Since the highly publicized deaths of George Floyd and Breonna Taylor, communities have grappled with how best to hold police officers who commit misconduct accountable and prevent them from engaging in future misconduct. In addition to internal administrative discipline by police departments, police officers can be held accountable for misconduct through criminal liability, civil liability and decertification. In recent years, there has been substantial momentum to eliminate “qualified immunity” for police officers so that these officers can be held personally liable, usually as a result of b...