Does Hot Spots Policing Inevitably Lead to Unfair and Abusive Police Practices, or Can We Maximize Both Fairness and Effectiveness in the New Proactive Policing?

I. Hot Spots Policing: Where it Came From and What We Know

Hot spots policing, also sometimes referred to as place-based policing, covers a range of police responses that all focus resources on the locations where crime is highly concentrated.25 The specific geographic area that makes up a hot spot has varied across studies, ranging from individual addresses or buildings,26 to single street segments (i.e. both sides of a street from intersection to intersection),27 to small groups of street segments with similar crime problems, such as a drug market.28 Hot spots are smaller than the units police departments have traditionally used to divide up patrol resources, such as patrol beats, zones, or sectors.

There is no single way to implement hot spots policing. Approaches can range rather dramatically across interventions.29 For example, strategies of hot spots policing are often based simply on drastically increasing officer time spent at hot spots, as was the case in the Minneapolis, Minnesota, Hot Spots Patrol Experiment.30 But hot spots policing can also employ much more complex interventions to do something about crime problems.31 In the Jersey City, New Jersey, Drug Market Analysis Program Experiment, for example, a three-step program (including identifying and analyzing problems, developing tailored responses, and maintaining crime control gains) was used to reduce problems at drug hot spots.32 Also in Jersey City, in the Jersey City POP Experiment, a problem-oriented policing approach was taken in developing a specific strategy for each of the violent crime hot spots.33

The idea of hot spots policing developed out of a collaboration between Lawrence Sherman and me at Rutgers University in the late 1980s, where I had taught and where Sherman spent time as a distinguished visiting faculty member. When we met, we both found that we shared common ground in our view of what had to be done in policing. Both of us felt that prevailing narratives about what the police could do about crime were wrong. Studies of policing in the previous decade provided a very strong narrative regarding the inability of the police to prevent crime. David Bayley summarized this well when he wrote on the first page of his influential book Police for the Future, that:

The police do not prevent crime. This is one of the best kept secrets of modern life. Experts know it, the police know it, but the public does not know it. Yet the police pretend that they are society’s best defense against crime . . . . This is a myth.34

Both Sherman and I thought that the police could prevent crime, but they had to reorient their focus to recognize that crime was highly concentrated in urban areas.

My critique of the academic narrative and standard police practices developed out of work I had done at the Vera Institute of Justice in New York. As part of an evaluation of a pilot community-policing program, I walked the “beat” with nine community police officers four days a week for a year. They were each assigned beat areas ranging between twelve and thirty blocks35 that were considered so-called bad neighborhoods. The Vera Institute, and indeed the field of criminology at the time, felt that crime was spread evenly across bad parts of town. After a few weeks in the field, however, it became apparent to me that the idea of bad neighborhoods belied the realities of crime in communities and how the police worked. We did not spend our time walking around the whole beat that was assigned. Rather, we spent most of our time at a few “bad places”: often a street segment between two intersections with a good deal of street activity or a few problematic facilities. This led me to the concept of crime hot spots. Importantly, my observations of the positive impacts of police focus on those hot spots led me to doubt the common wisdom that the police could not prevent crime.

Sherman’s interest in hot spots of crime developed out of a study of crime calls to the police in Minneapolis. With colleagues, he found that a very large proportion of crime was found at a relatively small number of places.36 Just 3.5% of the addresses in Minneapolis produced 50% of all crime calls to the police in a single year. Importantly, many studies since then have confirmed the very significant clustering of crime at micro-geographic units of analysis.37 In my Sutherland Address to the American Society of Criminology, I argued that the evidence of crime concentrations in urban areas made it possible to state a law of crime concentration at places.38 Figure 1 (placed at the end of this paper) shows data on crime incidents in five larger cities. As is apparent, crime is highly concentrated in large urban areas, with about fifty percent of crime on streets found at just five percent of streets, and twenty-five percent of crime found at just one percent of streets.

Based on the idea of hot spots of crime, Sherman and I argued that the police needed to refocus their crime control efforts. This was key, in our view, to creating effective policing strategies:

The premise of organizing patrol by beats is that crime could happen anywhere and that the entire beat must be patrolled. Computer-age data, however, have given new support to Henry Fielding’s ([1751] 1977) eighteenth century proposal that police pay special attention to a small number of locations at high risk of crime. If only 3 percent of the addresses in a city produce more than half of all the requests for police response, if no police cars are dispatched to 40 percent of the addresses and intersections in a city over one year, and, if among the 60 percent with any requests, the majority (31%) register only one request per year (Sherman, Gartin, and Buerger, 1989), then concentrating police in a few locations makes more sense than spreading them evenly through a beat.39

This led us to the Minneapolis Hot Spots Patrol Experiment. Recognizing that a strong research design would be necessary to overcome the common narrative that the police could not prevent crime, we implemented one of the first large-scale randomized experimental field trials in policing in Minneapolis, Minnesota. One hundred ten high-crime hot spots were randomly allocated to treatment and control conditions. The treatment sites received at least twice the level of police patrol as the control sites (dosage was measured throughout the study). The results of the Minneapolis Hot Spots Patrol Experiment stood in sharp contrast to findings in earlier studies. For the eight months in which the study was properly implemented, we found a significant relative improvement in the experimental as compared to control hot spots, both in terms of crime calls to the police and observations of disorder.40 We concluded that there were “clear, if modest, general deterrent effects of substantial increases in police presence in crime hot spots.”41 We noted that it was time for “criminologists to stop saying ‘there is no evidence’ that police patrol can affect crime.”42

In some sense, this was the beginning of the “new policing,” or at least the narrative that has come to predominate: the police, when properly deployed, can reduce crime. Since the Minneapolis study, there have been at least nineteen experimental and quasi-experimental evaluations of hot spots policing programs.43 The vast majority of these have shown significant crime prevention benefits. Indeed, twenty of twenty-five tests of hot spots policing show positive statistically significant findings, and all randomized trials evidenced significant positive crime prevention benefits.44 In 2004, the National Research Council issued a report on police practices that stated, “studies that focused police resources on crime hot spots provide the strongest collective evidence of police effectiveness that is now available.”45

A number of hot spots policing studies have looked at spatial displacement of crime as a response to police focus on high-crime places. Spatial crime displacement is the notion that efforts to eliminate specific crimes at a place will simply cause criminal activity to move elsewhere, thus negating any crime control gains. In their systematic review, Anthony Braga and others found statistically significant evidence of spatial displacement in only one study,46 and even there, the amount of displacement was far less than the main crime prevention benefit of the intervention.47 Thus, in nearly every study he reviewed, Braga found that crime did not simply shift from hot spots to nearby areas.48 Indeed, a more likely outcome of such interventions was a diffusion of crime control benefits, in which areas surrounding the target hot spots also showed a crime and disorder reduction.49 These significant findings for diffusion of crime control benefits to nearby areas further reinforce the idea that hot spots policing is effective in reducing crime in the city.

