1 W. L. Melville Lee, A History of the Police in England 204 (London: Methuen & Co., 1901) (reprinted in 1970 by Patterton Smith Publishing, Montclair. N.J.). For a comparison of the histories of English and American police, see Wilbur R. Miller, Cops and Bobbies: Police Authority in New Yolk and London, 1830–1870 (Chicago: University of Chicago Press, 1977).Google Scholar

2 Miller, supra note 1, at 4.Google Scholar

3 Edward Palmer Thompson, The Making of the English Working Class 82 (New York: Random House, 1966).Google Scholar

4 Anna A. Ramsey, Sir Robert Peel (New York: Dodd, Mead, 1938).Google Scholar

5 Lee, supra note 1, at 156.Google Scholar

6 Miller, supra note 1, at 33.Google Scholar

7 See Robert M. Fogelson, Big-City Police (Cambridge: Harvard University Press, 1977); Roger Lane, Policing the City: Boston 1822–1885 (Cambridge: Harvard University Press, 1967); James F. Richardson, The New York Police: Colonial Times to 1901 (New York: Oxford University Press, 1970).Google Scholar

8 Theodore J. Lowi, The End of Liberalism: Ideology, Policy, and the Crisis of Public Authority (2d ed. New York: W. W. Norton & Co., 1979).Google Scholar

9 Perhaps the most widely read is the report from the President's Commission on Law Enforcement and Administration of Justice, The Challenge of Crime in a Free Society (Washington, D.C.: Government Printing Office, 1967). See especially chapter 4, “The Police,” and chapter 5, “The Courts.” Several of the research reports submitted to that commission for consideration in preparing its final report still deserve a reading. See, e.g., Field Surveys I-V, which are reports on police practices in several American cities in the 1960s (Washington, D.C.: Government Printing Office, 1965–66). Who Is Guarding the Guardians? A Report on Police Practices (Washington, D.C.: U.S. Commission on Civil Rights, 1981) summarizes the conclusions of several task forces on the police, including police-related discussion from the National Commission on the Causes and Prevention of Violence (Rights in Conflict (Washington, D.C.: U.S. Government Printing Office, 1968)) and several reports from the violence commission itself. Chapter 4 lists the external controls, that may be used to hold police accountable. They include city governmental bodies and officials, state and federal prosecutors. federal agencies, and private police-watching groups, including quasi-governmental civilian review boards. We argue here that another private police watcher, the local media-both newspaper and broadcast outlets-should be added to that list). Several books catalog the role of police administrators in assuring that officers on the street are well chosen, well trained, and themselves well policed. One of the earliest and still very comprehensive is V. A. Leonard, Police Organization and Management (2d ed. Brooklyn, N.Y.: Foundation Press, 1964). An excellent issues-oriented overview is Louis A. Radelet, The Police and the Community: Studies (3d ed. Encino, Cal.: Glencoe Publishing Co. 1980). Bibliographies of materials concerning police administration are available from the International Association of Chiefs of Police, 13 First field Rd., Gaithersburg, Md. 20878. On the problems of hiring, see John H. McNamara, Uncertainties in Police Work: The Relevance of Police Recruits' Backgrounds and Training, in David J. Bordua, ed., The Police: Six Sociological Essays (New York: John Wiley & Sons, 1967); and Thomas C. Gray, Selecting for a Police Subculture, in Jerome H. Skolnick & Thomas C. Gray, eds., Police in America (Boston: Little, Brown & Co., 1975). On the potential and problems of self-policing through internal investigation and control. see Note, The Administration of Complaints by Civilians Against the Police, 77 Harv. L. Rev. 499 (1964). and the discussion of internal police controls in George E. Berkley, The Democratic Policeman (Boston: Beacon Press, 1969). For a discussion of the potential of self-regulation of police agencies as compared to the effectiveness of judicial oversight of police practices, see Carl McGowan, Rule-Making and the Police, 70 Mich. L. Rev. 659, 676 (1972).Google Scholar

10 See the American Bar Association's publication from the Project on Standards for Criminal Justice, Standard Relating to the Urban Police Function (Tent. Draft, 1972).Google Scholar

