Contributors

For the black men in my life, past and present—my grandfather, Robert L. Harris; my father, Eddie Walter Jordan; and my husband, Howard Neil Davis

Acknowledgments

This book would not have been possible without the hard work and dedication of so many people. I thank Erroll McDonald for his guidance, editorial assistance, and expert advice. I also thank Shawnta Albro, Gabrielle Best Husband, Sheryl Dublin, Layla Medina, Meaghan E. Mixon, and Summer Woods for their outstanding research assistance and Dean Camille A. Nelson and my colleagues at American University Washington College of Law for their support throughout the process. I owe a special debt of gratitude to Randall Kennedy, who generously suggested that I be offered the opportunity to edit this important anthology. Finally, I thank my dear husband, Howard Neil Davis, and all of my family and friends for their love, patience, and encouragement. I am deeply grateful to Bryan Stevenson, Marc Mauer, Kristin Henning, Renée McDonald Hutchins, Katheryn Russell-Brown, Tracey Meares, Tom Tyler, Roger A. Fairfax, Jr., Ronald F. Wright, Sherrilyn A. Ifill, Jin Hee Lee, Jeremy Travis, and Bruce Western for their extraordinary contributions to this book and for all they do to ensure fairness for poor people and people of color in the criminal justice system. I thank them and the many lawyers, activists, scholars, teachers, and artists who are fighting every day to assure that Black Lives Matter.

Introduction

ANGELA J. DAVIS

Michael Brown, Eric Garner, Tamir Rice, Walter Scott, Freddie Gray, Sam DuBose, Alton Sterling, Philando Castile, and Terence Crutcher are just some of the names on a long list of unarmed black boys and men who were killed by police officers in recent years. Although black men have been the victims of violence at the hands of the state since the time of slavery, technology and social media now permit us to literally bear witness to many of these killings, repeatedly. Millions of people have watched the video of a police officer choking Eric Garner to death as he struggled for air. Similarly, millions have watched the video of a police officer shooting Walter Scott in the back as he ran for his life. Who can ever forget the grainy footage of Tamir Rice—the twelve-year-old boy who was shot by a police officer while he played alone with a toy gun in a park near his home? Two videos—one from a police helicopter and another from a police dashboard camera—show Terence Crutcher walking away from police officers with his hands raised high in the air just before he was shot and killed. These images have evoked feelings of fear, sadness, and outrage and serve as a reminder that the lives of black men and boys continue to be devalued and destroyed with impunity at the hands of the state. To date, not one of the police officers who killed these men and boys has been convicted of a single crime. From the arrival of the first slaves in Jamestown in 1619 to the lynchings of the nineteenth and twentieth centuries to the present day—black boys and men have been unlawfully killed by those who were sworn to uphold the law and by vigilantes who took the law into their own hands. The National Museum of African American History and Culture, which opened its doors on September 24, 2016, includes exhibits that tell the story of many of these killings. Yet these killings are not just a part of African American history. They have continued well into the twenty-first century—almost four hundred years after the beginning of slavery—and persist with remarkable frequency and brutality during a time when America elected its first African American president.

Many of these race-based killings have inspired and reinvigorated movements for change. The brutal killing of fourteen-year-old Emmett Till in Mississippi in 1955, the murder of civil rights activist Medgar Evers in 1963, and the assassination of Martin Luther King in 1968 all serve as markers on the civil rights movement timeline, as did so many other killings of black men by white racists. Each tragic killing sparked nationwide protests and renewed activism in the struggle for civil rights and racial justice in the United States. The killing of seventeen-year-old Trayvon Martin in 2012 was a pivotal marker of racial violence against black men in the twenty- first century. Martin was killed by George Zimmerman, a white man who called the police when he saw Martin walking in his neighborhood. Zimmerman, a member of a neighborhood crime watch group, reported to the police that Martin looked “suspicious” and that he looked like he was “up to no good or on drugs or something.” Ignoring the dispatcher’s warning that he should not follow Martin, Zimmerman ultimately shot and killed him. Martin was unarmed and was on his way back to his father’s house after buying snacks at a local convenience store. Initially Zimmerman was not even charged with a crime, but after nationwide protests, he was charged with Martin’s murder. A jury ultimately acquitted him.1 The killing of Trayvon Martin, the initial failure of the prosecutor to charge Zimmerman with a crime, and Zimmerman’s ultimate acquittal captured the attention of the nation. President Obama even weighed in, stating, “Trayvon Martin could have been me 35 years ago.”2 Martin’s killing also inspired the phrase “Black Lives Matter.” The phrase trended on Twitter and all forms of social media and was displayed on posters carried in protests after Martin’s killing and after every killing of a black man or woman by a police officer from that day forward. Black Lives Matter ultimately became a social justice movement with chapters throughout the United States and Canada.

