Comparative police systems_preview

Copyrighted Material.

Philippine Copyright© 1969, 2003, 2013
by HARRY C. LORENZO, JR.

ALL RIGHTS RESERVED
No part of this book may be reproduced
without written permission from the Author

First Printing: 1969
Second Printing: 2003 by King’s Way, Cabanatuan City, Philippines
Third Printing: 2013 by Tri-Psyc Enterprises, Lorenzo Ville,
Cabanatuan City
Editor: Winston John Romero Casio
wjrc.chp@gmail.com


Contents

Preface ......................................................................... V
INTRODUCTION ............................................................... VII
CHAPTER 1
POLICING MODEL: UNITED STATES ................................ 1
CHAPTER 2
POLICING MODEL: ENGLAND .......................................... 31
CHAPTER 3
POLICING MODEL: FRANCE ............................................ 47
CHAPTER 4
POLICING MODEL: SWEDEN ........................................... 61
CHAPTER 5
POLICING MODEL: JAPAN ............................................... 75
CHAPTER 6
POLICING MODEL: RUSSIAN FEDERATION ...................... 87
CHAPTER 7
ASEAN POLICE SYSTEM .................................................. 99

A. INDONESIAN POLICE SYSTEM ......................... 99

B. ROYAL MALAYSIAN POLICE ............................. 103

C. SINGAPORE POLICE SYSTEM ...........................
114

D. THAI POLICE FORCE ........................................ 118
Chapter 8
PHILIPPINES AND INTERNATIONAL POLICING ................. 123

A. INTERNATIONAL CRIMINAL

ORGANIZATION of POLICE (INTERPOL) ............. 123

B. ASEAN NATIONAL POLICE (ASEANAPOL) .......... 35
1
References .................................................................. 141

Policing Model : United States

CHAPTER 1
POLICING MODEL: UNITED STATES1

INTRODUCTION

The history of the police is extremely relevant to understanding
the police today. The idea that the police are resistant to change is a
myth. In fact, American policing has changed tremendously, even in
the last twenty years. The study of history helps us understand how
and why these changes occur. It can illuminate the social and political
forces affecting the police, as well as the dynamics of planned reform.
Many current problems have long histories. Corruption, for example,
is deeply rooted in police history, and it is useful to understand its
origins and why it has been so difficult to eliminate. Some current
problems, on the other hand, are the result of yesterday’s “reform.”
The patrol car was hailed as a great advance because it allowed
efficient patrol coverage, but it isolated officers from the public
and contributed to police community relations problems. Other
reforms have succeeded. Recent controls over police use of deadly
force have cut the number of citizens shot and killed by the police
in half. It is useful to analyze why some reforms succeed, why
some problems resist elimination, and why other reforms fail.
THE ENGLISH HERITAGE

American policing is a product of its English heritage. The
English colonists brought with them the criminal justice system of
their country. This included English common law; the high value
placed on individual rights, the court system, forms of punishment,
and law enforcement institutions.
1
Walker, Samuel. The Police in America: An Introduction, (Second Edition:
United States of America: McGraw Hill, Inc., 1992).

1

2

AN INTRODUCTION TO COMPARATIVE POLICE SYSTEMS

General Characteristics

The English heritage contributed three enduring features to
American policing. The first is a tradition of limited police authority. The
American legal tradition seeks to protect individual liberty by limiting
government authority. Continental European countries, by contrast,
give their law enforcement agencies much broader powers. German
citizens, for example, are required to carry identity cards and report
changes of address to police authorities.

The second feature inherited from England is a tradition
of local control of law enforcement agencies. European countries,
by contrast, have centralized, national police forces. Local control
contributes to the third feature, namely, a highly decentralized and
fragmented system of law enforcement. The United States is unique
in having an estimated 20,000 separate law enforcement agencies,
subject only to minimal coordination and very little national control or
regulation.

Institutions

Formal law enforcement agencies emerged in England in the
thirteenth century. The constable assumed primary responsibility for
keeping the peace. An elected official of the manor or county parish,
the constable was also the local government executive. The Statute of
Winchester in 1285 added several important new elements. The “watch
and ward” required all men in a given town to serve on the night watch
to guard against fires, crimes, and suspicious persons. The “hue and
cry” made all citizens responsible for pursuing fugitives from justice.
Finally, the Statute of Winchester required all males to maintain
weapons in their homes for use in protecting the public peace.

