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I n d e p e nd e n ce • Re spe c t • I nte g r it y

Performance Audit
Improving the Completeness of Washington’s
Criminal History Records Database
June 15, 2015
Criminal history records include information on arrests and the disposition
of those arrests. They are used during criminal investigations, for charging
and sentencing decisions, and to conduct background checks for jobs and
volunteer positions. We found a third of the dispositions reported in the
Judicial Information System (JIS) in 2012 were missing from the Washington
State Identification System (WASIS). Almost 90 percent were for gross
misdeameanors, such as driving under the influence. Dispositions were missing
for thousands of people for offenses that would disqualify them from jobs and
volunteer positions with vulnerable populations.
We found dispositions were missing for two primary reasons: the person
arrested was never fingerprinted, or vital information was not included when
the disposition was entered into JIS. To improve the completeness of WASIS,
we recommend the Washington State Patrol seek changes to state laws and
rules to ensure all people arrested are fingerprinted and that all dispositions are
properly entered. We also recommend the Patrol take a more targeted approach
to working with local law enforcement agencies and courts to help them identify
and improve weaknesses in their processes to report arrests and dispositions.

Au dit N u m b e r: 1 0 1 3 6 7 5

Table of Contents
Executive Summary

3

Introduction

6

Background

7

Scope and Methodology

9

Audit Results

11

Recommendations

18

Agency Response

19

Appendix A: Initiative 900

24

Appendix B: State Laws Relevant to Ensuring
the Completeness of WASIS

25

The mission of the Washington State Auditor’s Office State Auditor’s Office contacts
The State Auditor’s Office holds state and local governments
accountable for the use of public resources.
The results of our work are widely distributed through a variety
of reports, which are available on our website and through our
free, electronic subscription service.
We take our role as partners in accountability seriously. We
provide training and technical assistance to governments and
have an extensive quality assurance program.
For more information about the State Auditor’s Office, visit
www.sao.wa.gov.

Americans with Disabilities
In accordance with the Americans with Disabilities Act, this
document will be made available in alternative formats. Please
email Communications@sao.wa.gov for more information.

Jan M. Jutte, CPA, CGFM – Acting State Auditor
360-902-0360, Auditor@sao.wa.gov
Chuck Pfeil, CPA – Director of State & Performance Audit
360-902-0366, Chuck.Pfeil@sao.wa.gov
Lou Adams, CPA – Deputy Director of Performance Audit
360-725-9741, Louella.Adams@sao.wa.gov
Susan Hoffman – Principal Performance Auditor
360-725-5620, Susan.Hoffman@sao.wa.gov
Thomas Shapley – Deputy Director for Communications
360-902-0367, Thomas.Shapley@sao.wa.gov

To request public records
Public Records Officer
360-725-5617, PublicRecords@sao.wa.gov

Criminal History Records | 2

Executive Summary
Criminal history records include information on arrests – and the final result of
those arrests – that law enforcement officers, prosecuting attorneys and judges
use to conduct investigations, to confirm identities, and to make charging and
sentencing decisions. These records are also used by employers to decide if
candidates are suitable for certain jobs, such as working with children or the
elderly, and retailers to ensure individuals may legally purchase firearms. So it
is vital that the state’s criminal history database known as the Washington State
Identification System (WASIS) includes complete records.
However, we found a third of the dispositions for charges reported in the Judicial
Information System (JIS) in 2012 were missing from WASIS, hindering the ability
of law enforcement and other decision makers to properly perform their jobs.
State law makes the Washington State Patrol responsible for maintaining WASIS
and for ensuring it is complete. State law also requires that independent local law
enforcement agencies, courts and county clerks provide the Patrol with criminal
history record information.

Process Control Numbers link dispositions to arrests
WASIS uses fingerprints to identify individuals and their criminal history record
information. A unique Process Control Number (PCN) is assigned to every arrest
when fingerprints are taken and is used to link the result of the arrest, called the
disposition, to the the appropriate arrest record. The illustration below shows how
arrest and disposition information is reported to WASIS.

Arrest reporting

Arrested and
booked

Fingerprinted
(Creation of PCN)

Arrest
report sent

Disposition reporting

WASIS
Arrest
report
with PCN

Disposition
report
with PCN

The PCN links the
disposition to the arrest

No charges
filed

No charges
filed

Law
Enforcement

Prosecuting
Attorney

Judgment

Court

JIS

Judgment
entered into JIS.
PCN triggers
transfer to
database.

If fingerprints are not taken, a PCN is not created and arrest information is not sent
to WASIS. Law enforcement agencies and prosecuting attorneys are responsible for
reporting dispositions when cases do not go to court. The majority of dispositions
that do go to court are sent to the Patrol through an interface between JIS and
WASIS. Dispositions entered into JIS will be sent electronically to WASIS only if
a PCN is also entered.

Washington’s Administrative
Office of the Courts
administers the statewide
court case management
system, known as JIS.
Although its use is not
required, it is used by the
vast majority of Washington
courts.

Criminal History Records :: Executive Summary | 3

Washington’s criminal history records database
is incomplete
To assess the completeness of WASIS, we matched calendar year 2012 disposition
records in JIS to those in WASIS and found that 33 percent were missing. Eleven
percent of the missing dispositions were for felony offenses, while 89 percent
were gross misdemeanors. The most common offenses missing dispositions were
driving under the influence, third degree theft, and fourth degree assault – all gross
misdemeanors. As WASIS is used to conduct background checks for individuals
who work with vulnerable populations, we further analyzed our results and found
that more than half of the individuals with missing dispositions had at least one
missing disposition for an offense on the state’s Department of Social and Health
Services’ list of disqualifying offenses. These offenses include such crimes as
harassment, child molestation and domestic violence.

Missing fingerprints and Process Control Numbers contribute to
incomplete criminal history records
Based on our analysis, we identified two primary reasons criminal history records
are incomplete: 1) fingerprints are not taken, resulting in a PCN not being created,
and 2) PCNs are not included when disposition information is entered into JIS.
To better understand why this occurs, we interviewed selected local law
enforcement and court clerks across the state. One reason fingerprints are not
taken is a state law that does not require law enforcement entities to fi ngerprint
individuals arrested for gross misdemeanors if they are not taken into custody.
We also found that even when fingerprints are taken, dispositions may not make
it to WASIS because JIS allows dispositions to be entered without the PCN. Court
staff we talked to said that when entering disposition information in JIS, they only
enter the PCN when they receive it from the law enforcement agency, even if they
know a particular charge should have one. A contributing factor we learned from
our interviews was that some law enforcement officials and court clerks lacked
an understanding of the purpose and use of the PCN and are not receiving clear
guidance from the Patrol.

