Reforming Queensland’s police complaints system: recent inquiries and the prospects of a best practice model

ABSTRACT This paper critiques three recent inquiries and recommended changes in practice around the management of complaints against police in the state of Queensland, Australia, with a view to advancing a best practice model internationally. A civilian oversight system, closely aligned to a ‘civilian control’ model, was introduced in Queensland as part of a reform program following the 1989 Fitzgerald Inquiry into police corruption. However, external control of complaints was almost completely eroded over a 30-year period. The resumption of police control resulted in recurring scandals and widespread stakeholder disaffection. These issues came to a head and were addressed to varying degrees through three inquiries across 2022: the Review of Culture and Accountability in the Queensland Public Sector (‘Coaldrake Review’), the Commission of Inquiry relating to the Crime and Corruption Commission (‘Fitzgerald and Wilson Inquiry’) and, in particular, the Commission of Inquiry into Queensland Police Service Responses to Domestic and Family Violence (‘Richards Inquiry’). The combined findings and recommendations demonstrated the need for rigorous institutional independence and transparency in the processing of complaints, along with a range of complementary integrity management strategies to ensure adequate accountability of police.

civilian oversight of police; complaints against police; mediation of complaints against police; police accountability; police integrity; police misconduct.

Background
Police reforms in post-Fitzgerald Queensland have been the subject of extensive scholarship, including national and international interest in the state's anti-corruption commission as a possible model agency suitable for adoption in other locations (Lewis, Ransley, & Homel, 2010;Liberty, 2000;Ransley & Johnstone, 2009). The 1987 Inquiry' into the Queensland Police identified pervasive corruption reinforced through a failed system of police investigating police. Fitzgerald (1989) described the police Internal Investigations Section as: The Fitzgerald Report recommended wide-ranging reforms, including the establishment of a powerful anti-corruption commission, which put the investigation and adjudication of allegations against police in the hands of an independent civilian agency. However, over the decades, the jurisdiction of the commission was eroded through a combination of external political influences and internal cultural factors, so that by the 2020s, the commission was largely a shell of its former self. Associated problems of recurring scandals and declining stakeholder confidence across the public sector led to a crisis situation in the early 2020s, forcing the state government to instigate a series of major inquiries.
The present study focuses on the findings and recommendations of the three official examinations of integrity issues occurring in 2022. The topic is salient both across Australia and internationally, given the constant problems of police misconduct and the challenges of the democratic management of the police. It would seem that a key part of the solution to ensuring optimal police integrity is to create a complaints management system that is fair and independent and also able to contribute to a broader set of integrity management strategies that minimise the use of force and build resilience against corruption.

Civilian oversight of police
Policing is widely recognised as an activity that attracts large numbers of citizen complaints. Scholars have identified the task environment-including exercising authority, depriving persons of their liberty and intervening in disputes-as the main source of intense pressures and temptations towards misconduct ( van Dijk, Hoogewoning, & Punch, 2015). Under modern compulsory disclosure regimes-designed to break the traditional culture of silence, solidarity and cover ups-internal allegations and reports are also generated in large numbers (Porter, Prenzler, & Fleming, 2012). How to manage and try to reduce the large and diverse numbers of complaints and allegations against police is a major policy challenge for governments. Police complaints systems have been analysed using various typologies depending on the levels of internal versus external involvement in investigations and adjudication. Prenzler and Ronken's (2001) three-part model has been adopted in recent years by scholars and government reviews (eg, Parliament of Victoria, 2018;Puddister & McNabb, 2021;Savage, 2013). The model refers to (1) 'internal affairs', (2) 'civilian review' and (3) 'civilian control'.
Reliance on internal affairs has characterised much of the history of policing. Under this system, all complaints were processed by police, with some very limited oversight by coroners, prosecutor offices, police boards, courts and commissions of inquiry; and with some attempts to generate impartiality at times through the engagement of senior officers and officers from other departments. Nonetheless, the model is strongly associated with the protection of corrupt officers and the persecution of complainants and whistleblowers.
In an attempt to reduce the problems of internal bias, some governments, mainly from the 1970s, established review-style bodies. These took diverse forms but were mainly tasked with 'desk-top' audits of police processes, with powers limited to criticisms and recommendations. Some more advanced agencies engaged in field investigations for more serious cases and could refer matters recommended for criminal prosecutions to the public prosecutor. Evaluations tend strongly to the view that the work of these agencies is largely tokenistic, undermined by police control of much of the processincluding final control over disciplinary outcomes (Prenzler & Ronken, 2001).
