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Recommended Citation US Department of Justice, "Local Prosecutors and Corporate Crime" (1993). National Institute of Justice Research in Brief. 30. https://digitalcommons.law.ggu.edu/nij-rib/30

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Chorks B. DeWitt, Director January 1993 Local Prosecutors and Corporate Crime by Michael L. Benson, Francis T. Cullen, and William J. Maakestad

Crimes committed by and for Since the Economic Crime Project was The first component of the study was a pose a serious threat to the health, safety, begun nearly 20 years ago, local re­ mail survey of 632 district attorneys with and financial welfare of consumers and sponse to corporate white-collar crime jurisdictions located in or near urban ar­ workers as well as to the orderly function­ has changed significantly. In the past, eas. 2 Completed questionnaires were re­ ing of the economy and the government. district attorneys concentrated almost ceived from 419 districts, a response rate Commonly known as corporate or organi­ exclusively on economic such as of 66 percent. The survey data were then zational crimes, these offenses raise special consumer fraud. They are now pros­ merged with economic, social , and official problems .for detection, prosecution, and ecuting a wider variety of cases, includ­ crime data for each jurisdiction. 3 The sec­ sanction. 1 Isolated efforts by individual ing occupational safety violations and ond component of the study involved case enforcement agencies have proven inad­ the illegal dumping of toxic waste. In studies in four jurisdictions: Cook County, equate against this type of crime, under­ nearly every , prosecutors have Illinois; Los Angeles County, California; scoring the need for a coordinated, sought criminal indictments against Dade County, Florida; and Nassau County, multistrategy response from Federal, , , and other New York. In each jurisdiction prosecu­ State, and local levels of government. business entities for noneconomic tors, regulatory officials, and representa­ offenses. tives of various law enforcement agencies Historically, the Federal Government has were interviewed regarding their views of This Research in Brief summarizes a assumed primary responsibility for control­ corporate crime and their interactions with ling corporate crime, but in the past two National Institute of Justice study of other law enforcement agencies. decades, local prosecutors have become local prosecutors' work against corpo­ increasingly concerned about this problem. rate crime. For the study, corporate In 1973 the National District Attorneys crime was defined as "a violation of a Trends In corporate crime Association established an Economic criminal statute either by a corporate prosecutions Crime Committee to encourage local pros­ entity or by its executives, employees, ecutors to enforce white-collar crime laws or agents acting on behalf of and for the One conclusion is that local prosecution of and to enhance their enforcement ability. benefit of the , , corporate crime is becoming more wide­ By 1975, 43 district attorneys' offices were or other form of business entity." spread. More than one-quarter of the sur­ participating in the committee's Economic vey respondents said that corporate Crime Project. prosecutions have increased during their

From the Director Local prosecutions of corporate crime, the National District Attorneys Association. successful prosecutions often require sub­ particularly crimes against the environment As this NIJ Research in Brief points out, stantial time and labor, the availability of and consumer fraud, are becoming more local district attorneys are now taking resources plays a significant role in local widespread. Six out of 10 local prosecutors corporate defendants to court for a growing activity against corporate crime. who responded to a recent National Institute variety of offenses, including occupational of Justice survey reported increased num­ safety violations and the illegal dumping of In addition to reporting on the results of the bers of corporate prosecutions by their toxic waste. survey, this Institute report offers suggestions offices. that may improve cooperation among Fed­ Local prosecutions of corporate offenders eral, S~,aMJ.Ac~ ~9119i~s in combat~r~ Once confined almost entirely to the Fed­ are not undertaken easily; as this report this pr~l\Wci~qjjWWERSITY eral courts, local prosecutions of corporate shows, the complex, often technical nature crimes have increased steadily since the of crimes committed in an organizational Charles B. DeWitt Economic Crime Project was established in setting can make them both costly and Director MAR 2 3 1993 1975 by the Economic Crime Committee of difficult to prosecute. And because National Institute of Justic:e FEDi::HAL Dt:J-v~olvrlY AI on.-. . .