The discussion of police use of force concludes that police agencies should consider developing guidelines that provide police officers with a range of options within which to make decisions regarding the appropriate level of force in particular situations. In addition, sustained training sessions that include practical application of the principles to realistic scenarios will increase the skill and confidence of police officers. Policy and training should balance citizens' rights to be free from unreasonable seizures and the interests of society in maintaining effective law enforcement while protecting the officers who must perform that duty. The data on the 116 police deaths revealed that 56 were shot to death, 2 were knifed to death, 1 was beaten, 1 was strangled, and the rest died of accidents or job-related illness. Body armor saved nearly 160 officers' lives; this was the first year in which more saves than deaths occurred and appeared to result from the increased use of soft body armor. One of the judicial decisions demonstrated that an employee in a high-profile, policy making position cannot make public statements, even on an issue of public concern, which are at odds with the employer's mission. The other case demonstrated that speech, even on issues of public concern, is not protected by the First Amendment when it occurs in a private setting rather than in a public forum. Table and reference notes