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Phillips, Kerri; Godfrey, James --- "A dangerous weapon in dangerous hands" [1999] AltLawJl 13; (1999) 24(2) Alternative Law Journal 71

‘It’s like having two cigarette butts jammed in your eyes’.[1]

Apart from entrenched corruption within the police service, arguably the most contentious issue in contemporary policing relates to police use of force. As the latest gimmick in law enforcement technologies, OC has been proclaimed as the solution for many ‘law and order problems’ such as street violence and police shootings.

While the use of OC[2] by police is a relatively recent phenomenon, other chemical irritants such as Chloroacetaphenone (otherwise known as CN or Mace) and Orthoschlorobenzalmalononitrite (CS or Tear Gas) have been used for the past 40 years.[3] Capsaicin, the active ingredient in OC, is the chemical responsible for the burning sensation in chillies, and the pain someone feels when it gets into their eyes, or into cuts. The immediate effects of OC are obvious and extremely painful, but to date, the long-term effects are largely unknown.

In a society where police relations with the ‘community’ are already strained, the use of OC is likely to exacerbate any existing problems. Some of the people most likely to bear the brunt of this new weapon are young people, Indigenous people, homeless people, intoxicated people, and people who have a mental illness.

OC has been widely used throughout the United States of America. It should be of enormous concern that it is now being issued and used in Australia without sufficient, informed debate or public consultation about its use — especially in light of its rejection by some countries and the contributing role that it has played in the deaths of many people.

History of use

While OC in a canister is new, chillies in their unrefined form, have been used as a ‘natural chemical weapon’ for centuries. The Chinese used to grind chillies, and then blow the mixture into their enemies’ eyes, while the Japanese used to throw paper bags of ground chillies. The Chinese also burned chillies in oil and then threw the resultant ‘stink pots’. ‘Native’ police officers in India also used chillies as an interrogation aid; indeed, one detective commented, that it is: ‘far pleasanter to sit comfortably in the shade rubbing red pepper into a poor devil’s eyes than to go about in the sun hunting up evidence’.[4]

OC’s use this century began in World War I, when it was dispensed as an incapacitating agent in the form of Acylated Vanillylamide. Since then, the Ministry of Defence in England at its Chemical Defence Establishment at Porton Down, has continued ‘researching analogues of capsicum’[5] in its ongoing endeavours to develop debilitating anti-personnel chemicals.

OC — its composition and effects

Capsaicin is the purified parent, single chemical entity, of the hundreds of components of Capsicum Oleoresin. It is usually obtained by grinding dried ripe chillies into a fine powder. The fruit of plants in the capsicum family normally contains between 0.1% and 1.0% Capsaicin.

Oleoresin is usually extracted by distilling the powder in a solvent and then evaporating the solvent. After evaporation or distillation, a thick, reddish-brown oily liquid is left. Capsaicin forms colourless platelets, which have an intense, burning taste. It is not particularly soluble in water, but it is in some organic solvents — such as petroleum benzene, alcohol, or ether. In order to make OC more marketable, it had to be water-soluble. So the manufacturers mixed raw OC with emulsifiers like Propylene Glycol or Polysorbate, which cause the OC to be held in suspension.[6]

There are two common methods of measuring the intensity of OC, both of which are inadequate. The first, which measures the burning sensation that a subject feels when a particular sample is placed on their tongue leads to a Scoville Heat Units (SHU) rating. This test, though, is extremely subjective, as it is based on an individual’s perception of heat, rather than on any objective, independent measurement. The other common method is to measure the percentage of OC in the product, but this ignores the differences that can exist in the composition and pungency of OC, both between manufacturers as well as amongst batches.[7]

The effects of the components of OC

My daughter said it felt like someone lit fire to her face and then poured Tabasco sauce into it.[8]

Within seconds of OC hitting a person’s face, they are usually temporarily blinded. As their airways swell and lungs constrict, the person struggles to breathe and begins to cough uncontrollably. Simultaneously, the pain from their skin and eyeballs burning causes them to double up. They start to sweat profusely and their body temperature drops by 6 degrees, as they begin to vomit. If the person is asthmatic, they are likely to suffer from reflexive bronchoconstriction and bronchospasms as well.[9]

