ACLU Washington Letter

This document is under embargo until November 10, 2021 at 2 p.m. PST.
November 10, 2021
SENT VIA ELECTRONIC MAIL

Kristen Clarke
Assistant Attorney General
United States Department of Justice Civil Rights Division
950 Pennsylvania Avenue NW
Washington D.C. 20530
Steven Rosenbaum
Assistant Attorney General
United States Department of Justice Civil Rights Division,
Special Litigation Section
950 Pennsylvania Avenue NW
Washington D.C. 20530
Honorable Nicholas W. Brown

United States Attorney for the Western District of Washington
700 Stewart Street, Suite 5220
Seattle, WA 98101
RE: Request to Investigate Pattern and Practice of Civil Rights Violations

by Vancouver Police Department, Clark County Sheriff’s Office, and
Vancouver-Clark County Joint Drug Task Force
Dear Ms. Clarke, Mr. Rosenbaum, and US Attorney Brown:
The American Civil Liberties Union of Washington and the community

organizations listed below request that the Civil Rights Division of the
Department of Justice (DOJ) open one or more pattern or practice investigations
into excessive force; discriminatory policing harming Vancouver and Clark
County area communities; and discriminatory policing arising from law
enforcement favoritism toward known white supremacist extremist groups. The
law enforcement agencies that should be investigated are the Vancouver Police
Department (VPD), the Clark County Sheriff’s Office (CCSO), and a joint drug
task force of both agencies (Task Force). Specifically, we request your
investigation into VPD, CCSO, and the Task Force’s excessive force and
disparate treatment of community residents who are Black, Pacific Islander,
Indigenous, persons of color, experiencing homelessness and/or experiencing
mental illness. We appreciate your immediate attention to this exigent matter;
another Clark County family is grieving the loss of a family member at the hands
of police as we write this letter.
I. FACTS WARRANTING INVESTIGATION
A. THERE HAVE BEEN AN ALARMING NUMBER OF POLICE SHOOTINGS OF

COMMUNITY MEMBERS, PARTICULARLY YOUNG BLACK AND PACIFIC ISLANDER
MEN, IN A SHORT PERIOD OF TIME, WITH NO ATTEMPT TO DE-ESCALATE OR USE
LESS LETHAL MEANS
We believe a DOJ investigation is now warranted into the repeated use of excessive force by VPD,
CCSO, and the Task Force. Over a 2.5-year period, there have been eight police-involved killings at the
hands of Vancouver police officers, Clark County sheriff’s office deputies, and drug task force agents.
This is the largest concentration of police killings across the state since Initiative 940, a statewide de-
escalation and mental health training requirement, was passed in Washington state in December 2018.
Of these, 63% of the people killed were people of color, including three Black men and two Pacific
Islanders, despite the fact that Black people and Pacific Islanders together account for no more than 3%
of the Clark County population.1
In each case, the use of lethal force was unnecessary and excessive. In nearly all cases, police justified
the use of lethal force with the same narrative that the person “failed to comply.” However, many of the
cases lack non-law enforcement corroborating witnesses, body camera footage, or dash camera footage
to verify these claims. Officers also killed people in crisis or who were suicidal. Many of these
incidents make clear that officers did not make efforts to de-escalate or use less lethal alternatives and
instead, multiple officers pointed their firearms and eventually shot and killed people, including those
identified immediately below.
On February 19, 2019, VPD officers shot and killed Clayton Joseph, a 16-year-old Pacific Islander-
Chuukese boy from Evergreen High School.2 Multiple officers arrived at his apartment complex
following reports of a fight involving two other youth. Officers alleged that Joseph was holding a knife
and that they ordered him to drop it.3 Officers claim that he refused and instead brandished the knife at
them, 4 however witnesses report that Joseph was on the scene, trying to defuse the fight and stop
someone from attacking his friend’s girlfriend.5 Without attempting less lethal alternatives, officers
fired one round at Joseph, killing him.6
On February 28, 2019, two VPD officers shot and killed Michael Eugene Pierce, a 29-year-old white
man experiencing homelessness and mental illness. Police claim that Pierce, who was living with
paranoid schizophrenia, was waving and pointing two brightly colored pellet guns – firearm replicas –
at himself and passersby.7 Several witnesses expressed that Pierce was experiencing a mental health
1
QuickFacts Clark County, Washington, U.S. CENSUS BUREAU,
https://www.census.gov/quickfacts/clarkcountywashington.
2
Kellee Azar, Friends Remember 16-Year-Old Killed by Police in Vancouver, KATU (Feb. 20, 2019),
https://katu.com/news/local/friends-remember-16-year-old-killed-by-police-in-vancouver.
3
Meerah Powell & Molly Solomon, 16-Year-Old with Knife Shot by Vancouver Police, Dies from Injuries, OPB
(Feb. 20, 2019), https://www.opb.org/news/article/vancouver-washington-police-shooting-fatal-teenager/.
4
Id.
5
Jerzy Shedlock & Jack Heffernan, Teen Shot by Vancouver Police Officer Was from Micronesia, THE
COLUMBIAN (Feb. 20, 2019), https://www.columbian.com/news/2019/feb/20/vancouver-police-officer-shoots-
man-during-disturbance-investigation/.
6
Meerah Powell & Molly Solomon, 16-Year-Old with Knife Shot by Vancouver Police, Dies from Injuries, OPB
(Feb. 20, 2019), https://www.opb.org/news/article/vancouver-washington-police-shooting-fatal-teenager/.
7
Jerzy Shedlock, Family: Man Shot, Killed by Vancouver Police Had Schizophrenia, Columbian (Mar. 1, 2019),
https://www.columbian.com/news/2019/mar/01/family-man-shot-killed-by-vancouver-police-had-schizophrenia/.
2
crisis.8 Additionally, a witness noted that they overheard Pierce make suicidal comments and pointed
the guns at his own head.9 When VPD arrived at the scene, officers armed themselves with .223 caliber
rifles before approaching.10 Officers claimed they ordered Pierce to drop the firearm replicas and that he
refused; without trying to deescalate, two VPD officers then fired five rounds from their rifles at Pierce,
killing him.11
On March 7, 2019, two VPD officers killed Carlos Hunter, a 43-year-old Black man, who was on the
way to pick up his son from elementary school.12 VPD was relying on an informant who
mischaracterized Hunter as being involved in the drug trade. Though Hunter was alleged to have been
involved in gang activity as a 13-year-old, he had not had any criminal history in over 18 years.13 In the
meantime, he had rehabilitated himself and transformed his life, motivated by a desire to support and
provide for his children, one of whom was born after he was killed. Officers in the regional drug task
force obtained a search warrant naming Hunter, and pulled him over in a traffic stop.14 Officers claim
that Hunter was uncooperative.15 While he remained seat belted in his car, multiple VPD officers
excessively shot Hunter in the torso over 16 times, killing him.16 Officers found no evidence of a crime
in Hunter’s car or home during the failed drug sting operation.17 Hunter was the third Vancouver,
Washington, resident killed in a three-week stretch.
On April 28, 2020, three VPD officers shot and killed William Abbe, a 50-year-old white man
experiencing homelessness and mental illness. Officers responded to reports of a fight between Abbe
and another person. Video footage of the encounter shows him in crisis, pacing while six VPD officers
surrounded him, rifles drawn, cornering him on a sidewalk next to busy oncoming traffic.18 Officers had
previously encountered Abbe, who suffered from a schizophrenia crisis.19 Officers claimed that Abbe
asked police to kill him.20 As he is seen either taking a step towards one of the officers or away from
them,21 three officers fired at Abbe, and killed him.22
On October 4, 2020, two VPD officers killed Andrew Williams, a 41-year-old white man experiencing
homelessness and mental illness. Officers responded to a call about an alleged fight between Williams
8
Jerzy Shedlock, Prosecutor: Vancouver Officers’ Use of Deadly Force on Homeless Man Justified, Columbian
(July 24, 2019), https://www.columbian.com/news/2019/jul/24/prosecutor-vancouver-officers-deadly-force-on-
homeless-man-justified/.
9
Id.
10
Id.
11
Id.
12
Troy Brynelson, Washington Changed Police Shooting Investigations, But Trust Remains in Low Supply, OPB
(Nov. 24, 2020), https://www.opb.org/article/2020/11/24/washington-state- police-shooting-investigations/.
13
Id.
14
Id.
15
Id.
16
Id.
17
Id.
18
Christopher Irwin, Vancouver Police Department Murder On Tape., YOUTUBE (Apr. 28, 2020),
https://www.youtube.com/watch?app=desktop&v=Ta-qqu44c7c.
19
Troy Brynelson & Brandon Roberts, Analysis Shows Most Shot by Vancouver Police Had Unaddressed Mental
Health Needs, OPB (Feb. 4, 2021), https://www.opb.org/article/2021/02/04/analysis-shows-most-shot-by-
vancouver-police-had-unaddressed-mental-health-needs/.
20
Id.
21
Christopher Irwin, Vancouver Police Department Murder On Tape., YOUTUBE (Apr. 28, 2020),
https://www.youtube.com/watch?app=desktop&v=Ta-qqu44c7c.
22
3
and someone he’d been in a relationship with.23 Williams had agreed to leave the fight and was walking
away from the apartment home when VPD officers arrived.24 One VPD officer chased after Williams
and fired her taser at him but missed. Officers allege Williams had a screwdriver and that they ordered
him to drop it.25 Officers claim that he refused and instead said “shoot me.”26 Two officers fired their
pistols at Williams, striking him in the abdomen and hip and killing him.27
On October 29, 2020, three Clark County sheriff’s deputies shot and killed Kevin Peterson Jr., a 21-
year-old Black man, during a drug sting operation, driven by an informant and a SnapChat message
from a few hours earlier.28 Peterson was sitting in his parked car when officers boxed his car in with
two unmarked vehicles.29 Peterson, startled, ran when approached by officers. He called the mother of
his child, Olivia Selto, who remained on the phone with him and reported that he sounded “terrified” as
he ran for his life.30 In about three minutes,31 multiple officers chased Peterson and fired 34 shots,
hitting him in the back and killing him as he ran away.32 After the shooting, the VPD and CCSO
claimed Peterson was armed with a firearm and fired at officers several times.33 However, the
investigation did not find evidence supporting the account but in fact found that Peterson was running
away from officers when he was shot and killed.34 Following the shooting, officers surrounded
Peterson’s body with barricades and refused to allow his body to be identified by family members for
nearly 12 hours.35
On February 4, 2021, a Clark County Sheriff’s deputy fatally shot Jenoah D. Donald, a 30-year-old
Black man, during a pretextual traffic stop after hearing about a drug house in the area.36 Instead of
23
Jerzy Shedlock, Documents Detail Fatal Vancouver Police Shooting in October, COLUMBIAN (Jan. 21, 2021),
https://www.columbian.com/news/2021/jan/21/documents-detail-fatal-vancouver-police-shooting-in-october/.
24
Id.
25
26
Id.
27
Jerzy Shedlock, Documents Detail Fatal Vancouver Police Shooting in October, THE COLUMBIAN (Jan. 21,
2021), https://www.columbian.com/news/2021/jan/21/documents-detail-fatal-vancouver-police-shooting-in-
october/.
28
Troy Brynelson, Family of Kevin Peterson Jr. Announces Plan to Sue Over His Killing by Police, OPB (Mar.
18, 2021), https://www.opb.org/article/2021/03/18/kevin-peterson-fatal-shooting-police-lawsuit/.
29
Troy Brynelson, Investigators Release Footage, New Details in Kevin Peterson Jr. Shooting, OPB (Nov. 25,
2020), https://www.opb.org/article/2020/11/25/kevin-peterson-jr-clark-county-police-shooting-footage/.
30
Troy Brynelson, Prosecutors Find Fatal Police Shooting of Kevin Peterson Jr. Justified, OPB (Aug. 16, 2021),
https://www.opb.org/article/2021/08/16/prosecutors-rule-fatal-police-shooting-of-kevin-peterson-jr-justified/.
31
Troy Brynelson, Kevin Peterson Jr.’s Partner Says Peterson Feared Lifetime Jail Sentence in Final Phone Call,
OPB (Dec. 18, 2020), https://www.opb.org/article/2020/12/18/kevin-peterson-jr-shooting-clark-county-sheriffs-
office/.
32
33
Kelly Moyer, Camas Police Detective to Lead Peterson Shooting-Death Investigation, CAMAS-WASHOUGAL
POST-REC. (Nov. 5, 2020), https://www.camaspostrecord.com/news/2020/nov/05/camas-police-detective-to-lead-
peterson-shooting-death-investigation/.
34
35
Kelly Moyer, Camas Police Detective to Lead Peterson Shooting-Death Investigation, CAMAS-WASHOUGAL
POST-REC. (Nov. 5, 2020), https://www.camaspostrecord.com/news/2020/nov/05/camas-police-detective-to-lead-
peterson-shooting-death-investigation/.
36
Troy Brynelson, Prosecutors Rule Fatal Police Shooting of Jenoah Donald Justified, OPB (July 13, 2021),
https://www.opb.org/article/2021/07/13/prosecutors-rule-fatal-police-shooting-of-jenoah-donald-justified/.
4
issuing a traffic ticket for a broken taillight, three officers confronted him.37 Officers ordered Donald to
exit the car, without explaining why, and threatened him with police dogs if he did not exit.38 Rather
than try to deescalate the situation, an officer punched him in the face and attempted to forcefully
remove Donald from his car.39 Officers claimed that Donald’s car began to move.40 One of the deputies
then shot Donald twice at close range.41 Donald, who was unarmed, died from his injuries in the
hospital eight days later.42
On October 17, 2021, Clark County Sheriff’s deputies shot and killed Kfin Karuo, a 28-year-old Pacific
Islander-Chuukese man.43 News reports indicate CCSO deputies attempted to stop Karuo’s car, and
police say he “failed to comply.” Police allege Karuo pointed a gun at them, but it's unclear “if there
were any witnesses to the shooting or if any footage captured the encounter. The Clark County Sheriff’s
Office does not use body or dashboard cameras.”44 Police claim they had probable cause to arrest Karuo
for first degree assault but have provided no details about that claim. This was the third fatal shooting
by CCSO deputies in a year, and all three were people of color. At the time of this shooting, CCSO
deputies also terrified a significant number of community members of color by the deputies’ “bursts of
rapid-fire gunshots” “tearing through [the community members’] houses.” The deputies shot into
multiple homes in the early morning hours, causing children and elders and others awakened by the
shots to be in shock and no longer feel safe in their homes. One home had 10 or more bullet holes in it.
“Another neighbor whose home was struck described hearing a bullet ricochet around her kitchen, into
her dining room and then into her laundry room.” A young woman in one of the homes was nearly
struck by the police bullets. The community members whose homes were riddled with police bullet
holes also stated that police left Karuo’s body lying in the community members’ driveway for hours
after the shooting. Family members report that Karuo’s father died shortly after learning of his son’s
death.45
In addition to the above incidents where community members lost their lives at the hands of police
violence, in November 2020 VPD shot another person of color, Irving Diaz Rodriguez, age 23 and
37
Troy Brynelson, Jenoah Donald, 30-Year-Old Black Man Shot by Clark County Deputies, Has Died, OPB (Feb.
12, 2021), https://www.opb.org/article/2021/02/12/jenoah-donald-clark-county-sheriffs-office-shooting-death/.
38
Id.
39
Id.
40
Id.
41
Id.
42
Id.
43
Troy Brynelson, ‘We’re absolutely at a loss:’ Family members identify Kfin Karuo as man shot and killed by
Clark County deputies, OPB (Oct. 19, 2021), https://www.opb.org/article/2021/10/19/clark-county-sheriffs-
deputies-shooting-kfin-karuo-death/?outputType=amp; see also Becca Robbins, East Vancouver residents shaken
by fatal shooting involving sheriff’s deputies, COLUMBIAN (Oct. 18, 2021),
https://www.columbian.com/news/2021/oct/18/east-vancouver-residents-shaken-by-fatal-shooting-involving-
sheriffs-deputies/; Maxine Bernstein, Clark County sheriff deputies shoot and kill armed man after car chase;
multiple bullets pierce mobile homes, OREGONIAN (Oct. 17, 2021),
https://www.oregonlive.com/crime/2021/10/clark-county-sheriff-deputies-shoot-and-kill-armed-man-after-car-
chase-multiple-bullets-pierce-mobile-homes.html; KGW Staff, Clark Co. Sheriff's Deputies fired first in Sunday
morning shooting with man wanted for assault with a gun, KGW8 (Oct. 19, 2021),
https://www.kgw.com/article/news/crime/clark-sheriff-sunday-morning-shootout/283-de2d0560-d5d8-47ea-9fad-
6850bb488901; @TroyWB, TWITTER (Oct. 17, 2021, 10:07 AM),
https://twitter.com/TroyWB/status/1450508921131601924; Becca Robbins, Investigators: Suspect pointed gun at
Clark County deputies before fatal shooting, COLUMBIAN (Oct. 19, 2021), https://clbn.us/maDpw.
44
Id.
45
Id.
5
diagnosed with schizophrenia, leaving him paralyzed.46 A mobile crisis team was able to calm
Rodriguez down, but VPD officers insisted on entering the scene to arrest him. VPD officers claim he
waved a bat at them. The officers shot at him and severely injured him. In contrast, in an October 2019
Vancouver incident involving a white man who had shot and killed one person and shot two others,
with no indication of mental illness, law enforcement did not fire their weapons during the incident.47
Throughout the 2.5-year period of incidents described above, each officer-involved shooting incident
resulted in death or severe injury – officers were shooting to kill. This deadly blanket response to a
range of circumstances and subjects reflects a lack of care or regard for the vulnerabilities and needs of
the person that police encounter (e.g., someone with a mental health disorder in the case of Abbe and
Pierce or a youth, in the case of Joseph), and the context. In addition to the lack of a more tailored
approach, it is striking that, except for the Peterson and Abbe cases, nearly all these cases involve
multiple officers and no bystander witnesses. There is no body camera or dash camera footage in these
cases, so the only account we have of what happened in these incidents is based on the word of the
officers. In each case, police justified the use of lethal force with the same narrative – that the person
resisted arrest (e.g., in the case of Joseph, a 16-year-old raising a knife as if to stab multiple officers),
but there is no one other than officers to confirm that. Civilian witnesses and video, when available (as
in the Peterson case), contradict, rather than corroborate, police statements.
This fact pattern across these cases suggests a culture of corroborating and silencing around police
misconduct, an informal norm commonly referred to as the blue wall of silence.48 The blue wall of
silence, or code of silence, is a harmful, entrenched part of law enforcement culture which poses a
formidable barrier to accountability. Moreover, the fact that we only have the officers’ accounts (which
they have days to prepare between an event and their interview) to go on is troubling, particularly given
the evidence that police make false claims about the people they kill (e.g., that they were armed and/or
didn’t comply with orders), and that this problem is systemic.49
In response to a growing number of officer-involved shootings, in June 2019 the City of Vancouver
commissioned the Police Executive Research Forum (PERF), a third-party organization, to conduct a
review into VPD’s culture, policies, and practices around the use of force.50 In its 90-page report
analyzing VPD’s use of force between 2017 and 2019, PERF found that VPD’s use of force incidents
rose by 65% with no apparent policy or reporting changes to explain the increase.51 PERF made several
findings requiring change and lists 84 separate recommendations.52 Of the 84 total recommendations,
10 were identified as needing immediate action, including:
46
47
Jessica Prokop & Calley Hair, One Dead in Shooting at Smith Tower in Vancouver; Suspect in Custody,
COLUMBIAN (Oct. 3, 2019), https://www.columbian.com/news/2019/oct/03/shots-fired-at-smith-tower-in-
vancouver/ ; Jonathan Levinson, Accused Vancouver Apartment Shooter Held Without Bail, OPB (Oct. 4, 2019),
https://www.opb.org/news/article/accused-vancouver-shooter-held-without-bail/.
48
See Thomas Nolan, Behind the Blue Wall of Silence, 12 MEN & MASCULINITIES 250 (2009), available at
https://journals.sagepub.com/doi/pdf/10.1177/1097184X09334700.
49
Sam Levin, ‘They Kill the Person Twice’: Police Spread Falsehoods After Using Deadly Force, Analysis Finds,
GUARDIAN (May 19, 2021), available at https://www.theguardian.com/us-news/2021/may/19/us-police-shootings-
george-floyd-press-releases-reports.
50
POLICE EXEC. RSCH. F., REVIEW OF THE VANCOUVER, WA POLICE DEPARTMENT 14 (2020),
https://www.cityofvancouver.us/sites/default/files/fileattachments/police_vpd/page/42481/vancouver_pd_final_re
port_june_2020.pdf.
51
Id. at 15.
52
See generally id.
6
• Prohibition of any type of neck restraint, or shooting at or from a moving vehicle;53
• Training and requirements that lieutenants who conduct reviews of critical incidents consider
the event in its entirety, which should include looking for ways to improve communications,
tactics, policy, training, and use of equipment;54
• Ensuring use of force reports are reviewed by each level of the police department’s command,
up to the assistant chief;55
• Meeting with community members to discuss changes and police reform.56
In an extremely concerning finding, PERF’s report outlines that VPD’s policy “does not direct officers
to only use force that is proportional to the threat encountered.”57 This lack of guidance about
proportionality in the exercise of force is reflected in police practices on the ground, as demonstrated by
the officer-involved shootings cited above. Additionally, PERF found multiple instances of
inconsistency and missing definitions across specific use of force policies and procedures.58
B. VPD & CCSO ENGAGE IN DISCRIMINATORY POLICING ALONG RACIAL, MENTAL

