-

OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OF THE INTERIOR 

Alleged Improper Dismissal of

Criminal Citations, U.S. Park

Police

INVESTIGATION

This is a revised version of the report prepared for public release.

Report Number: 20-0027 Date Posted on Web: June 24, 2020
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

I. EXECUTIVE SUMMARY 

We investigated allegations that a senior U.S. Park Police (USPP) official asked the United 

States Attorney’s Office to dismiss criminal citations (tickets) issued to Presidio Trust employees 

and contractors at the request of Presidio Trust officials. 

We found that a Presidio Trust official asked a senior USPP official to request the dismissal of 

several tickets stemming from two separate incidents that occurred at the Presidio and that the 

senior USPP official’s decisions to request the dismissals were, in part, influenced by these 

requests. In addition, while we found that the senior USPP official had the discretion to request 

that the tickets be dismissed and that there was no USPP General Order or U.S. Department of 

the Interior policy about the process or authority for dismissing tickets, the senior USPP official 

appeared to deviate from past USPP practices at the Presidio when requesting the dismissals. 

II. BACKGROUND 

The allegations were associated with two separate incidents involving Presidio Trust employees 

and contract employees in which a senior U.S. Park Police official requested that the United 

States Attorney’s Office (USAO) dismiss several USPP tickets. 

The Presidio Trust is the wholly owned Government corporation responsible for managing the 

Presidio of San Francisco, a national historic landmark. As part of managing the Presidio, the 

trust entered into a number of agreements with the USPP for law enforcement services. 

A. The 2017 Incident 

In summer 2017, trust employees brought their own alcohol into a Presidio recreation facility, 

which is prohibited. When the recreation facility manager asked them to leave the premises, the 

trust employees refused to leave. The recreation facility manager then called the USPP, which 

has exclusive law enforcement authority at the Presidio. 

Upon arrival, USPP officers asked the trust employees to leave the recreation facility, but 

eventually the officers had to physically remove one of the trust employees. Outside of the 

building, the same trust employee became disorderly, and USPP officers arrested the employee 

and issued the employee three tickets. Additionally, the USPP officers issued multiple tickets to 

three other trust employees who were involved in the incident. 

B. The 2019 Incident 

In early 2019, USPP officers were notified of an alarm at another Presidio recreation facility. 

Upon arriving at the scene, a USPP officer confronted three individuals outside the building 

where the alarm was triggered. The USPP officer requested identification from the three 

individuals. One of the individuals provided a Presidio recreation facility nametag but not any 

Government-issued identification. The other two individuals refused to comply, claiming that 

they did not hear the alarm and that they worked at the recreation facility. The USPP officer 

explained to them that while there was no audible alarm sounding, the alarm had indeed been 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

triggered, which the USPP officer then radioed and confirmed with the USPP dispatch. The 

USPP officer also detected the smell of alcohol when speaking with the individuals. 

The individual who provided a recreation facility nametag eventually provided a driver’s license. 

One of the other individuals became agitated and continued to refuse to identify themself. The 

USPP officer detained the individual and placed them in handcuffs in the back of the patrol car 

until the USPP officer’s supervising officer arrived. Ultimately, the USPP officer issued tickets 

to the two individuals who refused to provide Government-issued identification upon request. 

C. Past USPP Practice in Dismissing Tickets 

There is no USPP General Order or U.S. Department of the Interior policy that provides 

authority or identifies a process for dismissing tickets. 

The former chief of police told us that the USPP and the Department did not have any written 

policy for dismissing tickets. Instead, the former chief of police explained that discussions about 

dismissing a ticket would typically involve the arresting officer or the supervisor, and the 

prosecuting office. 

The Special Assistant United States Attorney (SAUSA) who primarily handles USPP criminal 

cases and tickets occurring at the Presidio told us that they typically dismissed tickets in petty 

offense cases only after considering if probable cause existed for the tickets, along with 

discussing the charges with the USPP court liaison officer, and possibly the charging officer if 

the SAUSA had questions about the “factual scenario.” The SAUSA told us it was “certainly not 

in the normal course . . . for me to talk to [senior USPP officials] about specific CVB [Central 

Violations Bureau] citations.” 