Many unarmed black men and boys have been killed since Trayvon Martin’s tragic death five years ago. Many of the killings occurred after police officers arguably engaged in racial profiling—stopping and harassing these men for no explainable reason other than the color of their skin. In all of the cases where black men were shot and killed, the officers claimed that they felt threatened, even though the men were unarmed and often running away or retreating. In almost all of the cases, the police officers were never arrested or charged with a crime.

The tragic killings of Trayvon Martin, Michael Brown, Eric Garner, Walter Scott, Tamir Rice, Freddie Gray, and others served as the catalyst for this anthology. But these killings also inspired the contributing authors to think about all of the ways that black men are

“policed”—in the broad sense of the word—heavily and harshly at every step of the criminal process. In fact, black men are policed and treated worse than their similarly situated white counterparts at every step of the criminal justice system, from arrest through sentencing. These unwarranted disparities exist whether black men are charged with crimes or are victims of crimes. Police officers stop, search, and arrest black men far more frequently than white men engaged in the same behavior. Prosecutors charge black men more frequently and with more serious crimes than white men who engage in the same behavior. And there are disproportionate numbers of black men in the nation’s prisons and jails. Criminal defendants, regardless of their race, are punished less harshly when their victims are black men. This anthology explores and explains the “policing” of black men—from slavery to the present day and at every stage of the criminal process and beyond.

Why Black Men?

Black men are not the only people of color to be treated worse than their similarly situated white counterparts at every step of the criminal process. Black women, Latino/a men and women, Native Americans, and other people of color also experience violence at the hands of the state and discriminatory treatment in the criminal justice system, as do people who are gay, lesbian, and/or transgender.3 This book’s focus on black men in no way trivializes the experiences of all people who face these harms. While acknowledging that other groups have been and continue to be oppressed and discriminated against, this book focuses on black men. In many ways, the experience of black men in the criminal justice system is unique. The most noticeable difference is that they are impacted more adversely than any other demographic in the United States—at every stage of the process.

Black Boys Are Disproportionately Arrested and Detained Black boys are more likely to be referred to the juvenile justice system than any other children. In 2011, black boys represented the greatest percentage of children placed in juvenile detention—903 black boys per 100,000 were sent to detention as compared to 125 black girls.4 A Rhode Island study found that black boys were 9.3 times more likely to spend time in juvenile detention than white boys.5

Over half the students arrested at school in the United States and referred to the juvenile justice system are black or Hispanic.6 While black students represent only 16 percent of student enrollment, they represent 27 percent of students referred to law enforcement and 31 percent of students subjected to in-school arrests.7 Black male students alone make up 18 percent of all referrals and arrests.8 Black Men Are Disproportionately Arrested

African Americans are 2.5 times more likely to be arrested than whites9 and 49 percent of black men can expect to be arrested at least once by age twenty-three compared to 44 percent of Hispanic men and 38 percent of white men.10 Police officers are permitted to stop and frisk individuals if they have “reasonable suspicion” that crime is afoot and that the person is armed and dangerous.11 However, numerous studies have shown that the practice of racial profiling has resulted in black men being targeted and disproportionately stopped, frisked, and arrested. For example, the New York Civil Liberties Union analyzed the New York Police Department’s 2011 stop-and-frisk database and found that 41.6 percent of all stops were of black and Latino men between the ages of fourteen and twenty-four, even though they make up only 4.7 percent of the population of New York.12 The same study found that no crime had been committed in 90 percent of the stops.13 Black men were disproportionately stopped. The number of stops of black men exceeded the city’s entire population of black men by 9,720.14 Black Men Are More Likely to Be Killed or Injured During a Police Encounter While more whites are killed by law enforcement than people of color, African Americans are killed at a disproportionate rate. In fact, black men are 21 times more likely to be killed by police than white men.15 Between 2010 and 2012, black boys ages fifteen through nineteen were killed at a rate of 31.17 per million compared to 1.47 per million for white boys of the same age group.16 In addition, a significant number of black men killed by police were unarmed. Data collected from January 1, 2015, to May 31, 2015, revealed that African Americans killed by the police were twice as likely to be unarmed as whites.17 An overwhelming 95 percent of these victims were men.18