HEALTH DISABILITY, AND ECONOMIC LINES, INFLICTING GREAT HARM ON
COMMUNITY MEMBERS
1. VPD & CCSO’s Discriminatory Policing is Demonstrated Through Racial Disparities in Use
of Force and Officer Involved Shootings (OIS)
In addition to the disturbing incidents of fatal police violence described above, other data show VPD
and CCSO officers operate with disproportionately high rates of aggression toward Black, Pacific
Islander, and other residents of color, as well as those facing homelessness and mental illness. Both the
city of Vancouver and Clark County have very small Black populations at around 2% each (2.3% in
Vancouver and 2.4% in Clark County).59 Yet three of the eight people recently killed in Clark County
were Black, and two were Pacific Islanders – representing 62.5% of the killings.
Data discussed in more detail below shows that relative to Vancouver City demographics, a Black
person is significantly more likely than a white person to be the subject of police use of force.
Community members pointed out after the police violence that took Jenoah Donald’s life, that it was
the second killing of a Black man by local law enforcement in fewer than four months. Also notable,
Clayton Joseph and Kfin Karuo, who were Micronesian, were two of the eight people police killed -
even though the Pacific Islander population in Vancouver is 1.5% and in Clark County it is less than
1%.60
Additionally, it is very likely the data under reports disparate treatment along racial lines: the PERF
report found that VPD’s use of force reporting form allows officers themselves to enter data regarding
the ethnicity of subjects, including reporting “unknown” ethnicity, and found that approximately 50%
53
Id. at 6.
54
Id. at 21.
55
Id. at 12.
56
Id. at 90.
57
Id. at 5.
58
Eric J. Holmes & James McElvain, PERF Use of Force Report, CITY OF VANCOUVER WASH. (Oct. 23, 2020),
https://www.cityofvancouver.us/police/page/perf-use-force-report.
59
United States Census Bureau, Quick Facts, https://www.census.gov/quickfacts/vancouvercitywashington &
60
Id.
7
of use of force incidents were reported with an “unknown” ethnicity subject.61 But even with that
caveat, of the use of force incidents where ethnicity was reported, PERF still found that between 2017
and 2019, 11.6% of use of force incidents involved Black community members despite Black residents
making up only 2.3% of Vancouver’s population.62
By comparison, the PERF report indicates that 75.1% of VPD’s use of force incidents over the three-
year period involved white people, with white residents making up 80.1% of Vancouver’s population.63
Use of force against white Vancouver residents is slightly less than their representation in the
population, whereas use of force against Black Vancouver community members occurs at a rate five
times higher than their representation in the population.64
Our analysis of VPD’s use of force data from 201965 and 202066 provided on the VPD website similarly
shows stark disparities. In both years, Black residents and Native Hawaiians and Pacific Islanders were
disproportionately subject to the use of force, compared to their representation in the Clark County
population based on population data for 2019.67 Native Hawaiians and Pacific Islanders made up 2.3%
of use of force incidents in 2019 and 2.8% in 2020 but are only 1.5% of the Vancouver population.68
Even more glaring, Black residents made up 13.4% of use of force incidents in 2019 and 17.1% in 2020
but, are only 2.3% of the Vancouver population.69 Black people continue to be overrepresented in force
61
POLICE EXEC. RSCH. F., REVIEW OF THE VANCOUVER, WA POLICE DEPARTMENT 14 (2020),
port_june_2020.pdf.
62
Id. at 14, 56; QuickFacts Vancouver City, Washington, U.S. CENSUS BUREAU,
https://www.census.gov/quickfacts/vancouvercitywashington.
63
POLICE EXEC. RSCH. F., REVIEW OF THE VANCOUVER, WA POLICE DEPARTMENT 14, 56 (2020),
port_june_2020.pdf ; QuickFacts Vancouver City, Washington, U.S. CENSUS BUREAU,
64
Id.
65
See generally Vancouver Police Department Use of Force Report (2019), City of Vancouver, Wash,
https://www.cityofvancouver.us/sites/default/files/fileattachments/police_vpd/page/42431/use_of_force_2019.pdf.
66
See generally Vancouver Police Department Use of Force Report (2020), CITY OF VANCOUVER, WASH,
https://www.cityofvancouver.us/sites/default/files/fileattachments/police_vpd/page/42431/use_of_force_2020_q1-
4.pdf.
67
https://www.census.gov/quickfacts/vancouvercitywashington. See generally Vancouver Police Department Use of
Force Report (2019), CITY OF VANCOUVER,
https://www.cityofvancouver.us/sites/default/files/fileattachments/police_vpd/page/42431/use_of_force_2019.pdf;
Vancouver Police Department Use of Force Report (2020), CITY OF VANCOUVER,
4.pdf.
68
4.pdf.
69
8
incidents in the first half of 2021 compared to their proportion in the population.70 Between January 1,
2021, and June 30, 2021, Black people made up 10.4% of use of force incidents.71 In contrast, white
people constituted 64.8% of force incidents even though they make up 80.1% of the Vancouver
population.72
The share of VPD use of force incidents against Black people increased markedly between 2019 and
2020, from 13.4% to 17.1%.73 For Native Hawaiians and Pacific Islanders, it increased as well, from
2.3% of use of force incidents to 2.8%.74 In contrast, it decreased significantly for whites/Caucasians,
from 77% to 70.4%.75 It is noteworthy that in 2019, the race of the subject was listed as “unknown” in
3% of use of force incidents.76 These numbers increased in 2020 to 6.6% of subjects being listed in use
of force incidents as “unknown” and 17.6% of subjects being listed as “unknown” in use of force
incidents in the first half of 2021.77
Overall, Black and Pacific Islander people together constituted 15.7% of VPD use of force incidents in
2019;19.9% of VPD use of force incidents in 2020; and 14.4% of VPD use of force incidents in the first
4.pdf .
70
See Vancouver Police Department Use of Force (2021 Q1-Q2), CITY OF VANCOUVER,
https://www.cityofvancouver.us/sites/default/files/fileattachments/police_vpd/page/42431/use_of_force_2021q2_
ytd.pdf.
71
See id.
72
See id.; QuickFacts Clark County, Washington, U.S. CENSUS BUREAU,
73
See Vancouver Police Department Use of Force Report (2019), CITY OF VANCOUVER,
4.pdf.
74
4.pdf.
75
4.pdf.
76
https://www.cityofvancouver.us/sites/default/files/fileattachments/police_vpd/page/42431/use_of_force_2019.pdf.
77
4.pdf; Vancouver Police Department Use of Force (2021 Q1-Q2), CITY OF VANCOUVER,
ytd.pdf.
9
half of 202178 - even though they constitute a mere 3.8% of the Vancouver population.79 In other words,
the representation of these groups in 2019 use-of-force incidents is 4.1 times their proportion in the
overall population, and 5.3 times their proportion in the overall population for 2020. And in light of the
growing number of use of force incidents that characterize a subject’s race as “unknown,” it is
reasonable to assume these grossly disproportionate numbers are even greater in reality.
2. VPD & CCSO’s Discriminatory Policing is Demonstrated Through Racial Disparities in Jail
Detentions and Traffic Stops
Jail detention rates also tell a story of disparate treatment of Black people and people of color in Clark
County. Data from the Vera Institute80 shows that in Clark County between 1990 and 2018, Black
people were jailed at rates dramatically higher than that of all other racial groups (see Figure 1, below).
In 2018, the most recent year for which data is available, Black people were jailed at a rate of 1,011
people per 100,000 residents aged 15-64 (i.e., about 1%). In contrast, white people were jailed at a rate
of 214 people per 100,000 residents (i.e., about 0.2%). In other words, Black people were jailed at a
rate approximately five times higher than that of white people. According to 2019 census data, Black
people constitute only 2.4% of the Clark County population, while white people make up 86.1% of the
population, i.e., the population of white people is 35 times larger than that of Black people.81 This
staggering difference in the rate at which Black people versus white people are jailed may reflect
disparities in policing that lead Black people to be arrested at much higher rates. An analysis of arrest
data for VPD and CCSO would help tell us more.
Figure 1: Clark County Jail Detention Rate Per 100,000 Residents by Racial Category82
Overall, between 1990 and 2015, the rate of jail detention for Black people in Clark County is higher
than that of other racial categories even when you compare it to the state average incarceration rate for
78
4.pdf; Vancouver Police Department Use of Force (2021 Q1-Q2), CITY OF VANCOUVER,
ytd.pdf. The category “American Indian/Alaska Native” is not included in the 2021 data like it was for 2019 and
2020. No explanation is provided.
79
See QuickFacts Vancouver city, Washington, U.S. CENSUS BUREAU,
80
Incarceration Trends Clark County, WA, VERA INSTITUTE OF JUSTICE, http://trends.vera.org/rates/clark-county-
wa (last visited Sept. 30, 2021).
81
Quick Facts Clark County, WA, U.S. CENSUS BUREAU,
82
Incarceration Trends Clark County, WA, VERA, http://trends.vera.org/rates/clark-county-wa (last visited Oct.
29, 2021).
10
Black people, which is also disproportionately high. In 2015, the most recent year state data available,
Black people in Clark County were jailed at nearly twice the average state rate of jail detention for that
population.83 The average state rate of jail detention of Black/African American people was 492 per
100,000 residents aged 15-64 (nearly 0.5%), versus Clark County’s rate, which was 967 per 100,000
residents aged 15-64 (nearly 1%) (see Figure 2, below). The jail detention rate for Black people in
Clark County in 2015 is also slightly higher than the national average rate of incarceration for Black
people.84 The average national rate of jail detention of Black/African American people was 847 per
100,000 residents aged 15-64 (about 0.8%), versus Clark County’ s rate, which was 967 per 100,000
residents aged 15-64 (about 1%)—about 1.1 times higher (see Figure 3, below).
Figure 2 Clark County Jail Detention Rate per 100,000 Residents by Racial Category Compared
to State Average85
Figure 3 Clark County Jail Detention Rate per 100,000 Residents by Racial Category Compared
to U.S. Average86
Similar to jail detention rates, an analysis of traffic stop data from the VPD reveals yet further evidence
of disparate policing. The data, obtained via a public records request, spans traffic stops made by the
VPD between January 28, 2020, and June 15, 2021, and shows that Black/African American drivers
and Hispanic drivers are stopped at 2.3 times the rate at which white drivers are.87 The rate is even
higher for Pacific Islander drivers, who are stopped at 2.8 times the rate of white drivers but make up
83
29, 2021).
84
29, 2021).
85
Id.
86
Id.
87
Vancouver Police Department Traffic Stop Data 1/20/20-6/15/21, (on file with author).
11
only 0.9% of the population.88 In contrast, white people make up 80.1% of the population.
An important caveat here is that the demographics of Clark County drivers likely differ from overall
Clark County demographics. Washington State data on car access by racial group support the fact that
the driver population in Clark County is whiter than the overall County population,89 which would
make the disparities described here even more severe.
3. VPD & CCSO’s Discriminatory Policing & Excessive Force is Demonstrated Through Use
of Force/OIS Against People Experiencing Homelessness and/or Mental Illness
A related pattern and practice warranting DOJ investigation is that people with mental illness are also
overrepresented in use of force incidents involving Vancouver and Clark County law enforcement
agencies. All three of the previously mentioned white men killed by VPD were experiencing
homelessness and were in a mental health crisis. According to the PERF report nearly one-third of
individuals involved in use of force incidents had at least one mental health indicator present.90 By
VPD’s own calculation, nearly a quarter (22.7%) of use of force incidents in 2019 involved individuals
“exhibiting symptoms of mental illness.” This increased to 36.4% (more than a third of use of force
incidents) in 2020. In the first half of 2021, 32% of force incidents involved subjects “exhibiting
symptoms of mental illness.”91
While the data alone is disturbing, evidence regarding the Abbe and Williams deaths further
demonstrates the need for a civil rights investigation. A review of public records (i.e., audio of 911
calls, police reports, police dispatch audio, transcripts of police interviews with witnesses, etc.) shows
there is little police consideration or understanding for how a subject with mental illness should inform
police contact. Equally disconcerting, there are startling similarities in the circumstances leading to the
killings which further underscore the problem.
Records show police officers responding to the scenes were aware that Abbe and Williams both
suffered with mental illness and had responded to calls about them in the past. Even with that
knowledge from previous contacts with Abbe and Williams, VPD escalated the crises when they
showed up on each scene in masse, including the presence of a K-9. As one of the witnesses to Mr.
Abbe’s shooting noted, “[t]he whole police department was over there.” Similarly, a witness to Mr.
Williams’ shooting said, “[t]his whole street was nothin’ but police cars.” This account was confirmed
by VPD Officer Musser, who stated that her entire shift followed her to the scene of Williams’ shooting
(PDR OIS WILLIAMS 000075). In fact, so many officers showed up at the Williams scene that some
were redundantly assigned tasks already assigned to others, e.g., stringing crime scene tape or keeping a
log of people with access to the scene. This huge showing of armed, uniformed officers, their K-9s, and
their cars with lights shining and sirens blaring was an overwhelming display of force for anyone, let
alone people that are in the throes of decompensation.
When you couple the described show of force with the fact that during the encounter with police, Abbe
88
Id.
89
Car Access Washington, NAT’L EQUITY ATLAS,
https://nationalequityatlas.org/indicators/Car_access#/?geo=02000000000053000.
90
POLICE EXEC. RSCH. F., REVIEW OF THE VANCOUVER, WA POLICE DEPARTMENT 14 (2020), at 15,
port_june_2020.pdf.
91
Vancouver Police Department Use of Force Report, CITY OF VANCOUVER (2021),
ytd.pdf.
12
and Williams both told the police to shoot them and both were in fact shot and killed by the police no
more than 10 minutes within contact, it is evident police made no meaningful effort to adapt their
approach to better address someone in a mental health crisis through de-escalation. Relevant public
records support this conclusion and tell a story of very little, if any, reliance on de-escalation
techniques. VPD’s go-tos in both cases were tasing, barking commands, and then firing on Abbe and
Williams. Strikingly, interviews with police also reveal that only one VPD officer can carry a less lethal
weapon, and that they do not carry batons, pepper spray, or shields which would allow for less lethal
interventions. The tasers they use are largely unreliable. As a result, VPD is a police force that has
failed to prioritize de-escalation.
C. VPD & CCSO ENGAGE IN DISCRIMINATORY POLICING THAT FAVORS KNOWN,

