HomeMy WebLinkAbout2011-05-19 BOE Ad Hoc PacketNOTICE OF SPECIAL MEETING
OF
AD HOC COMMITTEE OF THE BOARD OF ETHICS
CITY OF CHULA VISTA, CALIFORNIA
NOTICE IS HEREBY GIVEN THAT THE AD HOC COMMITTEE OF THE
BOARD OF ETHICS OF THE CITY OF CHULA VISTA WILL MEET IN
SPECIAL SESSION ON THURSDAY, MAY 19, 2011 AT 4:00 P.M. IN
THE EXECUTIVE CONFERENCE ROOM, LOCATED AT CITY HALL,
276 FOURTH AVENUE, CHULA VISTA, CALIFORNIA, TO CONSIDER
THE FOLLOWING:
Roll Call.
2. Review of Chapter 2.28.
3. Public Comments - This is an opportunity for the general public to address the
Board of Ethics on any subject matter that is not an agenda item.
4. Members' Comments.
5. Staff Comments.
Joyce M I. e ux, Secretary
The City of Chula Vista, in complying with the American With Disabilities Act, request individuals who require special
accommodations to access, attend and/or participate in a City meeting, activity or service request such accommodation at
least forty-eight (48) hours in advance for meetings and five (5) days for scheduled services and activities. Please contact
Legal Assistant Joyce Malveaux for specific information at (619) 691-5037 or Telecommunications Devices for the Deaf (TDD)
at (619) 476-5357. California Relay Service is also available for the hearing impaired.
At the discretion of the Board, all items appearing on this agenda, whether or not expressly listed for action, may be
deliberated and may be subject to action by the Board.
All public records relating to an agenda item on this agenda are available for public inspection at the time the record is
distributed to all, or a majority of all, members of the Board. Such records shall be available at the Office of the City Attorney
located at 276 4th Avenue, Chula Vista, California.
Notice Dated: 05/13/11
THE CHULA VISTA BOARD OF ETHICS IS COMMITTED TO HONOR THE
PUBLIC TRUST BY PROMOTING ETHICAL VALUES AND MONITORING
ETHICAL STANDARDS IN ALL ASPECTS OF CITY GOVERNMENT
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TY COUNCIL
STATEMENT
CITY OF
CHULAVISfA
Item No. 21
ITEM TITLE: ORDINANCE AMENDING CHULA VISTA MUNICIPAL
CODE CHAPTER 2.52, THE CITY'S CAMPAIGN
CONTRIBUTION ORDINANCE
SUBMITTED BY: BART C. MIESFELD, CITY ATTORNEY,yl\
REVIEWED BY: CITY ATTORNEY
4/5THS VOTE: YES 1-1 NO FX]
SUMMARY
At the October 12, 2010 City Council meeting, the City Attorney presented the City
Council with a report analyzing the City's Campaign Contributions ordinance and
identifying the provisions that were duplicative of the Political Reform Act ("PRA"), in
order to determine whether, and to what extent, the Fair Political Practices Commission
("FPPC") could enforce the ordinance. The City Council then directed the City
Attorney's office to return with amendments to the ordinance to: (i) delete the provisions
that duplicate the PRA; (ii) make updates necessitated by recent case law; and (iii) revise
the enforcement section. This item is brought forward in response to that direction.
ENVIRONMENTAL REVIEW
The Environmental Review Coordinator has reviewed the proposed activity for
compliance with the California Environmental Quality Act (CEQA) and has determined
that there is no possibility that the activity may have a significant effect on the
environment because it does not involve a physical change to the environment; therefore,
pursuant to Section 15061(b)(3) of the State CEQA Guidelines, the activity is not subject
to CEQA. Thus, no environmental review is necessary.
RECOMMENDATION
Council place the ordinance on first reading if it deems appropriate.
BOARDS/COMMISSION RECOMMENDATION
Not Applicable.
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NOVEMBER 23, 2010, Item Z
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DISCUSSION
1. BACKGROUND
The City's Charter requires the City Council to "adopt reasonable regulations related
to campaign contributions" in order to "avoid the potential for undue or improper
influence over elected officials resulting from excessive campaign contributions." The
regulations must be contained within the City's Municipal Code.' Chula Vista Municipal
Code Chapter 2.52, entitled, "Campaign Contributions," was enacted in 1989, in
compliance with the Charter requirement.
At the May 25, 2010 City Council meeting, the Council discussed the Campaign
Contributions ordinance and some Council members expressed concerns with the
ordinance. The Council directed the City Attomey to review the ordinance and return to
Council with recommendations regarding potentially repealing or amending the
ordinance. At the June 15, 2010 City Council meeting, Councilmember Ramirez initiated
further discussion of the ordinance. The discussion centered on the potential for repealing
Section 2.52.140, which contains the enforcement provisions of the ordinance. During the
discussion, certain Council members voiced concerns regarding the ordinance, including
the costs that the City has incurred to investigate complaints filed in recent years,
potential abuses, and the possibility of duplication of the enforcement efforts of other
agencies. As a result, the Council directed the City Attorney to return to the Council on
.lune 22, 2010 to present the Council with potential options for suspending enforcement
of the ordinance, pending the outcome of the City Attorney's comprehensive review and
analysis. The Council ultimately, voted to amend the ordinance to suspend Section
2.52.140 for 180 days.
