HomeMy WebLinkAbout061599 CC AgendaIn compliance with the Americans with Disabilities Act, if you need special assistance to participate in this
meeting, please contact the office of the City Clerk (909) 694-6444. Notification 48 hours prior to a meeting will
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AGENDA
A JOINT CITY COUNCIL/PLANNING COMMISSION
COMMUNITY SERVICES COMMISSION/PUBLIC/TRAFFIC SAFETY COMMISSION/
OLD TOWN REDEVELOPMENT ADVISORY COMMITTEE/
OLD TOWN LOCAL REVIEW BOARD
WORKSHOP MEETING
CITY COUNCIL CHAMBERS
43200 BUSINESS PARK DRIVE
JUNE 15, 1999 - 6:00 P.M.
CALL TO ORDER:
ROLL CALL:
City Councilmembers: Comerchero, Lindemans, Roberts, Stone, Ford
Planning Commissioners: Fahey, Mathewson, Naggar, Webster,
Guerriero
Public/Traffic Safety Commissioners: Connerton, Edwards,
Markham, Telesio, Coe
Community Services Commissioners: Henz, Meyler, Miller,
Nimeshein, Edwards
Old Town Redevelopment Advisory Committee: Jenkins, Testasecca,
Wedeking
Old Town Local Review Board: Allen, Baron, Blair, Mighell, Ross,
Harker
PUBLIC COMMENTS
A total of 30 minutes is provided so members of the public may address the Council on items that
appear within the Consent Calendar or ones that are not listed on the agenda. Speakers are
limited to two (2) minutes each. If you desire to speak to the Council on an item which is listed on
the Consent Calendar or a matter not listed on the agenda, a pink "Request to Speak" form
should be filled out and filed with the City Clerk.
When you are called to speak, please come forward and state your name for the record.
For all Public Hearing or Council Business matters on the agenda, a "Request to Speak" form
must be filed with the City Clerk prior to the Council addressing that item. There is a five (5)
minute time limit for individual speakers.
R:~Agenda\061099CIP
1
CITY COUNCIL/COMMISSION REPORTS
Reports by the members of the City Council/Commissions on matters not on the agenda will be
made at this time. A total, not to exceed, ten (10) minutes will be devoted to these reports.
COUNCIL/COMMISSION BUSINESS
1 Brown Act/Conflict of Interest Training
ADJOURNMENT
Next City Council meeting: Tuesday, July 13, 1999, at 7:00 P.M., in the City Council Chambers, 43200
Business Park Drive, Temecula, California.
Next Planning Commission meeting: Wednesday, June 16, 1999, at 6:00 P.M., in the City Council
Chambers, 43200 Business Park Drive, Temecula.
Next Community Services Commission meeting: Monday, July 12, 1999, at 7:00 P.M., in the City Council
Chambers, 43200 Business Park Drive, Temecula.
Next Public/Traffic Safety Commission meeting: Thursday, June 24, 1999, at 6:00 P.M., in the City Council
Chambers, 43200 Business Park Drive, Temecula.
Next Old Town Redevelopment Advisory Committee meeting: Tuesday, July 6, 1999, at 5:30 P.M., in the
Community Development Meeting Room, 43200 Business Park Drive, Temecula.
Next Old Town Local Review Board meeting: Monday, July 12, 1999, at 9:00 A.M., at the Temecula
Community Center on Pujol Street, Temecula.
R :~genda\061099CI P
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Conflicts of Interest
SUMMARY OF THE PRINCIPAL CONFLICT OF INTEREST
LAWS THAT APPLY TO LOCAL AGENCY DECISIONS
Kevin G. Ennis
This portion of the program materials provides a general summary of the relevant
conflict of interest laws and applicable conflict of interest regulations for typical decisions of
a local agency. Also included is a summary of laws prohibiting the receipt of gifts and
honoraria and limitations on the receipt of certain loans to public officials.
This paper is general in nature and may not cover all aspects of an actual conflict of
interest question. Thus it is not intended to constitute advice on specific conflict of interest
questions. In the event of an actual conflict of interest issue, you should contact your city
attorney or agency counsel for further advice.
GENERAL CONFLICT OF INTEREST LAWS THAT ARE
APPLICABLE TO DECISIONS OF AN AGENCY
There are 'three principal sets of conflict of interest laws that apply to decisions of a
local agency. There are also other laws that affect the ability of public officials to participate
in governmental decisions, receive gifts, acquire property or hold another office. Those
other laws will be summarized in the second part of this program material. The three
principal sets of conflict of interest laws are summarized below:
A. POLITICAL REFORM ACT
The California Political Reform Act (Governmere Code Section 81000 et seq., "Act")
is the principal law in California governing conflicts of interest for public officials.~-t Its
conflict of interest provisions are found at Government Code Section 87000 et seq. The Fair
Political Practices Commission ("FPPC") has interpreted the Act in a series of Regulations
found at 2 Cal. Code of Regulations, Section 18109 et seq.1~
The Act requires public officials to disqualify themselves from making, participating
in making, or in any way attempting to use their official position to influence a governmental
1/ At the end of this portion of the materials is a summary of additional provisions of the
Political Reform Act that regulate gifts, honoraria and loans to public officials.
2/ All statutory references are to the California Government Code unless otherwise
indicated. Regulations of the FPPC are referred to as "Regulation Section."
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decision in which they know or have reason to know they have a financial interest (Section
87 100).
An official has a f'mancial interest in a decision if it is reasonably foreseeable that the
decision will have a material f'mancial effect, distinguishable from its effect on the public
generally, on the official, a member of his or her immediate family, or on certain listed
financial interests. The listed financial interests are:
"(a) Any business entity in which the public official has a direct or indirect
investment worth One Thousand Dollars ($1,000) or more.
(b) Any real property in which the public official has a direct or indirect
interest worth One Thousand Dollars ($1,000) or more.
(c) Any source of income, other than gifts and other than loans by a commercial
lending institution in the regular course of business on terms available to the public
without regard to official status, aggregating two hundred fifty dollars ($250) or more
in value provided to, received by or promised to the public official within 12 months
prior to the time when the decision is made.
(d) Any business entity in which the public official is a director, officer, partner,
trustee, employee, or holds any position of management.
(e) Any donor of, or any intermediary or agent for a donor of, a gift or
gifts aggregating three hundred dollars ($300)!/or more in value provided to,
received by, or promised to the public official within 12 months prior to the
time when the decision is made .... "
(Section 87103).
The Regulations of the FPPC interpret and provide guidance to most of the terms
used in the Act as well as provide standards for determining if each element of the Act's
prohibitions has been satisfied.
1. The FPPC's Eight-Step Test for Analyzing Conflict of Interest Questions
The FPPC recently adopted new regulations for deciding if a conflict of interest exists
under the Act. At the beginning of those regulations is a new eight-step test that the FPPC
3/ The dollar amount in this paragraph (e) has been increased to $300 by the FPPC
pursuant to Regulation Section 18940.2.
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recommends be used when analyzing conflict of interest questions (Regulation Section
18700). That test is set forth below:
STEP ONE:
Is a Public Official Involved?
Determine whether the individual is a public official within the
meaning of the Act.
