HomeMy WebLinkAboutDocumentation_Regular_Tab 14_05/10/2007JONE S
FOSTER
JOHNSTON
& STUBBS, P.A.
Attorneys and Counselors
Memo
To: Michael Couzzo
From: Scott G. Hawkins and Striling C. Halversen
Date: April 26, 2007
Subject: Office of Village Attorney
Village of Tequesta
Our File No. 13153.1
ANALYSIS RE: OFFICE OF VILLAGE ATTORNEY
Introduction
At the April Village Council Meeting, the undersigned was directed to review the
issue of whether an amendment to the Village Charter would be required if the Village
Council chose to establish the office of Village Attorney to serve at the pleasure of the
Village Council. In this regard, questions were also presented during the meeting as to
whether such a structure could be implemented in a different manner. Per such
direction, the following issues were considered and our analysis appears below:
I. Issues:
A. Whether the Village Council should take steps to establish an office of
"Village Attorney," which position would serve at the pleasure of the
Village Council.
B. If the Village Council wishes to establish the office of Village Attorney to
serve at the pleasure of the Council, does the Charter need to be
amended or can the Office be established by ordinance.
II. Village Charter -Current Provisions:
April 23, 2007
Page 2
Currently, there is no provision concerning the office of Village Attorney in either the
Village Charter or the Village Code of Ordinances. In addition, the Village Charter
provides that the Village Manager will be responsible for hiring and firing all Village
personnel under the Village's Council-Manager form of governance. The Charter
expressly provides that the Village Council will not have the authority to dictate the
appointment or removal of any Village employee.
For example, Section 2.11 of the Village Charter provides:
Neither the Council nor any of its members shall in any manner dictate the
appointment or removal of any Village employee. (Emphasis added).
Section 3.03 of the Village Charter provides:
The Village Manager shall be the supervisor and manager of all public
business and affairs of the Village, but shall be responsible to the Village
Council for the administration of all the affairs of the Village coming under
the Village Manager's jurisdiction. The Village Manager's powers and
duties shall be as follows:
(3) To be responsible for the supervision of all departments of the Village
and to see that the laws and ordinances of the Village are enforced.
****
(6) To appoint, and when deemed necessary for the good of the Village,
suspend or remove any Village employee and/or department head
provided for, by, or under this Charter, or by ordinance, except as
otherwise provided by Florida law, this Charter or personnel rules adopted
by ordinance or resolution. The Village Manager may authorize any
department head to exercise these powers with respect to subordinates in
that department.
In addition, the Charter provides that the Village Manager shall appoint the Village Clerk
who will function under the supervision and direction of the Village Manager. Sec. 3.04,
Village Charter. Section 2-102 of the Village Code provides that the Department of
Community Development shall be subject to the supervision and control of the Village
Manager.
Section 3.01 of the Village Charter provides:
Village administration shall include a Village Manager, a Village Clerk and
such other department heads as may be provided for by this Charter,
Florida law or by vote of the Village Council.
April 23, 2007
Page 3
Section 3.05 of the Village Charter provides that the Village Council may establish
separate departments by ordinance and upon recommendation of the Village Manager.
However, each separate department head shall be appointed by and subject to the
supervision and direction of the Village Manager. Even if the Village Council passed an
ordinance to create a Legal Department, the Village Attorney as head of that Legal
Department, would still be subject to appointment and removal by the Village Manager.
As these provisions currently exist, the Village Attorney is subject to the direction and
control of the Village Manager and can only be appointed or removed by the Village
Manager.
III. Charter Amendment:
One option the Village Council could consider for establishing an independent office of
Village Attorney would be to amend the Charter.
A. Example -Town of Jupiter:
For example, Section 6 of the Town of Jupiter's Charter provides:
The council shall appoint a town attorney and such assistant town
attorneys as it deems necessary who shall serve at the pleasure of the
council and act as legal advisors for the town and all its officers on matters
relating to their official duties. The town attorney shall review the form of
all contracts to which the town is a party, for legal sufficiency, before the
contract shall become effective. (Emphasis added).
This provision in Jupiter's Charter provides a limitation on the Town Manager's
otherwise broad authority to appoint and remove Town employees and officers. The
following provisions of the Jupiter Charter are very similar to the provisions in the
Village's Charter providing for aCouncil-Manager form of governance. Section 5(d)(1)
of the Town of Jupiter's Charter provides:
The town manager shall be the chief administrative officer of the town and
shall be responsible to the council for the administration of all town affairs.
