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ORDINANCE NO.
AN ORDINANCE OF THE CITY OF SAN BERNARDINO REPEALING
CHAPTER 2.20 OF THE SAN BERNARDINO MUNICIPAL CODE RELATING TO CITY
ATTORNEY APPROVAL TO RETAIN OUTSIDE SPECIAL COUNSEL SERVICES.
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THE MAYOR AND COMMON COUNCIL OF THE CITY OF SAN BERNARDINO
DO ORDAIN AS FOLLOWS:
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SECTION 1. Chapter 2.20 of the San Bernardino Municipal Code is hereby repealed in
its entirety.
I HEREBY CERTIFY that the foregoing Ordinance was duly adopted by the Mayor and
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7 Common Council of the City of San Bernardino at a
meeting thereof, held on the
8 _ day of
,2001, by the following vote, to wit:
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COUNCIL MEMBERS:
ESTRADA
LIEN
MCGINNIS
SCHNETZ
SUAREZ
ANDERSON
MC CAMMACK
ABSTAIN ABSENT
AYES
NAYS
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City Clerk
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The foregoing Ordinance is hereby approved this _ day of
,2001.
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JUDITH VALLES, Mayor
City of San Bernardino
Approved as to form
and legal content:
JAMES F. PENMAN
City Attorney
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the officer or board appointing him, and when an appointment is made to fill a vacancy in
an unexpired term, the person appointed shall, if it be an appointive office, hold for the
unexpired term and if for an elective office until the next succeeding general municipal
election, at which time the office shall be filled for the balance of the term by an election.
(As amended by special election held November 4, 1924.)
(Section 231 repealed by election held February 6, 1973)
(Section 232 repealed by election held February 6, 1973)
(Section 233 repealed by election held March 6, 1979)
Section 234. Reimbursement For Expenses. That elective officers shall be
entitled to receive reimbursement for their necessary expenses while engaged on
Municipal business, including mileage in the City of San Bernardino, such expenses not
to exceed the expenses authorized for other City employees or officers.
(a) The Mayor and Common Council shall, with all due diligence, contract with the
Board of Administration of the State Employees Retirement System, and do all things
necessary to provide for the participation by the City of San Bernardino and the
employees thereof, in the State Employees Retirement System, with full credit being given
to the employees of said City for prior service rendered.
(b) That any contract so entered into by said Mayor and Common Council with the
Board of Administration of the State Employees Retirement System shall only be
terminated by an ordinance adopted by a majority vote of the electorate of the City of San
Bernardino. (As amended by elections held May 16, 1944, March 19, 1945 and March 7, 1989)
Section 235. Qualification of officers. The City Clerk and City Treasurer shall
have been qualified electors and residents of the City for a period of at least thirty (30)
consecutive days prior to their appointment or filing of their nomination papers for election
to office. (As amended by elections held February 6, 1973, and November 2, 1976)
(Section 236 repealed by election held February 4, 1969)
(Section 237 repealed by election held February 4, 1969)
Section 238. Power to Reject Bids and Readvertise. In all cases where
advertising is required for sealed proposals under Section 140 of this Charter, the Mayor
and Common Council, or any board or officer making such advertisement, shall have
power to reject any or all bids and readvertise in their discretion. (Section 238, Subsection
(a) repealed by election held February 6, 1973)
(Section 239 repealed by election held February 6, 1973)
Section 240. Taking or Damaging Private Property. Whenever it becomes
necessary for the City to take or damage private property for public use, the Mayor and
Common Council may direct proceedings to be taken therefor under the provisions of the
Code of Civil Procedure of this State to procure the same. (City Attorney Opinion No. 91-16)
. Section 241. Employment of Legal Counsel. The Mayor and Common Council
shall have power and authority to employ and engage such legal counsel and services
[Rev. January 23, 1998]
C - 33
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and other assistants, as may be necessary and proper for the interest and benefit of the
City and the inhabitants thereof. (City Attorney Opinion No. 89-11; City Attorney Opinion No.
87-59; City Attorney Opinion No. 87-36)
Section 242. Qualifications of City Employees and Appointment. The Mayor
and Common Council may prescribe the number, qualification and compensation of the
deputies, clerks, assistants, employees and attaches of the City Attorney, City Treasurer
and City Clerk. All deputies, clerks, assistants, attaches and employees of the City
Attomey, City Clerk and City Treasurer shall be appointed by the respective officers with
the consent and approval of the Mayor and Common Council, and shall hold office at the
pleasure of the officers appointing them. (As amended by special election held November 4,
1924.) (Scott v. Common Council (1996) 44 Ca/.App.4th 684, 687-688, 696; City Attorney Opinion
No. 93-19)
(Section 243 repealed by election held November 5. 1974)
Section 244. When Charter Takes Effect This Charter shall take effect from and
after its approval by the Legislature of the State of California.
