Canton Police AuditA searchable public record.

Front matter · PDF text layer

Town of Canton,
Massachusetts

Independent
Onsite Audit
of the Town of
Canton Police
Department

April 2025

Fiscal Years:
2015 – 2025

Date of Inspection:
November 18, 2024 – March 30, 2025

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2025 Independent Audit
of the Town of Canton
Police Department
5 Stones intelligence (5Si) was tasked with auditing the
Canton Police Department in accordance with the scope of
work order detailed within. 5Si’s report does not make any
findings of fact or conclusions of law regarding ongoing
criminal investigations or pending legal matters involving
the Canton Police Department.

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March 30, 2025

Dear Police Audit Committee,

On behalf of 5 Stones intelligence (5Si), we are presenting our review of the Canton Police Department’s
(PD) adherence to policies and procedures as further detailed in your Scope of Services agreement. Since
November of 2024, 5Si has partnered with Canton town officials, the Canton PD, and Canton residents to
identify, evaluate, and recommend structural and systemic improvements that the Canton PD can
implement to achieve a shared vision of safe, effective, and transparent law enforcement for the Town of
Canton.

Our report is the product of constructive collaboration between Canton town stakeholders, the public and
the Canton PD. The cooperation, transparency, and efforts of the Canton PD, specifically its leadership,
are a testimony to the power of collaborative change. We look forward to sharing our findings and our
continued work with you to support the implementation of our recommendations.

5Si’s audit included the evaluation of the Department’s organizational culture, policies, procedures,
regulations, crime scene protocols, professional standards and accountability, organizational structure
and governance, citizens privacy protections, management, and operations, hiring and training standards,
citizen’s complaints, the internal affairs process, evidence handling and processing, financial resources
and budgeting, and the effectiveness and the transparency of the department. Our Final Report has
identified opportunities for improvement in several areas and offers key recommendations as set forth in
the attached report.

We would like to express our gratitude to the leadership and members of the Canton PD for their
cooperation and support. They have been receptive to our engagement and have collaborated closely with
our team to provide the necessary information and resources to gain insight into the Department's
operations and develop actionable recommendations for enhancement. Additionally, the Canton PD has
embraced the suggestions put forth by 5Si and are actively working toward the implementation of those
recommendations which can be effectively executed.

We appreciate the opportunity to collaborate with you in reshaping public safety in the Town of Canton. It
is an honor for us to assist in your efforts to foster a secure and efficient law enforcement environment for
both the police force and the communities they serve.

Sincerely,

Brian Talay,
CEO
5 Stones intelligence
Washington, D.C.

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Table of Contents
Executive Summary ............................................................................................................................................................. 2
  Introduction..................................................................................................................................................................... 2
  Review, Scope, and Methodology ..................................................................................................................................... 3
  Evidence and Crime Scene Protocols ............................................................................................................................... 4
  Professional Standards-Internal Affairs ........................................................................................................................... 5
  Organizational Structure of Governance .......................................................................................................................... 5
  Management Operations and Culture .............................................................................................................................. 7
  Hiring, Training, Standards and Equipment ...................................................................................................................... 8
Background ....................................................................................................................................................................... 12
  The Canton Police Department (PD) ............................................................................................................................... 12
  Methodology of Audit ..................................................................................................................................................... 17
Section 1: Policies, Procedures and Regulations ................................................................................................................ 19
  A. Interrogating Suspects / Interviewing Witnesses or Victims ....................................................................................... 19
  B. Evidence, Search and Seizure, Electronic Devices and Chain of Custody ................................................................... 20
  C. Eyewitness Identification .......................................................................................................................................... 23
  D. Testifying ................................................................................................................................................................... 24
  E. Mental Health ............................................................................................................................................................ 26
  F. Handling of Juveniles ................................................................................................................................................. 27
  G. Community Relations ................................................................................................................................................ 29
  H. Hit & Run Investigations ............................................................................................................................................. 30
  I. Motor Vehicle Citations............................................................................................................................................... 32
  J. Protective Custody ..................................................................................................................................................... 33
  K. Telephone and Radio Use Including Personal Cell Phone ........................................................................................... 34
  L. CEO Notification ........................................................................................................................................................ 35
  M. Communications Standards of Conduct .................................................................................................................... 36
  N. Command Protocol and Order of Precedence ............................................................................................................ 38
  O. Dispatch Functions.................................................................................................................................................... 40
  P. Field Reporting........................................................................................................................................................... 42
  Q. Legal Process ............................................................................................................................................................ 43
  R. Media and Public Information .................................................................................................................................... 45
  S. Bias-Free Policing ...................................................................................................................................................... 48
  T. Alternatives to Arrest .................................................................................................................................................. 49
  U. Field Training and Evaluation Program ....................................................................................................................... 50
  V. In Car Video Recording ............................................................................................................................................... 51
  W. Body Camera Recording ............................................................................................................................................ 52
  X. Automated Plate Reader Policy/Flock Cameras ......................................................................................................... 52
  Y. Duty to Intervene........................................................................................................................................................ 53
  Z. Informants ................................................................................................................................................................. 53
  AA. Domestic Disputes .................................................................................................................................................. 56
  BB. Sexual Assaults ....................................................................................................................................................... 57
  CC. Dead Bodies ............................................................................................................................................................ 58
  DD. Cold Cases .............................................................................................................................................................. 61

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EE. Criminal Intelligence................................................................................................................................................ 61
   FF. Internal Affairs (IA) ................................................................................................................................................... 62
   GG. Victim Witness Rights ............................................................................................................................................. 64
   HH. Training ................................................................................................................................................................... 66
   II. Central Records ......................................................................................................................................................... 67
   JJ. Oath of Officer ........................................................................................................................................................... 69
   KK. Domestic Violence Involving LEO ............................................................................................................................. 71
   LL. Code of Conduct....................................................................................................................................................... 72
   MM. Roll Call Policy ....................................................................................................................................................... 73
   NN. Selection Process ................................................................................................................................................... 74
   OO. Dispatch Center Access and Use Policy .................................................................................................................. 75
   PP. School Resource Officer .......................................................................................................................................... 76
   QQ. Professional Conduct.............................................................................................................................................. 78
   RR. Special Operations .................................................................................................................................................. 79
   SS. Compliance with CALEA Standards on Specified Policies and Procedures ............................................................... 80
   TT. Officer Personal Vehicle Use .................................................................................................................................... 81
   UU. Overtime Policy and the Adherence of the Overtime ................................................................................................ 82
   VV. Use of Personal Cell Phones .................................................................................................................................... 82
Section 2: Crime Scene Protocols Overview ....................................................................................................................... 85
  Case File Audit of the Death of Boston Police Officer John O’Keefe ................................................................................ 87
  Case File Audit of the Death of Sandra Birchmore .......................................................................................................... 99
  Case File Audit of the Death of Craig Casey .................................................................................................................. 102
  Case File Audit of Damage to a House Under Construction ........................................................................................... 104
Section 3: Professional Standards and Accountability ..................................................................................................... 106
Section 4: Organizational Structure and Governance ....................................................................................................... 113
Section 5: Citizens Privacy Protections ............................................................................................................................ 120
Section 6: Management, Operations and Culture ............................................................................................................. 123
Section 7: Hiring, Training Standards, and Equipment ...................................................................................................... 131
Section 8: Citizens Complaint Process ............................................................................................................................. 141
Section 9: Conflicts of Interest ......................................................................................................................................... 146
Section 10: Select Board Oversight and Industry Standards ............................................................................................. 149
Section 11: Recommendations and Compliance Review .................................................................................................. 154
Section 12: Recommended Improvements....................................................................................................................... 156
Section 13: Forfeiture Forensic Review ............................................................................................................................ 158
Section 14: Evidence Review ............................................................................................................................................ 162
Section 15: Police Detail Financial Review ....................................................................................................................... 167
Section 16: Additional Administrative Items to Review ..................................................................................................... 171
Section 17: Civil Rights Review......................................................................................................................................... 174
Section 18: Liaison Interviews .......................................................................................................................................... 177
Section 19: Security ......................................................................................................................................................... 181
Section 20: Recommended Improvements and Summary ................................................................................................ 184

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EXECUTIVE
 SUMMARY
                                                     Image source: Boston Globe

Executive Summary · PDF text layer

EXECUTIVE SUMMARY

Introduction
The Town of Canton, Massachusetts and the Special Police Audit Committee
selected 5 Stones intelligence (5Si) to conduct an Independent Police Audit (IPA) of
the Canton Police Department (PD) in November 2024. Our Audit Team conducted
a thorough review of the scope of work which detailed areas for review including
crime scene protocols, professional standards, accountability processes,
organizational structure, and other operational aspects. This audit included a
financial review of overtime expenditures, asset forfeiture expenditures and police
detail finances.

The residents of Canton commissioned the police audit following the tragic death of a town resident,
Boston Police Officer John O’Keefe, on January 29, 2022. The community seeks to comprehensively
assess the department's strengths and identify areas where improvements can be made.

The audit was conducted from November 18, 2024 to March 30, 2025, reviewing activities spanning from
Fiscal Years (FY) 2015 to March 2025 at Canton PD. 5Si team members were present on-site for
approximately 12 weeks evaluating the day-to-day operations, the department's adherence to internal
policies and procedures, as well as compliance with applicable laws and regulations, including
Massachusetts General Laws and local by-laws. Over the following several months, 5Si conducted
interviews of all members of the Canton Police Department including over forty (40) police officers, and
other town employees. Many of the interviews were completed under the condition of anonymity. As part
of the inquiry, our team examined more than 98 policies, procedures, rules, and regulations.
Recommendations were put forward in various aspects of the project, such as professional standards,
civilian grievances and accountability, crime scene protocols, advanced training, and compliance with the
Massachusetts Police Accreditation Commission.

In conducting this audit, we received full cooperation from Chief Helena Rafferty and other members of
the police department and town employees. Prior to this audit, no member of the 5Si Audit Team had ever
met any current or former employees of the Canton PD, the Police Audit Committee, or the Select Board.
This report was not provided to any members of the department and/or town employees prior to April 1,
2025. The Audit Team provided updates to Robert McCarthy, Chairperson on the Police Audit Committee.

Our team conducted interviews with all Canton PD employees. The officers who agreed to be interviewed
were candid, cooperative, and forthright. Each officer was interviewed in private with no supervisors
present. No senior member of the Canton PD command staff, or Town Officials, interfered with or
attempted to influence the information and/or findings in this report. The Audit Team operated with
independence and autonomy during this audit. The Audit Team has extensive experience in investigative
processes, with expertise in conducting internal investigations, compliance, and inspection related
issues.

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Given the interest in this audit, it is important to understand what is included as part of this audit and what
is outside of the scope of this audit, as summarized below:

                    INCLUDED in the Audit                                  NOT Included in the Audit
  Assessment of policy compliance with standards of                 o Reinvestigation of any cases or
   law enforcement accreditation organizations.                        finding of fact.
  Assessment of the application of policy in recent                 o Analysis of evidence collected in
   investigations.                                                     ongoing or prior criminal cases.
  Assessment of the written policy and protocols as                 o Rendering any opinion of guilt or
   applied in recent investigations.                                   innocence of a party.
  Presentation of findings and recommendations.

Review, Scope, and Methodology
The audit was conducted in accordance with established criteria such as U.S. GAO Government Auditing
Standards, Massachusetts Police Officers Standards and Training (POST) Commission Standards, and
Commission on Accreditation for Law Enforcement Agencies (CALEA) Standards to ensure rigorous
assessment of the department's operations. The assessment entailed a thorough evaluation of the Canton
PD across a broad spectrum of operational and administrative areas. The Audit Team's focus extended
beyond mere compliance to encompass the department's effectiveness and efficiency in implementing
policies, procedures, rules, and regulations. We reviewed a total of 98 Canton PD policies governing
procedures, rules and regulations, as well as reports of investigation, crime scene preservation, and
training opportunities provided by Canton PD command staff. The Audit Team ensured a comprehensive
and unbiased assessment was completed in each section as outlined in the scope of work.

Additionally, employee interviews were conducted involving all members of the Canton PD, covering
leadership, patrol officers and detectives, in addition to key Town of Canton Department Heads, including
the Town Administrator, Superintendent of Schools and Select Board members. These interviews
highlighted areas of strength and efficiency, areas for potential improvement, and illustrated the
professionalism of the Canton PD officers during what has been described as a tumultuous time in the
Town of Canton’s history.

As the Audit Team worked through the scope of work, numerous findings highlighted discrepancies
between written policy and implementation. The Audit Team has put forth recommendations in the body of
this report in an effort to assist the Town of Canton in enhancing policy compliance and operational
efficiency. While the audit covered 20 sections, the areas of: Crime Scene Protocols; Professional
Standards and Accountability; Organizational Structure and Governance; Management, Operations and
Culture: Hiring, Training and Equipment: and Evidence, are the main areas in which the Audit Team
identified immediate action and development items.

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Evidence and Crime Scene Protocols
The Audit Team reviewed a series of crime scene incident reports spanning over a decade. While some
investigations were found to be in line with established guidelines, there were cases of policy breaches
mainly related to the use of digital photography for documenting crime scenes, as required by the Canton
PD's Evidence Collection and Preservation Policy. Additional shortcomings were identified in the areas of
crime scene preservation and detailed incident documentation. Our evaluation included a detailed
analysis of the Canton PD Policy and Procedure, with a specific focus on Evidence Collection No. 6.01
dated October 31, 2013. This policy outlines the responsibilities of first responders in evidence collection,
crime scene preservation, and documentation. Initial recommendations were for the sergeant or shift
commander to take charge of crime scenes, and for additional training for Canton PD personnel to handle
or supervise evidence collection.

During the examination, the Audit Team assessed the response and crime scene procedures carried out by
Canton PD officers on January 29, 2022, involving the tragic death of Boston Police Officer John O’Keefe at
34 Fairview Road in the early morning hours. These actions were compared against existing policies,
regulations, and requirements to determine compliance. The review of this major incident encompassed
crime scene investigations, police reports, evidence collection, crime scene security, interviews, and
evidence documentation. Policy violations were identified and are detailed both below and in the Final
Report.

          OBSERVATIONS AND FINDINGS
            •   First Responding Officers should have photographed Boston Police Officer John O’Keefe
                at the location of where he was found before Fire Rescue moved him to the rescue.
            •   All interviews of critical witnesses, including Jennifer McCabe and Kerry Roberts, should
                have been conducted at Canton PD on January 29, 2022, after John O’Keefe was
                transported to the hospital.
            •   Consensual Recorded Witness Interviews should have been conducted.
            •   The MSP along with Canton PD should have maintained a police presence at 34 Fairview
                Road pending the secondary search conducted by MSP crime scene units.
            •   ALL video footage (files) maintained on Canton PDs computer systems of Karen Read’s
                Lexus SUV while it was housed at Canton PD from January 29 through February 2, 2022,
                should have been requested and turned over early in the Karen Read case to lead
                investigators for any action as deemed appropriate.

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Professional Standards-Internal Affairs
In evaluating professional standards and processes, the Audit Team conducted an examination of Internal
Affairs (IA) investigations dating back to 1991. As a result, we found that there was a lack of organization
and consistency for the investigative files and for investigative efforts, particularly during the tenure of four
(4) different Canton Police Chiefs, namely John Ruane Jr., Peter Bright, Kenneth Berkowitz, and Helena
Rafferty. We examined seventy-five (75) IA investigative files over a twenty (20)-year period These seventy-
five (75) actions resulted in sixty-three (63) clearances and twelve (12) acts of sustained violations. The
twelve (12) sustained violations resulted in: four (4) suspensions, one (1) demotion and seven (7)
counseling/training sessions. The Audit Team determined that POST requirements were met as they
related to these inquiries and subsequent disciplinary actions. The most recent action occurred on
October 2, 2024. Two (2) complaints and results were sent to POST in accordance with policy.

It was noted that due to the department's size, establishing a designated Internal Affairs division or the
designation of a full-time Internal Affairs Investigator is not practical. The Audit Team found that complaint
files were not maintained in a consistent manner as methods of investigation, documentation and
processes were varied. While the Deputy Chief of Operations and Investigations is responsible for
overseeing internal investigations, we found some complaints filed by residents and/or violations of policy
and procedure by officers were handled directly by the Chief of Police, creating a conflict.

          OBSERVATIONS AND FINDINGS
            •   The Canton PD’s Internal Affairs process is inconsistent regarding investigation and
                documentation methods.
            •   The Audit Team found no instances where complaints were intentionally ignored, or officer
                misconduct was arbitrarily excused; but the consistency in how cases were handled
                varied greatly.
            •   Several misconduct complaints were handled directly by the Chief of Police. The Audit
                Team recommends hiring outside firms for IA investigations where conflicts and potential
                conflicts exist, or cases where multiple officers are involved.

Organizational Structure of Governance
The Canton PD's hierarchy framework and chain of command are well-defined, ensuring that
communication follows the appropriate channels to reach supervisors. Information flows smoothly to the
necessary authorities when senior decision-making is needed. By bringing in additional civilian staff
members, such as intelligence analysts, the department could greatly improve communication
capabilities, leading to increased efficiency and effectiveness.

The Audit Team found that the patrol division and investigative division frequently collaborate on crime
prevention and provide effective support to each other's efforts. Their teamwork and synchronization are
evident in their combined responses to incidents, such as a non-fatal shooting event in November 2024.

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During this occurrence, both divisions swiftly reacted, apprehended the shooter, and gathered crucial
evidence, including the weapon used. Their cohesive approach involved conducting interviews, examining
evidence, and liaising with prosecutors to file attempted murder charges against the offender. The unity
and coordination between the patrol and investigative divisions were outstanding and played a crucial role
in the successful resolution of the case. Patrol officers are actively engaged in cases and maintain close
collaboration with the detective division. Additionally, all details and activities were promptly
communicated to senior management and town officials, guaranteeing appropriate notifications within
the organization.

Canton PD patrol officers are tasked with handling both 911 calls and other calls for service, dispatching
calls for service to patrol units. The Audit Team recommends that the Canton PD should consider
transferring their dispatch and 911 responsibilities to the Holbrook Regional Dispatch Center. The
relocation of dispatch operations to the Holbrook Dispatch center will not incur any expenses for the Town
of Canton for a period of 3 years. Furthermore, this transition will ensure the provision of services,
maintenance, and upgrades to the radio communication systems such as transmitters and repeaters be
funded by the state. A secondary option would be for Canton PD to hire full-time dispatchers to assist
officers in taking calls for service, non-emergency, and emergency calls for service and other
administrative tasks.

These recommendations are based on best practices and are anticipated to enhance the efficiency of the
Canton PD while fulfilling various needs.

While the department has established and implemented standards for communicating with the public
regarding emergencies, the function that permits public feedback has been deactivated. This has limited
the possibility of productive discussions. Some individuals in the community along with social media
influencers have continuously targeted the police department and its personnel with scornful comments,
negative personal attacks, and severe critique even for the most basic aspects of their duties. This has
hampered efforts to establish a constructive dialogue.

          OBSERVATIONS AND FINDINGS
            •   The Canton PD had three (3) Internal Affairs investigations in the past year as the result of
                police officer dispatch failures.
            •   No civilian dispatchers are employed by the Canton PD.
            •   The Canton PD has only one (1) part-time civilian employee.

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Management Operations and Culture
The Audit Team observed Chief Rafferty's leadership style and found her approach and decision-making
abilities to be effective. Chief Rafferty is highly respected by the members of the department and
colleagues in the law enforcement community. There is a noticeable decrease in morale among
department members, largely due to public scrutiny regarding the Canton PD's handling of the crime
scene and the investigation into the death of Canton resident and Boston Police Officer, John O'Keefe.
While constructive feedback is beneficial, the continuation of personal criticisms has transformed from a
method for improvement to personal attacks. These attacks via various avenues such as social media,
phone calls, e-mails, and public demonstrations have had a significant negative impact on morale within
the department.

Social media personalities have claimed that the Canton PD deliberately mishandled the crime scene
where Mr. O’Keefe was found on January 29, 2022, and implied a possible cover-up within the department
to hide the circumstances around Mr. O’Keefe’s death. Following her arrest, Karen Read and her legal
team have asserted there is a conspiracy and cover-up involving law enforcement and witnesses.
Influential figures on social media from various regions have been tracking and amplifying these claims.
Multiple Canton PD officers have stated that they have experienced harassment from the public while
working, spending personal time with their families and children, and during off-duty police details. A
gathering of individuals supporting the "Free Karen Read" movement regularly protest outside the Canton
PD. There have been numerous accounts of officers encountering harassment, both in-person and online,
including through e-mails, voicemails, social media platforms, and YouTube. Members of the Audit Team
have received e-mails and text messages prompting team members to investigate allegations and alleged
cover-ups by police.

While tensions are strained within the community, it is incumbent upon the leadership for the Town of
Canton to remain unbiased and objective. Any lack of support from Town leadership coupled with the
vitriol expressed by some members of the public, has negatively impacted the morale of the officers.

The following two quotes given by two (2) separate Canton PD officers during their interviews highlight the
chasm that exist between the Canton PD and the Town Officials.

          “No one in this town will care about us until one of us gets murdered, even then
          half the town will probably celebrate that.”

          “Elected officials don’t care about us. Now the easiest way to gain popularity or
          get elected is to publicly trash us. They have no political platform, just trash the
          police. That’s it. It doesn't even have to be true, just do it.”

          OBSERVATIONS AND FINDINGS
            •   The Canton PD has above average morale as it relates to camaraderie and faith in the
                department.

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•   Interviews conducted by the Audit Team revealed that officers do not feel they have the
                support of Canton Town Officials.
            •   The Canton PD officers’ morale as it relates to its relationship with the Town is low.
            •   The Audit Team has been informed that Town meetings in the Town of Canton devolve and
                become contentious and unproductive.

Hiring, Training, Standards and Equipment
The Canton PD is a civil service department, which plays an important role in ranking and selecting new
officers. Prior to exercising police powers in the Commonwealth, individuals must successfully complete
the prescribed course of study for basic police training authorized by Municipal Police Training Committee
(MPTC). The Municipal Police Training Committee sets the standards for basic police training for
candidates hired by individual police departments throughout the Commonwealth. Those police
departments submit applications for their employees (or sponsored candidates) to the recruit academies.
Hiring practices vary by department and certain departments, operating by Civil Service, (Canton PD) must
follow a selection process set forth by statute.

All Canton PD recruits in accordance with state law must: 1) be a minimum of 21 years old; 2) be
employed or sponsored by the Canton PD, and 3) successfully complete the Massachusetts Human
Resource Division's Physical Ability Test (PAT) and medical examination before assignment to the
academy.

The Canton PD hiring process and the standards followed are in alignment with policy, civil service
requirements and industry best standards.

Additional training for Canton PD officers is required. While the Canton PD meets training requirements as
they relate to certifications and qualifications, our team recommends Canton PD detectives receive
advanced training in crime scene photography, crime scene documentation, evidence evaluation, and
collection.

The Audit Team recommends further training in the areas of crime scene management, report writing,
evidence collection, expert witness testifying, internal affairs, discovery rules and legal ethics.
Additionally, officers have expressed a desire for more training and while the Command Staff attempts to
fulfill each request, current budget constraints prevent them from doing so.

The Audit Team has pinpointed locations in the Town of Canton where the Canton PD portable radios are
not functional. Given that officers are not equipped with department-issued cell phones, the scenario
where a Canton PD officer may be dispatched from their marked patrol car to address an emergency
situation on Washington Street (Canton Central) without any means of communication is realistic and
concerning. This situation could leave the Town vulnerable to legal action.

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OBSERVATIONS AND FINDINGS
            •   The Canton PD detectives need advanced training in crime scene investigations.
            •   The Canton PD needs an increased training budget approved by the town.
            •   Civil Service Standards place a limitation on who can be hired by the Town of Canton.
            •   Portable Radios and their inability to provide complete coverage is problematic.
            •   Canton PD officers are not issued department cellular phones.

Below is a list of a few recommendations as they relate to the above observations and findings. The Final
Report contains numerous additional findings and recommendations.

          RECOMMENDATIONS
          This section sets forth our recommendations for changes in the department.
          Recommendation 1
          Interviews Conducted at the Canton PD. Interviews of witnesses should be conducted at the
          Canton PD whenever possible. These interviews should be recorded and conducted as soon as
          possible after an event.
          Recommendation 2
          All sergeant and patrol vehicles should have full crime scene kits including evidence
          collection bags, sealing equipment and digital cameras. Department phones or digital
          cameras should be placed in patrol cars for officers to document crime scenes. The Audit Team
          identified that officers and detectives used personal phones to photograph crime scenes. Patrol
          officers and sergeants noted that Canton PD has one (1) digital camera assigned to the
          detective division. Chief Rafferty is aware of this recommendation and is in the process of
          purchasing additional digital cameras for officers.
          Recommendation 3
          Re-write Canton PD policy and procedure related to utilization and authorization of personal
          phones to photograph or video crime scenes. All policy should be changed to mandate the
          utilization of ONLY department issued/owned phones to photograph crime scenes. Use of
          personal phones should be strictly prohibited.
          Recommendation 4
          Relinquish 911 and dispatch responsibilities to the Holbrook dispatch Center or Hire full
          time dispatchers. In the past six (6) months, the Audit Team identified three (3) separate
          occasions where patrol officers failed to dispatch officers to calls for service. The Audit Team
          found most neighboring police departments of similar size employ full-time dispatchers or

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utilize regional dispatch centers. These options must be evaluated by the Town of Canton as
          either could alleviate overtime costs while providing an extra police body where needed. The
          use of regional or full-time dispatchers would allow overtime funds to be redirected towards
          overtime expenses incurred while attending training. Additionally, the officers covering dispatch
          would be available to perform police functions on patrol instead. If regional dispatch is the
          selected alternative, any expenses from radio system upgrades and maintenance is covered by
          the Commonwealth.
          Recommendation 5
          Increase training opportunities for patrol officers, detectives, and sergeants. Specific training
          of note includes crime scene training, interrogation and witness interviews, and evidence
          documentation practices.
          Recommendation 6
          Chief of the Investigations Division should review all death investigation police reports to
          ensure completeness, accuracy and exhaustion of all investigative avenues. [Note: A Canton PD
          detective wrote that Sandra Birchmore died of a suicide in the initial report. It was later
          determined that she had been killed by strangulation.]
          Recommendation 7
          Provide prompt, proportional, and consistent discipline across the department. Discipline
          must be applied consistently to all employees and administered in a manner that prevents the
          appearance of undue favor to any employee. The Audit Team identified that several Internal
          Affairs cases were handled directly by the Chief of Police and instances where the discipline
          process was not always applied consistently.

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BACKGROUND
                                                     Image source: Boston Globe

Background · PDF text layer

BACKGROUND
In October 2024, the Town of Canton, Massachusetts, along with a Special Police Audit Committee,
selected 5 Stones intelligence (5Si) to conduct an Independent Police Audit (IPA) of the Canton Police PD.
This audit took place between November 18, 2024 and March 21, 2025, examining activities from Fiscal
Years (FY) 2015 through March 2025. The audit aimed to assess whether the CDP adhered to internal
policies and procedures, and to ensure compliance with all relevant laws and regulations, including
Massachusetts General Laws and local by-laws. The audit adhered to various standards such as U.S. GAO
Government Auditing Standards, Massachusetts Police Officers Standards and Training (POST)
Commission Standards, and Commission on Accreditation for Law Enforcement Agencies (CALEA)
Standards. A thorough review was conducted of citizen complaints, conflict of interest issues, crime
scene protocols, professional standards, accountability processes, organizational structure, and other
operational aspects. This audit included a financial review of forfeiture expenditures and police detail
finances and was carried out in partnership with the Special Police Audit Committee.

The audit was initiated following a special town meeting in November 2024, where residents of Canton
voted to audit the local police department in response to the death of Boston Police Officer, John O’Keefe,
in Canton and the police’s handling of the crime scene and subsequent investigation. Consequently, the
Canton Select Board formed a Special Police Audit Committee to oversee the audit. The committee was
chaired by Robert “Bob” McCarthy, with additional members including David Clough, Kathleen Howley,
Dr. Daniel Muse, and Colonel John Kelly (retired from the Massachusetts State Police).

The Canton Police Department (PD)
The Canton PD is a municipal police force in Massachusetts employing fifty (50) personnel, including forty-
two (42) sworn officers. The department is headed by Police Chief Helena Rafferty, who was appointed in
2022. Chief Rafferty, a 35-year veteran of the department and an FBI National Academy graduate,
ascended through the department's ranks to her current position. The majority of the department's officers
operate within the Patrol Division, focusing on responding to service calls and patrolling town streets,
schools, and businesses.

Canton PD Structure
The command structure of the Canton PD is as follows:

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When at full staff, the Canton PD has twenty-five (25) patrol officers and seven (7) sergeants. Currently,
the Canton PD is down seven (7) officers with another deployed (sergeant) on military leave.

Shifts and Staffing
The Town of Canton is divided into four (4) sectors: Northwest, Northeast, West and East. On the dayshifts
(7:45 a.m.- 3:45 p.m.) there is a uniformed officer assigned to each sector, a patrol sergeant who roves
and responds to any serious calls, and an administrative sergeant in the station. A lieutenant is assigned to
each dayshift serving as Station Commander. A minimum of one
detective is assigned to each dayshift with the remaining
detectives on call and available. Additionally, during the week
there are four (4) full-time school resource officers each assigned
to Canton High School, Blue Hills Regional High School and Galvin
Middle School, with the fourth officer assigned to service all three
(3) public elementary schools.

Evening shift (3:45 p.m.- 11:45 p.m.) is staffed the same as the day
shift, except for the school resource officers.

The overnight shift (11:45 p.m. - 7:45 a.m.) is staffed with four (4)
patrol officers and one (1) sergeant. The West and East sectors
become one sector while the Northwest and Northeast remain
separate sectors. Each of these three (3) sectors are staffed with a
patrol officer. The fourth officer is assigned to dispatch, and the
                                                                      11:45 p.m. – 7:45 a.m. shift staff of the
sergeant patrols city-wide as a roving unit available to respond as Canton PD
needed to any sector.

Criminal Investigation Division (CID)
The Canton PD has a Criminal Investigation Division (CID) that focuses on investigating violent offenders,
serious crimes and related offenses. The CID is commanded by a lieutenant detective who overseas one
(1) detective sergeant and three (3) detectives. The CID performs tactical operations, serves warrants, and
works in concert with the Massachusetts State Police (MSP), neighboring state and local law enforcement
agencies, and federal law enforcement agencies including the DEA, ATF and FBI. The CID Sergeant serves
as the police prosecutor at Norfolk County Superior Court.

The CID detectives are also responsible for conducting any internal investigations or inquiries initiated as
the result of a civilian complaint or allegation made by another Canton PD employee. The assignment of
investigative personnel is at the discretion of the Canton PD senior leadership.

Canton PD Rules of Conduct
Rules and Regulations H:1 state in part:

          “Each employee of the Canton Police Department is expected to show his loyalty
          to the organization through putting forth his best effort to accomplish the
          Department's goals and objectives. Police Department employees must comply

Background · PDF text layer

with the rules and regulations set forth by the Canton Police Department and are
          to act both publicly and privately in a manner reflecting the highest public
          interest. Actions taken by an employee contrary to this paragraph shall be
          grounds for disciplinary actions...”

This regulation is the backbone of the Canton PD expectation of professionalism, courtesy, and integrity.
The Canton PD code of conduct contains twelve (12) pages and addresses pertinent issues required by
CALEA and Massachusetts POST conduct expectations as they relate to such areas as: Professionalism
when working with other agencies, Dissemination of Information, Courtesy and Respect, Interaction with
the Public, Courtesy to the Public, Requests for Assistance, Professional Trust, Referrals for Service,
Discrimination, Disparaging Terms, Prejudice, Stereotyping, Anti-Semitism, Racism, Sexual Harassment,
Dishonesty, and Political Involvement.

All employees of the Canton PD, both sworn and non-sworn, are required to familiarize themselves with
the provisions of the Department’s Rules and Regulations. All Canton PD policies were reviewed and
updated by Chief Helena Rafferty in November 2024. Canton PD policies, procedures and regulations are
available via each desktop on the l-drive under the title “Canton Police Department Rules and
Regulations” and on each officer’s cell phone via the Blue Voice application.

2024 Canton Police Enforcement Statistics
In 2024, the Canton PD logged 9,071 dispatch entries of which 8,928 were police actions, calls for service,
or police-initiated contacts. Of these 8,928 encounters, 310 resulted in an eventual arrest, with 75
resulting in an immediate arrest and handcuffing of at least one defendant. The other 235 arrests resulted
from indictments, arrest warrants, or surrenders. Of the 310 arrests, 37 resulted in a “use of force”
incident, representing approximately 12% of all the arrests. The use of force numbers and types are
depicted in the chart below.

                                       Canton PD Police Enforcement Statistics

Background · PDF text layer

Scope of Work and Areas Evaluated
The Audit Team was asked to assess the following
programs and policies for compliance with
Massachusetts State POST and Massachusetts
Police Accreditation Commission Standards (MPAC)
requirements:

•   Interviewing witnesses or victims’ policy
•   Search and seizure policy
•   Eyewitness Identification policy
•   Interrogating suspects policy
•   Testifying policy
•   Mental Health policy
•   Handling of Juveniles policy
•   Chain of Custody – Evidence Property policy
•   Community Relations policy
•   Hit and Run Investigations policy
•   Motor Vehicle Citations policy
•   Protective Custody policy
•   Telephone and Radio Use, including personal cell Massachusetts Police Accreditation Commission
                                                     Certification
    phone, policy
•   CEO Notification policy                          •   Searching and Seizing Electronic Devices policy
•   Communications Standards of Conduct policy       •   Internal Affairs policy
•   Command Protocol and Order of Precedence         •   Victim Witness Rights policy
    policy                                           •   Training policy
•   Dispatch Functions policy                        •   Central Records policy
•   Field Reporting policy                           •   Oath of Officer policy
•   Legal Process policy                             •   Domestic Violence Involving LEO policy
•   Media and Public Information policy              •   Code of Conduct policy
•   Bias-Free Policing policy                        •   Roll Call policy
•   Alternatives to Arrest policy                    •   Selection Process policy
•   Field Training and Evaluation Program policy     •   Dispatch Center Access and Use policy
•   In-Car Video Recording policy                    •   School Resource Officer policy
•   Body Camera Recording policy                     •   Professional Conduct policy
•   Automated Plate Reader policy                    •   Evidence policy
•   Duty to Intervene policy                         •   Special Operations policy

Background · PDF text layer

•   Informants’ policy                                 •   Compliance with CALEA Standards on Specified
•   Domestic Disputes policy                               Policies and Procedures
•   Sexual Assaults policy                             •   Officer Personal Use Vehicle policy
•   Dead Bodies policy                                 •   Overtime policy and the adherence of the
                                                           overtime policy
•   Cold Cases policy
                                                       •   Use of Personal Cell Phones policy and
•   Criminal Intelligence policy
                                                           adherence to the policy

The requested assessment involved a comprehensive evaluation of the Canton PD in a range of
operational and administrative areas. The Audit Team reviewed the Canton PD’s policies, procedures,
rules, and regulations and evaluated Canton PD practices for compliance thereto. Below is a summary of
the key components of the assessment:

    1. Review of Documentation: The Audit Team reviewed various documents including policies,
       procedures, department directives, and training requirements provided by Chief Rafferty. The
       assessment aimed to ensure these documents align with Massachusetts State Laws, POST
       requirements, best practices, CALEA standards, and Canton PD’s MPAC certifications.

    2. Interviews Conducted: Approximately 55 interviews were conducted. The Audit Team received
       100% participation from the Canton PD–from leadership to officers and detectives. Interviews
       were conducted with the Town of Canton department heads, including the Town Administrator, the
       Superintendent of Canton Public Schools, and Select Board members. Multiple Town of Canton
       citizens established contact with the Audit Team and were also interviewed. These interviews
       sought insight on department culture, morale, leadership effectiveness, the influence of the Select
       Board on the department, and community relationships and concerns.

    3. Assessment Criteria: The assessment weighed department policies and their implementation
       against several criteria:

            a. Adherence: How well the Canton PD personnel follow existing policies and regulations.
            b. Alignment: The synchronization of policies with strategic and capital planning initiatives.
            c. Efficiency and Effectiveness: Evaluation of resource utilization and goal achievement.
            d. Financial Constraints: How effectively the department works within the town’s budgetary
               limitations.
            e. Compliance: Adherence to standards set by the GAO’s Government Auditing Standards,
               POST Commission, Massachusetts Police Accreditation Commission, Massachusetts
               General Laws, Code of Massachusetts Regulations, CALEA, and Town of Canton By-Laws.

    4. Findings and Recommendations: Specific findings and recommendations were not applicable in
       all areas of the audit; therefore, those sections will not be dissected in detail. Many of our findings
       assessed gaps in written policy and policy implementation. Where such gaps were noted, the Audit
       Team included recommendations for enhancing policy adherence and operational efficiency.

Background · PDF text layer

Canton PD’s internal controls and compliance oversight have improved since the initiation of the Audit
and are functioning, and Canton PD has effective leadership in place to supervise officers going forward.
Chief Rafferty has been advised of recommendations and implemented necessary changes to improve
crime scene and professional standards procedures.

Methodology of Audit
When evaluating the department's policies based on the given criteria, it is imperative to note certain
limitations to the assessment when it comes to budgetary evaluations. No law enforcement or public
safety policy should be limited for the purpose of operating within the financial restrictions of the town.
These policies are formulated to provide directives pertaining to public safety, officer safety, and
adherence to best practices within the law enforcement industry with the goal of ensuring protection from
and prevention of criminal actions. The notion that any public safety, officer safety, or effective law
enforcement practice should be limited to adhering to financial constraints is a decision that cannot be
endorsed by this Audit Team. This principle extends to Capital Planning Initiatives as well. Any initiatives
undertaken by the town must be in line with police policies and account for resulting budgetary
requirements. These policies and standards that the Canton PD must abide by are mandated by POST,
MPAC, and Massachusetts State Law, and therefore should not be limited by financial initiatives.
Synchronization of services with alignment to budgets is a historic challenge to police professionals.

The Canton PD holds a current certification from the Massachusetts Police Accreditation Commission
(MPAC). Recognizing the compliance of the Canton PD with MPAC, the Audit Team has incorporated the
CALEA requirements (considered the "Gold Standard" for law enforcement agencies), the POST
requirements, and Massachusetts law into our assessment of policy and procedure.

Each segment of the evaluation focused on specific points delineated by the Canton Audit Committee.
Whenever feasible, the Audit Team scrutinized documents, reports, and policies provided digitally to gain
a comprehensive understanding of procedures. In instances where digital review was not available, the
Audit Team examined physical copies of these documents on-site before proceeding with the evaluation
of the respective topics. The Audit Team meticulously evaluated the actions of the Canton PD against
established policies and procedures. Evaluation considered external factors beyond the Canton PD's
control and internal factors, such as training, resources, and staffing levels. Our observations have been
documented, and recommendations have been proposed where applicable to rectify identified gaps in
policy application and compliance. When the Scope of Work yielded repetitive findings, these were
amalgamated in sections to present a concise overview.

Overall, our audit sought to ensure the Canton PD complied with necessary regulations and operates
efficiently and effectively going forward – aligning its practices with broader strategic and financial goals
while maintaining strong community relationships. Given the size and nature of the request, the Audit
Team structured this report in alignment with the scope of work for ease of review.

Background · PDF text layer

SECTION 1:
 Policies, Procedures and Regulations

                                                     Image source: Boston Herald

Section 1: Policies, Procedures and Regulations · PDF text layer

SECTION 1: POLICIES, PROCEDURES AND REGULATIONS

A. Interrogating Suspects / Interviewing Witnesses or Victims
The policy is outlined under Policy No 2.08, in alignment with CALEA Standards 42.2.1 B, and provides
comprehensive guidance on interrogating suspects and interviewing witnesses or victims within the
Canton PD. Key elements of the policy are as follows.

Key Elements of the Policy
Compliance with Miranda Requirements:
•   Officers must issue Miranda warnings when appropriate, specifically from a Canton PD-issued
    Miranda warning card or documentation.
•   Awareness of language barriers, fatigue, medications, or mental health issues affecting the suspect's
    ability to understand the rights waiver is crucial.

Voluntary Statements:

Voluntary statements are acceptable under two (2) conditions:

•   After a clear waiver of Miranda rights.
•   As unprovoked spontaneous utterances, made freely without officer prompting.

Conducting Interviews:
•   Officers are encouraged to follow a structured approach, although the content and methods may vary
    based on the investigation's nature and the interview subject.
•   Proper interview techniques must be employed to enhance productivity, protect public rights,
    maintain professionalism, and increase interview efficiency.
Standardization and Consistency:

The review identified inconsistencies in the format, structure, and content of interview reports. These
inconsistencies indicate a need for a more uniform approach to both interviews and documentation.

          RECOMMENDATIONS
          The Canton PD’s policies regarding interrogations and interviews align with POST and CALEA
          standards, emphasizing the protection of constitutional rights and promoting effective
          investigative techniques. However, establishing a consistent approach to conducting interviews
          and documentation ensures the effectiveness and reliability of statements obtained by the
          department. These efforts will also support legal admissibility and enhance the overall quality of
          investigative work.

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Specific recommendations for the Canton PD include:
          Uniform Approach to Documentation
          Implement standardized templates or guidelines for reporting interviews, ensuring consistency
          in formatting, structure, and essential content. A template should be adaptable to appropriately
          document different types of interviews, but nonetheless provide a consistent structure to be
          used by the department.
          Ongoing Evaluation and Improvement
          Canton PD policies include self-evaluation mechanisms to assess interview effectiveness and
          remediate shortcomings. Commanding officers must consistently review the reports of
          subordinates ensuring effectiveness and thoroughness.
          The Officer in Charge (OIC) of the Investigations Unit should review any interviews deemed
          inadmissible in court or in cases where prosecution is declined. Such a review will identified
          shortcomings in the reports so improvements can be implemented appropriately.
          Separation of Suspects During Questioning
          When conducting interviews of multiple individuals, interviewees should be separated from
          each other prior to and during questioning. Detectives should record all interviews electronically
          when possible. Separating witnesses/suspects is a key factor in corroborating statements from
          multiple individuals.
          Training and Policy Amendments
          Where deficiencies are identified, amendments to existing policies should be made and
          additional training should be provided to ensure the changes are noted and understood.

B. Evidence, Search and Seizure, Electronic Devices and Chain of Custody
The audit of the Canton PD’s policies concerning Search and Seizure, Chain of Custody, Seizing Electronic
Devices and Evidence Handling reveals a comprehensive framework that meets established standards.
Below is a summary and review of the policies and related procedures.

Key Policy Areas Reviewed
Search and Seizure:
•   Covered under Policy No. 1.07.
•   Aligns with CALEA and POST Standards, ensuring that the rights of individuals are respected while
    allowing for effective law enforcement operations, specifically the execution of a search warrant and
    the seizing of physical property.
Chain of Custody:
•   Defined as the systematic documentation process that tracks evidence/property from discovery to
    custody with the department.

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•   Critical details recorded include location, date/time, and personnel involved in each transfer, ensuring
    continuity and accountability.
•   Emphasizes the use of a computerized records management system (IMC Enterprise Software
    Platform) for accurate tracking and management.
Evidence Handling:
•   Detailed in Policy No. 6.02.
•   Differentiates between temporary and permanent storage solutions to secure evidence:
     • Temporary Evidence Room: Includes lockers, shelves, and secure containers for immediate
       deposit.
     • Permanent Evidence Room: Highly secured, long-term storage with rigorous access control,
       monitored by 24-hour video surveillance.
•   Prohibits unauthorized storage of evidence outside designated areas, preventing mishandling or loss.
     • Managed by a designated Evidence/Property Officer who is accountable for the integrity of all
       evidence.
Seizing Electronic Devices:
•   Follows policy as outlined in Policy No. 6.02
•   Electronic evidence (cell phones / computers / tablets) should only be seized if:
     • Consent was provided to download and search the device.
     • It is anticipated that a search warrant will be obtained to search the device.
•   Canton PD policy calls for all electronic devices seized to be shut off/switched to airplane mode and
    sealed in a Faraday Bag, preventing the reception/transmission of EMF signals altering the contents of
    the device at the time of seizure.
Roles:
•   Evidence/Property Officer: Responsible for maintaining control over all evidence, ensuring proper
    storage, and processing procedures.
•   Impounding Officer: The initial officer collecting the evidence starts the chain of custody.
•   Confiscated Property: Items seized not directly related to evidence of a crime, e.g., firearms not
    involved in criminal cases, which are to be secured in a department armory.
•   Affiant: Sworn Officer or Detective that provided information under oath to the court magistrate or
    judge to obtain a warrant to search or seize evidence.

Audit Team’s Observations
Below is a summary of the Audit Team’s observations of physical facilities:

•   Evidence storage areas are under strict video monitoring with access controlled by electronic cards.
•   Evidence documentation is maintained in an electronic log controlled at the Town administration level.
•   Access to the main evidence vault is restricted with detailed entry logs maintained electronically.

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•   Surveillance footage of evidence access areas can be reviewed, but not altered, by either the primary
    or alternate evidence custodian.
•   All sworn officers have electronic card access to the temporary evidence holding and processing
    room, which is under 24-hour video surveillance.
•   All evidence brought into the station after hours for submission into evidence is logged in and then
    deposited into a secure temporary evidence container, pending final processing by the evidence
    custodian. Once evidence is secured in the temporary evidence container, the only person(s) that can
    retrieve the evidence are the Canton PD evidence custodian(s).

Inspection, Inventory, and Audit of Evidence Room in consideration of CALEA Standards
The Audit Team inspected the temporary storage, the evidence room, and evidence currently being held by
the Canton PD. In addition, we conducted spot checks of random evidentiary items upon arrival in
November of 2024. This review determined that the Canton PD is in compliance with policy and
procedures as recommended by CALEA Standards. [Note: Chief Rafferty provided the Audit Team with the
2022, 2023 and 2024 yearly audits of the evidence room, which covered the inspection of all seized money,
narcotics, firearms, sexual assault kits, and property evidence].

The 2022, 2023 and 2024 audits revealed that firearms were being stored along with other evidence in the
main system. While not a violation, a recommendation was in alignment with best practices to separate
firearms from traditional evidence. The Audit Team confirmed that the recommendations made from the
previous October 2024 audit had been adhered to and implemented. All firearms are now stored
separately and secured in a separate area in the evidence room.

The evidence room was recently re-organized into five (5) different areas: Narcotics Evidence, Firearms,
Sexual Assault Kits, Property and Alcohol. In February of 2025, the Audit Team conducted a second audit.
This audit was unannounced and included a review of a randomly selected part of the evidence room and
its contents. The Audit Team requested the production of randomly selected pieces of evidence spanning
multiple decades and types of cases. The Canton PD evidence custodian immediately located and
produced all evidentiary items requested, which were properly secured and maintained.

It is important to understand that there is not a policy that can tell an officer what will be classified as
evidence. The collection of evidence depends on the type of investigation and the role of the investigator.
Supervision, experience and discretion are key to correctly identifying evidence in an investigation. The
goal is to be thorough and fair while minimizing the impact to the lives and rights of the public. An officer
cannot simply take everything and sort it out later. The seizure of property has a direct impact on civilians
and what officers choose to seize must be considered to have immediate evidentiary value.

The Canton PD policy delineates the difference between the handling of drug evidence and non-drug
evidence and includes separate processing procedures for gun evidence, adhering to CALEA Standard
84.1.2B.

The Canton PD procedures and policies as they relate to evidence handling have been found to be
consistent with CALEA Standards 84 “Property and Evidence Control,” specifically 84.1.1 through 84.1.7;
83.2.1 (1D) (1F).

Section 1: Policies, Procedures and Regulations · PDF text layer

The Canton PD's policies on search, seizure, and evidence handling emphasize accountability, security,
and adherence to legal standards. The integration of technology, such as the IMC Enterprise Software
Platform and comprehensive surveillance systems, demonstrates an effort to ensure these practices. The
department does not allow unauthorized storage and tracks all evidence interactions. Overall, the Canton
PD demonstrates a commitment to best practices in law enforcement evidence management, ensuring
both legal compliance and the protection of evidence integrity throughout the process.

          RECOMMENDATIONS
          All Canton PD sergeant vehicles should be equipped with digital cameras for photographing and
          memorializing crime scenes, specifically the acquisition of evidence. Further, this equipment
          standard should be required by policy. All evidence should be photographed at the time of
          seizure by detectives and captured on body-worn cameras by patrol officers when possible.
          These photographs should be entered into evidence as a separate exhibit and their acquisition
          documented in the reporting of events.
          The Canton PD was found to be in compliance with evidence procedures during annual
          announced audits. The Audit Team recommends that the leadership of the Canton PD conduct
          “unannounced audits” with both the Evidence Custodian and the Alternate Evidence Custodian
          at different times. Doing so will ensure day-to-day operations remain in compliance with policy
          and requirements. Additionally, audits of this nature confirm that both the evidence custodian,
          and his alternate, can locate and retrieve exhibits in a correct manner according to policy.
          As recommended in Section 2: Crime Scene Protocols Overview, patrolmen and responding
          detectives should attend a “Crime Scene Preservation Class.” The Canton PD may only process
          minor crime scenes, but the ability to memorialize, preserve and maintain the crime scene until
          a processing unit arrives is crucial. “Minor” crime scenes may eventually become “major” crime
          scenes in the event of the later discovery of relevant evidence.
          All Canton PD marked units should have crime scene preservation kits (Crime Scene Tape,
          scribe equipment, etc.) and evidence collection kits in their vehicles. All sergeant and detective
          vehicles should have full crime scene kits including bags and sealing equipment.

C. Eyewitness Identification
The audit highlighted several key practices within the Canton PD's Eyewitness Identification Policy, such
as:

•   Blind Administration: Ensuring that the officer conducting the lineup does not know the identity of the
    suspect to prevent any unintentional cues to the witness.
•   Sequential Presentation: Presenting lineup members one at a time rather than all at once, which has
    been shown to reduce the risk of mistaken identification.
•   Use of Fillers: Carefully selecting non-suspect participants in lineups (fillers) who match the
    description of the perpetrator to ensure fairness.

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•   Comprehensive Instructions: Providing witnesses with clear and neutral instructions that emphasize
    the importance of accurate identification. For example, nothing that the suspect may or may not be
    present in the line-up.
•   Documenting Identifications: Meticulously recording the witness's confidence statement and the
    conditions of the identification process to maintain a clear and traceable record.

The review of actual cases and investigations confirmed that the Canton PD's policies were clearly
documented and effectively implemented. For example, in cases where a suspect was identified by an
eyewitness, the documentation showed consistent adherence to the policy, preserving both the validity of
the identification and the protections against wrongful conviction.

Overall, the Audit Team found Canton PD was in compliance with evidence-based practices and prioritized
safeguarding the rights of individuals involved in criminal investigations. A commitment to procedural rigor
and ethical standards not only helps in convicting the guilty, but more importantly in protecting the
innocent, thereby upholding the fundamental principles of justice.

          RECOMMENDATIONS
          None.

D. Testifying
Based on the review of the Canton PD policy 1.11 “Testifying in Court,” which was revised on January 1,
2024, the Audit Team noted the Canton PD practices adhere to the professional standards and
expectations when testifying in court.

Presenting evidence in court is a crucial step in a criminal case, marking the culmination of police efforts.
The effectiveness of this presentation hinges largely on the competency of the officer testifying. No matter
how thorough the investigative work leading up to the court appearance, a weak, incomplete, or
unsatisfactory testimony can undermine it all. The court evaluates not just the quality and quantity of the
evidence, but also how it is delivered. The officer's demeanor, appearance, attitude, and ability to
articulate clearly can heavily impact the credibility of their testimony, shaping the trial’s outcome
significantly. Despite personal investment in a case, officers must strive to present facts objectively during
testimony. It is paramount to avoid both downplaying and exaggerating circumstances to maintain
impartiality.

Navigating the legal complexities of criminal investigations and prosecutions demands collaboration
between police and prosecutors. Each party contributes unique skills to the prosecution team, with police
relying on prosecutors for legal expertise and prosecutors relying on police for investigative expertise.
Trials serve as a learning opportunity for police officers, allowing them to refine their skills and their
approach to future cases.

Section 1: Policies, Procedures and Regulations · PDF text layer

RECOMMENDATIONS
          The Audit Team has certified that the Canton PD policy regarding court testimony is clear and
          encompasses the requirements for successfully testifying at trial. In alignment with best
          standard practices, paragraph 5, Canton PD policy 1.11 which states:

               “Every court appearance should be a learning experience for a police officer. After every
               trial, especially if the case is lost, the officer(s) should go over their testimony and the
               evidence with the prosecutor and any other officers that were involved to learn further
               about the strengths and weaknesses in the case so as to improve the prosecution of the
               next case. Any objections or points of law that were raised during the trial that the officer
               does not understand should be clarified.”

