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HomeMy WebLinkAboutS05-City Attorney CITY OF SAN BERI~lRDINO -REQUEST CSR COUNCIL ACTION From: James F. Penman, City Attorney Subject: Resolution Amending Resolution 6413, Sections 12 and 14. Dept: City Attorney Date: _ December 14 , 1994 Synopsis of Previous Council action: November 7, 1994: Mayor and Council approved implementation of salary survey for Management and Confidential employees to be effective January 1, 1995. Recommended motion: Adopt Resolution i Signature. Diane C. Roth Ext. 5162 Contact person: Phone: Supporting data attached: Ward: FUNDING REQUIREMENTS: Amount: Source: (Acct No 1 (Acct. Description) Finance: Council Notes: 75-02fi2 Agenda Item No CITY OF SAN BERI~QRDINO -REQUEST C.bR COUNCIL ACTION STAFF REPORT On November 7, 1994, the Mayor and Council is closed session approved the implementation of the salary survey for Management and Confidential employees as indicated on the attached Minutes of Closed Session, and directed that Resolution No. 6413 be amended to reflect that action. The City Administrator presented to the City Attorney a resolution which contained provisions which were not reflected in the Council Minutes, as well as provisions which this office believes are not legal. Therefore, the City Attorney's Office presents this alternative resolution which conforms to the legal prior action of the Mayor and Council, implementing the salary range adjustments. 75.0264 ,`` C CLOSED SESSION ACTION 1C Council Member Negrete made a motion, seconded by Council Member Pope-Ludlam, that the comparisons to the County of San Bernardino classification titles contained within the salary survey for management and confidential employees dated July 7, 1994, be - deleted; that the survey be implemented based on Option Two, as set forth on page 18: "nearest dollar, minimum placement, step two"; that implementation shall be effective January 1, 1995; and that all subsequent step increases for management and confidential employees be based on a merit evaluation and not given before January 1996, nor shall any exceed five (5~) percent. The motion carried by the following vote: Ayes: Council Members Negrete, Curlin, Hernandez, Pope-Ludlam, Miller. Nays: Council Member Oberhelman. Absent: Council Member Devlin. END OF CLOSED SESSION 2 11/7/94 . ~ .~i 1 RESOLUTION NO. 2 RESOLUTION OF THE CITY OF SAN BERNARDINO AMENDING RESOLUTION N0. 6413, SECTIONS TWELVE AND FOURTEEN (CONFIDENTIAL AND 3 MANAGEMENT EMPLOYEES), TO CONFORM TO PRIOR COUNCIL ACTION. - 4 WHEREAS, on November 7, 1994, the Mayor and Council voted to b place all management and confidential positions into the salary g ranges recommended by the salary survey prepared by Personnel 7 Concepts, Inc.; and, g WHEREAS, they voted further to place all management and 9 confidential employees into the salary step in the above- 10 referenced range which is closest to, but not less than, their 11 current salary, and not lower than Step 2; 12 BE IT RESOLVED BY THE MAYOR AND COMMON COUNCIL OF THE CITY 13 OF SAN BERNARDINO AS FOLLOWS: 14 SECTION 1. Resolution 6413, Section Twelve, Confidential 15 Employees, is hereby amended as follows: 16 SECTION TWELVE: Confidential Employees: 17 Mary Rangg and Stevs Slassification Title 18 19 (3321) 2201 2311 2427 2548 2675 Secretary (LT) (Council, City Administrator) 20 (3323) 2223 2334 2451 2573 2702 Legal Secretary I (U) 21 ~ (3334) 2348 2466 2589 2719 2854 Computer Operator 23 (3341) 2432 2553 2681 2815 2956 Senior Secretary (i)1 (Administrative Office, 24 Council, Finance, Mayor, Personnel, 25 Planning & Building Services) 26 27 (3343) 2456 2579 2708 2843 2986 Legal Secretary II (LI) 28 (3346) 2493 2618 2749 2886 3030 Deputy City Clerk I (IT) 1 ' `"~ 1 RESOLUTION AMENDING RESOLUTION NO. 6413, SECTIONS TWELVE AND FOURTEEN (CONFIDENTIAL AND MANAGEMENT EMPLOYEES) 2 (3348) 2518 2644 2776 2915 3061 Account Clerk III (Payroll) - 3 Personnel Assistant 4 (3363) 2714 2849 2992 3142 3299 Paralegal I (iJ) 5 (3369) 2796 2936 3083 3237 3399 Executive Secretary (1J) 6 (3370) 2810 2951 3098 3253 3416 Administrative Operations 7 Supervisor M (City Attorney, City Treasurer) 8 Programmer 9 (3376) 2896 3040 3192 3352 3520 Deputy City Clerk II (L>) 10 11 (3421) 3624 3805 3996 4195 4405 Senior Accountant 12 (3422} 3642 3824 4016 4216 4427 Personnel Analyst 13 (3428) 3753 3941 4138 4344 4562 Programmer Analyst 14 (3434) 3867 4060 4263 4476 4700 City Attorney Investigator (U) 15 (3484) 4962 5210 5471 5744 6031 Deputy City Attorney I (U) 16 (3494) 5216 5477 5750 6038 6340 Deputy City Attorney II (LT) 17 (3504) 5483 5757 6045 6347 6664 Deputy City Attorney III (U) 18 19 (3514) 5763 6051 6354 6671 7005 Deputy City Attorney IV (TJ) 20 (3524) 6058 6361 6679 7013 7363 Senior Deputy City Attorney (iJ) 21 22 23 24 25 _ 26 27 28 z ~ - 1 RESOLUTION AMENDING RESOLUTION NO. 6413, SECTIONS TWELVE AND FOURTEEN (CONFIDENTIAL AND MANAGEMENT EMPLOYEES) 2 3 SECTION 2. Resolution 6413, Section Fourteen, Management 4 Employees, is hereby amended as follows: 5 6 SECTION FOURTEEN: Management Employees 7 Shy RanEe and Steos Classification Title 8 (FLAT) 1000 City Treasurer (U) 9 (4380) 2954 3102 3257 3420 3591 Cultural Affairs Coordinator (U) 10 Administrative Analyst 11 (4400) 3264 3427 3598 3778 3967 Administrative Operations 12 Supervisor II 13 3414 3584 3763 3952 4149 Division Chief - SBETA (U) _ Assistant Director/Division 14 Chief (JTPA)(U) 15 (4410) 3431 3602 3782 3971 4170 Project Coordinator (in 16 Administrative Assistant to the City Administrator (U) 17 (4417) 3553 3730 3917 4113 4318 Cemetery Superintendent (IJ) 18 19 (4418) 3570 3749 3936 4133 4340 Supervising Librarian 20 (4420) 3606 3786 3976 4175 4383 Business Registration Supervisor (U) 2l (4422) 3642 3824 4016 4216 4427 Affirmative Action Officer (U) 22 ~ (4440) 3984 4184 4393 4612 4843 Assistant to the Mayor (U) Disaster Preparedness 24 Coordinator (U) 25 (4441) 4004 4204 4415 4635 4867 Plan Check Engineer 26 (4444) 4065 4268 4481 4705 4941 Purchasing Manager (U) 27 28 (4448) 4147 4354 4572 4800 5040 Assistant City Librarian (in 3 1 RESOLUTION AMENDING RESOLUTION NO. 6413, SECTIONS TWELVE AND FOURTEEN (CONFIDENTIAL AND MANAGEMENT EMPLOYEES) 2 3 (4459) 4380 4599 4829 5071 5324 Fleet Manager (U) 4 (4460) 4402 4622 4854 5096 5351 Cable Television Manager (U) 5 Director of Animal Control (U) Executive Assistant to the g Council (U) Executive Assistant to the 7 Mayor (U) 8 (4466) 4536 4763 SOOT 5251 5514 Principal Planner 9 (4467) 4559 4787 5026 5277 5541 Superintendent of Parks (U) 10 Superintendent of Recreation (1J) 11 Director of Risk Management 12 13 (4472) 4674 4907 5153 5411 5681 Facilities Manager (U) Superintendent of 14 Sanitation (U) 15 (4473) 4697 4932 5179 5438 5704 Assistant to the City 16 Administrator (U) 17 (4479) 4840 5082 5336 5603 5883 Senior Civil Engineer 18 (4488) 5058 5311 5577 5856 6149 City Clerk (U) 19 (4489) 5087 5342 5609 5889 6184 Executive Director (Federal 20 Programs) (U) Traffic Engineer (tJ) 21 22 (4494) 5216 5477 5750 6038 6340 Civil Service Board Chief Examiner (ln 23 Assistant Director of Public Services (U) 24 25 (4509) 5621 5902 6197 6507 6832 Director of Management Information Services (U) 26 27 28 4 C ~ 1 RESOLUTION AMENDING RESOLUTION NO. 6413, SECTIONS TWELVE AND FOURTEEN (CONFIDENTIAL AND MANAGEMENT EMPLOYEES) 2 3 (4511)_ 5677 5961 6259 6572 6901 Assistant Director of _ Planning and Building 4 Services (i)) 5 (4517) 5850 6142 6449 6772 7111 Assistant City Engineer 6 (4523) 6028 6329 6645 6978 7327 City Librarian (U) 7 8 (4524) 6058 6361 6679 7013 7363 Director of Personnel (U) Director of Pazks, 9 Recreation & Community Services (U) 10 Director of Public Services (U) 11 (4532) 6300 6615 6946 7293 7658 City Attorney (iT) 12 (4541) 6594 6923 7270 7633 8015 Director of Planning & 13 Building Services ([n 14 (4543) 6660 6993 7342 7710 8095 Director of Finance ([J) 15 (4544) 6693 7028 7379 7748 8136 Assistant City Attorney (LJ) 16 (4556) 7106 7461 7834 8226 8637 Director of Public Works/City 17 Engineer (iJ) 18 (4558) 7173 7532 7909 8304 8719 City Administrator (iJ) 19 (4560) 7249 7612 7992 8392 8811 Assistant City Administrator 20 ~ 21 (4564) 7395 7765 8153 8561 8989 Senior Assistant City Attorney ~ 23 24 25 26 27 28 5 1 RESOLUTION AMENDING RESOLUTION NO. 6413, SECTIONS TWELVE AND FOURTEEN (CONFIDENTIAL AND MANAGEMENT EMPLOYEES) 2 $ SECTION 3. The amendments to Resolution 6413 contained 4 herein shall be effective on January 1, 1995. 5 I HEREBY CERTIFY that the foregoing resolution was duly g adopted by the Mayor and Common Council of the City of 7 San Bernardino at a meeting thereof, held on the $ day of 1994, by the following vote, to wit: 9 Council Members: AYES NAYS ABSTAIN ABSENT 10 NEGRETE 11 CURLIN 12 HERNANDEZ 13 OBERHELMAN 14 DEVLIN 15 POPE-LUDLAM 16 MILLER 17 1$ City Clerk 19 The foregoing resolution is hereby approved this day of 1994. 