Section 246. Civil Service Board - Appointment. A Civil Service Board is hereby
created which shall consist of five members who shall be qualified electors of the City and
appointed as hereinafter provided. The three members in office on the first Monday in
May, 1959, shall continue to serve for the remainder of their respective terms. On July 1,
1958, or as soon thereafter as this Charter amendment becomes effective, the Mayor,
with the consent and approval of the Council, shall appoint one member to serve until the
first Monday of May, 1959, and one to serve until the first Monday of May, 1961, and
thereafter, by rotation in the following manner: Two members shall be appointed on the
first Monday of May, 1959, two on the first Monday of May, 1961, and one on the first
Monday of May, 1963, each for a term ofsix years. On the first Monday of May, 1965, and
every odd numbered year thereafter, the Mayor with the consent and approval of the
Council, shall appoint the same number of members ofthe Civil Service Board for a term
of six years as the number of members whose term of office expires at that time, who
shall take office the first Monday of May of said year, or as soon thereafter as appointed
and qualified. Members of the Board shall not hold any other public office. (As added by
special election held November 4, 1924 and amended by special election held June 3, 1958.) (City
Attorney Opinion No. 95-12; City Attorney Opinion No. 93-7.; City Attorney Opinion No. 93-7; City
Attorney Opinion No. 91-8; City Attorney Opinion No. 91-4)
Section 247. Civil Service to Organize and Appoint Secretary. Immediately
after appointment and qualification the Board shall organize by electing one of its
members chairman. The Board shall appoint a Chief Examiner who shall also act as
Secretary of the Board. The Board may appoint such subordinates as the City Council
may, by ordinance, prescribe. (As added by special election held November 4, 1924.) (City
Attorney Opinion No. 95-12; City Attorney Opinion No 91-8; City Attorney Opinion No. 88-9.)
Section 248. Classified and Unclassified Civil Service. The Civil Service of the
City of San Bernardino is hereby divided into the unclassified and the classified service:
(1) The unclassified service shall include:
(a)
(b)
All officers elected by the people;
All officers appointed for a definite term;
[Rev. January 23, 1998]
C - 34
Recreation and Community Services Department during the process of its
preparation and make recommendations with respect thereto.
B The Commission shall advise the Mayor and Common Council on:
1. Community needs and problems for the purpose of providing a basis
for establishing departmental priorities, goals and objectives;
2 Programs and plans designed to meet stated goals and objectives in,
but not limited to, the following areas of concern: youth affairs, senior
affairs, consumer affairs, discrimination in housing and employment,
and community service centers;
3 Coordinating on a City-wide basis the work of those community
agencies and organizations engaged in the providing of human
services;
4. Evaluation of all community agencies and organizations receiving
City funds for the purpose of providing human services.
(Ord MC-313, 11-7-83: Ord. MC-299, 8-15-83: Ord. 334793,1973)
2.18.040 No compensation - Meetings.
Each member shall serve without compensation. Immediately after
appointment and qualification, the Commission shall organize by electing from
among its membership a chairman and a secretary. Regular meetings shall be held
at least once a month. Five members shall constitute a quorum, but a lesser number
of members may adjourn from time to time. (Ord. MC-299, 8-15-83; Ord. 334794,1973.)
Sections:
2.20.010
2.20.020
2.20.030
2.20.040
2.20.050
2.20.060
2.20.070
2.20.080
2.20.010 Definitions.
Chapter 2.20
SPECIAL COUNSEL SERVICES
Definitions.
Coordinated legal services.
Requests for legal services.
Retaining special counsel.
Scope of legal services.
Legal services procedures.
Outside counsel.
Confidentiality of matters related to prospective
or pending litigation.
A. "City" shall mean the City of San Bernardino, California.
B. "City Attorney" shall mean the City Attorney or, in his or her absence, the
Assistant City Attorney, or in the latter's absence, the highest ranking Deputy
[Rev .July), 2000J
2-19
City Attorney available.
C "Council" shall mean the Mayor and Common Council as that term is defined
in Section 40 of the San Bernardino City Charter.
D. "Special counsel" shall mean an attorney at law licensed to practice in the
State of California who specializes in a field such as bond financing, workers
compensation liability, public and property damage liability, water matters or
other specialized field.
(Ord MC-374,6-4-84.)
