Sheepdog Academy News


Ruling: Second Amendment Does Not Apply to “Machine Guns”

Sheepdog Academy’s alumni already know that H.R. 218-LEOSA, 18 U.S.C. §§ 926B, 926C does not apply to machine guns, silencers, or destructive devices.    For those who have not made it to one of our seminars or webinars and expected to argue that the Second Amendment to the United States Constitution protects and individual right to own or carry automatic firearms, be advised that four U.S. Circuit Courts have now held otherwise.
The Ninth Circuit Court of Appeals recently held in U.S. v. Mathew Henry that “machine guns” are “dangerous and unusual weapons” within the meaning of the Heller decision and therefore not included within the protections of the Second Amendment.  Henry, a resident of Alaska, was prosecuted for illegal possession of a “machine gun” within his home.  The firearm was a .308 caliber semi-auto rifle which Henry converted into an automatic rifle.  Agents from the ATF found conversion instructions, kits, and parts within Henry’s home.
The Ninth Circuit looked to Heller and noted that the High Court stated that the Second Amendment only protects the right to own certain weapons, and that it “does not protect those weapons not typically possessed by law-abiding citizens for lawful purposes, such as short-barreled shotguns.” Id. at 625. The Heller Court also concluded that the “historical tradition of prohibiting the carrying of ‘dangerous and unusual weapons’ ” limits the right to keep and carry arms. Id. at 627.
The Ninth Circuited acknowledged that Heller did not specify that machine guns were excluded, but relied upon decisions in other circuits for that support, citing United States v. Allen, 630 F.3d 762, 766 (8th Cir. 2011); United States v. Marzzarella, 614 F.3d 85, 94-95 (3d Cir. 2010). cert. denied, 131 S. Ct. 958 (2011); Hamblen v. United States, 591 F.3d 471, 472, 474 (6th Cir. 2009); United States v. Fincher, 538 F.3d 868, 874 (8th Cir. 2008), cert. denied, 555 U.S. 1174 (2009).
The Henry Court reasoned that a machine gun is “unusual” because private possession of all new machine guns, as well as all existing machine guns that were not lawfully possessed before the enactment of § 922(o), has been unlawful since 1986.   You can read the decision at

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Posted on 16 August 2012 | 4:28 pm

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Don't Shoot Me: For Active & Retired LEOs

When it comes to misidentification shootings, one part of the soultion is training that is recent, training that is relevant to the threats and conditions you are reasonably likely to encounter, and training that is realistic, which includes shoot-don’t shoot scenarios, different lighting conditions, moving targets, distracters, and threats that occasionally return fire.  Another part of the solution requires a uniform and recognizable identification system. 
While we work to raise our own level of training and the training of all active and retired LEOs, there is finally a simple, but genius, safety product available to us all-- the deployable safety banners by DSM Safety Products.  This was the missing part of the solution.

I first learned of DSM during the HR 218-LEOSA seminar we held in Arlington, VA in 2011, but did not really look into it until Dick Fairburn of PoliceOne recommended that I invest five minutes in a product that could save my life and the lives we lose to friendly fire every year.

On New Year’s Day 2012, Dick Fairburn was stirred to do something about the problem of blue-on-blue deaths.  On Long Island, New York, a drug store robbery eventually involved an off-duty federal agent, an off-duty NYPD officer and a retired Long Island officer.  All three active and retired sheepdogs were in plain clothes and when the gun play ended the federal agent was killed and three families were destroyed.

Dick searched once again for a way that armed plainclothes, off-duty and retired peace officers can better identify themselves should they decide to take action at a deadly force incident.  A product from DSM Safety Products, the brainchild of retired SWAT Sergeant, and former Marine, Mike Lessman, is the best option he had found.  The company name says it all, “Don’t Shoot Me Safety Products.”  Mike’s idea is a brightly colored, reflective banner you pull from a pouch on your belt to drape across your torso, Miss America-style.  Dick and others had considered some type of lightweight hat that would store in a similar pouch, but Mike’s banner makes more sense.  LEOs are trained to shoot center-mass, so the bright banner across the torso stands the best chance of being seen and recognized by a fellow sheepdog.

