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This research paper considers some of the conceptual and methodological issues researchers might face when conducting cross-national performance comparisons of policing systems. In doing so, it asks whether any similarities can be identified across jurisdictions that would allow national police forces to be compared. Many jurisdictions now have some mechanism in place by which to assess police performance at the national level. Clearly, debates around performance, effectiveness, and accountability are important when modern police organizations command multimillion dollar budgets, but they are also important in terms of public legitimacy: how the police perform within the context of their mandate and the degree to which they inspire public trust and confidence. This research paper suggests that considered in cross-national terms, there is considerable variation in the mechanisms used to assess and measure police performance. However, the trend towards internationalization and diversification in public policing has made the desire for cross-national analysis of policing systems more pressing. In the European Union (EU), for example, there have been attempts to both harmonize the Home Affairs policies of its 27 member states and standardize policing policies (particularly around drugs and antiterrorism). However, as we outline in the discussion, these efforts remain limited and are hindered by the differences among member states regarding how police organizations are structured, individual national political priorities, different legal systems, languages and political cultures, rivalries between national police organizations, and not to mention difficulties in compiling agreed performance criteria and targets that have a cross-national relevance. Quantitative cross-national crime data do exist, however, from which comparisons can be made, but such undertakings are also hampered by a multitude of problems, with reliability and validity issues particularly in abundance. These difficulties are also compounded by a relative lack of clarity about what exactly needs to be compared. The paper concludes by suggesting that while some correlations and similarities can be deduced, the existence of local cultural, political, and legal differences ensures that the act of comparison remains a difficult proposition.
Assessing The Key Data Sources
When considering cross-national analysis, the main question that arises is to whether any similarities and differences can be made measurable to any relevant extent. It is the case that some significant attempts have been made at cross-cultural comparisons and are, therefore, worthy of consideration. Bayley (1990), for one, has provided a comparative analysis of policing developments across different jurisdictions. Surprisingly, given their prominent role in maintaining social order across societies, he notes that the police have often been ignored in comparative analysis (Bayley 1990, p. 4). The main problem he identifies is that despite the fact that all policing systems have similar basic concepts, definitional elements, and organizational similarities, the actual practice of policing varies widely across jurisdictions, therefore, making any effort at cross-national comparison a difficult one (see Bayley 1990, Chapter 1). Nevertheless, there have been some attempts at measuring police performance internationally. For example, Dennis and Erdos (2005) in Cultures and Crimes: Policing in Four Nations compare policing methods in the UK, France, Germany, and the USA. They point out that what these nations have in common is that they have witnessed steep rises in crime and disorder from the late 1960s onwards. In order to make comparisons, they concentrate on measuring trends in easily comparable offense categories, such as robbery and burglary, for example. The authors come to the general conclusion that there is a clear link with between maintaining increases in police numbers and reducing crime. To this effect, they argue that continued rising crime rates in the UK can, in some part, be attributed to the lack of visibility of police “on the beat,” which has made crime, in their terms, a low-risk activity. Furthermore, they argue that in France, Germany, and the USA, there has been a more “effective” attempt to deal with crime through a larger and sustained resourcing of the criminal justice system. However, like other analyses that make use of crime statistics to measure police (and policy makers) activity, it raises all sorts of problematic questions around the reliance on “officially recorded” crime data. The differential patterns of development in community and public/private policing practices and the diversity in legal systems have produced divergent and inconsistent ways of recording offenses and what offenses are actually deemed recordable in the first place.
Other studies have mapped the police use of force in a variety of international contexts (e.g., see Stenning 2003). Researchers assessed both the extent to which force, including deadly force, was used and the normative justifications for it. Again there are considerable variations in the use of force by police in the jurisdictions chosen for the study with established democracies much more likely to have a tighter regulatory framework in place, and within the EU, a statutory requirement to abide by supranational legal directives such as the European Convention on Human Rights. The researchers noted that given the variations in levels of political and economic development and the pressures facing the police in the jurisdictions studied, it was difficult to draw any definitive cross-national comparison about the circumstances under which force would be deployed and its character.
