Only two cities, Philadelphia and New York, have used civilian review boards. In both cases, the boards were short-lived, and they failed to develop an effective civilian oversight function. This probably was the result both of police antipathy and their extremely limited powers. As a result of municipal liability in civil rights actions, a number of cities have established complaint bodies. One model, using internal civilian investigation, is exemplified by Chicago's Office of Professional Standards (OPS). The OPS is located within the police department and has available to it police resources for investigation of complaints. However, the OPS handles only the most serious complaints (others are handled by the Internal Affairs Division) and is unable to require that disciplinary action be taken. The Detroit Board of Police Commissioners is a civilian administrative body authorized both to control a department's internal complaints system and conduct independent investigations. The Board has powers to determine police policies and regulations, approve police budgets, and serve as the final appellate authority for employee discipline. Its Office of Chief Investigator has full access to department records; authority to interrogate officers; and receives, screens, and assigns for investigation all citizen complaints. In Flint, Mich.; an omsbudsman has power to subpoena witnesses, take testimony, and gather evidence relating to citizen complaints against all city employees and departments. However, the omsbudsman must be formally notified by police and cannot require disciplinary action. 37 footnotes.