HomeMy WebLinkAboutItem 39 - Resolution for Ballot Measure for Noncitizen Voting City Attorney Office
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Item # 39
City of Santa Ana
20 Civic Center Plaza, Santa Ana, CA 92701
Staff Report
November 7, 2023
TOPIC: Consider Whether to Adopt a Resolution to Place a Ballot Measure on the Ballot
for the November 5, 2024 Municipal Election Concerning Amending the City Charter to
Permit Voting by Noncitizen Residents in City Municipal Elections
AGENDA TITLE
Consider Whether to Adopt a Resolution Calling and Giving Notice of a General Municipal
Election to be held in the City of Santa Ana on November 5, 2024, Requesting
Consolidation with the Statewide General Election, and Placing a Ballot Measure Before
the Voters Asking Whether to Amend the Santa Ana City Charter to Authorize and
Implement Noncitizen Voting in Municipal Elections
RECOMMENDED ACTION
Approve a Resolution Calling and Giving Notice of a General Municipal Election to be
held in the City of Santa Ana on November 5, 2024 for the Submission of a Ballot Measure
to the Qualified Voters Proposing an Amendment to the Santa Ana City Charter to
Authorize and Implement Noncitizen Voting in Municipal Elections.
RESOLUTION NO. 2023-XXX entitled A RESOLUTION OF THE CITY COUNCIL OF
THE CITY OF SANTA ANA CALLING AND GIVING NOTICE OF A GENERAL
MUNICIPAL ELECTION TO BE HELD IN THE CITY OF SANTA ANA ON NOVEMBER
5, 2024 FOR THE SUBMISSION OF A BALLOT MEASURE TO THE QUALIFIED
VOTERS ASKING IF THE CITY OF SANTA ANA SHOULD PERMIT NONCITIZEN
VOTING IN ALL CITY MUNICIPAL ELECTIONS (includes determination that the
Resolution is not subject to the California Environmental Quality Act (CEQA) pursuant to
sections 15060(c)(2) and 15060(c)(3) of the State CEQA Guidelines because it will not
result in a direct or reasonably foreseeable indirect physical change in the environment
and it is not a “project” as defined in section 15378 of the State CEQA Guidelines)
GOVERNMENT CODE §84308 APPLIES: No
DISCUSSION
In July of 2022, while considering recommendations from a Council Ad Hoc Committee
formed to review and recommend amendments to the City of Santa Ana City Charter, the
Consider Whether to Adopt a Resolution to Place a Ballot Measure on the Ballot for the
November 5, 2024 Municipal Election Concerning Amending the City Charter to Permit
Voting by Noncitizen Residents in City Municipal Elections
November 7, 2023
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3
8
5
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issue of proposing a charter amendment to permit voting by noncitizens in municipal
elections was raised. At that time, the City Attorney advised that although towns in the
states of Maryland and Vermont had implemented similar proposals, the questions posed
presented an issue of first impression in California for a charter city like Santa Ana. The
City Attorney advised that the City and County of San Francisco had adopted noncitizen
voting rights for parents of school-aged children in school board elections and a proposal
in New York City had been struck down. At that time, the City Attorney advised the
Council that it could refer the matter to Council Charter Ad Hoc Committee for further
research and feasibility analysis. Days after this recommendation was made, a trial court
struck down the San Francisco measure.
In August of 2023, the California Court of Appeal decided the case. In James V. Lacy, et
al., v. City and County of San Francisco, et al., California Court of Appeal, First Appellate
District, Case No. A165899, the Court reversed the trial court decision and upheld the
legality of San Francisco’s voting program. However, the First District Court limited its
decision to San Francisco only. The Court stated that: “We decide today solely the issue
before us: the Constitution confers on the City the authority to expand the electorate for
school board elections to include noncitizen parents or guardians of City children.” The
court was careful to explicitly limit the breadth of its decision to San Francisco’s noncitizen
voting program in school board elections. The Court stated that its decision “does not
leave charter cities with limitless authority to determine the electorate for school board
elections or, for that matter, the election of other municipal officials,” since state and
federal constitutional constraints still apply.
Some assert that the Lacy decision authorizes charter cities like Santa Ana to pursue and
implement similar voting programs and others caution that the decision is limited. The
fact is that the law is not clearly settled. The City Council is advised to consider that the
proposal is certain to draw legal scrutiny and the San Francisco Chronicle reported that
the lead plaintiff in the San Francisco case has vowed to sue any other California city that
approves similar legislation. Lacy and the US Justice Foundation are reported to say that
they will file challenges in federal court. Federal litigation can be complicated and
expensive. A challenge of this type would require the City to engage expert outside legal
counsel.