2.20.020 Coordinated legal services.
The performance of all municipal legal services shall be coordinated,
centralized and processed through the City Attorney, subject to the provisions ofthis
Chapter. Any summons or claim served upon the Mayor or City Clerk or other City
officer shall be transmitted to the City Attorney immediately upon receipt. (MC-374,
6-4-84) (City Attorney Opinion No. 89-11; City Attorney Opinion No. 87-59)
2.20.030 Requests for legal services.
Requests for the performance of legal services for the City or any City officer
or department thereof shall be directed to the City Attorney. Requests for legal
services other than oral advice shall be made in writing. (Ord. MC-374, 6-4-84.) (City
Attorney Opinion No. 87-59)
2.20.040 Retaining special counsel.
Special counsel shall be retained by the Council pursuant to Charter Section
241 subject to the recommendation of the City Attorney that such counsel is
necessary in instances when legal specialization not possessed by the City Attorney
is required or when the City Attorney is unable or disqualified from performing such
legal services. Special counsel shall not be retained when the City Attorney is willing
and able to perform the legal services as a part of the ordinary professional functions
of his or her office. The City Attorney shall advise the Mayor and Common Council
as to the experience and qualifications of attorneys considered for retention as
special counsel. (Ord. MC-374, 6-4-84) (City Attorney Opinion No. 89-11; City Attorney
Opinion No. 87-59)
2.20.050 Scope of legal services.
The scope and cost of the legal services to be performed by special counsel
shall be authorized and delineated by the Council, and the scope of such services
shall not be modified except when relevant to such authorization, as determined by
the City Attorney. (Ord. MC-374, 6-4-84)
2.20.060 Legal services procedures.
The product of legal services performed by special counsel shall initially be
[Rev. July 5. 2000]
2-20
presented to the City Attorney for review and coordination before final submission
to prevent duplication and to enhance the quality of legal services. Special counsel
shall consult with the City Attorney concerning the legal services prior to completion.
The City Attorney and special counsel shall be named as co-counsel in any court
case or legal proceeding instituted. Any request or directions made to special
counsel from any City officer shall be coordinated through the City Attorney. The
City Attorney shall be briefed and informed prior to legal services being presented
to or performed on behalf of any City official or officer. (Ord. MC-374, 6-4-84)
2.20.070 Outside counsel.
Any City officer desiring legal services concerning City business from legal
counsel other than the City Attorney shall first inform the City Attorney of such
intended request for outside legal services to determine whether the City Attorney
is willing and able to provide such services. No City officer shall be authorized to
obligate the City for payment of services of outside counsel without the express
approval of the Council. No City officer shall utilize outside legal services concerning
City business without the approval of the City Attorney or Council; provided,
however, that nothing herein shall preclude any City officer from obtaining outside
legal services at his or her own expense concerning the personal or public rights,
duties, privileges or benefits of such officer as an individual or as an office holder,
or from obtaining at his or her own expense legal services of a private nature. (Ord.
MC-385, 6-18-84; Ord. MC-374, 6-4-84.) (City Attorney Opinion No. 89-11; City Attorney
Opinion No. 87-59; City Attorney Opinion No. 87-36)
2.20.080 Confidentiality of matters related to prospective or pending litigation.
The Council at a public meeting may authorize and appoint the Mayor or not
more than three members from the Council to act as its representative or
representatives, subject to coordination with the City Attorney, in communicating or
conferring with special counsel retained in special matters or court actions. Unless
authorized or appointed by the Council to communicate or confer with special
counsel, neither the Mayor nor any member of the Council shall confer with or give
any direction to special counsel concerning the case or court action, unless done in
a closed session held during meetings of the Council. This provision shall not limit
the right of the Mayor or any Council member to obtain information concerning any
such matter or court action from the City Attorney.
The Council shall limit discussion of the City's position in litigation, except as
to matters which are of public record, to closed sessions and shall keep attorney-
client communications and discussions at such closed sessions private and
confidential. (MC-374, 6-4-84.)
Chapter 2.22
PLANNING COMMISSION'
5 For statutory provisions on City planning commissions, see Gov. Code 965150; for
provision on City planning, see Gov. Code 965100 et seg.
[Rev. July 5. 2000]
2-21
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CITY OF S~ BERNARDINO
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300 NORTH "0" STREET. SAN BERNAROINO.CALlFORNIA 92418
JAMES F. PENMAN
CITY ATTORNEY
(714) 384-6355
June 30, 1987
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Opn No. 87-36
10.37 700.1
Honorable Mayor and Common Council
Re: City Council, Power to Retain Counsel
QUESTION
Can the Mayor and Common Council retain outside counsel? If
the answer is in the affirmative, must the Mayor and Common
Council first obtain the approval of the City Attorney before
retaining outside counsel?
ANALYSIS
The question centers on the interpretation of two Charter
sections which seem to conflict. Charter Section 55(d)
provides:
"The City Attorney shall be the chief
legal officer of the City; he shall represent
and advise the Mayor and Common Council and
all Citv officers in all matters of law
pertaining to their offices; he shall represent
and appear for the City in all legal actions
brought by or against the City . . . "
(Emphasis added)
Charter Section 241 authorizes the Mayor and Common Council to
employ legal counsel:
"Employment of legal counsel. The Mayor
and Common Council shall have the power and
authority to employ and engage such legal counsel
and services and other assistants, as may be
necessary and proper for the interest and benefit
of the City and the inhabitants thereof."