11 Id. at 125–32.Google Scholar

12 The general opinion of criminal justice professionals is that civilian review boards have not delivered the benefits of police accountability that 1960s reformers believed they would. We lack objective impact studies of how police behavior was affected in those cities that set up review boards. Implementation is a problem in any administrative reform, but we could hypothesize that accountability would have been fostered more effectively in those cities that gave their review boards independent investigatory and subpoena powers. Alternatively, these boards may have deterred police misconduct in certain closely knit, homogeneous cities, where the review boards were composed of representatives from leading powerful civil institutions (e.g., religious leaders, bank presidents, school teachers, police administrators), but not in cities with diverse ethnic and economic class populations that set up boards with identical review frameworks. Now that a decade has passed since most of these boards began to operate, the literature cries for a solid study assessing their impact on police practices. The rationale for instituting these boards is outlined in Paul Chevigny, Police Power: Police Abuses in New York City (New York: Pantheon Books, 1969), and discussed in Albert J. Reiss, Jr., The Police and the Public 180–207 (New Haven: Yale University Press, 1971). Evidence about impact of the boards is discussed in Edward J. Littlejohn, Civilian Police Commission: A Deterrent to Police Misconduct, 59 U. Det. J. Urb. L. 5 (1981). One of the few recent studies that attempts to assess empirical impact indicators of police review boards is Note, Complaint Review Boards in Florida: Who's Complaining? 7 Nova L.J. 353 (1983).Google Scholar

13 We are speaking here of lawsuits prosecuted by private citizen plaintiffs alleging that police have violated their civil rights. Such a cause of action arises from 42 U.S.C. § 1983, which reads: “Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress.” Monroe v. Pape, 365 U.S. 167 (1961), and Monell v. Department of Social Servs., 436 U.S. 658 (1978), assured citizens that neither abusive police acts nor policies encouraging them would be ignored by the courts. An introductory hornbook to the burgeoning law of civil rights actions is Chester. I. Antieau, Federal Civil Rights Acts, 2 vols. (2d ed. Rochester, N.Y.: Lawyers Co-operative Publishing Co., 1980). See also National Lawyers Guild, Police Misconduct: Law and Litigation, ed. Michael Avery & David Rudovsky (New York: Clark Boardman Co., 1980). A state tort claim attached to a section 1983 claim for denial of federal civil rights against police officers and their supervisors can be brought into federal court under pendent jurisdiction. For example, a lawsuit alleging wrongful death at the hands of a police officer could be pursued in most state courts, of course, since wrongful death is a well-recognized common law tort. The state claim becomes part of a federal lawsuit if appended to a section 1983 claim for denial of life and clue process (violation, of the Fourteenth Amendment) and for denial of the right to be free from assault and bodily injury (violation of a right arising from the Fifth and Fourteenth amendments). A common factual nexus between other torts (such as false imprisonment or invasion of privacy) and a federal civil rights violation often exists. A complaint alleging violation of civil rights under section 1983 and also tortious activity under state law assert, two claims and two wrongs, and a plaintiff may recover compensatory or injunctive relief for each of them.Google Scholar

14 Perhaps because few citizens are willing to invest the time and expenses of litigation in order to challenge simple routine police misconduct. It is difficult to estimate compensatory damages appropriate for redressing constitutional violations that may be real, but are nevertheless of short duration, difficult to prove, and likely to be compensated by only small monetary awards even if the plaintiff prevails. Illegal detentions for short periods, misdemeanor arrests made with less than probable cause, petty harassment of minority group members-these and other police practices may be degrading and unconstitutional, yet challenging them is seldom worth the costs of bringing wit unless a class action can he organized. Though civil litigation against police has increased markedly in the last ten years, most reported cases involve improper use of deadly force, brutal beatings, or false arrests and imprisonment causing plaintiffs to lose jobs and wages. Virtually all cases resulting in large damage awards against police officers reported over the past three years by a national law enforcement support group, for example, have involved death or severe physical harm to the plaintiffs. See in general 1979–1982 Legal Liability Reporter the journal published by Americans for Effective Law Enforcement in South Satl Francisco, California.Google Scholar