On July 13, 2010, the Council again discussed the Campaign Contributions
ordinance. That discussion centered primarily on enforcement of the ordinance. At the
end of the discussion, the Council directed the City Attorney to review the ordinance to
determine which of its provisions are duplicative of the PRA, in order to determine
whether, and to what extent, the FPPC could enforce the ordinance. The Council directed
the City Attorney to return to the Council to report the results of the ordinance review.
That report was presented to the Council on October 12, 2010. At that time, the Council
directed the City Attorney's office to return with amendments to the ordinance to: (i)
delete the provisions that duplicate the PRA; (ii) make updates necessitated by recent
case law; and (iii) revise the enforcement section. This item is brought forward in
response to that direction.
II. PROVISIONS DUPLICATING THE PRA
The Campaign Contributions ordinance can be found at Chula Vista Municipal Code
("CVMC") Chapter 2.52, Sections 2.52.040 through 2.52.120 set forth the substantive
provisions of the ordinance.2 In our October 12th staff report, we detailed our comparison
Chula Vista City Charter, Sec. 904
2 Attachment 1 to this Agenda Statement contains the entire text of the City's Campaign Contributions
ordinance for the Council's reference.
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NOVEMBER 23, 2010, Item Q- I
Page - 3 -
of the City's Campaign Contribution to the PRA. We identified the following provisions
as being duplicative:
2.52.040.C. (Prohibition against making a contribution in another's
name)
2.52.040.D. (Prohibition against aggregating husband and wife
contributions)
2.52.070.B. (Campaign contribution account personal funds to be
deposited)
2.52.090.A. (Return of contributions)
2.52.110 (Campaign statements)
Pursuant to the City Council's direction, we have prepared an amended ordinance which
deletes the above provisions. A copy of the draft amended ordinance, reflecting the
revisions in a redline/strikeout format, is attached as Attachment 2 to this Agenda
Statement for the Council's consideration.
In addition, CVMC section 2.52.080 (Surplus Campaign Funds) is essentially
duplicated at PRA section 89519(b). However, there are a couple of differences: (i) the
phrase "including loans to oneself up to an amount of $5,000" from CVMC 2.52.080.B.1.
is not included; and (ii) section 89519(b) also allows surplus funds to be used for:
"(1) The payment of outstanding campaign debts or elected officer's
expenses.
(4) Contributions to a political party committee, provided the campaign
funds are not used to support or oppose candidates for elective office.
However, the campaign funds may be used by a political party committee
to conduct partisan voter registration, partisan get -out -the -vote activities,
and slate mailers as that term is defined in Section 82048.3.
(5) Contributions to support or oppose any candidate for federal office,
any candidate for elective office in a state other than California, or any
ballot measure."
Because Section 2.52.080 is not exactly duplicated in the PRA, we have left it in the draft
amended ordinance. However, the Council could opt to delete section 2.52.080 and rely
on the FPPC to enforce PRA section 89519. Doing so would expand the acceptable uses
of surplus funds to include those in section 89519. Alternatively, the Council could retain
Section 2.52.080. Doing so would leave enforcement to the local enforcement authority
and would limit the acceptable uses of surplus funds to those in CVMC2.52.080.B.
Finally, we added some language to the ordinance in response to concerns voiced by
some of the Council members regarding adequately informing local candidates of
applicable FPPC provisions. Specifically, we added an opening paragraph in Section
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NOVEMBER 23, 2010, Item
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2.52.010 that notifies local candidates that they are required to comply with Chapter 2.52,
as well as the PRA and FPPC regulations, and providing the citations for easy reference.
111. LEGAL UPDATES
Several of the revisions reflected in the draft amended ordinance were made as a
result of recent Supreme Court and District Court decisions. These revisions primarily
affect the City's regulation of campaign contributions and are discussed below.
A. Basis for Limiting Campaign Contributions
Limitations on campaign contributions are subject to strict scrutiny because they
have been found to impinge on First Amendment rights. The only basis on which limits
on direct campaign contributions to candidates have been upheld is a governmental
interest in stemming the reality or appearance of corruption in the electoral process.
[Davis v. FEC (2008) 554 U.S. 724; Buckley v. Yaleo (1976) 424 U.S. 1.] As a result, we
have added language regarding the City's interest in preventing corruption and the
appearance of corruption in its local elections.
B. Amount of Campaign Contribution Limits
The City's ordinance currently limits the amount of contribution an individual can
make to $300, and prohibits an "organization," as that term is defined in the ordinance,
from making contributions. We have made some revisions to these provisions in response
to recent case law.
