Do not go to San Francisco, but if you do screw the flowers.

January 18, 2018


The Honorable London Breed
Acting Mayor and
President Board of Supervisors
1 Dr. Canton B. Goodlett Place
San Francisco, CA 94102
The Honorable Suzy Loftus
President Police Commission
1245 3rd Street
San Francisco, CA 94158

The Honorable Susan Christian
Chair San Francisco Human Rights
25 Van Ness Avenue, Suite 800
San Francisco, CA 94102

William Scott
Chief of Police
1245 3rd Street
San Francisco, CA 94158

Ronald L. Davis
Director Office of Community Oriented Policing Services
U.S. Department of Justice 
Office of Community Oriented Policing Services 
145 N Street NE
Washington, DC 20530

Dear Mayor, Supervisor, and Commissioners;

“If there be an object truly ridiculous in nature, it is an American patriot, signing resolutions of independency with the one hand, and with the other brandishing a whip over his affrighted slaves.” B. Banneker.

The following is an arithmetic analysis or stratification of vehicle stop data, collected by the city of San Francisco for the period, January 1, 2014 through December 31, 2017.  It is unadorned by deception. These are raw numbers; measurements. This report was begun before it was known that the US-DOJ had undertaken and completed a study that included analyses of traffic stops, in November 2016; a serendipitous fact for this report confirms, to some extent, the US-DOJ findings, even as it roundly rejects the methodologies used, by the Federal Government. The US-DOJ's benchmark for denominator selection is for the transparent purpose of diminishing abominable disparities. It is rejected and if you understood it, you would reject it too.

The dataset used in these measurements is offset 6 months into the future from that used by the USDOJ (Dec 2014-Dec 2016 vs. May 1, 2013–May 1, 2016.)  The number of records are 348, 544 vs. the 331,829 used by COPS. All outcomes, as appears on each record, have been included in this analysis; i.e. there is no mutual exclusion, since experience shows that motorists are sometimes subjected to multiple post-stop outcomes; I have seen as many as eight (8.)

The Basics

Figure A


The above is, for the most part, a reflection of unvalidateable SDPD-provided data. In the absence of record identifiers (Incident Numbers) consistency tests were impossible. I daresay that it gives me pause as I contemplate, and seek, and fail to find a valid reason for the removal of Incident Numbers. The invalid uselessness of Stop Time, in one or more of the data sources, was equally troubling. As a result, data reliability is unknown. Indeed, the data that the SDPD provides fails every data reliability test that the city espouses and recommends.[1]

Some categories of Stop Causes and Results of Search may seem to be duplicative. They are not. They are the result of the SDPD using three discrete data collection systems, and of the failure to use common data, across those systems, to drive dropdowns or checkboxes.[2] Accordingly, we have values like BOLO /APB / Warrant being made separate from BOLO/APB/Warrant; white-space matters.  Something somewhat-similar is true for “Search as a result of Probation or Parole” and “Searched as a result of Probation or Parole”; spelling matters. Sometimes the search results are embedded, at others they are not.

Granularity is achieved and illustrated in the below dashboard-like presentation of stop and post-stop outcomes.

My View and Measurements

This story is told through the use of visualizations, where the charted values are embedded or adjacent, rather than dispersed, as was done in a report prepared by a team of 18 COPS “experts.”

San Francisco’s Standard Post-Stop Items 2014-2016

Figure B


Figure B2- Comparative disparities to Whites


Distilled to the essentials, the data, in a confirmation and continuation of the lion’s share of the U.S. DOJ’s findings[3], shows in summary that:

1.       SAN FRANCISCO PD officers stopped (2.50 to population), searched, arrested, and cited (2.04 to population) more Blacks (and Hispanics, to a lesser extent) by proportion, than Whites. These findings remain constant, and so significant, over a span of years.
Figure C



2.       SAN FRANCISCO PD officers stopped, searched, arrested, and cited fewer Asians than Whites to population.

3.       The trend in adverse consequences for post-stop encounters shows worsening for Blacks and Hispanics. 

4.       The extraordinarily low citation-to-stops rate for Blacks is the result of an extraordinarily disproportionately high number of stops; the denominator effect on records (inverse). The inability to issue citations that are proportional to stops, that could survive judicial scrutiny and validation are strong indicators of bias in stops.To put it another way, after stops, SDPD police officers found far fewer reasons to ticket Blacks.

5.       The stop disproportion for Blacks, by far, outstrips that of all other groups.

6.       Some 14.70% of SAN FRANCISCO PD stops were of Blacks, who make up 5.87% of San Francisco’s population. When compared to the inverse disproportion enjoyed by Whites and Asians, Black stop disproportion is astronomical.