15 In this essay, we use the term media to refer to both broadcast and print outlets. Where distinctions between them are important for the themes discussed, we note these in the test. The reader who has an interest in the history of the broadcasting industry and how its unique powers and regulatory scheme impinge on First Amendment values may wish to read K. H. Coase, The Federal communications Commission, 2 J. Law & Econ, 1 (1959); the reply to Coase by Nicholas Johnson, Towers of Babel: The Chaos in Radio Spectrum Utilization and Allocation, 34 Law & Contemp. Probs. 505 (1969), for historical and policy overviews; and Lee Loevinger, Free Speech, Fairness, and Fiduciary Duty in Broadcasting, 34 Law & Contemp. Probs. 278 (1969), on First Amendment issues. These and other work illustrating the constitutional and regulatory problems arising from the broadcast industry are excerpted in Douglas H. Ginsburg, Regulation of Broadcasting: Law and Policy Towards Radio, Television and Cable Communications (St. Paul, Minn.: West Publishing Co., 1979).Google Scholar

16 Gaye Tuchman, Making News 157 (New York: Free Press, 1978).Google Scholar

17 The notion that the First Amendment is an admonition to the media to explore the broadest range of public concerns and topics permeates case law. Its origin undoubtedly is Meiklejohn's metaphor for the mission of the press: Media must offer the public “a marketplace of ideas,” from which a self-governing citizenry may “buy” the most compelling, reasoned, and true arguments. (The metaphor was originally formulated by Justice Holmes, who said that free speech resulted in “the power of a thought to get itself accepted in the competition of the market.” Abrams v. United States, 250 U.S. 616,630 (1919) (Holmes, J., dissenting). Note that Meiklejohn's analysis of the “marketplace” was not a pluralist assertion that all citizens should stubbornly hold their own opinions and that the marketplace of political decision making would establish a homeostatic balance among all the opinions. Rather, each citizen would debate and reason with others: the “market” is manifest when together citizens agree that one idea or policy is preferable to others. Alexander Meiklejohn, Free Speech and Its Relation to Self-Government 86–87 (New York: Harper & Bros., 1948). Meiklejohn said that “the welfare of the community requires that those who decide issues shall understand them,” and in the modern era the media are powerful providers of the raw material necessary for achieving understanding. Id. at 25. One example of a “facilitative” approach to the First Amendment is the FCC's fairness doctrine. Paradoxically, that policy requires that broadcasters be regulated (i.e., that they be restricted) in order to facilitate more speech. The fairness doctrine requires that television and radio stations investigate and report on important public issues and that they cover as many contrasting viewpoints as possible regarding those issues. Stations must even donate free air time to citizens who wish to offer opinions that may not have been presented in regular station programming on a particular issue. Cullman Broadcasting Co., 40 Op. F.C.C. 576 (1963). The Supreme Court recognized that the First Amendment contains a facilitative function when it held that the valid object of the fairness doctrine was “to enhance rather than abridge the freedoms of speech and press protected by the First Amendment.” Proving that the doctrine restricted station owners' economic interests wag not sufficient to prove a First Amendment violation if the restriction served to facilitate more speech. Red Lion Broadcasting Co. v. FCC. 395 U.S. 367, 375 (1969). The fairness doctrine does not require broadcast reporters to include every minority opinion or every possible interpretation of any given issue of “public importance,” but it does require a broadcast outlet to cover what in its “reasonable discretion” are all sides of a “controversial issue.” National Broadcasting Co. v. FCC, 516 F.2d 1101, 1102 (D.C. Cir. 1974), cert. denied sub nom. Accuracy in Media v. National Broadcasting Co., 424 U.S. 910 (1976). That case illustrates the implications of the fairness doctrine for investigative journalism. For a discussion of the fairness doctrine and the First Amendment as applied to broadcasting, see the report on the symposium, Broadcasting and the First Amendment: The Anatomy of a Constitutional Issue, Report on a Center Conference, Center Mag., May/June 1973, at 19. See especially the interchange between Harry Kalven, Jr., (at 36) and Antonin Scalia (at 38). For an essay that supports the Red Lion“facilitative restriction” on the ground that broadcasters would probably not be diligent in fulfilling their fiduciary duties to the public in news and public affairs programming without some minimal government regulation, see Bollinger, Lee C., Freedom of the Press and Public Access: Toward a Theory of Partial Regulation of the Mass Media, 75 Mich. L. Rev. 1 (1976).CrossRefGoogle Scholar