The manager shall have the following powers and duties:
The town manager shall hire, appoint or transfer qualified persons to the
position of department heads of the town as may be required. The
manager shall appoint, suspend or remove all town employees and
appointive administrative officers provided for by or under this Charter,
except as otherwise provided by law, this Charter, or personnel rules
adopted pursuant to this Charter.
April 23, 2007
Page 4
In addition, Section 3(b) of the Town of Jupiter's Charter provides:
Neither the council nor its members shall in any manner dictate the
appointment or removal of any town officers or employees whom the
manager or the manager's subordinates are empowered to appoint, but
the council shall have the power to remove the town manager as provided
by this Charter and may express its views and discuss all matters with the
manager. Except for the purpose of inquiries or investigations under this
Charter, the council and its members shall deal with town officers and
employees solely through the manager, and neither the council nor its
members shall give orders to any such officers or employees either
publicly or privately.
Under this approach, there is no conflict created by a Charter provision which
establishes the Town Attorney office and the overall structure of the Council-Manager
form of government. Only the Town Council-not the Town Manager-may appoint or
remove the Town Attorney. Under such an approach, however, all dealings with the
Town Attorney would still go directly through the Town Manager.
B. Application to Village of Tequesta:
If decided by the Village Council, the Village could amend its Charter to establish the
office of Village Attorney and provide that the Attorney will serve at the pleasure of the
Council like the Town of Jupiter's Charter provision. The Village Attorney would still
report directly to and be under the supervision of the Village Manager pursuant to the
Council-Manager form of governance. However, the power to appoint or remove the
Village Attorney would then be vested in the Village Council rather than the Village
Manager.
If the Village Council decides to amend the Charter to add this provision establishing a
Village Attorney, Section 2.11 of the Charter will also need to be amended. Currently,
this section provides:
Neither the Council nor any of its members shall in any manner dictate the
appointment or removal of an~lage employee. The Council shall have
the power to remove the Village Manager as provided by this Charter and
may express its views and discuss all matters with the Manager. Except
for the purpose of inquiries or investigations under this Charter, the
Council and its members shall deal with Village employees solely through
the Manager and neither the Council nor its members shall give orders to
any such officials or employees, either publicly or privately. (Emphasis
added).
April 23, 2007
Page 5
This language should be amended to read:
Neither the council nor its members shall in any manner dictate the
appointment or removal of any Village officers or employees whom the
manager is empowered to appoint.
A charter amendment would require the Village Council to follow the procedures set
forth in § 166.031(1), Fla. Stat. That section provides the following:
The governing body of a municipality may, by ordinance, or the electors of
a municipality may, by petition signed by 10 percent of the registered
electors as of the last preceding municipal general election, submit to the
electors of said municipality a proposed amendment to its charter, which
amendment may be to any part or to all of said charter except that part
describing the boundaries of such municipality. The governing body of the
municipality shall place the proposed amendment contained in the
ordinance or petition to a vote of the electors at the next general election
held within the municipality or at a special election called for such
purpose.
Therefore, a referendum would ultimately be required to amend the charter, which could
be costly and time consuming.
In making any changes with regard to the office of Village Attorney, consideration
should be given by Council to the lines of reporting between the Village Attorney and
the Village in order to avoid any potential for miscommunication.
IV. Ordinance:
In the alternative, the Village Council may consider enacting an ordinance which creates
the office of Village Attorney. This approach would require a vote of the Council after
proper notice and publication of the ordinance followed by two readings at public
hearings.
A. Example -Town of Palm Beach:
The Town of Palm Beach's Code of Ordinances provides an example of the creation of
Town Attorney by ordinance. Section 2-221 provides:
There is hereby established the position of town attorney.
Section 2-222 provides:
April 23, 2007
Page 6
Except as otherwise directed by the town council, it shall be the duty of the
town attorney to represent and advise the town and its officers in all legal
matters.
Like the Village of Tequesta and Jupiter, the Town of Palm Beach's Charter also
provides that the Town Manager will be the chief administrative officer of the Town and
supervise the day-to-day activities of the Town for all Town officers and employees
"placed in the charge of the Town Manager by or under this Charter or by any action of
the Town Council." Sec. 4.01, Town of Palm Beach Charter.
Section 4.04(a) of the Town of Palm Beach's Charter provides that the Town Manager
shall:
appoint and when deemed necessary for the good of the Town, suspend
or remove all Town employees and appointive administrative officers
provided for by or under this Charter or by ordinance, except as otherwise
provided by law, this Charter or personnel rules adopted by ordinance or
resolution.
