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HomeMy WebLinkAbout1990 1 i I OFFICE OF THE CITY ATTORNEY MEMORANDUM TO: Honorable mayor and members of the city council FROM: Debra A. Drayovitch, City Atto':ney SUBJECT! conflict of interest for Board Members DATE: December 71 1990 i At the last council meeting, councilmember Alexander asked me to prepare a complete briefing regarding the issue of conflict of interest for members of city boards and co.nm.issions. A brief j history of developments in this regard follows; i In March of 1989, Denise Harpool, Purchasing Buyer, realized that some City boardmembers were accepting work from the city and submitted a request for a legal "ruling on the eligibility of any i ! board or committee member to be a vendor/contractor of the City of Denton." Attached as Exhibit "A" is a copy of the opinion I prepared in response to her request. Upon receipt of this opinion, f John McGrane sent every boardmember a copy of the opinion, together with a memo. A copy of John's memo is attached as Exhibit "B". In the summer of 1989, the council. considered this subject at a work session. Jesus Nava presented options for the council's consideration, as outlined in his memo of June 16, 1989, a copy of which is attached as Exhibit "C". You considered these options at your council meeting of June 20, 1989 and determined to, (1) Leave the boards as they currently were, (2) Enlarge the selection pool of potential appointees, (3) Advise the members of the boards that they could bid on a city contract but must resign if they received the contract, (4) Rotate members for only two year termsf and (5) Publish a news release by the Mayor to seek additional volunteers. Despite this consensus, Mr. Mulroy continued to write the City letters indicating he felt he could continue to serve as a board member when working for the City. When he was the low bidder, hi.s bide were accepted and the purch4ssing department wrote him that upon accepting the bid, he was resigning his position as a board member. However, I do not know if the Mayor or any councilmembers ever advised him that continuing to accept work would result in his removal from office. F I Honorable m 'ior and Members of the City Council December 7, 1990 Page 2 in March, 1990, Mayor Stephens scheduled a meeting with members of the various code boards. At the meeting, he and I explained the city charter provision regarding conflict of interest for city officers and ho charged the boards with making a recommendation as to whether they should change the board structure to allow the met and 1 board members to contract with the City. T Board to Jackie ing considered these alternatives. Evidently, decided that they Doyle's memo, attached as Exhibit "D", they preferred to take no immediate action except for the Electric Code Board of Appeals. Couneilmember Alexander has requested that I summarize the history of the conflict of interest issuadis roof de you ,t to enforce available to the council. One option ard that section 14.04 of the city charter, and advise o b she has resigned upon knowingly accepting work from the City, as a board member. If the boardmember refuses to resign, the Mayor and councilmembers shall remove him from office. In the i alternative, you still have available the other options Jesus presented to you, namely: 1. Make all boards and commissions advisory in nature, with the exception of the Civil Service Commission and the Board of Adjustment. If their role were to become advisory, then their members would not be considered officers of the city within the context of Section 14.04 of the city { term into charter, and would therefor be able h it enter their contracts with the city during office. as final 2. dLeave the ecision-making boards and but commissions s the number and/or tenure of membership in ointerest lessen n the he probability situations. While you are considering this subject, I recommend that you may wish to consider directing me to prepare an ordinance which provides that a boardmember shall not appear before the board of a acceptable which he a member a The q uestion of whether item iwash practice arose when I gave abriWayne on legal slues anotherto the Building Code Board of Appeals. Allen board member advised that they might have to appear onbehalfeoBf arclient to present a request for a variance or an appeal to a. wanted to know whether it was legal for them to discuss and vote on 1 Honorable Mayor and members of the city Council December 7, 1990 Page 3 the rcquests. Attached as Exhibit "E" is a draft of a memorandum Joe has prepared in response to this request, along with a copy of I a memo that former City Attorney C.J. Taylor wrote on the same subject several years ago. To enact a regulation providing that a board member shall not represent himself before the board would alleviate any uncertainty about the question. Should you have any questions relative to this matter, please advise. Respectfully submitted, Debra A. Drayovitch DADSlkh Attachments r I xct Lloyd V. Harrell, City Manager r i~ O bIA OFFICE OF THE CITY ATTORNEY MEMORANDUM TO: Denise Manning, Purchasing Buyer FROM: Debra Adami Drayovitch, City Attorney SUBJECT; Legal Opinion No. 89-03 i 1 Whether City Board