18 Egon Bittner, The Functions of the Police in Modern Society: A Review of Background Factors, Current Practices, and Possible Role Models (Chevy Chase, Md.: National Institute of Mental Health, Center for Studies of Crime and Delinquency, 1970): Kenneth Culp Davis, Discretionary Justice: A Preliminary Inquiry (2d ed. Chicago: University of Illinois Press, 1971); Joseph Goldstein, Police Discretion Not to Invoke the Criminal Process: Low-Visibility Decisions in the Administration of Justice, 69 Yale L.J. 543 (1960).Google Scholar

19 E.g., see Kenneth Culp Davis, Police Discretion (St. Paul, Minn.: West Publishing Co., 1975); Herman Goldstein, Policing a Free Society (Cambridge, Mass.: Ballinger Publishing Co., 1977); William Ker Muir, Jr., Police: Streetcorner Politicians (Chicago: University of Chicago Press, 1977); Arthur Niederhoffer, Behind the Shield: The Police in Urban Society (Garden City, N.Y.: Doubleday & Co., 1967); Jonathan Rubinstein, City Police (New York: Farrar, Straus & Giroux, 1973); Jerome H. Skolnick, Justice Without Trial: Law Enforcement in Democratic Society (New York: John Wiley & Sons, 1966); James Q. Wilson, Varieties of Police Behavior: The Management of Law and Order in Eight Communities (Cambridge: Harvard University Press, 1968).Google Scholar

20 Duane H. Swank, Herbert Jacob, & Jack Moran, Newspaper Attentiveness to Crime, in Herbert Jacob et al., Governmental Responses to Crime: Crime on Urban Agendas 78–79 ([Washington, D.C.]: Department of Justice, National Institute of Justice, 1982). This study reports a content analysis of newspaper crime reporting in nine cities for the period 1948 to 1978.Google Scholar

21 Vincent Blasi, The Checking Value in First Amendment Theory, 1977 A.R.F. Res. J. 521.Google Scholar

22 Id. at 544.Google Scholar

23 Id. at 527.Google Scholar

24 Id. at 544–67.Google Scholar

25 Id. at 528.Google Scholar

26 Id. at 538.Google Scholar

27 Id.Google Scholar

28 Id. at 539.Google Scholar

29 Id. at 540.Google Scholar

30 Id. at 541.Google Scholar

31 Alexander Meiklejohn, Political Freedom: The Constitutional Powers of the People (New York: Oxford University Press, 1965).Google Scholar

32 Id. at 24.Google Scholar

33 Blasi supra note 20, at 562.Google Scholar

34 Id. at 561 (quoting James Madison, Federalist No. 10).Google Scholar

35 Meiklejohn, supra note 31, at 18.Google Scholar

36 Id. at 17.Google Scholar

37 Tuchman, supra note 16, at 2.Google Scholar

38 Id.Google Scholar

39 Meiklejohn, supra note 17, at ch. 1.Google Scholar

40 Laurence Tribe, American Constitutional Law (St. Paul, Minn.: West Publishing Co., 1968).Google Scholar

41 . 403 U.S. 15 (1971).Google Scholar

42 Analogizing free expression through various media to a town meeting is perhaps metaphorically accurate in some instances and inaccurate in others. A citizen absorbing media discussion of public issues has little opportunity to talk back, to discuss issues actively. In a town meeting, though, the ideas offered in the “marketplace” are tested on the spot. A television viewer or newspaper reader usually passively absorbs information about national affairs and trends, perhaps discusses them with friends and family, and actively “votes” only on election day, when issues and candidates tend to be generalized and attenuated-i.e., not specifically responsive to particular political questions. However, on the local, municipal level, the town meeting metaphor for media discussion of governmental functioning may be more accurate. Citizens often interact with police officers, but they do not often meet and discuss issues with members of Congress. If a particular issue concerning police functioning becomes important in local media, viewers or readers could presumably discuss the issue directly with members of city council, police administrators, and other citizens.Google Scholar

