U.S. Department of Justice

Office of Community Oriented Policing Services

www.cops.usdoj.gov

Drug Dealing in

Privately Owned

Apartment

Complexes

by

Rana Sampson

Problem-Oriented Guides for Police Series

No. 4

Drug Dealing in

Privately Owned

Apartment Complexes

Rana Sampson

This project was supported by cooperative agreement 

#99-CK-WX-K004 by the Office of Community Oriented

Policing Services, U.S. Department of Justice. The opinions

contained herein are those of the author(s) and do not

necessarily represent the official position of the U.S.

Department of Justice.

www.cops.usdoj.gov

Problem-Oriented Guides for Police Series

Guide No. 4

About the Guide Series i

About the Guide Series

The Problem-Oriented Guides for Police summarize knowledge

about how police can reduce the harm caused by specific

crime and disorder problems. They are guides to prevention

and to improving the overall response to incidents, not to

investigating offenses or handling specific incidents. The

guides are written for police–of whatever rank or assignment–

who must address the specific problem the guides cover. The

guides will be most useful to officers who

• Understand basic problem-oriented policing principles and

methods. The guides are not primers in problem-oriented

policing. They deal only briefly with the initial decision to

focus on a particular problem, methods to analyze the

problem, and means to assess the results of a problemoriented policing project. They are designed to help police

decide how best to analyze and address a problem they have

already identified. (An assessment guide has been produced

as a companion to this series and the COPS Office has also

published an introductory guide to problem analysis. For

those who want to learn more about the principles and

methods of problem-oriented policing, the assessment and

analysis guides, along with other recommended readings, are

listed at the back of this guide.)

• Can look at a problem in depth. Depending on the

complexity of the problem, you should be prepared to

spend perhaps weeks, or even months, analyzing and

responding to it. Carefully studying a problem before

responding helps you design the right strategy, one that is

most likely to work in your community. You should not

blindly adopt the responses others have used; you must

decide whether they are appropriate to your local situation.

What is true in one place may not be true elsewhere; what

works in one place may not work everywhere.
ii Drug Dealing in Privately Owned Apartment Complexes

• Are willing to consider new ways of doing police business.

The guides describe responses that other police

departments have used or that researchers have tested.

While not all of these responses will be appropriate to your

particular problem, they should help give a broader view of

the kinds of things you could do. You may think you

cannot implement some of these responses in your

jurisdiction, but perhaps you can. In many places, when

police have discovered a more effective response, they have

succeeded in having laws and policies changed, improving

the response to the problem.

• Understand the value and the limits of research knowledge.

For some types of problems, a lot of useful research is

available to the police; for other problems, little is available.

Accordingly, some guides in this series summarize existing

research whereas other guides illustrate the need for more

research on that particular problem. Regardless, research

has not provided definitive answers to all the questions you

might have about the problem. The research may help get

you started in designing your own responses, but it cannot

tell you exactly what to do. This will depend greatly on the

particular nature of your local problem. In the interest of

keeping the guides readable, not every piece of relevant

research has been cited, nor has every point been attributed

to its sources. To have done so would have overwhelmed

and distracted the reader. The references listed at the end of

each guide are those drawn on most heavily; they are not a

complete bibliography of research on the subject.

• Are willing to work with other community agencies to find

effective solutions to the problem. The police alone cannot

implement many of the responses discussed in the guides.

They must frequently implement them in partnership with

other responsible private and public entities. An effective

problem-solver must know how to forge genuine
About the Guide Series iii

partnerships with others and be prepared to invest

considerable effort in making these partnerships work.

These guides have drawn on research findings and police

practices in the United States, the United Kingdom, Canada,

Australia, New Zealand, the Netherlands, and Scandinavia.

Even though laws, customs and police practices vary from

country to country, it is apparent that the police everywhere

experience common problems. In a world that is becoming

increasingly interconnected, it is important that police be

aware of research and successful practices beyond the borders

of their own countries.

The COPS Office and the authors encourage you to provide

feedback on this guide and to report on your own agency's

experiences dealing with a similar problem. Your agency may

have effectively addressed a problem using responses not

considered in these guides and your experiences and

knowledge could benefit others. This information will be used

to update the guides. If you wish to provide feedback and

share your experiences it should be sent via e-mail to

cops_pubs@usdoj.gov.

Acknowledgments v

Acknowledgments

The Problem-Oriented Guides for Police series is very much a

collaborative effort. While each guide has a primary author,

other project team members, COPS Office staff and

anonymous peer reviewers contributed to each guide by

proposing text, recommending research and offering

suggestions on matters of format and style.

The principal project team developing the guide series

comprised Herman Goldstein, professor emeritus, University

of Wisconsin Law School; Ronald V. Clarke, professor of

criminal justice, Rutgers University; John E. Eck, associate

professor of criminal justice, University of Cincinnati;

Michael S. Scott, police consultant, Savannah, Ga.; Rana

Sampson, police consultant, San Diego; and Deborah Lamm

Weisel, director of police research, North Carolina State

University.

Karin Schmerler, Rita Varano and Nancy Leach oversaw the

project for the COPS Office. Megan Tate Murphy

coordinated the peer reviews for the COPS Office. Suzanne

Fregly edited the guides. Research for the guides was

conducted at the Criminal Justice Library at Rutgers

University under the direction of Phyllis Schultze by Gisela

Bichler-Robertson, Rob Guerette and Laura Wyckoff.

The project team also wishes to acknowledge the members of

the San Diego, National City and Savannah police

departments who provided feedback on the guides' format

and style in the early stages of the project, as well as the line

police officers, police executives and researchers who peer

reviewed each guide.

Contents

About the Guide Series . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i

Acknowledgments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v

The Problem of Drug Dealing in Privately Owned Apartment Complexes . . . . . . . . . . 1

Problem Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Related Problems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Factors Contributing to Drug Dealing in Privately Owned

Apartment Complexes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

What We Know About Drug Dealing in Privately Owned

Apartment Complexes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

What We Know About Open Drug Markets . . . . . . . . . . . . . . . . . . . . . . . . . . 4

What We Know About Closed Drug Markets . . . . . . . . . . . . . . . . . . . . . . . . 7

Understanding Your Local Problem . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Asking the Right Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Nature of the Drug Market . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Property Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Property Conditions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Drug Dealers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Drug Buyers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Measuring Your Effectiveness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

Responses to the Problem of Drug Dealing in Privately Owned

Apartment Complexes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

General Considerations for an Effective Strategy . . . . . . . . . . . . . . . . . . . . . . . . 18

Enlisting Property Owners' Help in Closing a Drug Market . . . . . . . . . . . . . 18

Enforcing Law and Agreements Violated by Drug Dealing in

Privately Owned Apartment Complexes . . . . . . . . . . . . . . . . . . . . . . . . 19

Contents vii
viii Drug Dealing in Privately Owned Apartment Complexes

Using What We Know From Research on Particular Strategies'

Effectiveness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

Taking Account of Displacement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Appendix A: Summary of Responses to Drug Dealing in 

Privately Owned Apartment Complexes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

Appendix B: Drugs, Crime and the Criminal Justice System . . . . . . . . . . . . . . . . . . . . . . . . . . 41

Endnotes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43

References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

About the Author . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49

Recommended Readings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51

Other Guides in This Series . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55
The Problem of Drug Dealing in Privately Owned Apartment Complexes 1

The Problem of Drug Dealing in Privately

Owned Apartment Complexes

If you have an apartment complex in your community where

drug dealing is occurring, you may have found that simply

making arrests has not closed the drug market. What else

could be done? Why is this problem occurring? What

conditions facilitate the drug market's operations, and what

remedies will work best? 

This guidebook addresses these issues. It describes the types

of drug markets found in apartment complexes and provides

questions to ask when analyzing those markets. It suggests

ways to encourage property owners to take more

responsibility for problems. Finally, it summarizes the full

range of measures you can use to address drug markets in

apartment complexes.

Problem Description

Drug markets in privately owned apartment complexes are

most often found in low-income areas where property owners

sometimes retreat (out of fear or financial considerations)

from investing in repairs and otherwise practicing effective

management.1 In these markets, users and dealers buy and

sell a wide range of illicit drugs, predominantly cocaine, crack

cocaine, heroin, and methamphetamine. The markets are

often extremely profitable for the dealer, and the income is

nontaxable.

A private security firm hired by a Cincinnati housing agency calculated the yearly

income of one apartment-complex drug market. Surveillance of the market showed

as many as 26 transactions an hour during peak sales times (rush hour and

lunchtime), less other times. With an average of $15 per transaction, estimated

gross revenues exceeded $2 million dollars annually.
2 Drug Dealing in Privately Owned Apartment Complexes

Drug dealing in apartment complexes can attract other

nuisance behavior that diminishes the residents' quality of life,

such as loitering; littering (including drug paraphernalia and

used condoms); trespassing; prostitution (including illegal

sexual activity on the property, in nearby yards, in alleys, or in

driveways);† drug use; abandoned vehicles; speeding vehicles;

parking problems; unwanted additional foot, car and bicycle

traffic in residential neighborhoods; public drinking; public

urination; gang formation; graffiti (establishing turf

ownership of a drug market); assaults; auto theft; auto breakins; residential and commercial burglaries; possession of and

trafficking in stolen property; weapons violations (including

gun possession and gun trafficking); robberies; drive-by

shootings; or other violent crime (including homicide). This

helps explain why successfully tackling a drug market can

bring about substantial decreases in crime in the surrounding

area.