Patrol could do more to improve the completeness of WASIS
While the Patrol has taken steps to improve the completeness of WASIS, it could do
more to ensure fingerprints are taken during arrests and PCNs are used to report
dispositions. As an example, while the Patrol has developed guidelines on the
use and purpose of PCNs, we found the guidelines lack specific direction and are
not reaching the right people. Providing direction and guidance to the hundreds
of law enforcement agencies, courts and county clerks involved in reporting
criminal history record information is difficult. However, the Patrol could do
more to reduce the occurrence of missing information by taking a more targeted
and direct approach in providing clear guidance, communicating that guidance
to the appropriate individuals, and working with law enforcement agencies and
courts to ensure the creation and use of PCNs.

Criminal History Records :: Executive Summary | 4

Recommendations
We recommend the Patrol:
1. Seek changes to state laws and/or administrative rules to require all
persons arrested for gross misdemeanors be fingerprinted.
2. Seek changes to state laws and/or administrative rules to require law
enforcement agencies, courts and county clerks include Process Control
Numbers when entering disposition information.
3. Clarify guidance provided to law enforcement agencies, courts and
county clerks on the use of the Process Control Number by providing
more specific directions on its use and how to address known issues when
reporting criminal history record information.
4. Develop a targeted approach for working with local law enforcement
agencies, courts and county clerks to improve the completeness of the
state’s criminal history records. This includes identifying those not
performing as well; working with them to identify areas of weaknesses
in their processes and procedures; and providing them with targeted
guidance and training to address the identified weaknesses.
5. Continue current efforts to work cooperatively with the Administrative
Office of the Courts to regularly share information and ideas on ways to
improve the completeness of criminal history records, including how
to improve communication and interactions with the state’s county clerks
and courts, and how to ensure that courts use Process Control Numbers
when entering dispositions in the Judicial Information System.
6. Continue to improve its processes to regularly reconcile the disposition
information contained in and received from the Judicial Information
System to the disposition information present in the Washington State
Indentification System.

Criminal History Records :: Executive Summary | 5

Introduction
Criminal history records include information on arrests – and the disposition of
those arrests – that law enforcement officers, prosecuting attorneys and judges
use to conduct investigations, to confirm identities, and to make charging and
sentencing decisions. These records are also used by employers to decide if
candidates are suitable for certain jobs, such as working with children or the
elderly, and retailers to ensure individuals may legally purchase firearms. If
information in the state’s criminal history records database is incomplete, law
enforcement may come to the wrong conclusions during investigations, a judge
may inappropriately order a lesser sentence, or an employer may wrongly offer or
deny someone employment.
The Washington State Patrol is statutorily responsible for maintaining
Washington’s criminal history records database and for ensuring it is complete
– containing arrest and disposition information for all felonies and gross
misdemeanors committed in the state. Washington shares these records with the
U.S. Federal Bureau of Investigation for inclusion in the national criminal history
record repository. The national repository is used to conduct the FBI’s fingerprintbased background checks. All states benefit if each state does all it can to ensure
the completeness of its criminal history records.
The Patrol relies on hundreds of independent, local law enforcement agencies, courts
and county clerks to provide the information needed to keep the state’s criminal
history records database, the Washington State Identification System (WASIS),
complete. State law requires them to send criminal history record information
for felonies and gross misdemeanors to the Patrol, but because so many agencies
are involved, each with its own processes and procedures, opportunities for
missing information may occur. Furthermore, two previous performance audits
pertaining to background checks performed by the State Auditor’s Office in 2012
and 2014, suggested potential issues with the completeness of the criminal history
record information in WASIS.
We designed this audit to answer the following question:
• Are Washington criminal history records complete, and if not, why not?

In 2012, 172 law
enforcement agencies
and 193 courts provided
information on hundreds
of thousands of arrests
and dispositions to the
Washington State Patrol for
inclusion in WASIS.

Criminal History Records :: Introduction | 6

Background
Federal law states that, to be complete, an individual criminal history record must
include both the arrest record and the disposition of that arrest. A disposition is
the result or conclusion of the criminal justice process associated with the arrest,
including: release without charges filed by prosecutors, charges dismissed by
the court, or a prosecution ending in acquittal or conviction. For WASIS to be
considered complete it must contain all statutorily required arrests – felonies and
gross misdemeanors – and all associated dispositions.
WASIS uses fingerprints to positively identify individuals and correctly associate
them with their criminal history. Completeness of an individual’s criminal
history record depends on the use of a unique Process Control Number (PCN)
to link disposition information to its associated arrest. PCNs are created when
fingerprints are taken. If fingerprints are not taken, a PCN is not created and
arrest information is not included in WASIS.
The majority of fingerprints are taken at jails using an electronic Live-Scan device,
which automatically generates a PCN and sends the fingerprints, along with the
arrest information and personal identifiers of the offender, like name and date
of birth, to WASIS. The device also creates a disposition report that includes
the PCN. If prints are taken manually using ink, jail staff use a fingerprint card
prestamped with a PCN number and mail it to the Patrol; Patrol staff then enter
the information into WASIS. Each prenumbered fingerprint card has a companion
disposition report bearing the same PCN.
The disposition of an arrest can be reported at several points in the process, with
different entities bearing responsibility for reporting at different points, depending
on when the disposition is finalized. The law enforcement agency, the prosecuting
attorney, and the county clerk or court in the county, district, or municipality may
each have its own method for reporting the disposition of the case.

Felonies, such as
robbery, are severe
crimes punishable by
imprisonment in a state
correctional institution for
typically more than one
year.
Gross misdemeanors,
such as driving under the
influence, are punishable
by up to 364 days in jail or
a $5,000 fine.
Misdemeanors, such as
driving without a valid
license, are punishable by
up to 90 days in jail or a
$1,000 fine. Misdemeanors
are not required to be
submitted to WASIS.

Exhibit 1 - PCNs link arrest and disposition information in WASIS

Arrest reporting

Arrested and
booked

Fingerprinted
(Creation of PCN)

Arrest
report sent

Disposition reporting

WASIS
Arrest
report
with PCN

Disposition
report
with PCN

The PCN links the
disposition to the arrest

No charges
filed

No charges
filed

Law
Enforcement

Prosecuting
Attorney

Judgment

Court

JIS

Judgment
entered into JIS.
PCN triggers
transfer to
database.