The immediate medical risks of OC are severe enough, but the long-term damage that Capsaicin and Capsaicinoids can cause, are potentially even more disturbing. In 1993, the US Army concluded that OC could cause ‘mutagenic effects, carcinogenic effects, sensitization, cardiovascular and pulmonary toxicity, neurotoxicity, as well as possible human fatalities ... [and that] ... there is a risk in using this product on a large and varied population.’[10]

In 1994, the British Home Office commissioned a report to establish whether Capsaicin could induce unscheduled DNA synthesis (UDS). Although the Hazelton Report found that UDS did not occur in its tests on rats, it was unable to establish any direct information about the number or type of DNA lesions that the exposure to Capsaicin caused. Furthermore, it did not investigate whether the human body can repair the DNA damage caused by Capsaicin.[11]

Capsaicin has a neuropeptide effect on the nervous system, which causes a release of substance P from the C fibres,[12] that ultimately reduces a person’s sensation of pain.[13] Interestingly, the phenolic components of the Oleorisin have the opposite effect to the pure Capsaicin — increasing neuropeptide synthesis and exacerbating pain and inflammation.[14] There are also reports that high levels of Capsaicin can cause nerve damage and possibly kill pain fibres.[15]

The propellants

The propellant in OC can constitute up to 95% of the product and is often flammable, poisonous, toxic and carcinogenic. Two components commonly found in OC are Methylene Chloride which is classified as being poisonous, toxic, carcinogenic and a hazardous waste, and Isopropyl alcohol, which is highly toxic and causes corneal burns and eye damage.[16]

Research into the effects of OC

Following 30 in-custody deaths in the USA in 1994, the American National Institute of Justice (NIJ) commissioned several research projects into the use of OC. Two of the resultant reports (by the International Association of Chiefs of Police — ‘Pepper Spray and In-Custody Deaths’ and by the NIJ — ‘Oleoresin Capsicum: Pepper Spray as a Use of Force Alternative’) dismissed OC as having been a relevant factor in any of the deaths.[17]

In 1995, the American Civil Liberties Union (ACLU) investigated the deaths of 26 people against whom OC had been used by Californian Police Officers. Although the ACLU found that OC had not been identified as the cause of death in any of these cases, it revealed that scientists knew so little about OC’s residual effects that medical examiners may not even know what to look for. Astonishingly, ten of the 26 autopsy reports did not even mention OC, which suggests that either the police never told the medical examiners that OC had been used on the suspect, or that OC was not considered as having, in any way, contributed to their death. Alternatively, when they were determining the cause of death, there were no available tests for OC.[18]

Twenty-four of these 26 people were reported to be ‘high on drugs’ or suffering from a ‘serious psychiatric disorder’. Interestingly, though, the autopsy reports found quantities of lethal drugs (Methylamphetamine or Cocaine) in only one quarter of them. The two people who had histories of serious mental illness had no traces of drugs in their bodies and ‘all had died of the frightening effects of schizophrenia or because their hearts failed as they fought with police after being pepper sprayed’.[19]

The ACLU reported that there had been no studies on the long-term health risks or special risks to particular groups, such as asthmatics, heart patients, the mentally ill or pregnant women. When the British Home Office’s scientific research branch found that OC posed too great a danger to asthmatics and pregnant women, it abandoned plans to introduce it in Britain.[20]

The ACLU Report was also concerned at the serious health risks if a person is sprayed with more than one burst of OC, corresponding with manufacturers’ advice that ‘if you hit a suspect’s target area, and it doesn’t work, it’s not going to work, and improperly prolonged spraying poses a health risk to the suspect’.[21] However, the temptation to just keep spraying may well prove irresistible.

OC — its use and abuse

The most widespread, documented use of OC has been in the USA, where between June 1994 and May 1995, Californian police, sheriffs and correction departments’ officers used pepper spray nearly 9000 times.[22] The growth in the use of OC has taken place, in spite of the revelation that the head of the Less than Lethal Weapons Programme at the FBI (Agent Thomas Ward) was paid $57,000 by an OC manufacturer (Capstun) to ensure approval of OC’s use by police throughout the US. Despite this lack of independent, objective assessment of the use of OC, the FBI’s findings are yet to be subjected to independent scrutiny.