Between the thirteenth and nineteenth centuries, the English
law enforcement tradition developed in an unsystematic manner.
New institutions were created and old ones changed. The sheriff
(originally “shire reeve”) appeared, from whom the American sheriff is
descended. The justice of the peace emerged in the fourteenth century
as an important element of the local system of justice. Much of the
responsibility for law enforcement, however, remained in the hands of
private individuals. Crime victims had to pursue offenders on their own.


CREATION OF THE MODERN POLICE: LONDON, 1829

By the early nineteenth century, the old system of law
enforcement began to collapse as London grew into a large industrial
city, with problems of poverty, public disorder and crime. The 1780
Gordon riots between Irish immigrants and local English residents
triggered a long debate over how to provide better public safety.
Parliament debated the question for nearly fifty years, finally creating
the London Metropolitan Police in 1829. The London police eventually
became the model for American law enforcement. The father of the
London police was Sir Robert Peel, from whom the term ‘Bobbies’
originated.

The London police introduced three new elements to modern
policing. These are the following: a new mission, strategy, and
organizational structure.
The mission was crime prevention, reflecting the utilitarian
idea that it was better to prevent crime than to respond after the fact.
Crime prevention, or deterrence, was to be achieved through a strategy
of preventive patrol. Officers would maintain a visible presence in the
community by continuously patrolling fixed “beats.” Peel borrowed
the organizational structure of the London police from the military,
including uniforms, rank designations, and, most important, the
authoritarian system of command and discipline. This quasi-militia
style prevails in American police administration to this day.
The continual presence of the police in the community was
another distinct feature of modern policing. It reflects the general
growth of government regulation in all aspects of social and economic
life. In a comparative study of the development of policing around the
world, David Bayley argues that the essential features of the modern
police are that they are “public, specialized, and professional.” They are
public in the sense that they transfer responsibility for public safety to
government agencies. They are specialized in the sense that they have
a distinct mission of law enforcement and crime prevention. Originally,
they are professional in the sense that they are fulltime, paid employees.
Bayley points out that the characteristics of modern policing did not
appear all at once. Even though the year 1829 is usually cited as the
origin of modern day policing, in reality the London model represented
a consolidation of features that had been developing for centuries.2

2
Dempsey, John and Frost, Linda. Introduction to Policing, (Sixth Edition:
United States of America: Cengage Learning, 2012). Page 9.

3

4


LAW ENFORCEMENT IN COLONIAL AMERICA

The first English colonists in America created law enforcement
institutions as soon as they established organized communities. These
early English institutions, however, eventually evolved and acquired
distinctive American features.
LAW ENFORCEMENT INSTITUTIONS

The principal law enforcement institutions in colonial
America were the sheriff, the constable, the watch, and the slave patrol.3

Appointed by the colonial governor, the sheriff was the
chief local government official, with many responsibilities: collecting
taxes, conducting elections, maintaining bridges and roads, and so
on. Criminal law enforcement was only a part of the sheriff’s role.
The constable also had some criminal law enforcement
responsibilities in colonial towns and cities. Initially an elective
position, the constable gradually evolved into a semi-professional
appointed office, in Boston and several other cities, the office
of constable became a desirable and often lucrative position.
The watch most nearly resembled the modern-day police,
Members of the watch patrolled the city to guard against fires,
crime, and disorder. Originally, it was strictly a night time activity;
gradually, the larger cities created day watches, Boston created
a watch in 1634. Following the English tradition, service on the
watch was a collective responsibility, with all adult males required
to serve. Over the years, increasing numbers of men tried to avoid
duty, either by outright evasion or by paying others to serve in their
place. Eventually, the watch evolved into a paid professional position.
The slave patrol was a distinctly American form of law
enforcement, it was created in the Southern states to guard against
slave revolts and capture runaway slaves. In some respects, the
slave patrols were the first modern police forces in this country. The
Charleston (South Carolina) slave patrol, with about 100 officers in
1837, was possibly the country’s largest police force at that time.
THE FIRST MODERN AMERICAN POLICE