          With that directive as guidance, the Audit Team recommends:
          Training on Testimony Clarity
          Our team recommends training to improve officer skills in understanding questions during
          testimony. Accurately and professionally answering questions establishes credibility and
          clarity for the officer and the information presented by the prosecution team. Additionally,
          professionalism in testimony limits the cross-examination parameters of the defense.
          Handling Disagreements Professionally
          Officers should understand it is ok to disagree with counsel and it can be accomplished
          without being confrontational. This includes understanding how to maintain composure and
          professionalism, even if the questioning becomes challenging, personal and contentious.
          Identifying Assumed Truths
          Training should include techniques for identifying and addressing assumed truths within
          questions. This skill helps officers provide accurate and precise answers, ensuring that their
          testimony remains consistent and credible.
          Exposure to High-Profile Cases
          Given the challenges that arise from limited exposure to high-profile cases, Canton PD should
          consider mock trials or role-playing exercises, in conjunction with the District Attorney’s (DA)
          Office, as part of their training to simulate the pressure and the delivery of accurate testimony.
          Continuous Skill Development
          Regular workshops and refresher courses could be implemented to ensure officers remain up
          to date with best practices and case law in courtroom testimony. Training sessions can be
          conducted in conjunction with the prosecutor's office and administered with limited expense.
          By focusing on these areas, the Canton PD can enhance the effectiveness and reliability of its
          officers' testimonies, particularly in high-stakes legal environments.

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E. Mental Health
The audit of the Canton PD mental health policy highlighted the successful implementation of a system
identified as the Canton Co-Response Jail Diversion Program. This program effectively addresses
individuals experiencing mental health and substance abuse issues and provides care, direction and
guidance to the family without law enforcement intervention. Key proactive measures, which were led by
Canton PD Chief Rafferty and Deputy Chief Patricia Sherill, have produced significant improvements in the
handling of mental health cases.

Proactive Steps and Achievements
Identification of Needs:
•   From 2020 to 2022, Canton PD responded to over 400 mental health-related calls and over 200
    substance abuse-related calls, indicating a need for specialized support.
•   Chief Rafferty and her team recognized the trend and subsequent need for a dedicated Mental Health
    Professional (MHP).
Funding and Implementation:
•   In December 2022, Canton PD successfully secured a grant from the Massachusetts Department of
    Mental Health for a Mental Health Professional (MHP) position.
•   The MHP works closely with officers, responding to calls and offering on-site mental health services to
    the Canton community.
Response and Effectiveness:
•   On average, the Canton PD and the MHP respond to around 40 calls per month, with the highest
    volume of calls occurring during evening shifts.
•   The MHP aids in de-escalating situations, provides immediate support, and reduces the necessity for
    legal actions.
•   Regular follow-ups and referrals to community-based services lower the likelihood of repeat police
    interactions.
Training and Collaboration:
•   The MHP provides training and shares valuable insights that preempt potential crises through
    collaboration with hospitals, churches, and recovery groups.
•   Knowledge shared with Canton PD officers enhances their response and documentation skills, aiding
    in mental health intervention.
Internal Benefits:
•   Canton PD officers recognize the MHP’s value in efficiently handling mental health calls. Interviews
    revealed unanimous sentiment that the Canton PD MHP is one of the most valuable assets within the
    department.
•   Though the MHP does not provide counseling, the MHP will guide officers to an appropriate personal
    mental health professional and appropriate resources to meet their personal needs.

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Sustainability Concerns:
•   Although Canton PD secured initial funding to hire a full-time MHP, funding delays from the DOJ
    highlight potential sustainability issues.

The Canton PD’s initiative to incorporate a full time MHP resulted in a valuable community asset in
managing the growing number of mental health crises. The presence of a MHP effectively decreases the
reliance on law enforcement actions, presents an on-site resource for the families of the affected and
fosters a collaborative environment between law enforcement and community resources. The ongoing
challenge remains securing consistent funding for the full-time MHP position to ensure continued support
and improvements within the department and the community.

          RECOMMENDATIONS
          Budget allocations should be considered by the town of Canton leadership. Canton PD should
          work with town officials at various levels to secure funding for the full-time MHP position should
          the grant no longer be available. The loss of this position could create a significant negative
          impact on the Town of Canton and surrounding communities.

F. Handling of Juveniles
The Audit Team found the departmental attitude as it relates to the handling of juveniles to be consistent
with the mental health policy of the Canton PD. The Canton PD command staff realizes that officers of the
Canton PD must have a basic understanding of the social and psychological factors that contribute to
juvenile behavior and further be familiar with societal conditions that can contribute to juvenile
delinquency.

Canton PD Policy No.1.12 “Handling of Juveniles” aligns with all requirements as set forth in CALEA
Standards 41.4.4 / 44.4.5 / 42.2.0 / 44.1.1 / 44.1.2 / 44.2.1 / 44.2.2 / 44.2.3 / 44.2.4 / 44.2.5 / 82.1.1 /
82.1.2 and 82.3.5. Further, these Canton PD procedures and guidelines for the handling, arresting, and
detention of juveniles follow the best standards and practices in the profession. Below is a summary
highlighting the key points in the Canton PD policy emphasized by Canton PD leadership.

Key Policy Areas Reviewed
Juvenile Definition and Arrest Overview
•   Juvenile Age: Defined as anyone under 18 years.
•   Under 12 Years: Cannot be charged with a crime.
•   Ages 12 to 18: Preferred method to bring juveniles to court is via summons unless there is a good
    standing belief they will not appear.
•   Arrest Warrants: Issued if there is reason to believe the juvenile will not respond to a summons, has
    not appeared as summoned, or violated probation terms.

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Handling of Juveniles
•   Designated Officer for Juvenile Matters: Typically, this is the School Resource Officer (SRO) who is
    trained in juvenile justice and stays updated with laws and handling directives.
•   Diversionary Programs: The SRO is knowledgeable about- and can direct intervention programs for
    juvenile offenders.
•   Responsibility Sharing: All department personnel must support juvenile operations.
Enforcement Alternatives
•   Considerations: Nature of the offense, juvenile's age, prior police contacts, community rehabilitation
    program availability, and complainant/victim recommendations.
•   Alternatives:
     • Release with no action or informal counseling.
     • Referral to community social services.
     • Limited custody with station house warning.
     • Citation, summons, or complaint.
     • Referral to juvenile court.
Juvenile Arrest and Detention Guidelines
•   Supervision: Notify patrol supervisor.
•   Rights: Advise juveniles of their constitutional rights using a Miranda Form specifically for juveniles.
•   Transport: To be done without unnecessary delay.
•   Notification: Inform parents/guardians promptly.
•   Documentation: Complete a detailed report of the juvenile process.
•   Right to Counsel: Ensured at every stage.
•   Constitutional Rights: Not lost due to age; greater protection during questioning and rights waiver.
Special Detention and Interrogation Considerations
•   Cell Holding Use: No secure custody for juveniles under 14 years of age. Secure custody can involve
    detention cells, locked rooms, or handcuffing juvenile defendants to stationary objects.
•   Supervision: Constant supervision required for juveniles in detention.
•   Separation from Adults: Juveniles must be separated from adult detainees by sight and sound.
•   Interrogation: Interrogations are conducted with limited officer presence, preferably with Family
    Services Unit involvement, and frequently scheduled breaks.
Supervisor's Role During Juvenile Arrests
•   Parental Notification: Ensure at least one (1) parent or legal guardian is informed.
•   Cause Inquiry: Confirm proper cause for arrest and legal treatment compliance.
•   Release Decision: Evaluate the release without a warrant.
•   Bail Magistrate Notification: In case of detention.
•   Agency Notification: Inform relevant agencies if the juvenile is in their custody.

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RECOMMENDATIONS
          The guidelines reflect Canton PD's emphasis on minimizing coercive actions and ensuring the
          protection and rights of juveniles during their interactions with law enforcement. Careful
          attention is paid to the specifics of juvenile detention, rights advisement, and the appropriate
          handling of each case to align with legal and departmental standards. Based upon the serious
          nature of handling juvenile offenders properly, we recommend that the Canton PD institute an
          annual training be attended by all sworn personnel concerning the handling of juvenile
          offenders. It is further recommended that officers certify that they have read and understood
          the corresponding policies related to the same.

G. Community Relations
The Audit Team reviewed Canton PD’s Community Relations policy as described in the rules and
regulations Section 1.17. The policy is in alignment with CALEA Standards 45.2.1 and emphasizes the
importance of an ongoing Community Relations Program to ensure effective communication between the
Canton PD and Canton citizens regarding department activities. The goal of a Community Relations
Program is to involve the public in problem solving and planning in cooperation with the department.
Specific points of consideration include the public perspective on new and old Canton PD programs as
well as alternatives to ineffective or unproductive policing practices.

The policy allows Canton PD to retain a position for a Community Relations Officer to serve as a liaison
between the Department and the community with the goal of identifying community concerns. During
Supervisor Staff Meetings, the Chief of Police will request information on current community concerns,
potential problems they have with law enforcement activities, and recommended actions addressing
previously identified concerns. Canton PD officers are required to report any public concerns of urgent
nature to their immediate supervisor upon gaining knowledge of the situation. Such situations include
potential racial unrest, potential labor/management conflicts that could result in violence, etc. The
information shall be passed to the Chief of Police who will develop a plan for an appropriate response. The
Chief of Police will seek feedback from the Community Relations Officer annually regarding overall
department performance, overall competence of the department, officers’ attitude and behavior toward
citizens, concern over safety and security within the community, and any recommendations or
suggestions.

          RECOMMENDATIONS
          Considering the current political climate and the current state of the public’s trust in the
          Canton PD, any adaptations to this policy should be conducted as a joint effort by the Canton
          PD administration and Town Selectman.

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H. Hit & Run Investigations
The Audit Team conducted a review of Canton PD’s Hit and Run Investigations policy in section 1.19 of the
rules and regulations. The policy states the objective of a hit and run investigation is to determine
responsibility for the collision and to identify both the offender and the vehicle involved. The policy directs
duties for both on-scene response and follow-up investigation following a hit and run incident.

Key Policy Areas Reviewed
On-Scene Duties:
•   The policy states that officers responding to a hit and run should first make provisions for the medical
    treatment of the victim if necessary. The officers must follow-up on the condition of the victim after
    he/she is transported to the hospital to ensure appropriate charges are filed, including motor vehicle
    homicide if it appears the victim may die or has died.
•   Officers should obtain the best possible description of the operator and the vehicle from the victim
    and witnesses. Important observations include vehicle make, model, year, color, extent and location
    of damage, license plate (including partial numbers or letters), unusual markings or equipment,
    direction of travel before/after the collision, number of passengers, if any, and their descriptions.
•   Any descriptive information obtained shall immediately be communicated to the dispatching officer.
•   Officers should search the area around the scene of the crash including the automobile (or pedestrian)
    which was struck for physical evidence.
    [Note: The policy makes a point to note that in the event a pedestrian is struck and injured, the officer
    should ask the hospital, if possible, to secure any such evidence which may have been dislodged from
    the victim’s clothing during transport. Further, officers should request hospital personnel give the
    victim’s clothing and any associated paint chips or glass fragments to police].
•   Photographs and measurements should be taken at the scene when required at the direction of the
    Shift Supervisor or detective on scene. Officers should examine the person and the clothing of the
    victim for evidence, particularly for traces of the vehicle. If necessary, an officer may take and preserve
    articles of clothing or other samples of evidence such as hair, blood, etc.
•   Officers should be observant for potential persons to be interviewed in the area of the scene. Where
    appropriate, officers should conduct a door-to-door canvas of residences and businesses in the
    vicinity of the hit and run scene.
•   A preliminary search for the suspect car and driver should be conducted as soon as possible.
    Notification of subject and vehicle descriptions should be made to all police on patrol, State Police
    and adjacent police departments via the BAPERN radio network. If motor vehicle homicide charges are
    being considered, the Chief, or the Chief’s designee, may decide to contact the media to enlist the
    public to aid in locating the suspect vehicle and driver.
•   If a reasonable effort to apprehend the offender is unsuccessful, officers should communicate such to
    dispatch and return to regular patrol duty unless directed otherwise by the proper authority.

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Follow-up Investigation Protocol:

The policy states that an in-depth or follow-up investigation should be conducted upon the direction of the
Detective Sergeant.

The follow-up investigation, if any, should include the following types of activity: records checks for stolen
vehicles, communication of relative information regarding the vehicle and driver to nearby departments, a
second search of the accident scene covering a wider area, repeated visits to- and surveillance of the
scene at the same time of day during which the accident occurred, and visits to local establishments
where a vehicle may be located for service (car washes, auto shops, etc.).

•   If the vehicle involved in the accident is located, it should be carefully examined. Specifically:
     • Dents and body damage should be measured as to width, depth and pattern. Photographs should
       be taken if possible.
     • Obtain samples of paint chips, broken glass, pieces of clothing, dirt, evidence of blood, hair, flesh,
       etc.
     • Inspect the interior for personal articles which may identify the offender.
     • Observe and note any signs of recent repair or any broken or missing parts.
        [Note: The policy is careful to note that the above steps should be taken in accordance with
        departmental policy and procedure. In the event a search warrant is sought, the vehicle should be
        kept under surveillance until a warrant is obtained. The identity of any person attempting to enter
        the vehicle or destroy evidence should be established.]
•   If the operator of the suspect vehicle is located, he/she should be questioned promptly, following
    Miranda procedures if applicable.

Finally, the policy requires that any hit and run accident reported with personal injury, with a suspect, or
with damage of approximately one thousand dollars ($1,000) or more, must be followed up with a full and
complete report, including details about the accident and the particulars of any follow-up investigation.

Findings
The relationship of this policy as it relates to the events of 34 Fairview Road is relevant only through
hindsight. At the time of the Canton PD response to 34 Fairview Road and the discovery of Boston Police
Officer John O’Keefe, the Canton PD did not know they were responding to the scene of an alleged Hit and
Run. The call for police came in as a complainant reporting an unconscious male discovered in the snow.
Canton PD initially prepared for an unattended death, and subsequent investigation by the MSP.

           RECOMMENDATIONS
          Follow the policies within Canton PD manual as appropriate to Hit and Run scenes.

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I. Motor Vehicle Citations
The Motor Vehicle Citations policy is detailed in Section 1.23 of the Canton PD policy guidelines and
references CALEA Standards 61.1.2 / 61.1.4 / 82.2.5 and 82.3.3. The Canton PD uses the Massachusetts
Motor Vehicle Citation form and the Motor Vehicle Automated Citations and Crash System (MACCS),
otherwise known as “E-Citations,” to record motorist violations. Citations are the method used to formally
notify the violator, the courts, and the Registry of Motor Vehicles that a violation has been committed by
the person named.

Canton PD officers have discretion as to what type of citation to issue a violator within the parameters of
Canton PD policy. The policy provides guidelines for issuing a citation to ensure officer actions are in line
with applicable laws and clearly prohibits an officer from justifying a stop or seizure of an individual
through racial, age, gender, or other type of profiling. Five (5) general categories of enforcement actions
are noted: a written warning, civil citation, criminal complaint, verbal warning, and physical arrest. Section
1.23 provides specific procedures to be followed with respect to each enforcement action.

The Motor Vehicle Citations policy requires officers to provide the violator with a copy of the citation in
some form. Officers are required to provide a copy in person as a primary option, but if the circumstances
are such that he cannot do so, he must provide a copy by mail. Officers are strongly encouraged to retain
copies of any citations issued for their own records for a minimum of one (1) year from the Date of
Issuance. Prior to the end of a shift, officers must place any citations issued into the appropriate secure
citation box. In the event a citation results in a criminal complaint or arrest, the officer must file a
complete report and fill out an Application for Complaint form according to procedures. Both must be
provided to the local Prosecutor through the Prosecutor’s box.

The Chief’s Administrative Assistant is responsible for removing any written citation copies from the
citation box daily, excluding weekends. Standard procedures for processing and notifications are
stipulated within the policy for three (3) categories of citations: written warnings, non-criminal citations,
and criminal traffic complaint and arrest reports.

All un-issued motor vehicle citation books shall be stored in the dispatch room and are accounted for
using “sign-out” logs. If an officer needs to “void” a citation, a written explanation as to why will be
forwarded to the on-duty Lieutenant.

Overall, the policy sets forth clear guidelines and procedures for issuing and documenting citations. There
are defined procedures for tracking and managing issued citations as well – from initial citation to turnover
to a prosecuting party if necessary.

          RECOMMENDATIONS
          None.

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J. Protective Custody
The Audit Team conducted a review of Protective Custody of Incapacitated Person(s) policy in Section
1.24 of the rules and regulations. The Canton PD policy aligns with CALEA Standards 44.2.2 / 72.5.1 and
72.7.1. The goal of the policy is to ensure officers can appropriately recognize an incapacitated person and
ensure they are taken into protective custody as needed. Canton PD policy acknowledges that alcoholism
is recognized as a disease and public intoxication is not a crime. Massachusetts law M.G.L.C. 111B
guarantees detoxification facilities for persons suffering from alcoholism and protective custody for
persons incapacitated from consumption of alcohol or controlled substances.

The policy makes clear that a person taken into protective custody is not considered to have been arrested
or charged with a crime. However, the stipulations of 111B does not negate criminal responsibility for
offenses related to driving under the influence, etc. To ensure clarity in the guidelines, formal definitions of
“alcoholism,” “facility,” and “incapacitated” are detailed within the policy.

In situations where action is necessary, but there is no criminal activity, Canton PD officers are permitted
to assist an incapacitated person, with or without their consent, to his/her residence, a treatment facility,
or the police station. The officer is to place the person in protective custody to transport the person to the
appropriate facility immediately.

In regard to handling of incapacitated persons, the policy provides guidelines for search and transport, the
safeguarding of their wellbeing at the station, circumstances surrounding release, and reports
documenting relevant information. The guidelines note Massachusetts Law requirements throughout, and
tailor the policy directives to ensure adherence to the relevant laws. The policy instructs officers on when
to seek medical assistance based on the condition of the incapacitated person.

Officers may request a person to submit to standard field sobriety tests to determine whether the person
is intoxicated but cannot force them to submit to tests. The policy notes any incapacitated person assisted
to the police station shall have the right to submit to a breathalyzer test and be informed of said right in
writing. Detailed within the policy is a template for the notice of rights required by law.

Overall, the policy clearly defines protocol for dealing with incapacitated persons in a manner that
prioritizes citizen safety.

          RECOMMENDATIONS
          None.

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K. Telephone and Radio Use Including Personal Cell Phone
The Audit Team conducted a comprehensive review of the regulations and policies concerning telephone,
radio, and personal cell phone usage within the department.

According to Section 2.12 of the rules and regulations it is mandated that all employees, specifically
officers, must possess a cellphone through which the department can reach them. Any changes to their
contact numbers must be promptly reported. The Audit Team confirmed that the use of personal cell
phones by Canton PD officers at crime scenes is permitted only as a last resort under the current policy.
When personal phones are used in such instances, they are subject to potential seizure as evidence.
Officers should opt to use department-issued tablets, laptops, or digital cameras when at crime scenes
instead of personal devices.

The primary mode of communication for officers receiving radio calls is through the Canton PD radio
system, a computer-based platform containing multiple channels that enable simultaneous
communication between officers on different channels. This system is operational 24/7 and allows
officers to communicate with dispatch, other officers within their patrol, counterparts from Fire Rescue
and neighboring police departments. Handheld radios with attachments are utilized when officers are
away from their patrol cars.

A thorough examination of the system monitoring logs spanning from 2020 to 2024 revealed no significant
issues or outages concerning the radio system. The Town of Canton has enlisted the expertise of a
telecommunications systems specialist, referred to as the resident IT specialist, responsible for
troubleshooting, maintaining, and overseeing the radio equipment, mobile data components, and
communication radio rooms. The specialist adheres to a preventive maintenance approach, conducting
routine inspections, repairs as necessary, and ensures the regular upkeep of portable radios. It remains
unclear whether the repairs are handled in-house.

The Audit Team conducted an inventory of all portable radios and found that all radios were properly
accounted for in inventory.

During the interviews with sworn officers, the Audit Team discovered that the Town of Canton has several
areas within the city limits where the portable radios do not have any reception or transmission
capabilities. These areas specifically, along Washington and Neponset streets, are in the center of town.
Lack of reliable communications in these areas creates a serious safety concern.

          RECOMMENDATIONS
          The Audit Team recommends that the use of personally owned cell phones to conduct official
          police business be prohibited immediately. The Audit Team further recommends the issuance
          of department owned cell phones to all sworn officers. If it is not financially feasible to issue all
          sworn officers a cellular phone, phones should be issued to officers of the rank of sergeant or
          higher. Phones for patrol officer use could be issued to the department and signed out at the
          beginning of each shift. Another option is to purchase individual phones to be assigned to each

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patrol car. Under no circumstances should a sworn officer use his or her personal phone for
          police business.
          The areas that do not provide reception or transmission capabilities for the portable radios
          must be addressed. This is a serious safety concern for the officers and could place the town in
          a legally liable situation should the officers fail to have radio communications. A failure in
          communications could result in injury to the officers or the inability to radio for medical
          services for a member of the community. Multiple officers notified the Audit Team that they
          were concerned about the portable radios not working properly in certain areas of the town.
          The Audit Team spoke with the Information Technology Specialist who is aware of the issues.

L. CEO Notification
The CEO Notification Policy for the Canton PD (Policy No.1.31) outlines a structured process for reporting
certain incidents, ensuring that relevant parties within the department are informed promptly about
critical situations. Below is a summary of the key points.

Key Policy Areas Reviewed
Purpose

The policy aims to facilitate a coordinated response to issues and ensure that information about
significant events is shared with command and appropriate administrative level supervisors, especially
outside normal business hours.

Notification Process:
•   General Protocol: Department members must report incidents through their chain of command. The
    Deputy Chief has the authority to report directly to the Chief of Police.
•   Immediate Notification: The Chief must be notified immediately for serious incidents, including:
     • Severe personal injury, death, or               • Missing juvenile cases
       potential death                                 • Serious injury or arrest of a Canton PD employee
     • Major events like civil disorders or power      • Incidents at local schools
       outages                                         • In-house custody attempted suicides
     • Mass casualty incidents                         • Home invasions
     • Hostage situations                              • Crimes involving firearms

•   Later Notification: For less urgent incidents, notification to the Chief can be delayed:
     • Arrest of other municipal employees             • Active building fires
     • Sexual assaults                                 • Civil rights violations
     • Psychiatric or medical incidents                • Suicide attempts
       involving violence                              • Events likely to attract press inquiries

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Responsibilities:

The highest-ranking officer on duty is responsible for making the necessary notifications, ensuring the last
on-duty Lieutenant and the Deputy Chief are informed as well. In the Chief’s absence, the Deputy Chief
acts as the Acting Chief.

Written Reports:

All incidents requiring notification also require a written report to be forwarded to the Chief of Police as
soon as possible after completion. This policy ensures that critical incidents are handled with appropriate
urgency and communicated effectively within the department.

           RECOMMENDATIONS
          While the Canton PD is following CALEA Standards 11.4.4 and Canton PD officers follow
          departmental policy, given the political climate of the town and considering the size of the
          department, we recommend the Deputy Chiefs and the Chief be immediately notified of all
          significant events listed above including those events that allow for delayed notification.

M. Communications Standards of Conduct
Upon reviewing the Canton PD policy No. 1.32, “Communications and Standards Conduct Policy”, the
Audit Team found the directives to be clear, concise and in alignment with CALEA Standards 41.3.7 /
81.1.2 / 81.2.2 / 81.2.3 / 81.2.4 and 81.2.10. Additionally, it was noted that the majority of officers are
compliant with the policy guidelines. The departmental communication policy states that all employees
must promptly, accurately, and comprehensively transmit official communications to other officers and
promptly notify their Officer-In-Charge of any critical police-related matters. Additionally, they are
required to inform relieving officers of any unresolved or potential issues for the next shift.

The Audit Team found that officers are generally consistent in adhering to communications procedures,
accurately conveying information, promptly notifying supervisors of significant police matters or calls
requiring their attention and utilizing roll calls to disseminate important updates related to police
activities. The protocols to accomplish this are in place, clearly conveyed and understood, though there
have been a few recent failures regarding this policy.

Findings
A notable incident occurred in 2024 when a veteran Canton PD police officer failed to notify supervisors
about a restraining order situation at an early childhood education center in Canton, leading to a child
abduction incident. Despite being informed by school representatives, the officer did not communicate
this critical information to his superiors or patrol officers. Consequently, the child was abducted by the
subject of the restraining order. Canton PD immediately responded to the abduction, issued a statewide
alert, and collaborated with law enforcement in Pawtucket, R.I., to apprehend the perpetrator. Chief

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Rafferty took appropriate action by suspending the officer for three (3) days due to the failure to comply
with departmental policies and procedures on departmental communications.

In conclusion, while most officers at Canton PD adhere to communication protocols, the incident
underscores the consequences of non-compliance with the department's policies and the importance of
timely and accurate communication in law enforcement operations.

Actions Taken
Chief Rafferty, recognizing the failure to adhere to the communications policy, enforced disciplinary action
against the officer in question, resulting in a three (3)-day suspension.

•   The policy violation had the serious consequence of a delayed response to a child abduction incident.
    This highlights the importance of adherence to policy.
•   Chief Rafferty’s immediate internal actions:
     • Corrected the behavior of the employee in question.
     • Demonstrated to the department that failure to adhere to departmental policy will not be tolerated.

Consequences and Resolution
•   Despite the initial failure in communication, the Canton PD responded effectively once the issue was
    known, resulting in a BOLO and successful coordination with other law enforcement authorities to
    apprehend the subject.
•   Despite the failure of an individual officer, Chief Rafferty and the departmental leadership acted
    quickly and decisively performing their functions effectively and returning the child safely while also
    apprehending the subject.

Implications for Future Conduct
The results of the audit and the above-mentioned incident can be used for training and practical
improvements within the department.

Additional emphasis is recommended regarding the vital role of communication in preventing similar
incidents.

          RECOMMENDATIONS
          Review and Reinforce Policies
          Continuous education on the importance of communication practices should be implemented
          to prevent similar lapses in the future. Consider hiring full-time dispatchers to work alongside
          officers to take emergency calls and non-emergency calls, evaluate other service needs, and to
          dispatch officers for calls for service.

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Incident Analysis
          The specific breakdown in communication should be analyzed to understand why the officer
          failed to act according to policy and to improve training and protocols accordingly.
          Strengthen Accountability Measures
          Ensure clear consequences for not following policy to reinforce the seriousness of compliance.
          Monitor Effectiveness of Reforms
          Post-incident evaluations should be conducted to assess the effectiveness of any
          implemented changes after such an event.
          Enhance Support Systems
          Consider additional support or backup systems to prevent single points of failure in
          communications, perhaps through technological means or by ensuring multiple people are
          made aware of critical information as it occurs, limiting the possibility of a communication
          failure.
          It is essential that the policies, such as No 1.32, are not only well written, but are effectively
          communicated, understood, and followed by all members of the police department to maintain
          high standards of community safety and trust.

N. Command Protocol and Order of Precedence
The Audit Team conducted a comprehensive review of the regulations and policies concerning command
protocol and order of precedence, specifically the Command Protocol and Order of Precedence in Section
1.34 of the rules and regulations. The policy aims to establish a clear chain of communication and
authority within the department and regulations and aligns with CALEA Standards 11.2.1 / 11.3.2 / 11.3.1
and 12.1.2.

Key Policy Areas Reviewed
According to Section 1.34, it is mandated that the designated chain of command be used in all internal
communications and the established order of command precedence shall be adhered to by officers. The
policy differentiates reporting requirements during field situations, administrative and routine situations,
and exceptional situations. In field situations, the command protocol is in the order as follows:

 1.   Chief of Police
 2.   Deputy Chief
 3.   Lieutenant (on shift or just coming off shift)
 4.   Shift Sergeant
 5.   Senior Police Officer
 6.   Police Officer
 7.   Probationary Police Officer

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In administrative and routine situations, the command protocol is in the order as follows:

 1.   Chief of Police
 2.   Deputy Chief
 3.   Lieutenant (on shift or just coming off shift)
 4.   Sergeant
 5.   Senior Police Officer
 6.   Police Officer
 7.   Probationary Police Officer

The policy provides for circumstances where the Chief of Police is absent, thereby allowing the Deputy
Chief to act in his/her capacity with authority to carry out day-to-day operations of the department. In
emergency situations where the Chief of Police and Deputy Chief are unavailable, the Lieutenant on shift
will be in charge.

Section 1.34 notes that each employee is accountable to only (1) supervisor at a given time and shall be
delegated authority commensurate with their responsibilities. Employees are responsible for activities
within their delegated authority and Supervisory personnel are accountable for the activities and
performances of personnel under their immediate control.

In exceptional situations, such as civil disturbances, hostage situations and other critical incidents, the
Incident Commander under ICS protocol will be in command. The policy cites the “All Hazards Plan” as
the guideline for exceptional situations. Guidelines exist within the policy to ensure there are no conflicting
leadership circumstances. The policy provides protocols for command in exceptional circumstances,
including instances when multiple supervisors are involved in an operation, or where command may be
relinquished to an officer of lesser rank with specialized training or expertise.

These protocols are clearly defined and followed within the Canton PD. It is impossible to predict or
outline situations which would justify deviation from this policy.

          RECOMMENDATIONS
          None.

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O. Dispatch Functions
The Audit Team reviewed the Dispatch Functions Policy, No 4.22. This review and analysis of the dispatch
functions policy shows it followed and aligned with the requirements as outlined in the CALEA Standards
81.3.1 and 81.3.2. This policy highlights the procedures and protocols in place for handling emergency
and non-emergency calls, accessing the dispatch center, protecting equipment, handling 911 calls,
backup resources, and external monitoring.

In 2024, Canton PD responded to a total of 9,108 calls for service with an average response time of around
five (5) minutes. All incoming calls are automatically logged in an electronic system that captures
important details such as caller ID, location, nature of the issue, units dispatched, outcomes, and
timestamps with corresponding comments for each step. The department operates with two (2) radio
systems: a primary system for dispatching units and logging all radio and call center activities, and a
secondary system primarily used as a backup, or for direct communication with neighboring towns. As a
911 emergency response center serving multiple surrounding towns, there is a protocol in place to divert
overflow emergency calls to the independent 911 call center operated by the Sharon Police Department.

Currently, the Canton PD utilizes a free 911 recording service to archive radio communications, with an
agreement set to expire in two (2) years (2027). The department is preparing to incur costs for storing
communications and videos once the current agreement ends. Currently, recordings are retained for 12
hardlines within the police station, but there are plans to expand this to include recordings from all
hardlines after the new contract is in place.

Key Points of Note
•   The Canton PD uses full-time police officers as dispatchers and has a computer-aided dispatch
    system in place.
•   Officers rotate assignments to dispatch in their regular shift rotation.
•   Access to the dispatch center is restricted to specific personnel to minimize distractions and ensure
    operability.
•   Essential communications equipment is securely stored and accessible only to authorized personnel.
•   The department handles a significant volume of calls for service with an average response time of
    approximately five (5) minutes. The time is largely dependent on the location of the request and the
    officer in that sector, or at the nearest location.
•   There are backup radio systems in place for communication redundancy.
•   Retention of recordings and communication data is a priority for the department, including a plan to
    build out future storage.
•   Backup resources and power supplies are available to ensure continuous operation in case of
    emergencies and power outages.
•   The department chose not to join a regional dispatch center due to concerns about effectiveness,
    maintenance costs, and potential risks to citizen safety with response times being dramatically
    increased. This decision was made based on the findings that the regional center would not be as
    efficient as the current setup.

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In January of 2025, the Audit Team reviewed the results compiled by “The Commonwealth of
Massachusetts Executive Office of Public Safety and Security, State 911 Department,” for the function of
the Canton PD dispatch and 911 capabilities. The report was compiled and authored by Ms. Monna
Wallace, Director of Programs, and recorded the testing results between the dates of July 1, 2024, and
December 17, 2024. The testing was random and conducted without the knowledge of the department.
Multiple tests could occur on one day and on consecutive days. On August 5, 2024, the department was
tested multiple times in both the morning and evening hours and tested again on consecutive days in early
September of 2024. The Canton PD Dispatch was tested on 34 occasions and passed each test.

          RECOMMENDATIONS
          The audit report indicates that no onsite corrections were reported, which suggests that the
          department's communication center is operating according to established policies and
          procedures. Overall, the information reviewed reflected a thorough examination of the
          Dispatch and Radio Call Center operations and highlights areas of strength and areas for
          potential improvement or future planning.
          Data Retention
          It is essential to address data retention: The department currently retains recordings of
          communications from various sources, including hardlines, radios, security cameras, booking
          rooms, cell recordings, and 911 calls. It is important to prepare for the upcoming expiration of
          the free recording service agreement and plan for the retention of these recordings in the future
          to avoid data loss.
          Civilian Dispatchers
          Additionally, as will be mentioned in Section 4: Organizational Structure and Governance, the
          Audit Team recommends the addition of civilian dispatchers to work alongside the officers.
          Currently, a sergeant and patrolmen are assigned to work the dispatch on each shift. The
          sergeant should be rotated onto the patrol shift as a fifth vehicle for the day and evening shifts,
          and as a fourth vehicle on the overnight shift. The civilian dispatcher can handle the majority of
          calls while referencing the institutional knowledge of the sworn officer.
          Based upon the Audit Team review of call volume, two (2) civilian dispatchers should be hired
          and assigned to work radio communications in the evening, allowing for the sworn officer to
          serve as a fourth patrol unit. This would also align the patrol sectors to match the day and
          evening rotations providing the greatest services to the citizens of Canton. [Note A patrol officer
          should still be assigned to dispatch along with a dispatcher to handle walk-in complaints, and
          be available for arrested subjects who are housed overnight at Canton PD.]

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P. Field Reporting
The Audit Team reviewed the Field Reporting System as documented under Canton PD policy No. 1.36.
This policy provides guidelines for creating various types of reports, standards for completing them, and
processes for review and submission. The initial Implementation of this policy was February 5, 2015, and it
was updated in 2017, 2020 and in January 2023. The policy and all updates meet the CALEA Standards
82.2.1 and 82.2.4 as written.

Officers can write reports for virtually any scenario that requires documentation. The decision to
document an incident cannot always be dictated by policy and requires the discretion of both the officer
and the officer's supervisor.

Basic Types of Reports and their Requirements
•   Incident Reports: Needed for certain police responses, some requiring detailed narratives. This
    classification is used as a catch-all and can document everything from a response to a call, to the
    observation of an officer.
•   Arrest Reports: Generated by the personnel responsible for or participating in the arrest of an
    individual and documenting the “who, what, when, where and why” elements of the arrest.
•   Complaint Applications: Filed when criminal charges are pursued. Must follow the assignment of an
    Arrest Report number and completion of an Arrest Report.
•   Motor Vehicle Crash Reports: Required under defined situations.
•   Field Interview Reports: Created and updated as necessary and covers both witnesses and suspects.
•   Citation Entry: Required for issuing any motor vehicle citations.

All relevant details pertaining to any incident with Canton PD involvement must be accurately documented
in the appropriate sections of the report, encompassing information about suspects, victims, witnesses,
offenses, addresses, vehicles, and property, among others. The report narrative and its fields must
address the following: who, what, when, where, how, and why (if known). The narrative should provide a
thorough account of the incident along with the actions taken or planned by the responding personnel. It is
crucial that the report narratives are clear, succinct, and factual, with information presented in a logical
and chronological manner. Errors in spelling, grammar, and sentence structure must be avoided, and
simple language should be used when necessary.

The responding officer is responsible for entering all details into the appropriate report upon completion of
the activity, or when time allows. Reports, regarding incidents, arrests, citations, accidents, or field
interviews, are to be finalized before the end of a shift, unless authorized by a supervisor for completion at
a later time. In such cases, the CAD narrative should contain sufficient information about the incident until
the full report is completed. All reports must be submitted to the shift supervisor for approval.

Supplemental narrative reports are to be submitted by an officer when further explanation or elaboration
on information from the initial field report is required. These reports can be filed by the initial officer, the
Canton PD’s Field-Reporting System supervisor, an assigned investigator, or additional responding
officers. They not only serve to provide more detailed narratives, but also to include confidential

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information that was not part of the initial report, such as investigative leads or unsubstantiated details
that could aid investigations. Supplemental reports should undergo the same review process as outlined
above.

          RECOMMENDATIONS
          In line with the recommendations made in the interrogation and witness interviews section, the
          Audit Team recommends Canton PD must standardize their report writing requirements and
          institute a required format with minimum standards and expectations. While not all reports will
          address the same areas, a consistent format should be implemented for reports reflecting
          consistency, regardless of the report's author and that author's position (Patrolman, Sergeant,
          Detective, etc.). Fields that are not applicable can be marked as such. Uniformity and
          consistency are required in report writing to establish and manage expectations and ensure
          completeness in reporting.
          As an example, all arrest reports should contain a section entitled “Use of Force.” Considering
          the statistics provided in this report, we know that 90% of the Canton PD’s arrests did not
          involve use of force. Statistically speaking, in 90% of the reports the recommended “Use of
          Force” section would read, “Use of Force: None.” Documenting a negative in this situation is
          very important because it hinders a defendant or the defendant's attorney from later claiming
          that an improper use of force was used while affecting the arrest. Consistent and complete
          documentation to include negatives leads to greater credibility when testifying and minimizes
          questions regarding content.

Q. Legal Process
The Audit Team reviewed the Canton PD’s Legal Process policy as well as the Canton PD’s adherence
thereto. The Legal Process policy, detailed in the Canton PD rules and regulations No. 1.38, outlines the
procedures for appropriately handling legal processes and aligns with CALEA Standards 74.1.1 / 74.1.2 /
74.1.3 / 74.2.1 / 74.3.1 / 74.3.2 and 74.4.1.

Key Policy Areas Reviewed
Canton PD Policy No. 1.38 defines criminal processes to include summonses, subpoenas, arrest
warrants, and search warrants issued by a Court of Law within the Commonwealth and civil processes to
include abuse prevention, harassment prevention or other orders issued by Massachusetts District
Courts, Family Courts and Probate Courts. The policy specifies procedures for execution of legal
processes and documentation thereof, including the following:

•   Any arrests made on a warrant must be supported by documentation that some agency has the
    warrant in its possession, and that to the best of their knowledge it is still in effect or that the warrant is
    active in the Warrant management System.

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•   No officer shall make an arrest on a warrant unless he/she confirms the present status of the warrant
    immediately before making the arrest.
•   Legal processes will be documented, and every reasonable attempt shall be made to serve them
    promptly.

The Canton PD has a Record of Legal Process form that is to be completed and associated with every legal
process document received by the department. The form serves as documentation that a legal document
has been received and appropriately addressed.

The policy acknowledges Canton PD officers have no authority to conduct an arrest or search outside of
the Commonwealth of Massachusetts and provides guidelines for legal process actions that occur within
the state of Massachusetts and outside of the Town of Canton. Massachusetts law allows any sworn
police officer to arrest any person at any place within the Commonwealth, providing the officer is aware
that there is an outstanding warrant for that person. As a matter of courtesy and professionalism, the
policy requires the shift supervisor to notify the lieutenant on duty and make appropriate notification to the
local Department with jurisdiction in the location that an arrest is occurring, if outside the Town of Canton.
Canton PD officers are required to ask the local Department for their assistance and cooperation in the
matter (allowing the agency to make the arrest or provide an escort for the Canton PD officers).

Canton PD policy specifies procedures regarding civil processes and asset forfeiture functions to ensure
Canton PD is in compliance with applicable Massachusetts laws. The policy cites the procedures in the
Evidence Collection and Preservation policy as an outline for recording, retaining, and maintaining seized
property. The Officer in Charge of the Detective Bureau is tasked with acting as a liaison with the District
Attorney’s Office to ensure compliance with all procedures relevant to legal forfeiture of property seized
under a search warrant or MGL C94C-547 (Property Subject to Forfeiture Under the Controlled Substances
Act). The designated officer is responsible for recording and filing copies of the documents and disposition
throughout the process and shall report directly to the Deputy Chief regarding these proceedings.

The Canton PD policy does not allow officers to request issuance of a “no-knock” warrant from a judge
unless: 1) probable cause was established that if the officer(s) announced their presence, their life or the
lives of others will be endangered; and 2) the officer filling out the affidavit attests that there is no reason
to believe that minor children or adults over the age of 65 are in the home, unless there is a credible risk of
imminent harm to the minor or adult over the age of 65 in the home.

          RECOMMENDATIONS
          None.

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R. Media and Public Information
The Audit Team conducted a thorough review of the Canton PD Media and Public Information Policy as
outlined in the Canton PD policy No.1.39, last reviewed on May 7, 2023. The Audit Team reviewed the
Canton PD’s current practices and protocols for proactively soliciting public comments concerning high-
profile incidents and crisis communications for consistency with the Media and Public Information policy,
which is in alignment with CALEA Standards 46.1.2 / 54.1.3 / 54.1.1 and 54.1.4. Chief Rafferty and Deputy
Chief Sheryll were interviewed regarding the Department’s policy, to include the use of Social Media
platforms to communicate with the community.

Deputy Chief Patricia Sheryll advised that a patrol officer is assigned the collateral duty of monitoring the
Canton PD’s social media postings and responses. Deputy Chief Sheryll said the designated patrol officer
is the only officer with “Administrator Privileges” for the platforms and has been properly trained and
equipped to handle this responsibility effectively. The Audit Team interviewed the patrol officer about his
responsibilities coordinating and running the social media platforms for the Canton PD. He advised that he
has been managing the social media platforms for the police department since the end of 2021 towards
the beginning of 2022.

Social Media Accounts

The Canton PD social media accounts were created in 2014 by the police department and have been
maintained regularly by a sworn police officer. The officer indicated that there are four (4) active platforms,
which include Facebook, X, Instagram, and Google Biz. In March 2021, there was an attempted illegal
takeover of the police department’s Google Biz platform. Canton PD officers promptly responded and
worked with Google to identify the perpetrator and prevent disinformation from being posted. The
attempted takeover was perpetrated by a town resident who was determined to be mentally unstable. For
this reason, no charges were filed. The Canton PD no longer utilizes the Google Biz platform to post any
messages. [Note: Canton PD tries to post on all platforms simultaneously, however based upon site visits
that indicate that the most popular social media platform is “X,” most of Canton PD’s posts are sent on the
X platform.]

With regards to Instagram, the Deputy Chief advised that the Chief had made the decision to block public
comments due to the large volume of inaccurate, threatening, or crude responses made to posts created
by the Canton PD, even to posts regarding community events or safety alerts. These comments made by
certain community members and outsiders have affected the morale of the officers in a negative way,
which will be detailed later in the report.

Platform Usage

The Canton PD is active on social media. It is crucial to consistently manage and monitor these platforms
to engage with the community and provide accurate information. According to the Canton PD website
(http://www.cantonpolice.com) the department has an active presence on various Social Media platforms
including Facebook, X and Instagram, and an inactive presence on Google Biz. An open-source search of
these platforms, a cursory analysis of the postings made by the department, and the community replies
revealed certain information, prompting some recommendations for improvement.

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Posting Frequency

It is noted that due to differing site visit frequencies, the majority of the Canton PD’s posts are sent on the
"X" platform. While it is important to prioritize the most popular platform, efforts should also be made to
maintain a consistent presence across all active platforms.

The department is operating within policy and departmental standards; however, the Audit Team has
found that the posts made by the Canton PD are not consistent across all social media platforms. For
example, “Missing Person Alerts” and follow-up messages should be posted in equal frequency. In 2021,
there were two (2) Missing Person related messages posted on Facebook, zero (0) posted on Instagram
and five (5) posted on X.

          RECOMMENDATIONS
            •   Conduct regular training sessions for officers involved in social media management,
                reviewing security protocols for social media accounts.
            •   Institute a social media manager for the Patrol and Detectives divisions as well as a
                Senior Lieutenant.
            •   Resume posting to social media outlets as it relates to immediate community concerns,
                such as accidents, construction closings and police activities.

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•   Ensure consistent and timely communications across all platforms to effectively engage
                with the community.
            •   Consider implementing a social media platform management software (i.e., HootSuite,
                Monday.com, etc.) to push social media posts simultaneously to all social media
                platforms used by Canton PD, to schedule posts, and to track social media activity across
                all three (3) platforms.
            •   Post the same messages across all social media platforms especially Safety Alerts and
                Missing Person Alerts.
            •   Secure social media accounts with two-factor authentication, whenever possible.
            •   Leave comments off.
          Public Comments on Social Media
          The decision for public comments on departmental social media, especially in the context of
          law enforcement and public safety, must be carefully weighed. Transparency and community
          engagement are critical components of modern policing and can foster trust and cooperation
          between the police department and the community it serves. Allowing the public to post
          comments can often provide valuable feedback, help the department address community
          concerns, and allow for a more open dialogue.
          However, there are associated risks with allowing public comments, especially concerning the
          potential dissemination of personally identifiable information (PII) of officers, or witnesses
          involved in police incidents, such as:
            •   Officer Safety: Public posting of PII could lead to targeted harassment or threats against
                officers and their families, compromising their safety and wellbeing.
            •   Privacy Concerns: Ensuring the privacy of both officers and civilians is imperative, and
                any platform that allows public comments could inadvertently become a channel for
                privacy breaches.
          Given these concerns, any policy allowing public comments should include strict moderation
          policies and procedures to protect officer PII. Additionally, a clear set of community standards
          should be established which detail what type of comments are permissible and the actions
          that will be taken if someone violates these standards.
          Ultimately, the decision to allow public comments should be made in consultation with all
          stakeholders, including legal advisors, to ensure that any policy implemented is both beneficial
          to the community and protective of the individuals involved.

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S. Bias-Free Policing
The Audit Team reviewed Canton PD Policy No. 1.41, Bias Free Policing and found that it aligns and meets
the requirements as established in CALEA Standards 41.4.0. Further, the Audit Team has reviewed reports
of police encounters spanning the past two (2) decades and have found no evidence of biased policing
based upon race, gender, or ethnicity.

The Canton PD has implemented several measures to identify and address instances of profiling based on
race, gender, or bias. These measures include:

•   Mandatory documentation of all interactions with motorists in the Canton PD’s computer system,
    including the individual's race, gender, age, reason for the interaction/stop, and search results, to
    track and analyze the diversity of citizens engaged with by the police department.
•   Utilization of citizen complaint procedures to investigate allegations of profiling filed directly with the
    Canton PD, or through state agencies, ensuring transparency and accountability in handling bias-
    related complaints.
•   Proactive review of performance, complaint, and employment information by supervisors to identify
    and address potentially problematic behavior among personnel, with a focus on promoting
    professionalism and addressing any concerns regarding disparities in interactions with motorists.
•   Directing officers to collect specific data on race, gender, and reasons for interactions and searches
    as per established protocols by the Secretary of Public Safety, when necessary, to ensure the
    collection of relevant information for analysis.
•   Conducting an annual administrative review of agency practices and citizen concerns by a designated
    Superior Officer selected by the Chief, who will examine written complaints, data on interactions with
    motorists, and any other formal or informal correspondence, and report findings to the Chief of Police
    for further action as needed.

These measures provide an effective method to address and prevent bias-based profiling while promoting
fair and equitable policing practices within the community.

          RECOMMENDATIONS
          While the program protecting against bias is robust, public forums are always recommended
          for community feedback.

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T. Alternatives to Arrest
The Canton PD policy No 1.43 concerning arrest alternative, emphasizes the protection of constitutional
and statutory rights for individuals who are arrested and taken into custody. It mandates immediate
release of an individual if an arrest is determined to be invalid and requires notification of the Chief of
Police or their designee in such cases.

Key Policy Areas Reviewed
The department's procedure under Policy No. 1.43 includes options for alternatives to arrest and grants
officers some discretion in certain situations. Officers are encouraged to consider the public interest and
the context of the situation, possibly opting not to arrest despite having justification.

Circumstances warranting discretion include:

•   Avoiding arrest to prevent escalating community tensions or sparking disorder.
•   Prioritizing response to more serious crimes or emergencies.
•   Acting as a mediator in minor disturbances like neighborhood quarrels or noisy parties (this is an
    example of a direct benefit of community policing).
•   Handling minor juvenile offenses with warnings and parental involvement.
•   Issuing summonses for minor offenses as an effective alternative to arrest.

These guidelines are designed to balance community law enforcement with community relations and a
effective policing strategy. The lack of law enforcement support from the community has drastically
affected Canton PD’s ability to allow officers to exercise discretion, thereby limiting the benefits of
employing a community police force.

          RECOMMENDATIONS
          We strongly recommend officers default their actions according to the documented laws and
          departmental policies. Any discretion utilized by officers exposes both the officer and the
          department to allegations of misconduct and prejudicial treatment; therefore, the
          recommendation of the Audit Team is to enforce the laws as written.

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U. Field Training and Evaluation Program
A comprehensive review of the Field Training and Evaluation Program (FTEP) Policy as outlined in Canton
PD policy No.1.45 and current application was conducted by the Audit Team, as well as in-depth
interviews with the Field Training Officers (FTO). The Audit Team found Canton PD policy No.1.45 to be in
alignment with CALEA Standards 1.3.12 / 33.4.2 / 33.4.1 and 33.4.3.

Key Policy Areas Reviewed
The primary objective of the FTEP is to equip trainee officers with the necessary skills to effectively carry
out their duties as police officers and to advance the standards of professionalism in law enforcement
through ongoing quality enhancement. The program model is based on the widely recognized "San Jose
Model," which involves pairing a student officer with specifically trained FTOs.

The Training Officer and the Training Coordinator will go over the expectations with each new recruit. A
receipt form will be submitted to record the issuance, receipt, and instruction provided. This process will
be completed before the officer is assigned to work independently. Each probationary officer will then
participate in a four (4) week on-the-job training/evaluation program with designated FTOs. This training
period will not change the one-year probationary period, which all newly appointed full-time officers in
Massachusetts must complete. (Source: Massachusetts Law 33.4.3 (a)).

During the training period, the Probationary Officer will be required to rotate their field training
assignments between at least two (2) different FTOs. The FTOs will document their evaluation of the
probationary officers, providing daily and weekly observation reports that cover various police activities
and interactions. Following the supervisory phase of field training, the evaluation process will continue
with periodic evaluations completed by the probationary officer’s supervisors.

During the review process, interviews were conducted with the Deputy Chief and the Training Coordinator,
who are responsible for the management and supervision of the FTEP. New full-time officers must
successfully complete an internal field training initiative, while all sworn officers are mandated to
participate in in-service training every two (2) years. The FTEP training officers are talented and well-
respected officers who have a sincere passion for law enforcement and the Town of Canton.

          RECOMMENDATIONS
          The Audit Team conducted interviews with both FTOs as well as new police officers within the
          Canton PD. Interviews with the FTOs revealed that new officers completed the required
          minimum four (4) weeks of FTEP training, meeting all Massachusetts state and CALEA
          minimum requirements. It is recommended that the FTEP program be expanded to eight (8)
          weeks, as opposed to the current four (4) week program. An eight (8)-week program expands
          the opportunity for additional exposure to the various types of calls and responses necessary
          as a police officer.

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V. In Car Video Recording
The Canton PD follows policies outlined in Policy No. 146 and CALEA Standards 41.3.8 to ensure
compliance with procedures related to their in-car camera program. The primary objective of the
department's use of audio-visual recordings is to provide an accurate representation of events to facilitate
effective evidence gathering and documentation. This practice serves to defend against civil lawsuits and
allegations of officer misconduct. The use of mobile video recording systems in police vehicles also serves
as a safeguard for patrol officers against unfounded accusations of misconduct during traffic stops.

Key Policy Areas Reviewed
•   Recording audio and video footage of motor vehicle stops, pursuits, and police responses in vehicles
    equipped with recording equipment.
•   Retaining video and audio recordings in accordance with records retention standards and making
    them available for court proceedings.
•   Ensuring that all police vehicles are equipped with motor video recording systems, with officers
    conducting pre-shift checks to ensure their operability.

Officers are trained in the proper use of In-Car Video (ICV) systems and are only authorized to use them
during on-duty engagements related to police functions, if safety allows. The use of ICV is required during
specific incidents such as calls for service, encounters with armed individuals, arrests involving the use of
force, search warrants, pursuits, and motor vehicle stops. Officers have the discretion to activate ICV
during incidental public interactions, and once activated, the recording should continue until the event
concludes to maintain data integrity. If an officer fails to deactivate the ICV, they are required to document
the reason for doing so.