Not all violent encounters with the police result in death, but black men fare worse in nonfatal encounters as well. A study conducted by the Justice Department’s Bureau of Justice Statistics (BJS) examined police use of nonfatal force between 2002 and 2011. The study found that African Americans were more likely to experience nonfatal force at the hands of police officers than either Hispanics or whites.19 Black Men Are Disproportionately Imprisoned and Receive Longer Sentences African Americans make up approximately 35 percent of the prison population in the United States,20 and by the end of 2015, black men constituted 34 percent of the American prison population.21 In 2015, 5,165 in 100,000 black men ages twenty-five to twenty-nine were imprisoned compared to 2,165 Hispanic men and 921 white men of the same ages.22 Remarkably, the number of black men in prison or jail, on probation, or on parole by the end of 2009 roughly equaled the number enslaved in 1850.23 One in three black men born in 2001 can expect to be incarcerated in his lifetime.24

Black men serve more time for their crimes than others similarly situated. Data collected by the U.S. Sentencing Commission between December 2007 and 2011 revealed that black men in federal prisons received sentences 19.5 percent longer than white men sentenced for the same crime.25 Blacks are also disproportionately sentenced to death. As of 2014, the national death row population is approximately 42 percent black, while the overall black population is only 13.6 percent.26

—

For all of these reasons, this anthology focuses on the plight of black men and boys. The extraordinarily disproportionate mistreatment of black boys and men at every step of the criminal process is explored in depth. As the essays make clear, the issues and problems are complex, as are the solutions. The authors are scholars, lawyers, and activists who have studied and, in some instances, personally experienced the phenomena about which they write. In these informative, well-researched, and sometimes poignant essays, the authors examine and explain the policing of the black man. Policing the Black Man: The Essays

A Presumption of Guilt: The Legacy of America’s History of Racial Injustice In the book’s deeply moving introductory essay, Bryan Stevenson traces the policing of black men from slavery to the present day. He explains how slavery firmly entrenched the regime of white supremacy in the United States. Stevenson makes it clear that the Black Codes passed after the Civil War and the shocking practice of convict leasing were the precursors of current discriminatory criminal laws and the modern-day policing of black men. His chilling examination of lynching and other forms of racialized terror present the sordid history of the criminal justice system’s treatment of black men who were victims of the most violent crimes. Stevenson reveals the seamless link between lynching and capital punishment and discusses the continuing well-documented racial disparities in the implementation of the death penalty. He closes with a discussion of the importance of this country’s confronting and acknowledging its history of racial violence. This essay lays a solid foundation for the remainder of the book and is essential to the reader’s understanding of how and why the American criminal justice system continues to police black men.

The Endurance of Racial Disparity in the Criminal Justice System In this essay, Marc Mauer provides an overview of most of the issues that are specifically addressed in the remaining chapters of the book. He describes the stark racial disparities that exist at every step of the criminal process, from arrest through sentencing. Mauer also explains the complex confluence of circumstances that resulted in these disparities—from harsh sentencing laws and policies to rising crime rates to discretionary decision-making by criminal justice officials. He discusses how race-neutral decisions result in unwarranted racial disparities. Mauer addresses all of these issues with a focus on black men, establishing that they have been more adversely affected than any other group. The essay ends with practical suggestions for reform and sets the stage for an exploration of the issues addressed in the remainder of the book. Boys to Men: The Role of Policing in the Socialization of Black Boys Kristin Henning’s essay on the policing of black boys is fundamental to understanding the policing of black men. As she states early in the essay, “Black boys are policed like no one else, not even black men.” Police officers persistently target, stop, and harass black boys wherever they are—on the street, in school, in stores—and no matter what they are doing. Henning explains how police officers see black boys not as children, but as dangerous criminals, even when they are not engaging in criminal or even suspicious behavior. She discusses a fascinating study that found that police officers tend to overestimate the age of black boys while underestimating the age of white boys. Henning explains the impact of this constant harassment on the psyche of black boys and the role that it plays in shaping their views of police officers. She then discusses how police officers respond when black boys react to the harassment, including the role of implicit bias. As a result of this treatment, black boys grow up with negative impressions of police officers and carry these impressions into adulthood. Henning’s explanation of how these interactions impact interactions between black men and the police is illuminating. She concludes the essay with concrete proposals for reform.

Racial Profiling: The Law, the Policy, and the Practice Racial profiling is at the very core of the policing of black men. Almost every stop, frisk, search, assault, or killing of black boys and men starts with racial profiling. Renée McDonald Hutchins defines and explains racial profiling and provides heart-wrenching examples that illustrate why this troubling phenomenon is so painful and damaging. She discusses the role of implicit bias and provides a comprehensive account of how the Supreme Court’s rulings have permitted police officers to continue to engage in this practice that is illegal in name only. Hutchins explains why the Court’s jurisprudence has made it so difficult to challenge racial profiling in the lower courts and concludes the essay with a discussion of recent efforts to end the practice.

