Introduction

Newswise — The killing of George Floyd, a Black man, by a white police officer in the United States sparked a national reckoning with police brutality and systemic racism. Protesters’ calls to defund the police, ban the use of choke holds, and end practices that target minority communities have prompted a public policy debate over police reform.

The U.S. approach to policing differs from those of other advanced democracies, in areas including organization, funding, training, relations with minority communities, use of force, and accountability.

Do democracies organize police differently?

Yes, and the number of police forces in the United States far surpasses those in other advanced democracies. Police systems in many countries in the Organization for Economic Cooperation and Development (OECD) are more centralized than the U.S. system. Some countries, such as Sweden, have a single national force organized and overseen by the federal government. Others have a few national forces with differing responsibilities. France, for example, has a national force with jurisdiction over cities and another force that focuses on rural areas. Still others, such as England and Wales, have regional forces that enjoy some autonomy but must comply with federal government standards, including on training and investigating misconduct.

The United States has about eighteen thousand law enforcement agencies, including local, state, and federal police forces. Canada, which administers police at the municipal, provincial, and federal levels, has fewer than three hundred law enforcement agencies.

Many experts argue that standardizing training, oversight, and disciplinary procedures through a central authority, such as a state’s attorney general, could help to address issues in U.S. policing. “Centralized administration of policing makes it possible to set and enforce uniform standards throughout the police force,” says Paul Hirschfield, a sociology professor at Rutgers University who has studied policing in Europe, where most forces are centralized. However, centralization can be a challenging process. In one recent effort, the Netherlands consolidated its twenty-five police divisions into a national police force, but tensions remained between local and national officials. The government later admitted that the reform was too ambitious, though it continues today.

How do countries fund their police?

Spending on law enforcement varies among similarly wealthy OECD members. At the low end, Finland spends less than 0.5 percent of its gross domestic product (GDP), while Hungary spends the most, at roughly 1.4 percent.

The United States spends close to 1 percent of its GDP on police. Local governments fund most of this, though state and federal governments finance their own law enforcement agencies. Activists and lawmakers have recently called to “defund” U.S. law enforcement agencies. To many people, this means diverting police funds to other services, including education, housing, mental health care, and community-led safety initiatives.

U.S. municipalities and states can receive financial and material support from the federal government. For example, the Department of Defense transfers excess military equipment to police, which has recently raised concerns that American police have become overly militarized. Canada’s military also supplies police with equipment.

In Mexico, as in the United States, states and cities fund police forces to supplement federal law enforcement. Critics say the result is that wealthier areas have better trained and equipped forces. Australian and Western European cities generally don’t fund their own police forces. One exception is Switzerland, where many municipalities finance local departments to augment regional forces.

U.S. policing has also drawn controversy over excessive fines, fees, and asset forfeiture, a widespread practice in which departments profit from seizing the assets of citizens, many of whom are never charged with a crime. Law enforcement agencies elsewhere, including in much of Canada and the United Kingdom, also profit from asset confiscation. In some countries where corruption is rampant, officers collect bribes. To combat this problem, the country of Georgia fired and rebuilt most of its police force following the country’s 2003 revolution, though it has since experienced backsliding.

What are police responsible for?

Police perform many duties, sometimes in situations they aren’t trained for. In the United States, not only do local officers patrol communities, investigate crimes, make arrests, and issue traffic citations, they also respond to mental health crises, domestic disputes, and noise complaints. Some experts argue that this broad mandate can lead to unnecessary escalation and use of force. Researchers estimate that one in ten police calls in the United States is related to mental health. Approximately 25 percent of people shot and killed by police in 2018 were experiencing mental health crises.

