Loading...
HomeMy WebLinkAboutNB2-Council Office Cll · OF SAN BERNARD[ 0 - REQU: 3T FOR COUNCIL At. . ION From: Councilman Jack Strickler Subject: Policy on Providing an Opinion Dept: Council Office Date: December 31, 1986 Synopsis of Previous Council action: Subject and dates of attached correspondence. Recommended motion: To discuss the hiring of an outside attorney to furnish the Mayor and Council with an opinion when necessary. ~ \\.'"'~ .~ ~~ 't.LJ Si lure Contact person: Phil Arvizo Phone: 5168 Supporting data attached: Yes Ward: N/A FUNDING REQUIREMENTS: Amount: Source: Finance: Council Notes: 75-0262 NEW BUSINESS Agenda Item No. JOHN K. VAN DE KAMP Attorney General 'In iJF (_ - ....iI jji-'ll -, loll "l/.;)/}.,-u 1985 Dfe (g AM State of California DEPARTMENT OF JUSTICE ~: 59 15]5 K STREET. SUITE 51l SACRAMENTO 958]4 (9)(;) 445-95,5,5 P. O. Box 944255 Sacramento 94244-2550 December 24, 1986 Mr. Jack Strickler Senior Council Member City of San Bernardino 300 North "D" Street San Bernardino, CA 92418 Dear Mr. Strickler: This is in reply to your December 17 request for "an op1n1on regarding the proper representation our City Attorney is to provide to the Common Council". The opinion function of the Attorney General is limited to providing opinions to state officials, district attorneys (and county counsels) and city prosecutors (limited) to criminal law questions). I have attached materials which explain the Attorney General's opinion functions. Since the Attorney General has no authority to provide opinions to city officials on civil law questions I must respectfully decline your request. It may be of some interest to know that this office is preparing an opinion on the question whether a county counsel has a duty to provide a legal opinion to an individual school trustee (Op. No. 86-404) requested by the County Counsel of Solano County. Sincerely, JOHN K. VAN DE KAMP ne~~ ACK WINKLER Assistant Attorney General Opinion Unit JW: lrh Attach. r~ 1 GOVERNMENT CODE ~ 12519. Opinions The Attorney General shall give his opinion in writing to the Legislature or either house thereof, and to the Governor, the Secre- ~ary of State, Controller, Treasurer, State Lands Commission, Super- mtendent of Public Instruction, any state agency prohibited by law from employing legal counsel other than the Attorney General, and any district attorney when required, upon any question of law relat- ing to their respective offices. The. Attorney General shall give his opinion in writing to a city prosecutmg attorney when required, upon any question of law relat- ing to crmlinal matters. ATTORNEY GENERAL'S OPINIONS (VOLUMB 64 FOREWORD State budget constraints have caused substantial reductions in the Opinion Unit staff. To better utilize limited staff in the performance of our opinion responsibilities under Government Code section 125'19 the following practices (some of long standing and some new) have been implemented: (1) All reque;ts for opinions must be in writing and relate to the re- quester's official duties. ~ (2) Requests submitted by or on behalf of anyone not entitled to an opinion under section 125'19 will be declined. (3) The opinion request must be sufficiently specific to permit precise legal analysis and the questions may be reframed to state more precisely the legal issues presented. Opinions will not be issued to resolve factual questions. (4) Requests will be declined when the questions: (a) are at issue in pending litigation; (b) call for interpretation of proposed constitutional amendments, statutes or regulations before their enactment; or (c) call for the interpretation of local charters, ordinances or regula- tions. (5') Requests submitted by local legal officers and by state officers having full time public legal counsel to advise them must be accompanied by a full legal analysis and conclusions on the questions presented. (6) The issues presented must have sufficient significance to justify the expense of preparing an opinion. Informal responses will be provided on opinion requests when appropriate. February I, 1982 GEORGE DEUKMEJIAN Attorney General of the State of California '. AlTORNEY GENERAL'S OPINIONS [VOLUME 66 FOREWORD Many questions have been asked concerning the nature and extenr of the At- torney General's responsibility to provide legal opinions. The following analysis was prepared to answer many of these questions. A. THE STATIlTES . (1) Anicle V. section 13. of the California Constitution designates the Attor. ney General as .. the chief law officet of the State." The specific responsibility to provide legal opinions is set forth in Governmenr Code section 12519 as follows: . 'The Anorney General shall give his opinion in wriung to the Legisla. ture or either house thereof. and to the Governor, the Secretary of State. Con- troller, Treasurer, State lands Commission, Superinrendenr of Public Instruction, any state agency prohibited by law from employing legal counsel other than the Attorney General, and any district attorney when required. upon any question of law relating to their respective offices. "The Attorney General shall give his opinion in writing to a city prosecut- ing attorney when required, upon any question of law relating to criminal .maners. " (2) Responsibility to provide legal opinions is imposed on other public law- yers by other statutes. (See Gov. Code. SS 26520 [district attorney), 26529, 27642, 27645. 