HomeMy WebLinkAboutSS3 - Campaign Contribution and Term LimitsAgenda Item No. SS3
June 9, 2009
CITY OF NEWPORT BEACH
OFFICE OF THE CITY ATTORNEY
TO Mayor and Members of the City Council
FROM: David HSLqL0jty Attorney
RE Term Limit Issues, June 9, 2009 Agenda Study Session Item. 3
A09 -00491 (X Ref. A09- 00452)
DATE : June 4, 2009
I believe I misunderstood the issues raised by Councilmember Curry in his request for
action at the April 28, 2009 Council meeting. I interpreted Councilmember Curry's
comments in the concept of "two consecutive terms" as provided for in Section 401 of the
Charter and mistakenly believed that there was a dispute over the phraseology of what
two consecutive terms were. I, therefore, addressed the issue believing others in the past
had raised a question of ambiguity and the Council wished to address the alleged
ambiguity in the context of a Charter amendment. That was my error.
Let me state clearly, that while the Charter does not say "two consecutive full terms," in
the context of the entire section, it is my legal opinion that the section means two full
terms. Since Section 401 addresses consecutive 'Your year terms," I am of the opinion
that the term limit provision allows a Councilmember to serve a partial term and then
proceed on to two consecutive four year full terms. Thus, while the Charter does not
specifically delineate that is an acceptable option, reading the Charter as a whole, it is my
opinion that was its intent.
The specific issue raised by Councilmember Curry, which I interpreted in terms of the
overall term limit issue, goes to whether or not a Councilmember may resign before
completion of his or her second full term and then stand for election for a third term, thus
taking advantage of the distinction between a partial and a `full' term. I agree with
Councilmember Curry's concern. This issue is not addressed in the Charter and could
conceivably cause difficulty should a Councilmember seek a third term through such an
artifice. Thus, it is appropriate to address the issue prior to facing such a scenario.
There are two potential methods for addressing the issue. Those are:
1. Charter Amendment: Since Newport Beach is a Charter City, you can
amend the Charter through a vote of the people eliminating this potential loophole. There
are many methods to achieve that end. Some of those possibilities are addressed in the
original staff report.
Mayor & Members of City Council
June 4, 2009
Page 2
2. Ordinance: The issue can be clarified through the enactment of an
ordinance. It is appropriate to clarify a Charter provision through enactment of an
ordinance so long as the ordinance does not conflict with Charter provisions. As such,
the Council can direct the preparation of an ordinance closing the loophole for insertion
into the general provisions of the municipal code. You could direct the preparation of an
ordinance that interprets the Charter provisions so that once a Councilmember is elected
to two consecutive full terms, the Councilmember could not resign and then seek
reelection to an additional term. You can designate how much of a term he or she may
serve and then resign. You could adopt an ordinance that interprets the Charter
provisions so that no Councilmember may serve any longer than a certain period of time,
as the United States Constitution provides for the office of the President.
It is the intention of our staff report to seek your direction. You can instruct us how you
wish to proceed. We will then return to you with recommendations of language to
achieve your goal.
On another note, we attach a list of local cities showing their campaign contribution limits
for the related study session item.
I apologize for my misunderstanding. At this point, we look forward to your direction on
how or if you wish to proceed with any changes on this issue.
DRq(
M Homer Bludau, City Manager
Leilani Brown, City Clerk
Study Session Staff Rpt 'Supp "06.05.09
ORANGE COUNTY CITIES CAMPAIGN CONTIRBUTION LIMITS
Anaheim
$1,700
Brea
no limit
Buena Park
no limit
Costa Mesa
no limit
Cypress
no limit
Dana Point
$630.00• indexed for inflation
Fullerton
no limit
Fountain Valley
$500.00
Garden Grove
no limit
Huntington Beach
$500.00
Irvine
$440.00
La Palma
no limit
La Habra
no limit
Laguna Beach
$360.00
Laguna Hills
no limit
Laguna Niguel
$1,000
Laguna Woods
$250.00
Lake Forrest
no limit
Los Alamitos
no limit
Mission Viejo
no limit
Orange
$1,000
Placentia
no limit
Rancho St. Margarita
no limit
San Clemente
no limit
San Juan Cap.