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Mayor and Common Council
June 30, 1987
Page Two
The courts characterize the seeming conflict between Sections
55(d) and 241 as a question of a public agency's authority to
contract for special services where a regular officer or
employee of the agency is obligated by law to perform such
special services. The rule is:
"Two sections of the Government Code . . .
expressly authorize a general law city, and other
public agencies, to employ and compensate personnel
for the performance of 'special services.' . . .
a public bodY mav not validly do this where a
reqular officer or employee thereof is obliqated
bv law to perform such services (citations) and is
willinq and able to do so as part of the ordinary
professional functions of his position.
" [Tlhis proscription applies to a chartered
city whose charter imposes upon one of its regular
officers, the duty to perform the services in question
" Montqomery v. Supreme Court. County of Solano
(1975) 46 Cal.App.3d 657, 668, 121 Cal.Rptr. 44)
(Emphasis added)
When this rule and the general rules for the interpretation of
Charter provisions are applied, Charter Sections 55(d) and 241
are not in conflict.
The applicable rules of Charter interpretation are:
"All provisions relating to the same
subject must be construed together so as to
harmonize with each other. If two apparently
conflicting sections can fairly be given an
operative effect through a different construction,
that construction will be given to avoid the
conflict. . ." (45 Cal.Jur.3d, Municipalities
Sec. 59)
The two sections harmonize where the Mayor and Common Council's
authority "to employ such legal counsel . . . may be necessary
. . . " is read to make the Mayor and Common Council's
authority to hire contingent on a finding of~. The ~
test is the one stated in the Montqomery case. The Mayor and
Common Council must find that there is no regular officer of
the City required by law to perform the service or that the
officer is disqualified or not willing or able to provide the
legal service as part of the ordinary professional function of
his position. When construed in this way, the apparent
conflict between Charter Sections 241 and 55(d) is resolved.
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Mayor and Common Council
June 30, 1987
Page Three
San Bernardino Municipal Code Chapter 2.20 is a specific
expression of the Montaomerv rule as it applies to the City
Attorney. San Bernardino Municipal Code Section 2.20.070
provides:
"Any City officer desiring legal services
concerning City business from legal counsel other
than the City Attorney shall first . . . determine
whether the Citv Attornev is willina and able to
provide such services . . . No City officer shall
utilize outside legal services concerning the City
business without the approval of the City Attorney
or Council . . . " (Emphasis added)
In the absence of San Bernardino Municipal Code Chapter 2.20,
the Charter mandates the basic relationship expressed in that
section. Addressing the issue in another context, the courts
have given an insight into the policy reasons behind the rule
let out in Montaomerv:
"The law will not indulge an implication
that a public agency has authority to spend public
funds which it does not need to spend; that it has
authority to pay for services which it may obtain
without payment; or that it may duplicate an expenditure
for services which the taxpayers have already provided."
Jovner v. Stockton (1961) 14 Cal.Rptr. 49, 54.
CONCLUSION
The Mayor and Common Council may retain outside counsel, but
they must first obtain a determination from the City Attorney
that he or she is either unwilling or unable to perform the
desired service.
Rl;.SP. ct.fUllY s.ubmitted,
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Deputy City Attorney
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cc: City Administrator
City Clerk
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CITY OF SAN; BERNARDINO
300 NORTH "0" STREET. SAN BERNARDINO. CALIFORNIA 92418
JAMES F. PENMAN
CITY ATTORNEY
17141384-1355
November 17, 1987
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Opinion No. 87-59
10.37
JAMES F. PENMAN
City Attorney
Re: Power of Council to Employ Outside Attorneys
ISSUE
Th~ issue has been raised as to whether the Mayor and Common
C~cil may employ outside attorneys at pUblic expense to
perform duties which the City Attorney would normally perform
and which he stands ready, willing and able to discharge.
ANALYSIS
The duties of the City Attorney are set forth in Section 55(dl
of the Charter of the City of San Bernardino. As last amended
on April 13, 1971, this subsection reads as follows:
"(dl The City Attorney shall be the chief
legal officer of the City; he shall represent
and advise the Mayor and Common Council and all
City officers in all matters of law pertaining
to their offices; he shall represent and
appear for the City in all legal actions
brought by or against the City, and prosecute
violations of City ordinances, he shall also
act and appear as attorney for any City officer
or employee who is a party to any legal action
in his official capacity; he shall attend
meetings of the City Council, draft proposed
ordinances and resolutions, give his advice
or opinion in writing when requested to do so
in writing by the Mayor or Common Councilor
other City official upon any matter pertaining
to municipal affairs; and otherwise to do and
perform all services incident to his position
and required by statute, this Charter or
general law."
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James F. Penman
November 17, 1987
Page Two
It is important to note that throughout this section the
mandatory "shall" is used.
In addition, Section 241 of the Charter provides:
"The Mayor and Common Council shall have power
and authority to employ and engage such legal
counsel and services and other assistants, as
may be necessary and proper for the interest
and benefit of the City and the inhabitants
thereof."