A "public official" is defined to include a "member, officer, employee, or
consultant" of a local government agency. Each one of those terms is defined to
further clarify the categories of persons subject to the requirements of the Act
(Regulation Section 18701).
A "member" includes members of boards or commissions with decision-
making authority. A board or commission possesses decision-making authority
whenever it may make a final governmental decision, it may compel a governmental
decision, or it makes substantive recommendations which are, and over an extended
period of time have been, regularly approved without significant amendment or
modification by another public official or governmental agency (Regulation Section
18701(a)(1)).
A "consultant" includes an individual who, pursuant to a contract with a state
or local government agency, is empowered to make a governmental decision or serve
in a staff capacity with the agency (Regulation Section 18701(a)(2)).
STEP TWO:
Is There a Government Decision Involved?
Determine whether the public official will be making,
participating in the making, or using or attempting to use his/her
official position to influence a governmental decision.
A public official "makes" a governmental decision, when the official, acting
within the authority of his or her office or position, votes on .a matter, appoints a
person, commits his or her agency to a course of action, enters into a contract, or
determines not to act unless such determination is made because of his or her
financial interest (Regulation Section 18702.1).
A public official "participates in making" a governmental decision, when the
official, acting within the authority of his or her office or position, negotiates, without
significant substantive review, with a third party, or advises or makes
recommendations to a decision-maker (Regulation Section 18702.2).
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A public official is "attempting to use his or her official position to influence"
a decision if, for purpose of influencing the decision, the official contacts, or appears
before, or otherwise attempts to influence any member, officer, employee or
consultant of the agency- (Regulation Section 18702.4). Special and less restrictive
rules apply when the official is attempting to influence a decision of another
governmental agency or an agency not under the budgetary control of the public
official's agency. Exceptions exist in situations where the public official appears
before the public agency as a member of the general public to represent specific and
limited "personal interests," speaks to the public or press, or negotiates his or her
compensation or terms of employment (Regulation Section 18702.4).
STEP THREE:
What are the Public Official's Economic Interests that Are
Affected?
Identify the public official's economic interests.
A public official's economic interests under the Act include those listed in
Section 87103. They include investments and positions in business entities, interests
in real property, sources of income and gifts, and the personal expenses, income,
assets and liabilities of the public official (Section 87103 and Regulation Sections
18703 - 18703.5).
STEP FOUR:
Are those Interests Directly or Indirectly Involved?
For each of the public official's economic interests, determine
whether that interest is directly or indirectly involved in the
governmental decision at issue.
A person, including business entities and sources of income or gifts, is
regarded as "directly involved" in a decision if that ~5erson or entity initiates or is a
named party in a proceeding (Regulation Section 18704.1). An interest in real
property is regarded as "directly involved" in a decision if the decision involves the
zoning or rezoning, annexation, sale or lease of the real property, involves the
issuance or denial of a license, permit or other entitlement, or certain other decisions
the specifically involve the subject property (Regulation Section 18704.2). A public
official's personal finances are deemed directly involved in a decision if the decision
has any personal financial effect on him or her or his or her immediate family (spouse
or dependent child) (Regulation Section 18704.5). Economic interests that do not
qualify as being "directly involved" are deemed to be "indirectly involved" in the
decision.
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STEP FIVE:
Which "Materiality" Standard Applies?
Determine the applicable materiality standard for each economic .'
interest.
A. Business entities. Business entities are regarded as "materially"
affected when those businesses are directly involved in the decision and are smaller in
financial size than those permitted for listing on a national or regional stock exchange.
Business entities that are directly involved in the decision and are large enough to be
listed on a national or regional stock exchange are regarded as materially affected by
the decision only if the public official's investment in the business entity is worth
$10,000 or more (Regulation Section 18705.1).
When business entities are only indirectly involved, the decision is regarded as
materially affecting that business entity only if the decision is likely to have specified
levels of financial effect depending on the size of the business entity (Regulation
Section 18705.1 (b)). For business entities listed in the most recently published
Fortune Magazine Directory of the 1,000 largest U.S. Corporations, a decision will
be found to materially affect the business entity if the decision will affect the gross
revenues, expenses, assets or liabilities by $1,000,000 or more in a fiscal year or
result in an increase or decrease in expenses by $250,000 or more in a fiscal year
(Regulation Section 18705. l(b)(1)). Businesses not listed on that Directory but which
are listed on the New York or American Stock Exchanges, are materially affected
when the decision affects the gross revenues, expenses, assets or liabilities of the
business entity by $250,000 or more in a fiscal year or results in an increase or
decrease in expenses by $100,000 or more in a fiscal year (Regulation Section
18705.1 (b)(1)).
Lower thresholds of materiality apply to businesses indirectly involved and
which are listed, of eligible for listing, on 'NASDAQ or on regional stock exchanges
.(Regulation Section 18705.1C0)(2) and (3)). For the smallest businesses, (those that
have net tangible assets of less than $4 million, pre-tax income of less than $750,000
in the last fiscal year or net income for that period of less fixan $400,000) a decision
will be found to materially affect the business entity if the decision will affect the
gross revenues, expenses, assets or liabilities of that entity by $10,000 or more in a
fiscal year or result in an increase or decrease in the entity's expenses by $2,500 or
more in a fiscal year (Regulation Section 18705.1(b)(7)).
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MATERIAL FINANCIAL EFFECTS WHERE
BUSINESS ENTITY IS INDIRECTLY INVOLVED IN A DECISION
(Regulation Section 18705.1)
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Type of Business
Listed on NYSE4j
and Fortune 1000
Listed on NYSE
or
Meets Standards for Fortune 1000
Listed on NASDAQs-/
Or
Meets Standards for NYSE~
Listed on Pacific Stock Exchange,
Meets Standards for Public Sale in
Cal. and Listed on State Eligibility
List
or
Meets Standards for NASDAQ1~
All Others
Increase or Increase or Increase or
Decrease in Decrease in Decrease in
Gross Revenues Expenses Assets/Liabilities
1,000,000 250,000 1,000,000
250,000 100,000 250,000
150,000 50,000 150,000
30,000 7,500 30,000
10,000 2,500 10,000
B. Real Property. Real property is "materially" affected by a decision
when the property is directly' involved in the decision. Real property that is only
indirectly involved in the decision is also "materially" affected when specified criteria
is satisfied. First, real property is "materially" affect if the decision involves
4/ New York Stock Exchange.
5/ National Association of Securities Dealers National Market List.
6/ New York Stock Exchange Standards are net tangible assets of at least $18,000,000 and
pre~tax income for the last fiscal year of at least $2,500,000.
7/ Standards for NASDAQ are net tangible assets of at least $4,000,000 and pre-tax income
for the last fiscal year of at least $750,000, with net income from that period of at least
$400,000.
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construction of, or improvements to, streets, water, sewer, storm drainage or similar
facilities, and the official's real property will receive new or substantially improved
service (Regulation Section 18705.2(b)(1)(B)).
Second, a decision is deemed to have a material financial effect on the
official's real property, if the official's property is located within 300 feet of the
boundaries of the property subject to the decision, unless there are unique facts to
indicate that the decision will have no financial effect at all on the official' s real
property interest (Regulation Section 18705.2(b)(1)(A)).