$250.00
Seal Beach
no limit
Santa Ana
$1,000
Stanton
no limit
Tustin
no limit
Villa Park
no limit
Westminster
no limit
Yorba Linda
no limit
CITY OF NEWPORT BEACH
CITY COUNCIL STAFF REPORT
Study Session Agenda Item No. SS3
June 9, 2009
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: David R. Hunt, City Attorney
David R. Hunt, 644 -3131, dhunt @city.newport- beach.ca.us
SUBJECT: CONSIDERATION OF ISSUES RELATED TO INCREASING CAMPAIGN
CONTRIBUTION LIMITS AND MORE CLEARLY DEFINING TERM
LIMITS FOR CITY COUNCIL OFFICE
ISSUE:
Should the City increase campaign contributions and clarify the provisions of the
Charter regarding term limits?
RECOMMENDATION:
Review and give direction to come back with ordinance changes and/or Charter
amendments as necessary.
DISCUSSION:
Background:
Councilmember Curry requested our office review two issues, first regarding the
potential increase of campaign contribution limits and second clarifying the issue of term
limits. We have done so. We have appended as Attachment "A" a memorandum
prepared by Catherine Wolcott of this office giving a general analysis of the issues and
possible options.
Campaign Contributions.
The Council has the authority to raise campaign contribution limits consistent with State
law. Councilmember Curry had discussed the possibility of raising the limits to
$1,000.00 per contributor and including a cost of living increase component. Both
options are available to the Council.
If the Council wishes to increase campaign contribution limits, it should amend its
ordinance as set forth in Chapter 1.25 of the Newport Beach Municipal Code. We have
CONSIDERATION OF ISSUES RELATED INCREASING CAMPAIGN
CONTRIBUTIONS AND MORE CLEARLY DEFINING TERM LIMITS
June 9, 2009
Page 2
prepared a proposed change increasing contributions to $1,000.00 and inserting a CPI
adjustment. The redline of such a proposal is appended as Attachment "B," for your
consideration.
Please give us direction as to how, or if, you wish to proceed. You have the option to
direct us to take no action, take action consistent with the redline, or give further
direction on how to proceed.
2. Clarification of Term Limits.
The provision governing term limits within the City is set out in City Charter Section 401.
That section states:
Section 401. Eligibility.
No person shall be eligible to hold office as a member of the City Council unless
he or she is, and shall have been for at least thirty (30) days immediately
preceding nomination or appointment, a registered elector of the district from
which he or she is nominated or appointed, and for at least thirty (30) days
immediately preceding his or her election or appointment, a registered elector of
the City.
Notwithstanding the provisions of Section 400, no person shall be or remain
eligible to hold office as a member of the City Council for more than two
consecutive four -year terms. Members of the City Council who have served one or
more terms prior to their current term shall be entitled to complete such term, but
shall not be eligible for re- election except as provided below. Members of the City
Council who are serving their first term as of the effective date of this amendment
shall be eligible to hold office during a second four year term when the current
term expires.
This section is intended to prevent persons from serving more than two
consecutive terms, and shall not be construed to render ineligible any person who
would not, by virtue of his or her election, serve more than two consecutive terms.
(As amended by amendments effective on June 19, 1968, June 6, 1964, April 8,
1980, and November 3, 1992)
As can be seen, the Charter does not clearly define the phrase "two consecutive terms."
The question becomes whether or not the phrase contemplates only full terms or does it
contemplate partial terms. Additionally, one must ask if it contemplates partial terms,
how long is such a term. These ambiguities could potentially cause issues in the future
should a Councilmember serve one full term and one partial term and seek reelection.
