Is Gang Membership a Crime? How RICO Laws Turn Groups into Gangs

By Kerry Martin

Associate Editor, Vol. 24


On June 18, 2018, in a courtroom at the Theodore Levin U.S. Courthouse in downtown Detroit, at the end of a long pretrial argument on a matter of evidence, defendant Corey Bailey stood up. The courtroom was nearly full: this was preparation for the blockbuster trial of the summer in Michigan’s Eastern District, the case of the Seven Mile Bloods.[1] Bailey had been sitting near the end of a long table of with his co-defendants, all Black, and each of their defense attorneys, almost all White. The attorneys had been vocal and at times irate during the proceeding, but the defendants had all sat in silence—until Bailey stood up and spoke.

“Your Honor,” he said, turning to Judge George Steeh. He stated some of his thoughts about the case as a whole, and then said this: “I’m okay with being a Seven Mile Blood, because that’s not a crime.”[2]

Is he right?

His argument is an uphill battle against the statute under which he and his co-defendants were all charged: conspiracy under the Racketeer Influenced and Corrupt Organizations Act, or RICO conspiracy.[3] A law that gained recognition as prosecutors’ most powerful tool against the highly organized and hierarchical Italian mafia, RICO conspiracy has now been stretched far beyond that.[4] RICO conspiracy is now used as a blunt instrument for sweeping up young men of color who are in any way associated with the one of the many small-fry “gangs” that have filled the void of organized crime in many American cities, including Detroit.[5] It is not supposed to criminalize mere membership in a gang, but it comes dangerously close to doing so.

RICO conspiracy comes with the astronomical sentences—up to twenty years in prison, which can be bumped up to life in prison or the death penalty by aggravating circumstances.

This expansion of RICO conspiracy is the result of legal and social realities. The legal realities are the vague, minimal elements of the RICO conspiracy statute and the breadth with which courts have chosen to read it.[6] The social reality is that when groups of low-income racial minorities spend time together and adopt symbols to signify their unity, sometimes but not always including a “gang” title, law enforcement will view each one of them as a “gang member” with its full criminal stigma.

Both of those realities came to bear in the Seven Mile Bloods case. The last indictment before trial charged all twenty-one defendants with RICO conspiracy.[7] So far, only two have been acquitted of RICO conspiracy, and two others have entered pleas of not guilty.[8] At least nine others have pleaded guilty to RICO conspiracy, and four more have been found guilty of RICO conspiracy by a jury, including Corey Bailey.[9] This high conviction rate is attributable to the ease with which prosecutors can prove the elements of RICO conspiracy, especially when a defendant’s professed gang membership is clear.

The elements of criminal RICO conspiracy are easily met. The statute simply states that “[i]t shall be unlawful for any person to conspire to violate” any of the substantive racketeering provisions described earlier in the statute.[10] Racketeering encompasses a broad array of crimes, including drug trafficking, robbery, and murder, whether completed or attempted.[11]

Case law has broken the RICO conspiracy statute down into five essential elements:

  1. That the association in question existed as an enterprise;
  2. That the activities of the enterprise affected interstate commerce;
  3. That the defendant associated with the enterprise;
  4. That the defendant knowingly agreed to participate in the conduct of the enterprise; and
  5. That the defendant and at least one other conspirator agreed that either the defendant or a co-conspirator would commit at least two acts of racketeering in furtherance of the enterprise.[12]

This fifth element is the closest thing to an “overt act” requirement, but it is a very low hurdle: the “agreement” can simply be an understanding between a defendant and any other alleged gang member that anyone in the gang would commit two racketeering acts.

For example, if Adam agrees on two occasions to help his co-gang-member Bob sell drugs, maybe by referring two buyers to Bob, then Adam has become liable for this fifth element of RICO conspiracy—and most likely liable for all other elements. Adam need not have committed any acts besides this, but as long as some kind of “enterprise” exists (like a “gang”), and Adam associated with the enterprise (which can be inferred from gang signs, colors, tattoos, social media posts, and more[13]), and Adam agreed to participate in its conduct (which can be inferred from the agreement to commit two acts of racketeering[14]), then Adam is guilty of RICO conspiracy, punishable by up to 20 years in prison.

