Six

Composed of Saint Paul residents, the Police Civilian Internal Affairs Review Commission (PCIARC or Commission) is the City’s civilian oversight group that reviews investigations into complaints from community members about misconduct by licensed officers of the Saint Paul Police Department (SPPD). The PCIARC recommends disciplinary actions and policy updates to the Saint Paul Chief of Police based on its review of complaints filed by community members. The PCIARC does not replace civil or criminal court, rather it makes recommendations to the Chief of Police regarding the conduct of police officers as employees, subject to the Minnesota Peace Officer Discipline Procedures Act (PODPA) and related state labor laws. The Chief of Police
has the final authority over any discipline assigned to a police officer. 

PCIARC History & Overview

Established in 1993 and operating under a review-focused model, the PCIARC provides oversight, recommends dispositions and policy changes, and promotes accountability through community engagement.

CLICK HERE: To learn more about the PCIARC and its history. 


A list of the active complaint intake centers is available on the PCIARC website.

CLICK HERE: To visit the PCIARC website

If your organization is interested in learning more about the PCIARC process and/or becoming a community complaint intake center, please contact the PCIARC Coordinator at CivilianReview@stpaul.gov or 651-266-8970.

A woman in a black-and-white patterned top stands at a podium with a microphone and laptop, looking to the side during a presentation.

PCIARC Cases Reviewed

The following table shows cases reviewed by the PCIARC since the Commission moved to HREEO in 2017.


In 2022, the PCIARC began publishing the total number of complaints filed with IAU, the number sent to the PCIARC for review, and the reasons the other complaints were not sent to PCIARC for review. The following table provides a summary of those numbers. Additional information about why not all complaints received by IAU is reviewed by the PCIARC is available in the “2024 Complaints received by IAU” section later in this report.

 

2017

2018

2019

2020

2021

2022

2023

2024

Cases Reviewed by PCIARC

29

42

44

39

21

19

34

52

Total Sworn Officers

54

70

72

81

26

32

66

97

Total Allegations

63

77

88

90

26

37

88

124

Total Complaints Received by IAU

Year

2022

2023

2024

Total Complaints

54

15

39

To PCIARC

91

44

47

Not to PCIARC

103

60

43

Please note: While 60 of the complaints received by IAU in 2024 were designated as going to the PCIARC, some of them will be reviewed by the Commissioners in 2025.

2024 PCIARC Commission Members

The PCIARC is comprised of up to nine community members representing a variety of Saint Paul neighborhoods, races, cultures, abilities, backgrounds, and incomes. After completing an application and interview process, residents are recommended to serve on the PCIARC by the Director of HREEO, appointed by the Mayor, and lastly, approved by City Council. Pursuant to § 102.02(c) of the Ordinance, members of the Saint Paul Police Federation and their immediate family are not eligible to serve on the PCIARC.
Prior to serving as a voting member, PCIARC Commissioners must complete training related to police work, investigation, relevant law, cultural competency, racial equity, implicit bias, sexual orientation, gender identity, physical disability, mental illness, and the emotional impact of abuse. Commissioners must also do a ridealong with an SPPD officer.

Commissioners Serving in 2024 Were:

Erin Hayes (Chair)First Term: February 2, 2022, to February 2, 2025
Sarah Florman (Vice Chair)First Term: February 1, 2023, to February 1, 2026
Eric ForstromSecond Term completed January 4, 2024
Shaval WebbFirst Term: February 2, 2022, to February 2, 2025
Nancy RodenborgFirst Term: February 2, 2022, to February 2, 2025
Nicohle SchluenderFirst Term: February 1, 2023, to December 4, 2024, resigned
Deborah AriremakoFirst Term: October 11, 2023, to January 10, 2025, resigned 
Lara ForstromFirst Term: May 1, 2024, to May 1, 2027

PCIARC Coordinator

The PCIARC has a full-time coordinator who works in the HREEO department. The coordinator serves on behalf of HREEO as a liaison among community members, the Commission, and SPPD. The coordinator works to build trust, increase transparency, and expand public access to the complaint investigation process. The coordinator receives complaints from the public and ensures the PCIARC process runs smoothly. They do not investigate complaints or vote on recommendations related to cases. The PCIARC coordinator serves at the appointment of the Director of HREEO in consultation with the Chief of Police. Sierra Cumberland served as the PCIARC Coordinator in 2024.