27647 [countY counsel) and 41801 (city attorney).) A review of these sta- tutes makes it dear that the Legislature has apportioned the responsibility for provid- ing legal opinions to public officials among public lawyers at both the state and IocaI leveb of government. (3) The language of section 12519, quoted above,limil3 the Attorney Gener- al's responsibility to provide legal opinions in two respects. First. opinions are provid- ed only to the public officials designated in the sratute. Second, only questions of law relating to the office of the requester require an opinion response. The cz- press direction to provide opinions under these limited circumsranccs implies an absence of any duty to provide legal opinions under other circumstanCes. B. THE REQPIENTS (1) Cotlstintio1l4l Ofjiurs. Anorney General's opinions are provided each of the state's constitutional officers. Though the Lieurenant Governor is not named specifically in section 12519, that office is considered a state agency authorized to request opinions under that section. (2) Legisi41on. Section 12 519 statcs that opinions shall be provided to .. the Legislature or either house thereof. ., This language has long been interpreted to " include individual legislators. Howevet. it does not include legislative committc:c:s or their consultants. (3) Sl4Ie Agencies. Sc:ction 12519 states that opinions shall be provided [0 "any state agency prohibited by law from employing legal counsel other than the AttOrney General." Many state agencies have been authorized to employ staff at. torneys. Government Code section 11157 provides that the Attorney General .. is the Ic:pi advisor of c:2Ch department [of state government I in all matters rdating to the department and to the powers and duties of its officers. ., Because: the Attor. I1c:T Gc:nc:raJ is the State's chief law officer. the office has traditionally provided lc:pi opinions to all State departments. agencies, boards and commissions, includ. ing those with staff counsel. However, requc:su for opinions from those: having full time staff counsel must be accompanied by the legal malysis and conclwions of staff counsel. (See C(10).) (4) i.ages. Sc:ction 12519 does not indicate whethet courts are state agencies authorized to rc:quc:sr opinions. This ambiguity was resolved by Government Code section 27647 which authorizes the county counsel to represent the judges of the superior. municipal and jwtice courts in the county" in all matters and questions of law pc:m.ining to any of such judge's duties." This evidences the Legislature's intent that advising trial judges is the responsibility of local public counsel. The Supmne CoUrt and CoUrt of Appeals are State agencies authorized to requc:sr opin. ions under section 12519. Such requests should come from the coutt at the rc:quc:sr of the chief jwrice or a presiding jwrice or. as is usually the case. be submitted by the Adminisrrarive Office of the CoUrts. (5) Dutri&t Altomeys ana Co.nty Co.nsels. Sc:ction 12519 states that opin. ions shall be provided to "any district attorney." Government Code section 26520 er sc:q. provide that district attorneys have civil law duties as well as their dusies as public prosecutors. Government Code sections 27640 and 27642 provide that a county board of supervisors may split the duties of the district attorney by ap- poincm, a county counsel who thereafter performs all the duties of the district at. torney ctt:ept those of public prosecutor. The Attorney General's responsibility to provide Ic:pi opinions to district attorneys has long bc:c:n interpreted to include eou.nty counsels so thar all counties will have access to Attorney General' s opinions with respc:cr to the laws relating to the civil as well as the prosecutoriaJ functions of the district attorney. (6) CiIy Prosecflton. Sc:ction 12519 States that opinions shall be provided to "a city prosecuting attorney when required. upon any question of law relating to aiminaI matters. ., This provision is limited to those: city offices which acrually prose:. cute: m.isdc:meanor casc:s arising in the city. It does not authorize opinions for city attorneys who do not prosecute aiminaI cases nor for city prosecutors on civil law q:=tions. .' (7) Reqflests o. Behalf of Others. Sc:ction 12519 States thar an opinion shall be gmn designated officers "upon any question of law relating to their n:spectige offices. ,. (Emphasis added. ) This does not authorize a designated officer to rc:quest an opinion on a question posed by someone elsc:. When it is apparent thar a o requc:sr is made on behalf of someone not authorized to requc:sr it by section 12519 the request will be declined. (8) Depflty or Assistant. .An opinion request should be signed by the prin. cipal officer or head of the agency authorized to mall;e the requc:sr. If the request is made by a deputy or assistant, inquiry will be made to vetify that it was autho- rized by the principal and the opinion will issue to the principal officet. not to the deputy or assistant. (9) Boara or Communi",. An opinion requc:sr from a board or commission must indicate that the requc:sr has been authorized by a majority vote of the board or commission. Opinion requests from individual members of a board or coJJuI1u.. sioil will be dc:clined. C. TIlE QUESTION The Attorney General's responsibility under section 12519 is to provide an opinion in writing to designated public officials "when required, upon any ques. tion of law relating to their respective offices." (1) WrittnI Reqrust. The words "when rc:quirc:d" in section 