The International Centre for the Prevention of Crime (Lelandais 2007) has recently engaged in an attempt to compare police performance in eight jurisdictions: the USA (New York City & Chicago), the UK, Canada (province of Quebec), Chile, Belgium, France, Australia, and New Zealand. What the research demonstrates is that the instruments used to assess police performance vary wildly within and between jurisdictions: Some national governments use the same managerialist performance indicators that are applied across the public sector as a whole (e.g., the UK); some assess performance via existing financial or public administration legislation (e.g., Quebec, France), while others adapt varieties of Computer Statistics packages (or COMPSTAT) (e.g., the USA – New York, New Zealand, Australia). Chile and Belgium adopt aspirational guidelines and action plans, while within the USA there are significant differences with the city of Chicago, for example, preferring the Alternative Policing Strategy (APS) to COMPSTAT. Even the nomenclature of what is being assessed varies from “police excellence” in Belgium, “high performance” in New Zealand, “best value” in the UK, and “quality of service” in Chile (Lelandais 2007). In some jurisdictions “performance” is taken to mean effectiveness in dealing with crime; in others it relates to public satisfaction and confidence in the police (which may have nothing to do with crime) or to fiscal and budgetary probity and managerial dexterity. Even if it was accepted, based on this analysis, that it just might be possible to construct cross-national performance indicators, there remain significant problems insofar as it equates policing with the police. This position, which is discussed below, is becoming untenable given the increasing blurring of the boundary between highly variant modes of public and private policing provision.
There are therefore huge difficulties in conducting cross-national research into policing organizations which hinge on the differences that exist between police organizations nationally and also differences in the way that the police are organized within the same jurisdiction. While nations in the west and north may subscribe to a notion of democratic policing, this takes on a rather different form in those countries that have a British common-law heritage (the USA, the UK – excluding Scotland, Australia, Canada, Republic of Ireland, New Zealand) compared to a Napoleonic or Roman civil law tradition (Scotland, all of continental Europe and Latin America, the province of Quebec, and so on). Most notably, in the UK, for example, public policing is based on the doctrine of “public consent,” while the “office of constable” which is rooted in common law ascribes all police officers irrespective of rank, a set of original, delegated powers which exist independently of their statutory authority or position on the bureaucratic hierarchy. Furthermore, even within the regions of the United Kingdom (Northern Ireland, Wales, Scotland, and England), there are considerable differences in how the police are organized. Scotland, for example, has a Roman law heritage, which impacts on the substantive nature of police powers and judicial procedure compared to England, Wales, and Northern Ireland, which share a common-law legal tradition. In these jurisdictions, until relatively recently (1985 in England and Wales and 2000 in Northern Ireland), the police retained prosecutorial powers that were largely absent in the system of Procurator Fiscal in Scotland and even more so in the Napoleonic/Roman law tradition of independent institution between accuser and accused. However, other common-law jurisdictions (e.g., the USA and Canada), recognizing the anomaly in the British system, typically have had district attorneys (or their equivalent) to direct investigations for a considerably longer period of time. In addition, it is difficult to compare the style and organization of policing within the UK historically. Until the recent reforms associated with the peace process, Northern Ireland had a highly militarized form of public policing undertaken by the Royal Ulster Constabulary (RUC) that owed more to the colonial form adopted across the British Empire in the nineteenth century and the continental gendarmerie than to the archetypal “British Bobby.”
The United States has a traditionally decentralized model of police organization with an amalgam of town, city, municipal, state, and federal forces. This system of tiering is also found in some European nations (Spain, Czech Republic, France, Italy, Germany, etc.) but not in others, for example, Norway, Sweden, the Republic of Ireland, and New Zealand who all maintain a single national police, albeit one that is demarcated into functional specialisms. Unlike many European police forces, the UK does not have a national police that is directly answerable to a central government department. Rather law enforcement is organized territorially in each legal system (England & Wales, Scotland, and Northern Ireland) with the police under the guidance of the relevant devolved administrations (Scotland and Northern Ireland) or the Home Office (England and Wales) but are operationally independent (in theory) from political direction.