Related Problems

The problem of drug dealing in privately owned apartment

complexes exhibits some similarities to related problems listed

below, though each requires its own analysis and response.

These related problems are not addressed in this guide:

• drug dealing in mobile home parks,

• drug dealing in private residences,

• drug dealing in public housing,

• drug dealing in motels and hotels, and

• street and hotel prostitution.††

† In England, a study done on three

drug markets where prostitution

occurred found that "sex markets can

play a significant part in the

development of drug markets (and

vice versa)" (May, Edmunds and

Hough 1999). The researchers noted

that "professionals estimated that

between two-thirds and threequarters of street workers might be

drug-dependent," and found that

many of the prostitutes spent much

of their daily earnings on drugs.

Thus, the influx of money from a

nearby prostitution market can

bolster a drug market, providing a

steady source of customers. These

dual markets are more difficult to

unravel and require additional

analysis of how one fuels the other.

†† While some of the same

principles involved in drug markets

apply to street and hotel prostitution

problems, these problems demand

their own solutions.
The Problem of Drug Dealing in Privately Owned Apartment Complexes 3

Factors Contributing to Drug Dealing in Privately

Owned Apartment Complexes

Understanding the factors that contribute to your problem

will help you frame your own local analysis questions,

determine good effectiveness measures, recognize key

intervention points, and select appropriate responses.

What We Know About Drug Dealing in Privately Owned

Apartment Complexes

Apartment complexes can harbor two main types of drug

markets–open and closed. In open markets, dealers sell to all

potential customers, screening out only those suspected of

being police or some other threat. In closed markets, dealers

sell only to people they know or to those vouched for by

other buyers.2

In choosing between two evils, closed markets pose less threat

to a community than open markets. Open markets in

apartment complexes are much more susceptible to drive-by

shootings, customers who care little about the property, and

customers who use drugs on the property. In comparison,

closed-market dealers are generally averse to attracting

attention to their operation, so they often keep their

customers' behavior in line.

Certain conditions make privately owned apartment

complexes in low-income, high-crime neighborhoods

susceptible to open-market drug dealing. These conditions are

outlined below.

Tenants and nearby residents with drug histories.

Chronic users often live near their markets so they can readily

buy drugs. This helps sustain the market. Also, drug markets

in low-income neighborhoods can provide a source of part-
4 Drug Dealing in Privately Owned Apartment Complexes

or full-time employment, and apartment complexes can be

ripe recruiting grounds due to a high population of poorly

paid, underemployed or unemployed tenants.

Easy access. Open drug markets in apartment complexes

typically operate near main streets. Other factors that appear

to facilitate open markets are ease of parking (or stopping)

for buyers, and access to apartment complex grounds.

Absentee owners and/or inadequate or untrained

property managers.† Property owners often do not live in

their apartment complexes, and in the case of smaller

complexes and those encumbered by debt, they may not

employ on-site managers, reducing the risk that visitors will be

stopped, questioned or prevented from entering the property.

In large apartment complexes, tenants, police and property

managers do not always know who belongs at the complex

and who does not. This makes it easy for people to come and

go unquestioned, and for drug traffic to appear as just

another part of the routine activity.††

Limited natural surveillance of property. Buyers are often

safeguarded from police surveillance because they purchase

drugs on private property, sometimes behind the security of

fences or shrubs, or inside an apartment.

What We Know About Open Drug Markets

Description. Open drug markets are likely to be outdoors

and, by their very nature, less secure than closed markets.

Dealers usually sell small amounts of drugs to each buyer, and

are highly vulnerable to market disruption and intervention

approaches. Open-market dealers may specialize in one drug,

or offer a variety of drugs. During the 1980s and early 1990s,

in many cities, open markets proliferated on street corners

and in publicly and privately owned apartment complexes.

† For some apartment complexes,

the building superintendent is the

property manager, responsible for

tenant selection and order

maintenance, among myriad other

duties.

†† For a fuller discussion of the

importance of "place" managers,

such as property owners, property

managers and apartment

superintendents, and their impact on

crime, see Felson (1995) and Eck and

Weisburd (1995). For research

indicating a link between poor

property management practices and

crime, see Eck and Wartell (1998);

Asbury (1988); Green Mazzerolle,

Kadleck and Roehl (1998); and

Clarke and Bichler-Robertson (1998).
The Problem of Drug Dealing in Privately Owned Apartment Complexes 5

Some of these still exist, but many are now hybrid, containing

elements of both open and closed markets. The hybrid

market remains open to almost all customers, and to reduce

risk, dealers may use security designed to screen potential

customers. Security may include countersurveillance,

electronic detection devices, prescreening interviews, frisk

searches, and use of pager sales to known customers. In

most ways, though, hybrid markets remain open.

Location. Open markets with stranger-to-stranger sales tend

to operate close to where people naturally congregate, so that

customer traffic is maximized and activities of law-abiding

community members mask the drug dealing. The markets are

often near major streets or other busy places, such as

shopping centers, office buildings, recreation areas, or schools.

Apartment complexes, especially those close to main streets,

are places of natural congregation, yet offer some degree of

security, often having multiple entrances and exits.

This open drug market, in the upper left corner of the photo, sits in front of

an apartment complex and across from a nude entertainment club. It is

located on a main street in an economically depressed area, within a few

blocks from a freeway.

Rana Sampson
6 Drug Dealing in Privately Owned Apartment Complexes

Dealer security. Operating off the public street on

apartment complex grounds gives dealers an advantage: they

can see if police are coming, and can escape into the security

of a specific apartment where officers cannot enter without a

warrant or a constitutionally recognized exception.

Property management. Open markets can operate on

apartment complex grounds only if there is no meaningful

intervention by the owner or property manager.3

Advertisement. Open markets must trade some measure of

security to achieve a high number of sales. Dealers advertise

by picking a location that acts as a "billboard." In other words,

the location itself is often one of the only means of

advertisement open to dealers, besides word of mouth. The

location must be visible enough to gain customers, but

discreet enough to discourage police intervention.

This open drug market in a small apartment complex is one block off a main

street with both street and alley access easing entry and escape. While most

open markets use street dealers as their billboard, others, like this one, are

more brazen.

Rana Sampson
The Problem of Drug Dealing in Privately Owned Apartment Complexes 7

Operations. Open markets may be 24-hour operations or

may operate only around busy times such as rush hour and

evenings. Some full-time operations employ numerous

workers (sometimes underage) who do a variety of tasks to

facilitate sales. These include dealing, steering potential

buyers to the market, alerting dealers to police, and running

special orders to favored customers.

Buyers. Open-air markets are attractive to buyers who look

to obtain their drugs in the shortest amount of time. These

might include hard-core users and those preferring the

safety of drive-through markets. When chronic users are

the bulk of a drug market, displacement, rather than market

elimination, will probably follow police intervention, since

chronic users are the most difficult to dissuade.

Vulnerabilities. Open markets are vulnerable to police

undercover and informant operations, alert and active

property management, and community intervention (such

as identifying where dealers hide stash); all these raise dealers'

risk level. Traffic management techniques such as altering

the direction of the street, creating a cul-de-sac or limiting

the number of escape routes raise buyers' risk level.

What We Know About Closed Drug Markets

Description. Closed drug markets are more likely to be

indoors, with dealers' supplying only friends and

acquaintances. The dealers can sell larger quantities of

drugs to individual buyers than in open markets because

they can easily store the necessary equipment, such as scales

and packaging supplies, inside an apartment. Closed-market

dealers may specialize in one drug, or offer a variety.†

† In a study of a particularly drugridden area of San Diego in the early

1990s, researchers found that crack

and cocaine markets were more likely

to be open markets and

methamphetamine markets more

likely to be closed markets (Eck

1998a). However, when a drug

becomes more fashionable, one may

find that open markets pop up to

accommodate increased customer

demand. In San Diego, although

methamphetamine sales are usually

found in closed indoor markets,

reports of open-market sales are

increasing.
8 Drug Dealing in Privately Owned Apartment Complexes

Location. Since dealers in closed markets rely on word of

mouth, they do not need to locate in busy or well-trafficked

areas. This means that tactics such as rerouting traffic or

increasing security at the apartment complex will have less of

an impact than on an open market.

Dealer security. In closed markets, dealers prefer secure

locations to a high volume of individual customers, because

high customer volume may raise the suspicions of neighbors

and police. Also, these markets are vulnerable to robbers who

know that dealers cannot rely on police to intercede. Some

dealers fortify their apartment doors, install multiple locks and

refuse entry to apartment handymen, to increase security.

Property management. In only a small percentage of cases

are owners in cahoots with dealers, suggesting that initially,

officers should seek to work with owners to address the

problem. Managers are more susceptible than property

owners, because they have less at stake. Dealers may offer

managers special favors or kickbacks to "turn a blind eye."

