HomeMy WebLinkAbout07-City Attorney
~~ITY OF SAN JECNARDINOo-
AEMORANDU::J
To HONORABLE MAYOR AND COMMON COUNCIL From
JAMES F, PENMAN
City Attorney
June 8, 1987
Subject Violation of Charter Section 55 (d), Date
Risk Management supervision of legal matters
Approved Date
700.18
Section 55 (d) of THE CHARTER of the CITY OF SAN BERNARDINO,
STATE OF CALIFORNIA, reads (in pertinent part) as follows:
"The City Attorney shall be the chief legal officer of the
City; . . . he shall represent and appear for the City in all
legal actions brought by or against the City, .. " (emphasis added).
The Mayor and Council of the City of San Bernardino have, in violation
of the above quoted Charter section, and, consequently, in violation
of State law and the Constitution of the State of California, assigned
numerous legal duties to the Risk Management office of this City.
Said legal duties include, but are not limited to, non-attorney
supervised investigation of legal claims filed against the City,
decision making on claims and potential and actual lawsuits, hiring
of attorneys in liability and Workers Compensation cases, making
recommendations to the Mayor and Council on the settlement of law
suits and potential lawsuits (in violation of the Charter mandate to
the City Attorney that " . . . he shall represent and advise the
Mayor and Common Council and all City officers in all matters of law
pertaining to their offices; . . ." Charter, Section 55 (d), emphasis
added), working and settlement of Worker's Compensation cases,
giving legal advice to departments and other City employees, and
doing all of the above without the advice, consultation with, consent,
and in the face of the opposition of the Office of City Attorney.
The manner in which other cities administer their risk management
programs and/or the issue of which administrative office is assigned
to supervise risk management functions in those cities is irrelevent
to this City. Likewise, the issue of insurance company reviews and
preferences as to who represents the City is also irrelevent to
our unique situation. Those factors are irrelevent because our
City Charter makes it clear that the City Attorney shall conduct and
be responsible for all leqal actions and advice in this City. The
Constitution of the State of California, as well as State statutory
law, gives our Charter the full force and effect of State law.
Numerous Federal and State Supreme Court decisions dictate that the
word, "shall", as used throughout the above-cited Charter section
is mandatory language and is not permissive.
The Mayor and Common Council have two legal options today:
1. Remove all legal functions assigned to the City Attorney
by the Charter from Risk Management and place them under the
City Attorney (i.e. investigation of claims, advice and decision
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MEMORANDUM
MAYOR AND COUNCIL
June 8, 1987
page 2
making on all claims, hiring of attorneys, working and
settlement of all Worker's Compensation cases, etc.).
Non-legal department functions (i.e. safety, health, etc.)
should remain under Risk Management, or,
2. Transfer supervision of the Risk Management Office
to the City Attorney from the City Administrator as to legal
department functions (as stated in option 1. preceding) only,
retaining under the City Administrator supervision of the
non-legal department functions (as stated in option 1. preceding).
The City Attorney is not the appropriate official to supervise
safety, health and similar risk management functions.
If the Mayor and Council do not wish, as a policy matter or for
administrative reasons, to have all of the legal affairs of this
City under the City Attorney as the present Charter requires, the
remedy is to prepare a Charter amendment and present same to the
electorate. At the present time, however, it is my duty to advise
you that you are not in compliance with the Charter in the allocation
of legal work to the Risk Management office.
No onus attaches to you prior to the date of this memorandum as I
am aware that this is the first time you have received official
notification of this violation.
I respectfully advise the Mayor and Council (now that you have
been informed and placed on notice) to immediately correct this
ongoing violation of the Charter, and to bring this City into
compliance with the law.
Respectfully Submitted,
/ . f)
A.".., f rc,..~"
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/ tAMES F. PENMAN
(/ity Attorney
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COUNCIL ACTION CORRESPONDENCE
To James Penman
City Attorney
Sub~ Request to Transfer the Risk
Management Division from the
Office of City Administrator
to the Office of the City Attor-
ney
Oltt June 3, 1987
Meeting Oltt June 1, 1987
AQlnda Item No, 54
Action
The request to transfer the Risk Management Division from the Office of the City
Administrator to the Office of the City Attorney, was continued to June 8, 1987.