-. HV6635B474 1993 Local prosecutors and corporate crime tenure in office. One-quarter reported that e Only one type of noneconomic crime­ Variation In local corporate they expected to prosecute more corporate environmental offenses-was prosecuted crime prosecution cases in the future. Less than 1 percent as often as economic crime. In 1988, 31 had seen or anticipated a decrease in percent of the offices handled at least one Because of their complex, technical nature, prosecutions. environmental offense. crimes committed in an organizational setting can be difficult to prosecute. Statis­ Prosecutors in large jurisdictions (those Most districts did not have data on the tical analysis revealed three significant with populations over 250,000) most fre­ specific number of corporate offenses causes for local variations in corporate quently reported increased rates of corpo­ handled in 1988. For this reason, the prev­ crime prosecution: availability of re­ rate prosecutions. Roughly 6 out of 10 alence of local corporate crime prosecu­ sources, community context, and regional respondents in large jurisdictions said tions can only be approximated (table 2). differences. These all affected how ag­ prosecutions had increased during their • Typically, 15 percent ofthe districts gressive local prosecutors were in respond­ tenures in office, and a majority expected ing to corporate crime. this trend to continue. handled more than three consumer fraud cases a year, while 20 percent of the dis­ Availability of resources. Because suc­ tricts handled one to three annually. cessful prosecutions often require substan­ Prevalence of corporate e About 10 percent of local prosecutors tial time and labor, the availability of crime prosecutions typically handled more than three false resources has a significant influence on local activity against corporate crime. In 1988 two-thirds of the survey respond­ claims, insurance fraud cases, or environ­ mental offenses per year. Large offices (as measured by the number ents said their offices prosecuted at least of full-time attorneys) conducted more one of nine types of corporate crime (table Prosecutors in the case study sites reported corporate prosecutions than small offices. 1). Although local prosecutors handled a that most of their resources were allocated Those offices that had joined an inter­ wider variety of corporate crimes in 1988 to combat economic offenses, but noted agency task force to combat white-collar than in previous years, economic crimes that environmental offenses were becom­ or economic crime or had established a still made up the bulk of their corporate ing more prevalent. As one prosecutor special unit tended to be more active than crime caseload. said, "The danger from this environmental offices lacking such arrangements. stuff is much greater than what we have to e Consumer fraud was the most frequent­ Community context. The economic, ly prosecuted corporate offense, with 41 worry about from drugs." Another noted, · "A day does not go by without my hearing demographic, and social makeup of the percent of the offices prosecuting at least community also plays a significant role in one case of consumer fraud. about some type of environmental issue on television or in the newspapers. The prob­ determining the aggressiveness of local • False claims and insurance fraud fol­ lems are immense." corporate crime prosecution. In the study, lowed as the most frequently prosecuted community context affected local prosecu­ economic crimes, with 31 percent of the tors' attention and reaction to certain types offices prosecuting at least one offense in of offenses. For example, prosecutors in these categories. Nassau County, New York, cited illegal disposal of medical waste as a significant environmental problem, while prosecutors in Cook County, Illinois, cited illegal dis­ Tablet. Percentage of Offices Prosecuting Selected Corporate posal or abandonment of toxic chemicals Crimes In 1988* by defunct metal-plating as a typical problem. Local prosecutors tended Corporate crime Yes No to be sensitive to the specific problems, needs, and expectations of the communi­ Consumer fraud 41% 59% ties in which they worked, much as are Securities fraud 22 78 local police forces. Insurance fraud 31 69 Regional differences. Regional differ­ Tax fraud 16 84 ences also affect the amount of local activ­ ity taken against corporate crime. In False claims 31 69 general, prosecutors in western States Workplace offenses 11 89 tended to be more active against most Environmental offenses 31 69 forms of corporate crime than their coun­ terparts in northeastern, midwestern, and Illegal payments 16 84 southern States (table 3). Compared to Unfair practices 8 92 offices in other regions, a larger percentage Any corporate offense 66 34 of western offices typically handled more . than three cases per year of most corporate • In 1988, did your office actually prosecute any of the following corporate offenses? crimes.