7.       Asians are 33.3% of the population but compose only 17.58% of stops; an inverse disparity to population, and to Whites.

8.       Whites are 41.70% of the population but compose just 37.33% of stops; an inverse disparity.

9.       Hispanics are 14.70% of the population but compose 13.12% of stops; an inverse disparity.

10.   Many stops continue to appear to be motivated by a “Hit”-driven desire to determine the parole or probationary status of individuals who were predominantly Black or Hispanic. However, there is no data to show how SAN FRANCISCO PD is able to say how such persons —those subject to 4th Waiver searches— may be identified. The disparities shown by these data are strongly suggestive that race is the basis of “identification.”

11.   Except for a relative few values, recent evaluations of post-stop outcomes show that Asians enjoy a favoured status with the SAN FRANCISCO PD. Many disparities are inverse (based on values less than), to those of Whites.

12.   All disparities between Blacks and Whites are massively statistically significant, spurious methodologies and covariates as employed by the USDOJ, notwithstanding.

13.   The City of San Francisco has offered no explanation for its failure to conform to the requirements of the California Public Records act with respect to its failure to include data for the 3rg Quarter 2017. Despite that data being available (it being the basis for San Francisco’s own report) that data was not provided. No explanation for the denial of data was provided.

Bias in the Benchmarks

I turn to the COPS prepared report for the City of San Francisco. The raw numbers —when they can be found in the COPS product, as in Table E.4— are not at significant variance with my computations; see Figure B. Accordingly, in net-effect, my examination tells the same story as was told by COPS, but it does so without the silliness of systemically-biased covariates (page 69 and 303 et seq.) based on officer-apportionment/assignment of blame for the accident and reporting. The COPS analysts claim:

Not-at-fault drivers served as an estimate of the driving population in the city, while at-fault drivers served as an estimate for those who violate traffic laws. If SFPD officers disproportionately stop minority drivers, a higher percentage of minority stops would be expected compared to the percentage of minority drivers involved in traffic collisions.”

And it is curious that Whites do not get this treatment in the computation of driving population. We are about the business of computing disparities are we not? Yes, the COPS report reads like an exercise in defining disparities down.

Such benchmarks, as used here, attempt to reduce black stop disparities to make them seem more palatable[4], and in doing so, they ignore the Reporting Biases — the selective revealing or suppression of informationthat are rife and rampant, where Blacks are concerned. Moreover, over and above the foregoing, attribution or assignment of blame for accidents, by LEAs, suffers from the same biases that these studies seek to identify and eradicate; a famous case and comment from Michael Mann:

As to the Palm Beach Gardens Police Department, it correctly changed its initial conclusion on account of obtaining and analyzing new evidence. Still, Williams might object to the police so unwaveringly blaming her in the first place: the statement, “THE DRIVER OF V1 IS AT FOR VIOLATING THE RIGHT OF WAY OF V2” in the traffic crash narrative left no room for debate at a time when the existence of video evidence had yet been ruled out, let alone studied.
Michael McCann is SI’s legal analyst. He is also an attorney and the Associate Dean for Academic Affairs at the University of New Hampshire School of Law.
The obtaining and analysis of “new” evidence, doubtless, were driven by the resources that are at the disposal of Venus Williams.

Michael McCann’s observation is of a commonplace occurrence and points to pre-judgment of the type that should be beneath an august organization, such as COPS[5], but here we are. The absence of nous in 18 “experts” is “shining plain”, other troublesome and concerning things are not, and they are not concealed either. The obvious refutation and exposure of the sophistry in this biased LEA “benchmark” is the ridiculously low-citation rates “enjoyed” by Blacks. People who cause accidents get tickets and the Blacks get fewer tickets than all, by rate to actual population.

To close this chapter: the expert analysts from COPS; the US-DOJ want us to believe that the people who traditionally have occupied the lower rungs of the economic ladder have a higher rate of possession of cars. They could have done better by driving by bus stops or by riding buses while counting riders by these examined groups.

Doubtless you have seen the SFPD-prepared report that conforms to the requirements of Admin. Code SEC. 96A.3 (a) (6) and I hope are alarmed by what it portends. That report, as presented, told me little or nothing. That is because it showed percentages and nothing else. Indeed, given the actual differences in population percentages for the examined groups, all things being equal, we should expect that Whites and Asians should always have the highest percentages; so what? Rates are the answer or remedy. For that reason, I manually entered[6] some of its data for the purpose of computing rates and raw disparities. My visualization-based measurements show said disparities for the 3rd Quarter[7].

They tell us that little has changed, other than the stop-disparities for Blacks have sky-rocketed in this third quarter, when compared to the prior three years.


