MEMORANDUM IN SUPPORT OF JOINT MOTION TO MODIFY PARAGRAPHS 80, 81(a), 115, AND 341 OF THE CONSENT DECREE
The United States of America and the City of Ferguson (“Parties”) jointly file this Memorandum in Support of their Motion to Modify Paragraphs 80, 81(a), 115, and 341 of the Consent Decree filed in this case. As set forth below, modification of these four provisions is appropriate because the modifications agreed to by the Parties are consistent with the intent and purpose of the original provisions, and will provide greater clarity to Ferguson Police Department (FPD) officers as they carry out their duties. The Parties have consulted with the lead Monitor, who supports the proposed modifications.