12519 imply char a formal request must be made by someone authorized to requc:sr an opinion be. fore a duty to provide the opinion arises. Such requests must be reduced to writing to avoid misunderstandings regarding the question presented. (2) Conjidenti41 Aaftce. .All formal opinions issued by the Attorney General are open to public inspc:ction under the Public Records Act and most are published. If a public official seeks a confidential opinion from the Attorney Genc:raJ the re. quest will be referred to the appropriate legal division for assignment to a deputy who will provide the opinion orally or by confidential letter of advice. (3) Rel4Jion to the Offiu. The question mwt relate in some manner to the; office of the person requesting the opinion. Usually this is apparent from the na. ture of the question and the office of the rc:quester. When the relation is not clear. inquiry will be made to establish what it is. Occasionally the rc:quc:sr uansmits a question posed by someone else. In such casc:s the rc:quest will be dc:clined unless it is ascertained that the rc:quc:srer has an official interest in the question other than to accommodate the person who first posed the question. (4) Qrustion of/4w. Sc:ction 12519 States char opinions shall be provided on "questions of law" not on other kinds of questions. Thw rc:quests for opinions to resolve facrual disputes or to resolve conflicting inferences which may arise: from cmain faces will be dc:clined. (5) Speciji& QfI'Stio1JS. Not every "legal" question is capable of being an- swered by an opinion. thar is by a conclwion based on precise legal analysis. Thus. . 'What is a crime?" calls for an encyclopedic review of the criminal law rather than an opinion. The courts do not ordinarily provide advisoty opinions and require an acruaJ case or controversy between specific parties before addressing lc:pi ques. tions and further limit the scope of legal issues by elaborate pleading and confer. enee ptoeedures. Sc:ction 12519 does not rc:quire an actUal controversy but it does m require thal the officers requesting opinions limit their requests to those ,3CtUa.I ,or potential legal problems which confront them in the performance of thel[ official duties, The Attorney General has long followed the practice of rc:fr2ming the ques- tions presented when this appored necessary or desirable. This is done, not only [0 assure a response thal will properly addras the legal problem confronted by the requesrer, but also to sufficiently define the circumstances so thal an opinion ~_ sponse based on precise legal analysis may be made. To that end the requesrer will often be contacted for more particulars of the problem. However, the Attorney General's office will not conduct surveys or make investigations to ascert2in the &as needed to properly fnune a question for legal analysis. (6) Co"j/i&t ofI,,~st. The Attorney General, like every other lawyer, may find there is a conflict of interest with respect ro a particular legal question by CCl- son of other legal matters the office is involved in, by prior legal business, personal business interest and the like. Of course, such a conflict would require the Attor- ney General ro decline the requesr for such an opinion. (7) I"terpreti"g!.ouJ Uwl. Occasionally an opinion is sought to interpret lo- cal charter provisions, ordinances, resolutions, regularions or rules. Since such meas- ures have no application ourside the local jurisdiction there is no need ro r~ew local counsel's interpret2tions to encourage statewide uniformity of interpreraaon. the principal purpose of providing Attorney General's opinions to, local counsel Further, since the principal responsibility for interpreting and enforang local meas- ures rem with local counsel, opinions which might conflict with the views of local counsel would hinder rather than aid the enforcement of such local laws. For these CC2.S0ns the Attorney General declines opinion requests calling for the interpret2. tion of local charters, ordinances, resolutions, regulations or rules. (8) Itlterprermg Petulmg Legis/lllio". Sometimes an opinion requesr coocems proposed legislation or constirutional amendments. Providing opinions on pcud_ ing bills would involve the Attorney General in the bill drafting process, a fuoc- tioo the law specificalIy assigns to the I..egislame Counsel Bureau. Providing opiniom on proposed constirutional amendments might inappropriarely interfere with the election process. For these re2SOns the Attorney General' s office has tr2ditionally declined opinion requests regarding the nlidity or interpretation of proposed lqis- lation or constirutional amendments prior to their enactment. (9) Pe"rimg LiJigfltic". Occasionally the legal question p~ted in an o~- ion requesr is an issue in litigation pending before the COurts or m some adminis- rr.uive proceeding. The Attorney General's office has tr2ditionally declined to proride opinions on such questions while the litigation is pending. There are two buic re2SOns for this practice. Fust, resolution of the litigation will often proride the answer to the quesrion. More signifiandy. the issuance of an Attorney Gener- al's opinion while litigation is pending on the issue might be considered as ID u- tempt to interfere with or influence the litigation. Of couae there is DO way the Attorney General's office an be aware of all issues in every casc being litipQ:d so the pnctice is nor foolproof. NC9Utheless, when the Off'lCC is aware of the