As Exhibit 1 shows, the PCN is created if an offender is fingerprinted; the
disposition report containing the PCN is sent by the law enforcement agency to
the prosecuting attorney or court depending on agreed-upon practices.
Criminal History Records :: Background | 7

If a person is arrested, but no charges are filed, the law enforcement agency would
report the disposition as “no charges filed.” If there is enough evidence to potentially
file charges, the case is forwarded to the prosecuting attorney. Prosecuting attorneys
assess whether they have sufficient evidence to file charges. If they do not, the
disposition of the arrest would again be reported as “no charges filed.”
If the prosecuting attorney decides to file charges, the case moves to the
appropriate court; at the conclusion of the court case, clerks will enter the
disposition (a plea, a dismissal, or a conviction) with the PCN, from the
disposition report, into the Judicial Information System (JIS). When a disposition
with a PCN is entered in JIS, an interface between the two systems automatically
sends the disposition to WASIS. If the clerk does not have a PCN, or does not
enter the PCN with the disposition information into JIS, the disposition will not
be electronically transferred to WASIS through the interface.

Washington’s
Administrative Office of
the Courts administers
the statewide court case
management system
known as JIS. Although
its use is not required, it is
used by the vast majority
of courts in Washington.

While most dispositions are submitted to Patrol through the interface between JIS
and WASIS, the prenumbered disposition form can also be mailed to the Patrol
where staff enter the information into WASIS.

Criminal History Records :: Background | 8

Scope and Methodology
Our audit was designed to determine whether WASIS was complete, and if not,
why not. To answer this question, we reviewed pertinent federal and state laws and
rules associated with the state’s criminal history records database to understand
the legal requirements of all parties that contribute information to WASIS. A list
of relevant state laws can be found in Appendix B.
We also interviewed agency staff at the Patrol and the Administrative Office of the
Courts to learn more about the processes used to enter criminal history record
information into WASIS. Based on those interviews and a review of documentation
provided by the Patrol and the Administrative Office of the Courts, we gained
an understanding of how disposition information is entered into JIS and is
electronically transferred to WASIS. To determine if adequate information system
controls were in place to ensure records from JIS were being correctly transferred
to WASIS, we conducted tests to see if all pertinent fields were required to be filled
in with logical values and if the Patrol had procedures and processes in place to
ensure all the required information was transferred to WASIS.
To test if criminal history records were complete, we matched disposition records
found in JIS for calendar year 2012 to disposition records in WASIS for the same
period. We focused on dispositions for felony and gross misdemeanor charges
because state law specifies they must be submitted to the criminal history records
database. We considered a disposition record to be missing if it appeared in JIS but
not in WASIS.
We did not search for missing arrest records in WASIS because available arrest
data did not include consistent information to allow a match to arrest information
in WASIS. The state’s central repository of booking data – the Washington
Association of Sheriffs and Police Chiefs Jail Booking and Reporting System
– collects data from the majority of jails in the state, but does not include
standardized information for any of the values it receives from the jails, making it
nearly impossible to perform an accurate match. The Jail Booking and Reporting
System also only includes arrests where the individual is taken into custody. In
addition, arrest information in JIS was also not consistent. JIS only has the date of
arrest if the PCN is also present, and only includes the offense the individual was
charged with in court. This charge could be different than the offense they were
arrested for, which is the offense included in WASIS.
Variations in how information was entered meant we had some difficulty matching
disposition records between the two systems. We used different combinations
of data fields to complete our match, including the PCN, State Identification
Number, FBI number, court case number, charge, disposition, and other offense
and demographic information (such as name and date of birth). As requested by
Patrol and the Administrative Office of Courts, we used the court case number to
confirm records were actual matches.
Some records contained incorrect information; many records revealed differences
in the way the same value was entered into records. For example, the charge of
Third Degree Theft was entered into JIS as ‘Third Degree Theft,” “Theft in the 3rd
Degree,” “Theft 3,” or other ways; WASIS usually recorded the charge as “Theft-3.”
We attempted to standardize the charges manually, but some were entered into
JIS in dozens of variations. Because of these data limitations, our calculations and
match results are not perfect and likely contain some inaccuracies.
Criminal History Records :: Scope & Methodology | 9

To understand the extent of incomplete criminal history records, we used our
match results to determine the number and percent of dispositions in JIS that were
not in WASIS. We also determined the number and percent of people with missing
dispositions, including those who were charged with felonies, or crimes on the
Department of Social and Health Services’ list of offenses that would disqualify
them from certain volunteer and employment positions. We did this by grouping
disposition records by name and date of birth to determine the number of unique
individuals, then calculated the number and percent of people that had at least
one missing disposition. Minor inaccuracies in this calculation can be attributed
to different people sharing the same name and birth date, spelling variations of a
name, or different names used by the same person.
To better understand why WASIS was missing dispositions, we talked with staff
and managers at selected local jails, county clerks’ offices and courts that provide
arrest and disposition information for inclusion in WASIS and JIS. We used our
match results to judgmentally select 16 courts – eight superior courts and eight
courts of limited jurisdiction. We conducted structured phone interviews with
eight courts that had high disposition match rates, and in-person visits with
eight low match rate courts. For the eight courts we visited, we also visited their
associated jails. We visited a total of five jails because two of the courts we visited
used the same jail, and two other jails were contracted tribal facilities.
During both our structured interviews and our visits, we asked about the processes
they used to create and update criminal history records. Also during our visits,
we attempted to trace several dispositions we identified as missing from WASIS
through the arrest and disposition reporting process to identify potential causes
for incomplete criminal history records.
Finally, we reviewed the guidance and training materials on how to report arrest
and disposition information that the Patrol provides to local jails and courts.

Audit performed to standards
We conducted this performance audit under the authority of state law (RCW
43.09.470), approved as Initiative 900 by Washington voters in 2005, and
in accordance with Generally Accepted Government Auditing standards
(December 2011 revision) issued by the U.S Government Accountability Office.
Those standards require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and conclusions
based on our audit objectives. We believe that the evidence obtained provides a
reasonable basis for our findings and conclusions based on our audit objectives.
See Appendix A, which addresses the I-900 areas covered in the audit.