Whereas OC is marketed as an alternative to the lethal use of force, the US experience of the last decade is littered with examples of its use as a tool to gain compliance and as a method of punishment. Indicative of this are the OC attacks on:

Perhaps the most well-publicised ‘uses’ of OC concerned several separate incidents, over a five-week period, in Eureka, California, in which sheriffs used OC against non-violent demonstrators.[24] The protesters were peacefully opposing attempts to clear a forest in their region, and in doing so, locked themselves together inside steel pipes and refused to move. On each occasion, the police applied OC from a cup with q-tips to their eyes. An application was made to stop the Humboldt County police from applying the OC directly to the faces of passive protesters. However, Judge Walker of the Federal Court, refused to grant an injunction, declaring that ‘to restrict the officers to negotiation in these circumstances would impair their ability to enforce the law and thus be a significant hardship’.[25]

The television footage of the demonstration outside the Eureka office of Rep. Frank Riggs showing four women writhing in pain and screaming caused so much outrage, that the Federal Government announced an inquiry to determine whether any federal, criminal civil rights violations occurred.[26]

All of these examples illustrate that OC, rather than being an alternative to lethal force, may well be used as a method of summary punishment. If OC is supposed to prevent fatalities, then why do people continue to die after being attacked with OC? Since the 1995 ACLU Report, there have been many more unresolved cases. In one instance, private security guards were ‘escorting’ Luis McIntyre out of a party in Boulder, Colorado, when off-duty police assisted and sprayed him. McIntyre stopped breathing and was pronounced dead at Boulder Hospital.[27] In another case, in Marietta, Georgia, police sprayed 32-year-old Edward Wolfertz three times after they had been called at 1.30 a.m. to a pancake house following a report of a suspicious person. Wolfertz was supposedly wanted for probation violations. The next morning, Edward Wolfertz was dead in police custody.[28]

In 1996, the continuing deaths prompted the San Francisco District Attorney’s office to order its investigators not to use pepper spray, stating ‘there’s got to be a better way out there ... there are too many problems with pepper spray’.[29]

OC has not yet been routinely issued to police throughout Australia. However, there are already some disturbing reports of its use. By the end of 1996 it had been issued to 1200 sergeants in Victoria.[30]

Although some police guidelines in Australia prohibit abuses like those referred to earlier, scenes reminiscent of those in Humboldt County took place in Brisbane Magistrates Court on 24 November 1997. After a fight broke out in Court, when one of 11 prisoners refused to change seats, one of the prisoners was dragged into an adjoining room where waiting Safety Response Team officers sprayed pepper spray into his eyes.[31]

In another incident, on 16 January 1997, Sheryl Black was sprayed with OC while inside her cell, at Knox Police Station. Police said it was a necessary measure, in order to prevent harm to her and others. Sheryl Black had been ‘armed’ with a plastic knife. Sheryl was an intellectually disabled, epileptic, asthmatic woman who had been in and out of institutions for most of her life. Two months after being sprayed with OC she was found dead in her cell. At the time she was sprayed, Sheryl had been in a cell by herself threatening nobody. Her alleged ‘threatening and violent behaviour’ included making threats to officers and against herself, and pressing the duress alarm.[32]

Last year, Australian viewers were confronted by the harrowing description of Belinda Morris’ experience of being ‘sprayed’ when she refused to get out of a police van at the Melbourne Custody Centre. Contrary to Commissioner’s Instruction Number 5, the police used OC on her in the confined space of the van, in a situation that did not involve ‘violent or serious confrontation’. Ms Morris suffered the prolonged affects of asthma for a week and a half following the incident.

It is obvious from the above examples that police discretion to use OC is very wide; for although there are ‘Instructions’ governing its use, senior police have referred to them as merely ‘advice’ and that officers should look at each situation in its totality.[33] For instance, requirements that a verbal warning be given can be dispensed with if the gravity of the situation makes it impracticable. Another restriction on its use is that ‘OC must not be carried by members rostered for duty at crowd control situations’. However, this clearly would not prevent special response teams, or back-up police arriving on the scene from using OC.