II. Does Hot Spots Policing Inevitably Lead to Racial or Ethnic Bias?

Hot spots policing is key to the narrative of an effective new proactive policing that has developed over the last decade. But as I noted at the outset, there is a growing argument that there is a “dark” side to hot spots policing strategies. They are seen as inevitably leading to biased policing. For many commenters and the media, as I noted in the introduction, the focus on crime hot spots is assumed to lead to policing that is heavily focused on minority and poor communities. Of course, policing in the United States has historically been heavily focused on disadvantaged and minority communities.50 Whether that is due to differential involvement of minorities and the poor in crime, or differential selection of minorities and the poor for police attention is a matter of debate.51 Whatever the cause, the key question is whether hot spots policing leads to greater focus and more bias than traditional policing approaches.

A key reason for the heightened presence of police in many minority and disadvantaged communities is that they are often places with higher levels of reported crime.52 Most American police agencies conform to a rapid response philosophy that leads them to put more cars in geographic areas where there is more crime.53 If you want to have police available to respond rapidly to emergency crime calls from citizens, you need to have cars patrolling in those areas routinely. Inevitably this leads to more police in poor and disadvantaged communities. In conversations with progressive police executives, I have been struck by their recognition as well that policing is a service and that communities with more serious crime problems need that service more than other communities. They also recognize that disadvantaged communities may have fewer resources—for example, less access to private policing—than do more affluent communities. In this sense, for progressive police executives the fact that there is more policing in minority and disadvantaged communities reflects their efforts to more fairly and equitably distribute police resources.

This perspective of course ignores the fact that increased levels of policing can lead to unintended negative consequences. Police service can lead to the reduction of liberties of citizens through such law enforcement actions as police stops or arrests. While the purpose of these activities may be to aid the community in its efforts to reduce crime, for individuals who live in communities where there are more police, this can mean an increased likelihood of being the focus of such actions. Of course, the extent of the intrusions on citizens will depend on the type of policing employed in a particular agency. However, it is common for the police to fall back upon their law enforcement powers in dealing with crime problems.54 Accordingly, irrespective of the motivation for allocating more police resources to disadvantaged and minority neighborhoods, this can lead to a greater probability of people in such communities having law enforcement contacts with the police.

Ideally, hot spots policing does not reinforce the community-focused idea of police services. Indeed, it pushes the police to think of bad places rather than bad communities. In this context, police resources are not focused on large geographic areas but on the specific places in communities where crime is concentrated. Figure 2 shows chronic crime hot spots in the city of Seattle, Washington. The figure depicts the one percent of streets that produced approximately twenty-five percent of crime each year in the city over a sixteen-year period. Disadvantaged minority areas are generally identified as being in the lower right hand side of the map. These are the so-called bad neighborhoods. Nonetheless, while these areas have hot spots of crime, hot spots are clearly distributed throughout the city. An important locus for hot spots is in the central business district. And hot spots can also be found in the wealthier Northern areas of the city, though in smaller numbers. Examination of other larger cities studied in this way generally leads to a similar portrait of the spread of hot spots across a city.55

Figure 3, which shows the crime trajectories over time of individual streets in the Southern part of Seattle, Washington, reinforces this idea further. In this figure, we see the street-by-street variability in crime within the more disadvantaged neighborhoods of Seattle. What is apparent is that most of the streets in a so-called bad neighborhood have little or no crime (represented by the thinner lighter tinted streets). There are chronic crime hot spots (represented by the wider dark tinted streets), but they represent a small proportion of the streets in the neighborhood. Accordingly, a hot spots focus should also concentrate and focus police activities on specific streets within communities. This should lead to less arbitrary allocations of police services, and ultimately should restrict the downside of police presence. Such careful targeting of the allocation of policing can in this sense reduce the dark side of police services, since law enforcement would be focused on specific blocks and not on whole neighborhoods.

III. Does the Focus on Hot Spots Inevitably Lead to Abusive Police Practices and Declining Police Legitimacy?

Even if hot spots policing focuses police activities more carefully, and therefore frees much of the community from the unintended negative consequences of policing, people who live on streets that are the focus of hot spots policing may be more likely to be stopped, questioned, or arrested. While there is a strong body of evidence that hot spots policing can reduce crime and disorder at crime hot spots, recent critiques of hot spots policing tactics have focused on potential increases in citizen fear of crime, or declines in collective efficacy and police legitimacy. These critiques argue that focusing intense police presence on small crime hot spots may have unintended negative consequences for the community or the police themselves.56

Rosenbaum argues, for example, that hot spots policing will lead to adverse impacts on police-community relations, and thus the legitimacy of the police in the community.57 Legitimacy refers to the “judgments that ordinary citizens make about the rightfulness of police conduct.”58 Research suggests that when citizens perceive police actions as legitimate, they are not only more likely to view the police more positively, but are also more likely to comply with the law in the future.59 While residents may initially be pleased to have the police addressing problems on their street, Rosenbaum suggests that over time there is a risk that residents may begin to feel like targets of the police rather than partners in crime prevention.60 Tammy Rinehart Kochel argues in turn, that the “police must recognize that in hot spots, they are working with populations who are more skeptical and less trusting of the police. Therefore, aggressive or intrusive policing tactics, while effective as short-term crime fighting strategies, may have long-term implications for police legitimacy.”61

Despite arguments that intensive interventions, such as hot spots policing, will have negative impacts on citizen perceptions, there is very little evidence to support this position. A study by Joshua Hinkle and I did find that police crackdowns on crime and disorder hot spots led people living in the targeted areas to become more fearful of crime.62 However, that study was based on a correlational design, in which the affected hot spot areas had levels of overall crime higher than the comparison areas used in the study. Moreover, a number of studies to date provide evidence of neutral or even positive impacts on citizen perceptions.