Next steps
Our performance audits of state programs and services are reviewed by the Joint
Legislative Audit and Review Committee (JLARC) and/or by other legislative
committees whose members wish to consider findings and recommendations on
specific topics. Representatives of the State Auditor’s Office will review this audit
with JLARC’s Initiative 900 Subcommittee in Olympia. The public will have the
opportunity to comment at this hearing. Please check the JLARC website for the
exact date, time, and location (www.leg.wa.gov/JLARC). The State Auditor’s Office
conducts periodic follow-up evaluations to assess the status of recommendations
and may conduct follow-up audits at its discretion.

Criminal History Records :: Scope & Methodology | 10

Audit Results
Washington’s criminal history records database is incomplete
We found a third of the 2012 disposition records in JIS were missing from WASIS.
Almost 90 percent were for gross misdeameanor charges, such as driving under the
influence. Dispositions were missing for thousands of people for offenses that would
disqualify them from jobs and volunteer positions with vulnerable populations. We
found they were missing for two primary reasons: fingerprints were not submitted
to WASIS, resulting in no PCN being created, or a PCN was not included when
entering the disposition of an arrest into JIS.
Concerns about the completeness of WASIS are well known. For each of the last
four years, the Patrol has identified and reported the percentage of arrests in WASIS
that have a disposition. Its most recent report reviewed 2013 arrest records and
found that 78.5 percent included a disposition and 21.5 percent did not. However,
the Patrol’s review does not account for criminal history records that are missing
because fingerprints and arrest records were not submitted to WASIS in the first
place. And while informative, the report does not address why disposition records
are missing.
For our evaluation of the completeness of WASIS, we matched dispositions
recorded in JIS to those in WASIS for calendar year 2012. We chose this approach
because whether or not defendants were fingerprinted, they would still proceed
through the criminal justice process and, if they appeared in court, their case
information would be entered into JIS. Thus, dispositions missing from WASIS
could either be the result of missing fingerprints, or the PCN not being entered in
JIS. Data limitations prevented us from determining the exact number of records
in WASIS lacking both fingerprints and the disposition, and the number lacking
just the disposition.
Before we completed our match, we also reviewed relevant system controls within
WASIS to determine if there were weaknesses in the system that may have prevented
dispositions in JIS from transferring to WASIS. While we did not find any control
issues that would prohibit properly entered dispositions to transfer from JIS to
WASIS, we did find that the Patrol does not have procedures in place to verify that
all disposition data is successfully transferred.

Criminal History Records :: Audit Results | 11

WASIS is missing 33 percent of dispositions found in JIS in 2012
We looked for matches for 245,776 dispositions – 177,770 for gross misdemeanors
and 68,006 for felony offenses – found in the JIS to dispositions found in WASIS.
As shown in Exhibit 2, we could not find matching dispositions for 81,100
(33  percent) of those dispositions in WASIS. We found that a disproportionate
amount, 89 percent, of the missing dispositions were for gross misdemeanors;
only 11 percent were for felony offenses. The most common crimes with missing
dispositions were driving under the influence, third degree theft, and fourth
degree assault – all gross misdemeanors.
Exhibit 2 - Of the 245,776 dispositions we tried to match, more than one-third
were not present in WASIS

Matched
dispositions

Missing
dispositions

33%

Felonies
11%
Gross
misdemeanors

89%

67%

Source: Auditor’s Office match results between JIS and WASIS.

Criminal History Records :: Audit Results | 12

Our match also found that superior courts, where felony cases are tried, had
fewer missing dispositions in WASIS than limited jurisdiction courts, where
gross misdemeanors are tried. As shown in Exhibit 3, 82 percent of superior
court dispositions were recorded in WASIS, while only 58 percent of dispositions
finalized in limited jurisdiction courts were recorded. This may be partially due
to state laws that require superior court judges to ensure that felony defendants
are fingerprinted.
Exhibit 3 - Dispositions reported by superior courts were more likely to
appear in WASIS
Superior court total dispositions: 93,771
Total missing dispositions: 17,226

Limited jurisdiction court total dispositions: 152,005
Total missing dispositions: 63,874
Missing dispositions
for other offenses

Missing dispositions
for other offenses

22%

5%
Missing dispositions for
disqualifying offenses

13%
Matched
dispositions

Missing dispositions for
disqualifying offenses

82%

20%

Matched
dispositions

58%

Source: Auditor’s Office match results between JIS and WASIS.

Records for almost 55,000 people lacked disposition information
Incomplete criminal history records affect people, not just database accuracy.
We found that the 81,100 dispositions missing from WASIS belong to 54,462
individuals. As shown in Exhibit 4, almost 28,000 of these people had at least one
missing disposition for crimes on the Department of Social and Health Services’
(DSHS) list of disqualifying offenses. These offenses include such crimes as
harassment, child molestation and domestic violence.
Exhibit 4 - Missing disposition information for almost 55,000 people could
affect numberous employment and licensing decisions
45% of the 120,388 individuals with dispositions in JIS lacked complete records in WASIS
Individuals with
missing dispositions
for other offenses

22%
Individuals with
missing dispositions for
disqualifying offenses

Individuals with
complete records

23%

55%

Source: Auditor’s Office match results between JIS and WASIS.

Criminal History Records :: Audit Results | 13

DSHS conducts background checks to decide if an applicant should be disqualified
from working with vulnerable populations. However, if the agency relied only on
data in WASIS, it might not be able to make the correct decision, because those
records can be incomplete:
• WASIS does not contain records for people who were arrested but
whose fingerprints were not submitted to generate a PCN and a
criminal history record.
• WASIS records do not have disposition information if it was not
reported using the person’s PCN.
Because DSHS is aware that disposition information may be missing from WASIS,
staff there also review court records for everyone seeking licenses or employment
from them. While this consumes additional resources when conducting
background checks, doing so gives staff a more complete picture of an applicant’s
criminal history. Other employers and licensors may not take these additional
steps: the result is people with criminal convictions may obtain licenses and
employment they should not have, or people with acquittals or dismissals may be
unfairly denied licenses and employment.

Dispositions for people with felony offenses are also missing
from WASIS
We also found 4,611 of the 54,462 people lacking dispositions had at least one
missing disposition for felony offenses; this included 462 people arrested for
murder, robbery, aggravated assault and rape. Felony convictions can affect
people’s voting rights, firearm privileges, and their ability to hold certain jobs.
Again, if WASIS was the only source used to conduct the background check, these
missing dispositions mean it is impossible to make fully informed decisions.

