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Item # 26
City of Santa Ana
20 Civic Center Plaza, Santa Ana, CA 92701
Staff Report
March 1, 2022
TOPIC: City Council Voting, Recusal for Conflicts, and Prohibiting Abstentions
AGENDA TITLE:
Ordinance Concerning City Council Voting, Recusal for Conflicts, and Prohibiting
Abstentions
RECOMMENDED ACTION
Consider one of the following options:
1. Approve the first reading of an ordinance concerning City Council voting, recusal
for conflicts, and prohibiting abstentions.
2. Provide direction to staff.
DISCUSSION
Introduction
At the meeting on May 5, 2020, the City Council addressed an item to discuss and
consider directing the City Manager to direct staff to draft a policy for the City Council’s
consideration regarding abstentions on votes on items on the City Council meeting
agendas. The item was reported in the minutes of the May 5, 2020 meeting as the City
Council directing staff to research state law, current existing policy on City Council
participation, and bring back to a future meeting for the City Council's consideration. The
councilmember sponsors of this item later discussed the matter with the City Manager
and City Attorney, and indicated that the matter could be added to a future City Council
goal-setting meeting for consideration.
At a more recent City Council meeting, Councilmember Lopez inquired about bringing
forth a policy or ordinance to address voting and abstentions with the goal of addressing
a way to enforce the current prohibition against abstentions on votes as set forth in
Section 2-105 of the Santa Ana Municipal Code.
Background
Santa Ana Municipal Code (SAMC) Section 2-105, which as adopted in 1952 and
amended in 1965, currently provides as follows:
City Council Voting, Recusal for Conflicts and Prohibiting Abstentions
March 1, 2022
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Sec. 2-105. - Voting by members.
No member of the council shall abstain from any vote unless disqualified, and no
disqualified member shall vote. Any disqualified member shall openly state to the
presiding officer the fact and nature of such disqualification and shall not be subject to
further inquiry. Where no clearly disqualifying conflict of interest appears, the matter of
disqualification may, at the request of the member affected, be decided by the other
members of the council. A member disqualified by conflict of interest shall request and be
granted permission by the presiding officer to absent himself from the room where the
council is meeting during debate and vote on the matter. Any member having a remote
interest in any matter shall divulge the same to the council before voting.
While violation of Section 2-105 is a misdemeanor, it is not practical to consider enforcing
this provision through a criminal action against a councilmember. Further, by past
practice, the City Council has not indicated a desire to strictly enforce this provision.
On May 5, 2020, the City Council discussed Section 2-105 and there was a desire for
staff to conduct further research and return to the City Council with recommended policy
changes or considerations. During this discussion, there were some very pointed
remarks about the need for all councilmembers to participate and vote, unless legally
conflicted or explaining one’s reason for abstaining on a vote.
Research based on voting policies in other general law and charter cities demonstrates
that cities have adopted rules prohibiting abstentions and imposing rules to ensure that
all who can legally vote take a vote or have an abstention serve as a concurrence or “yes”
vote. Based on that research, the previous direction by the City Council, and the recent
request, staff has prepared a proposed ordinance for consideration.
The proposed ordinance addresses all of the following:
Requires declaration of the result of votes taken.
References per Section 410 of the Santa Ana City Charter that no ordinance,
resolution, motion, or any item requiring a vote shall be passed, adopted, or
become effective unless it receives the affirmative vote of a majority of the full
membership of the City Council.
Provides that no member of the City Council shall be permitted to recuse
themselves from voting on an item on the City Council meeting agenda unless
(1) the councilmember is legally disqualified from voting due to a conflict of
interest (including a disqualification under the Political Reform Act or Government
Code Section 1090 et sec].) or other legal reason (such as common law conflict
of interest or bias) or (2) the councilmember is awaiting advice from the Fair
Political Practices Commission (FPPC) or (3) the councilmember states that they
are awaiting further information or clarification and will recuse themselves out of
an abundance of caution.
Prohibits participation in a vote if one has a conflict and provides that those with
a conflict shall leave the dais during the consideration of the matter, provided,
City Council Voting, Recusal for Conflicts and Prohibiting Abstentions
March 1, 2022
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however, that if the matter is being considered on the Consent Calendar and has
not been removed from Consent Calendar, the councilmember may remain on
the dais and disclose the reason.
Clarifies, consistent with state law, that a disqualified councilmember may speak
on the matter as a private citizen, but only to the extent allowed by the Section
18702.5 of the Regulations of the FPPC, or its successor sections.
Provides that if a councilmember abstains on a vote in violation of the prohibition,
the abstention shall be considered concurrence in the motion and the Clerk shall
record the councilmember’s abstention as a “yes” vote.
States that a tie vote means no action has been taken and the item under
consideration will not be placed upon a future agenda, unless by a majority vote
of the City Council staff is directed to place the item on a future agenda or based
on new information or changes in circumstances the City Manager places the
item on a future agenda.