43 . 376 U.S. 254 (1964).Google Scholar

44 Id. at 295.Google Scholar

45 To an extent, this problem can be addressed by encouraging suburban and rural areas to develop strong local broadcast and print outlets concerned with reporting mostly local news. Decentralization in licensing broadcast stations has in the past been a policy of the FCC; in addition, increasingly popular cable television, which usually produces some local programming, may portray the reality of the local scene more accurately than media from neighboring cities do. If citizens of lesser populated areas form such inaccurate perceptions of local social and political realities, local self-government arguably is harmed. New Jersey, for example, was for quite some time entirely devoid of locally owned and operated television stations. The citizens relied entirely on New York City and Philadelphia television stations for broadcasts about news and politics, but as might have been predicted, those stations carried very little coverage of New Jersey politics or news events. One incisive commentary says of this situation that “the result is that special interests can apply pressure on individual state legislators without having to worry about countervailing public pressures. A governor can't ‘go over the heads’ of the legislators or the lobbyists; there's nowhere overhead to go-at least not in New Jersey.” Frank Mankiewicz, The Political Costs of a TV Wasteland, Wash. Post, Jan. 2, 1976.Google Scholar

46 David Burnham discusses police organization, management, and corruption in How Police Corruption Is Built into the System-and a Few Ideas for What to Do About It, in Lawrence W. Sherman, ed., Police Corruption: A Sociological Perspective (Garden City, N.Y.: Anchor Books, 1974).Google Scholar

47 Reporters who develop a symbiotic relationship with their sources are eventually “captured” or co-opted. Yet this is difficult to avoid: a reporter needs good sources and also needs to learn as much as possible about the public organization under scrutiny. Sources within the organizations become the most important teachers, yet reporters run the risk of “becoming cops” (as their fellow reporters often say) because they adopt a police perspective on news. Herbert Gans, Deciding What's News 133 (New York: Pantheon Books, 1979).Google Scholar

48 Mike Brake, Establishing a Public Information Office, FBIL. Enforcement Bull., Oct. 1978, at 22.Google Scholar

49 An example of a news article that reported a change in the crime rate and then explained statistical interpretation, also advancing possible explanations for the change in rates, is Barbara Basler, Serious Crimes Nearing Record in New York, N.Y. Times, Nov. 18, 1980, at B1, col. 4. This includes quotes from Police Commissioner Robert S. McGuire and criminologists Alfred Blumstein and Marvin E. Wolfgang. Another quick and lively explanation of current crime statistics is Christopher Jencks, How We Live Now, review of A Statistical Portrait of the American People, by Andrew Hacker, N.Y. Times, Apr. 10, 1983, § 7 (Book Review), at 7.Google Scholar

50 Ian Taylor, Paul Walton, & Jock Young, The New Criminology: For a Social Theory of Deviance 11–14 (Boston: Routledge & Kegan Paul, 1973).Google Scholar

51 . Baker, Mary Holland et al., The Impact of a Crime Wave: Perceptions, Fear, and Confidence in the Police, 17 Law & Soc'y Rev. 319 (1983).Google Scholar

52 Of course, some reporting indeed does this. Our argument here is that it is scarce. We should note in passing two series we thought exemplary of “process reporting”: Benjamin L. Weiser & Athelia Knight, Street Cops, a seven-part series in the Wash. Post, July 17, 1983, at Al, col. 1; and Amy Linn, Andrew Ross, & Scott Winokur, With the Authority of Law: Police Violence in Richmond, San Francisco Examiner, a five-part series, June 19, 1983. The American Bar Association recognizes such reporting with its yearly Silver Gavel Awards, given to those newspapers and television stations that presented the best justice-related reporting for that year. WBBM-TV in Chicago, for example, delved deeply into the crime-rate question in “Killing Crime: A Police Cop-out,” revealing that the police department there regularly masked the true crime rate by labeling many cases unfounded, or classifying a crime as a lesser offense than the offense for which the defendant was prosecuted. A list of the 1983 awards is in 69 A.B.A. J. 1775 (1983).Google Scholar

53 Gans, supra note 47, at 303.Google Scholar

54 Gans points out that almost all reporting-descriptions of observable, empirical events or objects, termed “reality judgments”-implicitly contrasts the story's findings with an assessment of how the event or object ought to appear. He says: “When a story reports that a politician has been charged with corruption, it suggests, sotto vow, that corruption is bad and that politicians should be honest.” Gans, supra note 47, at 40. He used observation and content analysis to isolate and describe what national media organizations assumed represented the deepest values and underlying sociocultural consensus of their readers and viewers. (They include ethnocentrism, altruistic democracy, responsible capitalism, small-town pastoralism, individualism, moderatism, social order, and national leadership.) Applying this approach to the “self-government value” embraced here, we presume that as long as value judgments will inevitably underlie reporters' perceptions of their subjects, those values should be stated as explicitly as possible. Thus, if readers and viewers are to assess whether their public institutions are working well, descriptions of how they ought to work (from as many different shades of opinion as possible) should be presented with descriptions of how reporters find that they do work.Google Scholar