The civilian control model purports to cut through these problems by placing all complaints under the control of an external body, with extensive inquisitorial powers and a mission for improving police conduct. Ensuring procedural justice and improving public confidence in police are key goals. Agencies can also seek to integrate restorative justice into the complaints process through mediation services as well as deploying a range of advanced integrity management strategies such as covert surveillance and strategic analyses of police conduct issues. The model also includes a mission to encourage and monitor police internal integrity strategies, including, for example, training and procedural measures, internal discipline and remediation, early intervention systems, drug and alcohol testing and staff surveillance systems (such as body-worn cameras and station cameras, computer log-ins and conflict of interest checks).
There is an emerging consensus that the democratic accountability of police requires the independent investigation and resolution of complaints against police-free from the actual or perceived conflicts of interest entailed in internal investigations. The view is consistent with emerging human rights principles. For example, the Council of Europe's Commissioner for Human Rights (2009) set out five principles for effectiveness in the management of complaints against police, consistent with democratic accountability: 'independence', 'adequacy', 'promptness', openness to 'public scrutiny' and 'victim involvement ' (pp. 7-8). Independence is defined as the absence of 'institutional or hierarchical connections between the investigators and the officer complained against' (p. 7). In Smith's (2018) summary of the position in the European Union, 'An independent and effective police complaints system in which the public have trust and confidence is fundamental to the protection of human rights and combating impunity' (p. 96). A major United Nations (2011) review of oversight mechanisms, with a focus on optimising police compliance with human rights standards, argued that successful oversight requires 'full operational and hierarchical independence from the police' (p. 70; see also Hopkins, 2009).
This human rights perspective is consistent with the growing body of research showing that procedural justice principles-emphasising 'voice, neutrality, respect and trust' (Tyler, 2003)-constitute an essential precondition for public confidence and cooperation with police (Bolger & Walters, 2019). The application of these principles through non-police investigations of complaints has a particular resonance for minority groups, who often perceive police as biased in their interactions (Bolger & Walters, 2019), with grievances aggravated by internal investigations of complaints. This includes the fraught history of relations between Indigenous people and police in Australia, where numerous inquiries and reviews, including the 1987-1991 Royal Commission into Aboriginal Deaths in Custody, have called for completely independent processes for complaints by Indigenous persons (Johnston, 1991, s 29.5.23;Victorian Aboriginal Legal Service, 2022).
Elements of the civilian control model have been reported to be in operation in diverse jurisdictions internationally (Ho et al., 2021;Quah, 2020;Smith, 2010). However, there is very little on the public record about most of these systems. The Police Ombudsman for Northern Ireland, on the other hand, is widely considered to be the best incarnation of the model and one of the most studied oversight agencies (McCulloch & Maguire, 2022;Savage, 2013). It appears that the Ombudsman's independent management of complaints, and its work with the police service to improve officer conduct and eliminate sectarianism, have been crucial to the police reform project in Northern Ireland and the wider peace process (Topping, 2016). Since its inception in 2000, the Ombudsman has attracted extraordinarily high levels of public confidence and complainant and police officer confidence, and contributed to long-term improvements in police conduct and reduced complaints (McCulloch & Maguire, 2022;Prenzler & Porter, 2022). This contrasts with the high levels of stakeholder dissatisfaction in internal affairs and reviewstyle systems and the tendency for jurisdictions with these systems to have major recurring police conduct problems (McCulloch & Maguire, 2022;Prenzler & Porter, 2022).

The Queensland experience
As noted in the background section, the first iteration of Queensland's post-Fitzgerald anti-corruption agency-titled the Crime and Justice Commission-appeared to fit many of the requirements of the civilian control model in its police jurisdiction (Prenzler & Maguire, 2022). The persecution of police whistleblowers had been a major theme of the Inquiry. Consequently, protecting officers making complaints or disclosures was intended to be a key feature of the new system, along with protections for civilians. Part of this response involved the creation of a Witness Protection Division within the Commission. Overlapping this concern was the need for a fair and impartial investigative process, adequate discipline and the use of strategic intelligence to guide corruption prevention programs. The primary method to achieve these goals was the independent and rigorous processing of complaints, supported by proactive auditing, intelligence gathering and research. The new agency, established in 1989, was meant to serve as a permanent inquisitorial royal commission. Matters involving 'official misconduct'-'a broad term describing the misuse of authority and abuse of office by public officials'-were meant to be dealt with directly by the Official Misconduct Division (Fitzgerald, 1989, p. 365). Actionable cases would be prosecuted in a 'Misconduct Tribunal', located within the Commission but independent of it, headed by a judge, assessing evidence on the balance of probabilities, with authority to set administrative penalties including 'dismissal, reduction in rank, fines and forfeiture of benefits' (p. 315). Criminal matters would be referred to the Public Prosecutor. Complaints considered 'trivial or purely disciplinary' would be referred to the police, but with capacity for the Commission (and subject officers) to appeal outcomes to the Tribunal (p. 315).
