Combating gangs: the need for innovation.
There may be no greater factor contributing to a neighborhood's blight than the presence of an organized criminal street gang. As graphically described by the California Supreme Court in a recent case, one community had become an "urban war zone," and a 4-block neighborhood within this community was described as "an occupied territory" where "...murder, attempted murder...vandalism, arson, and theft are commonplace...[and where] area residents have had their garages used as urinals...and even their vehicles turned into a sullen canvas of gang graffiti."(2)
Communities throughout the country have implemented policing strategies aimed at addressing their criminal street gang problems, hoping to improve the quality of life in a local neighborhood and the community as a whole. These strategies often include the use of such long-existing provisions as loitering ordinances and injunctions. Many complex constitutional issues arise when these measures are used to combat gang activity. This article examines recent decisions by the Illinois Supreme Court, which found a gang loitering ordinance unconstitutional, and the California Supreme Court, which upheld the use of an injunction to target gang conduct that creates a "public nuisance."
CRIMINAL STREET GANG LOITERING ORDINANCES
The Chicago Experiment
In 1992, the Chicago City Council held hearings to address the problems gang members were causing in local communities. Community residents testified that gang members loiter as part of a strategy to establish turf, recruit new members, and intimidate rival gangs and members of the local community. As a result of these hearings, the city council enacted the Gang Congregation Ordinance.(3) This ordinance provided that:
Whenever a police officer observes a person whom he reasonably believes to be a criminal street gang member loitering in any public place with one or more other persons, he shall order all such persons to disperse and remove themselves from the area. Any person who does not promptly obey such an order is in violation of this section.
The ordinance further provided that it is an affirmative defense to an alleged violation if none of the individuals observed by the officer and ordered to disperse are members of a criminal street gang. Violations of the ordinance are punishable by a fine and up to 6 months' imprisonment. The ordinance contained a preamble, discussing the concerns that led to its creation, as well as definitions of key terms, such as "loiter" and "criminal street gang." The authors of the statute left it to the discretion of the police department to enact policy guidelines on enforcing the ordinance.
Once the ordinance enforcement began, numerous defendants attacked the constitutionality of the ordinance. The result of these challenges was a consolidation of approximately 70 cases for consideration by the Illinois Supreme Court in City of Chicago v. Morales.(4) In this case, the City of Chicago requested that the Illinois Supreme Court reverse a lower court determination that the ordinance was unconstitutional. The lower court held that the ordinance was unconstitutional on several grounds, including that it was unconstitutionally vague, overbroad, and in violation of the First Amendment.(5) In rejecting the city's request, the Illinois Supreme Court concluded that the ordinance violated due process of law because it was unconstitutionally vague and lent itself to arbitrary enforcement.(6) Because the court found the ordinance to be a violation of due process, it declined to reconsider the other findings by the lower court.
Quality-of-Life Statutes and Ordinances
Policing strategies aimed at addressing quality-of-life issues in public areas are not new. To address quality-of-life issues, state legislatures historically have provided law enforcement with a variety of tools such as statutes and ordinances addressing vagrancy and loitering, juvenile curfew laws, and ordinances prohibiting prostitution and aggressive panhandling. The issue often raised with such measures is their ability to survive a constitutional challenge. For example, statutes prohibiting vagrancy and loitering historically have been popular tools for maintaining public order and confer a broad amount of discretion to officers when making enforcement decisions.
The continued viability of such provisions was severely questioned when the U.S. Supreme Court invalidated a vagrancy ordinance in Papachristou v. City of Jacksonville.(7) The ordinance permitted an officer to arrest "...rogues and vagabonds, or dissolute persons who go about begging...[and] persons wandering or strolling around from place to place without any lawful purpose or object."(8) The U.S. Supreme Court concluded that the ordinance was unconstitutionally vague because it failed to provide adequate notice of the proscribed conduct and did not define the criminal behavior adequately, thus encouraging discriminatory and arbitrary enforcement.
The constitutionality of the gang loitering ordinance was analyzed by the Illinois Supreme Court within the legal framework of Papachristou and other such decisions, which address similar legislative enactments designed to target undesirable behavior. Like many of its predecessors, this ordinance was found to violate due process.
