agency and the new agency would be unlikely to have learned of the case in the media. Incentives for hiring unsuitable staff Gypsy cops usually move from agency to agency as lateral transfers, or law enforcement officers that have already been trained and certified. Lateral transfers are often preferred over new recruits as the hiring process is simplified. Some smaller agencies knowingly hire gypsy cops because they have difficulty in recruiting suitable officers. That may be because of a smaller population to recruit from, lower pay, limited training and growth potential, less exciting police activity and even less prestige. The vacancy of even one officer in a small agency of fewer than 10 officers can create substantial hardships on an agency that must provide 24-hour coverage to the community it serves. The agencies have a great incentive to fill the vacancy quickly, even if it means hiring someone unsuitable. Incentives for concealing a misconduct dismissal Problem officers are often allowed to resign in seemingly good standing and then go to another unsuspecting agency with a good recommendation from a previous chief or sheriff, who is eager to get rid of the problem officer. In other cases, small agencies with limited budgets may fear a costly lawsuit if they dismiss an officer through a formal disciplinary process. An officer who is facing a misconduct dismissal will often threaten the agency and its governmental entity with costly, lengthy, and unflattering litigation for wrongful discipline or wrongful unfit or adverse termination and make such claims public. An officer finally can often negotiate a positive departure from an agency once they realize that they can no longer continue to work there. They can leave with an apparent clean and positive record and the agency is simply relieved to be rid of the officer, who goes to another unsuspecting agency. Attempts to report problem officers by agencies can be overruled and overturned by administrative law hearings and actions. Such a ruling can be interpreted as a rebuke of the agency and can be a basis for the officer to litigate against the reporting agency. Fear of this potential outcome is also a factor in many agency heads simply taking the path of least resistance and giving a separating officer a positive report of separation. Most states have a consolidated retirement system for state, county and municipal peace officers, which is unaffected by transfers between agencies