There is evidence from a number studies that residents in crime hot spots who are subject to focused police attention welcome the concentration of police efforts in problem places.63 For example, a study linked to the Kansas City Gun Experiment64 found that the community at and near hot spots strongly supported the intensive patrols and perceived an improvement in the quality of life in the treatment neighborhood.65

One recent study by Anthony Braga and Brenda Bond examined community reaction to the problem-oriented policing initiative in Lowell, Massachusetts.66 Data from interviews showed that the community perceived improvements in social and physical disorder and had an increased number of contacts with the police. However, no statistically significant differences were found in fear of crime or perceptions of police tactics or demeanor.67 Recent experimental research from three cities in San Bernardino County, California, also found that a broken windows style intervention (in which the police focused on reducing incivilities) at hot spots had no impact on resident perceptions of fear of crime or police legitimacy.68 A randomized experiment in Illinois found that though there were initial declines in legitimacy from intensive police patrols and problem solving at hot spots, those effects withered quickly.69 Importantly, the study found no evidence of increases in perceived abuse by police in the hot spots that received the experimental interventions.70

Of course, hot spots policing practices in the field may include abusive policing practices in specific cases. For example, my colleagues and I found that stop, question, and frisk (SQF) tactics were carried out in New York City as a hot spots policing approach.71 While it was often assumed that SQFs were applied widely and randomly across neighborhoods in New York City, we found a strong correlation between crime hot spots and SQFs. A very large proportion of SQFs were found at a small number of places in the city. More than fifty percent of SQFs at street segments were found at one percent of the segments, and fifty percent of SQFs at intersections were found at five percent of the intersections.72 In turn, we found that SQFs in New York City were associated with significant crime deterrence at a micro-geographic level.73

But there is little question that the application of SQFs in New York City led to unintended negative consequences and abusive policing. In 2011, almost 700,000 people were stopped in New York City according to data provided by the police, and most were young, poor, and minorities.74 The growing dissatisfaction with the police in minority communities and especially among minority youth was a key factor in fueling the legal challenges to the NYPD’s SQF policies.75 As a result, in Floyd v. City of New York,76 the U.S. District Court for the Southern District of New York ruled that SQFs as carried out in New York were unconstitutional, and appointed a special monitor to institute substantive reforms.77

While hot spots policing does not necessarily lead to abusive police strategies, clearly unfair and abusive strategies can be used in hot spots policing programs. Hot spots policing is about the efficient focus of police resources at places where crime is concentrated. When police use policing models like increased police patrol or problem-oriented policing at crime hot spots, there is little evidence that people who live at those places are affected negatively either in terms of fear of crime, perceptions of the police, or police legitimacy. In turn, the one experimental study that examined the potential for abusive policing at hot spots found that citizens who lived in hot spots that were targeted with intensive police patrols or problem-oriented policing were not more likely to see the police as more abusive than those in the control condition.78

Police can of course use abusive tactics at crime hot spots, such as SQFs carried out on a major scale. And we would expect that if they did, it would lead to negative evaluations of the police and decreased police legitimacy, though we have no data as yet on these questions. But such tactics can also be applied more broadly and unrelated to hot spots policing. The larger question is whether hot spots policing can be carried out in ways that not only reduce potential negative outcomes, but also actually improve legitimacy evaluations of the police.

IV. Can We Maximize Effectiveness, Fairness, and Legitimacy All at the Same Time In the New Proactive Policing?79

In contrast to the strong scientific evidence on the crime prevention effectiveness of hot spots policing, there is far less rigorous evidence on the prospects of procedural fairness, consensus building, and transparency in improving community perceptions of the legitimacy of police actions. Practical experience and the available research evidence are strong enough, however, to observe that inappropriate police actions, such as excessive force, disrespectful treatment, and indiscriminate enforcement, have undesirable impacts on police-community relations. In short, there are more and less desirable ways to address crime and disorder problems in hot spot areas. Normative assessments of planned actions can be helpful in avoiding community backlash when concentrating police resources in small places.

My colleague Anthony Braga and I argue in our book, Policing Problem Places, that hot spots policing represents an approach to crime prevention that not only has the potential to generate strong crime prevention gains, but also, if implemented properly, increase police legitimacy in the eyes of community members.80 The police need active public cooperation, not simply political support and approval, to control crime and maintain order. Cooperation increases not only when the police are viewed as effective in preventing crime and maintaining order, but also when citizens see the police as legitimate authorities who are entitled to be obeyed.81 Legitimacy judgments are shaped by public views about the fairness of the processes the police use when dealing with members of the public.82

Hot spots policing programs should be developed and implemented by police managers with the ideas of legitimacy and fairness in mind. Minority residents tend to view the police with distrust and suspicion.83 At certain times and in certain places in U.S. history, the police have subjected African American communities to high levels of arrest, abusive and corrupt behavior, and physical brutality. More recently, ongoing poor relations between minorities and the police have been highlighted in the debate over racial profiling.84 As Lawrence Sherman observes, “counteracting this legacy may require more public accountability for the processes by which police select crime-prevention strategies and risk-factor targets.”85 A police focus on crime hot spots can be correlated with race, but the correlation is a coincidence rather than a cause. Public concern over racial profiling is often the result of poorly delineated offender profiles rather than more precisely drawn offense profiles, such as risk analyses that identify particular high-activity crime places in need of attention.86

The concentration of crime in space and time provides an important opportunity for consensus building and transparency in target selection that can go far in bringing the police closer to the communities they seek to serve. Within a community-policing framework, hot spots policing initiatives can be framed as collaborative exercises where the police and community jointly review crime maps and select particular places for focused attention. In these settings, police and community members can also discuss the range of strategies that might be adopted to address targeted crime hot spots.

Consensus and transparency, coupled with a tight focus on high-crime locations, can enhance the legitimacy of police intrusions that are necessary to intercept criminals for violating “risk laws,” such as those against carrying guns or driving while intoxicated. Increasing police presence and police-citizen contacts in high-activity places can be important strategies to reduce gun violence87 and drunk driving fatalities.88 To maintain the legitimacy of these important enforcement activities in crime hot spot areas, police need to pay attention to what Tom Tyler and others call “procedural justice,” in their interactions with citizens.89 Traffic and pedestrian stops need to be viewed as procedurally fair by citizens subjected to the police intrusion.