Officers might try to work with the manager first; if there are

indications that the manager is involved, officers might seek

to work solely with the owner.
The Problem of Drug Dealing in Privately Owned Apartment Complexes 9

Advertisement. Dealers in closed markets advertise by word

of mouth only. Police intervention in closed markets requires

highly specific knowledge of buyers, the seller and/or the

product to pass the initial scrutiny to enter. Police can often

gain this information from informants or nearby residents.

Operations. Closed markets require fewer employees because

the volume of buyers is smaller and the dealer wants to avoid

open advertisement of the market. Some closed markets in

apartment complexes operate only in evening hours, perhaps

indicating the dealer is legally employed during the day or is

simply minimizing risk by limiting hours.

This graphic depicts an arterial street in an economically depressed area with

high risk dealing areas denoted by the boxes and dots. 

John Eck
10 Drug Dealing in Privately Owned Apartment Complexes

Buyers. Closed markets attract buyers who want to lessen

their risk of getting caught by police and those who want the

certainty of purchasing the same or similar quality product

that the closed market dealer sells. These buyers have gained

the confidence of a closed market dealer perhaps because of

friendship, reliability or behavior (not exposing the dealer to

police or other intervention).

Vulnerabilities. Certain practices may increase the

vulnerability of closed markets–frequent property owner

inspections of each apartment, strict lease conditions, explicit

house rules, and immediate follow-through on eviction if

drug dealing is established.
Understanding Your Local Problem 11

Understanding Your Local Problem

The information provided above is only a generalized

description of drug dealing in privately owned apartment

complexes. You must combine the basic facts with a more

specific understanding of your local problem. Analysis is key

to understanding the exact nature of the drug market you are

trying to close and will help you design a more effective

response strategy. During analysis, it can be helpful to think of

the drug market as a business, examining it from a financial

point of view. Try to evaluate the risks, rewards, efforts, and

excuses dealers, buyers, property owners, and tenants might

take into account. This will help you ascertain the market's

potential resilience to certain interventions, and can provide

more persuasive evidence to property owners who consider

their investments from an economic point of view.

Asking the Right Questions

The following are some key questions you should ask in

analyzing your particular problem of drug dealing in privately

owned apartment complexes, even if the answers are not

always readily available. Your answers to these and other

questions will help you choose the most appropriate set of

responses later on.

Nature of the Drug Market

• Is the drug market open or closed? Can undercover officers

or informants make buys at the market? 

• What level of security is used at the market? 

• If arrests were made, did this close the market permanently?

If other enforcement actions were taken against the market

(surveillance, trash analysis, soliciting operations, etc.), did

this close the market? If not, additional analysis is required.
12 Drug Dealing in Privately Owned Apartment Complexes

• When does the market operate? Day of week, time of day,

peak times, winter hours, summer hours, weekend hours? 

• Does the market move indoors in winter, operating more

like a closed market? Surveillance by the police, the property

owner or even a private detective agency (hired by the

owner or tenants) can provide this information.

Property Management

• Who owns the apartment complex? Check tax records to

determine ownership.

• Is the owner aware of the problem? 

• How is the property managed? What techniques are used to

find tenants? What methods are used to prevent and

address illegal activity on the property? 

• Does the owner receive sufficient income to improve

management practices and other conditions that facilitate

drug dealing at the apartment complex?

• Is the property owner well-intentioned but in need of better

skills to address the problem? Is the property manager

participating, intentionally overlooking the problem or in

need of better skills? 

• Does the current visitor policy (or lack thereof) provide a

ready excuse for buyers' presence on the property?

• What do calls for police service reveal about the problem?

Compare several similar apartment complexes nearby to see

if this apartment complex uses a disproportionate share of

police services. A further refinement is to look at the

number of calls for service per apartment unit. Divide the

total number of calls from the apartment complex by the

number of rental units, and compare this number with

those for similar complexes nearby. If there is a recent

ownership change and sudden appearance of drug dealing,

compare the call history during the current owner's tenure

with that during the prior owner's.

• What does information from other agencies, such as code

enforcement, reveal about the property owner? Does the

owner have a history of poor management? Does the

owner generally comply with code? 
Understanding Your Local Problem 13

Property Conditions

• What physical conditions facilitate dealing at the complex? 

• How do the buyers get onto the property? Are there gates?

If so, do they prevent the police from gaining access? 

• Does the lighting facilitate drug dealing? 

• Does the property layout (parking design, side or back alleys,

shrubbery, entry and exit placement) facilitate dealing or

provide easy escape? 

• Does the layout make it easy to hide drugs?

Drug Dealers

• What are the risks and rewards to dealers in this particular

drug market?†

• What risk does the dealer face from the property owner or

from other tenants? 

• What do the tenants know about the drug activity (specific

apartments or specific parts of property; time frame of

illegal activity; identity of dealers, buyers and suppliers;

location of drugs; etc.)? How committed are they to

stopping the problem? Are there tenants willing to help

document the problem?††

• What risk does the dealer face of arrest or jail/prison time?

Verify whom police have arrested from the complex, and

the court sanctions imposed. List the rewards the main

dealers earn from the market, and analyze how legal tactics

can offset those rewards.

Drug Buyers

• How do buyers learn about the market? Is it through market

visibility or word of mouth (on the street or during jail

stays)? 

• What is the market's reputation for quality of drugs, cost of

drugs (e.g., the dealer gives discounts for large purchases or

to frequent buyers) and reliability (always open, rarely shut

down by police)?

• How do buyers find the market? 

† Ron Clarke (1997) uses a risk,

reward, effort, and excuse matrix as

the prism through which to view

offender behavior and devise

opportunity-blocking techniques.

†† Surveys or interviews of tenants

can help officers better understand

the level of risk dealers pose to them.

However, officers should be mindful

of exposing tenants to retaliation

from in-house dealers.
14 Drug Dealing in Privately Owned Apartment Complexes

• Is it near a main road or arterial street? Which route do

buyers use most? 

• How do buyers arrive at the market? By car or foot? 

• How does the market advertise? Do indicators on the main

street steer buyers to the market?

• Are most buyers chronic or occasional users? Interviews

with buyers at different times over a week should establish

if most are chronic or occasional users. Records checks on

buyers may confirm this as well.

• What are the risks and rewards to buyers in this particular

drug market? 

Measuring Your Effectiveness

Measurement allows you to determine to what degree your

efforts have succeeded, and suggests how you might modify

your responses if they are not producing the intended results.

You should take measures of your problem before you

implement responses, to determine how serious the problem

is, and after you implement them, to determine whether they

have been effective. All measures should be taken in both the

Establishing a Rough Estimate of Monetary Rewards: Ascertain

the average number of buyers (over an average two-day period,

allowing that markets have peak and slow sales times). Do not use the

first and 15th of the month (if they are the dates when people

receive government assistance checks in your area), and do not use

two peak days. Multiply the average number of buyers by the average

purchase amount, and then multiply that number by the total number

of two-day periods in the year. For example, if you observe 36 buys

during a two-day surveillance of the market, and if each buy is, on

average, $15, then the two-day total is $540. Multiply this amount,

$540, by 182 (the total number of two-day periods in the year). The

total estimated gross revenue of this market for one year is $98,280.
Understanding Your Local Problem 15

target area and the surrounding area. (For more detailed

guidance on measuring effectiveness, see the companion guide

to this series, Assessing Responses to Problems: An Introductory

Guide for Police Problem-Solvers.)

The following are potentially useful measures of the

effectiveness of responses to drug markets in privately owned

apartment complexes:

• number of calls for service for drug dealing at the

apartment complex;

• number of related calls for service (gun shots, robbery,

theft) at the complex;

• survey of tenants at the complex;

• number of citizen complaints about drug dealing at the

complex;

• difficulty in making undercover buys at the complex;

• number of drug dealers visible at the complex at particular

times, if it is an open market;

• arrests of repeat offenders (both dealers and buyers) at the

complex;

• traffic congestion in and beside the complex; and

• evidence of condoms, discarded syringes and other drugrelated paraphernalia at and beside the complex.

It is helpful to try to determine why the particular market

exists. You should base your hypothesis on the attributes of

the offenders, victims, and location, the three things that need

to come together to permit drug dealing to occur. Once you

form your hypothesis, collaborate with those the problem

affects to develop countermeasures to address the conditions and

behavior that give rise to the problem. Setting reasonable goals at

this stage helps to guide officers through the response stage,
16 Drug Dealing in Privately Owned Apartment Complexes

and sets up a framework for judging success or failure. Any of

the following goals might be achievable:

• increasing dealers' risk so that the market is no longer

profitable without substantial increased effort;

• removing the excuses buyers have for trespassing and

loitering on the property;

• engaging those who can help address the problem (the

property owner, manager, residents, and mortgagor) so that

improved property management practices can handle the

problem with routine interventions; and

• increasing buyers' effort and risk by changing traffic and

parking in and around the complex (using traffic rerouting,

resident parking only, parking fines, no-stopping zones,

etc.).
Responses to the Problem of Drug Dealing in Privately Owned Apartment Complexes 17

Responses to the Problem of Drug

Dealing in Privately Owned Apartment

Complexes

Your analysis of your local problem should give you a better

understanding of the factors contributing to it. Once you

have analyzed your local problem and established a baseline

for measuring effectiveness, you should consider possible

responses to address the problem.

