HomeMy WebLinkAboutAgenda Statement 1989/10/03 Item 9 COUNCIL AGENDA STATEMENT
Item -11r 9
Meeting Date 9/26 "r /0 31 j'
ITEM TITLE: Ordinance 3 31J
Z 'Amending Sections 2.52.040, 2.52.050 and
2.52.060 and Adding Sections 2.52.105, and 2.52.165 to the
Chula Vista Municipal Code Relating to Campaign Contribution
Disqualification and Disclosure
SUBMITTED BY: City Attorne '..---P
(4/5ths Vote: Yes No X )
The proposed ordinance would:
1. Prohibit campaign contributions prior to .January 1 of an election year;
2. Aggregate contributions from officers and agents of an organization
and require abstention if they total more than $2,500;
3. Extend the period during which a councilmember must abstain when the
aggregated contribution exceeds $2,500 to the councilmember's entire
term in office;
4. Require notice when a candidate contributes $5,000 or more of personal
funds to the campaign;
5. Clarify and emphasize the prohibition against "coerced" contributions.
6. Define "agent" consistent with the definition in the California
Administrative Code (Section 18438.3) .
7. Clarify that when a candidate is running for reelection or another
city office, the candidate may seek contributions from people who
contributed to his or her prior campaign.
RECOMMENDATION: Reduce the notice period for candidates' contributions to
their own campaign to 21 days and place the ordinance on
its first reading
BOARDS/COMMISSIONS RECOMMENDATION: The Charter Review Committee approved
the proposal to aggregate contributions (4-1), the proposal to extend the
disqualification period to the full term of office (3-2) and the proposal to
require notice when a candidate contributes personal funds in excess of $5,000
(5-0) .
Agenda Item No. 12- J
Meeting Date: 9/_26-/Z /0/3/81
81
Page 2
DISCUSSION:
At its joint meeting with the Charter Review Committee on August 24, 1989, the
City Council discussed the proposed amendments and directed staff to come back
with revisions. The latest revisions are underlined in the attached ordinance.
CONTRIBUTIONS MAY ONLY BE MADE IN AN ELECTION YEAR (CVMC §2.52.050A)
At Council's direction, this new section has been added which prohibits
contributions in any year but an election year. The language is similar to
the language in Proposition 68. Candidates will not be able to accept
contributions until January 1 of the election year. This will essentially cut
the fund raising period to ten months.
AGGREGATE CONTRIBUTIONS - ABSTENTION WHEN MORE THAN $2,500 (CVMC §2.52.165
A,B,D)
Council did not make a final decision on whether_to require abstention when
aggregated contributions exceed a certain amount. For purposes of
consideration, Council did direct that the amount in question be increased
from $250 to $2,500. The reason this amount was increased was because $250
was felt to be too restrictive. The example given was if 25 members of the
Chamber of Commerce gave more than $10 each to a councilmember, that
councilmember would have to abstain on matters affecting the Chamber.
The proposed ordinance would require councilmembers to abstain if they have
received in aggregate $2,500 from a party, participant or their agents or
officers. Parties and participants would have a duty to disclose this on the
record.
THE ABSTENTION PERIOD INCLUDES THE ENTIRE TERM OF OFFICE (CVMC §2.52.040F and
§2.52.165B)
Since Council did not make a final decision on whether to aggregate
contributions, there was also no final decision on how long the period of
abstention will be when aggregated contributions exceed $2,500. Under the
proposal before the City Council, councilmembers would be required to abstain
during their entire term of office. The Charter Review Committee voted 3-2 in
favor of this proposal.
Generally, the Political Reform Act requires an official to abstain for 12
months. The problem with this approach is that it might not deter
contributors from seeking to purchase influence with councilmembers when they
know that the councilmember is going to be participating in important
decisions affecting their interest later on in the councilmember's term of
office.
Agenda Item No. k2 0
Meeting Date: 9l /0
.2-6/T9--
Page 3
SIXTY DAYS NOTICE WHEN A CANDIDATE CONTRIBUTES $5,000 OR MORE IN PERSONAL
FUNDS TO CAMPAIGN (CVMC §2.52.105A)
At the joint meeting, Council opted for the Charter Review Committee's
recommendation requiring notice over staff's recommendation that would have
suspended contribution limits for rival candidates. The proposed ordinance
would now require a candidate to give 24 hours notice of a contribution to his
or her own campaign fund if the amount is more than $5,000. This part is
similar to state law. See Gov. Code §§84203 and 84204.
The potentially controversial aspect of this new regulation is that the notice
must be given at least 60 days before the election. If the candidate fails to
give timely notice, this section works as a prohibition of the contribution.