Fair policing requires police officers to treat citizens with respect and dignity throughout the interaction between a police officer and a citizen, to explain that their intrusion on the citizen’s activities was based on neutral and objective criteria, and to allow citizens the opportunity to explain their behavior.90 The particular strategies selected to address crime hot spots can obviously either enhance or undermine police legitimacy. Overly aggressive and indiscriminate arrest-based strategies are more likely to generate community concern and poor relations. Unfortunately, zero-tolerance approaches that advocate full enforcement of all laws, no matter how minor, to reduce serious crimes have been engaged in by police departments from Australia to Arizona.91 Zero-tolerance approaches are a perversion of the tight focus of broken windows policing on controlling disorderly behavior to prevent more serious crimes.92 Zero-tolerance strategies seem to generate more harm in disadvantaged communities already suffering from serious crime and disorder problems, as evidenced by studies suggesting elevated complaints against the police, and increased arrests and subsequent incarceration of young minority men.93

Police agencies need to move away from one-dimensional intensive enforcement efforts to control crime hot spots. Aggressive law enforcement strategies certainly have their place, but they can lead to negative outcomes as well. Although deterrence is an important component of crime prevention efforts of the police,94 negative interactions with the police run the risk of alienating not just offenders, but the wider community. Research suggests that the large-scale cycle of arrest, removal, and return of individuals damages the stability of familial and community relationships, disrupts neighborhood life, and erodes the capacity of neighborhoods for self-regulation.95 Police strategies at hot spots must balance the need for deterrence, with the importance of gaining trust on the streets where police work. Moreover, they have to place approaches that increase trust and cooperation of the community at the forefront of their efforts. This means that police in the field should integrate hot spots policing strategies with strategies that are meant to increase public trust in the police. While we have yet to develop clear evidence on this question, it is my proposition that we can maximize crime control and police legitimacy in the context of hot spots policing.

V. Is a New Generation of Hot Spots Policing Programs Possible?

Arguing that hot spots programs should be developed to maximize crime control and police legitimacy simultaneously leads to the question of what such programs would look like in practice. My colleagues and I are developing two such programs at this juncture, which should yield important guidance for hot spots policing programs in the future.

A.    Brooklyn Park: Assets Coming Together to Take Action

Charlotte Gill and I are working with the city of Brooklyn Park, Minnesota, to test whether hot spots policing can increase collective efficacy and enhance informal social controls at the same time that it improves evaluations of police legitimacy.96 “Collective efficacy” refers to the ability of communities to use informal social controls to solve community problems.97 The program in Brooklyn Park focuses police patrol on crime hot spots, but also focuses the police on increasing community trust and cooperation for collective action at the targeted places. We are conducting a randomized experimental evaluation of the program including forty-two crime hot spots. The evaluation will include both assessments of changes in crime and collective efficacy, and in citizen perceptions of the police and police legitimacy.

Brooklyn Park is well situated as the study site for this effort. With a population of about 78,000 people over twenty-six square miles,98 it is the second-largest suburb in the Minneapolis–St. Paul metropolitan area, and the sixth-largest city in the state of Minnesota.99 Traditionally a bedroom community for nearby Minneapolis, Brooklyn Park is 85-percent developed and has a high population density—almost 3000 residents per square mile.100 There is no true downtown area, but both residential and commercial properties exist in the city. The population of Brooklyn Park is highly diverse. About twenty percent of residents are foreign-born and almost fifty percent are non-White.101 Importantly, Brooklyn Park’s crime rate is the highest amongst Minneapolis–St. Paul suburbs, with 50,000 residents or more. Much of this crime is concentrated at hot spots characterized by low-income public housing and low-rent apartments, as well as residential areas that have been affected by economic hardship and foreclosures. The mixed land use, high population density and heterogeneity, and population turnover associated with these locations suggest a connection between low collective efficacy and crime.

At full strength, the Brooklyn Park Police Department (BPPD) has 108 sworn officers, with 48 officers, 9 sergeants, and 2 lieutenants assigned to patrol. The department has a long history of collaborating with community service providers, community coalitions, and schools. Former Chief Michael Davis was instrumental in developing a culture of community collaboration, and this has continued with the current leadership; however, BPPD sought a more systematic approach to community outreach and problem solving.

The program is organized around three essential preconditions of collective efficacy: (i) the establishment of proximal relationships with and between residents, (ii) the development of working trust between relevant parties, and (iii) the shared expectations that result from that trust and compel residents to act against social problems.102 The entire BPPD patrol force, including fifty patrol officers, participated in a one-day training in understanding the causal relationship between collective efficacy and crime, and how to apply this knowledge to community-building and problem-solving strategies. The content of the training day was specifically designed to operationalize collective efficacy at the street level.

The training was designed and delivered by the entire project team including senior officers and project coordinators from BPPD, the research team, and subject matter experts in collective efficacy and policing. Importantly, for buy-in, a small team of officers was selected to pilot test the first stage of the intervention in a selected location and report back at the training, so officers could connect the theory with practical application by their peers.

The intervention itself consists of a three-stage process termed, “Brooklyn Park: Assets Coming Together to Take Action” (BP-ACT).

1. Assets (asset identification).

Officers identify both the specific problems at hot spots and the key stakeholders and resources (“assets”) that should be involved in solving them. The problem solving process places primary emphasis on identification of key assets, such as residents, business owners, and community groups within the micro-community of the hot spot. Assets may also be anchor points (social service agencies, schools, places of worship, etc.) that may be outside the precise boundaries of the hot spot but are meaningful to residents.103 Officers identify these assets through conversations with local actors during their discretionary time, and by utilizing the local knowledge they obtain through regular police work. A procedural justice dialogue script guides these conversations, at least initially, to help build trust and social capital with and among residents.104 Importantly, this stage also involves assessing the liabilities at a location. We have seen that some individuals or organizations in a hot spot may be closely tied to the crime problems at that place and may not be best placed to help solve them. In this case, police also focus on stabilizing the location (in some cases, through more traditional law enforcement methods, albeit with a view to protecting community trust that has already been developed).

2. Coming together (coalescence).

This phase builds upon traditional community-oriented and problem-oriented approaches by emphasizing the creation of police-community problem-solving partnerships that build residents’ willingness to take ownership of local crime issues. During this phase, officers gather intelligence from the community, work with stakeholders to implement crime prevention strategies, and—key to our approach—use their training in collective efficacy and community building to focus residents on creating collective ownership over the hot spot. Officers match identified assets to identified problems within each hot spot through small group conversations or more formal meetings.