Dick contacted Mike about the DSM banners, which at that time were made in variations for Police, Security and CCW (Carrying a Concealed Weapon).  As one who carries under the HR218/Law Enforcement Officer’s Safety Act (LEOSA), Dick wanted an ID banner, but did not want one that merely identified himself as a CCW holder.  He had nothing against CCW carriers, he is a big proponent, but he felt that retired peace officers hold a higher rung on the ladder of firearms proficiency.  Mike told him that he had been considering adding a small “retired” designation on their “Police” banners for retirees, but was concerned about impersonation charges from some overzealous prosecutor.  That is because while LEOSA-armed retirees can carry nationwide, the law does not grant them police authority. 

Mike accepted Dick’s idea of creating a “LEOSA” banner for retired cops and the production models are already shipping.  At the same time, Mike and Dick agreed that most cops wouldn’t understand the meaning of a lime-green reflective banner emblazoned with the acronym LEOSA.  So, Dick promised Mike he would do whatever he could to begin a nationwide campaign to educate active-duty law enforcement officers on the banner’s meaning.  Doug Wyllie, the Senior Editor of was also immediately on board.  Dick then got me on board as well.

Mike Lessman and Steve Mannion
I met with Mike Lessman recently in Fort Lee, New Jersey to see the banner first hand and was instantly impressed with how light the pouch is and how quickly the banner can be deployed.  DSM has already sold “Police” banners to several Federal agencies who formerly carried raid jackets that were not as practical in warmer climates.

Most LEOs are trained to wear a badge anytime they carry a firearm.  Now, all should be trained to carry the banner on their weak side hip anytime they carry a firearm off-duty or in plain clothes.  The banners can go on the moment before a team goes active on a pre-planned raid, or in a reactive situation after a LEO has taken cover and drawn their handgun.  Either way, we know a LEO will be killed every 12 to 14 months by friendly fire.  So, p-OSHA should mandate that they be purchased for every LEO in the country.  But, since that will not happen anytime soon, it is incumbent upon each of us to do our part to protect ourselves and each other.

So, here begins our education:

Police Banner

Boys & Girls of the Law Enforcement Community, add a new and important word to your vocabulary – LEOSA.  If you encounter someone during a high-stress event that is wearing a high-visibility banner with the letters LEOSA, that means they are an armed, retired or off-duty peace officer.  If this person has a gun in their hand, they are FRIEND, not foe.  They may have already stopped an active shooter event, or may be available to assist you in confronting such a threat.   We know that such killing sprees occur almost weekly somewhere in the country and the more competent, armed sheepdogs we have on the street the more likely we are to have someone there to stop the senseless killing.  DSM Safety Products requires proof of your status before they will sell you a banner, to prevent them falling into the wrong hands.

Help us spread the word.  Mention this at shift briefings or post these pictures on the bulletin board of your squad room.

LEOSA = Armed, Retired or Off-duty LEO

Active officers should consider using the police version to protect themselves off duty inside their own jurisdictions.  Dick and I are not making a single penny from promoting this product, but if it saves even one life we will consider ourselves rich men.  Mike Lessman has designed a product that can help prevent catastrophic blue-on-blue deaths and, just as important to us old retired folks, blue-on-gray deaths.

You can buy these safety banners direct from DSM at:

Pass the word!       

Not Here, Not Today!

Dick Fairburn and Steve Mannion

Upcoming seminars:

Seminar: HR 218-LEOSA  at  The Marksman, 525 Industrial Park Drive, Newport News, VA 23608
Date: April 28, 2012  Clatime: 10:00 am to 3:00 pm EST
Early Bird Special: $60 with advanced online registration by April 14th
At  the door:  $75.00 cash only

Seminar: HR 218-LEOSA at  Las Vegas Metro Police Dept, Las Vegas, NV 89106
Date: May 24, 2012  Class time: 11:00 am to 4:00 pm PST
Early Bird Special: $50 with advanced online registration by May 10th
Pre-registration: $60 May 11th thru May 23rd
At  the door:  $75.00 cash only

Seminar: Building A Better Gunfighter at  Las Vegas Metro Police Dept, Las Vegas, NV 89106
Date: May 25, 2012  Class time: 8:30 am to 3:30 pm PST
Early Bird Special: $50 with advanced online registration by May 10th
Pre-registration: $60 May 11th thru May 24th
At  the door:  $75.00 cash only

“Like us” on Facebook and See what agencies and what LEOs have been to our seminars and webinars:

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Posted on 15 April 2012 | 5:25 pm

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Use of Force & Consequences: Florida Neighborhood Watch

George Zimmerman and Trayvon Martin
  The tragic death of 17 year old Trayvon Martin who was “allegedly” shot by 28 year old George Zimmerman has caused some to criticize or question Florida's stand your ground law.  At this point we do not even know if Zimmerman used that law properly, what if anything he knew about that law or what he thought it authorized.  So, we instead question the training standard.