III. RESULTS OF INVESTIGATION 

A. Facts 

1. The Senior USPP Official Requested Dismissal of the 2017 Incident Tickets 

As noted above, in the summer of 2017, USPP officers issued multiple tickets to four trust 

employees in response to a disturbance at a Presidio recreation facility. 

In fall 2017, the Presidio Trust official submitted complaints against the USPP officers involved 

in the 2017 Incident to a USPP manager alleging the USPP officers used excessive force. The 

USPP subsequently initiated an internal investigation and concluded that the allegations were 

“not sustained” and that the use of force during the incident was reasonable. 

USPP investigators determined during the investigation, however, that the tickets the USPP 

issued related to the incident had not been submitted to the Central Violations Bureau (CVB) due 

to an administrative oversight. Upon this realization, the USPP then submitted the tickets to the 

CVB —nearly 6 months after the incident and less than 60 days after the Presidio Trust official 

filed the excessive force complaints. 

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On an agenda for a spring 2018 Presidio Trust internal meeting, the Presidio Trust official noted 

that they planned to ask the USPP to drop the 2017 Incident charges. The next morning, the 

Presidio Trust official sent an email to the senior USPP official with the subject line “Per our 

discussion re charges,” which listed the names and ticket numbers of the trust employees who 

were cited in the 2017 Incident. 

The Presidio Trust official confirmed calling and asking the senior USPP official to dismiss the 

2017 Incident tickets. The Presidio Trust official explained that the delayed processing of the 

tickets created an appearance of retaliation against the trust employees because they believed that 

the tickets had been dismissed and were revived only after they provided statements supporting 

their excessive force complaints against the USPP officers. 

Later that afternoon, at the senior USPP official’s direction, a USPP manager sent an email to the 

SAUSA requesting dismissal of the tickets issued to trust employees. In response, the SAUSA 

said that they would dismiss these citations at the USPP’s request. The SAUSA told us that they 

believed the untimely processing of the tickets through CVB caused “prejudice” to the case. 

The USPP officer who made the arrest and issued tickets in the 2017 Incident told us that their 

USPP superiors or the USAO never consulted the USPP officer about the incident. The senior 

USPP official told us that the USPP manager and a USPP supervisor both disagreed with the 

decision to request dismissal of the tickets, but the senior USPP official nonetheless directed the 

USPP manager to request that the USAO do so. The USPP manager confirmed this discussion. 

The senior USPP official initially said that the Presidio Trust official did not expressly ask them 

to dismiss the tickets. In a follow-up interview, the senior USPP official clarified that although 

they believed the Presidio Trust official did not ask them outright to dismiss the tickets, the 

Presidio Trust official had made it clear that they did not want the case to move forward in court. 

2. The Senior USPP Official Requested Dismissal of the 2019 Incident Tickets 

As noted above, in early 2019, a USPP officer responded to an alarm at a Presidio recreation 

facility. The USPP officer confronted three employees outside the main building, requested that 

they provide identification—which they refused to provide—and ultimately issued tickets to two 

of the individuals for failing to provide Government-issued identification upon a police officer’s 

request. 

The next morning, the Presidio Trust official forwarded an email to the senior USPP official that 

contained a summary of the incident from the perspective of a recreation facility supervisor who 

was not present during the incident. In the forwarded email to the senior USPP official, the 

Presidio Trust official wrote, “I would like to discuss this with you ASAP. I will call you.” 

During an OIG interview, the senior USPP official relayed the recreation facility supervisor’s 

interpretation of the incident, while acknowledging that the supervisor was not present during the 

incident. When asked if they spoke with the USPP manager or the primary USPP officer who 

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issued the tickets to seek their side of the story to assess the veracity of the recreation facility 

supervisor’s statements, the senior USPP official admitted that they had not done so. 

When we showed the USPP officer the recreation facility supervisor’s email summary of the 

incident, the USPP officer cited multiple inaccuracies in the supervisor’s representation. The 

USPP officer also expressed frustration that they were never asked to articulate or justify their 

reasoning for issuing the tickets. 

We also confirmed that, unlike the 2017 Incident, the tickets were timely submitted to the CVB. 