CONSIDERATION OF ISSUES RELATED INCREASING CAMPAIGN
CONTRIBUTIONS AND MORE CLEARLY DEFINING TERM LIMITS
June 9, 2009
Page 3
If you wish to address this issue, it must be addressed through an amendment to the
City Charter. Amending the Charter requires vote of the people. If you wish to proceed
to clarify this issue, we recommend placing the matter on the November 2, 2010 general
municipal election. There are no other general elections scheduled prior to that time. In
order to put the issue on the general election, we would need to notify the County Clerk
on or before June 28, 2010 (E -127). You can schedule a special election, but the
anticipated cost would be well in excess of $200,000.00 and we would recommend
against pursuing this issue through a special election.
Please give us direction if you wish to proceed and how you wish to define 'consecutive
terms." You may identify a consecutive term consistent with the United States
Constitution in which a President can serve two consecutive terms, but not in excess of
10 years total consecutively.
CONCLUSION:
Please give us direction, if, or how, you wish to proceed. We shall bring these matters
back to you for action consistent with the direction you give.
Public Notice: NIA
Environmental Review: No environmental review is required.
Funding Availability NIA
Prepared & Submitted by:
SIGNATURE
David R. Hunt,
City Attorney
Attachment A: May 21, 2009 memo prepared by Catherine Wolcott
Attachment B: Redline Proposal Amending Chapter 1.25
A09-00452
Study Session Staff Report 06.09.09
ATTACHMENT A
Study Session Memo
Campaign Contribution Limits
May 21, 2009 memo prepared by Catherine Wolcott
CITY OF NEWPORT BEACH
CITY ATTORNEY'S OFFICE
TO David Hunt
FROM: Catherine Wolcott
RE Campaign Contribution and Term Limits
DATE : May 21, 2009
Assignment: At the request of City Council member Keith Curry, draft and present the City
Council with the following amendments to Newport Beach Municipal Code Chapter 1.25:
1. Raise individual campaign contribution limits from the current $500 to $1,000 per person,
and
2. Provide for adjustment of contribution limits based on Consumer Price Index (CPI)
Councilman Curry also requested that staff prepare language clarifying an ambiguity in the City
charter provisions regarding City Council term limits. Newport Beach City Charter Section
401 (Eligibility) currently provides that no person shall be eligible to hold office as a City Council
member for more than two consecutive terms, but is silent on the issue of eligibility of Council
members who have served less than two entire consecutive terms. The wording of the charter
language can also be clarified as to whether an individual who has served two consecutive terms
as a Council member can be eligible to serve for additional non - consecutive terms.
Statutory Background — Campaign Contribution Limits:
The Political Reform Act of 1974 (codified in Title 9 of the California Government Code) sets forth
campaign contribution limits for individuals, different types of committees and aggregates of
individuals and affiliated entities. Specific limits are set forth in Government Code Sections 5301,
5302, and 5303 for contributions to candidates for state office (the State Legislature), and the
Governor and other statewide elected offices (Lieutenant Governor, Attorney General, Insurance
Commissioner, Controller, Secretary of State, Treasurer, Superintendant of Public Instruction, and
Board of Equalization, per the FPPC website.) For individual contributors, campaign contribution
limits currently range from $3,200 (for a state legislative candidate) to $21,200 (for Governor.)
It is well established that the City has the authority to enact limits on campaign contributions for
elections to local elective office within the City. California Election Code Section 10202 provides
that "[a] city may, by ordinance or resolution, limit campaign contributions in municipal elections."
Government Code Section 81013 states that local agencies may impose requirements in addition
to those imposed by the act on any person, so long as the requirements do not prevent that
person from complying with applicable provisions of the Political Reform Act. Government Code
Section 85703 also provides, "Nothing in this act shall nullify contribution limitations or prohibitions
of any local jurisdiction that apply to elections for local elective office, except that those provisions
may not conflict with the provisions of Section 85312." (Section 85312 pertains to payments for
communication to members of organizations.)
Campaign Contribution Limits
May 22, 2009
Page: 2
Increasing Individual Contributions to $1,000
Specific limits on candidates for local office are not listed in the Political Reform Act. The FPPC
website notes that nothing in Proposition 34 nullifies local contribution limits. The FPPC website
notes a number of the provisions of the Act which do apply to local candidates, including Sections
85703, 85700, 85312, 85500(b), 855501, 85919, 84204(b), 84305.6, 84511, 84501 - 84510,
91005.5 and 85701. None of these sections limit the City's ability to impose or increase its
individual campaign contribution limits to the level requested, or to enact legislation providing for
future CPI increases.