Contact the PCIARC Coordinator with questions or to file a complaint:

CivilianReview@stpaul.gov 651-266-8970

Internal Affairs Unit (IAU)

Saint Paul Police Department Internal Affairs Unit Staff 

IAU coordinates, supervises, and investigates complaints against SPPD and/or allegations of misconduct against individual licensed police officers. In the PCIARC process, IAU’s function is to impartially collect evidence, interview witnesses, and provide a complete report to the PCIARC and to the administration of SPPD for review and disposition. IAU is comprised of both professional support staff and SPPD Sergeant investigators. Commanders Jake Peterson, John Cajacob, and Matt Toronto led IAU for portions of 2024.

2024 Internal Affairs Unit Complaint Data

In addition to filing complaints with HREEO or submitting on the PCIARC website, community members may file complaints of police misconduct directly with SPPD’s IAU.

Please note: Only complaints involving sworn Saint Paul police officers that are outlined in the PCIARC Ordinance have the potential to be reviewed by the Commission. If a complaint does not involve a sworn Saint Paul police officer or does not fall within the categories listed above, it may be closed by the SPPD IAU without PCIARC review. 

Additionally, only complaints filed directly with HREEO are reviewed by the PCIARC Coordinator before they are referred to SPPD’s IAU for investigation. The PCIARC Coordinator is not informed of cases filed directly with IAU until an investigation is complete and only if a case will go to the PCIARC for review and consideration.

2024 Complaints Received by IAU

Only a portion of complaints filed go to the PCIARC for review. The following table captures the total number of complaints from community members that IAU investigated in 2024 and indicates the portion sent to the PCIARC for review. At each monthly PCIARC meeting, IAU provides summary data regarding complaints that will not be submitted to the PCIARC for review.

2024ComplaintsComplaints to PCIARC for ReviewComplaints not to PCIARC for Review
Jan514
Feb13103
Mar945
Apr1156
May853
Jun844
July642
Aug12102
Sep514
Oct716
Nov321
Dec16133
Total1036043

2024 Complaints Not Submitted to PCIARC for Review

Of the 103 complaints from community members that IAU investigated in 2024, 60 were designated to go to the PCIARC for review and 43 were not. Some of them will be reviewed by the PCIARC in 2025. This table captures the reasons why 43 complaints did not go to the PCIARC for review.

2024No Policy ViolationDoes not Meet PODPAComplaint WithdrawnNot Sworn EmployeeNot City of Saint Paul EmployeeOpen Criminal or Civil
Jan102010
Feb100011
Mar202001
Apr011130
May000012
Jun111010
July001010
Aug000011
Sep000031
Oct001023
Nov000010
Dec000012
Total52811611
Definitions of Complaints Not Sent to PCIARC for Review
No Policy Violation: This category includes instances where a complainant has filed a complaint yet there is no alleged policy violation against the employee. Per IAU, some examples of cases submitted that have been given this classification include Mental Health Referral, Lack of Information, and Dispute Information. One example of a case in this category is when a community member used the PCIARC complaint form to dispute a speeding ticket they received. The information provided did not allege that an officer did anything wrong, rather the complainant did not agree with getting a ticket. Because there was no policy violation by SPPD or any individual officer, the information was not submitted to the PCIARC for review.Not Sworn Employee: The complaint must be about a sworn SPPD officer in their capacity as an employee in order to undergo the PCIARC process. If a complaint is made against a staff member of SPPD who is not a licensed police officer, the case would be investigated and resolved by IAU only.
Does Not Meet PODPA: The complaint does not satisfy the statutory requirements in Minnesota for opening an internal affairs complaint against a police officer.Not City of Saint Paul Employee: SPPD often receives complaints regarding officers who work in a different city or county. Those complaints are recorded as received and marked “Not Our Employee” by IAU and are not submitted to the PCIARC for review.
Complaint Withdrawn: The complainant withdrew their complaint.Open Criminal or Civil: There is an active criminal or civil case related to the incident currently progressing through the legal system. IAU believes that initiating an internal investigation at this stage could compromise the complainant's rights. Complainants may choose to request that IAU continue the investigation while the case is pending, or they may opt for the investigation to proceed after the criminal or civil case is concluded.

PCIARC Case Review Process

In the PCIARC process, a community member files a complaint against a sworn police officer in their capacity as an employee of the City of Saint Paul. The community member who filed the complaint is known as the complainant throughout the process. This process considers whether officers violated SPPD policy and is different than, and does not replace, civil or criminal legal action. The PCIARC follows an administrative process detailed in the Ordinance.

