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TO: -° ' BOARD OF SUPERVISORS a�,""""""_-
FROM: INTERNAL OPERATIONS COMMITTEE Costa
DATE: DECEMBER 11, 2001 ' - CountyCOOK
SUBJECT: PROPOSED AMENDMENTS TO THE ELECTION CAMPAIGN ORDINANCE
SPECIFIC REQUEST(S)OR RECOMMENDATION(S)&BACKGROUND AND JUSTIFICATION
RECOMMENDATIONS:
1. DECLARE the Board's intent to introduce an ordinance to be operative on December 1,
2002 providing that limits on campaign contributions for Countywide elective offices are
imposed per election cycle rather than calendar or fiscal year.
2. SCHEDULE for discussion by the Board after March 5, 2002 but no later than May 2002 the
determination of appropriate contribution limits to be incorporated in the ordinance, and
DIRECT staff to prepare the ordinance for introduction at that time, subject to the Board's
determination on contribution limits.
BACKGROUND:
On October 16, 2001, the Board of Supervisors referred to the Internal Operations (10) Committee
review of proposed amendments to the Election Campaign Ordinance and directed the Committee
to conduct a public forum on the proposed amendments at the earliest possible date. In response,
the 10 Committee conducted a public forum to discuss the proposed amendments at its regular
meeting on November 19, 2001. Public notification of this meeting was provided as legally
required, and also to the'incumbents and candidates for the affected elective seats. The League of
Women Voters, speakers at the October 16 Board of Supervisors meeting, and other individuals
with known interest in this issue were also individually contacted, as indicated on the agenda
distribution list. In addition, the Contra Costa Times publicized the meeting in an article published
in the Sunday edition, the day prior to the meeting.
CONTINUED ON ATTACHMENT: YES SIGNATURE:
RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE
APPROVE OTHER
SIGNATURE(S):
HN GIOIA,CHAIR MARK DeSAULNIER
ACTION OF BOARD ON eC $ilk APPROVE AS RECOMMENDED D OTHER
VOTE OF SUPERVISORS I HEREBY CERTIFY THAT THIS IS A TRUE
AND CORRECT COPY OF AN ACTION TAKEN
UNANIMOUS(ABSENT ) AND ENTERED ON THE MINUTES OF THE
BOARD OF SUPERVISORS ON THE DATE
AYES: NOES: SHOWN.
ABSENT: ABSTAIN:
ATTESTED,b If U--kk. I
CONTACT: JULIE ENEA(925)335-1077 JOHN SWEETEN,CLER OF THE
BOARD OF SUPERVIS RS AND
COUNTY ADMINISTRATOR
CC: INTERNAL OPERATIONS COMMITTEE STAFF
INCUMBENTS AND CANDIDATES FOR COUNTYWIDE ELECTIVE OFFICES
COUNTY COUNSEL
COUNTY ADMINISTRATOR
l
BY O DEPUTY
Proposed Amendments to Election Campaign Ordinance December 11, 2001
Internal Operations Committee Page 2
The proposed amendments to the Elections Campaign Ordinance would apply only to non-
supervisorial offices and would provide that a person or broad-based political committee could
contribute up to a specified amount per election cycle rather than per calendar or fiscal year. This
change is recommended to address possible legal challenges and inconsistencies caused by the
change in the date of the primary election from June to March and to help even the campaign
fundraising opportunities for all candidates.
Inasmuch as the current ordinance may be subject to legal challenge, our Committee recommends
that the Board immediately declare its intent to adopt the recommended changes. However, to
avoid the potential for confusion that would likely result if such changes were implemented during
the current election cycle, our Committee recommends that the changes not be made operative
until the beginning of the next election cycle (after November 2002).
The appropriate dollar limits for individual and broad-based political action committees requires.
further analysis. Therefore, our. Committee recommends that the Board of Supervisors revisit this
issue after the March 2002 primary election and make a determination on the appropriate limit for
campaign contributions, to be incorporated in the forthcoming ordinance.
Office of the County Counsel Contra Costa County
651 Pine Street, 9th Floor Phone: (925) 335-1800
Martinez, CA 94553 Fax: (925)646-1078
Date: November 14, 2001
To: Internal Operations Committee
From: Silvano B. Marchesi, County Counsel
By: Mary Ann McNett Mason, Deputy County Counsel • �f /�
Re: Contribution limits applicable to Candidates for Countywide Office(Assessor,
Auditor, County Clerk, District Attorney, Sheriff, Treasurer/Tax Collector)
After the Board of Supervisors referred this matter to the Internal Operations
Committee on October 16, 2001, we revised the draft ordinance that would amend Ordinance
Code sections 530-2.402 "Individual Campaign Contributions" and 530=2.404 "Broad Based
Political Committees." These sections, which apply only to non-supervisorial candidates, would
be amended to impose contribution limits solely on a per election cycle basis. Copies of the
revised draft ordinance and of our memorandum of October 2, 2001 discussing the existing
ordinance provisions applicable to non-supervisorial candidates, are attached. In the revised draft
ordinance, additions to the existing ordinance sections are shown by redlining and deletions are
shown by strikeout.