Under state law, ICV footage may not be admissible in court if the camera was not properly mounted on
the vehicle. Moreover, ICV recordings in Massachusetts are limited to events occurring in public areas or
within public view, excluding private properties.

          RECOMMENDATIONS
          None.

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W. Body Camera Recording
In 2024, the Canton PD implemented the use of Body-Worn Cameras (BWCs) as
outlined in policy No. 146. A senior lieutenant who is responsible for overseeing
BWC reviews within the department stated during an audit interview that the
Canton PD has recently acquired BWCs and has not encountered any operational
issues thus far.

Before utilizing the BWCs, all officers receive training on proper usage, operations
and calibration, and this training is documented in their records. Detectives and
School Resource Officers are specifically assigned BWCs and are required to
activate them during high-risk activities.                                              Motorola Body Worn
                                                                                        Camera utilized by
Officers are instructed to make a reasonable effort to inform civilians that they are   Canton PD officers.
being recorded by the BWC, unless under exigent circumstances, immediate
threats, or concerns for safety. Consent is not required for recording, but officers must state the reason
when deactivating the BWC. If a BWC fails to record an incident, officers must document this failure in
writing. Officers are prohibited from using the BWCs to record violations of the Canton PD policy. Duty
Supervisors are assigned to monitor officers using the department-issued BWCs, and any instances of
non-compliance are investigated by the Chief of Police or their designee.

The supervisor of the BWC program reported no issues regarding the activation or non-activation of the
cameras. Body camera recordings are securely uploaded to a cloud storage location managed by the
vendor, Motorola, who also supplies and maintains the BWC equipment. Officers are not allowed to use
flash drives to access the video files to prevent potential file corruption. Any necessary redaction of video
footage is done in collaboration with the District Attorneys' office as required.

Observations
Our team spoke with Chief Rafferty and her team that oversees the BWC program and noted that all
express positive feedback toward the BWCs and their usage.

X. Automated Plate Reader Policy/Flock Cameras
Canton PD has Flock cameras placed in certain locations throughout the town. The cameras were
purchased with equitable sharing funds at no cost to Canton residents. The cameras have assisted
officers and detectives to solve several crimes that have occurred in the town. They have become a
valuable law enforcement tool for the Canton PD. The Canton PD does not authorize or use the traditional
LPR systems.

          RECOMMENDATIONS
          The department should purchase additional cameras to be placed in areas where traffic is
          heavy, near schools, and other heavily populated areas within the town.

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Y. Duty to Intervene
In accordance with the Canton PD Rules and Regulations as outlined in Canton PD policy 1.51 and as
delineated in Section 15 (a) of MGL Chapter 6E of Section 30, Chapter 253 of the Acts of 2020, it is
mandated that if an officer witnesses another officer using physical force, including deadly force, that is
deemed excessive or not objectively reasonable given the circumstances, they must intervene to halt the
use of unjustifiable force. However, this intervention should not take place if it puts the officer or another
individual at immediate risk of harm.

Moreover, as per Section 15 (b) of MGL Chapter 6E of Section 30, Chapter 253 of the Acts of 2020, if an
officer observes another officer utilizing unwarranted physical force, they are required to promptly report
the incident to an appropriate supervisor, ensuring this is done before the end of their shift. The reporting
officer must then draft a comprehensive written statement detailing the event in accordance with the
established uniform procedures. This detailed statement should be included in the supervisor's official
report. The Audit Team reviewed over ten years of investigations and police encounters and did not find
any evidence of failure to abide by these policies and regulations.

          RECOMMENDATIONS
          The Audit Team discovered no evidence or information that this policy is not being followed.
          Our recommendation is to include this policy in an acknowledgment and certification to be
          signed and acknowledged by individual officers annually.

Z. Informants
Informant Guidelines
The Canton PD’s Informants Policy and Procedures as outlined in Canton PD policy No. 2.01 are in line
with CALEA Standards 42.2.7, which emphasize the importance of maintaining confidentiality and ethical
conduct when dealing with informants.

Confidential Informant Management
Confidential informants will be given a unique code number to ensure their anonymity. The Officer in
Charge of the Detective Bureau will keep a comprehensive file containing personal details, criminal
background, contact information, and past involvement in operations of each informant. This file is
contained in a lock file container with access limited to detectives and senior officials. Senior investigators
at Canton PD will assess the potential risks to the public associated with using the informant. The decision
to engage the informant will depend on the level of risk involved and the type of criminal activities the
informant can help uncover.
Handling of Informants

Our team found that Canton PD detectives utilize confidential sources (Informants) for information on
crimes that occur or have occurred in the town. The Officer in Charge of the Detective Bureau is

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responsible for ensuring officers and detectives follow the policy and informants are treated courteously
irrespective of their background. Investigators should fulfill all ethical promises made to the informants to
maintain trust. Informants should never be allowed to take control of any part of an investigation.

Juvenile Informants

Special precautions are necessary when using juvenile informants. Permission from at least one (1) parent
or legal guardian is required, and meetings with juvenile informants should involve two (2) officers. Our
team recommends that the Canton PD should not utilize juvenile informants to assist in cases. The Canton
PD as a practice does not use Juvenile Informants.

Dealing with Criminal Activity

Approval from the Chief of Police, or their designee, is required for informants to engage in activities that
would otherwise be criminal. Unauthorized criminal activity by an informant should be reported to the
Chief of Police for appropriate action. Currently the Canton PD has not authorized an informant to engage
in criminal activity.

Remuneration of Informants
The remuneration of informants is under the purview of the Officer in Charge of the Detective Bureau. Only
informants registered in the master file are eligible for compensation, and rigorous records of payments
should be maintained. The Canton PD does not offer financial compensation to informants. Those utilized
by the Canton PD are known as "defendant informants" and cooperate with the aim of potentially reducing
their sentence or charges. Any decisions related to sentence reduction or charge alteration are
determined by the presiding judge in the case, not by the Canton PD. The Canton PD does not make any
assurances or definitive statements to informants about their legal outcomes. Instead, the level of
cooperation provided by the informant is conveyed to the district attorney's office for review and
presentation to the judge.
Dismissing Informants

If an informant becomes undesirable due to various reasons the OIC Detective Bureau should be informed
of the circumstances and decide on further use. The reasons for dismissal should be documented in the
master file.

Additionally, while the Canton PD is not required to obtain approval from the District Attorney’s Office for
informant use, the District Attorney’s Office can assist in strategy decisions for informant use in
considerations of safety and legal processes. Informants are often utilized to initiate proactive
investigations and are kept out of the investigative reports to ensure their safety and confidentiality.
Protective measures are taken to safeguard informants, and in some cases, this may lead to a case
dismissal to prevent exposure to the informant's identity. The District Attorney’s Office commended the
manner in which Canton PD initiates, controls, and utilizes their informants and source of information.

After a review of investigations and established informant usage, the Audit Team determined all Canton PD
informants are established and utilized in conjunction with all policies and regulations. The Audit Team

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reviewed several informant files and found them to be in proper order. All policies and regulations are
followed.

          RECOMMENDATIONS
          While the Audit Team observed nothing that contradicted policy concerning informant
          establishment and usage, the following recommendations are strongly encouraged to be
          added to the current operating procedures and policy manuals.
            •   A minimum of two (2) sworn officers be required when meeting with an established or
                potential informant. No exceptions.
            •   Every time Canton PD officers meet with the informant, officers should search the
                informant for contraband and weapons, regardless of the length of usage. This enables
                the informant to testify in court that they are searched every time they meet the
                controlling officers negating any insinuations concerning contraband seized.
            •   Canton PD will conduct thorough background checks to include a full Criminal History
                including photos and fingerprints when documenting or establishing the informant.
            •   Canton PD sergeant will provide a summary of the informant's reliability and their
                planned usage to the lieutenant over investigations (intelligence/operational).
            •   Canton PD detective will author an Initial Activation Report to be approved by a lieutenant
                or higher-ranking Canton PD official.
            •   CDP Lieutenant of Investigations, or higher-ranking Canton PD official, will conduct
                periodic assessments (180 days) for validating continued establishment and use of an
                informant. This will include meeting with the informant outside the presence of the
                Canton PD controlling officers and ensuring all rules and policies are met and fulfilled.
            •   All usage, debriefings and information obtained from or through the use of an informant
                will be documented, and copies of those reports will be maintained in the informant file
                as well as the respective case file.
          All informants will be debriefed every 90 days, at minimum, and this quarterly debriefing will be
          maintained in the informant file.

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AA. Domestic Disputes
The Audit Team reviewed Canton PD policy No.2.02, Domestic Disputes. The Canton PD acknowledges
and teaches its officers that Domestic Violence is a widespread issue that impacts individuals across all
demographics and does not discriminate. The objective of their policy is to set forth protocols and provide
guidance to officers when addressing domestic violence incidents. Domestic violence is a criminal
offense, and in cases where there is sufficient evidence, arrest is considered an appropriate and preferred
course of action by the court. Regardless of one's profession, every individual is accountable for their
actions that infringe upon laws such as M.G.L. c. 208, 209, 209A, 209C, and/or Superior Court orders. This
approach is in compliance with CALEA Standards 41.4.5.

Key Policy Areas Reviewed
When a law enforcement officers respond to domestic disturbances, they frequently have little to no
information on the aggressor or domestic dynamics, which presents a very dangerous situation. Canton
PD policy dictates that in situations involving domestic violence officers must promptly respond to the
dispute due to the high risk of injury to either party or household member. When dispatched to a
suspected domestic call it is advisable to send two (2) officers to the scene if possible. Additionally,
officers should be equipped with the following information:

•   Any existing warrants through CJIS and the Warrant Management System.
•   The suspect's criminal history.
•   Any protective orders against the suspect, including those held by individuals other than the victim.
•   Other pertinent details known to the department, particularly relating to past incidents at the address
    or involving the parties, as well as the potential presence of firearms.
•   Information on firearms identification cards and/or licenses to carry issued to the residents.

This protocol is crucial for ensuring the safety and well-being of all parties involved in domestic disputes.

One of the resources on staff at the Canton PD is the Mental Health Professional (MHP) described in
Section 1, Part E. The MHP collaborates with uniformed officers and provides prompt counseling options
and alternatives to law enforcement engagement. According to Massachusetts law, if officers witness any
physical harm being done or observe injuries or evidence of abuse on either individual, they must
apprehend the aggressor. Examples of injuries or markings stated in this section encompass bruising,
scratches, and red marks. In the absence of these physical signs, the domestic disturbance scenario
transforms into an argument, or counseling session where both parties allege mistreatment by the other.

Given the unpredictable nature of domestic disturbance calls and the inability for law enforcement to
ascertain the relationship dynamics of the parties, the number of individuals involved, weapons present,
previous injuries, etc., the policy must outline parameters within which to work. The Canton PD policy
provides clear instruction on what must be addressed and how to safely navigate a domestic disturbance
situation.

The Canton PD provided the following statistical data related to domestic violence and family services
calls for service.

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Domestic Violence incident statistics for the time period between January 1, 2023 and December 31, 2024
indicated that Canton PD had a total of 321 log entries (calls for service), listed below in the IMC
computer database. During 2023, Canton PD reported 52 arrests/complaints for domestic violence
related offenses. In 2024, Canton PD reported 66 arrests/complaints for domestic violence related
offenses.

          RECOMMENDATIONS
          None.

BB. Sexual Assaults
The Audit Team reviewed Canton PD policy No. 2.03: Sexual Assault Investigations. This policy has been
implemented since 2009 and previously reviewed in 2009, 2014, 2016, 2017, 2020 and 2023. Further
examination of this policy confirms it complies with CALEA Standards 33.6.1 and 82.2.1.

Key Policy Areas Reviewed
The Canton PD policy concerning sexual assault is consistent with Policy No. 2.02 as outlined above in
that it emphasizes key laws which must be adhered to while dealing with an extremely sensitive and
horrific crime. The Canton PD takes extra measure to ensure its officers understand Massachusetts Rules
of Evidence Section 413, “First Complaint of Sexual Assault” (a) and (b) which states in part:

          “(a) Admissibility of First Complaint. Testimony by the recipient of a
          complainant's first complaint of an alleged sexual assault regarding the fact of
          the first complaint and the circumstances surrounding the making of that first
          complaint, including details of the complaint, is admissible for the limited
          purpose of assisting the jury in determining whether to credit the complainant's
          testimony about the alleged sexual assault, not to prove the truth of the
          allegations.(b) Admissibility of Additional Reports of a Sexual Assault Under an
          Alternative Evidentiary Basis. When otherwise admissible testimony or evidence
          other than the first complaint includes or implies that a report of a sexual assault
          was made, it may be admitted only if the trial judge determines that (1) it serves
          an evidentiary purpose other than to corroborate the testimony of the alleged
          victim and (2) its probative value outweighs its prejudicial effect.”

The first interview in these types of investigations is extremely crucial and could fall under the “First
Complaint” doctrine. Canton PD personnel are required to be well-versed in the "First Complaint" doctrine
and its significance in cases of rape and other sexual assaults. According to this doctrine, a witness can
testify about a sexual assault victim's initial report of the crime regardless of how much time has passed
since the incident occurred. The witness can provide details about the crime, the circumstances
surrounding the victim's report, and why the report was made at that time. There is no longer a
requirement for the victim's complaint to be made promptly or reasonably after the assault. Only one (1)
witness can testify about the victim's initial complaint, which should be the first person the victim

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confided in about the assault. Since police officers and investigators often serve as the first recipients of
such complaints, they must meticulously document every detail shared by the victim to testify accurately
and effectively in any subsequent legal proceedings.

Rape is an inherently damaging experience for the victim, causing both physical and mental harm. It is
crucial for law enforcement officers to understand that investigating a rape case requires utmost
sensitivity and tact to gather all the necessary information about the crime and the perpetrator's method
of operation. Investigating rape and sexual assault is one of the most challenging tasks for any police
officer, and successful prosecution becomes nearly impossible without the victim's full cooperation. A
well-conducted and professional interview can yield vital information for apprehending the suspect and
collecting evidence for a conviction.

          RECOMMENDATIONS
          Given the gravity of these investigations and the potential impact of Massachusetts Rules of
          Evidence Section 413 on the successful prosecution of a sexual assault case, it is
          recommended that the Canton PD ensure at least two (2) detectives receive training in
          handling sexual assault cases, interview techniques, and crime scene processing and
          preservation. The Audit Team recognizes that the Massachusetts State Police will ultimately
          handle and process the crime scene in instances of sexual assault. However, since Canton PD
          officers have a singular opportunity to document these scenes as first responders and
          considering the significance of the "First Complaint" doctrine, it is imperative that Canton PD
          officers undergo specialized training in dealing with such crimes.

CC. Dead Bodies
The Audit Team reviewed the Canton PD policy No.2.05, “Dead Bodies,” which in summary, dictates the
following actions to be taken by its officers.

•   Classify a death into one of four (4) categories (the Manner of Death): Homicide, Suicide, Accidental
    Death, or Natural Cause. It is vital to act promptly and knowledgeably in response to the discovery of a
    dead body, adhering to established policies.
•   As per Massachusetts General Law (MGL) Part 1, Title VI, Chapter 38, Section 3, individuals must
    immediately notify the Office of the Chief Medical Examiner under various circumstances, such as
    deaths involving criminal violence, accidents, suicides, suspicious circumstances, abuse suspicions,
    poison or drug-related deaths, among others.

The responsibility of establishing the cause of death falls under the jurisdiction of the medical examiner,
(cause of death is the specific injury or disease that leads to death) while determining the manner of death
generally lies with the police. As indicated in MGL C.38s.4, manner of death is the determination of how
the injury or disease leading to death occurred. The medical examiner takes charge of the deceased's body
and any personal property found, unless the property is considered evidence of a crime.

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In cases of unnatural deaths, all property, including potential evidence like suicide notes, must be
retained by the police department unless directed otherwise by the District Attorney’s Office. It is essential
to maintain the integrity of the crime scene and handle the deceased person's belongings with care.

In incidents of unattended deaths or deaths falling under the criteria listed in MGL C. 38 s. 3, both the
medical examiner and the District Attorney’s Office must be informed. However, in attended deaths where
the cause appears natural and non-suspicious, the medical examiner may not need to be present at the
scene, provided a death certificate is signed by an appropriate individual.

Unattended death procedures require immediate actions by the responding officer, including initiating
resuscitation if applicable and notifying the necessary authorities. The scene should be secured, and
efforts made to preserve any potential evidence until the arrival of the medical examiner and District
Attorney’s representatives.

Findings and Observations

Overall, the handling of deceased individuals requires thorough adherence to statutory provisions, careful
documentation of the scene, cooperation between law enforcement and medical examiners, and proper
notification of relevant authorities following established protocols.

The Audit Team reviewed policy, procedures, evidence collection, and the preservation of evidence related
to death investigations, to include the death investigation of Boston Police Officer John O’Keefe. We made
observations and recommendations listed below. Our team made additional recommendations and
findings which are detailed later in this report. See below.

•   First responding officers should have photographed the scene (location of Mr. O’Keefe) before fire
    rescue arrived.
•   The Canton PD properly notified the Massachusetts State Police (MSP); however, the MSP were not
    decisive in their response to the notification. Pending MSP acceptance, it is a Canton PD crime scene
    and should have been handled as such.
•   The arriving Canton PD units were not properly equipped with crime scene equipment allowing for
    proper crime scene processing (evidence bags, digital camera, collection kits, etc.).
•   The Canton PD should have maintained a presence with at least one patrol officer and marked patrol
    unit at 34 Fairview Road to preserve the crime scene, pending further investigation by MSP.

It is important to acknowledge that despite the challenging blizzard conditions and the delayed response
from the MSP, the Canton PD officers made an effort to uncover and protect evidence. The innovative use
of a leaf blower to systematically search through the snow-covered crime scene was instrumental in
uncovering evidence near Mr. O’Keefe's body. Considering the delayed arrival of the MSP and absence of
crime scene equipment on hand, the Canton PD officers were resourceful in their attempts to safeguard
physical and biological evidence.

On March 20, 2025, at approximately 5:28 p.m., Canton PD responded to a report of an unconscious male
who was believed to be overdosed. When officers arrived, they were met by the calling party, who
discovered the male subject in the doorway to the house. Canton PD officers observed the male subject

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laying on the floor in front of the doorway. Officers immediately secured the scene and notified Detective
Sergeant and other detectives who responded to the scene. Canton Fire Department and Paramedics
responded on scene and pronounced the male subject deceased at 5:35 p.m.

Notifications were made to the Massachusetts State Police detectives assigned to the Norfolk District
Attorney’s Office and the medical examiner's office in conjunction with Massachusetts Law, who then
responded to the scene. Prior to their arrival, the Canton PD took digital photographs of the scene,
secured evidence, and obtained witness statements (recorded on body worn cameras) from individuals at
the scene who had critical information. This investigative action was in line with Canton PD policies,
procedures, and best practices. The Canton PD noted in reports that the manner of death was sudden
death (overdose).

These actions demonstrate that the Audit Team’s recommendations related to crime scene preservation
and handling are being successfully implemented and making effective changes in the operations of the
Canton PD.

          RECOMMENDATIONS
          Scenario-Based Tabletop Training
          In line with previously recommended training focused on Crime Scene Preservation and
          Documentation, it is also recommended the department implement scenario-based tabletop
          exercises for uniformed officers in a classroom setting during in-service training. These
          exercises can simulate a variety of crime scenes scenarios. Moreover, these scenarios should
          include the detective division as well as third line supervisors, to illuminate the communication
          process and expose possible gaps to current procedures.
          Tabletop exercises provide an opportunity for officers to anticipate potential challenges and
          initiate constructive discussions without the need for elaborate setups or travel. This cost-
          effective training method allows for simultaneous training of all officers and is a common
          practice employed by federal law enforcement agencies as well as all military branches. By
          engaging in these scenarios, officers can gain essential knowledge on the proper procedures
          while familiarizing themselves with potential obstacles that could arise. This proactive
          approach enables the department to equip each officer effectively and ensure they are well-
          prepared to fulfill their duties.
          Standard Evidence Collection Equipment
          It is further recommended that all patrol officers have standard evidence collection equipment
          in their patrol cars. The Audit Team understands that while the MSP will ultimately handle and
          process crime scenes involving dead bodies, the Canton PD officers will be the first responders
          and should be equipped to adequately secure the scene and pertinent evidence until MSP
          arrival. As the first responders, Canton PD officers should receive training on evidence
          collection and preservation relevant to crime scenes involving dead bodies in the event that the
          MSP response is not timely to prevent the erosion of pertinent evidence.

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DD. Cold Cases
The Audit Team reviewed Canton PD policy No.2.06, “Cold          Key Definitions:
Cases” and found it to be in alignment with CALEA
                                                                 • Cold Case: A criminal investigation that
Standards 42.2.9.                                                  remains unsolved after one year, with all
                                                                   known leads exhausted. A suspect may or
The objective of this policy is to ensure that all major cases
                                                                   may not have been identified during the
are diligently investigated while appropriate procedures           original investigation.
are in place for handling unsolved cold cases.
                                                                 • Major Cases: Major cases include homicide,
This policy reflects Canton PD’s commitment to                     any suspicious death, rape, kidnapping,
investigating all major cases until resolution while               assault resulting in serious bodily harm,
                                                                   arson, terrorism-related incidents, and other
managing limited investigative resources effectively . If a
                                                                   cases as determined by the Criminal
case remains unsolved after one (1) year with no new               Investigations Unit Supervisor.
evidence or leads, it will be deemed a "cold case" and is
then subject to the procedures outlined in the policy.

This policy allows the Canton PD to maintain its commitment to pursuing justice for victims and holding
perpetrators accountable, even in cases that have grown cold over time.

          RECOMMENDATIONS
          None.

EE. Criminal Intelligence
The Audit Team reviewed COD Policy No. 2.07 “Criminal Intelligence” and found it in alignment with
CALEA Standards 42.1.5 and 2.1.4.

The policy covers intelligence activities which primarily focus on gathering, analyzing, and disseminating
information regarding suspicious occurrences and criminal intelligence, which may not always be directly
tied to an ongoing criminal inquiry. Maintaining the legal and ethical integrity of the information collection,
handling, and distribution processes is crucial. Legal mandates and privacy regulations prohibit law
enforcement agencies from obtaining and sharing data that is not considered relevant to criminal activity.

The Canton PD has instituted several safeguards regarding its legal obligations and in consideration of the
rights of its citizens. The policy states in part:

•   Intelligence gathering efforts shall not interfere with the exercise of constitutionally guaranteed rights
    and privileges; and
•   No intelligence information shall be gathered or retained unless it specifically relates to criminal
    conduct or to activities that present a threat to the community.

The Canton PD policy clearly outlines the requirements and expectations as it relates to
Maintaining/Storing, Safeguarding/Processing and Utilizing intelligence.

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RECOMMENDATIONS
          Consistent with the recommendations as they relate to Informants and Documentation and
          Report Writing, the Audit Team suggest careful consideration be given to the documentation of
          all intelligence, with special consideration given to verbal debriefings. A clear chain of custody
          is easier to establish for physical evidence such as documents, electronic records, video and
          audio recordings, but quite often the most valuable intelligence is gleaned through informant
          debriefings as well as witness statements. At the time a statement is acquired it may not have
          relevance or be thought of as intelligence. Consistent formatting in recording and
          memorializing this type of information will assist in preserving and maintaining the integrity of
          reports.

FF. Internal Affairs (IA)
The Audit Team conducted a thorough review of both the internal affairs (IA) policy as documented in
Canton PD Policy No. 4.01 as well as the existing IA investigations. This section will speak only to the
policy. The policy, its implementation and the IA investigations are thoroughly assessed in Section 3:
Professional Standards and Accountability.

Policy No.4.01 as documented is in alignment with and meets the requirements of CALEA Standards
11.4.4 / 26.1. / 26.1.2 / 26.1.14 / 26.1.5 / 26.1.7 / 26.1.8 / 45.2.1.1 / 52.1.2 / 52.1.3 / 52.1.4 / 52.1.5 /
52.2.1 / 52.2.2 / 52.2.3 / 52.2.4 / 52.2.5 / 52.2.6 / 52.2.7 / 52.2.8 and 52.2.9, as well as Massachusetts
POST REC-01 / IA-01 through IA-06 and Conduct 01. This policy was last reviewed on January 15, 2025.

A relationship built on trust and confidence between the employees of the police department and the
citizens of the community is crucial for achieving law enforcement goals. All police personnel are
expected to conduct themselves in a manner that reflects positively on themselves and the department,
both on and off duty. Upholding a high standard of conduct establishes the reputation of the department,
in turn garnering support from the community for department objectives. In the Canton PD, the IA function
may be delegated by the Chief to the Deputy Chief, who can then assign a lieutenant to investigate. For the
purpose of this policy, the term Internal Affairs Section will encompass any of the aforementioned roles.

The IA function is vital for ensuring professional conduct within a law enforcement agency. The
department's integrity is directly corelated to the personal integrity of each employee. The quality of IA
investigations in response to misconduct allegations significantly shapes the public perception of the
department. The primary purpose of the IA function is to address allegations of misconduct within the
police department and among its staff to ensure department integrity and preserve community trust. An
officer tasked with conducting an IA investigation must oversee the investigation of complaints against all
employees, supervise inquiries into alleged misconduct within the department, and uphold the
confidentiality of IA investigations and records. A thorough IA investigation is essential for maintaining the
department's integrity, ensuring objectivity, fairness, and justice through comprehensive and impartial
reviews.

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The policy is thoroughly written and provides clear instruction and guidelines on the IA process. Primary
objectives include:

•   Protection of the public                           •   Removal of unfit personnel
•   Protection of the employee                         •   Correction of procedural problems
•   Protection of the Department                       •   Address training deficiencies

Any initiated IA investigation must begin promptly upon receipt of the complaint and should be concluded
within ten (10) days after the assigned officer contacts the complainant. In cases of extenuating
circumstances, the officer must provide written notice documenting the reasons for the delay to the Chief,
who has the authority to approve an extension of the investigation timeframe. Formal complaint forms are
accessible at the Canton PD, and once submitted, the arrival time and date will be recorded with a copy
being furnished to the complainant. In cases where a violation is considered minor, the Canton PD will
adhere to the minimum standards stipulated by the POST Commission policies. These complaints may be
shared with the Commission upon request or in alignment with any relevant Commission policy.

To align with the Police Reform Act requirements, all IA investigations regarding officer misconduct
complaints must be completed with a final decision reached within one (1) year of the complaint's
submission or notification from the Commission regarding the filed complaint. The Commission reserves
the right to extend the investigation timeline for valid reasons. All applicable Policies and Procedures will
be revised to comply with these regulations. The Canton PD policy itself is well written and detailed. It
encompasses all aspects of an IA investigation as well as the proper procedure to be taken.

          RECOMMENDATIONS
          Recommendations as they relate to Canton PD policy No 4.01 are addressed thoroughly in
          Section 3: Professional Standards and Accountability. There are no specific recommendations
          to the policy itself as it is well written. The recommendations made in Section 3 will address the
          overall Internal Affairs program and recommend changes to the implementation of and
          adherence to this policy.

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GG. Victim Witness Rights                                     Key Definitions:
The Audit Team reviewed Canton PD Policy No. 4.03.            • Victim: A person who suffers physical, financial, or
This policy dealing with the rights of both Victims and         emotional harm as the direct result of a specified
Witnesses meets and exceeds the requirements                    crime or delinquency offense committed upon his
                                                                person or property. Also regarded as victims are:
established in CALEA Standards 55.1.1 / 55.1.2 /                1.) a spouse, child, parent, or legal guardian of a
55.2.1 / 55.2.2 / 55.2.3 / 55.2.24 / 55.2.5 / 55.2.6 and        minor victim; and 2.) a spouse, child, sibling,
22.2.4. Beyond ensuring the rights are understood by            parent, or legal guardian of a homicide victim. (The
its officers, the Canton PD takes extra steps to ensure         definition excludes any person involved in a crime
the officers understand the impact of being a victim of         as a perpetrator or accomplice).
a crime, as well as being a witness and having to             • Victim Advocate: A person authorized by the
navigate the legal system as a civilian.                        District Attorney’s Office or another agency to
                                                                assist victims in specified ways. Such advocates
Key Policy Areas Reviewed                                       may be paid employees of the District Attorney’s
                                                                Office or trained volunteers (unpaid citizens).
The Canton PD policy No. 4.03 prioritizes the care and
                                                              • Witness: A person who--as determined by the law
support of crime victims and witnesses. Historically,
                                                                enforcement agency--has information or evidence
law enforcement agencies have focused primarily on              relevant to the investigation of a specified crime
apprehending offenders, unaware of the needs of those           (all felonies, all misdemeanor crimes against
affected by the crime until they are required to testify in     persons, and, upon the recommendation of the
court. When victims and witnesses feel they are not             responding officer, other crimes). When the
treated well, or feel threatened, their willingness to          witness is a minor, the term "witness" includes an
cooperate with the authorities may be compromised.              appropriate family member. "Witness" includes
                                                                neither defense witnesses nor anyone involved in
This lack of full cooperation can significantly impact
                                                                the crime as a perpetrator or accomplice. All
investigations and legal proceedings.                           victims are witnesses.
The Canton PD efforts to raise awareness about this issue are aimed at improving the relationship
between the police and victims/witnesses. By maintaining a positive connection, victims and witnesses
can better handle the aftermath of the crime, enhance the perception of the police as a community-
focused organization, and ultimately increase their cooperation in ongoing investigations and legal cases.

Massachusetts General Law Part111, Title IV, Chapter 258B states:

          “Rights Afforded to Victims, Witnesses and Family Members”, (d) states in part:
          “(d) for victims and witnesses, to be provided with information by the prosecutor
          as to the level of protection available and to receive protection from the local law
          enforcement agencies from harm and threats of harm arising out of their
          cooperation with law enforcement and prosecution efforts.”

In accordance with Massachusetts General Law Chapter 258, the Canton PD Policy instructs that
individuals who have faced threats, or have credible reasons to fear intimidation, should be provided with
immediate support and protection. In cases of victim/witness intimidation, the following protocol should
be followed:

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•   If an officer becomes aware of victim/witness intimidation they should:
     • Notify the Shift Supervisor without delay to arrange for the safety and protection of the victim or
       witness. The level of assistance provided should be based on the specific circumstances and the
       level of danger faced by the victim/witness. Measures should be taken to ensure the safety of the
       individual.
     • Take necessary legal actions against the perpetrator, including filing charges and seeking a
       warrant, if required.
     • Inform the Criminal Investigation Unit and Department Court Prosecutor for further potential legal
       proceedings.
•   In situations where the victim/witness is located outside the jurisdiction of the police department:
     • The Shift Supervisor should immediately contact the relevant police agency in that area to inform
       them of the threat and request necessary precautions be taken.
     • Efforts should be made to alert the victim/witness about the potential danger and inform them that
       local authorities have been notified.
     • Notification should also be sent to the Department Court Prosecutor to initiate appropriate legal
       actions in response to the situation.

The Canton PD policy is detailed and in compliance with CALEA Standards. Additionally, the Canton PD
upheld and implemented this policy effectively on two (2) occasions as it related to Witness Intimidation
involving witnesses in the trial of Ms. Karen Read.

          RECOMMENDATIONS
          On two (2) occasions, the Canton PD responded to threats of witness intimidation and took
          appropriate actions as dictated and required by Massachusetts General Law Chapter 258b.
          The Audit Team reviewed both of those police actions, one of which was a more in-depth
          investigation, and found in both instances the Canton PD acted within policy and within the
          best interests of the citizens in Town of Canton. Those investigations, while required by law, did
          not coincide with the public opinion and have been scrutinized on social media. These two (2)
          instances cited above were just two of the many incidents reviewed by the Audit Team that
          qualify as Victim/Witness intimidation.
          The Audit Team recommends that the Canton PD enforce all laws as applicable and as cited in
          Massachusetts General Law Chapter 253b regardless of public sentiment.

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HH. Training
The Canton PD Policy No. 4.04 relates to Training, Organization and Administration. CDP Policy No.4.04 is
in compliance with CALEA Standards 33.1.1 / 33.1.2 / 33.1.3 / 33.1.4 / 33.1.7 / 33.2.1 / 33.3.1 / 33.3.2 /
33.4.1 / 33.4.2 / 33.5.1 / 33.5.3 / 33.6.2 / 33.7.1 / 33.7.2 / 33.8.2 / 1.13.12 / 72.1.1 / 1.1.11 / 1.1.12 and
1.1.13.

The Audit Team reviewed the training policy in depth. While recommendations will be made regarding the
training requirements, opportunities and necessities, those requirements will be made under Section 7:
Hiring, Training Standards and Equipment.

Key Policy Areas Reviewed
Canton PD Policy No.4.04 clearly defines and acknowledges that training has been consistently
recognized as a crucial responsibility within every law enforcement organization. Firstly, officers who are
well-trained are typically better equipped to confidently and appropriately handle a wide range of
situations. Secondly, training contributes to improved productivity and efficiency among personnel. Lastly,
it promotes teamwork and a shared sense of purpose within the agency. Recently, there has been a
growing trend for agencies to be legally liable for the behavior of their staff and for any deficiencies in
training, whether initial or ongoing.

Training initiatives must be designed to meet the specific needs of the agency and ensure that all training
activities are accounted for. It is essential that the training aligns with the goals and objectives of the
department and town. Training opportunities are largely dependent on budget restrictions.

The Canton PD’s official training committee, which reports directly to the Chief of Police and is led by the
Training Coordinator, will convene on an annual basis. This committee will have the responsibility of
assessing and appraising all internal training initiatives to ensure they align with staff and operational
requirements, comply with legal mandates, and uphold agency regulations. It will also provide
recommendations for new training focus areas and contribute to the refinement and creation of programs
accordingly. The committee will operate under the jurisdiction of the Chief of Police. The current
composition of the Training Committee includes the following members:

•   Chief of Police                                    •   Family Services Unit Supervisor
•   Deputy Chief                                       •   Training Coordinator
•   Detective Bureau Supervisor                        •   Principal Field Training Officer

The Chief of Police retains ultimate authority over the appointment and substitution of committee
constituents. The Canton PD training coordinator was interviewed at length on multiple occasions by the
Audit Team. In addition to his duties as Training Coordinator, he is also the primary “Use of Force”
instructor for the Canton PD. The Training Coordinator is well versed on Canton PD Policy No. 4.04 and his
responsibilities for the coordination of training.

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RECOMMENDATIONS
          There are no recommendations as they relate to the training policy. Several training
          recommendations have been noted and will be provided in Section 2: Crime Scene Protocols,
          Section 3: Professional Standards and Accountability, and Section 7: Hiring, Training Standards
          and Equipment.

II. Central Records
The Audit Team reviewed the Central Records policy of the Canton Police Department in Section 4.06 of
the rules and regulations. Section 4.06 aligns with CALEA Standards 72.1.3 / 82.1.1-.9 / 82.2.1-.5 / 82.3.1-
.5 / 17.4.2 / 17.4.3 and 42.1.3. The purpose of the Central Records policy is to designate records reporting
and management procedures that allow Canton PD to provide effective law enforcement services and
satisfy legal requirements and responsibilities.

Key Policy Areas Reviewed
The Deputy Chief is responsible for managing Records procedures which include the following: report
review, report control, records maintenance, records retrieval, dissemination of records and destruction
of any record. The policy notes that Canton PD permits the dissemination of public data in compliance
with the standards of the Massachusetts Criminal History Systems Board. The dissemination of
department records is strictly controlled by Criminal Offender Record Information (CORI) guidelines and
M.G.L. C66.S10. The Deputy Chief approves the release of all reports. The policy stipulates that records
can be requested from the Deputy Chief through a Records Request form left in the Deputy Chief’s
mailbox or through an email request to the Deputy Chief.

Key points regarding records management policy expectations:

•   Officers assigned to work at the desk are required to record the following activity that occurs within the
    community:
     • Citizen reports of a crime
     • Citizen complaints (crime related)
     • Citizen requests for service when an officer is dispatched, an employee is assigned to investigate,
       or an employee is assigned to follow up
     • Criminal and non-criminal cases initiated by officers
     • Incidents involving arrests, citations or summonses
•   Dispatching officers are required to initiate a Call Number (Log Entry) whenever a member of the
    public makes a call for service and to record all pertinent information to the request.
•   Complete and accurate data entry responsibilities regarding the IMC system are the responsibility of
    the desk officer and the patrol officer or shift Supervisor.
•   Desk officers must enter all necessary data into IMC as specified within the policy.
•   The Chief of Police will assign designees responsible for each of the following records:

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• Department Written Directive Systems                 • Motor Vehicle Citations
     • Control of Copy Reproduction                         • UCR and NIBR’s reporting
     • IMC data review and updates.

The policy details precise procedures the Canton PD must follow to ensure accurate, complete, and
relevant data be recorded and maintained. Shift supervisors are responsible for reviewing the reports of
patrol officers assigned to them based on specific criteria delineated within the policy (including
neatness, grammar, content, etc.). The Deputy Chief is responsible for reviewing reports to ensure
compliance with NIBRS reporting as well as quality metrics. An evaluation report on the Report Review
process must be submitted twice annually to the Chief of Police, noting the number of reports reviewed,
the number returned for correction, a breakdown of most frequent errors, the names of individuals
needing remedial report writing training, and suggestions for improving the process.

The Canton PD most frequently uses the following types of reports in daily operations:

•   Incident Reports                                   •   Restraining Order Reports
•   Offense Reports                                    •   Property Reports
•   Arrest (Booking) Reports (Criminal History File) •     Motor Vehicle Crash Reports (generates a log
•   Supplemental Reports                                   entry and requires completion of the IMC/IMC
                                                           traffic form)
•   Field Interview Reports
                                                       •   Motor Vehicle Citations
•   Warrant Reports

The Central Records policy not only notes specific instructions associated with the most frequently used
forms but also delineates standards for regularly reviewing existing forms to improve functionality,
eliminate obsolete or repetitive forms, and ensure uniformity and simplicity in design. The policy ensures
record retention procedures are in compliance with Massachusetts General Laws Chapter 66, Section 8
which requires police departments to retain records in accordance with the Supervisor of Public Records'
“Retention Schedule.” The Deputy Chief is responsible for ensuring compliance to this policy.

Canton PD has procedures for handling funds specified within the Central Records Policy as well, to
include the following requirements:

•   The Chief of Police does not authorize officers to accept cash payments for special services
    contracted through the department, such as printing off copies of crash/incident reports. Payments
    must be made in the form of a personal or cashier’s check.
•   All officers and clerical staff should be aware of costs associated with copying and mailing police
    reports, a breakdown of which is to be maintained in the records office.
•   The officer in charge of issuing gun permits is required to document all fees collected for the licenses
    and ensure that payment has cleared prior to the issuing of the license.

Canton PD policy strives to ensure information is maintained accurately and securely, while still being
accessible as needed to perform police functions. Records security is ensured by the Deputy Chief. The
Records Section of the police department is restricted access to ensure security of department records.

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Dissemination of public records is strictly controlled by CORI standards and the Massachusetts General
Laws Chapter 66, Section 10. Operational records are always accessible through the IMC system to
facilitate investigations and other law enforcement services. When Police Reports are removed from the
files for law enforcement purposes (i.e. court, civil litigation, etc.) a note is left in place of the records
documenting the following: date removed, name of the officer or person removing the report, incident
number of the report, and the purpose for removal.

Protection of police intelligence is imperative to law enforcement operations, as evidenced by the
guidelines in the Central Records policy. The Canton PD computer system is only accessible through
passwords used by department employees. The Information System Manager (ISM) is appointed by the
Town of Canton and is responsible for controlling access security. The ISM is responsible for performing
weekly scheduled data back-ups and proper storage of computer data files, including on-site and off-site
stored information. The ISM is also responsible for reporting any access violations directly to the Chief of
Police.

Records are only authorized to be released pursuant to M.G.L. Chapter 6, Section 172, as stated in the
policy. Canton PD requires officers and civilian personnel be trained in the use of IMC systems
accordingly. Canton PD restricts access to sensitive cases, including sexual assault reports. A lieutenant
must approve access to these reports. Reports involving juveniles are to be clearly marked “JUVENILE”
and access to arrest information is strictly limited to those who have a legal right to access the
information. Information dissemination of such sensitive files is specifically addressed in the policy to
ensure clarity.

Overall, the Central Records policy thoroughly addresses the standards and procedures for retaining,
maintaining, securing, and disseminating information.

          RECOMMENDATIONS
          None.

JJ. Oath of Officer
The Audit Team reviewed the Oath of Office policy detailed in Section 4.07 of the rules and regulations. The
policy is uniform with CALEA Standards 11.1.0 / 16.3.0 / 26.0.1 and 26.0.2 and encompasses the mission
of the police department in a form that satisfies state and local requirements, as well as affirms the
commitment to upholding the Constitution of the United States. The Canton PD Oath of Office, mission
statement, and Code of Ethics ensures members of the department reflect a commitment to each.

Oath of Office
All newly hired officers are required by policy to appear before the Town Clerk and take the Oath of Office,
then maintain a sworn, signed copy of the Oath in their personnel file. The policy cites Massachusetts
General Laws, Chapter 41, Section 98, entitled “Powers and Duties” as the basis of authority for their
sworn officers.

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The Oath of Office is as follows:

          “I, _________ do solemnly swear that I support the Constitution of the United
          States of America, and the Constitution and laws of the Commonwealth of
          Massachusetts, the by-laws of the Town of Canton, and the Rules, Regulations
          and all lawful directives (written as well as unwritten) of the Canton Police
          Department, and that I faithfully discharge the duties of the office of
          ______________, to which I have been appointed according to the law and the best
          of my ability.”

Mission Statement
In addition to the Oath of Office, the policy clearly defines the mission statement of the Canton Police
Department.

          “It is the primary mission of the Canton Police Department to deliver professional
          police services to the residents and business owners of Canton as well as those
          who visit our community regardless of race, religion, ethnic origin or sexual
          orientation.”

The mission statement reflects Canton PD’s commitment to quality policing practices and establishing
protocols that ensure such practices. Every member of Canton PD is required by policy to accept
responsibility for achieving the mission.

Code of Ethics
The Oath of Office policy details a code of ethics to be followed by their officers, and a code of ethics to be
followed by civilian employees. The Code of Ethics for sworn officers is as follows:

          “As a Law Enforcement Officer, my fundamental duty is to mankind; to safeguard
          lives and property; to protect the innocent against deception, the weak against
          oppression or intimidation, and the peaceful against violence or disorder; and to
          respect the Constitutional rights of all man to liberty, equality, and justice.

          I will keep my private life unsullied as an example to all; maintain courageous
          calm in the face of danger, scorn, or ridicule; develop self-restraint; and be
          constantly mindful of the welfare of others. Honest in thought and deed in my
          personal and official life, I will be exemplary in obeying the laws of the land and
          the regulations of my department. Whatever I see or hear of a confidential nature
          or that is confided to me in my official capacity will be kept ever secret unless
          revelation is necessary in the performance of my duty.

          I will never act officiously or permit personal feelings, prejudices, animosities or
          friendships to influence my decisions. With no compromise for crime and with
          relentless prosecution of criminals, I will enforce the law courteously and
          appropriately without fear or favor, malice or ill will, never employing
          unnecessary force or violence and never accepting gratuities.

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I recognize the badge of my office as a symbol of public faith, and I accept it, as a
          public trust to be held so long as I am true to the ethics of the police service. I will
          constantly strive to achieve these objectives and ideals, dedicating myself to my
          chosen profession... Law Enforcement.”

The Canton PD Code of Ethics reflects a commitment to the personal and professional standards of an
exemplary law enforcement officer and in turn, to the community they commit to serve. To ensure
commitment to the code, Canton PD officers are required by policy to receive ethics training twice a year
at a minimum.

          RECOMMENDATIONS
          While no recommendations are being made under this section the Audit Team has observed
          that Canton PD officers demonstrate a notable commitment to their code of ethics by
          continuing to serve/perform policing duties despite the perception that they have limited
          support from members of the community or elected officials. More information will be provided
          in this report under Section 6: Management Operations and Culture.

KK. Domestic Violence Involving LEO
The Audit Team reviewed and assessed CDP Policy No. 4.10 and found it to be in alignment with and
fulfilled the requirements of CALEA Standards 11.4.4 and 52.2.2.

Key Policy Areas Reviewed
Incidents of domestic violence involving law enforcement personnel pose particular challenges for
investigating officers. Officers must balance protecting the victim from further harm while enforcing
domestic violence laws. Victims of such abuse may be hesitant to report the incidents against an officer,
making it crucial for responding officers to take appropriate action based on evidence, regardless of the
abuser's occupation. Police officers responding to domestic violence incidents involving their colleagues
have an added and increased responsibility to uphold the integrity of their profession and the trust placed
in them by the public. Failing to enforce the law in such cases not only harms the victim but undermines
the credibility of law enforcement as a whole and erodes the trust of the community.

Canton PD policy No.4.10 recognizes that officers may be involved in domestic violence incidents and
establishes clear procedures for addressing such matters involving law enforcement personnel. The
policies provide guidance on how to manage situations where an officer is implicated in domestic violence
to ensure compliance with all legal requirements while caring for the safety and security of the victim. The
Canton PD’s policy on Domestic Violence Involving Law Enforcement Personnel is designed to assist
officers in navigating these complex scenarios by upholding the principles of justice and accountability
within the law enforcement community.

The Canton PD’s policy reflects a firm stance against domestic violence involving police officers,
regardless of jurisdiction. When allegations of police officer involved domestic violence arise, swift action

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will be taken to safeguard the victim, apprehend the offender, and conduct thorough internal and criminal
investigations. If an officer is proven guilty of domestic violence in court, their law enforcement authority
may be revoked.

All reported incidents of domestic violence involving members of the law enforcement community will be
diligently investigated by, or under the supervision of, a senior officer. It is the duty of the supervisory
officer to ensure that all necessary enforcement measures consistent with departmental policies and
procedures be taken in response to domestic violence cases. Immediate notification of any domestic
violence incidents involving a department member should be made to the Chief of Police, or their
designated representative, or to the Chairman of the Board of Selectmen if the Chief is directly involved.

There are no exceptions for incidents of domestic violence involving law enforcement personnel from
other agencies within the Town of Canton jurisdiction. Those allegations will be meticulously investigated
under the guidance of a supervisory officer, who is responsible for informing the Chief of Police. Failure to
adhere to the statutory requirements, departmental rules, and policies related to handling domestic
violence situations will result in disciplinary measures. The policy clearly and concisely explains relevant
definitions, pertinent case laws, and mandatory In-Service Training for patrolmen and supervisors.

          RECOMMENDATIONS
          None.

LL. Code of Conduct
The Audit Team reviewed the Canton PD Code of Conduct policy in Section 4.11 of the rules and
regulations. The policy references CALEA Standards 26.0.3 / 26.1.1 / 12.1.3 and 22.3.4. Section 4.11
summarizes the Canton PD approach to discipline and states the policy is to be read in conjunction with
Policy 1.49 Professional Conduct. There are five (5) interdependent disciplinary processes noted within
the policy: Selection, Training, Direction, Supervision, and Accountability.

Key Policy Areas Reviewed
The policy details expectations and standards for professional responsibilities on duty and prohibited
conduct, including conflicts of interest potentially affecting performance of duties. Most notably, officers
are expected to provide assistance when requested in an expeditious manner, maintain appropriate
physical fitness and neat appearance, maintain a knowledge of the Town of Canton community, and state
facts truthfully at all times. Furthermore, professional standards of conduct include standards of care and
security for department issued firearms and awareness of department activities upon entry to duty. To
avoid conflicts of interest or the appearance thereof, the policy provides guidelines for participation in
political activities, outside employment, membership in organizations, testimonials, and gifts. Canton PD
officers are strictly forbidden from using their official position for personal or financial gain, obtaining
special privileges, or avoiding consequences of illegal acts.

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In addition to the professional standards described above, Canton PD officers are expected by policy to be
courteous and considerate to members of the public and their fellow officers. Canton PD officers are
required to demonstrate attention to duty, avoiding activities, such as cell phone use in public, which may
convey a lack of conscientiousness on the part of the officer.

Disciplinary actions addressing failures in any of the above derive from state statute Mass. Gen. Laws Ch.
31 § 43, or other measures deemed appropriate by the Chief of Police. The state statute provides for a
review of disciplinary procedures before the Civil Service Commission and by the state courts when
necessary. Disciplinary actions range from a letter of reprimand to discharge from the department.

          RECOMMENDATIONS
          While the Audit Team has no recommendations as it relates to policy, there are
          recommendations regarding the process and the documentation of both civilian complaints
          and internal affairs investigations. These items are covered in detail in Section 3: Professional
          Standards and Accountability.”

MM. Roll Call Policy
The Audit Team conducted a review of the Roll Call Policy and conducted interviews with the Deputy Chief
of Operations, Deputy Chief of Administration, all patrol sergeants as well as the sergeant of the detective
division. This policy was put into effect in 2010, and has since been evaluated in the years 2014, 2016,
2018, and 2020. Section 4.15 is in alignment with CALEA Standards 41.1.1 / 41.1.2 / 1.3.9 / 12.1.4 / 42.2.6
and 33.5.2.

Roll Call serves as a crucial communication tool between officers on duty and their immediate
supervisors. It also functions as a training tool, facilitating the dissemination of information, directives,
and documents within the department. Moreover, Roll Call is utilized to inspect officers' attire and
equipment, inform the oncoming shift of any significant events, and to encourage constructive feedback
on department policies and activities. The primary method for sharing Roll Call information is through the
dispatch daily log provided by the Station Officer in the form of a briefing to the oncoming shift. To ensure
comprehensive reporting, each log entry should ideally include as many details as possible, such as the
caller's name and contact number, locations of officers dispatched to significant events, as well as the
names and contact numbers of involved parties, witnesses, and/or suspects.

          RECOMMENDATIONS
          None.

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NN. Selection Process
Additional information will be provided to the process and its application in Section 7: Hiring, Training
Standards and Equipment.

Canton PD’s Selection Process policy is detailed in Section 4.16 of the rules and regulations. The policy is
in alignment with CALEA Standards 32.1.1-.4 / 32.2.1-.6 / 16.3.2 and 16.3.8. Rigorous standards for
selection and hiring detailed within the policy demonstrate Canton PD’s commitment to selecting the best
candidates to become Canton PD officers, while ensuring a fair and equitable application process.

Key Policy Areas Reviewed
Selection guidelines are set forth within the policy based upon criteria established by the Town of Canton
Personnel Policy and Police Reform Act (POST) procedures. The following conditions of employment must
exist for an individual to be eligible for application:

•   The individual must pass a national decertification check through MPTC’s Executive Director’s Office.
    Canton PD will not employ a decertified officer in any capacity.
•   The applicant is required to obtain and maintain their certification through POST.

Once a person is certified as eligible, the selectees undergo a screening process to see if they meet the
criteria for employment. The screening process includes notification to the applicants of the selection
process criteria in writing, including the dates and locations of the events, expected duration, and policy
on retesting and reevaluation. Requirements for background investigations, medical examinations,
psychological examination, and physical ability testing are clearly stipulated in the policy.

The selection process includes various activities specified within the policy, including activities such as
passing the Civil Service exam, application packets and interviews, background checks, and psychological
and medical testing. The Chief of Police is responsible for coordinating the selection process and
forwarding the results to the Town Manager.

The Conditional Offer of Employment stage consists of four (4) stages:

•   Academy Trained Candidate (includes an applicant who has already completed a police academy and
    goes straight to a Field Training program).
•   Non-Academy Trained Candidate (applicants who have not completed a police academy have a
    conditional offer of employment pending successful completion of the academy).
•   Probationary Period (all new employees are considered probationary during the first twelve (12)
    months of service with the Canton PD).
•   Performance Review (employees nearing the end of the probationary period receive a standard formal
    performance review).

The Chief of Police makes recommendations to the Town Manager of applicants who have successfully
completed the performance review stage. Applicants who are not chosen will be notified in writing within
thirty (30) days of completion of the process.

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RECOMMENDATIONS
          None.

OO. Dispatch Center Access and Use Policy
The Audit Team reviewed the Dispatch Center Access and Use Policy stipulated in Section 4.22 of the rules
and regulations. The purpose of the policy is to ensure department communications are protected through
security measures detailed within. Section 4.22 is in alignment with CALEA Standards 81.3.1 and 81.3.2.

Existing guidelines within the policy strive to ensure the Dispatch Center environment is conducive to:

           “Minimal distractions of assigned staff, highest levels of officers safety, prompt
          and efficient service to the community and other agencies, [and] accurate
          exchange of information with all involved parties.”