1

A complaint of police misconduct is received by HREEO

A complaint of police misconduct is received by HREEO and/or SPPD’s IAU, depending on how it was submitted by a community member. Please note, the PCIARC Coordinator in HREEO is not informed of cases filed directly with IAU until, and only if, a case is scheduled to be reviewed by the PCIARC

2

Complaint is reviewed

Once received, the complaint is reviewed to ensure that it has been properly signed. Under state law, complaints are official only when signed by the complainant.

3

IAU confirms the complaint

IAU confirms that the complaint is about an active, licensed police officer with SPPD. IAU determines if the complaint is eligible for PCIARC review based on the ordinance and identifies which department policies may be involved. IAU Investigations can take approximately 8–12 weeks.  If a complaint does not involve a sworn Saint Paul police officer and/or does not fall within the categories listed above, it may be closed by IAU without PCIARC review. 

4

The investigation is complete

When the investigation is complete, the case may be scheduled to go to the PCIARC for review and consideration. If so, IAU notifies the PCIARC Coordinator and provides the Commissioners with case materials. Case materials may include a summary of the investigation, interviews, statements of the officers involved, and all accompanying evidence. These materials are made available two weeks before the PCIARC’s next meeting when it is set to discuss the case. 

5

Complainants have a right to make a statement

As complainants have a right to make a statement at the PCIARC meeting, the coordinator will notify complainants that their case is scheduled to be discussed at the next PCIARC meeting.   

6

Additional Statements

If a complainant chooses to make a statement, the officer(s) listed in the complaint will also be given the opportunity to make a statement if they attend the meeting. If any statements are given at a meeting, the case will be considered at a later meeting as statement(s) are transcribed and the IAU reviews the transcript for any new facts that may need follow-up investigation. Officers have the right to receive a copy of statements made about the incident and provide a response.  

7

PCIARC Commissioners review and discuss the case

PCIARC Commissioners review all case materials and discuss the case. Their objective is to assess if the police officer involved violated policies in their capacity as an employee. On each case, the PCIARC recommends a disposition and may recommend disciplinary action to the Chief of Police.  

8

Receiving a recommendation from the PCIARC

After receiving a recommendation from the PCIARC, the Chief of Police makes a final decision on the case. If the Chief of Police rejects the PCIARC's recommendation or issues an action different from the PCIARC's recommendation, it is called a departure. 

9

Chief issues a departure

If the Chief issues a departure, they notify the PCIARC Coordinator in writing of the actions they intend to take instead. The PCIARC Coordinator notifies the Commissioners. The PCIARC Chair has five business days to discuss any concerns with the Chief of Police.  

10

Chief of Police decides to take disciplinary action

If the Chief of Police decides to take disciplinary action, the officer(s) may file a grievance as allowed by their employment contract. 

11

Grievance process has been completed

Once the grievance process has been completed, if applicable, a case has reached final disposition, and the complainant is notified of result of their complaint by IAU in a letter

Types of Cases Reviewed by the PCIARC 

The PCIARC Ordinance outlines which cases are eligible for PCIARC review. The PCIARC reviews cases regarding alleged acts of: 

  • Excessive force
  • Improper conduct
  • Improper procedure
  • Inappropriate use of firearms
  • Discrimination (as defined by Saint Paul Legislative Code § 183.02)
  • Racial profiling
  • Poor public relations
  • Complaints referred by the Mayor, Chief of Police, and/or the Director of HREEO

Please note: Only complaints involving sworn Saint Paul police officers within the categories outlined in the PCIARC Ordinance have the potential to be reviewed by the PCIARC. If a complaint does not involve a sworn Saint Paul police officer and/or does not fall within the categories listed above, it may be closed by the IAU without PCIARC review. 

Additionally, only complaints filed directly with HREEO are reviewed by the PCIARC Coordinator before they are referred to SPPD’s IAU for investigation. The PCIARC Coordinator is not informed of cases filed directly with IAU until an investigation is complete and only if a case will go to the PCIARC for review and consideration.

2024 PCIARC Case Review Data

Summary data reflects the 52 cases reviewed by the PCIARC, as well as disposition and disciplinary
recommendations made to the Chief of Police. Some of the complaints reviewed by the PCIARC in 2024 were filed in 2023.

  • The complaint classification “Improper Procedure” was the most common type of complaint received.
  • Of the reviewed cases, “Not Sustained” was the most frequently recommended disposition.