Adoption of the proposed ordinance will modernize a law in the SAMC that was last
addressed in 1965 and provide needed clarity on the issues of voting, conflicts, recusals
and abstentions.
ENVIRONMENTAL IMPACT
There is no environmental impact associated with this action.
FISCAL IMPACT
There is no fiscal impact associated with this action.
EXHIBIT(S)
1. Ordinance
Submitted By: Kristine Ridge, City Manager
Approved By: Kristine Ridge, City Manager
Ordinance No. NS-XXX
Page 1 of 4
ORDINANCE NO. NS-XXX
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY
OF SANTA ANA AMENDING SECTION 2-105 OF THE
SANTA ANA MUNICIPAL CODE TO PROHIBIT
ABSTENTIONS UNLESS LEGALLY REQUIRED, TO
REQUIRE UNAUTHORIZED ABSTENTIONS TO BE
COUNTED AND RECORDED AS A VOTE WITH THE
MAJORITY, AND TO DESCRIBE THE CONFLICT
DISQUALIFICATION PROCESS
THE CITY COUNCIL OF THE CITY OF SANTA ANA DOES ORDAIN AS
FOLLOWS:
Section 1. The City Council of the City of Santa Ana hereby finds,
determines, and declares as follows:
A. The City of Santa Ana seeks to ensure that the Mayor and Members
of the City Council, elected to carry out the business of the City, act upon all
agenda items presented for consideration.
B. The California Political Reform Act and regulations promulgated
thereunder by the Fair Political Practices Commission require the Mayor and
Councilmembers to disclose conflicts of interest, and new rules require
disclosure when an elected official is absent for only a portion of a meeting
where the member has a conflict on an agenda item.
C. If the Mayor or a Councilmember does not have a legally
disqualifying conflict of interest, he or she should not be permitted to refrain
from voting on an item requiring a vote.
D. Since 1952, the Santa Ana Municipal Code has stated in pertinent
part that “no member of the council shall abstain from any vote unless
disqualified.” However, because there is no practical way to enforce this
charter provision, the City Council desires to provide that an abstention will be
counted and recorded as a “yes” vote.
Section 2. Pursuant to the California Environmental Quality Act ("CEQA") and the State CEQA Guidelines, the adoption of this ordinance is exempt from CEQA review pursuant to 14 California Code of Regulations section 15061(b)(3).
Section 3. Section 2-105 of Article II (City Council) of Chapter 2 (Administration) of the Santa Ana Municipal Code is hereby amended to read in its entirety as follows:
Ordinance No. NS-XXX
Page 2 of 4
Sec. 2-105. - Voting by Members - Disqualifications and Abstentions.
It is the policy of the Santa Ana City Council that all members present at a City
Council meeting fully participate in the discussion of a matter and shall vote for or against
an ordinance, resolution, motion, or any other item requiring a vote, unless disqualified
by conflict of interest or other legal reason as provided in this section.
(a) If the vote is a voice vote, the Mayor or Clerk of the Council shall declare
the result and note for the record all yes votes and all no votes. The Council may also
vote by roll call or electronic means visible to the public. Regardless of the manner of
voting, the results reflecting all yes and no votes, and the members of the Council who
cast them, shall be clearly set forth for the record. In accordance with Section 410 of the
Santa Ana City Charter, except as otherwise provided elsewhere in the charter or by law,
no ordinance, resolution or motion shall be passed, adopted, or become effective unless
it receives the affirmative vote of a majority of the full membership of the City Council.
(b) No member of the Council shall be permitted to recuse himself or herself
from voting on any item on the City Council agenda requiring a vote unless:
(1) The councilmember is legally disqualified from voting due to a
conflict of interest (including a disqualification under the Political Reform Act or
Government Code Section 1090 et seq.) or other legal reason (such as common law
conflict of interest or bias); or
(2) The councilmember is awaiting advice from the Fair Political
Practices Commission; or
(3) The councilmember states that he or she is awaiting further
information or clarification and will recuse themself out of an abundance of caution.
(c) If a councilmember is disqualified from voting due to a conflict, the member
shall not participate in the consideration of the matter, shall not be counted for the
purpose of the quorum, and shall leave the dais during the consideration of the matter;
provided, however, that if the matter is being considered on the consent calendar and
has not been removed from the consent calendar, the councilmember may remain on the
dais and disclose the reason for disqualification. A disqualified councilmember may
speak on the matter as a private citizen, but only to the extent allowed by the Section
18702.5 of the Regulations of the Fair Political Practices Commission, or its successor
sections.
(d) If a councilmember abstains on a vote in violation of this rule, the abstention
shall be considered concurrence in the item being voted upon, and the City Clerk shall
record that councilmember’s abstention as a “yes” vote.
(e) A tie vote means that no action has been taken, and the item under
consideration shall not be placed upon a future agenda, unless by a majority vote of the
Council, city staff is directed to place the item on a future agenda, or based on new
Ordinance No. NS-XXX
Page 3 of 4
information or changes in circumstances, the City Manager places the item on a future
agenda.
