Leadership Conference Comments on National Use of Force Data Collection

Census and Data Equity Resources, Justice Reform Resources 05.29.25

View a PDF of the comments here.

May 29, 2025

Linda Shriver

Acting Unit Chief, Crime and Law Enforcement Statistics Unit
FBI, CJIS Division, Module D-2
1000 Custer Hollow Road
Clarksburg, West Virginia 26306

RE: Response to OMB No. 1110-0071, Extension of National Use-of-Force Data Collection

Dear Acting Unit Chief Shriver,

On behalf of The Leadership Conference on Civil and Human Rights, a coalition charged by its diverse membership of more than 240 national organizations to promote and protect the civil and human rights of all persons in the United States, we write in response to the request for comments regarding the extension of the National Use-of-Force Data Collection by the Federal Bureau of Investigation’s (FBI) Uniform Crime Reporting (UCR) program. We strongly support the extension and continuation of this collection, as robust data collection is critical to making informed policy decisions, ensuring government accountability, and rebuilding public trust in law enforcement and the criminal-legal system.

The comprehensive collection of data is essential to efficient governance and quality policymaking. With reliable data, policymakers are less likely to waste taxpayer funds on ineffective policies. Data collection can provide evidence that helps the federal government track trends, decide where best to focus resources, and develop and adopt best practices. Government cannot be efficient if it does not collect and rely upon comprehensive and accurate data.

The Leadership Conference and its partners have long fought for comprehensive data collection about deaths in custody and deaths and injuries caused by law enforcement use of force.[1] Use of deadly force by police has increased over the past years and disproportionately affects Black and Brown communities.[2] The ongoing lack of consistent, public data on these incidents has contributed to a crisis in public confidence, particularly among communities of color. As law enforcement officers are public servants with the ability to utilize firearms and force, law enforcement agencies have an obligation to account for their actions with data reporting, and the federal government has an obligation to gather and use this data in its work. Knowing the number and circumstances of police use of force and firearm discharge is crucial to developing policies that could reduce the number of such use-of-force incidents. This data is also critical to providing the public and the Department of Justice (DOJ) the information needed to ensure law enforcement agencies are complying with civil rights laws and to assisting DOJ with fulfilling its enforcement responsibilities. Without comprehensive data on use-of-force incidents, there can be no accountability for unlawful actions.

While we appreciate that data collection could pose some burden for law enforcement agencies and the federal government, it is absolutely critical that DOJ and OMB not prioritize burden alleviation over complete, accurate, and transparent data about police use of force and firearm discharge. There is no higher purpose of government than protecting its people, and a comprehensive accounting of the killing or use of force by public servants is essential to fulfilling that purpose and enhancing government transparency. In fact, we believe that this collection could be improved if reporting were mandatory and if more disaggregated data reported by law enforcement was shared with the public.

We urge you to extend the UCR National Use-of-Force Collection, as gathering  data is critical to government transparency, accountability, and efficiency, and is a key part of the federal government’s obligation to protect all its people. If you have any questions, please contact Chloé White, senior policy counsel, justice, at [email protected].

Sincerely,

Jesselyn McCurdy
Executive Vice President of Government Affairs

 

[1] See, e.g., “Recommendations for DOJ to Improve Death in Custody Reporting.” Project on Government Oversight and The Leadership Conference on Civil and Human Rights. March 8, 2024. https://www.pogo.org/policy-letters/recommendations-for-doj-to-improve-death-in-custody-reporting;  “Civil Rights Groups Launch National Database on Police Use of Force.” The Leadership Conference on Civil and Human Rights. Feb. 11, 2021. https://civilrights.org/2021/02/11/civil-rights-group-launches-national-database-on-police-use-of-force/.  “Comments on the Death in Custody Reporting Act of 2013 (DCRA).” The Leadership Conference on Civil and Human Rights. Aug. 7, 2018. https://civilrights.org/resource/comments-on-the-death-in-custody-reporting-act-of-2013-dcra/.

[2] Rich, Steven, et al. “Since George Floyd’s Murder, Police Killings Keep Rising, Not Falling.” The New York Times. May 24, 2025. https://www.nytimes.com/2025/05/24/us/police-killings-george-floyd.html.