A candidate wishing to challenge this provision would characterize it as a
prohibition upon the right to expend his or her own funds. The candidate
might argue that he or she didn't have reason to know that the contribution
was necessary until after the notice period had elapsed and that the
restriction is, therefore, unreasonable. Buckley _v. Valeo (1976) 424 U.S.1;
46 L.Ed.2d 659, held that government may not limit the amount of money a
candidate contributes to his or her own campaign.
The Buckley case has resulted in wealthy candidates being given a distinct
advantage in campaigns. This runs directly counter to our own goals of
creating a "level playing field" and reducing the influence of money in city
elections. There is no question now that political expression lies at the
core of First Amendment values. Buckley, supra. Nevertheless, in other areas
dealing with First Amendment expression, the courts have upheld reasonable
"time, place and manner" restrictions on First Amendment rights. (See Ward v.
Rock Against Racism (1989) U.S. , 57 U.S.L. Week 4879). Our proposed
regulation does not prohibit a candidate _from contributing to his or her own
campaign, but merely puts a time and manner restriction on this contribution.
Last month, Justice Benke, writing for the Fourth District Court of Appeal in
Sundance Saloon, Inc. v. San Diego 89 D.A.R. 11078, discussed the standard for
time, place and manner restrictions and stated:
Perhaps the classic statement as to when time, place and
manner restrictions on protected speech are proper was
made by Justice Warren in United States v. O'Brien (1968)
391 U.S. 367, 377 (88 S.Ct. 1673) : "A government
regulation is sufficiently justified if it is within the
constitutional power of the government; if it furthers an
important or substantial governmental interest; if the
governmental interest is unrelated to the suppression of
free speech; and if the incidental restriction on alleged
First Amendment freedoms is no greater than is essential
to the furtherance of that interest."
Agenda Item No. - q 013/n
Meeting Date: 90
Page 4
The City does have a substantial interest in assuring that public office is
open to anyone and that personal wealth is not the determinative factor in who
gets elected. The purpose of the regulation is not to "suppress the free
expression" of the wealthy candidate, but rather to give all candidates a
reasonable time to react to the infusion of one candidate's personal wealth
into the campaign. The regulation is as narrowly drawn as is practicable. If
candidates don't have at least sixty days to react, there will be insufficient
time to raise "combating" contributions and prepare a response prior to the
election.
This regulation is an innovative approach to the problem associated with
wealthy candidates and we have no assurance that the courts are going to
uphold its validity. Courts do not show the same deference to legislative
actions when First Amendment rights are involved as they do in less sensitive
areas. Spiritual Psychic Science Church v. City of Azusa (1985) 39 Cal.3d
501, 514, 217 Cal.Rptr. 225. The "safe" approach would be to delete this
regulation from the ordinance or to reduce the amount of notice required from
60 days to some lesser time. Much depends on what-our theory is for requiring
this notice. If the theory is that the rival candidates will now have a
reasonable chance to raise "combating" funds, it would be difficult to make
this work without 60 days notice. If the theory is that the candidates will
be able to raise this issue at candidate forums and with the media, then three
weeks may be sufficient time.
It's going to come down to a balancing test between the City's interest in
limiting the influence of money on its elections and the candidate's right to
express support for his or her own candidacy by using his or her own funds.
The scale is going to be tilted against the City because this is a highly
protected right. Given the constitutional constraints, it would be my
recommendation that we reduce the notice period to 21 days and rely primarily
on candidate's forums and the media to remedy the problem.
EXPENDITURES OF $5,000 OR MORE BY INDEPENDENT COMMITTEES (CVMC §2.52.106)
At the conclusion of the joint meeting, Council directed staff to draft a
provision dealing with independent expenditures similar to the provision
dealing with contributions by a candidate to his or her own campaign. The
proposed amendment is attached as Exhibit "A" to this report, but is not
included in the ordinance.
The notice requirement creates a different problem when applied to independent
expenditures as opposed to contributions to one own's candidacy. A candidate
knows at least 88 days before the election that he is she is running for
office because that is when the candidate must file for the office. (Ca.
Election Code §22302.5) . A person who might wish to make an independent
Agenda Item No. 112' q 0 1316'7
Meeting Date: 9/
Page 5
expenditure might not receive very much information about the candidates for a
local office until the last month prior to the election. Typically, that is
when campaigns for local office heat up and the general public starts to see
flyers, debates, candidate forums and press coverage. The campaign itself is
an educational process for the voters and they might not make up their minds
until just before the election after they have had an opportunity to consider
the information that comes out of this process. At that point, if the person
wanted to make an independent expenditure our ordinance would prohibit it
because the person failed to give the proper notice.