LOCAL AND REGIONAL, WHITE SUPREMACIST EXTREMIST GROUPS
A number of recent incidents show the disparate treatment of Black and brown community members by
the Vancouver Police Department and the Clark County Sheriff’s Office, compared to violent white
supremacist extremist groups and their members. Clark County residents have provided evidence of
disparate treatment which are supported by photos, videos, social media, and news media; and
corroborated by VPD and CCSO organizational materials and communications obtained through Public
Records Act requests (i.e., law enforcement operation plans, reports, email communications,
correspondence from concerned community members about demonstrations, etc.). These together show
disparity in the way VPD and CCSO respond to demonstrations by Black people and people of color
against police violence (of which they are often the target), compared to the way they respond to
demonstrations by white supremacist groups.
In general, VPD and CCSO treat Black demonstrators as threats from whom the community needs
protection. In contrast, acts of violence by armed white supremacist extremists are treated as exercising
protected free speech and are viewed by police as in need of protection from others, including those in
support of Black Lives Matter (BLM), even though there is a well-documented pattern of these white
supremacist hate groups harming people demonstrating against police violence both nationally and
locally. When supremacist groups disrupt demonstrations against police violence, and harass and
violently attack Black demonstrators, VPD and CCSO refuse to intervene to protect Black and other
community members under active assault. And despite multiple requests by impacted community
members for law enforcement to investigate and protect residents from threats of and doxing and
physical violence by white supremacist groups, VPD and CCSO routinely appear to treat embedded
domestic extremist groups’ adverse conduct leniently, in contrast to the documented disparate treatment
of communities of color described above.
Washington state is a hotspot for violent extremist groups dedicated to advancing white supremacy.
According to the most recent analysis from Southern Poverty Law Center (SPLC), there are 22 hate
groups in Washington State, eight statewide.92 The focus of this letter is four groups that have been
active in Vancouver and Clark County: Patriot Prayer, Proud Boys, Community of Police Supporters
Northwest (COPS NW), and Washington Three Percenters (WA3%). Together, these groups are part of
a vast network that spans the Washington/Oregon border. Their members are active in Vancouver and
Clark County and in nearby Portland, Oregon, often promoting and attending each other’s events, and
some of them plan and participate in extremist rallies around the US. There is evidence that these
groups - particularly Patriot Prayer and COPS NW - have friendly ties with local law enforcement,
which may explain the favoritism toward these groups and their followers.
92
In 2020, 22 Hate Groups Were Tracked in Washington, SPLC S. POVERTY L. CTR.,
https://www.splcenter.org/states/washington.
13
1. Disparate Deployment of Law Enforcement Resources and Failure to Protect Black and
Brown Protestors: Justice for Kevin Peterson Jr. Vigil—October 30, 2020
On October 30, 2020 - the day after the killing of Kevin Peterson Jr. by a CCSO sheriff’s deputy,
members of Mr. Peterson’s family, supportive friends, and other community members gathered for a
peaceful vigil to mourn and grieve. Community members at this solemn gathering reported being
confronted by an armed, hostile group of white supremacist extremists whose members verbally
harassed and physically attacked the mourning family and supporters with bear mace paintballs, and
other threats of violence.93 Trucks were driven by white supremacist extremists at vigil attendees, and
the family of another victim of police violence (Hunter) was violently attacked with fists and bear
mace. Many of those attacked required medical assistance, including a Black woman driving by in her
car with her husband and two young children who had their car shot with paintballs and bear mace
sprayed into their car.94 White supremacists drove oversized trucks violently through the vigil area and
caused property damage, prompting the closure of a Fred Meyer store across the street. In the face of
this violent conduct, there was no law enforcement intervention or presence (1) to stop the white
supremacist groups from further terrorizing the community or (2) to protect the Black and other
community members being threatened, harassed and attacked. CCSO failed to respond, allowing the
members of the supremacist groups to terrorize peaceful mourners at a vigil. The white supremacist
groups present were later determined to be Patriot Prayer supporters,95 and members of the Proud Boys,
Sons of Liberty (Proud Boys splinter group), and COPS NW.96
2. Disparate Law Enforcement Designations of “Expressive Speech”: Patriot Prayer

