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HomeMy WebLinkAboutMsc Correspondence & Term Limit Docs - CITY CIF CMOS UE ephone: (612) 784-3055 1f of a cJ�l(ayoz Fax: (612) 784-3462 "Quite Simply the Best' JERRY 1,INKE Match 6, 1996 • The Honorable Kenneth J.Fitzpatrick jgai Chief Judge, Second Judicial District Ramsey County Courthouse 15 West Kellogg Blvd. St. Paul.MN 55102 Re: City of Mounds View Charter Commission Dear Judge Fitzpatrick: The City of Mounds View is served by a Charter Commission appointed pursuant to Minn. Stat.,, • Chapter 410. The district court through its Chief Judge,is vested with certain powers in regard to the charter commission Minn. Stat. 410.05 (1994). As Mayor of the City of Mounds View. I respectfully request, on behalf of the City Council, your guidance in a matter that has arisen concerning actions proposed by certain members of the Mounds View Charter Commission. The Mounds View Charter Commission,by a 8-5 vote,requested the City Council to include in our charter an amendment adopted by the voters in November 1994. That amendment placed limits on the number of terms that may be served by the city's elected officials. Subsequent to that election_ a virtually identical amendment was found unconstitutional by the Minnesota Supreme Court in Minneapolis Tenn Limits Coalition-v.Keefe, 535 N.W. 2d 306 (1995).—In-that decision-the-court held that such a charter amendment is manifestly unconstitutional and therefore need not be placed on the ballot The Charter Commission is fully aware of the Keefe,decision and has been informed by the City Attorney that the Mounds View charter amendment is unconstitutional in light of that decision. The City Attorney has also advised the City Council that we should not include the amendment in the charter. Nevertheless, the Charter Commission continues to insist that the unconstitutional amendment be printed in the charter. A copy of the proposed amendment is enclosed. The City Council's concern arises from two issues. First, from a public policy perspective we do not believe that it is wise to have an unconstitutional provision included in the Charter. Second. we believe that the Charter Commission's attempts to require the City to publish the unconstitutional amendment is a violation of their oath of office to •hold the United States and Minnesota Constitutions. :>. ; - -^ _ 6; • The Honorable Kenneth J. Fitzpatrick March 4, 1996 Page 2 Because the district court is charged with the responsibility for overseeing the Charter Commission, on behalf of the City Council I respectfully request that you address the following issues and take any other action which is appropriate: 1. Do charter commission members who knowingly ignore a Minnesota Supreme Court ruling and willingly participate in efforts to print an unconstitutional charter amendment in the City Charter violate their oath"of office? 2. If such a violation of a commissioner's oath of office has occurred, is such action sufficient grounds for the district court to remove a commissioner from office under Minn. Stat., 410.05, subd. 2? 3. If sufficient grounds exist to remove a commissioner from office under these facts, the District Court is respectfully requested to take the appropriate action under Minn. Stat., 410.05,subd.2 to remove any commissioners from office who have violated their office by voting to request printing of the unconstitutional amendment. Thank you in advance for your assistance and consideration. pVe truly yours. J Linke, Mayor Enclosure cc: Mounds View City Council(wto enclosure) Robert C. Long, City Attorney(w/o enclosure) Paul Harrington, Interim City Administrator(w/o enclosure) MOUNDS VIEW CHARTER COMMISSION MINUTES Regular M ecting: 11-30-95 1. Call tet C)rder-by Chair Risk Warren at 7:1111 p.m. . 2. it I 1 'all -Present: l yen Hwpecc-z:. Virrgil Bewx_lt;rry Linda:.nave l.+ns. Duane McCarty.:arty.lean Miller. Richard Otnait.Laurie Schley.Rhonda Sntefja.Roger Stigney.Russ Watton. Bill Weiner.Ruth White. Absent: ((emitted)Julie Trude- 1301 w ilsun. 3. Aunruval_of M ink- Motion by Virgil Beyer and second by l�;n Burgers to approve the minutes of meeting 11-$-95.mMxrm approved 4. CommissionBusit s-Explanation of decttnlettg.by Richard Oman-Charter draft 95-1 and new Charter redline. Motion by Laurie Schley and tei%u id l+ykm Linke ut send Clutter draft 95-i to die City Colwell withoUt the Term Limits and Priretaty Election amendments. Motion by Richard Oman and second by Ruth White to amend the oririnal motion by keeping the Tenn limits amendment in drat 95- 1.Jerry Linke handed nut a tea I npion rrghinting tont timittt.and there wns di!teats:ehi>e cnaacrning the proper role of the Council on the term limits amendment The motion was clarified and a Roll Call Vatc wit requested by the(hair. Question- keep the term limits amendment in charter Draft 95-1. Yes: Ruth White.Dill Wrenn.Rieger Stigney.Jean Miller.!)emote:McCattt.Virgil Beyer.Richard Mot. Russ Warm. No: lthtindat Strieij;t L)ai.t: Long.Jerry Linke.Len Burgers.Luria Schley. MnnON APIROVPI) S to 5. Motion by Ruth White and second by Duane McCarty to amend the otrigitutt mutein by including the primary t:lecxion• amendment it the Charter. Discussion centered an die viability ofthitc amendment bait approved rfby the City Council.and the possibility difcicrtiling the approval oftht;updated Ctarter. .1 roll call vote was requested by the(-hair. Question- keep the prima?elections amendment in C'lbarter draft 95-1 YEN:: Virgil L3eycr. Len Burgers-Dave tong.Duane McCarty.Jean Milttt,)& 'er Stigney. 13i11 Wermer. Ruth White. No: Jerry_Linke.Rich rd Oman. ltheiida Stneija Russ Warren. Abstain:Jeune Schley. 1tt(IT10N APPROVED 9 to d There wt then disettssiOrt regarding-time fir final review introduction of ftMhcr amendments. and the view that we had a goad document in Clutter draft 95.1.It was pointed out by tin Burgers than new amendments to the Charter can be made any time in the titture.A toil call vote was renowned by the r'hair. Question- Irti ward Chatter draft 95-t to the City Council for appy vat. The Russ Warren.l.ntrrir Schley.i:ichard Oman.Loan Surgery.Jerry tMike. nate Long.Rhonda Stnwila. Nei: Virgil beyer, Duane McCarty_Jean Miller. Roger Stigney.!lilt %Verner.Roth White. MC)rinN APP1ttWEI) 7 - 5. Adji urn:ten;-Motion by Jerry Linke and st.-t.nnd by neve Lung to adjourn at K•?p p.m..Mt T1'IUN APPROVED. R) UNAPPROVED STATE OF MINNESOTA SECOND JUDICIAL DISTRICT KENNETH J. FITZPATRICK CHIEF JUDGE April 2. 1996 =rely Linke, Mayer City of Mounds View 2401 Highway 10 Mounds View MN 55112-1499 RE: CITY OF MOUNDS VIEW CHARIER COMMISSION Dear Mayor Linke: Regarding your request for guidance or information as•to actions taken by the charter commission, it would be inappropriate for the court to comment either one way or another regarding what position the court might take in a legal matter. As in all cases, the court must remain neutral and is not allowed to prejudge one side or the other. I would suggest you seek advice from your legal counsel. Very truly yours, Kenneth J. Fitzpatrick Chief Judge �.€l ?r , _ 350 Courthouse. Saint Paul, Minnesota 55102 t (612) 266-8342 KENNEDYt&GRAVEN CRA'U►'ener at Lir* ern P$IWwr*Ceske.Mlytwovat.Mkw a Pts ter52 (s12►33'1.M eoRRi t n.tlee>'eM IMUrm . Astor sad J*MU J.?NOK50W.JR. In*li.E 1N.11At?!yt*ow 'Ao Cawes.tte RU041"R,S Irl north i tteaeo LAllet M.+ptts►atN STt$ tt 11.SAM81111 S4Mk NO.bttsseeolr slit BOp$tE L.wryLxeNs SOt t 11. 3•m'Nt�L. 14121223-M33 Jot Y.TANG Jote L at:A�+ DA 1- e ttr O Paesiselte(5121 SPAMSPAMDolt,t,L GRA.tN QHH* f•:o.t�r,I CJ.xraeNtA*1.01 L.L EFEvERt O�CO�hsRL PO M.LUNI'4 . v:R11t*S DIRECT DIAL RMeR?C.CARLOW PROFIT C LIw+G 3379202 DORM L.DA�.v ON PAM C.Ln it wcLLnionoK 1L Low JAMCS M.Q1ltn'it1W Prawn B.11t CURt1R A,PCAeaON T.2*'SALAfkr May 23, 1996 The Honorable Kenneth J. Fitzpatrick Chief Judge, Second Judicial District Room 1350 Ramsey County Courthouse 15 West Kellogg Boulevard St. Paul, MN 55102 RE: City of Mounds View Charter Commission Dear Judge Fitzpatrick: On March 8, 1998, the Mayor of Mounds View wrote to you asking for responses to three questions relating to the activities of the Mounds View Charter Commission (copy of letter attached as Exhibit A). As you will recall that activity consisted of continuing efforts of eight of the Commission members to require the expenditure of public funds to have the City's codification service print an unconstitutional term limits amendment in the Charter (the name of eight membeersat he seek advice fromare included on Exhibit thit B). You responded to the Mayor's letter by suggesting e City attorney. At the May 13, 1998 Mounds.View City Council meeting, I was requested by the Mayor-and City Councilmembersto-formally request that you exercise your role and authority as the appointing authority of charter commission member toremovethese — eight members of the Mounds View Charter Commission. The City believes that these eight Commission members have violated their official duties by knowingly and w kingly voting to require the wasteful expenditure of public funds to print a Charter Amendment which has been ruled unconstitutional by thae Minnesota tSupreme reme Court. The City also believes that the willful act of ignoring Court ruling on the Minnesota Constitution to onholdh eeight Mintiesota Commiss on members is a violation of their oaths of office P Minnesota Statutes, section 410.05 confers authority upon you as the Chief Judge of the Second Judicial District to