20 21 Tom Minor, Mayor 22 City of San Bernardino 23 Approved as to form and legal content: 24 JAMES F. PENMAN, 25 City Attorney 26 ~ $y: ~ w 27 28 1 6 r C I T Y O F S A N B E R N A R D I N O INTEROFFICE MEMORANDUM TO: J~4MES F. PENMAN, City Attorney FROM: DIANE CATRAN ROTH, Deputy City Attorney DATE: December 14, 1994 RE: Resolution Implementing Management and Confidential Salary Adjustments Attached is a copy of the proposed resolution "implementing" the management and confidential employees' salary adjustments, and a copy of the minutes of the closed session action. The way it is being implemented, the salary ranges for each position recommended by the survey are being adopted, but the individuals occupying the positions are being downgraded to the lowest step (above Step 1) which does not result in a decrease in salary. The proposed resolution amends the salary resolution (NO. 6413), not only to amend the salary ranges, but also to amend the rules by which salaries are advanced from step to step for management and confidential employees. There are several legal problems with this resolution, as well as many inequities. 1. The resolution does not accurately reflect the Council's action as reported in the minutes of the closed session. (Our office was excluded from closed session when this was discussed so we do not know whether all of these issues were addressed or voted upon, but the minutes certainly do not reflect that all of these actions were taken.) 2. The City has a system of five 5$ salary steps. This resolution allows for salary increases of from 18 to 58, depending upon the employee's evaluation. (Several managers have told me that Shauna told them that employees would have to "walk on water" to receive a full step advancement.) This completely disposes of the step system for management and confidential employees. This was not part of the original proposal that was presented to SBCMA, and it does not appear in the minutes of Council action. 3. This changes everyone's anniversary date to January 1. That means that people who are not now at the top step of their range whose anniversary dates are in February or March, for example, will now have to wait almost an extra year for the raise they were scheduled for. Rather than receiving the 5~ they expect in February, they m~ get 18 eleven months later. These people would effectively get no raises. (The City Administrator is proposing that the people with anniversary dates in January get their step increase in January, 1995, and then be placed in their new step on this new schedule. Peggy Ducey has told me that there S-5 , izly~9~ James F. Penman, City Attorney Re: Resolution Implementing Management and Confidential Salarp Adjustments December 14, 1944 Page 2 are three people in that situation.) This was not part of the proposal presented to the members of SBCMA. 4. It prohibits any other merit increases prior to January, 1996. (This is stated in the minutes of Council action.) There are many employees effectively getting no raises. (There are several employees who have been topped out for years getting $2 to $5 per month increases. Although they may have been topped out for some time and are now being moved to a lower step which will allow for advancement, their department heads will not be permitted to give them any merit increases for a year.) The SBCMA members did not have the figures when this proposal was presented, and did not realize how inequitable it was. (This is partly because when the Council voted on this, they removed the County from the survey as a comparable agency, which completely changed the results.) Unfortunately -- and purely by chance -- many of the employees who are getting the smallest raises are the lower paid employees, such as secretaries, clerks, and personnel analysts. I wonder if the Council would have approved this scheme had they been fully aware of how inequitably it would affect employees. For example: Position ~ Below ~ Increase $ Increase Market eff. 1/95 eff. 1/95 Exec.Asst. to Council 9.9$ 4.28 $ 205 Exec. Sec'y to Council 5.18 0,18 3 Director of Finance 11.08 5.7$ 380 Sr. Accountant 4.1$ 0.18 5 Director of Personnel 8.88 2.68 181 Personnel Analyst 4.18 0.18 4 Sup t. of Sanitation 12.1 1.7$ 87 Assistant to Mayor 12.8 1.8$ 76 5. Several legal issues are raised by the resolution's requirement that salary step advances for all employees be contingent upon written evaluations: a. The Council does not have jurisdiction to require other elected officials to do written evaluations of their staff. b. The Council does not have jurisdiction to require the elected officials to submit their evaluations of their staff to the Mayor for review. (This resolution