HomeMy WebLinkAboutAgenda Statement 1981/10/20 Item 15COUNCIL AGENDA STATEMENT
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ITEM TITL
SUBMITTED
Our
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Item
Meeting Date ~~ ~
_. Ordinance ~y,~,~ Amending §9.20.110 of the Municipal Code dealing
with the period of validity of a solicitor's permit
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BY: City Attorney (4/5ths Vote: Yes No~_)
solicitor's permit ordinance presently limits the period of
dity of a permit to 90 days, which constitutes an unconstitutional
riction on religious and charitable solicitation.
RECOMMENDATION:
Place Ordinance on First Reading deleting the 90 day
limitation upon the validity of solicitation permits
/COMMISSION RECOMMENDATION:
DISCIUSST.ON:
N/A
The ity Council recently amended the solicitation ordinance as it
applies to religious and charitable organizations in order to con-
for to recent case law. One section was overlooked when these amend-
men were made and that section, 9.20.110, which limits the validity
of permit to a 90 day period, constitutes an unconstitutional re-
• stri tion on religious and charitable solicitation. Both Cali-
forn'a and U. S. Supreme Court cases have held that the First
Amen ment protects the right of religious and charitable organiza-
tion to solicit funds. Any limitation upon this right may only
be b sed upon a compelling governmental reason which must outweigh
the rganization's right to freely exercise their religious rights.
Our rdinance presently allows us to identify the solicitors and
to a sure ourselves that the money solicited is used for religious
or c aritable purposes, There appears to be no compelling reason
why uch an organization should not be allowed to solicit at any
time once these concerns have been addressed. Therefore, tYie
limi ation appears to be an unconstitutional restriction on First
Amen ment rights and staff would recommend that it be deleted from
the unicipal Code.
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quent to the Council meeting of October 6, 1981, the City Attorney
wed the proposed limitation of the 90 day period of validity for
ious and charitable solicitation permits. Z would concur with
arlier opinion given to the City Council.in the A-113 that there
not seem to be a compelling reason to impose a 90 day restriction
the exercise of this First Amendment right.
continued on page two
Form A-11~ (Rev. 11/79)
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Agenda Item No. }4~'~"
Meeting Date of
Page Two r~~//
he permit application itself requires that the time frame
or the solicitation be stated indicating the preferred dates
or the beginning and ending of such solicitation. I believe
hat this gives adequate control to a legitimate policing
Aeration.
urther, it must be remembered that a permit is not required
y an established religious or charitable organization, e.g.,
he Baptist Church, Salvation Army or the Red Cross. Such
rganizations have an ongoing program of solicitation. The
bvious intent of the ordinance from its inception was to
aintain some record of persons operating within the community
ho may, in fact, not constitute legitimate religious or
haritable organizations and monies collected may not be
evoted to the purpose for which the solicitation is conducted.
~wever, the permit process may not now set up any impediments
.ich were previously presumed to act as a deterrent to fraudu-
nt solicitations and the best that can be hoped for is that
.rough an awareness of persons carrying out solicitations
the community, that law enforcement officials can monitor
ch programs and through investigative work, establish fraudu-
nt conduct. Such a program is certainly not enhanced by the
day limitation on the validity of permits and notification
the police and any other law enforcement agencies is as
fectively secured through other provisions of the ordinance
ich require the stipulation of the time frame during which
e solicitation is to be carried out.
I would also note that the City of San Diego in its pre-1981
o dinance although setting a period of three months validity
t the permit, did grant the discretion to the Chief of Police
t authorize a twelve month period of validity as distinguished
f rm our six month maximum. Therefore, the validation period
o the permit is clearly an arbitrary one with little reference
t a factual basis.
FISCAL IMPACT: N/A
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