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103 Minn. L. Rev. 844, *913

202 See Perrin v. United States, 444 U.S. 37, 50 (1979) (broadly interpreting "bribery" in 18 U.S.C. § 1952 to include bribery of private individuals); supra Part III.B.1 and note 161 (citing Perrin in discussion of anti-corruption prosecutions under 18 U.S.C. § 1952).

203 See, e.g., Wis. Stat.§§175.47, 950.04(1v)(do), 950.08(2g)(h) (2014) (codifying Wis. Act 348 (2013)) (requiring investigations of "officer-involved deaths" to be conducted by investigators from a different agency).

204 See Data Collection: Mortality in Correctional Institutes (MCI) (Formerly Deaths in Custody Reporting Program (DCRP)), Bureau Just. Stat., https://www.bjs.gov/index.cfm?ty=dcdetail&iid=243 (last visited Oct. 30, 2018) (providing data collection since 2000 for jails, since 2001 for prisons, and since 2003 during arrests). The Death in Custody Reporting Act of 2000, 42 U.S.C. § 13704 (2006), required local agencies to report deaths until it lapsed in 2006. Hunter Schwartz, Congress Decides to Get Serious About Tracking Police Shootings, Wash. Post (Dec. 11, 2014), https://www.washingtonpost.com/news/post-politics/wp/2014/12/11/congress-decides-to-get-serious-about-tracking - police-shootings. It was renewed in 2014. Death in Custody Act of 2013, Pub. L. 113-242, 128 Stat. 2860 (codified as amended in scattered sections of 42 U.S.C). In the interim years, the Bureau collected data voluntarily reported by local agencies. Pete Kasperowicz, House Bill Would Require States to Report on Prisoner Deaths, Hill (Dec. 6, 2013), https://thehill.com/blogs/floor-action/government-oversight/192354-house-to-require-states-to-report-on-prisoner -deaths.

205 See supra note 113.

206 E.g., Ed Krayewski, Prosecutors in Chicago, Cleveland Lose Re-Election Bids After Police Abuse Controversies, Reason (Mar. 16, 2016), http://reason .com/blog/2016/03/16/prosecutors-in-chicago-cleveland-lose-re.

207 Id.; see also Justin Glawe, Anita Alvarez, Chicago's Top Prosecutor, Cleared Killer Cops 68 Times, Daily Beast (Mar. 14, 2016), http://www .thedailybeast.com/articles/2016/03/14/anita-alvarez-chicago-s-top-prosecutor -cleared-killer-cops-68-times.html.

208 See Manslaughter Conviction for Ex-Officer, N.Y. Times, Aug. 5, 2016, at A15; Richard Perez-Pena, Officer Indicted in Shooting Death of Unarmed Man, N.Y. Times, July 30, 2015, at A1; Mark Berman, Minn. Officer Acquitted in Shooting of Philando Castile During Traffic Stop, Dismissed From Police Force, Wash. Post (June 17, 2017), https://www.washingtonpost.com/news/post -nation/wp/2017/06/16/minn-officer-acquitted-of-manslaughter-for-shooting -philando-castile-during-traffic-stop; Chris Dixon, Ex-Officer Seeks Bond in Shooting Death of Walter Scott, N.Y. Times (Sept. 11, 2015), https://www. nytimes.com/2015/09/12/us/officer-seeks-bond-in-shooting-death-of-walter - scott.html (stating that officer was charged with murder); Wil S. Hylton, Baltimore vs. Marilyn Mosby, N.Y. Times Mag. (Sept. 28, 2016), https://www.nytimes.com/2016/10/02/magazine /marilyn-mosby-freddie-gray-baltimore.html (describing the failure to convict any of six officers indicted for the April 2015 death of Freddie Gray); Justin Juozapavicius, Tulsa Officer Acquitted In Man's Shooting Death Is Returning To The Police Force, Associated Press (May 19, 2017), https://www.apnews.com/9af40bcdbbd84f6e95fb3a430d4016c0.

209 Monica Davey & Mitch Smith, Justice Department Is Expected to Investigate Chicago Police, N.Y. Times, Dec. 7, 2015, at A10 (reporting on the Justice Department's investigation into the patterns and practices of the Chicago Police Department in the wake of Laquan McDonald shooting); Mitch Smith, Chicago Officer Pleads Not Guilty to Charge of Murder in Death of a Teenager, N.Y. Times, Dec. 30, 2015, at A12 (stating that a police officer was charged for the 2014 fatal shooting of a teenager just before video footage of the incident was released).

210 For one notable political response, see La. Stat. Ann. §§14:107.2(A), (E) (2018) (creating the "Blue Lives Matter" law); Kevin Conlon, Louisiana Governor Signs "Blue Lives Matter' Bill, CNN (May 27, 2016), https://www.cnn.com/2016/05/26/us/louisiana-blue-lives-matter-law/index.html (describing passage of House Bill 953).

211 See, e.g., W. David Ball, Tough on Crime (on the State's Dime): How Violent Crime Does Not Drive California Counties' Incarceration Rates - And Why It Should, 28 Ga. St. U. L. Rev. 987, 1018-34 (2012) (analyzing data from 2000-2009 and describing how county-level criminal justice officials, including prosecutors, vary greatly in their use of state incarceration as a response to crime); Erika Martin, While Some California DAs Are Throwing Out Old Pot Convictions, L.A. County's Jackie Lacey Takes a Different Path, KTLA5 (Feb. 3, 2018), https://ktla.com/2018/02/03/while-some-california-das-are-throwing-out -old-pot-convictions-angelenos-will-have-to-be-proactive-in-clearing-records (describing different policies among California district attorneys on expungement of marijuana offenses); cf. Civil Rights Div., U.S. Dep't of Justice, Investigation of the Ferguson Police Department 10-15 (2015), https://www.justice.gov/sites/default/files/opa/press-releases/attachments/2015/03/04/ferguson_police_department_report.pdf (describing prosecution policies motivated by revenue-generating goals).

212 The alternative of administrative review within the Crown Prosecution Service relies on whatever independence is sustained by the bureaucratic hierarchy, administrative regulations, and professional norms. See supra note 111 and accompanying text.

DAVID SCHOEN
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