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City Administrator
l\i,k Management
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/SHAUNA CLARK
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INTEROFFICE MEMORANDUM
8705-1508
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TO:
RAYMOND D. SCHWEITZER. CITY ADMINISTRATOR
','
FROM: E. M. LIGHT, DIRECTOR OF RISK MANAGEMENT
SUBJECT: SURVEY - MUNICIPAL RISK MANAGEMENT PROGRAMS
DATE :
May 28, 1987
(7088)
COPIES:
MAYOR EVLYN WILCOX
-------------------------------------------------------------
In anticipation of some possible proposed organizational
changes, we discussed conducting a survey to ascertain the
Risk Management structures of other relatively comparable
municipalities. In consideration of other issues already
raised during my one month tenure with the City, I expanded
the survey to incorporate' a comparison of these apparently
controversial issues. In essence, the focus is to look at
the Risk Management reporting relationships, settlement
authority levels, and legal defense arrangements in a sample
of other relatively large California charter cities,
To avoid adverse selection or skew the results of the sample,
I chose the ten cities in the Authority for California
Cities Excess Liability (ACCEL) Pool, informally known as the
"large cities pool," plus five cities which are presently
exploring participation in the Independent Cities Risk
Management Authority (ICRMA) large cities liability insurance
pool, The result is a good cross section of cities from
relatively small Visalia to San Diego, the second largest
city in the State,
Exhibit I details the relative size of the cities and shows
the Risk Management reporting relationships. Of special
significance, in twelve of the fifteen cities the Risk
Manager reports to someone other than the City Attorney. On
the other hand, in Palo Alto and Santa Ana, the Risk Managers
have a dual reporting relationship, reporting to their
respective City Attorneys only insofar as liability issues
(we all know what the management organization experts say
about dual reporting relationships). In only one of the
fifteen' cities, however, does the Risk Manager report
directly and only to the City Attorney,
These results are not surprising.
report to top executive officers.
tiated by the following excerpt
Risk Managers should
This is further substan-
from a 1985 book entitled
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I NTE:;':OFF:::E MEMORANDUM:
SURV~v - IIUNICIPAL RISK
May ~B, 1987
Page 2
8705-1508
MANAGEMENT PROGRAMS
R i s k 1/ a :l age m e n:Lil.d..4u._~ - H ow j; 0 G u i.d..ILJ~,Ll.l:ls;,.4.l_]iQ~.ll..J:.nJU.D.j;
pub' sne~ in cooperation with the Public Risk and Insurance
Mana~~~er~ Association by the International City Management
Ass c::: ' a ~ " : n .
-If the person designated risk manager is someone
other than a person with general executive respon-
sibilities (for example, someone other than a city
or village mayor or manager, a town supervisor, a
county manager, etc.) or someone who a1 ready
reports to such a person (for example, the budget
officer), then Rrovision should be made for the
risk manager to report directly to a top executive
person. This will emphasize the importance of the
~isk management program to all local officials and
~mp10yees, It wf11 also make clear to them that
the risk manager can easily call upon a high level
of authority for assistance if other parties fail
';0 coope ra'te."
-Those with a special obligation to assist the risk
~anager include the municipal attorney, the budget
~fficer, and other persons with special expertise,
such as in property appraisal (the assessor),
safety (police officers and firefighters), engine-
ering (the city -engineer), etc."
I s-=:-cnS")' believe the va1fdity-of the above statements.
Thro~~t. Cl:! experience with the City of Pomona where I
repo:---=e::: :::rect1y to the City Administrator, I can attest to
the "'Z!::t 't~at th i s arrangement g reat1 y fac il itated my ab 11 ity
to e-=-=":::e;"'t1y perform all of the Risk Management functions.
Exhi= -~ :: details settlement authority arrangements for both
workao-s' ::ompensation and public liability in the sample
citi=. ::- the area of workers' compensation, nine of the
fift~r. ":sl< Managers have un1 imited workers' compensation
sett- ~llle"''!: authority. Three more have at least $20,000 of
authc.:--:t;)'. This is consfstent with the rating procedure of
the .::-<e:-s' compensation system which pretty much dictates
the 'S-e";";~ement value of cases, I.e., it is determined by
stat:...-:=s i!.~:: usually subject to minimal negotiation,
Inso"'~'" as liability settlement authority, the first line
authc.-'~:es range from $1,500 to $20,000, However, in eight
of tr:: f:fteen cities, either the Risk Manager alone, or in
comb'-at:or with one or more other officials, has authority
to .=;-e";t~e for $5,000. This is reasonable and is
cc~nc ::e-tal1y the minimum provided by statute under the Tort
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INTEROFFICE MEMO~ANDUM: 8105-1508
SURVEY - MUNICIPAL RISK MANAGEMENT PROGRAMS
May 28, 1981
Page 4
evidence of this philosophy and coincident goal, In ad-
dition, my short time with the City of West Covina opened my
eyes to one of the best "team work" efforts since my five
year private sector tenure as an executive with the
progressive Getty Oil Company.