The following response strategies provide a foundation of

ideas for addressing your particular problem. These strategies

are drawn from a variety of research studies and police

reports. Several of these strategies may apply to your

community's problem. It is critical that you tailor responses to

local circumstances, and that you can justify each response

based on reliable analysis. In most cases, an effective strategy

will involve implementing several different responses. Law

enforcement responses alone are seldom effective in reducing

or solving the problem. Do not limit yourself to considering

what police can do: give careful consideration to who else in

your community shares responsibility for the problem and can

help police better respond to it.

Because a drug market can become entrenched fairly quickly,

budding drug markets should not be ignored. Early

intervention makes good use of scarce police resources since

entrenched drug markets are fertile ground for other criminal

activity.†

† During this stage, officers will

also assess the resources available to

them (personnel, equipment, time,

money, etc.) and the political

sentiment of the community and

government administrators (police,

mayoral, legislative, prosecutorial)

toward civil, criminal and other

remedies.
18 Drug Dealing in Privately Owned Apartment Complexes

General Considerations for an Effective Strategy

1. Enlisting property owners' help in closing a drug

market. Drug dealing in apartment complexes exacts high

costs. Aside from the health costs associated with use and

addiction, and the physical risks to the safety of tenants,

property managers and dealers themselves, there are

considerable financial costs to the property owner. Consider

using these costs to engage the property owner in tackling the

problem.

Most apartment complexes where drug dealing occurs

experience many other problems as well, including high tenant

turnover and vacancy rates; vandalism or squatting in vacant

apartments; increased calls to police; increased police presence

on the property; poor reputation of the complex and the

property management among neighbors, police and local

realtors; lower property values for the complex and for

surrounding properties; fear among law-abiding tenants

(including fear of retribution); apathy among law-abiding

tenants if they perceive the property owner as ignoring or

encouraging the market; ceding of common space by lawabiding tenants to those engaged in crime; isolation of lawabiding tenants who stay indoors when dealing (and crimes

associated with dealing) are more prevalent; and illicit gun

possession by those (sometimes juveniles) seeking to protect

themselves against dealers. The presence of drug-dealing

tenants in an apartment complex sometimes attracts other

criminals as tenants, because the drug dealing can mask their

activities or provide them with a ready market for their

activities.
Responses to the Problem of Drug Dealing in Privately Owned Apartment Complexes 19

In addition, the property owner might incur these typical

financial costs:

$ 500 Average cost if drug dealer simply stops 

paying rent for one month

50 Dispossessor warrant 

25 Writ of Possession

250 Loss of rent due to tenant turnover

150 Labor costs of a painter 

100 Paint costs

100 General cleaning of apartment

40 Carpet cleaning

$1,215 Cost to property owner (if there is no 

damage to the apartment)†

2. Enforcing laws and agreements violated by drug

dealing in privately owned apartment complexes. When

selecting responses, consider which specific laws and

agreements are violated by drug dealing in open or closed

markets.

• Apartment complex rules: sometimes referred to as

"house rules" concerning visitors, noise, use of space, etc.

• State laws: narcotics laws (trafficking, possession and

intoxication); alcohol laws; loitering and trespassing laws;

health codes; child welfare laws, including child

endangerment (if a child is in a dealer's apartment); elder

abuse laws (if a dealer is taking advantage of an older

person and using his or her residence to deal drugs);

vandalism laws; harassment laws; nuisance laws; certain

asset forfeiture laws.

• Federal laws: drug-free school zone laws (when the market

is near a school); federal tax laws; certain asset forfeiture

laws; federal (and sometimes state) housing voucher

programs providing disadvantaged tenants with apartments

† Officer Tracy Walden, Savannah

(Ga.) Police Department, uses these

estimates to show owners of

apartment complexes where drug

dealing is occurring just how

significant the cost of one dealer can

be to their bottom line. In San

Diego, some dealers in apartment

complexes file for bankruptcy when

faced with eviction, adding six more

months to the eviction process (and

a loss of six months in unpaid rent).

In addition, other tenants sometimes

bail out of their leases if drug

dealing occurs on a property,

increasing the number of vacancies

and loss of monthly rent.
20 Drug Dealing in Privately Owned Apartment Complexes

in private complexes subject property owners to special

conditions.

• Local laws: nuisance laws; alcohol laws; health codes; local

building, fire and environmental code violations (especially

if dangerous drugs are chemically mixed in an apartment);

dog leash violations (if dangerous dogs are used to protect

the market); business or zoning laws regarding operation of

an illegal business in a residential property.

• Legal conditions: probation and parole conditions

prohibiting visiting or mixing with other probationers or

parolees, such as often occurs in a drug market.

Using What We Know From Research on Particular

Strategies' Effectiveness 

Appendix A outlines a wider range of possible responses to

drug dealing in apartment complexes than is presented here.

Here we discuss only those responses that have been

Example: Police, fire, building, code enforcement, recreation, and planning departments

in Ontario, California, met to prioritize crime hot spots there. The team conducted site

visits and met with apartment owners. They worked with renters "to unite them in

demanding better property management." They trained apartment managers to find

responsible renters, and informed owners of their rights and responsibilities. Lowinterest loans were available to owners who conformed to city codes; civil and criminal

remedies were reserved for those who did not. The team recruited city services for cleanup and repair, as well as for creating recreation programs for children. Property values

increased in the target area and in the surrounding areas. After the interventions, the

target area experienced significant declines in calls for city services (which were now

responded to through the joint efforts of city government and property managers). Parts

of the target area experienced up to a 73 percent decrease in complaints to city agencies

concerning conditions and problems at the properties.4
Responses to the Problem of Drug Dealing in Privately Owned Apartment Complexes 21

evaluated through research. It will be evident that some of

those most used by police have more limited effectiveness

than previously thought.

3. Applying intensive police enforcement. Research

suggests that intensive police enforcement at drug hot spots,

sometimes referred to as "sweeps" or "crackdowns," has an

impact on some buyers, particularly those who want to buy

only at markets where the risk of arrest is low. However,

intensive enforcement alone can have other, perhaps

unintended, consequences. These include alienation of lawabiding community members stopped and questioned, and

displacement of drug dealing indoors, thus making it more

resistant to police interventions. In addition, because intensive

police enforcement is by its very nature temporary, the impact

is often only short-term and dependent on the resiliency of

the market and the buyers.† Use of this tactic may also give

law-abiding tenants and the property owner the unrealistic

notion that a drug market is solely a police problem. Some

officers have argued that intensive enforcement shows the

community that the police care about the problem; however,

some of the unintended effects may, in fact, have the opposite

result.††

4. Arresting dealers and buyers. Arrest is effective if local

courts are willing to impose meaningful sentences on dealers

and buyers. This often depends on jail and prison

overcrowding and on the number of prior convictions of an

arrestee. In many cases, the courts allow those arrested for

selling drugs to plead to lesser offenses, or release them on

bail between arrest and trial or arrest and plea-bargaining. It is

estimated that more than 90 percent of filed criminal cases

nationwide result in plea-bargaining. Appendix B provides

more details about drugs and the criminal justice system.

† In one study in Kansas City, Mo.,

the effect of intensive enforcement,

including undercover buys, warrant

searches and arrests, lasted only two

weeks, after which it almost

completely disappeared (Sherman

and Rogan 1995).

†† Other approaches involving the

property owner and tenants may have

significantly longer-term impact,

leaving these two groups better

equipped to handle similar problems

in the future.
22 Drug Dealing in Privately Owned Apartment Complexes

5. Increasing place guardianship. Research suggests that

improved place management can block opportunities for

certain crimes, such as drug dealing. Ways to increase place

guardianship include:

• showing the owner the financial costs of having a drug

market on the property,

• engaging the mortgage bank that holds the loan on the

property,

• outlining the physical risks to the owner,

• providing training for the landlord, and

• engaging tenants or neighbors in information-gathering and

market disruption.

If the owner's profits from the property are so low that it is

financially impossible for the owner to wait to find a screened

tenant, then applying pressure to the owner will not help. In

such a case, consider leveraging a small amount of

community investment funds to give the owner the economic

ability to screen potential tenants and improve security at the

complex.†

6. Making physical changes at the property. Limiting

access may deter some buyers because it increases their effort

in purchasing drugs, but limiting access may also deter the

† On several occasions, police

agencies in National City and

Fontana, Calif., collaborated with

community development or housing

agencies to offer "fixer upper" grants

to property owners who initially

balked at the expense of crime

prevention and code compliance

improvements.

A property owner on a high-risk block affixed this sign

to deter potential offenders from the location. 

Rana Sampson
Responses to the Problem of Drug Dealing in Privately Owned Apartment Complexes 23

police from entering the property. Limiting escape routes can

increase buyers' and dealers' risk of getting caught. As for

lighting, dealers may prefer it to be good so that they can

better see their customers and the police. Good lighting also

reduces the risk that the dealer will get robbed, because it

increases the probability of the dealer's identifying the robber.