Third, in situations where the official's real property is located outside a radius
of 300 feet, but any part of the property is located within a radius of 2,500 feet of the
boundaries of the property subject to the decision, the decision is regarded as
materially affecting the official's property if the decision will have a reasonably
foreseeable financial effect on the official's property of:
(a) Ten thousand dollars ($10,000) or more on the fair market value of the
real property; or
(b) Will affect the rental value of the property by $1,000 or more per
12 month period (Regulation Section 18702.5((b)(1)(C)).
Fourth, when the official's real property is located outside a radius of 2,500
feet of the boundaries of the property subject to the decision, the decision is presumed
to not have a material financial effect on the value of the official's property unless:
(a) There are specific circumstances regarding the decision, its
effect, and the nature of the real property in which the official has an
interest, which make it reasonably foreseeable that the fair market value
will be affected by $10,000 or the rental value of the real property will
be affected by. $1,000 or more in a 12 month period; and
(b) Either of the following apply:
(1) The effect will not be substantially the same as the effect upon
at least 25 percent of all the properties which are within a 2,500 foot
radius of the boundaries of the real property in which the official has
an interest; or
(2) There are not at least 10 properties under separate ownership
within a 2,500 foot radius of the property in which the official has an
interest (Regulation Section 18702.5(b)(2)).
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MATERIAL FINANCIAL EFFECTS WHERE
REAL PROPERTY IS INDIRECTLY INVOLVED
IN A DECISION
(Regulation Section 18705.2)
C,
0-300 feet - presumption of materialivy unless special circumstances
300-2500 feet - materialiVy found only if $10,000 impact or $1,000 effect
on rental value in a 12-month period
2500 + - presumption of no materialiVy unless special circumstances
C. Sources of Income of Gifts. Sources of income are "materially"
affected if they are directly involved in the decision. Business entities or non-profit
entities that are sources of income and are indirectly involved in the decision are
"materially" affected when the decision affects the entity by specified thresholds
depending on the financial size of the entity (Regulation Section 18705.3). Sources of
income that are individuals are "materially" affected if the decision affects the
individual's income, investments, liabilities or assets by $1,000 or more, affects their
real property in the manner mentioned in the prior paragraph, or if there is a "nexus"
between the official's receipt of the income and the governmental decision (Regulation
Section 18705.3(b)(3) and (c)). Sources of gifts are "materially" affected if the
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source of the gift is directly involved in the decision or if the decision is likely to
affect the source of the gift in a manner deemed. material for business entities, non-
profit entities or individuals, whichever is applicable (Regulation Section 18705.4).
STEP SIX:
Does the Decision Affect the Economic Interests of the Public
Official "Materially" ?
Determine whether it is reasonably foreseeable that the
governmental decision will have a material financial effect on
each economic interest.
A material financial effect on an economic interest is reasonably foreseeable if
it is substantially likely that one or more of the materiality standards applicable to that
economic interest will be met as a result of the governmental decision. (Regulation
Section 18705.5)
STEP SEVEN:
Does the "Public Generally" Exception Apply?
Determine if the reasonably foreseeable financial effect is
distinguishable from the effect on the public generally.
Once it is determined that it is reasonably foreseeable that the decision will
have a material financial effect on a public official's financial interest or interests, the
· decision must be evaluated under the "public generally" exception (Regulation
Sections 18707 et seq.). The public generally exception provides that even if the
decision will have a reasonably foreseeable material financial effect on the official's
financial interest, disqualification is required only if the effect on the public official is
distinguishable from the effect on the financial interests of the public generally or a
significant segment of that public. The "public generally" is comprised of the entire
jurisdiction of the public agency (In re Legan, 9 FPPC Ops. 1 (1985)).
This "public generally exception" involves two core elements. First, the
governmental decision must affect a "significant segment" of the public in the
jurisdiction of the public agency. For decisions that affect a business entity in which
the official has an economic interest, fifty percent of all businesses have to be affected
by the decision. For decisions that affect an official's other economic interests, the
decision must affect either ten percent of the population of the jurisdiction or ten
percent of all property owners, all home owners, or all households in the jurisdiction
or district the official represents. In addition, for decisions that affect any of the
official's economic interests, the decision affects a "significant segment" if it will
affect 5,000 individuals who are residents of the jurisdiction (Regulation Section
18707(b)(1)).
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The second core element of the public generally exception is the governmental
decision must affect the official's economic interest in substantially the same manner
as it will affect the significant segment identified above (Regulation Section
18707(b)(2)).
Specialized "public generally exceptions" exist for decisions to establish or
adjust assessments, taxes, fees, charges, or rates (Regulation Section 18707.1), for
decisions affecting an official's principal residence located in a "small jurisdiction"
(having a population of 25,000 or less), decisions affecting principal industries, trades
or professions in the jurisdiction (Regulation Section 18707.3), decisions made by'
appointed members of certain types of board or commissions (Regulation Section
187047.4), decisions affecting sources of income to owners of retail business entities
(Regulation Section 18707.5), or decisions in specified "states of emergency"
(Regulation Section 18707.6)).
STEP EIGHT:
Is the Public Official's Participation Legally Required?
Determine if the public official's participation is legally required
despite the conflict of interest.
A public official is permitted to participate in making a governmental decision,
despite having a conflict of interest in the decision, if there exists no alternative
source of decision consistent with the purposes and terms of the statute authorizing
the decision. (Regulation Section 18708). This exception is applied when a quorum
of a legislative body cannot be convened due to the disqualifying conflicts of interests
of its members. In that situation, one, or as many members as is needed to create the
minimum number for the quorum, may be selected at random to participate. In these
situations, stringent disclosure requirements apply, not only regarding the basis of the
selected member's conflict of interest, but also the reason why there is no alternative
source of decision-making authority (Regulation Section 18708(b)). This rule is
construed narrowly and may not be invoked to permit an official, who is otherwise
disqualified, to vote to break a tie or to vote if a quorum can be convened of other
members of the agency who are not disqualified, whether or not such other members
are actually present at the time of the decision (Regulation Section 18708(c)).
2. Abstention
When a public official has a conflict of interest under the Act, he or she is required to
abstain from making, participating in the making, or using or attempting to use his or her
official position to influence the local agency's decision regarding the project (Government
Code Section 87103). Abstention avoids a violation of the conflict of interest provisions of
the Act. Persons who are members of a legislative body should announce their abstention at
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the meeting of the legislative body at which the decision is presented, and before the item is
discussed. Their announcement is required to be accompanied by disclosure of the financial
interest that causes the conflict of interest. These announcements must be carefully and fully -
entered into the minutes of the legislative body. Upon an abstention, it is recommended that
the public official step off the legislative body's dais and remain outside the legislative
body's meeting room each time the legislative body considers the item. Public officials who
are not members of a legislative body should announce their abstention in writing made to
the official's supervisor or appointed power (Regulation Section 18702.1(1)(5)).
A public official with a disqualifying conflict of interest in a decision is permitted to
have limited contact with the public agency regarding that decision under certain
circumstances. Recognizing that public officials have, at certain times, the need and right to
represent their own personal interests, the FPPC has created an exception that permits a
disqualified official to speak to a legislative body of which he or she is a member or a
legislative body under the budgetary control of the legislative body of which they are a
member (Regulation Section 18702.4(b)). This exception permits an official to appear in the
same manner as any other member of the general public solely to represent his or her
"personal interests." The term "personal interests" is defined to include an interest in real
property or a business entity that is wholly owned by. the official or members of his or her
immediate family (spouse or dependent children). It also includes business entities over
which the official, or the official and his or her spouse, exercise sole direction and control.