Zimmerman was reportedly involved in a neighborhood watch when he observed and began following Martin.  Martin was not observed engaged in any illegal activity, but Zimmerman reported his presence to local police dispatch as suspicious.  Dispatch told Zimmerman not to pursue, but shortly thereafter there was a confrontation and Martin was dead.

Pushed to the center of the controversy is Florida law Chapter 776.013, which includes what is called a “stand your ground” provision.  The law states as follows:

(3)A person who is not engaged in an unlawful activity and who is attacked in any other place where he or she has a right to be has no duty to retreat and has the right to stand his or her ground and meet force with force, including deadly force if he or she reasonably believes it is necessary to do so to prevent death or great bodily harm to himself or herself or another or to prevent the commission of a forcible felony. [Id.].

Some contend that if Zimmerman had a duty to retreat, Martin would still be alive and that the stand your ground law needs to be abolished.  If so, we could expect that such shootings do not occur in states with duty to retreat laws, but we know that is not the case.  New York has had two tragic shootings of active LEOs by retired LEOs in the past year.

Each of these three incidents may have been prevented if training standards were higher, but we will never know.  What we do know is that New York does not require any training or even firearms qualification by retired LEO permit holders.  Thankfully, LEOSA has at least imposed a qualification requirement on those retired LEOs who wish to carry under its protection.  Florida’s training standard for civilians is higher than New York’s standard for retired LEOs, but could be improved.

Federal courts have said that training must be recent, relevant, and realistic.  Law enforcement agencies have interpreted the “recent” element to require an annual or semi-annual range qualification.  Some Federal agencies require quarterly qualification.  Florida permit holders are only required to qualify once every seven years.  So, any responsible permit holder should be qualifying more frequently even if not required to maintain their permit.

Firearms training should also be relevant.  Many law enforcement agencies require LEOs to qualify with every weapon they carry.  LEOSA has no such requirement for active LEOs, but requires retired LEOs to qualify with a firearm of the type carried.  New Jersey judges typically require permit holders to qualify with the weapon to be carried.  Florida and other states should at least consider requiring permit holders to qualify with a firearm of the same type carried, i.e., revolver or semi-auto.

Realism is the requirement on which most programs probably deserve a failing grade.  Deadly force encounters may occur during daylight or lowlight conditions, and many but not all law enforcement agencies require their members to qualify under both conditions.  Those that do not invite problems and civil liability.

Nonetheless, realism means more than just lighting conditions.  Training should incorporate scenarios that the trainee is reasonably likely to encounter.  Was Zimmerman trained how to respond to an unarmed teenager who probably did not like being followed?

Many LEOs are required to demonstrate “judgment” in use of force scenarios during basic training, but not during in-service training.  That violates the requirement that such training be recent.  Such training is often done on the mats where a potential assailant wears padding and engages the recruit LEO.  It can also entail sophisticated simulators or unsophisticated videos that LEOs are graded against during shoot, don’t shoot scenarios. 

We are not aware of any state that imposes a “judgmental” requirement on civilian permit holders to demonstrate their judgment in shoot, don’t shoot scenarios.  So, before re-writing a law that most people may never read, consider what the training standard should be for someone to lawfully carry a firearm in public. 

Then, if you carry, ask yourself whether your training is adequate?  Are you physically prepared to engage if deadly force is not appropriate? 

Do you have insurance to address the criminal and civil probes that may follow a use of force situation?