On September 19, 2023, the City Council addressed a request by Councilmembers
Hernandez and Vazquez to: Discuss and Consider Directing the City Manager and the
City Attorney to Prepare for the City Council’s Consideration Resolution Options to Place
the Issue of Noncitizen Voting in City Council and Mayoral Elections on the November
2024 Ballot and Further Discuss and Consider Directing the City Manager to Prepare a
Cost and Implementation Analysis of Establishing Noncitizen Voting. A majority of the
Council provided direction to prepare the documents necessary to proceed with the ballot
measure as an advisory question.
Consider Whether to Adopt a Resolution to Place a Ballot Measure on the Ballot for the
November 5, 2024 Municipal Election Concerning Amending the City Charter to Permit
Voting by Noncitizen Residents in City Municipal Elections
November 7, 2023
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3
8
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On October 17, 2023, the documents were presented to the City Council and further
direction was given to staff to modify the recitals in the Resolution, expand the original
proposal from voting in city council and mayoral elections to all municipal elections,
including elections on referenda, initiative, and ballot questions and prepare the text
necessary to present the matter to the voters as an amendment to the City Charter.
The Resolution before the City Council incorporates Council direction with the exception
of a recital citing racism as the reason for citizen voting eligibility. The Council should
also be aware that certain statements and facts included in the recitals that the Council
directed to be added have not been independently verified.
FISCAL IMPACT
Estimated costs for a City General Municipal Election on November 5, 2024 are $279,085
- $327,742, as noted for the previous Council action calling the election for the submission
of a ballot measure.
The estimated cost to add an additional measure (3000 words and 2 pages) is $8,500.
Sufficient funds to accommodate the 2024 General Municipal Election will be presented
to City Council for consideration during the FY 2024/25 budget approval process.
(Account No. 01107031 62300)
If the measure is approved by the voters and challenged, estimated legal costs could
exceed $500,000. Additional costs to implement the change to Charter Section 1203, if
approved, are unknown at this time.
EXHIBIT(S)
1. Proposed Resolution
Submitted By: Sonia Carvalho, City Attorney
Approved By: Steven A. Mendoza, Acting City Manager
Resolution No. 2023-XXX
Page 1 of 5
RESOLUTION NO. 2023-XXX
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
SANTA ANA CALLING AND GIVING NOTICE OF A
GENERAL MUNICIPAL ELECTION TO BE HELD IN THE
CITY OF SANTA ANA ON NOVEMBER 5, 2024 FOR THE
SUBMISSION OF A BALLOT MEASURE TO THE
QUALIFIED VOTERS ASKING IF THE CITY OF SANTA ANA
SHOULD PERMIT NONCITIZEN VOTING IN ALL CITY
MUNICIPAL ELECTIONS
WHEREAS, noncitizen residents make up 24 percent of Santa Ana’s total
population and about 30 percent of its voting-age population; and
WHEREAS, the City Council acknowledges the importance of the immigrant
community to the city of Santa Ana and recognizes their right to have their voices heard
in local decision-making that directly affects their lives; and
WHEREAS, the City Council believes that giving immigrants a voice in local
elections will encourage greater interest and investment in local issues, ultimately
benefiting the entire community; and
WHEREAS, the City Council previously enacted an ordinance making Santa Ana,
a sanctuary city, to recognize the contributions of its diverse, immigrant population to
ensure they feel safe interacting with local government officials; and
WHEREAS, the City Council has implemented initiatives such as the Immigrant
Legal Defense Fund which allocates funding to legal defense of Santa Ana immigrant
residents who face detention and deportation; and
WHEREAS, a growing multiracial and multigenerational coalition of Santa Ana
residents and community-based organizations have come together with the shared belief
that all residents, regardless of citizenship status should have an equal say in the City’s
municipal elections; and
WHEREAS, the City Council previously enacted an ordinance amending, it’s
municipal code to permit qualified immigrant residents to serve on City Boards,
Commissions and Committees; and
WHEREAS, currently tens of thousands of noncitizen residence and mixed status
families pay taxes yet feel disenfranchised, and do not believe they have representation
in key decisions that impact their lives; and
WHEREAS, local governments in other states have allowed non-citizen residents
to vote in local elections; and
Resolution No. 2023-XXX
Page 2 of 6
WHEREAS, arguments can be made that the California constitution gives charter
cities the power to allow non-citizen residents to vote in local elections; and
WHEREAS, on September 19, 2023, Councilmembers Hernandez and Vazquez
brought forth a councilmember request for consideration of proposing a ballot measure
to the voters regarding noncitizen voting in municipal elections;
WHEREAS, on October 17, 2023, the City Council voted to direct staff to prepare
the ballot measure items to place the ballot mea sure before the voters at the November
5, 2024 election;
WHEREAS, pursuant to California Elections Code section 92 55, the City Council
is authorized to submit this question to the voters at the November 5, 2024 General
Municipal Election; and
WHEREAS, the City Council desires to consolidate the General Municipal Election
for the measure described herein with the Statewide General Election to be held on
November 5, 2024.
BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF SANTA ANA AS
FOLLOWS:
Section 1. The foregoing recitals are true and correct and are hereby
incorporated by reference.
Section 2 Pursuant to the California Elections Code, and any other applicable
requirements of the laws of the State of California relating to charter cities, the City
Council, by majority vote, hereby calls and orders to be held in the City of Santa Ana on
Tuesday, November 5, 2024, a General Municipal Elections for the purpose of submitting
the ballot measure question to the qualified voters of the City of Santa Ana.
Section 3. The California Elections Code directs that the City Council approve the
form of the ballot question to be submitted to the voters and the City of Santa Ana desires,
on its own motion, to submit to the voters a question of whether to permit noncitizens to
vote in all municipal elections at which municipal officers are elected, ballot measures are
considered, and initiatives and referenda are proposed, at the General Municipal Election
to be held on Tuesday, November 5, 2024.
Section 4. The ballot question and full text for the proposed ballot measure shall
be as follows, with identification as determined in accordance with the California Elections
Code:
Resolution No. 2023-XXX
Page 3 of 6
MEASURE #___
PROPOSED AMENDMENT TO SECTION 1203
OF THE SANTA ANA CITY CHARTER
Shall the City of Santa Ana City Charter be amended to allow
City residents who are not citizens of the United States to vote in all
City of Santa Ana municipal elections at which municipal officers are
elected, ballot measures are considered, and initiatives and
referenda are proposed, in accordance with ordinances, policies, and
regulations to be adopted by the City Council in order to implement
the charter amendment prior to the November 2026 general
municipal election?
Yes
No
Full Text of the City Charter Amendment (text to be added, if approved, is underlined):
Sec. 1203. – Manner of Elections and Voting.
Unless otherwise provided by ordinance, all elections shall be held in accordance with
the provisions of the Elections Code of the State of California, as the same now exist or
may hereafter be amended, for the holding of elections in general law cities, insofar as
the same are not in conflict with this charter or any ordinance adopted in accordance with
this charter.
The City Council shall adopt an ordinance and additional policies and regulations, as
needed, authorizing any person who has established residency in the City and who is not
otherwise disqualified from voting under Sections 2 and 4 of Article II of the California
Constitution or any implementing State statute or City ordinance or resolution, to vote in
all municipal elections regardless of whether the person is a United States citizen. The
City Council shall adopt such policies, regulations, and ordinances implementing this
Section 1203 so that noncitizens may participate in elections on or prior to the general
municipal election to be held in November of 2026.
Section 5. The question to be submitted to the voters is set forth above and other
implementing actions may need to be taken by the voters and the City Council should the
voters approve the measure.
Section 6. If the ballot measure receives a majority of the votes cast on it at the
election, the question shall be approved.
Section 7. The City Clerk, in coordination with the Orange County Registrar of
Voters, is authorized, instructed and directed to procure and furnish any and all official
ballots, notices, printed matter and all supplies, equipment and paraphernalia that may
Resolution No. 2023-XXX
Page 4 of 6
be necessary in order to properly and lawfully conduct the election. The ballots to be
used at the election shall be in form and content as required by law.
Section 8. The City Council consents to the consolidation of the election on this
Measure with all other elections being held in the same territory on November 5, 2024,
and to hold and conduct the consolidated election in the manner prescribed in Election
Code Section 10418. In accordance with Section 10403 of the Elections Code, the
Board of Supervisors of Orange County is hereby requested to consent to consolidation
of the election on this Measure with the Statewide General Election and all other
elections being held in the same territory on November 5, 2024, and to having the
Registrar of Voters render such election services to the City of Santa Ana as may be
requested by the City Clerk of said City, the County of Orange to be reimbursed in full
for such services as are performed.
Section 9. The election services requested by the City of the County Registrar
of Voters, or such other official as may be appropriate and which office r is hereby
authorized and directed to perform, if said Board of Supervisors consents, include: the
preparation, printing, and mailing of sample ballots and voter information guides; the
establishment or appointment of precincts, voting centers, and election officers; opening
and closing of voting centers, and making such publications as are required by law in
connection therewith; the furnishing of ballots, voting booths, and other necessary
supplies or materials for voting centers; the canvassing of the returns of the election and
the furnishing of the results of such canvassing to the City Clerk; and the performance of
such other election services as may be requested by the City Clerk.
