Memphis Security Insider Independent Coverage · Est. 2018
Industry News

DOJ Investigation Into MPD Could Reshape Memphis Private Security for Years

Sarah Chen · · 8 min read

On January 7, 2023, five Memphis police officers beat Tyre Nichols during a traffic stop near Raines Road and Ross Road. He died three days later. Within two weeks, all five officers were fired and charged with second-degree murder. MPD disbanded the SCORPION unit they belonged to. And by July of that year, the U.S. Department of Justice had opened a pattern-or-practice investigation into the entire Memphis Police Department.

Fifteen months into that investigation, the private security industry in Memphis is already feeling the effects. If you run a TDCI-licensed contract security company in Tennessee, the next two years could be the most consequential of your career.

What a Pattern-or-Practice Investigation Actually Means

The DOJ’s authority to investigate local police departments comes from 34 U.S.C. Section 12601. The probe into MPD is examining whether the department engaged in a pattern of excessive force, unreasonable searches and seizures, or discriminatory policing. Investigators from the DOJ’s Civil Rights Division have been in Memphis since mid-2023, reviewing records, interviewing officers, and meeting with community members.

This is the same process that produced consent decrees in Baltimore, Chicago, Cleveland, Ferguson, and more than two dozen other cities since the 1990s. The playbook is well established. DOJ investigates. DOJ publishes findings. The city either agrees to a consent decree (a court-supervised reform plan) or faces a federal lawsuit.

Memphis city officials have cooperated with the investigation. Mayor Paul Young has said publicly that the city wants to work with federal authorities, not fight them. That tone is worth noting because cities that resist (like pre-Nichols Memphis under Jim Strickland’s initial approach to police oversight) tend to get harsher terms in the eventual agreement.

Nobody knows exactly what DOJ will find or when the report drops. Based on timelines from comparable investigations, a findings letter could come as early as late 2024 or sometime in 2025. The investigation into Louisville Metro Police after the Breonna Taylor case took about 16 months from opening to published findings. MPD’s probe is now at the 15-month mark.

The Federal Trial Changes the Calculus

The criminal case against the former SCORPION officers is proceeding on a parallel track. Federal prosecutors charged all five with civil rights violations. Jury selection for the federal trial could begin later this year or early 2025.

This matters for the security industry because the trial will keep MPD reform in the national spotlight for months. Every week of testimony means another round of headlines about police violence in Memphis. Every headline makes it harder for MPD to recruit new officers. And every unfilled patrol position creates a gap that private security companies are being asked to fill.

MPD’s authorized strength is roughly 2,000 sworn officers. Actual headcount has hovered around 1,700 to 1,800 for most of the past year, depending on which numbers you trust. The recruiting pipeline has slowed since the Nichols case. Starting pay increases approved in 2023 helped, but they haven’t solved the problem. Young officers are harder to attract to a department under federal investigation. Lateral transfers from other agencies have slowed.

The math is straightforward: fewer cops on the street means more demand for private security.

Private Security Companies Are Already Seeing It

Three security company owners I spoke with over the past month all described the same trend. RFP volume is up. Property managers who previously relied on MPD patrol coverage for their complexes are now budgeting for contracted guard services. Apartment complexes in Hickory Hill and Raleigh that never had security are now putting out bids.

“We’ve gotten more cold calls in Q1 of this year than all of 2023,” one owner of a mid-size Memphis firm told me. He asked not to be named because several of his contracts are with city-affiliated properties. “It’s not just the volume. The size of the contracts is bigger. People want armed officers. They want 24/7 coverage. A year ago, they wanted a guard on weekends.”

This tracks with what happened in other cities after DOJ investigations. In Baltimore, after the consent decree following Freddie Gray’s death, private security spending by businesses and property managers increased an estimated 30% over three years, according to ASIS International data. Cleveland saw similar growth. The pattern repeats because the underlying dynamic is the same: police departments under consent decrees pull back from discretionary enforcement while they retrain, restructure, and comply with new use-of-force policies. Property owners and business operators fill the gap with private security.

If the DOJ issues findings and Memphis agrees to a consent decree (the most likely outcome based on the city’s cooperative posture), the reforms would probably include new use-of-force policies, enhanced de-escalation training, changes to vehicle pursuit protocols, additional oversight mechanisms, and mandatory data collection on stops and arrests.