In those European countries governed by a Napoleonic/Roman civil law tradition, the lines governing the responsibilities of the police and military authorities are also rather blurred with many countries (Austria, France, Portugal, Italy, Belgium, Switzerland, etc.) maintaining a gendarmerie that is administratively under the control of the civil authorities in some cases, but under military control in others. For example, gendarmes (individual officers) can be dispatched overseas as part of humanitarian and peacekeeping missions alongside the regular army, but in the majority of circumstances, they are used for regular policing duties. In some cases, the roles and responsibilities of the gendarmerie in relation to the civil police are unclear, and in Italy, for instance, you can report a crime either to the Carabinieri (gendarmerie), the Polizia di Stato (national civil police), or the Vigili urbani (municipal or local police). It is not unusual to find both the Polizia di Stato and the Vigili urbani turning up to the scene of a road traffic accident, and determining what organization will deal with the situation is often just a case of negotiation or more likely “who got there first.” Furthermore, Italy also maintains a corps of the regular army that is dedicated exclusively to “police” duties – the Guardia di Finanza – that deals with financial crime as well as illegal immigration and border controls. Somewhat unusually, Guardia di Finanza officers have the right to demand and check customer receipts for purchases made in shops and restaurants. To complicate matters further, some European countries, such as Belgium, have disposed of their gendarmerie and moved towards decentralized and regionally autonomous police services, while others such as the Netherlands and Scotland (as a semiautonomous region of the UK) are seeking to nationalize and centralize their police operations.
There are also considerable variations in the degree of functional specialization found among national police organizations. In the UK, all police officers can find themselves performing crowd and riot control duties, but in France, this is the almost exclusive responsibility of a reserve unit of the Police Nationale – the Compagnies Re´publicaines de Se´curite´ (CRS). Again, however, the situation is muddied by the existence of a specialized unit of the gendarmerie (the gendarmerie mobile) that performs similar duties.
Even within Europe then, assessing cross-national police performance begs the following question: performance of what and of whom? There are simply too many organizations performing policing type functions and where the lines of authority and responsibility are unclear to make any kind of clear comparison. Fundamental differences are also evident when we start to go beyond the core European Union nations. Post-communist policing systems within those countries that comprised the former Warsaw Pact have moved (or are moving) to less authoritarian and repressive dispensations, but even here there is considerable variations, with those states that have negotiated access to the EU being further along the developmental trajectory than those that have not. Compare the situation in the Czech Republic with that of Belarus, for example. Similarly, in Asia there is considerable differentiation in the organization and structure of the police, not to mention adherence to democratic norms and human rights standards. In South Korea and Japan policing is generally “rights based” and in accordance with democratic norms, but in other states, India, Sri Lanka, Pakistan, and Bangladesh, the situation is described by the Commonwealth Human Rights Initiative (2007) as “grim,” with key concerns in and around human rights, accountability, and governance abound. Policing in Hong Kong represents a rather curious hybrid case, having structural similarities with both the British “colonial” and “metropolitan” models given the legacy of its history, but which also appears to be influenced by policing developments in mainland China (Lau 2004). Importantly, however, we know next to nothing about the structure and organization of policing in the People’s Republic of China, which has received almost no attention in the comparative research literature (though see Tanner 2005). In the Middle East, policing structures reflect particular religious, cultural, and political sensibilities that make comparative analysis difficult, if not futile. In Islamic theocracies such as Iran and Saudi Arabia (and Afghanistan historically, though increasingly so again), the Mutawwa’in (religious police, though the religious police are referred to as Basij-e Mostaz’afin in Iran.) rigorously enforce Sharia law which applies to everyone irrespective of whether they are Muslim or not. Since there is no formal separation of church and state in Iran and Saudi Arabia, the Mutawwa’in have powers, duties, and responsibilities that rival, if not exceed, those of the regular police, not to mention a degree of influence that has simply no equivalent in Western democracies.
The argument being made here is that due to the huge variation in the organization of policing between and within nations, any kind of cross-national comparison is difficult if not nigh on impossible. This is further complicated by the variability of their core mandate (citizen safety, public order, or religious/cultural concerns) and huge disparities in adherence to democratic norms and international human rights standards. Academic research is further hampered by the rivalries between national police organizations or between the police and the gendarmerie that makes such comparative assessments difficult. One of us (Ellison) has had personal involvement with a reform endeavor involving the Turkish police which was seriously (though not fatally) hampered by the unwillingness of the Jandarma (gendarmerie) to participate in the study because of a legacy of hostility and mistrust of the Turkish National Police (TNP). This might not have mattered but for the fact that the Jandarma (gendarmerie) are the de facto police in much of eastern Turkey and perform all the tasks and functions that the TNP perform in the rest of the country. Therefore, the research was only able to glimpse a partial picture of the organization of public policing in Turkey and as such was limited in terms of the overall conclusions and recommendations that could be made.