Memorial—September 30, 2020
Disparate treatment is also evident in VPD events operation plans and communications and
designations of which events are designated “expressive speech” versus those that are not. VPD
designated Patriot Prayer events “expressive speech” but did not designate BLM events or similar
events protesting police violence in the same manner. For example, in the case of the Kevin Peterson Jr.
vigil, the VPD operations plan did not include this designation, but VPD did make such a designation
for a September 30, 2020 memorial organized by Patriot Prayer for a supporter who was killed during a
protest in Portland.97 The expressive speech designation for that event reads, “[e]xpressive speech is a
protected class of activities, the sole purpose of which is to exercise the right of free speech. VPD and
VFD are aware of expressive speech events organized in the City of Vancouver and monitor the events
as needed for public safety.”98 On the other hand, two other anti-racism/anti-police violence events
happening that same week, according to email communications, were disallowed the free speech events
designation. This corroborates the Vancouver and Clark County community member’s experiences of
the disparate treatment by VPD and CCSO at the October 30, 2020 vigil for Kevin Peterson Jr.
93
https://twitter.com/IGD_News/status/1322460951732494351.
94
@Claudio_Report, TWITTER (Oct. 31, 2020, 10:43 AM),
https://twitter.com/Claudio_Report/status/1322595125319532544.
95
@RoseCityAntifa, TWITTER (Oct. 31, 2020, 12:24 AM),
https://twitter.com/RoseCityAntifa/status/1322439172762738691.
96
@MrOlmos, TWITTER (Oct. 30, 2020, 9:04 PM), https://twitter.com/MrOlmos/status/1322388946349744128.
97
Conrad Wilson, Slain Portland Protester Supported Right-Wing Group Patriot Prayer, NPR (Sept. 1, 2020),
https://www.npr.org/2020/09/01/908222877/slain-portland-protester-supported-right-wing-group-patriot-prayer.
98
Vancouver Police Department Operational Plan: Patriot Prayer Memorial, (August 2, 2020), (on file with
author).
14
3. Disparate Treatment in Uses of Law Enforcement Resources and Protection: Patriot
Prayer/WA3% Clark County Courthouse Demonstration for Kelly Carroll & Demonstrations
in front of City Attorney’s Home June 2020
Patriot Prayer received similar favorable treatment at a protest organized with WA3% and others in
front of the Clark County Courthouse for Kelly Carroll, a local business owner who was facing criminal
charges.99 VPD’s operational plan indicates that the department designated this event as an expressive
speech event, and VPD went out of its way to create a welcoming environment for these groups to
express their views:
The Vancouver Police Department is committed to supporting the First Amendment

Rights of all citizens and will endeavor to create a safe environment for this to take
place. We will not have a large police presence at the courthouse. Supervisors will
make an initial introduction, encourage the safety of those present and then clear.
The event will be monitored by plain clothes personnel and information relayed to
the Incident Commander if visible police presence is needed. VPD will coordinate
with CCSO personnel if they require assistance in protecting their facility behind
the Courthouse or the Courthouse itself. Vancouver Police Traffic officers will be
present for traffic safety, respond to calls for service and patrol the surrounding
areas. All previous protests to this point have been peaceful…100
Two days later, on June 22, Gibson and members of WA3% assembled again, to demand that CCSO
Sheriff David Atkin shield Carroll from legal consequences for intentionally breaking the law. During
the protest, Sheriff Atkins met with the protestors by phone and “agreed to hold a meeting with Kelly
Carroll.”101 The group then marched to the home of city attorney Kevin McClure, where they protested
out front in an effort to pressure McClure to drop the charges against Carroll.102 McClure’s home
address was shared via a video posted publicly by WA3%.103 This protest in front of McClure’s home,
during which there was no police intervention, was a precursor to the nearly nine-hour long protest in
front of McClure and his counterpart City Attorney Jonathan Young’s homes several days later, on June
28, 2021. This latter protest and lack of VPD intervention is detailed below.
4. White Supremacist Extremist Groups and Their Ties to Each Other and Local Law
Enforcement
a. Patriot Prayer
The white supremacist groups who engaged in violence at the October 30, 2020 Peterson vigil were
mobilized by Patriot Prayer, its founder Joey Gibson and others. Gibson is the founder and leader of
Patriot Prayer who, according to Western States Center (WSC) is a bridge between the various white
99
Chuck Tanner, Three Percenters, Patriot Prayer Protest Clark County Sheriff, City Prosecutor, IREHR (June
23, 2020), https://www.irehr.org/2020/06/23/three-percenters-patriot-prayer-protest-clark-county-sheriff-city-
prosecutor/.
100
Vancouver Police Department Operational Plan, (June 20, 2020), (on file with author).
101
Chuck Tanner, Three Percenters, Patriot Prayer Protest Clark County Sheriff, City Prosecutor, IREHR (June
23, 2020), https://www.irehr.org/2020/06/23/three-percenters-patriot-prayer-protest-clark-county-sheriff-city-
prosecutor/.
102
Id.
103
Id.
15
supremacist extremist groups in Washington and Oregon. Ahead of the Kevin Peterson Jr. vigil, Gibson
put out a call to his large following, inciting them to show up at the vigil.104
Gibson founded Patriot Prayer in Clark County in 2016. Patriot Prayer relies on inciting violence to
antagonize and intimidate counter-protestors. These were the same tactics used on mourners at the
Kevin Peterson Jr. vigil. Patriot Prayer often organizes with the white supremacist group Proud Boys at
events where, according to the SPLC: “[e]ach time, the goal…has been the same: to incite violent
confrontations with counter-protesters, blame any resulting violence on the left, and press for further
repression and retaliation against those they consider their political adversaries.”105 In 2019, Gibson was
charged by Multnomah County [Oregon] with felony riot after he and fellow Patriot Prayer members
instigated a brawl with members of Antifa outside of a pub.106 Court documents describe how Gibson
and other Patriot Prayer members used threats and taunts “in an effort to clearly provoke a physical
altercation.”107
Patriot Prayer and Gibson promote the events of other white supremacist terror groups on his platform.
As discussed below, despite Patriot Prayer’s history of violence and targeting Black people, Gibson and
Patriot Prayer benefit from a deferential, if not friendly, relationship with VPD, and specifically with
the lead of the VPD intelligence unit, Sergeant Patrick Moore. This translates into disparities in the way
VPD polices Patriot Prayer and Gibson, versus Gibson’s adversaries.
For the event at the city attorneys’ homes on June 2, created by Gibson, a couple of public officials
decided to move their families out of town to an undisclosed location “because they were growing more
concerned for their safety.”108 In spite of these concerns and evidence that city attorneys McClure and
Young were being harassed and intimidated, Officer Long’s report states CCSO “had made them aware
they would not be responding to terminate the protest in front of McClure’s residence unless there was
an emergency.”109 In other words, law enforcement did not intervene in the protest or arrest anyone.
Similarly, VPD Sergeant Moore’s supplemental report depicts Gibson and WA3% as law-abiding and
respectful during the protests, essentially erasing any concern that public officials had about the protests
by these white supremacist extremists:
In summary, organizer Kelli Steward [sic] of the People’s Rights of Washington,