Meanwhile, we will be presenting live LEOSA seminars in Newport News, Virginia on 28 April 2012 and in Las Vegas, Nevada on 24 May 2012.  Dick Fairburn will present his seminar: Building A Better Gunfighter on 25 May 2012 in Las Vegas.  Register now to take advantage of early bird rates.  See our website for information on course registration:

“Like us” on Facebook and See what agencies and what LEOs have been to our seminars and webinars:

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Posted on 23 March 2012 | 2:02 pm

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Sheepdog Exclusive: LEOSA Tested In Hawaii (This Ain't Kansas)

For those who have attended a Sheepdog Academy seminar or webinar, you know that Hawaii is not the most LEOSA friendly state in the union.  Handgun carry permits are not a realistic option in Hawaii, so for retired LEOs and all off-duty LEOs other than active Federal LEOs who carry off-duty under Federal agency authority, LEOSA is the only statutory carry authority in Hawaii.  Hawaii bans ammunition magazines above ten rounds and requires handgun registration which is preempted by LEOSA. 
In November 2011, we wrote about off-duty Diplomatic Security Special Agent Chris Deedy who was charged by Hawaiian authorities in an alleged fatal shooting inside a McDonalds in Waikiki, Hawaii.  Deedy's nose was reportedly broken by the aggressor prior to the shooting which was captured on video and is expected to argue self-defense.  Since Agent Deedy carried both under LEOSA and his agency’s authority in Hawaii, his case is a mixed LEOSA case.  However, Mark Hunsaker, a potential witness in the Deedy case has tested LEOSA in Hawaii.  No, this was not a defense gimmick.  This was valiant conduct which embodies why Congress enacted H.R. 218-LEOSA.
Hunsaker is a licensed accountant in Hawaii and consults for Federal agencies in criminal prosecutions against accountants.  He was not, however, consulted by the Deedy defense team for his accounting skills.  Hunsaker is also a use of force expert.  When he is not preparing 1040 tax forms or assisting the FBI, he moonlights one week per month on the mainland as a deputy sheriff in Chautauqua County, Kansas.

Deputy Sheriff Hunsaker in Kansas
 On February 29, 2012, Hunsaker was at a local park when he observed what appeared to be a fight between two men.  One man had a hammer and the other a meat cleaver.  Hunsaker was armed with a .45, a cell phone, and his wits.
He took cover, dialed 9-11, and informed the communications center that he was an off-duty officer, described the scene, and requested uniformed assistance.  Before the local police arrived, Hunsaker was able to stop the fight from a safe distance.  Hunsaker then approached the man with the hammer, he had a wound on the back of his head.  "Then he started to go back with the hammer, back towards the guy with the meat cleaver."  Hunasker ordered the man with the hammer to stop, which he did.  That suspect then fled.
Hunsaker did not pursue, instead he kept sight of the man with the cleaver and waited for the local police.  A lone officer was first to respond and Hunsaker assisted as the officer approached and ordered the man to drop the cleaver.  The suspect was non-compliant and was subdued by additional responding officers.
Hunsaker likely saved one or both men from killing each other.  Hunsaker said it best, "I'm not there to enforce laws," "I'm in there to stop great bodily harm or death."  This is precisely the sort of conduct Congress hoped for when it enacted LEOSA in 2004 and expanded its coverage in 2010.  800,000 qualified law enforcement officers and perhaps one million qualified retired LEOs with authority to carry concealed firearms nationwide to stop violent crime and terrorists who prey upon our society.
We thank Federal LEO Bullock for alerting us to this story.  If you know of a LEOSA news story or pending case, let us know so we can help inform others.
An active off-duty officer who was recently arrested for unlawful possession outside his jurisdiction called us in February 2012 and reported that he had already spent $25,000 in legal fees and wished he had taken one of our classes before he was arrested.  That officer had been on our contact list for two years and never attended any of our seminars or webinars.  Was he too cheap to spend a few dollars or did he think he already knew all he had to?  Who knows but that profile no doubt sounds like an active or retired LEO that you know.
Compare his story to the retired LEO alumni from one of our seminars who mistakenly drove into Canada with a backup handgun buried in his trunk.  He had no problems leaving the country, but was detained when he crossed the border back into the U.S.  Well trained U.S. CBP officers found the handgun.  The stunned retired LEO had forgotten about it, and when questioned by CBP said, I have my “grand jury kit” and can explain.  One of the CBP officers responded, ‘you must have taken the Sheepdog Academy LEOSA seminar.’ The retired LEO was then allowed to continue on with his journey and very happy that $50 spent on our seminar saved him a night in jail and thousands of dollars in legal fees.
We cannot guarantee that outcome in every case, but can guarantee we know more about LEOSA than you do and can help you reduce your risk of arrest or risk of being sued for carrying off-duty or as a retiree.  Help us help you by signing up today for our DVD and/or seminar materials booklet. 
Meanwhile, we will be presenting live LEOSA seminars in Newport News, Virginia on 28 April 2012 and in Las Vegas, Nevada on 24 May 2012. “Like us” on Facebook and see our website for information on course registration:

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Posted on 4 March 2012 | 9:56 pm

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Off-duty Officer Wins LEOSA Settlement for False Arrest

Jason Davis, Esq.
Would you rather spend $40 on a Sheepdog Academy LESOA webinar or $44,000 in a settlement? 

Coast Guard Reserve Petty Officer Jose Diaz has won a $44,000 settlement from the City of San Fernando, California for false arrest because one of their police officers did not understand HR218-LEOSA.  Jason Davis, Esq. represented Diaz who is at least the seventh Coast Guardsmen arrested on charges for unlawfully posessing a firearm since LEOSA was enacted in 2004 and the seventh to beat the charges.  Davis and Diaz, however, are the first team to recover a cash settlement. 

Davis relied on the Booth case to establish that Diaz was covered by LEOSA.  The U.S. Coast Guard has since issued ALCOAST 549/10 which makes clear that certified boarding officers, boarding team members and specified other Coast Guard personnel are covered by LEOSA.

The San Fernando Police Department is also reportedly now required to implement new policies and procedures regarding LEOSA.  Diaz argued that the Police Department had a contest to see who could make more gun arrests.  In November of 2007, Diaz was driving to a shooting range when he was subject to a motor vehicle stop to check his vehicle registration.

Upon approaching Diaz’s vehicle, the Officer observed a firearms case in the rear seat with a cable lock around the handle of the case. The Officer opened the case which contained two loaded magazines and an unloaded Glock pistol.  

Diaz showed his Coast Guard ID and told the Officer that the LEOSA permitted him to carry a firearm, but the Officer did not believe that Diaz was covered by the Law Enforcement Officers Safety Act.  Obviously, the arresting officer failed to attend any of Sheepdog Academy's 12 seminars and webinars on the topic.  Shame on him.

The Officer arrested Diaz for unlawful possession of a loaded firearm.  Diaz was spent one day and night in jail.  The weapons charges were later dismissed.

Regretfully, no one from Diaz' Command was willing to testify in his case.   Nonetheless, Davis and Diaz obtained a great result on their own and Diaz is now being all he can be in the Army National Guard.

If you did not attend our February 2011 or November 2010 LEOSA Seminars, you MUST attend our next LEOSA seminar being held on Saturday, 21 May 2011 from 10 am to 2 pm at the Essex County Police Academy in Cedar Grove, New Jersey.  You can register online by clicking here

If you cannot attend, you can order our November 2010 seminar materials

Or contact us to host a live webinar or seminar at your police academy. 
If you want faster LEOSA updates, click “Like It” on our Facebook Page.

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Posted on 24 January 2011 | 8:14 pm

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Warning: N.J. State Police & Hollow Points

The N.J. State Police Firearms Unit has requested that the N.J. Division of Criminal Justice reconsider its guidance regarding the possession of hollow nose ammunition by retired officers.  Bottom line, Retired LEOs cannot legally carry hollow nose bullets in New Jersey unless the RLEO is LEOSA compliant. 
We will discuss this issue in detail at our upcoming LEOSA seminar.

If you did not attend our February 2011 or November 2010 LEOSA Seminars, you MUST attend our next LEOSA seminar being held on Saturday, 21 May 2011 from 10 am to 2 pm at the Essex County Police Academy in Cedar Grove, New Jersey.  You can register online by clicking here

If you cannot attend, you can order our November 2010 seminar materials

Or contact us to host a live webinar or seminar at your police academy. 
If you want faster LEOSA updates, click “Like It” on our Facebook Page.

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Posted on 21 January 2011 | 1:07 pm

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LEOSA: Shootout Leaves Two Injured And Everybody Gets Sued

Probationary Officer Bryan Pour
Does your agency have a LEOSA policy?  If not, it should.