Questions also arise in relation to the context of modern “policing” and what it should be taken to mean in the twenty-first century. Against a background of advancing economic liberalism, the European Union (EU), North American, and Australasian nations have shifted to forms of partnership policing, which has overseen a flattening out of policing across civil society to harness more private enterprise in its provision and delivery. Who or what “the police” can be taken to mean under these circumstances is becoming increasingly muddled. In the UK, for example, many police forces employ Police Community Support Officers (PCSOs) who are uniformed personnel, but not sworn officers, and who have a range of limited powers in relation to antisocial behavior, traffic, and so on. PCSOs have been described by the previous Commissioner of the London Metropolitan Police, Sir Ian Blair, as part of what he termed “the extended police family,” but have been criticized by the police employees association, the Police Federation, for attempting to police on the cheap. The public meanwhile are unsure of what the role of PCSOs is supposed to be, since their legal powers are rather limited and their status somewhat vague. Indeed, in England and Wales the distinction between public and private is likely to be further distorted by the current government’s reform agenda via the Police Reform and Social Responsibility Bill, which will likely result in a fundamental restructuring of the British police. Proposals are currently underway to outsource a number of key services to the private sector such as forensics, emergency call logging, crime information systems, as well as the widespread establishment of strategic partnerships with private firms being encouraged to engage in crime reduction initiatives. Already, in many UK towns and cities, parking and minor traffic enforcement duties are performed almost exclusively by private companies who are contracted by local authorities.
However, such public-private hybrid activities are not just confined to crime prevention and reduction. There is considerable evidence that national security policing (or high policing) is increasingly contracted to the corporate sector, and in the context of global insecurity, we are seeing something of a state-corporate symbiosis emerging whereby public and private actors engage in “a mutually beneficial application of game theory to achieve proximate objectives” (O’Reilly and Ellison 2006, p. 14). Increased privatization, marketization, commodification, and hybridization have all problematized the very nature of policing and its delivery across a myriad of domains. One cannot, for example, analyze the counterterrorism “performance” of the US police separately from the huge corporate infrastructure (security consultancies, security contractors, risk advisors, and so forth) that has grown up around homeland security. To put the point more simply, it is becoming much harder to track and measure who does what, when, and how, making efforts at constructing crossnational baselines that are empirically verifiable, reliable, and generalizable difficult, if not again, nigh on impossible. Furthermore, in those jurisdictions that are characterized by high levels of violent crime (South Africa and Brazil are cases in point), private security arguably eclipses public policing – at least for those that can afford it. In both jurisdictions thousands of heavily armed private security firms with alluring names such as “Blue Angels” provide security services in response to a near total lack of trust and confidence in the public police. Furthermore, high levels of crime in the Brazilian favelas have spurred grassroots forms of civil policing, with hundreds of authoritarian paramilitary style, Autodefesas Comunita´rias (citizen defense committees), emerging to effectively take the law into their own hands and to deal with transgressors through a variety of extralegal punishments, such as shootings and beatings. This blurring of the boundaries between public and private policing/security further complicates any attempt at comparative analysis, unless we know in detail what these relationships are, and are able to control for the activities of public and private actors in a way that makes analytical sense.
Even focusing on specific models of policing does not lead to any productive conclusions. A general strategy of policing that we find being implemented across the globe is community orientated policing, which, therefore, might provide us with a base from which to make comparative analyses. Irrespective of whether it “works” or not, community policing allows police forces across the world to use a common language and as a philosophy offers a meeting point for “stakeholders” that becomes a forum for discussion and international collaboration via biand multilateral exchanges, reform efforts, conferences, seminars, and the movement of policing personnel within what Otwin Marenin has termed the “transnational policing policy community”(Marenin 2007). So at least in theory, it may provide a unified vision of global policing by establishing a series of international benchmarks. However, much of this remains aspirational, and as Brogden and Nijhar (2005) assert, owing to the different historical and political development of policing systems, the relationships between state institutions such as the police and the community are greatly differentiated between jurisdictions. This results in community policing becoming quite differently understood across and even within nations (2005, pp. 104–107). Brogden and Nijhar (2005, p. 110) expose such stark differences in the way community policing is deployed, particularly in regard to whether policing functions are centralized or decentralized that it is almost impossible to generalize from jurisdiction to jurisdiction. In some jurisdictions, such as Belgium, Northern Ireland, and Chicago, for example, attempts have been made to place community orientated policing strategies at the core of all police activities. But, in the most part, such strategies remain on the periphery of policing priorities, often playing second fiddle to national security priorities and the maintenance of social order. Certainly, the extent to which policing systems are autonomous from the state authority has a significant impact on the relationship between citizens and criminal justice system, skewing some police systems more towards maintaining social order and the political status quo than others.
