The Commission submitted formal comments to the Allegheny County Bar Association’s Administrative Law Sub-Committee, opposing the use of risk assessment tools in Allegheny County because of their minimal impact on public safety and tendency to incorporate structural racism into individuals’ pre-trial outcomes. The Sub-Committee was formed to address systemic inequality and racial oppression in our criminal justice system by seeking input and specific recommendations from interested stakeholders on ways to modernize state and local rules of court as they apply to bail, probation, and incarceration in Allegheny County.