The person wishing to make the independent expenditure would be able to make a
strong argument that our ordinance is actually a prohibition against
independent expenditures. By the time a person reasonably could be informed
about the candidates and could make a decision as to whom to support, our
ordinance would prohibit the independent expenditure. It is clear that the
court considers independent expenditures to be constitutionally protected
expression. FEC v. National Conservative Political Action Committee (1985)
470 U.S. 480; 105 S.Ct. 1459; 84 L.Ed2d 455. This protection of independent
expenditures has created a loophole which politically sophisticated
individuals and organizations will undoubtedly exploit. While our proposed
regulation would help to deter the resulting unfairness, it could also result
in the de facto prohibition of legitimate independent expenditures in
violation of First Amendment rights. In FEC v. Nat. Conservative Political
Action Committee, the court found that no countervailing governmental interest
was sufficiently strong enough to justify a $1,000 limitation on independent
expenditures by political action committees. Given the lack of deference to
legislative action in this sensitive area, there would be considerable risk
that this regulation would be found to be invalid.
"COERCED" CONTRIBUTIONS PROHIBITED (CVMC §2.52.060B)
The proposed amendment emphasizes and strengthens the prohibition against
contributions which are "financed, maintained or controlled" by anyone other
than the person making the contribution.
"AGENT" DEFINED PER STATE LAW (CVMC §2.52.040A)
The definition of "agent" used in the Political Reform Act (see Admin. Code
§l8438.3) is now included in the City Code. "Agent" includes anyone who
represents a party or participant in connection with a proceeding involving a
license, permit or other entitlement for use. If the agent is also acting as
an employee or member of a law, architectural, engineering or consulting firm,
both the individual and the firm are "agents".
CONTRIBUTIONS IN SUBSEQUENT ELECTIONS (CVMC §2.52.050C)
Council directed that the ordinance be clarified so that when a councilmember
is running for reelection, the Councilmember may go back to a contributor to
their prior election and seek another contribution for the reelection
Agenda Item No. 1,2- ' /
Meeting Date: 9/2 -& /Vi 3( e�
Page 6
campaign. This same logic would apply to a councilmember running for the
Mayor's office or for a Mayor running for a Council seat. Section 2.52.050C
specifically allows this.
FISCAL IMPACT: There could be some additional enforcement costs associated
with aggregated contributions. It would be difficult to predict how much this
would be at this time.
6198a
Item 1-2"
EXHIBIT "A"
Sec. 2. 52 .106 Independent Campaign Expenditures or
Contributions .
A. No individual or committee shall expend or contribute
more than $5,000 in support of a City candidate
unless and until the following conditions are met:
(1) Written notice of the individual or
organization ' s intent to expend in excess of
$5,000 shall be provided to the City Clerk. The
notice shall be delivered personally or sent by
registered mail and shall specify the amount to
be expended or contributed; and
( 2) The required notice shall be given no later than
twenty-four ( 24) hours after the date of the
expenditure or sixty ( 60) days prior to the
election, whichever occurs first.
'4 •
by the City Coun 91 of
Chula Vista, California
Dated 9-° g
COUNCIL AGENDA STATEMENT
Item 9
Meeting Date 10/3/89
ITEM TITLE: Ordinance 2334 - Amending Sections 2 . 52. 040 , 2. 52. 040 & 2. 52. 060
and Adding Sections 2. 52. 105 and 2. 52. 165 to the Municipal Code
Relating to Campaign ontribution Disqualification and Disclosure
SUBMITTED BY: City Attorney gik (4/5ths Vote: Yes No X )
AO
The ordinance has been revised pursuant to Council direction
at its September 26, 1989 meeting to limit the notice period
of personal contributions to 21 days and set at $1, 000 the
limit on aggregate contributions before abstention is
required.
RECOMMENDATION: Place ordinance .on second reading and
adoption.
beerCei /Padeht.
by the City Council of
Chula Vista, California
14 -5-842
Dated
•
Form A-113 (Rev. 11/79)
j 1 r
I �
1 . _J
DISPOSAL CORPORATION 6670 Federal Boulevard
Lemon Grove,California 92045(619)287-7555:
Mayor Greg Cox and
City Council Members
City of Chula Vista
276 Fourth Avenue
Chula Vista, Ca. 92010
August 31 , 1989
Dear Mayor Cox,
Pursuant to the letter received from Assistant City Attorney
D. Richard Rudolf regarding matters arising from Edco Disposal
Corporation' s contractual agreement with the State of California
School Systems , namely the Sweetwater Union Hiah Schooll District.
We would like to apply for a franchise per Mr. Rudolf ' s instruct-
ions . Whereby we will provide trash removal service to those
school sites located within the City of Chula Vista.
We understand that the necessary documents are being prepared
for signture . Please keep us informed . Thank you.
Very truely yours ,
EDCO DISPOSAL CORPORATION
cc.
D. Richard Rudolf
Assistant City Attorney
Eugene Asmus
Assistant City Manager