Some countries, as well as several U.S. cities, have sought to address this by creating specialized units to respond to mental health emergencies. In Stockholm, some paramedics drive mental health ambulances. Through a similar program known as CAHOOTS in the Oregon cities of Eugene and Springfield, unarmed medics and crisis workers respond to 911 calls relating to individuals experiencing psychological crises. In 2019, they responded to twenty-four thousand calls, about 20 percent of total 911 dispatches. Other countries rely on unarmed professionals to respond to low-level crimes. In England and Wales, community support officers can fine someone who litters or confiscate alcohol from a minor, but they must ask police officers to make arrests. Experts say these and similar programs have reduced incidents of police violence.

“Just look at what police are doing right now and ask, ‘In which of these situations do I need an armed first responder?’ If we don’t need an armed first responder, why are police doing it in the first place?” says Tracey L. Meares, professor at Yale Law School and founding director of the school’s Justice Collaboratory.

What training do police undergo?

The duration and type of training varies widely worldwide. Recruits in the United States spend significantly less time in police academies than those in most European countries. Basic U.S. training programs take twenty-one weeks on average, whereas similar European programs can last more than three years [PDF]. In Finland and Norway, recruits study policing in national colleges, spending part of the time in an internship with local police, and earn degrees in criminal justice or related fields.

With hundreds of police academies, the United States lacks national standards for what recruits should learn. U.S. academies tend to emphasize technical skills rather than communication and restraint. According to a 2013 U.S. Bureau of Justice Statistics report [PDF], academies on average spent the most time—seventy-one hours—on firearm skills, compared with twenty-one hours on de-escalation training (which teaches how to use conversation and other tactics to calm a situation without using force) and crisis-intervention strategies. In Germany, firearms training focuses on how to avoid using force. Japanese officers are trained to use martial arts.

Is police violence against civilians widespread?

Police brutality remains a problem in many advanced democracies. Officers worldwide have used aggressive means, such as rubber bullets and tear gas, to crack down on protesters, including French police during the Yellow Vests protests that began in late 2018. Police have also used excessive force when enforcing coronavirus restrictions in recent months; Kenyan and Nigerian police have killed more than thirty people amid the pandemic.

The United States far surpasses most wealthy democracies in killings by police. U.S. police killed an estimated 7,666 people between 2013 and 2019. By comparison, at least 224 people died in encounters with Canadian police during that period. Some countries, such as Finland and Norway, have gone years without police killings.

The UN Code of Conduct for Law Enforcement Officials [PDF], adopted by the General Assembly in 1979, says officers should only use force as a last resort. U.S. police can legally use deadly force if they reasonably believe they or other people are in danger, but some critics have questioned whether officers can make this judgment call. Canadian law has a similar provision. In contrast, the European Convention on Human Rights, which has been ratified by forty-seven countries, permits force only when “absolutely necessary,” and individual countries more strictly regulate its use. For instance, most ban neck restraints, the controversial tactic that resulted in Floyd’s death.

In the United States, police are armed, increasingly with military-grade equipment. By contrast, more than a dozen other democracies generally do not arm their police with guns and may instead rely on firearm-equipped teams that can respond to high-risk situations. In Ireland, most police are not even trained to use firearms. UK police, who are usually unarmed, have themselves resisted calls for them to bear arms, in line with their philosophy of policing by consent, which maintains that police legitimacy is contingent on public approval of their actions. New Zealand’s unarmed police also follow this approach.

U.S. police departments often point to the country’s high rate of civilian gun ownership—more than 120 weapons for every 100 residents—to justify arming themselves. Forty-four U.S. police officers were gunned down in 2019. That same year, officers shot and killed almost twenty-three times more civilians. All countries where police aren’t armed more tightly regulate civilian gun ownership than the United States does. In Iceland, where gun ownership is common, there has only been one documented case of a civilian killed by police in the country’s history.

How common are strained police-minority relations?

Worldwide, police often have tense relationships with minority communities. U.S. policing has a long history of discrimination. Today, Black Americans are 20 percent more likely to have their vehicles pulled over and three times more likely than white Americans to be killed by police. Discriminatory policing contributes to high rates of incarceration among minorities, oftentimes resulting in disenfranchisement, recidivism, and generational poverty.