According to the policy, the Dispatch Center is outfitted with bullet proof glass in areas of public access.
Security cameras are, by policy, positioned inside and outside the department to monitor access. The
policy directs that the Dispatch Center must remain free of distractions as it is a hub of communication
between the public and responding personnel.

Overall, the policy clearly states the expectations and standards for ensuring a safe and effective
environment prepared to intake communications from the public and respond accordingly.

          RECOMMENDATIONS
          Access to dispatch is granted to all members of the department as each has a professional
          reason to enter the area. Entering the area of dispatch should be limited to only those
          individuals with a specific assignment or shift duties related to the dispatcher.
          Canton PD should hire full-time in-house dispatchers for all three (3) shifts. In the past six (6)
          months, our team identified three (3) separate occasions where patrol officers failed to
          dispatch officers for calls for service. We also found most neighboring police departments
          similar in size employ full-time dispatchers. [Note: The Audit Team discussed these
          recommendations with Chief Rafferty and Select Board members.]
          Hiring full-time dispatchers for all three (3) shifts will assist patrol officers that currently act as
          dispatchers and perform all functions in the dispatch center.

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PP. School Resource Officer
The Audit Team conducted a review of the Canton PD School Resource Officer policy and interviewed all
four (4) full-time School Resource Officers (SROs) within the Canton PD jurisdiction. It was found that
Canton PD maintains Memorandums of Understanding (MOUs) with both Blue Hills Regional Technical
School and Canton Public Schools, with MOUs being renewed annually. These agreements are governed
by Massachusetts General Laws Chapter 71, Section 37P, as amended by Section 79 of Chapter 253 of the
Acts of 2020, serving to formalize the relationship between Canton PD SROs and the School District.

Under Section 37P of the Massachusetts Law, a School Resource Officer is defined as a duly sworn
municipal police officer or a special officer appointed by the Chief of Police tasked with providing law
enforcement and security services to elementary and secondary public schools. The law stipulates certain
requirements for the selection and training of SROs, emphasizing the importance of fostering an optimal
learning environment through specialized training relating to working with adolescents and children.

The MOUs between Canton PD and the respective schools outlines the goals and objectives of the SRO
program. The SRO program fosters safe and supportive school environments while promoting partnership
communications and procedures for responding to student conduct. An emphasis placed on training for
SROs and school personnel in best practices and appropriate intervention strategies.

As part of the MOUs, leadership from the school districts is required to provide yearly evaluations of the
SRO program and individual SRO performance. Feedback from the Superintendents of Canton Public
Schools and Blue Hills Regional Technical School regarding the Canton PD SROs was overwhelmingly
positive, with the SROs being described as valuable assets to the school communities.

Thank you notes and letters from students in the Canton Public School system to Canton PD SROs

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The interviews with the SROs revealed their dedication to their roles within the community, with examples
of going above and beyond to enhance their skills and support the students. The SROs function as a law
enforcement resource within the schools, providing security, guidance counseling, and informal
education opportunities. They also play a role in community policing by building trust with students and
parents through various interactions.

While Canton PD SROs do not have assigned police cruisers or department-issued phones, they utilize
their personal cars to travel to their assigned schools and have access to school security camera footage
when needed. The SROs primarily wear plain clothes to work with occasional use of uniforms and engage
in various activities within the schools to support students and enhance safety.

Overall, the audit findings indicated a positive and collaborative relationship between Canton PD SROs
and the school districts, with a focus on creating a safe and supportive environment for students.

Key Findings
The Canton PD employs four (4) full-time School Resource Officers (SROs) who are assigned to various
levels of schools, including high school, middle school, and elementary schools. These officers are
responsible for tracking student arrests and civilian contacts within the school environment. Their primary
objective is to maintain a safe and secure learning environment so that teachers can focus on teaching
and students can engage in learning effectively. The SROs also strive to be positive role models for
students by developing relationships built on trust and fostering positive interactions. SROs collaborate
with faculty and the administration team to deliver safety education programs and provide a visible law
enforcement presence on school grounds to address any necessary law enforcement actions.

The Superintendent of Schools works with the SROs, reporting any student arrests or issues to ensure a
coordinated approach to school safety. The SROs monitor activities on school grounds by keeping track of
student contacts. They are also deployed in uniform and undercover at school sporting events to help
identify and address any potential issues involving students and external influences.

The Canton PD Policy and Procedures No. 4.26, directs SROs report to the Chief of Police through their
supervisory chain of command and are required to comply with all department policies. Additionally, while
on duty at their assigned school, SROs have a secondary chain of command that starts within the school
staff, from assistant principal(s) to the School Principal, up to the Canton Superintendent of the School
District.

Given their dual role within the police department and school environment, SROs are mandated to
participate in mandatory in-service training programs sponsored by the Municipal Police Training
Committee, as per Massachusetts General Laws Chapter 6 Section 116H.

          RECOMMENDATIONS
          Currently, one (1) officer is assigned and responsible for covering three (3) elementary schools
          in the Town of Canton. While this officer excels at coordinating his presence at each school and
          varying his whereabouts unpredictably, it is logistically impossible for him to be in three (3)

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places simultaneously. It is advisable for additional resources to be assigned so that each
          school can have its own officer present to ensure student safety.

QQ. Professional Conduct
The Audit Team reviewed the Professional Conduct policy in Section 4.28 of the rules and regulations. The
policy is in alignment with CALEA Standards 12.1.3 / 22.3.4 and 26.1.1 and states its purpose of ensuring
professionalism, ethics and integrity of Canton PD officers in the performance of their duties.

Key Policy Areas Reviewed
Canton PD officers are required to hold themselves to the professional standards of conduct as defined in
Section 4.28 at all times on and off duty. Professional standards set forth within the policy include
guidelines on the following.

Key Policy Areas Reviewed
•   Officers are expected to maintain a professional uniform and appearance with cognizance of public
    perception.
•   Employees have a right to privacy in their off duty conduct to the extent that it does not affect the
    employee’s ability or fitness for duty.
•   Officers are to keep from unbecoming conduct. While examples of “unbecoming conduct” are not
    explicitly outlined within the policy, it is defined as a “catch all” provision including conduct that is of
    such nature that would “alert a reasonable employee that their conduct under the circumstances
    would be inappropriate.” This provision exists to note the importance of employees understanding that
    their connection to Canton PD does not stop while on duty but continues through their personal life.
    Therefore, Canton PD employees must refrain from conduct which “tends to indicate that the
    employee is unfit to continue as a member of the Department, or tends to impair the operation,
    morale, integrity, reputation or effectiveness of the Department or its members.”
•   Officers are expected to avoid all situations where conflicts of interest exist – both in fact and
    appearance – keeping in mind their position of public trust. M.G.L. c. 268A is provided as a guide
    concerning situations giving rise to conflicts of interest.
•   Canton PD officers must avoid membership in organizations that would interfere with the performance
    of their duties as well as associations with persons who they know or should know, are under criminal
    investigation.
•   The policy reiterates that Canton PD employees are prohibited from seeking undue influence, buying,
    selling, or receiving anything from complainants, suspects, defendants, witnesses, etc., or making any
    arrangement that permits a person from escaping penalty for wrongdoing.
•   Canton PD employees may not use Department letterhead for private correspondence, nor use the
    department mailing address for private purposes without the permission of the Chief of Police.
•   The Chief of Police must approve any off-duty employment.

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•   Canton PD Officers must abide by “Amanda’s Law” C. 271 Section 51, which prohibits taking or
    transmitting images of crime victims by first responders.
•   The Professional Conduct policy strives to ensure Canton PD Officers conduct themselves in such a
    way as to perform their official duties in a manner that demonstrates respect and earns the public
    trust.

          RECOMMENDATIONS
          None.

RR. Special Operations
The Audit Team reviewed the Special Operations policy as defined in Section 7.01 of the rules and
regulations and in alignment with CALEA Standards 2.1.3 / 2.1.4 / 11.4.4 / 22.3.1 / 33.6.2 / 41.2.4 / 41.2.5 /
46.1.2 / 46.2.1 / 46.2.2 / 46.2.3 / 46.2.5 / 46.2.6 and 46.2.7. The purpose of the policy is to provide
guidelines for preparation for and response to emergencies and disasters.

Key Policy Areas Reviewed
Special Disaster or Emergency Planning

Section 7.01 requires the Canton PD to respond to emergencies and disasters, obtain appropriate
resources, and address emergencies in a manner that preserves life, peace and property. The policy cites
an “All Hazards Plan” that is in place for responding to general emergencies and disasters. The policy
defines four (4) categories of events requiring special disaster or emergency planning: a breach of the
peace, civil disturbances, disasters, and unusual occurrences. Expectations and guidelines for the initial
response to an emergency are detailed within the policy.

Emergency Situations

The policy cites M.G.L. c41 s98 as a basis of authority for standards in responding to emergency
situations. The statute gives police officers authority to suppress and prevent disturbances and disorder,
disperse any assembly of three (3) or more persons, and to enter any building to suppress a riot or breach
of the peace therein.

In the event a situation arises to an unmanageable level, the policy states that the Chief of Police may
request assistance from the National Guard. If a state of emergency is declared or requested, Canton PD
must assign an officer to be the liaison to the Officer of the Adjutant General to assist with coordinating
response efforts.

Tactical teams are available for assistance as well. Canton PD relies on outside tactical teams such as
METRO-LEC, according to the policy. Patrol forces are responsible for maintaining security until the
outside tactical teams have arrived. The policy dictates the information to be gathered by Canton PD
officers in preparation for a tactical team response. Canton PD allows for certain officers to be assigned to

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the METRO-LEC tactical team when specific standards are met, as defined within the policy, and pursuant
to approval from the Chief.

Special Events

Canton PD policy provides for a Special Event officer-in-charge to be appointed on the occasions of
special events or activities occurring within the Town of Canton, including parades, sporting events, or any
other event that requires advanced special planning. The policy outlines the responsibilities and
expectations of the Special Events officer with the goal of ensuring community safety and traffic control.

Overall, the policy establishes protocol for preparing for emergencies, disasters, and special events of
varying nature. Canton PD officers are given clear and detailed guidance on law enforcement procedures
when responding to such events, with a clear emphasis on community safety.

          RECOMMENDATIONS
          None.

SS. Compliance with CALEA Standards on Specified Policies and Procedures
The Audit Team recently reviewed the CALEA Standards to assess the Canton PD's compliance thereto.
CALEA Standards enhance public safety services by setting best practices, promoting excellence, building
public trust, and identifying areas for improvement. The department received its Initial Accreditation in
November 2007 and has been reaccredited multiple times since, with the latest being in 2021. CALEA
currently offers two (2) Tiers of accreditation, with Tier 2 requiring compliance with 483 standards and Tier
1 with 183 standards. In addition to CALEA, the police department has been MPAC certified, and received
the MPAC award in 2014 and 2018.

The CALEA accreditation is voluntary and typically takes up to twenty-six (26) months to complete. The
MPA Commission offers two (2) tiers of professional credentialing programs, Certification and
Accreditation, with the latter consisting of 216 standards, of which 96 are mandatory and 120 are optional.

Findings from the recent audit show that the Canton PD does not currently hold a CALEA accreditation.
Although the department's written Policies and Procedures align with the CALEA standards, the
accreditation has not been consistently renewed annually over the past 17 years.

          RECOMMENDATIONS
          The Audit Team recommends updating the CALEA accreditation or incorporating MPAC
          standards into the existing Policies and Procedures.
          Furthermore, a comparison between CALEA and MPAC standards reveals that while both
          organizations assess law enforcement agencies, they serve different purposes with varying

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assessment methods. CALEA aims to improve public safety services through professional
          standards, while MPAC assesses a wide range of performance metrics.
          It is advised that the Canton PD take steps to address the discrepancies in accreditation and
          standards compliance to ensure accountability and adherence to best practices in law
          enforcement.

TT. Officer Personal Vehicle Use
The Audit Team reviewed the Canton PD policy on Canton PD equipment, specifically department vehicle
use for the Canton Police Department: Rules, Regulations and Policies booklet, Section IV “General,
Employment and Operations” subsection P. “Equipment.” The policy prohibits any member of the Canton
PD from misusing or abusing a city-owned vehicle and requires that all accidents involving a police vehicle
be investigated by an outside agency.

Canton PD’s rules and regulations Section 4.14 discusses Police Vehicle Readiness and aligns with CALEA
Standards 41.1.3 / 41.3.1 / 41.3.2 / 41.3.3 / 41.3.5 and 61.3.3. The policy references Massachusetts
General Laws Chapter 89, Section 7-B as a guideline for driving operations of a police vehicle. Regarding
personal use of police vehicles, the policy notes that no person shall be permitted to be an occupant or
ride in the department vehicle, except when necessary for the performance of duty, or otherwise approved
by the Chief of Police.

The Audit Team reviewed the “Town of Canton Contract of Employment – Police Chief” as it relates to
vehicle use. The contract stipulates that the Chief of Police is authorized to use a municipally supplied
vehicle for her unrestricted personal use as well as commuting to and from work, consistent with rules and
regulations established from time to time by the Select Board.

Canton Police Department Rules and Regulations Section 4.3, “Use of Department Vehicles/Equipment”
states Canton PD officers are not permitted to use any department vehicle outside of regular shift duties,
or on a detail, without the prior approval of the Deputy Chief of Operations. Officers assigned a take home
vehicle may not use the vehicle for “personal use” unless approved in their union or personal contract.

          RECOMMENDATIONS
          None.

Section 1: Policies, Procedures and Regulations · PDF text layer

UU. Overtime Policy and the Adherence of the Overtime
Contract Rules regarding “Minimum Manning” play a critical role in expenditures of the overtime budget.

From July 1, 2024, through December 31, 2024, Canton PD expended $142,462.81 (12101-51320) to fill
shift work for officers using sick, vacation and personal days. [Note: One (1) sergeant is on military leave.]

In addition, Chief Rafferty utilized forfeiture funds, $378,244 from the Equitable Sharing Funds to fund
overtime expenses for shift work.

Line-item overtime includes vacation, administrative leave, military leave, and detective overtime for
investigations.

Patrol Shift Minimum Manning
•   Day Shift – Four (4) patrol officers and one (1) sergeant.
•   Second Shift – Four (4) patrol officers and one (1) sergeant.
•   Third Shift – Three (3) patrol officers and one (1) sergeant.

One (1) additional patrol officer serves as a dispatcher on all three (3) shifts. Due to staff shortages,
military leave, sick time, and vacation time, a shortage of patrol staffing results in overtime for patrol
officers and sergeants.

Deputy Chief of Police Thomas Keleher audits overtime expenditures on a quarterly basis.

          RECOMMENDATIONS
          As stated in Section 6: Management Operations and Culture, we recommend adding additional
          officers to the organization table once the department gets to full staff. The additional officer
          positions will reduce the amount of overtime funding required now to meet minimum staffing
          requirements.

VV. Use of Personal Cell Phones
The Audit Team reviewed Canton PD policy 2.12: Guidelines and Policies Concerning Personal cell
phones. Every employee (officer) must possess a mobile phone for departmental communication
purposes and must promptly inform the department of any changes to their contact number. The Audit
Team found that Canton PD officers are in compliance with this policy. Officers often utilize personal
phones to photograph crime scenes, which is only permissible as a last resort under current policy and
procedure No 6.01.

Equipment, Telephone and Radio Use Including Personal Cell Phone Policy
The Canton PD has a policy regarding the use of personally owned equipment or devices for photographing
evidence at crime scenes. The policy states that personal cell phones can be used as a last resort when

Section 1: Policies, Procedures and Regulations · PDF text layer

department-issued equipment is not available. However, during an audit, it was discovered that officers
and detectives were not provided with department-issued mobile phones.

Following a meeting between Chief Rafferty, Select Board Chair Michael Loughran, and the Audit Team, it
was recommended that all Canton PD officers should be equipped with department-issued mobile
phones. As a result, in January 2025, Chief Rafferty issued mobile cellular phones (Apple iPhones)
specifically for the detective division. A new policy was implemented to ensure that only department-
issued mobile phones are used to photograph evidence at crime scenes, in accordance with policy 83.2.2,
which states that digital cameras should be used for this purpose. The Audit Team interviewed department
employees who stated that often they utilize personal phones or laptops to photograph crime scenes. The
Audit Team recommended that all Canton PD sergeant vehicles should be equipped with digital cameras,
and mobile phones be issued to all Canton PD officers.

          RECOMMENDATIONS
          The Audit Team found that Canton PD officers are permitted to use personal phones for
          contacting witnesses or confidential sources during the course of their duty and utilizing
          personal phones and to photograph crime scenes as a last resort when department cameras or
          computers are not available. This is an alarming practice that has become routine out of
          necessity.
          It is recommended that all officers of the Canton PD be issued departmental phones. At a
          minimum, all officers at the rank of sergeant and above, as well as the detectives in the
          investigative division should be issued departmental phones. The issues taking place in current
          prosecutions clearly demonstrate the need to have departmental phones, as well as the
          negative consequences of utilizing personal phones for investigative work.

Section 1: Policies, Procedures and Regulations · PDF text layer

SECTION 2:
 Crime Scene Protocols Overview

                                                     Image source: Boston Herald

Section 2: Crime Scene Protocols Overview · PDF text layer

SECTION 2: CRIME SCENE PROTOCOLS OVERVIEW
An audit was conducted to review the crime scene protocols, policies, and compliance standards in place
at the Canton PD at the time of various incidents. The Audit Team assessed various aspects related to
crime scene investigation procedures, evidence collection, preservation, and adherence to industry
standards. The review included staffing of trained detectives, equipment, crime scene documentation and
existing protocols for responding to crime scenes in inclement weather.

a) Analysis of Crime Scene Protocols:

The Audit Team reviewed Canton Police Department (Canton PD) Policy and Procedure, specifically
focusing on Evidence Collection No. 6.01 dated October 31, 2013. The policy outlines the responsibilities
of first responders, including evidence preservation and protection of the crime scene. Policy designates
the sergeant or shift commander to take command of crime scenes and mandates the involvement of
trained personnel for evidence collection. Canton PD collaborates with external agencies like Plymouth
County Sheriff’s Office and Massachusetts State Police (MSP) for crime scene processing.

b) Evaluation of Adherence to Procedures:

The Audit Team carefully examined a set of crime scene incident reports spanning ten (10) years. While
some investigations were found to be within policy guidelines others violated protocols and policy. The
Audit Team found failures in compliance with existing Canton PD policies regarding crime scene
documentation, photography, processing, and preservation as required by Canton PD's Evidence
Collection and Preservation Policy.

c) Assessment of Evidence Collection and Compliance:

The Bureau of Criminal Identification Unit at Canton PD is responsible for maintaining a Crime Scene
Search Kit for evidence processing. Canton PD has agreements with the Plymouth County Sheriff’s Office
and the MSP for utilizing their crime scene technicians in cases where additional capabilities and expertise
are deemed necessary. Notification to and relinquishing the investigation to the MSP is mandatory in
instances involving unattended deaths as mandated by Massachusetts Law.

d) Establishment of Protocols for Inclement Weather:

Updated protocols related to evidence collection and preservation, including procedures for handling
crime scenes in inclement weather, were introduced by Chief Helena Rafferty on October 31, 2023. These
protocols align with CALEA standards and best practices.

e) Review of Documentation Practices:

Documentation practices related to crime scene investigations, evidence processing, civilian complaints,
and internal affairs investigations were thoroughly examined during the audit and detailed in Sections, 2,
3, and 14. The Audit Team reviewed the crime scene response and investigative procedures carried out by
Canton PD officers in relation to incidents involving Boston Police Officer John O’Keefe's severe injury and
subsequent death on January 29, 2022 at 34 Fairview Road. The team compared these actions to
established policies, regulations, and requirements to assess compliance. Moreover, the audit included a

Section 2: Crime Scene Protocols Overview · PDF text layer

review of Canton PD's crime scene response and investigative steps following the Sandra Birchmore death
investigation on February 4, 2021.

f) Review prior crime scene training and suggest recommended training and process improvements:

While newly promoted Sergeant’s receive additional formal training, Canton PD officers promoting into the
position of detective receive no additional formal training. The Audit Team recommends formal training in
the areas of: Crime Scene Preservation, Crime Scene Photography, Electronic Communications and
Exploitation, Interviewing Techniques, Crime Scene Documentation, Evidence Collection and Legal
Admissibility.

Section 2: Crime Scene Protocols Overview · PDF text layer

January 29, 2022

Case File Audit of the
Death of Boston Police
Officer John O’Keefe

                                                                      Boston Police Officer John O’Keefe

As requested by the Canton Police Audit Committee and Canton Town residents, the Audit Team reviewed
the initial police response, crime scene investigative actions, police reports, evidence collection, and
evidence documentation to ensure policy and procedures were followed by Canton PD surrounding the
death investigation of Boston Police Officer John O’Keefe.

Photo Taken on February 2, 2022, of 34 Fairview Road, Canton, MA by Craig Walker, Boston Globe, Getty Images

Section 2: Crime Scene Protocols Overview · PDF text layer

Canton PD Calls for Service at 34 Fairview Road, Canton, MA., on January 29, 2022

    05:04 a.m.      •   Canton PD receives a call on                            Audio clip of the Canton PD
                        January 29, 2022, at approximately                      call placed by Ms. Roberts to
                        05:04 a.m., Kerry Roberts called the                    report that Mr. O’Keefe had not
                        Canton Police Department (Canton                        returned home:
                                                                                https://drive.google.com/file/d/
                        PD). Ms. Roberts reported that Mr.                      1hQtIeFc4mSnoYWSCYfnD23G
                        O’Keefe had not returned home the                       f68RZLDPl/view
                        previous evening. Reference is
                        made to call for police on January 29, 2022, by Ms. Roberts.
    06:04 a.m.      •   Norwood PD/Canton PD received a                            Audio clip of the 911 call
                        911 call for police from Jennifer                          placed by Ms. McCabe on the
                        McCabe, who reported that there                            morning of January 29, 2022 at
                        was a guy unresponsive in the                              34 Fairview Road:
                        snow at 34 Fairview Road. Ms.                              https://drive.google.com/file/d/
                                                                                   1sLUL4dJQ2m7wrJIZ78nCxmp
                        McCabe identified the male as                              5Ibpl8Alv/view
                        John O’Keefe.
                    •   Ms. McCabe’s call was passed over to Canton Fire Rescue Emergency Medical
                        Service (EMS) wherein Ms. Mcabe stated she thinks he [Mr. O’Keefe] passed away.
                        Reference is made on the 911 call to police.
                    •   Sergeant Goode dispatches Officer Saraf and Mullaney to 34 Fairview Road.
                    •   Sergeant Goode notifies Sergeant Lank and Lt. Gallagher to respond.
    06:09 a.m.      •   Canton PD Officer Steven Saraf arrives at 34 Fairview Road, observed Ms. McCabe,
                        Karen Read and Kerry Roberts, who were over the body of John O’Keefe, performing
                        CPR. They reported he was not breathing. Officer Saraf noted Mr. O’Keefe was
                        bleeding and his skin was cold to the touch. Moments later, Canton Fire responded
                        and took over first aid response. Officer Saraf reported Karen Read was distraught
                        and could not tell him what happened.

    06:12 a.m.      •   Canton PD Officer Mullaney arrived and observed a female conducting CPR on John
                        O’Keefe. Officer Mullaney reported he arrived in concert with fire rescue personnel
                        and assisted them with placing John O’Keefe in the rescue. Officer Mullaney
                        reported Ms. Read was hysterical and made statements such as “Is he dead” and
                        “that’s my boyfriend.”
                    •   Officer Mullaney reported that Sergeant Goode told Ms. Roberts to take Ms. Read
                        home.
                    •   Officer Mullaney reported Read’s father called Canton PD and reported Karen Read
                        was suicidal and Sergeant Goode ordered Ms. Roberts to return to the scene with
                        Ms. Read.
                    •   Ms. Read was then recommended for medical evaluation, Section 12, and
                        transported to Good Samaritan Hospital for evaluation.

Section 2: Crime Scene Protocols Overview · PDF text layer

06:12 a.m.      •   Canton Fire Department and Emergency Medical Service (EMS) arrived and
                        rendered first aid to Mr. O’Keefe
    06:14 a.m.      •   Canton PD Sergeant Sean Goode arrived at the scene and noted that Mr. O’Keefe
                        was in the ambulance (rescue) with paramedics. Ms. McCabe, Ms. Read, and Ms.
                        Roberts were standing outside the rescue.
                    •   Sergeant Good reported that he asked Ms. Read how she arrived at 34 Fairview Road
                        and Ms. Read stated “I don’t know.”
                    •   Sergeant Goode reported that Ms. Read was yelling and was acting hysterical,
                        stating “is he dead?” Sergeant Good reported that he asked Ms. Read if she drove to
                        34 Fairview Road last night and she replied “I think so” and “I can’t remember.”
                    •   Ms. Read and Ms. McCabe were placed in the backseat of patrol car 682.
                    •   On scene, Ms. McCabe provided Sergeant Goode with a timeline of events leading
                        up to the discovery of John O’Keefe.
                    •   Sergeant Good reported that he interviewed Ms. Roberts on scene and she gave him
                        a timeline of events that led her to 34 Fairview Road.
    06:24 a.m.      •   Canton PD Detective Sergeant Lank arrived at the scene and took command.
                        Sergeant Lank noted that Ms. Read was hysterical and attempts to obtain a
                        statement from her were unsuccessful. According to the officers on scene, Ms. Read
                        mentioned that she did not remember being at 34 Fairview Road.
    06:38 a.m.      •   Sergeant Lank contacted MSP CPAC Unit and briefed a summary of the condition of
                        John O’Keefe. Sergeant Lank receives a return call from Trooper Michael Proctor
                        who was briefed on the situation.
                    •   While Canton PD Officers were at the
                        scene, they reported they heard Ms. Read
                        make statements, such as “is he going to
                        die?” and “is he dead?” and further noted
                        that Ms. Read was hysterical. Sergeant
                        Lank noted that Sergeant Goode advised
                        that Mr. O’Keefe had been bleeding from
                        his nose and mouth, and had swelling
                        around his eyes.
                    •   Sergeant Lank took a statement from
                        Jennifer McCabe who provided a timeline     Canton PD Dashcam Photo of MS. Read on
                                                                    the roadway in front of 34 Fairview Road on
                        of the events that led Ms. McCabe, Ms.
                                                                    the morning of January 29, 2022.
                        Roberts and Ms. Read to 34 Fairview
                        Road.
                    •   After taking a statement from Ms. McCabe on scene, Sergeant Lank reported he
                        contacted the owners of 34 Fairview Road, Brian and Nicole Albert, who provided
                        statements. [Note: Matthew McCabe was at 34 Fairview Road at this time and gave a
                        statement to Sergeant Lank.]

Section 2: Crime Scene Protocols Overview · PDF text layer

09:00 a.m.      •    Sergeant Lank was contacted at Canton PD by Ms. McCabe who requested Sergeant
                         Lank return to 34 Fairview Road. Sergeant Lank and Lieutenant Paul Gallagher
                         responded to 34 Fairview Road, and spoke to Ms. McCabe who advised that when
                         Ms. McCabe, Ms. Roberts and Ms. Read were driving around looking for John
                         O’Keefe, Ms. Read stated something to the effect “I hope I didn’t hit him,” and
                         believed Ms. Read made these statements on scene in the presence of a police
                         officer. [Note: This information is documented in Sergeant Lank’s police report and
                         supplemental narrative report of events.]
Approximately       •    Canton Fire Rescue transported Mr. O’Keefe to the Good Samaritan Hospital in
   06:24 a.m.            Brockton, MA.
                    •    Canton Fire Rescue transported Ms. Read to the hospital for evaluation after her
                         father William Read called Canton PD and claimed she was suicidal.
    07:50 a.m.      •    Mr. O’Keefe is declared dead at Good Samaritan Hospital.

34 Fairview Road Crime Scene Search
Canton PD Detective Team: Sergeant Sean Goode, Sergeant Michael Lank and Lieutenant Paul Gallagher.
[Note: Sergeant Lank notified MSP Norfolk County Investigative Unit at 06:38 a.m., who reported they were
not responding to the scene.]

Canton PD Photos of 34 Fairview Road, and the location of Mr. O’Keefe taken on January 29, 2022

Section 2: Crime Scene Protocols Overview · PDF text layer

Lieutenant (Lt.) Paul Gallagher arrived at 07:00 a.m. and was brought to the area where John O’Keefe’s
body was found.

Due to the heavy snow and
winds, detectives utilized a leaf
blower to identify evidence.

Canton PD took photos and
videotaped the evidence
collection. Both Sergeant Lank,
Sergeant Goode, and Lieutenant
                                Photo taken on January 29, 2022, at 34    Canton PD Lieutenant holding the
Gallagher searched the area     Fairview Road, Canton PD crime scene      cocktail glass seized from the
and discovered a broken         search using a leaf blower.               yard at 34 Fairview Road.
drinking glass and small
amounts of blood. Canton PD detectives reported that they only searched an area around where Mr.
O’Keefe’s body was found which would not have encompassed the entire yard area.

Canton PD detectives secured the blood evidence in red solo cups and placed them in a Stop & Shop
grocery bag. The drinking glass was secured in an evidence bag, and all evidence was taken to Canton PD.
The cocktail glass was turned over to the MSP crime technicians for testing on February 1, 2022.
Detectives said the blood evidence was secured in a refrigerator in the evidence/property room. MSP
crime lab technicians took custody of the evidence on February 1, 2022.

Thomas Keleher, Canton PD Deputy Chief of the Investigative Division, who resided across the street from
34 Fairview Road provided the solo cups to detectives. Deputy Chief Keleher recused himself from the
investigation because he knew the Albert family, who were the owners of the home at 34 Fairview Road.

Canton PD detectives cleared the scene at 34 Fairview Road sometime after 08:00 a.m. and responded to
the Canton PD with the evidence collected.

Later in the morning, at approximately 0900 a.m., Ms. McCabe called Sgt. Lank at the Canton PD and
asked him to come to 34 Fairview Road. Minutes later, Sgt. Lank and Lieutenant Gallagher responded to 34
Fairview Road and were met by Ms. McCabe who reported that she recalled when Ms. Read was driving
with her (Read) she said something to the effect of “I hope I didn’t hit him.” Ms. McCabe said Read also
made the same statements at 34 Fairview Road when they (Read, Roberts and McCabe) found John
O’Keefe. [Note: This information was documented in Sgt. Lank’s investigative reports].

Canton PD Detectives said they did not have probable cause to obtain a search warrant and did not
request permission to search the Albert house, as they had no information that Mr. O’Keefe ever entered
the home at the time.

[Note: A search warrant infringes on an individual's Fourth Amendment rights and requires substantial
evidence or witness testimony, neither of which was present in this case. Moreover, Canton PD did not
seek permission to search the house as there was no indication that Mr. O’Keefe was inside, or that a crime
had occurred inside the house.]

Section 2: Crime Scene Protocols Overview · PDF text layer

c

                                      b

                  a

                                                                                                      a

Ring Camera Photos of Ms. Read’s Lexus SUV [a], Ms. Roberts SUV [b], and Mr. O’Keefe’s SUV [c] at Mr. O’Keefe’s house at
around 05:35 a.m. on January 29, 2022.

At approximately 08:23 a.m., Canton PD officers
responded to the O’Keefe residence at 1 Meadow
Lane and conducted a check on the well-being of
Mr. O’Keefe’s niece.

Ms. Read’s Lexus SUV is pictured parked in the
driveway. After leaving the hospital, Ms. Read,
along with her family, went to 1 Meadow Lane and
recovered her Lexus SUV LX 570.

Karen Read Arrested
On February 2, 2022, Ms. Read was arrested by
Massachusetts State Police and was charged with Canton PD Dashcam photo of Ms. Read’s Lexus SUV on
                                                    January 29, 2022, at approximately 08:23 am., at Mr. O’Keefe’s
manslaughter, motor vehicle homicide, and           driveway.
leaving the scene of a motor vehicle collision
causing death. On June 10, 2022, a Norfolk County grand jury indicted Ms. Read on charges of second-
degree murder, manslaughter while operating under the influence of alcohol, and leaving the scene of
personal injury and death.

Attorneys for Ms. Read claimed that Mr. O’Keefe was assaulted, and his body was later placed outside of
34 Fairview Road, Canton, MA, as part of an alleged a coverup by law enforcement.

[Note: Our team has not discovered any information that would indicate that any actions by Canton PD
officers or detectives were a part of a conspiracy to frame any individual for the murder of Mr. O’Keefe.]

Ms. Read’s first trial in Stoughton District Court ended on July 1, 2024, in a mistrial. Ms. Read faces a
second trial beginning on April 1, 2025.

Section 2: Crime Scene Protocols Overview · PDF text layer

Video (files) Footage Evidence of Karen Read’s Lexus SUV 570 at Canton PD Sallyport
On January 29, 2022, MSP executed a search warrant for Ms. Read’s Lexus Sports Utility Vehicle (SUV) in
Dighton, MA at Ms. Read’s parents' home. The Audit Team found MSP requested that Ms. Read’s vehicle be
brought back to Canton PD. Chief Rafferty said this request was granted because the Canton PD is near
the Norfolk District Attorney's Office and MSP did not have adequate temperature-controlled storage
facilities close-by. MSP coordinated for the Lexus SUV to be towed to the Canton PD garage and arrived at
the Canton PD garage at approximately 5:35 p.m. on January 29, 2022.

Canton PD video cameras documented the Lexus SUV arriving at the Canton PD sallyport on January 29,
2022. Shortly thereafter, MSP and Canton PD secured the vehicle with yellow tape (surrounding the SUV).

[Note: MSP crime scene technicians searched and processed the vehicle on February 1, 2022. Canton PD
acknowledged and the Town of Canton has confirmed that one camera in the sallyport records abnormally
in a mirrored fashion. Three (3) cameras in the Town of Canton have been found to have this issue and this
camera malfunction is not isolated to only the Canton PD cameras.]

Photos from video footage of Ms. Read’s Lexus SUV at the Canton PD sallyport on January 29, 2022

Photo of Ms. Read’s SUV in the sallyport                      Outside photos of the Canton PD garage

The Audit Team interviewed the Town of Canton Information Technology (IT) Specialist who stated that the
Canton PD building has twenty-eight (28) cameras that are placed both inside and on the exterior of the
building, including in the sallyport garage. The IT Specialist said most of the cameras installed are analog
cameras (low resolution) and have been in place for many years.

Section 2: Crime Scene Protocols Overview · PDF text layer

Cameras located inside of the sallyport at Canton PD, and inside view of Bay #3

As part of the audit, a Canton PD Sergeant (retired) met with the Audit Team and advised he downloaded
camera footage videos related to Karen Read’s Lexus SUV. Chief Rafferty said the vehicle was in the
custody of Canton PD from January 29, 2022, until February 2, 2022.

The Audit Team also reviewed a memorandum sent to Chief Helena Rafferty on February 27, 2025, that
detailed the following in summary.

Canton PD Sergeant wrote, beginning in February 2022, MSP Troopers requested copies of video from the
Canton PD sallyport from January 29, 2022. Canton PD downloaded Video (1) and provided the exhibit to
MSP.

In June 2023, again MSP requested video footage of Ms. Read’s Lexus SUV being brought into the Canton
PD sallyport, specifically the outside camera footage. The Canton PD Sergeant stated he downloaded all
video recordings that covered the period that Ms. Read’s Lexus SUV was held at Canton PD. [Note: Due to
the large size of the files, a Canton PD Sergeant separated the videos and saved them into six (6) hour
blocks. The outside video footage was relinquished to the custody of the MSP.]

In April 2024, while Ms. Read’s trial was being held, Chief Rafferty directed the Canton PD sergeant to
download additional video footage from January 29, 2022, (the early morning hours footage) because it
showed ATF Special Agent Brian Higgins arriving at Canton PD. The video was downloaded and turned over
to the MSP. On or about January 24, 2025, Canton PD produced another video of Ms. Read’s Lexus SUV
arriving at the Canton PD sallyport on January 29, 2022, and the video was downloaded and turned over to
the MSP.

The Audit Team learned that the video footage files related to Ms. Read’s Lexus SUV were saved in Canton
PD computer database folders. The Audit Team was informed that all video evidence saved related to Ms.
Read’s Lexus SUV was on a Canton PD workstation computer. Chief Rafferty confirmed no personal
computers were utilized for video storage and/or used for any file storage.

Section 2: Crime Scene Protocols Overview · PDF text layer

Canton PD confirmed all video files turned over to MSP or the Norfolk County District Attorney’s Office
were downloaded on a compact disc or USB device.

Secondary Search of 34 Fairview Road
The Audit Team learned from Canton PD that on January 29,
2024, at approximately 5:45 p.m., MSP Special Emergency
Response Team (SERT) conducted a second search at 34
Fairview Road. During that search, pieces of a red plastic
taillight were recovered in addition to a Nike shoe. Over the
next several days, as the snow melted, numerous taillight
pieces were recovered at 34 Fairview Road by investigators
informally as they traversed the area. Approximately 45
pieces in total were discovered. Conditions at the scene of
the search were less than ideal. Significant snowfall had
accumulated with the center of the street being plowed,                 Pieces of a red taillight next to the hydrant at the
                                                                        edge of the property line for 34 Fairview Road
pushing snow to the side of the road. [Note: The snowstorm
accumulated at least 20 inches of snow in Canton, MA.]

                                  A taillight and a Nike shoe seized at 34 Fairview Road

On February 4, 2022, at 8:50 a.m., Canton Police Chief Kenneth Berkowitz summoned Sgt. Lank to 34
Fairview Road to retrieve pieces of what he believed to be part of a red plastic taillight near where John
O’Keefe was discovered. Sgt. Lank along with a Canton PD Detective responded to 34 Fairview Road and
maintained a presence and took photos until Massachusetts State Police Trooper Yuri Bukhenik
responded and took custody of the evidence.

Observations and Findings
Canton PD detectives did not have access to evidence collection kits (in Canton PD vehicles or at the
Canton PD headquarters) to secure the blood evidence located near the body of Mr. O’Keefe at 34 Fairview
Road. Canton PD detectives stated they only utilized solo cups as a last resort to preserve the forensic
evidence until it was transferred to the MSP crime scene forensic unit.

Section 2: Crime Scene Protocols Overview · PDF text layer

The Audit Team found Canton PD did not follow policy and procedures related to evidence collection and
preservation. The Audit Team found that there were no Bureau of Criminal Identification Unit(s) initially on
scene, nor were crime scene kits available or used for evidence collection. [Note: According to the
Massachusetts Crime Lab, plastic is not recommended for packaging or storing moist or wet evidence
items due to the acceleration of the decomposition of biological materials on the evidence.]

•   No photos were taken of John O’Keefe (exact location of where his body was found) by Canton PD
    officers at 34 Fairview Road.
•   Canton PD officers used personal phones to photograph and video the evidence collection at 34
    Fairview Road. Pursuant to Canton PD policy, a digital camera or laptop computer should have been
    used to photograph the crime scene.
•   Canton PD first officer on the scene should have photographed John O’Keefe where he was found
    before he was moved by fire rescue to the ambulance.
•   Jennifer McCabe and Kerri Roberts should have been interviewed (and the interviews should have
    been recorded) at the Canton PD after Mr. O’Keefe was taken to the hospital. Both witnesses
    accompanied Ms. Read and drove with Ms. Read to 34 Fairview Road.
•   Nicole and Brian Albert should have been interviewed at Canton PD.
•   Both MSP and Canton PD failed to maintain police presence at 34 Fairview Road to maintain the
    integrity of the crime scene. Both agencies should have coordinated to have an officer(s) maintain a
    presence at 34 Fairview Road, pending the second search by MSP.

The Audit Team found there was incomplete
coordination requesting all video files in the custody of
Canton PD regarding the Canton PD sallyport camera
footage of Karen Read’s Lexus SUV. The vehicle was
maintained from January 29, 2022, to February 2, 2022,
at Canton PD.

ALL video footage (files) maintained on Canton PDs
computer systems of Karen Read’s Lexus SUV while it
was housed at Canton PD from January 29 through
February 2, 2022, should have been requested and
turned over early in the Karen Read case to lead
investigators for any action as deemed appropriate.

Due to the blizzard conditions on the morning of January
29, 2022, and the coordination of personnel, the MSP
waited until after 4:45 p.m. to begin coordinating a
secondary search of the crime scene at 34 Fairview
Road.

•   Each piece of evidence should be carefully logged        The National Weather Service broadcasted a severe
    and tracked to establish the timeline of its handling.   blizzard warning for Canton, Massachusetts
                                                             recommending travel only in emergency circumstances.

Section 2: Crime Scene Protocols Overview · PDF text layer

Officers should refrain from using personally owned phones to video or photograph crime scenes.
•   Once evidence is processed, it should be stored in a secure and controlled environment, such as an
    evidence room with restricted access.
•   If there is any doubt about the legal requirements, it is essential to consult with the department’s legal
    advisors to ensure the integrity of the investigation.

          RECOMMENDATIONS
          Recommendation 1:
          Increase training opportunities for patrol officers and sergeants to access crime scene
          management training and witness interview and interrogation training.
          Recommendation 2:
          The Chief of the Investigations Division should review all death investigation police reports and
          ensure all investigative avenues were completed before reports are finalized. Ensure that all
          documentation is prepared in a format that can be used as evidence in court.
          Recommendation 3:
          Rewrite Canton PD policy and procedure related to utilization and authorization of personal cell
          phones to photograph or video crime scenes. All policy should be changed to require the use of
          ONLY department issued/owned cell phones to photograph crime scenes. No use of personal
          cell phones should be allowed.
          Recommendation 4:
          All Sergeant and Patrol vehicles should be equipped with full crime scene kits including bags,
          sealing equipment and digital cameras. Department phones should be placed in patrol cars for
          officers to utilize to document crime scenes. Patrol Officers and Sergeants advised the Audit
          Team that Canton PD has one (1) digital camera at headquarters.
          Recommendation 5:
          Prevailing law dictates that the MSP or the District Attorney’s office will lead death
          investigations, but it does not preclude the Canton PD from assisting MSP in such
          investigations. The Audit Team recommends Canton PD should engage and support MSP and
          District Attorney’s Office as deemed appropriate.

Corrective Action
On October 31, 2023, Chief Helena Rafferty updated the Canton PD Policy and Procedures related to
Evidence Collection and Preservation. Reference is made to Canton PD Order Number 6.01. The new
policy includes protocols including handling crime scenes in inclement weather. The new policy and
procedures regarding evidence collection and preservation are consistent with CALEA standards and best
practices.

Section 2: Crime Scene Protocols Overview · PDF text layer

The Audit Team verified that the department purchased crime scene kits that are now available for crime
scene collection for all Canton PD officers. Audit Team discovered that Canton PD has only one (1) digital
camera which is assigned to the detective division. [Note: Chief Rafferty advised she is in the process of
purchasing new digital cameras.]

Audit Team recommended that officers should receive crime scene training, which Chief Rafferty
confirmed she supports. In February 2025, Chief Rafferty, in coordination with the Information Technology
Specialist, purchased five (5) iPhones for utilization for the Detective Division.

Conclusion
The Audit Team found no evidence supporting claims that any Canton PD officers tampered with evidence
located at the 34 Fairview Road crime scene. The Audit Team further found that the only Canton Police
Officers that should have been recused from the police investigation at 34 Fairview Road were Detective
Kevin Albert and Deputy Chief Keleher. Canton PD has full investigative authority to work in concert with
the Norfolk District Attorney’s office and Massachusetts State Police on death investigations.

Based on interviews and review of investigative reports, the Audit Team determined that Canton PD as first
responders worked on the initial crime scene and conducted initial interviews of some witnesses at the
scene. The Audit Team did find policy and procedure failures related to crime scene processing.

The Audit Team has determined that Canton PD’s internal controls and compliance oversight have
improved since the initiation of this Audit and that effective leadership is in place to supervise future
critical incidents. The Audit Team has advised Chief Rafferty regarding our recommendations and Chief
Rafferty has confirmed the implementation of new crime scene procedures.

Section 2: Crime Scene Protocols Overview · PDF text layer

February 4, 2021

Case File Audit
of the Death of
Sandra Birchmore

                                                               Sandra Birchmore

Sandra Birchmore Crime Scene, 3307 Windsor Woods, Canton, Massachusetts
As part of the Canton Police Department crime scene audit the Audit Team reviewed the Canton PD police
response to Windsor Woods 3307, Canton, MA, beginning on the morning of February 4, 2021. Our team
carefully reviewed Canton PD police reports and crime scene documentation surrounding the discovery of
the death of Sandra Birchmore on February 4, 2021.

Canton PD Initial Response to Sandra Birchmore’s Crime Scene on February 4, 2021

   10:00 a.m. •       February 4, 2021, Sharon School Resource Officer contacted the Canton PD School
                      Resource Officer to check on Sandra Birchmore. Ms. Birchmore worked at East
                      Elementary School located in Sharon, Massachusetts and had not shown up for work
                      and employees were unable to contact her.
   10:55 a.m. •       Canton PD Officers responded to 3307 Windsor Woods to make contact with Ms.
                      Birchmore, with negative results (no one answered the door).
                  •   Canton PD observed Ms. Birchmore’s vehicle was in the apartment complex parking
                      lot, covered in snow and had not been moved since the snowfall on Monday, February
                      1, 2021.
                  •   Canton PD officers spoke with a property manager, who provided a key to access the
                      apartment.
                  •   Canton PD officers entered the apartment and observed Ms. Birchmore in the
                      bedroom seated on the floor with a belt/lanyard string/rope around her neck, secured
                      around the bedroom closet door handle and appeared deceased. Ms. Birchmore’s
                      cell phone was on the floor located close to her body.

Section 2: Crime Scene Protocols Overview · PDF text layer

•   Canton PD officers contacted Canton PD supervisors, who ordered officers to hold
                      and secure the scene until Canton PD detectives could arrive. Shortly thereafter,
                      Canton PD detectives arrived at the scene.
    11:46 a.m. •      Canton Fire Rescue/Paramedics arrived and pronounced Ms. Birchmore deceased.
                  •   Pursuant to Massachusetts General Laws, Canton PD notified MSP Troopers assigned
                      to the Norfolk District Attorney’s Office. Canton PD also notified the medical
                      examiner's office. Both the MSP and medical examiner’s office responded.
                  •   Canton PD Detective and MSP Trooper entered the apartment and after viewing the
                      apartment proceeded to the bedroom where they found Ms. Birchmore.
                  •   MSP Crime Scene Services processed and digitally photographed the scene. Ms.
                      Birchmore’s mobile phone and laptop computer were seized.
                  •   Canton PD cleared the scene after the medical examiner's office removed Ms.
                      Birchmore from the apartment.

•   Ms. Birchmore’s next of kin contacted the Canton PD by
    phone and was notified by the Canton PD that Ms.
    Birchmore was found deceased.
•   On February 5, 2021, Canton PD Sergeant received an
    electronic message (e-mail) from a witness who related
    she had information regarding Ms. Birchmore’s death.
    This information was passed to MSP for action.
•   On February 5, 2021, Ms. Birchmore’s next of kin, stated
    she was aware that Ms. Birchmore was pregnant and
    that the father of the baby was Stoughton Police Officer
    Matthew Farwell.

Follow-up Investigation by
Canton PD on February 6, 2021
•   On February 6, 2021, Canton PD detectives conducted Photos from video of Matthew Farwell at Windsor
    follow-up investigation at Windsor Woods and              Woods-Canton, MA: lobby, arrival, and departure.
    interviewed a witness who advised Canton PD
    detectives that Ms. Birchmore was involved in an intimate relationship with a police officer, who was
    alleged to be the father of her unborn child.
•   Canton PD detectives received information from a second witness who said Ms. Birchmore had been
    dating a police officer, who did not want the baby, and if Ms. Birchmore did not get an abortion, he
    [boyfriend] would take care of the problem himself.
•   On February 6, 2021, Canton PD and MSP coordinated a second review of video footage at Windsor
    Woods.
•   After the review of video footage investigators identified a male subject, (later identified as Stoughton
    Police Detective Matthew Farwell) arrive at Windsor Woods on February 1, 2021, at 9:27 p.m. and
    departed at 9:56 p.m. Mr. Farwell was observed entering the apartment complex lobby and entering

Section 2: Crime Scene Protocols Overview · PDF text layer

the elevator. Video revealed Mr. Farwell was at Windsor
                                                                    A person wearing a mask and standing in a hallway
                                                                    AI-generated content may be incorrect.

    Woods for approximately 28 minutes.
    [See Video: https://crimetimelines.com/wp-
    content/uploads/2024/06/Survailance-Apt-Video.mp4]
•   Canton PD detectives learned from a Windsor Woods
    maintenance worker that the person in the video looked like
    the man who helped Ms. Birchmore move into her
    apartment.                                                                                                          Video of Matthew Farwell
•   On February 6, 2021, Canton PD and MSP conducted a                                                                  entering the Windsor Woods
                                                                                                                        apartment complex in Canton,
    second search of Ms. Birchmore’s apartment.                                                                         MA
[Note: After a lengthy federal investigation, Matthew Farwell was
indicted by a federal grand jury in Boston on August 27, 2024. Mr. Farwell is accused of killing Sandra
Birchmore on February 1, 2021, in Canton, Massachusetts by strangulation to prevent her from providing
information to law enforcement regarding potential federal crimes.]

          RECOMMENDATIONS
          Pursuant to Canton PD policy and procedures, officers should digitally photograph all crime
          scenes and sketch the scene.
          The Audit Team reviewed a Canton PD police report prepared by a detective who wrote that
          Sandra Birchmore died of a suicide. We recommend death investigative reports be reviewed by
          the Chief of the Investigations Division and approved prior to being finalized.
          As stated above the Canton PD should remain involved in death investigations that occur within
          the Town of Canton.

Conclusion
On February 4, 2021, Canton PD officers conducted the initial police response to the Sandra Birchmore
crime scene and followed all procedures related to crime scene preservation. Canton PD detectives
conducted follow-up investigation with MSP detectives on February 6, 2021, at 3307 Windsor Woods and
received critical information from witnesses.

As a result of investigative efforts investigators identified Stoughton Police Officer Matthew Farwell was
present at Ms. Birchmore’s apartment on the evening of February 1, 2021. Further, witness interviews
revealed Mr. Farwell was involved in a long-standing intimate relationship with Ms. Birchmore.

Chief Rafferty advised the Audit Team after February 6, 2021, Canton PD relinquished all investigative
authority of the Sandra Birchmore death investigation to the Massachusetts State Police and Norfolk
District Attorney’s Office.

Section 2: Crime Scene Protocols Overview · PDF text layer

December 5, 2018

Case File Audit
of the Death of
Craig Casey

2018 Accident Scene and Recovery for the Body of Craig Casey in Canton, MA
As part of the audit, the Audit Team reviewed an accident investigation report documenting an incident
that occurred on Pleasant Street in the Town of Canton on December 24, 2018, around 05:15 a.m. Canton
PD reported they responded to the scene of a one car accident on Pleasant Street and conducted a
preliminary investigation. No driver was located near the vehicle and the Canton PD Officers initially
believed that the operator had fled the scene. Canton PD officers reported they searched the area on foot,
with the assistance of several community members with negative results. Canton PD officers remained on
scene for about 45 minutes until the car was towed. [Note: The operator of the car had fled the scene of an
accident in nearby Stoughton minutes before he crashed his car on Pleasant Street in Canton].

After the Canton PD cleared the scene at approximately 06:00 am, one hour later at approximately 7:00
am, a passing motorist observed Casey's body, (first reported to dispatch as someone sleeping on the
lawn), on the lawn of a house at 676 Pleasant Street. Canton PD responded back to the scene on Pleasant
Street, along with Town of Canton fire rescue and found Mr. Casey who was pronounced dead. Canton PD
officers made notifications to the Massachusetts State Police (MSP) and to Norfolk District Attorney’s
Office, who responded to the scene and conducted further investigation. The Medical Examiner’s office
arrived and took custody of the body (Casey).

Findings and Observations
We found the Canton PD did not document the accident scene with photos of the vehicle or take photos of
where the body was found. We found the Canton PD did not send a supervisor (Sergeant or Lieutenant) to
676 Pleasant Street to provide guidance or operational command. No witness statements were taken by
officers at 676 Pleasant Street as the result of the subsequent 07:00 am call.