(Regulation Section 18702.4(b)).
3. Penalties for Violation
Administrative, civil and criminal penalties exist for violation of the conflict of
interest provisions of the Act. Administrative penalties are levied by the FPPC after hearing
or entry of stipulated statement of facts and may include up to a $5,000 free per violation, a
cease and desist order, and an order to file reports (Section 83116). Civil penalties include
injunctive relief that may be sought by the district attorney or any' person residing in the
jurisdiction (Section 91003). In the event a court finds that the actions would not have been
taken but for the action of the official with the conflict of interest,. the court is empowered to
void the decision (Section 91003). Misdemeanor criminal penalties are provided in situations
where a knowing or willful violation of the act occurs (Section 91000) and, generally,
persons convicted of violating the act may not be a candidate for elective office or act as a
lobbyist for four years after the conviction (Section 91002). The statute of limitations for
civil and criminal enforcement actions is four years from the date of the violation (Section
91000(c) and 9101 1(b)). The statute of limitations for administrative actions brought by the
FPPC is five years from the date of the violation (Section 91000.5).
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4. Seeking Advice on Conflict of Interest Questions
It is important to note that only a formal advice letter from the FPPC staff can
immunize a public official from potential enforcement by the FPPC or the District Attorney
in the event the public official participates in a decision and someone subsequently alleges the
public official had a prohibited conflict of interest. A formal advice letter usually takes the
Commission staff at least a month to prepare and is only provided if the request relates to
prospective acts as distinguished from past acts and it if contains sufficient facts upon which
the FPPC is able to render a decision. Informal written advice (without immunity from
potential enforcement action) may also be requested from the FPPC staff as well as informal
telephonic advice through their technical assistance division at (916) 322-5660. Based on the
time-frames required to obtain formal or informal written advice from the FPPC, it is
important for public officials to consult their city attorney or local agency counsel as earlier
as possible so as to provide adequate time to gather all relevant facts, draft a letter to the
FPPC, and respond to the advice once given.
B.. GOVERNMENT CODE SECTION 1090
Government Code Section 1090 provides:
"Members of the Legislature, state, county, district, judicial district,
and city officers or employees shall not be financially interested in any
contract made by them in their official capacity, or by any body or board of
which they are members. Nor shall state, county, district, judicial district,
and city officers or employees be purchasers at any sale or vendors at any
purchase made by them in their official capacity.
"As used in this article, 'district' means any agency of the state formed
pursuant to general law or special act, for the local performance of governmental or
proprietary functions within limited boundaries.'
The prohibition contained in Section 1090 is intended to preclude a public official
from using his or her official position as a government officer or employee to obtain business
or financial advantage. The purpose of the prohibition is to remove the possibility of any
personal influence which might bear on an official' s decision-making activities with respect
to contracts entered into by the governmental agency.
Upon the enactment of the Political Reform Act of 1974, a question arose as to
whether that new law impliedly repealed or preempted the provisions of Section 1090. This
question was first addressed by the Attorney General in 1976 wherein that Office concluded
in 59 Ops. Cal. Att'y. Gen. 604, 671 (1976) that the Political Reform Act did not impliedly
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repeal or preempt Section 1090. Since that time, courts and the Attorney General have
consistently considered Section 1090 as having continuing effect (See, Fraser-Yamor Agency,
Inc. v. County of Del Norte, 68 Cal. App.3d 201 (1977), People v. Vallerga, 67 Cal. App.3d
847 (1977), City Council v. McKinley, 80 Cal. App.3d 204 (1978), City of imperial Beach v.
Bailey, 103 Cal. App.3d 191 (1980), Thomson v. Call, 38 Cal.3d 633 (1985), Campagna v.
City of Sanger, 42 Cal. App.4th 533 (1996), rev. den. and Opinions of the California Attorney
General at 67 Ops. Cal. Att'y Gem 369, 375 (1984), 69 Cal. Att'y. Gen. 102 (1986), 70
Ops. Cal. Att'y. Gen. 45, 47 (1987) and 73 Ops. Cat. Att'y. Gen. 191, 194-195 (1990)).
More recently, in People v. Honig, 48 Cal. App.4th 289, 328-29 (1996), the defendant
in a criminal case for violations of Section 1090 argued that the provisions of the Political
Reform Act superseded Section 1090. The court declined to so rule, holding instead that the
term "financially interested" in Section 1090 has a different meaning than the term "material
financial effect" in the Political Reform Act. As recently as January of this year, a
California Court of Appeal again held that the Political Reform Act and Section 1090 are
"two different statutory schemes." (City of Vernon v. Central Basin Water Dist., 69
Cal. App.4th 508, 513 (1999)).
Section 1090 is unlike the Political Reform Act and the Common Law Doctrine
Against Conflicts of Interest which require the public official with the conflict of interest
only to abstain from participation in the decision. Section 1090 prevents the local agency
from even entering into the contract in which one of its officers or employees has a financial
interest unless certain exceptions apply. Specifically, if an official is a member of a board or
commission which executes the contract, he or she is conclusively presumed to be involved
in the making of his or her agency's contracts (Thomson v. Call, supra, at p. 649). This
absolute prohibition applies regardless of whether the contract is found to be fair and
equitable or the official abstains from all participation in the decision. (Thomson, supra, at
p. 649-650, Fraser-.Yamor Agency, Inc. v. County of Del None, supra, at pp. 211-212, and
City of imperial Beach, supra, at p. 195)). Only the existence of a "remote" or "non-
interest" within the meaning of specified provisions discussed below provide an exception to
this rule.
1. Three Principal Components to Section 1090
The prohibition contained in Section 1090 involves three principal components:
(1) the person subject to the prohibition must be an officer or employee of one of the types
of listed governmental entities; (2) the public officer or employee must be financially
interested in the contract; and (3) the contract must be made either (i) by the public official
in his or her official capacity; or (ii) by the body or board of which he or she is a member.
1999 SPRING SEMINAR
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I[
II
, a. Officer or Employee of Listed Government Entity
The first element is whether the person subject to the prohibition is an officer or
employee of "the Legislature, state, county, district, judicial district," or a "city officer or
employee.' Virtually every officer or employee or a municipality or local governmental
district is subject to the prohibitions of Section 1090.
b. Financial Interest in a Contract
The second element of the prohibition is the existence of a direct or indirect financial
interest in a contract. The term "financially interested" has been interpreted to include any
direct interest, such as that involved when an officer enters directly into a contract with the
body of which he is a member. It has also been interpreted to include indirect financial
interests in a contract, where for example, a public official would gain something financially
by the making of the contract (Fraser-Yamor Agency, Inc. v. County of Del None, 68
Cal. App.3d 201 (1977)).