litiga. tion initially, an opinion requesr on the issues raised therein will be declined and when made aware of such litigation latc:r, opinion prepamions will be rerminated. IV After litigation on the issue has termin:ued, the Attorney General's office will nor- mally respond to any legal questions which remain. (10) ReqlU/Ur'J Opi1lio". If the law requires a public officer to be a lawyer or the offi;e is provided with full time saiI counsel. that lawyer has the primary responsibility for resolving the legal issues which relate to thal office. The legisla. tive wthorizarion for such an officer to requesr an opinion from the Attorney Genc:r- al was intended as a means of reviewing the acrcise of that Primary responsibility al the officer's requesr, not as a replacement for it. This is the rationale which un- derlies the long sanding pnctice that an opinion requesr from an officer who must be an attorney or who has full time saiI counsel will be declined unless it is ac. companied by the legal conclusions, suppotted by a full legal analysis, prepared by such counsel. John K. Van de Kamp M:Jmey GeurgJ of the SI4te of CzlifOmiII v $ ~ ~ > =- C ::: ~~ ~ > :r ... ~ >>'< = Co. :l! Cl ... ..: ::: (! :l! S ~ a e-: ~' ;, ~ ~ ;;: (1 0 " .. .. ~\oIt ;. 3 ~ g' ~ ~ -, .. '<ire ~ 'E =, : 00 52:!" Q.. .. -. Q.. ~:8'a. ~~ is -. -" Q.." '< c, < _ ~ :J 2. ~ ~ ~ $ "" .. Q.. II :l! ~ 3 C\;:;' .. ..... :r a = .. ... '< .. :r ." 1! III ... ~ ~.~ ~ 1=\"... r:r~ ,.. --. ~ ii'" 1;;' ~ ::'>:l! [:::. o _ g S-~:ro . e: -..... ;. -. -.0 0 ... (1 00." <T''' '" 5' .. g '" -. .. ~ -, g .. !!, i; .. = = " 0 c.. - 3 ..... -;ci;' if ~ _ .. ~~"i ~ ~ ~ ~ e .. f"') c.. ~ ;,;.gst ~,~ S'3,"g E. ~ ;'" ~ ~ ~~~.g~ III ~ 0 5' :::, .. :l! '2, 2' g .., 0 =, .: 0 a '2, a ' "'" ~ =" ;l ~ s., ~ ;l;;' 2: - "",;;' - g if ::I' .. 2.... 1:;" co..... "0 i:[O~ ~ ~ .. ~ ~ . E 0.."'0 Q.. ~. c ~ ... ... "5l ltl ~ a, if ~ ~ 0 ::I > ~ Q....... 0 ::: !!~'H :~ -'.., 3 .. ~ ~~~S' .~ 9 5' ~ t~OQ~ !l. S S ~ 10 ~ "g : Q.. -, - o g ~ ;::;-." 0 .. 5' '2. !, > -." - _ ~ _, :r ~ ~ a ~ ~ Q..1ll ~ >Vt...tl-<'-"=g- ... c ~ 1"'. =- 0 .... C '" <T'... 2 ::: -,., 3 ~ ~' :a 3 ~ ~ a if &. "'" ~Iil~=-:Ta~;:;<~ ~ 5" 2: ~ ~ =... 5" c... !2. ~ " r"\ i;j" c.. oc -. - c ; ~ = :r _. N -5 - ... 3 r"\ .., c.. 2.." .. :r ~ ;; a g, .:: 1'"\ 0 ;. g -~. C\ ~ r"\ " -. ~ ~ ".... . I3Q 0 0 " ~ -,:r :r 3 ..... if 0 ;. ~ Q E ~ - ~ E Q~:SO~3"~-"3 $ .. 3 0 e " 9 1f~~ ~ if!!, 2..[ ~ '2 _, Cl c 2.. Ii' e: 5' " 5' 5' ~ 9 3 Z " ;. _ 00 ~"'IC~aCf)c"'QC~ 5if2..e!,s.,=3"5l~Q ::;' . <T' :. c ~ if 5" ~ !! :l! '< !: .; 2 5' - Cl '< "'. _ f'I <: e OQ OQ ~ ~ C) ~ -. ~ ::: <T' :r :l! _ -, .. 5'~ !l'irZIll;:J~ ~.5 a ~, [ ~ 5' ::: s., 2., li 0 -, .. 0 - ~ .. ~ ..... g , ~ 08..5 = 0 '" :I " ~ 5' ;: " 0 '2. :l. 9- ~3 ... 2' · ~ ~ 0< ea' :J :r.:Q..c.._ !!s.,if~,,~!!:l3 Q.."'''~;2Q..~:J!! '" if ~ 5' 2.. 3 <T'....,,, c.. !! f Q.. _. . =- '< g-> g ." 9.-~a:fi ~~ e ~ ~ ~;- ~ ~. ~:' 2: 3. ~g->ifQ..2..::;'!! ifJlJl (1 :::.;. ~ 0 > 0 ~ oQt"t~ Sa::;"tJ~ ..... ~ 3 ::: ::0 ~ iI 2: 3 ;. <T' S\ 3 C\ '" ~ Q _. f\'<f't :"""'O,<G= ;. ~ ~ ir 0 ~ 3 a' !! > s., g ir ~ '" -, 3 S 3 c Q.. ::: a. -, '$ ~.l ~ ~ ~: ;.] ~ t 11 ~ g' i ;- ~=!!~ifE.a2..~.. [3il :Si' Q.....Q..:t">;0; <T'..Q.. a.2!!-~' "'" :::"~'<-2 ";;Q..;''''' l ~ ~. i g i ~ ~ if ~: ~ ~ ~ !!: :< . .;: II !:r ~ ,&, _ . Cl Ill' 5' ~ iI c;. ~ ~ :l!.. i.." ~!! 5' :r Q.. /I l - . Q.. '" :5 $ S '" ; ~ "5' .. '< ;; ~. '" Co a .. - if > 00 "~ J f~. ..j '2 I :.. ~ 5' ! i"'I [:! -<: ! t9g~3""2i' ~~a:;:,,~ ~ ~ ] g' a t ~ :::':l 5 ~ ~ ;;. c. ~ g r ~ i- ~ 5: .. a. ~ ~';. ~ 8 ~ ;. !! a. ~. I r a Ct. sr ~ ~ ::: ;' ..... ~ IS'" f. ~ a ~ ;;. :: i"'I ~ . Coo. :" .. ~ . . ~ '< ~ l 2, . i" s., 2' ;l~ ~ ~ ~ . - e. ~ ~ I g. ~ C!! ~.;;. go II' C\ ~ :t ~ [l ~ i ~ ~ ~ '"' 0' i;. ~ c ~ s., 1 ir ~ 5' ~ ~ 3:' f a ~ ~ l~" ~~~la g-~O'~. ~ g I ~ ~. ! .e l i ~: lJ f i ~ .....,i'!. g.silr ~~c;.lC\ Q.. t [ g. ~ ..;. j ~ /I 9- ~ g. " ~ ~ $ a a i ::- S'!! ~ !' ~ 1: ~. ; ~ ! f Ii ~ ~ ! !! r ~ ~ ~ ;-~. a t ~ g' ~ ~. ~] a ~. If g' S: a. i: r r ~ i ~ ~: ~ :l! !i;Q.. _".~ go ~ i, !2 .. ~ 6 if' c;. g. " c, Q aif~lI!:l!if..9~ II ,,2..;1 S g.. = ~ = g-> ~ ~ 2 ... !:: -, - :"' .5 Ii- ~ ~ _ ::.. "< CII o ;; ;. ; ~i;'s ~';;l .... 'li " - 5' ~ 1.: ~.. 3 2.. -, c !!'E~i" " <T' -, !! t't =-= II Q. s.,"I;'; 000,< ~sra:;. 10' i e .. 'B .. ;; E <T':l! -. ~ - -,,, :" ;. ;; ~ rJ .. '" 3 1 .. o. e ' :l! ::!, -.. -. ::: g .. !T. 9 <T'iI ::: =-. g' =. -. '" ... "" -. - :> ~.g ~ ~ o ~'2'< 3 a ~ 9 ~ g':- ~ .. :rQ.. il 0 9 5' ;;~ ~ I: ~ .. a " /I a: 5' ~ ~ ~ .. < -.;;' 9 ;~s;. .g .. ~ _.~ c. ~. ii"~ 0 ~ ;; g '2. ~" :r 2. - S ~ 12 if ...: c' a c. s., Q.."':; 15: ~ i1. ~ ~ ; ~ > .2 If ::: ~1J '< i Cl i ~'l ~~ i " g ;I ~2,a a f. B if1= I ~. ~ 9 g 8 > a ~. J ~ 2, Cl!~ I' ~ .- t. .. ::: o 3 ~ ..; :l! t :r 9 ? .2 ~ c il 10' '< .2.. Cl c ... 1 ~ ! ~ ,&, ; a ~, g' ;. o ;;' ~~ :l! 5' ~ g' S' 5' ~ :l!.., o _. Q 5' ~'oo " ~a .. ~ c. :::~ a1! :~ 5' 00 ... ~ "0,:, ~,., .g,<g.~~ ~ c.. ~ .... : ~' la' ;;' ~ s ;l ~ ~. c... 0.. ~ rt ~:~~-~ (1 8 fQ[f~ 3 3 2 " ... ::- 3 ....,~ '< 0 -, ~ :l! ~ ~'Q.. ~ ~3~aa '2.",~~ j ~,~ if ~ ~. Jl 5' ~ ; '" ii"'" ~ (JQ .Q.. 00 9 :> <' c ~ t g .. l~~'~~ !! ! .....~",. '< iI ;p ~ 2. ~ifS!;~g a I'i -< 5' c. i" ;- s., :l! g " .. '" :::, o :r 2 ~ 1:. ~ t'I 8.!' ~ _>0 ; ::: ." ~ a ' ~.3 ! ~ ~ 5' Cl ill .~ ,i 00 9 ~ --! ra: ... t'I ... IY o .~c: e ~ f. i~ .a ~ III a ~ ~"2 = = ~ ~ o III IY > ~ &' -::, .' :.; III R- ~ . ... .... < o if' "g " ~ ~ :r :. ~!i;g ;;-ii"- 't:l!~ 000 ", s..... 2: Q ~ :' s., ~ ll!;'~ ~ .. 