even requires the Council itself to submit their staff's evaluations for review by the Mayor. See, p.2, lines 10-11.) James F. Penman, City Attorney Re: Resolution Implementing Managemeat and Confidential Salary Adjustments December 14, 1994 Page 3 c. The Council cannot require the Chief Examiner to be evaluated by the City Administrator, or make his step increases contingent upon City Administrator approval, as he is employed by the Civil Service Board. d. Under the Charter department heads function under the general supervision of the Mayor. The requirement that department heads be evaluated by the City Administrator is an illegal delegation of the Mayor's authority by the Council. e. Doing written evaluations may destroy the at-will status of those employees who currently serve at-will. (At the least, it is inadvisable to do written evaluations, of at-will employees because they can only work to the City's detriment in the event of a termination.) 6. This resolution requires recommendations for salary increases to be submitted by the City Administrator for all department heads except elected officials. This also presents some legal problems: a. Making salary increases for the Civil Service Chief Examiner contingent upon recommendation of the City Administrator is contrary to the Charter. b. This Resolution would continue the practice of department heads recommending step advancements for their employees, except for elected officials, and those must be recommended by the Mayor. However, making step increases for the City Clerk's staff, for example, contingent upon the Mayor's recommendation conflicts with the Charter. c. Making salary increases for department heads contingent upon the recommendation of the City Administrator is an unlawful delegation of the Mayor's general supervisory authority under the Charter. 7. Subsection (f) may violate the California Family and Medical Care Act [Government Code § 12945.2(g)) in cases where the leave of absence was for reasons covered by the Act. (On its face the Act appears to prohibit extending the time for salary advancement if leave is taken pursuant to that section.) 8. we have not explored whether SBCMA is an employee organization under the Meyers-Milias-Brown Act, but I believe that the City's past dealings with SBCMA may make it so de facto. If it is covered, very little of those rule changes were bargained for, ~o ~/ '~'' James F. Penman, City Attorney Re: Resolution Implementing Management and Confidential Salary Adjustments December 14, 1994 Page 4 or even told to the employees prior to the Council's action, and they would all be within the scope of representation. Our office has again been put in a very difficult situation with this resolution. Legal advice is often not sought when the ideas are being proposed, and we do not see them until the Council is about to vote upon them. In this case a resolution was sent to us for signature to memorialize an action the Council has already allegedly taken. We were not consulted about these proposals. In fact, we were specifically excluded from the formulation of this plan and the closed session where it was discussed, allegedly because we have a conflict of interest. (However, all confidential employees have the same conflict of interest -- that is the definition of a "confidential employee" and the reason we are forbidden by law from negotiating on behalf of other bargaining units. We have no more conflict of interest than Peggy Ducey, Barbara Dillon or Barbara Pachon, who helped to formulate and also benefit by this resolution.) If our office were consulted from the beginning we could work together to find legal means of achieving the desired results. As it stands, there is now on the agenda a resolution with legal problems that could substantially adversely affect the City. IANE CATRAN ROTH Deputy City Attorney G O C I T Y O F S A N B E R~C~~RDD~~~l~ ~IS~F~` INTEROFFICE MEMORA~UPQ,EC 1S P2.47 TO: Mayor and Common Council FROM: James F. Penman, City Attorney DATE: December 15, 1994 RE: Resolution Implementing Management and Confidential Salary Adjustments COPY TO: Rachel Clark, City Clerk; David C. Kennedy, City Treasurer; SBCMA members We have submitted a resolution that will be on the agenda for Monday, December 19, 1994, authorizing the implementation of the salary survey exactly as Administration prepared it but without the extra rules about merit increases, etc. The resolution submitted by this office will permit the raises to be given as planned while allowing