7. Sending notification letters to, and meeting with,

property owners concerning drug dealing. In a San Diego

study, notification letters from police to property owners,

coupled with meetings between police and property owners,

increased the probability that dealers would be evicted. This

also reduced crime at the rental properties as much as 60

percent compared with sites that received no follow-up

intervention involving a meeting.5 Police agencies should

follow up regularly with those property owners who only

reluctantly improve management practices. Police should

monitor calls for service at the properties to detect any

resurgence of illegal activity, and should document every

The owner of this property on a high-risk block off of a main street

sends mixed messages to potential dealers looking to set up

operations. Next to the “Now Renting” sign is a “No Trespassing”

sign, but to its left is the “Residents Only” parking sign, which is

lopsided and falling down. The security gate is propped open

eliminating its value. 

Rana Sampson
24 Drug Dealing in Privately Owned Apartment Complexes

interaction with the property owners in writing. Notification

letters often list consequences for inaction, including

abatement, which is described next.

8. Applying civil remedies, including abatement

proceedings. Different types of civil remedies can be used to

deal with properties sheltering drug markets, including

temporary injunctive relief, temporary seizure of premises,

permanent seizure of premises, and monetary damages. The

district attorney, the police or private citizens can sue in civil

court for abatement and/or for financial restitution for the

harmed parties.6

9. Evicting drug dealers. The Milwaukee Police Department

sought out evicted drug dealers in their new homes to

determine if eviction simply displaced dealing to a new area.

They found that less than 20 percent of those who were not

in jail or prison were still in the drug trade, indicating that

displacement levels were low.7

10. Offering drug treatment. Research indicates that there

are different ways to offer drug treatment, and that the

varying models also vary in effectiveness.

• The information model. Sharing information about drug

treatment with users (verbally, through handouts or posters,

or by providing phone numbers of referral services) does

not appear to be highly effective.†

• The proactive model. Involving drug outreach workers at the

site as part of a multiagency response to problems can be

effective.8

• The incentive model. Coerced court-based referral, as part of

the conditions of probation or sentencing, is effective if

coupled with drug-use monitoring and screening.9

† Information referral schemes

evaluated in England found they

"tend not to lead users into

treatment." In Thames Valley,

England, police found that one

information referral campaign elicited

only four calls from users during the

course of a year (Newburn and Elliot

1998:13-14).
Responses to the Problem of Drug Dealing in Privately Owned Apartment Complexes 25

Officers should try to arrange for chronic users to enter

court-ordered, monitored drug treatment to begin lessening

their reliance on particular markets. The fewer the chronic

users, the more vulnerable the market is to police

intervention, such as buy-and-bust operations. This is because

recreational users are more likely to have jobs and, as a result,

want to avoid the risk of arrest, since it might impact their

employment.

Taking Account of Displacement

There is evidence that if displacement occurs, it is not one-forone. In other words, displacement may be only partial, not

enough to cancel the benefits of the countermeasures because

the displaced criminal activity lessens and is, as a result, more

manageable for the police and community to address.

Displacement indoors. Intensive enforcement alone can

displace an open market indoors. Driving a market indoors

negatively impacts it, decreasing its customer base because it

must rely on word of mouth for advertisement, rather than

visual cues. Also, an indoor market is less convenient to

buyers (they must park, not just stop momentarily), and

buyers may feel less safe, as they now have to enter dealers'

homes. However, residents of an apartment complex may not

find this a complete solution. Property management must

improve to rid the complex of the market.

Displacement nearby. If property management becomes

effective, an apartment-complex drug market must close

down or move. A review of the displacement literature

suggests that there may be ways to minimize nearby

displacement.
26 Drug Dealing in Privately Owned Apartment Complexes

• Open-market dealers have what is referred to as "high place

attachment." They rely on the natural and established

routine of foot and car traffic to supply a high volume of

buyers. It is high risk for dealers to set up shop in

unfamiliar territory; doing so can lead to inter-turf drug

warfare, so nearby complexes or other nearby areas with

low levels of property guardianship are most at risk for

displacement.

• Displacement nearby should be expected since it allows the

market to keep most of its customers. Developing a

thorough understanding of the reasons the drug market

succeeded in the apartment complex can shed light on the

conditions that must be changed nearby, especially in nearby

complexes, to avert potential displacement.†

† For a more detailed discussion of

displacement and drug markets, see

Jacobson (1999).

This apartment complex is at high risk for dealing. It is on a

block that has had drug markets, is off of an arterial street,

backs onto an alley providing multiple entries and exits, is

tagged “Kelow,” (probably purposefully misspelled), its alleyside security gate is propped open, and the dumpster is propped

open offering an easy hiding place for stash. While a “Residents

Only” parking sign is visible, the owner must do more to

prevent nearby markets from displacing to this complex. 

Rana Sampson
Appendix A 27

Appendix A: Summary of Responses to

Drug Dealing in Privately Owned

Apartment Complexes

The table below summarizes the responses to drug dealing in

privately owned apartment complexes, the mechanism by

which they are intended to work, the conditions under which

they ought to work best, and some factors you should

consider before implementing a particular response. There are

more responses listed here than in the text where only those

responses that have been evaluated through research are

discussed. It is critical that you tailor responses to local

circumstances, and that you can justify each response based

on reliable analysis. In most cases, an effective strategy will

involve implementing several different responses. Law

enforcement responses alone are seldom effective in reducing

or solving the problem.

Enforcing a city

ordinance or state

law requiring

owners to address

conditions that

foster drug

markets on

private property 

Sending a letter to

the property

owner from the

police 

chief

Increases the

owner's risk, and

removes the

owner's excuses

for not addressing

conditions

facilitating the

market 

Removes the

owner's excuse of

ignorance, and

increases the risk

for ignoring the

problem

...sanctions are

part of the

ordinance/law,

and the city

attorney or

prosecutor is

willing to proceed

...the letter

outlines legal

responsibility and

potential

consequences for

failure to act, as

well as the value

of improved

management

practices and

environmental

changes in

eliminating drug

markets

Requires local or

state legislation 

Letter must be

based on state or

city law requiring

owner action

Response How It

Works

Works

Best If...

Considerations
28 Drug Dealing in Privately Owned Apartment Complexes

† John Campbell collaborated

with the Portland (Ore.) Police

Bureau to create and deliver the

first police-sponsored landlord

training curricula in the United

States. Campbell, who fought a

crack house operating on his block,

conducted intensive research,

including interviews of property

owners, and concluded, "Most

landlords are not skilled in the

prevention of illegal activity, but are

willing to learn.... [Property

owners] prefer to act responsibly,

but lack the tools to do so"

(Sampson and Scott 2000). John

Campbell can be reached through

his web site at www.cdri.com.

†† For further information about

the crime-free multi-housing

program, contact the Mesa (Ariz.)

Police Department at 480.644.2211.

Removes the

owner's excuse

that he or she was

unaware of the

problem and its

extent, and

underscores the

need for the

owner to improve

management

practices

Removes the

owner's excuse of

ignorance

Removes the

owner's excuse of

ignorance

Removes the

owner's excuse of

inability to

address illegal

activity, raises the

owner's awareness

of the legal

consequences for

failure to act, and

provides

incentives for the

owner to operate

a crime-free

complex

If the owner is "in

cahoots" with the

dealer then police

must keep from the

owner the names of

those complaining

to the police about

the dealing 

In certain

circumstances, the

owner may perceive

that the costs of

making

improvements may

be higher for the

owner than the

financial costs

associated with

allowing the drug

dealing

An apartment

managers'

association within

the community may

be able to offer the

training.

An apartment

managers'

association within

the community may

be able to monitor

and manage the

initiative.

...used in

combination with

the above

responses

...the owner is

solvent, or

community

development

housing upgrade

loans are available

...tailored to the

laws within one's

jurisdiction 

...tailored to the

laws within one's

jurisdiction, and

the incentive to

the owner is

meaningful

How It

Works

Works

Best If... Response Considerations

Supplying the

owner with callsfor-service data for

his or her property,

and with

comparison data

for well-run nearby

properties

Meeting with the

owner and

outlining the costs

associated with

allowing drug

dealing on the

property

Establishing a

landlord training

program †

Establishing a

crime-free multihousing program ††
Appendix A 29

Engaging an

apartment

managers'

association to work

with the owner to

upgrade the

owner’s property

management skills

Running credit

checks of

prospective tenants

Verifying

prospective tenants'

income sources

Doing a criminal

history check of all

prospective tenants

Increases the risk

to the owner for

failing to remedy

conditions at the

property, and

removes the

owner's excuse

that he or she

does not know

how to address or

is unaware of the

problem 

Removes the

excuse for tenant

dealing, and

weeds out drug

dealers whose

income is not

reported 

Employers are

called (using

phone numbers

from the 411

directory, not

from the

prospective

tenant). If the

prospective

tenant is selfemployed, copies

of bank

statements and

tax returns are

requested. This

removes excuses

for tenant dealing

Removes excuses

for tenant dealing

...the association

is competent and

well-regarded

...the credit

report also

documents courtordered evictions

and past

addresses of

prospective

tenants

...the system is

set up to verify

the income of all

potential tenants

...an apartment

owners'

association has

established a legal

system for doing

so

It would be unfair

to have an

association deal

with a property

owner who is

behaving criminally;

the association

should address only

those cases in which

the owner is not

suspected of

collusion 

Must be done in a

nondiscriminatory

way

Must be done in a

nondiscriminatory

way

Some jurisdictions

permit this; others

do not 

Response How It

Works

Works

Best If...