Section 2-136 of the Town of Palm Beach's Code thereafter provides a list of certain
appointive administrative officials of the Town pursuant to Section 4.04(a) of the
Charter. These include Finance Director, Director of Planning, Zoning and Building,
Human Resources Director, Recreation Director, Chief of Police and Fire Chief. Sec. 2-
136, Town of Palm Beach Code. However, the Town Attorney is not included in this list.
The Town Attorney is therefore not subject to the Town Manager's appointment or
removal powers. The Town Attorney is instead directed by the Town Council.
B. Application to Village of Tequesta:
The Village may choose to enact similar ordinances creating the position of Village
Attorney.
Section 3.03 of the Village Charter provides:
The Village Manager shall be the supervisor and manager of all public
business and affairs of the Village, but shall be responsible to the Village
Council for the administration of all the affairs of the Village coming under
the Village Manager's jurisdiction. The Village Manager's powers and
duties shall be as follows:
(6) To appoint, and when deemed necessary for the good of the Village,
suspend or remove any Village employee and/or department head
provided for, by, or under this Charter, or by ordinance, except as
. .
April 23, 2007
Page 7
otherwise provided by Florida law, this Charter or personnel rules adopted
by ordinance or resolution. (Emphasis added).
In addition, Section 1.01 of the Village Charter provides:
The municipal government provided hereby shall be a Village Council-
Manager government. Subject only to the limitations imposed by the
constitution and laws of this state and by this Charter, all powers of the
Village shall be vested in an elective Council, hereinafter referred to as the
Village Council, which shall enact local legislation, adopt budgets,
determine policies, and appoint a Village Manager as hereinafter
prescribed. Except as limited in this Charter, the Village Manager shall
execute the laws and administer the government of the Village. All powers
of the Village shall be exercised in the manner provided by this Charter or
if the manner be not provided then in such manner as may be set forth by
ordinance. (Emphasis added).
The indication of Section 3.03 is that the Village Manager's authority to appoint and
remove Village employees and department heads may be limited by personnel rules
adopted by ordinance or resolution. If there is no mention in the Charter about a
particular subject, such as the Village Attorney, then the subject can be governed by
ordinance.
In addition, the Village Council has the authority to establish a new department by
ordinance. See Sec. 3.01 and Sec. 3.05, Village Charter. If the Council establishes a
Legal Department by ordinance, then the head of the Legal Department would be the
Village Attorney. The Village could then adopt personnel rules by ordinance or
resolution which limit the authority of the Village Manager to appoint or remove the
Village Attorney. Instead, the ordinance or resolution would provide that the Village
Attorney serves at the pleasure of the Village Council.
In order to comply with the Council-Manager form of governance, the Village Attorney
would still be supervised by the Village Manager and would report directly to the Village
Manager.
Note, however, that Section 2.11 of the Village Charter might still be problematic. This
section provides:
Neither the Council nor any of its members shall in any manner dictate the
appointment or removal of any Village employee. (Emphasis added).
This language may need to be amended as recommended in the discussion above,
even if the Village decides to establish the office of Village Attorney by ordinance rather
than charter amendment. In order to amend this charter provision, the Village would still
April 23, 2007
Page 8
be required to hold a referendum. To avoid this problem, the ordinance should refer to
the Village Attorney as an "officer" rather than an "employee" of the Village.
In making any changes with regard to the office of Village Attorney, consideration
should be given by Council to the lines of reporting between the Village Attorney and
the Village in order to avoid any potential for miscommunication.
V. Resolution or Personnel Policy:
The Council may determine that it is not necessary to create an "Office of Village
Attorney" in the Charter or Code of Ordinances. Other municipalities such as the Town
of Jupiter Island and the Town of Gulf Stream have charters which do not include
references to the town attorney as an "office." Nor do they include any reference to the
town attorney in the ordinances. This issue can be treated as a policy issue without the
need for amending the charter or ordinances.
For example, the Village Council may choose instead to adopt a policy by resolution to
provide that the appointment or removal of the Village Attorney by the Village Manager
will only be approved pursuant to a majority vote of the Council. As an independent
contractor having a contractual relationship with the Village, the Village Attorney is not
currently considered an "officer," "head of department" or "employee" under the Village
Charter or Code. Therefore, the policy would not conflict with the Village Manager's
authority to appoint and remove those other appointive or employee positions within the
Village. The Village Attorney would still report directly to the Village Manager in
accordance with the Council-Manager form of governance.
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