3. Taking action (follow-up).

In the taking action phase, patrol officers submit information on their activities to BPPD’s project coordinator. Officers and the project coordinator then collaborate to assess and track the implementation and progress of agreed-upon community actions in a shared project database. We are now in the sixth month of project implementation, and there is strong evidence that the patrol force can move beyond its law enforcement role to an approach that seeks to emphasize community building at hot spots. While ordinary patrols and enforcement actions made up some 63.4% of the activities at the treatment locations in the first two months of the project, by the fifth and sixth months, identifying assets and interactions with community members made up 63.0% of activities. In turn, in most of the hot spots in the study, police have organized community meetings with the goal of developing action plans on the streets.

We will see over time whether these efforts and this reorientation of how hot spots are dealt with in a city will have positive outcomes. Prior research suggests that the focus on crime hot spots will yield crime prevention gains. We hope that the community engagement focus of the study will in turn allow such gains, while also increasing collective efficacy and evaluations of police legitimacy.

B.    Procedural Justice Policing at Crime Hot Spots

Cody Telep, Anthony Braga, Tracey Meares, and I are developing a second innovative approach with the Police Foundation in Washington, D.C., that seeks to maximize crime control and evaluations of police legitimacy simultaneously. The Arnold Foundation has funded our project, and we have received commitments from four cities for a multi-city randomized trial. We seek to answer two key questions: (1) Can the development of a hot spots policing program with a strong procedural justice component enhance citizen perceptions of police legitimacy? (2) Can the program improve the effectiveness of hot spots policing, leading to greater long-term crime prevention gains?

Tom Tyler and Yuen Huo note that legitimacy can arise from giving citizens either favorable outcomes, or simply a sense that the outcomes are equitable (distributive justice).105 But they argue that the greatest legitimacy and legal compliance are produced when police attend to procedural justice,106 which is “an evaluation of the fairness of the manner in which [a person’s] problem or dispute was handled.”107 Police officers often face situations where it is difficult to produce a positive outcome for all parties. A traffic violator, for example, will not view a speeding ticket as a favorable outcome. Nevertheless, according to the procedural justice framework, if the officer treats the citizen fairly, the citizen is likely to accept the outcome, and this display of fairness will enhance or at least not decrease the legitimacy of the police.108 The President’s Task Force has also identified procedural justice as a key concern for agency efforts to enhance citizen perceptions of police legitimacy. The Task Force concluded that “law enforcement culture should embrace a guardian mindset to build public trust and legitimacy. Toward that end, police and sheriffs’ departments should adopt procedural justice as the guiding principle for internal and external policies and practices to guide their interactions with the citizens they serve.”109 Our question is whether hot spots policing enhanced with procedural justice training will allow police to maximize crime prevention and police legitimacy simultaneously.

A few field studies have examined the impact of procedural justice approaches and increased legitimacy on the behavior of citizens. Stephen Mastrofski and colleagues found that factors related to legitimacy were key predictors of citizen compliance with police directives.110 In a re-analysis of data from the Milwaukee Domestic Violence Experiment, Raymond Paternoster and colleagues found that when officers arrested domestic violence suspects using principles of procedural justice, the suspects were significantly less likely to re-engage in domestic violence.111 This effect was consistent across suspects with different demographic characteristics. They concluded that perceived procedural justice nullified the criminogenic influence of being arrested for spousal offenses.112 John McCluskey found in his analysis of police requests for citizen self-control (ending disorderly behavior, leaving the scene) that multiple procedural justice characteristics were significant.113 Respectful treatment from the police doubled the odds of compliance, while disrespectful behavior made noncompliance almost twice as likely.114 When the police cut off a citizen from telling his or her side of the story, resistance was two times more likely, and compliance was significantly more likely when the police showed they were interested in gathering information to make an informed decision.115

In our study, we want to see whether hot spots policing enhanced with procedural justice training can have a direct impact on offending at the hot spots, and a longer term impact on compliance with the law more generally among people that have contact with the police. If both of these outcomes are found, combined with increased perceptions of police legitimacy, it would mean that we cannot only simultaneously prevent crime and increase police legitimacy, but that this approach also increases crime prevention benefits over standard hot spots policing approaches.

We will identify forty to fifty crime hot spots in each of the four agencies (160–200 total), which would be divided equally between a “standard hot spots policing” condition and an “enhancing procedural justice in hot spots” condition. Officers will be assigned to focus extra time and enforcement activity on street blocks in the “standard hot spots” condition using traditional law enforcement approaches. Half the hot spots will be in the “enhancing procedural justice in hot spots” condition and receive intensive police attention in addition to efforts to increase the use of procedural justice in police-citizen interactions. Officers would similarly focus extra time and enforcement activity on assigned street blocks, but would receive forty hours of training related to procedural justice and enhancing citizen perceptions of police legitimacy. The training will be developed as part of the project and emphasize the quality of interactions with the public. Topics will include giving citizens a sense of participation and ways to demonstrate neutrality and respect. Officers in this group will also use a checklist in the field to reinforce the training.

Data to assess the impact of the intervention on crime will come from official data (calls for service, arrests, and incident reports before, during, and after the intervention). We will also examine resident perceptions of legitimacy with door-to-door interviews before and after the intervention, and conduct a survey of people who had police contact in hot spots under both conditions.

VI. Conclusion

Narratives are important in crime prevention. In the 1970s, a dominant narrative emerged that assumed that the police could not prevent crime. Over the last two decades, that narrative has been overturned by one that recognizes that proactive policing can be effective in reducing crime. The development of hot spots policing approaches has been key to the development of this new proactive policing. Today, there is little doubt that such strategies can be effective in reducing crime without displacement. But as I noted at the outset, a new narrative is developing that argues that hot spots policing, as well as other proactive deterrence based policing strategies, are likely to lead to biased and abusive police practices. I have argued that hot spots policing properly implemented is likely to lead to less biased policing than traditional strategies. Moreover, there is little evidence that hot spots policing per se leads to abusive policing practices. Rather, abusive policing approaches can be applied in hot spots policing just as they can be applied more generally in standard policing practices. Finally, I argued for a new generation of programs and practices in hot spots policing that attempts to maximize crime control and legitimacy simultaneously, and I described two ongoing examples of programs that are taking this approach.