.Th..e scope of the financial interests to which Section 1090 applies is broad. In
Thomson v. Call, supra, at p. 645-46, the California Supreme Court described the breadth of
the statute this way:
"Section 1090 forbids city officers such as Call from being 'financially
interested in any contract made by them in their official capacity, or by any
body or board of which they are members.' The proscribed interest certainly
includes any direct interest, such as that involved when an officer enters
directly into a contract with the body of which he is a member. California
courts have also consistently Voided such contracts where the public officer
was found to have an indirect interest therein .... Neither the absence of
actual fraud nor the possibility of a 'good faith' mistake on Call's part can
affect the conclusion that this contract violates section 1090 and is therefore
void." (Citations omitted, emphasis added.)
In that case, a city councilman sold certain real property to a third party, knowing
that the city was negotiating a deal to acquire multiple parcels of property in that area for a
publid park. The third party then conveyed the councilman's property to the City, in an
apparent attempt to evade the provisions of Section 1090. The court essentially "unwound"
and invalidated the entire transaction based on the councilman's interest in the transaction.
The court refused to focus on the isolated contract between the city and the third-party that
bought the property from the councilmember, but rather viewed all of the successive
contracts as one complex multi-party agreement. The court ordered the councilmember to
disgorge all funds he received in the transaction and ordered that the City retain title to the
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property. The court noted that this type of severe remedy was necessary to discourage
violations of Section 1090.
In People v. Vallerga, supra, at p. 867, the court summarized prior court decisions
addressing financial interests under Section 1090 as follows:
"However devious and winding the chain may be which connects the officer
with the forbidden contract, if it can be followed and the connection made, the
contract is void."
The second part of this component is the existence of a "contract" within the meaning
of Section 1090. General contract principles apply to this determination and include such
arrangements as purchase and service contracts but also development agreements between a
city and a developer (78 Ops. Cal. Att'y. Gen. 230 (1995)) and payments for conference
attendance expenses (75 Ops. Cal. Atty. Gem 20 (1992)).
C,
Contract "Made" by the Official or by a Body or Board of which the
Official is a Member
The third element is that the contract has to be "made" either by the official or
employee acting in his or her official capacity, or by any body or board of which the official
is a member. The term "made," as used in the statute has been interpreted broadly by the
courts to encompass such elements in the making of a contract as preliminary discussions,
negotiations, compromises, reasoning, planning, drawing of plans or specifications and
solicitation for bids (Mitbrae Association for Residential Survival v. City of MiIbrae, 262
Cal. App.2d 222, 237 (1968); City Council of San Diego v. McKinley, 80 Cal. App.3d 204,
(1978)). A city council's approval of a simple purchase order as part of the approval of a
demand warrant registrar is most likely to constitute the making of a contract within the
scope of Section 1090.
2. Exceptions to Section 1090
There are two codi~ed sets of exceptions to Section 1090. The first is Section 1091
which specifies certain "remote interests." If an official merely has a remote interest, then
the local agency may enter into the contract as long as the official abstains from participating
in any way in the decision. The second set of exceptions is found in Section 1091.5. These
exceptions are called the "non-interest" exceptions and provide that the interests which fall
within those exceptions are excluded from the scope of Section 1090 altogether.
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3. Penalties
A violation of Section 1090 may result in severe penalties. A contract made in
violation of Section 1090 is deemed void (Section 1092). Any person subject to Section 1090
who willfully violates Section 1090 is guilty of a felony and subject to a free and
imprisonment in a state prison (Section 1097). He or she may also be forever barred from
holding public office in this state (Section 1097).
C. COMMON LAW DOCTRINE AGAINST CONFLICTS OF INTEREST
The common law doctrine against conflicts of interest is the judicial expression of the
public policy against public officials using their official positions for private benefit (see,
Terry v. Bender, 143 Cal. App.2d 198,206 (1956)). This doctrine has been primarily applied
to require a public official to abstain from participation in cases where the public official's
private financial interest may conflict with his or her official duties (64 Ops. Cal. Atty. Gen.
795,797 (1981)).
By virtue of holding public office, an elected official "is impliedly bound to exercise
the powers conferred on him with disinterested skill, zeal, and diligence and primarily for
the benefit of the public." (Noble v. City of Palo Alto, 89 Cal. App. 47, 51 (1928)). An
elected official bears a fiduciary duty to exercise the powers of office for the benefit of the
public and is not permitted to use those powers for the benefit of a private interest/~; see
also Nussbaum v. Weeks, 214 Cal. App.3d 1589, 1597-98 (1989)).
This doctrine is an independent basis from the Political Reform Act for requiring
local agency officials and employees to abstain from participating in local agency discussions
or decisions involving matters in which they have a financial interest. Violation of the
common law duty to avoid conflicts of interest can constitute official misconduct and result
in a loss of office (See Nussbaum, 214 Cal. App.3d at 1597-98).
H. OTHER SPECIALIZED CONFLICT OF INTEREST LAWS
A. Incompatible Outside Activities (Government Code Section 1126 et seq.)
California Government Code Section 1126 provides:
"(a) Except as provided in Sections 1128 and 1129, a local agency
officer or employee shall not engage in any employment, activity, or enterprise
for compensation which is inconsistent, incompatible, in conflict with, or
inimical to his or her duties as a local agency officer or employee or with the
duties, functions, or responsibilities of his or her appointing power or the
agency by which he or she is employed .... "
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The provisions of Section 1126 prohibit officials and employees of a local government
agency from engaging in outside employment or activities where any ~art of the employment
or activity will be subject to approval by any other offleer, employee, board or commission
of the local agency. Exceptions are created to permit a public official to engage in outside
employment by a private business (Section 1127), and to permit an attorney employed by a
local agency in a non-elective position to serve on an appointed or elected governmental
board of another agency (Section 1128).
However, the court in Mazzola v. City and County of San Francisco, 112 Cal. App.3d
141 (1980) ruled that Section 1126 provides only authorization to implement standards for
incompatibility pursuant to paragraph (b) of Section 1126. The court ruled that the
restrictions of Section 1126 are not self-executing because existing and future employees
should have notice that specific outside activities are or are not compatible with their duties
as an officer or employee of the local agency. Thus, Section 1126 would not bar a public
official from holding a position outside their public agency unless the public agency in which
they serve as a public official adopts an ordinance in compliance with the requirements of
Section 1126 that specifies that the two positions or activities are incompatible.
In light of the court's decision in Mazzola, the Attorney General ruled that Section
1126 did not apply to any elected official, such as a city councilmember, since elected
officials do not have an "appointing power" that can promulgate guidelines for their activities
pursuant to Section 1126. However, if a local agency adopts such guidelines, they can be
made applicable to officers and employees subordinate to the legislative body of the local
agency, including members of advisory boards and commissions.
B. Common Law Doctrine Against Incompatible Offices
The common law doctrine against incompatibility of offices arose from a concern that
the public interest would suffer where one person holds two public offices which might
possibly come into conflict. The California Supreme Court set forth the following test for
incompatibility of office in People ex rel. Chapman v. Rapsey, 16 Cal.2d 636 (1940):
"Two offices are said to be incompatible when the holder tannot in every
instance discharge the duties of each. Incompatibility arises, therefore, from
the nature of the duties of the offices, when there is an inconsistency in the
functions of the two, where the functions of the two are inherently inconsistent
or repugnant, as where antagonism would result in the attempt by one person
to discharge the duties of both offices, or where the nature and duties of the
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two offices are such as to render it improper from considerations of public
policy for one person to retain both." (16 Cal.2d at 641-642).