along with Joey Gibson from the group Patriot Prayer, held an organized protest out
front of Assistant City Attorney’s Kevin McClure’s residence…During all these
events, organizers Kelli Stewart and Joey Gibson both reminded individuals
attending to not commit any crimes, do not trespass, do not threaten or intimidate,
do not violate the VMC noise ordinance and to make sure they clean up after
104
Video is no longer available. Here is a link to the screenshot of the YouTube video Gibson made, titled
“Call2Action: Portland Antifa coming to Vancouver, WA tonight.”
https://twtext.com/article/1322298850531373059.
105
SPLC Statement on Proud Boys Rally in Portland, Ore, SPLC S. POVERTY L. CTR.,
https://www.splcenter.org/presscenter/splc-statement-proud-boys-rally-portland-ore.
106
Katie Shepherd, Patriot Prayer Leader Joey Gibson Will Face Criminal Charges in May Day Riot, His Lawyer
Says, WILLAMETTE WEEK (Aug. 15, 2019), https://www.wweek.com/news/courts/2019/08/15/patriot-prayer-
leader-joey-gibson-will-face-criminal-charges-in-may-day-riot-his-lawyer-says/.
107
Affidavit in Support of Arrest Warrant for Violation at 2, Oregon v. Gibson, No. 19CR53042 (Cir. Ct. Or. Aug.
12, 2019); see also Documents Detail Joey Gibson’s Felony Riot Charge, KOIN (Sept. 5, 2019),
https://www.koin.com/news/crime/documents-detail-joey-gibsons-felony-riot-charge/.
108
Affidavit in Support of Arrest Warrant for Violation at 2, Oregon v. Gibson, No. 19CR53042 (Cir. Ct. Or. Aug.
12, 2019) at p. 7.
109
Id. at p. 8.
16
themselves when they leave the area.”110
In October 2020, VPD launched an investigation into comments Moore made in an interview with a
defense attorney about the police response to the Patriot Prayer demonstration in front of the city
attorneys’ homes.111 According to city attorney Jonathan Young, who was present for the interview and
lodged the complaint, in the interview, Moore said Gibson is “ not the problem” at protests and that he
“attracts an unwelcome crowd, specifically antifa and Black Lives Matter.”112
Moore’s bias towards Patriot Prayer and Gibson is also evident in a June 2020 email communication to
“City VPD Command” about efforts to plan for upcoming events and protests relating to the police
murder of George Floyd.113 Moore wrote:
I called and spoke with Joey Gibson There is a lot of misinformation being sent out
on social media by a [sic] various groups. Joey has been pretty vocal and typically
posts all his events and appearances on social media. During our conversation, I asked
Joey about his upcoming events. Joey stated he doesn’t have current events planned,
nor did he plan on attending other events planned by other organizations. However,
he mentioned if there were an event planned by Black Lives Matter, ‘there would be
people there to monitor the event.’ Joey was cooperative and stated I could call him
at any time for information114
Moore’s portrayal of Gibson as helpful, trustworthy, and transparent, shows favorable bias toward
Gibson and Patriot Prayer over other “various groups” that according to Moore, sow misinformation.115
He depicts Gibson as someone who stays out of the fray and who is a helpful resource to the police.116
In the email, he states plainly and without reproach that Gibson plans to deploy “people” (presumably
his supporters) to surveil any event planned by BLM.117 The fact that Moore makes this statement
without acknowledging how concerning this would be to Black and brown communities suggests that
perhaps Moore sees Gibson and his followers as law enforcement allies. At the very least, it is
representative of the larger trends, described in this letter, of white supremacist groups engaged in
violent conduct acting with impunity from law enforcement.
The records described above, including VPD’s email communications, police reports, and operational
plans, corroborate the experience of the community with disparate policing, as described throughout
this letter. As explained in detail above, Gibson and Patriot Prayer enjoy extreme deference from Moore
and VPD. Moore’s regard for Gibson and Patriot Prayer and his averseness to their adversaries like
BLM belies the role that Gibson and his followers often play at events as instigators of violence against
Black people and people of color, often in partnership with the Proud Boys.118 It also does not account
for the significant community concern about Gibson and Patriot Prayer’s presence in Vancouver and
110
Id. at p. 41.
111
Jerzy Shedlock, Vancouver Police Department Investigates Sergeant’s Comments on Patriot Prayer, BLM,
THE COLUMBIAN (Oct. 14, 2020), https://www.columbian.com/news/2020/oct/14/vancouver-police-department-
investigates-sergeants-comments-on-patriot-prayer-blm/.
112
Id.
113
Email from Pat Moore, Sergeant, Vancouver Police Dep’t, to City VPD Command DL (June 3, 2020, 9:37 PM)
(on file with author).
114
Id.
115
Id.
116
Id.
117
Id.
118 SPLC Statement on Proud Boys Rally in Portland, Ore, SPLC S. POVERTY L. CTR. (Sept. 25, 2020),
https://www.splcenter.org/presscenter/splc-statement-proud-boys-rally-portland-ore.
17
Clark County, which Moore is very much aware of. Public records show an abundance of emails to
VPD from individual community members leading up to and in the aftermath of Patriot Prayer
demonstrations, detailing fear and concerns about the group and Gibson specifically. One email in
particular details the experience of a Black person being accosted by a Patriot Prayer follower.119 Yet
none of this is reflected in the way VPD (or CCSO) treat Gibson and Patriot Prayer.
b. Proud Boys and ties with Patriot Prayer
Patriot Prayer and Gibson “attract[ ] many who are openly racist, and white supremacists have praised
the group.”120 According to Randy Blazak, a sociology professor at the University of Oregon who has
studied hate crimes and hate groups for 25 years, although Gibson and others claim to hold events in
support of, among other things, free speech, “they often don’t really care about the free speech of, say,
Muslims or Black Lives Matter.”121 Patriot Prayer and the Proud Boys regularly team up at violent
rallies and are a common fixture at protests in both Vancouver and Portland.122 The Proud Boys have
been described by various U.S. counter-terrorism/law enforcement agencies and hate watchdog groups
as a dangerous white supremacist group or gang.123 Accordingly, SPLC designates them as a hate group
and “one of a handful of far-right groups instrumental in instigating violence and unrest in the Pacific
Northwest,” although their reach goes much farther than this region.124
An internal affairs report from the CCSO describes the recruiting activities of the Proud Boys in the
Southwest Washington and Oregon areas and their engagement in the escalation of violence at political
rallies.125 The report notes that in 2018, the FBI included the Washington-Oregon Proud Boys during a
presentation to the CCSO on “domestically inspired acts of violence.”126 It also details that a CCSO
deputy sheriff was fired for discriminatory and harassing conduct after her connections to the Proud
Boys group became publicly known.127 Clark County Deputy Erin Willey was placed on leave and
ultimately terminated for posting multiple photos of herself in “Proud Boys Girls” apparel and
admitting to participating in a Proud Boys initiation ritual by videotaping a physical, violent attack as a
119
Email from Julia Berreth, Vancouver resident, to VANPD, (September 1, 2020, 11:11 AM), (on file with
author).
120
Daniel Politi, What Is Patriot Prayer?, SLATE (Aug. 30, 2020), https://slate.com/news-and-
politics/2020/08/what-is-patriot-prayer-far-right-group-confrontations-portland.html.
121
Lilly Fowler, Patriot Prayer Leader Dislikes Racists, But They Seem to Hear a Whistle, CROSSCUT (Aug. 24,
2017), https://crosscut.com/2017/08/patriot-prayer-joey-gibson-white-supremacists-rally.
122
What We Know About Patriot Prayer, SPLC S. POVERTY L. CTR., (Aug. 31, 2020),
https://www.splcenter.org/hatewatch/2020/08/31/what-we-know-about-patriot-prayer.
123
Jason Wilson, Proud Boys Are a Dangerous ‘White Supremacist’ Group Say US Agencies, THE GUARDIAN
(Oct. 1, 2020), https://www.theguardian.com/world/2020/oct/01/proud-boys-white-supremacist-group-law-
enforcement-agencies.
124
For example, members of the Proud Boys were participants in the Unite the Right Rally in Charlottesville,
Virginia in 2017, which was organized by a former Proud Boys member. Proud Boys, SPLC S. POVERTY L. CTR.,
https://www.splcenter.org/fighting-hate/extremist-files/group/proud-boys . Moreover, so far 30 individuals with
alleged connections to the Proud Boys have been charged in the January 6, 2021 Capitol Riot. Tim Mak, Some
Proud Boys Are Moving to Local Politics as Scrutiny of Far-Right Group Ramps Up, NPR (June 28, 2021),
https://www.npr.org/2021/06/28/1010328631/some-proud-boys-are-moving-to-local-politics-as-scrutiny-of-far-
right-group-ramp.
125
Conrad Wilson, Clark County Report Says FBI Classifies Proud Boys as Extremist Group, OPB (Nov. 19,
2018), https://www.opb.org/news/article/fbi-proud-boys-extremist-group-white-nationalism/.
126
Amelia Templeton & Conrad Wilson, Portland FBI Head Clarifies Statement on Proud Boys, OPB (Dec. 4,
2018), https://www.opb.org/news/article/portland-fbi-proud-boys-clarifies-statement/.
127
Andy Matarrese, Deputy Fired Over Proud Boys Sweatshirt, COLUMBIAN (July 20, 2018),
https://www.columbian.com/news/2018/jul/20/clark-county-sheriffs-deputy-fired-proud-boys-sweatshirt/.
18
means of gaining membership.128 A journalist brought Willey’s membership with the Proud Boys to
light.129 In 2020, she joined the Napavine Police Department and now patrols a community just about an
hour north of Clark County.130
Although this deputy was terminated, community members have reason to believe there remain close
ties between extremist groups and law enforcement officers in the area, for the reasons discussed below.
The past known infiltration of extremists and ongoing evidence of line officers’ tolerance of extremist
crime suggests DOJ investigation into these ties is warranted.
c. COPS NW
Like Patriot Prayer and Gibson, COPS NW and its founder and leader Audra Price, enjoy friendly ties
with local law enforcement in Clark County and Portland, Oregon. She and COPS NW are responsible
for inciting violence against the Kevin Peterson Jr. vigil-goers by amplifying the event on her platform.
Those who have been observing and documenting the proliferation of extremist groups note the
increasing cross-pollination between these arguably ideologically fringe groups and the more
mainstream groups.131 The rise of COPS NW and its association with the Proud Boys, Patriot Prayer,
and other extremist groups is emblematic of this trend. COPS NW describes itself as a “Back the Blue”
group supporting the police in the Southwest Washington and Portland areas.132 Price has carefully
cultivated an image of COPS NW as a group that opposes BLM and has self-deputized the white
supremacist extremist group as there to lend support to local law enforcement as they battle with these
groups to protect cities from danger and destruction.133 This is a narrative that Price, the daughter of a
retired deputy, spreads via various media.134
For example, COPS NW’s public facing Instagram (which belongs to Price)135 features groups of adults
and children dressed in blue, holding up pro-law enforcement signs and waving American “Thin Blue
Line” flags at street corners. Some of the adults are armed.136 Price also appeared on the Lars Larson
Show in August 2020 where, through lies lacking any reality, she described BLM protestors as violent
rioters who are “now moving into residential areas…and they are attacking residential areas, people that
are in their own homes, and we’re scared to death and… we don’t know what to do….We’re trying to
hold onto our cities.”137 She and the show’s host indicate that BLM protesters do these things with
impunity because the “hands of police” are tied and there isn’t political will to arrest and hold
128
Brandy Zadrozny & Corky Siemaszko, The Boys and Girls of White Nationalism: ‘Proud’ Groups Labeled
‘Extremist’ in Newly Revealed FBI Files, NBC NEWS (Nov. 20, 2018), https://www.nbcnews.com/news/us-
news/boy-girls-white-nationalism-proud-groups-labeled-extremist-newly-revealed-n938546.
129
Id.
130
Jackson Gardner, Napavine Police Department Hired Woman Fired from Clark County Sheriff’s Office for
Affiliation with Proud Boys, THE CHRONICLE (July 27, 2020), https://www.chronline.com/stories/napavine-police-
department-hired-woman-fired-from-clark-county-sheriffs-office-for-affiliation,2277.
131
Jason Wilson, Proud Boys Are a Dangerous ‘White Supremacist’ Group Say US Agencies, THE
GUARDIAN (Oct. 1, 2020), https://www.theguardian.com/world/2020/oct/01/proud-boys-white-supremacist-group-
law-enforcement-agencies.
132
Hannah Ray Lambert, Back the Blue: Police Supporters Rally Outside Justice Center, KOIN (July 6, 2020),
https://www.koin.com/news/special-reports/back-the-blue-police-supporters-rally-outside-justice-center/.
133
Id.
134
Id.
135
Audra Price (@copsnw), INSTAGRAM, https://www.instagram.com/copsnw/?hl=en (last visited Sept. 30, 2021).
136
See id.
137
Portland’s “Peaceful Protesters” Have Shown That They Are Everything But Peaceful, LARS LARSON SHOW
(Aug. 11, 2020), https://www.larslarson.com/portlands-peaceful-protesters-have-shown-that-they-are-everything-
but-peaceful/.
19
accountable supporters of this movement. Along with other COPS NW members Shelby Walman and
Sally Hill, Audra is quoted in a July 2020 article that promotes this narrative.138
The narrative Price has crafted belies more nefarious activities that her group engages in with Patriot
Prayer, the Proud Boys, and individually known Neo-Nazis. Under the guise of being pro-police and
pro-community safety, Price provides venues, both online (via her private COPS NW Facebook page)
and in person (e.g., through innocuous sounding “flag waves”), for these groups to fraternize and
foment hate and violence against Black community members and those in support of BLM.
Like Patriot Prayer, COPS NW amplified the counter-protest for the Peterson vigil. More specifically,
Price wrote on the private COPS NW Facebook page:
Antifa will show up, but we don’t need to be afraid. It’s time we start standing up in
larger numbers. They WILL move into our neighborhoods if we don’t take a
stand...If you think you are safe at home, you are not. It’s time to take a stand for our
families and for our country.139
There is also evidence that COPS NW, Price and others made unsupported statements on Facebook that
there was rioting the night before and that city infrastructure was being targeted with explosives, as a
tactic for motivating people.140 In another post she wrote, “Vancouver meeting place for flagwave [sic]
tonight is Fred Meyer in hazel dell. I updated the event.”141 One of the commenters on the posts
attempts to dissuade Price and her followers from attending the event, citing “Our Patriots/Protectors
are going to have their hands full tonight and they shouldn’t need to worry about another group of
people to protect or look after...I’m sure Vancouver police feel the same.”142 In response, Price wrote “I
was asked to make the flagwave [sic] there by patriot.”143 When asked who the “patriot” is, Price wrote,
“with respect, that should not be openly discussed...”144 Although it is not clear who “patriot” is, Price
has often been a mouthpiece for Gibson and Patriot Prayer.
There are additional indications that local law enforcement is in communication with members of
COPS NW ahead of protests. In one direct message, for example, a law enforcement officer in
Vancouver allegedly wrote that “patriots” and “pro law enforcement supporters” are “NEEDED to help
protect the city.”145 A screenshot of this message was pasted to the COPS NW Facebook page, along
with the following message from Price: “Needing patriots again tonight in Vancouver. We have been
asked for assistance by our LEOs, so please invite everyone you know. This is it guys. This is where the
rubber meets the road. They need us and we need to be there for them every night if that’s what it
takes.”146
138
Hannah Ray Lambert, Back the Blue: Police Supporters Rally Outside Justice Center, KOIN (July 6,
2020), https://www.koin.com/news/special-reports/back-the-blue-police-supporters-rally-outside-justice-
center/; Jason Wilson, Breadth of Rightwing Portland Protest Network Reveals Energized Trump Base, THE
GUARDIAN (Sept. 3, 2020), https://www.theguardian.com/us-news/2020/sep/03/how-the-rightwing-portland-
protest-organizers-represent.
139
John – Full Rev Media, TWTEXT.COM, https://twtext.com/article/1322298850531373059.
140
John – Full Rev Media, TWTEXT.COM, https://twtext.com/article/1322298850531373059.
141
@RoseCityAntifa, TWITTER (Nov. 3, 2020, 3:31 PM),
https://twitter.com/RoseCityAntifa/status/1323769802083627009/photo/1.
142
Id.
143
Id
144
Id.
145
@Johnnthelefty, TWITTER (Nov. 1, 2020, 6:31 PM),
https://twitter.com/Johnnthelefty/status/1323090389289504770/photo/1.
146
Id. at https://twitter.com/Johnnthelefty/status/1323090389289504770/photo/2.
20
d. WA3%
In addition to the Proud Boys, Patriot Prayer has attracted extremist groups like Oath Keepers and the
Three Percenters (WA3%), founded by Matt Marshall.147 WA3% is a militia organization and a sub-
group to the national Three Percenters, “anti-government extremists who are part of the militia
movement.” 148
Under Marshall’s leadership, WA3% “allied its cause” with the Proud Boys and Patriot Prayer.149
Although Marshall’s role changed recently, he remains in leadership. In his words, “I still 100% support
[WA3%’s] cause and mission.”150 In March 2021, as part of a training on Extremist Organizations and
Activities, the US Department of Defense and Joint Base Lewis-McChord designated WA 3% as an
antigovernmental militia151 and included them on an extremist list that includes two dozen other
extremist groups including the Proud Boys.152
In an email from Marshall to WA3% members and followers, titled “JBLM [Joint Base Lewis-
McChord] Spreading Political Propaganda,” Marshall objects to being classified as an
“antigovernmental/criminal gang” because WA3% “has had communications/interactions about our
events for pre-planning” with a host of law enforcement entities, including Capitol Police, Washington
State Patrol, Washington State Sheriff’s association, Seattle Police, Tacoma Police, Olympia Police,
and the FBI Seattle Field Office.”153 In the email, Marshall also states he was invited to speak at the
Washington State Sheriff’s Association quarterly meeting in 2020.154
This information suggests that WA3% and Marshall have close, friendly ties with local law
enforcement throughout Washington state. This friendliness was reflected in the way VPD treated
WA3% protestors at the Carroll event described above, and at the Patriot Prayer demonstration in front
of City Attorneys’ homes on June 28, 2020.
5. White supremacist extremist groups in Clark County WA and Multnomah County OR