The Audit Team reviewed the MSP accident investigation report which detailed that on Monday December
24, 2018, at approximately 05:15 a.m., a 2016 Ford Edge (vehicle) was traveling north on Pleasant Street in
Canton, at a high rate of speed (over 80 mph) and upon passing Sawyer Avenue the Ford began to
negotiate a moderate left bearing curve. The vehicle exited the eastern edge of the roadway and began to

Section 2: Crime Scene Protocols Overview · PDF text layer

enter a counterclockwise rotation. The vehicle traversed several driveways before impacting a large
diameter tree. After impact the vehicle rolled, eventually coming to rest right side up facing southwest.
According to reports prepared by the MSP Collision Analysis and Reconstruction Section on December 24,
2018, during the crash (rollover sequence) the operator (Casey) who was unbelted was ejected from the
vehicle. Mr. Casey was found approximately 94 feet north from the Ford’s area of final rest and on the front
lawn of 676 Pleasant Street.

MSP Photos
The below listed photos were obtained by MSP at Interstate Wrecker Service storage facility in Dedham,
Massachusetts on Thursday, December 27, 2018.

                    Photos of Craig Casey’s vehicle at the Interstate Wrecker Service storage facility

          RECOMMENDATIONS
            •   Pursuant to Canton PD policy and procedures, Canton PD initial response should always
                include digitally photographing all crime scenes and sketching the scene, regardless of
                whether the investigation is transferred to another law enforcement agency, such as the
                Massachusetts State Police.
            •   Send a Canton PD supervisor to all critical incidents.
            •   As stated above the Canton PD should remain involved in all death investigations that
                occur within the Town of Canton.

Section 2: Crime Scene Protocols Overview · PDF text layer

November 23, 2024

Case File Audit of
Damage to a House
Under Construction

House Party Damage at 25 Holly Way, Canton, MA
Because of the political climate in the Town of Canton the Audit Team reviewed a case file concerning the
malicious damage to a home that occurred on the evening of November 23, 2024, at 25 Holly Way in
Canton. The investigative activities occurred while the Audit Team was on site. [Note: Numerous juvenile
subjects attended a house party at a home that was under construction. Many of the subjects were
identified as drinking alcohol and one subject was observed on video kicking a dead rabbit.]

Canton PD investigation revealed that multiple juvenile subjects damaged the inside of the home, causing
approximately $20,000 in damages. The investigative team, including patrol officers, effectively obtained
information from the complainant and documented the damage to the house via video and digital
photographs, and were able to identify multiple individuals involved in the incident that caused significant
damage to the property.

Chief Rafferty effectively organized a team of detectives from both Canton PD and neighboring police
departments to conduct a thorough investigation. All the juvenile subjects who were responsible for the
damage to the home were identified. The Audit Team found that the complainant was reimbursed for the
damage to his home and declined to press charges, signing a declination of prosecution. One (1) juvenile
subject was identified as being responsible for bringing the deceased rabbit to the home. We found
prosecution was declined by the Massachusetts Environmental Police. Canton PD followed all policies
and procedures related to collection and preservation of evidence and crime scenes.

Canton PD efforts and responses to this matter were effectively completed and in accordance with all
policies and best practices.

Findings
None.

Section 2: Crime Scene Protocols Overview · PDF text layer

SECTION 3:
 Professional Standards and Accountability

                                                     Image source: Boston Herald

Section 3: Professional Standards and Accountability · PDF text layer

SECTION 3: PROFESSIONAL STANDARDS AND
ACCOUNTABILITY
Massachusetts State Law requires each police department to report disciplinary actions to the
Massachusetts Police Standards and Training (POST) Commission that are related to all police officers
involved in violating policies and procedures and who violate state or federal laws. Departments should
implement an early intervention policy for tracking complaints to identify an officer who may exhibit a
pattern of actions requiring intervention. The early warning or early intervention system should include
documentation in a computerized database of police officer performance indicators, including uses of
force, citizen complaints, arrests, traffic stops, officer discipline records, use of sick leave, and others.

To maintain and adhere to state policies, all Canton PD employees have the Blue Voice App on mobile
phones which allows officers to review Canton PD policy and procedure, rules and regulations, case law,
statutes, and by-laws. [Note: These mobile phones referenced are personally owned by the officers. This
practice is not in alignment with best operations and procedures and is addressed in several areas of this
report.]

a) Review adherence to professional standards (such as ethical guidelines, best practices, and
industry norms).

Canton PD policies are in accordance with POST guidelines. On February 3, 2023 the Executive Director of
the Massachusetts POST Commission emailed the Chiefs and Sheriffs within the state explaining that only
certain levels of sustained misconduct should be reported. Specifically, sustained misconduct of a
serious nature, any conduct using excessive force, or any conduct that would be a violation of a civilian's
rights was to be reported. Canton PD Chief Rafferty exceeded Massachusetts POST reporting
requirements regarding the reporting required of sustained misconduct investigations, consistently
reporting all sustained allegations regardless of severity. Since this email notification, Chief Rafferty has
revised her submission and remains in full compliance with POST requirements despite public perception.

b) Evaluate how the department ensures accountability for its actions.

The Audit Team reviewed multiple years of civilian and defendant complaints starting with the most
recent. Each complaint was evaluated at the Chief and Deputy Chief level and often the Chief and/or one
of the Chief Deputies would investigate the allegation. This is the result of the political climate, and the
public scrutiny placed upon the Canton PD. The Audit Team found that all complaints and allegations were
assessed, investigated when appropriate, and discipline was issued when required and necessary,
although these matters were not handled in the manner typically associated with Internal Affairs
investigations. The complaint files were not maintained in a consistent manner and the methods of
investigation and investigators varied. While the Deputy Chief of Operations and Investigations was
responsible for overseeing the investigation, the Chief of Police handled some cases directly. The Audit
Team found that the retirement of personnel has left a void of experienced investigators capable of
performing an Internal Affairs investigation.

Section 3: Professional Standards and Accountability · PDF text layer

c) Consider transparency and responsiveness to public concerns.

The Audit Team found some complaints were not investigated. We found some allegations made against
officers lacked a formal investigative process. However, the Audit Team did not find any evidence or
intentional negligence of concealing the allegations to protect officers. Each complaint was addressed to
correct the actions (misconduct) of the officer in question in accordance with POST and Canton PD
policies and procedures.

d) Review Internal Affairs Accountability.

The Audit Team reviewed 75 internal affairs files dating back to 1991. The Audit Team found action taken
by the Chief of Police resulting in adverse action (suspensions) of officers was not consistent with
violations that were identified. We found one (1) officer was placed on administrative leave for several
weeks pending the completion of an internal affairs investigation. The Audit Team believes the officer
should have been available to work at headquarters on restricted duty versus being placed on paid
administrative leave. We found another Canton PD officer was transferred from the detective bureau to
night patrol, without a formal investigation conducted. Again, the chief of police conducted the inquiry
versus a formal internal affairs investigation. The Audit Team has made significant recommendations
which will improve the accountability and transparency of the Canton PD’s internal affairs process and the
handling of civilian complaints. These recommendations will improve the internal affairs process at every
stage and will assist the Canton PD in providing annual reports to the town indicating the number of
complaints received, internal affair investigations initiated, and any discipline issued as a result.

e) Review adherence to compliance with officer misconduct and professional conduct.

The standards of the department as they relate to professionalism and expected professional conduct are
in alignment with POST requirements. Professional standards and the responsibility to meet those
standards are ultimately up to the individual officer. It is the responsibility of the department to ensure that
its officers uphold the expected standards of professionalism and conduct, and hold those that do not
accountable by administering corrective action when necessary. This is accomplished through a
transparent internal affairs process. It is recommended that Canton PD officers annually certify they have
read and understand the Canton PD Standards of Conduct.

f) Review disciplinary procedures and adherence to them, including past adherence to the mandated
reporting of complaints alleging officer misconduct to the Peace Officer Standards and Training (POST)
Commission, including past demotions and promotions for the past 25 years.

And

g) Review the lack of Officer disciplinary actions – acknowledging Canton has had only one disciplinary
action recorded in the last 25 years.

The Audit Team found this statement to be inaccurate. A review of civilian complaints, internal affairs
investigations and disciplinary actions revealed that since September 28, 1991, seventy-five (75) internal
affairs inquiries have occurred. These inquiries were initiated as the result of civilian complaints or at the
direction of management based upon performance. These 75 actions resulted in 63 clearances, and 12
acts of sustained violations. The 12 sustained violations resulted in four (4) suspensions, one (1) demotion

Section 3: Professional Standards and Accountability · PDF text layer

and seven (7) counseling/training sessions. POST requirements as they related to these inquiries and
subsequent disciplinary actions were met.

The most recent action occurred on October 2, 2024. Two (2) complaints were filed and results were sent
to POST in accordance with POST policy. As stated above, Canton PD policies are in accordance with
POST guidelines. On February 3, 2023, the Executive Director of the Massachusetts POST Commission
emailed the Chiefs and Sheriffs within the state explaining that only certain levels of sustained misconduct
should be reported. Specifically, sustained misconduct of a serious nature, or any conduct using
excessive force, or any conduct that would be a violation of a civilian's constitutional rights was to be
reported. Canton PD Chief Rafferty exceeded Massachusetts POST reporting requirements regarding the
reporting required of sustained misconduct investigations, reporting all sustained allegations regardless
of severity. Simple civilian complaints filed with the Canton PD are not required by POST mandate and
Canton PD policy to be reported to POST.

Furthermore, while it is important to acknowledge, process, and review every civilian complaint, it is not
always necessary, or appropriate, for all complaints to trigger an internal affairs inquiry.

h) Review adherence and compliance to policies and procedures of the Canton Police Department's
liaison to the Stoughton District Court (a position known as "Police Prosecutor") and the Norfolk
County District Attorney’s Office, and whether all citizens are treated fairly and equitably.

The Audit Team interviewed the Police Prosecutor. This position is more than a liaison position and
requires a senior officer, preferably holding rank. The current Police Prosecutor understands his role and
responsibility and is well respected in the courts by other law enforcement, prosecutors, and defense
attorneys. He stated that he has felt the effect of the current town climate within the court proceedings.
Other professional law enforcement officers, as well as prosecutors and defense attorneys, have all
acknowledged the public scrutiny: the social media posts and vocal protesting have negatively affected
the Town of Canton’s police force. Despite this, the Police Prosecutor remains positive and utilizes this
position to ensure the prosecutors receive all necessary information in a timely manner to meet court
requirements as they relate to production and discovery. Additional resources in the form of full-time
police officers should be allocated to the Canton PD. The current Police Prosecutor holds two (2) full-time
positions as the Sergeant of Detectives and Police Prosecutor.

Section 3: Professional Standards and Accountability · PDF text layer

Findings
An examination of Internal Affairs (IA) investigations dating back to 1991 revealed a lack of organization
and consistency in the files, particularly during the tenure of four (4) different Canton Police Chiefs,
namely John Ruane Jr., Peter Bright, Ken Berkowicz, and Helena Rafferty. The biggest improvements to
both the written policies and the internal affairs process have occurred in the past four (4) years under
then Chief Berkowicz and now Chief Rafferty. While recent files from the past fourteen (14) months under
the supervision of Chief Rafferty showed improvement in thoroughness and documentation, there
remained issues with content consistency and a uniformed structure of the system. It was noted that due
to the department's size, and staffing shortages, establishing a designated IA division, or the designation
of a full-time IA investigator had not been practical. However, no instances of intentional negligence or
misconduct minimization were found. One (1) incomplete investigation from 2002 was discovered, as the
IA designated investigator had passed away, halting progress on the case. This case was never reassigned,
nor was it brought to a conclusion. This sole example highlights the need for consistent internal systems
and documentation to prevent such lapses.

The Audit Team examined seventy-five (75) investigative files over a twenty (20)-year period and concluded
that the IA process requires significant enhancements as it relates to its process and documentation. In a
specific case from 2015 involving a Canton PD detective's inappropriate relationship with a drug-addicted
individual, procedural shortcomings were identified. The detective received a ten (10)-day suspension,
was demoted from the detective division and was reassigned, but formal complaint procedures were not
followed, and the IA investigations lacked formal processes, such as documented witness interviews and
an explanation on the final decision.

Another incident reviewed involved a Canton PD detective who unintentionally and tragically, left his dog
in his personal car while reporting early for work at the Canton PD. The dog was later found deceased.
While the Detective was rightfully not criminally charged, it was crucial that a comprehensive investigation
should be conducted. This should have involved obtaining a detailed statement from the detective
outlining his actions. Additionally, this should have involved acquiring statements from witnesses within
the department corroborating the detective's activities, attitude and actions leading up to the discovery of
the dog. An official statement from the responding Animal Control Officer and a declination from the
District Attorney stating that they are not pursuing charges should have been part of the investigative
process. If done in this manner, the investigative file could have been referenced by case number. We
found there were two (2) instances involving civilians residing in the Town of Canton who committed
similar acts accidentally, resulting in the loss of beloved family pets. While neither individual was charged,
the process should have been documented in detail. In all instances, it should be noted that common
sense and discretion were utilized by both senior officers as well as civilians. We found no evidence that
the department tried to conceal the event. Rather, the actions of senior officials and the decisions made
exhibited compassion for a decorated officer, who was already emotionally devastated.

All investigative proceedings, as well as any actions taken, or not taken, must be meticulously
documented in the investigative file to maintain transparency and accountability with the town
stakeholders and citizens. Had the investigation of the loss of the detective’s pet been performed as
described above, it would not have changed the ultimate outcome. However, it would have allowed the
Canton PD to appropriately respond to the public outcry for a Canton PD detective to be legally punished

Section 3: Professional Standards and Accountability · PDF text layer

for an accidental loss of a pet. A proper internal affairs investigation would have protected the officer from
the public outcry for punishment that was not levied against civilians for the same type of case.

We found another incident in 2024, where a Canton PD officer was subject to disciplinary measures due to
policy violations. The Audit Team identified that the complainant did not utilize the proper Canton PD
protocol for filing complaints, and instead, directly lodged the complaint with the Chief of Police.
Consequently, the Chief personally oversaw the investigation, conducted interviews and imposed a
suspension. The absence of established investigation procedures, such as internal affairs case numbers,
delegated internal affairs investigators and witness interviews, was noticeable in many instances, with IA
investigations predominantly being managed by the Chief of Police. The complainant placed the Chief in a
compromising situation making her a witness to the misconduct, rather than solely the adjudicator as the
Chief should have been. Our team identified multiple instances where the Chief of Police handled the
complaint directly, interviewed the employee and proposed the discipline, versus having the IA
investigator conduct the investigation, as per policy.

More recently, in an effort to mitigate conflicts of interest, Chief Rafferty enlisted the services of an
external independent organization to investigate allegations of misconduct. The Audit Team affirmed that
these outsourced investigations were comprehensive, thorough, and substantiated by comprehensive
case records and documentation. However, as cited below, it is suggested that the IA processes of the
Canton PD be enhanced with a focus on implementing formal investigation protocols and ensuring
oversight by designated Canton PD personnel. The Audit Team recommends that IA investigations be
conducted by the Canton PD in accordance with their policy when appropriate. Since the Canton PD is a
small department, when investigations involve conflicts of interest, or multiple officers, we recommend
hiring outside firms to conduct the IA investigation. The following recommendations will allow the Canton
PD to conduct fair, thorough and transparent investigations into alleged misconduct. Canton PD should
maintain a searchable filing system which will allow for accurate reporting and save the department
money on outsourced investigations.

          RECOMMENDATIONS
          Process
          All civilian complaints to the police department should be documented on a Canton PD
          complaint form and filed with the Canton PD Desk Sergeant or e-mailed to a department
          complaint intake email. Any civilian who enters the Canton PD with a complaint should be
          provided with the form and an opportunity to complete it. All completed forms should be
          entered into the dispatch log with a timestamp and receipt, then forwarded to the Deputy Chief
          of Operations (DC-Ops) and Investigations for processing, numbering, evaluation and further
          action if necessary.
          In cases where an IA investigation is warranted, the DC-Ops should record his rationale in a
          report, assign an IA number to the complaint (in addition to the civilian complaint number), and
          appoint an investigator of suitable rank and experience to conduct the investigation. The DC-
          Ops should inform the Chief about the allegation and subsequent investigation, ensuring

Section 3: Professional Standards and Accountability · PDF text layer

compliance with POST requirements. The investigator(s) should take recorded statements,
          collect physical evidence and review any material as necessary. All evidence obtained during
          the IA investigation should be handled as regular evidence, labeled and processed with exhibit
          numbers. When the investigation is complete, the entire packet should be sent back to the DC-
          Ops for review.
          Upon completion of the IA investigation, the entire file, including reports, interviews,
          transcripts, and evidence, should be reviewed by the DC-Ops for thoroughness. If the
          investigation is deemed comprehensive and capable of assessing the validity of the complaint,
          the file should be passed on to the Deputy Chief of Administration (DC-Admin) for further
          review as it pertains to policy violations.
          The DC-Admin should examine the file for policy violations by any Canton PD member,
          irrespective of the original complaint and allegation. Misconduct violations should be identified
          by policy number, directives, date of infraction, and specific details outlining the misconduct.
          The DC-Admin should record the findings of misconduct violations, or lack thereof, in an
          official report. The IA file should then go to the Chief of Police for final decision based on Police
          Collective Bargaining agreements, Town By-Laws, Civil Service regulations, and CMR 555. In
          instances where misconduct or policy violations are confirmed, a disciplinary matrix should be
          used to ensure consistent corrective actions are taken with all officers for similar sustained
          charges of misconduct.
          The Chief should review the file and the report outlining the policy violations. The Chief should
          make a decision to find the misconduct substantiated or unsubstantiated. For unsubstantiated
          misconduct, the officer should receive a Letter of Caution, a Letter of Warning, or a Letter of
          Clearance. Discipline warranted for substantiated misconduct should be issued by the Chief in
          accordance with Town Policy, POST requirements, and the collective bargaining agreement. A
          copy of the final decision should be given to the officer and included in the IA Investigative file
          and utilized as a closing document. Upon closing the file, the DC-Ops should then contact the
          original complainant and inform them of the investigation and its conclusion. The complainant
          is entitled to know that their allegation was unsubstantiated and closed, or that it was
          substantiated and resulted in discipline to the officer and closed. The Canton PD has no
          requirement to provide further explanation.
          The implementation of the above format, or a similar format that meets the rules and
          requirements of the department, is crucial for transparency and fairness, fostering an
          environment within the department of accountability.
          [Note: According to Canton PD Rules and Regulations, officers are subject to disciplinary
          actions outlined in statute (M.G.L c. 31 sec. 43) and other appropriate measures deemed fit by
          the Chief, including letters of reprimand. Procedural requirements governing notice and
          hearings will be followed.]

Section 3: Professional Standards and Accountability · PDF text layer

SECTION 4:
 Organizational Structure & Governance

                                                     Image source: Boston Herald

Section 4: Organizational Structure and Governance · PDF text layer

SECTION 4: ORGANIZATIONAL STRUCTURE AND GOVERNANCE
Chief of Police
Chief Helena Rafferty is the head of the Canton Police Department (Canton PD), overseeing a team of
sworn officers, administrative staff, and part-time officers. She ensures that the department operates in
compliance with laws and regulations while meeting organizational goals. Chief Rafferty, a 35-year veteran
of the police force, was appointed in June 2022 and graduated from the FBI National Academy. She holds a
BA in Criminal Justice, a Master’s in Criminal Justice, and a Certificate in Public Administration. Chief
Rafferty has experience working in various roles within the department and has received awards for
leadership and humanitarian work during her service.

Deputy Chief Patricia Sherrill has dedicated over three (3) decades to the Canton PD, commencing her
tenure as a patrol officer in 1993. She is a graduate of the FBI National Academy in Quantico, VA.
Throughout her career she demonstrated exemplary leadership skills and was promoted to sergeant in
1999, where she oversaw the patrol division's operations. Her commitment and expertise led to her further
advancement to the rank of lieutenant in 2005, where she managed the patrol division and undertook
various administrative responsibilities assigned by the Chief of Police. In 2022, Deputy Chief Sherrill
achieved a significant milestone in her career with a promotion to Deputy Chief of Administration, where
she currently reports directly to the Chief of Police. Notably, she holds the distinction of being the second
female in the department's history to hold the role of Deputy Chief. In addition to her administrative duties,
she serves as the Department's Public Information Officer, handling media inquiries from both local and
national outlets, managing freedom of information requests, and coordinating official responses on behalf
of the Chief of Police. Deputy Chief Sherrill specializes in domestic violence issues and has undergone
extensive training in this field throughout her career. She is an active member of the Norfolk County
Domestic Violence High Risk Team, demonstrating her commitment to addressing and preventing
domestic violence in the community.

Deputy Chief Thomas Keleher has been a member of the Canton PD since April 1992. Beginning his career
as a patrol officer, he advanced to the rank of Lieutenant in 2006, gaining experience in the Patrol Division
and as a First Line Supervisor. He currently holds the position of Deputy Chief of Operations and Detective
Bureau. Deputy Chief Keleher graduated from Canton High School in 1988. He furthered his education at
Bridgeton Academy in Maine, completing the one (1) year preparatory program. He earned a Bachelor's
Degree in Criminal Justice from Western New England College and a Master's Certificate in Public
Administration from Suffolk University. In December 2008, Deputy Chief Keleher graduated from the FBI
National Academy in Quantico, VA, known for its exceptional academic training in investigations,
management, and fitness. He is one of only three (3) active members at Canton PD, alongside Chief
Helena Rafferty and Deputy Chief Patty Sherrill, to have graduated from this prestigious program. Deputy
Chief Keleher leads the METRO-SWAT Crisis Negotiation Team, overseeing a team of twenty (20)
negotiators that respond to crisis situations in more than fifty (50) communities. He has been the team
commander since 2012 and is actively involved in the Joint Terrorism Task Force, collaborating with law
enforcement partners at all levels to stay informed on national crime trends.

The Investigative Division consists of a team of detectives and a sergeant and addressed serious crimes.
The Patrol Division also includes four school resource officers who are assigned to patrol and support

Section 4: Organizational Structure and Governance · PDF text layer

schools. Deputy Chief Patricia Sherrill leads the Administrative Division, overseeing training, grants,
policies, part-time officers, school resource officers, and crossing guards. Both deputies report directly to
Chief Rafferty.

The command structure includes the Chief, two (2) Deputy Chiefs, three (3) Lieutenants, seven (7)
Sergeants, four (4) Detectives, four (4) School Resource Officers, and nineteen (19) Patrol Officers. The
department currently has two (2) officers in the police academy. Canton PD consists of forty-one (41)
police officers in total, with Chief Rafferty advocating for additional staff to reach the desired total of fifty
(50) officers.

The Canton PD command staff’s leadership has been essential in the operations and growth of the Canton
Police Department, ensuring public safety and effective law enforcement in the community.

Command Structure
Organizational Chart Written Directive No. 4.29

The Canton Police Department will utilize the following organizational structure with the importance of
adhering to the Chain-of-Command:

[Note: Current staffing levels at Canton PD show a shortage of eight (8) officers, with twenty-five (25) full
staff patrol officers and a total staff of forty-one (41) police officers. The Chief of Police has consistently
requested additional personnel in each budget cycle, highlighting the need for a total of fifty (50) sworn
officers. At present, there are three (3) recruits (two (2) male, one (1) female) undergoing training at the
police academy, set to graduate in June 2025.]

Section 4: Organizational Structure and Governance · PDF text layer

a) Analyze how the police department is organized, including reporting lines, hierarchy, organizational
chart, and decision-making processes.

The Canton PD's hierarchal framework and chain of command are clearly defined, ensuring that
communication follows the appropriate channels to reach supervisors. Information flows smoothly to the
necessary authorities when senior decision-making is required. By incorporating additional civilian staff
members, such as intelligence analysts, the department could significantly enhance its communication
capabilities, resulting in greater efficiency and effectiveness.

b) Assess the effectiveness of communication channels across all devices within the department.

The Audit Team concluded that all lines of communication in the department are well established,
understood, and aligned with the appropriate hierarchy and the chain of command.

c) Evaluate cross-functionality and collaboration between different units, departments, or divisions

The Audit Team discovered that the patrol division and investigative division frequently collaborate on
crime prevention and effectively support each other's efforts. Their teamwork and synergy are evident in
their joint responses to incidents, such as a non-fatal shooting incident in November 2024. During this
event both divisions quickly responded, apprehending the shooter and collecting crucial evidence,
including the weapon used. Their unified strategy involved conducting interviews, analyzing evidence, and
coordinating with prosecutors to file attempted murder charges against the perpetrator. The cohesion and
synchronization between the patrol and investigative divisions were effective and played a significant role
in the successful resolution of the case. Patrol officers are often actively engaged in cases and work
closely with the detective division. Furthermore, all information and actions were promptly reported to
senior management and town officials, ensuring proper notifications at the appropriate levels within the
organization.

The Audit Team identified that a Memorandum of Understanding is current with the Bureau of Alcohol,
Tobacco and Firearms (ATF) Special Agent in Charge James Ferguson and Boston Field Division and
Canton Police Department Chief Helena Rafferty, dated February 9, 2024. In summary, the task force
agreement allows the partnership of ATF and Canton PD to investigate firearms trafficking and related
violence, to gather intelligence, conduct undercover operations, and investigate shootings in Norfolk
County and surrounding areas, with physical locations at the ATF Bridgewater Office and the Canton
Police Department. [Note: ATF has a satellite office inside the Canton PD with one (1) ATF Special Agent
operating out of this office.]

Our team conducted an audit of firearms cases, related arrests, and/or joint cases worked between
Canton PD and ATF Special Agents from 2018-2024. As a result, our team determined that a total of twelve
(12) cases were initiated, resulting in arrests of three (3) subjects for felon in possession of a firearm. Two
(2) arrests were made of individuals involved in controlled purchases of firearms; two (2) other cases
related to recovering a firearms incident to arrest. In addition, ATF and Canton PD conducted search
warrants and arrests related to a home invasion and recovered ammunition and firearms. ATF also
provides informal training to Canton PD officers on firearms tracing.

Section 4: Organizational Structure and Governance · PDF text layer

d) Evaluate using a strong vs weak Chief in terms of governance.

The Massachusetts General Laws make a distinction between a "strong" and "weak" chief of police
through General Laws Chapter 41 Section 97A and 97. The key discrepancy between the strong and weak
chief lies in the authority granted to the chief. A strong chief has more autonomy in managing the police
department, being able to establish policies and procedures with minimal interference from town officials
or the Select Board. In contrast, a weak chief, like the one in the Town of Canton, is subject to oversight by
the Select Board, with the chief reporting to the Town Administrator.

Under the weak chief statute, the Select Board is empowered to appoint the Police Chief to oversee day-
to-day operations and to appoint additional officers as necessary. The board can also establish
regulations for the police department. The appointment and discipline of police officers are governed by
Section 13 Chapter 41. Reappointment is required after a one (1)-year probationary period unless there is
just cause, or as specified in a collective bargaining agreement, with due process procedures in place.

On the other hand, the strong chief statute permits the Select Board to appoint the police chief, who then
has the authority to establish department regulations, subject to approval from the Select Board. While
the Select Board retains ultimate authority, the chief holds greater responsibility in managing the
department, which includes overseeing officers and departmental property, as well as assigning duties.

Effective oversight ensures that the police chief is responsible for financial and budget decisions,
departmental functions, and the maintenance of professional standards among officers.

Chief Rafferty demonstrates effective and fair handling of sensitive police matters and investigations. She
consistently deflects credit to her management team, highlighting the officers' work. Throughout our
observations and interactions with Chief Rafferty over the past four (4) months, she has exhibited clear
communication skills and fostered a positive work environment. Overall, Chief Rafferty's leadership style
emphasizes fairness, transparency, and a genuine concern for the well-being of both the community and
the department's personnel.

e) Make recommendations to streamline the Canton Police Departments operations.

The Audit Team conducted a review of the operational protocols of the Police Department and found that
while the department functions efficiently and professionally, there are recommendations that could
further improve operational efficiency:

•   Acknowledge and accept that the Police Department has the authority to and should resume its own
    responsibilities and conduct its internal affairs (IA) investigations.
•   Cease the expenditure on outsourcing tasks that the department has the capability to perform itself.
•   Increase the number of officers trained in crime scene processing, management, and preservation.
•   Train officers in report writing to improve their skills and require the submission of concise, detailed
    incident reports that explain how the situation was addressed and resolved.
•   Provide training for officers in courtroom testimony.

Section 4: Organizational Structure and Governance · PDF text layer

•      Ensure all police vehicles are equipped with essential evidence collection tools, such as digital
       cameras and department-issued cell phones. It is impractical to use a department-issued laptop for
       capturing photos/videos at a scene.
•      The police prosecutor officer and the detective sergeant positions should not be combined.
•      Hire administrative staff, including a secretary or for the C-suite and detective bureau, as well as
       interns and analysts.
•      Hire dispatchers who can work with uniformed officers to handle emergency and non-emergency calls,
       enter data and service information requests from the public.
f) Assess protocols for proactively soliciting public comments about high-profile incidents and crisis
communications and assess adherence to those protocols.

The Audit Team assessed the protocols the Canton PD uses to actively seek public feedback on high-
profile incidents and crisis communication. Chief Rafferty and Deputy Chief Sheryll were interviewed to
discuss the Department's efforts to engage with the community.

Although the department has established, implemented, and currently maintains protocols for informing
the public about emergency situations, the feature allowing public comments has been disabled,
hindering the potential for constructive dialogue. Certain members of the community have persistently
subjected the police department and its officers to ridicule, negative personal remarks, and harsh
criticism over their routine job functions. This undermines the chances of fostering positive
communication.

According to information on the Canton PD website, the department actively utilizes several social media
platforms, such as Facebook, X, and Instagram. A thorough search through these platforms has allowed
for a preliminary analysis of the department’s posts and the community’s responses, which has led to
potential recommendations.

Based on the available data, it appears that the Canton PD made thirty (30) posts on Facebook in 2024,
sixty-seven (67) posts in 2023, and eighty (80) posts in 2022. These 30 Facebook posts have been
categorized and examined for further review and insights.

               Facebook Post Subject | Number of Posts

                               Total Posts

    Holiday Greetings and Donations (TFT)

                      Missing person alert

              Safety advisories, awareness

             Traffic advisories, awareness

        Community advisories, awareness

                                             0   10   20    30          40          50      60   70   80      90

                                                                 2024        2023    2022

Section 4: Organizational Structure and Governance · PDF text layer

RECOMMENDATIONS
          The police department should resume posting public announcements, notifications, and public
          warnings of importance on all relevant social media platforms immediately, the two (2) most
          prominent being X and Facebook. Public comments should remain disabled until they can
          become beneficial and promote a positive exchange of information.
          Additionally, the Town of Canton Should:
            •   Acknowledge and accept that the Police Department has the authority to and should
                resume its own responsibilities and conduct its internal affairs (IA) investigations.
            •   Cease the expenditure on outsourcing tasks that the department has the capability to
                perform itself. Outsource internal affairs investigations when a conflict of interest is
                identified, or multiple officers are involved.
            •   Increase the number of officers trained in crime scene processing, management and
                preservation.
            •   Train officers in report writing to improve their skills and require the submission of
                concise, detailed incident reports that explain how the situation was addressed and
                resolved.
            •   Provide training for officers in courtroom testimony.
            •   Ensure all police vehicles are equipped with essential evidence collection tools, such as
                digital cameras and department-issued cell phones. It is impractical to use a
                department-issued laptop for capturing photos/videos at a scene.
            •   The Chief of Police should assign an officer to serve as the police prosecutor at court.
                Currently, the Detective Sergeant is serving a dual role of police prosecutor and
                supervising detectives In case work.
            •   Hire administrative staff, including a secretary or for the C-suite and detective bureau, as
                well as interns and or analysts. A full-time Administrative Assistant for the Detective
                Bureau is needed.
            •   Hire dispatchers who can work with uniformed officers to handle emergency and non-
                emergency calls, enter data, and service information requests from the public.

Section 4: Organizational Structure and Governance · PDF text layer

SECTION 5:
 Citizens Privacy Protections

Section 5: Citizens Privacy Protections · PDF text layer

SECTION 5: CITIZENS PRIVACY PROTECTIONS
a) Evaluate policies and practices related to handling citizens’ personal information.

The Audit Team has examined the protocols for managing confidential data, particularly pertaining to
private individuals who may be involved as witnesses in complaints, crimes, or as concerned citizens. Our
team determined that the department is fully compliant with its policies aimed at safeguarding such
information.

b) Assess compliance with local, state, and federal data protection laws (e.g., CCPA, GDPR. HIPAA).

The following is a list of a few of the requirements and safeguards in place that the Canton PD must follow
regarding the protection of personal data. The Canton PD is bound by more regulations and requirements
than any other standard business. Additionally, they are also required to maintain logs of training and
certification in addition to their policy.

•   CJIS Terms and Policy
     • The department must maintain direct terminal access to the Criminal Justice Information System
       (CJIS).
     • The utilization of a CJIS workstation is restricted to criminal justice purposes exclusively, which
       involve carrying out official criminal justice duties.
     • In case of any damage to a CJIS workstation, each operator is required to promptly report it to their
       supervisor. It is the responsibility of the agency to report any inoperable CJIS workstation to the
       supervisor.
     • No alterations or modifications shall be made to any CJIS equipment, including CJIS workstations,
       mobile data workstations, or personal digital assistants/palm pilots, from their configured setup.
       Any changes must be performed by the DCJIS or the device's contract vendor, with notification and
       approval from the DCJIS.
     • Remote access to department workstations will only be granted to authorized personnel, ensuring
       proper access logging for authorized connections.
     • All CJIS information transmitted through a network segment must be safeguarded according to the
       FBI CJIS Security Policy.
     • Operators of CJIS workstations must undergo training, testing, and certification as per procedures
       established by the DCJIS before operating a workstation, with biannual recertification thereafter.
     • Each CJIS workstation operator is required to use their assigned password when accessing the
       CJIS network and must not disclose this password under any circumstances. Accessing the
       network using another individual's password is strictly prohibited.
     • All operators must log onto the network at the beginning of their workday and log off at the end to
       ensure proper tracking of transactions under the respective usernames. This measure prevents
       one operator from being held liable for another's CJIS transactions and guards against
       unauthorized access.
     • Agencies inputting records into CJIS must maintain continuous monitoring of their CJIS
       workstations and printers twenty-four (24) hours per day, seven (7) days per week.

Section 5: Citizens Privacy Protections · PDF text layer

•   Massachusetts Public Records Law (Covers HIPPA-DOB-SS)
•   Amanda’s Law, which centers around preventing first responders from taking and sharing
    unauthorized photos of crime scenes.
•   Canton PD Rules and Regulations Policy No. 4.16 Page 11
•   Canton PD Public Information Policy No. 1.39
•   Canton PD Communications Policy No. 1.32
•   Canton PD Dispatch Function Policy No. 1.35
•   Canton PD Written Directive Policy No. 4.08
•   Canton PD Mobile Data Access Policy No. 4.12
•   The Canton PD computer systems include the ability to monitor who and when anyone has viewed a
    specific report/information as well as monitoring who may have made edits to the report.
c) Review data access controls, encryption, and retention policies.

In addition to the above-mentioned controls, methods and regulations used to monitor and limit access to
certain data, much of the equipment and tools utilized by the Canton PD, such as Flock cameras, NCIC,
and CJIS databases, all contain their own individual safeguards, such as time data that is requested to be
logged by Flock on the logging user access, records requests and supervisory reviews.

Investigators accessing and making a request, aside from being electronically identified, must provide a
reason for the data request. Flock information, which does not identify individuals, is deleted every thirty
(30) days.

Canton PD policy clearly outlines permissible usage parameters and unauthorized usage of CJIS systems
or NCIS systems is a crime.

Retention of this information is not optional, nor is it subjective to the department or Chief. Coordination
with the District Attorney’s Office is essential, and once a final action has been completed and the District
Attorney’s approval is granted, the Canton PD Deputy Chief of Administration refers to the Massachusetts
Law Table of Retention for Police Records which establishes the retention period that vary by case type
and age. Examples are:

•   Unprosecuted cases: Retained for 6 years after final action.
•   Landmark cases: Retained permanently.
•   Criminal cases: Retained for 35 years after final action.
•   Medicaid, insurance, or unemployment fraud cases: Retained for 25 years after final action.
•   Litigation involving fatalities: Retained for 25 years after final action.
•   Civil cases: Retained for 20 years after final action.

          RECOMMENDATIONS
          None.

Section 5: Citizens Privacy Protections · PDF text layer

SECTION 6:
 Management, Operations and Culture

Section 6: Management, Operations and Culture · PDF text layer

SECTION 6: MANAGEMENT, OPERATIONS AND CULTURE
a) Assess leadership effectiveness, management practices, and decision-making.

After monitoring Chief Rafferty's performance in leading the department, it is evident that her leadership
style and decision-making skills are effective. The department holds great respect for Chief Rafferty,
including officers, colleagues, and command staff. However, morale within the department is notably low,
primarily stemming from public scrutiny surrounding the Canton PD’s handling of the crime scene and the
investigation into the death of Canton resident and Boston Police Officer John O'Keefe. While criticism can
be constructive, the continuous and personalized nature of the attacks have shifted public feedback from
being a means of professional improvement to consisting of personal attacks on officers. These attacks
via social media, phone calls, emails, and public protests have significantly affected morale within the
department.

b) Evaluate operational efficiency, resource allocation, and performance metrics.

The leadership within the Canton PD effectively manages, utilizes and applies departmental resources to
meet the responsibilities and requirements of the police department. Senior management, led by Deputy
Chief of Administration Sherril, adequately assesses the department’s needs based upon trends, officer
feedback and personal observations, while exploring opportunities to meet those needs through federal
grants. A notable example is the approved grant for the Mental Health Professional (MHP), which is crucial
for maximizing resource utilization. The primary performance metric requiring assessment is the
department’s minimum staffing requirements. A significant portion of the budget must be allocated to
fulfill these staffing needs to ensure the town’s safety. While additional training is necessary and has been
emphasized throughout this report, funding for training cannot take precedence over the funding required
to adequately staff each shift.

For FY 2024, an overtime deficit of $378,244.00 was covered by forfeiture funds. Additionally, the town
spent $145,000 on overtime funds. The deficit resulted from overtime caused by:

•   Investigations.
•   School resource officer after hour extracurricular events, such as High School sporting events, plays,
    meetings and clubs.
•   Town events include road races, July 4th fireworks, elections and political meetings.
•   Officers attending training, or officers covering shifts for those attending a training.
•   Fulfill shift requirements that are short due to attrition or officers utilizing leave such as vacation, sick
    or personal days.
•   Replacements for Military and Administrative Leave.
•   Court overtime or shift/patrol replacement when an officer must attend court.
c) Explore the organizational culture within the police department.

Many officers in the department share a common commitment to giving back to the community, often
coming from families with ties to law enforcement. Several officers' parents were longstanding members
of the Canton PD. This sense of service is central to the culture within the police department. The

Section 6: Management, Operations and Culture · PDF text layer

department's size facilitates a seamless flow of information among officers regarding important matters
that affect their work, fostering an environment of trust, transparency, and collaboration. Many officers
(nearly 48%) have roots in the local area, having grown up in the town and returned after completing
college or military service, to join the force.

Officers maintain close familial and social connections, with many having family members and
acquaintances in the community, including on the Select Board, in town administration, and among
business leaders.

Chief Rafferty is dedicated to fostering open communication with community members and town officials,
taking their feedback seriously and conveying their concerns to her team. She promotes a supportive
environment where team members' perspectives are respected and acknowledged, cultivating a culture of
empowerment and gratitude within the organization. Despite these efforts, recent observations by the
Audit Team have revealed that the community interactions have devolved into unproductive criticism and
critique towards the command staff and the police department. The focus has shifted away from
constructive dialogue and towards negative exchanges, hindering the ability to reach mutual
understanding and agreement on various issues.

Police memorabilia dating back to the 1950-1970s                          Recording of Police Interview 1973

d) Explore morale in the Police Department.

Observations affecting Morale:

•   Various social media figures have alleged the Canton PD intentionally mishandled the crime scene
    where Mr. O’Keefe was discovered on January 29, 2022, and suggested a conspiracy within the
    department to cover-up Mr. O’Keefe’s death. Karen Read was arrested on February 1, 2022, by MSP
    detectives for allegedly striking John O’Keefe with her vehicle and leaving the scene. Ms. Read was
    charged with manslaughter, motor vehicle homicide, and leaving the scene of an accident. Since her
    arrest on February 1, 2022, Karen Read and her defense team have alleged that there is a cover-up and
    conspiracy involving law enforcement and witnesses for the death of Mr. O’Keefe. Social media
    influencers across the country have fueled these allegations.

Section 6: Management, Operations and Culture · PDF text layer

•   The Audit Team has found that multiple family members of Canton PD officers have been subjected to
    harassment by various individuals, both residents and non-residents, including a social media figure.
    In one instance, a social media figure contacted the wife of a Canton PD officer and left a disrespectful
    voicemail on her cell phone, disparaging her husband and spreading accusations about his character.
    Additionally, an officer was harassed by the same social media figure while attending a New England
    Patriots football game. The Chief of Police faced harassment from individuals during an off-duty
    assignment at Gillette Stadium. Canton PD officers notified the Audit Team that this social media
    figure has continually harassed witnesses on-line and in person, especially the McCabe family. This
    social media figure followed a witness to a high school sporting event calling the witness a “cop killer.”
    This social media figure has been charged with witness intimidation by the Norfolk County District
    Attorney’s office.
•   Several Canton PD officers have reported being harassed by the public while on duty, during personal
    time with family and children, and while working off-duty police details. A group of “Free Karen Read”
    supporters hold weekly pickets at the Canton PD. Numerous instances have occurred where officers
    have faced harassment in person and online through e-mails, voicemails, social media, and on
    YouTube. Members of the Audit Team have been approached in public, contacted through emails and
    text messages, and have been encouraged to “expose the cover-up.”
•   The Audit Team has found that certain individuals use the
    Freedom of Information Act (FOIA) to obtain information
    about ongoing police investigations, budget allocations,
    overtime expenditures, and resolved cases. The
    information gleaned from these requests has been shared
    on social media. For instance, the Canton PD responded
    to an attempted suicide in 2019. Officers responding to
    the scene saved the individual's life, and a Canton PD
    Sergeant received an award for his actions. On February
    17, 2025, the Audit Team was contacted and informed
    that the individual had actually been murdered by the
    Canton PD and this was a part of “another cover up.” The
    Audit Team located the individual from June of 2019 and
    confirmed they are alive and doing well.                  A letter awarding a Canton PD Sgt. the
                                                                  Massachusetts State Police Medal of Lifesaving
•   Such requests strain the Canton PD’s resources as
    officers must devote time and effort to fulfilling these FOIA requests. For example, a citizen who
    received a traffic violation used FOIA to request details on all instances in the Town of Canton where
    drivers were pulled over and ticketed for using their phones while driving, despite having a clean driving
    record. Requests such as these place a significant burden on Canton PD resources.

Section 6: Management, Operations and Culture · PDF text layer

Outside a hearing on the Karen Read Trial, a social media
figure confronts Chief Rafferty                           Free Karen Read Picketers and a sign mocking Judge Canone.

                       Protesters supporting Karen Read and a text message sent to Chief Rafferty.

Section 6: Management, Operations and Culture · PDF text layer

Social Media post alleging conspiracy and corruption

Interviews and Officers Perception
The Audit Team successfully conducted interviews with all Canton PD officers and personnel, achieving
100% participation. Officers reported that the department is under significant pressure due to the
proliferation of misinformation, witness coercion, and a lack of support from elected officials. Officers
explained certain individuals, referred to as "influencers," are spreading false narratives about officers
involved in the O’Keefe and Birchmore cases without any substantiating evidence. These influencers are
primarily motivated by financial gain, fabricating sensational stories based on speculation to attract public
attention. They operate without adhering to journalistic standards, or rules of evidence, gaining notoriety
by circulating unfounded narratives in pursuit of fame and viewership.

The following are statements made by Canton PD officers during the in-person interviews with the Audit
Team:

          “I love this town, and they used to love us too. Those days were great, but they
          are gone.”

          “No one in this town will care about us until one of us gets murdered, even then
          half the town will probably celebrate that.”

          “Elected officials don’t care about us. Now the easiest way to gain popularity or
          get elected is to publicly trash us. They have no political platform, just trash the
          police. That’s it. It doesn't even have to be true, just do it.”

          “People in town just keep fueling the false rumors and it is going to get one of us
          killed.”

Section 6: Management, Operations and Culture · PDF text layer

“I have wanted to be a Canton Police Officer since I can remember, I love this job
          and this town. My biggest fear now is if I die on this job, will the town continue to
          harass my wife and kids.”

          “My wife asks me every day, why I would risk my life for a town that wouldn't
          care if I died. Every day, I tell her I love this town and the guys I work with.
          That’s why I go to work.”

          “I would have left this shit show a year ago. There is so much more money being
          offered by other towns. Towns that care about their cops, but I’m not going to
          leave the Chief. She could have left two years ago, but she stays and gets kicked
          in the gut every day for us. That’s the only reason she is here, she cares about us,
          yeah, I’m not leaving.”

Despite the above, officers report to work daily and serve the Town of Canton. Two (2) of Canton PD’s
youngest officers grew up in Canton and have witnessed the public vitriol over the last two (2) years. Yet,
despite the negative publicity and open hostility towards the department, they applied for- and took an
oath to become Canton Police Officers. During the week of February 17 through 21, 2025, officers saved
the lives of two (2) citizens in the town and arrested another on assault charges for seriously injuring a
young woman on Valentine’s Day. Despite low morale due to public sentiment, relationships and respect
amongst fellow officers remain strong, and the commitment to serve and protect the public has been
observed daily by the Audit Team.

e) Review the Canton Police Department’s operations procedures.

The operational procedures of the Canton PD comply with established standards set forth by MPAC, POST,
and CALEA. These procedures align with industry norms and either meet or exceed the operational
protocols of neighboring departments. The department operates within a paramilitary structure with a
clear hierarchy of rank and command. The command staff demonstrates diligence in effectively utilizing
equipment, funding, and limited training resources. They also display resourcefulness by actively pursuing
external funding to secure critical positions within the department, such as the full-time Mental Health
Professional and additional roles for school resource officers. These positions play a crucial role in serving
and protecting the community. The presence of these resources reflects the dedication and determination
of the current Canton PD command staff.

          RECOMMENDATIONS
          It is recommended that two (2) additional School Resource Officer positions, one for each
          elementary school, be created and fully funded. School resource officers from the Canton PD
          play a crucial role in the community by serving as liaisons between the school board and the
          Canton PD. They ensure the safety of the Town’s children during school days and special
          events, foster positive relationships with the community and police department. However, with
          only one (1) resource officer serving the three (3) elementary schools, two (2) schools

Section 6: Management, Operations and Culture · PDF text layer

inevitably remain uncovered with a police presence. It is recommended that additional funding
          be allocated to hire additional school resource officers to cover each school adequately.
          Additionally, we recommend to fully fund a position for the Mental Health Professional (MHP).
          This year’s grant renewal for the MHP was delayed, causing uncertainty as to the ability to
          retain the professional. The MHP has been identified as a valuable asset by all department
          personnel during in-person interviews.
          Effective communication channels should be established among town leaders, elected
          officials, and department officers. Meetings should be held directly with elected town leaders
          and department officers to facilitate discussions focused on enhancing communication. To
          ensure efficiency, these meetings should remain closed to the public, thus promoting greater
          productivity.

Section 6: Management, Operations and Culture · PDF text layer

SECTION 7:
 Hiring, Training Standards & Equipment

Section 7: Hiring, Training Standards, and Equipment · PDF text layer

SECTION 7: HIRING, TRAINING STANDARDS, AND EQUIPMENT
a) Evaluate initial training programs for new cadets and continuing education

The Audit Team analyzed Canton PD's hiring, training, and promotion data from 2015 to 2024.

Potential candidates for the Canton PD and surrounding departments in the Commonwealth must first
complete the required basic police training course authorized by the Municipal Police Training Committee
(MPTC). This committee establishes the training standards for prospective police officers hired by various
police departments in the Commonwealth. Interested candidates are typically sponsored by their
respective police departments and enroll in the recruit academies approved by the MPTC.

The selection process for police departments can differ, with some following Civil Service guidelines like
the Canton PD. The Canton PD, under Chief Rafferty's leadership, regularly communicates with the MPTC
to discuss expected job openings, academy availability and the need for recruit officer training.

Any potential Canton PD recruits are mandated to meet certain criteria as per state regulations, including
being at least 21 years old, being sponsored by the Canton PD, passing the Physical Agility Test (PAT) and a
medical examination conducted by the Massachusetts Human Resource Division before joining the
academy. The Canton PD's recruitment process involves several stages to ensure that the most qualified
candidates are selected. Specifically, applicants must meet the following state requirements:

•   Demonstrate physical, mental, and emotional fitness to carry out the essential duties of a full-time
    police officer.
•   Meet the minimum standards established by the Massachusetts MPTC for permanent full-time police
    officers.
•   Submit a comprehensive application packet with all required supporting documentation.
•   Provide fingerprints and undergo a thorough background investigation conducted by the Canton PD.
•   Fulfill all statutory requirements outlined by the POST Commission to obtain certification as a law
    enforcement officer under Chapter 6E, Section 4.
•   Have a clear record in the National Decertification Index.
•   Successfully pass a psychological "Fitness for Duty" assessment.
•   Clear a medical and physical examination.
•   Successfully complete the PAT, administered by the Commonwealth of Massachusetts.
•   Meet the fitness standards set by the MPTC, specifically the Cooper Aerobic Institute standards for
    Entry-Level Fitness.
•   Participate in a final interview screening conducted by Canton PD leadership.
•   Successfully complete the recruit officer academy operated by the MPTC.

These requirements are designed to ensure that candidates have the necessary skills, abilities, character,
and qualifications to serve as police officers in the Canton PD. Upon graduation new officers must
complete a Field Training Evaluation Program, (FTEP)

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b) Review training during probationary period and c) Review compliance with Post Commission
training standards

Following the completion of their training at the MPTC academy, new Canton Police Officers (CPOs) are
required to undergo a one (1) year probationary period as outlined in Massachusetts Civil Service law
Chapter 31, Section 61, and Massachusetts POST requirements. At the commencement of the
probationary period, new recruits participate in the Field Training Evaluation Program (FTEP) under the
supervision of the Training Liaison Officer, Canton PD Deputy Chief Sherill.

The Canton PD FTEP Program is designed to provide newly certified officers with practical training
immediately after their graduation. During this program, new officers are paired with a senior Canton PD
patrolman (FTO) for a minimum of four (4) weeks (equivalent to twenty (20) training days), during which
they rotate through shifts under the guidance of three (3) different FTOs. The aim is to expose the new
officers to real-world scenarios and provide them with hands-on experience, reinforcing the skills learned
at the academy.

Throughout the FTO Program, the FTO assesses the new officer's performance, attitude, and application of
academy teachings. Real-time feedback and constructive criticism are provided to help the new officer
improve and excel within the Canton PD. Additionally, new officers are trained on Canton PD policies,
procedures, conduct rules, and expected behavior. [Note: Our team interviewed officers who
recommended the FTO program should be more than four (4) weeks of training.]

Observations of the new officers are documented daily and weekly by the FTO, covering all aspects of their
job performance and adherence to departmental policies. The Canton PD currently has two (2) FTOs, with
a third officer scheduled for certification. Canton PD Policy Section 1.45 outlines the departmental policy
regarding the FTO program, with FTOs selected by the Chief of Police based on the department's needs
and the officers' level of experience.

FTOs undergo initial training through a forty (40) hour program conducted by the MPTC, with refresher
courses every two (2) years. They are also required to attend annual in-service training on laws and
policies, in line with CALEA requirements. FTOs operate under the supervision of the shift commander or
another designated senior officer, ensuring compliance with Massachusetts and CALEA standards.

The candidate list is based solely on the score of a written exam, with the exception that veterans and
dependents of police officers killed in the line of duty are automatically placed at the top of the list.
Additionally, if there are any police officers anywhere in the Commonwealth who have been laid off and
have not been hired back, they also go to the top of the list for consideration. Candidates are interviewed
and the Appointing Authority (Town Select Board) decides on which candidate receives a conditional offer
of employment. The conditional offer of employment is made pending the successful completion of a
psychological exam (paid for by the town), a medical exam (paid for by the town), and a Physical Abilities
test administered by Civil Service. If the town selects anyone, but the highest ranked candidate, they must
put in writing why a higher ranked (based solely on test scores and/or veteran or other preference) person
was not selected. This decision is subject to an appeal to the Civil Service Commission by anyone who is
aggrieved by the decision.

Section 7: Hiring, Training Standards, and Equipment · PDF text layer

Promotions
In 2024, Hanrahan Consulting was hired by the town to conduct assessment center testing for Canton PD
Sergeant and Lieutenant applicants. Justin Hanrahan, the Watertown Police Chief, oversaw the promotion
exams. Canton PD takes the requisite number of names from the top of the list of candidates, restricted to
a formula of 2N+1, or 3 candidates if promoting one (1) Sergeant or Lieutenant (it could be more
candidates if there are tied scores). This decision is subject to an appeal to the Civil Service Commission
by anyone who is aggrieved by the decision.