Incompatibility of offices is not measured only by conflicts which do exist, but also
by those conflicts which might arise (People ex rel. Chapman, 16 Cal.2d 636, 641-642
(1940); 66 Cal. Atty. Gen. 382, 384 (1983); 64 Ops. Cal. Atty. Gen. 288,289 (1981)).
In order to determine whether two positions are in conflict, it is necessary to
determine first whether the positions are public offices. No statutory definition is given to
the term "public officer." However, in People ex rel. Chapman v. Rapsey, supra, the court
stated:
"[A] public office is said to be the right, authority, and duty, created and
conferred by law--the tenure of which is not transient, occasional, or
incidental--by which for a given period an individual is invested with power to
perform a public function for public benefit . . .
"One of the prime requisites is that the office be created by the
Constitution' or authorized by some statute. And it is essential that the
incumbent be clothed with a part of the sovereignty of the state to be exercised
in the interest of the public." (16 Cal.2d at 640).
Incompatibility can be triggered if the duties of the two offices "overlap so that their
exercise may require contradictory or inconsistent action, to the detriment of the public
interest." (People ex. rel. Bagshaw v. Thomson, 55 Cal. App.2d 147, 150 (1942)). Only one
significant clash of duties and loyalties is required to make offices incompatible (37 Ops.
Cat. Atty. Gen. 21, 22 (1961). The policy set forth in People ex rel. Chapman v. Rapsey
includes prospective as well as present clashes of duti.es and loyalties (63 Ops. Cat. Atty.
Gen. 623 (1980)). :
Disqualification 9f oneself from participating in those situations of potential conflict
has not been authorized as a remedy for incompatible offices. The general rule provides:
"The existence of devices to avoid.. . [conflicts] neither changes the nature
of the potential conflicts nor provides assurances that they would be employed
(38 Ops. Cal. Atty. Gen. 121, 125 (1961)). Accordingly, the ability to abstain
when a conflict arises will not excuse the incompatibility or obviate the effects
of the doctrine." (66 Ops. Cal. Atty. Gem 176, 177 (1983)).
The effect of the doctrine of incompatibility of offices is that a public official who
enters upon the duties of a second office must vacate the first office if the two are
incompatible (People ex rel Chapman v. Rapsey, 16 Cal.2d 636, 644 (1940)).
1999 SPRING SEMINAR Page 107
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Ill
III
C. Redevelopment Conflicts
Health and Safety Code Section 33130 requires any officer or employee of a city or
redevelopment agency who is required to participate in the formulation of, or to approve
plans or policies for, the redevelopmerit of a project area, to immediately disclose his or her
ownership interest in any real property located within the proposed project area. This
requirement applies to members of a city council, a planning commission and other officers
and employees of a city or redevelopmerit agency. Failure to make the disclosure constitutes
misconduct in office.
Section 33130 also precludes any city or redevelopment agency official who is
required to participate in the formulation of, or to approve plans or policies for, the
redevelopment of a project area, from acquiring any interest in property located within the
boundaries of the project area. This means that redevelopment agency employees and
persons elected to the city council and serving as agency board members may not purchase
property in the redevelopmerit agency's project area. Also, if the redevelopment agency
commences the process to establish a new project area, city and redevelopment agency
employees and officials involved in redevelopment decisions are precluded from acquiring
any additional or new interests in property within that new project area boundary.
As discussed below, there are three exceptions to the prohibition against acquiring
interests in property in a project area. Upon acquiring any interest under one of these
exceptions, disclosure of the interest is required.
The first exception allows an officer or employee to acquire an interest for the
purpose of participating as an owner or re-entering into business if that officer or employee
has owned a substantially equal interest to that being acquired for three years immediately
preceding the selection of the project area (Section 33130(b)).
The second exception allows an officer or employee to enter into a rental agreement
or lease of property for the purpose of the principal business, occupation, or profession of
the officer or employee. However, this exception is limited to rental agreements or leases
that have terms substantially equivalent to those offered the general public. Also the rental
agreement or lease may not allow the property to be sublet at a rate in excess of the rate in
the original rental agreement or lease (Section 33130(c)).
The third exception allows for the purchase or lease of property for personal
residential use, but only after the redevelopment agency has certified that all construction or
improvements to the property have been completed (Section 33 130.5).
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Ill
De
Discount Passes on Common Carriers (California Constitution, Article
XII, Section 7)
Article XII, Section'7 of the California Constitution states:
"A transportation company may not grant free passes or discounts to anyone
holding in office in this state; and the acceptance of a pass or discount by a
public officer, other than a Public Utilities Commissioner, shall work a
forfeiture of that office. A Public Utilities Commissioner may not hold an
official relation to nor have a financial interest in a person or corporation
subject to regulation by the commission."
The Attorney General has explained this provision applies in the following manner:
The prohibition applies to public officers, both elected and non-elected, but not
employees.
The prohibition applies to interstate and foreign carriers as well as domestic
carriers, and to transportation received outside California.
The prohibition applies irrespective of whether the pass or discount was
provided in connection with personal or public business.
4. Violation of the prohibition is punishable by forfeiture of office.
There have only been a few decisions that address this Constitutional prohibition. In
one Opinion, the Attorney General granted leave to sue two members of a city council who
accepted free airline tickets to London given by Laker Airlines as part of the airline's
promotion of its new Los Angeles to London service. Despite the fact that the
councilmembers were unaware of the prohibition, the Attorney General allowed a quo
warranto suit that subsequently settled before judgment (See 76 Ops. Cal. Arty. Gen. 1, 3,
(1993)).
In another Opinion, the mayor of a city received an upgrade from a coach seat to a
first class seat on Hawaiian Airlines (76 Ops. Cal. Atty. Gen. 3 (1993)). There, the mayor's
ticket was one of 20 first-class upgraded tickets that the airline was allowed to provide to
"high profile, prominent members of the community." At issue was whether that situation
fit within an exception to the Constitutional prohibition for situations when the free
transportation or discount is provided to a public officer as a member of a larger group
unrelated to the official's position. The Attorney General ruled that the facts did not satisfy
the exception and that a violation of the prohibition had occurred.
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The exception considered in that Opinion stemmed out of a 1984 Opinion of the
Attorney General which held that a public officer could accept first-class ticket upgrades by
virtue of the airline's policy to do so for all persons on their honeymoon. In 67 Ops. Cal.
Atty. Gen. 81 (1984), the Attorney General concluded that a public officer, whose spouse
was a flight attendant, could accept a free transportation pass or discount when such was
offered to all spouses of flight attendants without distinction to the official status of the
recipient.
Consequently, if the pass or discount is provided to the official because of his or her
position as a governmental official, the prohibition applies. If it is provided to the official as
a member of a larger group that is not related to the functions of his or her office, the
prohibition may not be applicable.
1]I. LAWS THAT PROHIBIT CERTAIN GIFTS, HONORARIA AND LOANS
The Political Reform Act was mended in the last few years to preclude elected local
officials from receiving certain gifts, honoraria and loans. These prohibitions apply whether
or not the source of the gift, honorarium or loan is, or will ever be, affected by a decision of
the official's agency. Additionally, these limitations apply to certain other designated local
officials, including planning commissioners.