and Commission Members May Enter Into Contracts With The City DATE: April 20, 1989 in your request of March 30, 1989, you have requested "a ruling on the eligibility of any board or committee member to be a vendor/contractor for the City of Denton. Basically, you ask { whether city board and commission members are eligibly to be awarded bids on city projects. If a board member submitted the low bid for a particular project to sell goods or services to the city pursuant to a contract. Section 14.04 of the Chaser of the City of Denton reads as £ollowt. Section 14.04. Personal Interest. ' No officer or employee of the City of Denton shall have a financial interest, direct or indirect, in any contract with the city, or be financially interested, directly or indirectly, in the sale to j or by the City of any land, materials, supplies or 1 services, except on behalf of the City as an officer I or employee. Any willful violation of this section shall constitute malfeasance in office, and any officer or emeployse guilty thereof shall forfeit his office or position. The Texas courts have had several occasions to discuss charter provistona similar to 02ection1 14.04. In city of Edinbur v. Ellis, 5~P S.W.2d 99 (Tex. Comm n. App. 1933) tie court scussa Me general rule that municipal contracts in which officers or employees have a personal pecuniary interest are void as against public policy. In Delta Electric Construction Company v. Cie of San Antonio, 437 S.W, 20 602 ex. v. pp* an non o , wrd- n.r.e.) the court considered a contract between the city and a member of the city'a electrical board and held it was against public policy and void. The court reached this decision even though the contract was for worS. in the water department and the the lelectrical dno vote on the award of the contracto water department and had Denise Manning April 20, 1989 Page 2 The court in Delta Electric discussed whether a member of the San Antonio Electrical oar was an officer and, after much discussion, concluded lie was. The San Antonio Charter provision, ~ust as that of the Denton Charter, does not define the ter4, 'officer". The Supreme Court of Texas, in Kimbrou h v, Barnett, 93 Tex. 301, 55 S.W. 120 approved the follow ng e n t on o an office: The term office is defined by Mr. Mechem, in his work on Public Officers (section 1), thus: 'Public office is the right, authority and duty created and conferred by law, by which, for a given period, either fixed by law, or enduring at the pleasure of the creating power, an individual is interested with some portion of the sovereign junctions of the government, to be exercised by him for the benefit of the public. The correctness of this definition is nowhere questioned, so far as we know, and it is useless to add supporting authorities. The Delta Court, in reaching its conclusion relied on the follow-wing facts: (1) The Electrical Board was created by ordinance of the city; (2) The Board Members are appointed by the City Council upon recommendation of the city Manager; (3) The Board passes upon the qualifications of all applicants for certificates of electrical licenses; (4) The Board may review all decisions of the ` Chief Electrical Inapeoator and his assistants; (5) The Board may alter, amend, or revoke actions or decisions of the inspectors; (6) The board has the power to suspend or revoke the certificate or licensee of persons found guilty of certain practices,; (7) The members of the board serve for a fixed term of office; and Denise Manning April 20, 1989 ' Page 3 (8) Members of the board take an oath of office and receive a fixed compensation. Tho court concluded that the Electrical Board "performs and sovereign r functions of the city for the benefit of the public, thus its members constitute officers of the city. The fact that the officer (the Electrical Board member) did not influence in any way the the award contact was contract vold. was held to not be determinative of whether Applying the definition set forth in Delta Electric, those persons serving on boards and commissions of " the City Ti Denton which serve purely in an advisory capacity and do not exercise any sovereign power are not, in the opinion of the undersigned, officers within the context of Section 14.04 of the Charter and may enter into contracts with the city during their term of office. Those boards and commissions are as follows: ~ j Library Board i Airport Advisory Board Citizens Traffic Safety Support Commission Human Resources Committee Parks and Recreation Board Community Development Block Grant Committee Members of the following boards and commissions perform as officers of thr city: Electrical Code Board Board of Adjustment LJ Building Code Board Civil Service Commission Plumbing and Mechanical Code Board Planning and Zoning Commission Therefore, a member of an of these boards and commissions would ' to willfully tenter into a ~oconG act with the city during his term of office. e ra am ayov DAD/lh cc: Mayor Ray Stephens City Council Members Lloyd V. Harrell 33031 I / j i d CITY o{pENTON, TFXAS MUNICIPAL 9UILDING DENTON, TEXAS 76201 TELEPHONE (817) 566.6 1 i MHM9AANDOM } I DATEt April 26, 1989 i S0I All Board and Commission Members i i FRONt John F. ycGrans, Executive Director