The subsequent history of the various integrity commissions in Queensland has entailed a major departure from this vision. Much of what occurred in the early years remains undocumented, although one report stated that, 'from its inception, the Criminal Justice Commission … vigorously investigated all complaints of police misconduct or official misconduct that were deemed to warrant investigation' (Crime and Misconduct Commission, 2004, p. 4). A major assessment of the first five years of the reform program by the Criminal Justice Commission (1997) found that the proportion of investigated complaints that were substantiated rose from approximately 14% pre-Fitzgerald to an average of 27% per year in the four years after the full establishment of the new system (pp. 60-62). Survey data also showed a strong improvement in public confidence in police integrity, although the report lacked data on complainant and police officer experiences of the system.
The 1997 review of reform also identified a number of operational problems (Criminal Justice Commission, 1997). The Commission's lack of phone tapping powers-since corrected-was a major handicap, as was the absence of adequate adjudicative powers-a situation that was never rectified. The report identified the police weakening of Commission disciplinary recommendations as a significant problem. Too many matters were downgraded, with tariffs such as reprimands or counselling. The problem was compounded by a misdirection of the Commission's efforts towards criminal prosecutions, many of which were unsuccessful. This was despite Fitzgerald's recommendation that disciplinary and administrative action occur independently of criminal prosecutions (1989, p. 386). Overall, very little use was made of tribunals as envisaged by Fitzgerald. This was partly because tribunals reportedly involved unacceptable delays and took an 'excessively legalistic' approach, resulting in an unexpected number of dismissals (Criminal Justice Commission, 1996, s 3.15). The overall result was that the Commission found the three adjudicative options unsatisfactory. With no apparent control over outcomes, the Commission often found itself impotently expressing a 'not happy' response over final decisions and sanctions administered by the police or courts (eg, Viellaris, 2009, p. 1).
One of the most concerning aspects of the Criminal Justice Commission's operations was its failure to engage in genuinely independent investigations. Fitzgerald referred to a mix of seconded police and specialist civilian staff in the new commission (1989, p. 313). However, despite being institutionally separate to the police service, the Commission remained heavily dependent on approximately 100 seconded officers to conduct its investigations, with limited supervision by lawyers. This situation was exacerbated by a trend towards referring complaints to the police for in-house processing. The reasons for this are unclear, although the volume of complaints and slow turnaround times might have been a factor. By 1994, it was reported that 64% of public complaints were investigated by the police, with 18% investigated by the Commission (most likely by seconded police) and 7% investigated jointly (Criminal Justice Commission, 1994, p. 53). In effect, the old system of police investigating police predominated, with the presumption-supported by limited evidence-that civilian review would solve the problem of apparent or real bias. Numerous complaints were also directed to an informal resolution process controlled by police, introduced as an initiative of the Commission. The option somewhat improved the low rate of complainant satisfaction, although the process was often tokenistic, and many complainants expressed a preference for an independently managed mediation option (Riley, Prenzler, & McKillop, 2020).
As the 1990s progressed, and more information emerged about the operations of the Commission, the revelations evinced a profound disenchantment amongst journalists, scholars and civil libertarians (Prenzler, 2009). Journalist Phil Dickie-whose investigations led to the Fitzgerald Inquiry-described the Criminal Justice Commission as 'a useful repository for burying complaints' (in Prenzler, 2009, p. 588). In a rare report on complainant satisfaction in 1994, only 27.8% of survey respondents were satisfied with the formal investigation of their complaint, with 18.8% 'fairly dissatisfied' and 53.5% 'very dissatisfied' (total dissatisfied = 72.3%) (Criminal Justice Commission, 1994, p. 60). By the end of the decade, the situation had deteriorated to the extent that one academic assessment was forced to the conclusion that very little had changed since Fitzgerald's comprehensive condemnation of the Police Complaints Tribunal as highly detached and ineffective (see background section above). For example, the Crime and Misconduct Commission, which replaced the Criminal Justice Commission in 2002 (Prenzler, 2009, pp. 582-583): generally complies with the principle of devolution set out in the Act in Section 34C. It investigates fewer than 2 per cent of the approximately 3,500 complaints it receives each yeardespite a budget of $37 million and a staff of 350. The remaining complaints are dealt with in house by government departments and local government. The commission also lacks public accessibility. It is bunkered down in the Brisbane CBD, with no offices in regional centres in an enormous decentralised state.