Section 4. If any section, subsection, sentence, clause, phrase or portion of
this ordinance is for any reason held to be invalid or unconstitutional by the decision of
any court of competent jurisdiction, such decision shall not affect the validity of the
remaining portions of this ordinance. The City Council of the City of Santa Ana hereby
declares that it would have adopted this ordinance and each section, subsection,
sentence, clause, phrase or portion thereof irrespective of the fact that any one or more
sections, subsections, sentences, clauses, phrases, or portions be declared invalid or
unconstitutional.
Section 5. This Ordinance shall become effective thirty (30) days after its
adoption.
Section 6. The Clerk of the Council shall certify the adoption of this ordinance
and shall cause the same to be published as required by law.
ADOPTED this _______ day of ___________, 2022.
_________________________
Vicente Sarmiento
Mayor
APPROVED AS TO FORM:
Sonia R. Carvalho, City Attorney
By:_________________________
John M. Funk
Sr. Assistant City Attorney
AYES: Councilmembers ______________________________________
NOES: Councilmembers _______________________________________
ABSTAIN: Councilmembers _______________________________________
NOT PRESENT: Councilmembers _______________________________________
Ordinance No. NS-XXX
Page 4 of 4
CERTIFICATE OF ATTESTATION AND ORIGINALITY
I, Daisy Gomez, Clerk of the Council, do hereby attest to and certify the attached Ordinance No.
NS-____________ to be the original ordinance adopted by the City Council of the City of Santa
Ana on _______________, and that said ordinance was published in accordance with the Charter
of the City of Santa Ana.
Date: ________________ ____________________________________
Clerk of the Council
City of Santa Ana
Voting, Recusal, and Abstentions
City Manager’s Office
March 1, 2022
Slide 1
City Council Policy on Voting,
Recusal for Conflicts, and
Prohibiting Abstentions
Voting, Recusal, and Abstentions
City Manager’s Office
March 1, 2022
Slide 2
Background
Voting, Recusal, and Abstentions
City Manager’s Office
March 1, 2022
Slide 3
Timeline
May 5, 2020: at the request of Mayor Pro Tem
Bacerra and Councilmember Penaloza, the City
Council discussed and considered directing the City
Manager to direct staff to prepare a policy
regarding abstentions on votes on items on City
Council meeting agendas.
The City Council directed staff to research state law
and current existing policy on City Council
participation, and to bring back a policy to a future
meeting for the City Council's consideration.
Voting, Recusal, and Abstentions
City Manager’s Office
March 1, 2022
Slide 4
Existing Policy
Section 2-105 of the Municipal Code provides as
follows:
No member of the council shall abstain from any vote unless
disqualified, and no disqualified member shall vote. Any
disqualified member shall openly state to the presiding officer the
fact and nature of such disqualification and shall not be subject
to further inquiry. Where no clearly disqualifying conflict of
interest appears, the matter of disqualification may, at the
request of the member affected, be decided by the other
members of the council. A member disqualified by conflict of
interest shall request and be granted permission by the presiding
officer to absent himself from the room where the council is
meeting during debate and vote on the matter. Any member
having a remote interest in any matter shall divulge the same to
the council before voting.
Voting, Recusal, and Abstentions
City Manager’s Office
March 1, 2022
Slide 5
Proposed Ordinance
Voting, Recusal, and Abstentions
City Manager’s Office
March 1, 2022
Slide 6
Requires declaration of the result of votes taken.
References, per the City Charter, that any agenda item requiring a vote shall be passed, adopted, or become
effective unless it receives the affirmative vote of a majority of the full membership of the City Council.
Provides that no member of the City Council shall be permitted to recuse themselves from voting on an
item on the City Council meeting agenda unless:
1) the councilmember is legally disqualified from voting due to a conflict of interest or other legal reason (such as
common law conflict of interest or bias)
2) the councilmember is awaiting advice from the Fair Political Practices Commission (FPPC)
3) the councilmember states that they are awaiting further information or clarification and will recuse themselves out
of an abundance of caution.
Prohibits participation in a vote if one has a conflict and provides that those with a conflict shall leave the
dais during the consideration of the matter, provided, however, that if the matter is being considered on the
Consent Calendar and has not been removed from Consent Calendar, the councilmember may remain on the
dais and disclose the reason.
Clarifies, consistent with state law, that a disqualified councilmember may speak on the matter as a private
citizen.
Provides that if a councilmember abstains on a vote in violation of the prohibition, the abstention shall be
considered concurrence in the motion and the Clerk shall record the councilmember’s abstention as a “
yes” vote.
States that a tie vote means no action has been taken and the item under consideration will not be placed
upon a future agenda, unless by a majority vote of the City or based on new information or changes in
circumstances, in which the City Manager places the item on a future agenda.
Voting, Recusal, and Abstentions
City Manager’s Office
March 1, 2022
Slide 7
Questions?