appoint and remove charter commission members. This request to remove the eight Charter Commission members does not require you to act in your judicial capacity to rule on a legal matter before the Court as you indicated in your April 2, 1996 letter (copy of letter attached as Exhibit C). Rather, this removal request requires you to act only In an administrative capacity in your 71010417118 141J123-36 The Honorable Kenneth .7. Fitzpatrick May 23, 1996 Page 2 role as the appropriate appointing authority to remove charter commissioners according to the clear terms and authority granted in the statute. Minnesota statutes, 1 410.05, subd. 2 states that "[a]ny member may be removed at any time from office, by written order of the district court, the reason for such removal being stated in the order." The City's request to remove the commissioners is made pursuant to this provision. The City of Mounds View respectfully requests that you issue a written order removing the eight Charter Commission members for the following reasons to be stated in the order: 1. Minnesota Statutes, Section 410.05, subdivision 2 requires that each charter commission member must file, along with an acceptance of the appointment, an oath of office which requires that members uphold the Constitution of the State of Minnesota. After having been informed by the City Attorney of Mounds View that the Mounds View Charter Amendment providing for term limits for the City's elected offices is unconstitutional based on Minneapolis Term Limits Coalition v. Keefe, 535 N.W.2d 306 (Minn. 1955), the eight members o the Mounds View Charter Commission who voted to print the unconstitutional amendment to the City Charter have chosen to ignore the ruling of the Minnesota Supreme Court and in doing so have violated their oaths of office by not upholding the Minnesota Constitution as recently interpreted by the Court. 2. The eight Charter Commission members who voted to require that the unconstitutional Charter Amendment be printed in the City's Charter knowingly acted to cause a misuse and waste of public funds, and thus violated their official duties as appointed charter commission members. If the unconstitutional Amendment were to be printed as requested by the eight Charter Commission members, it would result in the wasteful expenditure of between $2,000 and 52,500 to have the City's current codification service, _Sterling Codifiers of Weiser, Idaho, include the unconstitutional amendment in the City's Charter. Some additional amount of public funds would again be wasted when Sterling Codifiers would later have to remove the unconstitutional amendment. Avoiding such a waste of taxpayers' dollars has been clearly recognized by the Minnesota Supreme Court. The Keefe decision relies upon earlier Minnesota Supreme Court decisions which cognize that where a proposed charter amendment is manifestly unconstitutional, the city is not required to ut the matter on the ballot because the City should be able to avoid what would amount to "a total waste of taxpayers' money," Davies v. City of Minneapolis 318 N.W.2d 498, 504 (Minn. 1982) and what would be "ultimately cleaned to be futile." Ii11A v. City of Minneapolis, 198 N.W.2d 531, 536 (Minn_ 1972). 3. If the to be eere C ity's Charter, it would mislead the citizens of MunView to part tof emlimits 119310066 MU/25-36 The Honorable Kenneth J. Fitzpatrick May 23, 1998 Page 3 applied to city offices. If such a course of conduct were permissible, it would encourage continuing public deception through official acts by Charter Commissioners. The City of Mounds View respectfully requests that you issue a written order removing the eight Mounds View Charter Commission members for the reasons set forth above. Very truly yours, ^(•to Robert C. Long City Attorney City of Mounds view RCL:jes cc: Mayor and City Councilmembers (w/o enclosures) Chuck Whiting, City Administrator (w/o enclosures) MEMORANDUM TO: Bob Long FROM: Dan Grcensweig DATE: December 19. 1995 RE: Charter Commission The Legislature "may require that [charter] commission members be freeholders. provide for their appointment by judges of the district court, and permit any member to hold any other elective or appointive office other than judicial " Minn. Const. art. 12, § 5. It is not clear, however, whether the Legislatures powers under this language are subject to the restriction that "the legislature of this state may provide for removal of inferior officers for malfeasance or nonfeasance in the performance of their duties." Minn. Const. art. 8, § 5 (emphasis added). This latter constitutional clause has been construed to mean that an inferior officer may not constitutionally be removed from office except on these grounds. Jacobsen v. Nagel, 96 N.W 2d 569(Minta. 1959). There is no doubt that a charter commission member is an "officer." State cx rel. Peterson v. Fraser, 254 N.W. 776, 780 (Minn 1934). Significantly, appointed municipal officers are more likely than elected officers to be subject to removal without adherence to constitutional limitations on such removal. Cf. Sykes v. City of Minneapolis. 144 N.W. 453, 455 (Minn. 1913) Especially "[wjhere no tenure of office is fixed by law, and no provision is made for the removal of the incumbent, the power of removal is a necessary incident to the power of appointment." Parrish City of St Paul,87 N.W. 1124. 1125 (Minn. 1901). _ Neverthelcss, the right to remove an appomtcd officer is not unfettered. "When a statute creates an office for a fixed term, the right to remove is not incident to the power to Appoint. State-ex rel: - - village of Chisholm v. Bergeron, 194 N.W. 624, 624 (Minn. 1923). Particularly when a commission is clearly meant to have independent authority, an inference can be made that removal must only be for "cause." Id. at 625: see also State cx rel. Todd v. Essiing, 128 N.W.2d 307, 311 n.4 (Minn. 1964) (after appointment made by executive branch to fixed-term office. removal may only be for malfeasance or nonfeasance). Several factors suggest that removal of a charter commission member is restricted to at least some degree. A chatter commission member is appointed to a fixed term. Minn. Stat. § 410.05, subd. 2 (1994). Moreover, the attorney general has likened that position to a "legislative office." the implication being that charter commissions should have a good deal of autonomy. Op. Atty. Gen 358-E-i (1946). Finally, Charter commissions derive made that a charterr origination ddirectly from member constitution. Hence, a reasonably strong argument DJG9?069 Mu125-t1 should indeed be considered an officer for the purpose of the constitutional restrictions on removal from office. The question remains. however, whether the constitutional language authorizing the Legislature to provide for the appointment of charter commission members by implication allows the Legislature to provide for their removal for other than malfeasance or nonfeasance. As noted. "Cw]here no tenure of office is fixed by law, and no provision is made for the removal of the incumbent, the power of removal is a necessary incident to the power of appointment." Parrish, 87 at 1125 In the case of charter commissions, the constitution does not fix a tenure of office. Furthermore. one could argue that the constitutional provision pertaining to charter commissions does not provide for the removal of members. Taken together. this supports the notion that the Legislature has an incidental power to remove or provide for the removal of those members. On the other hand,one could argue that there is indeed a provision for the removal of an incumbent member. namely the constitutional authority to remove a member only for nonfeasance or malfeasance. If so, the Legislature would not have the incidental power to remove commission members. In any event, assuming that the Legislature does have the power to provide for the removal of charter commission members for reasons other than malfeasance or nonfeasance, the issue is whether it used that power. The Legislature has provided: Any member may be removed at any time from office, by written order of the district court, the reason for such removal being stated in the order. When any member has failed to perform the duties of office and has failed to attend four consecutive meetings without being excused by the commission, the secretary of the charter commission shall file a certificate with the court setting forth those facts and the district court shall thereupon make its order of removal. . . . Minn.Stat. §410.05,subd. 2. This statute is far from clear. To begin with, it seems clear that a charter commission may not be removed entirely at will. since _the district court is required to state the "reason for. . . removal" in its order.. 1d. The next sentence of the statute unfortunately creates a conjunctive condition; that is, a member shall be removed from office if he or she fails to perform the duties of the office and has four consecutive unexcused absences from commission meetings. Id. (emphasis added). The problem is that because the court must state a reason for removal, the statute suggests that removal cannot be for no cause or for bad cause. Nonetheless, it is difficult to conceive of anything besides failure to perform duties or attendance that reasonably justifies removal. The only way to reconcile these sentences is to read them as stating that a court_nity remove a member who fails to attend meetings but does not fail to perform other official duties, or a member who fails to perform other official duties but does not fail to attend eti other official al a at a court o rt must remove a member who both fails to attend meetings and fails to perform If this is a correct interpretation, though, what the statute really describes is nonfeasance. DJG98n69 MU125-11 2 Nonfeasance is the "neglect or refusal, without sufficient excuse, to do that which is the officer's legal duty to do." Jacobsen. 