In coordination with the police union, the town human resources division is given statutory authority to
establish the form and content of these examinations, written or assessment center exams. By statute, all
candidate examinations must fairly test the knowledge, skills and abilities that can be practically and
reliably measured, and which are required to perform the job.

The Audit Team conducted interviews with Canton PD officers who took part in the 2024 promotion
process for the rank of Sergeant. These officers indicated that the selection process involved the use of a
scenario-based assessment center to evaluate and rank the candidates. Three (3) scenarios were
presented to assess the applicants. Some officers expressed the view that the scenarios did not effectively
reflect the daily responsibilities of a Canton PD Sergeant. They mentioned that Chief Helena Rafferty and
Westwood Chief Jeffrey Silva acted as role players and evaluated the applicants.

Several candidates suggested that Canton PD officers should have a minimum of five (5) years of
experience before being considered for promotion. However, in line with Massachusetts Civil Service
regulations, the Canton PD allowed candidates with just one (1) year of service to participate and apply for
promotion. The scoring system incorporated considerations, such as years of service, educational
background, leadership certifications, and training. Some officers also claimed that political factors could
influence promotion decisions within the Canton PD.

In another instance, our team spoke with Canton PD officers who applied for a detective position within
the department. One (1) detective applicant reported that the selection process involved a panel
consisting of Canton PD command staff members and an ATF Special Agent.

d) Evaluate whether the town has the personal and departmental equipment that would be expected in
a town of its size.

The Audit Team evaluated police personnel, and administrative staff, assigned to departments similar in
size. We also conducted an interview with a Chief of Police from a neighboring town, who disclosed his
department has significantly more civilian staff, and highlighted the benefits of employing two (2) civilian
dispatchers on each shift to support police operations, allowing officers to focus on crucial tasks. In
contrast, the Canton PD does not currently utilize civilian dispatchers or full-time administrative staff. At
present, the Canton PD has a part-time administrative assistant who handles various tasks such as
payroll, police details, billing, accounts management, and monitors department expenditures.

e) Review the effectiveness of training incentives and other educational increments.

The Quinn Bill, also referred to as the Police Career Incentive Pay Program (PCIPP), was established by the
Massachusetts legislature in 1970 to incentivize police officers to pursue education in criminal justice.

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Research indicated that the criminal justice system would be enhanced by having a higher number of
officers with advanced degrees in the field. Under the program, officers received additional compensation
tied to the level of degree achieved: ten percent (10%) for an associate’s degree, twenty percent (20%) for
a bachelor's degree, and twenty-five (25%) for a master's degree or a law degree. The Quinn bill applies to
the Canton PD officers as it relates to educational benefits. This benefit is paid by the Town of Canton.

In addition to the Quinn Bill the police department offers incentives for training and certifications in:
Emergency Medical Training, Use of Force, Firearms Instructor, First Responder, Accident Investigations,
Exam and Promotions officer, Firearms Licensing, Background investigations, National Incident Based
Reporting Systems (NIBRS), Range Officer, Fleet Officer, Range Officer, School resource Officer, Field
Training Officer, Less then Lethal Force (Taser) Instructor and Community Liaison Officer. These incentives
range in pay from $1,450 annually to $9,400 annually and are negotiated by their respective unions.

f) Review Town of Canton police department hiring practices and make recommendations.

Civil Service plays an important role in ranking and selecting new officers. Prior to exercising police powers
in the Commonwealth, individuals must successfully complete the prescribed course of study for basic
police training authorized by Municipal Police Training Committee (MPTC). The Municipal Police Training
Committee sets the standards for basic police training for candidates hired by individual police
departments throughout the Commonwealth. Those police departments submit applications for their
employee (or sponsored candidate) to our recruit academies. Hiring practices vary by department and
certain departments, operating by Civil Service, (Canton PD) must follow a selection process set forth by
statute.

All Canton PD recruits in accordance with state law must: 1.) be a minimum of 21 years old; 2.) be
employed or sponsored by the Canton PD, and 3.) successfully complete the Massachusetts Human
Resource Division's Physical Ability Test (PAT) and medical examination before assignment to the
academy.

The Canton PD’s hiring process consists of multiple phases ensuring the most qualified applicants are
hired. Specifically, candidates must meet the state requirements of:

•   Demonstrating a sufficient physical, mental and emotional condition to perform essential job
    functions of a full-time police officer.
•   Successfully meet the minimum standards for a permanent full-time police officer as established by
    the MPTC.
•   Submission of an application packet containing supporting documentation.
•   Submission of fingerprints and successfully completing a background investigation conducted by the
    Canton PD.
•   Fulfillment of all statutory requirements as set forth by the POST Commission to become a certified
    law enforcement officer under Chapter 6E Section 4.
•   Returning as a negative check within the National Decertification Index.
•   Passing a psychological “Fitness for Duty” assessment.
•   Passing a medical/physical examination.

Section 7: Hiring, Training Standards, and Equipment · PDF text layer

•   Successfully completing the Commonwealth of Massachusetts Physical Agility Test (PAT).
•   Successfully completing the MPTC Entry-Level Fitness Standards (Cooper Aerobic Institute).
•   Passing a final interview screening consisting of Canton PD leadership.
•   Successfully completing the MPTC operated recruit officer academy.

It is vital to emphasize the caliber of the Background Investigations (BI) carried out by Canton PD
investigators on potential candidates. These BI investigations play a crucial role in evaluating the
character and moral values of applicants before they are hired by the Town of Canton. The Canton PD
assigns detectives to handle the BIs of prospective employees, ensuring a rigorous vetting process to
identify the most competent and deserving candidates for the Canton PD.

Thorough interviews are conducted as part of the investigation process, but their effectiveness is
contingent upon the honesty, integrity, and accuracy of the interviewees. Should the information provided
to the investigator be incomplete, untruthful, or inaccurate, the reliability of the BI may be compromised
without the investigator's knowledge. It is imperative for the investigator to verify the information to the
best of their ability and to recognize and address any conflicting details, even after the completion of the
investigation. Accuracy and truthfulness stand as the paramount elements in any investigative process.

In 2024, the Canton PD brought onboard a new police recruit, referred to as “the recruit.” In early
September 2023, the recruit disclosed during a Canton PD interview that a past incident with his then-
girlfriend resulted in a "police contact." This incident did not lead to any arrests or the filing of restraining
or protective orders. The Canton PD, upon learning about this, obtained the police report detailing the
"police contact," which revealed it stemmed from a verbal argument with no violence or assault indicated.
Efforts to reach the girlfriend for a statement corroborating this information proved unsuccessful.

Additionally, the Canton PD's background investigation referenced a separate inquiry done by the
Massachusetts State Police in the same year. The State Police had interviewed the girlfriend, who
confirmed no physical altercation occurred during the argument that resulted in the "police contact" and
asserted that the recruit had never been violent in their three (3)-year relationship. Based on this, the State
Police proceeded with the recruit's application process.

The decision to hire the recruit was made following a comprehensive background investigation that found
no red flags that would hinder the recruit's success as a police officer. Relying on the credibility of the
information provided by the state police investigation, the Canton PD moved forward with hiring the
recruit. The recruit graduated from the police academy in May 2024 and joined the Canton Police
Department.

Subsequently, as a Canton Police Officer, (CPO) the former recruit, now serving as officer, applied for a
position with the Braintree Police Department (PD) in late August/early September 2024. The town of
Braintree conducted its own background check, discovered the same information pertaining to the “police
contact” and interviewed the girlfriend who had returned to town. During this interview, the girlfriend
expressed surprise that the CPO was now an officer and recounted instances of concerning behavior,
including alleging that the CPO had been physically aggressive towards her during their relationship. The
girlfriend admitted she had not disclosed this information earlier to the State Police and further admitted

Section 7: Hiring, Training Standards, and Equipment · PDF text layer

she avoided contact with the Canton PD because she did not want to be questioned about this incident,
out of fear for her safety by the CPO.

Upon being informed of these allegations by the Braintree PD Chief, Canton PD Chief Rafferty took
immediate action. An IA investigation was initiated, the CPO was placed on administrative leave, and a
preservation order was issued to secure all relevant records. To ensure an unbiased investigation, an
external investigator was hired.

Before the IA investigation concluded, the CPO resigned from the department voluntarily. This instance
highlights the commitment of the Canton PD to hiring and retaining only the most qualified individuals.
Notably, no formal complaint was ever filed, and the decision to investigate was driven by the command
staff and the Chief's discretion.

The Canton PDs hiring practices and background investigations are in compliance, with POST Standards
and MPAC requirements.

g) Review the adherence to compliance of 555 CRM 1.00 PEACE OFFICER STANDARDS AND TRAINING
COMMISSION.

The Audit Team reviewed 555 CRM1.00 Peace Officer Standards and Training (POST) Commissions
requirements and measured its compliance to the Canton PD. According to POST555, this is a basic
summary of the Minimum Requirements for Internal Agency Investigations.

•   Upon receipt of a complaint, the agency must initiate an internal investigation within fourteen (14)
    days or promptly request an extension if necessary due to external investigatory efforts. The request
    should include a proposed timeline for starting the investigation and reasons for the delay.
•   Internal investigations may be conducted by an investigator from within the agency, or by an external
    investigator. The assigned investigator must be impartial and report directly to the agency head, or a
    designated official, excluding those involved in the complaint.
•   The investigator should:
     • Preserve all potentially relevant evidence, such as documents, e-mails, text messages, and
       recordings.
     • Notify the officer and their bargaining unit of the ongoing investigation.
     • Interview relevant witnesses, including the complainant, alleged victim, involved officer, and
       witnesses. Interviews should be documented, and interviewees have the right to representation
       and translation services.
•   Investigations must maintain confidentiality within legal limits.
•   The investigation should be concluded within ninety (90) days of receiving the complaint, with the
    option to request an extension if needed, providing a timeline and reasons for the delay before the
    ninety (90)-day mark.

Section 7: Hiring, Training Standards, and Equipment · PDF text layer

Internal Investigation Reports
Once the internal investigation is concluded, the agency's head must promptly forward a signed
investigation report by the investigator to the division of standards. The report should include:

•   An account of the evidence or complaint allegation.
•   Details of the investigation and resolution of the complaint, including any disciplinary actions
    suggested by the investigator, a supervising officer, or initiated by the agency's head.
•   A list of witnesses interviewed, noting whether each interview was recorded and reasons for any
    unrecorded interviews, along with a summary of all collected evidence.
•   Documentation of any inaccessible witnesses, or evidence and explanations for their unavailability, as
    well as any instances of evidence destruction, or loss with details of such incidents.
•   Findings of fact determined by the investigator.
•   The investigator's assessment of whether the facts reveal behavior that violates laws or officer
    standards.
•   Reasons for any delays in submitting the investigation report beyond the ninety (90)-day timeframe
    specified in 555 CMR 1.01(2)(e).
•   If disciplinary actions, such as retraining, suspension, or termination were suggested or imposed, the
    agency head's recommendation to the commission on implementing such actions, including potential
    certification revocation.

Final Disposition of Internal Investigations by an Agency
Upon finalizing the complaint resolution and disciplinary measures, if any, the agency head shall promptly
send a final report to the division of standards, including:

•   Overview of the adjudicatory process.
•   Any disciplinary actions proposed initially by the investigator or a supervising officer.
•   Details of disciplinary actions enforced by the agency head.
•   Recommendations from the agency head, backed by facts from the investigation report, on how the
    commission should proceed with recommended disciplinary actions, such as retraining, suspension,
    or certification revocation.
•   Confirmation of the officer's legal representation or authorized representative status.

h) Solicit and summarize employee top recommendations for excellence

When presented this question, officers unanimously requested the following:

•   More training opportunities.
•   Support from Town Boards and Town elected officials. The officers expressed a need for support from
    their elected leaders and the town officials they represent.
•   Equipment upgrades, such as radios communications enhancements and ballistic shields.

Section 7: Hiring, Training Standards, and Equipment · PDF text layer

Other comments and recommendations from the officer interviews were captured in Section 6, part (d):
Explore the Morale of the Department.

          RECOMMENDATIONS
          The Audit Team recommends the department hire an intelligence analyst to support the
          Detective Bureau. The intelligence analyst could also assist the Deputy Chief of Police with
          tasks, such as managing Freedom of Information Act (FOIA) requests, investigative inquiries,
          and police report redactions. It is important to note that the Deputy Chief of Administration
          oversees FOIA responses.
          Furthermore, the Audit Team suggests hiring one (1) civilian dispatcher for each shift to work
          alongside a uniformed police officer in the dispatch area. The additional personnel would
          ensure continuous coverage for phone calls, radio communications, and walk-in inquiries
          without compromising any specific duty. This setup would also enable sergeants to focus on
          supervising patrol officers, responding to calls, maximizing the presence of officers patrolling
          assigned areas, preventing illegal activity, and enforcing laws.
          The Audit Team suggests addressing the following equipment needs for Canton PD officers in
          addition to the recommended hire positions:
            •   Portable Radio Coverage: The portable radios currently in use have dead zones, notably
                one on Washington Street in the center of town. This presents a serious safety concern as
                officers are unable to communicate with the department when outside of their vehicles.
                Immediate assistance requests or medical aid for civilians become impossible without
                returning to the vehicle. It is essential to address this issue for effective communication.
            •   Home to Work Utilization of Police Vehicles: The on-call detective, detective sergeant,
                and detective lieutenant should have the privilege of utilizing police vehicles from home
                to work. Responding investigators and supervisors should not have to use personal
                vehicles when called to a scene. The practice of having to switch vehicles at the station
                before responding to a call is inefficient and needs to be improved.
            •   Cellular Phones: Ideally, every Canton PD officer should have a department-issued
                phone. If this is not feasible, supervisors of the rank of sergeant or higher should be
                provided with department-issued phones. Additionally, each patrol vehicle should be
                equipped with a department-issued phone to ensure constant communication,
                especially in areas with poor radio coverage.
            •   Digital Cameras for Sergeants and Lieutenants: Each sergeant and lieutenant vehicle
                should be equipped with digital cameras for documentation purposes. This will aid in
                preserving evidence and documenting incidents effectively.
            •   Crime Scene Processing Equipment for Detectives: Detective vehicles should be
                equipped with crime scene processing and collection equipment to facilitate thorough
                investigations and evidence collection.

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•   Crime Scene Preservation Equipment for Patrol Cars: Each patrol car should be
                equipped with crime scene preservation kits, and documentation equipment to ensure
                proper handling of crime scenes and evidence.
          Addressing these equipment needs will enhance the operational efficiency and safety of
          Canton PD officers, contributing to effective law enforcement practices.
          As it relates to 555 CRM 1 POST-For those violations and allegations of misconduct that rise to
          the level of POST reporting requirements, a review of those internal investigations and its
          process found the Canton PD is in full compliance.
          Where a variation from policy and/or best practices existed was on the allegations of
          misconduct that did not rise to the level of POST certification requirements. The handling of
          those matters varied in the manner in which they were investigated, documented and
          adjudicated. The Aduit Team found no evidence of misconduct being arbitrarily dismissed or
          ignored, and each allegation was addressed; however, the lack of consistent documentation,
          manner of investigation and methods utilized to address allegations and complaints was not
          always in the best practices. As was outlined in Section 3: Professional Standards and
          Accountability, the Audit Team has recommended a system for the receipt, documentation,
          investigation, adjudication, and reporting of allegations of misconduct and civilian complaint

Section 7: Hiring, Training Standards, and Equipment · PDF text layer

SECTION 8:
 Citizens Complaint Process

Section 8: Citizens Complaint Process · PDF text layer

SECTION 8: CITIZENS COMPLAINT PROCESS
a) Examine the process for receiving, tracking, and resolving complaints.

The Canton Police Department (Canton PD) offers a complaint form accessible to town citizens, available
on their website and at the police department's service window. The tracking and resolution of complaints
is overseen by the Chief of Police, who is responsible for recommending disciplinary and adverse actions
against Canton PD employees. The Chief maintains investigative files for complaints, investigations, and
suggestions.

According to Canton PD Rules and Regulations, upon receiving a complaint that warrants an internal
affairs (IA) investigation, the Canton PD will conduct an investigation within ten (10) days. The officer must
document any delays and seek the Chief's permission for extensions. Once the complaint is submitted,
the acceptance date and time are noted for the complainant's records.

In the event of exigent circumstances preventing completion, the investigating officer must inform the
Chief in writing. The Chief of Police must inform both the employee under investigation and the
complainant of the internal investigation results within seven (7) days post-completion.

The Officer-in-Charge is required to update the Chief on the investigation progress every five (5) days.
Employee rights are safeguarded, with employees receiving a written statement outlining the allegations,
as well as their rights before any questioning. The employee can request legal representation if the
investigation does not face undue delays and may have representation present if they anticipate
disciplinary action.

The Audit Team reviewed several years' worth of civilian and defendant complaints, starting with the most
recent, involving the current senior administration. Each complaint was evaluated at the Chief /Deputy
Chief level and often the Chief and/or one of her Chief Deputies would investigate the allegation. This is
undoubtedly the result of the political climate, and the public scrutiny placed upon the Canton PD. The
Audit Team found that all complaints and allegations were assessed, investigated when appropriate with
discipline issued when required and necessary, although these matters were not handled in the manner
typically associated with IA investigations.

The complaint files were not maintained in a consistent manner and the methods of investigation varied.
While the Deputy Chief of Operations and Investigations was responsible for overseeing the investigation,
recent retirement of personnel has left a void of experienced investigators capable of performing an IA
investigation. Additionally, in an apparent effort to appease the public, senior management of the Canton
PD have started handling the entirety of the process to include the investigation, evaluation, and
adjudication of the allegation, or they have opted to hire outside independent investigators to perform
duties that can and should be conducted internally by senior detectives.

b) Assess transparency in complaint handling.

During the past five (5) months, the Audit Team has been examining IA investigations, civilian complaints,
and allegations of misconduct involving members of the Canton PD. In the late 1990s, the Canton PD
would typically receive three (3) to five (5) complaints in a year. However, this volume has been on the rise
due to increased rumors and public scrutiny. The Audit Team has not found any evidence of the Canton PD

Section 8: Citizens Complaint Process · PDF text layer

attempting to conceal or cover up sustained misconduct. As cited in Section 3: Professional Standards
and Accountability, and Section 7, part (g): Compliance with Peace Officer Standards Training and
Commission Regulations, and in Section 8, part (a): The Process for Receiving, Tracking, and Resolving
Complaints, the Canton PD has historically lacked consistency in the process.

Under Chief Rafferty's tenure as Chief, there has been a noticeable improvement in accountability,
documentation, and process implementation. Due to public perception concerns regarding corruption
and misconduct, the Canton PD has decided to hire independent outside investigators at the town's
expense to conduct these investigations.

The Canton PD has been compliant in reporting investigations of serious allegations as defined by POST
standards. The Audit Team's recommendations aim to help Canton PD establish a comprehensive
oversight system and structured processes for investigating misconduct allegations thoroughly,
irrespective of the source. This system will also facilitate real-time, accurate, and transparent reporting to
oversight boards and elected officials within the town.

c) Review timelines for complaint resolution.

In accordance with Canton PD Rules and Regulations, when a complaint is received IA is responsible for
overseeing an investigation that should be completed within ten (10) days after the assigned officer has
made communication with the complainant. Any delays in the investigation process and requests for
extensions should be submitted to the Chief for approval. All Canton PD policies and POST requirements
regarding extensions were adhered to in cases where delays have exceeded the ten (10)-day timeframe.
Outsourcing IA investigations to external parties can impact the timeliness and completion of misconduct
investigations and complaint resolutions.

d) Evaluate communication with complainants.

While the department must establish and operate consistently within a system regarding the process for
submitting complaints, acknowledging the receipt of complaints, and informing complainants of the
commencement and outcome of IA actions, no obligation exists to provide complainants with updates on
the investigation or an explanation for findings.

Canton PD adheres to these guidelines and provides more information to complainants than is required
which can be detrimental to the department. Excessive communication can lead to additional allegations
and create a potentially unfair environment for the officers.

The complainant has a right to:

•   File the complaint and receive a copy of the complaint and verification of its filing.
•   Be notified that an internal affairs investigation will take place.
•   Be notified of the investigation findings, and if it was an IA investigation, know whether the complaint
    was unfounded, substantiated, or unsubstantiated.

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e) Recommend enhancements to ensure fair and efficient complaint resolution.

The department has established protocols for handling complaints and maintains a comprehensive policy
that adheres to CALEA and POST standards for addressing complaints effectively.

However, there is a need for the department to ensure uniformity in the application of disciplinary
measures such as suspensions, reprimands, and counseling sessions for officers. It is imperative that all
disciplinary outcomes are thoroughly documented, stored in a secure database, and used as a reference
for maintaining consistent and equitable treatment for similar cases of sustained misconduct. The Chief of
Police should oversee disciplinary matters using this system, ensuring fairness and impartiality in
decision-making while preventing external influences from affecting disciplinary actions.

The department's reliance on outsourced investigations, coupled with heightened public scrutiny and the
expectation for strict disciplinary responses to policy violations, may inadvertently introduce bias into the
disciplinary system.

f) Review policy of complaints and compliance to policy, and if all complaints are acted on fairly and
equitably.

As stated above, the department has established protocols for handling complaints and maintains a
comprehensive policy that adheres to CALEA and POST standards for addressing complaints effectively.

The issues that exist in the current environment are driven by the public demand for immediate and harsh
penalties for allegations of misconduct. The Chief of Police, with the approval of the Select Board, relieved
a Detective from his duties prior to the completion of an internal investigation. The Detective was placed
on paid administrative leave for three (3) months while the IA investigation was ongoing. This action was
taken due to allegations that the detective lost his firearm and consumed an alcoholic beverage (beer), in
violation of department policies and procedures, while on duty.

Following the IA investigation, it was determined that the detective had indeed violated policies and
procedures, and he was subsequently suspended for three (3) days. An audit of the department's IA
investigations spanning two (2) decades found that the detective had been treated unfairly by being placed
on administrative leave for three (3) months before the investigation was completed. The Audit Team
noted that other Canton PD officers faced more serious allegations, including those that resulted in
suspensions and demotions, yet remained on full duty throughout their investigations.

The resulting discipline issued to the Detective was appropriate, however if the IA investigation was
handled by a senior lieutenant in-house, as it should have been, the investigation could have been
completed in under a week to include interviews, schedules, and conclusions. Doing so would have saved
the town money and department resources.

This scenario underscores the necessity of the database discussed in part (e) Recommend Enhancements
to Ensure Fair and Efficient Complaint Resolution, as well as the importance of retaining records of all
disciplinary actions taken. Placing the Detective on administrative leave prematurely was likely driven by
misguided public pressure and scrutiny. It also emphasizes the challenge of managing public expectations
regarding police command decisions, which can potentially compromise the impartiality and consistency
of officer treatment within the department.

Section 8: Citizens Complaint Process · PDF text layer

g) Review and analyze workflows to respond to concerns in a timely manner.

The police department should avoid outsourcing investigations to external firms when senior detective
lieutenants are capable of conducting them effectively. This reallocation of funds seems unnecessary and
may be driven by a desire to appease public opinion, which remains unsatisfied with past outcomes.
Investing these financial resources in training and acquiring essential equipment would be a more
justifiable use of resources.

All civilian complaints should be directed to the Canton PD Desk Sergeant. When a civilian enters the
Canton PD with a complaint, they will receive a form to complete. The completed form will be logged in
dispatch with a time stamp, a copy provided to the complainant, and the original sent to the Deputy Chief
of Operations and Investigations for assessment and further action. In cases where an Internal Affairs (IA)
investigation is warranted, the Deputy Chief of Operations will document the rationale in a report, assign
an IA number to the complaint, and appoint an investigator with suitable rank and experience.
Investigators should conduct recorded statements that can later be transcribed and submitted in writing.
All evidence obtained during the IA investigation must be handled like evidence. Any confirmed
misconduct or policy violations should be addressed using a disciplinary matrix to ensure consistency in
corrective actions.

The Deputy Chief of Operations will inform the Chief about the investigation and allegations, ensuring
compliance with POST requirements. Upon completion of the IA investigation, the entire file will be
reviewed by the Deputy Chief of Operations for completeness. If deemed thorough enough to assess the
validity of the complaint, the file will be passed onto the Deputy Chief of Administration for further review
of policy violation.

The Deputy Chief of Administration will analyze the file for policy violations by any Canton PD member,
regardless of the original complaint recipient. Misconduct violations will be documented by policy
number, directives, infraction date, and specific details of misconduct. The findings will be recorded, and
a report, along with the complaint and the IA file, will be submitted to the Chief for a final decision based
on collective bargaining agreements, town by-laws, civil service regulations, and CMR 555.

The Chief will document her decision on counseling, reprimand, discipline, or clearance with the officer
receiving a copy of the decision letter as the final IA Investigation document.

According to policy, the Canton PD must conclude an investigation within ten (10) days of the investigator
contacting the complainant. POST mandates that an investigation must begin within fourteen (14) days of
receiving the complaint.

Communication with the complainant should be limited to the necessary information required by POST,
such as acknowledging receipt and providing an outcome of the investigation if applicable. Excessive
communication with complainants should be avoided once the department has fulfilled its obligations.
While the Town Selectman has the right to review and seek clarification on internal affairs investigation
findings, these results should not be subject to public negotiation.

Section 8: Citizens Complaint Process · PDF text layer

SECTION 9:
 Conflicts of Interest

Section 9: Conflicts of Interest · PDF text layer

SECTION 9: CONFLICTS OF INTEREST
a) Review potential conflicts of interest and adherence to conflict-of-interest rules, laws, and
regulations among officers, staff, elected officials, and appointed officials as related to the Canton
Police Department.

The Audit Team found no conflicts of interest among Canton PD Officers in relation to elected officials.
Canton employs a community policing strategy, with nearly 40% of officers having ties to the town. While
relationships between department members and the community are common, they do not necessarily
indicate conflicts of interest. However, the department's frequent self-recusals from investigations,
interviews, and police actions in efforts to prevent perceived conflicts of interest have inadvertently
created the perception that one exists.

b) Assess policies on gifts, secondary employment, and relationships.

The Canton PD has implemented strict Rules and Regulations that prevent officers from accepting gifts or
engaging in secondary employment. According to these regulations, employees are not permitted to
request, solicit, or receive gifts, loans, rewards, or fees connected to their roles within the department,
unless specifically permitted by departmental policy.

It is explicitly stated that employees must not receive any form of compensation from any source with the
intention of gifting it to an active officer, or employee without prior authorization from the Chief of Police.
Any unauthorized gifts or rewards received by an employee must be promptly reported to the Chief along
with details of the circumstances. Additionally, regulations set by the State Ethics Commission forbid the
acceptance of gifts or gratuities exceeding a total value of $50.

Upon review, the Audit Team did not find any instances of these policies being violated.

c) Review disclosure procedures and see if they have been followed.
The Audit Team has thoroughly examined records, FOIA requests, investigations, incidents related to
mental health, civilian contacts, civilian complaints, and non-enforcement police contacts. Our team has
not uncovered any evidence suggesting the existence of a conflict of interest that was not disclosed. No
evidence was found indicating conflicts of interest have influenced police actions, criminal investigations,
evidence gathering, crime scene processing, or the overall workflow of the Canton PD's daily operations.
d) Review the influence of family members of the police and elected officials.

Select Board member, Chris Albert, is the brother of Canton PD detective. Selectman Chris Albert recuses
himself from all votes relating to patrolmen and detective contracts.

e) Review cases that were handed over to the Attorney General and the State Police for conflicts of
interest and report back on the outcomes of those investigations when possible.

The Audit Team found no instances of cases being referred to the Attorney General or State Police due to
conflicts of interest. In cases, such as with Sandra Birchmore and John O’Keefe, the State Police took
control in accordance with Massachusetts Law Title VI, Chapter 38, Section 4, which requires the District
Attorney, or their designee, to supervise death investigations alongside relevant agencies. However, the

Section 9: Conflicts of Interest · PDF text layer

Canton PD was not barred, or forced to recuse themselves from involvement, but chose to step back in
what the audit committee views as an unjustified action. In the instance of John O’Keefe, the Canton PD
decided not to participate in follow-up interviews of witnesses with MSP due to perceived conflicts of
interest. [Note: Canton PD conducted witness interviews of several individuals on the morning of January
29, 2022.]. As first responders, the Canton PD is obligated to enforce the law and conduct investigations.
Their recusal, undertaken to address public concerns, led to delays in securing the crime scene, managing
witnesses, and documenting statements.

f) Review any potential conflicts of interest between the Canton Police Department and State or
Federal agencies.

The Audit Team found no conflicts of interest between state and federal agencies. Inquiries with federal
and state law enforcement agencies showed that the men and women in the Canton PD are respected in
the law enforcement community.

g) Recommend measures to prevent and address conflicts.

Canton PD officers are required to recuse themselves from investigations if they have a personal
connection with a complainant, or a person under investigation, and that relationship compromises their
impartiality. Currently, Canton PD regulations do not explicitly detail procedures for officers dealing with
potential conflicts of interest during investigations, thus leaving the decision on how to proceed at the
discretion of the officer and Canton PD leadership. This approach is deemed appropriate for a department
of Canton's magnitude. Each situation encountered by an officer presents unique difficulties, and
collaboration among officers is crucial. Oversight by senior personnel is an important factor in avoiding
conflicts of interest. By encouraging and enforcing ethical behaviors, as well as empowering Canton PD
officers, conflicts of interest can be effectively managed. The current standard practice of removing
officers from cases involving familiar individuals without clear guidelines undercuts the department's
neutral recusal process.

Section 9: Conflicts of Interest · PDF text layer

SECTION 10:
 Select Board Oversight &
 Industry Standards

                                                     Image source: Boston Herald

Section 10: Select Board Oversight and Industry Standards · PDF text layer

SECTION 10: SELECT BOARD OVERSIGHT AND INDUSTRY
STANDARDS
a) Assess the oversight of the Police Department provided by the Select Board.

The Board is responsible for the general policy development, policy implementation, and delivery of
municipal services involving the Canton PD. The Select Board, as outlined in the charter and by-laws,
functions as commissioners with direct oversight of the police department. Consisting of five (5)
members, the Select Board is tasked with supervising the department and appointing the Police Chief. The
authority to provide direct oversight and regular supervision of the police department is delegated to the
Town Administrator. Each board member reserves the right to speak on any issue, but agrees and
understands that they cannot act alone, or act in a manner inconsistent with the Select Board
Administrative Code of Conduct.

Chief Rafferty is currently serving under a one (1)-year contract, a decision reportedly influenced by citizen
concerns regarding the handling of the John O'Keefe investigation by the Canton PD, with Chief Rafferty
having served as Acting Chief of Police during the death incident on January 29, 2022.

Chair Loughran noted that former Chief Berkowitz had previously received multi-year contracts from the
Select Board. The Board maintains direct communication with the Chief of Police on matters of public
safety and authorizes budget allocations. In cases of critical incidents, or serious crimes within the town,
Chief Rafferty informs the Town Administrator, who typically informs the Select Board.

Chief Rafferty meets monthly with all Select Board members to discuss public safety issues, ongoing
initiatives, and budgetary needs. In November 2024 the Chair of the Select Board received a complaint
from a business owner, who alleged a possible criminal offense involving a Select Board member. The
Select Board and Town Administrator then contacted the Chief of Police with the allegation and video of
the violation.

This was an inappropriate action by the Town Administrator, Select Board member and ultimately the
Chief of Police. When notified, the Chief should have directed the complainant to the police department’s
desk sergeant to file a formal complaint in the same manner required of citizens. The complaint would
include their statements and any evidence supporting the allegation. This would follow the standard
procedures the Audit Team has outlined in other sections of this report for handling information and
complaints on potential crimes or violations. In bypassing these steps and handing the information
directly to the Chief, they unintentionally put both the Chief and the department in a difficult position,
where any decisions regarding the allegations would be scrutinized. Additionally, this type of complaint
makes the Chief a witness, while still acting as the final adjudicator for the department.

Interviews with Select Board members indicate a positive and constructive relationship with the police
department, though not all select board members are police supporters.

Section 10: Select Board Oversight and Industry Standards · PDF text layer

b) Determine who was/is the point of contact person on the Select Board who communicates with the
Police Chief.

The Audit Team found that there is no designated primary contact person from the Select Board who
regularly communicates with Chief Rafferty. Chief Rafferty mentioned that Select Board Member Patrica
Boyden had requested regularly occurring monthly meetings with her to discuss police matters. In addition
to Ms. Boyden, Chief Rafferty interacts with other Select Board members, such as Chris Albert, Chair
Michael Loughran, Vice-Chair John McCourt, and John Connolly. Chief Rafferty receives direct calls from
the Select Board members and addresses any inquiries they may have. It is important to note that, as per
the Town of Canton charter, the Select Board has oversight of the police chief, but the Town Administrator
provides direct oversight and supervises the police chief.

The Audit Team conducted interviews with the select board members and learned the following
information:

Michael C. Loughran, Chair

On December 5, 2024, Michael Loughran, Select Board Chair was interviewed. Chair Loughran stated he
has a good working relationship with Chief Rafferty. Mr. Loughran advised he is briefed regularly on public
safety issues. All Select Board members have access to Chief Rafferty and there is no single point of
contact that communicates with the Police Chief. Chair Loughlan stated he, along with other members of
the Select Board, have confidence in Chief Rafferty’s ability to lead the department. He further explained
the death of Boston Police Officer John O’Keefe has caused a serious divide among members of the
community who have lost confidence in the police department.

John R. McCourt, Vice-Chair

On December 5, 2024, John R McCourt was interviewed and said that he has been on the Select Board for
twenty (20) months. Mr. McCourt is a lifelong resident of the Town of Canton and employed with the
housing authority. When asked what level of confidence he has with Canton PD and the leadership, he
said “I am in the middle,” but overall is satisfied with the police department. He interacts with Chief
Rafferty, but not regularly. Mr. McCourt said he would prefer a more effective way of receiving information
related to critical incidents that happen in the town. He was not notified of an incident involving numerous
juveniles in the town that vandalized a home the day before Thanksgiving.

John Connolly

On February 21, 2025, John Connolly was interviewed. Mr. Connolly is a lifelong resident of the town. He
has an excellent working relationship with Chief Rafferty and other members of the Canton PD and has
been a member of the Select Board for over thirty (30) years. Mr. Connolly was aware the Canton PD is
understaffed and would work with the Select Board to obtain additional funding for officers. He spoke with
Chief Rafferty about staffing and will recommend the police department to add two (2) police officers to
the Table of Organization. Mr. Connolly has full confidence in the police department and fully supports
Chief Rafferty to be retained for an additional three (3) years. He would recommend adding administrative
staff to the department to support officers. Mr. Connolly stated that Select Board members select new
officers, approve promotions, and approve new contracts for all officers.

Section 10: Select Board Oversight and Industry Standards · PDF text layer

Chris Albert

Mr. Albert mentioned that he is among the most recent additions to the Select Board and made it known
that his brother serves as a detective within the Canton PD. He shared that he plays a role in negotiating
contracts with the police force, excluding those involving the patrol and detective union. Mr. Albert
expressed that he maintains a positive rapport with Chief Rafferty and other department personnel.
Additionally, he noted that the Select Board takes part in the selection and approval process for newly
recruited officers.

Regarding the Karen Read case, Mr. Albert indicated that it has had a significantly adverse impact on
himself, his business, and his family. He disclosed that he and his family have faced harassment, both in
person at his establishment and via phone calls received by his business. Despite these challenges, he
emphasized his affection for the Canton community.

Patrica Boyden

On February 21, 2025, an interview was conducted with Patrica Boyden, a lifelong resident of the town.
Ms. Boyden mentioned that she regularly meets with Chief Rafferty to discuss the needs of the police
department and the community. She indicated that while the Select Board oversees the police
department, the Town Administrator serves as the direct supervisor of Chief Rafferty. Ms. Boyden
expressed her support for the police department and mentioned her familiarity with many of the young
officers, as they grew up alongside her daughter in Canton.

Ms. Boyden highlighted the police response to the John O’Keefe death on January 29, 2022, suggesting
that it could have been handled better. She specifically mentioned that officers should have been
equipped with evidence kits to gather evidence at 34 Fairview Road. Additionally, Ms. Boyden felt that a
police car should have been stationed at the location until the Massachusetts State Police conducted their
search of the yard. Ms. Boyden pointed out that some residents believed the police mishandled the crime
scene at 34 Fairview Road. She also emphasized the importance of increased community policing efforts
within the department.

c) Compare this oversight to industry standards and best practices.

The Town of Canton Select Board, by Administrative Code, acts as commissioners and has direct oversight
of municipal departments and the police department, and direct oversight is delegated to the Town
Administrator. The Select Board, which is a five (5)-member board, is responsible for selecting the Police
Chief, who reports to the Town Administrator Charles Doody.

•   We compared industry standards of the Canton Select Board oversight of the Canton PD with other
    towns in the state of Massachusetts.
•   Other towns similar in size and scope have similar forms of government that provide oversight and
    direction of police departments.
•   The Select Boards serves as the Chief Policy-Making Agency of the town.
•   The Town Administrator supervises the day-to-day service areas of the Select Board.

Section 10: Select Board Oversight and Industry Standards · PDF text layer

The Select Board, in coordination with the appropriate town officials, is responsible for the budget
approval and the formulation and promulgation of policy directives for town agencies.

d) Review official town communications of all major stakeholders regarding the oversight of the
Canton Police Department by the Canton Select Board in its role as Police Commissioners.

The Audit Team reviewed multiple communications from Select Board members and major stakeholders
regarding oversight of the Canton PD. A Select Board Member has contacted the Chief of Police in a
unilateral fashion asking for individual meetings and updates. Of the communications reviewed, the Audit
Team found no unilateral communications to the Canton PD command staff by Select Board member
Chris Albert.

The Audit Team has witnessed dozens of members of the community, appointed officials and citizens
contact Chief Rafferty directly for a variety of reasons. While none of the communications appear to have
malicious intent, several unilateral communications by the Select Board members appear to be in
violation of Section IV. Powers, Duties, and Obligations of the Select Board which states in part:

          ...The Board shall strive to refrain from involvement in day to day operations of
          the Town government. Concerns and questions about the operation of a
          department and/or its employees, and suggestions for improvements should be
          addressed to the Board via the Town Administrator.

Section 10: Select Board Oversight and Industry Standards · PDF text layer

SECTION 11:
 Recommendations & Compliance Review

                                                     Image source: Boston Herald

Section 11: Recommendations and Compliance Review · PDF text layer

SECTION 11: RECOMMENDATIONS AND COMPLIANCE REVIEW
a) Based on the audit findings, recommend necessary improvements to all aspects of the Police
Department.

Recommendations have been made throughout this document and will be collected and listed with the
summary in Section 18: Recommendations and Summary.

b) Ensure compliance with legal requirements and community expectations.

The Canton PD is compliant with Massachusetts State Law, CALEA, and POST standards in terms of
policies and directives. During the audit committee interviews in October of 2024, it was noted by the
Audit Team that there may be transitional gaps from policy to application, and deviations from policy
adherence can occur due to various factors, and that deviation does not necessarily indicate intentional
wrongdoing or corruption. The Audit Team has found no evidence of malfeasance in instances where
Canton PD policy and its application do not align.

Measuring community expectations against legal requirements may not always be feasible unless both
align closely. In the current environment, the Audit Team has observed that community expectations in the
Town of Canton can be inconsistent and unrealistic. The Town of Canton should be reassured that the
Canton PD is fair, transparent, and responsive by following department policies.

c) The auditor should review all Federal, State, and local laws, regulations, and standards within the
policies and procedures of the Canton Police Department and verify adherence to compliance.

The Canton PD is compliant with relevant federal and state laws. The Canton PD has shown consistent
adherence to standards set by POST, MPAC, and CALEA. Additionally, the Canton PD successfully passed
a recent compliance assessment and certification from MPAC which is valid until June of 2027.

After reviewing policies and procedures, the Audit Team found that the written policies and directives of
the Canton PD align with certifying bodies and denote the expected best practices of the profession.

Section 11: Recommendations and Compliance Review · PDF text layer

SECTION 12:
 Recommended Improvements

                                                     Image source: Boston Herald

Section 12: Recommended Improvements · PDF text layer

SECTION 12: RECOMMENDED IMPROVEMENTS
This section will be reported in the closing section of the document and referenced as Section 20:
Recommended Improvements and Summary.

Section 12: Recommended Improvements · PDF text layer

SECTION 13:
 Forfeiture of Forensic Review

                                                     Image source: Boston Herald

Section 13: Forfeiture Forensic Review · PDF text layer

SECTION 13: FORFEITURE FORENSIC REVIEW
a) Review the cash forfeiture balances, deposits, and withdrawals, as well as management,
administration, and expenditure procedures going back 25 years (as possible).

The Audit Team completed a forfeiture forensic review of equitable sharing funds received by the Canton
Police Department (Canton PD) from the Department of Justice (DOJ) Equitable Sharing Program and
Commonwealth of Massachusetts. The objective of the audit was to assess whether the cash and/or
property received by the Canton PD through the Equitable Sharing Program was accounted for properly
and used for permissible purposes as defined by applicable regulations and guidelines. We reviewed asset
sharing and cash deposits from 2006-2024 and found that the department is efficiently tracking deposits,
withdrawals, expenditures, and has a positive cash balance.

Equitable sharing revenues represent a share of the proceeds from the forfeiture of assets seized in the
course of certain criminal investigations. [Note: The DOJ asset sharing came from the Drug Enforcement
Administration’s (DEA) criminal investigations]. From 2015 through 2024 Canton PD received over $1.8
million dollars from DOJ asset sharing. We found that Canton PD complied with the equitable sharing
guidelines.

The Audit Team reviewed asset sharing received from the DOJ Equitable Sharing Program, from Fiscal
Years (FY) 2015 through 2024. The amounts below include interest on monies.

                                                                                                                      $395,262.40

                                                      $106,891.20
   $79,907.84                $87,517.58                             $90,418.87
                                                                                              $71,471.28 $72,283.41
                                                                                 $43,733.53
                $17,894.87                $7,911.02

      2015        2016         2017         2018         2019         2020         2021         2022        2023         2024

                         Asset sharing received from the DOJ Equitable Sharing Program (2015-2024)

The Audit Team conducted interviews (including Chief Rafferty and the Canton Finance Director who
manages the forfeiture accounts), examined financial records, and reviewed forfeiture proceeds and
expenditures of equitable sharing funds. We relied on computer generated data (spreadsheets) to identify
equitably shared revenues and property purchased or awarded to the Canton PD during the audit period.

As a result of the audit, we concluded the Canton PD appropriately spent and accounted for all equitable
sharing funds from both the DOJ and the Commonwealth of Massachusetts. The equitable sharing monies
were spent on specific authorized police equipment and justified overtime for officers.

Section 13: Forfeiture Forensic Review · PDF text layer

This audit did not identify any purchases of concerns regarding Canton PD’s acquisitions of equipment.
We found the Canton PD has procedures for completing and submitting Equitable Sharing Agreement and
Certification (ESAC) reports to DOJ, and documentation to the Commonwealth of Massachusetts.

The Canton PD began the audit period with a balance of $180,591.19. During the period of October 1,
2023, through September 30, 2024, the Canton PD received $381,156.30 and spent $375,495.66 in
equitable sharing funds, primarily on salaries (overtime). They spent other monies on law enforcement
equipment and subscriptions. We found that the funds received and spent were within policy and in the
best interest of the Town of Canton.

From 2015-2024, equitable sharing funds were spent on salaries (overtime to meet minimum staffing
requirements) and law enforcement equipment such as police vehicles, tactical gear, computers,
portable radios, vehicle dashboard cameras, Flock cameras, tasers, video servers, firearms and other law
enforcement related necessary equipment. We found that sharing funds were spent on promotional
exams for sergeants and lieutenants in 2020, in the amount of $17,000. We recommend that the Town of
Canton pay for the exams, versus using equitable sharing funds.

Equitable Sharing Program
The Audit Team identified that the Canton PD conducts yearly audits
on all accountable property purchased with equitable sharing funds.
We found that the management and administration of the accounts
was acceptable, and we did not identify any deficiencies. The Town of
Canton Finance Department records all equitable sharing funds and
expenses related to expenditures of funds in its accounting system.
Chief Rafferty coordinates expenditures of equitable sharing funds
with the finance department,

Equitable Sharing Funds Expenditures: FY 2015-2024
According to its accounting records, the Canton PD spent DOJ equitable sharing funds as shown below:

                                                                                                                         $384,676.06

                                                          $269,309.62

                $208,000.34
  $194,022.28                 $188,534.40

                                            $118,324.28                 $112,281.81
                                                                                      $71,447.13 $71,471.28 $72,283.41

      2015         2016          2017          2018          2019          2020         2021       2022        2023         2024
                                        Spend of DOJ Equitable Sharing Funds (2015-2024)

Section 13: Forfeiture Forensic Review · PDF text layer

The Audit Team has reviewed 100% of the total funds expended and determined the expenditures of DOJ
equitable sharing funds were permissible and supported by adequate documentation.

Audit Approach
The Audit Team reviewed Canton PD’s compliance with the Equitable Sharing Program to assess whether
it accounted for equitable sharing funds properly and used the sharing funds for permissible purposes.
[Note: We applied the Equitable Sharing Guide as our primary criteria.]

The Audit Team reviewed the Equitable Sharing Guide which provides procedures for submitting sharing
requests and outlines the proper use of- and accounting for equitable sharing assets. To conduct the
audit, the Audit Team reviewed the Canton PD’s compliance with the following:

•   Equitable Sharing Agreement and Certification Reports to determine if these documents were
    complete and accurate.
•   Finance Department accounting for equitable sharing resources to determine whether standard
    accounting procedures were used to track equitable sharing assets.
•   Use of equitable sharing resources to determine if equitable sharing cash and property were used for
    permissible law enforcement purposes.
•   Reviewed the Canton PD inventory process that maintained a manual spreadsheet of inventory,
    ensured that it was updated when equipment was added, disposed of, or reassigned.

Commonwealth of Massachusetts
The Audit Team reviewed Canton PD’s compliance with the Commonwealth of Massachusetts General
Laws, Chapter 47 (d) to assess whether the department accounted for equitable sharing funds properly
and used the sharing funds for permissible purposes. Pursuant to the laws, proceeds seized were split
equally between the Norfolk County District Attorney’s Office and Canton PD. The Audit Team met with the
First Assistant District Attorney who stated they process criminal seizures for the Town of Canton and
review probable cause for the asset seizures. We determined that Canton PD was following policies and
procedures. From 2006-2024 Canton PD received $319,171.70 in asset sharing from state seizures and
were found to be in compliance with policies and procedures.

Section 13: Forfeiture Forensic Review · PDF text layer

SECTION 14:
 Evidence Review

                                                     Image source: Boston Herald

Section 14: Evidence Review · PDF text layer

SECTION 14: EVIDENCE REVIEW
a) Review evidence room procedures and adherence to procedures.

The Canton PD evidence procedures are sound and in alignment with industry best standards. The
department's records management system utilizes a well-known public safety software package known as
IMC. This software is one of the prevalent police records management software systems found in
Massachusetts. The IMC system has a very functional evidence and property component available. IMC is
a police records management software formerly provided by Tri Tech Systems, now called Central Square.

The Canton PD Chain of Custody-Evidence/Property Policy No. 1.16 (11/26/2023) meets Accreditation
standards. The Canton PD received its first Certification from the Massachusetts Police Accreditation
Commission in 2017, became fully Accredited in 2018, and has been re-accredited twice since.

b) Review whether the department has sufficient evidence collection supplies and items.

The Audit Team conducted a visual and physical inspection of the evidence collection materials which
included plastic evidence bags, paper evidence bags, cardboard boxes, sealing materials, access to
evidence lockers and access to an electronic logbook. Evidence collection supplies are accessible to all
officers and are located in the Temporary Evidence Storage room. Officers can pick up supplies as needed,
and the supplies are replenished regularly by the Evidence Custodian who is responsible for the evidence
materials and evidence rooms. The Audit Team concluded that the equipment is adequate and conforms
with the current MPAC standards.

c) Review whether evidence room policies and procedures meet industry standards.

The Audit Team conducted a physical assessment and noted the evidence storage areas are under strict
video monitoring with access controlled by electronic cards. This information is maintained in an
electronic log controlled at the Town Administrator. Surveillance footage of evidence access areas can be
reviewed, but not altered, by either the primary or alternate evidence custodian. All sworn officers have
electronic card access to the temporary evidence holding and processing room, which is under 24-hour
video surveillance. All evidence brought into the station after-hours for submission into evidence is logged
and deposited into a secure temporary evidence container, pending final processing by the evidence
custodian. Once it is secured in the temporary evidence container, the only person(s) that can retrieve it is
the Canton PD evidence custodian(s). Access is restricted and detailed entry logs are maintained
electronically.

d) Review officer evidence collection training.

The Audit Team reviewed the officer evidence collection training and found that all officers have received
basic training in evidence collection. Evidence collection training is an ongoing practice, and officers
receive continual training and updates on current laws and practices during their in-service training, which
is held bi-annually. The Canton PD is in conformance with the CALEA and MPAC standards of evidence
collection training. It is crucial to remember that virtually anything can be, or become evidence, therefore
it must be handled, recorded and documented appropriately. The essence of a good and thorough
evidence collection program encompasses the ability to answer the following questions:

Section 14: Evidence Review · PDF text layer

• What was discovered?
     • Who discovered it?
     • Where have they discovered it?
     • What have they done with it?
e) Review officer access to evidence room and limit/revise per best practices.

The Audit Team conducted a physical and visual inspection of the evidence storage area and interviewed
the Evidence Custodian. The evidence storage area is divided into two (2) rooms with the first one is
accessible to all officers and can be accessed twenty-four (24) hours per day, seven (7) days per week.
This first room is where the temporary storage lockers are located as well as a section of available
evidence collection materials, two (2) sets of overflow storage lockers and an additional wall of small
evidence lockers. After the evidence is locked into a container, the key is secured in the same locker and
can only be accessed again by the Evidence Custodian, who is equipped with a master key. No officer can
access, manipulate, destroy, add or alter evidence once it is placed into a temporary locked evidence
container. The second room is where all the evidence is stored and classified by year and is only
accessible to the Evidence Custodian. This system and the electronic safeguards in place make it virtually
impossible for evidence tampering or altering to take place once evidence has entered the evidence
storage areas.

Accessibility limits to the Evidence Rooms is in conformance with current CALEA and MPAC standards.

f) Assess adherence to/implementation of recommendations from past evidence audits.

A review of prior audits and recommendations show that the Canton PD has implemented all
recommendations not requiring major building renovations or significant budget enhancements. Those
recommendations that require building modifications have either been completed or they are at the town
level pending approval and funding for completion. The Canton PD is compliant with all previous
recommendations.

g) Conduct a year-over-year inventory of the evidence room content, including firearms, cash, and
drugs.

The Audit Team conducted a visual inspection of the Temporary Storage of Evidence and the Evidence
Vault, which is assigned to the Canton PD Primary Evidence Custodian, for oversight and maintenance.
There are approximately 16,000 items of evidentiary value stored in the Evidence Vault at Canton PD. A
complete inventory and detailed audit was performed by an independent audit team from Pomeroy
Resources Inc. in October 2024—six (6) weeks prior to the arrival of the 5Si Audit Team. The Audit Team on
multiple occasions, one of which was unannounced, and conducted inventory checks of random items
including firearms and drugs, finding no inventory discrepancies.

The Audit Team found that the firearms are properly stored in the evidence room. Firearms are only sent for
Ballistics Testing on a case-by-case basis, and their disposal is backlogged. Ballistics Testing and Disposal
is handled by a non-government contracting company named New England Ballistics, which performs this
service at no charge to the Canton PD.

The audit concluded that the evidence, and the records relating thereto, are being maintained in

Section 14: Evidence Review · PDF text layer

full compliance with the procedures outlined in the directives of the Canton PD, proper accountability
procedures are being maintained, evidence is properly stored and protected from damage and
deterioration, and the Evidence Rooms are being maintained in a clean and orderly condition.

h) Review chain of custody laws, including completeness and accuracy.

The Audit Team, in addition to reviewing policy, reviewed the collection and processing measures for
documenting the chain of custody of evidence. The Canton PD is in full compliance, however, the Audit
Team did make recommendations regarding the documentation of evidence.

i) Review the collection, editing, and preservation of videos used for evidence.