The U.S. Supreme Court has upheld this broad interpretation of RICO conspiracy. In Salinas v. United States, Justice Kennedy wrote for the unanimous court:

Section 1962(d) . . . is even more comprehensive than the general conspiracy provision applicable to federal crimes . . . since it contains no requirement of an overt or specific act . . . [RICO] conspiracy may exist and be punished whether or not the substantive crime ensues, for the conspiracy is a distinct evil, dangerous to the public, and so punishable in itself.[15]

U.S. attorneys seem to have taken this reading of RICO conspiracy as carte blanche from the highest court in the land. Accordingly, lower courts have been loathe to place limits on liability for RICO conspiracy, and instead have rubber-stamped its use as a prosecutorial dragnet.[16] This judicial erosion of the elements of RICO conspiracy has turned the statute into more powerful a weapon than was ever intended. For prosecutors nowadays, RICO conspiracy is like fishing with dynamite.

Take the 2014 case United States v. Campbell.[17] Three allegations were made against Edward Campbell to support a charge of RICO conspiracy: “that he regularly sold cocaine and marijuana, that he had been found in possession of a plastic bag containing numerous individually wrapped bags of crack cocaine, and that a photograph posted to a MySpace page showed him making a hand sign signifying membership in [a gang].”[18]

As evidence, one gang member witness testified that “he saw Campbell sell cocaine at a ‘dope house’ run by Campbell’s co-defendant, an alleged leader of the enterprise.”[19] When Campbell was found with the bags of crack, his cousin, another gang member, was in the apartment.[20] And one witness’s testimony also alleged that Campbell participated in a drive-by shooting, which Campbell denied.[21] Despite there being no further evidence that these acts were done in furtherance of the gang, the court affirmed his conviction for RICO conspiracy, ruling that a “rational juror could infer from this evidence that Campbell agreed that he or someone else would commit two RICO predicate acts.”[22]

Is this what the law of RICO conspiracy was designed for? To maximize sentences for drug and gun offenses for anyone who dares associate in any way with a gang? Federal sentences for drug and gun crimes are high enough already.[23] I find it difficult to see the added value of charging RICO conspiracy in many of these cases—other than to assist an inference of guilt-by-association.

Perhaps that is what makes RICO conspiracy such a powerful tool: it is a crime with a built-in propensity inference. Normally, the rule against character evidence works to prevent juries from thinking that a defendant is the “kind of person” more likely to do something.[24] But in RICO conspiracy, being that “kind of person” is essentially an element of the crime. Charging RICO conspiracy makes all evidence that carries even a hint of gang relation relevant and admissible.[25]

This type of evidence inflames racial bias. Tattoos and hand signals on Black and Brown bodies are more likely to be viewed as gang-related. Boasts of crime by Black and Brown rappers in their lyrics and music videos are more likely to be taken at face value. Symbols, emojis, and slang by Black and Brown social media users are more likely to be construed as coded language between gang members. Would any of this be true if the defendants were White?

Charges of RICO conspiracy lay bare an entire life: how you dress, what your tattoos and rap lyrics mean, what you post online, where you spend your free-time, who your friends and family are. All of this is on table for prosecutors as they cook their story of how you furthered your gang’s activities. With racial bias working in prosecutors’ favor, a RICO conviction is an easy win. And if it goes to a jury and they don’t get you for RICO, they still might see enough evidence of what a bad person you are to make them think that you deserve to get locked up anyway.

Maybe it is a crime to be a Seven Mile Blood.

[1] For a detailed, multi-part exposé on the Seven Mile Bloods case, see Robert Snell, Death By Instagram, Dᴇᴛʀᴏɪᴛ Fʀᴇᴇ Pʀᴇꜱꜱ, April 2018,

[2] Based on the writer’s personal observations.

[3] 18 U.S.C. § 1962(d).

[4] See Tʜᴇ Mᴏʙ Mᴜꜱᴇᴜᴍ, Rudolph Giuliani, (“Giuliani decided to prosecute the leaders of the [Italian mafia] families and their upper-level cohorts together under the federal Racketeer Influenced and Corrupt Organizations Act, or RICO, for allegedly conspiring to commit felonies including contract murders, loan sharking, extortion, labor racketeering and drug trafficking. It was the first time RICO, passed by Congress in 1970, was employed to prosecute a major federal case.”)