06 N.w.2d at 573.1 The final question is then whether a charter commission member commits nonfeasance by voting in favor of a clearly unconstitutional charter amendment.2 The charter commission members arc sworn to "support the constitution of the United States and of this state and to discharge faithfully the duties of his office to the best of his judgment and ability.' Minn. Stat. § 3511.05: Minn. Cotist. art. 5, §6. Arguably, they have violated this oath by insisting upon an expenditure of taxpayer funds even though the purpose for which the expenditure is being made is clearly unconstitutional.' In practice. though.it is unlikely that a court would find that this by itself constitutes nonfeasance sufficient to justify removal from office. See Jacobsen, 96 N.W.2d at 573 (dispute over expenditures of public funds is political issue, not question of nonfeasance). My recommendation. in light of this somewhat confusing constitutional and statutory scheme, is to throw the issue back on thc district court without clearly describing the standard by which removal of a charter commissioner should be evaluated. Although the statute does not define the procedure by which a court may be prompted to initiate such a removal. the city could probably use the same procedure as is used for appointment of a commission, presentation to the court of a resolution of thc city council requesting such action. Minn. Stat. § 410.05, subd. 1 (1994). l think it would be best that an attorney draft the resolution on behalf of the city. Malfeasance "is not susceptible of an exact definition," but refers "to evil conduct or an illegal deed." Jacobsen, 96 N.W.2d at 573. Nothing in the charter commission members' activities has remotely approached this standard, 2 I am assuming that the amendment is indeed unconstitutional. ' I would be very careful about pushing rson argument 'bee r moved- from mdo not think we office simply want to establish a precedent that p because he or she votes for an unconstitutional measure. bh7G98669 WI 5-11 3 1 1 • 306 Minn. 535 NORTH WESTERN REPORTER. 3d SERIES ed. The conditions udder which additional Gsrdebring.J..sled a dissenting opinion disbursements were to be made are clearly in which Anderson. J., joined. I stated in the construction loan agreement stringer. J.. Sled dissenting opirdon. ' and it cannot reasonably be interpreted to • create a mere option. Like the mortgagee in tions �,� Phelps. (the Bank watts obligationfor 1• Municipal charterproposed amendment is man- advance the furl of thet of featly then city council may gin, the. completionrof � theorefuse to plade proposal on ballot r'� property. That the Bank the conditions (receipt of Ken waivers) and Z. Officers and Public Employ/eel X18 relied on others(inspections by Bank person- nen does not change the priority of its re- Provision of State Constitution allowing corded mortgage. '. legislature to establish •quatifta tions"for lo- . cal government officers refers to dlementa of . Accordingly. the court of appeals decision performgnyee requiring particular �' of is affirmed. candidate such as physical agility or edu- cation level, but does not authorise legisla- ture to set'eligibility requirements-for pub.i4lc office which have nothing to do with abili- ty to perforin ditties of office such as age and rs dem► requirements. and which are gov- erned / by separate constitution /provision guaranteeing universal eligibilitt for public r dike. M.S.A. Const. Air 7.16: Art 12, MINNEAPOLIS 'PERM LIMN § S. COALITION. et *L. See publication Words and Phrases ' Plaintiffis. for other judicial constructions and def- initiots9- - •. tions �145c2� t 3. Municipal Corpora Merry KEEFE. et aL Defettdeoyta Proposed amendment to city charter �C 8137. limiting terms of elected City offi is would change e� I'j supreme Court df Mitmeaotar _ See in violation of constitutional guarantee of 4--1996=---_ ua ►eri+ sal eligiblhity for public office. which F Aug; ane such changes be Made by eon= , required stitutioiial amendment; term limits were not Bled action in federal court Association Blemerely "qualifications"Tor local government seeldng declaratory and iryuncte relief officers which could be established by legisla- eft'from , ceun�•s refusal to place proposed tion under authority of separate constit on- .,. term limits amendment to city charter on s.1 provision. M.S.A Const. Art?.it 6; Art ' election ballot. The United States District ie. I s. f,( Court for the District of Minnesota certified the Court on whether amendment would vio- Sys by • bate State Constitution. The Supreme Court, An amendment to the minneapolia city Keith CJ., held that proposed amendment charter limiting the terms of fecal elected to city charter limiting WIN of e]ected city officals would violate Article VII. Section 6 #" officials would change "eligibility require- of tete Minnesota Constitution. menta"for local office in violation of constitu- �-_ tional guarantee of universal eligNlity for public office. Christopher J. Dietaen, Peter J. Coyle. Certified question answered in affirms tarkin. Hoffman. Daly & Lindgren. Ltd.. Bloomington, for plaintiffs. five. s' E MPLS. TERM LIMITS COALITION •• KEEFE tem. 307 Ii . Op r OS et•w.ld ass Med. t++si the office of City • , eight consecutive years in • I. westing 0 Smell Brady.City Atty Joseph M.yaBat. Council. � • f CityAtty..Office of City Atty.. Minns- passage the this ordi- ; I.{' Ash Keefe. Service prior determining n8 ' } s � spTls, for Merry ounce shall not . Minae- length 1•1 'coni A. Reitz, Asst~ County Atty.. Section RUCTION. ' ' ` spoils. for Marge Christianson. •'` p45 Clerk Is hereby instructed to contact.est �Zi endue la matin heard. considered and decided by the ly as he would do if so instructed by a I i 1 City o may court en bane. resolution of the Mayor or City Council in i.' writing, within 30 days after adoption of r'f ballot. OPINION this order• all state legislators and �� s+P1�� ®18 members of the United States Conger ; , istitntion allowing iO;i i H. Chief Justice. „ l�„e ,ny eob�eate�itlde the city ` s 'for la Thisnae cosies to us on as Order of limiter and � ° it is the •�} 4 f rticit!ens to dints of Certa$cation issued by the United States Dis- resolute desire of the dticens of the city of ' j , ability lrict:Cotirt for the District of 1Kinneeora PIT- Miemeapolis that term limit be enacted by .1:4 :, Mm limits and the unit. �;,E'4 al authorize or edu- stunt to Minnesota Statutes section 480.061 the kgislata re of um •ji±`.� (1994) (Uniform Cerllfieation of Questions of ed Stag Conte and that the�.for w Act). 'Ihe vet fed question is as fol- tive tenure in r `i ice to do with alb- than six years(three terms)in the enwhich s: and lis states House or told n �d are gw- Would an amendment to the Minneapolis (two terms)in the t ,�., no car limiting the terms of local more theethan }� digedlity n7.§ 6 of United States Senate. and no more } 6 fiat, public ; elected ofti 'cots violate Article the comae y�in either the Miens i'1' **newts Constitution. to or State House. The i . ?. lh 6: Art 12, Ste a�the question in the awe. tote State Sens People of the city of Minneapolis y f . , eds and PhrasesSince the adoption of its city charter' the instnrd all state and federal i tractions and d City of Minneapolis has been a home rule represent any of this cit? to and ` 1 i v Charter city pursuant to Minnesota Statutes •►idually do the promote tional �tl'• WW1 ®1�9(Z) Chapter 410. Plaintiff Mildte-eP is Term 1 binding legislation 'term n or a i ; . , ent to city tion (`MYLG"l is se nnincorpo- a1endment enacting 1 . Charter Limits Coalition vras Placea The instruction lints s and d city officiall cal f- rated asmociation citric ifled in this section far lozal of proposed amendment to the city charter on resolution shah! io effect for sa i 4 t national g+a'eoof the November& 1994 general election ballot mem y are reqs to eyed these ; , *bleb .. for ase city of being the terrrn+ Changes. and shall so state on its i pulikie °rave• con- of the mayor and city eountl members m Section & gEVERABIIrtTt. 1f aril► �' • ager to n net___ t years._individual plaintiffs are them- of this petiti� shall be declared_un- j mita i On -_Part-- g1sa11--__- �� t eottinmttee�— i court. - � established loyal by l here of the 994 steering a n constitutlot*al b - andur Call others. by • August 15. 1994. plaintiffs filed Peso remain in full famei•. Mini- << aon_stftution- '` with the Office of Elections and Voter 1 Fob a recommendation by the .. .,. Separate toplace their proposedthe pin- Ata 7.$ 6: Ari. ter amendment g g1. neapolis Charts Commission p :mei it on the bat- th amendment on the Officeoi Electionsry A gidof the city 'i of and posed amendment ,: — yg .. Voter Registration the that the petition lot. and attorney based on the advice famendmenthcity Os Court Iron certified that the proposed •• contained a cient number amendment d h the 1yliaGo' n�� •: to t the Minneapolis elected voter signatures. The proposedmould violate the Mi.the� terms of local Section - states: Se not to place the 4 the city council the ballot. e Article n. 6 - LIMITS. Notwith- , d later, theends!parr signed the city ton. Section L 'iEBM mats standing arty other provision of list to Items resolution. t �- contrary,no person may file to be a tandi- prber 14. 