the legal problems to be resolved. The problems-we have identified are serious legal concerns and must be resolved before the proposed additional rules are approved. Please review the attached memorandum from Diane Roth detailing the problems. Respectfully submitted, ES F. PENMAN City Attorney Attachment JFP/js [Sa18rq.Mem] S-~ C ~ C I T Y O F S A N B E R N A R D I N O INTEROFFICE MEMORANDUM TO: JAMES F. PENMAN, City Attorney FROM: DIANE CATRAN ROTH, Deputy City Attorney DATE: December 14, 1994 RE: Resolution Implementing Management and Confidential Salary Adjustments Attached is a copy of the proposed resolution "implementing" the management and confidential employees' salary adjustments, and a copy of the minutes of the closed session action. The way it is being implemented, the salary ranges for each position recommended by the survey are being adopted, but the individuals occupying the positions are being downgraded to the lowest step (above Step 1) which does not result in a decrease in salary. The proposed resolution amends the salary resolution (No. 6413), not only to amend the salary ranges, but also to amend the rules by which salaries are advanced from step to step for management and confidential employees. There are several legal problems with this resolution, as well as many inequities. 1. The resolution does not accurately reflect the Council's action as reported in the minutes of the closed session. (Our office was excluded from closed session when this was discussed so we do not know whether all of these issues were addressed or voted upon, but the minutes certainly do not reflect that all of these actions were taken.) 2. The City has a system of five 58 salary steps. This resolution allows for salary increases of from 1$ to 58, depending upon the employee's evaluation. (Several managers have told me that Shauna told them that employees would have to "walk on water" to receive a full step advancement.) This completely disposes of the step system for management and confidential employees. This was not part of the original proposal that was presented to SBCMA, and it does not appear in the minutes of Council action. 3. This changes everyone's anniversary date to January 1. That means that people who are not now at the top step of their range whose anniversary dates are in February or March, for example, will now have to wait almost an extra year for the raise they were scheduled for. Rather than receiving the 5$ they expect in February, they may get 1$ eleven months later. These people would effectively get no raises. (The City Administrator is proposing that the people with anniversary dates in January get their step increase in January, 1995, and then be placed in their new step on this new schedule. Peggy Ducey has told me that there James F. Penman, City Attorney Re: Resolution Implementing Management and Confidential Salary Adjustments December 14, 1994 Page 2 are three people in that situation.) This was not part of the proposal presented to the members of SBCMA. 4. It prohibits any other merit increases prior to January, 1996. (This is stated in the minutes of Council action.) There are many employees effectively getting no raises. (There are several employees who have been topped out for years getting $2 to $5 per month increases. Although they may have been topped out for some time and are now being moved to a lower step which will allow for advancement, their department heads will not be permitted to give them any merit increases for a year.) The SBCMA members did not have the figures when this proposal was presented, and did not realize how inequitable it was. (This is partly because when the Council voted on this, they removed the County from the survey as a comparable agency, which completely changed the results.) Unfortunately -- and purely by chance -- many of the employees who are getting the smallest raises are the lower paid employees, such as secretaries, clerks, and personnel analysts. I wonder if the Council would have approved this scheme had they been fully aware of how inequitably it would affect employees. For example: Position $ Below $ Increase $ Increase Market eff. 1/95 eff. 1/95 Exec.Asst. to Council 9.98 4.2$ $ 205 Exec. Sec'y to Council 5.1~ 0.1$ 3 Director of Finance 11.0$ 5.78 380 Sr. Accountant 4.1~ 0.18 5 Director of Personnel 8.8$ 2.6$ 181 Personnel Analyst 4.1$ 0.18 4 Supt. of Sanitation 12.1 1.78 87 Assistant to Mayor 12.8$ 1.8$ 76 5. Several legal issues are raised by the resolution's requirement that salary step