The question then becomes, what
Charter sections to each other?
as follows:
is the relation of these two
The general rule can be stated
"Whatever duties are imposed on officers by
law must be personally discharged by them
and the City cannot relieve its officers from
discharging their regular duties by contracting
by ordinance or otherwise with other persons
to perform part or all of them." (2 McQuillin,
Municipal Corporations, 3d Ed. Rev., Section
10.38, pg. 840; see also 52 Cal.Jur.III
"Public Officers, etc." Section 57 and House
v. Los Anaeles Countv (1894) 104 C 73. 78.)
Nationally, with reference to legal officers the cases are
mixed. However, it seems very clear that the decisions turn on
the individual charter or statute involved.
"It has in numerous cases been decided that
where the corporation has regular counsel,
charged with the duty of conducting all the
law business in which the corporation is
interested, contracts for additional or extra
legal services are unauthorized. This role
has frequently been applied to the engagements
of attorneys by municipal boards, commissions,
departments, or officials, for the performance
of services within the proper sphere of
activity of the city attorney, or city law
department." (10 McQuillin, Municipal
CorDoratio~, 3d Ed. Rev., Section 29.12,
pgs. 244-245.)
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James F. Penman
November 17, 1987
Page Three
In the case of Denman v. Webster(1903) 139 C 452, the
California Supreme Court considered the claim for compensation
for legal services provided by Attorney Denman allegedly on
behalf of the San Francisco Board of Education. The underlying
question involved which individual had a right to a seat on the
Board. The Court concluded that the question as to who had a
right to the seat was not a pUblic question but a private one
and, as a result, the Board did not have the authority to use
public funds to employ counsel for this purpose. Since the
Charter of the City and County of San Francisco imposed on the
City Attorney the obligation to represent the Board of
Education, Justice Shaw, in a concurring opinion, stated:
"If the law provides an attorney upon whom
the board may call when a defense to any
suit is necessary, it cannot ignore this
provision and put the district to the
expense of paying some other attorney for
services which it is the duty of the
attorney thus provided to perform."
(at page 456)
In Dadmore v. City of San Dieao (1908) 9 Cal.App. 549, the
City, by ordinance, created the office of Special Prosecutor
and appointed Attorney Dadmore to that position. After
performing the specified duties, he sought payment and was
refused. The court reviewed the charter provision in question
which authorized the city council to "employ other attorneys to
take charge of any such litigation, or to assist the city
attorney therein." The court stated:
" . . . under the charter of the City of
San Diego the City Council cannot relieve
a Charter officer of the city from the
duties devolving upon him by the charter
and designate another to perform such
duties." (at page 551)
The court concluded that the authority in the charter provlslon
did not authorize the employment of outside counsel to perform
prosecutorial duties.
In ~~en County v. Shinn (1891) 88 C 510, the Supreme Court in
considering an old statutory provision relating to the power of
boards of supervisors in general law counties concluded that
such boards have the authority to hire outside counsel. But
even here the court noted that such authority rested upon the
ground:
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James F. Penman
November 17, 1987
Page Four
" . . . that the district attorney may be
incompetent, or sick, or absent from the
county, or engaged in other business, so
that he cannot attend to it, or the business
to be transacted may be outside of the
county." (at page 512)
FOllowing action by the legislature in amending the subject
provision relied upon in Lassen, the Supreme Court once again
considered the issue in Merced Count v v. Cook (1898) 120 C 275:
"There is no doubt that the enactment of this
amendment [limiting the power of boards of
supervisors to hire outside counsell was
occasioned by the somewhat common and
indiscriminate action indulged in by boards
of supervisors of hiring outside attorneys
to conduct county litigation. There can be
no question but that the district attorney
of the county is the officer authorized
by law to take charge of and conduct such
litigation. He is an officer of the county
elected by the people for that purpose and no
board of supervisors had (sic) the arbitrary
power to displace him in the conduct of its
litigation and substitute other attorneys.
. . . If the board of superivsors could portion
out the legal business of the county as .
appertaining to license matters to outside
attorneys, it could likewise apportion to
such attorneys all other branches of legal business
in which the county was directly interested,
and thus relieve and deprive the district
attorney of the very labors which are devolved
upon him by the law, and which he was elected by
the people to perform, and which under his
oath of office he is bound to perform"
(at page 277-278)
In the case of M~~ri~m v. Barnum (1897) 116 C 619, the Supreme
Court rejected an agreement to employ outside counsel to give
legal advice to the Fresno County Board of Supervisors since
the court concluded that such responsibilities were included
within the duties of the District Attorney.
In the case of Rafael v. ~~ (1916) 31 C.A. 623, the City
Attorney of the City of San Francisco gave certain legal advice
to the City's Civil Service Commission, which advice was
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James F. Penman
November 17, 1987
Page Five
ignored. Thereupon, the Commission was sued on the basis of
those actions. The City Attorney offered to defend the suit
but the offer was rejected and the Commission hired outside
counsel. The court concluded that such employment was outside
the authority of the Charter and therefore illegal.