of Finance SU&JECTt CONTRACTS WITH THH CITY 1 Attached is a copy of a legal opinion from the city Attorney's office addressing the issue of whether city Board and Commission members may enter into contkacts with the Clty. As 14.04 of the Charter deals with personal eInta[est" the legal opinion, Section " or employee Of the City of Denton shall hays financialt interest, directly or and tes that indireotly, with any contract with the City, ' ono officer The opinion also cites case law which addresses the definition of officers of cities, The City Attorney states that, in her opinior;, Section 14,04 of t Charter does not include those persons that serve puroly in an advisory Capacity and do not exercise any sovereign he continue to purchase goods and/or services from these Individuals, heThistwould include members of the following Boards and Commissional o Tice Library Board o The Human Resources Comsittee o Airport Advisory Board o citisena Traffic safety Support Commission Parka i Recreation aoard o Comsunity Development Block Grant Committee However, the City Attorney does feel that members of the following Boards and Commissions perform acts as officers of the City and would come under the context of Section 140042 o The Electrical Code Boacd o The Building Code Board o The Board of ACommissio mnt o Planning and Zoning Commission o C ivil Service o Plumbing i Mechanical anianica al Board ~r7~R~.,w.r.•~ - r _ T ..,-~.,5-- v W- - --r --,1 .--mow--- Memo to Board and Commission Members S April 26, 1989 Page 2 The administrative staff in sympathetic with the problem and the potential confltct that exists between having good qualified board members and receiving lowest and best bids from its vendors, The staff has communicated this to City Council and the subject is currently under 'review. Hopefully, the Council will be able to implement a system that would help mitigate any effects of Section 14.04. However, until ouch time that official action can be taken either through Council action or a change in the section of the City Charter, we must follow tL* advice of our City Attorney and the Chart_er_ of the City ofi Denton which requires that Board and Commission members which can exercise sovereign power and perform as officeri of the City shall not be able to sell goods. or perform services to the City of Denton, Should have any questions, or if you would like to discuss this memo in further detailr please feel free to contact me at 566••8320. J n plcQrane J?Mc Os a! ✓ Attachment cot Lloyd V. Harrell, City Manager mayor and members of the City Council r t 4469? e z 1 Gate: June 16, 1989 To: Lloyd V. Harrell, City Manager From: Jesus Nava •Jr., Assistant to the City Manaqer Sub.iect: CONFLICT OF INTEREST WITH BOARDS AND COMMISSIONS i John McGrane, Debra Eirayovitch, and I have discussed the ongainq problem of decision making board and commission members being y ineliqible to be awarded contracts. The following alternatives may assist us in solving this matter. 1 ALTERNATIVES 1. Male all boards and commissions advisory in nature, with the exception of the Civil Service Commission and the board of AdJustment. If their role became advisory then their members would not be considered officers of the City, !vithin the context of Section 14.o4 of the City Charter, and would therefore be able to enter into contracts with the city during their term i of office. j Ordinance changes would be required to make the boards and commissions advisory. However, there would be a neqative impact. The City Council would be responsible for any and all appeals to decisions made by the boards and commissions. 2. Leavp the boards and commissions as final decision-making bodies, but reduce the number and/or tenure of their membership in order to lessen the probability of conflict of interest situations. Reducing the memhership and/or tenure of boards and commissions would lessen the need to appoint as many professionals and would thereby increase the number of contractors that would be eligible to bid for City business. Currently, the technical boards have 7 members (Electrical Code, Building Code, and Plumbing and Mechanical). These technical code boards present the greatest problem and reducing their membership may help. Changes in membership and tenure would also require changes in ordinances. The negative impact of shortening the current tenure of members would be having to make appointments mare frequently. In addition, this action could make it more difficult to obtain a quorum. 3. Leave the boards and commissions as they are and concentrate on enforcement of Section 14.44 of the City Charter, "Personal Interest". Under this option, staff would inform board and commission members of the Municipal Code requirements and request that they complete i Conflict of Interest Statements. The statements would require that each appointee, as an officer of the City, disclose his or her financial interests, direct and indirect, in any and all contracts with the City. These statements would then be shared with the Purchasing Department who would check them to avoid conflict of interest situations. r Attached is a memo from Debra giving a legal opinion an whether city boards and commission members may enter into contracts with the city. It represents our official position an the matter. i If additional information is needed, please contact me. I ccs John McGrane, Finance Director Debra Drayovitch, City Attorney { r { i r i 1 JAA C1 o>I06M70N, TEXAS MUNICIPAL BUILDING Y DENTON, TEXAS 76201 / TELEPHONE (817) 566-8200 MhMORANDUM DATE: June 290 1990 TO: Deborah Drayovitch, City Attorney FROM., Jackie Doyle, Building Official SUBJECT: Conflict of Interest regarding Board members r J 1. Building Code Board's recommendation is to leave law as presently written. 