Due Process Challenge of Vagueness
Fundamental to the notion of due process is the requirement that a statute provide people of reasonable intelligence an opportunity to distinguish between lawful and unlawful conduct and thus not require them to speculate as to whether certain conduct is prohibited.(9)
As a result of such cases as Papachristou, courts routinely have held that broadly worded vagrancy and loitering statutes that do not target other unlawful conduct are unconstitutional because they fail to provide adequate notice of the proscribed behavior.(10) Relying on this guidance, the Illinois Supreme Court concluded that the gang loitering notice failed to identify the illegal conduct adequately and made normally innocent activities appear criminal.(11)
The gang loitering ordinance permitted police officers to order anyone to leave the area whom they reasonably believed to be a criminal street gang member loitering in a public place with others. The term loiter was defined as "to remain in any one place with no apparent purpose." The court concluded that the ordinance did not adequately define the criminal behavior and included innocent conduct, like stepping inside a doorway to avoid inclement weather.
The court also rejected the government's argument that the additional element of loitering with a criminal street gang member made the ordinance constitutional. The government's argument maintained that the combination of these two elements brought the ordinance within other decisions that previously upheld loitering statutes and sufficiently informed citizens as to what is forbidden. Examples of statutes that have survived constitutional scrutiny include loitering to solicit a lewd or unlawful act(12) and loitering in an unusual manner under circumstances that warrant alarm.(13) The court rejected the government's contention that vagueness would be cured by the additional element of the officer's reasonable belief that one Of the persons is a gang member. The court noted that even if an officer has knowledge that an individual is a gang member, there is no requirement that other individuals loitering with the gang member have such knowledge.(14)
The second inquiry in the vagueness challenge is whether a statute defines the proscribed behavior sufficiently so that it does not encourage arbitrary and discriminatory enforcement. The U.S. Supreme Court has expressed concern with legislative provisions that fail to provide adequate guidelines to law enforcement and thus "impermissibly delegate basic policy matters to police...for resolution on an ad hoc and subjective basis, with the attendant dangers of arbitrary and discriminatory application."(15) The Illinois Supreme Court concluded that the gang loitering ordinance's ambiguous language fostered arbitrary and discriminatory enforcement.
While the ordinance was found to be unconstitutional, the Illinois Supreme Court did not suggest that these deficiencies could not be cured by developing a more precise definition of the proscribed behavior, as well as safeguards to prevent arbitrary and discriminatory enforcement. For example, would an ordinance prohibiting gang members from loitering with the intent to harass or intimidate others survive constitutional challenge?
An alternative approach to combating criminal street gang activity is to use a carefully tailored injunction that targets specific behavior. The U.S. Supreme Court opined that injunctions have some advantages over statutes "in that they can be tailored by a trial judge to afford more precise relief than a statute where a violation of the law has already occurred."(16) However, the Court also recognized that injunctions carry a potential of censorship and discriminatory application because they are "the product of individual judges rather than of legislatures."(17) In upholding the issuance of an injunction against a criminal street gang in Gallo v. Acuna,(18) the California Supreme Court referenced the advantage of the injunction - the ability to seek a more precise, or surgical, remedy.
CRIMINAL STREET GANG INJUNCTION
The California Experiment
Officials in several California cities implemented a program to address the problem of criminal street gangs in specific neighborhoods after recognizing the destruction they can cause in a specific, often-clearly defined neighborhood. Several municipalities have used civil injunctions to abate gang activity under the theory that ongoing gang activity is a public nuisance.(19)
The judicial remedy of an injunction is a preventive measure to guard against future injury by requiring a party to refrain from doing or continuing to do certain acts. Before a court will grant this relief, the requesting party must demonstrate that unless the injunction is granted, it will continue to suffer irreparable harm, and remedies at law are inadequate.(20) While it is beyond the scope of this article to delineate the differing jurisdictional requirements for the issuance of injunctions, the following discussion addresses the government's authority to prohibit, or enjoin, certain gang activities that constitute a public nuisance.