A. Limitations on the Receipt of Gifts
1. General Gift Limitation - Government Code Section 89503(a) provides:
"No elected state officer, elected officer of a local government
agency, or other individual specified in Section 87200 [includes
Planning Commissioners] shall accept gifts from any single
source in any calendar year with a total value of more than two
hundred mew dollars [$3001.' (Emphasis added).
A similar limitation prohibits a city employee designated in a conflict of
interest code from accepting gifts from a single source totaling more than $300
in value in any calendar year, if the gifts would be required to be reported on
his or her statement of economic interests (Section 89503(c)).
Biennial Gift Limit Adjustment - The Act authorizes the FPPC to make an
inflationary adjustment of the limitations set forth in Section 89503 every two
years (Section 89503(f)). The most recent adjustment became effective on
January 1, 1999, and the gift limitation is now $300.
1999 SPRING SEMINAR Page 110
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,
Exceptions to Gifts and Gift Limitations
Basic Exqeptions - FPPC Regulation Section 18942 is summarized
below: None of the foliowing is a gift and none is subject to any
limitation on gifts:
(1) Informational Materials - such as books, calendars, videotapes,
and free or discounted admission to educational conferences that are
provided to assist the official in the performance of official duties.
(2) Returned Gifts - A gift that is not used and that, within 30 days
after receipt, is returned or donated pursuant Regulation Section 18943,
or for which reimbursement is paid pursuant to Regulation Section
18943. However, a gift will still be regarded as accepted if the official
returns the gift but takes an income tax deduction for the value of the
returned gift.
(3) Family Gifts - A gift from an individual' s spouse, child, parent,
grandparent, grandchild, brother, sister, parent-in-law, brother-in-law,
sister-in-law, nephew, niece, aunt, uncle, or fu:st cousin or the spouse
of any such person, unless the donor is acting as an agent or
intermediary for any other person.
(4) Campaign Contributions - Please note, however, campaign
contributions are required to be reported.
(5) Inherited Money or Property - Any devise or inheritance.
(6) Awards - A personalized plaque or trophy with an individual
value of less than two hundred fifty dollars ($250).
(7) Home Hospitality - Hospitality (including food, beverages, or
occasional lodging) provided to an official by an individual in his or
her home when the individual or a member of the individual's family is
present.
,(8) Presents on Personal or Family Occasions - Presents exchanged
between an official and an individual, other than a lobbyist, on
holidays, birthdays, or similar occasions provided that the presents
exchanged are not substantially disproportionate in value.
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(9) Admission and Incidentals at Speaking Events - Free
admission, and refreshments and similar non-cash nominal benefits
provided to an official during the entire event at which the official
gives a speech, participates in a panel or seminar, or provides a similar
service, and actual intrastate transportation and any necessary lodging
and subsistence provided directly in connection with the speech, panel,
seminar, or service, including but not limited to meals and beverages
on the day of the activity. These items are not payments and need not
be reported by any official.
(10) Campaign Travel - The transportation, lodging, and subsistence
provided in direct connection with campaign activities, including
attendance at political fundraisers.
Gifts to a Public Official's Family - FPPC Regulation Section 18944 provides
(in summary):
a. Gifts given directly to members of an official's immediate family are
not gifts to the official unless used or disposed of by the official or given by
the recipient member of the official's immediate family to the official for
disposition or use at the official's discretion.
b. Gifts delivered by mail or other written communication are given
directly to members of the official's immediate family if the family members'
names or familial designations (such as "spouse") appear in the address on the
envelope or in the communication tendering or offering the gift, and the gift is
intended for their use or enjoyment.
c. A gift given to the official, but designated for the official and spouse or
family, is a gift to the official if the official exercises discretion and control
over who will actually use the gift.
d. If the official enjoys direct benefit from a singie gift, as well as
members of the official's family, the full value of the gift is attributable to the
official. Examples, include a television that is given to a member of the
official's family but which is generally used by the entire family, including the
public official.
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Tickets to Political and Charitable Fundraisers - FPPC Regulation Section
18946.4 provides (in summary):
a. Nonprofit Fundraiser - Except as provided in subdivision (b), a ticket
to a fundraising event for a nonprofit, tax-exempt organization (that is not a
political campaign committee) shall be valued as follows:
(1) Where the event is a fundraising event for a nonprofit
organization, and the ticket clearly states that a portion of the ticket
price is a donation to the organization, then the value of the gift is the
face value of the ticket or admission reduced by the amount of the
donation.
(2) If the ticket has no stated price or no stated donation portion,
the value of the gift is the fair market value of any food, beverage, or
other tangible benefits provided to each attendee.
b. Fundraiser for a religious, charitable, scientific, literary or
educational organization - Where the event is a fundraising event for an
organization exempt from taxation under Section 501(c)(3) of the Internal
Revenue Code, the ticket or other admission privilege has no value.
c. Political Fundraiser - Where the event is a fundraising event for a
campaign committee or candidate, the ticket or other admission privilege has
no value.
Prizes and Awards from Competitions - A prize or an award received shall be
reported as a gift unless the prize or award is received in a bona fide
competition not related to the recipient's status as an official or candidate. A
prize or award which is not reported as a gift shall be reported as income.
7. Certain Gifts of Travel Exempt from Gift Limitations - FPPC Regulation
Section 18950.1 provides (in summary):
a. Travel In Connection With Speeches, Panels, and Seminars
(1)
A payment made for travel, including actual transportation and
related lodging and subsistence, is not subject to the prohibitions
or limitations on honoraria and gifts if:
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e,
(A)
The travel is reasonably related to a legislative or
governmental purpose, or to an issue of state, national,
or international public policy, and
(B)
The travel, including actual transportation and related
lodging and subsistence, is in connection with a speech
given by the official or candidate; the lodging and
subsistence expenses are limited to the day immediately
preceding, the day of, and the day immediately following
the speech; and the travel is within the United States.
Travel Provided by Governmental Entity or Charity A payment made for
travel, including actual transportation and related lodging and subsistence, is
not subject to the prohibitions or limitations on honoraria and girls if:
(1) The travel is reasonably related to a legislative or governmental
purpose, or to an issue of state, national, or international public policy;
and
(2) The payment is provided by a government, a governmental
agency, a foreign government, a governmental authority, a bona fide
public or private educational institution, defined in Section 203 of the
Revenue and Taxation Code, or by a nonprofit charitable or religious
organization that is exempt from taxation under Section 501(c)(3) of the
Internal Revenue Code, or by a person that is domicfled outside the
United States and that substantially satisfies the requirements for tax
exempt status under Section 501(c)(3) of the Internal Revenue Code.
TraVel Paid From Campaign Funds - A payment made for transportation and
necessary lodging and subsistence, which payment is made from campaign
funds as permitted by Government Code Section 89513, or which is a
contribution, is not an honorarium or a girl.
Travel Provided By Of~cial's Agency - A payment made for transportation
and necessary lodging and subsistence, which payment is made by the agency
of an official, is not an honorarium or a girl.
Travel In Connection With Bona Fide Business - A payment made for
transportation, lodging, and subsistence, which payment is reasonably
necessary in connection with a bona fide business trade, or profession, and
which satisfies the criteria for federal income tax deductions for business
expenses specified in Sections 162 and 274 of the Internal Revenue Code, is
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el999 Richards, Watson & C, ershon
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,
b,
c,
d,
not an honorarium or gift unless the sole or predominant activity of the
business, trade or profession is making speeches.