Considerations
30 Drug Dealing in Privately Owned Apartment Complexes

Doing reference

checks of

prospective

tenants' prior

tenancies

Establishing a nocash policy–the

property owner

does not accept

cash for deposits

or monthly rent

Adding a drug

addendum to

lease agreements

Conducting

police

surveillance from

a vacant

apartment in the

complex or from

another vantage

point

Calls to prior

landlords of a

prospective tenant

to ascertain if

criminal activity

was evident

remove excuses

for tenant dealing.

For Section 8

renters, inquiries

should be made to

the local housing

authority 

Prevents those

engaged in an

illegal, cash-only

business from

residing at the

property

Removes excuses

and eases the

eviction process

by putting tenants

on notice that

drug activity will

not be tolerated

Removes the

police or property

owner excuse of

lack of knowledge

of the conditions

that facilitate the

market 

...there is an

apartment

owners'

association that

facilitates doing

so

...the owner

establishes the

policy in writing 

...the property

owner enforces it

...the surveillance

focuses not just

on the players,

but also on the

conditions that

facilitate the

market (e.g.,

parking, design,

lack of natural

surveillance)

Response How It

Works

Works

Best If...

Considerations

Calls to the tenant's

current landlord

may not yield any

information;

however, interviews

of previous

landlords might

Some law-abiding

people mistrust

banks and pay only

by cash

State law may

require that

property owners

give tenants notice

of any new

provisions to the

lease

The vantage point

from the apartment

may not give police

a full sense of the

market 
Appendix A 31

Surveying tenants

Having tenants

document illegal

activity

Preventing access

to vacant

apartments if

they are used for

dealing or taking

drugs

Posting "No

Trespassing" signs

Raises the risk for

dealers and buyers

if tenants are

willing to provide

details about

them, peak market

times, and specific

apartments or

outdoor locations

where dealing is

occurring

Logs kept for use

in civil and

criminal court

raise the risks to

dealers and

remove the

criminal justice

system's excuses

concerning the

chronic nature of

the market

Removes dealers'

and users' excuse

for being on the

property, and

increases the risk

of a possession

arrest because

drugs have to be

carried off the

property

Removes buyers'

and nonresident

dealers' excuse for

being on the

property

...a plainclothes

officer does the

surveying and

leaves a business

card with a

number that

tenants fearful of

being seen

speaking to police

can call

...police can

follow up, and the

information is

specific and useful

enough

...the apartments

are checked

frequently for

break-ins

...the property

owner signs over

the right to

enforce to police

and gives police

an updated list of

tenants' names

Response How It

Works

Works

Best If...

Considerations

If tenants' primary

language is not

English, several

translated versions

of the survey may

be needed

Need to ensure that

the sources of

information are not

discoverable in

court

Boarded-up

apartments are not

aesthetically

pleasing

Time-consuming

for the police; may

need semi-constant

maintenance if

other remedies are

not used in

combination
32 Drug Dealing in Privately Owned Apartment Complexes

Improving

property access

control and

having restricted

parking for

tenants

Establishing

owner

expectations for

property

management and

security staff

Having property

management staff

keep an in-house

log of illegal

activity on the

property

Restricts buyers'

and nonresident

dealers' access to

the property.

Tenant-only

parking deters

buyers from

entering the

property in

vehicles;

eliminating visitor

spots has a similar

effect. Buyers

have to scout for

neighborhood

parking, and are at

increased risk

because they have

to leave the

property on foot,

with drugs on

them

Removes the

staff's excuses that

they are unaware

of their

responsibility in

addressing illegal

activity on the

property

Removes the

owner's excuse of

ignorance and

provides

documentation

for eviction

...tenants agree

to the change and

do not try to

sabotage the

system 

...expectations

are in writing and

reflected in job

descriptions and

performance

evaluations

...management or

police responses

to the activity are

also detailed in

the log

Financial costs

Should be done in

combination with

other cited

management

practices

Log must be

safeguarded from

theft

Response How It

Works

Works

Best If...

Considerations
Appendix A 33

Engaging the

property

mortgagor to

prevent the

property from

losing its value

because of

entrenched drug

dealing

Enforcing codes

Detecting and

arresting tenant

drug dealers

The bank or

lending agency

(holding the

mortgage on the

property) is

informed about

the drug market

and provided with

data on calls for

police service and

arrests; criminal

activity on the

property removes

the owner's

monetary excuses

for not acting 

Removes the

owner's excuses if

code violations at

the property

facilitate the drug

market, forces the

owner to gain

compliance, and

increases the

owner's financial

risk if he or she

does not comply

The use of

undercover buys

and the issuance

of search warrants

for active drug

apartments

increase dealers'

risk 

...the mortgagor

requires that the

owner develop an

improved safetysecurity plan to

address the drug

market 

...the code

enforcement

agency

understands that

certain code

violations

facilitate drug

markets, and is

willing to assist

...in an open

market; in closed

markets, police

must have enough

information to

lawfully gain

access to an

apartment

Disclosure of

information must

be legally allowed

Should use code

enforcement

nondiscriminatorily

when targeting

those conditions

that facilitate the

drug market

Once police gain

lawful access, it may

be appropriate to

bring in other

agencies such as

health, codes, child

or adult protective

services, and animal

control

Response How It

Works

Works

Best If...

Considerations
34 Drug Dealing in Privately Owned Apartment Complexes

Limiting potential

buyers' ability to

cruise through

the area in search

of open drug

markets

Prohibiting or

limiting on-street

parking

Using asset

forfeiture

Rerouting and

managing traffic,

redesigning roads

and dead-ending

streets so they're

inaccessible from

main

thoroughfares

increase potential

buyers' effort, and

also increase their

risk of getting

caught by limiting

the number of

escape routes

"Resident-only

parking" on the

street outside of

the apartment

complex forces

buyers to park

and walk farther

to access the

market, and

increases the risk

to buyers because

they must return

to their vehicle

with drugs in

hand

Forfeiture of cars

or property used

by dealers

increases dealers'

efforts and

decreases their

rewards

...residents are

committed to

redesign to

eliminate dealing

...residents are

committed to

parking

restrictions to

eliminate dealing

...prosecutors are

willing to apply

the law

Potential

inconvenience to

residents

Residents with

legitimate visitors

may find this

onerous

Must have a local,

state or federal law

authorizing it

Response How It

Works

Works

Best If...

Considerations
Appendix A 35

Having legitimate

tenants attend

court hearings

(court watch)

Using vertical

prosecution

Having the

prosecution seek

court-ordered,

monitored

treatment of

chronic users

who buy at the

apartment

complex 

Using surveillance

cameras

Court watch at

judicial hearings

of dealers and

buyers

discourages the

criminal justice

system from

treating drug

dealing and use as

only a personal

harm or

"victimless" crime

Assigning one

prosecutor to all

cases arising from

the same

apartment

complex removes

the excuse that

the problem is not

chronic, and

increases the risk

to an ongoing

drug operation 

As a condition of

probation or

sentencing, raises

users' risk through

consistent

monitoring and

jail time if caught,

and removes their

excuse for being

on the property,

taking them out

of the drug

market

Raises the risk

that dealers will be

identified and

caught, and

potentially raises

the risk of

prosecution due

to the strength of

evidence

...more than a

few tenants

attend, creating

safety in numbers,

and the judge tells

the accused dealer

or buyer that any

retaliation will

result in greater

punishment 

...the

prosecutor's

office is familiar

with the use of

vertical

prosecutions, and

judges are willing

to approach

caseloads this way

...combined with

geographic

probation to keep

users away from

the particular

market 

...cameras are

bullet- resistant,

dealers' identities

are clear, and the

evidence is usable

in court 

Potential

intimidation of lawabiding tenants

Judges may prefer

random assignment

of cases

Resource-intensive

Cost and

monitoring of

cameras

Response How It

Works

Works

Best If...

Considerations
36 Drug Dealing in Privately Owned Apartment Complexes

Enforcing tax

laws

Providing space

for alternative

legal activities on

the property

Launching an

information

campaign

targeting buyers

at the apartment

complex

Having lawabiding tenants

petition the

property owner

Decreases dealers'

rewards through

tax sanctions for

unreported

income or

operation of an

illegal business

Counters or

overrides the use

of outdoor space

for drug dealing,

removes dealers'

and users' excuse

for being on the

property, and

increases the risk

to dealers and

users through

increased natural

surveillance of the

premises

Information

distributed to

buyers concerning

overdoses,

chemicals used in

cutting drugs, and

the risk of arrest

at the complex

removes excuses

and increases

buyers' perception

of risks; increases

buyers' effort, as

they have to

search for less

risky markets

Pressures the

owner to address

the market

conditions,

removes excuses

and decreases

rewards if the

owner fails to

comply

...federal and

state officials are

willing to act

...tenants are

involved in

selecting activities

and are willing to

participate

...information is

available about

the type of drugs

sold at the

complex

...tenants agree

to all move out if

the owner fails to

take action within

a certain amount

of time, and this

is stated in the

petition 

The criteria that

must be met for

state and federal

authorities to

intervene must be

arranged in advance

Participants' safety 

Determine who

should distribute

the information-the

owner, police, lawabiding tenants.