As revised, draft section 530-2.402 "Individual campaign contributions"would
provide that a person or non-broad based committee could contribute up to (an amount to be
specified) per election cycle. At any point in the election cycle, the contributor could make the
maximum contribution, or a series of contributions that did not exceed the maximum
contribution.
Draft section 530-2.404 would provide that a broad based political committee could
contribute up to (an amount to be specified)per election cycle and that in the aggregate, a
candidate could not accept more than (an amount to be specified) per election cycle from all
broad based political committees. These limits would apply to all contributions, not only to cash
contributions.
Draft section V "Effective and Operative Date" now provides that the ordinance will
take effect 30 days after passage,but will become operative on a date to be specified. Thus,
depending on the date specified, the ordinance could become operative on a date subsequent to
the effective date.
In the event that the Board of Supervisors adopts the draft ordinance with modified
contribution limits and an operative date during the current election cycle, the draft ordinance
includes a section intended to clarify the Board's intent 1) that candidates and their treasurers
will not be subject to sanction for the receipt of contributions prior to the operative date of the
November 14, 2001
Page 2
new ordinance if such contributions were lawful when made, even if the contributions exceed
any new contribution limits and 2) that the candidate will not be required to refund all or part of
contributions received prior to the operative date of the new ordinance if such contributions were
lawful when received.
MAM/am
attachments
cc: County Administrator
Jim Sepulveda, Deputy District Attorney
Steve Weir, County Clerk-Recorder
ORDINANCE NO. 2001-
(Amendments to Division 530 Election Campaign)
The Contra Costa County Board of Supervisors ordains as follows (omitting the parenthetical
footnotes from the official text of the enacted or amended provisions of the County Ordinance
Code).
SECTION I. SUN AARY. This ordinance amends Division 530, Election Campaign, section
530-2.402 to provide that limits on individual campaign contributions for non-supervisorial
candidates are imposed per election cycle and amends section 530-2.404 to provide that limits on
broad based political committee contributions for non-supervisorial candidates are imposed per
election cycle. This ordinance adds an uncodified section clarifying the Board's intent that no
candidate shall be subject to sanction for receipt of lawful contributions prior to the effective
?�•' -''.: ....:......��., ':.?;5:s:s;•.. ..w:':Yom',:.:' .� .. .. ...:
operative date of this ordinance and specif esttie operative date;.ofttie ordinance:
SECTION II.. Section 530-2.402 is amended to read:
530-2.402 Individual campaign contributions. In a single county election cycle, no
person or political committee(other than the candidate or a broad based political committee)"
shall make, and no candidate or campaign treasurer shall accept, any contribution to or for a
single candidate for county office.or to or for a committee authorized in writing by the candidate
to accept contributions for him or her, which will cause the total amount contributed by such
person or political committee in support of that candidate fortliat election cycle.to exceed one
thousand six hundred seventr-five dollars, provided, that in any calendat
year in which the candidate does nat stwid foi election the m nitted contribution shall
be limited to two hwidred twenty-five dollars and in the calendar year in which the candidate
stwids fbi election, the n Ltribution shall be five hwidred dollars fbr the period from
imitz . n�
December
eco L__1 1 SI-ef4hat+--ye—E1f.
(Ords. 01- § 2, 89-11, 84-9).
SECTION III. Section 530-2.402 is amended to read:
530-2.404 Broad based political committees. In anyfiscal year a"single county election
cycle, no broad based political committee shall make, and no candidate or campaign treasurer
shall accept, any cash contribution to or for a single candidate for county office or to or for a
committee authorized in writing by the candidate to accept contributions for him orkl%er, which
will cause the total amount contributed by such broad based political committee in support of
that candidate in for that fiscal year election cycle to exceed five thousmid
dollars, provided, nevertheless, that the total aggregate amount of contributions from all broad
based political committees which that may be accepted by a single candidate in an election cycle
1
shall not exceed twenty-five thousand dollars.
(Ords. 01- , § 3, 89-11).