199d• filed a J. Coyle. date for election to a term that would ]trot .n U.S.plaintiffstCourt hetyea. Peter person to serve more than eight verified Comp sari the punt Sint & Lin$gren. Ltd-, causeosthe aeain the office of Mayor or seeking a declaratory judgment sing. • consecutive years • 308 Minn. 335 NORTH WESTERN REPORTER, 2d SERIES tion meets the technical requirements int- Asadsews a Brach. 155 Minn. 38. 191 N.w- eligibility "except posed by state law and that the dty counci'l's 1012(1923). In the present ase.the Minn- this constitution' action violated plaintiffs' rights under the :polis City Council. following the advice of timid floor and It ' First and Fourteenth Amendments of the _ the chafer commission and the city attorney. meat of addition: •• U.S Constitution. Further, on September rejected plaintiffs' proposed chi amend- Citing the court 0 . 23.1994.plaintiffs filed a motion fir prelim went on the ground that it was manifestly v. Grose. 502 N= nary injunction seeking to enjoin the defen- unconstitutionaL As requested by the Unit- plaintiffs iti>rtlter dents t from refiring to place the proposed ed States District Court,we consider wheth- contemplated by • amendment on the city-wide ballot for the er an amendment to the Minneapolis city section 6 is foam forthcoming election. charter limiting the terms of local elected Under article 10 Following a hearing and a verbal riling o would violate Article VII. Section 6 tore tray kid 3,! from the bench on October 3. 1994. the ifs- of the Minnesota Constitution. organization. ad 's • trier court filed a memorandum opinion and Article VII. Section 6 of the Minnesota dmisIo' • said dim order denying plaintiffs*motion for a pretimi Constitution provides: units • 11 ns and fol naryeert.injunction and certifying the question to Sec. s Visibility to hold office.of this nth the this court cry person who by the provisions article is entitled to vote at any election entitied s Con Artitlo XII.Section 5 a the Minn- and is 21 years of age is eligible for any quiring that cars sees m Constitution.home mile charter amend- office elective by the people in the district t meats tory be proposed "by a charter - wherein he has resided so days previous to i t The t the o local g petition of five patentas of the deter- the election. except as otherwise provided p�langur a ;.i�.� voters of government unit as rises the in this eotistitntion,ar the constitution and for local offices :;;. mined by law and shall not become effective law of the united States. • until approved by the voters by the majorityof these add'stim required by law." Amendments also may be In Pavlick v. Growc thin court interpreted of sheriff did i proposed and adopted In any other manner article VII.section 6 as establishing universal elective office u provided by law." td pursuant to this eon- eligibility few public office: forcefitQy the h ianedots stitutional authority, the legislature has get This constitutio l si812. 813.514. forth additional methods of charter amend- press ee an important democratic para edge the anent Miitnesotg Statutes section 410.12 ple—that all citizens meeting mit nal. nn, addressed including a certification process for amend- changing requirements are eligible for the enact addition • meats proposed by a dtirene petition. Un- elective postdates that control torus.govern- plaintiffs nate • der these provisions. amendments meeting merit. The opinions of this court applying ten."in matte the-tethnicst requirementashall-be_submit.- Article vil. $ection 6. have consistently rulecihaw ties h ted to the qualified voters at a general or held that.as a guarantee of utdveisal eligisessedby the spetial election and published as in the cast bility for public office, its standards may such power i of the original charter." Mintt.Stat f 410.12. not be made more restrictive by legislative held." Stota i sand. 4. authorized by an- Zea established in other Gonstiittutie on�al�i�ision. 83 t19510. [i] Nevertheless,it is proposedwell 284 N.W.2d 174. 176 Olian.1979). Crookston. if • ;` =Pen.5 that when a car De spite this guarantee of universal eligtbil- article XIi. e amen •� ay r u un�o.Q- plaintiffs argot that home rule charter for office. so th • ct7 na ro" ity posal on the ballot. See D avfes It City of cities have been delegated broad power by [21 We di ► Minnettpotfa. 316 N.W2d 498 (Minn.1982): the Iegislature and are constitutionally u for reasoning is • Housing Auth. of Min- rived to impose eligibility requirementsA critical dig �,iti City of.Redevelopmentthat the fication'for npnpotis v. of.Minneapolis, 293 Minn- local officials. Plaintiffs first assert } 227, 198 N-W2d 581 (1972): Stale ex ori. article VII. section 6 guarantee of universal i i 2. Vic disc Mitutoaptblis. James?bland. a Minneapolis City Court ease 1. Defendants inr this action invade: Merry r • Keefe. City Clerk of the City of Minneapolis: Council Christtnber.n. SupervisoreCof the Elections changeable ' a Joyce of treil. y fDirectorMof theneapo s:Elections Depart- Marge for Hennepin County: Pat O'Cem• tion. Clan a'; ) trent . the Gen of the Minneapolis lis Jackie Cherry. r Ser'tces Dr•ision Manager for r.wcen an e C' barites. President of the MitJtreapolia City Coup- nor. Taxpayer til: Sharon Sayles Belton. Mayor of the City of Hennepin County. and Hennepin County eon is ham .a COALITION e. MpT,S• TERM LiMIT3 KEEFE MM- 309 . i.I rite:ass et wad NG t we& ow A qualification is an de- ase. , except as otherw a provided in meat" for office. a particular de �. 33. 191 NAV. elig " nq met+k of performance g •`' tltb cons � � >!nterelY s co ability on the part of perms seelattg the ase.the Minns- totution for the enact- agility or the a I # recta g the advice of t>d !lootuiremetita position. such °f eduhe at- se cite attot•lsey, in t courttof ppeals'o do in Elbert t�aent of a particular level of educat by chart r amend- C tg the casrf of appeals°ia°dn 19931. We believe that the leglsi ims a was manifestly itde. 502 N.W.2d 810 {Minnapp• established v. contend that the exception the carni of appeals ed by the Unit. ' tufa VII. gUs�lifirati°"for office and into this o i }:� consider trhet>ti. conplated by the Iattguage of Ei�requirements.°n theether ►lea l electedd . section 6 is found in artide XII. mon 3-isla- �havelnothing do melte one's ae tyer of tam! Coder article XII. ty ebon 8. *Ublee perform the duties of the owe in question. i� e the Sectiot► B hire may provide ni la+► for conthe age and residency require- c Mk. mgmii�egtion. administration, consolidation. and �shed in article VII. section 5- ,' n and dissolution of local government me s team d in such as that cae. f the Mibtteaots tom! a a and appointi'e officers includ'n+g Clearly. * is as �it suc Y requirement be-., • traits tions for off." leterpreling this ex- cause plaintiffs it has sinothing to dol with the particular '• � told ions of E - the court of appeals •s ability perform 3°b' rather.it Rovisiotts this tul3onalif7► a statute t e' P based a factorthej ,unrelatedr to 1. et any election tany atter for the office of slier is a restriction = eligible ftrr any ifisuccessfidtf caring that candidatescomplete pew off,Nana- job per'f°rman°e' . ale in the district � �� •� court held that til Applying this �� pres. .,. Article I days previous to section 3 autho ent . we conclude that although ;: 1`�1°e provided plain !atone to en • � ai, section 3 of the I °th Cgh Arti1pe �� "`, _constitution for n the of the to astab 4 ` for local affi;, the for ,e o''• locale off•the :a • :. rAtlons e�bl� ib ear court of sheriff did not violate the Id ,t owe the cure t° des term hglbili- 'vision universal t elective office un et erste meta add not a !i frac Mit8-814. f,oniougstita limit Is alt artiI.. ae1ato'4- t auteor+sed bion foreef'Ii1iy 812» Sill-81t. thou I�� acre n is no to the ' ; ieng mini .rind- edge that the court appeals mold XII.section 8 as as excepts a I article ran- I sting Inittinasl.un- addrd o�Y whether *maws a office. � assi,'wer � pie eligible for the enact additional qualifications for eectian a ore and hold that an I `' his their applying govern- pati dote that under the home r+ S eeetm an m the awe er his to eo applying tem."in snifters of municipal concern. to the elected offidsls il Barre vet l eat]y rule duces have all the legal► _power pa. amendment save as tg e 6 of its standards sessed by the lestalabite of the ea LY of fall state- ,""''sd Yio a on p uratic- Mitttsesett`I—�' ( . eatiin -such -e.ret Teton of Low ti.Citif df t visio-by tem held. Sfatt. N.w2d gl. GAItDEgRING. Justice (dissets ion I, stskhotistied by as 2i2 Minn.526.528.91 t To me.fee qti 41 on.19?n. Crookston, (19581• Plaintiffs assert that under I respectfullydissen of the u tics -by ° 'a�ahtiaotdt� and of our s;• - nn.19Z9). C ,,.., , if e-'^� � � tioa�s ble state toriprovisions 3 of the ��- if universal eligibii' for" xII dry.._ previous . Article XII.Section ' 'i lame rule charter for !!o too � Miiisteaota Constitsitiatt lnQ°'`� •1,��'i�' A broad power by �t We do not agree that p t line Loral tritrietia legiglation wafFe t& •'I'. tslitaitiotialll►avtho- reasoning � dispositive in the present tee- The legfelat� may provide by law I� Y st'4us•rt.that for A critical distinction exists between a"qay' for : elective and provide appointivelo1F : Cirst assert that the {,cosi for office and aft•rehgt'Witl+require- Constitution.Which refers to universal our own Mint+esotile N ion 6.but refers to ,, 4. a Minneapolis tsrsi�+ .uNgiwn Mi in I. t ct'tes to s recent f3 S. Suotzme ti a oMinneCity 2•t;ourt case in support of its proposition the that "qualifications for le VII. a snick MI r s'�On "qualification- are e" n Supreme Cot foundIOn City of Minneapolis: changeable ale and and "q� �' no similar hedist net c us+dcr the meprovisionsours of the Division of the Melons tion. Clea and that a term f limit is aweight in ciao tote I n el:An Pat (Mort- tioa. dearly our analysis o[the distinction�' federal constitution bears no g •' ,� f)t•nsiori Managerfor don nis baesed eligibility on the ny ique language of ted of our discussion ttuepin 1 . 