3 f;' ;r :r;;~ 5' ': a ~ ~:::, < if ~ 3 ? g' 3 S Q.. 9 3 a - ~ oli' ~Cl~ 9 a ~ .. '" _. ~ if g .. > ;: 7 a '" fIi ~ -. " ::0 g->~ ~ ~ 5' 5' > ~ ;. c;. ~" 0 !! .. C !l ~! j ::- ::: if = ii. 9 ~ 1 8. II Q.. 5' !, "* ~ ~ ." 3 ~ ~ ~ g' ~ ~ ;. "g~ ;l 00 = il 9 '< g.!! <..' ".. 0" ... ~ ~ g' ; Cl ~ ~ ~ ~ ~ ~ ~ ; 3 .. ~ Q.. e ~ 9 "..... s ,," !!. a !! '< III ~' 2 .g' -~' s., s., 9 't ~ 'B 8'; 3 Q.. c' ~ ~ &' c .. 0 .., <T''' ~!! e., - 5' c; fi _."'." g., ~ ~;::;- '< 'B 0: S " ~' '< ~ 5 :; g-> a ..! - '2 ~::t.- <& !! i' 5' a c, S a' ~ ~ ~ 5' ;.! s., ... Q.. 0" g o..~ l=l;; a:s - > .. .. ii1 ::l .. E-1! ~. '" 11 '. .. ::: S ~ [ :r a. i ~ a ~ ~ : ~ ~' ~ ~ ~ "8 Q.. ~ =- a go g. :; .. '2, ~"~ ~ ~ "" S if ! 2. .. iil ~ 'i e. g ~ :r ~ !l ;I' ~ ~ -l . ~ ~ I ~ a s.,~"; ~ > ;. ~ 1 I[!. S ~,= ~!2 s., ~ are, :::", iil~a"'1!!c;.9-s.,[. > ~ ~~ -/I. 11::: r ~ 1 9- S' . ~ > ~ ! g 1: r 4!9 "~:l!g1:::""''''<~ oll!!Cl:l! :r- ::I'! . Cl." ~'< g!,,] 0 F.; !ilIa lc~oil::l ~~ ." -c ;: f. 2.. ;:' e!, a, 2...2 Ill' Cl 50 I'i' g. 1 1 ~ if. g' ~ ~ ~ R ~ g so. : I: '&'i ~: ~. ~ ~ ;. ~ 2. !$ ~ a' ~ .~ 1[";;'< llli 3 : l! ~ ... g. Ii r f i iJ f. 8 ~ . B: o:!. ~;; II .. .. ~ ~;c 'B ~ ~ll ~ii ~ c;.~ >::: g g,:'< i;'l S!; 5 . g ~ !. .. /I a i ~ .. a. S" a ~ s.,.1 ~ if S' ~ g' 5'.3 ~ 9. 1 ~!- ~" ~ ~ i ~r ~ g 3: 3 .. ~ ~ s., '< '< - ,&, o :r C :' tI ~ :r~- ~ ::: g 0''' .g 3 :r ... -. .. .. .. < ~'~ ~ , ~ 9 ~ III Cl"" ~ ~ ~8 ~ ~, _00 o if;' :l! .. ~'1 ~l l!l :l! Q.. III or 1! ~ ... ", .. = :;:: 2..B s s., ." c:: 0;= ::!!(3 Z'" oJ"" Zm "'< 0?2 "tic:: --!:! :to mz >> :jz 00 ;=1"" Zm mC'l -<> Cll"" mm Z"l'l ;;il >q I"" o "l'l g " Z m 0( Cl m Z m " > I"" Vi Cl ;= m ~ o ;= o o ." Z o z CI> '< o I"" C 3: m C\ Qll \0 Qll ~ !::==8~~O" -i ~ a ~'~ ~ ~ l ~ 0';'" :l!~"i~~1'i 5' ::0 > -. ~ "5l ..' :. ~ ~oogli- i;'lo":l! S' ~ .. ~ ~ !l 1 i'" sr 00 !! < !I n' Q.. -, l!i .., Q.. 2. l:; a ,g "" a ... c... 5 "" S" ~ <:r=10" :rOOC a: "'. II ~ g ~ III 52: a &.;l 5' - ; 10" ~ :l S' 2" 5' S" lf ~ a Q.. S'" ;: ~ Ill' 9 :J '< 0(0- 2' :r ~ II a :- ~ i::i ~'''! a9-_if<T' if:r S i." > g: ~ 9 Q. ~ 'B~a-:::2..~:Tg"5l 2; ~ =: 1 ~ :l! ~ ~ ~. ~ _. ~ 5" a ~ - .. 2. ;. "" !ll -. a 2.. 0 .gi~~~'B~"i S'" ..... ~ li" a Co ~ 5' ~. !'l ~ 2. { :;. ~ i ~ ~: r t i ~ i f ift ~9-'B g> l ~ i 0: ~ f~: i ~ 0( 5 !! ~. 8' ~.3 1- ~ 2.;. 5' ~ ~ If:>ilo;l-Qa ~a-if~Ai3 ;, ; .. . ~ !/ 2.j; ~ u 'o~$~ ~ ~ .~ J ~ ~ \,J _ _ """ . -5~ .0\ ~ .5 ; 1 ~ ; ~i 6 ~ E ~ Z .. ci. .5 . \,J l:i Co. .. C 6 - -c; !S ~cl ~~ 1 ~E:: 0 w.,,_ !S e 6 ~ .:: C ~ ~ ~ = w ~ ::I. 6 ~ ljj$ ~t'i~ : e ~ i ..2 ::; -= ~ W -< Ii ~ ~~..c"'" ~ ~ ~ ..! 6 c ;: " 1; .~ :~ & :/ 1 ~,.; .<: 0.<: .~] a ~ ~~'o..... 4J.o . " it: &. f ~ ~g~~ i 6 ~ t' ~ 1:: < o .. ~ 8 II .:: t: .s. ..!: 0 ~ ~ ..'" > CCl .. c .<: .- e~ s~ \,J .. ~~ = "0 .5 >- "8 J > ." .. ~ ] 6 ~ ~ >- 0 .. lC ~ ~ < ClO . ." 's ~ ~ Co. ._, < ~ ~ . ....!!a -6'0"'" ,-w\C 0.<: ~ WI .SO ~ .~ ~ ~ .5 IJ- 5--= ~ u t- t ..c =:::: ..... v ~ ~ 0 . ::I C > 8-8"i '-." " P ; ~ .5 ~ ~ r ~ 'iI ~ _ ..Q ::I 0 e . t: ;: ... e ~.5! ~ e 82~ ~li '0 .s ~ s ~.r j '... 1! !S i::: lC. lei .~ .~ ~ ~.~ i e i leo~.s lie~ :0 u'" < i': s --.::: w-=~ -;ll~.<: g E'c u."..o.~ ] ~ !: l! S!fl ~ ~ {Q _ _.=" ii~ ~l~t :~j ~ l~ 0 ~ '.., ; . ~ t' -= E .! ~ a ~.~ ~ ~ i E=::I ~ l!"'.... ~t-~ o ~ ~ .. 0 \C g'2 ~ -- '" ~ :F ~ ;Jl'c .- .,,", t' t ~ O "" 'e- ~ 1 t: co ~ ~ cO ~ ~ .; 0\ 0 8 ~ :::...- cc ~ c 2 1! =i - ." \,J '" < "' 08.. J l:i'f."'::::,~,.;..r g'o1 ,.; 6... ~;~.:,,~ 'c ~ ~ ~ ~ IS ~ !! Q 0 ~ ;;; .lS..j ~, i:: i':-,.; >- 5,.; g.r ci. o - .. i! "'... .- -C) .Q., tool ~ ~ ~ ~ F; WI ~ .5 """ < """2" Bp o..~ Co.~. F ~ .~ l:!:t :< lfl 1:: 3 ~ P ~ . . ...... WI _ . _ < V') _ . _u ~ \C g ~ . :!;! ." .2- .~ .... .=:l ~ ~ ~ :; J:: c c ~ : . 8~~-~:88;c :5 ~ ~ ~ : ~ ~ ~ ] .~ Q., l"I..c .-... ...._ c .... ~ (;.~.5 : 1 ~ &"; : ';; -= :J: 5' - .. c.... .= = t .c.~ 'E ~..; 1 ~ :: E ~ E :: ~.~ ~ lJ 8 ~ L'~~S~ott~~ t'.- .. c'<: E c...:: " ;:; E-w,,'-' o.<:~'" 8<~~~g1;Sig>- ... CIQ - .- c ~ ....- .... < ~ >-. e- ~ .2 :; ..! .5 E ;-...cE~~o"g.S '- ~.~ ~ ; E -: ~ ~: -< o ci.. 0 < ~ .- c..c :; ~ !Jt Q. ~ "'C ~.- Co.. :i < l.- N '-1 _ &..2 Cool 0 ~'" ....: '-1.c ~ ""....All: .5 \.l - t: -u '"5 e ::J .~ ~ Q. -S :"E g ""' ~ ~ g .5 -S ~.5 [ ~ r-.. .~ (~ ;.5 ~ .=.." " "'-..Q"'" Eoo~~ -! - e .." ..c._.__ -W'"'I.""NO ,,_'" ~oo... '<:-'=E,,= Q.~oN~St""Oe .7~..c~...li:""..c C c ~ ~ ::J - ~ ~ "" ~ .5 .2 ...0.!~"'O=-~ ~:.~ c ~ - "" .. ~ ~ ~ "" -a ~ ~ g ~ ..c .5 S.~ ~ 5~i'_c~~fE~ C ~ C :; " ~ fj .; ~ = - ".2 8 >. .. ~ 0'" ~ ..1o.J 5~:; ::::J !:: 0" ~ ~ .~ ~ :=5 .~ :.,. -; ~ i < ~ g r- u ~ g .9 "'" ..; ~ ~ -E ~ ~:5 E ~ ~ ~ ~ :: 0 ~ g..:;; -6 ~ ~'Ot:>~~~ ""'0 u ~ '"- ~ I V tJ .. ~ " "-0 ...E "'~ . l:i >0 l:i..Ev>_",. 6 .~ ~ .. e-." '" ;:: ~ :a ... ~ :; C ." '" t' ~ Jl .~ ~ j ") 6 8 ~~ i!! ~ .= ~ ~ ~.s .~!5~~ ~ s:: .! -g it 1 ~ = w ~.- 5'" .... W '0 :J 8- ~ .~ i ~ i !ii :/.!! .= .! - ":' ~ 1 g .8 g '; 1 ~ 't ~ :~ !:s .t f i i 6 ~ ~ e-~:e ~ ":' > ~ ... ~'" ~ 11 ...-;: ;' ;Jl]~~.g; o " = 6 - II ~ '" w ..... .. ~, ! ~.~8~~~!-.~ .. .!I c - ";' -.! -; > !:.!5'" '" ~U .. CCl. t: ~ '" ! '" '" -; !i<~"':::!i: ~ .!:. = ~ 1! ~ ~ . '" _" . .<: w.e _ '" > ~ i ~.5 11 0\'" .i::::. "' . E ~:5~") iil~ j c! 11'00 - ::::. ~ ~ E E .s ." ~ 1 .1:: ~ ~ ~ c ~ lie.S - .~ > -of "I>O::I~ ~ ~~1~@ [~ Q c. ~ ~ I<l o Z. < l:i > 5 .~ :.: t' Z C :J: g Q,< ~ .... '" ~ .. ~ .;; - ,...: f f'f'"\ :/ ~ 1 i ~ < ~. a .~ .~~ .~ ~ ~ ow'" .. .. '" " ..- E lier- 6 8 ~ll ~l~ 5 ~ ~"5~ .~.,,~. ~ .!! "" ~ ~ g g ~.~ i .s~'o!.8""~d "'1;1~ -" ;..."'..,,- swi~\'i ""1! '- .::. '8 .!i~1fi1!al i >- . ].~ i ~ ") ~ o ~ l! .. Q" '" .50'" a ]jJ :; l~lj :ii'o:::-~::::' 5' -."