An explicit 'devolution' policy, embodied in the Crime and Misconduct Act 2001, was developed by a working party involving police and members of the anti-corruption commission. Among other things, the group sought to reduce delays in complaints processing and adopt a less punitive, more behaviourally oriented approach to complaints management through 'managerial resolution'. This involved counselling of an officer by a more senior officer, completely cutting out the complainant (Crime and Misconduct Commission, 2004). Devolution entailed a further enlargement of the police role in processing complaints-with the Commission's supervision and auditing functions and capacity to conduct independent investigations, ostensibly creating an effective balance between 'encouraging police managers to take responsibility for promoting integrity in their workplace and ensuring an appropriate level of external investigation and independent review' (Crime and Misconduct Commission, 2004, p. 13).
The devolution policy became entrenched, with the current Crime and Corruption Act 2001 requiring the police commissioner hold 'primary responsibility for dealing with complaints involving police misconduct' (s 41(1)), and with direct authority for disciplinary matters under the Police Service Administration Act 1990. The Crime and Corruption Commission has discretion to review the police process and take over investigations as it sees fit. It can also refer matters for adjudication to the Queensland Civil and Administrative Appeals Tribunal or the Public Prosecutor. The Commission's oversight covers 'corrupt conduct' in the public sector, and 'corrupt conduct' and lower-level 'misconduct' in the police (Crime and Corruption Act 2001). It also has a large role in combatting serious and organised crime. In 2021-2022, according to the Crime and Corruption Commission's Annual Report, it assessed 3889 complaints of 'suspected corruption', involving 8859 allegations, across the Queensland public sector. Of these complaints, 26 investigations were commenced (0.7%) and 3126 were forwarded on to other agencies (2022, p. 37). Of 21 investigations finalised in 2021-2022, 73 criminal charges were made against 8 persons and 19 recommendations were made regarding disciplinary action against 12 persons. The proportions of these data relating to police were not included in the report, nor were stakeholder experience data, and there was no evidence to suggest a substantial role for the Commission in regard to complaints against police. The role of the anti-corruption commission in police integrity had become almost completely opaque. As far as can be ascertained, the discretionary powers it retained to independently investigate and review matters meant that it remained marginally within the 'civilian review' category of oversight-although the system was very close to the 'internal affairs' model, with police having near-complete control.
The various versions of Queensland's anti-corruption commissions have been granted many of the investigative powers and resources consistent with a best practice external model of police integrity management. They have had powers to compel answers to questions, seize evidence, arrest suspects, apply for search warrants and conduct covert operations, and they have had own motion powers to pursue any matters regardless of complaints (see Fitzgerald, 1989, p. 313). Over the decades there has been a fairly steady stream of convictions, dismissals and resignations of police emanating from the commissions' work that have provided some reassurance of vigilance and determination in combatting misconduct (Prenzler, 2009). At the same time, there have also been recurring problems with misconduct scandals; findings of inadequate investigations, discipline and prevention; stakeholder disaffection; and repeated calls for a decisive shift away from the dominant system of police investigating police (eg, Crime and Corruption Commission, 2015Commission, , 2017Crime and Misconduct Commission, 2011;Crockford, 2021;Flori v Winter [2019]; Gregoire, 2019;Independent Expert Panel, 2011;Prenzler, 2009;Queensland Council of Civil Liberties, 2010;Wotton v State of Queensland [2016]).