Authority to Issue the Injunction
Many of the acts that are targeted within a criminal street gang injunction are punishable as criminal offenses. Generally, injunctive relief is not deemed to be appropriate if its purpose is merely to enjoin the commission of a criminal act per se because such a remedy would effectively punish criminal activity without providing for due process.(21) However, the mere fact that the order targets conduct that is punishable as a criminal offense does not preclude a finding that an injunction is appropriate. The conduct that the order targets is not necessarily the criminal activity but, rather, the nuisance created by the cumulative effect of many acts, some of which may be criminal.(22)
Abating a Public Nuisance
Using an injunction to abate a public nuisance is perhaps the most common use of this form of judicial relief. The term "nuisance" is generally regarded as interference with the use and enjoyment of property, as well as interference with personal interests, such as being subjected to a pattern of acts that are offensive or harmful.(23) A public nuisance affects a community or neighborhood as a whole. While the concept of a public nuisance exists within common law, most jurisdictions have enacted statutes superseding common law definitions.(24) When seeking an injunction to abate the ongoing nuisance created by a criminal street gang, the government must ensure that it identifies conduct covered by the definition of nuisance. To support its claim, it is imperative that the government secure the cooperation of neighborhood residents by obtaining signed declarations that describe the conditions they are forced to endure. In Gallo v. Acuna, the court recognized that gang members:
Congregate on lawns, on sidewalks, and in front of apartment complexes at all hours of the day and night. They display a casual contempt to notions of law and order and decency - openly drinking, smoking dope, sniffing toluene, and even snorting cocaine laid out in neat lines on residents' cars.(25)
The court concluded that the conduct of the gang members as described by law enforcement and community residents met the definition of a public nuisance.(26)
Targeting Specific Conduct: Post-Acuna Injunction
Relying on the Gallo v. Acuna decision, authorities in Los Angeles, in August of 1997, successfully enjoined members of a criminal street gang from engaging in a number of activities, including:
* Standing, sitting, walking, driving, gathering, or appearing anywhere in public view with any two or more named defendants or known 18th Street Gang members, but not including when all individuals are within a dwelling unit.
* Selling, possessing, or using, without a prescription, any controlled substance or related paraphernalia, including but not limited to, rolling papers and pipes used for illegal drug use or riding a bicycle to facilitate any of the foregoing activities
* Acting as a lookout, whistling, yelling or otherwise signaling with a flashlight or "walkie talkie" or riding a bicycle or other means to warn other person[s] of an approaching law enforcement officer
* Harassing, intimidating, or threatening the peace or safety of any person by the use of vulgar or abusive language, whether 1) in retribution for any past complaint or to prevent a future complaint about the defendants' gang and nuisance activities, or 2) for any other purpose; or
* Urinating or defecating in public or any place open to public view.(27)
Recognizing that this order has not yet been challenged, it is illustrative of the types of behavior the government has attempted to enjoin.
POTENTIAL FIRST AMENDMENT CHALLENGES
Gang members targeted by an injunction may allege that it impermissibly infringes on their constitutionally protected rights. Due to the nature of the conduct targeted in the injunction, the gang members likely will allege unconstitutional interference with their right of association and freedom of speech and that they have been denied due process.
Right of Association
The injunction in Gallo v. Acuna prohibited gang members from gathering, walking, and otherwise associating with one another in the specified area.(28) The lower California court held that this prohibition violated First Amendment principles guaranteeing individuals the right of association.(29) The California Supreme Court disagreed.
The U.S. Supreme Court has recognized a limited right of association but specifically has rejected the proposition that the First Amendment affords absolute protection to associations. The U.S. Supreme Court identifies two forms of associations entitled to First Amendment protection: 1) those with intimate value, and 2) those that are instrumental to the expression of First Amendment values.(30)
The U.S. Supreme Court has held that inherent in the Constitution is the right to "attend the creation and sustenance of a family - marriage, the raising and education of children...and cohabitation with one's relatives."(31) Implicit in this is the need to maintain intimate associations, meaning those characterized by their relative smallness, the high degree of selectively in decisions to begin and maintain affiliation, and the seclusion from others in critical aspects of the relationship.(32)
The Constitution also is said to protect associations whose members are joined together to pursue "a wide variety of political, social, economic, educational, religious, and cultural ends."(33) Such associations are afforded protection because their existence is essential to the expression of speech, religious principles, and political views.