." f~ fl 6& 1 = - ~ =.5 J ; 'j g N ") .~ 6 - t'" J! _.il j ,.; il'i .. '0 ~ .r ~ ! a .1 l:l 'Il ~ ~ e i CCl e ;,'" - 1~ ~ 1l r~s~"'~ .;: ~-<; s r~ ~ = .5 \'i 'f ~.~ ~.~ '0 ~ II ~ .. "'." . - ." l! ~ "'-] g:'::~~.J2 .s~ia .e ~ .!I". Q. '- 1 :/_.<: t: 0 v " - ... ..< i ~.!"'!>>l" ~ .511 ~ i~ ~ {! :!2 .5 0\ ~ w S E fa .8 2 .! '5.. J ~ ! ~ '" "' <.l!I ~ 11E.g j Q = ~ ~ >-l - '0 w .5~a~ - >- -51Cl;.i.:l is ---1 .!t", ~el1!~~ . ~;;~ .s~13 .~ e ~! 2- 8 :! '0 ..;- ...,.... ~ ~l!:. 1i;i~ .. i ~ r t~, ~ ei~1! ...~iS ~ ..'" ~~ ~ .~ i ~ J - 8 6 'Il i.!! · ~::::. e o..! .s rp-c r ~11 .j :/ E \,J.!:! ~ ~- 'Il -al ., l i i;;jtj~ 8 :; ~ S] .~.s 1 ~~.<:- ~~ ii . 'I ~d 11 .~ '0 ~ ~ 'i 'i "'~ ~ ~;~1~ w "5 ~ ~-- ,;- ; till i ::e "' .- . j .5 ~ _ ~ ~ .l!I :! j J r '1 >- ~~ '0 .~} ~ ~.! ~ ] ~ . . .- ,.g i = I ~ -: . 1 ~ i :~ ~ ~ .2 II l:~ ;j l;iif . 1.5 ~! I j] ~ l:i ' ..1! · ~.:: ~ ~ ~ .~ ~ -s . '" 6 .!i :/ J!..! f'll ~, !j . 1:: 1.J~~ a"" ~ 2 Q"W~]:iI:::'" .., =.5 - ~ .- d & < \'i 5.l!I ~ ~ .. 'g 1 ": . . ~ ~ t' ~ !! ~ \,J:! .5 1 HI!d .~ ~ ~ '" : r~ '8, .~ 1'" .~. ~ ~ ~ . ij~~ ~'oE~S :~ _ .2. "'." . < ~ 2 i .51 =~ ~~'~ r - II Ii ' '= .! w i ~ ~ .: ~'o g ~ . ~ . < ; ~ ~ 1 .e .1:" - I ... ';; l'~'~ '> w ~." '>1'1 '" l ~ ~ .- ~ E .~ ~ E ! j 1 '0 ~ .5 ~ .! ~ < j ~ 'i &. ." 5'~ '" - ..: ~ .~ . l! t ",.., .s E" \J - . . .~ e I ~ ~ t:l fo -.! :J5 ..~15._"] s::]~ ~ ~ 1 r~ " .~ .~ j N ~ ~ .s ,.; ~ ~ " w t:l ~ ~ .... 15. 5 'r ~ ~. '0 ~ '.J.s~,!l\,J~i:::::. :/ ig~a; \c' 1 i .- ~ ~ .. .c . r"" 1:: w \,J '" 1~.se~ =1 .,,~~"'-;o .. ~ ~ j e '0 .s ~& g ~ .2-.5 ") ~ ; i ~ ~ ~ ~ 1:: E -a 1;- .sc!~ -'.t .~ ~ l:i w..] :~ ~ ~ N ~." E 1:: - !!EE~ 18'0 :~ ~v · ~jl~=~" 13 e 91.s' ! ~ g~~", ]<~ :/ 'i-ll l:! -; .~ .5 &,':: .l!I ~ >-. ~ ~ w '': .~ "" ~ wE- 15. EW:;~~J~ w ~.~ II .l!I ~~~ . .. ~11 ~ E ~ l -.! ti g .. " o .e 2;;;g. CCl"l!~~ W ".<: 6. < ...... e! ~'ji .s ~ 'c .~ :< c ~ ": .~ ~i= - . 8 v - 5 = .~ = ,~ e ~ :g:e~,^~ . tit 5 .:: e ' c - - t'll N' c...... ::l .- " ..:'0 ~ 's ...- ClO ~ .- " ~ ~ .. = '" .. \,J 6 t:i < '" \.i .<:l a.... 0 2 .. .. .. ~ g Ii c .- > "'t:l 0\ -. '^ [; ~ l:i .. :a .. - '" &. " ~ :J: .;; e2~ .. ...,.~ = 8 ~ :a "i !a.;::::. ~~e,.; t ~ -= .l!I ~ .<: .5 6 J =;e . " /' ,/ .: ~ . CIT ERN ARD IN 0 300 NORTH "0" STREET, SAN BERNARDINO, CALIFORNIA 92418 JACK STRICKLER Councilman, S.venth Ward (714) 383~ December 17, 1986 Honorable John Van de Kamp Attorney General state of California 1515 WK" street, suite 511 Sacramento, CA 95814 Dear Sir: Please peruse the attached information and furnish an opinion regarding the proper representation our City Attorney is to provide to the Common Council. Several Council Members are of the opinion that the City Attorney is attempting to shirk his responsibilities. Thank you very much for any assistance you can provide in this matter. J K STRICKLER enior Council Member JS: jv Attchs. cc: Mayor Evlyn Wilcox Mr. Ralph Prince, City Attorney Mr. Ray Schweitzer, Acting City Administrator " CITY OF SAN Br~NARDIt\'" - MEMORANL JM To Hon. Mayor and Common Council Subject Legal Representat ion in Conf 1 ict of Interest Cases From Ralph R. Prine. City Attorn.y November 19, 1986 Oat. Approved Oat. 700.1, 700.61 The Political Reform Act of 1974, Government Code Sections 81000, et seq., contains provisions for enforcement in Chapter 11, Sections 91000, et seq. The At~orney General is responsible for enforcing the criminal provisions of the Political Reform Act of 1974, and the District Attorney has concurrent powers and responsibilities. Section 91001 provides that the District Attorneys are the civil prosecutors with respect to any agency other than a state agency. Government Code Section 91001.5 provides as follows: -In any case in which a district attorney could act as the civil or criminal prosecutor under the provisions of this title, the elected city attorney of any charter city may act as the civil or criminal prosecutor with respect to any violations of this title occurring within the city.- Although Section 91001.5 provides that the elected city attorney of a charter city m~y (discretionary) act as the civil prosecutor, there may e occasions when the District Attorney would request the elected city attorney to act as the civil prosecutor or the public interest may mandate that the city attorney act as the prosecutor. The past practice of this office has been to endorse the enforcement of th. civil penalties and remedies and criminal provisions of Titl. 19 by the District Attorney and the Fair Politic~l Practices Commission because of their expertise in thes. specialized fields of prosecution. However, Section 91001.5, which authorizes the elected city attorney of a charter cl_y to act as a civil or cri.tnal prosecutor with respect to any violations occurring within the City, does present a problem of representing conflicting interests when the Office of the City Attorney obtains facts and renders legal advice to a city official concerning a possible conflict of interest. Recently, the California State Bar publicly reproved Ira Reiner, Los Angeles District Attorney, for violating professional rules of misconduct (. ., ... elry Oil rH.