During the early morning hours of November 9, 2008, four off-duty St. Louis, Missouri police officers were socializing at Mack -N- Mick’s Sports Bar outside of Ponton Beach, Illinois.  Police Officers Bryan Pour, Christopher Hantak, Philip Meyer, and another were in plain clothes, but were openly advertising that they were police officers by showing their badges and through other conduct.  All but the unidentified officer were carrying their service handguns. Since Illinois does not issue carry permits or offer reciprocity, the three were carrying concealed firearms under LEOSA.

Pour, age 26, however, was ejected from the bar because of his level of intoxication, but he remained in the parking lot.  That is where he became involved in a scuffle with three civilians outside—Kevin Elliott, Ted Wallace, and John Hadley.  Pour ended up on the ground.  Accounts of what happened next differ.

According to Jeffrey Bladdick, age 25, a friend of the three civilians, he observed Pour on the ground and helped lift him to his feet.  Once on his feet, Pour allegedly spun around and fired one round into Bladdick’s torso.  Bladdick testified that he had not interacted or conversed with Pour at anytime prior to picking him up off the ground.  He also testified that he had no idea Pour was a police officer prior to the shooting.

Either way, Pontoon Beach Police then arrived.  Responding Police Officer Aaron Morgan then shot off-duty St. Louis Police Officer Christopher Hantak in the head and once in the shoulder after Hantack reportedly refused to drop his handgun.  Hantak was intoxicated at the time.  Police Officer Morgan was subsequently cleared by a Grand Jury investigation, but was sued by Hantak for alleged excessive force.

According to Pour’s attorney, Bladdick struck him over the head with a pipe and that Pour acted in self-defense.  Nonetheless, the St. Louis Police Department terminated the employment of Officers Pour, Hantak, and Meyer.  Pour later pled guilty in August 2009 to a reduced charge of aggravated discharge of a firearm and received four years probation because of a request for leniency by Bladdick.

Bladdick sued Pour, the members of the St. Louis Police Department Board of Police Commissioners, and the bar.  Pour and his agency were sued under the Civil Rights Act, 42 U.S.C. § 1983.  Pour was also sued for negligence.

To establish a claim under § 1983, Bladdick must show that Pour “acted under color of state law.”  However, Pour was not in St. Louis and therefore was not acting under state law.  He had no police power.  Instead, he carried into Illinois under LEOSA, which is Federal law.  At the time of the shooting, Pour was intoxicated and was thus outside the scope of LEOSA coverage as wells as outside the scope of his agency’s policy.

The Federal Court dismissed the § 1983 claims against Pour, holding that he “was acting as a private citizen at the time” and not under color of law.  It reasoned that his agency’s policy stripped him of authority once he became intoxicated.  The policy specifically stated, “LEOSA does not provide authority for a person to carry a concealed firearm while under the influence of alcohol or any other intoxicating or hallucinating substance.”  Everything Pour did after he became intoxicated was done for personal reasons, not to further any official policy.  Carrying an agency firearm alone, was not enough to establish § 1983 liability.

The Federal Court also dismissed the § 1983 claims against the St. Louis Police Department and reasoned that although the Police Department failed to prohibit the carriage of its firearms across state lines, its LEOSA policy did prohibit carriage of agency firearms while intoxicated and provided for sanctions and other discipline.

Bladdick’s state law negligence claims against Pour and the bar were dismissed without prejudice on December 8, 2010, but can be refiled in state court.  Importantly, however, while § 1983 claims allow prevailing plaintiffs to recover their attorney fees, negligence claims typically do not.

The lessons here, include the following: 1) Agencies need to have well written LEOSA policies; 2) agencies need to train their officers about LEOSA; 3) booze and firearms do not mix; and 4) anyone who carries a firearm must have LEOSA training and appropriate insurance coverage.

If you did not attend our February 2011 or November 2010 LEOSA Seminars, you MUST attend our next LEOSA seminar being held on Saturday, 21 May 2011 from 10 am to 2 pm at the Essex County Police Academy in Cedar Grove, New Jersey.  You can register online by clicking here

If you cannot attend, you can order our November 2010 seminar materials

Or contact us to host a live webinar or seminar at your police academy. 
If you want faster LEOSA updates, click “Like It” on our Facebook Page.

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Posted on 17 January 2011 | 11:40 am

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