2 and representatives from Federal, State, Table 2. Frequency of Prosecutions In a Typical Year* and local law enforcement agencies. Frequency • Creating special units for economic crimes, which allows prosecutors to Fewer than About More than develop the technical and legal expertise 1 case 1-3 cases 3 cases necessary to handle complex cases by con­ Corporate crime Never per year per year per year centrating on these types of crimes. Consumer fraud 32% 33% 20% 15% This survey found that 24 percent of local prosecutors were using one or the other (or Securities fraud 57 28 12 3 both) of these special control strategies. Insurance fraud 38 39 15 9 • Twenty-three percent of the respond­ Tax fraud 61 25 8 6 ents had a special in-house unit in their False claims 40 34 15 11 office for investigating and prosecuting Workplace offenses 68 25 5 1 economic or white-collar crimes. Environmental offenses 45 34 13 8 • Eight percent were involved in an interagency task force or strike group fo­ Illegal payments 51 37 10 2 cusing on economic or white-collar crime. Unfair trade practices 75 18 3 5 • Of those involved in an interagency *Typically, how often does your office prosecute the corporate criminal offenses listed task force, 75 percent also had a special below? unit. The use of special control strategies varied The higher level of activity among pros­ Networking and special units by size of district and region of the country ecutors in the West may be due to the and was more prevalent in large jurisdic­ types of offices and communities they The Economic Crime Project discovered tions than in small ones. -;erve. First, the western offices sampled two ways for local prosecutors to augment #ere located in districts with compara­ resources and increase efficiency against • Fourteen of the 30 largest offices were tively large populations. Along with their corporate crime: involved in an interagency task force, greater population size, these districts may compared to only one of the 30 smallest • Using interagency teams to analyze, offices. have more business activity, and therefore, investigate, and prosecute complex white­ more potential offenses than districts in collar crimes. These networks typically • More than 70 percent of the respond­ other regions. Second, the western offices include prosecutors; regulatory officials; ents in large jurisdictions used one or more tended to have more attorneys and investi­ gators than offices in other regions. Third, legal or cultural factors unique to western States may cause local prosecutors to take a comparatively more vigorous approach Table 3. Percentage of Offices Prosecuting More Than Three to corporate crime. However, the true Cases per Year, by Region* cause of regional variation remains uncl~ar and deserves further investigation.4 Region Crime South West Northeast Midwest Discovery of corporate Consumer fraud 11% 42% 16% 9% offenses Securities fraud 3 9 2 3 District attorneys learned about corporate Insurance fraud 8 15 13 6 misconduct through a variety of official Tax fraud 7 9 2 5 and unofficial sources. Most often, cases came to the attention of prosecutors after False claims 9 30 12 7 complaints by business and citizen victims. Workplace offenses 3 2 0 0 The second most common sources were the local police and State regulatory Environmental offenses 3 33 9 6 agencies, followed by the State police and Illegal payments 2 2 5 2 State attorney general's offices. Federal Unfair trade practices 28 0 2 1w enforcement and regulatory agencies did not refer many cases to local prosecu­ • Typically, how often does your office prosecute the corporate criminal offenses listed tors (table 4). below?

3 Constraints on prosecutorial · Table 4. Frequency of Referrals From Selected Sources* discretion Frequency Before deciding to proceed with a corpo­ rate case, prosecutors reported they consid­ Fewer than About More than ered many factors, including the type of 1 case 1-3 cases 3 cases offense, resources available, actions of Referral source Never per year per year per year other agencies, preferences of victims, and Local police 25% 40% 20% 15% potential impact of the prosecution on the local community. Some of these factors State police 41 37 16 6 limited the prosecutor's willingness to State attorney general 40 37 16 6 proceed with a corporate prosecution, State regulatory agency 28 39 20 14 while others increased it. Federal regulatory agency 71 22 6 1 Factors that limited prosecution. The most important factors limiting local pros­ U.S. Attorney's Office 0.3 72 23 5 ecution of corporate crimes were inad­ FBI 63 29 7 1 equate resources, legal constraints, and Business victims 22 37 19 21 availability of alternative remedies. Citizen victims 18 37 23 22 • Seventy percent of the survey respond­ Public interest groups 59 28 9 4 ents were less willing to prosecute if State or Federal regulatory agencies had already • In general, how often do the sources listed below refer potential corporate criminal acted in a case. cases to your office for investigation or prosecution? • About 60 percent stated they probably would limit their willingness to prosecute of the special strategies, compared to less Joint investigations with Federal