coordinate and act regionally with each other and local law enforcement: Supremacist groups
and ties to Portland Law Enforcement
Patriot Prayer is very active in violent demonstrations in Portland, Oregon, where Gibson has close
personal ties with Lieutenant Jeff Niiya, the head of the Portland Police Bureau Rapid Response Team,
147
Jane Coaston, The Pro-Trump, Anti-Left Patriot Prayer Group, Explained, VOX (Sept. 8, 2020),
https://www.vox.com/2020/9/8/21417403/patriot-prayer-explained-portland.
148
Three Percenters, ADL, https://www.adl.org/resources/backgrounders/three-percenters (last visited Sept. 30,
2021).
149
Chuck Tanner & Devin Burghart, Far-Right, Militia to Press Clark County Sheriff to Join Reopen Cause,
IREHR (June 22, 2020), https://www.irehr.org/2020/06/22/far-right-militia-to-press-clark-county-sheriff-to-join-
reopen-cause/#_ftnref13.
150
Id.
151
Joel Moreno, Washington Three Percenters Say Defense Department Is Wrong to Label Them Extremists,
KOMONEWS (Mar. 22, 2021), https://komonews.com/news/local/washington-three-percenters-say-defense-
department-is-wrong-to-label-them-extremists.
152
Id.
153
E-mail from Matt Marshall, Founder/Pub. Rels. Wash. 3%, to Wash. 3% (Mar. 20, 2021, 12:03 AM) (on file
with author).
154
Id.
21
which patrols political rallies.155 In 2019 Niiya came under fire after a local paper revealed hundreds of
text messages from 2017 and 2018 between him and Gibson.156 Despite Niiya’s official role as a
commanding officer tasked with communicating with protest organizers, the text messages revealed a
friendly and cooperative relationship between Patriot Prayer, Gibson and the lieutenant that go beyond
event planning.
Texts between Niiya and Gibson indicate law enforcement coordinated with white supremacist
extremist groups by providing Gibson legal and tactical information, including notice of the movements
of counter-protestors during demonstrations and “warned Gibson to tell Patriot Prayer members with
active warrants to keep a low profile at demonstrations so as not to draw police attention.”157 Niiya even
offered wishes of congratulations to Gibson on his plans to run for Senate, expressing concern for the
safety of his family: “I want you to know you can trust me. Don’t want to burn that.”158 In another text
exchange, Gibson apologized to Niiya for making a public announcement that “Portland police has our
back,” writing that “It slipped.”159 Corroborating those texts is a video from Gibson’s livestream at a
violent rally in Portland on June 3, 2018, which shows Portland police officers essentially making a
deal with members of Patriot Prayer to avoid their arrest, in spite of probable cause to arrest them.160
According to the officers in the video, the deal was authorized by Lieutenant Niiya.161 This deal,
however, was not extended to counter-protesters. Nevertheless, an investigation by the Independent
Police Review, a division of the City Auditor’s Office, cleared him of wrongdoing.162
This is not the first time a member of law enforcement coordinated with Patriot Prayer and Gibson over
counter-protestors. In 2019, Thurston County resident Joseph Robinson filed a civil lawsuit against
Gibson, other members of Patriot Prayer, and three Washington State Patrol officers, alleging these
parties violated his civil rights in 2017 at a protest at Evergreen State College that turned violent.163
According to Robinson’s lawyer, Gibson and members of Patriot Prayer “grabbed [Robinson], threw
him to the ground, searched him and dragged him over to officers and said, ‘Arrest him,'” - which is
what the they did.164 Charges against Robinson were dropped but not before a year had passed.
More recently, in August 2021, it was documented that the Portland Police Bureau (PPB) officially
chose to “stand back” and let the Proud Boys violently attack protesters, resulting in an exchange of
155
Jason Wilson, Portland Police and Far-Right Leader Had Friendly Relationship, Texts Reveal, THE GUARDIAN
(Feb. 15, 2019), https://www.theguardian.com/world/2019/feb/15/joey-gibson-portland-police-relationship-
cooperation-text-messages.
156
Text Conversations, POLICE BUREAU, https://www.portlandoregon.gov/police/78708.
157
Text Messages Between Patriot Prayer Leader, Portland Cop Spur Calls for Investigation, OREGONLIVE (Feb.
15, 2019), https://www.oregonlive.com/portland/2019/02/text-messages-between-patriot-prayer-leader-portland-
cop-spur-calls-for-investigation.html.
158
Jason Wilson, Portland Police and Far-Right Leader Had Friendly Relationship, Texts Reveal, THE GUARDIAN
(Feb. 15, 2019), https://www.theguardian.com/world/2019/feb/15/joey-gibson-portland-police-relationship-
cooperation-text-messages.
159
Alex Zielinski, Texts Show Protective Relationship Between Portland Cops and Patriot Prayer, PORTLAND
MERCURY (Feb. 14, 2019), https://www.portlandmercury.com/blogtown/2019/02/14/25885836/texts-show-
protective-relationship-between-portland-cops-and-patriot-prayer.
160
Jason Wilson, Exclusive: Video Shows Portland Officers Made Deal with Far-Right Group Leader, THE
GUARDIAN (Mar. 1, 2019), https://amp.theguardian.com/us-news/2019/mar/01/exclusive-video-shows-portland-
officers-made-deal-with-far-right-group-leader.
161
Id.
162
Independent Police Review, (May 22, 2019), https://www.portlandoregon.gov/ipr/article/741821.
163
Jonathan Levinson, Civil Rights Lawsuit Filed Against Joey Gibson and Washington Police Officers, OPB
(Nov. 5, 2019), https://www.opb.org/news/article/washington-police-officers-joey-gibson-civil-rights-lawsuit-
patriot-prayer/.
164
Id.
22
gunfire on a downtown street.165 And in October 2021, it was reported that “dozens” of Oregon law
enforcement officers, including those currently at PPB, have joined the Oath Keepers extremist group
since 2009; several members of the group have been charged with crimes in connection with the
January 6 insurrection at the US Capitol.166
In October 2020, COPS NW, Price and another organized a GoFundMe on behalf of COPS NW to
benefit the Portland Police Bureau’s Rapid Response Team (RRT), the same entity helmed by
Lieutenant Niiya who shared friendly texts with Patriot Prayer’s Gibson.167 They sought to support the
RRT for spending “140 plus days responding to violent attacks from Antifa and BLM.”168 An update
from December 2020, featuring a photo of Price with the RRT after raising $5,480 in gift cards and
gifts,169 suggests that COPS NW is currying favor with law enforcement, both by villainizing and
attacking BLM and through the use of expensive gifts, which do not appear to have been rejected by
RRT. Undoubtedly, COPS NW and Price are relying on the notion that they have the support and
backing of Portland law enforcement to encourage followers to show up to peaceful demonstrations
with the sole purpose of sowing violence.
D. THE PROBLEM OF SYSTEMIC RACISM IN CLARK COUNTY/VANCOUVER