Having worked to overcome the “nothing works” narrative in policing, it would be a pity if new policing strategies—such as hot spots policing—were abandoned based on assumptions of negative unintended outcomes. The task is to take the knowledge we have gained over the last few decades and to enhance hot spots policing by recognizing the importance of citizen evaluations of the police. I suspect that if we do this we will not only increase legitimacy evaluations of the police, but we will also increase crime prevention gains. But unlike the evidence on the crime control outcomes of hot spots policing, we still know little about whether enhancing hot spots policing, or other policing strategies for that matter, in conjunction with procedural justice approaches will improve policing. It is time to develop an evidence base for these questions.

VII. Figures

Figure 1: Crime Concentration in Five Cities*

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*Reprinted from: David Weisburd, The Law of Crime Concentration and the Criminology of Place, 53 Criminology 133, 144 (2015).

Figure 2: Chronic Hot Spot Street Segments in Seattle, Washington*

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*Reprinted from: David Weisburd et al., Understanding and Controlling Hot Spots of Crime: The Importance of Formal and Informal Social Controls, 15 Prevention Sci. 31, 35 (2013).

Figure 3: Street-by-Street Variability in Crime Trends in Southern Seattle, Washington*

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*Reprinted from: David Weisburd et al., The Criminology of Place: Street Segments and Our Understanding of the Crime Problem 73 (2012).