2, Plumbing and Mechanical Code Board's recommendation I is to leave law as is until charter is amended and then change law. 3. The hlectricai Code Board suggests that boards have seven members made up oftthr a ex-officio members and four noncontr contractors would provide input, but would have no vote, and the four noncontractor members would be voting members (need an additional number of voting members). Sorry this is late and very brief, but I wanted to get thee basic information to you. If you need more information, plea! let me know. e Build ngoOfficial ,J~yN291996 ' 0013S CITY OF OP` ' LEGAL "eT. .r , 1 I, I 1 OFFICE OF THE CITY ATTORNEY MEMORANDUM To: Wayne Allen, Building Code Board 4 FROM. Joe D. Morris, Assistant City Attorney ! SUBJECT: Officials Representing Clients Before a Board DATE: November 28, 1990 4 You ask whether a member of the Building code Board may appear 1 before the Board to represent a client requesting a variance. For the following reasons, we believe a public official may not lawfully represent a client before a board of which the member sits. Members of the Building Code Board of Appeals are public officials of the City. A public office is a public trust which imposes upon the officer the performance of certain duties for the common good. Those duties are fiduciary in character. The official is under an obligation to serve the public with the highest fidelity and undivided loyalty. It requires the officer to subordinate his own private or personal interest when necessary to avoid a conflict. f The authorities generally agree that these settled principles I prevent a board member from representing a private party before the board of which he is a member; f it is the duty of public officials to refrain from I outside activities which interfere with the proper discharge of their duties. . . . And an officer cannot lawfully act as the agent of one person where the private agency will come in conflict with his official duties. To act Per one of the parties imposes an interest adverse to the other. 63 AM. JUR. 2d Public officials and Employe@s § 321. If you have any questions or comments about this matter, please call at your convenience. J D. Morris JDM/lkh cc: Lloyd V. Harrell, city Manager beb y } T rte. 1w- ~WV~ uITY OF DENTON, TEXAS OFFICE OF THE CITY ATTORNEY VLVORANDUM C.J. Taylor, Jr., City Attorney Joe D. Worris, Assistant City Attorney Robert B. Hunter, Assistant City Attorney DATE: July 19, 1983 TO: G. Chris Hartung, City Manager FROM: C. J. Taylor, Jr., City Attorney I ` SUBJECT: 0 inion NO. 346 Whether a member of the Planning and Zoning Commission may represent clients before the Commission i I am in receipt of your memorandum dated July 15, 1983 wherein you %I state that a member of the Planning and Zoning Commission, whose occupation is velated to land development, recently presented a zoning change request to the Commission on behalf of his client. I You further state that the Commission member announced he had a conflict of interest, left his seat, joined the audience, and addressed the Commission on behalf of his client. You add that the member also prepared the site plan which accompanied the zoning request. You ask whether these facts may constitute a possible conflict of interest. It is a fundamental rule of law that`a public official is not eligible to participate in a matter which affects his personal pecuniary interest. Hager v. State ex rel. TeVault, 446 S.W.2d 43, 49 (Tex.Civ.App.--Beaumont, 19090 writ re ti, n.r.e.). In recognition of this rule, it is generally held that a municipal officer may be prohibited from representing private interests before certain governmental agencies, using confidential information acquired during his public tenure for personal gain and accepting employment, either, during the course of his public duties or for a specified period thereafter, which will require or induce the officer to disclose confidential information or information not available to thus public generally. Rhyne, The Law of Local Go!lernment Operations, 1980 Ed., p. 156. Recognizing -that broad, ars rulings relating to adverse interests may discourage qualified persons from serving as public officers, the courts have tended to determine the issue on a case by case basis, depending on the par- ticular set of facts involved. Lever, the overwhelming majority of cases have found a conflict of interest to exist where the public official has a business relationship with an interested party ti. Chris Hartung July 19, 1983 Page 2 concerning the subject matter. before the same agency, board, or commission of which the official is a member. 