SECTION IV. EFFECT OF CONTRIBUTION RECEIVED BEFORE THE OPERATIVE
DATE OF THIS ORDINANCE. No county candidate or campaign treasurer who was subject to
the provisions of sections 530-2.402 and 530-2.404 before the effective operati'Ve date of this
ordinance shall be subject to civil or criminal sanction.for receipt of a contribution prior to the
effective operative date of this ordinance if such contribution was lawful when received, whether
or-not the amount of such contribution would have exceeded the contribution limits applicable to
such candidate after the effective gperative date of this ordinance. Nothing in this ordinance
shall require a candidate or his or her campaign treasurer to refund all or part of a contribution
received prior to the effective oper t ve date of this ordinance if such contribution was lawful
when received.
SECTION V. EFFECTIVE AND OPERATIVE DATE. This ordinance becomes effective 30
days after passage, and within 15 days after passage shall be published once with the names of
supervisors voting for and against it in the a newspaper
published in this Count This>ordiriarice shall be o'eratie ori< J`
PASSED ON , by the following vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
ATTEST: JOHN SWEETEN, Clerk of the
Board and County Administrator
By:
Deputy Board Chair
[SEAL]
2
Office of the County Counsel Contra Costa County
651 Pine Street, 9th Floor Phone:(925)335-1800
Martinez, CA 94553 Fax:(925)646-1078
Date: October 2, 2001
To: Supervisor John Gioia
From: Silvano B. Marchesi, County Counsel
By: Mary Ann McNett Mason, Deputy County Counsel .�
Re: Contribution limits applicable to Candidates for Countywide Office(Assessor,
Auditor,County Clerk,District Attorney, Sheriff,Treasurer/Tax Collector)
You have asked that this office address the possible amendment of the provisions of
the County's Election Campaign Ordinance that impose contribution limits on candidates for
countywide office. Specifically we have been asked to review Ordinance Code sections 530-
2.402"Individual Campaign Contributions" and 530-2.404"Broad based political committees."
These sections apply only to candidates for countywide office: Assessor; Auditor; County Clerk;
District Attorney; Sheriff;Treasurer/Tax Collector. These sections do not apply to candidates
for County Supervisor.
A. Current Ordinance
Section 530-2.402 provides that in an election cycle a person may not contribute
more than$1,675 to a candidate for the above-referenced county offices. In addition,the section
imposes per year contribution limits throughout the term of the election cycle. During years in
which an election is not held, a person may contribute$225 a year. During election years, a
person may contribute$500 from January 1 to June 30 and$500 from July 1 to December 31.
Taken together,the annual contributions add up to the maximum amount of$1,675. Thus, if a
candidate was elected to office in June 1998,during the subsequent election cycle, a contributor
could have donated$ 500 from July to December 1998 and$225 per year for 1999,2000, and
2001, and could donate$ 500 again January 1, 2002.
Section 530-2.402 was enacted in 1984, when the primary election still occurred in
June. Since that time,the Board has amended the definition of"election cycle"to account for the
March primary,but has not addressed the contribution timeframes in section 530-2.402. (Ord.
Code, § 530-2.212.) Thus, in an election year a non-supervisorial candidate has a two month
period to raise$500 contributions before the March primary, and a runoff candidate cannot raise
an additional $500 toward the general election until July 1. (Ord. Code, § 530-2.402.)
Section 530-2.404 provides that a broad based political committee may contribute up
to $ 5,000 cash to a non-supervisorial candidate per fiscal year. Once a candidate is elected, the
subsequent election cycle spans four different fiscal years. (Ord. Code, § 530-2.212.) A broad
based political committee that contributes the maximum amount to the same candidate each
October 2, 2001
Page 2
fiscal year would contribute$20,000 over the course of an election cycle. A candidate may
Accept an aggregate total of$25,000 from broad based political action committees over the
course of the election cycle. (Ord. Code, § 530-2.404.)
In our view, inasmuch as these sections impose contribution limits by calendar year
or fiscal year and not solely per election cycle, they may be subject to legal challenge. The
imposition of campaign contribution limits by fiscal year rather than by election has been held
unconstitutional on the grounds that limits by fiscal year restrict free speech and favor
incumbents against challengers. (Service Employees Int I Union v. Fair Political Practices.
Com., 955 F.2d 1312, 1321, (9`h Cir. Cal. 1992.) We think that this reasoning also would apply
to limits imposed by calendar year in that such limits operate the same as limits by fiscal year.
B. Draft Ordinance
As requested, to address possible legal challenges and inconsistencies caused by the
change in the date of the primary election,we have drafted a proposed ordinance that would
amend sections 530-2.402 and 530-2.404 to impose contribution limits on a per election cycle
basis only. All reference to contributions by fiscal year or calendar year would be removed.