Missing fingerprints and PCNs contribute to incomplete
criminal history records
The completeness of WASIS is founded on consistent creation and entry of PCNs
by all law enforcement agencies, courts and county clerks that report criminal
history record information. Based on our data match results, interviews with staff
at the Patrol, and interviews with officials at selected law enforcement agencies
and courts, we identified several possible causes for incomplete records:
• Fingerprints are not taken during “cite and release” arrests or
upon booking
• Fingerprints may be taken, but jail staff do not transfer the PCN to the
appropriate court or prosecutor
• Court clerks do not enter the PCN into JIS upon the disposition of a case

One reason fingerprints are not taken is the use of
“cite and release” at arrest
State law allows law enforcement entities to forego fingerprinting offenders
arrested for gross misdemeanors at the time of their arrest if they are not taken
into custody. Officers can instead give the offender a citation and a date to appear
in court. This practice, known as “cite and release,” often results in fingerprints
not being taken: without prints, and a corresponding PCN, these arrests are not
included in WASIS.

Driving under the
influence, a gross
misdemeanor, accounted
for 15% of the dispositions
missing from WASIS.

Criminal History Records :: Audit Results | 14

We could not determine the number of dispositions missing from WASIS because
fingerprints were not taken. But given the fact that we found a disproportionate
percentage of gross misdemeanors with missing dispositions from WASIS, it is
possible they were missing because they were for cite and release arrests. In reviewing
our results, Patrol found that more than half of the 200 missing dispositions they
examined were missing because there was no arrest record in WASIS.
An incident in April 2015 points to the effect cite and release has on background
checks. While driving a bus carrying senior citizens on a day trip, an individual
was arrested for driving under the influence. He turned out to have a prior arrest
for the same offense, which would have disqualified him from driving the bus. He
did not mention the earlier arrest on his application and it did not appear on his
background check because the offense was not in WASIS. This happened because
he was cited and released for the prior offense; he was not booked into jail and
fingerprints were not taken, resulting in the arrest not being entered into WASIS.

There may be other reasons fingerprints are not recorded
We also found instances where the offender was taken into custody but not
fingerprinted. Law enforcement agency officials told us that offenders are
sometimes not immediately fingerprinted because they have injuries to their
hands, or are being disruptive. Others are admitted to the hospital before being
sent to the jail. In these cases, the offender is supposed to be fingerprinted as soon
as the next opportunity arises. Sometimes, fingerprints are rejected by the Patrol
due to poor quality after the offender has been released from jail; at other times,
fingerprints are taken but not sent to the Patrol. During our visits to local law
enforcement agencies, we found several instances where defendants were booked
into jail, but we could not find any indication that they were ever fingerprinted.

PCNs are not used consistently when staff enter dispositions
For the disposition of an offender’s case to transfer automatically to WASIS,
creating a complete criminal history record, county clerk and court staff must
enter the offender’s PCN into JIS. However, we found that JIS allows disposition
information to be entered without a PCN.
Court clerks told us they only enter PCNs when they receive them from the law
enforcement agency, even if they know a particular charge should have a PCN.
The clerks at several courts said that establishing PCNs is the responsibility of
the law enforcement agency, not theirs. Furthermore, court clerks said that they
were unlikely to contact the law enforcement agency to request a PCN, or to have
a defendant fingerprinted to establish a PCN.

Inconsistent understanding of the importance of the PCN to WASIS
contributes to incomplete records
Staff at county clerks’ offices, courts and law enforcement agencies we visited
did not always understand the purpose of the PCN. One booking officer at a jail
we visited said that, because they were unaware of the role of the PCN in the
reporting process, he and his colleagues had not always forwarded disposition
reports containing PCNs to the courts. They only began doing so about two and
a half years ago after the sergeant wondered what the number was used for and
conducted his own research to gain a better understanding of it. Another booking
officer at a different location said that he had not received any guidance materials
from the Patrol related to the processing of criminal history records.

Criminal History Records :: Audit Results | 15

Several court clerks told us that they did not know the PCN was essential for
the disposition to transfer from JIS to WASIS. One clerk believed the PCN was
just another unique person identifier used by the federal government and did
not question why she never received PCNs from the law enforcement agency in
her area. When we asked court clerks if they knew about Patrol-issued guidance,
many did not know such guidance was available.

Patrol could do more to improve the completeness of WASIS
The Patrol has already taken some steps to improve the completeness of WASIS,
such as providing training and guidance on the use and importance of the PCN.
However, by taking a more targeted and direct approach in working with local law
enforcement agencies and courts, the Patrol could help them identify weaknesses
in the processes they use to report arrests and dispositions and improve them.
This, in turn, would improve the completeness of WASIS.
Improve the quality of guidance and target the right users
For example, the Patrol has developed guidance that describes the PCN, its purpose
and its use, but as we learned from our visits to local law enforcement agencies,
courts and county clerks, these guidelines are not always reaching the right
people. Some of the jail and court employees with direct responsibility for creating
and updating criminal records told us they lacked a general understanding of the
PCN’s purpose.
Our own review of the guidelines found them to be informative, but lacking
in specific direction on how to ensure PCNs are created and used. Patrol
managers responsible for developing and distributing the guidelines have a clear
understanding of the issues within the reporting process that lead to incomplete
records, but the guidelines themselves offer local entities little instruction on how
to address them.
Work closely with local entities that have higher rates of missing dispositions
The Patrol has also held meetings with stakeholders in three counties to discuss their
criminal record reporting processes and ways to improve them. Patrol managers
said that these meetings were beneficial and led to great improvements in reporting
from those counties. If the Patrol actively approached law enforcement agencies
and courts with higher rates of missing dispositions it would likely increase the
percentage of complete criminal history records in WASIS through improved
reporting. The Patrol could use the findings from its Annual Compliance Report
on disposition reporting to identify local law enforcement agencies and courts
that need the most help in improving their processes.
Develop strategies to communicate with courthouse staff
The Patrol has established a collaborative relationship with the Administrative
Office of the Courts that provides a forum to resolve issues on the transfer of
disposition information from JIS to WASIS. The Patrol could leverage this
relationship to improve its strategies for communicating and coordinating with
court staff.