"Limits on contributions to political campaigns are permissible under the First Amendment as long
as the Government demonstrates that the limits are closely drawn to match a sufficiently
important government interest." Citizens for Clean Government v. City of San Diego, 474 F.3d
647, 650 (9fh Cir. 2007), quoting Randall v. Sorrelf, 126 S.Ct. 2479, 2491 (2006) (internal quotation
marks omitted.) The purpose and findings listed in existing NBMC Section 1.25.010 are sufficient
to demonstrate important government interests (avoiding corruption, or appearance thereof;
encouraging fundraising from a broader range or persons). Campaign contribution limits are
restrictions that are closely drawn to further those interests.
Raising the contribution limit to $1,000 per individual contributor does not appear to undermine the
City's stated interests. The City's current individual campaign contribution limit of $500 was
adopted in 1995. Costs associated with political campaigns have increased over the intervening
14 years, to the extent that an individual contribution of $1,000 appears no more likely to result in
corruption, the appearance of corruption, or limiting fundraising efforts to a narrow range of
contributors than a contribution of $500 would have created in 1995.
At least two other cities reviewed (Torrance and
limits of $1,000. Other cities reviewed included
Beach ($500.)
Providing for Adjustments to Contribution Limits
Santa Ana) had individual campaign contribution
Dana Point ($450), Irvine ($300) and Huntington
Proposition 34 added Section 83124 to the Political Reform Act. Cal. Gov. Code Section 83124
requires that contribution and expenditure limits for elected state offices be increased or
decreased in accordance with changes in the Consumer Price Index in January of every odd -
numbered year. For elections to state office, adjustments shall be rounded to the nearest one
hundred dollars ($100) for limitations on contributions, and to the nearest one thousand dollars
($1,000) for limitations on expenditures.
Although many cities in Orange County have enacted provisions tying adjustments in individual
local campaign contribution limits to the Consumer Price Index (CPI), the Newport Beach
Municipal Code currently contains no provision for increases or decreases tied to the CPI. To
allow for such fluctuations in costs, proposed language is provided in the attached redline of the
current ordinance.
Other requirements
Government Code Section 81009.5 requires any local government that enacts, amends or repeals
any ordinance or other provision of law affecting campaign contributions and expenditures to file a
copy of the action with the Fair Political Practices Commission. If adopted, this amendment will
need to be filed with the FPPC.
Recommendation — Campaign Contribution Limits — draft language to amend NBMC Chapter
1.25 is attached hereto as Attachment A. it increases the limit for individual campaign
Campaign Contribution Limits
May 22, 2009
Page: 3
contributions, and for the solicitation and acceptance of such individual contributions, to $1,000. It
also provides two options for tying the limit to fluctuations in the CPI; one is very specific and
provides for computation of individual years and rounding the total adjusted amount for a two year
period, and one is much simpler and provides for increases or decreases in the CPI within an
entire two -year period. Another variable to consider is whether the Council wishes to approve the
adjusted limits by Council resolution, or whether the fluctuation should be handled entirely at the
staff level. Language providing for both options is provided in the attachment.
City Council Term Limits
Section 401 of the Charter of the City of Newport Beach states
Notwithstanding the provisions of Section 400, no person shall be or remain eligible to
hold office as a member of the City Council for more than two consecutive four -year
terms. Members of the City Council who have served one or more terms prior to their
current term shall be entitled to complete such term, but shall not be eligible for re-
election except as provided below. Members of the City Council who are serving their
first term as of the effective date of this amendment shall be eligible to hold office during
a second four year term when the current term expires.
This section is intended to prevent persons from serving more than two consecutive
terms, and shall not be construed to render ineligible any person who would not, by
virtue of his or her election, serve more than two consecutive terms.