Additions to the existing ordinance sections are shown by redlining and deletions are shown by
strikeout:
As drafted, section 530-2.402 "Individual campaign contributions"would provide
that a person or non-broad based committee could give up to $1,675 per election cycle. At any
point in the election cycle,the contributor could make the maximum contribution, or a series of
contributions that did not exceed the maximum contribution.
As drafted, section 530-2.404 would provide that a broad based political committee
could contribution up to(an amount.to be specified)per election cycle and that in the aggregate,
a candidate could not accept more than(an amount to be specified)per election cycle from all
broad based political committees. These limits would apply to all contributions, not only to cash
contributions.
In the event that the Board of Supervisors adopts the draft ordinance with modified
contribution limits and an effective date during the current election cycle, the draft ordinance
includes a section intended to clarify the Board's intent 1)that candidates and their treasurers
will not be subject to sanction for the receipt of contributions prior to the effective date of the
new ordinance if such contributions were lawful when made,even if the contributions exceed
any new contribution limits and 2) that the candidate will not be required to refund all or part of
contributions received prior to the effective date of the new ordinance if such contributions were
lawful when received.
MAMIam
October 2, 2001
Page 3
attachment
cc: Members, Board of Supervisors
County Administrator
Jim Sepulveda, Deputy District Attorney
Steve Weir, County Clerk-Recorder
Clerk of the Board(Press Box)
t ``�•.6� L .,per
t GAYLE B. U I LKEMA COUNTY ADMINISTRATION BLDG.
651 PINE STREF:r,ROOM 108A
o: •..lainI�` CONTRA COSTA COUNTY BOARD OF SUPERVISORS
�.. r MARTINEZ,CA 94553-1293
SUPERVISORIAL DISTRICT 2
�v'• (915)335-1046—FAX(925)335-1076
,rT ouK;f;
MEMO
DATE: November 6, 2001
TO: 'Julie Enea
FROM: Gayle B. Uilkema, By: Lauri Byers
SUBJECT: Election Campaign Ordinance
The attached letter is for consideration of the I.O. committee regarding the election
campaign ordinance.
Thank you for your assistance in this matter.
GBU/Isb
CONTRA COSTA Cnl:'"
RECEIVED
NOV 8 �nnl
OFFICE C
CoUPI►DM� .: . '►'R
.f - --
RECDkTED
E
j OCT 2 2001 .
October 12, 2001. UL
TO : Contra Costa Board of Supervisors; Gayle Uilkema, Chairman
FROM : Ray Sloan
RE : Item D.3; Election Campaign Ordinance
This is a follow-up to the. remarks I made before the Board of Supervisors Octpber 9".
I tried to make the point that the present election campaign ordinance is cumbersom*convoluted
and discriminatory. In trying to understand the ordinance I have had a few election attorneys look
at the ordinance and conclude that it is written in a manner that seems to be deliberately
confusing.
The ordinance as it exists, imposing the per year contribution limits throughout the term is
discriminatory in favor of the incumbent office holder. Your own counsel states, "In as much as
these sections impose contribution limits by calendar year or fiscal year and not solely per election
cycle, they may be subject to legal challenge." In Service Employees Int'1 v. Fair Political
Practices Com., (955 F.2d 1312, 1321) appellees argue that in tying the contribution limits to
fiscal years. "Challengers do not typically decide to run for office years in advance of the election.
As a result, they are unable to engage in fund-raising during each fiscal year between elections as
incumbents commonly do."
I believe that it is paramount that to maintain the integrity of the elections for county
offices that the Board of Supervisors, as the regulatory agency, encourage and maintain rules, as
they relate to campaign contributions, so as to foster county campaigns on a fair playing field.
Fundraising is the cornerstone of being able to be competitive in getting ones message out
to the voters. In most cases, the money a candidate raises in the early stages of the campaign
signals to the press who is a viable candidate and who isn't. All of the members of this body
know the challenge of raising money for campaigns defines in most cases who will prevail.
The present ordinance does a disservice to the free flow of information, and in the ability
of a candidate to communicate to the constituency. It is too restrictive for a candidate to raise
money in our large county. If a candidate cannot raise the money to get a message out in a timely
manner we will not have elections that are competitive. By enacting the recommendation of
allowing a maximun individual contribution of.$1,675 for the March and November election, it
will take some of the pressure oft, allowing the candidates to seek larger campaign contributions.
If the ordinance is viewed as wrong, it does absolutely no good to wait until after the
election to fix it.