One of the most high-profile and protracted signal events that encapsulated these problems concerned the death of Aboriginal man Cameron (Mulrunji) Doomadgee on Palm Island in 2004 (Anti-Discrimination Commission Queensland, 2018). Doomadgee was arrested for a public nuisance offence, and died from a split liver and ruptured portal vein at the local watchhouse following an altercation with the arresting officer. An internal police investigation was conducted in an environment of intense controversy. Communication of the autopsy results sparked a riot on the island in which the courthouse, police station and other buildings were burnt down. Police then shut down the island and masked officers raided the homes of 18 families. The case resulted in three inquests, a review by a former Chief Justice, the suicide of a key witness, a failed manslaughter charge, a parliamentary select committee inquiry, a class action for racial discrimination and a failed appeal. The police investigations were found to be compromised and flawed but recommendations for disciplinary action against six officers were ignored. The class action against the Queensland government over the post-riot raid resulted in a $30 million settlement and apology with 447 persons in 2018 (Anti-Discrimination Commission Queensland, 2018, p. 42). Much of what occurred would have been prevented had the anti-corruption commission conducted a fully independent initial investigation and, earlier, directed the police service to implement recommendations of the Royal Commission into Aboriginal Deaths in Custody regarding health services for intoxicated arrestees. One inquest report recommended that deaths associated with police contact be 'undertaken solely or primarily by the CMC (Crime and Misconduct Commission)' (Hine, 2010, p. 150). However, this recommendation was ignored by the government (Mazerolle et al., 2022, p. 17).
The precise reasons for the failure of reform are unclear. The leadership of the main political parties gave unqualified support to Fitzgerald's recommendations in the immediate aftermath of the Inquiry (Prasser, 1989). Subsequently, the powerful Queensland Police Union of Employees conspired with the conservative coalition at times to reduce the anti-corruption commission's powers and give more authority back to police (Prenzler, 2009). However, the conservatives have only held power for short periods on two occasions in the last 34 years. It might also have been the case that the ruling Labor Party sought to appease the Union, although less explicitly, and Labor governments have been accused of seeking to avoid scrutiny by the Commission. Labor's support for a weak civilian review model of public sector accountability has flown in the face of public opinion and key stakeholder opinion. It also appears to have been the case that successive management regimes in the Commission have lacked the necessary commitment to support the civilian control model. Critics have referred to the dominance of lawyers, an excessive concern with legal processes and disinterest in complainants (see Prenzler, 2009).

Three investigations
The following subsections describe the main police-related findings of the three highprofile examinations of public sector accountability issues occurring in Queensland in 2022. The focus is on the Richards Inquiry, which included a systematic critique of the police complaints system with major reform implications.

The Fitzgerald and Wilson Inquiry
The Commission of Inquiry Relating to the Crime and Corruption Commission was established in January 2022, primarily to investigate a controversial failed criminal prosecution of local government councillors. The commissioners were former Fitzgerald Inquiry head Tony Fitzgerald and retired judge Alan Wilson. The Inquiry operated within very narrow terms of reference but was able to address some issues with implications for the Crime and Corruption Commission's police jurisdiction. These included the compatibility of the Commission's crime and corruption fighting roles and the adequacy of the devolution policy. The report stated explicitly that the Commission was overly dependent on seconded police, whose role entailed a conflict of loyalties and potential for 'institutional capture' (Fitzgerald & Wilson, 2022, p. 6). One major recommendation included the adoption of 'a predominantly civilianised model for (the CCC's) Corruption Division', through a reduced reliance on police investigators, installation of a civilian as the Executive Director in Corruption Operations and specialised training for corruption investigators (p. 142). The report also recommended a much stronger focus on prevention (p. 143) and use of a wider set of case disposition options beyond criminal prosecutions (p. 6).

The Coaldrake Review
The Review of Culture and Accountability in the Queensland Public Sector was established in February 2022. Peter Coaldrake held senior positions in Queensland universities and the Queensland public service, with expertise in public sector management. The review was initiated by the government in response to a series of issues around probity, including issues of lobbying, ministerial standards, public service standards and complaints management. Coaldrake described 'an integrity system under stress trying to keep check on a culture that, from the top down, is not meeting public expectations' (2022, p. 1). The findings emphasised the need for enlarged 'independence, transparency, integrity, accountability and impartiality' across government (p. 4). This included a recommendation for a centralised complaints 'clearing house', to ensure better tracking of complaints and a stronger focus by the Crime and Corruption Commission on 'serious corruption' (p. 3). Overall, despite the criticisms of ethical standards, the review showed almost no interest in the key area of police integrity and simply reinforced the Commission's devolution policy.