In Montaomerv v. Superior Cou~ (1975) 46 Ca1.App.3d 657 a
general law city took action to relieve its contract city
attorney of the responsibility of prosecuting certain other
violations, with the attorney's concurrence. The court, in
considering this question, concluded:
"Several authorities hold that a public body
may not validly . . . [employ outside personnel
for special services] where a regular officer
or employee thereof is obligated by law to
perform such services (citations ommitted)
and is willing and able to do so as part of
the ordinary professional functions of his
position (citations omitted).
"Although this proscription applies to a
chartered city whose charter imposes upon
one of its regular city officers the duty
to perform the services in question
(citation omitted), it does not apply
to preclude a general law city from
employing special counsel to perform
prosecutorial duties where it has divested
its regular city attorney of such duties."
(at page 668-669)
When read in light of the foregoing law, the Charter provisions
of the City of San Bernardino first quoted mean that the City
Attorney of the City of San Bernardino has the responsibility
and must provide all the legal responsibilities of the City.
However, upon his request, the Mayor and Common Council may
employ attorneys to assist him in that duty both in-house and
outside. This may occur when there is more work than he can
do, when the work is beyond his expertise (such as bond
counsel), or when he is legally disqualified. But the Mayor
and Council may not employ independent legal assistance when
the City Attorney is ready, willing and able to provide the
service.
This rule has been codified in San Bernardino Municipal Code
Chapter 2.20 although it is clearly the law even in the absence
of this provision. Section 2.20.020 requires the City Attorney
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James F. Penman
November 17, 1987
Page Six
to coordinate all legal services for the City. Section
2.20.030 requires all requests for legal servies to be directed
to the City Attorney. Of special significance are the
provisions of Sections 2.02.040 and 2.20.070. These sections
set forth the procedures and conditions for the employment of
special or outside counsel. Section 2.20.040 provides as
follows:
"Special counsel shall be retained by the
Council pursuant to Charter Section 241 subject
to the recommendation of the City Attorney that
such counsel is necessary in instances when legal
specialization not possessed by the City Attorney
is required or when the City Attorney is unable
or disqualified from performing such legal
services. special counsel shall not be retained
when the City Attorney is willing and able to
perform the legal services as a part of the
ordinary professional functions of his or her
office. The City Attorney shall advise the
Mayor and Common Council as to the experience
and qualifications of attorneys considered for
retention as special counsel."
Section 2.20.070 states:
"Any City officer desiring legal services
concerning City business from legal counsel other
than the City Attorney shall first inform the
City Attorney of such intended request for outside
legal services to determine whether the City
Attorney is willing and able to provide such
services. No City officer shall be authorized
to obligate the City for payment of services of
outside counsel without the express approval of
the Council. No City officer shall utilize outside
legal services concerning City business without
the approval of the City Attorney or Council,
provided, however, that nothing herein shall
preclude any City officer from obtaining outside
legal services at his or her own expense concerning
the personal or public rights, duties, privileges
or benefits of such officer as an individual or as
an office holder, or from Obtaining at his or her
own expense legal services of a private nature."
--
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,~
BERNARDINO
300 NORTH "D" STREET, SAN BERNARDINO. CALIFORNIA Q241B
JAMES F. PENMAN
CITY ATTORNiY
17141384-15355
April 14, 1989
Opinion No. 89-11
10.39
TO: Donald Burnett
Chief of Police
RE: Power of Departments to Employ Outside Attorneys
ISSUE
The issue has been raised as to whether individual
departments may employ outside attorneys at public expense to
perform duties which the City Attorney would normally perform and
which he stands ready, willing and able to discharge.
CONCLUSION
Neither individual departments nor the Mayor and Common
Council on their behalf, may employ outside attorneys at public
expense over the objection of the City Attorney to provide the
services that he is ready, willing and able to provide and which
is his duty as the elected City Attorney under the Charter of the
City of San Bernardino to provide.
ANALYSIS
The duties of the City Attorney are set forth in Section
55(d) of the Charter of the City of San Bernardino. As last
amended on November 8, 1988, this subsection reads as follows:
"( d) The City Attorney shall be the chief legal
officer of the City; he or she shall represent and
advise the Mayor and Common Council and all City
officers in all matters of law pertaining to their
offices; he or she shall represent and appear for the
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Chief Burnett
Opinion 89-11
April 14, 1989
City in all legal actions brought by or against the
City, and prosecute violations of City ordinances, and
may prosecute violations of state law which are
misdemeanors or infractions and for which the City
Attorney is specifically granted the power of
enforcement by state law without approval of the
District Attorney, or those violations which are drug
or vice related; he or she shall also act and appear as
attorney for any City officer or employee who is a
party to any legal action in his or her official
capacity; he or she shall attend meetings of the City
Council, draft proposed ordinances and resolutions,
give his or her advice or opinion in writing when
requested to do so in writing by the Mayor or Common
Councilor other City official upon any matter
pertaining to municipal affairs; and otherwise to do
and perform all services incident to his or her
position and required by statute, this Charter or
general law."