agencies if personnel were insufficient. than 10 percent of their counterparts in were rare. Less than 10 percent of the • More than 50 percent said they would small districts. respondents said they worked with the be less willing to prosecute if victims were Federal Bureau of Investigation (FBI), the • Special units and interagency networks not or if criminal intent was U.S. Attorney's Office, or a Federal regu­ difficult to establish in a corporate context. were more common in western and, to a latory agency as often as once a year. In lesser extent, northeastern districts than in three out of five offices, prosecutors never The inadequacies of resources at the local midwestern or southern districts. worked with these Federal agencies. level became apparent during visits to the case study sites. Even in relatively large Some prosecutors interviewed during the well-to-do offices, prosecutors often did Cooperation with other case study visits faulted Federal investiga­ agencies not have basic equipment. For example, tive agencies for not referring cases to prosecutors in one of the largest districts local officials. Although local prosecutors Jointly coordinated investigations are an lamented that they did not have dicta­ recognized the need for Federal agencies to integral part of networking. Local prosecu­ phones and that memorandums, briefs, and focus on large cases, they believed that tors reported collaborating most often with other documents had to be written in long­ some small, unpursued cases may have local police and State regulatory agencies hand before office secretaries could type had significant local impact. While ac­ on joint investigations of corporate crimes them. knowledging different priorities, the pros­ (table 5). ecutors believed that too many cases have An investigator in the same district pointed • The highest number, 38 percent, re­ escaped enforcement. Better communica­ out that a car phone and an answering ported working with local police on one or tion between Federal and local officials machine would greatly improve her effi­ more corporate cases annually. could provide prosecutors with leads to ciency and productivity, enabling her to pursue local cases not pursued by Federal receive and return calls as she traveled • Twenty-eight percent said they worked agencies. around the city working her cases. Without with State regulatory agencies on one or a phone, her time in the car was, as she put more corporate cases each year. However, despite growing recognition of it, "mostly wasted." She and other inter­ the seriousness of corporate crime and viewees noted that these items are standard • At least once a year, more than 20 per­ widespread knowledge that traditional cent of prosecutors worked with the State equipment in all but the smallest private methods of law enforcement are inad­ law firms. attorney general's office and State police. equate, the development of coordinated, • Almost 20 percent of prosecutors coop­ multistrategy responses from Federal, On a more substantive level, prosecutors in erated with another jurisdiction at least State, and local governments remains more one district commented that their ability t( once a year. an ideal than a reality. develop and dispose of environmental

4 :ases was seriously diminished by the lack In contrast, 40 percent of the respondents corporate crime conviction. In contrast, uf access to adequate laboratory facilities. ranked of other offenders as the less than 10 percent ranked retribution as For example, delays in identifying poten­ most important objective in pursuing cor­ the most important objective in prosecut­ tially toxic substances limited the prosecu­ porate crimes. In the view of one experi­ ing street criminals. tors' options in responding to cases of enced prosecutor: Most of the prosecutors interviewed at the illegal disposal or handling of toxic wastes. case study sites echoed these opinions, As one prosecutor explained, to "fmd out There's only one advantage to cor­ arguing that corporate offenders were more what's in a substance 6 months later is too porate prosecutions-in terms of its easily deterred than ordinary street offend­ late in an environmental case. How can deterrence value, one prosecution is ers. Furthermore, prosecutors expressed a you walk in [to a court) and [ask] for in­ worth 500. I've prosecuted maybe strong sense of moral outrage over the junctive relief and say there's an immedi­ 50 murderers, and I've never de­ "arrogance" and "callousness" of many ate need to close this [business] down terred a street murderer. I've prob­ business offenders, particularly those in­ when you've waited 6 months? How can ably prosecuted one industrial volved in repeated and intentional viola­ you do anything criminally-and talk murderer, and I think we've deterred tions. For these offenders, the impositidn about how bad this is-if our office lets it a whole lot of people-at least woke of criminal sanctions for the sake of deter­ go 6 months at a time?'' them up-so some people are trying to do the right thing. So even with a rence and retribution was regarded as Factors that increased prosecution. The lack of resources, one corporate appropriate, necessary, and