• 25See David Weisburd, Place-Based Policing, Ideas in Am. Policing, Jan. 2008, at 4.
• 26See Sherman et al., supra note 19, at 33.
• 27See Sherman & Weisburd, supra note 10, at 633.
• 28See David Weisburd et al., Does Crime Just Move Around the Corner? A Controlled Study of Spatial Displacement and Diffusion of Crime Control Benefits, 44 Criminology 549, 562 (2006).
• 29See Weisburd, supra note 25.
• 30Id. at 4; see Sherman & Weisburd, supra note 10, at 634.
• 31Weisburd, supra note 25, at 4.
• 32Id.; see Weisburd & Green, supra note 17, at 717–18.
• 33Weisburd, supra note 25, at 4; see Anthony A. Braga et al., Problem-Oriented Policing in Violent Crime Places: A Randomized Controlled Experiment, 37 Criminology 541 (1999).
• 34Bayley, supra note 8, at 3.
• 35See David Weisburd & Jerome E. McElroy, Enacting the CPO Role: Findings from the New York City Pilot Program in Community Policing, in Community Policing: Rhetoric or Reality 89, 90 (Jack R. Greene & Stephen D. Mastrofski eds., 1988).
• 36See Sherman, supra note 19; Sherman et al., supra note 19, at 37–39.
• 37See, e.g., Wayman J. Crow & James L. Bull, Robbery Deterrence: An Applied Behavioral Science Institute (W. Behavioral Sci. Inst. 1975); Glenn L. Pierce et al., The Character of Police Work: Strategies and Tactical Implications (1988); Dennis W. Roncek, Schools and Crime, in Analyzing Crime Patterns: Frontiers of Practice 153 (Victor Goldsmith et al. eds., 2000); David Weisburd et al., Staking out the Next Generation of Studies of the Criminology of Place: Collecting Prospective Longitudinal Data at Crime Hot Spots, in The Future of Criminology 236 (Rolf Loeber & Brandon C. Welsh eds., 2012); Martin A. Andresen & Nicolas Malleson, Testing the Stability of Crime Patterns: Implications for Theory and Policy, 000 J. of Res. in Crime & Delinq. 1 (2010); Anthony A. Braga et al., The Effects of Hot Spots Policing on Crime: An Updated Systematic Review and Meta-Analysis, 31 Just. Q. 633 (2014); Patricia L. Brantingham & Paul J. Brantingham, A Theoretical Model of Hot Spot Generation, 8 Stud. on Crime & Crime Prevention 7 (1999); Andrea S. N. Curman et al., Crime and Place: A Longitudinal Examination of Street Segment Patterns in Vancouver, BC, 31 J. of Quantitative Criminology 127 (2015); David Weisburd & Shai Amram, The Law of Concentrations of Crime at Place: The Case of Tel Aviv-Jaffa, 15 Police Prac. & Res. 101 (2014); Weisburd & Green, supra note 17; David Weisburd et al., Hot Spots of Juvenile Crime: A Longitudinal Study of Arrest Incidents at Street Segments in Seattle, Washington, 25 J. of Quantitative Criminology 443 (2009); David Weisburd et al., Contrasting Crime General and Crime Specific Theory: The Case of Hot Spots of Crime, in 4 New Directions in Criminological Theory 45 (Freda Adler & William S. Laufer eds., 1993); David Weisburd et al., Trajectories of Crime at Places: A Longitudinal Study of Street Segments in the City of Seattle, 42 Criminology 283 (2004).
• 38See David Weisburd, The Law of Crime Concentration and the Criminology of Place, 53 Criminology 133, 138 (2015) (“This law states that for a defined measure of crime at a specific microgeographic unit, the concentration of crime will fall within a narrow bandwidth of percentages for a defined cumulative portion of crime.”).
• 39Sherman & Weisburd, supra note 10, at 629 (citation omitted).
• 40See id. at 642–43.
• 41Id. at 645.
• 42Id. at 647.
• 43See, e.g., Anthony Braga et al., Hot Spots Policing Effects on Crime 6 (David B. Wilson & Charlotte Gill eds., Campbell Systematic Reviews 8th ed. 2012).
• 44See id.
• 45Wesley Skogan & Kathleen Frydl, The Effectiveness of Police Activities in Reducing Crime, Disorder, and Fear, in Fairness and Effectiveness in Policing: The Evidence 217, 250 (Nat’l Academies Press, 2004).
• 46Braga et al., supra note 43, at 26.
• 47Id. at 93–94 (citing Jerry H. Ratcliffe et al., The Philadelphia Foot Patrol Experiment: A Randomized Controlled Trial of Police Patrol Effectiveness in Violent Crime Hotspots, 49 Criminology 795 (2011)).
• 48See id. at 21–22; see also Weisburd et al., supra note 28, at 554.
• 49See, e.g., Ronald V. Clarke & David Weisburd, Diffusion of Crime Control Benefits: Observations on the Reverse of Displacement, in 2 Crime Prevention Studies 165 (Ronald V. Clarke ed., Crim. Just. Press 1994).
• 50See Gary Cordner, Community Policing, in The Oxford Handbook of Police and Policing 148 (Michael D. Reisig & Robert J. Kane eds., 2014); Kristina Murphy & Adrian Cherney, Policing Ethnic Minority Groups with Procedural Justice: An Empirical Study (Alfred Deakin Research Inst., Working Paper No. 02, 2010).
• 51See Alex R. Piquero, Disproportionate Minority Contact, 18 Juv. Just. 59 (2008).
• 52See Charis E. Kubrin, Crime and the Racial Composition of Communities, in Encyclopedia of Criminology and Criminal Justice 673–81 (David Weisburd & Gerban Jan Nicolaas Bruinsma eds., 2013); Steven Raphael & Melissa Sills, Urban Crime in the United States, in A Companion to Urban Economics (Richard Arnott & Dan McMillen eds., 2005); Steven Raphael & Michael Stoll, Why Are So Many Americans in Prison?, in Do Prisons Make Us Safer? The Benefits and Costs of the Prison Boom (Steven Raphael & Michael Stoll eds., 2009).
• 53See generally Richard C. Larson, MIT Press, Urban Police Patrol Analysis (1972); Stephen Sacks, Evaluation of Police Patrol Patterns (Economics Working Papers, Working paper No. 200317, 2003).
• 54Anthony A. Braga & David Weisburd, Problem-Oriented Policing: The Disconnect Between Principles and Practice, in Police Innovation: Contrasting Perspectives 133–52 (David Weisburd & Anthony A. Braga eds., 2006).
• 55See, e.g., Weisburd & Amram, supra note 37, at 107; David Weisburd et al., Could Innovations in Policing Have Contributed to the New York City Crime Drop Even in a Period of Declining Police Strength?: The Case of Stop, Question and Frisk as a Hot Spots Policing Strategy, 31 Just. Q. 129 (2014).
• 56See, e.g., Joshua C. Hinkle & David Weisburd, The Irony of Broken Windows Policing: A Micro-Place Study of the Relationship Between Disorder, Focused Police Crackdowns and Fear of Crime, 36 J. of Crim. Just. 503, 508–10 (2008); Kochel, supra note 20, at 362–67; Rosenbaum, supra note 20.
• 57Rosenbaum, supra note 20, at 253–54.
• 58Wesley Skogan & Kathleen Frydl, Police Fairness: Legitimacy as the Consent of the Public, in Fairness and Effectiveness in Policing: The Evidence 291, 291 (Nat’l Academies Press, 2004).
• 59See id. at 291–92.
• 60Rosenbaum, supra note 20, at 253.
• 61Kochel, supra note 20, at 366.
• 62See Hinkle & Weisburd, supra note 56, at 508.
• 63See, e.g., Steven Chermak et al., Citizens’ Perceptions of Aggressive Traffic Enforcement Strategies, 18 Just. Q. 365 (2001); Nicholas Corsaro et al., Evaluating a Policing Strategy Intended to Disrupt an Illicit Street-Level Drug Market, Evaluation Rev., 2010, at 25–26.
• 64See generally Lawrence W. Sherman & Dennis P. Rogan, Effects of Gun Seizures on Gun Violence: “Hot Spots” Patrol in Kansas City, 12 Just. Q. 673 (1995).
• 65See James W. Shaw, Community Policing Against Guns: Public Opinion of the Kansas City Gun Experiment, 12 Just. Q. 695, 706–09 (1995).
• 66See Anthony A. Braga & Brenda J. Bond, Community Perceptions of Police Crime Prevention Efforts: Using Interviews in Small Areas to Evaluate Crime Reduction Strategies, in 24 Evaluating Crime Reduction Initiatives 87 (Johannes Knutsson & Nick Tilley eds., Criminal Justice Press 2009); Anthony A. Braga & Brenda J. Bond, Policing Crime and Disorder Hot Spots: A Randomized Controlled Trial, 46 Criminology 577 (2008).
• 67Braga & Bond, Community Perceptions, supra note 66, at 110.