advances for all employees be contingent upon written evaluations: a. The Council does not have jurisdiction to require other elected officials to do written evaluations of their staff. b. The Council does not have jurisdiction to require the elected officials to submit their evaluations of their staff to the Mayor for review. (This resolution even requires the Council itself to submit their staff's evaluations for review by the Mayor. See, p.2, lines 10-11.) v James F. Penman, City Attorney Re: Resolution implementing Management and Confidential Salary Adjustments December 14, 1994 Page 3 c. The Council cannot require the Chief Examiner to be _ evaluated by the City Administrator, or make his step increases contingent upon City Administrator approval, as he is employed by the Civil Service Board. d. Under the Charter department heads function under the general supervision of the Mayor. The requirement that department heads be evaluated by the City Administrator is an illegal delegation of the Mayor's authority by the Council. e. Doing written evaluations may destroy the at-will status of those employees who currently serve at-will. (At the least, it is inadvisable to do written evaluations of at-will employees because they can only work to the City's detriment in the event of a termination.) 6. This resolution requires recommendations for salary increases to be submitted by the City Administrator for all department heads except elected officials. This also presents some legal problems: a. Making salary increases for the Civil Service Chief Examiner contingent upon recommendation of the City Administrator is contrary to the Charter. b. This Resolution would continue the practice of department heads recommending step advancements for their employees, except for elected officials, and those must be recommended by the Mayor. However, making step increases for the City Clerk's staff, for example, contingent upon the Mayor's recommendation conflicts with the Charter. c. Making salary increases for department heads contingent upon the recommendation of the City Administrator is an unlawful delegation of the Mayor's general supervisory authority under the Charter. 7. Subsection (f) may violate the California Family and Medical Care Act [Government Code ~ 12945.2(g)] in cases where the leave of absence was for reasons covered by the Act. (on its face the Act appears to prohibit extending the time for salary advancement if leave is taken pursuant to that section.) 8. We have not explored whether SBCMA is an employee organization under the Meyers-Milias-Brown Act, but I believe that the City's past dealings with SBCMA may make it so de facto. if it is covered, very little of those rule changes were bargained for, James F. Penman, City Attorney Re: Resolution Implementing Management and Confidential Salary Adjustments December 14, 1994 Page 4 or even told to the employees prior to the Council's action, and they would all be within the scope of representation. Our office has again been put in a very difficult situation with this resolution. Legal advice is often not sought when the ideas are being proposed, and we do not see them until the Council is about to vote upon them. In this case a resolution was sent to us for signature to memorialize an action the Council has already allegedly taken. We were not consulted about these proposals. In fact, we were specifically excluded from the formulation of this plan and the closed session where it was discussed, allegedly because we have a conflict of interest. (However, all confidential employees have the same conflict of interest -- that is the definition of a "confidential employee" and the reason we are forbidden by law from negotiating on behalf of other bargaining units. We have no more conflict of interest than Peggy Ducey, Barbara Dillon or Barbara Pachon, who helped to formulate and also benefit by this resolution.) If our office were consulted from the beginning we could work together to find legal means of achieving the desired results. As it stands, there is now on the agenda a resolution with legal problems that could substantially adversely affect the City. IANE CATRAN ROTH Deputy City Attorney F C I T Y O F S A N B E R N A R D I N O INTEROFFICE MEMORANDUM TO: Mayor and Common Council FROM: James F. Penman, City Attorney DATE: December 15, 1994 RE: Resolution implementing Management and Confidential Salary Adjustments COPY TO: Rachel Clark, City Clerk; David C. Kennedy, City Treasurer; SBCMA members We have submitted a