Prohibitions on Receipt of Honoraria
Basic Prohibition - Government Code Section 89502 provides that no elected
officer of a local government agency nor any official listed in Government
Code Section 87200 (which includes planning commissioners) shall accept an
honorarium.
An "honorarium" means any payment made in consideration for any speech
given, article published, or attendance at any public or private conference,
convention, meeting, social event, meal, or like gathering.
Summary of Exceptions to Prohibition on Honoraria
a,
Earned Income Exception - "Honorarium" does not include income
earned for personal services if:
(1)
The services are provided in connection with an individual's
business or the individual's practice of or employment in a bona
fide business, trade, or profession, such as teaching, practicing
law, medicine, insurance, real estate, banking, or building
contracting; and
(2)
The services are customarily provided in connection with the
business, trade, or profession (Regulation Section 18932).
Information Materials - "Honorarium" does not include information materials
such as books, calendars, videotapes, or free or discounted admission to
educational conferences that are provided to assist the official in the
performance of official duties (Regulation Section 18932.4(a)).
Family Payments - "Honorarium' does not include a payment received from
one's spouse, child, parent, grandparent, grandchild, brother, sister, parent-in-
law, brother-in-law, sister-in-law, nephew, niece, aunt, uncle or first cousin or
the spouse of any such person. However, a payment from any such person is
an honorarinm if the donor is acting as an agent or intermediary for any
person not listed in this paragraph (Regulation Section 18932.4(b)).
Campaign contributions - However, campaign contributions are required to be
reported (Regulation Section 18932.4(c)).
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Personalized Plaque or Trophy - Honorarium does not include a personalized
plaque or trophy with an individual value of less than two hundred and fifty
dollars ($250) (Regulation Section 18932.4(d)).
Admission and Incidentals at Place of Speech - "Honorarium" does not
include free admission, refreshments and similar non-cash nominal benefits
provided to an official during the entire event at which the official gives a
speech, participates in a panel or seminar, or provides a similar service, and
actual intrastate transportation and any necessary lodging and subsistence
provided directly in connection with the speech, panel, seminar, or service,
including but not limited to meals and beverages on the day of the activity.
(Regulation Section 18932.4(e)).
g,
Incidentals at Private Conference - "Honorarium" does not include any of the
following items, when provided to an individual who attends any public or
private conference, convention, meeting, social event, meal, or like gathering
without providing any substantive service:
(1) Benefits, other than cash, provided at the conference,
convention, meeting, social event, meal, or gathering.
(2) Free admission and food or beverages provided at the
conference, convention, meeting, social event, meal, or gathering
(Regulation Section 18932.4(f)).
he
Travel That Is Exempt From Gifts - Any payment made for transportation,
lodging and subsistence that is exempted by the gift exceptions (Regulation
Section 18932.4(g)).
C. Prohibitions on Receipt of Certain Types of Loans
Prohibition on Loans Exceeding $250 from Other City Officials, Employees,
Consultants and Contractors - Effective January 1, 1998, elected officials and
other city officials specified in Section 87200 (Planning Commissioners, City
Managers, City Treasurers, City Attorneys, etc. ,) may not receive a personal
loan that exceeds $250 at any given time from an officer, employee, member
or consultant of your city or any local government agency over which your
city exercises direction and control (Section 87460(a) and (b)). In addition,
elected officials and other city officials specified in Section 87200 may not
receive a personal loan that exceeds $250 at any given time from any
individual or entity that has a contract with your city or any agency over
which your city exercises direction and control (Section 87460(c) and (d)).
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Requirement for Loans of $500 or More front Other Persons and Entities to
be in Writing - Elected local officials may not receive a personal loan of $500
or more unless the loan is made in writing and clearly states that terms of the
loan. The loan document must include the names of the parties to the loan
agreement, as well as the date, amount, interest rate, and term of the loan.
The loan document must also include the date or dates when payments are due
and the amount of the payments (Section 87461).
Exceptions to Loan Limits and Documentation Requirements - The following
loans are not subject to the limits and documentation requirements specified in
subparts 1 and 2 above:
Loans received from banks or other financial institutions, and retail or
credit card 'transactions, made in the normal course of business on
terms available to members of the public without regard to official
status.
Loans received by an elected officer's or candidate's campaign
committee.
Loans received from the elected or appointed official's spouse, child,
parent, grandparent, grandchild, brother, sister, parent-in-law, brother-
in-law, sister-in-law, nephew, niece, aunt, uncle, or first cousin, or the
spouse of any such person unless he or she is acting as an agent or
intermediary for another person not covered by this exemption.
d. Loans made, or offered in writing, prior to January 1, 1998.
Loans that Become Gifts Subject to the Gift Prohibition - Under the following
circumstances, a personal loan received by any public official (elected and
other officials specified in Section 87200, as well as any other local
government official or employee required to file a Statement of Economic
Interest) may become a gift and subject to gift and reporting limitations:
a,
If the loan has a defined date or dates for repayment and has not been
repaid, the loan will become a gift when the statute of limitations for
filing an action for default has expired.
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If the loan has no defined date or dates for repayment, the loan will
become a girl if it remains unpaid when one year has elapsed from-the
later of:
(1) the date the loan was made;
(2)
the date the last payment of $100 or more was made on the
loan; or
(3)
the date upon which the official has made payments aggregating
to less than $250 during the previous 12-month period.
Exceptions -- Loans that Do Not Become Gifts - The following loans will not
become gifts to an official:
a. A loan made to an elected officer's or candidate's campaign committee.
b,
A loan on which the creditor has taken reasonable action to collect the
balance due.
A loan described above on which the creditor, based on reasonable
business considerations, has not undertaken collection action.
(However, except in a criminal action, the creditor has the burden of
proving that the decision not to take collection action was based on
reasonable business considerations.)
d,
A loan made to an official who has filed for bankruptcy and the loan is
ultimately discharged in bankruptcy.
e,
A loan that would not be considered a gift as outlined in Part III (A)(3)
of this Summary (e.g. loans from family members) (Section 87462).
D. Penalties for violation of Gift and Honoraria Llmits
Persons who violate the gift or honoraria limitations are subject to a civil action
brought by the FPPC for up to three times the amount of the unlawful gift or honoraria
(Section 89521). Violators are also subject to administrative sanctions, which include fines
of up to $5,000 per violation, but they are exempt from civil or criminal penalties contained
in Section 91000 et seq. (Section 89520). Persons who violate the loan restrictions are
subject to administrative sanctions, which include fines of up to $5,000 per violation (Section
91005.5) and are also subject to civil or criminal penalties contained in Section 91000 et seq.
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We hope that this material is helpful to you. However, please remember that this
general introduction to conflict of interest laws and the FPPC's regulations does not cover
every potential decision of the local agency in which conflict of interest laws are implicated.
The application of these laws must be analyzed on a case-by-case basis in light of each public
offlcial's particular economic interests and the government decision being made. Thus, while
certain generalizations can be drawn, it is important to seek conflict of interest advice from
your city attorney or agency counsel whenever questions arise.
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