Section 10. The precincts, ballot drop box locations and hours of ope rations, vote
center locations and hours of operations, vote -by-mail procedures and timing, and
election officers, and all other persons and procedures for the General Municipal Election
shall be the same as those utilized by the County of Orange.
Section 11. All ballots shall be tallied at a central counting place and not at the
precincts. Said central counting place shall be at a County center as designated by the
Registrar of Voters.
Section 12. The City Clerk is hereby directed to transmit a copy of the Measure
set forth in Section 4 above to the City Attorney, who shall prepare an impartial analysis
of the Measure in accordance with Section 9280 of the Elections Code not to exceed 500
words in length. The impartial analysis shall show the effect of the Measure on existing
law and the operation of the Measure. It shall also include a statement indicating whether
the Measure was placed on the ballot by a petition signed by the requisite number of
voters or by the City Council. In the event the entire text of the Measure is not printed on
the ballot, or in the voter information portion of the sample ballot, there shall be printed
immediately below the impartial analysis, in no less than 10 -font bold type, the following:
“The above statement is an impartial analysis of Ordinance or Measure ____. If
you desire a copy of the ordinance or measure, please call the election official’s
Resolution No. 2023-XXX
Page 5 of 6
office at (714) 647-6520 and a copy will be mailed at no cost to you.” The impartial
analysis shall be filed no later than the deadline for direct arguments.
Section 13. All persons qualified to vote at municipal elections in the City on the
day of election herein provided shall be qualified to vote on the Measure hereby submitted
at the General Municipal Election.
Section 14. In all particulars not recited in the Resolution, the election shall be
held and conducted as provided by law for holding general municipal elections in the City.
Section 15. Notice of the time and place of holding the election is hereby given,
and the City Clerk is authorized, instructed, and directed to give further or additional notice
of the election in the time, form, and manner as required by law.
Section 16. The City Clerk shall receive the canvass as it pertains to the election
and shall certify the results to the City Council, as required by law.
Section 17. Pursuant to California Elections Code Section 9295, this Resolution
and the included Measure will be available for public examination for no fewer than ten
(10) calendar days prior to being submitted for printing in the voter information guide.
Section 18. The City Council finds and determines that this Resolution is not
subject to the California Environmental Quality Act (CEQA) pursuant to sections
15060(c)(2) and 15060(c)(3) of the State CEQA Guidelines because it will not result in a
direct or reasonably foreseeable indirect physical change in the environment, as there is
no possibility it will have a significant effect on the environment and it is not a “project,”
as defined in section 15378 of the State CEQA Guidelin es. Furthermore, the Resolution
falls within the “common sense” CEQA exemption set forth in CEQA Guidelines section
15061(b)(3), excluding projects where “it can be seen with certainty that there is no
possibility that the activity in question may have a significant effect on the environment.”
Section 19. If any section, subsection, sentence, clause, phrase or provision of
this Resolution or the application thereof to any person or circumstances is held invalid
or unconstitutional by any court of competent jurisdiction, such invalidity or
unconstitutionality shall not affect the validity of any other provision or applications, and
to this end the provisions of this Resolution are declared to be severable. The City Cou ncil
hereby declares that it would have passed this Resolution and each section, subsection,
sentence, clause, phrase or provision thereof, irrespective of the fact that any one or more
sections, subsections, sentences, clauses, phrases or provisions there of be declared
invalid or unconstitutional.
Section 20. This Resolution shall take effect immediately upon its adoption by a
majority of the City Council.
Section 21. The City Clerk is hereby directed to certify to the passage and adoption
of this Resolution and to file a certified copy of this Resolution with the Orange County
Resolution No. 2023-XXX
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Board of Supervisors and the Registrar of Voters of Orange County at least eighty-eight
(88) days before the date of the election.
ADOPTED this ____ day of November, 2023.
Valerie Amezcua
Mayor
APPROVED AS TO FORM:
Sonia R. Carvalho
City Attorney
By:
Laura A. Rossini
Chief Assistant City Attorney
AYES: Councilmembers
NOES: Councilmembers
ABSTAIN: Councilmembers
NOT PRESENT: Councilmembers
CERTIFICATE OF ATTESTATION AND ORIGINALITY
I, Jennifer L. Hall, City Clerk, do hereby attest to and certify the attached Resolution No.
2023 -XXX to be the original resolution adopted by the City Council of the City of Santa
Ana on _____________________, 2023.
Date:
City Clerk
City of Santa Ana