=M~ ". Hon. Mayor and Common Council November 19, 1986 page 2 while serving as City Attorney because a city official conferred with a member of his staff concerning a possible conflict of interest and a superior Court judge ruled that any evidence developed during what the court termed an attorney-client relationship was tainted and could not be used against the city official. The State Bar determined that Rules of Professional Conduct 4-101 and 5-102(b), concerning representing conflicting interests and accepting employment adverse to the interests of the client, had been violated. In order to avoid entanglement with the rule concerning the representation of conflicting interests, the policy of the City Attorney under Government Code Section 91001.5 and Government Code Section 1090 will be to represent the interests of the City of San Bernardino, a municipal corporation, and the Community Development Commission, a public body corporate, in connection with the rendering of legal advice to city and commission officials concerning conflicts of interest under the Political Reform Act of 1974. (Title 19) and Government Code Section 1090. In accordance with this policy, all requests for legal advice concerning possible conflicts of interest will be referred to the Mayor and Common Council (or the Community Development Commission, if appropriate) at a public meeting for direction to render such legal advice on behalf of the City of San Bernardino or the community Development Commission to the Mayor and Common Council. Such legal advice would be given at a public meeting of the legislative body or would be addressed to the Mayor and Common Councilor commission and become a public record. In the event any city officer, other than the Mayor and Member. of the Common Council, request. l~al advice concerning a possible conflle~ of interest, such officer would be requested to ask the Mayor and Common Councilor Commission to direct the rendering of such legal advice with the understanding that the advice would be to the Mayor and Common Council as elected representatives of the City of San Bernardino, a municipal corporation, or the Community Development Commission, a public body corporate, and that the municipal corporation or public body corporate would be the only client of the attorney rendering such legal advIce. 11/19/86 Ron. Mayor and Common Council November 19, 1986 Page 3 I hope that this policy will meet with your approval and that it will serve the best interests of the City of San Bernardino and its citizens. /~~~. RALPH H. PRINCE City Attorney RHP:lr , ..-. .. 11/19/86 CITY OF SAN BflNARDIN - MEMORAN(}dM~ To Jack Strickler, Chairman tlTl C;: S.ti t[:\!iAi.~:~a Legislative Review Committee Subject Legal Representation in Cot)n~m 15 P:1 4: 17 of Interest Cases . Il".... . .~_ From Ralph H. Prince City Attorney December 12, 1986 Date Approved Date 700 . 6 l, 760. 3 In accordance with your disapproval of Item No. 1 and the discussion at the meeting of the Legislative Review Committee held on December 11, 1986, concerning legal representation in conflict of interest cases, the following proposed policy is set forth: .,.-- -A council member who desires legal advice concerning a possible conflict of interest shall discuss with the City Attorney the establishment of an attorney-client relationship concerning legal advice. In the event the City Attorney determines under Government Code Section 91001.5, which empowers an elected city attorney of a charter city to act as a civil prosecutor with respect to any violations of the Political Reform Act of 1974, that providing advice to the council member might constitute representation of conflicting interests under the Rules of Professional Conduct of the State Bar of California, he shall so advise the council member and request a waiver of confidentiality. If the council member prefers not to waive confidentiality and desires attorney services rendered in confidence, such council member may request the appointment by the City Council of outside special counsel to render such legal advice. The City Council shall determine, with the recommendation of the City Attorney, whether special counsel shall be retained at city expense to advise the council member. An attorney-client relationship will be established between the council member and the outside special counsel retained for the purpose of rendering a legal opinion concerning the possible conflict of interest, and the client shall have the right to keep such advice as confidential and privileged.- Although I do not concur with the above proposed policy, I . can understand why a council member would feel the necessity under certain circumstances for such a policy. The policy appears to be legal under the Charter and the Government Code sections involving conflict of interest matters. ,1/ '/~ C /'(~/I~~- RALPH H. PRINCE City Attorney RHP : 1 r cc Councilman Gordon Quiel Councilman Jack Reilly , .\ " ! , , the general supervision of all City officers elected or appointed, except Councilmen, He shall have power to discharge any City appointive officer or employee, for dereliction, neglect or non-performance of duty, except employees in the classified service, and may suspend any employees in the classified service pending a hearing before the civil service board. (Section 52, as amended by a special election held on the 4th day of November, 1924.) (Section 53 repealed by election held on the 7th day of June, 1966 and approved by State Legislature.) , City Attorn.y Section 55. (a) The office of City Attorney shall be a full-time position, and the incumbent shall not engage in private practice. (b) To be eligible to hold the office of City Attorney, the person elected or appointed shall be an attorney at law, duly licensed as such under the laws of the State of Califor- nia, and