Criminal History Records :: Audit Results | 16

Several factors make it difficult for the Patrol to take action
to improve the completeness of WASIS
Patrol officials told us they face several challenges in providing targeted guidance and
training to entities that report criminal history record information. In particular,
the state law that allows cite and release complicates their efforts by making it
difficult for the Patrol to require offenders be fingerprinted when arrested.
Furthermore, while state law makes the Patrol responsible for the completeness of
WASIS, and requires law enforcement entities, prosecuting attorneys and courts
to report arrest and disposition information to the Patrol, it does not give the
Patrol any authority over these entities to enforce these requirements.
This legal gap is complicated by the decentralized structure of the hundreds
of reporting entities that includes independently elected sheriffs, prosecuting
attorneys, court clerks, and judges. According to Patrol managers, it creates an
environment in which they find it difficult to provide specific and prescriptive
guidance on what processes entities should have in place to ensure the creation
and use of the PCN.

Criminal History Records :: Audit Results | 17

Recommendations
Although the Patrol has taken significant steps to improve the completeness of
criminal history records contained within the Washington State Identification
System, our audit work suggests there are additional steps it could take to further
improve the completeness of criminal history records. These include:
1. Seek changes to state laws and/or administrative rules to require all
persons arrested for gross misdemeanors be fingerprinted.
2. Seek changes to state laws and/or administrative rules to require law
enforcement agencies, courts and county clerks include Process Control
Numbers when entering disposition information.
3. Clarify guidance provided to law enforcement agencies, courts and
county clerks on the use of the Process Control Number by providing
more specific directions on its use and how to address known issues when
reporting criminal history record information.
4. Develop a targeted approach for working with local law enforcement
agencies, courts and county clerks to improve the completeness of the
state’s criminal history records. This includes identifying those not
performing as well; working with them to identify areas of weaknesses
in their processes and procedures; and providing them with targeted
guidance and training to address the identified weaknesses.
5. Continue current efforts to work cooperatively with the Administrative
Office of the Courts to regularly share information and ideas on ways to
improve the completeness of criminal history records, including how
to improve communication and interactions with the state’s county clerks
and courts, and how to ensure that courts use Process Control Numbers
when entering dispositions in the Judicial Information System.
6. Continue to improve its processes to regularly reconcile the disposition
information contained in and received from the Judicial Information
System to the disposition information present in the Washington State
Indentification System.

Criminal History Records :: Audit Results | 18

Agency Response

STATE OF WASHINGTON
June 11, 2015

Ms. Jan Jutte
Acting Washington State Auditor
P.O. Box 40021
Olympia WA 98504-0021
Dear Ms. Jutte:
Thank you for the opportunity to respond to the State Auditor’s Office (SAO) performance audit
report on Improving the Completeness of Washington’s Criminal History Records Database.
Our agencies worked together to provide this joint response.
The Washington State Patrol (WSP) operates the state’s repository for criminal history records
information. This information is provided by law enforcement agencies, prosecuting attorneys,
and courts throughout the state and is used extensively for making decisions that affect public
safety. Through processes already in place, the WSP has been informally recognized by the
Federal Bureau of Investigation as one of the leading organizations in the country in providing
complete criminal history information to the national system.
The enclosed management response addresses the audit recommendations for the six areas of
improvement to WSP processes to ensure the completeness of arrest and disposition information
reported to and distributed by WSP. The agency already had activities in place in support of
recommendations 4 and 5 prior to the audit. Activities in support of recommendation 6 were
completed prior to the release of the report.
The report indicates two primary reasons for incomplete information: 1) fingerprints are not
taken at the time of arrest, and 2) Process Control Numbers (PCNs) are not included when
dispositions are entered in the court system. WSP has long known about, and continually
addresses, these two contributors to incomplete criminal history information. We appreciate the
report recognizing that WSP relies on hundreds of independent local law enforcement agencies,
courts, and county clerks to provide the information needed to keep the state’s criminal history
records database complete. WSP’s Criminal Records Division provides formal and informal
training, as well as regular and ongoing feedback, to contributing agencies about the importance
of submitting fingerprints at the time of arrest and including the PCN on document submissions.
While WSP has responsibility for complete and accurate criminal history information, the
agency has experienced challenges with moving information through local, county, and state
agency processes and systems. We strongly believe that other law enforcement agencies,
prosecutors, and the courts share a responsibility for ensuring the accuracy and completeness
Criminal HIstory Records :: Agency Response | 19

Ms. Jan Jutte
June 11, 2015
Page 2 of 2

of these records. WSP will continue to provide training and information outlining requirements
to these entities and rely upon their respective processes to ensure compliance.
WSP will strive to implement the recommendations in the report and continue its efforts to
collaborate with the hundreds of Washington law enforcement agencies, prosecutors, and courts
to provide complete and accurate criminal history record information.
We thank the State Auditor’s Office and the audit team for their work.
Sincerely,

Chief John R. Batiste
Washington State Patrol

David Schumacher, Director
Office of Financial Management

Enclosure
cc:

Joby Shimomura, Chief of Staff, Office of the Governor
Kelly Wicker, Deputy Chief of Staff, Office of the Governor
Miguel Pérez-Gibson, Executive Director of Legislative Affairs, Office of the Governor
Matt Steuerwalt, Director, Executive Policy Office, Office of the Governor
Tracy Guerin, Deputy Director, Office of Financial Management
Wendy Korthuis-Smith, Director, Results Washington, Office of the Governor
Tammy Firkins, Performance Audit Liaison, Results Washington, Office of the Governor
Jim Anderson, Criminal Records Division, Washington State Patrol
Dr. Donald Sorenson, Risk Management Division, Washington State Patrol

Criminal HIstory Records :: Agency Response | 20

OFFICIAL STATE CABINET AGENCY RESPONSE TO THE PERFORMANCE AUDIT ON IMPROVING
THE COMPLETENESS OF WASHINGTON’S CRIMINAL HISTORY RECORDS DATABASE
JUNE 11, 2015
This coordinated management response to the State Auditor’s Office (SAO) performance audit
report received May 28, 2015, is provided by the Washington State Patrol (WSP) and the Office of
Financial Management (OFM).
SAO Performance Audit Objectives:
The SAO designed the performance audit to answer the question:
1. Are Washington criminal history records complete, and if not, why not?

SAO Finding 1: Washington’s criminal history record database is incomplete.
SAO Finding 2: Missing fingerprints and Process Control Numbers (PCNs) contribute to
incomplete criminal history records.
SAO Finding 3: Patrol could do more to improve the completeness of the criminal history database
known as the Washington State Identification System (WASIS).
SAO Finding 4: Several factors make it difficult for the Patrol to take action to improve the
completeness of WASIS.