Application to Criminal Street Gangs
Based on the above U.S. Supreme Court guidance, the court in Gallo v. Acuna stated: Without minimizing the value of the gang to its members as a loosely structured, elective form of social association, that characteristic is in itself insufficient to command constitutional protection within the circumscribed area of Rocksprings.(34)
The court assumed that the gang members may share common views and feel connected by the association and that even some members may be related but rejected the notion that this brought them within the definition of intimate association or that the gang was engaged in expression that furthered First Amendment interests. Furthermore, the court noted that the prohibition only extended to the 4-block target area (Rocksprings) and applied only during those hours of the day in which most of the criminal and intimidating conduct occurs.(35)
Furthermore, assuming there are First Amendment associational interests implicated by the criminal street gang injunction, such interests arguably are outweighed by the compelling interests of the government in abating the ongoing nuisance created by the gang's conduct. This goal is not achievable by using significantly less intrusive means.(36)
Infringement on Free Speech
The government may seek to enjoin conduct that includes some form of speech. For example, the injunction may address harassing, intimidating, or threatening others, including using abusive language. Attempts by the government to place restrictions on speech carry a presumption of unconstitutionality. However, courts have recognized that not all forms of speech are protected and that even if they are, there may be instances where the interests at stake are sufficiently compelling to permit the application of reasonable restrictions.
In the criminal street gang injunction, the government may seek to enjoin the use of so-called fighting words, meaning words "which by their very utterance tend to incite an immediate breach of the peace."(37) Targeting such speech likely would not violate the First Amendment if the restrictions are designed to address threatening speech that carries with it a threat of group force or retaliation because such speech likely would not be deemed protected.(38)
A heavy burden is imposed on the government if it seeks to restrict such expression as the use of verbal and hand signals gang members use to identify themselves. The U.S. Supreme Court has recognized that injunctions can place content-neutral restrictions on protected speech as long as the injunction affects no more speech than necessary in order to serve the government's interest.(39) Restrictions that target harassing speech and speech designed to intimidate likely would survive challenge because the goal is to address a form of communication and its threatening message and not the content of the communication itself.(40)
If the restriction is content based, a more stringent standard is applied, requiring that the government show that a compelling interest is at stake and that the restriction has been narrowly drawn to achieve that end.(41) Rarely will the First Amendment be found to tolerate a content based restriction on speech.(42) Whether the proposed restriction is content neutral or content based is a fact-sensitive inquiry and would depend on the expression targeted. It is likely that a court would perceive a restriction that seeks to prohibit the expression of gang identity to be content based. The ability of such a restriction to survive challenge is doubtful because it would be difficult to show that merely restricting individuals from identifying their gang membership would diminish the more significant nuisance caused by the gang's conduct.
In Gallo v. Acuna, the defendants raised a due process challenge not unlike that levied against statutory measures addressing conduct similar to that named in the injunction. The defendants claimed that the measure violated due process as being overbroad and ineffectual because of vagueness. The contention that the injunction is overbroad is contrary to its very definition - a remedy that is narrowly crafted and surgically applied to a specific, target area against individuals who are informed beforehand of the government's efforts. Further, its terms reach only those specified in the order and do not extend to third parties. As stated by the court in Acuna:
Like the injunction in Madsen, the trial court's interlocutory decree here does not embody the broad and abstract commands of a statute. Instead, it is the product of a concrete judicial proceeding prompted by particular events - inimical to the well-being of the residents of [the target area] - that led to a specific request by the city for preventive relief.(43)
A provision can be sufficiently specific and clear but still violate due process if it reaches conduct beyond that necessary to address the significant governmental interests at stake. The conduct the government seeks to prohibit would thus have to be linked clearly to the existence of the nuisance. The participation of the residents of the targeted area is critical because it will be through their declarations, along with the collection of criminal history information on the subjects, that this nuisance link can be established.
As discussed earlier in the context of the loitering ordinance, due process challenges also involve claims that a provision is unconstitutionally vague because it fails to provide people with advance notice of the proscribed behavior and lends itself to arbitrary and discriminatory enforcement. An injunction that is narrowly tailored to address the conduct creating the nuisance and supported by declarations and other evidence should survive a vagueness challenge. The nature of the injunction itself argues against vagueness because it addresses specific conduct by named individuals who have been provided notice before its enforcement(44) and given an opportunity to appear in court to challenge the government's request.