The bottom line is that the City of San Bernardino either
wants a true, cost saving, Risk Management Program or just a
figurehead for a chara\l-e-. A true Risk Manager's goal is to
save the City monies which it may otherwise lose through
excessive workers' compensation, public liability, and
property losses, including expenses related thereto, i.e"
legal fees, etc. In line with this goal, the true Risk
~anager is not desirous of building an empire with attendant
costs which might neutralize, or even exceed, the potential
savings. The true Risk Manager is well versed in business
administration in order to evaluate the least cost alterna-
tives, I meet the aforementioned criteria: I am a true Risk
Management professional: and therefore, for the envisioned
good of the City and my own self consciousness, I must not,
and I will not, compromise the cr-iteria set forth for
effective Risk Management.
I will propose specific recommendations if the Mayor, Common
Council, and you appear to be receptive to my philosophy and
request such recommendations, Otherwise, as you well know,
it would be a fruitless effort and waste everybody's time at
the taxpayers' expense. Please advise.
e~-~
E. M, Light
Director of Risk Management
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C I T Y 0 F SAN B ERN A R DIN 0
INTEROFFICE MEMORANDUM
8705-1508
TO:
RAYMOND D. SCHWEITZER, CITY ADMINISTRATOR
~
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0"
"
.......
FROM: E. M. LIGHT, DIRECTOR OF RISK MANAGEMENT
SUBJECT: SURVEY - MUNICIPAL RISK MANAGEMENT PROGRAMS
DATE:
May 28, 1987
(7088)
COPIES:
MAYOR EVLYN WILCOX
In anticipation of some possible proposed organizational
changes, we discussed conducting a survey to ascertain the
Risk Management structures of other relatively comparable
municipalities. In consideration of other issues already
raised during my one month tenure with the City, I expanded
the survey to incorporate a comparison of these apparently
controversial issues. In essence, the focus is to look at
the Risk Management reporting relationships, settlement
authority levels, and legal defense arrangements in a sample
of other relatively large California charter cities.
To avoid adverse selection or skew the results of the sample,
I chose the ten cities in the Authorfty for California
Cities Excess Liability (ACCEL) Pool, informally known as the
"large cities pool," plus five cities which are presently
exploring participation in the Independent Cities Risk
Management Authority (ICRMA) large cities liability insurance
pool. The result is a good cross section of cities from
relatively small Visalia to San Diego, the second largest
city in the State.
Exhibit I details the relative size of the cities and shows
the Risk Management reporting relationships, Of special
significance, in twelve of the fifteen cities the Risk
Manager reports to someone other than the City Attorney. On
the other hand, in Palo Alto and Santa Ana, the Risk Managers
have a dual reporting relationship, reporting to their
respective City Attorneys only insofar as liability issues
(we all know what the management organization experts say
about dual reporting relationships). In only one of the
fifteen cities, however, does the Risk Manager report
directly and only to the City Attorney,
These results are not surprising.
report to top executive officers.
tiated by the following excerpt
Risk Managers should
This is further substan-
from a 1985 book entitled
1
,
c
o
o
~
INTEROFFICE MEMORANDUM: 8705-1508
SURVEY - MUNICIPAL RISK MANAGEMENT PROGRAMS
May 28, 1987
Page 2
B..llk__~M~~JIUlllt Today: A-Holi__1~ll.d.~ for U)c'A,LG.QYli.nmu1
published in cooperation with the Public Risk and Insurance
Management Association by the International City Management
Association.
"If the person designated risk manager is someone
other than a person with general executive respon-
sibilities (for example, someone other than a city
or village mayor or manager, a town supervisor, a
county manager, etc,) or someone who already
reports to such a person (for example, the budget
officer), then provision should be made for the
risk manager to report directly to a top executive
person, This will emphasize the importance of the
risk management program to all local officials and
employees, It will also make clear to them that
the risk manager can easily call upon a high level
of authority for assistance if other parties fail
to cooperate."
"Those with a special obligation to assist the risk
manager include the municipal attorney, the budget
officer, and other persons with special expertise,
such as in property appraisal (the assessor),
safety (police officers and firefighters), engine-
ering (the city engineer), etc,"
I strongly believe the validity of the above statements.