10 ALR3d 694, Disqualification for Bias or interest of Administrative Officer Sitting in Zoning Proceeding. Once it is found that a public official has a conflict of interest, the courts may void the action taken and hold that any action tainted by the participation of' an officer having an adverse interest is invalid even though the vote of the interested officer was not determinative of the result. Rhyne, supra, at 157. Even where the officer casts no vote at all, the courts have found that such officer's participation in the proceedings invalidated the action on the basis of the "mutual backscratching" theory, because " of the possibility that the official would be in a position to trade E favors with other officials. Sands and Libonati, Loc.Govt,Law Section 11.10, For example, in -T Ott VI. H- ewell, 22 NJ Super 106, 91 A2d 667 (1952), the Court voided a zoning proceeding because a member had sold the subject property to the petitioner and participated in the discussion. Even though the vote of the disqualified member was not necessary to the action taken, the Court observed that the member's participation in the discussion may have influenced the opinion of the other members and thus have cast suspicion on the impartiality of the decision. Similarly, the Court P nullified a zoning decision in Bove v. Board of Review, 185 A2d 751 (1962,R1) where the Chairman disqualified himself and abstained from voting .because of a conflict of interest (he had represented the { petitioners in similar real estate matters in the past), yet continued to participate in the discussion. I In view of the foregoing, it is the opinion of this office that a Planning and Zoning Commission member who has been retained by a ` client to perform work on any part of the subject matter pertaining to the business of the Commission must not: only announce such con- 'flict and disqualify himself from voting, but must refrain from any participation at every stage of the proceeding. To avoid any charges that the proceedings were tainted by such conflict, the safest practice would be for such member to leave the room during the proceedings'. Of course, the City Council has the authority, by ordinance, to prohibit any members of the various city boards and commissions from accepting any employment or representing any clients in connection with any matters which are before such boards and commissions. r R. C. J 4LJ TJR:jcs CJ xc: Mayor and City Council Planning and Zoning Commission Jeff Meyer v mrz AVI t .3 3 MECHANICAL, INC. 7 hlecwvllcaf F WilostwIf (lolMwclors N T ACrL A000120C aApril 24, 1990 city of Denton 901-B Texas street Denton, Texas 76201 ATTENTION: MR. TOM SHAW Dear Tom, This firm is in receipt of Purchase Order PC 96262 from your office with amended paragraph referencing my Plumbing Board membership (attached). Please be advised that I was a duly appiinted Boai:d Member prior to your issuance of subject Purchase Order and several others in the past. { If the City feels its conflict of interest opinion is truly valid and enforceable, it is questioned why the City continues is contract with Board Members. It appears as if the fearful of its own policy making, Concerning this particular contract it is curious to note that without this firm's low bid the City would be paying almost three times the cost to an out of town contractor. } Perhaps after a year of dellberation it should not be too optimistic to expect a resolution in the near future. B the way, when is the last time that you know o/f someone a consenting to major surgery without a second doctor's opinion? Yours very truly, CBS MECHANICAL, INO, Joseph S, Mulroy President JSM/mmk APRZ 61990 or,: city Council Board Members Richard Hayes C" orn~„To City Manager ti~GAL N %,-c.ity Attorney 5001 WEST UNIVERSITY ORWE OENTON, TEXAS 76201 (817)381.7568 MEr140(214)434-1 Ull, i tisa`s ~ MAY 2 I~ May 22, 1989 MECHANICAL, INC. C l CITY Mechanical 8 Wdu,lrlal ConlraclorS `FACLA000720C city of Denton 1 901-B Texas Street Denton, Texas 76201 ATTENTION: DENISE MANNINO Dear Ms. Manning: This Eiza is in receipt of G1tY 1989eletterurregazd~n9 emY #PC 90734 and 90735 and your May l7, i appointment on the Mechanical Board. It is my understanding that the city council will soonlmeel to resolve the issues recently brought forth by your dpartmen. To avoid o activetparticipationp(abstain from lvoting) iuntil sthe matteraIs n resolved. Please be reminded that my appointment was by the City Council at the rerommendatlon of the Mayor, at a time when this firm was conducting business as usual with the City. It is only sensible that if the auspices under which I serve have been changed by the Council, then it would be incumbent upon the Council to rescind my appointment issuefto be considered by of are the matters this npoint their n zetime aolution there in the Council + 1. If the legal opinion is applied as written, whom from i the active local business citizenry can the council call upon to repzesent both the community and industry standards? 