The Richards Inquiry
The Commission of Inquiry into Queensland Police Service Responses to Domestic and Family Violence, led by Judge Deborah Richards, was established by the Queensland Government in May 2022 as part of its response to a Women's Safety and Justice Taskforce report (2021). Among other things, the Taskforce recommended an investigation into cultural issues within the police that might impede an optimal response to domestic violence, especially towards victims (p. xxviii). There were specific concerns about 'the way police deal with officers alleged to be perpetrators of domestic violence' and 'about the way police deal with complaints about police handling of domestic violence matters' (p. x). The Commission's terms of reference included 'the adequacy of the current conduct and complaints handling processes against officers to ensure community confidence in the QPS' (Richards, 2022, p. 354). This topic allowed the Commission to engage in a comprehensive assessment of the management of all complaints against police.
The Richards Commission approached its task via interviews; surveys of police and victims of domestic violence; receipt of submissions; extensive questioning of witnesses; and analysis of policies, practices and administrative data. Unexpectantly perhaps, significant testimony centred on responses to internal complaints by officers about sex discrimination and sexual harassment. The Commission also engaged contract research by Dr Michael Maguire and Professor Tim Prenzler on the issue of complaints management. Dr Maguire had been the Police Ombudsman for Northern Ireland between 2012-2019 and also the Chief Inspector of Criminal Justice in Northern Ireland responsible for inspections into the main justice agencies. Professor Prenzler had 30 years' experience researching police accountability issues, including extensive work on the Queensland case.
The consultancy report (Prenzler & Maguire, 2022) reviewed five decades of experience internationally with different types of systems for investigating complaints and regulating police conduct. Sources included commissions of inquiry, government reviews, public opinion surveys, complainant surveys, surveys of police, expert opinions, legislation, high-profile signal event cases, agency performance data and studies regarding reduced complaints against police and improvements in police conduct. Dr Maguire also included reflective material on his 11 years as the Police Ombudsman and as Chief Inspector of Criminal Justice in Northern Ireland. The report concluded that the weight of evidence strongly supported the creation of an external civilian-dominated body for managing complaints and other sources of information about possible police misconduct as the best method of fulfilling procedural justice criteria-including for police officers-satisfying stakeholder expectations, maximising public confidence and optimising police integrity.
Richards' final report-A Call for Change-was handed down in November 2022. The Inquiry found that complaints management was deficient in every aspect, particularly in terms of intrinsic bias, including extensive conflicts of interest between officers receiving complaints and officers conducting investigations and carrying out disciplinary interventions. There was entrenched cronyism, sexism and racism; persecution and harassment of complainants; substandard discipline; failure to address behavioural issues; an excessive burden on local commanders; opaque data; and lack of communication with complainants. The system 'fail(ed) to meet community expectations of independence and transparency', and also failed to generate the confidence of police employees (p. 324). Of particular note was the description of the Local Management Resolution system as 'broken' (p. 324).
The recommendations went straight to the heart of the problem of police control of the process with an unequivocal requirement for the adoption of a civilian control system. This would be operationalised through the creation of an 'independent Police Integrity Unit', modelled on the Police Ombudsman for Northern Ireland, located within the Crime and Corruption Commission. The unit, intended to be fully functioning by May 2024, would 'deal with all complaints in relation to police' (Richards, 2022, p. 30) and 'must, at a minimum': . be led by a Senior Executive Officer who is a civilian . provide for whistleblower protections . include a victim advocate . include identified positions for First Nations staff in the intake and victim advocacy teams . include civilian investigators, and transition to a predominantly civilianised model as soon as possible . implement an adequate complaints management system, including fit for purpose data collection and reporting, including providing for aggregate trends analysis . publicly report annually on activities and outcomes.
Drawing on the example of the Police Ombudsman for Northern Ireland, Richards specified the proportions of former police in the new Integrity Unit, with some allowance for a greater proportion during the implementation phase to optimise the capabilities of experienced officers (p. 328): It is envisaged that, after the first six years of the [Police Integrity Unit's] operations, the number of investigators who are or who have been police officers should not be more than 40% in any PIU office. After 10 years of the PIU's operations, the number of investigators who are or who have been police officers should not be more than 25% in any PIU office.
There was also a recommendation for specialist training of non-police investigators (p. 329), and scope was also provided for the unit to receive appeals against decisions made in the previous dysfunctional system (p. 327). The Unit would also work with the Coroner on deaths during police operations. All complaints would be channelled to the Unit through the central clearinghouse recommended in the Coaldrake Review (p. 327).