According to the senior USPP official, later in the day, after receiving the Presidio Trust 

official’s email containing the recreation facility supervisor’s representation of the 2019 Incident, 

the senior USPP official had a discussion with the USPP manager about where the USPP “fell 

short” in handling the 2019 Incident. The senior USPP official stated that because the employee 

was wearing a Presidio recreation facility shirt, the officer could assume the person worked at the 

recreation facility, thus obviating the need for the individual to produce Government-issued 

identification upon the USPP officer’s request. The senior USPP official confirmed during the 

OIG interview that the USPP manager disagreed with this reasoning. 

An NPS Visitor and Resource Protection executive stated that they did not agree with the 

argument that a Presidio recreation facility shirt could represent sufficient identification to a 

USPP officer, thus allowing the individual to refuse an officer’s request for identification. 

The senior USPP official also asserted that the USPP officer should have called a supervisor to 

the scene—rather than demand the employee’s Government-issued identification—after the 

recreation facility employee told the USPP officer that the officer should know who they were 

without identification because “you were here just last week.” When asked if the senior USPP 

official was essentially telling USPP officers to call a supervisor when a trust employee fails to 

obey a lawful order, the senior USPP official stated, “So I think discretion being the better part 

of valor in this case, yes. Absolutely.” 

In spring 2019, the two ticketed individuals attended a pretrial meeting at the Federal courthouse. 

According to the SAUSA, the individuals thought the citations had been dismissed after their 

bosses met with the USPP. The SAUSA told the two individuals that they were not aware of a 

meeting and never received a request from USPP to have the tickets dismissed. The SAUSA said 

they offered the two individuals community service hours to resolve the tickets, but the 

individuals declined to accept because, the SAUSA believed, “they wanted to go back to their 

bosses and kind of get confirmation of this meeting that happened and if there was any decision 

or request to have them dismissed.” 

On the evening of the pretrial meeting, a Presidio Trust employee sent the Presidio Trust official 

an email summarizing the meeting. The Presidio Trust official forwarded the email to the senior 

USPP official the next morning, writing, “Please read and I will call you today. This relates to 

the citing of our [recreation facility] staff where you acknowledged that your staff had not acted 

appropriately. I would have expected you all to handle this differently and am very 

disappointed.” 

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The senior USPP official immediately forwarded the Presidio Trust official’s email to another 

USPP official, who recalled discussing the 2019 Incident tickets with the senior USPP official 

and telling them “Just do your due diligence and come back to me. Let's talk about it. And 

whatever your decision . . . if I vote it to be reasonable after you've talked to command staff, 

Presidio Trust staff, and the AUSA out there, I’ll support you. Whatever you need to do.” The 

former official told us that the senior USPP official came back to them before talking to the 

AUSA and told the former official that they decided to request the tickets be dismissed. The 

former official said that they again told the senior USPP official to reach out to the AUSA to get 

their perspective before the senior USPP official made the decision to dismiss the tickets. 

Later that month the Presidio Trust official sent an email to the senior USPP official stating, 

“[J]ust wanted to make sure that you have called the US Attorney’s Office to get the charges 

dismissed against the [recreation facility] employees. Their next court date is [redacted] so I need 

to hear back from you by [redacted] so we can let them know.” 

The next day, the senior USPP official texted the SAUSA requesting a telephone conversation. 

Later that afternoon, the senior USPP official called the SAUSA and directly requested dismissal 

of the tickets. The senior USPP official then followed up the phone call with an email to the 

SAUSA confirming the request to dismiss the tickets. The SAUSA responded that they received 

the email and would dismiss the citations. 

According to the SAUSA, after reading the USPP officer’s incident report they “thought that 

there was at least enough to move forward with the case,” which was why the SAUSA offered 

the subjects community service instead of initially dismissing it. The SAUSA told us, “I certainly 

wasn’t going to dismiss” the tickets on the day of the pretrial meeting, but then got a call from 

the senior USPP official requesting the tickets be dismissed. The SAUSA explained that when 

they are told the agency “wants this to go away,” they say, “okay.” 