• 68David Weisburd et al., The Possible “Backfire” Effects of Broken Windows Policing at Crime Hot Spots: An Experimental Assessment of Impacts on Legitimacy, Fear and Collective Efficacy, 7 J. Experimental Criminology 297, 299, 310 (2011).
• 69See Tammy Rinehart Kochel et al., St Louis County Hot Spots in Residential Areas (SCHIRA) Final Report: Assessing the Effects of Hot Spots Policing Strategies on Police Legitimacy, Crime, and Collective Efficacy 9–10 (2015).
• 70See id. at 10–11.
• 71See Weisburd et al., supra note 55, at 139–46.
• 72See id. at 141.
• 73David Weisburd et al., Do Stop, Question, and Frisk Practices Deter Crime?, 15 Criminology & Pub. Pol’y 31, 46–47 (2016).
• 74See id. at 48.
• 75See Andrew Gelman et al., An Analysis of the New York City Police Department’s “Stop-and-Frisk” Policy in the Context of Claims of Racial Bias, 102 J. of the Am. Stat. Ass’n 813, 813 (2007).
• 76959 F. Supp. 2d 540 (S.D.N.Y. 2013).
• 77See Joseph Goldstein, Judge Rejects New York’s Stop-and-Frisk Policy, N.Y. Times (Aug. 12, 2013), http://www.nytimes.com/2013/08/13/nyregion/stop-and-frisk-practice-violated-rights-judge-rules.html?_r=0 (http://perma.cc/V7XC-VHPS]; Floyd v. City of New York, Ctr. for Constitutional Rights, http://ccrjustice.org/ home/what-we-do/our-cases/floyd-et-al-v-city-new-york-et-al (http://perma.cc/WG63-ULKU).
• 78See Kochel et al., supra note 69.
• 79This section relies heavily on work Anthony Braga and I published. See Anthony Braga & David Weisburd, Policing Problem Places: Crime Hot Spots and Effective Prevention (2010).
• 80Braga & Weisburd, supra note 54.
• 81See Tom R. Tyler & Jeffrey Fagan, Legitimacy and Cooperation: Why Do People Help the Police Fight Crime in Their Communities?, 6 Ohio St. J. of Crim. L. 231, 262 (2008).
• 82See, e.g., Tom R. Tyler, Why People Obey the Law (Yale Univ. 1990); Tom R. Tyler et al., Reintegrative Shaming, Procedural Justice, and Recidivism: The Engagement of Offenders’ Psychological Mechanisms in the Canberra RISE Drinking-and-Driving Experiment, 41 Law & Soc’y Rev. 553, 565 (2007).
• 83See Ronald Weitzer & Steven A. Tuch, Race and Policing in America: Conflict and Reform 5–6 (Cambridge Univ. Press 2006).
• 84See, e.g., Jeffrey Fagan & Garth Davies, Street Stops and Broken Windows: Terry, Race and Disorder in New York City, 28 Fordham Urb. L.J. 457 (2000) (finding police in New York City stop and frisk individuals largely based on race); David A. Harris, Stories, the Statistics, and the Law: Why “Driving While Black” Matters, 84 Minn. L. Rev. 265 (1999) (finding police use traffic stops as a pretense to search black drivers).
• 85Lawrence W. Sherman, Fair and Effective Policing, in Crime: Public Policies for Crime Control 383, 395 (James Q. Wilson & Joan Petersilia eds., Inst. for Contemporary Studies 2002).
• 86See id. at 397–98.
• 87See Sherman & Rogan, supra note 64 (finding intensive police patrol of gun hot spots reduced gun-related violence).
• 88Cf. Lawrence W. Sherman, Attacking Crime: Police and Crime Control, 15 Crime & Just. 159, 199–203 (1992) (problem-solving and directed patrol are two popular strategies police use to alleviate soft crime, which includes drunk-driving).
• 89See generally Tyler, supra note 82, at 6–7, 115–61; Tyler et al., supra note 82; Tyler & Fagan, supra note 81, at 264–65 (finding procedural justice is a key factor in shaping police legitimacy).
• 90See Skogan & Frydl, supra note 45.
• 91See Sherman, supra note 85, at 394.
• 92Cf. George L. Kelling & James Q. Wilson, Broken Windows: The Police and Neighborhood Safety, Atlantic Monthly (Mar. 1982), http://www.theatlantic.com/doc /198203/broken-windows (http://perma.cc/H6LD-D25R] (arguing modern-day policing has shifted from the broken-windows approach that focused on community disorder to a focus on individual conduct).
• 93See, e.g., Judith A. Greene, Zero Tolerance: A Case Study of Police Policies and Practices in New York City, 45 Crime & Delinq. 171, 176–77 (1999); Bernard E. Harcourt & Jens Ludwig, Reefer Madness: Broken Windows Policing and Misdemeanor Marijuana Arrests in New York City, 1989–2000, 6 Criminology & Pub. Pol’y 165 (2007).
• 94See, e.g., Daniel S. Nagin et al., Deterrence, Criminal Opportunities, and Police, 53 Criminology 74, 84–85, 93 (2015); Cynthia Lum & Daniel Nagin, Reinventing American Policing: A Seven-Point Blueprint for the 21st Century, 2015 Translational Criminology 2, 3–4.
• 95See, e.g., Todd R. Clear, Imprisoning communities: How Mass Incarceration Makes Disadvantaged Neighborhoods Worse 58–59, 73–85 (2007); Bruce Western, Punishment and Inequality in America (Russell Sage Found. 2006).
• 96See David Weisburd et al., Increasing Collective Efficacy and Social Capital at Crime Hot Spots: New Crime Control Tools for Police, Policing, July 12, 2015 (describing the ongoing Brooklyn Park research project).
• 97See, e.g., Robert J. Sampson, Great American City: Chicago and the Enduring Neighborhood Effect 127 (Univ. of Chicago Press 2012); Christopher R. Browning et al., The Paradox of Social Organization: Networks, Collective Efficacy, and Violent Crime in Urban Neighborhoods, 83 Soc. Forces 503, 504 (2004); Robert J. Sampson et al., Neighborhoods and Violent Crime: A Multilevel Study of Collective Efficacy, 277 Science 918, 919 (1997).
• 98U.S. Census Bureau, Brooklyn Park (city), Minnesota, State & County Quick Facts, http://quickfacts.census.gov/qfd/states/27/2707966.html (http://perma.cc/E32Z-XUWR] (last updated Dec. 2, 2015, 9:30 AM).
• 99Brooklyn Park FAQ, Brooklyn Park, http://www.brooklynpark.org/ faq/ (https://perma.cc/Y677-YPCH).
• 100U.S. Census Bureau, supra note 98.
• 101Id.
• 102Cf. Sampson et al., supra note 97, at 919 (“[I]t is the linkage of mutual trust and the willingness to intervene for the common good that defines the neighborhood context of collective efficacy.”).
• 103See Craig D. Uchida et al., Data-Driven Crime Prevention: New Tools for Community Involvement and Crime Control 2, 7 (Justice & Sec. Strategies 2013).
• 104See Lorraine Mazerolle et al., Procedural Justice, Routine Encounters and Citizen Perceptions of Police: Main Findings from the Queensland Community Engagement Trial (QCET), 8 J. of Experimental Criminology 343, 351–53 (2012).
• 105Tom R. Tyler & Yuen J. Huo, Trust in the Law: Encouraging Public Cooperation with the Police and Courts 50–51 (Russell Sage Found. 2002).
• 106Id.
• 107Skogan & Frydl, supra note 58, at 301. While we focus here on Tyler’s process-based model of procedural justice, legitimacy, and compliance, we recognize that some scholars have argued that factors other than procedural justice also have strong impacts on citizen perceptions of legitimacy. See, e.g., Anthony Bottoms & Justice Tankebe, Beyond Procedural Justice: A Dialogic Approach to Legitimacy in Criminal Justice, 102 J. of Crim. L. & Criminology 119 (2012).
• 108See Tyler & Fagan, supra note 81.
• 109Office of Cmty. Oriented Policing Services, Final Report of the President’s Task Force on 21st Century Policing 9 (2015).
• 110See Stephen D. Mastrofski et al., Compliance on Demand: The Public’s Response to Specific Police Requests, 33 J. of Res. in Crime & Delinq. 269, 298 (1996).
• 111See Raymond Paternoster et al., Do Fair Procedures Matter? The Effect of Procedural Justice on Spouse Assault, 31 Law & Soc’y Rev. 163, 192 (1997).
• 112See id.; see also Lawrence W. Sherman, Defiance, Deterrence, and Irrelevance: A Theory of the Criminal Sanction, 30 J. of Res. in Crime & Delinq. 445 (1993).
• 113See John D. McCluskey, Police Requests for Compliance: Coercive and Procedurally Just Tactics 114–15 (Marilyn McShane & Frank P. Williams III eds., LFB Scholarly Publ’g 2003).
• 114Id. at 88, 91.
• 115Id.