Availability of other

rentals at

comparable prices

Response How It

Works

Works

Best If...

Considerations
Appendix A 37

† "Safe Streets Now" programs

operate in several cities, including

San Diego. For more information,

call 619.299.5408.

Obtaining a

temporary

restraining order

against the

property owner

Taking civil action

for monetary

damages

A court order

restraining the

owner from

operating the

property in a way

that facilitates

drug dealing, and

requiring that the

owner make

management and

environmental

changes to

address the

market. Removes

the owner's

excuses, reduces

rewards and

increases the

owner's risk if in

noncompliance

Several cities have

a "Safe Streets

Now" program in

which residents of

drug markets sue

property owners

in civil court for

monetary

damages caused

by such things as

the disruption of

residents' peaceful

enjoyment of

their property.†

This approach

reduces the

reward for

owners who allow

activity at the

expense of

neighbors and

their property

values

...the court is

willing to apply

the law this way

...residents are

trained and

organized to

follow through

May need to

educate the court

about the legality of

doing so

Seed money for

starting the

program

Response How It

Works

Works

Best If...

Considerations
38 Drug Dealing in Privately Owned Apartment Complexes

† To prove liability, a tenant must

establish that (1) the property owner

had a duty to provide reasonable

security; (2) the property owner

breached the duty; and (3) this breach

of duty was the cause in fact and (4)

was the foreseeable cause of (5) the

tenant's injury or harm (Kennedy and

Hupp 1998:25). Other civil actions

might include those for maintaining a

nuisance, causing loss of quiet

enjoyment or inflicting emotional

distress.

Applying

nuisance

abatement

Taking civil action

for foreseeable

consequences 

Police, tenants or

neighbors file civil

action against the

property owner

for nuisance

abatement

(temporarily or

permanently

taking the

property away

from the owner) if

the owner fails to

address conditions

facilitating the

drug market.

Removes the

owner's excuses

for poor

management and

decreases the

owner's rewards

Tenants bring civil

tort action against

the property

owner, asserting

the owner's

liability for

operating the

premises in a way

that is sure to

cause them harm.

The suit alleges

the owner is

responsible for

providing security

against

foreseeable

crimes.† Removes

the owner's

excuses, increases

the owner's risks

and decreases the

owner's rewards

...local

government

leaders are willing

to follow through

if police file the

case

...there are

pervasive, repeat

calls for service

about drug

dealing, and the

owner fails to

make needed

changes

Response How It

Works

Works

Best If...

Considerations

City or state law

must permit doing

so

Educating tenants

about the law
Appendix A 39

Holding

community

antidrug marches

at the property

owner's home

Getting media

attention

Potentially

galvanizes

community

support to engage

the owner in

improving

property

management

practices, and

reduces the

owner's rewards 

Draws media

attention to the

drug market and

management

practices if the

property owner

actively resists

taking remedial

action, and

potentially reduces

the rewards for

owning property

in the community

...organized by

tenants

...organized by

tenants

In some

communities, there

are anti-picketing

ordinances that

should be reviewed

first

If the owner

complies and makes

changes, the media

should be invited

back to show those

changes

Response How It

Works

Works

Best If...

Considerations

Appendix B 41

Appendix B: Drugs, Crime and the

Criminal Justice System

Understanding drugs' impact on crime underscores the need

to look beyond the criminal justice system for additional

responses in managing the problem.

Drug Use and Crime Facts

Bureau of Justice Statistics, U.S. Department of Justice, 1999 Data

• About two-thirds of adult arrestees and more than half of juvenile arrestees tested positive

for at least one drug during the 1998 Arrestees Drug Abuse Monitoring program sampling

arrestees in 35 metropolitan areas.

• Thirty-three percent of state prisoners reported in 1997 that they had committed their offense

while under the influence of drugs.

• Sixteen percent of convicted jail inmates said they had committed their offense to get money

for drugs.

• Of convicted property and drug offenders, about one in four had committed their crimes to

get money for drugs.

• In 1997, 5.1 percent (over 700) of all homicides were drug-related.

• The first national survey of adults on probation, conducted in 1995, reported that 14 percent

of them were on drugs when they committed their offense.

• In 1998, the number of arrests for drug possession exceeded 1.2 million nationwide.

• In 1998, the number of arrests for sale and manufacture of drugs exceeded 300,000

nationwide.

• In 1998, drug arrests accounted for 30 percent of all arrests nationwide.

• In 1994, the last year for which statistics were released, 66 percent of arrestees charged with a

felony drug offense in the 75 most populous counties were released prior to case disposition.

• The average time from arrest to sentencing by jury trial was 285 days for drug trafficking

cases.

• In 1995, 32 percent of all probationers (43 percent of felons and 17 percent of

misdemeanants) were subject to mandatory drug testing.

• According to 1997 data, 36 percent of the U.S. population reported illicit drug use at least

once in their lifetime, 11 percent reported drug use within the last year, and 6 percent

reported drug use within the last month.

• In 1996, the last year for which statistics were available, 114,180 cases of cocaine use and

70,463 cases of heroin use required hospital emergency-room attention.

Endnotes 43

Endnotes

1 Eck (1998a). 2 Jacobson (1999). See also Eck (1998a, 1998b). 3 Eck and Weisburd (1995). 4 Ontario Police Department (1994). 5 Eck (1998b). See also Eck and Wartell (1998). 6 Davis and Lurigio (1998). 7 Davis and Lurigio (1998). 8 Newburn and Elliot (1998). 9 Newburn and Elliot (1998).

References 45

References

Asbury, K. (1988). "Social Control in a Local Community:

The Role of the Apartment Superintendent." Journal of

Research in Crime and Delinquency 25(4):411-425.

Bureau of Justice Statistics, U.S. Department of Justice

(1999). "Drug Use and Crime Facts." Available at

www.ojp.usdoj.gov/bjs (data last revised Oct. 14, 1999).

Clarke, R. (1997). "Introduction." In R. Clarke (ed.), Situational

Crime Prevention: Successful Case Studies, 2nd ed. Guilderland,

N.Y.: Harrow and Heston.

Clarke, R., and G. Bichler-Robertson (1998). "Place Managers,

Slumlords and Crime in Low-Rent Apartment Buildings."

Security Journal 11(1):11-19.

Davis, R., and A. Lurigio (1998). "Civil Abatement as a Tool

for Controlling Drug Dealing in Rental Properties." Security

Journal 11(1):45-50.

Eck, J. (1999). "Drug Market Places: How They Form and

How They Can Be Prevented." In C. Sole Brito and T.

Allan (eds.), Problem-Oriented Policing: Crime-Specific Problems,

Critical Issues and Making POP Work, Vol. 2. Washington,

D.C.: Police Executive Research Forum.

(1998a). "A General Model of the Geography of

Illicit Retail Marketplaces." In J. Eck and D. Weisburd (eds.),

Crime and Place. Crime Prevention Studies, Vol. 4. Monsey, N.Y.:

Willow Tree Press.

(1998b). "Preventing Crime by Controlling Drug

Dealing on Private Rental Property." Security Journal 11(1):

37-43.
46 Drug Dealing in Privately Owned Apartment Complexes

Eck, J., and J. Wartell (1998). "Improving the Management of

Rental Properties With Drug Problems: A Randomized

Experiment." Civil Remedies and Crime Prevention. Crime

Prevention Studies, Vol. 9. Monsey, N.Y.: Criminal Justice

Press.

Eck, J., and D. Weisburd (1995). "Crime Places in Crime

Theory." In J. Eck and D. Weisburd (eds.), Crime and Place.

Crime Prevention Studies, Vol. 4. Monsey, N.Y.: Criminal

Justice Press.

Felson, M. (1995). "Those Who Discourage Crime." In J. Eck

and D. Weisburd (eds.), Crime and Place. Crime Prevention

Studies, Vol. 4. Monsey, N.Y.: Criminal Justice Press.

Green Mazerolle, L., C. Kadleck and J. Roehl (1998).

"Controlling Drug and Disorder Problems: The Role of

Place Managers." Criminology 36(2):371-402.

Jacobson, J. (1999). Policing Drug Hot-Spots. Policing and Reducing

Crime. Police Research Series, Paper 109. London: Home

Office.

Kennedy, D., and R. Hupp (1998). "Apartment Security and

Litigation: Key Issues." Security Journal 11(1):21-28.

May, T., M. Edmunds and M. Hough (1999). Street Business:

The Links Between Sex and Drug Markets. Police Research Series,

Paper 118. London: Home Office.

Newburn, T., and J. Elliot (1998). Police Anti-Drugs Strategies:

Tackling Drugs Together Three Years On. Crime Detection and

Prevention Series, Paper 89. London: Home Office.

Ontario (California) Police Department (1994). Multiagency

Team Problem Hot-Spots POP Project. Document on file

with author.
References 47

Sampson, R., and M. Scott (2000). "Apartment Complex

Crime in San Diego, Calif." In R. Sampson and M. Scott

(eds.), Tackling Crime and Other Public-Safety Problems: Case

Studies in Problem-Solving. Washington, D.C.: U.S. Department

of Justice, Office of Community Oriented Policing

Services. Available at www.cops.usdoj.gov.

