HomeMy WebLinkAboutDocumentation_Regular_Tab 10C_12/12/1996 •
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JONES, FOSTER, JOHNSTON & STUB
ATTORNEYS AND COUNSELORS Villa
FLAGLER CENTER TOWER
505 SOUTH FLAGLER DRIVE
LARRY B.ALEXANDER MICHAEL T.KRANZ ELEVENTH FLOOR
CARL ANGELOFF JOHN BLAIR McCRACKEN WEST PALM BEACH,FLORIDA 33401
M.TRACEY BIAGIOTTI - SCOTT L.MCMULLEN
CLAY C.BROOKER DAVIO PRATT P.O. BOX 3475
JOYCE A.CONWAY JOHN C.RANDOLPH Village Manaer
MARGARET L COOPER STEVEN J.ROTHMAN WEST PALM BEACH,FLORIDA 33402-3475 O E NES
EDWARD DIAZ PETER A.SACHS b .$ 11 1 3
REBECCA G.DOANE D.CULVER SMITH M (561)859-3000
CHRISTOPHER S.DUKE SIDNEYJL STUSBS FAX:(561)832-1454 . OLFE
N.MICHAEL EASLEY ALLEN R.TOMLINSON 1933-1991
SCOTT O.HAWKINS JOHN S.TRIMPER
THORNTON M.HENRY BRIAN K.WAXMAN WRITER'S DIRECT UNE: RETIRED
WILLIAM A.FOSTER
PETER S.HOLTON H.ADAMS WEAVER
MARK B.KLEINFELD OF COUNSEL
L.MARTIN FLANAGAN
JACK A.PLISCO
November 14, 1996
Mr. Thomas G. Bradford
Village Manager
Village of Tequesta
Post Office Box 3273
Tequesta, Florida 33469-0273
RE: Village of Tequesta
Quasi-Judicial Proceedings
Our File No. 13153 .1
Dear Tom:
I am providing you with a copy of revised Florida Statute Section
286 .0115 which relates to quasi-judicial proceedings on local
government land use maters. This law took effect October 1, 1996,
and is applicable for those local governmental entities who wish to
• adopt it by way of resolution or ordinance. You will note that the
primary changes to the law which we already have in effect in the
.Village come at sections (2) (a) , (b) and (c) which are underlined.
The purpose of this letter is to simply advise you, the Mayor and
Village Council of this new law, in the event you wish to consider
incorporating this new language into a resolution.
Sincerely,
JONES, i.TER, JOHNSTON & STUBBS, P.A.
.hn C. Randolph
JCR\ssm
Enclosure
Ch. 96-324 LAWS OF FLORIDA Ch. 96-324 Ch. 96-324 LAWS OF FLORIDA Ch. 96-324
1. Provision Providing for payment in full of all payments due or to come (1) The front or square footage of each parcel of land; or
due on debt obligations, pension payments, and all payments and charges
imposed or mandated by federal or state law and for all judgments and past (2) An alternative methodology, so long as the amount of the assessment
due accounts,as priority items of expenditures. for each parcel of land is not in excess of the proportional benefits as compared
to other assessments on other parcels of land.
2. Establishment of a basis of priority budgeting or zero-based budgeting,
so as to eliminate low-priority Section 31. Section 286.0115, Florida Statutes, is amended to read:
ity items that,whisk are not affordable. ,286.0115 Access to local public officials;Quasi-iudicial proceedings on local
3. The prohibition of a level of operations which can be government land use matters.—
sustained only with nonrecurring revenues. (1W AU HORIT-. A county or municipality may adopt an ordinance
(4) During the financial emergency period, the local governmental entity or resolution removing the presumption of prejudice from ex parte communi-
cations with local public officials by establishing a process to disclose ex parte
thecommunications with such officials pursuant to this subsection section or by
prior
provisions of the United States Constitution except with open ap- adopting an alternative process for such disclosure. However,this subsection
proval of the Governor. section does not require a county or municipality to adopt any ordinance or
Section 28. Section 218.504,Florida Statutes,is amended to read:
resolution establishing a disclosure process.
j)2)( DEFINITION.—As used in this subsection section,the term"local
218.504 Cessation of state action.—The Governor hal shall•-have the au- public official"means any elected or appointed public official holding a county
thority to terminate all state actions pursuant toss.218.50-218.504.Cessation or municipal office who recommends or takes quasi-judicial action as a mem-
of state action jnust shall not occur until the Governor has determined that: ber of a board or commission. The term does not include a member of the
board or commission of any state agency or authority.