The current Charter provisions are silent as to the eligibility of former Council members who
served one full and one partial consecutive term. The Charter language could also be
amended to provide clearer guidance on whether an individual who has served two consecutive
terms is eligible to later serve another term that is not consecutive.
Proposed amended Charter language is attached hereto as Attachment B. Alternate options
provided include language permitting /prohibiting Council members who have already served
two consecutive terms from eligibility for future terms after an intervening period, and clarifying
the effect of an incomplete term on eligibility when an individual is serving an appointed or
elected term.
Catherine Wolcott
Deputy City Attorney
F: \users \cat \shared \cathywolcoti \campaign limits memo.doc
ATTACHMENT B
Study Session Memo
Campaign Contribution Limits
Redline Proposal Amending Chapter 1.25
0
ORDINANCE NO. 2009 -
AN ORDINANCE OF THE CITY COUNCIL OF THE
CITY OF NEWPORT BEACH, CALIFORNIA,
AMENDING CHAPTER 1.25 TO NEWPORT BEACH
MUNICIPAL CODE PERTAINING TO MUNICIPAL
ELECTION CAMPAIGN CONTRIBUTION AND
EXPENDITURE CONTROL
NOW THEREFORE, the City Council of the City of Newport Beach, California, HEREBY
ORDAINS as follows:
SECTION 1: Chapter 1.25 of Newport Beach Municipal Code is hereby amended to read as
follows:
Sections:
1.25.010
Purpose and Findings.
1.25.015
Intent.
1.25.020
Definitions.
1.25.030
Campaign Contributions -- Limitations.
1.25.040
Penalties.
1.25.050
Severability.
1.25.010.
Purpose and Findings.
The City Council of the City of Newport Beach finds and declares as follows
A. The primary purpose of the ordinance cbdified in this chapter is to prevent corruption, or
the appearance of corruption, which results from the real or imagined influence of large
contributions on the conduct or actions of candidates elected to office.
6. The limits on contributions to candidates and controlled committees imposed by this
chapter will encourage candidates and their supporters to raise funds from a greater
number of persons than would otherwise involve themselves in the political process.
C. Contribution limits encourage persons to expend funds that would otherwise be
contributed to candidates on direct political expression which will broaden the
discussion and debate on issues of importance to the electorate.
D. These contribution limits will not reduce the total amount of money potentially available,
or used, to promote expression in the context of a political campaign, but will increase
.the amount of independent expenditures and encourage the dissemination of political
expression through a wider variety of media sources.
1
E. Local campaign contribution limits are municipal affairs and this chapter is authorized
pursuant to the laws and Constitution of the Slate of California, as well as the Charter of
the City of Newport Beach.
F. The contribution limitations imposed by-this chapter are consistent with the spirit, intent
and letter of the Political Reform Act of 1974.
1.25.015 Intent.
The intent of this chapter is to impose limits on the amount of money that may be contributed
to a candidate or controlled committee to achieve the purposes specified in Section 1.25.010.
This chapter is not intended, and shall not be construed, to establish any reporting, filing, or
procedural requirement in addition to, or different from, the Political Reform Act or the
regulations adopted by the Fair Political Practices Commission (FPPC).
1.25.020 Definitions.
The terms used in this chapter shall have the same definitions as specified in the Political
Reform Act, and FPPC regulations. In those cases where definitions in the Political Reform Act
or FPPC regulations contain a specific reference to any State election, candidate, or electoral
criteria, the definition shall be modified to reflect the municipal equivalent, or in the absence of
,a municipal equivalent, to delete the specific reference.
1.25.030 Campaign Contributions-- Limitalions.
A. Contributions by Persons to Candidates or Controlled Committee(s). No person shall
make any contribution to a candidate and /or the candidates controlled committee(s),
with respect to any single election, which would cause the total amount contributed by
such person to the candidate and the candidate's controlled committee(s), when
combined, to exceed five-Mundredone lhousawl dollars ($688$1,(100.00).