deserved. factors most likely to increase a prosecu­ prosecution is much more valuable tor's willingness to proceed against a cor­ than one street crime prosecution. The prosecutor as porate wrongdoer involved the nature of the offense and the characteristics of the Addressing the same issue, another problem solver offender. More than 90 percent of the prosecutor commented on environmental crime: While acknowledging the importance of respqndents indicated they would be more convicting and punishing the guilty, some willing to prosecute cases that involved the Everybody agrees that criminal prosecutors interviewed at the case study following: prosecution is the big hammer on sites articulated a broader concept of their • Physical harm to victims. environmental people. The proof is role in the criminal process. In their view, how loud they squeal when you file the prosecutor's central function is reduc­ • Evidence of multiple offenses. the case, and boy, do they squeal. tion of criminal activity; deterrence is not • Large numbers of victims. merely a hoped-for byproduct of the pun­ 'Despite the supposed moral neutrality of ishment process. So, rather than devote many corporate offenses, a notable propor­ • Substantial economic harm. themselves exclusively to the development tion of prosecutors felt that corporate of­ of prosecutable cases, these prosecutors Only slightly less important were the fenders deserve to be punished. Indeed, 35 attempt to control criminal activity through education and deterrence functions of percent ranked retribution as either the first alternative means, an approach that has prosecution. More than 85 percent said the or second most important objective in a been called "the prosecutor as problem "need to deter other potential corporate offenders" would increase their willingness to prosecute. About 75 percent felt simi­ larly about the "need to demonstrate Table 5. Frequency of Joint Investigations With Selected Agencies* publicly that the law applies equally to all offenders." Frequency

Goals of prosecution Fewer than About More than 1 case 1-3 cases 3 cases In general, district attorneys pursued dif­ Agency Never per year per year per year ferent goals when prosecuting corporate as opposed to ordinary street crimes. In the Local police 29% 33% 22% 16% case of a traditional street crime committed State police 45 33 16 7 by an individual, the most important objec­ State attorney general 39 39 16 5 tive for local prosecutors tended to be either deterrence or incapacitation. State regulatory agency 35 36 16 12 Federal regulatory agency 70 23 6 • About 33 percent of the respondents rated incapacitation or deterrence of the U.S. Attorney's Office 67 26 6 2 offender as the most important objective in FBI 61 29 7 3 lJrosecuting ordinary street crimes. Another prosecutor 44 35 18 3 ~ Orily 16 percent rated deterrence of * How often does your office cooperate on joint investigations of corporate crimes with other street criminals as the most important the agencies listed below? objective in this type of case.

5 solver."5 Although it was more the excep­ Sharing information. Local prosecutors tion on the case (for example, victims, tion than the rule, the case studies uncov­ cited a need for a centralized information suspects, and modus operandi). Investiga­ ered evidence that such an approach is not clearinghouse and brief bank to allow tors could use this data base to obtain both uncommon among local prosecutors. prosecutors to benefit from the collective information on the case and the name of knowledge and experience of their col­ the investigator to coordinate activities. For example, this strategy was used in a leagues nationwide. For example, prosecu­ Such a network would be particularly case involving a well-respected corpora­ tors in small communities could draw on useful in large urban areas where multiple tion that had violated a State law govern­ the experience and wisdom of prosecutors agencies in different jurisdictions often ing the transportation and disposal of toxic in large urban centers. Such a clearing­ work in geographical proximity. materials. Although there was enough house could also contain information on evidence to pursue a criminal indictment, alternative sanctions, innovative sentenc­ Many technical details would require care­ ful consideration. For example, when a the prosecutor elected not to file charges. ing, and other enforcement techniques. It Instead, he negotiated an agreement in would be especially useful in relatively computer network is installed, files would need to be protected so that only the inves­ which the corporation paid a substantial new areas of prosecution such as environ­ tigator entering a case into the data base civil fine, donated money to a local hazard­ men~ and workplace-related crimes. ous waste project, and reimbursed the could alter information pertaining to it; , entire cost of the investigation. The money Automation. The potential of computers other investigators would need appropriate from the civil fme was used to fund a to coordinate work among investigators in security clearances to read a file without conference on environmental problems for different agencies could be