Racial, religious, and other minorities are also stopped more often by police in much of Europe, despite generally lower crime rates among these groups. France has long struggled with rampant police targeting and abuse of Black and Arab people, which has at times sparked mass protests. Human rights activists have accused police in several OECD countries—including Greece, Italy, and North Macedonia—of arbitrarily detaining, torturing, or otherwise abusing refugees and migrants. Frequent deaths of indigenous Australians in police custody and prison have fueled outrage for decades.

New data-driven policing tools, which use technology to surveil the public and predict crime, could exacerbate racialized policing in Europe and the United States, according to anti-racism researchers. Facial recognition tools are less able to accurately distinguish between people of color, and U.S. police forces have faced allegations of perpetuating racism through data-driven profiling.

Discrimination has dampened public confidence in law enforcement. In the United States, trust in police varies by race [PDF], with Black Americans less trusting of police than others. Europeans typically trust police more than legal or political systems, though confidence in police is lower among certain minority groups than the general public. LGBTQ+ people are often wary of police. India’s Muslim communities share a distrust of police, who have been accused in recent years of failing to stop violent anti-Muslim mobs.

How have countries sought to improve police-minority relations?

Some countries have moved to diversify their forces. Some U.S. law enforcement experts say police diversity increases innovation, minimizes biases, and improves community relations. Northern Ireland, scarred by decades of conflict between the Catholic minority and Protestant majority, implemented a policy that the two groups each comprise half of its police recruits. This led to widespread trust in police by both groups, experts say, though there are still fewer Catholic officers.

Research on U.S. police has found that hiring more Black officers doesn’t necessarily reduce fatal encounters with Black civilians. Similarly, in postapartheid South Africa, which has a national police force, the government has pushed to employ more Black officers, especially in leadership positions; yet poor Black communities still suffer disproportionately from police violence.

Departments worldwide have also implemented community policing techniques to ease tensions. This includes deploying community liaisons, which in Australia work alongside officers to reduce crime and foster cross-cultural understanding and communication between police and minority groups. In Richmond, California, community policing efforts slashed crime rates and increased trust in police. Broadly, however, community policing tactics have had mixed results.

What does police accountability look like?

UN guidelines state that any effective police accountability system [PDF] must increase civilian control over the police, investigate cases of misconduct and act swiftly to address them, and reduce corruption.

Many countries rely on independent oversight bodies that have nationwide jurisdiction. In Denmark, an independent watchdog reviews all misconduct complaints and alleged criminal offenses by police. In England and Wales, police forces have separate departments to investigate complaints, and they are legally required to refer serious misconduct cases, including any killing by an officer, to an independent watchdog. That watchdog agency also sets standards for how local departments should handle complaints.

In contrast, U.S. law primarily allows police departments to investigate themselves, though there are exceptions. Some states, such as New Jersey, require local departments to turn over investigations into officer-involved shootings to county or state authorities. Cities and municipalities also have their own oversight practices. The Department of Justice (DOJ) can pressure departments to address systemic issues using consent decrees, or court-approved agreements between the DOJ and local law enforcement agencies. The DOJ signed fourteen consent decrees during the Barack Obama administration; the Donald J. Trump administration has discouraged their use, and the DOJ has filed no new consent decrees since 2017.

Many complainants of police abuse or misconduct never see an investigation or punishment for the officer involved. Canadian officers involved in fatal interactions are rarely charged, according to one study of such incidents between 2000 and 2017. Likewise, U.S. officers rarely face legal consequences for shooting and killing civilians. They are also often shielded from lawsuits through a controversial doctrine known as qualified immunity. Even when an officer is found guilty of misconduct and fired, there are few mechanisms to prevent them from being rehired by other police departments.

One strategy to prevent convicted officers from returning to the field is a national database that tracks officers’ terminations and criminal convictions. In a June 2020 executive order, President Trump directed the attorney general to create such a registry. The order also conditioned federal funds on whether departments meet certain training standards and prohibit choke holds, and it called for increased roles for mental health professionals and social workers.

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