(1) The unit-of local governmental entity government:
)(3) ACCESS-nERMITTED Any person not otherwise prohibited by
(a) Has established and is operating an effective financial accounting and statute, charter provision, or ordinance may discuss with any local public
reporting system. official the merits of any matter on which action may be taken by any board
or commission on which the local public official is a member. If adopted by
(b) Has corrected or eliminated the fiscal emergency conditions outlined county or municipal ordinance or resolution,adherence to the following proce-
in s. 218.503. dures shall remove the presumption of prejudice arising from ex parte commu-
nications with local public officials.
(2) No new fiscal emergency conditions exist.
Section 29. Each countyand municipality shall annuallyprovide the De- �c The substance uf any diex parte communication with a local public
p y official which relates to quasi-judicial action pending before the official is not
partment of Transportation with uniform program data.The data must con- presumed prejudicial to the action if the subject of the communication and the
form to the local governmental entity's fiscal year and must include,but need identity of the person, group, or entity with whom the communication took
not be limited to,details on transportation receipts and expenditures and on place is disclosed and made a part of the record before final action on the
the number of miles of road for which the local governmental entity is respon- matter.
Bible.The Department of Transportation shall inform each local governmental
entity of the method and format for submitting the data.The Department of 1414 A local public official may read a written communication from any
Transportation shall compile the data and shall furnish the compilation,of person.However,a written communication that relates to quasi-judicial action
data to any interested person upon request. pending before a local public official shall not be presumed prejudicial to the
action, and such written communication shall be made a part of the record
Section 30. Section 170.201,Florida Statutes, is created to read: before final action on the matter.
170.201 Special assessments.—In addition to other lawful authority to levy 3,4e Local public officials may conduct investigations and site visits and
and collect special assessments,the governing body of a municipality may levy may receive expert opinions regarding quasi-judicial action pending before
and collect special assessments to fund capital improvements and municipal them. Such activities shall not be presumed prejudicial to the action if the
services, including, but not limited to, fire protection, emergency medical existence of the investigation,site visit,or expert opinion is made a part of the
services,garbage disposal,sewer improvement,street improvement,and park- record before final action on the matter.
ing facilities. The governing body of a municipality may apportion costa of 4.,(4 Disclosure made pursuant to subparagraphs 1..2..and 3.paragraphs
such special assessments based on: )rand--(c) must be made before or during the public meeting at which
24 25
CODING: Words strikes are deletions;words underlined are additions. CODING: Words stfikes are deletions; words underlined are additions. 251
Ch. 96-324 LAWS OF FLORIDA Ch. 96-324 252
a vote is taken on such matters, so that persons who have opinions contrary
to those expressed in the ex parte communication are given a reasonable
opportunity to refute or respond to the communication.This subsection sec-
tion does not subject local public officials to part III of chapter 112 for not
complying with this paragraph subsection.
(2)(a) Notwithstanding the provisions of subsection(1).a county or munic-
ipality may adopt an ordinance or resolution establishing the procedures and
provisions of this subsection for quasi-iudicial proceedings on local govern-
ment land use matters.The ordinance or resolution shall provide procedures
and provisions identical to this subsection.However,this subsection does not
require a county or municipality to adopt sucl an ordinance or resolution,.
(b) In a auasi-iudicial proceeding on local government land use matters.
person who appears before the decisionmaking body who is not a party or
party-intervenor shall be allowed to testify before the decisionmaking body,
subject to control by the decisionmaking body. and may be requested to
respond to questions from the decisionmaking body.but need not be sworn as
a witness._is not required to be subject to cross-examination.and is not re-
quired to be qualified as an expert witness, The decisionmaking body shall
assign weight and credibility to such testimony as it deems appropriate. A •
party or party-intervenor in a quasi-iudicial proceeding on local government
land use matters.upon reauest by another party or party-intervenor.shall be
sworn as a witness.shall be subject to cross-examination by other parties or
party-intervenors.and shall be required to be aualified as an expert witness,
cis appropriate,
(c) In a quasi-judicial proceeding on local government land use matters,q
person may not be precluded from communicating directly with a member of
the decisionmaking body by application of ex parte communication prohibi-
tions.Disclosure of such communications by a member of the decisionmaking
body is not required.and such nondisclosure shall not be presumed Dreludicial
to the decision of the decisionmaking body.All decisions of the decisionmaking
body in a quasi-judicial Proceeding on local government land use matters must
he supported by substantial.competent evidence in the record pertinent to the
proceeding. irrespective of such communications,
jay RULES. This section does not restrict the authority of any board
or commission to establish rules or procedures governing public hearings or
contacts with local public officials.
