On the last day of the inquest into the death in custody of Aunty Tanya Day, her children have called for individual charges to be made against the Victoria Police officers involved in her death.
The 55-year-old grandmother was arrested at Castlemaine Train Station for public drunkenness in December 2017 after falling asleep on a VLine train bound for Melbourne.
After being taken into police custody, she hit her head several times in a police cell, and later died in hospital from her injuries.
The family says if there is no criminal investigation, there will be more deaths in custody.
"There is no doubt in our mind that Victoria Police are responsible for our mum's death, that she died in custody because police targeted her for being Aboriginal, then ignored her and left her to die on the floor of a police cell," daughter Belinda Day told reporters outside the court in Melbourne on Monday.
"Victoria Police still have not apologised for our mum's death. Without accountability, there will never be justice."
The family's submission also included requests for the Coroner to recommend police not investigate themselves, and called for her to make a ruling in favour of systemic racism.
They have argued that it, along with unconscious bias, played a "central role" in Ms Day's death, because public drunkenness laws were more likely to be applied to her as an Aboriginal woman.
In court, police counsel asked Coroner Caitlin English not to "be influenced by the opinions of the interested parties", but acknowledged the facts did "give rise to great concern".
Since the conclusion of the Royal Commission into Aboriginal Deaths in Custody in 1991, hundreds of Aboriginal have died in custody.
Nationwide, a police officer has never been criminally charged for an Indigenous death in custody.
"We have told the Coroner that the two most important things for us are that she finds that racism was a cause of our mum’s death and that she refer the police who were supposed to care for our mum for criminal investigation," Ms Day's son, Warren Stevens said in a closing statement.
"Without accountability, more Aboriginal people will die in custody."
Coroner Caitlin English will now take 6 months to consider submissions and evidence, and determine an outcome.