If we assume (at a stretch) that the core mandate of many police organizations is crime reduction, then sources of international crime data might be useful when attempting to make cross-national comparisons between individual forces. These include data collated by INTERPOL, the United Nations Crime Surveys, and the European Sourcebook (see Stamatel 2006). In the INTERPOL data, police representatives of the member nations complete quantitative returns on police records in 11 offense categories: murder, sex offenses (including rape), serious assault, all kinds of theft, robbery, breaking and entering, motor offenses, fraud, counterfeiting, and drug offenses. However, as Stamatel reports (2006, p. 16), although the definitions for each offense are rounded as closely as possible within clear definitional frameworks, the data process is a voluntary one which provides little in terms of quality control measures over offense categorization. Even INTERPOL itself notes that “the figures must be interpreted with caution” (Interpol 1999).
With regard to the United Nations Crime Survey, the UN has been collecting crime data since 1970 – with “a view to improving the analysis and dissemination of that information globally” (United Nations Office on Drugs and Crime 2007). The data is based upon multilingual questionnaires given to UN crime and police coordinators in member countries (Stamatel 2006, p. 17). They record aggregate national level crime figures within four areas: police, prosecution, courts, and corrections. Again, data is based upon offenses reported to the police and is collected within 10 offense categories: homicide, rape, assault, thefts, fraud, embezzlement, drug-related crime, bribery, corruption, and kidnapping. However, not all member states report back evenly nor are the data easily fixed within the same categories. For the data that compare prosecution and courts systems, it is not at all clear how the effects of different prosecution systems are controlled for, such as whether they are adversarial or inquisitorial, nor do they control for the effects of plea bargaining where some cases do not go to trial, which is used much more extensively in the USA and the UK than in other jurisdictions. Such data must be approached with caution, and it is difficult to make any cross-national assessments of the police or indeed of criminal justice agencies more generally.
Thirdly, the European Sourcebook of Crime and Criminal Justice Statistics started collecting data in 1990. It collates data within the categories of homicide, assaults, rape, armed robbery, motor vehicle theft, burglaries, drug-related offenses, and people trafficking. Unlike the other two sources, the European Sourcebook also collates information about the number of offenders by crime type and the percentage of offenders who are female, minors, and nonnationals (Stamatel 2006, p. 18). The sourcebook also claims to offer a higher level of quality control in the data collection effort (Stamatel 2006, p. 19). This includes standard classification schemes that are implemented over the course of the data collation process and the fact that data collection are easier to undertake within the European Union since most states have a closer affinity with regard to their crime classification. However, the sourcebook suggests that even within the European Union, there are multiple dimensions to crime classification and data collection that vary considerably between Western, Central, and Eastern European nations (Krajewski 2011). To take just one example, there is considerable cross-national variation in the statutory definition, reporting, recording, and prosecution of rape within European jurisdictions (Lovett and Kelly 2009).
International Victimization Survey
By its very nature, policing is a subjective exercise, located in huge amounts of discretion and partiality in what crimes are prosecuted and recorded. Thus, police statistics provide a skewed picture of offending and are limited to illustrating, at best, broader trends in crime (Maguire 2002; Skogan 1975). Moreover, it has been extensively documented that there are validity and reliability issues with official crime statistics as a means for assessing levels of crime and police performance in any given jurisdiction (see Maguire 2002; Skogan 1975).
So, in addition to police records that are the mainstay of the three sources indentified above, the International Crime Victimization Survey (ICVS) collects data on victimization rates (see Van Dijk et al. 1990). The ICVS provides researchers with some detailed points of comparison with officially recorded data and, therefore, is worth considering further. Most industrialized democracies have a long tradition of publishing victimization surveys (e.g., see British Crime Survey or the National Crime Victimization Survey). The ICVS surveys cross-national household experiences of crime, perceptions of policing, as well as general feelings of safety and security. The ICVS was initiated in 1987 by a group of European criminologists with expertise in national crime surveys (Van Dijk et al. 1990), and initially it was operationalized in 14 industrialized countries. The survey seeks to advance international comparative criminological research beyond the constraints of officially recorded crime data to produce estimates of victimization that can be used for international comparison. Surveys have taken place in 1992, 1996, 2000, 2005, and 2008, with 140 surveys now having been deployed in over 78 different countries – sampling over 320,000 citizens. The present database covers 325,454 individual respondents. Crime categories are broken down into vehicle-related crimes (theft of a car, theft from a car, theft of a motorcycle or moped, theft of a bicycle), burglary, attempted burglary, theft of personal property, and contact crimes (robbery, sexual offenses, and assault and threat).