It is important to note that throughout this section the
mandatory "shall" is used.
In addition, Section 241 of the Charter provides:
"The Mayor and Common Council shall have power and
authority to employ and engage such legal counsel and
services and other assistants, as may be necessary and
proper for the interest and benefit of the City and the
inhabitants thereof."
The question then becomes, what is the relation of these two
Charter sections to each other? The general rule can be stated
as follows:
"Whatever duties are imposed on officers by law must be
personally discharged by them and the city cannot
relieve its officers from discharging their regular
duties by contracting by ordinance or otherwise with
other persons to perform part or all of them." (2
McQuillin, Municipal Corporations, 3d Ed. Rev., Section
10.38, pg. 1113; see also 52 Cal. Jur. III "Public
Officers, etc." Section 57 and House v. Los Angeles
County (1894) 104 C 73, 78.)
Nationally, with reference to legal officers the cases are
mixed. However, it seems very clear that the decisions turn on
the individual charter or statute involved.
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Chief Burnett
Opinion No. 89-11
April 14, 1989
"It has innumerous cases been decided that where the
corporation has regular counsel, charged with the duty
of conducting all the law business in which the
corporation is interested, contracts for additional or
extra legal services are unauthorized. This rule has
frequently been applied to the engagements of attorneys
by municipal boards, commissions, departments, or
officials, for the performance of services within the
proper sphere of activity of the city attorney, or city
law department." (10 McQuillin, Municipal
Corporations, 3d Ed. Rev., Section 29.12, pg. 245.)
In the case of Denman v. Webster (1903) 139 C 452, the
California Supreme Court considered the claim for compensation
for legal services provided by Attorney Denman allegedly on
behalf of the San Francisco Board of Education. The underlying
question involved which individual had a right to a seat on the
Board. The Court concluded that the question as to who had a
right to the seat was not a public question but a private one
and, as a result, the Board did not have the authority to use
public funds to employ counsel for this purpose. Since the
Charter of the City and County of San Francisco imposed on the
City Attorney the obligation to represent the Board of Education,
Justice Shaw, in his concurring opinion, stated:
"If the law provides an attorney upon whom the board
may call when a defense to any suit is necessary, it
cannot ignore this provision and put the district to
the expense of paying some other attorney for services
which it is the duty of the attorney thus provided to
perform." (at page 456)
In Dadmore v. City of San Diego (1908) 9 Cal.App. 549, the
City, by ordinance, created the office of Special Prosecutor and
appointed Attorney Dadmore to that position. After performing
the specified duties, he sought payment and was refused. The
court reviewed the charter provision in question which authorized
the city council to "employ other attorneys to take charge of
any such litigation, or to assist the city attorney therein."
The court stated:
" . . . under the charter of the City of San Diego the
City Council cannot relieve a Charter officer of the
city from the duties devolving upon him by the charter
and designate another to perform such duties." (at
page 551)
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Chief Burnett
Opinion No. 89-11
April 14, 1989
The court concluded that the authority in the charter
provision did not authorize the employment of outside counsel to
perform prosecutorial duties.
In Lassen County v. Shinn (1891) 88 C 510, the Supreme Court
in considering an old statutory provision relating to the power
of boards of supervisors in general law counties concluded that
such boards had the authority to hire outside counsel. But even
here the court noted that such authority rested upon the ground:
" . . . that the district attorney may be incompetent,
or sick, or absent from the county, or engaged in other
business, so that he cannot attend to it, or the
business to be transacted may be outside of the
county," (at page 512)
Following action by the legislature in amending the subject
provision relied upon in Lassen, the Supreme court once again
considered the issue in Merced County v. Cook (1898) 120 C 275:
"There is no doubt that the enactment of this amendment
[limiting the power of boards of supervisors to hire
outside counsel] was occasioned by the somewhat common
and indiscriminate action indulged in by boards of
supervisors of hiring outside attorneys to conduct
county litigation. There can be no question but that
the district attorney of the county is the officer
authorized by law to take charge of and conduct such
litigation. He is an officer of the county elected by
the people for that purpose and no board of supervisors
had (sic) the arbitrary power to displace him in the
conduct of its litigation and substitute other
attorneys. ... If the board of supervisors could
portion out the legal business of the county as
appertaining to license matters to outside attorneys,
it could likewise apportion to such attorneys all other
branches of legal business in which the county was
directly interested, and thus relieve and deprive the
district attorney of the very labors which are devolved
upon him by the law, and which he was elected by the
people to perform, and which under his oath of office
he is bound to perform." (at page 277-278)
In the case of Merriam v. Barnum (1897) 116 C 619, the
Supreme Court rejected an agreement to employ outside counsel to
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Chief Burnett
Opinion No. 89-11
April 14, 1989
give legal advice to the Fresno County Board of Supervisors since
the court concluded that such responsibilities were included
within the duties of the District Attorney.