The Police Integrity Unit was intended to be part of fundamental 'cultural change' in the Police Service (p. 147ff). The Unit would manage complaints regarding 'sexism and misogyny', and it was posited that its work would 'go a considerable way to addressing the cultural issues of sexism and misogyny in the organisation' (p. 163). To buttress the cultural change process, the report recommended a focus on providing welfare assistance to complainants in this category through the availability of a 'Peer Support Office' (p. 163). It was posited that the system would also encourage victims of sexist behaviours to make complaints.
The Inquiry also responded to the allegation that the Crime and Corruption Commission was remote from its constituency, including in terms of its single location in the state capital CBD. A range of outreach activities was prescribed, including (Richards, 2022, p. 326): . ensuring that [the Police Integrity Unit] has a regional presence, and capacity for people to make complaints in person . promoting the establishment of the PIU and increasing awareness of how to make a complaint, and relevant confidentiality protections . embedding regular community awareness and participant (police and complainants) satisfaction surveys . reporting (at a minimum) annually on the number and types of complaints, declared conflicts of interest, progress and outcomes of investigations, and data on public awareness and participant satisfaction surveys.

Discussion
The three Queensland police integrity-related inquiries reviewed here generated diverse findings, depending on their terms of reference, methods and rigour. Nonetheless, they all identified a common problem of poor performance in the area of integrity-a situation strongly related to inadequate 'independence'. The Coaldrake Review was the most limited in its reach, diagnosing an integrity problem and a lack of independence in public institutions, but ignoring the issue of what counts as an adequate response to complaints across the steps of reception, assessment, investigation and adjudication. Surprisingly, and somewhat out of step with current conventions, the Coaldrake Report did not include a review of the scientific literature. Consequently, it failed to consider the merits of a civilian control model of integrity management and failed to provide a solution to the problem of internal biases in the existing system in Queensland.
The Coaldrake Review also ignored issues of complainant and other stakeholder dissatisfaction and the link between complaints management and behavioural improvements. Some merit could be seen in the recommendation for a central clearinghouse for complaints in terms of ensuring that all public sector complaints are recorded and forwarded to the appropriate authority. However, the concern with 'serious corruption' in the anti-corruption commission's jurisdiction left complainants with matters deemed intermediate or minor without an adequate recourse. There was an associated lack of empathy with complainants as likely victims of abuses. The concern with serious complaints also ignored the tendency of agencies to understate the impacts of matters leading to complaints and the problem of patterns of repeated 'minor' complaints. A clearinghouse could easily provide just another 'repository for burying complaints' (Dickie in Prenzler, 2009, p. 588).
The Fitzgerald and Wilson Inquiry was a little more promising in its findings and recommendations. As noted, the Inquiry was restricted by its narrow terms of reference. Nonetheless, it found scope to recommend 'a predominantly civilianised model' for the CCC's anti-corruption work (p. 142). At the same time, the report stopped short of advocating a mature civilian control system. There was a recommendation to review and reduce reliance on seconded police, although no caps or exclusions were specified in regard to the role of current or former police in the Commission. Overall, the Inquiry represented only a minor advance in improving the independence and reach of the anti-corruption commission in regard to police accountability.
The Richards Inquiry, on the other hand, demonstrated an extraordinarily wellinformed grasp of the issues at stake in the management of complaints against police and in police integrity management more broadly. The Inquiry generated a very clear set of recommendations that should lead to something very close to a genuine civilian controlled complaints system and optimum integrity management system. For example, the Report referenced Fitzgerald and Wilson's concern with 'institutional capture' of the anti-corruption commission while taking the very practical step of placing a quota on former and current police within the Police Integrity Unit (Richards, 2022, p. 328).
The Richards Report adopted the large majority of the recommendations of the Prenzler and Maguire (2022) review, including some very specific elements, such as regular independent audits of Integrity Unit investigations, adoption of a state-of-the-art early intervention system (operated by police but supported and overseen by the unit) and the strategic use of complaints data to design behavioural improvement and complaint reduction strategies. At the same time, the full array of integrity management strategies recommended to support a mature complaints system was not cited. Examples include drug and alcohol testing, and overt and covert surveillance systems. It might have been the case that the Inquiry felt these were outside its scope in not being directly related to complaints.
One area where the report clearly departed from the recommendations of the literature review was in regard to Local Management Resolution. This system was criticised by Prenzler and Maguire as a convenient and superficial means of disposing of complaints. The Richards Inquiry (2022) described the system as 'broken' and a 'toothless tiger' (p. 16). It found that 83% of complaints actioned by the police service were managed this way-including 'serious conduct stemming from sexism, misogyny and racism or systemic bullying'-when the system was originally designed for only very minor complaints and not for repeat complaints (p. 19). Despite this, the report recommended the retention of Local Management Resolution for minor disciplinary matters, albeit under the direction of the independent Police Integrity Unit (p. 328). This position also went against the evidence that strongly favoured a restorative justice approachinvolving face-to-face, independently managed mediation between complainants and officers-as a default option for many complaints, with a strong learning component built in (Prenzler & Maguire, 2022, p. 35).