52

Total

Cases

124

Total

Allegations

97

Total

Officers

Some Things to Consider

  • Each case reviewed by the PCIARC can have multiple allegations. For example, allegations investigated for a single complaint could be improper conduct, improper procedure, and poor public relations.
  • A complaint can also have multiple officers listed in the case.
  • Each officer listed could be considered for one allegation or multiple. For example, a complaint is filed against Officer A and Officer B. The complainant alleges Officer A engaged in discrimination and improper procedure and that Officer B engaged in improper procedure only. This singular complaint would involve two officers and three total allegations.

1

Discrimination

85

Improper Procedure

Excessive Force

11

Poor Public Relations

22 

Improper Conduct

124

Total Allegations

Under the review-focused model, PCIARC Commissioners review all case materials, hold case deliberations, and recommend a determination on investigations as to if an officer violated a policy. That determination is called a disposition. Commissioners may also recommend disciplinary action to the Chief of Police and make policy recommendations to SPPD. Under Saint Paul’s review-focused model, the PCIARC may only recommend a disposition because the Chief of Police is the decisionmaker on dispositions. Under PODPA, the Chief of Police is the decisionmaker on any discipline issued.

Recommended Dispositions

The PCIARC Bylaws outline the dispositions the PCIARC may recommend: 

  1. Unfounded: Allegation is false or not factual
  2. Exonerated: Incident occurred but was lawful and proper
  3. Not Sustained: Insufficient evidence either to prove or disprove the allegation
  4. Sustained: Allegation is supported by sufficient evidence
  5. Policy Failure: Allegation is factual and followed proper procedure, however, that procedure has proven to be faulty
2024 Disposition Recommendations: Not Sustained 32, Exonerated 29, Unfounded 25, Sustained 24, Policy Failure 14.

Recommended Discipline

The Saint Paul Police Federation Collective Bargaining Agreement states that employees will be disciplined “in accordance with the concept of progressive discipline,” meaning that each new discipline issued will be more severe than the last to help employees improve or correct their actions. The disciplines below appear in order of severity. 

  1. Oral Reprimand: Verbal order to correct the employee for a violation of a department rule, regulation, or procedure, which is then reduced to writing
  2. Written Reprimand: Written order to correct the employee for a violation of a department rule, regulation, or procedure
  3. Suspension: Unpaid suspension from work that is no more than 30 days
  4. Demotion: Reduction in rank.
  5. Termination: Termination of employment 

This is the frequency of disciplinary actions recommended by the PCIARC in 2024.

15

Oral Reprimand

1

3-Day Suspension

1

10-Day Suspension

4

Written Reprimand

1

5-Day Suspension  
Retraining is not defined as discipline in the SPPD labor contract though it may be recommended by the PCIARC and must be paired with other discipline. In 2024, the PCIARC recommended retraining five times.

2024 Demographic Information of Cases Reviewed by the PCIARC 

Complainant income: Most common was “Not asked” (17), followed by “No answer” (9) and “Less than $20,000” (8); other ranges had fewer.
 
 
Complainant race: Most were White (15), Black (13), or No answer (11); fewer identified as other races or chose not to respond.
 
Complainant age: 19-25 (2), 26-34 (11), 35-54 (18); 55-64 (2), 65+ (4), No answer (14), Prefer not to answer (1).
 

Chief of Police Departures from PCIARC Recommendations

Under the city’s review-focused model, the Chief of Police has authority to accept or depart from the PCIARC’s recommended disposition and discipline. If the Chief of Police rejects the PCIARC's recommendation or issues an action different from the PCIARC's recommendation, it is called a departure. Under state law and the Saint Paul Police Federation Collective Bargaining Agreement, officers have the right to challenge an employment discipline decision through arbitration, which may result in discipline decisions being overturned.

In 2024, Chief of Police Axel Henry departed from a disposition recommended by the PCIARC nine times and departed from disciplinary actions recommended by the PCIARC 15 times.

Please note, this chart includes departures received in 2024. Some of these departures are regarding recommendations issued by the PCIARC in 2023.