SAO Recommendation 1: Seek changes to state laws and/or administrative rules to require all
persons arrested for gross misdemeanors be fingerprinted.
STATE RESPONSE: WSP will explore this recommendation with stakeholders to determine the
best course of action about possible legislative changes. Legislative changes requiring all persons
arrested for gross misdemeanors to be fingerprinted would have significant workload and fiscal
impacts on law enforcement agencies and jails.
Action Steps and Time Frame
Ì

Establish a work group with stakeholders to include the Administrative Office of the Courts
(AOC) and Washington Association of Sheriffs & Police Chiefs to determine the best strategy
for addressing the recommendation. By March 15, 2016.

Ì

Deliver legislative/rulemaking recommendations to WSP executive staff. By April 30, 2016.

Ì

Discuss potential legislative changes with OFM. By September 15, 2016.

SAO Recommendation 2: Seek changes to state laws and/or administrative rules to require law
enforcement agencies and courts use PCNs when entering disposition information.

Criminal HIstory Records :: Agency Response | 21

STATE RESPONSE: WSP will explore this recommendation with stakeholders to determine the
best course of action about possible legislative changes. The PCN is already required (WAC 44616-070) at the time of fingerprinting and for electronic disposition submission from the AOC
Judicial Information System (JIS).
Action Steps and Time Frame
Ì

Establish a work group with stakeholders to include AOC and the Washington Association of
Sheriffs & Police Chiefs to determine the best strategy for addressing the recommendation. By
March 15, 2016.

Ì

Deliver legislative/rulemaking recommendations to WSP executive staff. By April 30, 2016.

Ì

Discuss potential legislative changes with OFM. By September 15, 2016.

SAO Recommendation 3: Clarify guidance provided to law enforcement agencies and courts on
the use of the Process Control Number (PCN) by providing more specific directions on its use and
how to address known issues when reporting criminal history record information.
STATE RESPONSE: To supplement free PCN training already provided by WSP, the agency will
update PCN written materials to include requirements that law enforcement agencies, prosecutors,
and courts must follow to submit the most accurate and complete criminal history record information.
Action Steps and Time Frame
Ì

Publish and distribute new PCN directions to law enforcement agencies and courts. By
December 31, 2015.

SAO Recommendation 4: Develop a targeted approach for working with local law enforcement
agencies and courts to improve the completeness of the state’s criminal history records, including
identifying those not performing as well; working with them to identify areas of weaknesses in their
processes and procedures; and providing them with targeted guidance and training to address the
identified weaknesses.
STATE RESPONSE: WSP will continue efforts that began in 2013, including meeting with staff
from county law enforcement agencies, related courts, prosecutor offices and jails, to discuss
methods and best practices on submitting arrest cards and dispositions. The objective is to enhance
the completeness and accuracy of criminal history records information contained in the criminal
history records database.
Action Steps and Time Frame
Ì

Meet with staff from county law enforcement agencies, related courts, prosecutor offices, and
jails to discuss requirements for submitting arrest cards and dispositions. Ongoing.

2
Criminal HIstory Records :: Agency Response | 22

SAO Recommendation 5: Continue current efforts to cooperate with the Administrative Office of
the Courts to regularly share information and ideas on how to improve the completeness of criminal
history records including how to improve communication and interactions with the state’s courts,
and how to ensure that courts use PCNs when entering dispositions in the JIS.
STATE RESPONSE: WSP will continue efforts with AOC to regularly share information and
ideas on how to improve the completeness and accuracy of criminal history records. These efforts
include exploring electronic methods to transmit and receive data in the criminal history records
database. Additionally, WSP continues to accept invitations to attend court clerk conferences to
present about criminal history record information requirements and requirements for taking and
submitting fingerprints and disposition information.
Action Steps and Time Frame
Ì

Collaborate with AOC on ways to improve the completeness of criminal history information.
Ongoing.

SAO Recommendation 6: Develop a process to regularly reconcile the disposition information
contained in and received from the Judicial Information System to the disposition information
present in the state’s criminal history records database.
STATE RESPONSE: WSP has already developed a process to daily reconcile the disposition
information submitted from the JIS. Completed.
Action Steps and Time Frame
Ì

Reconcile disposition information received from the courts to the disposition information that is
entered into the state’s criminal history records database. Ongoing.

3
Criminal HIstory Records :: Agency Response | 23

Appendix A: Initiative 900
Initiative 900, approved by Washington voters in 2005 and enacted into state law in 2006, authorized the State
Auditor’s Office to conduct independent, comprehensive performance audits of state and local governments.
Specifically, the law directs the Auditor’s Office to “review and analyze the economy, efficiency, and effectiveness
of the policies, management, fiscal affairs, and operations of state and local governments, agencies, programs, and
accounts.” Performance audits are to be conducted according to U.S. General Accountability Office government
auditing standards.
In addition, the law identifies nine elements that are to be considered within the scope of each performance audit.
The State Auditor’s Office evaluates the relevance of all nine elements to each audit. The table below indicates which
elements are addressed in the audit. Specific issues are discussed in the Results and Recommendations section of
this report.
I-900 element
1.

Identify cost savings

2.

Identify services that can be reduced or
eliminated

3.

Identify programs or services that can be
transferred to the private sector

4.

Analyze gaps or overlaps in programs or
services and provide recommendations to
correct them
Assess feasibility of pooling information
technology systems within the
department

5.

6.

7.

8.

9.

Analyze departmental roles and
functions, and provide recommendations
to change or eliminate them
Provide recommendations for statutory
or regulatory changes that may be
necessary for the department to properly
carry out its functions
Analyze departmental performance,
data performance measures, and
self-assessment systems
Identify relevant best practices

Addressed in the audit
No. The purpose of this audit was to determine the completeness of criminal
history records and why they might be incomplete, not on identifying cost
savings.
No. The state is required by federal law to maintain a database (WASIS)
of criminal history records in order to participate in the federal fingerprint
based background check program. Therefore, we did not consider a
reduction or elimination of services.
No. The purpose of this audit was to determine the completeness of
criminal history records and to identify ways to improve the level of
completeness. It did not consider whether any of the processes related to
WASIS could be transferred to the private sector.
Yes. In determining why WASIS was incomplete, we looked at whether gaps
in the process to enter arrest and disposition information into WASIS might
be the cause.
No. The purpose of this audit was to determine the completeness of
criminal history records and why they might be incomplete. While we did
look at the two information systems used in the criminal history record
reporting process, we did so to determine how they impact the completeness
of WASIS, not whether they could by pooled.
Yes. The audit identified key personnel and their roles and responsibilities
in the state’s criminal history records reporting process and determined
where improvements could be made.
Yes. The audit identified laws that create opportunities for offenders to
not be fingerprinted and recommended changes to these laws to require
fingerprints be taken in order to improve the completeness of WASIS.
Yes. The rate of completeness of WASIS is a measure of performance for
the Patrol. Our audit evaluated how the Patrol measures completeness and
makes recommendations to improve both how performance is measured
and how to improve the rate of completeness.
Yes. We used strategies from the federal government on how to improve
disposition reporting in our evaluation of the state’s criminal history record
reporting process and in formulating our recommendations.
Criminal History Records :: Appendix A | 24