[5] Jordan Blair Woods, Systemic Racial Bias and RICO’s Application to Criminal Street and Prison Gangs, Mɪᴄʜ. J. ᴏꜰ Rᴀᴄᴇ & Lᴀᴡ 303 (2012).

[6] See, e.g., Salinas v. United States, 522 U.S. 52 (1997).

[7] Sixth Superseding Indictment at 2, United States v. Arnold et al., No. 15-20652 (E.D. Mich. 2018), ECF No. 812.

[8] Ascertained by studying the electronic docket in United States v. Arnold et al., No. 15-20652 (E.D. Mich. 2018),

[9] Id.; see also U.S. Dep’t of Justice, Four Members of the Seven Mile Bloods Street Gang Convicted of Racketeering and Other Related Offenses, Aug. 27, 2018,

[10] 18 U.S.C. § 1962.

[11] 18 U.S.C. § 1961(1)(A, D)

[12] See, e.g., United States v. Jefferson, No. 14-20119, 2016 WL 337021, at *3 (E.D. Mich. Jan. 28, 2016), aff’d sub nom. United States v. Johnson, No. 1538, 2018 WL 1137518 (6th Cir. Mar. 2, 2018).

[13] See, e.g., United States v. Rios, 830 F.3d 403, 421 (6th Cir. 2016), cert. denied sub nom. Casillas v. United States, 137 S. Ct. 1120, (2017) (“Gang-affiliation evidence may be highly probative of an individual’s membership in a particular gang, so it has been held admissible, in cases where the interrelationship between people is a central issue”) (internal quotation marks omitted); see also Sarah Baumgartel, The Crime of Associating with Criminals? An Argument for Extending the Reves “Operation or Management” Test to Rico Conspiracy, 97 J. Cʀɪᴍ. L. & Cʀɪᴍɪɴᴏʟᴏɢʏ 1 (2006).

[14] See, e.g., United States v. Sinito, 723 F.2d 1250, 1261 (6th Cir. 1983) (“An agreement can be shown if the defendant objectively manifested an agreement to participate directly or indirectly in the affairs of an enterprise through the commission of two or more predicate crimes.”) (internal quotation marks omitted); United States v. Hughes, 895 F.2d 1135, 1141 (6th Cir. 1990) (“Defendants’ agreement to participate in the RICO conspiracy may be inferred from their acts.”).

[15] Salinas, 522 U.S. at 53, 66.

[16] See, e.g., United States v. Hughes, 895 F.2d 1135, 1140 (6th Cir. 1990) (“A conspirator need not have agreed to commit every crime within the scope of the conspiracy, so long as it is reasonable to infer that each crime was intended to further the enterprise’s affairs . . . Moreover, it is not necessary for each conspirator to participate in every phase of the criminal venture, provided there is assent to contribute to a common enterprise.”); Sinito, 723 F.2d at 1261 (“It is unnecessary that the underlying predicate acts be interrelated as long as the acts are connected to the affairs of the enterprise.”).

[17] United States v. Campbell, 567 F. App’x 422 (6th Cir. 2014).

[18] Id. at 423.

[19] Id.

[20] Id.

[21] Id. at 424.

[22] Id.

[23] See, e.g., Jon Schuppe, As Drug Sentencing Debate Rages, ‘Ridiculous’ Sentences Persist, NBC Nᴇᴡꜱ, May 2, 2016, (“Intended to sideline high-level traffickers, [federal mandatory minimum sentences] have been used to sweep thousands of nonviolent, small-time offenders into epic prison terms.”); Rachel Weiner, Judge Laments 40-year Sentence for Meth Dealer as ‘Excessive’ and ‘Wrong’, Tʜᴇ Wᴀꜱʜɪɴɢᴛᴏɴ Pᴏꜱᴛ, July 2, 2018, (“There was no evidence that Turner carried a gun or was involved in a situation where guns were used. But [Turner being in the presence of guns] resulted in convictions on two counts of having a firearm while dealing drugs. That extended his sentence by 30 years, because the two mandatory minimum sentences — five years for a first offense and 25 for a second — must run consecutive to the 10-year mandatory minimum for his two drug crimes.”).