more fully altering it. law enforcement and regulatory officials. explored. Agencies often have cases stored in a computer data base, but have no way Regional laboratories. Regional laborato­ In this case, the prosecutor believed that of knowing what cases other agencies are ries to serve multiple local jurisdictions this approach both educated and deterred working on. A centralized computer data would make economic sense for hard­ other potential offenders, while the confer­ bank might be particularly useful to local pressed prosecutors, and the feasibility of ence fostered environmental awareness prosecutors in situations involving certain setting up such laboratories to analyze among local officials. Preventing other types of financial fraud or in cases in chemical and environmental evidence corporate environmental violations took which victims are located in widely scat­ should be explored. These laboratories precedence here over enforcing the law tered areas and offenders are mobile. could analyze and identify chemical against a particular offender. samples quickly, thus enabling local pros­ Many law enforcement agencies now use ecutors to respond to cases that Federal computers for record keeping and case agencies may deem too small or too local Policy implications . These computer files could in impact to pursue. tell investigators when someone in their In dealing with corporate offenders, local Publicizing of prosecutions. Finally, local own agency is working on a particular prosecutors often fmd themselves compet­ prosecutors and other law enforcement ing with well-fmanced and well-staffed case, thus reducing duplication of effort and facilitating information sharing. agencies could take advantage of height­ law frrms with vast fmancial and person­ ened public concern over corporate crime nel resources, which can put up stiff legal Computer networks. Some prosecutors by publicizing their prosecutions of such obstacles for prosecutors to overcome. and investigators suggested that a local offenses. The public needs to hear that The effort is often expensive and time­ computer network linking agencies could local prosecutors regard these crimes as consuming, especially for prosecutors who provide access to a common data base of serious and to learn how to identify and have limited staff and are facing these ongoing investigations and cases. The data report them. Ultimately, effective law challenges for the first time. The following base entries could contain information on enforcement depends on the support of ideas on consolidating resources may be the investigator (for example; name, tele­ concerned citizens who are willing to worthy of exploration. phone number, and agency) and informa- become involved.

6 otes of activity against corporate crime. The dependent variable in the regression analy­ Michael L. Benson. Ph.D .• is associ­ 1. Corporate crime is a form of white­ sis was a scale measuring the overall level ate professot of sociology. Univer­ collar crime. The distinctive feature of of activity against corporate crime. To sity of Tennessee. Francis T. Cullen. corporate crime is that the offense is com­ construct the scale, the prosecutors' re­ Ph.D., is professor of criminal jus­ mitted primarily for the benefit of an on­ sponses to the question on how often the lice and sociology, Department of going legitimate business enterprise, rather office typically prosecutes the selected , University of Cin­ than for the individual who carries out the corporate crimes (see table 2) were as­ cinnati. William J. Maake tad, JD.• offense. signed ordinal ranks and summed. The is associate professor of manage­ 2. The sample was drawn from a mailing independent variables were number of ment. We tern Dlinois University. list provided by the National District Attor­ attorneys, presence of a special unit, level This project was supported by Grant neys Association. Districts were classified of retail , and region. All of #88-lJ-CX-0044 from me ational as urban if they were located in a Metro­ the independent variables exerted statisti­ Institute of Justice. politan Statistical Area (MSA), as defmed cally significant effects and collectively by the U.S. Census Bureau. explained 40 percent of the variance in the activity scale. Points of view or opinions expressed 3. Data were abstracted from the County in this publication are those of the and City Data Book (1988), Files on Dis­ 5. Goldstock, R., 1991. "The Prosecutor as authors and do not necessarily repre­ kette. U.S. Bureau of the Census. Problem Solver." Occasional Paper from sent the official position or policies the Center for Research in Crime and of the U.S. Department of Justice. 4. A multiple regression analysis not dis­ Justice, X. New York University School of cussed in this Brief confirmed the impor­ Law. tance of resources, community context, and regional location in determining levels The National Institute ofJustice is a compo­ nent ofthe Office ofJustice Programs, which also includes the Bureau of Justice Assist­ ance, Bureau of Justice Statistics, Office of Juvenile Justice and Delinquency Preven­ tion, and the Office for Victims of Crime.

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