Appendix B: State Laws Relevant to Ensuring the
Completeness of WASIS
This appendix includes several state laws that are relevant to the completeness of WASIS. Italics are used
to show wording that most impacts criminal history record completeness.
•

Reporting entities (law enforcement and courts) are required to provide arrest and disposition
information to the Patrol for retention in WASIS
RCW 43.43.740: Photographing and fingerprinting — Transmittal of data.
(1) It shall be the duty of the sheriff or director of public safety of every county, and the chief
of police of every city or town, and of every chief officer of other law enforcement agencies
duly operating within this state to furnish within seventy-two hours from the time of arrest
to the section the required sets of fingerprints together with other identifying data as may
be prescribed by the chief, of any person lawfully arrested, fingerprinted, and photographed
pursuant to RCW 43.43.735…
RCW 43.43.745: Convicted persons, fingerprinting required, records — Furloughs, information
to section, notice to local agencies — Arrests, disposition information — Convicts, information to
section, notice to local agencies — Registration of sex offenders.
(1) It shall be the duty of the sheriff or director of public safety of every county, or the chief
of police of each city or town, or of every chief officer of other law enforcement agencies
operating within this state, to record the fingerprints of all persons held in or remanded to
their custody when convicted of any crime as provided in RCW 43.43.735 for which the penalty
of imprisonment might be imposed and to disseminate and file such fingerprints in the same
manner as those recorded upon arrest pursuant to RCW 43.43.745 and 43.43.740.
(3) Disposition of the charge for which the arrest was made shall be reported to the section at
whatever stage in the proceedings a final disposition occurs by the arresting law enforcement
agency, county prosecutor, city attorney, or court having jurisdiction over the offense:
PROVIDED, That the chief shall promulgate rules pursuant to chapter 34.05 RCW to carry
out the provisions of this subsection.
RCW 10.97.045: Disposition data to initiating agency and state patrol.
Whenever a court or other criminal justice agency reaches a disposition of a criminal
proceeding, the court or other criminal justice agency shall furnish the disposition data to the
agency initiating the criminal history record for that charge and to the identification section
of the Washington state patrol as required under RCW 43.43.745…
RCW 10.98.050: Officials’ duties.
(1) It is the duty of the chief law enforcement officer or the local director of corrections to
transmit within seventy-two hours from the time of arrest to the section fingerprints together
with other identifying data as may be prescribed by the section, and statutory violations of
any person lawfully arrested, fingerprinted, and photographed under RCW 43.43.735. The
disposition report shall be transmitted to the prosecuting attorney, county clerk, or appropriate
court of limited jurisdiction, whichever is responsible for transmitting the report to the section
under RCW 10.98.010.
(2) At the preliminary hearing or the arraignment of a felony case, the judge shall ensure that
the felony defendants have been fingerprinted and an arrest and fingerprint form transmitted
to the section. In cases where fingerprints have not been taken, the judge shall order the
chief law enforcement officer of the jurisdiction or the local director of corrections, or, in the
case of a juvenile, the juvenile court administrator to initiate an arrest and fingerprint form
and transmit it to the section. The disposition report shall be transmitted to the prosecuting
attorney.
Criminal History Records :: Appendix B | 25

RCW 10.98.090 Disposition forms — Coding.
(1) In all cases where an arrest and fingerprint form is transmitted to the section, the originating
agency shall code the form indicating which agency is initially responsible for reporting the
disposition to the section. Coding shall include but not be limited to the prosecuting attorney,
superior court, district court, municipal court, or the originating agency.
(2) In the case of a superior court or felony disposition, the county clerk or prosecuting
attorney shall promptly transmit the completed disposition information to the section… In a
county where the judicial information system or other secure method of electronic transfer of
information has been implemented between the court and the section, the county clerk shall
electronically provide the disposition information… In the case of a lower court disposition,
the district or municipal court administrator shall either promptly transmit the completed
disposition form or, in a county where the judicial information system or other secure method
of electronic transfer of information has been implemented between the court and the section,
electronically provide the disposition information to the section. For all other dispositions the
originating agency shall promptly transmit the completed disposition form to the section.
•

Fingerprint cards are to include a unique tracking number and identification as defined by the Patrol
RCW 10.98.060: Arrest and fingerprint form.
The arrest and fingerprint form shall include but not be limited to the following:
(1) Unique numbers associated with the arrest charges. The unique numbering system may
be controlled by the local law enforcement agency; however, the section shall approve of the
numbering system and maintain a current catalog of approved local numbering systems.
The purpose of the unique numbering system is to allow tracking of arrest charges through
disposition;
(2) An organization code;
(3) Date of arrest;
(4) Local identification number;
(5) The prescribed fingerprints;
(6) Individual identification information and other information prescribed by the section.

•

Individuals arrested for violations punishable as gross misdemeanors are not required to be fingerprinted
at time of arrest if not taken into custody – “Cite and Release”
RCW 43.43.735 - Photographing and fingerprinting — Powers and duties of law enforcement agencies
— Other data.
(1) It shall be the duty of the sheriff or director of public safety of every county, and the chief of
police of every city or town, and of every chief officer of other law enforcement agencies duly
operating within this state, to cause the photographing and fingerprinting of all adults and
juveniles lawfully arrested for the commission of any criminal offense constituting a felony
or gross misdemeanor. (a) When such juveniles are brought directly to a juvenile detention
facility, the juvenile court administrator is also authorized, but not required, to cause the
photographing, fingerprinting, and record transmittal to the appropriate law enforcement
agency; and (b) a further exception may be made when the arrest is for a violation punishable
as a gross misdemeanor and the arrested person is not taken into custody.

Criminal History Records :: Appendix B | 26