Through my experience with the City of Pomona where I
reported directly to the City Administrator, I can attest to
the fact that this arrangement greatly facilitated my ability
to efficiently perform all of the Risk Management functions.
Exhibit II details settlement authority arrangements for both
workers' compensation and public liability in the sample
cities. In the area of workers' compensation, nine of the
fifteen Risk Managers have unlimited workers' compensation
settlement authority. Three more have at least $20,000 of
authority, This is consistent with the rating procedure of
the workers' compensation system which pretty much dictates
the settlement value of cases, 1.e., it is determined by
statute and usually subject to minimal negotiation.
Insofar as liability settlement authority, the first line
authorities range from $1,500 to $20,000. However, in eight
of the fifteen cities, either the Risk Manager alone, or in
combination with one or more other officials, has authority
to settle for $5,000. This is reasonable and is
coincidentally the minimum provided by statute under the Tort
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INTEROFFICE MEMORANDUM:
SURVEY - MUNICIPAL RISK
May 28, 1987
Page 3
8705-1508
MANAGEMENT PROGRAMS
Claims Act of 1963. This antiquated provision in the
California Government Code allows authority to settle claims
up to S5,000 by a representative of a municipality without
Council approval unless the Council provides more stringent
guidelines, such as our S2,OOO limit adopted by resolution,
or the more restrictive Sl,500 limit still in effect in
8urbank.
Times have changed since 1963. There have been vast
increases in the cost of living and the value of services. A
mere "fender bender" in one of today's new cars can exceed
S2,OOO. Should the City Council devote its valuable time to
such routine matters when it's dealing with an annual budget
in excess of $70,000,000 and other pressing matters? Most
city councils think not,
Exhibit II also addresses workers' compensation and liability
(tort) legal representation. Who does the better, and the
most efficient, job; the City Attorney's office or outside
independent specialists? This is obviously open to debate
but is probably dependent upon the size, skill, and diversity
of the City Attorneys staff. The survey shows that nine
cities rely heavily on the City Attorney for liability
services and even for workers' compensation services in four
cities, It's definitely not an impossibilityl
On the other hand, liability insurance companies and
liability insurance pooling authorities cast a sharp eye at
such in-house arrangements, especially if they have not
proven a "good" past track record. Also, excess workers'
compensation insurance carriers are very much interested in
who is handling the City's litigated workers' compensation
claims. In fact, interest is so strong in both workers'
compensation and liability that insurance companies and
pooling authorities are certain to request resumes of those
attorneys providing the City's defense in order to ascertain
total education, training, and especially jury trial
experience. This whole issue of legal services would appear
to be a critical concern of the City at this time when it is
vigorously searching for a liability insurance market or a
viable pooling alternative.
The foregoing is not to say that I am adverse to City At-
torney involvement. On the contrary, I am a strong advocate
of a teamwork philosophy. We should all work together toward
the same goal, i.e., the good of the City and its citizenry.
To me, this equates to the best possible service at the least
possible cost, My record of mutual cooperation with the City
Attorney of the City of Pomona for more than eleven years is
c
1''"\
V
INTEROFFICE MEMORANDUM:
SURVEY - MUNICIPAL RISK
May 28, 1987
Page 4
o
:J
8705-1508
MANAGEMENT PROGRAMS
evidence of this philosophy and coincident goal. In ad-
dition, my short time with the City of West Covina opened my
eyes to one of the best "team work" efforts since my five
year private sector tenure as an executive with the
progressive Getty Oil Company.
The bottom line is that the City of San Bernardino either
wants a true, cost saving, Risk Management Program or just a
figurehead for a charade. A true Risk Manager's goal is to
save the City monies which it may otherwise lose through
excessive workers' compensation, public liability, and
property losses, including expenses related thereto, i,e.,
legal fees, etc. In line with this goal, the true Risk
Manager is not desirous of building an empire with attendant
costs which might neutralize, or even exceed, the potential
savings. The true Risk Manager is well versed in business
administration in order to evaluate the least cost alterna-
tives. I meet the aforementioned criteria: I am a true Risk
Management professional: and therefore, for the envisioned
good of the City and my own self consciousness, I must not,
and I will not, compromise the criteria set forth for
effective Risk Management.
I will propose specific recommendations if the Mayor, Common
Council, and you appear to be receptive to my philosophy and
request such recommendations. Otherwise, as you well know,
it would be a fruitless effort and waste everybody's time at
the taxpayers' expense. Please advise.
e~.~
E. M. Light
Director of Risk Management
EL/sf
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