CONNECTED TO POLICE CIVIL RIGHTS VIOLATIONS
Institutional bias and racism against Black and brown people in Clark County and Vancouver extend
well beyond policing and is a systemic problem that is often initiated through policing. It is pervasive in
the jail system, the court system, and in its main lawmaking body.
1. Clark County Jail Violates the Rights of People of Color
In May 2019, Washington State passed the Keep Washington Working Act (KWW), which prohibits
information sharing and collaboration between local law enforcement and federal immigration agencies.
Since then, the ACLU-WA has obtained emails between Clark County and ICE, through a Public
Records Act request by the University of Washington Center for Human Rights (UWCHR), which
show evidence of systematic information sharing in violation of KWW. This includes Clark County jail
staff responding to ICE requests for information, flagging specific inmates for ICE based on the
inmate’s nationality.170 These “almost daily” actions to share information with immigration authorities
target the Latinx community,171 despite only being 10.2% of the population.172 In April 2020, where jail
staff facilitated the immigration detention of a Mexican citizen, despite the state law prohibition on
doing so, the detainee’s brother said, “I think that you should not be judged by the color of your skin. ...
165
Robert Mackey, Portland’s Bizarre Experiment With Note Policing Proud Boys Rampage Ends in Gunfire,
INTERCEPT (Aug. 23, 2021), https://theintercept.com/2021/08/23/portland-police-proud-boys-protest/.
166
Jonathan Levinson, Dozens of Oregon Law Enforcement Officers Have Been Members of the Far-Right Oath
Keepers Militia, OPB (Oct. 15, 2021), https://www.opb.org/article/2021/10/15/dozens-of-oregon-law-
enforcement-officers-joined-far-right-oath-keepers-militia/.
167
Chri Sta & Audra Price, Christmas Gift Baskets for Portland RRT, GOFUNDME (Dec. 20, 2020),
https://www.gofundme.com/f/christmas-gift-baskets-for-portland-rrt.
168
Id.
169
Id.
170
See UWCHR’s August 2020 report detailing these systemic violations. Protecting Immigrant Rights: Is
Washington’s Law Working?, THE HENRY M. JACKSON SCHOOL INT’L STUDIES (Aug. 11, 2021),
https://jsis.washington.edu/humanrights/2021/08/11/protecting-immigrant-rights-is-washingtons-law-working/.
171
Troy Brynelson, Clark County Jail’s Communications with ICE Raise Legal Questions, OPB (July 1, 2021),
https://www.opb.org/article/2021/07/01/clark-county-jail-communications-with-ice-raise-legal-questions/.
172
Quick Facts Clark County, Washington, U.S. CENSUS BUREAU,
23
Just because your name is not John Smith,” he said, “you get to be treated differently.’”173 Clark
County’s repeated violations of state law meant to protect immigrants and their communities is further
evidence of the disparate treatment by local law enforcement of its residents who are people of color
and is indicative of a problem that is widespread and systemic.
2. Clark County Courts Have Documented Evidence of Blatant Racism
Similar to Clark County jail, racism has also been documented within the Clark County court system.
Transcripts from a recent conversation between Clark County District Court Judge Darvin Zimmerman
and another recently revealed that anti-Blackness is present throughout the legal system, including in
the courts. Speaking to a County Commissioner in a courtroom about the death of Kevin Peterson Jr.,
Judge Zimmerman described Peterson as, “[t]he Black guy they were trying to make an angel out of,”
and said he believed Peterson had a “death wish” and referred to Peterson as “so dumb.”174 Further
describing Peterson’s family member, Judge Zimmerman commented, “[t]he next day, he wakes up
with dollar signs in his eyes and George Floyd’s attorneys had already contacted him,” and that the
family’s GoFundMe page was “like getting money under false pretenses.”175 Following the release of
the transcript, community members reported feeling unable to trust judges such as Judge Zimmerman to
rule without prejudice when they know them to have such anti-Black bias.176
3. Clark County Council Has Documented Evidence of Racial Bias
At a series of listening sessions in mid-2020 in front of the Clark County Councilors, speakers from the
NAACP of Vancouver, the YWCA, the Southwest Washington League of United Latin American
Citizens, and the Clark County Volunteer Lawyers Program outlined systemic racism in the county.
One member of the NAACP Vancouver Legal Redress Committee noted that “systemic racism in Clark
County is alive and well today.”177 The NAACP Vancouver Vice President explained that systemic
racism is a longstanding problem in Clark County that can be traced back to a tight connection between
the Ku Klux Klan and county leadership in the 1920s and 1930s.178
At least one member of the Clark County Council, Chair Eileen Quiring, publicly declared during a
council meeting that she does not believe Clark County has any systemic racism.179 Following her
remarks, the NAACP Vancouver and the League of United Latin American Citizens (LULAC) called
173
Troy Brynelson, Clark County Jail’s Communications with ICE Raise Legal Questions, OPB (July 1, 2021),
https://www.opb.org/article/2021/07/01/clark-county-jail-communications-with-ice-raise-legal-questions/.
174
Fox 12 Staff, Clark Co. Judge Caught Making Comments about Black Man Killed by Police Plans to Retire,
Fox 12 Oregon (Jun. 3, 2021), https://www.kptv.com/news/clark-co-judge-caught-making-comments-about-
black-man-killed-by-police-plans-to-retire/article_75bcf736-c4ac-11eb-ac82-db46673aa504.html.
175
Id.
176
Jerzy Shedlock & Jessica Prokop, Clark County Judge Faces Condemnation, Call for Resignation After
Comments, COLUMBIAN (Mar. 15, 2021), https://www.columbian.com/news/2021/mar/15/clark-county-judge-
faces-condemnation-call-for-resignation-after-comments/.
177
Chris Brown, Clark County Organizations Detail Systemic Racism in First of Three Listening Sessions, Clark
County Today (Aug. 4, 2020), https://www.clarkcountytoday.com/news/clark-county-organizations-detail-
systemic-racism-in-first-of-three-listening-sessions/.
178
Id.
179
Jack Heffernan, Ethics Complaint Filed Against Quiring Over Systemic Racism Discussion, THE COLUMBIAN
(July 3, 2020), https://www.columbian.com/news/2020/jul/03/ethics-complaint-filed-against-quiring-over-
systemic-racism-talks/.
24
for her resignation.180 In NAACP’s letter to Chair Quiring, community members expressed they were
“deeply concerned by [her] denial of the systemic racism that exists in Clark County.”181 Similarly, the
LULAC letter stated, “[t]hrough her expressive racist statement, Quiring has demonstrated a callous
disregard for Black and brown people living in Clark County. In our community, racial inequities are
visible in the law, as well as in thoughts, actions and inactions.”182
In response to repeated outcries from affected community members and organizations, the Clark
County Council, which doubles as the county’s health board, passed a resolution declaring systemic
racism in Clark County a public health crisis.183
E. THE HARM INFLICTED BY POLICE ON THE VANCOUVER/CLARK COUNTY

COMMUNITIES OF COLOR CAUSES PHYSICAL, EMOTIONAL, AND
PSYCHOLOGICAL HARMS
The disparate treatment of the VPD, CCSO, and the Task Force toward people of color significantly
impacts the local community emotionally, psychologically, and physically. Police brutality is a social
determinant of a community’s overall health. Police brutality is more than just physical, excessive or
deadly use of force—it also constitutes emotional violence, psychological intimidation and verbal
assault.184 Such brutality is dehumanizing, particularly to Black residents, who are significantly more
likely to experience police brutality than whites.185
The experience of communities of color—who are subjected to harassment, routine unwarranted

searches, and deaths— “send[s] a message” that “their bodies are police property, disposable, and
undeserving of dignity and justice.”186 By repeatedly and continuously experiencing and witnessing
police brutality, communities of color face increased physical, emotional and psychological stress.
Communities of color should not disparately be subjected to these harms.
1. The Mental Health Impact of Police Brutality on Communities of Color
Disparate treatment of communities of color by law enforcement exacerbates mistrust towards law
enforcement.187 Excessive use of force by law enforcement results in fear and distrust from
communities whom the police are sworn to protect.188 Law enforcement failure to protect their
constituents’ rights constitutes an “abuse of authority” and a “breach of trust,” and is likely to have an
180
Jessica Prokop, NAACP, LULAC Call for Clark County Council Chair Quiring to Step Down Over Remarks,
COLUMBIAN (June 27, 2020), https://www.columbian.com/news/2020/jun/27/naacp-lulac-call-for-clark-county-
council-chair-quiring-to-step-down-over-remarks/.
181
Id.
182
Id.
183
John Notarianni, Clark County Declares Racism a Public Health Crisis, OPB (Dec. 7, 2020),
https://www.opb.org/article/2020/12/07/clark-county-declares-racism-public-health-crisis/.
184
Sirry Alang, et al., Police Brutality and Black Health: Setting the Agenda for Public Health Scholars, Am J
Public Health. 107(5), 662–65 (May 2017).
185
Id.
186
Id.
187
Investigation of the Baltimore City Police Department, U.S. DEP’T OF JUST., 4, 7 (Aug. 10, 2016),
https://www.justice.gov/crt/file/883296/download (stating that there is profound lack of trust among African
American residents as a result of targeting policing disproportionately harming African-American residents).
188
Id. at 23; see also Glob. Neigh. v. Respect Wash., 7 Wn. App. 2d 354, 402, 434 P.3d 1024, 1049-50 (2019)
(quoting Parada v. Anoka Cty., 332 F. Supp. 3d 1229, 1235 (D. Minn. 2018)) (recognizing that Latinos are less
likely to report crimes, even when they are victims, to law enforcement due to fear that the police will inquire about
immigration status); see also Binette v. Sabo, 244 Conn. 23, 43–44, 710 A.2d 688, 698 (1998).
25
“even more harmful, emotional and psychological effect on the aggrieved citizen than that resulting
from the tortious conduct of a private citizen.”189
The increased distrust of law enforcement can significantly decrease the likelihood that individuals seek
assistance from law enforcement when they are victims of a crime.190 Thus, there is a growing concern
regarding community mistrust among people of color in Vancouver towards VPD, CCSO, and the Task
Force, which further alienates potential allies in crime prevention.
“While the Vancouver Police Department targets Black and brown residents with disproportionate
harassment, arrests, shootings and killings, it continues to look the other way as armed White militants
and vigilantes disrupt and endanger peaceful gatherings,” said Shareefah Hoover from the Clark County
Justice Group. “This disparate treatment must stop. Until the Vancouver Police Department
demonstrates the same commitment to safeguarding the lives and rights of Black and brown people as it
does to right-wing terrorists, we will continue to see a decline in trust between community members
and law enforcement officers.”
It is also both disturbing and unsurprising that the disproportionate use of police force on communities
of color is associated with poor mental health. Trauma, hopelessness, anxiety, and fear are all stressors
experienced by people of color.191 Police violence is associated with greater odds for distress and
suicide attempts among people of color.192 People of color experience “trauma, anxiety, hopelessness,
and fear about future police encounters.”193 Indeed, studies show that individuals who report more
contact with the police also report “more trauma and anxiety symptoms.”194 In 2018, a study found that
police killings of unarmed Black people were associated with increased mental health problems for
Black individuals living in that state over the following three months.195 This is a significant public
health issue since there are, on average, roughly 1,000 police killings in the US annually, and Black
189
Binette v. Sabo, 244 Conn. 23, 44, 710 A.2d 688, 698 (1998).
190
Investigation of the Ferguson Police Department, U.S. DEP’T OF JUST., 79 (Mar. 4, 2015),
https://www.justice.gov/sites/default/files/crt/legacy/2015/03/04/ferguson_findings_3-4-15.pdf.
191
Ana Sandoui, Police Violence: Physical and Mental Health Impacts on Black Americans, MED. NEWS TODAY
(June 22, 2020), https://www.medicalnewstoday.com/articles/police-violence-physical-and-mental-health-
impacts-on-black-americans#Consequences-for-mental-health.
192
Univ. of Michigan, Study Identifies How Police Violence Contributes to Mental Health Woes, VICE PRESIDENT
FOR COMMC’NS MICH. NEWS UNIV. OF MICH. (Oct. 1, 2020), https://news.umich.edu/study-identifies-how-police-
violence-contributes-to-mental-health-woes/.
193
194
195
Christina Pazzanese, How Unjust Police Killings Damage the Mental Health of Black Americans, HARVARD
GAZETTE (May 13, 2021), https://news.harvard.edu/gazette/story/2021/05/how-unjust-police-killings-damage-the-
mental-health-of-black-americans/ ; see also Jacob Bor, Atheendar S Venkataramani, David R Williams, &
Alexander C Tsai, Police Killings and their Spillover Effects on the Mental Health of Black Americans, 392
LANCET 302, 306–307 (2018); see also David R. Williams, Jourdyn Lawrence, & Brigette Davis, Racism and
Health: Evidence and Needed Research, 40 Ann. Rev. of Pub. Health 105, 115 (2019); Lisa H. Thurau & Johanna
Wald, Police Killings, Brutality Damaging Mental Health of Black Community, USA TODAY (Sept. 15, 2018),
https://www.usatoday.com/story/opinion/policing/spotlight/2018/09/14/police-brutality-damaging-black-
communitys-mental-health/1218566002/ (stating that failure to treat police killings of unarmed black Americans
as a public health issue produces the following mental health problems: “heightened perceptions of threat and
vulnerability, lack of fairness, lower social status, lower beliefs about one own worth, activation of prior traumas,
and identification with the deceased.”).
26
Americans comprise a disproportionate 25%-30% of those killings.196
This study also found that police brutality negatively impacts the mental health of Black individuals,
even when there is no direct connection to those who have been killed by the police.197 In contrast,
police killings of unarmed white Americans had no effect on the mental health of white Americans.198
Thus, there is a causal link between perceived racism among Black people and depression, anxiety,
increased substance use, feelings of hopelessness, and suicidal ideation in Black adults and youth.199
“The pain of losing my brother is compounded by police doing nothing when white supremacists and
right-wing terrorists harass and attack us while we’re out trying to support other families who’ve lost
loved ones to police violence,” said Nickeia Hunter, whose brother Carlos Hunter was shot and killed
by Vancouver police in 2019. Members of her family were attacked with bear spray by white
supremacist extremists while attending a vigil for Kevin Peterson Jr. in October 2020. “We come
together to mourn and we’re attacked. We come together to protest inequality and we’re attacked. The
stress and anxiety caused by knowing there’s nowhere to go and no way to stay safe wears on you.”
Across the country, Black men are roughly 2.5 times more likely to be killed by police than are white
men, and Black women are roughly 1.4 times more likely to be killed by police than white women.200
Police use of force is a leading cause of death among young Black men.201 A 2018 study examined the
mental health of 38,993 Black adults who had exposure to one or more police killings of unarmed Black
individuals. This study found that Black adults with exposure to police killings reported more “poor
mental health days.”202 Police brutality impacts the mental health of communities of color.
2. The Physical Toll of Police Brutality on Communities of Color
Systemic racism and police brutality are public health issues which disproportionally affect
196
Christina Pazzanese, How Unjust Police Killings Damage the Mental Health of Black Americans, HARVARD
GAZETTE (May 13, 2021), https://news.harvard.edu/gazette/story/2021/05/how-unjust-police-killings-damage-the-
mental-health-of-black-americans/.
197
Lisa H. Thurau & Johanna Wald, Police Killings, Brutality Damaging Mental Health of Black Community,
USA TODAY (Sept. 15, 2018), https://www.usatoday.com/story/opinion/policing/spotlight/2018/09/14/police-
brutality-damaging-black-communitys-mental-health/1218566002/.
198
Jacob Bor, Atheendar S Venkataramani, David R Williams, & Alexander C Tsai, Police Killings and their
Spillover Effects on the Mental Health of Black Americans, 392 LANCET 302, 306–307 (2018).
199
Erin Streatean, Student Notebook: Police Brutality and Mental Health in the African American Community,
ASS’N FOR PSYCH. SCI. (Aug. 28, 2020), https://www.psychologicalscience.org/observer/police-brutality-mental-
health.
200
impacts-on-black-americans#Consequences-for-mental-health; see also Frank Edwards, Hedwig Lee & Michael
Esposito, Risk of Being Killed by Police Use of Force in the United States by Age, Race-Ethnicity, and Sex, PROC.
OF THE NAT’L ACAD. OF SCIS. OF THE U.S. OF AM., 116(34) (Aug. 20, 2019),
https://www.pnas.org/content/116/34/16793.
201
impacts-on-black-americans#Consequences-for-mental-health .
202
impacts-on-black-americans#Consequences-for-mental-health (citing Jacob Bor, et al., Police Killings and Their
Spillover Effects on the Mental Health of Black Americans: A Population-Based, Quasi-Experimental Study, 392
LANCET 10144 (June 21, 2018), https://www.thelancet.com/journals/lancet/article/PIIS0140-6736(18)31130-
9/fulltext .
27
communities of color. When faced with a threat, the human body “produces hormones and other signals
that turn on the systems that are necessary for survival in the short term.”203 This leads to increased
respiratory rate and increased heart rate.204 However, when the threat “becomes reoccurring and
persistent,” the stress results in “rapid wear and tear on organs and elevated allostatic load.”205 Chronic
stress can lead to diabetes, stroke, ulcers, cognitive impairment, autoimmune disorders, accelerated
aging, and death.206 The “deterioration of organs and systems caused by increased allostatic load occurs
more frequently in Black populations”207 because Black people are significantly more likely to be
subject to police violence in their lifetimes than white people.208
There is a “higher risk of diabetes and obesity” for those “living in minority communities with a high
concentration of use of force by police.”209 In communities with “large racial differences in police use
of force” there is also “an increased risk of poor/fair self-rated health [and] high blood pressure.”210
In addition to the physical conditions and diseases associated with police brutality, communities of
color also suffer “years of life lost” at a significantly higher rate than white communities. A 2018 report
estimated that years of life lost (YLLs), which “estimate the number of years a person could have lived
had they not died prematurely,” is a key metric “for comparing the burden of diseases and injuries
across different populations.”211 The study found that people of color, who make up only 38.5% of the
population, represent 51.5% of YLLs.212
The physical toll police brutality takes on people of color is extremely alarming. Even public reactions
to police brutality can exacerbate the physical stress felt by communities of color. The routine
justification of police killings, the scrutiny of Black people’s reactions to police brutality, the negative
assessments of the way people protest, and racist public reactions to violence – such as victim blaming
– all contribute to the disproportionate amount of chronic stress endured by communities of color.
“Listening to Judge Zimmerman's casual disregard for Kevin Peterson Jr.’s life felt like a physical
blow,” said Jasmine Tolbert, Vancouver NAACP President. “Not only did the judge fail to take Mr.
Peterson’s killing by police seriously, he mocked and insulted the family’s efforts to seek justice. When
people who hold positions of public trust react to a Black man’s killing like that, it sends a message that
our lives are not valued and takes a toll on the community—physically and emotionally.”
203
204
Id.
205
Id. Allostatic load is the cumulative burden of chronic stress on the human body. See also Duru OK, et al.,
Allostatic Load Burden and Racial Disparities in Mortality, J Natl Med Assoc. Jan-Feb; 104(1-2), 89–95 (2012).
206
207
Id.
208
Frank Edwards, Hedwig Lee & Michael Esposito, Risk of Being Killed by Police Use of Force in the United
States by Age, Race-Ethnicity, and Sex, PROC. OF THE NAT’L ACAD. OF SCIS. OF THE U.S. OF AM., 116(34) (Aug.
20, 2019), https://www.pnas.org/content/116/34/16793.
209
210
Id.
211
Id.
212
Id.
28
II. LEGAL AUTHORITY
The above-described patterns of civil rights violations by VPD, CCSO, and the Task Force, including
use of excessive force, disparate treatment harming communities of color and others, and disparate
treatment favoring violent white supremacist extremist groups, warrant Department of Justice
investigation. As a result, we are asking DOJ to investigate:
A. INVESTIGATION REQUEST #1: EXCESSIVE FORCE
The Violent Crime Control and Law Enforcement Act of 1994, 42 U.S.C. 14141 (“Section 14141”),
authorizes the United States Attorney General to conduct investigations to eliminate a “pattern or
practice of conduct by law enforcement officers … that deprives persons of rights, privileges, or
immunities secured or protected by the Constitution or laws of the United States.” The DOJ’s website
explains that it investigates “use of excessive force, unlawful stops, searches, or arrests; and
discriminatory policing.”213
Incorporating the abovementioned facts, the signers of this letter ask that DOJ initiate an investigation
under this statute because the disturbing incidents of excessive force inflicted on residents of Vancouver
and Clark County, and especially on persons of color and those experiencing homelessness and mental
illness, have continued, including in recent days, despite actions and statements from City and County
leadership. There is enough evidence to investigate whether the pattern of inflicting injury and death
involves force that is excessive and/or biased, particularly since so many deaths occurred in such a short
period of time, with police escalating the confrontations and shooting to kill. Moreover, there appears to
be a culture of silence and troubling indications that multiple officers involved in a shooting repeat the
same justification without or in contradiction to external evidence. Distrust of the police by
communities of color continues to grow, and it becomes harder for Vancouver and Clark County law
enforcement to keep everyone safe.
The DOJ is well-equipped to investigate the causes of these repeated incidents. The DOJ also has
authority to conduct an investigation of multiple agencies or task forces. DOJ’s investigation should
determine why the VPD, CCSO, and Task Force officers initiated or escalated the confrontations;
whether and why the officers perceived a threat from certain individuals; whether officers view the use
of force differently when they are confronting a Black person or another person of color; why the
officers chose not to use de-escalation tactics in responding to perceived minor law violations in order
to avoid the use of violence; whether VPD, CCSO, and Task Force employees and officers who witness
excessive force promptly reported it, remained silent, or covered for each other; whether VPD, CCSO,
and Task Force supervisors promptly and properly gathered the evidence and fully investigated the
allegation of use of force; and where relevant, what caused contradictions between the initial statements
of the officers involved and other evidence.
B. INVESTIGATION REQUEST #2: DISPARATE OR DISCRIMINATORY POLICING

