In 2010, the ACLU found hundreds of incidents of police spying on legal political and protest activity in thirty-three states since 2001.28 In 2003, Oakland police infiltrated an anti-police-brutality organization and played an active role in planning and coordinating events, including the route of a march. This represents a fundamental conflict of interest and abuse of police power and crosses the line from passive observation into active manipulation. The impropriety is compounded by the fact that the target of these demonstrations was the police themselves.