To combat the escalation of crime, especially the problems presented by criminal street gangs, many policy makers in the law enforcement community have turned to innovative strategies, such as civil injunctions and new ways to use old statutory provisions. Challengers to these approaches often raise claims that the government is interfering with constitutionally protected rights. Yet, the Constitution does not permit every person the unfettered right to do as he or she wants. As stated recently by the California Supreme Court in enjoining certain conduct of a criminal street gang:
Liberty unrestrained is an invitation to anarchy. Freedom and responsibility are joined at the hip. Wise accommodation between liberty and order always has been, and ever will be, indispensable for a democratic society.(45)
This judicial support for the use of an aggressive approach to combat gang activity certainly is not an invitation for the government to act without restraint. It does illustrate, however, that the courts recognize the government's responsibility to assist those who are truly suffering - the residents in those small neighborhoods decimated by the activities of local street gangs.
1 For a discussion on the resurgence of investigation and prosecution of quality-of-life crimes see William J. Bratton, The New York City Police Department's Civil Enforcement of Quality-of-Life Crimes, J.L. & Pol'y 447 (1995).
2 People v. Acuna, 929 P. 2d 596, 601 (Cal. 1997), cert. denied, 117 S. Ct. 2513 (1997).
3 Chicago Municipal Ordinance, 8-4-015(c)(1), the Gang Congregation Ordinance, June 17, 1992.
4 1997 WL 638789 (Ill. 10/17/97) (No. 80479, 80485, 80668).
5 City of Chicago v. Youkhana, 660 N.E.2d 34 (111. 1995).
6 Morales at 63892.
7 405 U.S. 156 (1972).
8 Papachristou v. City of Jacksonville, 405 U.S. 156, 157 (1972), citing Jacksonville Ordinance Code [section]26-57.
9 "Papachristou v. City of Jacksonville, 405 U.S. 156, 162. quoting Lanzetta v. New Jersey, 306 U.S. 451, 453 (1939) ("[all persons] are entitled to be informed as to what the State commands or forbids"): and Kolender v. Lawson, 461 U.S. 352 (1983).
10 Shuttlesworth v. City of Birmingham, 382 U.S. 87. 92 (1965) (antiloitering ordinance found to be unconstitutionally vague because it allowed a person to "stand on a public sidewalk only at the whim of any police officer"). Examples of other antiloitering statutes found to be unconstitutional include Powell v. Stone, 507 F.2d 93 (9th Cir. 1974); Ricks v. District of Columbia, 414 F.2d 1097 (D.C.Cir. 1968); and People v. Berck, 300 N.E.2d 411 (N.Y. 1973).
11 City of Chicago v. Morales, 1997 WL 638789, 638794; and Papachristou at 163.
12 People v. Superior Court, 758 P.2d 1046 (Cal. 1988).
13 State v. Ecker, 311 So. 2d 104 (Fla. 1975); and Bell v. State, 313 S.E.2d 678 (Ga. 1984).
14 Morales at 638796, citing Gallo v. Acuna, 929 P.2d 596 (Cal. 1997) for proposition that "actual knowledge on part of the defendant of other party's gang membership status [is necessary] in order for injunction to pass scrutiny under the vagueness doctrine."
15 Grayned v. City of Rockford, 408 U.S. 104, 108-109 (1972); and Kolender v. Lawson, 461 U.S. 352 (1983).
16 Madsen v. Women's Health Center, 114 S.Ct. 2516, 2524 (1994).
17 Id. at 2524 and 2539, quoting the dissenting opinion of J. Scalia.
18 929 P.2d 596 (Cal. 1997).
19 For a practical discussion of the process of obtaining a criminal street gang injunction, see Jeffrey R. Cameron, M.P.A., and John Skipper, "The Civil Injunction - A Preemptive Strike Against Gangs," FBI Law Enforcement Bulletin, November 1997, 11-15.
20 Easyriders Freedom F.I.G.H.T. v. Hannigan, 92 F.3d 1486 (9th Cir. 1996).
21 U.S. v. Dixon, 509 U.S. 688 (1993) (Supreme Court determined that prosecution of the defendant for violation of a court order and subsequent, second prosecution for engaging in the conduct that was the basis of the court order was barred by the Double Jeopardy Clause; the Supreme Court noted that the use of a court order to prevent the commission of a criminal act was unusual). In re Debs, 158 U.S. 564 (1895).
22 Airlines Reporting Corp. v. Barry, 825 F.2d 1220, 1222 (8th Cir. 1987) ("No court, state or federal, is barred from enjoining activity that causes or threatens injury to property merely because the activity, in addition to being tortious, is a violation of the criminal law").