2. How far does the legal opinion extend? Shall those who are employed by or. contract with the City be forced to disp^se of their securityiholdings or resign boaroaita, s at inst that £undinghor business intanysmanasr7er(o ive city p 3. Does this legal opinion suggest that the integrity of ' previous Board activities are in question? As you may well knov, provisions are already in force to excuse individual members from participating in Board action whenever a potential conflict of interest exists. If there is a spocific complaint that this policy is not strictly adhered to, then that would appear to be the issue, rather thanfthe overall integrity of the many city Boards' ioning. 8001 WEST UNlVENS17YDRfVE DENTON, TEXAS 78101 (817)387.7588 METRO (211) ,SA•11 1 i r~. Page Y y, If the recent opinion is applied a without lotthat x n it stand up 9 consideration 0 ill reaching legal :asai flcations7 11 tha Clt:y Council WIhe gsensible ieve due nslbls dappl I trust ication of the matter and offe guidlncl:has t he ves:y aea~c future. recent legal opinion Yours very trulYr C88-HoCRAMICALP INC. I 1 oseph S. Mulroy president f JOK/mm5 t ce% Mayor Ray Stephens Hugh Ayer Bob GOrtor► Randall BOYd Linnie HcAdams 1 Jane Hopkins Jim Alexander Inspector Jackie D*YIe, Chief Buildl,rsg George Becker Richard cooper Bob Sullivan JOEL Peploe - Pete Nock.- -Bill Burley at Law Richard Hayes, Attorney 'E 11 38 City of Denton City Council Minutes June 26, 1989 Page 2 4. The Council discussed the City of Denton Boards and Commissions relative to regulations governing conflicts of interest. Jesus Nava, Assistant to the City Manager, reviewed three alternatives to the governing of conflicts of interest; (1) make all the boards/commissions advisory - Council. would then have to review all the recommendations from those boards, (2) i leave the boards/commissions as final decision making but reduce the number of members and tenure of the boards - this would require ordinance changes for those affected boards and would probably result in more frequent appointments with possible difficulties obtaining a quorum, (3) leave the boards/ commissions as they presently are but have stricter enforcement of the Cr>de of Ordinances currently governing conflicts of j interest. The boards presenting the most problems were the Building Code board, the Electrical Code Board, and the Plumbing and Mechanical Code Board. Council Member McAdams suggested a notice be published in the newspaper requesting volunteers for certain boards such as the Plumbing and Mechanical Board, Building Code Board and Electrical Code Board, if there were no responses to the notice, then look at other alternatives. Council, Member Boyd agreed with Council Member McAdams to enlarge the selection pool and to possibly make the boards more advisory in nature rather than final decision making. Council Member Hopkins did not wish to leave the boards as they were because there appeared to be such a conflict existing with those boards, Council Member Gorton stated that he felt those three boards could be made advisory because he did not see the volume of requests that the Council would have to deal with. Council Member Boyd suggested contacting professional agencies to locate more people. Some individuals may not work in Denton but would be licensed to be appointed to the boards. Mayor Pro Tem Ayer suggested reducing the members of the Plumbing and Mechanical Code Board plus enlarging the selection pool, Debra Drayovitch, City Attorney, stated that the members of the mentioned boards could bid on contracts but must resign if they were awarded the contract. City of Denton City Council Minutes June 20, 1989 Page 3 il was (1) leave the boards as they Consensus of the Counc potential currently were, (2) enlarge the selection pool of ust resign if they received appointees, (3) advise the members of the boards that they could bid on a city contract but m two year terms and the ctt rotate to seek additional (5) publish volunteers. The Council convened into Executive Session to discuss 5 Lincolnwood vs. Cit legal matters (discussed in re. Flow and appo n men s estate, and per-"'s eT oar of Denton), real all City of Denton Boards and cons dered appointments to commissions). ~ to the Regular Session at 7:00 p.m. The Council then convened in in the Council Chambers. r Pro Tem Ayer) Council Members Alexander, PRESENT: Mayo Boyd, Gorton, Hopkins and McAdams. ABSENT; Mayor Stephens f received a presentation of awards for l The Council er Recycling Contest and winners of the City of Denton Newspaper Yard of the Month. art of !I Cecile Carson, Administrative Analyst, stated that as p ? the efforts to compete in thementeandrsolidh waste,~ttheaCityaof j to be aware of littenewspapers• Pioneer Paper Stock agreed to Denton was recycling contest. help sponsor a recycling made the Jack Lina, Plant Manager-Pioneer Paper stock, y { presentations to the following individuals: 4th Place - Alpha Lambda Delta - $50 3rd Place - Phi Chi Theta - $75 2nd Place - Preceptor Theta Chi - $150 1st Place - Grace Temple Baptist church - $300 Lena stated that 400 tons of newspaper had been col de ted i0 Denton during the last year and that the City receiye $12t for that paper. Carson then pr Eddie dandh Martha Harding E, Hh & awards Lindene and Joan Lair, and Gera Mace. l I I CITY OF DENTON AFFIRMATION OF QUALIFICATIONS A A r1 As a duly appointed member of the Board of Adjustment of the City of Denton, 1 Texas, I have taken the prescribed oath of office. i I also hereby affirm that: (1) I am a qualified voter of the Cityr (2) I am not in arrears in the payment of any taxes or other liabilities due the city) Financial interests, direct or indirect in (3) I do not and shall not have any materials, supplies of any contracts job, work service of anywiland,1e City, or be interested in the sale to or by the City ~ equipment) and term, I understand It shall felony during my (4 ) constitute cause convicted cremoval. 