OFFICER TOLD TO MEET STOP QUOTA
It wasn’t until months after King filed suit that his attorney, civil rights lawyer Stephen Drew, obtained what he deemed a critical piece of evidence through discovery.
It came in the form of a memo, issued the month before the traffic stop, to Abbate.

In the “counseling memo,” (PDF) Abbate’s supervisors chastised him for failing to meet “the mandatory minimum expectations for traffic stops.”
In the month of December 2018, Abbate had made 27 stops instead of the required 28.
“After meeting with you it is clear you understand you are required to make a minimum of 2 traffic stops for each 10-hour shift,” the memo signed by First Lt. David Robinson and Lt. Aaron Sawyer reads in part.


A copy of a counseling memo sent to Rockford Public Safety Office Zachary Abbate. 
Robinson is now Rockford’s police chief, while Sawyer is off the force after racking up two criminal convictions in separate incidents.

“It is important that you meet the minimum performance standards to avoid progressive discipline. We expect your performance will improve and we will be monitoring it closely over the next several months,” the memo concluded.
The document was dated Feb. 4, 2019. King was stopped March 20.
“It was astounding. It was, when I found that out,” King said. “Then it was frustrating. Then I was ticked off about it because it affected me.”
King’s attorney, Stephen Drew, said Rockford’s stop quota encourages bad policing and violates the spirit of Michigan’s ban on citation quotas.

It’s illegal in Michigan for police departments to enforce ticket quotas but the state law does not address stop quotas.
“If you have a policy like that and you’re enforcing it with discipline, it’s not positive for the citizens of Rockford who may be getting followed (by police),” Drew explained. “It’s not positive for the people coming to visit the residents of Rockford or even their businesses, and it certainly wasn’t positive for Mr. King. We think the evidence clearly shows that he did stop at the stop sign and that the traffic stop was a false pretense.”
In depositions, Robinson and Sawyer confirmed the department required its officers to make a certain number of stops.
In another court filing (PDF), the city’s attorneys pointed out officers did not have to make two stops every single shift. Instead, the lawyers wrote, officers needed to average two stops per shift each month.

“It is admitted that defendants had a policy in place in which all officers were required to average two traffic stops per every 10-hour shift per month,” wrote Rockford’s attorneys, Michael S. Bogren and Charles L. Bogren of Plunkett Cooney.

ROCKFORD SAYS STOP QUOTA NO LONGER EXISTS
Rockford DPS declined to comment for this report, citing the ongoing lawsuit.
But when Target 8 followed up to ask if the department still required two stops per shift, the Plunkett Cooney attorneys responded by email.
“Since that question is not directly in issue in the King litigation, the answer to your question is “no;” there is no such requirement,” Michael Bogren wrote.
Target 8 followed up to ask when and why the quota was discontinued but received no response.
In a deposition (PDF) dated Jan. 14, 2022, Aaron Sawyer told Stephen Drew the stop expectation, two per shift, was still in place to his knowledge. Sawyer resigned from the police department in December 2021.
“My question is, is the policy in place that was in place when you wrote this memo … as far as you know?” Drew asked in the January deposition.
“Yes, the expectations are still there,” Sawyer replied. “There’s not a written policy on it, it’s just an expectation.”
GRPD CHIEF: WE WON’T BE DOING QUOTAS
Grand Rapids’ new police chief, Eric Winstrom, mentioned the issue of enforcement quotas at a recent reception.
Later, Target 8 asked him to elaborate on his position regarding the practice.
“It’s not something the Grand Rapids Police Department does or will do while I’m here,” said Winstrom from his office at police headquarters.
Winstrom, who previously served more than twenty years with the Chicago Police Department, said quotas fail to consider conditions and context.
“Everyone may have been driving perfectly legally that day. There may have been very little traffic. It could be snow conditions,” explained Winstrom, who said there are some shifts during which an officer will make no traffic stops at all.
“It could be because you’re super busy with other stuff; it could be because there’s great driving going on, or not much driving going on,” he said.
Winstrom also stressed that stopping a vehicle is a seizure. 
“You’re stopping someone from going about their life, and we take that very seriously. It also could be a potentially dangerous situation depending on what’s going on. So, you need a good reason to make a traffic stop, and if the reason is because I was told I have to make x amount of traffic stops, that’s potentially a problem,” Winstrom said.
“(If a driver) says, ‘hey, I don’t think you had a reason to pull me over,’ now it seems like maybe the number (the officer) was trying to hit maybe crept into their brain. Maybe it wasn’t all about probable cause or reasonable suspicion,” explained Winstrom.
“We won’t be doing quotas here in the Grand Rapids Police Department.”
ACLU: QUOTAS ARE FLATLY UNCONSTITUTIONAL
Mark Fancher of the American Civil Liberties Union said quotas are “flatly unconstitutional.”
“To say that a police officer on the front end is going to have to stop people places extreme pressure on the officer to stop people when they lack the probable cause or reasonable suspicion that’s required by the Constitution,” explained Fancher in a Zoom interview.
Fancher also said quotas prompt officers to target people of color or drivers who clearly have little power.
“When police officers are aware of the fact that (quotas) are a questionable practice, one that is not fully on point with what the Constitution requires, then the thought processes they can conceivably go through are, ‘whomever I stop is potentially going to challenge this, so let me stop someone who is either simply not going to challenge it because they feel powerless… or if they do challenge it, they’re not going to have the kind of credibility that is going to result in my getting in trouble,'” Fancher said. 
He went on to explain, “So, unfortunately, because of racial history and racial stereotypes, their officers, when they do this analysis, conclude the people who are best to stop under these circumstances are people of color, or, if they’re white, people who are clearly powerless… low income.. or people who are not going to be credible.”