 In 2013, Hogan-Howe was criticised for defending police officers who had, according to an appeal court ruling, used "inhuman and degrading treatment", in breach of the Human Rights Act, when handling an autistic boy in a swimming pool.The criticism was specifically directed against the money spent on the appeal and his refusal to apologise and to improve training police officers for the humane treatment of disabled people.In September 2012, Hogan-Howe did ask an independent commission headed by Lord Adebowale to review cases where people with a mental illness died or were harmed after contact with police.