The Audit Team examined the Canton PD's video preservation methods and procedures. Video
preservation is carried out on a dedicated desktop computer stationed near the evidence room. All videos
are downloaded using this computer, which can be used for viewing and redacting purposes, but not for
making alterations (except for limited editing like redactions for public release). The videos can be
accessed by officers using the same computer station.

The Canton PD's practices for collecting, reviewing, editing, and preserving videos for evidence align with
the MPAC standards.

j) Review firearm chain of custody in evidence.

Firearms seized by the Canton PD have strict handling procedures that must be followed due to the
potential danger they pose as evidence. All firearms acquired by the Canton PD are handled with the
utmost safety precautions. Seized guns are taken directly to Police Headquarters and never left
unattended in a vehicle. Before determining if a firearm is loaded (visually and manually clearing the
weapon), the Canton PD officer must assess if forensic examination is required, and if so, the weapon will
not be unloaded. Guns seized by the Canton PD not needing further examination will have their
ammunition checked in a secure area and stored with the action open. Any removed ammunition must be
bagged separately and submitted with the firearm as evidence. Prior to submitting to the Evidence Officer,
all seized firearms must be checked through the CJIS/NCIC database, with a copy of the results attached
to the Canton PD officer's report. Each firearm will be placed in a dedicated firearms evidence box and
stored in a locker in the Temporary Evidence area until transferred to the designated shelf in the
Permanent Evidence Room for firearms storage.

These summarized practices are being done and are in alignment with previous audit recommendations as
well as CALEA Standards.

k) Review evidence tracking software usage.

The Canton PD evidence procedures are in alignment with industry best standards. The software
management system utilizes a well-known public safety software package known as IMC. This particular
software is one of the prevalent police records management software systems found in Massachusetts.
The IMC system has a very functional evidence and property component available. IMC is a police records
management software formerly provided by Tri Tech Systems, now called Central Square.

Section 14: Evidence Review · PDF text layer

RECOMMENDATIONS
          The Audit Team recommends assigning part-time personnel, preferably a retired sworn officer,
          who would provide periodic assistance in properly disposing of evidence that is no longer
          needed. These part-time officers can better coordinate with the police prosecutors for those
          cases that have been adjudicated with their final action documented, and with the approval of
          the prosecutors' office, and dispose of evidence no longer required.
          A Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) Special Agent is housed within the
          Canton PD station on the second floor. The Audit Team recommends obtaining Ballistic Testing
          by ATF on all firearms and running a trace for ownership and NCIC check.
          Documentation regarding the chain of custody on evidence could be improved on standard
          report writing. The Audit Team recommends that every report contain an “Evidence Section”
          and in that section any evidence that is acquired is detailed in description, discovery, by who,
          and what they did with the item until its submission into the Canton PD evidence vault.

Section 14: Evidence Review · PDF text layer

SECTION 15:
 Police Detail Financial Review

                                                     Image source: Boston Herald

Section 15: Police Detail Financial Review · PDF text layer

SECTION 15: POLICE DETAIL FINANCIAL REVIEW
Police Details
Canton PD has strict internal controls and operates at a satisfactory level in all areas documenting,
monitoring, and supervising police details. The Chief of Police maintains appropriate controls of police
detail oversight and has appropriate internal controls to monitor details worked by full-time and part-time
officers. The Canton PD Administrative Assistant maintains time and attendance records, monitors detail
payroll functions, accounts payable and received.

Detail costs are reimbursed in full by the Town of Canton, or by third parties, such as National Grid,
Eversource, Bay State Gas, Verizon, MA Department of Transportation, and other third-party vendors who
obtain police services. The Canton Department of Public Works (DPW), School Department and other
departments hire officers for details. The Town of Canton is obligated to pay officer overtime based on
rank. For example, if a sergeant works a police detail for the DPW, they will be paid at a rate of time and a
half of their hourly rate of pay. Third party vendors are billed directly from Canton PD, who receives
payments (reimbursement) for transfer of the funds to the Town of Canton Treasurer/Collector’s office.

Canton PD maintains a detailed log to ensure the police details are distributed fairly amongst all the
officers, and most importantly, all requests are filled. [Note: Private Vendor Details are paid at a set
overtime rate of $67.86 per hour. The Town of Canton charges an administrative fee of $6.10 per hour
above the $67.86 rate of pay. Weekend, Holiday, and Night detail rates are billed at $77.02 per hour.] The
chart below reflects overtime (detail) costs at the department from FY 2020-2024:

 $1,200,000.00
                    $1,088,293.47

 $1,000,000.00                             $900,915.16
                                                                                  $884,392.72

                                                            $785,563.44
   $800,000.00
                                                                                                $662,727.66

   $600,000.00

   $400,000.00

                                          $237,462.24                                           $242,151.36
                                                            $173,639.96           $187,487.47
   $200,000.00      $137,015.45

         $0.00
                      FY 2020               FY 2021            FY 2022              FY 2023       FY 2024

                                    Private Vendors       Detail Pay from the Town of Canton

                          2020 – 2024 Overtime (detail) Costs at the Canton Police Department

Section 15: Police Detail Financial Review · PDF text layer

•   Part-time officers are authorized to work police details and are paid an hourly rate of $67.86 per hour.
•   A total of $4,321,892.45 was received from third party vendors for police details from 2020-2024. The
    Town of Canton reimbursed the Canton PD a total of $987,756.88 for police details from 2020-2024.
•   Total for detail overtime from 2020-2024: $5,309,649.33.

a) The administrative audit shall review the police details fund and the reason for the uncollectable
allowance of $91,074 as described by the Town FY23 Annual Comprehensive Financial Report
performed by Roselli and Clark.

We reviewed a breakdown of customer (private vendor) uncollected payments outstanding to the
department. The dates of uncollected payments range from 2019-2024. Most of the uncollected payments
are from small businesses that hired officers for private details.

Administrative Assistant and the Chief of Police reported uncollected funds are still actively being pursued
for collection. Chief Rafferty reported that larger vendors that conduct business with the department
sometimes delay payments until the end of the month. [Note: Some of the vendors (companies) pay
invoices on a net thirty (30)-day payment cycle.]

The department collection rate is just under 99% for the monies outstanding. Since the inception of the
audit, reimbursements continue to come in and the outstanding balances are being collected.

Further, neither the Police Department nor its senior officials should not be accepting monies on behalf of
the town.

b) The onboarding process for customers that use police details should be reviewed, and
recommendations should be provided on how to streamline and improve the process.

We reviewed procedures for onboarding new customers and existing customers. Normally, Canton PD will
take a request from a vendor and input the information, date, time, number of officers, contact
information and vendor company, which are placed into a scheduling system (Crew Sense). The Chief of
Police and Administrative Assistant reviews the request for police details services, ensures vendors and/or
businesses have approved town permits before approvals. We found that the Administrative Assistant has
implemented a new process of sending invoices weekly to vendors to expedite payments. The Canton PD
is a service provider for the Town of Canton. Once the service is provided and the bill is issued it should be
incumbent upon the Finance Director and the billing department for the town to collect monies owed.

          RECOMMENDATIONS
          The Canton PD should continue to accept, schedule and provide services to those businesses
          and customers requesting police details. Once the detail service has been provided, the
          Canton PD will create and send the vendor/customer an invoice, copying the Town of Canton
          (Finance Director or their designee) with instructions for the vendor to submit payment to the
          Town of Canton.

Section 15: Police Detail Financial Review · PDF text layer

The responsibility to ensure invoice payments should fall to the Town of Canton, Finance
          Director. Under no circumstances should the Canton PD be accepting cash/checks or
          payments.
          Communication between the Canton PD Administrative Assistant and the Town of Canton
          Office of Finance is crucial, as the Office of Finance should advise the Canton PD if there are
          outstanding collections to be made prior to accepting detail requests from certain businesses.

Section 15: Police Detail Financial Review · PDF text layer

SECTION 16:
 Additional Administrative Items to Review

                                                     Image source: Boston Herald

Section 16: Additional Administrative Items to Review · PDF text layer

SECTION 16: ADDITIONAL ADMINISTRATIVE ITEMS TO
REVIEW
a) Review all cash fund accounts maintenance and general ledgers.

Canton PD Administrative Assistant oversees police detail accounts, ledgers, and payroll submissions. No
inaccuracies were identified. All accounts were accurate and standard accounting practices were used.
We found the town finance department is responsible for overall account reconciliation for the
department and general ledgers, cash fund accounts and maintenance.

b) Review communications and scheduling between Canton Municipal departments and the Canton
Police Department regarding police details.

The Canton PD Administrative Assistant is responsible for scheduling and communicating with municipal
departments and private vendors that request police details. On occasion, department heads will
communicate directly with Chief Rafferty and request police details. Most communications sent from
municipal departments to Canton PD requesting police details are phone calls to the police dispatch
center. We determined the scheduling systems are in place to service the town in an effective manner. In
the event the Canton PD is requested and unable to fulfill the request for detail, the request will be
forwarded and filled by a neighboring town police officer.

c) Review grant applications submitted and the number of grants received. Review grant opportunities
available to the department to make sure the department has maximized all available Federal and
State grants.

The Audit Team conducted a thorough review of grant applications and found that the department has
been successful in capturing grants to enhance police services and the police budget. Deputy Chief
Patricia Sherrill, for instance, secured a grant from the Commonwealth of Massachusetts Department of
Health to hire a Mental Health Professional. In 2022, the Department received $118,000 to support a full-
time mental health clinician who collaborates with officers in responding to calls related to mental health
issues involving citizens. This grant has been successfully renewed in the past three (3) years.

The Select Board approved multiple grant applications submitted by the Canton PD, resulting in funding
allocations of $100,000 for body-worn cameras, $121,759 for personal line items of patrol officers and
sergeants, $89,336 for a training grant providing sixteen (16) hours of legal updates for employees, and
$27,529 for a road safety grant for officers to conduct traffic enforcement. Deputy Chief Sherill
consistently looks for grant opportunities that fill applicable needs for the Canton PD.

d) Review the process and quality of performance reviews of senior officers, including the Chief of
Police.

The Select Board does not currently carry out written performance evaluations for senior leaders or the
Chief of Police. However, as per the contract, the Select Board holds the power to assess the performance
of senior leaders and the chief of police. Currently, there are no established formal mechanisms in place
for individual accountability, such as mid-year assessments or final performance reviews, aimed at
enhancing future performances. Enhancing the process could involve implementing a results-focused

Section 16: Additional Administrative Items to Review · PDF text layer

written performance appraisal system that documents achievements and areas requiring enhancement.
Introducing a structured evaluation form covering areas like leadership, program management, best
practices, and coalition building could help streamline the appraisal process.

e) Review process of responding to burglar alarms throughout the town.
The Canton PD has established protocols for promptly and securely addressing calls. Documentation of
their discoveries and communication with dispatch are recorded in the activity log. Equally, the
department does not discriminate in responding to burglar/house alarms for designated town authorities.

An examination of dispatch records for burglar alarms revealed a lapse in Canton PD dispatching a patrol
car in response to a burglar/house alarm in May 2024. Chief Rafferty was promptly alerted to this issue and
took corrective action through the disciplinary process.

f) Review the use of personal cell phones and the practice of “self-dispatching.”

Throughout this report, the Audit Team strongly recommends that Canton PD officers refrain from using
their personal cell phones for work-related purposes. Instead, the Audit Team suggests that the Town of
Canton provide all Canton PD officers with departmental phones as previously advised.

The term "self-dispatching" has been prominently featured in public statements by the Karen Read trial
team and has been circulating on social media insinuating some wrongdoing within the Canton PD. While
off-duty police officers in Massachusetts are not obligated to respond to crimes, it would be disheartening
to think that an off-duty officer would choose to ignore a person in need. Massachusetts Police
Accreditation Standards delineate an officer's authority and protections from liability off-duty.

The Audit Team did not discover any instances of Canton PD officers inappropriately “self-dispatching” or
involving themselves in public encounters. All assistance provided by off-duty Canton PD officers was
deemed appropriate by Canton PD leadership and members of the community.

Massachusetts General Law Chapter 258 outlines the rules and restrictions concerning civil liability
protection for police officers. Specifically, officers are granted liability protection for their on and off-duty
actions, unless the officer knows or should have known, their actions were in violation of the law or
department policies.

While off duty and within the jurisdiction of their municipality, an officer may conduct an arrest only under
the following circumstances:

•   There is an immediate need to prevent a crime, or apprehend a suspect,
•   The offense warrants a full custodial arrest, and
•   The officer can provide police identification during the arrest.

          RECOMMENDATIONS
          None.

Section 16: Additional Administrative Items to Review · PDF text layer

SECTION 17:
 Civil Rights Review

                                                     Image source: Boston Herald

Section 17: Civil Rights Review · PDF text layer

SECTION 17: CIVIL RIGHTS REVIEW
a) Review civil rights complaints and intake process to ensure compliance with all state and federal
mandates.

The Audit Team determined that the Canton PD is committed to accepting and investigating civil rights
complaints about any actions and performance of personnel. Chief Rafferty said her team is committed to
providing the highest level of quality police service to all citizens. Our team did not identify any instances
of civil rights complaints made against any officers. We checked with both state and federal authorities
and determined that no civil rights complaints were made against members of Canton PD.

Whether an allegation or complaint appears to be valid or baseless, each complaint should be objectively
evaluated, and the investigation should be well documented should a question arise at a later date. All
information obtained during the investigation of a personnel complaint is considered confidential.
Therefore, it is imperative that all documents pertaining to personnel complaints be properly secured to
protect all parties involved (See Section 3: Professional Standards and Accountability).

b) Review the involvement of uniformed officers and the use of municipal resources in any town
political process, including meetings, petitions, and elections.

We examined all complaints lodged by residents, as well as the procedures for receiving and monitoring
them, to verify that the Canton PD adhered to all applicable protocols, as well as state and federal laws.
Our team investigated the engagement of uniformed officers to ascertain whether they made use of town
resources in any capacity related to local politics, elections, or public meetings beyond their official
responsibilities. Additionally, we reached out to the Town of Canton Attorney to identify any legal actions
taken against Canton PD personnel. We have no information that would indicate any involvement with a
member of the Canton PD as it relates to town meetings, petitions, and elections, or in using municipal
resources in anything other than an official capacity.

c) Review the department’s compliance with Title IV and DOJ laws and regulations.

This law (Title VI of the Civil Rights Act of 1964) prohibits discrimination based on race, color, sex, or
national origin for organizations receiving federal funding. The Canton PD policy aligns with, and practices
in accordance with this legislation. The Department of Justice (DOJ) is responsible for enforcing Title IV
and has the power to step in if a law enforcement agency is found to be systemically violating individuals'
rights. Massachusetts has established guidelines detailing the processes for investigating and resolving
complaints against law enforcement officers. The Canton PD has addressed gaps in policy application in
Section 3 on Professional Standards and Accountability, and Section 8 on the Citizens Complaint Process.
There have been no Civil Rights investigations involving the Canton PD in the last decade to knowledge of
the Audit Team.

There was a Federal Grand Jury convened in the District of Massachusetts that concluded without findings
or indictments.

Section 17: Civil Rights Review · PDF text layer

RECOMMENDATIONS
          It would be beneficial for Canton Town Leaders to acknowledge to the public that:
            •   Settlements made by insurance companies do not entail an admission of guilt, but rather
                are typically based on financial considerations.
            •   Insurance companies have no ability to negotiate or place promotional limitations on an
                officer’s career as a part of a settlement.

Section 17: Civil Rights Review · PDF text layer

SECTION 18:
 Liaison Interviews

                                                     Image source: Boston Herald

Section 18: Liaison Interviews · PDF text layer

SECTION 18: LIAISON INTERVIEWS
Ms. Kendall O’Halloran, Chair of the Canton School Committee

On December 3, 2024, Kendall O'Halloran, Chair of the Canton School Committee, was interviewed. Ms.
O’Halloran said the school committee has a strong partnership with Chief Rafferty and members of the
Canton PD. She stated that Chief Rafferty cares about the community and is always available when called
upon by the committee, and school superintendent.

Ms. O’Halloran has lived in the Town of Canton for seventeen (17) years, is on the Canton Community
Preservation Committee, and has had positive experiences with Canton PD officers. Ms. O’Halloran
described Chief Rafferty as very responsive to the committee’s needs and a good leader for the
community. Ms. O’Halloran said she personally witnessed Chief Rafferty deescalate a situation when
unauthorized political activities were occurring on school property.

Derek Folan, Superintendent of the Town of Canton Public Schools

On December 3, 2024, Derek Folan, Superintendent of the Town of Canton Public Schools, was
interviewed. He stated that he had an exceptional working relationship with Chief Helena Rafferty and
School Resource Officers. Superintendent Folan praised Chief Rafferty for her dedication and leadership
to the Town of Canton. He described Chief Rafferty as an exceptional leader for the Canton Alliance for
Substance Abuse Committee and Cops for Cancer. Superintendent Folan said the success of the Town of
Canton School System is directly related to the open communication and “trust built with Chief Rafferty”
and the Canton PD. He praised the work of three (3) Canton PD School Resource Officers who are
assigned to the Canton High School, Middle School, and Elementary Schools.

Superintendent Folan said officers who worked at athletics events and town meetings were always
professional and highlighted the outstanding work officers who assist at these events.

He noted that parents of athletes have been harassed by a “blogger” at various school sporting events,
which further necessitated guidance and assistance from Chief Rafferty, which she immediately provided.

Greg Connors, Assistant District Attorney, Norfolk District Attorney’s Office

On December 5, 2024, Greg Connors, Assistant District Attorney (ADA), was interviewed and said he has a
positive working relationship with members of the Canton PD. He highlighted numerous investigations
where detectives had successfully arrested violators for serious crimes that had occurred in the Town of
Canton. He stated the Norfolk District Attorney’s (DA) office services forty-seven (47) police departments
in Norfolk County, MA. Mr. Connors considered Canton PD to be in the top one third (1/3) out of the five (5)
surrounding police departments in terms of the quality of their work and the caliber of officers that he
deals with.

ADA Connors commended Canton PD officers, both retired and current, for their work, indicating a strong
collaborative relationship between his office and the Canton PD. The accessibility of a duty phone at the
DA’s office streamlined the process of case submissions, allowing officers to seek advice or report cases
at any time.

Section 18: Liaison Interviews · PDF text layer

Emphasizing the importance of the Body Worn Camera (BWC) program for officer safety, ADA Connors
advocated for its continued use within the Canton PD based on his positive experiences. However, he
noted a deficiency in the utilization of License Plate Readers (LPRs) within the Town of Canton, resulting in
a specific robbery case remaining uncharged. ADA Connors praised the Canton PD detectives for their
successful apprehension of a shooter in a recent case and commended the exemplary work of the Juvenile
Probation officer.

Charles Doody, Town of Canton, Town Administrator

The Audit Team interviewed Town of Canton, Town Administrator Charles Doody. Administrator Doody has
held the position of Town Administrator since October 2022 after serving the Town of Canton as a fireman
for 28 years. Administrator Doody ascended to the position of Chief of the Fire Department in 2008. He is a
lifelong Canton native and graduated from Canton High School. Administrator Doody has known the Chief
Rafferty and her executive staff for his entire professional career. He maintains a positive working
relationship with the Canton PD and command staff and has confidence in their abilities. Administrator
Doody stated the Canton PD is professional and responsive. They are open to collaboration and receptive
to request from his office or his representative to accommodate the Town of Canton at public events.

          RECOMMENDATIONS
          In relation to the investigative reports authored by Canton PD members and the interview with
          ADA Connors, The Audit Team noted potential deficiencies in the reporting process. These
          included inconsistencies and gaps in information. The Audit Team conferred with ADA Connors
          to ensure some of the recommendations being made by the Audit Team would align with the
          objectives of the District Attorney’s office. ADA Connors agreed with the below
          recommendations.
            •   Officer Identification: The Canton PD reports should prominently feature the names of
                all officers involved in the incidents, as well as the names of judges, prosecutors and
                defense attorneys related to the case.
            •   Simplify Reporting: The Canton PD should consolidate multiple brief reports into a
                single, detailed and concise/comprehensive report. This approach would help prevent
                contradictory statements and inaccuracies.
            •   Use of Audio Recording Devices: Canton PD Officers and detectives should utilize audio
                recording devices during witness and suspect interviews, with consent whenever
                possible. This would ensure accurate documentation of interactions.
            •   Department Issued Mobile Phones: Each member of Canton PD should be equipped
                with a department-issued mobile phone for official use. This would facilitate effective
                communication of work-related information and allow for the capture of photographs at
                crime scenes.

Section 18: Liaison Interviews · PDF text layer

Additionally, ADA Connors raised safety concerns about ATF operations. He noted that some
          operations orchestrated by agents seemed to target arrests in the Town of Canton, raising
          concerns about the safety of such initiatives.
          ADA Connors supported the implementation of the Body Worn Camera (BWC) program,
          advocating for its utilization by the Canton PD. Drawing from his own positive encounters, he
          highlighted the benefits of the BWC program, particularly in enhancing officer safety.
          Concerning the involvement of informants in State cases, ADA Connors stated that in the State
          of Massachusetts, informants lacked legal protections. Their role was confined to providing
          "initial tips," and they were managed accordingly. Expressing reservations, ADA Connors
          discouraged the reliance on informants in proactive undercover police operations to mitigate
          potential risks of exposure.

Section 18: Liaison Interviews · PDF text layer

SECTION 19:
 Security

Section 19: Security · PDF text layer

SECTION 19: SECURITY
The Audit Team conducted an on-site security assessment of the Canton PD.

•   The department has access for the public to enter the department in the lobby area where the public
    can obtain reports, file reports and/or conduct other business. This area is not secured. Furthermore,
    after a detailed physical assessment of the building there are numerous vulnerabilities inside the
    building that threaten the safety of the officers and ultimately the public. The Audit Team will not list
    the vulnerabilities in this document but will provide an oral briefing to elected officials in the Town of
    Canton upon request.
•   Scan card access to other areas of the department is limited to sworn officers and other employees,
    however several doors lack key card locks.
•   The department has video cameras located on all floors, hallway areas, and cameras positioned in
    other areas of the department, including the sallyport area (garage), cellblock area, property rooms,
    evidence and radio communication space. The video system does not clearly record the activity on
    Washington street at the end of the Drive, nor does it provide coverage around the permitter of the
    building.
•   We reviewed the IT systems to ensure that cameras are adequately preserving the potential evidence
    in the event it is needed for court purposes. The current set-up is on a motion detection system and
    can preserve recordings for approximately 800 days depending on the amount of activity.
•   The exterior of the building and the rear parking lot is open to the public. Police cruisers are accessible
    from a tree line and there is no barrier fence around the parking lot. Cruisers, their content, and the
    officers are vulnerable from this area. The only protection offered at the rear of the department is a sign
    stating authorized personnel only.

Access from the tree line in the rear of the PD. Rear of the department is Completely exposed.

Section 19: Security · PDF text layer

RECOMMENDATIONS
          The following are in alignment with industry best standards and practices:
            •   The rear parking area where police vehicles and personal vehicles are parked needs to be
                secured with security fencing with privacy slats. Police cruisers which contain law
                enforcement equipment and firearms should be parked within secure spaces.
            •   Install an electronic rolling and retracting gate and an eight (8)-foot chain link fence, with
                privacy slats and intercom for security prior to the sally port entrance. This protects the
                public and provides much needed security for the police department.
            •   The entrance to the department and the front of the building facing Washington street
                needs safety bollards, which provide a barrier to vehicles from damaging or ramming the
                doorway and building.
            •   Contact the Office of the Secretary of Public Safety and Security for potential funding
                sources to enhance the security posture of the headquarters facility and surrounding
                property. This office provides grants under the 8000-0313 Local Public Safety Projects
                and Grants Earmarks.

Section 19: Security · PDF text layer

SECTION 20:
 Recommended Improvements & Summary

Section 20: Recommended Improvements and Summary · PDF text layer

SECTION 20: RECOMMENDED IMPROVEMENTS AND
SUMMARY
a) Based on the findings, propose specific enhancements and e) Provide a complete report of
compliance issues and how they can be improved and enforced to industry standards.

I. Section 1, part (b): Interrogating Suspects / Interviewing Witnesses or Victims
Uniform approach to documentation:
•   Implement standardized templates.
Ongoing evaluation and improvement:
•   Evaluate interview effectiveness and remediate shortcomings.
•   Commanding officer review.
•   The Officer in Charge (OIC) of the Investigations Unit reviews reports deemed inadmissible in court, or
    where prosecution declined.
Separation of suspects during questioning:
•   Suspects should be mirandized and separated from each other prior to- and during interviews.
Training and policy amendments:
•   Where deficiencies are identified, implement amendments to policy and corrective training.

II. Section 1, part (c): Evidence and Evidence collection and processing
Officers should be equipped with essential equipment readily available in their vehicles:
•   All sergeant vehicles should be equipped with digital cameras for photographing and memorializing
    crime scenes.
•   All Canton PD marked units should have crime scene preservation kits and evidence collection kits.
•   All sergeant’s vehicles and detective vehicles should have full crime scene kits including evidence
    bags and sealing equipment.
Photographs of evidence should be documented and recorded as evidence:
•   Evidence should be photographed at the time of seizure.
•   Evidence photographs should be entered into evidence as their own exhibit.
Unscheduled audits of the evidence room:
•   Canton PD should conduct “unannounced audits.”
Additional crime scene processing training:
•   Patrolmen and detectives should attend “Crime Scene Preservation Class.”

III. Section 1, part (d): Testifying
Training on testimony clarity:
•   Officers should be trained to respond to questions professionally and accurately.

Section 20: Recommended Improvements and Summary · PDF text layer

Handling disagreements professionally:
•   Officers should learn strategies to maintain composure and professionalism despite challenging
    questions.
Identifying assumed truths:
•   Training should include techniques for identifying and addressing assumed truths within questions.
Exposure to high-profile cases:
•   Mock trials or role-playing exercises simulate the pressures of such trials and practice skill
    development.
Continuous skill development:
•   Regular workshops and refresher courses focusing on best practices in courtroom testimony.
•   Explore no-cost training opportunities with the prosecutor's office.

IV. Section 1, part (e): Mental Health Policy
Funding for a Mental Health Professional:
•   Budget allocations should be considered by the Town of Canton leadership in conjunction with town
    officials at various levels to secure funding for this position should the grant be no longer available.

V. Section 1, part (f): Juveniles
Annual training on appropriately handling juvenile offenders:
•   Institute an annual training to be attended by all sworn personnel concerning the handling of juvenile
    offenders.
•   Require written certification from officers that they have read and understand the corresponding
    policies related to handling of juveniles.

VI. Section 1, part (g): Community Relations Policy
Joint review of community relations policy with the Canton Town Selectman:
•   Policy adaptations should be conducted as a joint effort by the Canton PD administration and Town
    Selectman.

VII. Section 1, part (k): Radio and Personal Cell Phone Use
Funds for department issued cellphones:
•   Issue department-owned cell phones to all sworn officers.
•   As a second option, purchase department phones for patrol officers to sign out at the beginning of
    each shift, or issue individual phones to the respective patrol cars.
Policy requiring department communications only be conducted on department cell phones:
•   Prohibit the use of personal cell phones to conduct police business.
Address inadequate radio communications:
•   Ensure that radio communications are available and reliable in all areas of the Town of Canton.

Section 20: Recommended Improvements and Summary · PDF text layer

•   Canton PD should work with the Information Technology Specialist and Town Select Board members
    to identify funding needs for updated equipment, or an otherwise appropriate resolution.

VIII. Section 1, part (l): CEO Notification Policy
Notification to the Chief AND Deputy Chiefs:
•   The Deputy Chiefs AND Chief should be immediately notified of all significant events as detailed in the
    CEO Notification Policy, including those events that allow for delayed notification.

IX. Section 1, part (m): Communications Standards of Conduct Policy
Review and reinforce policies:
•   Implement continuing education or policy acknowledgment requirement regarding communication
    policies.
Incident analysis:
•   The specific breakdown in communication should be analyzed to understand why the officer failed to
    act according to policy and to improve training and protocols accordingly.
Strengthen accountability measures:
•   Ensure that there are clear consequences for not following policy to reinforce the seriousness of
    compliance.
Monitor Effectiveness of Reforms:
•   Post-incident evaluations should be conducted to assess the effectiveness of any implemented
    changes.
Enhance support systems:
•   Consider additional support or backup systems to prevent single points of failure in communications.

X. Section 1, part (o): Dispatch Functions
Establish a long-term data retention plan:
•   Plan for the upcoming expiration of the free recording service agreement and plan for the retention of
    these recordings in the future.
Assign civilian dispatchers to work dispatch shifts with officers:
•   A civilian dispatcher can handle the majority of the calls while retaining the institutional knowledge of
    the sworn officer.

XI. Section 1, part (p): Field Reporting Policy
Employ standardized report writing protocols:
•   Standardize report writing requirements.
•   Develop a required format with minimum standards and expectations.
•   Fields that are not applicable can be marked as such. Documenting any lack of action by marking
    “none” or “N/A.”

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XII. Section 1, part (r): Social Media Policy
Develop and conduct social media use training:
•   Conduct regular training sessions for officers involved in social media management, reviewing security
    protocols for social media accounts.
Institute a social media manager:
•   For the Patrol and Detectives Divisions as well as a Senior Lieutenant.
Resume social media posts:
•   Resume posting to social media outlets as it relates to immediate community concerns, such as
    accidents, construction closings and police activities.
•   Ensure consistent and timely communications across all platforms to effectively engage with the
    community.
•   Post the same messages across all social media platforms, especially Safety and Missing Person
    Alerts.
•   Leave comments off.

XIII. Section 1, part (t): Alternatives to Arrest
Arrest alternatives should be based on written policy or legal protocols:
•   Default actions should be based on laws and departmental policies.

XIV. Section 1, part (u): Field Training Program
Expand the FTEP program:
•   The FTEP program should be expanded to 8 weeks to create opportunity for additional exposure to the
    various types of calls and responses necessary as a police officer.

XV. Section 1, part (w): Body-Worn Cameras
Body-worn camera training:
•   The official overseeing the BWC program should coordinate with the sergeant in charge of training to
    conduct training.
•   BWC videos that capture positive and negative actions are a great training tool for the Canton PD.

XVI. Section 1, part (x): LPR’s / Flock Cameras
•   Purchase additional cameras.

XVII. Section 1, part (z): Informants
Updated procedures for meeting with informants:
•   Require a minimum of two (2) officers to be present when meeting with an established or potential
    informant.
•   The informant should be searched for contraband and weapons prior to every meeting.

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•   Conduct thorough background checks to include a full criminal history, photos and fingerprints when
    establishing an informant.
•   Canton PD sergeants should provide a summary of the informant's reliability and their planned usage
    to the Lieutenant over Investigations.
•   Canton PD detective should author an initial activation report to be approved by a lieutenant or higher-
    ranking Canton PD official.
•   CDP Lieutenant of Investigations, or higher-ranking Canton PD official, should conduct periodic
    assessments (180 days) to validate continued establishment and use of an informant.
•   All usage, debriefings and information obtained from, or through the use, of an informant should be
    documented and copies of those reports should be maintained in the informant file as well as the
    respective case file.
•   All informants should be debriefed every ninety (90) days at minimum. This quarterly debriefing should
    be maintained in the informant file.

XVIII. Section 1, part (bb): Sexual Assaults
Crime scene response training emphasizing first responder protocols:
•   Canton PD officers should undergo training in proper procedures upon immediate response to the
    scene, especially considering the significance of the "First Complaint" in sexual assault cases.

XIX. Section 1, part (cc): Dead Bodies Policy
Crime scene training including scenarios and tabletop exercises:
•   Conduct tabletop exercises to provide a training opportunity for officers to anticipate potential
    challenges and initiate constructive discussions. Exercises can be conducted locally without the need
    for elaborate setups or travel.
•   Develop a proactive training approach that enables the department to equip each officer effectively
    and ensure they are well-prepared to fulfill their duties.
•   Officers should photograph all crime scenes that resulted in suspicious deaths.
All police vehicles should be equipped with standard evidence collection equipment:
•   All patrol officers should have standard evidence collection equipment in their patrol cars.
•   As the first responders, Canton PD officers should receive training on evidence collection and
    preservation relevant to crimes scenes involving dead bodies.

XX. Section 1, part (ee): Criminal Intelligence
Ensure documentation of all criminal intelligence:
•   Develop a consistent format for documenting and memorializing all criminal intelligence.

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XXI. Section 1, part (gg): Victim Witness Rights
Ensure enforcement of laws as written:
•   Canton PD should enforce all laws as applicable and as cited in Massachusetts General Law Chapter
    253b regardless of public sentiment.

XXII. Section 1, part (pp): School Resource Officer Policy
Assign one (1) SRO to each school:
•   It is advisable for additional resources to be assigned so that each school can always have its own
    officer present, rather than requiring one (1) officer to cover three (3) schools.

XXIII. Section 1, part (ss): CALEA Standards on Specified Policies
Updating CALEA accreditation or incorporating MPAC standards into existing policies:
•   Update the CALEA accreditation or incorporate MPAC standards into the existing Policies and
    Procedures of the Canton Police Department to enhance overall standards compliance.

XXIV. Section 1, part (vv): Personal Use of Cellular Phones
Policy prohibition against the use of personal cellphones for department business:
•   All officers of the Canton PD should be issued departmental phones.
•   At a minimum, all officers of the rank of sergeant and above, as well as the detectives in the
    investigative division, should be issued departmental phones.
•   Use of personal phones to conduct department business should be prohibited.

XXV. Section 2: Crime Scene Protocols
Canton PD should digitally photograph all crime scenes upon initial response:
•   Canton PD should conduct basic scene security and documentation, including photographs and a
    sketch of the scene, regardless of whether the investigation is transferred to another law enforcement
    agency, such as the Massachusetts State Police.
Crime scene training:
•   Training in Crime Scene Preservation/Processing.
Evidence collection equipment:
•   Ensure readily available collection equipment.
Change the culture of expectations for response to a scene:
•   Even though the investigation will be turned over to Massachusetts State Police, Canton PD should
    take ownership of the scene as the first responders and conduct follow-up investigations with MSP.

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XXVI. Section 3: Professional Standards and Accountability
The Internal Affairs (IA) Complaints/Investigation procedures should be updated to include a formal
investigation process with improvement recommendations or corrections.
•   In addition to the existing policy in Section 4.01, a formal investigation process should be established.
    Such a process should include witness interviews, statements in writing or recorded interviews by
    officers.
•   Recommendations should be made in the findings report such as additional training needed or
    protocols to improve the officer’s conduct.
Pursuant to existing policy, any citizen complaints regarding misconduct are directed to the police
department and reported to “the Officer in Charge.”
1. If an officer is made aware of a citizen wishing to file a civilian complaint, whether against that officer
   or another officer, the officer should immediately contact a supervisor. It then becomes that
   supervisor’s responsibility to immediately respond to the scene and interview the complainant.
2. The supervisor should offer to accompany the complainant to Canton PD for the purpose of providing
   the complainant with the proper civilian complaint forms and any additional resources or assistance
   that may be necessary.
3. Whether at Canton PD or in the field, a supervisor shall meet with and interview the complainant and
   determine the nature of the complaint. That supervisor will assess the complaint and determine if
   immediate action is necessary based on the nature of the complaint.
4. If it is determined that immediate action is necessary, that supervisor shall immediately contact the
   commanding officer.
5. If the supervisor determines that the nature of the complaint does not require immediate action, that
   supervisor will provide the complainant with a civilian complaint form and shall also explain to the
   complainant the civilian complaint process.
6. If the supervisor obtains information during his/her initial inquiry that would prove or disprove the
   allegation made, that supervisor will document and forward the information in writing to the Chief of
   Police for action as deemed appropriate.
7. The Chief of Police shall be notified of all complaints against the agency or its members in a timely
   manner.
8. Allegations of criminal conduct, as well as incidents that are/will likely be high-profile in nature, shall
   be brought to the immediate attention of the Chief of Police.
52.1.1: Immediate Resolution of a Complaint

In some cases, a complaint can be resolved to the complainant’s satisfaction at the time by the Shift
Supervisor.

•   This immediate resolution can often be accomplished if the incident is clearly not of a serious nature,
    or arises from a misunderstanding, or lack of knowledge of the law or limitations of a police officer’s
    authority.

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•   If a complaint that arose from misunderstanding, or lack of knowledge of the law was resolved by the
    Shift Supervisor, a notation will be made by the Shift Supervisor in his/her own file, however, no formal
    complaint form should be filed.

[Note: The Audit Team agrees with the policy and procedures related to resolving complaints to satisfy the
complainant.]

Internal Affairs (IA) Responsibility

•   The Deputy Chief of Operations is granted the authority to oversee and assign investigative authority of
    IA investigations. The Deputy Chief of Police will report directly to the Chief of Police on the progress of
    the investigation.
•   The Chief of Police shall be notified of all complaints against the agency, or its members in a timely
    manner.
•   Allegations of criminal conduct, as well as incidents that are/will likely be high-profile in nature, shall
    be brought to the immediate attention of the Chief of Police.
•   Upon the receipt of a complaint, an IA member should be assigned to investigate and/or document the
    complaint.
     • IA members shall ensure that all applicable protocols pertaining to civilian complaint forms are
       executed.
     • All complaints of officer misconduct shall be entered by the assigned IA Investigator into a Canton
       PD case file, preferably a software application designated for this purpose. The software can be
       used to document the incident and the steps taken by the department via entering all pertinent
       information in the appropriate data fields and narratives.
•   The IA investigator shall make periodic updates to the complainant of the status of the investigation.
Process:
•   All civilian complaints to the police department should be documented on a Canton PD complaint
    form and filed with the Canton PD Desk Sergeant or e-mailed to a department email address utilized to
    receive complaints. Any civilian who enters the Canton PD with a complaint will be provided with the
    form and an opportunity to complete it. All completed forms will be entered into the dispatch log with a
    time stamp and receipt and then forwarded to the Deputy Chief of Operations (DC-Ops) and
    Investigations for processing, numbering, evaluation and further action if necessary.
•   In cases where an IA investigation is warranted, the DC-Ops will record his rationale in a report, assign
    an IA number to the complaint, (in addition to the civilian complaint number) and appoint an
    investigator of suitable rank and experience to conduct the investigation. The DC-Ops will inform the
    Chief about the allegation and subsequent investigation, ensuring compliance with POST
    requirements. The investigator(s) should take recorded statements, collect physical evidence, and
    review any material as necessary. All evidence obtained during the IA investigation should be handled
    as regular evidence, labeled and processed with exhibit numbers. When the investigation is complete,
    the entire packet will be sent back to the DC-Ops for review.
•   Upon completion of the IA investigation, the entire file, including reports, interviews, transcripts, and
    evidence, will be reviewed by the DC-Ops for thoroughness. If the investigation is deemed

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comprehensive and capable of assessing the validity of the complaint, the file will be passed on to the
    Deputy Chief of Administration (DC-Admin) for further review as it pertains to policy violations.
•   The DC-Admin will examine the file for policy violations by any Canton PD member, irrespective of the
    original complaint and allegation. Misconduct violations will be identified by policy number, directives,
    date of infraction, and specific details outlining the misconduct. The DC-Admin will record the findings
    of misconduct violations, or lack thereof, in an official report and the findings report and IA file will
    then go to the Chief of Police for final decision based on Police Collective Bargaining agreements,
    Town By-Laws, Civil Service regulations, and CMR 555. In instances where misconduct or policy
    violations are confirmed, a disciplinary matrix should be used to ensure consistent corrective actions
    are taken with all officers for similar sustained charges of misconduct.
•   The Chief will review the file and the report outlining the policy violations. The Chief will make a
    decision to find the misconduct substantiated or unsubstantiated. For unsubstantiated misconduct,
    the officer will receive a Letter of Caution, a Letter of Warning, or a Letter of Clearance. Discipline
    warranted for substantiated misconduct will be issued by the Chief in accordance with Town Policy,
    POST requirements, and the collective bargaining agreement. A copy of the final decision will be given
    to the officer and included in the IA Investigative file and utilized as a closing document. Upon the file
    closing, the DC-Ops will then contact the original complainant and inform them of the investigation
    and its conclusion. The complainant is entitled to know that their allegation was unsubstantiated and
    closed, or it was substantiated and resulted in discipline to the officer and closed. The Canton PD has
    no requirement to provide further explanation.

The implementation of the above format, or a similar format that meets the rules and requirements of the
department, is crucial for transparency and fairness, fostering an environment within the department of
accountability.

[Note: According to Canton PD Rules and Regulations, officers are subject to disciplinary actions outlined
in statute (M.G.L c. 31 sec. 43) and other appropriate measures deemed fit by the Chief, including letters of
reprimand. Procedural requirements governing notice and hearings will be followed.]

Records:
•   Maintain case files pertaining to current investigations or closed/unsubstantiated investigations for all
    complaints made against the Canton PD and/or its employees within secured areas over which only
    the Chief of Police or designee has access and control. The Officer in Charge of the investigation shall
    see that all records and reports of investigations are in a locked desk or cabinet to ensure
    confidentiality. [52.1.2 (3,4,5)]
•   All completed investigation files will be locked in the office of the Chief of Police. [52.1.2 (5)]
•   When employees are notified that they have become the subject of an IA investigation, a written
    statement of the allegations and the employee's rights and responsibilities relative to the investigation
    shall be issued to the employee at the time of said notification.
•   All information obtained during the investigation of a personnel complaint is considered confidential.
    Therefore, it is imperative that all documents pertaining to personnel complaints be properly secured
    to protect all parties involved.

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•   Under current policy, the IA investigation details a full written report to be submitted to the Chief of
    Police. The report will include the following.
     • The original complaint report
     • Any additional statements taken from the complainant or statements obtained from witnesses
     • Any statement made, or reports submitted by the department employee under investigation
     • A summary of all evidence gathered
     • Any mitigating circumstances
     • An evaluation of the complaint and a “conclusion of fact” as to whether the charges made by the
       complainant were:
          • Valid and supported by sufficient evidence
          • Un-sustained because of inadequate or insufficient evidence
          • Unfounded as the allegations were without foundation; or
          • Unjustified or unwarranted as the actions of the accused department employee were in
            compliance with law or in accordance with Department policy and procedure 52.2.8.

XXVII. Section 4: Organizational Structure and Governance
•   The police department should resume posting public announcements, notifications and public
    warnings of importance on all relevant social media platforms immediately,
•   Public comments should remain disabled until they can become beneficial and promote a positive
    exchange of information.

Additionally, the Town of Canton Should:

•   Canton PD has the authority to investigate misconduct complaints per their policy. However, the Audit
    Team recommends hiring outside firms for IA investigations where conflicts and potential conflicts
    exist, or cases where multiple officers are involved.
•   Increase the number of officers trained in crime scene processing, management and preservation.
•   Train officers in report writing to improve their skills and require the submission of concise, detailed
    incident reports that explain how the situation was addressed and resolved.
•   Provide training for officers in courtroom testimony.
•   Ensure all police vehicles are equipped with essential evidence collection tools, such as digital
    cameras and department-issued cell phones. It is impractical to use a department-issued laptop for
    capturing photos/videos at a scene.
•   The police prosecutor officer and the detective sergeant positions should not be combined.
•   Hire administrative staff, including a secretary or for the C-suite and detective bureau, as well as
    interns and or analysts. A full-time Administrative Assistant for the Detective Bureau is desperately
    needed.
•   Hire dispatchers who can work with uniformed officers to handle emergency and non-emergency calls,
    enter data, and service information requests from the public.

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XXVIII. Section 6: Management Operations and Culture
Secure permanent funding for additional positions:
•   Secure permanent funding for a Mental Health Professional (MHP).
•   Secure permanent funding for two (2) additional SRO positions, one (1) for each elementary school.
•   The grant renewal for the Mental Health Professional (MHP) was delayed this year, causing
    uncertainty. The MHP has been identified as a valuable asset by all department personnel during in-
    person interviews.
Conduct IA investigations in-house:
•   The Audit Team recommends that IA investigations be conducted by the Canton PD in accordance with
    their policy when appropriate. Since the Canton PD is a small department, when investigations involve
    conflicts of interest, or multiple officers, we recommend hiring outside firms to conduct the IA
    investigation.
•   Four (4) IA cases were investigated by a contracted independent investigator from 2022-2024. This
    cost of $27,360.00 was paid from the Canton PD budget.
Hire outside entity to conduct IA investigations:
•   The Audit Team recommends that IA investigations be conducted by an outside entity to avoid any
    internal conflicts within a small department. The expense of hiring an outside reviewer is minor
    compared to the potential time and expense spent addressing allegations of bias or inconsistent
    processes.
•   The Audit Team recommends hiring outside firms for IA investigations where conflicts and potential
    conflicts exist, or cases where multiple officers are involved.
Effective communication channels should be established between town leaders, elected officials, and
officers in the department:
•   Meetings should be held directly with elected town leaders and department officers for productive
    discussions, with a focus on improving communication.
•   These meetings should not be open to the public to ensure efficiency in making the meetings
    productive.

XXIX. Section 7: Hiring Training Standards and Equipment
Hire an Intelligence Analyst to support the Detective Bureau:
•   Assist the Deputy Chief of Police with tasks like managing Freedom of Information Act (FOIA) requests,
    investigative inquiries, and police report redactions.
Hire a Civilian Dispatcher for each shift:
•   Bringing on one (1) civilian dispatcher for each shift to work alongside a uniformed police officer
•   Additional personnel would ensure continuous coverage for phone calls, radio communications, and
    walk-in inquiries without compromising any specific duty.
•   This setup would also enable sergeants to focus on supervising patrols, maximizing the presence of
    officers on the streets.

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Address the following equipment needs for Canton PD officers:
•   Portable Radio Coverage: "dead zones" present a serious safety issue for officers.
•   Home-to-Work Utilization of Police Vehicles: on-call Detective, Detective Sergeant, and Detective
    Lieutenant
•   Cellular Phones: All Canton PD officers should have a department-issued phone.
        • At a minimum, supervisors of the rank of sergeant or higher should be provided with department-
          issued phones.
        • Each patrol vehicle should be equipped with a department-issued phone.
•   Digital cameras for sergeants and lieutenants
•   Crime scene processing equipment for detectives
•   Crime scene preservation equipment for patrol cars

Addressing these equipment needs will enhance the operational efficiency and safety of Canton PD
officers, contributing to effective law enforcement practices.

XXX. Section 14: Evidence Review
•   Assigning part-time personnel, preferably a retired sworn officer, to the evidence room.
•   Better coordination with the police prosecutor for those cases that have been adjudicated.
•   Obtaining Ballistic Testing by ATF on all firearms, even if they were just found, and run a trace for
    ownership and NCIC check.
•   Documentation regarding the chain of custody on evidence could be improved in standard report
    writing.

XXXI. Section 15: Police Detail Financial Review
    •     The Canton PD should continue to accept, schedule and provide services to those businesses and
          customers requesting police details.
    •     Canton PD will create and send the vendor/customer an invoice, copying the Town of Canton
          Finance Director.
    •     Responsibility to ensure invoice payment lays the Town of Canton, Department of Finance.
    •     Under no circumstances should the Canton PD be accepting cash/checks or payments.
    •     Town of Canton advises police of business or individuals not eligible for detail coverage.

XXXII. Section 18: Liaison Interviews
    •     Simplify Reporting: Consolidate multiple brief reports into a single, detailed and
          concise/comprehensive report.
    •     Officer Identification: Reports should prominently feature the names of all officers involved in the
          incidents, as well as the names of judges, prosecutors and defense attorneys related to the case.

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•   Use of Audio Recording Devices: Officers and detectives should utilize audio recording devices
        during witness and suspect interviews, with consent whenever possible.
    •   Department Issued Mobile Phones: ADA Connors concurred with prior recommendations that
        each member of Canton PD should be equipped with a department-issued mobile phone for
        official use.

XXXIII. Section 19: Security Assessment
    •   The rear parking area for police vehicles and officers’ personal vehicles needs to be secured with
        security fencing. Police cruisers are parked there, most of which contain law enforcement
        equipment and firearms.
    •   Install an electronic, rolling, and retracting gate and an eight (8)-foot chain link fence, with privacy
        slats, and intercom for security.
    •   The entrance to the department and the front of the building facing Washington street need safety
        bollards, which provide a barrier to vehicles from damaging or ramming the doorway and building.
b) Prioritize improvements based on risk and impact.

The top priority should be given to recommendations that enhance safety and efficiency in police
operations. Suggestions such as providing portable radios, issuing cellular phones to Canton PD officers,
and improving evidence training directly impact both the community and public/officer safety.
Additionally, physical security enhancements at Canton PD headquarters must not be overlooked.

Evaluating the feasibility of conducting training in-house or in collaboration with other state agencies can
help minimize costs, as such training often only requires overtime expenditures.

Most of the recommendations involve the need for additional training and equipment, sometimes both. It
is essential for the Town of Canton to review and potentially increase the training budget for Canton PD,
which has remained stagnant for the past three (3) years. The current training budget of $100,000 for FY
2023, 2024, and 2025 has not been sufficient, considering that Canton PD spends an average of $170,000
annually on mandated training, certifications, and legal requirements. Budget shortfalls have been
covered by the Asset Forfeiture Fund (AFF) shared assets, but those monies cannot be counted on
annually.

The Town of Canton leadership should carefully assess their priorities regarding Canton PD training and
consider reallocating resources to ensure that officers receive the necessary training and equipment
recommended to perform their duties effectively and safely.

A prioritization for the implementation of recommendations should be:

•   Safety (first the public and second the officers)
•   Civil Liability of the Town of Canton
•   Police department efficiency
•   Financial Constraints Increase in Training Budgets

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c) Provide actionable steps for implementation and e) Provide a complete report of compliance issues
and how they can be improved and enforced to industry standards
Implementation of Recommended Improvement Strategies for Compliances Issues:

Throughout the report, recommendations have been made in response to all compliance issues. The
specific recommendations are noted following every policy or section reviewed within Section 1 and
summarized in Section 20, part (a). All compliance issues noted can be remediated by either 1) ensuring
the policies in place are followed as written, or 2) developing policies to address any issues as they evolve
not currently addressed by existing policies. The Canton PD policies are well written and all are aligned
with CALEA and MPAC Standards. Policies identified within the above-mentioned sections that were not
followed as written should be noted and addressed through the recommended implementation strategy
below.

The proposed strategy for implementing the recommended corrections to compliance issues as noted in
Sections 20, part (a) and (e) is as follows:

•   The Canton PD should establish protocols to ensure adherence to the already written policies; to
    include annual certification by officers acknowledging they have read and understand departmental
    policies
•   Initiate low-cost training for Canton PD officers addressing compliance issues; (training conducted in
    conjunction with another agency such as the DA’s office)
•   Apply for funding to the Town of Canton to secure external training and additional equipment where
    needed.
Strategies to Ensure Adherence to Policies as Written:
•   Many recommendations were made regarding policies that were already in place but not followed in
    every applicable instance. Establishing protocols and practices as needed to ensure current policies
    are followed is an immediately available course of remedial action.
•   Where noted within the report, policies with multiple compliance issues should be reviewed with an
    oversight protocol in mind.
•  Policies that evolve and become insufficient should be immediately updated with the policy directives
   recommended within the report.
Examples:
     • Immediately begin an annual certification process requiring Canton PD officers to sign a certificate
       affirming they have read and understood Canton PD policy as written. Important policies to review
       and certify include:
          • Handling of Juveniles Policy
          • Duty to Intervene Policy
          • Sexual Assault Policy
     • Update policies to include MPAC standards since MPAC holds Canton PD’s current accreditation.
       Alternatively, obtain a current CALEA accreditation since most policies are in line with CALEA
       standards.