4 . NY �` 310 Minn. NORTH STERN REPORTER. Zd SERIES oiBc> November 8. 1994 elected , ;•4 tai un ts1 including Sulk qualificationsfor which estabhslnes a 8 6 of the Minnesota l• ordinance,artstonY with the to hold . (ofn• gnka�t d p , ion is without theualifica IS in h .nth per, late- m by the ptarmic : limitation; Ilse proms bon. Rather the tYto vote at s • (emphasis is does o Say the leg;elaa (S of Article XII. Section g, majority entitled of age le el limited to considers tg only educations'(Mali- P A a eXII. c sad arcane ergo Years oth- engages convoluted distinguishsada "qualifies- went elective by the p ` fie spe s.c category. o . Th or no ment from"eptitigbdity » Nath electswherein he has redid 'There isn be no trio_esthe on. e mabout whether the legislature can �- mg in the state constitution itself- our be this les rpt t elected the qualifications cases. aappos'� . A.-term Y �� '�°� this ansiys s of the �, of the United �' n and therefbte the'Pests- We must afford thecharter presumption of 'n• ' t t� kind hereto a duly 101100ing "goer is a qusllf'cato � •L.l _, skt irsese • t do .., o ed t r o tutionality as we would ly to a u std sets the pous cas t� 1 legislative tute- WZd 188, this authority to 1n �� P99 N. ' Our previous home rule �extendMinneapolis. In Co"'''"ns .1adin�1� ndents have not even ��n�6,,,a . State ea eta Twee of Loeaed v City of Csoolc- 'come close to satisfying the substantial bur► The h�o m'Governing kind of a4s' rgs:tiu{ stmt. we said: den of woof applicable to thein its this vvoutd solidatiote. divi.Kiot cask rule is that, in ve constitutional oblation. Therefore.negative. olida on. d urns imp home the answer the certified question the change of ba possessedelective died sspP sll ttea legislative re of the state.save as such power d. The ANDERSON. Justit a (dissenting)- qualification.*o, . is expressly• or impliedly 'contrary I join it the dissent of Justice Gardcbring. fer of muntY 94 adoption of any chatter pr at may not uben char to the Public policy of the state. as peva] RINGER. Judge. dissenting- - feared urs se closed by the general laws or its psis dissent. I would answer the d by a antUc code, is also forbidden I respe� question. fa„•,� , es to" cert�e question in the negative.is fts>filled Mit►n-Const art homeris limited There is no ap Placing like legislature. It . Coate the Procedural toe+the No- tl or by to 2 b1if h with snd sub ect to tae � - proper term Lim amendment em I be• Further. tion fo the state." But these limitations o "saber 8, 199A ballot- COQ ° • te_ettanaazd of constsds- ms Doty that if t -_ - -- - ----- • of-d+st'�-Pt'o1°'i- - - the-spps'°� ' *ions as to eny subjectIlevetimer is the same as the chaster- to impose 4u ' not forbid the appropriate to the review fly conduct moi niacipal se ofet. st- apple to a duly enacted legislative stab too does the Cit those exist- smendmele is presumed ride chartist mw differ fromute---the proposed 262 though�' See State v. Hama. � [,cruaeu u Cibe v fats Renes' ' Wed 81.98 (1958) constitutionst.390 Sole' : Hamams a 91 N 11V 2d Si t (citations ibn. + 91 N. N W lis 299 N.Wld 188.. Mike gene (citations osrdtl+ed). Caa+,m�s "' of •►t�,not be municipal cos • of a home rule 142{Minn.198D). AecordisB1y, -St ` 21+ar the ed IS o stricken unless the challenging party demon- at city ate charter as fvilao+sthat it is in violation of the consd - e legish 1) its char provisions must be consis-d beyond a reasonable doubt: See Ham's legislis a U' } .... with the public policy of the state.and tion2d at 380: In es Tvete�402 N W.2d adoption of ure of be in harmo- '�N' City of Richfield it to the pubo _- ;1 (�xis--�-.-�-- - tutaon�a Sd 5`1, 553 (Minn.1987): closed by f1 ny with and stated to the rousts Load No. itis. Intl Asan of Firs Fighters. W2d•42, 45 (Minn.1979). also f by gt� Leos of the state. 216 N. to tri `, o • does rot go so far as VII.4 6 of the Minnesota Constitu- cris liirzt suggest >that the proposed.,�limits-ordi- Articlet for determining t tie . ggestto a plainly un- tion is the starting pOin a home elnst is rdt Hance is p contrary c whether the City of Minnenpoles, lace • and er ale public policy- he Minnesota i ne because rule charter may. vtAS required to p dersteod Con- Artuti XII.Section thoef legislature ���, peiiants proposed term limits amendment on the state." stitution authorizes e MPLS. TERN LIMITS COALITION v. KEEFE Minn. 311 1 [he it S3S N grad 306(Min& NILS} t- lected officials, the November & 1994 ballot. Article VII, forbid the adoption of charter provisions as ` 1 h establishes a4 6 of the Minnesota Constitution provides: to any subject appropriate to the orderly i th the cons Eligibility to hold o®ce- Every person conduct of municipal affairs.although they the plain Lan- who by the provisions of this article is may differ from those of existing general (; 3,the rnatiortty entitled to +►ore at any election and is 21 lags. p�°n of Buck a charter is - ( ;t d $rs years of age is eligible for any office legislation. f , Irish "4 - elective by the people in the district Id at 628, 91 N w2d at 88 (quoting Mian.;,- meats." Nall- wherein he has resided 30 days previous to Const, art nr, § 36) (citations omitted). itself. nor our the election. esxept as other+e providedMy of departure from the majority is i't' ► analysis. constitution and11 in Chia constitution,or the fust, ata failure to even consider tI►at Appel- presumption • !. ,' moons of thelaw of the United States. !lei•:` ' lams' proposed amendment does not ��•: ptesursption Minn.Const.art vfl. # 6(emphasis added). ,`£`` . an eligibility or qualification standard for aa- •`.: apply to a duly Following the "exception"clause to the reed scoring or holding elective office at all The ., Gttflliams ay. step.we are lead to Article XII. § 3 of the proposed charter amendprent provides in ` . k!'1'; • X99 N. .Ed 138. Minnesota Constitution: pertinent part: I ;.;1 • 11 Is have not even legislation affecting- anyother' of 1.oca1 Government; Notwithatattdfng provision► : :: substantial bus- The legislature may provide by faux for the law to the contrary.no pent'''.++ray}ale to ! :i 1 In in this kind of creation. orgard7atian. adtnird�stratian. con- be a candidate for election to a term that :: l:; 1 aeon. I would sotidation, division and dissolution of local would cause the person to serve more than t in the negative, government units and their functions. for eight consecutive years in the office of ' the change of boundaries thereof.for their Mayor eight eonsec+rtr►e y in ire , '. Ming). elective and appointive ofuers including office of City Canna. /;i // : ', dice Gardebring for of cations se office and for the trans- (emphasis added). 'I'ke plain language of the.,' fen of county seats. A county boundary �p� simply prohibits "ffi[h+61 to he a may not be changed or county seat trans- candidate for election * ' ' i a ) t tt t rating. hib►tioti t , ; ferrel until approved in each county af- that clearly leaves other avenues open for . ' ' 1° d . the fected by a majority of the voters voting on achieving the office—for example. through tlla the question. write-in vote or, in some circumstances, by T. pl�ellantst Minn.Const. art.XII. $ 3(emphasis added). appointment. If the proposed amendment ;.i a for placing the The legislature.then.has constitutional au- were it~ fad an eu.,.hiiit,v standard in viola- • �+ Imenttwequ on the No- 1 i''?' nseque:rtly. I thorny to establish am In qualifications eem agreement elective tion of Minn- Coast a Sill. 1 6. unless ;E bffiee. nigher.I in agreement with the encompassed by a constitutional exception,it ;; .:. last the sta d3tr� • maionly that if the 1egislat a has authority would prohibit the taking of office etion, . ! , as startdsrd • to impose qualifications for elective office. so That is not at all the proposal we have here. 5 1 4 legislative slabtoo-does_-the City cf--Minneapolis as ahome amort-- -- r is presumed In Stale ex set Torun of Next,sig the-fate of appellants' .• Lowellc e.charter dry- ?52 MInm. &26, to obtain a public vote on their proposal.the u Xart+ls 488 '�.,.z' KO: Guilliauta u tx City of C�nokatatt. r testy p to narrawty define"quail- '., ;. 