[24] Fed. R. Evid. 404(a)(1) (“Evidence of a person’s character or character trait is not admissible to prove that on a particular occasion the person acted in accordance with the character or trait.”); cf. Fed. R. Evid. 403 (“The court may exclude relevant evidence if its probative value is substantially outweighed by a danger of . . . unfair prejudice . . . .”).

[25] RICO conspiracy most likely facilitates the admission of otherwise-inadmissible evidence through the carve-out in Rule 404(b)(2): “This evidence may be admissible for another purpose, such as proving motive, opportunity, intent, preparation, plan, knowledge, identity, absence of mistake, or lack of accident.” Fed. R. Evid. 404(b)(2).

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Arbitrary Paternalism and the SEC Accredited-Investor Standard

By Leah Duncan

Associate Editor, Vol. 24

Seal_of_the_United_States_Securities_and_Exchange_Commission.svgIn developing the current accredited investor requirements to balance competing considerations of investor protection and capital formation, the Securities and Exchange Commission has used proxies that give rise to discrimination against communities of color.[1] While this problem is on its face economic in nature, I will approach it through the lens of race and ethnicity to illuminate the ways in which the accredited investor requirement excludes communities of color from avenues to wealth.

Pursuant to the Securities Act of 1933, the SEC requires that a company or private fund either register the sale or offering of their securities or be exempted based on a safe harbor regulation. Section 4(a)(2) of the Act provides an exemption for private sales which are further governed by Regulation D requirements that dictate purchasers must be “accredited investors.”

So, what does it mean to be an accredited investor? The SEC defines an accredited investor as anyone who “has a net worth over $1 million alone or together with a spouse” or someone who “has earned income that exceeded $200,000 or $300,000 together with a spouse in each of the prior two years, and reasonably expects the same for the current year.”[2] In order for a person to invest in a private security offering, they must comply with at least one of these requirements. The goals of these requirements include protection of investors and the facilitation of capital formation.[3] The SEC has had to grapple with how to balance these two aims. Over-protection of investors could make it more burdensome for some investors to participate in the capital markets. While too much focus on facilitating capital formation may leave investors prey to heightened risk of financial harm. With these concerns in mind, the SEC has decided that income and net-worth “serve as proxies for financial experience, sophistication, and adequate bargaining power.”[4]

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What the Passage of Michigan’s Proposal One Means for Black and Latinx People

By Elizabeth Morales-Saucedo

Associate Editor, Vol. 24

Marijuana-Legalization-e1477695073120-680x380On November 6, 2018, 56% of Michigan voters supported the passage of Proposal One approving the legalization of recreational use and possession of marijuana by persons 21 and older.[1] Michigan is the tenth state in the United States, and the first state in the Midwest, to legalize the recreational use of marijuana.[2] The initiative is set to become law by November 26, 2018, according to Secretary of State spokesman Fred Woodhams.[3] Before Michigan residents ‘light up,’ however, caution is advised as marijuana is still an illegal substance under federal law.[4] This advice is particularly true for Black and Latinx people who will likely continue to face higher arrest rates for marijuana than white people after its legalization.[5]

As Michigan is the tenth state to legalize marijuana, some lessons can be learned from the experiences of previous states who passed similar legislation. Specifically, data collected from Colorado, Alaska, and Washington, D.C. helps answer the question; what does the passage of Proposal One mean for Michigan and its communities of color?

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California’s Efforts to Reform Bail Leaves Much to be Desired

By Jules Hayer

Associate Editor, Vol. 24

California Governor Jerry Brown Addresses Dept. Of Justice Lawsuit Against CaliforniaDespite recent developments in California to overhaul the bail system, the state still has a long way to go in order to create effective change. In January of this year the California Court of Appeals ruled that, before setting bail, judges must take into account the financial situation of a defendant and determine whether the defendant can be released without imposing a danger to public safety.[1] Moreover, the prosecution bears the burden of presenting clear and convincing evidence which establishes that no conditions of release would ensure the safety of the community, thus requiring the confinement of the person while awaiting trial.[2]

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How Jeff Sessions is Quietly Transforming Immigration Law to Promote His Anti-Immigrant Agenda

By Samantha Kulhanek

Associate Editor, Vol. 24

Seal_of_the_Executive_Office_for_Immigration_ReviewThe Attorney General’s authority to refer Board of Immigration Appeals (“BIA”) decisions to himself for review was established via regulation in 1940,[1] and yet this power appears to be receiving more attention today than it ever has.[2] The appointment of Jeff Sessions as Attorney General prompted a string of these unique reviews,[3] in which Sessions has attempted to profoundly alter the way immigration courts interpret certain provisions of the Immigration & Nationality Act (“INA”).