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• Institute post-incident evaluations of deviations from policy to review effectiveness of policy
       corrections.
     • Updated the Social Media Policy with recommendations within the report in consideration of the
       current community climate.
     • Evaluate and update policies, such as the Bias-free Policing Policy, with feedback from community
       discussion forums.
     • Update the Informant Policy with the recommended protocols detailed within the report.
     • Ensure policies are followed as written along with applicable Massachusetts laws, regardless of
       public sentiment, including the Victim Witness Rights policy.
     • Amend the Officer Vehicle Use Policy to include parameters dictating personal use of police
       vehicles.
     • Update the Dispatch Policy to limit access to the dispatch area to only those involved in dispatch
       functions.
•   Examples of Evidence and Related Policy Protocols:
     • Immediately implement report writing templates or guidelines that ensures consistency in
       formatting and structure. Ensure documentation is completed of any non-action, not only action or
       use of force. Confer with the Norfolk DA’s office for content.
     • Additionally, establish a report writing review process that requires all reports to be reviewed by a
       supervisor for accuracy and completeness.
     • Implement a checklist to guide a supervisor review of crime scene response protocols to ensure all
       required follow-up is complete, including Canton PD responsibilities and documented turnover to
       MSP.
     • Establish protocols for “unannounced” evidence room audits.
     • Ensure proper documentation of all criminal intelligence received, regardless of perceived
       relevance at the time.
•   Personal Cellphone Policy
     • Immediately amend Canton PD Policy to prohibit the use of personal cellphones for conducting
       any departmental business, including photographing crime scenes.
•   CEO Notification Policy
     • The CEO Notification Policy should be amended to require notification to both the Chief and the
       Deputy Chiefs.
•   Ensure any amendments to the Community Relations Policy are made as a joint effort between the
    Canton PD Administration and the Town Select Board.
Conduct No-Cost Training and Protocol Adjustments:
•   Where feasible, conduct cost-free training. Opportunities can be created locally within the department
    through self-contained training that does not require outside instructors or travel. The District
    Attorney’s office can be a resource for no-cost training in:
     • Discovery Compliance
     • Legal Ethics

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• Testifying and Courtroom Procedures
•   Other cost-free training includes scheduled table-top exercises within the Canton PD.
     • Training can include rehearsing crime scene responses which allows officers to mentally rehearse
       what their response will be when called upon. This ensures police officers are prepared, and
       vehicles are properly equipped with gear needed prior to a real-world response.
•   The Canton PD FTEP program for new officers should be extended to eight (8) weeks.
Develop Funding Proposal for Outside Training and Equipment.
•   Application for funding to the Town Select Board should be made for outside training needed to ensure
    compliance with policy and best practices.
•   Equipment:
     • Officers should be provided with department issued cellphones for conducting police business.
     • Each police vehicle should be stocked with basic crime scene collection equipment.
     • Each police vehicle, or at a minimum, each detective and supervisor vehicle, should be equipped
       with a digital camera.
     • Allocate necessary funds to diagnose the Canton PD radio communications issues where there is
       little to no transmission or reception capabilities covering certain areas of the Town of Canton.
       Ensure Canton PD has the funds needed to purchase additional equipment to resolve the issue.
     • Funds should be obtained for additional Flock traffic cameras to be installed within the Town of
       Canton.
•   Support:
     • Funding for a full-time Mental Health Professional should be explored through the Town of Canton
       in the event of DOJ funding delays.
     • Civilian dispatchers should be hired to work in the dispatch center alongside sworn officers.
     • Funding should be obtained for at least two (2) more school resource officers to ensure a police
       presence at each elementary school at all times.
     • Additional funding for more full-time officers will reduce the need for overtime funding.
•   Training:
     • Funding should be obtained for patrolmen and detectives to attend a “Crime Scene Preservation”
       class.
     • At least two (2) detectives should receive training in sexual assault crime scene response.
     • Overtime funding should be allotted for officers to attend no-cost training when time is required to
       do so.

Further recommendations made within the report should be prioritized and implemented in line with the
above implementation strategy.

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d) Consider community input and stakeholder engagement.

Rebuilding Community Trust
Law enforcement is tasked with the difficult job of maintaining the trust of the community while acting as
an enforcement body for community members in violation of the law. While criminal enforcement is a
necessary and vital community service, it invites the highest forms of examination and criticism. Any
deprivation of basic freedoms (through seizures, searches, fines, criminal penalties, etc.) is relentlessly
and rightfully scrutinized. Tragedies that deeply affect community members prompt the highest
expectations of a police response. Police officers must respond to emergencies immediately, with little
opportunity to plan and ponder regardless of the conditions. Their actions, though legally reviewed from
the perspective of a reasonable officer at the time of event, are reviewed by the community and media
from the perspective of hindsight with unlimited speculation.

Policy guidelines are pertinent to demonstrating an officer’s accurate and successful performance of
investigative duties in the face of criticism. When policies and guidelines are not followed or protocols do
not exist, a dangerous perception gap is created between what should have happened and what actually
happened. This gives critiquing parties (including community members, media and defense attorneys) the
space to fill the gap with reasonable doubt as to the credibility of the officer or entire department.
Inevitably, imperfect conditions will always be present when conducting law enforcement operations,
making policies nearly impossible to always follow. Officers will occasionally make honest mistakes when
responding to rapidly evolving situations. Police are expected to follow 100% of the rules while dealing
with criminals, who are expected to follow none.

Nevertheless, this is a responsibility law enforcement officers commit to bear at the outset of their
careers, as reflected in their Oath of Office. Therefore, officers must prioritize their position of “public
trust” through continually earning the public’s trust. Ensuring a commitment to the community they serve
includes proving themselves trustworthy through not only community policing programs, but through
continuity in following established guidelines and procedures. Departmental support is paramount in this
effort as officers require clear guidance not only in the policy guidelines, but in the practical adherence
thereto. Practical “real-world” training should be conducted regarding guidelines that cover crime scenes,
report writing, use of force, etc., and how to appropriately document where deviations from policy must
occur. Additionally, mentorship programs should be encouraged for new officers by the senior officers
with exceptional reputations for integrity and experience in police work. As the expectations of policy
compliance increase, policies should be routinely reviewed so that obsolete policies are eliminated, and
overly complex policies are changed. Department officers must be able to count on Canton PD
management and Town Select Board members to trust they are not being set up for failure with impossible
or impractical expectations. In the event an officer is found to be in repeated or reckless violation of
policies, disciplinary review, and if necessary, disciplinary action should occur. Records documenting any
corrective action taken should be maintained to demonstrate accountability in practice.

Efforts to repair the relationship between the Canton PD and the Town of Canton community must be an
ongoing process. The Audit Team noted instances where some policies were not fully followed and noted
recommended changes within. Proven records demonstrate compliance with even the smallest policies

Section 20: Recommended Improvements and Summary · PDF text layer

produce a tangible metric of trustworthiness. Efforts to initiate compliance metrics demonstrate
transparency with the community of the Town of Canton.

Additionally, Canton PD could develop a path to deeper public trust through continued engagement with
the citizens of the Town of Canton. The Audit Team noted commendable efforts of the department inviting
engagement with the community – specifically the SRO program. When feasible, opportunities should be
explored for educating the community on law enforcement practices and procedures (i.e., Department
events where Canton PD officers use community demonstrations, or “academies” to inform participants
of typical law enforcement scenarios and practices). Engaging with the community in this way not only
invites understanding of the challenges facing police, but also facilitates an appreciation for law
enforcement officers as true professionals in their field.

April 5, 2025 Presentation · PDF text layer

“For such a time as this”

             Independent Audit of the Canton Police
              Department’s Policies and Procedures,
           Compliance and Adherence to the Rules and
                         Regulations

                       April 5, 2025

April 5, 2025 Presentation · PDF text layer

5Si Introduction

➢ It is important to note that the report produced by 5Si does not provide legal opinions on
  unresolved legal issues or is it an independent investigation on existing criminal cases involving the
  Canton Police Department.

➢ All information reviewed for the purposes of the Audit was provided by the Canton Police
  Department, the District Attorneys Office, concerned citizens and Town Officials.

➢ 5Si’s Audit Team reviewed all policy and procedures and analyzed the CPD’s application of those
  policies.

April 5, 2025 Presentation · PDF text layer

5Si Tasking

➢ 5Si was tasked to conduct an audit of the Canton Police Department.

➢ 5Si did not arbitrarily select areas to audit.

➢ The areas covered in the Audit Report were selected and dictated by the Procurement Committee
  and specifically detailed over 8 pages in the scope of work.

April 5, 2025 Presentation · PDF text layer

5Si Tasking

Included in Assessment                          Not included in Assessment

➢ Assess the Canton PD written Policy and       ➢ Reinvestigation of any alleged crimes
  measure it against the Massachusetts
  Accrediting authorities                       ➢ Gathering or collecting any new
                                                  evidence
➢ Assess the application of Canton PD policy
  in recent investigations
                                                ➢ Interfering or Impacting any ongoing
➢ Identify and analyze deviations from policy     criminal proceedings

➢ Identify Gaps and make recommendations

April 5, 2025 Presentation · PDF text layer

Scope of Work

Project Objectives as outlined in the Request for Proposal:
Page 3 Paragraph 2 Stated: The scope of services for this engagement includes, but is not limited to: an
audit of Canton Police department (CPD) policies and procedures, and adherence to the policies and
procedures; including Policies, Procedures, and Regulations; Crime Scene Protocols; Professional
Standards and Accountability; Organizational Structure and Governance; Citizens’ Privacy Protections;
Management, Operations, and Culture; Hiring, Training Standards, and Equipment; Citizens’ Complaints
Process; Conflicts of Interest; Select Board Oversight and Industry Standards; Recommendations and
Compliance Review; Recommended Improvements; Evidence Review; Police Detail Financial Review;
Additional Administrative Items to Review; Civil Rights Review; and Presentation of Findings and
recommendations.
➢ Page 3 Paragraph 4 stated: The community is interested to understand what the department is doing
  well, and more importantly, what the department could improve upon...

➢ The Scope of work outlined the above areas of concentration over 8 pages.

April 5, 2025 Presentation · PDF text layer

Areas of Review

                     CPD Operations/Areas Reviewed

➢ CPD Policy                                  ➢ Select Board Industry and Standards
➢ Crime Scene Protocols                       ➢ Recommendations and Compliance
➢ Professional Standards and Accountability   ➢ Forfeiture Forensic Review
➢ Organizational Structure and Governance     ➢ Evidence Review
➢ Citizens Privacy Protections                ➢ Police Detail Financial Review
➢ Management, Operations and Culture          ➢ Additional Administrative Items
➢ Hiring, Training Standards and Equipment    ➢ Civil Rights Review
➢ Citizens Complaint Process                  ➢ Disclosure of Legal Issues
➢ Conflicts of Interest

April 5, 2025 Presentation · PDF text layer

5Si Methodology

➢ When feasible, the audit team scrutinized all documents, reports, and policies digitally.

➢ In instances where digital review was not viable, physical examination of these documents
  occurred on-site at the Canton Police Department.

➢ The audit team assessed the actions of the CPD against established policies and
  procedures.

➢ Observations / Findings and Applicable Recommendations documented.

April 5, 2025 Presentation · PDF text layer

Policies, Procedures,
                             Regulations

➢ 98 Policies & CPD Rules and Regulations      ➢ MPAC re-certification of the CPD in June of 2024
  Assessed
➢ CPD Policies and their application weighed   ➢ 5Si utilized Mass GL/POST and CALEA as
  against:                                     measuring sticks
    ➢ Massachusetts Police Accreditation
       Compliance (MPAC)                       ➢ CALEA –Considered the “Gold Standard for Law
    ➢ Massachusetts Police Standards and       Enforcement” is an international certification for
       Training Requirements (POST)            public safety agencies
    ➢ Massachusetts General Law (Mass GL)
    ➢ Commission on Accreditation For Law      ➢ 483 standards related to Law Enforcement
       Enforcement Agencies (CALEA)

April 5, 2025 Presentation · PDF text layer

Policies, Procedures,
                            Regulations

➢ CPD Policy and Directives meet or exceed all POST, Mass GL
  and CALEA requirements
➢ Some of the recommendations made to enhance existing
  policy or its application were:

    ➢ CPD officers Personal Phone Use
    ➢ Annual Certifications/Acknowledgments
    ➢ Documentation Practices
    ➢ Photographs
    ➢ Crime Scene Preservation
    ➢ Civilian Complaints
    ➢ Cameras

April 5, 2025 Presentation · PDF text layer

Crime Scene Protocols

➢ The Audit Team Reviewed Police Actions at multiple crime scenes spanning the last ten
  years.

➢ Deviations of policy and investigative best practices existed as it related to the policies at
  various scenes.

➢ The Audit Team did not uncover any information suggesting intentional misconduct, or a
  conspiracy to conceal evidence or alter material facts in any investigation.

April 5, 2025 Presentation · PDF text layer

Crime Scene Protocols

                                                          Recommendations
➢Mass GL- Part 1, Title VI, Chapter 38, Section 3,
individuals must immediately notify the Office of the     ➢ Crime Scene Preservation
Chief Medical Examiner for deaths involving; criminal
                                                          ➢ Interviews
violence, accidents, suicides...
                                                          ➢ Photographs
➢CPD IS NOT RECUSED- Mass GL Part 1, Title VI,
Chapter 38, Section 4 states: “The district attorney or   ➢ Documentation
his law enforcement representative (Mass State Police)    ➢ Evidence Collection Methods
shall direct and control the investigation...and shall
coordinate the investigation with... the police             ➢ Coordination
department within whose jurisdiction the death
                                                          ➢ Ownership of Crime Scene / Coordination
occurred”...                                                   ➢ Stop Recusing-
                                                             ➢ Recusal ≠ Integrity

April 5, 2025 Presentation · PDF text layer

Professional Standards and
              Accountability

➢Internal Affairs (IA) =Professional Standards/Civilian Complaints/Officer
Misconduct

➢CPD Policy as it relates to Professional Standards is in alignment with
POST/MPAC and CALEA requirement’s

➢Inconsistency in Policy Execution, Documentation and Process
    ➢Each IA had an appropriate outcome
    ➢The method of investigation for each IA was inconsistent
    ➢The documentation for each IA was inconsistent
    ➢This practice spanned the tenure of 4 Chiefs

➢This Lack of Consistency opens the doors for questions/accusations

April 5, 2025 Presentation · PDF text layer

Professional Standards and
                               Accountability

➢The audit team reviewed 75 internal affairs
investigations and disciplinary actions back to September
28, 1991                                                    ➢All POST requirements as they related to these
                                                            inquiries and subsequent disciplinary actions were met.
➢These 75 actions resulted in:
   ➢ 63 clearances                                          ➢On February 3, 2023, the Executive Director of the
   ➢ 12 acts of sustained violations, resulting in;         Massachusetts Post Commission emailed the Chiefs and
   ➢4 suspensions, 1 demotion and 7                         Sheriffs stating only certain levels of sustained
   counseling/training sessions                             misconduct should be reported, specifically, sustained
                                                            misconduct of a serious nature was to be reported.
➢These IA’s were the result of
   ➢ civilian complaints                                    ➢CPD Chief Rafferty exceeded Massachusetts POST
   ➢at the direction of supervision based upon              reporting requirements.
   performance/observations

April 5, 2025 Presentation · PDF text layer

Professional Standards and
      Accountability
           ➢ Two Cases: Correct outcomes inconsistent process
              ➢Detective with family pet
                   ➢Correct outcome
                   ➢Consistent with civilian cases before and after
                   ➢Process should have been more thorough
                   ➢Final decision was consistent with precedent and
                   appropriate

               ➢Detective leaves Badge-Alcohol Consumption on Duty
                  ➢Unnecessary Reaction
                  ➢Non-Beneficial - Officer-Administrative Leave
                  ➢Unnecessary Outsourced investigation ($/Time)
                  ➢Unnecessary Delay -3 Months vs 5 Days
                  ➢ Final Decision was consistent with precedent and
                  appropriate

April 5, 2025 Presentation · PDF text layer

Professional Standards and
                     Accountability
                                        RECOMMENDATIONS
➢All complaints must be handled the exact same way
     ➢Detailed process
        ➢Document the Negative
     ➢No Calls to the Chief/Deputy Chief/ or Officer

➢Officers Should
    ➢Provide Complaint Form
    ➢Accept Complaint Form
    ➢Provide time stamped receipt to complainant
    ➢Forward to Deputy Chief

➢Officers Should Not
    ➢Try to Mediate
    ➢Offer Suggestions/Responses
    ➢Calm or appease complainant

April 5, 2025 Presentation · PDF text layer

Professional Standards and
                      Accountability
                                         RECOMMENDATIONS
➢Limit the Outsourcing of IA Investigations

➢Assignment & training for Senior Lieutenant, Sgt and Detective for IA Investigation

➢Completed investigations are to be reviewed by Deputy Chief of Operations for thoroughness and
then forwarded Deputy Chief of Administration for Policy violations

➢Completed investigation to include policy violations forwarded to Chief for Final Decision

➢Any disciplinary action will be issued by Chief with Select Board concurrence as dictated in Town by
Laws and Union Contract

April 5, 2025 Presentation · PDF text layer

Organizational Structure and
                    Governance

➢Paramilitary Hierarchical Structure

➢Chain of Command is receptive and available to all officers

➢Communication flows appropriately between patrol, detective and command divisions

➢FOIA requests

➢Recommendations-
   ➢The Department should continue /resume public safety notification
   ➢Additional Administrative Employees

April 5, 2025 Presentation · PDF text layer

Citizen’s Privacy

➢ The Police Department is compliant with all     ➢ Unprosecuted cases: Retained for 6 years after final
  laws and policy requirements as it relates to     action
  citizens data
                                                  ➢ Landmark cases: Retained permanently
➢ Computer data bases / Indices utilized by
  CPD contain their own electronic
                                                  ➢ Criminal cases: Retained for 35 years after final action
  surveillance and safeguards

➢ Retainment of personal information is           ➢ Medicaid, insurance, or unemployment fraud cases:
  established by the MGL Table of Retention         Retained for 25 years after final action

➢ This is established in conjunction with the     ➢ Litigation involving fatalities: Retained for 25 years after
  District Attorney and dictated by the type of     final action
  investigation
                                                  ➢ Civil cases: Retained for 20 years after final action

April 5, 2025 Presentation · PDF text layer

Management Operations
                        and Culture
➢The Chief and the CPD Command Staff have the respect of their employees and law enforcement
counterparts.

➢The CPD effectively utilizes its resources as they relate to overtime for minimum staffing
requirements and town commitments such as sporting events, holidays and elections.

➢The culture within the department and amongst its officers as it relates to each other and their
responsibilities is positive and centered on serving the community.

➢The community relationship is fractured and affecting morale.

➢Public comments specifically by Town Leaders in public forums, have contributed to the morale of
the officers.

➢Recommendations: Meetings between Town officials and police officers to candidly discuss issues

April 5, 2025 Presentation · PDF text layer

Management Operations
     and Culture
             ➢ “My wife asks me every day, why I would risk my life
               for a town that wouldn't care if I died. Every day, I
               tell her I love this town and the guys I work with.
               That’s why I go to work.”

             ➢ “No one in this town will care about us until one of
               us gets murdered, even then half the town will
               probably celebrate that.”

             ➢ “Elected officials don’t care about us. Now the
               easiest way to gain popularity or get elected is to
               publicly trash us. They have no political platform,
               just trash the police. That’s it. It doesn't even have
               to be true, just do it.

             ➢ “People in town just keep fueling the false rumors
               and it is going to get one of us killed.”

April 5, 2025 Presentation · PDF text layer

Hiring, Training and
                Standards
                              HIRING

➢CPD is a Civil Service Department

➢Potential Candidates hired with approval of Select Board

➢Recruits attend Municipal Police Training Committee Academy

➢Upon Graduation Compete Field Training Officer Program

➢ One year of Probationary Status

April 5, 2025 Presentation · PDF text layer

Hiring, Training and
                    Standards
                                  TRAINING

➢ Training for recruits and FTO mandated by POST and MPAC requirements

➢ In Service Training for experienced officers is a budgetary concern

➢ Almost 70% of officers interviewed say they want more training

➢ Difference between being qualified and being trained

➢ Recommendations
   ➢ Each officer receive an 8-hour allotment for additional elective training
      (in addition to annual certifications and requirements)
   ➢ Allocate monies to address training deficiencies

April 5, 2025 Presentation · PDF text layer

Hiring, Training and
                              Standards
                                         Promotions
➢ 2024-Hanrahan Consulting was hired to perform assessment center testing for Sergeant and
  Lieutenant positions

➢ CPD takes the requisite number from civil service list utilizing the 2n+1 formula for
  candidates
    ➢ N=Openings

➢ A number of officers feel there should be a minimum of 5 years experience to promote to
  supervisor
    ➢ (civil service laws require 1)

➢ Recommendations
   ➢ Hiring additional civilian staff
   ➢ Dispatchers / Intelligence Analysts
   ➢ Administrative Assistants

April 5, 2025 Presentation · PDF text layer

Conflicts of Interest

➢ The Audit Team found no conflicts of interests among CPD officers and Town Officials.
  Further, no conflicts of interest have influenced police actions, criminal investigations,
  evidence gathering, crime scene processing, or the overall workflow of the CPD's daily
  operations.

➢ The Audit Team has examined records, FOIA requests, investigations, incidents related to
  mental health, civilian contacts, civilian complaints, and non-enforcement police contacts.
  We have not found any evidence suggesting the existence of a conflict of interest in any of
  the mentioned areas that was not disclosed.

➢ CPD daily operations have been hindered by excessive and unnecessary actions taken to
  prevent any appearance of conflict/impropriety. (Unnecessary Voluntary Recusals)

April 5, 2025 Presentation · PDF text layer

Conflicts of Interest

➢ The Audit Team found no instances of cases being referred to the Attorney General or
  State Police due to conflicts of interest.

➢ The Sandra Birchmore and John O’Keefe investigations were controlled by the State Police
  in line with Massachusetts law Title VI, Chapter 38, section 4.

➢ Any CPD recusal was voluntary demonstrating a commitment to transparency amid public
  scrutiny.

➢ While the CPD's voluntary recusal reflected ethical standards, it also led led to lapses in
  the timing and securing of the crime scene, managing witnesses, sharing information and
  documenting statements.

➢ Recommendations

    ➢ Limit Voluntary Recusals to the most extreme situations

April 5, 2025 Presentation · PDF text layer

Select Board Oversight

➢ The Canton Select Board, as outlined in the charter, functions as commissioners with
  direct oversight of the police department.
    ➢ No Influence on Promotions
    ➢ Approve New Hires

➢ No designated primary point of contact from the Select Board.

➢ The Select Board is responsible for the budget, formulation and promulgation of policy
  directives and guidelines.

➢ Town Communications- The Audit Team reviewed email communications of Stakeholders
  and the CPD Leadership. One Select Board member has had regular communications and
  has requested monthly meetings with the Chief.

April 5, 2025 Presentation · PDF text layer

Financial Audit
                                Asset Forfeiture Fund (AFF)
                                     Monies Received

                                                                                                                           $395,262.40

                                                         $106,891.20
                                $87,517.58                             $90,418.87
      $79,907.84                                                                                 $71,471.28   $72,283.41
                                                                                    $43,733.53
                   $17,894.87
                                             $7,911.02

        2015         2016         2017         2018         2019         2020         2021         2022         2023          2024

➢ Totals above represent shared proceeds from the DOJ Asset Forfeiture Fund (AFF).
➢ CPD has one officer assigned to a DEA Task Force
➢ From 2015 through 2024 CPD received over $1.8 million dollars from DOJ asset sharing
➢ CPD complied with the equitable sharing guidelines

April 5, 2025 Presentation · PDF text layer

Financial Audit
                                       AFF Expenditures
                                                                                                                                   $384,676.06

                                                                $269,309.62

                      $208,000.34
        $194,022.28                 $188,534.40

                                                  $118,324.28                 $112,281.81

                                                                                            $71,447.13   $71,471.28   $72,283.41

           2015          2016          2017          2018          2019          2020         2021         2022         2023          2024

➢ During the period of October 1, 2023, through September 30, 2024, CPD received $381,156.30
➢ 2024-$375,495.66 of equitable sharing funds were spent on salaries (Staffing minimum-overtime)
➢ Additional monies spent on Law Enforcement Equipment.
➢ CPD complied with the equitable sharing guidelines.
➢ CPD cannot rely on AFF Sharing

April 5, 2025 Presentation · PDF text layer

Financial Audit
                                           Police Details
                   ➢ Total amounts for CPD details from 2020-2024: $5,309,649.33

                   ➢ Total amount outstanding of $91,074 is approximately 1.3% of the CPD’s
                     billable services for that same time frame

                   ➢ The department collection rate is just under 99% for the monies owed. Since
                     the inception of the audit reimbursements continue to come in and the
                     outstanding balance for details worked is approximately $17,000 (or .32%)
Fiscal Year (FY)           Detail Spend                        Fiscal Year (FY)         Detail Spend

FY 2020                    $1,088,293.47                       FY 2020                  $137,015.45

FY 2021                    $900.915.16                         FY 2021                  $237,462.24

FY 2022                    $785,563.44                         FY 2022                  $173,639.96

FY 2023                    $884,392.72                         FY 2023                  $187,487.47

FY 2024                    $662,727.66                         FY 2024                  $242,151.36

Total                      $4,321,892.45                       Total                    $987,756.88

             CPD Private Details                                                  Town Details

April 5, 2025 Presentation · PDF text layer

Evidence
                                  Collection

➢ A review CPD investigations revealed sporadic deviations from CPD policy as it relates to
  documentation and collection

➢ External factors must be considered

➢ Documentation standards varied

➢ Photographs of crime scenes

➢ Blood Evidence Collection kits were not available in the CPD in January 2022
    ➢ CPD does not Process Crime Scenes- Plymouth/MSP

April 5, 2025 Presentation · PDF text layer

Evidence
                Collection
➢ Leaf Blower

April 5, 2025 Presentation · PDF text layer; image title and attribution transcribed

Independent Study

[Image text: title and attribution transcribed]
Innovative Techniques for Collecting Snow Impression Evidence
James Wolfe
Justice Center, University of Alaska, Anchorage, Alaska

April 5, 2025 Presentation · PDF text layer

Evidence
                                  Storage

➢ A complete inventory and detailed audit was performed by an independent audit team
  from Pomeroy Resources Inc. in October 2024.

➢ The CPD has/started in conjunction with the town to implement all recommendations.

➢ The evidence storage areas are under strict video monitoring with electronic access,
  digitally recorded, and maintained by the Town Administrator.

➢ Surveillance footage of evidence access areas can be reviewed, but not altered by CPD.

➢ The Audit Team on 3 different occasions, one of which was unannounced, conducted
  random inventory checks of exhibits (16,000 exhibits on site) found no discrepancies.

➢ The Audit team found that the CPD has complied with or has started the process in
  conjunction with the town to implement all prior recommendations.

April 5, 2025 Presentation · PDF text layer

Recommendations

 Questions?

Canton Audit Questions and Answers · PDF text layer

Question # 3453-      Requested Email copy of Report-
Answer :      https://town.canton.ma.us/1080/Police-Audit-Report-and-Information-Sess
Question # 3457- “What is the specific language or assumption by 911 caller that
dictates crime scene protocol vs accident scene protocol. Also, what are the different
procedures governing each? If the victim has not been declared dead, is it standard
procedure to photograph him/her or does that typically only occur when death is
certain? If the victim is potentially revivable, don’t life-saving techniques take
precedence over ‘crime’ scene processing, particularly if the facts initially available
do not specifically indicate a crime?”

Answer:       Preservation of life and prevention of bodily harm always take precedence
over investigative techniques. Regardless of whether a scene is initially classified as an
“accident” or a “crime,” it requires immediate preservation, thorough documentation, and
detailed photography. An accident scene can rapidly evolve into a crime scene based on
newly discovered evidence or witness statements. Therefore, both types of scenes must
be approached with the same level of care and attention, focusing on the preservation and
documentation of information and evidence.

There is no single, definitive language that automatically classifies a scene as either an
accident or a crime. The responding officer’s discretion, training, and experience are
critical in identifying the nature of the situation and initiating the appropriate response.

Questions # 3459- “How was info, quotes given by canton police verified/
authenticated? It seems like you took the word of canton police department much of
the time. Why Didn’t you speak with social media (Turtleboy), canton residents, police
victims, former chief, Brian Higgins, etc to get the full picture? Since the select board
plays a critical role of the police, why weren’t they investigated thoroughly?
(Especially certain long-standing members who have been complicit in the system).
Since the select board hired you, was there any understanding that you would walk a
line or not criticize certain people to affect the final report?”

Answer:       The scope of work was clearly defined and limited to specific areas of
assessment. Our role was not to “investigate,” but rather to evaluate the Canton Police
Department’s (CPD) policies and procedures as written, and to assess their application in
real-world scenarios. When deviations from policy or its application were identified, we
analyzed the contributing factors and recommended strategies for improvement.

At no point did the scope of work call for, suggest, or authorize an investigation into any
Town of Canton committee, Select Board member, or individual elected official. Interviews
with Canton residents, town officials, and elected officials were conducted when
appropriate. No interference from any member of the Select Board or any town official was
encountered during the assessment.

Canton Audit Questions and Answers · PDF text layer

Question # 3460- “One of the key things posted online about your investigation is
"you did not find any indication of conspiracies, corruption or coverrups" (sic) I don't
disagree with that comment but is it equally important to clearly caveat that with "but
there were many things excluded from the scope of our work that COULD have
identified any of these items particularly in the Karen Read case where we did not look
at the Sallyport videos or video system itself, we didn't verify the authenticity of any
videos and we didn't review ANY evidence in such case"? I know you have scope
limitations in the back of the report before given all the hype on the case, your
statement that you found nothing being misinterpreted by many can you please
confirm that you agree with the statement I have written or something similar in the
alternative?

Answer:        As stated in the report and at the presentation the scope of our assessment
was dictated by the scope of work provided by the Town of Canton which specifically
outlined the areas to be assessed. Our assessment focused on CPD policy and its
implementation. Based upon our findings when deviations occurred, they were not the
result of corruption nor where they done intentionally with malicious intent. Outside of the
parameters of our assessment, we are not able to make declarative statements
concerning possibilities.
Question # 3461- “In the public form (sic) you mentioned that the town paid a
personal expense of a police officer for a $700 car cleaning. You later indicated this
officer repaid the expense at an unknown date in connection with the audit much later
than the expense was paid. Is it not a policy violation to knowingly submit personal
expenses to the town for reimbursement? Do you believe any officers involved should
be reprimanded given there doesn't appear to have been a plan to correct this matter
before it came up in the audit and the matter involves the officers integrity? Lastly, did
you do a financial audit of officer expenses to determine if this matter is isolated or
prevalent? If you didn't do an audit of other expenses do you think it is important to
clarify this to the citizens who would not understand the scope of your audit clearly
that other such items MAY exist?

Answer-        The officer did not submit this expense for reimbursement. Rather, the
department’s leadership took the initiative to cover the cleaning costs while the officer was
on leave, with the understanding that the officer would reimburse the expense upon
returning to full duty. There was no attempt to conceal that department funds had been
used. A communication gap occurred, as the Chief was on temporary travel when the
Assistant Chief arranged the payment. Upon the Chief’s return, communication at the
command level was unclear, resulting in the reimbursement not being processed as
intended. Once the issue was identified during the audit (February/March 2025) and
brought to the attention of CPD Command staff, the officer immediately reimbursed the
department. Our audit of time sheets, overtime records, and asset forfeiture fund
expenditures found that CPD was in compliance with all applicable policies and
regulations related to law enforcement activities.

Canton Audit Questions and Answers · PDF text layer

When issuing internal discipline, it is important to distinguish between actions that are
intentional and those arising from carelessness or oversight without malicious intent
(similar to a “Douglas Factors” assessment). While no discipline is warranted in this case,
thorough documentation and a formal investigation—including a statement from the
detective—should have been completed.

Question # 3462- “During the session you gave Jen McCabe glowing reviews for her
911 call. When you made such comments did you take into account that (i) she stated
they flipped him over but testimony in the case by two others is that he was face up,
(ii) she stated the man got out of the car but her testimony is that the man did not get
out of the car and (iii) she stated the man had been out there a couple of hours when
her testimony indicates he had been out there approximately 6 hours? You inferred
her comments were accurate and helpful when a large part of the community believes
that nothing in her call was accurate. Is there anything you would like to clarify
relative to the comments you made re: her 911 call?”

Answer-       No. Reviewing and evaluating trial testimony by witnesses was not a part of
the Audit. During the 911 call, when asked by Canton Fire Rescue about John O’Keefe, Ms.
McCabe answered questions as requested by the 911 operator, enabling rescue personnel
to have advanced information about his condition prior the arrival of rescue personnel.
Question # 3463- “In your report you have indicated the Canton Police responded to
the O'Keefe crime scene as a man in the snow. During testimony Jen McCabe, the
person that made the 911 call, indicated that she told multiple EMT/police officers on
the scene that Karen said "I think I hit him". Years later she clarified she stated to
these individuals "I hit him". Since based on her testimony it seems so apparent that
the 911 caller and officers on scene were well aware this was a hit and run murder,
why is there no mention of these policies in your report regarding what the officers
should have done in that scene including immediately securing her vehicle until a
warrant was obtained? I am confused by the disconnect between the statements the
911 caller is adamant she heard and communicated to those on site were not (i) acted
on by the officers or (ii) mentioned in their reports so I would appreciate your
clarification of how you considered such information/statements in your report.”

Answer-        Trial testimony and facts learned or alleged after the fact were not
considered when assessing the response of the CPD the morning of January 29, 2022, as
reported. The 911 call posted and included in the report speaks for itself. There was no
indication that the initial responding o_icer’s believed Mr. O’Keefe’s condition was a result
of a hit and run.
[Note: The Audit Report outlined witness interviews protocols including investigators
should consensually record interviews of witnesses.]

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Question # 3464- “Independence and objectivity are integral during the audit. As a
licensed CPA with many years of experience, a cold read of your report appears to
include apparent bias. Statements are not appropriately tailored for scope
limitations, some statements seem made with no related audit procedures/basis for
such statements such that they are easily taken out of context. You offer qualitative
observations on personnel which is clearly outside the scope of a compliance audit.
Can you please confirm if there are any prior relationships or distant relationships
that have not previously been disclosed that have resulted in the appearance of an
inappropriate biased relationship with those that hired you and those you audited? In
addition, I do not believe governance for the audit was appropriate in that the Police
Audit Chair showed no respect for the engagement, discounted findings,
inappropriately limited access to citizens input throughout and the Police Chief was
the central point of contact. How did you consider these limitations/abnormalities
and why are none of them mentioned in your report? In closing, I don't believe a one
sided report that appears to be a mouthpiece for those that were opposed to the audit
will do anything to help heal the community or address this matters that need to be
addressed in the community. Many citizens still will not feel safe when you state it is
ok to call the cell numbers you always called before you ring dispatch and when you
defend a 38 page report related rubber duckies and say it was deserved/well done
when the case was dismissed. Did you consider the case was dismissed in your
conclusion on whether this was a good use of resources? This was a lost opportunity
to help this community heal and that is unfortunate.”

Answer-       Thank you for your opinions. No prior relationships existed between the
Audit Team members, any Town o_icial or members of the Canton PD. The Inner workings
of the Canton Police Audit Procurement Committee and the actions of the Chair were not
in the scope of work, nor were they subject to assessment by the Audit Team.

The dismissal on the part of the judge is not a reflection of the investigation nor does it
negate its necessity.

Question # 3465- “The two-minute timeframe did not permit me enough time to
thank 5 Stones intelligence, Inc., for their detailed audit of the Canton Police
Department. As I noted, I wish they performed more community engagement, I
understand that their scope may have been limited by how the RFP and contract were
designed, and the limited access they were permitted to individuals because of how
the organizers set this up. It is an unfortunate outcome for those who were hoping this
audit would provide more opportunity to address the trust issues some people in
Canton are experiencing. Yet, I am still hopeful we can utilize the audit findings to
collectively work towards this goal, and our town leadership will take the opportunity
to lead this effort. Related to one of the questions I asked at the audit presentation on
4/5, I would like to let 5 Stones and those who heard the discussion know that I was
informed by Louis Jutras, Canton's head of IT, that the information regarding the radio

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communication system implementation was inaccurate. Per Mr. Jutras, radio
replacement project is in progress. Police have received their new portables and in
vehicle radios. Cabinets and repeaters have also arrived. Distribution and installation
of this equipment begins this month. The comment around the GMS project should
have been reported that radio coverage will be further enhanced when this project is
completed as we are looking to install an additional repeater at this site to enhance
communication in that area. Specific to the dead spots, some issues were already
addressed when an antenna was replaced a few months ago but others won't be fixed
until the new equipment is installed. The expectation is that the new site
will be installed and operational by May, and the project to be completed by
September. The project covers 6 sites for new equipment, 75 + portable radios, and
about 55 in vehicle radios so just getting all of the equipment takes time, which is
understandable. While I cannot speak to what 5 Stones was told or heard,
because these details did not make the audit report, I think it is worth noting that the
dead spot issues for our police department's radios represent a serious safety issue
that had been identified and steps to address them were already in process prior to
the audit. Best Regards, Greg Murphy.”

Answer-       “Thank you. While we agree with the information you provided above, it is
important to note that even though the issue is ‘in the process of being addressed,’ dead
spots where the handheld radios were ineffective and failed to provide adequate
communication still existed as of the day of the presentation.”

Question # 3466- “Thank you for the opportunity to submit questions and for your
important work. While I believe there is much in the report that will help improve
police operations, I'm seeking your additional input on proposed ideas to
help restore trust between Canton residents and the CPD. RE: Section 1.G. / Section
20.VI: Community Relations Policy - Did 5 Stones include any specific
recommendations to the CPD in terms of adapting this policy in light of the current
state of public trust? For example, Section 45.2 of the CALEA Standards
addresses Community involvement, including Quarterly Progress Reports and
Citizens Surveys. Please explain if these are currently being used by the CPD? If not,
could these types of activities help address our public trust gap? RE: Section 1.SS. /
Section 20.XXIII: Compliance with CALEA Standards on Specified Policies and
Procedures - Please explain whether there are any standards related to fostering
public trust, transparency, and accountability other than CALEA 45.2? Can you give an
example of the types of steps the CPD could take to ensure accountability and
adherence to this type of standard / best practice. What value, if
any, would MPAC’s Road Map to Certification and Accreditation have, if any, in
helping the CPD, Select Board, and other stakeholders develop an implementation
roadmap for the audit recommendations? Section 4 / Section 20, XXVII: Organization
Structure and Governance - During the Public Form you stated that Canton

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does not need a civilian advisory board. Alternatively, you recommended police ride-
alongs. The report states "Transparency and community engagement are critical
components of modern policing and can foster trust and cooperation between the
police department and the community it serves." Do you have any experience
auditing, designing and/or implementing other activities that foster transparency and
community engagement? For example, I understand there are citizen police
academies, neighborhood walk-and-talks, and coffee with a cop events. If yes, is
there any data indicating their effectiveness in positively addressing low police and
citizen morale / trust? If no, do you know any other organizations or resources that
may be able to help Canton bridge the trust gap at scale? Section 6: / Section
20:XXVIII: Management Operations and Culture – Is there an equivalent SRO-type
position for the community at large? What roles, responsibilities, and skills
should this broader role have? How would this position compare to Canton's
Community Relations Officer position described in Section 1.G? How do these roles
and responsibilities compare to what one would find in a mature community policing
program? How would you compare Canton’s community policing program to the
peer group you evaluated? Is this a reasonable comparison given the public trust
issue Canton is currently dealing with? Section 10: Select Board Oversight and
Industry Standards - Does 5 Stones have any experience in assessing, developing
and/or implementing police department evaluation programs that include
in their scope injury or harm to public trust, community perceptions, and police
community relations? Do you know if Canton is currently using any metrics to help
assess department and/or individual performance in these areas? Does 5 Stones have
any recommendations on how the residents of Canton could best be
engaged by the CPD and Select Board to help evaluate the appropriateness of these
measures for our use? Section 20.XXXIII.d. Consider Community Input and
Stakeholder Engagement & Implementation Roadmap -Does 5 Stones have any insight
/ recommended research the Town of Canton could use to more thoroughly
address its public trust-related issues?”

Answer:        “The recommendations related to the issues outlined above are included in
the report and have been shared with Town leadership. These suggestions align with
industry best practices and standards. However, all proposed actions require approval,
funding, and implementation at the executive level, along with coordination with the police
union. Programs such as Citizen Academies, ride-alongs with officers, and ‘A Day with a
Cop’ are effective tools for fostering communication and building community trust. As
noted in the report, it is the responsibility of Town leadership to implement these strategies
to promote trust and transparency, rather than contribute to the anger and frustration felt
by community members.”

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Question # 3467- “You appear to give Helena Rafferty rave reviews for her
leadership and commitment to change/improve/address recommendations. In my
opinion, a Police Chief should take the initiative to identify gaps and address them
and also understand best practices through her own training and networking. It's
concerning in 2025 that she didn't understand it is not appropriate for officers to use
personal cell phones to conduct business for legal and other obvious reasons. In
reaching your conclusions that she is sufficiently qualified and recommended by you
to continue to serve as Police Chief, how did you consider that under her leadership (i)
she thought it was appropriate to spend $200k on a kitchen over essential items such
as cameras, cell phones and training and (ii) she didn't identify on her own, prior to any
audit, that additional officer training was necessary when her officers did not take
photos, did not photo the TAILIGHT, and did not do many other important items in the
investigations either Officer John O'Keefe or Sandra Birchmore? Similarly, given the
lack of confidence in her leadership by many in the community, wouldn't it be worth
consideration to NOT renew her contract and bring in a highly skilled Police Chief with
the requisite skills to restore faith in the police department, address the findings in
your reports based on their knowledge and expertise without the need to hire you for
additional services? This recommendation seems a bit self-serving since you appear
to be her crutch to get her to do her job appropriately.”

Answer-       We did not make any statements regarding Chief Rafferty’s contract or future
tenure, nor did we offer “rave reviews” as suggested. Additionally, the report contains no
language supporting the claim that we concluded she is “sufficiently qualified and
recommended to continue serving as Police Chief.” Our report simply stated that “...her
leadership style was effective, and she was receptive to our recommendations.”

The decision to renew Chief Rafferty’s contract rests solely with the Select Board. The
Police Audit Committee did not request, and the Audit Team was not tasked with, making
recommendations regarding contract extensions for the Chief of Police or any member of
the command staff.

Question # 3468- “Recently in court, Attorney Brennan indicated that certain
Sallyport videos were replaced. In the session yesterday you indicated no cameras
had been replaced due to the pending litigation. Who was incorrect
Attorney Brennan or what you stated yesterday in response to a question?

Answer-        We were advised by Canton IT Specialist that the mirrored camera inside
the sallyport was not replaced as we stated in the question-and-answer segment on April
5, 2025.

Question # 3469- “In the discussion yesterday you mentioned discretion was
appropriate in the case of the Officer whose dog unfortunately passed away in his car.
How do you reconcile/explain no charges in this case when in the of another person

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who left a dog in their vehicle in January 2024 in Canton there were charges levied
against a Braintree man although in that case the dog survived? You mentioned the
environmental police did not levy charges for the rabbit incident. The incident
involved underage drinking and property damage. Were any charges levied for those
individuals? I understand there were Alberts present. There were balloons filled with
chemicals tossed on the lawns of Karen Read supporters. Were those charges
investigated and were any charges ever filed? As you review the responses to all the
questions above to (sic) you see why citizens believe they are not treated fairly and
anyone associated with the CPD get a pass with respect to the law?”

Answer-         The Audit Team determined that the use of discretion was appropriate in the
tragic incident involving the officer’s dog. Discretion is a critical element of law
enforcement decision-making, and not all cases are handled identically. During our
presentation, we cited three similar cases: in two, no charges were filed, and in one,
charges were pursued. We did not review cases from neighboring towns. It is important to
note that decisions regarding charges and prosecution are made by the investigative
division in collaboration with the Norfolk District Attorney’s Office.

Regarding the Thanksgiving home incident, the homeowner declined to press charges and
instead requested restitution for damages, totaling approximately $20,000. Law
enforcement interviewed approximately 18 juvenile subjects, and no criminal charges
were filed. To ensure transparency and mitigate any concerns of impropriety, the Canton
Police Department requested assistance from a neighboring police agency during the
investigation.

As for other allegations, such as the “Balloon Case,” the complainant is advised to follow
up directly with the Canton Police Department to inquire whether an investigation was
conducted and to request copies of any related reports.

Question # 3470- “I am following up on a question I asked 5 Stones during the Q&A
portion of their audit presentation. While they acknowledged the current hierarchy
above the police chief works, I would like to know, given that the managing person or
body would rarely have detailed knowledge about policing, what responsibilities
should the person or body in this oversight position be expected to do/provide the
chief and police department in terms of: a. Setting policy and direction? b. Overseeing
operations? c. Managing resources and strategy? d.
Setting expectations for leadership?

Answer-        The individual or governing body in this role holds the responsibility of
ensuring that the Chief of Police is effectively fulfilling their duties in a manner that serves
the best interests of the Town. Communication is critical; it is incumbent upon the
governing body to establish clear lines of communication and to set measurable
expectations for both the Chief and the police department.

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While the governing body may not possess expertise in policing or investigations, it should
nonetheless establish clear standards and performance expectations. Regular requests
for and reviews of statistical information—such as internal affairs investigations, citizen
complaints, investigations initiated and prosecuted, and use of force statistics—can
provide valuable insights into the department’s operational effectiveness and the quality of
its leadership.

Question # 3471- “The Canton PD follows the state's Civil Service hiring process but
many communities in Massachusetts have opted out of the civil service system for
hiring. One main reason they cited for doing this is because they were seeking greater
flexibility in hiring and promoting public safety personnel, particularly police and fire
sta=. While you referenced the CPD's hiring process, given the challenges filling
current positions and the additional positions you recommended, did you review the
civil service hiring process as it relates to Canton and the potential benefits and
drawbacks of choosing to opt out? If so, what were your conclusions? Would
you advise Canton to opt out of the civil service process?”

Answer-        Yes, we did review the benefits and restrictions of leaving the civil service
hiring practices. There are many benefits to leaving civil service as many departments
have done and it is our recommendations that leaving civil service would be extremely
beneficial to the Town of Canton as well as the CPD.

Question # 3472-      “In the discussion at the April 3rd meeting with three Audit
Committee, 5 Stones discussed the cameras at the police station being motion
activated. Based on what you saw, did recordings stop the moment movement
stopped or is there a lag between the motion stopping and the camera stopping
recording? I ask because cameras I am familiar with other cameras and how motion
sensitivity works for them. They start recording as soon as motion is detected and turn
off only after a defined period of time there is no motion. If there is a lag with the police
cameras, how long is it? I ask because footage I've seen from a particular case did not
only stop the moment motion stopped but apparently stopped while there was active
motion. I also understand the motion sensitivity is also based on the camera's set
motion zone, the area of detection, if you will, for the camera. Were you able to assess
these settings of the cameras to determine whether they are set to detect motion in all
pertinent areas in the sally port? Was the field scaled back at all from detecting
motion in any portion of the camera's field of view? If so, were you able to determine a
reason for the settings? Best Regards, Greg Murphy”

Answer-       The Audit Team was advised that cameras are motion activated. We did not
assess the settings in the sallyport, because of the ongoing trials, and their evidentiary
value. Our assessment focused on the policy to have a recording device in place as well as
a proper retention and retrieval system with access integrity safeguards. Regarding your

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other questions, they would be best addressed through a FOIA requests to the Town IT
manager.

Question # 3473- I see 5 Stones reviewed many policies, including the relatively
new Body Camera Recording Policy. They noted that detectives and SROs used them
in their report but started (sic) at the 4/5 presentation on the audit that all officers
wear them. Can you confirm that all officers now wear them? Also, based on your
review, is this policy document complete and through? Finally, is this policy one that
can and should be made public so citizens can read and understand the policy the
police are following? Best Regards, Greg Murphy

Answer-        All Canton PD o_icers have been utilizing Body Worn Cameras (BWC) since
November 2024. The policy is complete and in line with the Department of Justice policy.
Clarification or requests for policies is the right of every citizen of the Town of Canton, and
review of that policy will provide clarity on when and how the cameras are activated and
what happens with the subsequent recordings concerning their review and possible
retention.

Questions # 3474- “In the Hit and Run Investigations section of 5 Stones' audit
report, you explicitly called out that the incident at 34 Fairview involving Officer John
O'Keefe was only determined to be a hit and run in hindsight. In your opinion, how long
should it have taken to determine that an unresponsive man, only feet from the road,
with both eyes black and swollen, and a gash on the back of his head, in a snowstorm
may have been a hit and run, or at least was something worthy of investigation as a
potential hit and run, or at least something that warranted several of the steps you
outlined for this scenario such as, taking photos of the scene and conducting a door-
to-door canvas of residences in the area to ask people what they may have witnessed,
as well as maybe seeking potential video footage from anyone who has cameras in the
area that may have captured something? As you know, anyone who records video
probably has their footage overwritten in a matter of days so, requesting these
recordings in a timely fashion is critical to potentially confirm exactly what happened.
Best Regards, Greg Murphy”

Answer-        The Audit Team was tasked with assessing the CPD compliance with policy
and procedures. Based on CPD policies, CPD o_icers did not comply with all of their crime
scene protocols prescribed by CPD policies and procedures as noted in the audit report.
The Audit Team was notified that o_icers did conduct canvassing of the area to determine
if any video footage was available with negative results. All possibilities within reason
should be entertained upon arrival at a scene and as stated above both suspected
“Accident Scenes” and “Crime Scenes” should be handled in a similar fashion.

Question # 3476-    Is it normal policy and procedure for a cop to drink and “forget”
his badge & GUN in his friends car?! Is it normal for cops to black out while driving a

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police vehicle? As someone who has received a DUI before, I’m disgusted that the
same people arresting me are out doing the same thing. They are supposed to be role
models for the town. The current canton Police are the farthest thing from role
models. Make it make sense? If I move to Canton, can I drink and drive legally? I might
consider What a joke, Kevin Albert is!

Answer-      The Audit Team found Detective Albert was in violation of policies and
procedures as they related to drinking and operating a Town vehicle.

Question # 3478- “I attended Saturday’s presentation, and I was very impressed
with Five Stones Intelligence's work and Mr. Germanowski’s clear and thorough
presentation. However, Mr. McKnight’s statement that Jennifer McCabe discovering
Officer O’Keefe’s body on the lawn “must have been very traumatic for her and
obviously still traumatic to this day” seems to indicate that Five Stones made up their
mind on what happened to Officer O'Keefe based on hearing biased information. I am
personally aware of quite a bit of evidence indicating that finding Officer O’Keefe that
morning was not a surprise to Ms. McCabe. This bias is quite concerning, since a jury
was not able to reach that conclusion in the first trial. It seems that Five Stones
achieved their goal of pleasing the Town Administrator and Chief Rafferty, but it is the
single thing that makes me question whether or not there is bias in the rest of the
report’s data. Can you please explain how you came to the conclusion that Ms.
McCabe didn’t already know that Officer O’Keefe was on the lawn at 34 Fairview when
she arrived with Ms. Read that morning? Thank you, Sarah Norton Canton, MA.”

Answer-         The Audit Team reviewed police reports and the 911 call made on the
morning of the discovery of John O’Keefe. Critical incidents are often traumatic events for
all parties involved. The Audit Team was not hired by nor where they hired to please Chief
Rafferty or the Town Administrator. Our team did not re-investigate the John O’Keefe case,
but rather reviewed the policies, procedures, as well as their implementation to ensure
officers followed the policies as written.

Our team was made aware that Ms. Read contacted Ms. McCabe and Ms. Roberts the
morning of January 29.2022 and stated to both that John O’Keefe did not return home the
previous evening.

5Si does not have authority to investigate criminal matters. Any information or evidence
you may have or that you are aware of involving this criminal matter should be passed to
the Norfolk County District Attorney, the Massachusetts State Police, or an appropriate
law enforcement authority.

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Question # 3479-       As “Independent” and non-bias auditors, were you told that Sgt.
Mike Lank has a LONG history of coming to the aid of the Albert family, specifically
Chris and Tim Albert. This came up in the Karen Read trial under cross examination of
Mike Lank. Do you know who the Lopilato brothers are? Chris Albert and Mike Lank
were at a bar And when they left, Chris got into an argument with one of the Lopilato
brothers. Mike Lank stepped in to protect Chris Albert and ultimately beat and bit Mr.
Lopilato. This happened on August 31, 2002 and you can read the court filing case
number: 1:05-cv-10012-WGY Lopilato et al v. Officer Michael Lank et al Also, Tim
Albert, (another Albert brother) was driving and hit a parked car and fled the scene
leaving a trail of transmission fluid leading back to his childhood home at 34 Fairview
rd. Mike Lank followed the trail and Tim Albert admitted he hit parked cars and fled the
scene. He was not charged. He was not interviewed at the police station. And he only
received a misdemeanor. Saying Sgt Lank has no conflict of interest and shouldn’t
have recused himself is highly inappropriate. Did you hear dashcam audio from
1/29/22 where Mike Lank says John O’Keefe was in a fight? Did you know / were you
aware that witness Jen McCabe went to Mike Lanks house the very next day, on
January 30, 2022 and was there for about an hour? Did you know that the other witness
on scene, Kerry Roberts, is good friends with Mike Lanks wife?

Answer-       “The Audit Team is aware of the ‘Lopilato incident’ and of statements made
by independent witnesses corroborating then-Officer Lank’s response, as documented in
law enforcement reports. We were not made aware of any incident involving Tim Albert.
None of the issues presented in this question fall within the scope of the audit.”