23 International News Service v. Associated Press, 248 U.S. 215 (1918).
24 Gallo v. Acuna, 929 P.2d 596, 603 (Cal. 1997) ("The public nuisance doctrine is aimed at the protection and redress of community interests and, at least in theory, embodies a kind of collective ideal of civil life, which the courts have vindicated by equitable remedies since the beginning of the 16th century").
25 Id. at 601.
26 Id. at 604. The California Court of Appeals struck down several provisions of the original injunction as impermissibly infringing on constitutional rights. The court did, however, uphold several provisions, such as: a) trespassing or encouraging others to trespass on private property; b) blocking egress and ingress to public sidewalks or any driveways in the target area: c) discharging any firearm; d) demanding entry into any residence; e) littering in public: and f) urinating or defecating in a public place or anywhere open to public view. Gallo v. Acuna, 40 Cal.Rptr.2d 589, 592-600 (Cal. App. 6 Dist. 1995).
27 See People v. 18th Street Gang, No. Bc 175684 (L.A. Superior Court 1997), Government's Notice of Motion and Motion for Injunctive Relief to Abate a Public Nuisance. In the 11/12/97 edition of USA Today. success of the government's efforts in abating the activities of the 18th Street Gang in Los Angeles were discussed in an article titled "Injunction Quashes L.A. Gang."
28 The defendants were enjoined from: standing, sitting, walking, driving, gathering or appearing anywhere in public view with any other defendant or with any other known "VST" (Varrio Sureno Town or Varrio Sureno Treces) or "VSL" (Varris Sureno Locos) member. Gallo at 608.
29 See Gallo v. Acuna, 40 Cal. Rptr. 2d 589 (Cal. App. 6 Dist. 1995).
30 See Roberts v. United States Jaycees, 468 U.S. 609 (1984); and Dallas v. Stranglin, 490 U.S. 19 (1989).
31 Roberts v. United States Jaycees, 468 U.S. 609, 619 (1984).
32 Id. at 620.
33 Id. at 622.
34 Acuna at 608-609.
35 Id. at 609. See also Madsen v. Women's Health Center, 114 S.Ct. 2516, 2530 (1994) ("First Amendment [protection] does not extend to joining others for the purpose of depriving third parties of their lawful rights").
36 See Roberts v. United States Jaycees at 623 (limitations may be imposed on expressive associations without violating the First Amendment where the government can demonstrate that compelling interests are at stake): and Madsen v. Women's Health Center, 114 S.Ct. 2516, 2528-2529 (Supreme Court upheld noise restrictions on protestors near abortion clinics as the order burdened no more speech than necessary to ensure the health and well-being of patients but struck down a restriction on "images observable" as restricting more speech than necessary).
37 R.A.V. v. St. Paul, 505 U.S. 377 (1992); and Chaplinsky v. New Hampshire, 315 U.S. 568 (1942).
38 The Acuna case is instructive to the extent that the court upheld the prohibition enjoining defendants from "intimidating, annoying, harassing...residents of Rocksprings...known to have complained about gang activities. Acuna at 613, quoting paragraph a) of the injunction.
39 Madsen v. Women's Health Center, 114 S.Ct. 2516, 2525 (1994). The Supreme Court also distinguished this case from cases involving statutes that have the effect of restricting speech, stating that "if this were a content-neutral, generally applicable statute, instead of an injunctive order,...we would determine whether the time, place, [and] manner regulations were 'narrowly tailored to serve a significant governmental interest.' " Madsen at 2524, quoting Ward v. Rock Against Racism, 491 U.S. 781, 791 (1989).
40 Madsen at 2524.
42 R.A.V. v. St. Paul, 505 U.S. 377 (1992).
43 Acuna at 610.
44 Id. at 612-614.
45 Id. at 603, quoting Kovacs v. Cooper, 336 U.S. 77, 89 (1949).
Law enforcement officers of other than federal jurisdiction who are interested in this article should consult their legal advisors. Some police procedures ruled permissible under federal constitutional law are of questionable legality under state law or are not permitted at all.
Special Agent Lisa A. Regini is a legal instructor at the FBI Academy.
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|Title Annotation:||strategies to prevent crimes perpetrated by street gangs|
|Author:||Regini, Lisa A.|
|Publication:||The FBI Law Enforcement Bulletin|
|Date:||Feb 1, 1998|
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