Section 32. This act shall take effect October 1, 1996.
Became a law without the Governor's approval May 31, 1996.
Filed in Office Secretary of State May 30, 1996.
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CODING: Words sirikea are deletions;words underlined are additions.
VILLAGE OF TEQUESTA
r;fdi /;�' Post Office Box 32-3 • S- Teque;t.i I)rive
;ZW. �.�� � o Tequesta, FloricL•t 33.409-02-3 • (it, ) ;;-h_2(x)
(i61) i�i?tt3
N eO
November 19, 1996
John C. Randolph, Esq.
Jones, Foster, Johnston & Stubbs, P.A.
P.O. Box 3475
West Palm Beach, Florida 33402-3475
Re: Quasi-Judicial Proceedings
Dear Skip:
This is in response to your letter dated November 14, 1996,
regarding the above referenced subject.
. It is my recollection that the Village Council adopted a
Resolution relative to quasi-judicial proceedings relative to
local government land use matters . Accordingly, I believe we
should adopt a new resolution that would cause our procedures to
comply with the new Florida Statute Section 286.0115 .
Would you be so kind as to draft such a resolution and forward it
to me for consideration by the Village Council at their meeting
on December 12, 1996 .
Should you have any questions in regard to this request, please
contact me at your convenience.
Sincerely,
Thomas G. Bradford
Village Manager
TGB/cm
c: Scott D. Ladd, Building Official, w/attachment
attorney\111996
JONES, FOSTER, JOHNSTON & STUBBS, P.A.
ATTORNEYS AND ooUNSELoRB
FLAMER CENTER TOWER
606 SOUTH FLAOLE1 DRIVE
,t I ALammI yiaumr.,QWQ ELEVENTH FLOOR
JONN Y�/�G12N WEST PALM BEACH.FLORIDA 37401
HMW F.L1yE MML
�V• a UQQ KMJIfR
Otn T L I&I FN ALtlCf.m
W C.6f10VNElI QAYIO FMTf WRY maws:*��' A.m JWA OHN c.K�NDOlr1 P.O. BOX 3476
uw.tw
..roc. P A WEST PALM BEACH.FLORIDA 7340za176
• E O E.u,KE M ONEY A. te+v bII (551)5S .3OOo ~ttfw,w�l'�
I.EKa.EY ALLEN R.�bMu1iON . FAX:(681)572-1464 .AUL C.WOIFE
�1 ear IIENp1le.rwYMA MW+m
�' U.N M.I M y MIER'S DIRECT LINE:IL WAXMAN
rM A.R
!KiF1NFg,�,p WLLIAY A.FO{Tlll
OF comm.
L YMTN FLAN11LiAI.
JACA A PUBCO
December 5, 1996 VIA FAX: 575-6203
Mr. Thomas G. Bradford
Village Manager
Village of Tequesta
Post Office Box 3273 viliaoe of Tequesta
Tequesta, Florida 33469-0273
RE: Village of Tequesta PLC 5 1996
OLfir File No. 13153 .1
\':'Tags Managers Office
Dear Tom:
Enclosed for your consideration and the consideration of the
Village Council is draft Resolution incorporating the provisions of
Florida Statute 286.0115.
Please call me if you have any questions.
Sincerely,
JONES, e
TER, JOHNSTON & STUBBS, P.A.
404
-4gi
John C.; Randolph
O'CR\ssm
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RESOLUTION NO. 4-96/97
A RESOLUTION OF THE VILLAGE COUNCIL OF THE
VILLAGE OF TEQUESTA, PALM BEACH COUNTY,
• FLORIDA, AUTHORIZING EX PARTE COMMUNICATIONS
IN QUASI-JUDICIAL MATTERS RELATING TO THE
VILLAGE OF TEQUESTA COUNCIL, ITS COMMISSIONS
AND BOARDS, PURSUANT TO THE TERMS OF FLORIDA
STATUTE 286.0115 ATTACHED HERETO; PROVIDING AN
i EFFECTIVE DATE.
WHEREAS, the Florida legislature, has amended Florida Statute
286.0115 relating to quasi-judicial proceedings on local government '
land use matters; and
I WHEREAS, the Village Council of the Village of Tequesta wishes
to adopt the disclosure requirements contained within the
provisions of Florida Statute 286.0115.