Black Men and the Police: Making Implicit Bias Explicit Many of the essays in this anthology refer to the phenomenon of implicit bias—the unconscious bias that results from exposure to negative stereotypes and attitudes. In this essay, Katheryn Russell- Brown explains implicit bias and its role in police officers’ interactions with black men. She discusses the so-called “shooter studies” that indicate that police officers perceive black men as more threatening and dangerous than white men and are therefore more inclined to shoot unarmed black men than similarly situated white men. Russell-Brown examines recommendations for reform within police departments and the need to address implicit bias at its core through a revamping of the K–12 curriculum in public schools. Policing: A Model for the Twenty-first Century

In this essay, Tracey Meares and Tom Tyler explore the relationship between the police and communities of color. They discuss why communities of color tend to trust police officers less than white communities and propose a model of procedural justice to improve the level of trust. Meares and Tyler examine the obvious and not-so- obvious reasons why it is important to close this deficit of trust—for the benefit of both the communities and the police officers. Drawing on Meares’s service on President Obama’s Task Force on 21st Century Policing, they present ideas for a new model that will improve the relationship between police and communities of color while addressing the legitimate concerns of both.

The Prosecution of Black Men

In this essay, I explain how and why prosecutors are the most powerful officials in the criminal justice system. I discuss their discretion and power in the charging and plea-bargaining process before setting forth the ways in which these decisions impact the lives of black men—as criminal defendants and as victims of crimes. I use hypothetical and real examples to illustrate how prosecutorial decisions result in black men being treated worse than their similarly situated white counterparts. I also explore the dearth of African American prosecutors and discuss whether the race of the prosecutor has an impact on the treatment of black men. I conclude with a discussion of the Vera Institute of Justice’s Prosecution and Racial Justice Program, a project that sought to address the role of prosecutors in the unwarranted racial disparities in the criminal justice system.

The Grand Jury and Police Violence Against Black Men Grand juries decide whether an individual should face criminal charges. The vast majority of grand juries almost always bring charges against defendants, primarily because the standard for charging is so low (“probable cause”) and because grand juries are entirely controlled by the prosecutor. Yet in cases involving police officers who kill black men, grand juries rarely return an indictment. In this essay, Roger A. Fairfax Jr. explains the history and purpose of the grand jury before exploring the grand jury’s problematic role in the investigation of police officers involved in the killings of black men. Fairfax discusses the grand jury investigations of the killings of Freddie Gray, Michael Brown, Eric Garner, Walter Scott, Tamir Rice, and Laquan McDonald. He explains why most of the police officers were not indicted and concludes with suggestions for reform of the grand jury in cases involving police shootings.

Elected Prosecutors and Police Accountability

The prosecutors who were criticized for their failure to criminally charge police officers who killed unarmed black men and boys were all elected officials. In this essay, Ronald F. Wright examines the complex relationship between elected prosecutors and police officers and the problems associated with holding prosecutors accountable through the electoral process, especially the difficulty of challenging incumbents. He discusses and compares the elections of prosecutors in jurisdictions where police officers were involved in the deaths of unarmed black men. Wright explores the challenges African American voters face in prosecutorial elections and suggests reforms to make prosecutors more responsive to minority voters. Do Black Lives Matter to the Courts?

African Americans have always looked to the Supreme Court for protection from discrimination and all forms of injustice. In this essay, Sherrilyn A. Ifill and Jin Hee Lee demonstrate how the Court has often failed to safeguard the rights of African Americans. They outline the Court’s “sordid history dealing with race in this country,” beginning with the infamous Dred Scott decision. Ifill and Lee discuss how Justice John Marshall Harlan’s declaration that “our Constitution is color-blind” in his dissent in Plessy v. Ferguson was turned on its head in the modern-day reverse discrimination cases that ignore the specific history of racism against black individuals. They persuasively argue that, by requiring discriminatory intent by a specific actor, the Court fails to acknowledge structural racism and fails to provide viable legal remedies to black men who are the victims of police violence.

Poverty, Violence, and Black Incarceration

The last essay provides important insight into the relationship between poverty, violence, and the incarceration of black men. Jeremy Travis and Bruce Western discuss the research that shows how the overincarceration of black men grew out of poverty and violence. They argue that the overuse of incarceration has created a social inequality that has prevented African Americans from fully participating in American life. Travis and Western maintain that mass incarceration has not had an appreciable impact on public safety and has resulted in devastating consequences for the African American community that have the potential to last for generations. They call for a criminal justice reform agenda that advances peace and justice in African American communities.