Modern police forces were established in the United States
about ten years after the creation of the London police. As in England, the
old system of law enforcement broke under the impact of urbanization,
industrialization, and immigration. Beginning in the 1830s, a wave
of riots struck American cities. Disorder became a more serious and
3

Ibid, Page 11.


more frequent problem, Boston had major riots in 1834, 1835, and
1837. In 1838, Abraham Lincoln—then a member of the Illinois state
legislature-warned of the “increasing disregard for law which pervades
the country.” Many riots were clashes between different ethnic groups:
Irish or German immigrants against native-born English Protestants.
Other riots were economic in nature. During economic crises, for
example, angry depositors often stormed and destroyed banks. Disputes
over moral questions also resulted in mass violence. In several cases,
people objecting to new medical practices attacked hospitals. Finally,
racial violence grew in the years before the Civil War, with proslavery
whites attacking abolitionists and free black citizens in Northern cities.

Despite the breakdown in law and order, Americans moved
very slowly in creating new police forces. New York City did not create
a new police force until 1845, eleven years after the first outbreak
of riots. Philadelphia followed a more erratic course. Between 1833
and 1854, in the face of recurring riots the city wrestled with the
problem of police reform before finally creating a consolidated, citywide
police force on the London model. These delays reflected deep public
uncertainty about modern police methods. For many Americans, police
officers dispersed throughout the community brought to mind the
hated British colonial army. Others were afraid that rival politicians
would fight for control of the police department to their own partisan
advantage—a fear that proved to be correct. Finally, many people
were reluctant to raise the taxes necessary to pay for a large police
force. This conflict between the desire for greater protection and the
reluctance to pay for it remained a long tradition in American policing.

Many of the early American police departments were little
more than expanded versions of the existing watch system. The Boston
police department began with only nine officers in 1838. The first
American police officers did not wear uniforms; they were identified only
by a distinctive hat and badge. Nor did they carry firearms. Weapons
did not become standard police equipment until the late nineteenth
century, as community crime and violence rose to more serious levels.

From the London model, Americans borrowed the mission
of crime prevention, the strategy of visible patrol over fixed beats, and
some elements of the quasi-military organizational structure. The
most important difference was in the nature of the political control
over police departments. The United States was a far more democratic
country than Britain. American voters—only white males with
property until the latter part of the century-exercised direct control
over all government agencies. (In London, by contrast, voters had no
direct control over the new police force.) As a result, American police
departments were immersed in local politics, a situation that led to many

5

6


serious problems. The commissioners of the London police, freed from
political influence, were able to maintain high personnel standards.
AMERICAN POLICING IN THE NINETEENTH CENTURY

Personnel Standards: Personnel standards, for all
practical purposes, did not exist; Officers were selected entirely
on the basis of their political connections. In New York City, a
$300 payment to the Tammany Hall political machine was the only
requirement for appointment to the force. Lack of intelligence, poor
health, and a criminal record were no barriers to employment.

Recruits were handed a badge, a baton, and a copy of the
department rules (if one existed), and were sent out on patrol duty.
Only a few departments offered any formal pre-service training to new
officers. Cincinnati created a police academy in 1888, but it lasted only
a few years. New York City established a School of Pistol Practice in
1895, but offered no training in any other aspect of policing until 1909.
Yet an investigation of the New York police academy in 1913 found
that no tests were given and all recruits were automatically passed.
The first textbook on police administration did not appear until 1909.

Police officers had no job security and could be fired at will.
In some instances, almost the entire police force was dismissed after
an election. Nonetheless, it was an attractive job because salaries were
generally higher than those for most blue collar jobs. In 1880 officers
in most big cities earned $900 a year, compared with $450 for factory
workers.

Jobs on the police force were a major form of political
patronage, and the composition of departments reflected the ethnic
and religious makeup of the cities. When politicians of English and
Protestant background controlled a city, these ethnic groups dominated
the police department. Discrimination against recent immigrants was
common. Irish-Americans were discriminated against until they won
political power. The appointment of Barney McGinniskin, the first
Irish-American police officer in Boston, created a major political crisis
in 1851. German-Americans were strong in Cleveland, Cincinnati,
Milwaukee, and St. Louis. Other groups fought for their share of
patronage appointments. After the Civil War, blacks were appointed as
officers in northern cities where the Republicans were in power.