Introduction of OC to Australia

In 1996 Victoria became the first State in Australia to introduce OC. The decision to introduce OC into the armory of Victoria Police was justified as a response to growing public concern over the high number of people being shot by the police. More States have since followed suit. On 1 April 1998, the Minister for NSW Police stated in a media release that training for NSW Police in the use of OC had begun, and more than 500 canisters had been issued to the ‘frontline of the 11 police regions’. Sections of the Queensland Police Service have now been issued with OC. Police in South Australia have undertaken trials of OC, and in Tasmania, officers are being trained in its use. The Northern Territory has also announced its intention to introduce OC. Police in Western Australia, however, did not want to be issued with OC, with Assistant Commissioner, Bob Kacera, stating that: ‘We would need to be firmly convinced that it was thoroughly effective. We are not yet convinced that it is. And we are not convinced as an organisation that it needs to be put into our hierarchy of weapons.’[34]

Between 1988 and 1995 Victorian Police were involved in 24 fatal shootings. In 1994 alone, nine people — six of whom had a history of mental illness — were shot dead by police.[35] Although police argued for OC’s introduction in response to two fatal shootings that occurred just 36 hours apart in early 1994, police in that State had, in fact, been discussing its use for at least the previous 12 months as part of the recommendations carried out by Project Beacon. The Police had been investigating the use of OC overseas, as well as conducting tests on police recruits at the Training Academy.[36]

Task Force Victor was established by the Victorian Minister for Police and Emergency Services, Pat McNamara, in 1994 to investigate the high number of fatal shootings by police. Project Beacon was then established at the end of the same year in order to implement some of the recommendations contained in the Task Force Report, including the introduction of OC as part of its ‘safety first’ program.

In September 1995, Chief Commissioner of Victoria Police, Neil Comrie, announced that there would be a six-month trial of OC, before its approval as standard police equipment. The trial commenced in April 1996. In July 1997, the Police announced that OC would be issued to 2000 police supervisors and that all operational police would be trained in its use and issued with it by the end of 1998.

Will OC reduce the number of fatal shootings by police?

Capsicum spray will give NSW police what they need to defuse dangerous situations and save lives — theirs and others.[37]

While manufacturers disagree over the situations in which OC should be used, police have continually sold the concept of OC to the public as a way to reduce fatal police shootings. In Victoria, Chief Commissioner Comrie, defended the decision to introduce OC, describing it as ‘an alternative to firearms. If, in the exercise, we save one life through the use of this spray, then I think it is a worthwhile exercise.’[38] However, the question remains whether or not OC can and will actually be used in situations where police would normally resort to the use of a firearm. Indeed, from the evidence given by Victorian police at coronial inquiries, it is clear that police are instructed to use their firearm whenever they are confronted by someone wielding a firearm or an edged weapon.[39]

An analysis of 34 fatal shootings by police in Australia between 1994 and 1998, reveals that in every case, the person killed was either wielding an edged weapon or a firearm, or the police had mistakenly believed that they were armed.

These Australian findings correspond with similar studies in the United States. For example, in a nine-month study conducted in one US Police Department between 1996 and 1997, it was found that very few incidents where OC was used involved suspects brandishing a firearm or knife.[40]

Police are trained to deploy a firearm or OC canister with both hands. The way in which police are trained to use their weapons though, requires them to only pull one weapon in these situations, as ‘under high stress, the brain’s message intended for one hand can go to both hands and result in an unintentionally discharged firearm, perhaps wounding or killing the subject or another officer’.[41]

Indeed, police themselves argue that OC cannot be used instead of a firearm:

Normally [OC] is not intended to be used for defence against an attack with a knife or bludgeon, which are deadly weapons. OC is not intended to be used to stop a person; it is meant to control and, in essence, slow down a person. Ask yourself: If someone is trying to stab me, do I want them to stop or do I want them to slow down? The answer is clear.[42]

When asked about the measures the NSW Police Service has been taking, and intends to take, to avoid its officers killing citizens in situations similar to those surrounding the death of Roni Levi, at Bondi Beach, NSW Police Chief Commissioner Ryan answered: ‘We are actually reviewing all of the procedures in relation to police use of firearms. I know it’s not going to be particularly popular, but we are introducing a different form of baton for officers to carry and also a spray, which can hopefully be used before — in preference to a firearm’.[43] Ryan’s statement is extremely naïve. When Barry Brooks, from the Los Angeles Police Force was questioned about situations, like that at Bondi, he remarked: ‘You could spray them from a distance of about ten feet but, you know, with a knife, I mean you’d be looking at that’d be four, so I’m not sure if you’d want to’.[44] It is clearly problematic that the effective range for OC is approximately 3–4 metres and yet there is a 6 metre safety zone for knives.

When discussing the fatal shooting of Roni Levi, Leonie Manns, executive officer of the Mental Health Co-ordinating Council, stated: ‘It’s a very big issue that police aren’t adequately trained to deal with people with mental illness. An experienced person would have known to keep the person talking.’[45] Even an inexperienced person should have attempted alternative methods (like a handful of sand). In another indictment of the actions of the police, the NSW Coroner’s Report into Roni Levi’s death, also pointed to the need for more police training when dealing with people with a mental illness.