91 N.SSt2d 81 (1968). We held Ration" for office under Minn. Const. art. • N 2d 1�' jt]he genu rule is that in matters of ' sly.it maynot beXII. § 8 as "az' element perfortnattte re �, e. ging partydam_ mut�pal concern. home rule cities have guarana a particular ability"of on the part of the 14.1.,1• in of _ all the legislative power po-�aessed by the candidate for office. Because the term limits ' 4 o t the cO legislature of the state.save as such poweron does not relate to "s particular t ou te' See N.W.2Ham . or impliedly withheld. The pro"i„ o concluder.it must be • ii'.:; 4u�2 N.R►2d is a tion otY p ability, so the maj rity 1't adoption of eny charter provision contrary an ell 'bility requirement. thus falling out- hr of v to the public policy of the state, as lis- side the parameters of Minn.Covet.art.XII. •t • .a p'irte Ffghte+s closed by general laws or its penal code,is unconstitutitmal" t i ;a fi .1929). conferred upon § 3. and "manifestly I also forbidden. The power majority's analysis therefore tuns on . .i, (for oto Constibi- cities to frame and adopt home rale char- the nartro+#entire tion it accords the terms ,` t for determining term is limited by the provision that"such , :' "eligible" and "qushfication. �;,({�i... • .eapolis, as a home charter shall always be in harmony with meaning of terms "eligible" �,r 'Aired to place cap. and subject to the constitution and laws of plainThe thes the ("rag le" ,Illi;.nits amendment on the state." But these limitations do not and "qualification" sugges .. .'. .lili 535 NORTH WESTERN REPORTER. 2d SERIES• ified to be judge i 312 rt Minn. to be chosen: qed ing patient hS11 n an In itsamendment recent the and elected proper ' `" and defrdng"qualified"eligible as pathic Ind virtually intercd the u d. sited: entitled; Web- prem'C . p eme 1 diva strildage 'ent roi c ess Constitution that Fro , M) (emph a added% see else 1858 nttstyy disch . C otherwise eligibleonthe candidateaeral fora Third New Pia D iowarg 3 as menu rgi Coag Cosaeana8 onae2v� 2 (3d ed. 1961)(defining ;¢"fitted or and slynaiitaes�• lot if that candidate of had thalre Uniteddyto be chosen peso ter terms,the States gtutit�" as"fitted (as by endow- ti+ie specified to nen ` Wee in terms of defining qualified ors y i> lath ; i Supreme Court Cfronstitution the' States meats of accomplishments) •• "whether the or al titutlon sestils peet tit's of impulses i6 s l the T pose' competent. and(3)comb from• eg to or at in �tutiot�• (emphasiswarrantthe sonelih t spetSt tea Tera terms simply the Teem L[�•it.�, 15E, u Thorn-2 two line distinction in definition the major- constitute dt t United 5 `� __._, 115 5.Ct• 1842. bright {�shtu�t of the 881 (U.S..1995)('mph itY gives lacle t standard. Revert 1847. 131 i the Court exFliatly refers applicable a p?olon to ply a terra limits ballot added). qualifications. tb.—U.S. Finally. term limits asC qualtfi the �' Mental—.116 S.Ct at 1844 Menu limits.ince dish�a the City j. aitY otht+.r qUa rateon far Cif". is the of one of tete fight of So tali sibly restrict the ability of voters tai rig of regi€c"' B. cotis mote wham they wish."). re- hiitSee 9 ejl n peatedly :; nt lythe Cou+ Da F°ae + tf6 U. for ment bear refer in the U States Goss 86 U.Coto.L Rt►x 47.l0(1956){ & ,fitted. for membership U�. 115 S.Ct at the history and aitn8 of the uritis di> sons Corot at ' `- and referring to initiatives as forms that to public 1845 (a S the "a� fishing Any went of chi U. "— S. Cotter. art. I. 12. el. 2 (establishing democracy"). with great caution. �. ents applicable t0 right sthehouldbe d the tight of the tuba.• thit �. membership R Wim. ea to to their Z. Not 'House of Representatives); en Costar. The "`"""13ty voters of the City of Minneapolis I. I a, et 8 (establishing meSenat5� tissue. hieeging Per .' gsesnetets appli�le to the c'r'ate)): ballots on this imposes sossslity oiaa id. —U.S. at x, 115 S.Ct. at 1849 d errtrlreatlon on sn all too h arroSP det�nstion tioFr era'intenttdebates of the term.`01ygr °n I do ( tis Framers' that the not believe respotsdenm havt• �"maa3featlltg the 1: be geed den of proof of demonstrating Mumma • in the _. -- s-reasonablengidoubt. met their bor.- relatioo basis added):,is. �ttstltutionaltt)►_�'ot'd_ I Mer. ... a tlua 11 (S.0 (holding"tsv)e U.S.at 115 w, a at 1849 e tottsss custclUde Dow, we in pow tv. heroin 898 U.S.486.89 S.Ct. 1944. 23 tom+, McCormack allows that. fuses IFEd.2d 491 (1969)3 that history Framers in Respondent. �vitlt re€pect b° Com to establish iceddntt 8. Com• Respo ;o '' tended the onsittetl)). The .. y:� q— court ualifications." holds that the challenged EL Comntittsidner of Human 4. 2 term limits amendment imposes an additional Maria SOrMvi et at, stoner rtts• �•,. "qualification" upon are ,, and unconstitutional qu Nos. C6 g 95-484- lw cantdidate .that would effect a 5-144. C4- to e CongressionalFederal torrents- 5uFreCoa>� of Miruseso� cot �^ fundamental chak in — U.S. at tt; 4. >�' Del t3onal framework. Aug- vh 115 S.Ca at 1845• definition of the 5•i Moreover. a incorporates he tern, "quali- Commissioner of Human Services and :� terra"fig. e. intlade Dictionary 521• of special to Comm 1241 tb s 1 R��ig"eligi le" as"fit count'appealed Roto order • lYjl1 (6th ed.1990)( CITY OF MOUNDS VIEW CHARTER COMMISSION RESOLUTION 96-2 Where as; Councilmember Susan Hankner submitted a letter of resignation effective December 31, 1996 to the City Council on September 23, 1996 and, Where as; The City Council accepted Councilmember Hankner's resignation by a simple motion adopted at the regular council meeting on September 23, 1996, and Where as; The City's Attorney determined the City Charter to be silent in describing the conditions of vacancies on the City Council and recommended the City Council follow procedures for filling council vacancies under state law, and 4_ Where .s; The City Council declar-• the vacanc --ted by Coun ' ber Hankn- re-'gnation • exist now fo •urpo es of the •-neral : lectio o be he d on N. -mber 5, 1996 .•. on Dece be 1, 1996 f• •urposes o •erfo ing the •. of a counci - ber, and Where as; The City Council ordered that the candidate for city council receiving the third highest plural vote in the general election on November 5, 1996 as eligible to fulfill the duties of Councilmember Hankner's remaining two year term of office beginning January 1, 1997, and Ppc..r, Where as; The foregoing actions by the City Council afe-nonconforming to the City Charter, and Where as; The conditions of vacancies in elected city offices are stipulated in Section 2.05 of the City Charter which states: Sec. 2.05 Vacancies. A vacancy in the council, whether it be in the office of mayor or councilmember, shall be deemed to exist in case of the failure of any person elected thereto to qualify, or by reason of the death, resignation in writing filed with the clerk-administrator, removal from office, non-residence in the city, conviction of a felony of any such person after his/her election, or by reason of the failure of any councilmember without good cause to attend council meetings for a period of three consecutive months. In each such case the council shall by resolution declare the vacancy to exist. , and Where as; The City Charter requires in Sec. 4.05. Vacancy of Municipal Elected Office. Subdivision 1. When a vacancy in an elected office of the city occurs with 365 days or more remaining in the term of the vacated office, there shall be a special election held within ninety days after the vacancy occurs to elect a successor to serve for the remainder of the unexpired term of the office vacated. , and Where as; The City Charter requires in Section 4.05 Subd. 5. When a vacancy in an elected municipal office occurs within 120 days prior to a regular municipal election date, the special election to fill the vacancy shall coincide with the regular election. If the vacancy occurs within sixty days prior to the regular election date, the notice of such vacancy shall be published as soon as is practicable. If, within the 120 day period before a regular municipal election, the vacancy occurs in the office of mayor or in the office of either or both of the councilmembers whose seats are to be decided in the election, said vacancy shall be considered not to exist for purposes of the election. However, if such vacancy occurs in the office of either of the other two councilmembers, the seat shall be filled by the candidate for councilmember with the third highest vote total, or, in the case of two vacancies, the third and fourth highest vote totals. Where two vacancies exist, the candidate with the third highest total shall fill the vacancy in the office having the longest unexpired term. , and Where as; The Charter does not provide for conditional resignations by elected officials of the city, and Where as: Minnesota State Law sets forth in Chapter 410.21 Application of general election laws. The provisions of any charter of any such city adopted pursuant to this chapter shall be valid and shall control as to nominations, primary elections, and elections for municipal offices, notwithstanding that such charter provisions may be inconsistent with any general law relating thereto, and such general laws shall apply only in so far as consistent with such charter. HIST: (1295) 1909 c 170 s 6 , Which confirms the authority of the city charter over state laws, and Where as; The City Council action on September 23, 1996 in accepting Councilmember Hankner's resignation by simple motion was nonconforming to Charter Section 2.05, Minnesota State Law 410.21 and Charter Section 4.05, Now Therefore be it resolved, The Charter Commission of the City of Mounds View respectfully notifies the City Council that council processes on September 23, 1996, regarding the resignation of Councilmember Susan Hankner, appear nonconforming to requirements of both the Charter and state law, and Be It Further Resolved, the Charter Commission commends Councilmember Susan Hankner for her efforts to avoid the added expenses of a special election, and Be It Further Resolved, the Charter Commission of the City of Mounds View respectfully suggests Councilmember Susan Hankner resubmit her resignation effective by November 4, 1996 to ensure compliance with charter requirements should it remain her desire to avoid a special election. Those voting in favor of the resolution: Those voting against the resolution: Signed: Secretary Signed: Chairman October 3, 1996 ._ . . . . . eaf: MOc.UJ'DS VIEW CtTY CHART a- (as a ianeraa.k Fut- i; mem) I Y aetiri.GM : ( SC✓T, 2.0 s --- • - YeStina.