Patrol Work: Police patrol was hopelessly inefficient. The
lack of communications systems made it impossible to respond to
crime and disorder. Officers patrolled on foot and were spread very


thin. In Chicago beats were three and four miles long. In many cities
entire areas were not patrolled at all.

Supervision was extremely weak. Officers easily evaded
duty and spent much of their time in saloons and barber shops.
Rain, snow, and extremely hot weather were powerful incentives for
officers to avoid patrolling. Sergeants also patrolled on foot and found
it nearly impossible to keep track of the officers under their command.

The first primitive communications system involved a
network of call boxes through which patrol officers could call in to the
station house. Officers devised ways of sabotaging the system. The first
boxes could be taken out of service by leaving the receiver off the hook.
Some systems did not indicate the location of the call box, and officers
simply lied about where they were.

Without an effective communications system, citizens could
not contact the police. In the event of a crime or disturbance, a citizen
had to personally locate a police officer. Even if one could be found,
the officer had to walk to the scene. Officers had no efficient way of
summoning help in the case of major disturbances.

The Citizen’s View of Policing: In later years, a nostalgic
image developed of the nineteenth-century foot patrol officer, He
was seen as a friendly person who maintained close relations with
neighborhood residents. If his methods were often rough, he was at
least effective in maintaining order. This view has little if any basis
in fact. It is doubtful that the first American police officers had close
relations with people on their beats. Officers were few in number,
personnel turnover was rapid, and population movement was even
greater than it is today. Police officers frequently used physical force,
and there is no evidence that it helped to control disorder.

The truth is that nineteenth-century police officers enjoyed
little citizen respect and faced much open hostility. Citizens regarded
them as political hacks rather than as public servants. Juvenile
gangs made a sport of throwing rocks at the police or taunting
them. People who were arrested often fought back (about 80% of
all arrests involved public drunkenness). Discipline was virtually
nonexistent, and excessive use of force became commonplace.

In a provocative study of police activity in London and
New York City, Wilbur Miller analyzes the reasons that policing in
the two cities developed in such different directions. He argues that
in London a high level of mutual respect emerged between citizens
and police. Although many citizens were initially hostile to the new
police, they came to respect officers because of their civil conduct.

7

8


Police restraint, in turn, was the result of high personnel standards
and strict supervision. Over the long run, increasing public respect
reinforced police civility. In the United States, by contrast, hostility
rather than restraint became the rule. Public disrespect was typically
greeted by police brutality, which went unpunished. Continued use of
force by the police only encouraged more public hostility. Ultimately,
this vicious circle led to a complete lack of public respect for police
officers and a lack of professionalism in American policing.

Citizen violence in the United States also led to greater
use of police firearms. As late as 1880 the police in Brooklyn
(then an independent city of 500,000 people) were unarmed. In
some cities weapons were optional or carried at the discretion
of a sergeant. Firearms did not become standard equipment for
police officers until after the Civil War. The police adopted firearms
mainly in response to the rising level of violence around them.

THE ORIGINS OF POLICE PROFESSIONALISM: THE TWENTIETH
CENTURY

American policing underwent a dramatic change ¡n
the twentieth century. There were to principal forces for change.
First, a movement to establish professional standards in policing,
which appeared at the turn of the century, eventually succeeded
in raising the quality of policing. Second, the introduction
of modern communications technology in the middle of the
century transformed both police work and police administration.
THE PROFESSIONALIZATION MOVEMENT

Around the turn of the century, a new generation of leaders
launched an organized effort to professionalize the police. Police
reform was part of a much broader movement in the United States
between 1900 and 1917. Progressivism, as it was known, attacked
economic abuses (by regulating big business), social welfare abuses
(by seeking child labor laws), local government corruption and many
other problems.

The two most prominent leaders of the professionalization
movement were Richard Sylvester and August Vollmer. Sylvester
was superintendent of the District of Columbia police from 1898 to
1915 and president of the International Association of Chiefs of Police
(IACP) from 1901 to 1915. He made the IACP the national voice of

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