shall have been engaged in the practice of law for at least five (5) years prior to his election or appointment, and shall have been a resident and elector of the City for a period of at least thirty (30) consecutive days next preceding the appointment or the filing of nomination papers for election to the office. (Section 55 (b) as amended by election held the 2nd day of November, 1976.) (e) In the event a vacancy shall occur in the office of City Attorney during his term, such vacancy shall be filled by appointment by the Mayor and Common Council, which appointment shall be valid until the next general municipal election, at which time a City Attorney shall be elected for the remainder of any unexpired term, or for a full term in accordance with Article II of this Charter. (d) 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 re- quested to do so in writing by the Mayor or Common Council or other City official upon any matter pertaining to municipal affairs; and otherwise to do and perform III services incident to his position and required by statute, this Charter or general law. .. . . (Section 55 (1) amenrfed by election held April 13, 1971 and approved by State Legis- mture.) Power to Discharge or suspend City Attorney Duties of " (e) The salary of the City Attorney shall be fixed by the Mayor and Common Coun- Salary eil. but shall not be less than seventy.five hundred dollars ($7,500.00) per annum. He shall be provided with office space and equipment, and clerical help by the City. -14- (f) Section 24.C of Article I I of this Charter is hereby repealed. (g) This amendment of Section 55 of the City Charter shall go into effect on the second Monday in May, 1959, unless a vacancy shall occur in the office of the City Attorney subsequent to the municipal election of April 12, 1955, in which event it shall go into effect immediatel.,. upon such vacancy rising. (As amended by election held the 12th day of April, 1955.) City Clerk Section 60. The duties of the City Clerk shall be to keep the corporate seal and all City Clerk, books, papers, records and other documents belonging to his office, attend all meetings Duties of of the Mayor and Common Council and keep a journal of the proceedings. He shall have full power and authority to take all affidavits and arj;ninister all oaths necessary in the transaction of city business, but shall make no charge therefor. His official books and records shall be kept properly indexl:1d and be open to public inspection during office hours. He shall number and keep a record of all demands allowed and certified to him, showing the date of approval, to whom the same is allowed, the nature of the claim, and the fund out of which the same is payable. He shall issue all licenses and countersign all warrants on the City Treasury, except warrants of the boards, and shall do and perform all other acts required of him by this Charter, or by ordinance, or which may be required of him by the Mayor and Common Council. (Section 60 as amended by election held the 4th day of February, 1969 and approved by the Legislature February 25, 1969.) City Assessor (Section 65 repealed by election held on the 6th rfay of February, 1973 and approved by State Legislature.) Treasurer Section 70. The Treasurer shall receive and payout all moneys belonging to the Treasurer, City, and shall keep an account of all receipts and expenditures, under such rules and Duties of regulations as may be prescribed. He shall make a monthly statement to the Mayor and Common Council of the receipts and expenditures of the preceding month, and shall perform all duties required of him by law and the Mayor and the Common Council. He shall not payout any monies belonging to the City except on claims presented, allowed and submitted in the manner provided by this Charter. . (Section 75 repealed by election held..on the 6th day of February, 1973 anrJ approved by State Legislature.) . (Section 80 repealed by election held on the 2nd day of November, 1976.) (Section 81 repealed by election held on the 2nd day of November, 1976.) (Section 82 repealed by election held on the 2nd day of November, 1976.) -15- ,...'1 -~ P. O. Box 944255 Sacramento 94244-2550 elii iJf <. - .....fi v>'} ,.- "'I .'....t),Ha 1986 DEe '( g AM ~J: 59 ~-u~ ~S JOHN K. VAN DE KAMP Attorney General State of California DEPARTMENT OF JUSTICE 1515 K STREET, SUITE 511 SACRAMENTO 95814 (916) 445-9.555 December 24, 1986 Mr. Jack Strickler Senior Council Member City of San Bernardino 300 North "D" Street San Bernardino, CA 92418 Dear Mr. Strickler: This is in reply to your December 17 request for "an oplnlon regarding the proper representation our City Attorney is to provide to the Common Council". The opinion function of the Attorney General is limited to providing opinions to state officials, district attorneys (and county counsels) and city prosecutors (limited) to criminal law questions). I have attached materials which explain the Attorney General's opinion functions. Since the Attorney General has no authority to provide opinions to city officials on civil law questions I must respectfully decline your request. It may be of some interest to know that this office is preparing an opinion on the question whether a county counsel has a duty to provide a legal opinion to an individual school trustee (Op. No. 86-404) requested by the County Counsel of Solano County. Sincerely, JOHN K. VAN DE RAMP ne i?tU ACK WINKLER Assistant Attorney General Opinion Unit JW: lrh Attach. ~