09-30-09, The General Council for the First Amendment Coalition Responds to Question Regarding the Intent of the “before or during” Wording of the Brown Act

 

 

Dear Mr. Weber:

 

The general rule when a court applies a statute like the Brown Act is that if the statute is clear, then the court should not look to legislative intent.  See, e.g., Prachasaisoradej v. Ralphs Grocery Co., 42 Cal. 4th 217, 227 (2007) (Whenever [a court] construe[s] ... provision, [it] look[s] first to its words, assigning them their usual and ordinary meanings, and reading them in context.  If the words themselves are clear, we assume they mean what they say, and the plain meaning governs.”).

 

In any event, the only legislative history I could find of the amendment to the Brown Act that added the words "before or during the committee's consideration of the item," (SB No. 100, 1991 Reg. Sess.), does not shed much light on the issue:

Under existing provisions of the Ralph M. Brown Act, the actions of legislative bodies of local agencies are required to be taken openly and their deliberations are required to be conducted openly. Under this existing law, every agenda for regular meetings is required to provide an opportunity for members of the public to directly address the legislative body on items of interest to the public that are within the subject matter jurisdiction of the legislative body. However, in the case of a city council or board of supervisors, that opportunity need not be provided if an opportunity to address a committee of the council or board considering the item has been provided, unless the item has been substantially changed.
   

This bill would provide that the opportunity of the public to be heard on an item shall be provided before or during the consideration of that item by the legislative body or committee of the legislative body.

1991 Cal ALS 66

Sorry not to be able to provide anything along the lines you were looking for.  Good luck.

 

Sincerely,

Katherine Keating

Katherine Keating
Holme Roberts & Owen LLP
560 Mission Street, 25th Floor
San Francisco, California 94105-2994
415-268-1972 (Direct); 415-268-1999 (Fax)
katherine.keating@hro.com


From: halweber@earthlink.net [mailto:halweber@earthlink.net]
Sent:
Wednesday, September 23, 2009 7:56 PM
To: Katherine Keating
Cc: Francke - Terry; Scheer- Peter
Subject: RE: Hotline Form Submission (Our Ref. No. 51221-00010)

Katherine:

 

Thank you for your reply to my Hotline Submission.

 

Without providing legal advice, can you tell me the intent of the authors of Brown Act Section 54954.3 (a) " Every agenda for regular meetings shall provide an opportunity for members of the public to directly address the legislative body on any item of interest to the public, before or during the legislative body's consideration of the item, ........"

 

Was the intent of the authors to allow a legislative body to select EITHER "before" OR "during" for permitting the public to address the legislative body, or was the intent of the authors to allow the public to address the body BOTH "before" AND "during" agenda items, despite the actual wording?

 

Sincerely,

 

Harold Weber

halweber@earthlink.net

 

 

----- Original Message -----

From: Katherine Keating

To: halweber@earthlink.net

Sent: 9/23/2009 6:22:09 PM

Subject: RE: Hotline Form Submission (Our Ref. No. 51221-00010)

 

Dear Mr. Weber:

Holme Roberts & Owen LLP is general counsel for the First Amendment Coalition and responds to First Amendment Coalition hotline inquiries. In responding to these inquiries, we can give general information regarding open government and speech issues but cannot provide specific legal advice or representation.

Thank you for your message, which I assume you sent for informational purposes only.  Best of luck.

Sincerely,
Katherine Keating

Katherine Keating
Holme Roberts & Owen LLP
560 Mission Street, 25th Floor
San Francisco, California 94105-2994
415-268-1972 (Direct); 415-268-1999 (Fax)
katherine.keating@hro.com

 

-----Original Message-----
From: halweber@earthlink.net [mailto:halweber@earthlink.net]
Sent:
Friday, September 04, 2009 5:08 PM
To: hotline@cfac.org
Subject: Hotline Form Submission

The form below was submitted by halweber@earthlink.net from Ip address: 67.142.130.13 on  09/04/2009 at 08:07 pm
-------------------------------------------------------------------------

name: Harold G. Weber (Hal)
address:
414 Arden Avenue, Apt. #1
business: 
city:
Glendale
state: CA
zip: 91203-1114
phone: 818-547-1296
email: halweber@earthlink.net
Have_checked_Q&A?: Yes
member: No
haveused: No
ifyes: The same.
message: I have sent the following e-mail to Glendale City Attorney Scott Howard regarding what I believe is a violation of the Brown Act by Mayor Frank Quintero:

Glendale City Attorney Scott Howard:
Copies to:  Mayor Frank Quintero, Council Members John Drayman, Laura Friedman, Ara Najarian and Dave Weaver, and City Manager Jim Starbird

Reference:  California Attorney General Opinion No. 92-212, May 7, 1992 (http://www.cfac.org/AGOpinions/opinion_75_89.html)

From the above reference:
“(a) Every agenda for regular meetings shall provide an opportunity for members of the public to directly address the legislative body on any item of interest to the public, before or during the legislative body\'s consideration of the item, that is within the subject matter jurisdiction of the legislative body, provided that no action shall be taken on any item not appearing on the agenda unless the action is otherwise authorized by subdivision (b) of Section 54954.2. However, in the case of a meeting of a city council in a city or a board of supervisors in a city and county, the agenda need not provide an opportunity for members of the public to address the council or board on any item that has already been considered by a committee, composed exclusively of members of the council or board, at a public meeting wherein all interested members of the public were afforded the opportunity to address the committee on the item, before or during the committee\'s consideration of the item, unless the item has been substantially changed since the committee heard the item, as determined by the council or board.”

According to the above content from Opinion No. 92-212 by Attorney General Daniel E. Lungren, Mayor Frank Quintero has been violating this provision of the Brown Act by refusing to allow members of the public to address the Glendale City Council on agenda items unless they announce their desire to do so before consideration of the item commences.  Members of the public have no way of knowing beforehand everything that is going to come up during an agenda item presentation to which they may take exception, and therefore wish to address the council.  For that reason it is essential that members of the public be allowed to announce their desire to speak on an agenda item during its presentation.

Please advise Mayor Quintero that his newly invented method of denying the public its right to address the city council is a violation of the Brown Act.

Sincerely,
Hal Weber, (halweber@earthlink.net)
 
Submit: Submit
protectwebformcode: poloce