1 if I shall be the above qualifications, I also have been made aware of in addition to meeting provides: III (Rules and procedures before section 1-44, Article which Fissions) o i Chapter 1 of the Code of ordinances of the City f Denton,, Tex Quotum. A quorum for the transaction of business of a board shall be a majority of the members appointed to said board. Voting Requited. No attending member of a board shall be excused or shall abstain from voting on any matter before the ointerest'hish invvoted•is where such required except where a board member's , such member shall announce such interest enter member's personal interest is involved, at the commencement odefate ondauchimatter and shallsabstaineErom mvoting a thllerenoton. i into discussion financials interest, could have a does affects then member*' sin A member beshall be fore considered to r.oci any matter or those of a business with which the member is asated• called and scheduled Absentee. All board members shall attend all regularly board unecused at the meetings of the board of which he is a member. The andx scheduled n at meetings fifty of (50) member from more than three (3) regularly called board of which he is a member in any one year or lack of attendance the the mors familygillnesseeor ndeath) shall yearbe consideredh"causer" ass that percent of result of personal term is used the City Council from such board~tY of Denton, 1959, foe removal , 19 Dated this day of J signature a Examples of situations where a board member has a personal interest include, but are not limited tot ownership of real or personal ptopetty which is the subject of a board delibeerration, an interest in the form of ownership, or In the receipt C services or dividends from a business which has a matter before for of salarYr board. If a relative within the first or second degree of affinity office Anytime mayy exalso ist,exist, InterestInterest a board member has s~oncerned interest, that a a personal personal a of board m the City Attorney should be consulted. 2654a x : t - - \ 1 CITY OF DENTON STATEMENT OF PERSONAL AND FINANCIAL INTERESTS Personal and Financial IntereatlOwie.ng A peSrsoannalOffind Texas, i hereby disclose the fol eof Denton, acefirnaofncithe i alCinttyrests within the City of Denton: Employer: Ownership of Business and/or, Properties: i Otherec Dated this day of Signature - 1 1 i 2654s i i LEGAL ISSUES: AN OVERVIEW FOR MEMBERS OF CITY BOARDS AND COMMISSIONS y Powers and Duties 1 Conflicts of Interest Open Meetings Personal Liability J Criminal Misconduct Prepared by: Joe D. Morris Assistant City Attorney City of Denton July 23, 1990 E the Civil Service Commission, the City of Denton has Includ og fourteen permanent boards, committees, or commissions, The mem- mmissions serve voluntarily without com- rs of those boards and co bepensation, unselfishly giving of their time for the interest of the community. We have prepared this paper in the hope of assisting board members by reviewing some legal issues relevant to your duties. er will address: (1) the creation of boards and the ap This p conflicts of interest; (3) the require- f extent of their powers (z) ments for open meetings; (4) the personal liability of board the laws involving criminal misconduct. For members; and (5) convenience, we will refer to all administrative bodies as boards. We have attached copies of the cited provisions of state law for t your reference. creation and Powers of Boards ` All permanent boards of the City are creatures of state law, the City charter, or an ordinance or resolution. The law creating a board establishes the number of members, their qualifications to serve, the terms of office, and the board's powers and duties. A owers conferred upon it by the act board may, only exercise those p As a board member, you have no individual authority ' creating it. separate from that of the boards you can only act as a board. In order to properly perform your duties you must know the extent of When you are appointed your delegated duties and powers. you should receive the following! W 4 N 3 1. A opY of the act (i.e., the state law, City charter, or City ordinance or resolution) which establishes the board on which you serve and sets forth it general powers and duties. 