HARMING COMMUNITIES OF COLOR AND OTHERS
Here too, Section 14141 authorizes the DOJ to investigate a pattern or practice of conduct by law
enforcement officers that deprives persons of rights, privileges, or immunities secured or protected by
the Constitution or laws of the United States, including and especially disparate or biased policing. The
above incidents of excessive force, combined with the use of force data demonstrating a
disproportionately high use of force against Black, Pacific Islander, and other people of color, plus
213
Conduct of Law Enforcement Agencies, U.S. DEP’T OF JUST. (Apr. 21, 2021),
https://www.justice.gov/crt/conduct-law-enforcement-agencies.
29
evidence from other sources demonstrating disparate treatment in police handling of particular
incidents, provide strong evidence that investigation of bias in Clark County and Vancouver law
enforcement is needed. Such disparate treatment that robs residents of protection by police officers –
and sometimes of life – warrants DOJ investigation.
C. INVESTIGATION REQUEST #3: DISPARATE OR DISCRIMINATORY POLICING

INVOLVING LAW ENFORCEMENT FAVORITISM TO WHITE SUPREMACIST
EXTREMISTS
Finally, the DOJ is equipped to investigate any and all discriminatory favoritism between Vancouver
and Clark County law enforcement and white supremacist extremists. As recently as May 4, 2021,
Attorney General Merrick Garland has prioritized investigation and prosecution of domestic
terrorism214.
Extremist groups’ infiltration of law enforcement agencies poses numerous legal and policy problems
warranting DOJ investigation. It perpetuates racial bias in a government function funded by taxpayer
dollars, discriminates in policing services in ways that inflict great harm on Black, Pacific Islander,
Indigenous, and communities of color, and allows the extremist groups to gain “inside knowledge”
about law enforcement, knowledge used to further empower and facilitate the crimes of the extremist
groups. See, e.g., the Clark County deputy sheriff fired for conduct supporting the Proud Boy Girls,
where the deputy had access to sensitive and confidential law enforcement information while belonging
to an extremist group engaged in criminal activity.215 The cross-state-lines activity of white supremacist
groups and their interactions with law enforcement in the Vancouver/Clark County area also support a
DOJ civil rights investigation.
III. CONCLUSION
All residents of Vancouver and Clark County deserve equal and professional treatment by police
officers. There is a dire need to “bring to light” whether there is a persistent pattern of misconduct, and
remedy any systemic deficiencies, as DOJ states on its website.216 The incidents and evidence described
here erode already strained relationships between the community and local law enforcement. Together
they also demonstrate a pattern of disparate policing.
We request that the Civil Rights Division of the Department of Justice promptly investigate whether the
VPD, CCSO, and the Task Force have engaged in a pattern or practice of violations of civil rights by
using unnecessary and excessive force against the residents of Vancouver and Clark County in violation
of federal law, by engaging in disparate treatment along racial, disability, and economic lines, and/or by
displaying favoritism to known white supremacist extremist groups. The DOJ has the authority and
tools to investigate these tragic incidents; to evaluate VPD and CCSO’s policies, practices, training and
supervision; and to enter agreements with the City of Vancouver and Clark County. Through such an
investigation, the DOJ can improve equality, fairness, and public safety throughout Vancouver and
Clark County.
214
Matt Zapotosky, Garland emphasizes need for funding on domestic terrorism and civil rights work,
WASHINGTON POST (May 4, 2021), https://www.washingtonpost.com/national-security/merrick-garland-hearing-
justice-department-budget/2021/05/03/4024cb18-ac28-11eb-b476-c3b287e52a01_story.html.
215
Andy Matarrese, Deputy fired over Proud Boys sweatshirt, COLUMBIAN (July 20, 2018),
https://www.columbian.com/news/2018/jul/20/clark-county-sheriffs-deputy-fired-proud-boys-sweatshirt/.
216
How Department of Justice Civil Rights Division Conducts Pattern-or-Practice Investigation, DEP’T OF JUST.,
https://www.justice.gov/file/how-pp-investigations-work/download.
30
Sincerely,
NAACP Vancouver Branch 1139

ACLU of Washington
31

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What incidents are prompting the request for investigation?

What incidents are prompting the request for investigation?

What groups are alleged to experience disparate treatment?

What groups are alleged to experience disparate treatment?

This document is under embargo until November 10, 2021 at 2 p.m. PST.

November 10, 2021

SENT VIA ELECTRONIC MAIL

Honorable Nicholas W. Brown

RE: Request to Investigate Pattern and Practice of Civil Rights Violations

Dear Ms. Clarke, Mr. Rosenbaum, and US Attorney Brown:

The American Civil Liberties Union of Washington and the community

A. THERE HAVE BEEN AN ALARMING NUMBER OF POLICE SHOOTINGS OF

B. VPD & CCSO ENGAGE IN DISCRIMINATORY POLICING ALONG RACIAL, MENTAL

C. VPD & CCSO ENGAGE IN DISCRIMINATORY POLICING THAT FAVORS KNOWN,

2. Disparate Law Enforcement Designations of “Expressive Speech”: Patriot Prayer

The Vancouver Police Department is committed to supporting the First Amendment

In summary, organizer Kelli Steward [sic] of the People’s Rights of Washington,

b. Proud Boys and ties with Patriot Prayer

5. White supremacist extremist groups in Clark County WA and Multnomah County OR

D. THE PROBLEM OF SYSTEMIC RACISM IN CLARK COUNTY/VANCOUVER

1. Clark County Jail Violates the Rights of People of Color

2. Clark County Courts Have Documented Evidence of Blatant Racism

3. Clark County Council Has Documented Evidence of Racial Bias

E. THE HARM INFLICTED BY POLICE ON THE VANCOUVER/CLARK COUNTY

The experience of communities of color—who are subjected to harassment, routine unwarranted

1. The Mental Health Impact of Police Brutality on Communities of Color

2. The Physical Toll of Police Brutality on Communities of Color

A. INVESTIGATION REQUEST #1: EXCESSIVE FORCE

B. INVESTIGATION REQUEST #2: DISPARATE OR DISCRIMINATORY POLICING

C. INVESTIGATION REQUEST #3: DISPARATE OR DISCRIMINATORY POLICING

NAACP Vancouver Branch 1139

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