The most publicized example of Sessions’s exercise of this referral power thus far has been his decision in Matter of A-B-, where he attempted to effectively narrow the circumstances in which individuals fleeing gang violence or domestic abuse may receive asylum in the U.S.[4] However, some of Sessions’s other decisions resulting from his use of the referral power have received relatively little attention, and yet may have massive consequences for the immigration system. Three decisions in particular have attacked the discretion of immigration judges and threaten to interfere with their judicial independence and how they handle their dockets.

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Countering Violent Extremism Under the Trump Administration: The True Focus is Minority Communities, Not Domestic Extremism

By Mackenzie Walz

Associate Editor, Vol. 24

PF_17.07.26_MuslimAmericans_lede_640x320Through the Homeland Security Act of 2002, Congress established the prevention of domestic terrorist attacks as one of the Department of Homeland Security’s primary missions and appropriated ten million dollars “for a countering violent extremism (CVE) initiative to help states and local communities” combat these threats.[1] Pursuant to the Act, in 2011 the Obama Administration created and implemented the “first national strategy” to prevent domestic violent extremism, entitled “Empowering Local Partners to Prevent Violent Extremism in the United States.”[2] Taking a community-based approach, the program was designed to distribute federal funds to local organizations – educational institutions, non-profits, or law enforcement agencies – which would provide community members with the requisite resources and education to identify signs of extremist radicalization.[3] The ultimate goal was for community members and local leaders to develop relationships of trust through this engagement, which would empower community members, once educated, to report any identified signs of extremism.[4]

While the program was designed to combat all types of violent extremism, in operation and effect it targeted Muslim-American communities.[5] Instead of building relationships of trust between community members and these local leaders, as it was intended to do, it bred mistrust, as the program in some communities “appeared to be doubling as a means of surveillance.”[6] This mistrust made some members of the Muslim-American community hesitant to reach out to law enforcement officers to report signs of radicalization,[7] rendering the outreach program less effective.

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Department of Education Reopens Anti-Discrimination Case, Sparks Controversy

By Rose Lapp

Associate Editor, Volume 24

NR09WaksmanInstitute3254_pgIn 2011, The Zionist Organization of America filed a religious discrimination claim against Rutgers University with the Department of Education Office of Civil Rights (“OCR”). The complaint had three claims. One of these claims, the one being addressed by the Department of Education and by this piece, arose out of an event held on campus by a pro-Palestinian group.[1] Allegedly, there was originally free admission to the event, but the organizers began charging admission “only after [they] observed ‘150 Zionists’ who ‘just showed up.’”[2]

Under Title VI of the Civil Rights Act of 1964, OCR has jurisdiction over discrimination on the basis of race, color and national origin.[3] Under Title IX of the Educational Amendments of 1972, the office has jurisdiction over sex discrimination claims.[4] Section 504 of the Rehabilitation Act of 1973 and the Age Discrimination Act of 1975 gives OCR jurisdiction over discrimination on the basis of disability and discrimination on the basis of age, respectively.[5] The office does not, however, have jurisdiction over religious discrimination claims.

In 2014, on the grounds that there was insufficient evidence of discrimination on the basis of national origin, the Department of Education closed the case.[6] However, now four years later, Kenneth Marcus, the current Assistant Secretary for the Office of Civil Rights at the Department of Education, has reopened the case.[7] He has indicated that he will reexamine the complaint as “possible discrimination against an ethnic group,”[8] and has expanded the definition of anti-Semitism in the OCR context to a “working definition” that is used in other government agencies.[9] This definition includes “denying the Jewish people their right to self-determination” and “applying double standards by requiring of it a behavior not expected or demanded of any other democratic nation.”[10] These changes will likely have serious consequences for discrimination claims brought by Jewish students.