The senior USPP official acknowledged that the Presidio Trust official had asked to dismiss the 

2019 Incident tickets. The senior USPP official told us, however, that they had already made the 

decision to request dismissal of the tickets. 

The USPP manager told us that they asked the senior USPP official not to direct them to request 

that the SAUSA dismiss the 2019 Incident tickets—as the senior USPP official had done with 

the 2017 Incident tickets—because the USPP manager believed the tickets should be handled 

through the court system. The USPP manager said, “I told [the senior USPP official] pointblank, 

‘Do not ask me to have these tickets dismissed. I will not do it. . . . You could charge me for not 

obeying a direct order, whatever you need to do, but this is the second time this has happened. 

You need to let the courts run its course.’ And [the senior USPP official] never asked me. 

Apparently, [they] did it [themselves] this time.” 

The USPP manager further detailed their assessment of the senior USPP official’s decision to 

request dismissal of the 2019 Incident tickets, stating: 

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The tickets were submitted timely. There's no . . . administrative reason to dismiss 

these. And my biggest issue is you've now taken somebody who felt entitled to 

not give us what we needed to do our jobs, which is just presenting ID, and you're 

. . . basically reinforcing that what [they] did was okay. So you're telling [them] 

that [they] can do it again; and my biggest fear is that if it happens again, then it's 

gonna escalate. “I don't have to give you my ID ‘cause last time proved I didn't 

have to do it. I'm not gonna do it again.” And my biggest concern is it's gonna end 

up leading to a use of force that isn't necessary and nobody needs. 

3. The Senior USPP Official Believed that the USPP Is Subordinate to the Presidio Trust 

Leadership 

In the OIG interview, the senior USPP official told us that they believed that the USPP is 

subordinate to the Presidio Trust leadership in the same way USPP is subordinate to a park 

superintendent. In contrast, the former chief of police told us that the USPP are not subordinate 

to Presidio Trust leadership or park superintendents, because USPP have a centralized command 

structure. The NPS Visitor and Resource Protection executive further clarified to us that the 

USPP does not need to take direction from the trust leadership, but rather they need to work 

together given the many political influences and concerns at the Presidio. 

B. Analysis 

As noted above, while there is no USPP General Order or Department policy that provides 

authority or identifies a process for dismissing tickets, the practice—as outlined by the former 

chief of police and the SAUSA—typically involved the SAUSA’s assessment of the underlying 

probable cause and a discussion between the SAUSA and the citing officer, supervisor, or court 

liaison. The senior USPP official noted the lack of specific policy for dismissing tickets and told 

us, “we make discretionary decisions all the time.” 

1. The 2017 Incident 

The Presidio Trust official told us that they asked the senior USPP official to request dismissal of 

the 2017 Incident tickets. The senior USPP official appeared to deviate from the established 

practice for dismissing tickets by inserting themselves into the process and directing a USPP 

manager to request their dismissal. 

We found, however, that the USPP’s failure to timely submit the tickets to the CVB caused 

prejudice to the case. Additionally, there was an appearance of retaliation against the subjects, as 

the tickets were not submitted to CVB until after the subjects filed claims of excessive force 

against the USPP officers involved in the incident. We believe these two factors provided 

support for the senior USPP official’s use of discretion to request that the tickets be dismissed. 

2. The 2019 Incident 

Similar to the 2017 Incident tickets, the Presidio Trust official acknowledged asking the senior 

USPP official to dismiss the tickets, and the senior USPP official appeared to deviate from the 

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USPP practice for dismissing tickets by not seeking input from the issuing officer or the officer’s 

supervisor and personally requesting the SAUSA to dismiss the tickets. 

Dissimilar to the 2017 Incident tickets, however, where an administrative oversight created 

prejudice to the case and an appearance of retaliation, the evidence indicates that the 2019 

Incident tickets were processed in a timely manner. Accordingly, we found that the senior USPP 

official’s use of discretion to request dismissal of the 2019 Incident tickets appeared to have 

been, in part, influenced by the Presidio Trust official’s request to do so. 

IV. SUBJECT 

Senior USPP Official. 

V. DISPOSITION 

We will provide this report to the Deputy Director, Exercising the Authority of the Director of 

the NPS, for any actions deemed necessary. 

7 
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