55 Max Weber, The Theory of Social and Economic Organization, trans. A. M. Henderson & Talcott Parsons (Glencoe, III.: Free Press, 1947).Google Scholar

56 David Johnston, Burglar Alarms-False Reports Drain Police Resources, L.A. Times, Aug. 9, 1982, pt. 2, at 1–3.Google Scholar

57 David Johnston discusses this point in Bureaucrats with Guns, Calif. Journalism Rev., Winter 1983, at 22.Google Scholar

58 See Eugene Bardach & Robert A. Kagan, Going by the Book: The Problem of Regulatory Unreasonableness (Philadelphia: Temple University Press, 1982).Google Scholar

59 . Schuck, Peter H., Organization Theory and the Teaching of Administrative Law, 33 J. Legal Educ. 13, 15 (1983). Schuck's article offers a nice introduction to organization theory that would be useful to the journalist as well as to the teacher of administrative law.Google Scholar

60 The concept of “organizational purpose” was explicated in 1938 by Chester I. Barnard in The Functions of the Executive (Cambridge: Harvard University Press, 1938), and expanded and developed by two more generations of organizational theorists and sociologists of organization. A more modern code word for “purpose” is “value,” though that term is now used almost as a generic definition of any normative stance taken by an organization's leadership. To see it in its original formulation, see the discussion of “institutional embodiment of purpose” as “infusing the organizations with value” in Philip Selznick, Leadership in Administration: A Sociological Interpretation (Evanston, III.: Row, Peterson & Co., 1957). See also further development of this idea in Philippe Nonet & Philip Selznick, Law and Society in Transition: Toward Responsive Law, especially 110–12 (New York: Octagon Books, 1978), and especially in Philippe Nonet, The Legitimation of Purposive Decisions, 68 Calif. L. Rev. 263 (1980).Google Scholar

61 Todd Gitlin, The Whole World Is Watching: Mass Media in the Making and Unmaking of the New Left 28 (Berkeley: University of California Press, 1980).Google Scholar

62 Gans, supra note 47, at 282.Google Scholar

63 Because these power sources regularly offer news items related to highly visible individuals involved in public events, the news media often interprets public organizational behavior in terms of the officials who are the symbolic leaders of the organizations. This belief in turn evolves into an unspoken assumption that policies of complex organizations result from individual leaders' wishes, not from a process of achieving organizational performance by group effort. “The news tends to treat group members as followers,” says Cans. Id. at 63. But a deeper analysis of public organizations would require an explanation of how policies are generated and implemented through group decision making and interaction. Consider, for example, how much air time and column space are expended in reporting about the president's acts and pronouncements, yet how little describes how his policies are generated or implemented.Google Scholar

64 Gans, supra note 47, at 282.Google Scholar

65 Id.Google Scholar

66 Id. at 283.Google Scholar

67 Though news personnel apparently assume that readers and viewers want the shock and “whodunit” that crime stories provide and that the broadcast ratings or newspaper sales will therefore be higher than blander competitors', we should perhaps be skeptical. If a crime event were reported simply and illuminated with broader explanations of how public bureaucracies respond to it, most news consumers would probably be well satisfied. At least, in the absence of empirical proof that consumers prefer only scandal and “whodunits,” we can speculate that the aversion to institutional reporting is perhaps based only on “old editors' tales”.Google Scholar

68 There are a few institutes that train working reporters to specialize in legal matters. Columbia University's Graduate School of Journalism offers a year-long program for reporters from major metropolitan dailies to hone their legal reporting skills, including criminal justice reporting. Other universities offer specialized training for reporters to learn other fields. The Bagehot Fellowships are offered to reporters who want to improve their knowledge of economics. Perhaps similar training could be offered for reporters concerned with criminal justice matters.Google Scholar