However, even the success of a negotiator cannot guarantee police restraint from using OC. In another incident, in Queensland,[46] police sprayed a man with OC, after a negotiator had persuaded him to throw down his knife. At the time he was sprayed, the man posed no threat to police or bystanders.

There are already examples within Australia where OC has failed to prevent a fatal shooting. In July 1997, Craig Colman of Bayswater in Victoria, was shot in the chest after police claimed that OC had failed to stop him advancing with a knife — the man allegedly having used a shirt to shield his eyes from OC. The police had been called by the man’s partner to intervene in a property dispute. The constable who shot Mr Colman was reported to have been in ‘fear of her life’. After the incident, the Opposition police spokesperson, Andre Haermeyer, criticised the Victorian Government for relying too heavily on the use of OC to prevent fatal shootings. He also highlighted the fact that the Government had failed to implement most of the 90 recommendations made by Task Force Victor, including the recommendation that crisis support units be expanded.[47]

In April last year, Victorian police shot dead a man who had been wielding a hammer and attempting to break into an automatic teller machine. This was the second man shot dead within a week. The previous incident had involved a 24-year-old father of three, Wade Smith of Bendigo, who allegedly threatened two police officers with a rifle. The rifle was found not to be loaded.[48] Police never stated their reasons for failing to use OC in either of these situations.

Conclusion

It is clear that OC will not solve the problem of fatal police shootings. It is an additional weapon for police, and not an alternative to existing lethal weapons. Furthermore, encouraging police to use OC may actually increase the likelihood that they will resort to using their firearms as they will be less inclined to resolve problems using containment and negotiation skills. If the OC fails to deter, then police, particularly at close quarters may well resort to their guns.

OC is a potentially dangerous cocktail of toxic chemicals and the evidence from where it has been used, indicates that it is not merely its abuse that is the problem; rather, it is its very use. The harmful short-term and long-term effects of OC, together with its likely target groups, lead us to conclude that OC is an additional tool of both compliance and punishment. Its burgeoning expansion into the armouries of police forces as well as private security firms in Australia must be challenged.