Arguably, the ICVS is the most comprehensive instrument yet developed to undertake an international comparative study of volume crimes, victimization, and perceptions of the police and criminal justice agencies. Significantly, the data is derived from surveys among the general public and, therefore, not influenced by political or institutional prerogatives. For the IVCS, validity and reliability is better maintained through the standardization of questionnaires, and results are presented within statistical confidence margins (see Lynch 2006). But full standardization, in all aspects of design, has still to be proven, especially for the surveys deployed in developing countries. Even if the ICVS provides data that are fit for international comparison, we have to be wary of country-specific circumstances that will not always allow for fully standardized methodology to be applied. Moreover, although the ICVS provides a measure of common crimes, the comparatively small samples sizes precludes estimations of less prevalent crimes such as rapes or aggravated assaults. The ICVS also ignores victimization by complex crimes such as largesse forms of corruption or organized crime, which victimizes collective populations rather than individuals.
Victim surveys and recorded crime statistic invariably produce two quite different pictures of the volume and distribution of crime. Yet, it is not clear whether this is because victim-based statistics are more accurate than recoded crime statistics or vice versa (Skogan 1975). Although some might argue that levels of recorded crimes cannot be reliably used for comparing levels of common crime across countries, measurement procedures in both formats illustrate characteristic errors. Nevertheless, victim surveys seem a slightly more productive source from which to undertake cross-national comparative analysis, although this should not be exaggerated and we still need to be cognizant of a whole range of conceptual and methodological issues.
Dilemmas And Problems
Difficulties With Cross-National Analysis
This research paper has so far described three main sources of data that might be used to help in the production of cross-national comparisons of policing systems. Besides some of the specific issues already observed within each method, a number of general problems with undertaking such analyses can be identified. For instance, there are no unilinear patterns of development that all nations follow, and likewise, in many developing nations the structures of public policing and criminal justice generally diverge considerably from those found in advanced liberal democracies. Critics have observed that “western” ethnocentric concepts and categories are often superimposed on less industrially developed countries and their translation varies enormously (Shichor 1990, p. 65; Nelken 2009). Cultural and geopolitical differences, therefore, make direct comparisons difficult (Nelken 2009). Still, it might be argued that cross-national analyses could be made across nations that have evolved into similar advanced democratic civic systems – such as the EU or North America – where measurable, complex, bureaucratic, and recording infrastructures such as performance indicators are deployed (see Collier 2001). For example, an inordinate number of indicators have been used to measure success and failure in crime reduction. Some indicators measure public satisfaction rates of police organizations, others crime clear up rates, while others track victimization rates. Certainly, patterns can be found on a number of key measures. Nevertheless, although liberal democracies are similar and more transparent, difficulties still arise, as performance indicators often track spurious clearance rates and measure arrests and detections rather than what has been achieved through say crime prevention measures. Performance indicators, however, usually coalesce around what have been termed “volume crimes” – due to their often uniformity in definition and large volumes in occurrence – and, therefore, are perhaps the easiest to measure. Again, differences arise in the way nation states not only record crimes but also in the administrative infrastructure available for recording to take place (see Krajewski 2011).
On another level, offense categories themselves often prove problematic, as they do not easily subscribe to exactly the same definitional boundaries. Dealing with antisocial behavior is a key issue for the UK police, frequently ranking as the number one priority concern among the public, but it proves problematic when trying to fit it into a singular definitional or legal framework. Reducing analysis to one variable that is common and uniform in most societies, such as “homicide,” for example, might provide a good indicator, not just of rates between countries but also police performance in investigative terms. Indeed, various studies have used homicide to make cross-national/ cross-cultural comparisons (e.g., see Avison and Loring 1986; Krahn et al. 1986). Still, what might look superficially similar is often framed within local, cultural, political, and legal contexts that limit our ability to make generalizations (Nelken 2009).