NOW, TuEREFORE, BE IT RESOLVED BY THE VILLAGE COUNCIL OF THE
I VILLAGE OF TEQUESTA, PALM BEACH COUNTY, FLORIDA, as follows:
I
Section ', The Village hereby adopts the provisions of
1. Florida Statute 286.0115, relating to quasi-judicial proceedings on
local provideI
government land use matters so as to that ex parte j
jlcommunications in regard to such matters shall not be presumed
il prejudicial.
11
Section 2. The Village hereby adopts the following 1
I' disclosure requirements incorporated within Florida Statute j
!I
ii 286.0115_
r I
1; A. The substance of any ex parte communication with a I
;.
local public official which relates to quasi-
i
d judicial action pending before the official, is not i
,I
!; _ presumed prejudicial to the action if the subject
jl of the communication and the identity of the
I I
'1
0
I
•I person,
group or entity with whom the communication
took place is disclosed and made a part of the
ii record before final action on the matter. '
B. . A local public official may read a written
communication from any person. However, a written
communication that relates to a quasi-judicial
action pending before a local public official shall
not be presumed prejudicial to the action, and such
written communication shall be made a part of the
I
record before final action on the matter. I
C. Local public officials may conduct investigations
• and site visits and may receive expert opinions
regarding quasi-judicial action pending before
them. Such activities shall not be presumed
I
'
prejudicial to the action if the existence of the
investigation, site visit, or expert opinion is
r' I
Ii made a part of the record before final action on I
i
the matter.
i
I ara
Pgraphs A, H and C D. Disclosure made pursuant to r
I
II must be made before or during the public meeting at
I
11 which a vote is taken on such matters, so that
persons who have opinions contrary to those
is expressed in the ex parte communication are given a I
i
�' reasonable opportunityr
to refute or respond to the I
i
communication.
I
II I
I.
2
H
.
I
i
i
ii
I;
Section 3. Notwithstanding the provisions of Section 2
hereof, the following provisions shall apply to quasi-judicial
proceedings relating to local government land use matters:
. A. In a quasi-judicial proceeding on local government
i. land use matters, a person who appears before the
I;
decisionmaking body who is not a party or party-
:
intervenor shall be allowed to testify before the
decisionmaking body, subject to control by the
decisionmaking body, and may be requested to
respond to questions from the decisionmaking body,
but need not be sworn as a witness, is not required
to be subject to cross-examination, and is not
required to be qualified as an expert witness. The
I decisionmaking body shall assig
n weight and •
credibility to such testimony as it deems
appropriate. A party or party-intervenor in a
i quasi- judicial
proceeding on local government land
I ±� use matters, upon request by another party or
jl I
II party-intervenor, shall . be sworn as a witness,
i 1 .,
shall be subject to cross-examination by other
�; parties or party-intervenors, and shall be required
I �� to be qualified as an expert witness, as
11 appropriate. j
li( i r
iiii
B. In a quasi-judicial proceeding on local government land use matters, a person may not be precluded
I! from communicating directly with a member of the
0
111 3
F
i�
1
1
decisionmaking body or by application of ex parte
Communication prohibitions, Disclosure of such
communications by a member of the decisionmaking 1
body is not required, and such nondisclosure shall
not be presumed prejudicial to the decision of the
• i
decisionmaking body. All decisions of the
decisionmaking body in a quasi-judicial proceeding
on local government land use matters must be
I supported by substantial, competent evidence in the
1 record
pertinent to the proceeding, irrespective of
such communications.
Sectim-1.. This Resolution shall become effective
immediately upon passage.
TIM FOREGOING RESOLUTION was offered by Councilmember
III , who moved its adoption. The Resolution
was seconded by Councilmember
_ and upon
being put to a vote, the vote was as follows:
!I FOR ADOPTWN AGAINST ADOPTION
1I
Ii 4
The Mayor thereupon declared the
Resolution duly passed and
adopted this dayof
1996.
!! i
MAYOR OF TEQUESTA
' I
Ron T. Mackail
1 ATTEST:
ii
Village Clerk
JCR\13153-01\RESOLU=I.ES(2
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{1) 'natant err square helm deeds pascal etf teems;or _
.:. .�.�, , • .• . .► , , , ,r.r.�-Trrt l ., . a .