resolution that will be on the agenda for Monday, December 19, 1994, authorizing the implementation of the salary survey exactly as Administration prepared it but without the extra rules about merit increases, etc. The resolution submitted by this office will permit the raises to be given as planned while allowing the legal problems to be resolved. The problems we have identified are serious legal concerns and must be resolved before the proposed additional rules are approved. Please review the attached memorandum from Diane Roth detailing the problems. Respectfully submitted, I ~ ES F. PENMAN City Attorney Attachment ,TFP/js [Salary•Mem1 7- S-5 j C I T Y O F S A N B E R N A R D I N O INTEROFFICE MEMORANDUM TO: JAMES F. PENMAN, City Attorney FROM: DIANE CATRAN ROTH, Deputy City Attorney DATE: December 14, 1994 RE: Resolution implementing Management and Confidential Salary Adjustments Attached is a copy of the proposed resolution "implementing" the management and confidential employees' salary adjustments, and a copy of the minutes of the closed session action. The way it is being implemented, the salary ranges for each position recommended by the survey are being adopted, but the individuals occupying the positions are being downgraded to the lowest step (above Step 1) which does not result in a decrease in salary. The proposed resolution amends the salary resolution (NO. 6413), not only to amend the salary ranges, but also to amend the rules by which salaries are advanced from step to step for management and confidential employees. There are several legal problems with this resolution, as well as many inequities. 1. The resolution does not accurately reflect the Council's action as reported in the minutes of the closed session. (Our office was excluded from closed session when this was discussed so we do not know whether all of these issues were addressed or voted upon, but the minutes certainly do not reflect that all of these actions were taken.) 2. The City has a system of five 58 salary steps. This resolution allows for salary increases of from 18 to 58, depending upon the employee's evaluation. (Several managers have told me that Shauna told them that employees would have to "walk on water° to receive a full step advancement.) This completely disposes of the step system for management and confidential employees. This was not part of the original proposal that was presented to SBCMA, and it does not appear in the minutes of Council action. 3. This changes everyone's anniversary date to January 1. That means that people who are not now at the top step of their range whose anniversary dates are in February or March, for example, will now have to wait almost an extra year for the raise they were scheduled for. Rather than receiving the 5$ they expect in February, they m~ get 1~ eleven months later. These people would effectively get no raises. (The City Administrator is proposing that the people with anniversary dates in January get their step increase in January, 1995, and then be placed in their new step on this new schedule. Peggy Ducey has told me that there James F. Penman, City Attorney Re: Resolution Implementing Management and Confidential Salary Adjustments December 14, 1994 Page 2 are three people in that situation.) This was not part of the proposal presented to the members of SBCMA. 4. It prohibits any other merit increases prior to January, 1996. (This is stated in the minutes of Council action.) There are many employees effectively getting no raises. (There are several employees who have been topped out for years getting $2 to $5 per month increases. Although they may have been topped out for some time and are now being moved to a lower step which will allow for advancement, their department heads will not be permitted to give them any merit increases for a year.) The SBCMA members did not have the figures when this proposal was presented, and did not realize how inequitable it was. (This is partly because when the Council voted on this, they removed the County from the survey as a comparable agency, which completely changed the results.) Unfortunately -- and purely by chance -- many of the emgloyees who are getting the smallest raises are the lower paid employees, such as secretaries, clerks, and personnel analysts. I wonder if the Council would have approved this scheme had they been fully aware of how inequitably it would affect employees. For example: Position 8 Below 8 Increase $ Increase Market eff. 1/95 eff. 1/95 Exec.Asst. to Council 9.98 4.28 $ 205 Exec. Sec'y to Council 5.18 0.18 3 Director of Finance 11.08 5.78 380 • Sr. Accountant 4.18 0.18 5 Director of Personnel 8.88 2.68 181 Personnel Analyst 4.18 0.18 4 Supt. of Sanitation 12.18 1.78 87 Assistant to Mayor 12.88 1.88 76 5. Several legal issues are raised by the resolution's requirement that salary step advances for all employees be contingent upon written evaluations: a. The Council does not have jurisdiction to require other elected officials to do written evaluations of their staff. b. The Council does not have jurisdiction to require the elected officials to submit their evaluations of their staff to the Mayor for review. (This resolution even requires the Council itself to submit their staff's evaluations for review by the Mayor. See, p.2, lines 10-11.) ' -,~ ^,~ L,. James F. Penman, City Attorney Re: Resolution Implementing Management and Confidential Salary Adjustments December 14, 1994 Page 3 c. The Council cannot require the Chief Examiner to be evaluated by the City Administrator, or make his step increases contingent upon City Administrator approval, as he is employed by the Civil Service Board. d. Under the Charter department heads function under the general supervision of the Mayor. The requirement that department heads be evaluated by the City Administrator is an illegal delegation of the Mayor's authority by the Council. e. Doing written evaluations may destroy the at-will status of those employees who currently serve at-will. (At the least, it is inadvisable to do written evaluations of at-will employees because they can only work to the City's detriment in the event of a termination.) 6. This resolution requires recommendations for salary increases to be submitted by the City Administrator for all department heads except elected officials. This also presents some legal problems: a. Making salary increases for the Civil Service Chief Examiner contingent upon recommendation of the City Administrator is contrary to the Charter. b. This Resolution would continue the practice of department heads recommending step advancements for their employees, except for elected officials, and those must be recommended by the Mayor. However, making step increases for the City Clerk's staff, for example, contingent upon the Mayor's recommendation conflicts with the Charter. c. Making salary increases for department heads contingent upon the recommendation of the City Administrator is an unlawful delegation of the Mayor's general supervisory authority under the Charter. 7. Subsection (f) may violate the California Family and Medical Care Act [Government Code S 12945.2(g)] in cases where the leave of absence was for reasons covered by the Act. (On its face the Act appears to prohibit extending the time for salary advancement if leave is taken pursuant to that section.) 8. We have not explored whether SBCMA is an employee organization under the Meyers-Milias-Brown Act, but I believe that the City's past dealings with SBCMA may make it so de facto. If it is covered, very little of those rule changes were bargained for, James F. Penma~ City Attorney Re: Resolution Implementing Management sad Confidential Salary Adjustments December 14, 1994 Page 4 or even told to the employees prior to the Council's action, and they would all be within the scope of representation. Our office has again been put in a very difficult situation with this resolution. Legal advice is often not sought when the ideas are being proposed, and we do not see them until the Council is about to vote upon them. In this case a resolution was sent to us for signature to memorialize an action the Council has already allegedly taken. We were not consulted about these proposals. in fact, we were specifically excluded from the formulation of this plan and the closed session where it was discussed, allegedly because we have a conflict of interest. (however, all confidential employees have the same conflict of interest -- that is the definition of a "confidential employee" and the reason we are forbidden by law from negotiating on behalf of other bargaining units. we have no more conflict of interest than Peggy Ducey, Barbara Dillon or Barbara Pachon, who helped to formulate and also benefit by this resolution.) If our office were consulted from the beginning we could work together to find legal means of achieving the desired results. As it stands, there is now on the agenda a resolution with legal problems that could substantially adversely affect the City. IANE CATRAN ROT Deputy City Attorney