First, in a recent challenge to the City of San Diego's campaign contribution
ordinance, a federal district court enjoined San Diego's ban on contributions by political
parties, but subsequently upheld a $1,000 limit on such contributions. [Thalheimer, et al.
v. City of San Diego, et al. (S.D. Cal. Feb. 16, 2010) 706 F.Supp.2d 1065; Thalheimer, et
al. v. City of San Diego (S.D. Cal. Sep. 3, 2010) _ F. Supp.2d ___._, 2010 U.S.Dist. LEXIS
92090.1 As a result, we added language to the ordinance to clearly exempt political
parties from the definition of "organization" and to limit campaign contributions by
political parties to $1,000. The City Council could choose to increase that limit, but we
would not recommend imposing a lower limit because it may be subject to a
Constitutional challenge.
Second, the United States Supreme Court has opined as to factors to be
considered in determining whether campaign contribution limits would withstand
Constitutional scrutiny; one factor considered is whether the limit is indexed to inflation.
[Randall v. Sorrel (2006) 548 U.S. 230: U.S. Supreme Court struck down $400 Vermont
contribution limit on state elective office, partially because the limit was not indexed to
inflation.] In response, we amended the ordinance to provide that both the individual
contribution limit and the'political party contribution limit be indexed to inflation.
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NOVEMBER 23, 2010, Item '2-1
Page -5-
C. Limitations on Expenditures
Although the Supreme Court has approved limitations on campaign contributions,
subject to strict scrutiny, it has rejected such limitations on campaign expenditures. It
affirmed this position in a decision earlier this year in which it held unconstitutional the
long-standing ban on corporations and labor unions using their general treasury funds to
make independent expenditures on behalf of federal candidates. [Citizens United v.
Federal Election Com. (2010) 130 S.Ct. 876.] The City's ordinance does not limit
campaign expenditures. However, so that the ordinance is not misconstrued, we have
added language to clarify that the contribution limitations do not limit expenditures.
D. Application to Elected City Attorney
Finally, we revised the ordinance to include the City Attorney in the definition of
"City elective office." This change was made in response to the Charter amendment
making the City Attorney an elected, rather than appointed, position.
IV. ENFORCEMENT
We also revised the enforcement provisions of the ordinance, in response to
comments from the Council members. The changes to section 2.52.140 are summarized
below.
A. Bifurcation of Review and Investigation Responsibilities
As revised, the amended ordinance essentially constitutes a bifurcated version of
the prior enforcement approach. The amended ordinance retains the panel counsel,
selected by the City Attorney, for review of complaints alleging violations of the
ordinance. However, there would be an initial review of the complaint; any follow-up
investigation would be handled separately. Specifically, the first panel counsel would be
responsible for reviewing the complaint and making a probable cause determination. If he
or she determines the complaint is meritless, the complaint will be returned to the
complainant and no further action will be taken. If the enforcement authority determines
there is probable cause to find there was a knowing or willful violation of the chapter, the
complaint will be forwarded to the District Attorney for handling. If the enforcement
authority determines there is probable cause to find there was a negligent violation of the
chapter, the complaint will be returned to the City Attorney, who will forward it to the
next attorney in the panel counsel rotation for investigation and further handling. The
primary aim of this approach is to expeditiously obtain an initial determination of the
merits of the complaint by a qualified, unbiased reviewer and then to get it to the
appropriate authority if further investigation is warranted.
B. Reliance on Other Agencies
In response to Council member concerns regarding duplication of efforts of other
agencies and the enforcement costs to the City, we also revised the ordinance to utilize
other agencies when appropriate. The amended ordinance provides that the District
Attorney will receive complaints that alleging knowing or willful violations and that the
violations of the PRA will be sent to the FPPC and will not be investigated by the
enforcement authority. We also eliminated the $100,000 appropriation mandate. The
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NOVEMBER 23, 2010, Item 2-1
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intent of these revisions is to limit the role of the enforcement authority, and
consequently, the cost to the City of enforcing the ordinance.
C. Other
Additional revisions were made in response to various Council member
comments. Those include: (i) reducing the amount of the per violation fine from $5,000
to $500, in order to reduce the disparity in how fines were meted out; (ii) modifying the
limitations period so that, whether the enforcement authority chooses to pursue a
complaint as a civil or an administrative matter, the limitations period is four years in
either case; and (iii) adding language and penalties to dissuade the filing of meritless
complaints.
DECISION MAKER CONFLICT
Staff has reviewed the decision contemplated by this action and has determined that it is
not site specific and consequently, the 500 -foot rule found in California Code of
Regulations section 18704.2(a)(1), is not applicable to this decision.
CURRENT YEAR FISCAL IMPACT
The General Fund currently reflects a budget of $100,000 to investigate alleged
violations of the City's Campaign Contributions Ordinance.
ONGOING FISCAL IMPACT
Eliminating the requirement to investigate alleged violations of the Campaign
Contributions Ordinance would result in budgetary savings of $100,000. There would
continue to be unanticipated litigation expenses if the City was required to pay for
attorney services on behalf of the City employee being investigated.
ATTACHMENTS
Attachment 1 - Chula Vista Municipal Code Chapter 2.52
Attachment 2 — Proposed Amended Chapter 2.52 - Redline
Prepared by: Jill DS Maland, Assistant City Attorney, Office of the City Attorney
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