Fears* parcetoTlandls notln excess ottlu prnpor tvnelbenelita as compared �frA T'�ratite or respond to the communication. his palmation see-
to other assessments on other parcels of land. t+an does not subject local public officials to part III of chapter 112 for not t
complying with this Daraerenh subsection. r
r
Section 31. Section 288.0116,Florida Statutes,le amended to reed: (2i(el Notwithatandinfthe provisions ofaubse tion fn.a county ormunic- c
‘Q1380116.A topeal ublicofficiale;auaei-iudlcisinroceedingeonload • - c
lien . .. ,r •vrf .r . ill ,. .�.,., . , t . . ,.
sc4erti ere laic 8'rrtat ' provision;of this-subsection for ausai-iu•(c al nroceedinds on focal rn-
merpt Ian _use maw.Thnyrdltpnce or resolution shell Provide vrocedurr
(i) A county or municipality may adapt an ordinance and oroylanE!.(denticel to this subsection However this automation do s not
or resolution removingthe presumption of prejudice from al parte oommunl- rewrite a county onunicioelity to adopt euci en ordinance or resoluti ,-
cations with local purz on,
public officials by establishing a process to d iecloee ex parte G
communications with such officials pursuant to!hie eeotiaa`or by fill in aueei lndiclai proceeding on local rovernment land usesnettere.e
ado thi an alternative process for such disclosure. owI r,this ubeectlon, person who aanes befog he dreidonmaline body who is not a arty pr -
seottes►doe not require a county or municipality to adopt any oldinanoe or oath-intervenor a�I1 be al owed to etifv before the deciei nmeki=biddy L
resolution establishing a disclosure process. rubiect to control by the ecl�i ionmakGn body, and may be ?minuted to c
used In this motion,the term"local respond to Questions from the decietonmak ng body.but need not be ewom u r
public official'means any elected or appoint public official holding a county 3 iced to.witness,'"not jffe required to be sots to croae-edect for al and body o el c-
or municipal office who recommends or takes quasi-judicial action as a mem- bred to aha and�j credibility
el 1a t expert witness The as
deems am seep c
maiden welirht_ansLcnd�b(ljsv to such testimony as it deems aagronrfate:.� c
bar of a board or commission.The term does not Include a member of the 2Arty or party-intervenor in a a esi-in ciel proceeding n local eovernment
board or commission of any state agency or authority. and usematters.upon reoueet by another party or vary-intervenor.shalt be
prom as a witness.shall be subject to cross-examination by other particle or c j�{3} may discus
s otherwise prohibited by arty-intervenors.and shell he reaufred to be qualified as in ezvert witness,
statute,
charter provision, or ordinance discuss with any local public � Q
official the merits of any matter on which action may be taken by any board is azprooriete. t
or commission on which the load public official is a member.If adopted by
county or municipal ordinance or resolution,adherence to the following prose- lc) .In a aueai-iudicial proc-sedinp on local aoyentmen lanF ee matters.a
nurse shall remove the presumption of prejudice arising from ex parte comma- lemon may not be PrecludedJrorncommunicetinr directly with a member of 9
he eciaio makine bodv by epvlicatlon of ex parte communication vrohib-
oicatione with local public officials. 3 - c
;ions.Disclosure of such communications by a member of the decisionmaking C
delThe substance of any ex parte communication with a local public body is not recuired.end such nondisclosure shall not be presumed preiudicial C
l which relates to quasi-judicial action pending before the official is not post a decision of the deeisionmakinr body.All decisions of the deciaionmaki g c
presumed prejudicial to the action if the subject of the communication and the body in a Quasi-iuulicia i oloceedins on local royernmcnt land use matters must,
identity of the person,group,or entity with whom the communication took ae sunvorted byeubstantiel.competent evidence in the record_pertinentto the
place is disclosed and made a part of the record before final action on the lroceedinr,irreanective of such communications,
matter.
( RULES.—Thies section does not restrict the authority of any board
2.(b) A local public official may read a written communication from any 3r commission to establish rules or procedures governing public hearings or
person.However,a written communication that relates to quasi-judicial action mntacts•with local public officials.
pending before a local public official shell not be presumed prejudicial to the
action,and such written communication shell be made a part of the record Section 92. This act shall take effect October 1, 1996.
before final action on the matter. Became a law without the Governor's approval May 31, 1996.
(S Local public officials may conduct investigations end Nita visite and Filed in Office Secretary of State May 90, 1996.
may receive expert opinions regarding quasi-judicial action pending before
them. Such activitiea shell not be presumed prejudicial to the action if the
existence of the inveetigetlon,site visit,or expert opinion is made a put of the
record before final action on the matter.
4,d Disclosure made pursuant to puboarsrrenhs 1..2..and 3,paragraphs -
(a)rib),and-(a)must be made before or during the public meeting et which
25 28
CODING: Words slailisa an deletions;wads yodsriinsd are additions. 251 CODING: Words striiren are deletions;words underlined are additions.