NOTES

1. Lizette Alvarez and Cara Buckley, “Zimmerman Is Acquitted in Trayvon Martin Killing,” New York Times, July 13, 2013, http://www.nytimes.com/ 2013/ 07/ 14/ us/ george-zimmerman-verdict-trayvon-martin.html?_r=0. 2. James S. Brady, “Remarks by the President on Trayvon Martin,” news release, July 19, 2013, https://www.whitehouse.gov/ the-press-office/ 2013/ 07/ 19/ remarks-president- trayvon-martin.

3. Terrence Rogers, “Using International Human Rights Law to Combat Racial Discrimination in the U.S. Criminal Justice System,” Scholar: St. Mary’s Law Review on Minority Issues 14 (Winter 2011): 389–405; Sally Kohn, “Greasing the Wheel: How the Criminal Justice System Hurts Gay, Lesbian, Bisexual, and Transgendered People and Why Hate Crime Laws Won’t Save Them,” New York University Review of Law and Social Change 27 (2001–2002): 260–64; Kimberlé Williams Crenshaw and Andrea J. Ritchie, Say Her Name: Resisting Police Brutality Against Black Women

(New York: African American Policy Forum, 2015); Teri A. McMurtry-Chubb,

“#SayHerName #BlackWomensLivesMatter: State Violence in Policing the Black Female Body,” Mercer Law Review 67 (2016): 651; Mike Males, “Who Are Police Killing?” Center on Juvenile and Criminal Justice website (Aug. 26, 2014), http://www.cjcj.org/ news/ 8113.

4. “Juvenile Detention,” Child Trends, accessed August 20, 2015, http://www.childtrends.org/ ?indicators=juvenile-detention. 5. The School-to-Prison Pipeline in Black and White (American Civil Liberties Union of Rhode Island, 2015), 6.

6. Catherine E. Lhamon and Jocelyn Samuels, Dear Colleague Letter: Nondiscriminatory Administration of School Discipline (U.S. Department of Justice and U.S. Department of Education, 2014), 3–4, http://www.justice.gov/ sites/ default/ files/ crt/ legacy/ 2014/ 01/ 08/ dcl.pdf.

7. Civil Rights Data Collection: Data Snapshot: School Discipline (U.S. Department of Education Office for Civil Rights, 2014), 6, http://ocrdata.ed.gov/ Downloads/ CRDC- School-Discipline-Snapshot.pdf.

8. “2011–12 Discipline Estimations by Discipline Type,” U.S. Department of Education, Office for Civil Rights, Civil Rights Data Collection, accessed August 20, 2015, http://ocrdata.ed.gov/ StateNationalEstimations/ Estimations_2011_12. 9. Jamal Hagler, “8 Facts You Should Know About the Criminal Justice System and People of Color,” Center for American Progress, May 28, 2015, https://www.americanprogress.org/ issues/ race/ news/ 2015/ 05/ 28/ 113436/ 8-facts- you-should-know-about-the-criminal-justice-system-and-people-of-color/. 10. Robert Brame, et al., “Demographic Patterns of Cumulative Arrest Prevalence by Ages 18 and 23,” Crime & Delinquency (January 2014): 474–76. 11. Terry v. Ohio, 392 U.S. 1 (1968).

12. “New NYCLU Report Finds NYPD Stop-and-Frisk Practices Ineffective, Reveals Depth of Racial Disparities,” New York Civil Liberties Union, May 9, 2012, http://www.nyclu.org/ news/ new-nyclu-report-finds-nypd-stop-and-frisk-practices- ineffective-reveals-depth-of-racial-dispar.

13. Ibid.

14. Ibid.

15. Ryan Gabrielson, Ryann Grochowski Jones, and Eric Sagara, “Deadly Force, in Black and White,” ProPublica, October 10, 2014, http://www.propublica.org/ article/ deadly- force-in-black-and-white.

16. Ibid.

17. Jon Swaine, Oliver Laughland, and Jamiles Lartey, “Black Americans Killed by Police Twice as Likely to Be Unarmed as White People,” The Guardian, June 1, 2015, http://www.theguardian.com/ us-news/ 2015/ jun/ 01/ black-americans-killed-by- police-analysis.

18. Ibid.

19. U.S. Department of Justice, Bureau of Justice Statistics, Police Use of Nonfatal Force, 2002–11, by Shelley Hyland, Ph.D, Lynn Langton, Ph.D., and Elizabeth Davis. NCJ 249216 (Washington, DC: U.S. Government Printing Office, 2015), 1, http://www.bjs.gov/ content/ pub/ pdf/ punf0211.pdf. 20. U.S. Department of Justice, Bureau of

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