Figure D


The overall disparities are trending adversely to the interest of Blacks. The raw disparity to local population percentage, for the Third Quarter, is up to 3.39 from the 2.50 that was computed for 2014-2016. I daresay that there are no convenient accident reports to water-down this massive disparity.

Figure E

Figure F


Finally;   Admin. Code SEC. 96A.3 (a) (5) requires collection of: The race or ethnicity, sex, and approximate age of (A) all individuals subject to the Detention, (B) the driver of a vehicle stopped during a Traffic Stop, and/or (C) the passengers of a vehicle stopped during a Traffic Stop, if the Officer has reasonable suspicion to detain such passengers. The Officer may collect information on age and sex by verbally asking the individual or by requesting to see identification. The Officer may collect information on race or ethnicity by verbally asking the individual

1. The Supreme Court, 10 years ago, in U.S. Supreme Court decision in Brendlin v. California, --- U.S. ---, 2007 WL 1730143 (June 18, 2007) decided that passengers are detained during traffic stops. Data must be collected for each occupant.
2. RIPA prohibits questions on race or ethnicity being directed to detainees.
 Administrative Code, SEC. 96A needs revision.

Ignorance, allied with power, is the most ferocious enemy justice can have,—James Baldwin

There is much evidence of ignorance in the COPS analysis; the reaction (or lack thereof) to it, and the Administrative Code that gave birth to it. But what impresses most is the desire to avoid Federal oversight of the operations of the SDPD. In that regard, the signal lesson of the University of Michigan is instructive.














[1] https://datasf.gitbooks.io/datasf-guides-data-quality/content/step_1_collect_needs_and_requirements.html
[2] The eStops table contained 4855 records. One record was populated by NULLS. 331,829
[3] Disparities in stop, arrest, and search data between ethnic or racial groups in the city and county of San Francisco persist. The assessment team’s analyses of the SFPD’s traffic stop data reveal disparities related to the SFPD’s issuance of warnings, citations, arrests, and searches based upon racial and ethnic categories. The SFPD’s data demonstrate that African-American drivers are more likely to be warned, arrested, and searched than White drivers, and Hispanic drivers are more likely to arrested and searched than White drivers. https://www.sfdph.org/dph/files/jrp/DOJ-Report.pdf page 61.

But see the disgraceful methodology — based on at-fault reports by California LEAs— used by the US-DOJ to rationalize and diminish the 250% disparity. See https://www.sfdph.org/dph/files/jrp/DOJ-Report.pdf, at page 297: Not-at-fault drivers served as an estimate of the driving population in the city, while at-fault drivers served as an estimate for those who violate traffic laws. If SFPD officers disproportionately stop minority drivers, a higher percentage of minority stops would be expected compared to the percentage of minority drivers involved in traffic. By implication, California LEA’s find Blacks to be at-fault around 3 times as often as Whites. Venus Williams, initially found at-fault by a LEA, due to her race, a common experience for Blacks, does not live in California. Venus Williams has resources.

Reports and judgments  by California LEAs are the issue. Again, the tone-deafness or cynical nature of the US-DOJ using a blame-apportionment benchmark as a tool, to diminish disparities, is disgraceful, astounding but not surprising. Those comedians suggest that Blacks though only 5.7 of population, are 12% of the driving population. Right! I suggest that they drive pass bus stops in San Francisco.

Also unsurprising is the failure to explain the effect of the high Black stop rates on the low Black Citation rates; a condition contrapositive to the COPS-embraced methodology that suggests that the people at the bottom of the economic scale drive more; transparent bigotry.  More productive would have been an explanation of the quite self-evident that the low citation rates “enjoyed” by the Blacks; the result of the inverse relationship between stops and citations. On this matter the US-DOJ chose silence when words would matter. Doubtless it is clear to them (COPS) that citations were not being issued to blacks (16.04 points below the mean) because the judiciary would not have sustained them.

[4] The inadvisability of using self-reporting data (At-fault traffic accident reports) from a source that is itself being investigated for bias,  to validate, authenticate or to be the basis of a measurement methodology, is cynical at best, scandalous at worst. To this analyst, it is flabbergasting and he heartily recommends the recent experience of Venus Williams and The New Jim Crow as remedies. See also Reliability of self-report data @http://www.creative-wisdom.com/teaching/WBI/memory.shtml.
[5] Here, the bias shows that COPS it is more than an acronym or abbreviation; it is a form of self-service.
[6] The SDPD failed to provide the data that it used in its report, despite receiving a lawful request for it.
[7] Page 6 shows the number of Traffic stops to be 24, 682, but the computed total is 24,862.

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