Another area where the prescribed reforms potentially departed from best practice was in the adjudication of cases. Prenzler and Maguire (2022) emphasised the absolute importance of this element of the process, given that police control of discipline frequently undermines the authority of external investigative agencies, and the consultancy report emphasised the advantages of the Northern Ireland system. Sections 59(5)(b) and (6)(a) of the Police (Northern Ireland) Act 1998 state that if 'the Chief Constable is unwilling to bring (the recommended) disciplinary proceedings, the Ombudsman may, after consultation with the Chief Constable, direct him to bring disciplinary proceedings … it shall be the duty of the Chief Constable to comply with a direction under subsection (5)'. In practice, as Dr Maguire testified, concern for the Police Service's reputation and a shared interest in combatting poor behaviour have meant that this authority was rarely invoked; but it exists as a crucial fall-back mechanism. The Richards Report also placed responsibility for disciplinary recommendations in the hands of the Police Integrity Unit, but the Unit would be obliged to seek redress for unsatisfactory police responses through judicial review (p. 326). Police would 'retain control for member discipline outcomes (with input from the PIU)' (p. 328). Given the problems with tribunals and courts in the past, as outlined earlier, and the absence of guidelines for managing police misconduct matters in the courts, this is a potential point of major weakness in the new system.
On a more positive note, the Richards Inquiry's concern with complainants, and potential complainants, as victims of abuse is particularly commendable. The recommendation for victim advocacy and support as part of the functions of the Police Integrity Unit is highly innovative and adds a major additional role for oversight agencies world-wide, entailing a shift away from a strictly legal evidence-based and adversarial approach to complaints towards a more therapeutic model. The recommendation included dedicated positions for First Nations officers.
Overall then, the Richards Inquiry represents the most comprehensive, rigorous and well-informed assessment of the police complaints system in Queensland since the 1989 Fitzgerald Report. The Richards Report addressed the critical issues referred to in the Fitzgerald and Wilson Report and spoke to the silences in the Coaldrake Report. It also came on the heels of numerous earlier inquiries, reviews and studies pointing in the same direction (eg, see Richards, 2022, Appendix J). The recommendation regarding the adoption of the civilian control model represents the best opportunity to date to correct the almost complete erosion of civilian authority and the disastrous restoration of police control of the police integrity management system in Queensland.
Genuine implementation of Richards' recommendations is now the key issue. Some optimism might be garnered from the fact that the core recommendation regarding a Police Integrity Unit was reportedly supported by the majority of key parties with legal representation at the Inquiry: the Police Service, Crime and Corruption Commission and the Women's Legal Service Queensland (p. 326). The Queensland Police Union of Employees defended the existing system, without providing substantive evidence. The Union is likely to remain a source of opposition to the reforms, with potential influence on the Labor government and, in particular, the conservative opposition. To date, the government has given 'in-principle' support to the recommendations but stopped short of an unequivocal commitment to implementing the full package of changes (Attorney-General, 30 March, 2023). Unqualified commitments were made by politicians at the time of the Fitzgerald Report and subsequently abandoned. Presumably it was with this scenario in mind that the Richards Inquiry set out a detailed implementation timetable, appointment of an 'independent implementation supervisor' and a long-term system for monitoring reform (2022, p. 31). Nonetheless, the record of reform in Queensland, and politicisation of the process, does not bode well.

Conclusion
The three recent integrity probes conducted in Queensland and analysed here contain valuable lessons for policy-makers grappling with issues of police accountability. As outlined briefly in the literature review for this paper, vulnerability to misconduct is a primary feature of modern democratic policing, and optimal integrity management strategies are needed to ensure police operate in the public interest at all times and refrain from abusing their authority. In that regard, the Queensland experience over more than three decades demonstrates the redundancy of both the internal affairs and the civilian review models of complaints management, and the urgent need for adoption of the civilian control model. Ideally, based on the recommendations of the Richards Inquiry, Queensland will soon join Northern Ireland in demonstrating the benefits of a robust independent complaints management and integrity oversight system for police.