In the case of Rafael v. Boyle (1916) 31 C.A. 623, the City
Attorney of the City of San Francisco gave certain legal advice
to the City's Civil Service Commission, which advice was ignored.
Thereupon, the Commission was sued on the basis of those actions.
The City Attorney offered to defend the suit but the offer was
rejected and the Commission hired outside counsel. The court
concluded that such employment was outside the authority of the
Charter and therefore illegal.
In Montgomery v. Superior Court (1975) 46 Cal.App.3d 657 a
general law city took action to relieve its contract city
attorney of the responsibility of prosecuting certain violations,
with the attorney's concurrence. The court, in considering this
question, concluded:
"Several authorities hold that a public body may not
validly. . [employ outside personnel for special
services] where a regular officer or employee thereof
is obligated by law to perform such services (citations
omitted) and is willing and able to do so as part of
the ordinary professional functions of his position
(citations omitted).
"Although this proscription applies to a chartered city
whose charter imposes upon one of its regular city
officers the duty to perform the services in question
(citation omitted), it does not apply to preclude a
general law city from employing special counsel to
perform prosecutorial duties where it has divested its
regular city attorney of such duties." (at page 668-
669)
The Charter of the city of San Bernardino makes it clear
that the power to authorize new positions and to establish the
duties of officers is reserved to the Mayor and Council and may
not be exercised independently by other city offices (Charter
Sections 40(x), 181, and 241; see also 3 McQuillin, Municipal
Corporations, 3d Ed. Rev., Section 12.127, pg. 481).
When read in light of the foregoing law, the Charter
provisions of the City of San Bernardino herein quoted mean that
the City Attorney of the City of San Bernardino has the
responsibility and must provide all the legal duties of the City.
However, upon his request, the Mayor and Common Council may
5
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Chief Burnett
Opinion No. 89- 11
April 14, 1989
employ attorneys to assist him in that duty both in-house and
outside. This may occur when there is more work than he can do,
when the work is beyond his expertise (such as bond counsel), or
when he is legally disqualified. But the Mayor and Council may
not employ nor authorize an individual department to employ
independent legal assistance when the City Attorney is ready,
willing and able to provide the service.
This rule has been codified in San Bernardino Municipal Code
Chapter 2.20 although it is clearly the law even in the absence
of this provision. Section 2.20.020 requires the City Attorney
to coordinate all legal services for the City. Section 2.20.030
requires all requests for legal services to be directed to the
City Attorney. Of special significance are the provisions of
Sections 2.02.040 and 2.20.070. These sections set forth the
procedures and conditions for the employment of special or
outside counsel. Section 2.20.040 provides as follows:
"Special counsel shall be retained by the Council
pursuant to Charter Section 241 subject to the
recommendation of the City Attorney that such counsel
is necessary in instances when legal specialization not
possessed by the City Attorney is required or when the
City Attorney is unable or disqualified from performing
such legal services. Special counsel shall not be
retained when the City Attorney is willing and able to
perform the legal services as a part of the ordinary
professional functions of his or her office. The City
Attorney shall advise the Mayor and Common Council as
to the experience and qualifications of attorneys
considered for retention as special counsel."
Section 2.20.070 states:
"Any City officer desiring legal services
concerning City business from legal counsel other than
the City Attorney shall first inform the City Attorney
of such intended request for outside legal services to
determine whether the City Attorney is willing and able
to provide such services. No City officer shall be
authorized to obligate the City for payment of services
of outside counsel without the express approval of the
Council. No City officer shall utilize outside legal
services concerning City business without the approval
of the City Attorney or Council; provided, however,
that nothing herein shall preclude any City officer
from obtaining outside legal services at his or her own
expense concerning the personal or public rights,
6
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Chief Burnett
Opinion 89- 11
April 14, 1989
duties, privileges or benefits of such officer as an
individual or as an office hOlder, or from obtaining at
his or her own expense legal services of a private
nature."
In addition to the clear legal prohibition outlined above,
as a practical matter, if each city department sought to hire its
own independent counsel not only would the cost soon become
exorbitant but the efficiency of having one office with the
ability to assign attorneys to tasks as needed would be lost.
Respectfully submitted,
BARLOW
City Attorney
Concur:
(1~ 7)~
~y Attorney
AB:br
cc: Mayor
City Council
City Clerk
City Treasurer
City Administrator
Department Heads
7
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James F. Penman
November 17, 1987
Page Seven
CONCLUSION
The Mayor and Common Council may not employ outside attorneys
at pUblic expense over the objection of the City Attorney to
provide the services that he is ready, willing and able to
provide and which is his duty as the elected City Attorney
under the Charter of the City of San Bernardino.
Respectfully submitted,
/
DENNIS A
Sr. Asst.
RLOW
City Attorney
DAB:cm
cc: Mayor
City Administrator
City Clerk