Every one of those reforms takes time to implement. Training cycles alone can eat 12 to 18 months. During that transition period, officers will be learning new procedures, supervisors will be adjusting to new accountability requirements, and the department’s overall operational tempo will slow.

That slowdown creates opportunity for private security in specific, predictable ways.

First: response times. If MPD officers are spending more time on documentation and compliance (consent decrees always increase paperwork), patrol coverage thins. Businesses that can’t afford longer response times will contract private armed response services. This is exactly what happened in Chicago after the 2019 consent decree there.

Second: proactive patrol. MPD has already pulled back on aggressive proactive policing since the SCORPION disbandment. A consent decree would formalize those restrictions. Property owners who relied on MPD drive-throughs as a deterrent will need to replace that presence with contracted patrol.

Third: special events. Consent decree cities often restrict how officers can be deployed to private events on overtime. That pushes event security demand entirely onto the private sector. Memphis, with its tourism economy centered on Beale Street, Graceland, FedExForum events, and Liberty Bowl games, has a substantial event security market.

The Licensing Framework Is Already in Place

Tennessee regulates private security under T.C.A. 62-35-101, the Private Protective Services Act. TDCI’s Board for Private Protective Services oversees company licensing, individual guard registration, and training requirements. The framework is mature and well-enforced compared to some states.

That matters because a surge in demand without adequate regulatory infrastructure creates problems. Tennessee doesn’t have that issue. The state requires background checks, minimum training hours, and active company licensure. Companies operating without proper TDCI credentials face fines and criminal penalties.

For established TDCI-licensed firms, this is an advantage. New entrants hoping to capitalize on increased demand will need to go through the full licensing process, which takes time. Companies that are already licensed, staffed, and operational have a head start that could be worth millions in new contracts over the next three to five years.

The Board processes about 4,000 individual guard registrations annually. If demand spikes the way it did in other consent decree cities, that number could jump 25% to 40% within two years. Whether TDCI has the administrative capacity to process that increase without bottlenecks is an open question. The Board’s staff hasn’t grown significantly in the past decade.

Positioning for What’s Coming

Smart security company operators in Memphis are already making moves. Some are investing in training infrastructure to get ahead of the staffing demand. Others are building relationships with commercial property management firms that are likely to need services once the consent decree process begins.

The companies best positioned are those with clean TDCI records, adequate insurance, trained armed personnel, and the operational flexibility to scale. A consent decree doesn’t create demand overnight. It creates a sustained, multi-year increase that rewards companies with the infrastructure to grow steadily.

There’s also a risk here that’s worth naming. If too many operators rush into the Memphis market chasing consent decree demand, quality drops. Untrained guards, sloppy operations, and cut-rate pricing undermine the entire industry’s credibility. The worst outcome for Memphis private security would be a consent decree that cleans up MPD while the private sector fills the gap with substandard service. TDCI enforcement will be tested.

The Waiting Game

The DOJ investigation is still officially ongoing. No findings letter has been issued. No consent decree has been negotiated. Everything described above is based on what happened in comparable cities, conversations with industry participants, and the observable trends already in motion.

Maybe DOJ’s findings will be narrow. Maybe Memphis negotiates a voluntary agreement instead of a full consent decree. Maybe MPD’s reforms under Chief Davis move fast enough that the operational impact is smaller than expected.

Those are real possibilities. They’re also the optimistic scenarios. Every security company owner I spoke with is planning for the more likely outcome: a consent decree that takes years to implement and fundamentally changes how public safety works in Memphis.

The federal trial of the former SCORPION officers will put this issue back in front of the country. The DOJ findings letter will put it in front of city hall. And the demand for private security, which is already climbing, will keep climbing regardless.

Tyre Nichols died fifteen months ago at a traffic stop a few miles from Baptist Memorial Hospital. The ripple effects of that night haven’t finished spreading. For the private security industry in Memphis, they may just be starting.

SC

Sarah Chen

Senior Analyst

Sarah specializes in security industry data, licensing trends, and regulatory analysis. She holds a degree in criminal justice from the University of Memphis.

Tags: DOJ Memphis police investigation 2024MPD reform private security impactTyre Nichols case security industryMemphis private security demand

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