References


[1] Herald Sun, 28 May 1996, p.1.
[2] The authors have used the term OC instead of the more commonly used terms ‘capsicum spray’, ‘capsicum gas’ or ‘pepper spray’ as they believe that such terms have connotations that the chemical is somehow natural and safe. It is their aim in this paper to show that this is not the case.
[3] The authors have used the term OC instead of the more commonly used terms ‘capsicum spray’, ‘capsicum gas’ or ‘pepper spray’ as they believe that such terms have connotations that the chemical is somehow natural and safe. It is their aim in this paper to show that this is not the case.
[4] Garchik, L. ‘A Justice Weighs in on Pepper Spray’, San Francisco Chronicle, 3 November 1997, referring to a 1943 Supreme Court decision in which Justice Felix Frankfurter quoted from James Fitzjames Stephen’s history of English criminal law.
[5] Statewatch, vol. 6, no. 2, March-April 1996, p.3.
[6] For further information see Doubet, M., The Medical Implications of OC Sprays, PPCT Research Publications, 1997, pp.7-8.
[7] DuBay, D., in Doubet, M., above.
[8] Gunnhild Vardal, describing her daughter Ebony’s reaction when Royal Canadian Mounted Police used OC to attack a group of about 400 young people who were inside the Canadian Mental Health Association Hall in Kamloops on 6 April 1996. Kamloops — The Daily News, 8 April 1996.
[9] Stopford, W., ‘Statement Concerning the Pathophysiology of Capsaicin and Risks Associated with Oleoresin Capsicum Exposure’, Division of Occupational and Environmental Medicine, Duke University Medical Centre, Durham, NC, 22 March 1996.
[10] Aberdeen Proving Ground Study (1993), cited in Statewatch, above, ref. 5, p.3.
[11] Dean, S., ‘Final Report — Capsaicin: Measurement of Unscheduled DNA Synthesis in Rat Liver Using an In Vivo/In Vitro Procedure’, Hazleton, December 1994, p.10.
[12] Substance P is a neurotransmitter of pain. It transmits painful impulses from the periphery to the central nervous system and is found primarily in type C fibres. When purified Capsaicin is administered, it stops the sensory neurons from producing substance P, which diminishes their ability to send pain signals to the brain. Dean, S., above, p.7.
[13] Hence its use to relieve pain for some sufferers of rheumatoid arthritis or osteoarthritis. Dean, S., above, p.5.
[14] Doubet, M., above, p.7.
[15] DuBay, D., in Doubet, M., above, p.8.
[16] DuBay, D., in Doubet, M., above, p.8.
[17] American Civil Liberties Union of Southern California (ACLU), Pepper Spray Update: More Fatalities, More Questions, June 1995, p.17.
[18] For further information see ACLU above.
[19] ACLU, above, p.28.
[20] Guardian, 16 May 1995, quoted in: Campaign Against Repressive Police Equipment and Training (CARPET), ‘Capsicum Spray: Lethal Intervention’, Press release of CARPET, 11 September, 1995.
[21] ‘Pepper Spray Victim had History of Drugs’ in: San Francisco Chronicle @ http://sfgate.com/cgi-bin/article.cgi?file+chronicle/ archive/1997/10/22MN15444.DTL
[22] ACLU Report, above, p.28.
[23] Pan, P. and Castaneda, R., ‘Use of Pepper Spray on Webber Criticized’, Washington Post, 22 January, 1998, p.D1.
[24] Statement from North Coast First, see North Coast Earth First web site at www.macronet.org/macronet/headwaters/special.html.
[25] La Ganga, M., ‘Judge refuses to block use of pepper spray at sit-ins’, Los Angeles Times , 15 November 1997.
[26] Announced by Justice Department spokesman, Myron Marlin, reported in ‘FBI Investigating use of Pepper Spray’, Los Angeles Times, 1 November 1997.
[27] Stahl, A., ‘Man Dies After Hit With Pepper Spray’, Denver Post, 6 August 1997.
[28] Payne, D. ‘Man Sprayed by Pepper Gas Dies’, The Atlanta Journal and Constitution, 29 July 1997, p.C05.
[29] Chief Investigator Dan Addario, cited on ACLU’s web page ‘District Attorney’s Investigators Ordered Not to Use Pepper Spray’, 3 May 1996.
[30] Rouw, J. and Cookes, T., ‘Police back spray despite shooting’, Age, 19 July 1997, p.A2.
[31] Courier Mail, 25 November 1997.
[32] ABC Radio National Breakfast Program with Peter Tompson, interview with Assistant Commissioner Ray Shuey, 4 April, 1997.
[33] Assistant Commissioner Ray Shuey, above, and Sunday program, 5 April 1998.
[34] Ransley, P., ‘Chemical Weapons on Australian Streets’, Sunday program, 5 April 1998.
[35] Miller, M., ‘Aerosol Armoury’, Police Life, November 1995, p.10.
[36] Schetzer, L., ‘Victorian Police Plan to use Chemical Weapons’, (1994) 6(1) Current Issues in Criminal Justice 153.
[37] Media Release, Police Capsicum Spray Training Underway, Minister, 1 April 1998.
[38] Age, 2 September 1995, p.3.
[39] Capsicum Spray Monitoring Committee, ‘Capsicum Spray Briefing Paper’, November 1997.
[40] National Institute of Justice, 1997, quoted in McCulloch, J., chapter of PhD thesis, 1999.
[41] National Institute of Justice, 1994, quoted in McCulloch, J, ref. 40, above.
[42] ‘The Attacker Brought a Knife to a Gun Fight!’, Police 1995 p.38, in Ref. 39, above.
[43] Commissioner P. Ryan answering a question put by J. Godfrey, 13 May 1998 at a meeting of Library Society, at State Library, Sydney.
[44] ABC 2BL Richard Glover 5.25 p.m., 11 March 1998. Discussion with Police Officer from Los Angeles on the use of Capsicum Sprays. Interview with Barry Brooks, Los Angeles Police Force.
[45] Evans, M., Lamont, L. and Bernoth, A., ‘Police Under Fire Over Beach Killing’, Sydney Morning Herald, 30 June 1997.
[46] Ransley, above.
[47] Rouw, J. and Cookes, T., above.
[48] Donovan, P., Shiel, F. and Conroy, P., ‘Victorian Police Shoot Dead Two Men in a Week’, Sydney Morning Herald, 11 April 1998.


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