Sherman, L., and D. Rogan (1995). "Deterrent Effects of

Police Raids on Crack Houses: A Randomized, Controlled

Experiment." Justice Quarterly 12(4):755-781.

About the Author 49

About the Author

Rana Sampson

Rana Sampson is a national problem-oriented policing

consultant and the former director of public safety for the

University of San Diego. She was previously a White House

Fellow; National Institute of Justice Fellow; senior researcher

and trainer at the Police Executive Research Forum; attorney;

and patrol officer, undercover narcotics officer and patrol

sergeant with the New York City Police Department, where

she was awarded several commendations of merit and won

the National Improvement of Justice Award. She is the

coauthor (with Michael Scott) of Tackling Crime and Other

Public-Safety Problems: Case Studies in Problem-Solving, which

documents high-quality crime control efforts from around the

United States, Canada and Europe. She is a judge for the

Herman Goldstein Award for Excellence in ProblemOriented Policing, a former judge for the police Fulbright

awards, and a commissioner with California's Commission on

Peace Officer Standards and Training. Sampson holds a law

degree from Harvard and a bachelor's degree from Barnard

College, Columbia University.

Recommended Readings 51

Recommended Readings

• A Police Guide to Surveying Citizens and Their

Environments, Bureau of Justice Assistance, 1993. This

guide offers a practical introduction for police practitioners

to two types of surveys that police find useful: surveying

public opinion and surveying the physical environment. It

provides guidance on whether and how to conduct costeffective surveys.

• Assessing Responses to Problems: An Introductory

Guide for Police Problem-Solvers, by John E. Eck (U.S.

Department of Justice, Office of Community Oriented

Policing Services, 2001). This guide is a companion to the

Problem-Oriented Guides for Police series. It provides basic

guidance to measuring and assessing problem-oriented

policing efforts. Available at www.cops.usdoj.gov.

• Conducting Community Surveys, by Deborah Weisel

(Bureau of Justice Statistics and Office of Community

Oriented Policing Services, 1999). This guide, along with

accompanying computer software, provides practical, basic

pointers for police in conducting community surveys. The

document is also available at www.ojp.usdoj.gov/bjs.

• Crime Prevention Studies, edited by Ronald V. Clarke

(Criminal Justice Press, 1993, et seq.). This is a series of

volumes of applied and theoretical research on reducing

opportunities for crime. Many chapters are evaluations of

initiatives to reduce specific crime and disorder problems.
52 Drug Dealing in Privately Owned Apartment Complexes

• Excellence in Problem-Oriented Policing: The 1999

Herman Goldstein Award Winners. This document

produced by the National Institute of Justice in

collaboration with the Office of Community Oriented

Policing Services and the Police Executive Research Forum

provides detailed reports of the best submissions to the

annual award program that recognizes exemplary problemoriented responses to various community problems. A

similar publication is available for the award winners from

subsequent years. The documents are also available at

www.ojp.usdoj.gov/nij.

• Not Rocket Science? Problem-Solving and Crime

Reduction, by Tim Read and Nick Tilley (Home Office

Crime Reduction Research Series, 2000). Identifies and

describes the factors that make problem-solving effective or

ineffective as it is being practiced in police forces in

England and Wales.

• Opportunity Makes the Thief: Practical Theory for

Crime Prevention, by Marcus Felson and Ronald V. Clarke

(Home Office Police Research Series, Paper No. 98, 1998).

Explains how crime theories such as routine activity theory,

rational choice theory and crime pattern theory have

practical implications for the police in their efforts to

prevent crime.

• Problem-Oriented Policing, by Herman Goldstein

(McGraw-Hill, 1990, and Temple University Press, 1990).

Explains the principles and methods of problem-oriented

policing, provides examples of it in practice, and discusses

how a police agency can implement the concept.
Recommended Readings 53

• Problem-Oriented Policing: Reflections on the First 20

Years, by Michael S. Scott (U.S. Department of Justice,

Office of Community Oriented Policing Services, 2000).

Describes how the most critical elements of Herman

Goldstein's problem-oriented policing model have

developed in practice over its 20-year history, and proposes

future directions for problem-oriented policing. The report

is also available at www.cops.usdoj.gov.

• Problem-Solving: Problem-Oriented Policing in Newport

News, by John E. Eck and William Spelman (Police

Executive Research Forum, 1987). Explains the rationale

behind problem-oriented policing and the problem-solving

process, and provides examples of effective problemsolving in one agency.

• Problem-Solving Tips: A Guide to Reducing Crime and

Disorder Through Problem-Solving Partnerships, by

Karin Schmerler, Matt Perkins, Scott Phillips, Tammy

Rinehart and Meg Townsend (U.S. Department of Justice,

Office of Community Oriented Policing Services, 1998)

(also available at www.cops.usdoj.gov). Provides a brief

introduction to problem-solving, basic information on the

SARA model and detailed suggestions about the problemsolving process.

• Situational Crime Prevention: Successful Case Studies,

Second Edition, edited by Ronald V. Clarke (Harrow and

Heston, 1997). Explains the principles and methods of

situational crime prevention, and presents over 20 case
54 Drug Dealing in Privately Owned Apartment Complexes

studies of effective crime prevention initiatives.

• Tackling Crime and Other Public-Safety Problems: Case

Studies in Problem-Solving, by Rana Sampson and

Michael S. Scott (U.S. Department of Justice, Office of

Community Oriented Policing Services, 2000) (also available

at www.cops.usdoj.gov). Presents case studies of effective

police problem-solving on 18 types of crime and disorder

problems.

• Using Analysis for Problem-Solving: A Guidebook for

Law Enforcement, by Timothy S. Bynum (U.S.

Department of Justice, Office of Community Oriented

Policing Services, 2001). Provides an introduction for

police to analyzing problems within the context of

problem-oriented policing. Available at www.cops.usdoj.gov.

• Using Research: A Primer for Law Enforcement

Managers, Second Edition, by John E. Eck and Nancy G.

LaVigne (Police Executive Research Forum, 1994). Explains

many of the basics of research as it applies to police

management and problem-solving.
Other Guides in This Series 55

Other Guides in This Series

Problem-Oriented Guides for Police series (available at

www.cops.usdoj.gov):

1. Assaults in and Around Bars. Michael S. Scott. 2001.

2. Street Prostitution. Michael S. Scott. 2001.

3. Speeding in Residential Areas. Michael S. Scott. 2001.

4. Drug Dealing in Privately Owned Apartment Complexes.

Rana Sampson. 2001.

5. False Burglar Alarms. Rana Sampson. 2001.

6. Disorderly Youth in Public Places. Michael S. Scott. 2001.

7. Loud Car Stereos. Michael S. Scott. 2001.

8. Robbery at Automated Teller Machines. Michael S. Scott. 2001.

9. Graffiti. Deborah Lamm Weisel. 2002.

10. Thefts of and From Cars in Parking Facilities. Ronald V.

Clarke. 2002.

11. Shoplifting. Ronald V. Clarke. 2002.

12. Bullying in Schools. Rana Sampson. 2002.

13. Panhandling. Michael S. Scott. 2002.

14. Rave Parties. Michael S. Scott. 2002.

15. Burglary of Retail Establishments. Ronald V. Clarke. 2002.

16. Clandestine Drug Labs. Michael S. Scott. 2002.

17. Acquaintance Rape of College Students. Rana Sampson. 2002.

18. Burglary of Single-Family Houses. Deborah Lamm Weisel.

2002.

19. Misuse and Abuse of 911. Rana Sampson. 2002.

Companion guide to the Problem-Oriented Guides for Police series:

• Assessing Responses to Problems: An Introductory Guide for

Police Problem-Solvers. John E. Eck. 2002.
56 Drug Dealing in Privately Owned Apartment Complexes

Other Related COPS Office Publications

• Using Analysis for Problem-Solving: A Guidebook for Law

Enforcement. Timothy S. Bynum.

• Problem-Oriented Policing: Reflections on the First 20 Years.

Michael S. Scott. 2001.

• Tackling Crime and Other Public-Safety Problems: Case

Studies in Problem-Solving. Rana Sampson and Michael S. Scott.

2000.

• Community Policing, Community Justice, and Restorative

Justice: Exploring the Links for the Delivery of a Balanced

Approach to Public Safety. Caroline G. Nicholl. 1999.

• Toolbox for Implementing Restorative Justice and Advancing

Community Policing. Caroline G. Nicholl. 2000.

• Problem-Solving Tips: A Guide to Reducing Crime and

Disorder Through Problem-Solving Partnerships. Karin

Schmerler, Matt Perkins, Scott Phillips, Tammy Rinehart and

Meg Townsend. 1998.

For more information about the Problem-Oriented Guides for Police series

and other COPS Office publications, please call the Department of

Justice Response Center at 1.800.421.6770 or check our website at

www.cops.usdoj.gov.

FOR MORE INFORMATION:

U.S. Department of Justice

Office of Community Oriented Policing Services

1100 Vermont Avenue, NW

Washington, D.C. 20530

To obtain details on COPS programs, call the

U.S. Department of Justice Response Center at 1.800.421.6770

Visit the COPS internet web site by the address listed below.

e05021553 Created Date: June 03, 2002

www.cops.usdoj.gov