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46 Stan. L. Rev. 1717 (1993-1994)
Psychological Health Tests for Violence-Prone Police Officers: Objectives, Shortcomings, and Alternatives

handle is hein.journals/stflr46 and id is 1731 raw text is: Psychological Health Tests for Violence-
Prone Police Officers: Objectives,
Shortcomings, and Alternatives
Michelle A. Travis*
The beating of Rodney King in Los Angeles focused public attention on the
issue of police brutality and sparked a debate about how police departments
might avoid similar incidents in the future. In this note, Michelle A. Travis
examines one response: psychological tests that purport to identify and screen
out potentially violent individuals before they are hired as police officers. Sur-
veying the tests most frequently used by police departments, Ms. Travis con-
cludes not only that the tests are unreliable, but also that their use in
employment decisions may violate the Americans with Disabilities Act by
targeting a mental disability. She concludes by suggesting alternatives to psy-
chological testing that avoid the scientific and legal pitfalls of behavior predic-
tion and focus on addressing the job-related stress and other situational
factors that may trigger police violence.
In June 1989, a Memphis county sheriff repeatedly kicked twenty-eight-
year-old Michael Gates, then violently choked him to death.' The sheriff sus-
pected Gates of a drug violation. In February 1991, five New York City police
officers forced twenty-one-year-old Federico Pereira face down on the ground,
cuffed his wrists behind his back, and allegedly kicked, choked, and suffocated
him to death. The officers suspected Pereira of stealing a car.2 And in April
1991, a New Jersey police officer interrupted fourteen-year-old Uriah Hannah
while he was playing on a sidewalk near his home and allegedly choked him
until his parents intervened to stop the abuse. The officer claimed that Hannah
was obstructing traffic with his remote-controlled toy car.3
While few people have heard of Federico Pereira, Michael Gates, or Uriah
Hannah, almost no one will forget that on March 3, 1991, Los Angeles police
* J.D., Stanford Law School; B.A., Psychology, Cornell University. I would like to thank Profes-
sor Henry Greely for his helpful comments on earlier drafts of this note, my colleagues on the Stanford
Law Review for their thorough editing and insightful suggestions, and my fiane6, Richard Dickson, for
his endless patience, support, and encouragemenL
1. This conclusion is drawn from Richard Lacayo, Law and Disorder, TLMF, Apr. 1, 1991, at 18,
19, which reported that Michael Gates' body was covered with shoe-shaped bruises.
2. Id.
3. Id. at 19-20.


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