Allegation Classification 

PCIARC Disposition

Chief Disposition 

PCIARC Discipline Recommendation

Chief Discipline Implemented 

Improper Procedure & Improper Conduct

Sustained

Sustained 

Termination 

  5-day suspension

Improper Procedure & Improper Conduct

Sustained

Sustained 

Termination 

7-day suspension  

Improper Procedure  

Sustained

Exonerated  

5-day suspension

None  

Poor Public Relations

Sustained

    
Sustained

10-day suspension

Written reprimand 

Improper Procedure

Exonerated 

    
Sustained

None 

    
Written reprimand 

Improper Procedure

Exonerated 

    
Sustained

None  

Oral reprimand

Improper Procedure

Sustained

    
Sustained

Oral reprimand  

Supervisory Counseling

Improper Conduct 

Sustained

    
Sustained

    
3-day suspension

Oral reprimand

Improper Procedure  

Sustained

Unfounded 

Written reprimand 

None  

Improper Procedure  

Sustained

Not Sustained

Written reprimand

None  

Improper Procedure  

Sustained

Not Sustained

Oral reprimand  

None  

Improper Procedure  

Sustained

Not Sustained

Oral reprimand  

None  

Improper Procedure  

Sustained

Not Sustained

Oral reprimand  

None  

Improper Procedure  

Sustained

Unfounded

Oral reprimand  

None  

Improper Procedure  

Sustained

Unfounded

Oral reprimand  

None  

Three

Strengthening Community: Policy Recommendations

As shown in the previous data, the PCIARC recommended the disposition of policy failure for 14 of the allegations reviewed by the PCIARC in 2024. Per §102.03(g) of the Ordinance, when the PCIARC recommends the disposition of policy failure, they may also include a recommendation on how that policy could be updated. The PCIARC recommended the following SPPD policies be revised: 

  • 416.01 – Online Reporting and Teleserve
  • 442.18 – Body Worn Camera Policy
  • 363.20 – Breach of Trust 

At the March 2024 PCIARC meeting, the Commission discussed trends they noticed in how SPPD responded to calls for service related to domestic violence. This discussion did not include case-specific information and was held during the public portion of the meeting. 

As a Result of the Discussion, the Commission Suggested:

  • Comparison of written policy on domestic violence and training officers receive to ensure consistency;
  • Greater involvement of domestic violence advocates to better support officers and victims alike;
  • Standardized resources for officers to provide to victims, and;
  • Additional training for officers.

Connect with the PCIARC

PCIARC Meetings

There are two portions of PCIARC monthly meetings, a public portion and a closed portion. The public portion of a Commission meeting includes administrative business, updates from SPPD, HREEO, and community organizations, and training. All community members are welcome to attend the public portion of meetings, either virtually or in person. The closed portion of the meeting consists of case review and discussion that is regulated by state data privacy and open meeting laws. The closed meeting portion is not open to the public. Visit the PCIARC website for dates, locations, and links to join the public portion of the meeting.

In 2024, the PCIARC received trainings or updates in the following areas during the public portion of meetings:In 2024, the PCIARC held discussion on the following topics during the public portion of meetings:
  • SPPD Employee Assistance Program (EAP)
  • Principles for Effective Oversight (Established by
    NACOLE)
  • 2023 Legislative Criminal Updates
  • Warrantless Entry and Exigent Circumstances
  • Miranda Rights
  • Saint Paul COAST Unit and Other Mental Health
    Services
  • Family Violence Unit
  • PCIARC Bylaws and SOPs (Standard Operating Procedures)
  • PCIARC Remote Attendance Policy
  • Trends in Cases Related to Response to Domestic Violence
  • Chief Departure Letter Sharing Process
  • City Budget Engagement
  • Commissioner Lara Forstrom and Coordinator Sierra Cumberland attended the 2024 Annual NACOLE Conference and shared highlights

2024 Annual Summit

The PCIARC is required to hold an Annual Summit to review PCIARC complaint and case data, including complainant demographics, PCIARC recommendations, and known case outcomes.

The PCIARC held its 2024 Annual Summit on May 16, 2024, at the Rondo Community Library in Saint Paul. The summit provided an opportunity for community members to learn more about the PCIARC process, ask the Commissioners questions, and review data from the 2023 Annual Report. Mayor Melvin Carter and Chief of Police Axel Henry provided remarks on their vision for public safety in Saint Paul. Brooke Blakey, Director of the Office of Neighborhood Safety, and DJ Brooks, Executive Director of World Youth Connect, spoke about a recent Public Safety Community-Based Indicators Pilot, which captured perceptions of safety by members of the community ages 13-24. PCIARC Chair Erin Hayes, Chief Henry, and Commissioners also discussed their experiences with the Commission and answered questions. A video recording of the 2024 PCIARC Summit is available online.

Request a Presentation

Do you know a community group that may be interested in learning about the PCIARC? Contact the PCIARC Coordinator to set up a presentation about the PCIARC and other programs housed in HREEO, such as Labor Standards and Human Rights Investigations. Presentations are free and can be done either virtually or in person. HREEO also attends community events to share information with community members. Please let us know about your upcoming event to help HREEO spread the word! We look forward to working with you!

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Last Edited: May 8, 2025