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Trump’s Efforts to Deport People Back to “Sh**hole” Countries Stalled by Equal Protection Clause

By Kerry Martin

Associate Editor, Vol. 24

TPSHow racist can the President of the United States be in determining immigration policy before he violates the Equal Protection Clause? A lot depends on who the target is—and with recipients of temporary protected status, Trump may have picked on the wrong people.

Donald Trump announced his candidacy with anti-Latino animus (“When Mexico sends its people…”)[1] and has not backed down since entering the White House. In response to allegations of crime by Central American immigrants on Long Island, President Trump remarked: “They come from Central America. They’re tougher than any people you’ve ever met. They’re killing and raping everybody out there.”[2] Of Haitians, Trump said they “all have AIDS”[3] and asked, “why do we need more Haitians?”[4] And in response to an immigration proposal that would have included protections for Salvadorans, Haitians, and some Africans, Trump inquired, “Why are we having all these people from shithole countries come here?”[5]

This racial animus seems inextricable from every immigration policy decision made by the Trump Administration, from ramping up internal enforcement and border protection, to pushing for legislation that would curb “chain migration” and fund a border wall. But it has proven difficult, at least for purposes of stating a legal claim, to tie these broad-sweeping policy choices to Trump’s racist statements, even if “[e]veryone knows”[6] that the two are related.

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Do Indigent and Incarcerated Women Have a Real Right to Reproductive Justice?

By Hira Baig
Associate Editor, Volume 23


Reproductive justice is not just concerned with women having access to the healthcare they need, it is also concerned with the disparate impact caused by restrictions on reproductive healthcare. Historically, the more restrictions the Court allows on abortion, the more challenging it becomes for indigent women, women of color, and incarcerated women to get the healthcare they need. In order to achieve reproductive justice, scholars and advocates alike ought to think of a comprehensive way to help all women access the reproductive healthcare they need before, during, and even after pregnancy.

Currently, the doctrine surrounding reproductive healthcare, primarily abortion, does not account for women’s social contexts and allows restrictions that keep minority and indigent women from enjoying equal protection of the laws. It comes as no surprise that indigent women face severe restrictions when trying to access abortion. Incarcerated women, however, face even greater hurdles.

Today, prisons and jails in the United States confine approximately 206,000 women.[1] Approximately 6-10% of women are already pregnant when they enter a prison or jail.[2] Doctor visits for pregnant women in prison are infrequent, with only 54% of women who reported being pregnant in state prisons receiving pregnancy care.[3]

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The End of Mass Incarceration: A Blueprint for Transformative Change

By Rasheed Stewart
Associate Editor, Vol. 23

He sued the Philadelphia Police Department over 75 times.[1]  As a career civil rights and criminal defense attorney he routinely represented individuals subjected to the oppressive forces of racism pervading law enforcement and the criminal justice system.[2] His nationally acclaimed representation of arrested protestors involved with the “Black Lives Matter” movement solidified his reputation among black and brown people as an authentic, hard-nosed movement lawyer.[3]  And now, as Philadelphia’s District Attorney, Larry Krasner has managed to put forth a radical, yet replicable platform for ending mass incarceration.

Within three months, Krasner has issued several of the most transformative policies that any prosecutor in U.S. history has dared to even imagine.  Rather unsurprisingly, Krasner’s new policies have quickly managed to enrage union leaders of the Philadelphia Fraternal Order of Police,[4] while simultaneously galvanizing influential civil rights activists like Shaun King, in supporting his vision for systemic change.[5]  To demonstrate his unrelenting approach to transformative change, Krasner has hit the ground running with a flurry of noteworthy edicts.  First, to “broadly reorganize the office’s structure and implement cultural change,” Krasner dismissed 31 members of the office just three days into office, including trial attorneys and several supervisor level staff members.[6]  Second, in responding to a judge’s order, Krasner publicly released a secret list of current and former police officers whom prosecutors have sought to keep off the witness stand after a review determined they had a long history of lying, racial bias, or brutality.[7]  Moreover, Krasner’s ‘Do Not Call’ list now legitimately sends the foreboding message that cronyism between police officers and ADA’s have no place in an ethically transformed criminal justice system.

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