Even within the UK, for instance, Scotland defines homicide as including the offenses of “murder” and “culpable homicide,” whereas in England and Wales, it is defined as including “murder,” “manslaughter,” and “infanticide” (Richards 1999). Elsewhere in the European Union, causing death by dangerous driving qualifies as manslaughter in some jurisdictions, but not all. In the UK suicide was only decriminalized in 1961 and prior to that time was regarded in law as a form of self-homicide. Currently, many jurisdictions regard death as the result of assisted suicide second-degree murder or manslaughter. However, in Australia’s Northern Territory, the use of the so-called Deliverance Machine to perform an assisted suicide was legal between 1995 and 1997 with the death not recorded as homicide. Similarly, in Switzerland assisted suicide remains legal with critics claiming that current legislation contributes to “suicide tourism” from other jurisdictions. Even for those offenses deemed to be homicides, initially around 15 % are reclassified as “other” following police or court action (Richards 1999). In a major study of homicide statistics in 36 European nations (Anamort European Project 2008), the researchers found that the misclassification of homicides was a significant problem in 14 of the countries surveyed. The combined effects of such misclassification were felt to “lead to underestimation of the magnitude of the deaths due to homicides in all of these countries” (Anamort European Project 2008, p. 3). The main problem appeared to relate to the lack of accurate information provided to coders on the cause of death which had not been forwarded from the police or coroner’s office. This appeared to be less of a problem among the established democracies of northern and Western Europe owing mainly to higher standards in forensic investigation/pathology but also, as noted above, to more efficient transmission of medicolegal data to national statistical offices (Anamort European Project 2008, p. 3).
Furthermore, as Richards (1999, p. 30) points out, in a number of jurisdictions, homicide statistics are compiled from when a death was registered as a homicide rather than when the death occurred. In the UK, all cases of suspected homicide are referred to the coroner’s court. However, in complex cases it is not unusual for the determination of cause of death to be made up to several years and in some cases decades later. The Police Service of Northern Ireland’s (PSNI) Historical Enquiries Team (HET) which was established to investigate over 1,800 cold-case deaths arising from the conflict is currently reinvestigating deaths that occurred 40 years ago. So far, a number of these cases have been referred to the coroner’s court for a determination on the actual cause of death. Our point then is that even attempting to compare police investigative performance between jurisdictions for something as ostensibly straightforward as homicide that seems to be measurable across a number of jurisdictions is fraught with difficulties around definition, classification, and ultimately interpretation.
To reiterate the starting points, clearly, as policing has become a multimillion dollar and a more globally transnational exercise, the pursuit for efficiency has produced an expected desire to measure police performance on a cross-national basis. This research paper asked whether any similarities could actually be identified across different nations in order to undertake such measurements. Three data sources have been considered: (a) academic comparative research, (b) official crime data, and (c) international victimization surveys. In these contexts, the paper has directed the reader to some of the difficulties that encompass carrying out any adequate and robust cross-national comparisons of policing systems. Comparison both requires understanding and interpreting what those in other jurisdictions are trying to achieve. Whether it is comparing a particular police organization’s performance data or using crime statistics as a barometer of police performance, the cultural and administrative differences that characterize the organization of policing at the cross-national level have to be considered. Surveys such as the European Sourcebook can provide rich comparative data, which given the continued harmonization among states within the EU can lead us to perceive that international comparisons are becoming easier. However, within the EU there are inconsistent levels of technology and robust administration systems to accurately record crime which tends to give rather anomalous results in comparative terms. For example, some of the new accession states (Latvia, Lithuania, Estonia, Poland) appear on some indices to have even crime rates lower than that of Sweden, which traditionally within Western Europe has had low crime rates coupled with high levels of social welfare provision (Krajewski 2011). In addition, as noted above, some EU nations are shifting to decentralize their police (Belgium), some are tending towards enhanced centralization (the Netherlands, Scotland), and some are maintaining traditional organizational structures (Germany, France, Italy, Spain), while others are further privatizing aspects of the police role and function (England and Wales). These organizational differences are coupled with variant cultural understandings of “crime” and “justice,” variations in recording practices, the lack of comprehensive national datasets, and different legal cultures and political systems that lead us towards the conclusion that, to say the least, an objective benchmark comparative analysis is a tough proposition. Yet, despite the problems that have been identified, aggregate crime statistics may provide the most useful indicator of cross-national police performance, although these need to be qualified heavily and interpreted with some caution. Overall, however, the international vagaries of policing mean that a definitive cross-national comparative analysis remains a rather elusive goal.
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