It is my opinion within a reasonable degree of law enforcement and security certainty that the municipal defendants failed to provide adequate security. As a result of that failure, plaintiff fell from the float railing that came loose.
Good and accepted standards of care and practice within the field of security and law enforcement require that the defendants provide adequate security equipment along the parade route. It is my professional opinion, within a reasonable degree of certainty that municipal defendants acted negligently in failing to provide adequate security equipment along the parade route in that “sawhorse” barricades were used rather than metal “interlocking” barricades.
Good and accepted standards of care and practice require that the defendants provide adequate security personnel along the parade route. It is my professional opinion, within a reasonable degree of certainty that the defendants acted negligently in allowing pedestrians to “flood” the parade route, entering beyond the barricades and the police officers assigned to control the perimeter. Standards further required that there be sufficient police along the parade route to prevent pedestrians from “flooding” the parade route and/or otherwise entering the parade without authority.
Standards require that defendants provide adequate security personnel on the float itself. It is my professional opinion that the defendants acted negligently in failing to assign adequate security personnel to the float itself. The presence of a single undercover officer was insufficient to properly supervise the float and/or otherwise deter persons from attempting to gain unauthorized access to the float. Parade organizers knew or should have known, as was known to the float owner, that pedestrians would flood into the parade route and that walkers would otherwise attempt to jump onto a float as it progressed along the route. As such, parade organizers should have hired additional security, to properly protect the floats and float riders from attempting to jump up on a float.
Based upon the records as reviewed herein, the float and pedestrian participants of the parade were not provided with any instructions to prohibit, restrict and/or otherwise discourage attempts to jump onto other otherwise board floats without authority. The police department and parade organizer knew or should have known that persons would attempt to board the float without authority to do so during the parade and should have taken measures to prevent such unauthorized attempts at access by way of instructions to the participants and additional security on the ground next to the floats to prevent and/or discourage such activity. In this instance, there was simply no visible security around the floats to spectators or parade participants to serve as a deterrent to those attempting to climb aboard floats during the
The expert leads a university policy department’s emergency management program.