B. Acceptance or Solicitation by Candidates or Controlled Committee(s). No candidate or
controlled committee shall solicit or accept any contribution from any person which
would cause the total amount contributed by such person, with respect to any single
election, to the candidate and the candidate's controlled oommittee(s), when combined, -
- to exceed the sum of `'` done thousand dollars ($689$1, 000.00). - -
C.. Contributions by Candidates. The provisions of subsections (A) and (B) shall not apply
to contributions from a candidate to his or her controlled committee(s) nor to the
expenditure, by the candidate, of his or her personal funds.. - - - D. Contributions to Committees. Contributions made to any person or a committee, and
not to a candidate or controlled committee, shall not be considered as contributions to
the candidate or controlled committee notwithstanding the fact that such person or '-
committee supports the candidate or uses the contribution with a view to bringing about - the nomination or election of the candidate.
2
E. Anonymous Contributions. No candidate or controlled committee shall accept
anonymous contributions, with respect to any single election, which would cause the
total amount of anonymous contributions received by the candidate and the candidate's
controlled committee(s), when combined, to exceed two hundred dollars ($200.00). - -—
Subject to the provisions of State law, in the event any candidate or controlled [sofa acted: Font (Default) adal I2 1x not
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shall promptly pay that sum to the City for deposit into the general fund to be used to
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Consumer Price Index (CPI) over the 2�ev_ious two (2) vear period. The City Clerk shall use
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each year separately adding the adjustment for each year to the prior years Jimil and then
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A. Any person who knowingly and willfully violates the provisions of Section 1.25.030 is
guilty of a misdemeanor.
B. In addition to any criminal penalty, if, after a candidate is elected, the candidate is
convicted of a violation of the provisions of Section 1.25.030, the election to office of
such candidate shall be void and the office shall become vacant as of the date of
conviction or on the dale upon which the candidate would otherwise take office,
whichever occurs later. In such event, the vacancy shall be filled in accordance with the
provisions of 403 of the City Charter. If a candidate is convicted of a violation of Section
1.25.030 at any time prior to the election of the candidate, the candidacy shall be
terminated immediately and the candidate shall no longer be eligible for election.
C. The City Attorney shall have the power to enforce this chapter only to the extent that
office has authority to enforce provisions of the Political Reform Act. In the event that
the City Attorney is not authorized to enforce the provisions of this chapter, the District
Attorney shall generally function as criminal prosecutor and the City Council shall have
the authority to appoint a special counsel to enforce civil penalties as provided in
subsection (B), or to function as the criminal prosecutor in the event that the District
Attorney is unable or unwilling to do so.
1.25.050 Severability.
If any provision of the ordinance codified in this chapter, or the application of such provision to
any person or circumstances, shall be held invalid, the remainder of the ordinance codified in
this chapter to the extent it can be given effect, or the application of such provision to persons
or circumstances other than those to which it is held invalid, shall not be affected thereby, and
to this end the provisions of the ordinance codified in this chapter are severable.
SECTION: 2: That if any section, subsection, sentence, clause or phrase of this Ordinance is for
any reason held to be invalid or unconstitutional, such decision shall not affect the validity or
constitutionality of the remaining portions of this Ordinance. The City Council hereby declares
that it would have passed this Ordinance and each section, subsection, clause or phrase hereof,
irrespective of the fact that any one to more sections, subsections, sentences, clauses and
phrases be declared unconstitutional.
SECTION 3: The Mayor shall sign and the City Clerk shall attest to the passage of this
Ordinance. The City Clerk shall cause the same to be published once in the official newspaper
within fifteen (15) days after its adoption.
This Ordinance was introduced at a regular meeting of the City Council of the City of Newport
Beach held on the day of , 2009, and adopted on the _ day of
2009, by the following vote, to -wit:
AYES, COUNCILMEMBERS
4
NOES, COUNCILMEMBERS
ABSENT, COUNCILMEMBERS
MAYOR
Edward Selich
ATTEST:
By
Leilani Brown, City Clerk
APPROVED AS TO FORM:
OFFICE OF THE CITY ATTORNEY
By
David R. Hunt, City Attorney