•}-i.rn 1n wri-1-.7k STA ttr L rr . l I ----- ht Cows c:1 01 recaJJ4.1+x, atec):ret Vaeax1 -o exit+ Secy, 4,VS Vaccdnct1 i►as VBcart41 ►s remaA'sbi COUne i 1 occurred w j#h�„ No � � N o 5417 C 1ZO Sys Fri Cir -dei NNmore i „ a r. (lAk.1 •�-o a r,er ,tib 1 366•clays Ytr)?e-t g ai SJb (a, YDS / ` . 7 Special 6,0i-Fh*.1 )SJb i 904"111 i / , • S + ems - CV a ca n.4) N 4-h ird 11111144-1 1,6s- couReil rnennber yr -90r 5.i, b _ y ei-e. ,r. )S,,so C re-a le4+14 w � 9e ri tra.l 71CaA' a. rr1 YES i�O \ ► ' . YA c a.,c..� ' , • KENNEDY & GRAVEN CHARTERED Attorneys at Law JAMES J.THOMSON 470 Pillsbury Center,Minneapolis,Minnesota 55402 LARRY M.WERTHEIM ROBERT A.ALSO? (612)337.9300 BONNIE L.WILKINS BRUCE M.BATTERSON JOE Y.YANG RONALD H.BATTY Facsimile(612)337-9310 — STEPHEN J.BUBUL JOHN B.DEAN DAVID L.GRAVEN(1929.1991) DANIEL J.GREENSWEIG DAVID J.KENNEDY OF COUNSEL CHARLES L.LEFEVERE ROBERT C.CARLSON JOHN M.LEFEVRE,JR. WRITER'S DIRECT DIAL ROBERT L.DAVIDSON ROBERT J.LINDALL WELLINGTON H.LAW ROBERT C.LONG FLOYD B.OLSON JAMES M.STROMMEN CORRINE H.THOMSON 337-9202 CURTIS A.PEARSON T.JAY SALMEN October 10, 1996 Chuck Whiting City Clerk-Administrator City of Mounds View 2401 Highway 10 Mounds View, MN 55112 RE: Legal Opinion on Charter and Statutory Procedures for Declaring and Filling City Council Vacancies Our File No. MU125-38 Dear Chuck: You have asked for a legal opinion on the procedure for declaring and filling a vacancy on the City Council under the Mounds View City Charter (Charter) and under state statutes in relation to the letter of resignation that Councilmember Hankner submitted at the September 23, 1996 City Council meeting. This legal opinion is a formal written opinion setting forth the procedures that I outlined to you and the City Council verbally before and during the September 23 City Council meeting. OPINION Issue No. 1: Procedure for Declaring a Vacancy Under Section 2.05 of the Charter, a vacancy in the Council shall be deemed to exist upon the occurrence of one of several events, including a "resignation in writing filed with the City Clerk- Administrator." Minnesota Statutes, Section 351.01, subd. 3(b) allows a resignation to be made expressly to take effect at a future date, as Councilmember Hankner did with her September 23 resignation making it effective December 31, 1996. Minnesota Statutes, Section 351.055 states that"if a future vacancy becomes certain to occur and the vacancy must be filled by a special election, the appropriate authorities may begin procedures leading the special election so that a successor may be elected at the earliest possible time." RCL111384 MU125-38 Chuck Whiting October 10, 1996 Page 2 Applying general state law on election matters in a manner consistent with the provisions of the Charter is permitted by Section 4.03 of the Charter. Therefore, the City Council could accept Councilmember Hankner's written resignation at the September 23 meeting and declare a vacancy to exist under the terms of the Charter and state law. To avoid any procedural questions such as those raised by the Charter Commission regarding the manner in which the Council accepted Councilmember Hankner's resignation, the Council should act by written resolution at its October 14 meeting to ratify the action taken by motion at the September 23 meeting accepting Councilmember Hanker's resignation. Issue No. 2: Procedure for Filling a Vacancy The procedure for filling a vacancy that occurs within 120 days prior to a regular municipal election date is set forth in Section 4.05, subd. 5 of the Charter. That section states in part as follows: When a vacancy in an elected municipal office occurs within 120 days prior to a regular municipal election date, a special election to fill the vacancy shall coincide with the regular election. If the vacancy occurs within 60 days prior to an election date, the notice of such vacancy shall be published as soon as practicable. If within the 120-day period before a regular municipal election, the vacancy occurs in the office of the mayor or in the office of either or both of the councilmembers whose seats are to be decided in the election, said vacancy shall be considered not to exist for purposes of the election. However, if such vacancy occurs in the office of either of the other two councilmembers, the seat shall be filled by the candidate for councilmember with a third highest vote total, or in the case of two vacancies, the third and fourth highest vote totals. (Emphasis added) Pursuant to Section 4.02 of the Charter, no one may file for a municipal election later than 56 days before the election. Therefore, in the case of Councilmember Hankner's resignation, which created a vacancy occurring less than 56 days prior to the regular municipal election, the City Clerk could publish notice of the vacancy as soon as practicable pursuant to Section 4.05, subd. 5 of the Charter and the vacancy would be filled by the third highest vote-getter among the candidates for the two City Council seats that had been listed on the ballot as set forth in the procedures under Section 4.05, subd. 5 of the Charter. Under Minnesota Statutes, Section 205.16, subd. 4, the City Clerk must provide written notice to the county auditor regarding the offices and questions to be voted on in the election. Therefore, the ballot would properly indicate that voters should vote for the two city council offices which had been certified to the Ramsey County Auditor and Election Bureau. However, pursuant to Section 4.05, subd. 5 of the Charter, the third highest vote getter for these two council offices would fill the vacancy. RCL111384 MU125-38 Chuck Whiting October 10, 1996 Page 3 Conclusion The Council accepts Councilmember Hankner's resignation of September 23, 1996,by Resolution and declares a vacancy to exist. State law specifically allows the resignation to take effect at a future date. The Council vacancy is then filled pursuant to Section 4.05, subd. 5 of the Charter in which the third highest vote getter for the two council seats listed on the ballot fills the vacancy. Please feel free to contact me if youhave any questions. Sincerely, Robert C. Long RCL:j es RCL111384 MU125-38 ' KENNEDY & GRAVEN f:HARTEREa) Atturitys ii Lucy 470 Pit%btury(renter.Mum-volts,Minuetota 614)2 (612)3374500 CORRINS R.THOMSON ROBERT A-ALSOP and JAmt.s J.THOMSON,JR. $RUG6 ht-$ATTERSON 70R Connerre Bolding,8 East Fourth Street 1.A1:RY M.WERTNEIM RONALD H.BATTY Saint Fadi,PidinDWPII 55141 BONNIE L WILKINS STPnim J.BUi6VL (612)225-4438 JOE X-'YANG RAIN B.DEAN --- DANIEL J-tMEENBWEIG Bactimite 012)37-9310 DAVID L,(MAVEN(1929-1001) DAVID J.KENNEDY CHARLES X.-LEFEYI F c OF COUNSEL JOHN M.LFSEYRE,JR- WHITe,31E�.Ry'S D RU CT D1Ai. ROBERTC.CAON RQSENT J_LINDALL a] X 4sy0 ROBEK C -DAYI�Ji014 Et0$ERT C.LONG WELLINGTON H.LAW JAMES M.STRom?ifEN FLOYD B.OLSON CURT A.PEAMISON T,JAY Sn3.MRN May 23, 1996 The Honorable Kenneth J. Fitzpatrick Chief Judge, Second Judicial District Room 1350 Ramsey County Courthouse 15 West Kellogg Boulevard St. Paul, MN 55102 RE: City of Mounds View Charter Commission Dear Judge Fitzpatrick: On March 6, 1996, the Mayor of Mounds View wrote to you asking for responses to three questions relating to the activities of the Mounds View Charter Commission (copy of letter attached as Exhibit A). As you will recall that activity consisted of continuing efforts of eight of the Commission members to require the expenditure of public funds to have the City's codification service print an unconstitutional term limits amendment in the Charter (the name of eight members are included on Exhibit B). You responded to the Mayor's letter by suggesting that he seek advice from the City attorney. At the May 13, 1996 Mounds View City Council meeting, I was requested by the Mayor and City Councilmembers to formally request that you exercise your role and authority as the appointing authority of charter commission members to remove these eight members of the Mounds View Charter Commission. The City believes that these eight Commission members have violated their official duties by knowingly and willingly voting to require the wasteful expenditure of public funds to print a Charter Amendment which has been ruled unconstitutional by the Minnesota Supreme Court. The City also believes that the willful act of ignoring a Minnesota Supreme Court ruling on the Minnesota Constitution by the eight Charter Commission members is a violation of their oaths of office to uphold the Minnesota Constitution- Minnesota Statutes, section 410.05 confers authority upon you as the Chief Judge of the Second Judicial District to appoint and remove charter commission members. This request to remove the eight Charter Commission members does not require you to act in your judicial capacity to rule on a legal matter before the Court as you indicated in your April 2, 1996 letter(copy of letter attached as Exhibit C). Rather, this removal request requires you to act only in an administrative capacity in your FE0ioa7s8 14[1125-2& 17/Z 9DVd OEE6LEEZL9'OE 142/WHO 8 1O3MN9M'WO ld b6'60 96-6Z-2-MN The Honorable Kenneth .1. Fitzpatrick May 23, 1996 Page 2 role as the appropriate appointing authority to remove charter commissioners according to the clear terms and authority granted in the statute. Minnesota Statutes, § 410.05, subd. 2 states that "[a]ny member may be removed at any time from office, by written order of tin!' district court, the reason for such removal being stated in the order." The City's request to remove the commissioners is made pursuant to this provision. The City of Mounds View respectfully requests that you issue a written order removing the eight Charter Commission members for the following reasons to be stated in the order: 1. Minnesota Statutes, Section 410.05, subdivision 2 requires that each charter commission member must file, along with an acceptance of the appointment, an oath of office which requires that members uphold the Constitution of the State of Minnesota. After having been informed by the City Attorney of Mounds View that the Mounds View Charter Amendment providing for term limits for the City's elected offices is unconstitutional based on Minneapolis Term Limits Coalition v. Keefe, 535 N.W.2d 306 (Minn. 1995), the eight members of the Mounds View Charter Commission who voted to print the unconstitutional amendment to the City Charter have chosen to ignore the ruling of the Minnesota Supreme Court and in doing so have violated their oaths of office by not upholding the Minnesota Constitution as recently interpreted by the Court- _ 2. The eight Charter Commission members who voted to require that the unconstitutional Charter Amendment be printed in the City's Charter knowingly acted to cause a misuse and waste of public funds, and thus violated their official duties as appointed charter commission members. If the unconstitutional Amendment were to be printed as requested by the eight Charter Commission members, it would result in the wasteful expenditure of between $2,000 and $2,500 to have the City's current codification service, Sterling Codifiers of Weiser, Idaho, include the unconstitutional amendment in the City's Charter. Some additional amount of public funds would again be wasted when Sterling Codifiers would later have to remove the unconstitutional amendment. Avoiding such a waste of taxpayers' dollars has been clearly recognized by the Minnesota Supreme Court. The Keefe decision relies upon earlier Minnesota Supreme Court decisions which recognize that where a proposed charter amendment is manifestly unconstitutional, the city is not required to put the matter on the ballot because the City should be able to avoid what would amount to "a total'waste of taxpayers' money," Davies v. City of Minneapolis, 316 N.W.2d 498, 504 (Minn. 1982) and what would be"ultimately destined to be futile." HRA v. City of Minneayolis, 198 N.W.2d. 531, 536 (Minn. 1972). 3. If the unconstitutional amendment were to be printed as part of the City's Charter, it would mislead the citizens of Mounds View to believe term limits aso104788 ti/E anvd OIEGGEEEI9'0I N3AV D '8 h03NN3N'HO?I3 St'60 9E-bZ-MiW r ` The Honorable Kenneth J. Fitzpatrick May 23, 1996 Page 3 applied to city offices. If such a course of conduct were permissible, it would encourage continuix'g public deception through official acts by Charter Commissioners. The City of Mounds View respectfully requests that you issue a written order removing the eight Mounds View Charter Commission members for the reasons set forth above. Very truly yours, C71.1,-tC4- -1(\f‘e_.\ Robert C. Long City Attorney City of Moun-d.s View Rales cc; Mayor and City Councilmembers (w/o enclosures) Chuck Whit;rig, City Administrator (w/o enclosures) FA0104788 10125-#8 p b/b 3Mtd 01E6L££ZI9'01 N311'd2I9 'S 1Q3NNa i=waId Bb'60 96-17Z-AVN C017 OF OUNDS Phone: (612) 784-3055 JEW Of/LE o f ffiE ay°' Fax: (612) 784-3462 "Quite Simply the Best" JERRY LINKS March 6, 1996 • The Honorable Kenneth J. Fitzpatrick Chief Judge, Second Judicial District Ramsey County Courthouse 15 West Kellogg Blvd. St. Paul, MN 55102 Re: City of Mounds View Charter Commission Dear Judge Fitzpatrick: The City of Mounds View is served by a Charter Commission appointed pursuant to Minn. Stat., Chapter 410. The district court,through its Chief Judge, is vested with certain-powers in regard to the charter commission Minn. Stat., 410.05 (1994). As Mayor of the City of Mounds View, I respectfully request, on behalf of the City Council, your guidance in a matter that has arisen concerning actions proposed by certain members of the Mounds View Charter Commission. The Mounds View Charter Commission,by a 8-5 vote, requested the City Council to include in our charter an amendment adopted by the voters in November 1994. That amendment placed limits on the number of terms that may be served by the city's elected officials. Subsequent to that election, a virtually identical amendment was found unconstitutional by the Minnesota Supreme Court in Minneapolis Term Limits Coalition v. Keefe, 535 N.W. 2d 306 (1995). In that decision the court held that such a charter amendment is manifestly unconstitutional and therefore need not be placed on the ballot. The Charter Commission is fully aware of the Keefe decision and has been informed by the City Attorney that the Mounds View charter amendment is unconstitutional in light of that decision. The City Attorney has also advised the City Council that we should not include the amendment in the charter. Nevertheless, the Charter Commission continues to insist that the unconstitutional amendment be printed in the charter. A copy of the proposed amendment is enclosed. The City Council's concern arises from two issues. First, from a public policy perspective we do not believe that it is wise to have an unconstitutional provision included in the Charter. Second, we believe that the Charter Commission's attempts to require the City to publish the unconstitutional amendment is a violation of their oath of office to uphold the United States and Minnesota Constitutions. PRINTED WITH �� SOYINK 74(11 L-Iirdhtnimi 1!1 NArvnrnrdc \/ioui u i FG110_1 AOC zef CITY OF MOUNDS VIEW Agenda Section REQUEST FOR COUNCIL CONSIDERATION Report Number: STAFF REPORT Report Date: 10/10/96 ' � ' `ihi CITY COUNCIL MEETING DATE Ar October 14, 1996 Special Order of Bus. ts.PasineePeS _ Consent Agenda Public Hearings Council Business Item Description: Review of September 23, 1996 City Council Meeting Minutes and Subsequent Consideration of Resolutions 5029 and 5030. Executive Director's Review/Recommendation: -No Comments to supplement this report -Comments attached. Explanation/Summary(attach supplement sheets as necessary) Summary:.Some questions were raised about whether the City Council should have accepted Sue Hankner's resignation and the ensuing declaration of vacancy by resolution instead of by motion. Mounds View City Charter requires that a resolution be passed for this type of action and the Council may want to consider affirming their actions of the last meeting by adopting resolutions 5029 and 5030 as drafted by City Attorney Bob Long. Bob and I discussed the appropriate way in which to do this, either by having the Council amend their minutes of the September 23 actions to reflect the actions as resolutions, or to simply proceed with the normal adoption of the minutes and then readdress the actions with reaffirming resolutions. The reason for this is as much consistency with past practice as with anything else. have also asked Bob to send me a letter outlining the position he stated regarding the Council's appropriate course of action for accepting the resignation and then declaring a vacancy. As the Council is aware by now, much of this is being questioned by the Charter Commission, with the essential concern being that without a special election, voters will be voting for two candidates for three seats. The timing of the resignation, after the notice of filings close, has the most to do with that situation. I expect to have Bob's letter by Monday and will forward copies to the Council as soon as possible. As for Monday evening, I recommend the Council ask Bob to review the option to adopt the two resolutions at the time the Council is reviewing the Council minutes. If the Council chooses, it can approve the minutes with the actions as motions as it happened, then add to the agenda the two resolutions reaffirming the actions. Also, the Council may want to take this opportunity to acknowledge the resolution it received from the Charter Commission last week. C/L4(.},a Chuck Whiting, Cit Administrator S • • RESOLUTION NO. 5029 CITY OF MOUNDS VIEW COUNTY OF RAMSEY STATE OF MINNESOTA RESOLUTION ACCEPTING COUNCILMEMBER HANKNER'S LETTER OF RESIGNATION Whereas, Councilmember Hankner at the September 23, 1996 Council Meeting submitted to the City Council and the City Clerk Administrator a written letter resigning from the City Council; and Whereas,the City Council approved a Motion accepting Councilmember Hankner's resignation at the September 23, 1996 Council Meeting. Now, Therefore, Be It Resolved that the Mounds View City Council hereby ratifies its action of September 23, 1996 accepting Councilmember Hankner's resignation by Motion and hereby accepts Councilmember Hankner's resignation by Resolution. 111 Adopted this 14th day of October, 1996 ATTEST: Mayor Linke (SEAL) Clerk Administrator Whiting •