2. A copy of Article III of Chapter I of the City Code of ordinances which sets the general rules and procedures for all City boards and commissions. d f 3. A copy of any written rules or procedures adopted by the ; board on which you serve. Some, but not all boards, have adopted rules govern'ig the procedures for conducting their meetings, ~ 1 ~ 4, Finally, and most importantly, a copy of the adopted regulations or ordinances over which the board has jurisdiction. You should generally be familiar with the regulations or ordinances or a keep a copy with you for reference at your meetings. k Boards may generally be divided into two types: boards that i exercise the sovereign (governmental) functions of the government and boards that perform strictly advisory functions. Boards do not have any legislative or law-making authority themselves; all legislative powers are reserved to the City Council. City policies are established by the Council through its legislative enactments, usually in the form of local laws, called ordinances. In order to carry out those policies, boards are established and delegated the power to administer those ordinances. These delegated powers are often called judicial or quasi-judicial powers. The following boards generally perform judicial or quasi-judicial functions by administering particular ordinances or regulations: Building Code Board (Uniform Building Code) Page 2 I~ i Board oT Adjustment (Zoning Ordinance) Civil Service Commission (State Laws and Regulations of Police & Fire Departmeiits) Electrical Code Board (Uniform Electrical Code) Historical Landmark Commission (Historic Landmark Preservation Ordinance) Planning and Zoning Commission (Subdivision Regulations) Plumbing and Mechanical Code Board (Uniform Plumbing Code , and Mechanical Code) Boards that exercise quasi-judicial powers apply particular regulations to specific facts to make judgments or decisions on matters within their jurisdiction. However, in rf,:ar.ing those r decisions, they do not have unbridled discretion. Board members are constrained by the ordinances adopted for their guidance. Even if a board doubts the wisdom of a regulation, the member cannot f legally ignore the regulation. The adoption of the regulation was a legislative function by the Y governing body. A board that ignores the regulation or attempts to determine anew the wisdom of the regulation illegally usurps the legislative function of the city council. It is the board's legal duty to carry out the adopted policy by applying the rules or regulations to particular facts to make a decision. Advisory boards are exactly what the name implies. They advise or make recommendations to a person, another board, or the City Council. They have not been delegated any of the sovereign functions of the government and have, no final decision-making authority. The following boards are advisory boards; Page 3 i Library board Airport Advisory Board Public Utilities Board Citizens Traffic. Safety support Commission Human Services Committee Parks and Recreation Board Community Development Block Grant committee i Cable TV Advisory Board ! i Data Processing Advisory Board The distinction between boards that exercise sovereign powers and advisory boards is important. First, the former are subject to the State's opening meetings law, while the latter are not. members of boards that exercise governmental powers are Second, public officials of the City because they perform official acts on behalf of the city and may, in limited cases, be held personally liable for those acts. The State's open meetings law and the lia- bility of public officials will be discussed below, open Meeting Requirements A. charter or Ordinance Requirements All meetings of boards must comply with the requirements of 's charter, for the charter or ordinance creating them. The city ustmAnt and example, requires that all meetings of the Board of Adj the meetings of the Public Utilities Board be open to the public- The charter requirements control regardless of whether the board Page 4 . ,4 closed meetings for allowing to the state law legally hold would be subject these boards can never certain matters. Therefore, closed meetings for any purpose- Texas open meetings Aat the Texas ~ B I commonly referred to as boards state statute, ll There is a the meetings of a Which applies to Ths open Meetings Act, 6252 17, V'T.C.S). I strictly advisory tarticle should Ac discuss and whicf, are not that public officials Public based on the notion utinyr so that the li t is b scr Public business under public their public officials are vote on to know what ortunity contains criminal will have the opP that the act ~ You should remember doing of the Acto penalties for violations e under tine Act. the Sotice Of Meeting City staff to post 1• j h most boards rely on aware that it Althouq u should be comply with for board meetingsr YO appropriate notice which does not to participate in a meeting the Act is unlawful of the Act. All boards cover the notice requirements rior to the meeting 2 hours p an agenda at least 7 agenda must post This means that the subject of the meeting which the board describing the item of public business should describe each or take action. failure to to discuss of posted agendas is the intends one frequent defect before the board. matter coming describe particular Erom the adequately a agenda purpose bee of posting an The sufficiency perspective of the general public. The page 5 I i, agenda is -o give notice to the public of what subjects will be considered by a board and what action, if any, will be taken at the 1 meeting. A board cannot take any action for which proper notice has not been given. A board may always do less than what the agenda indicates is to be done, but never more. For example, if an item is merely posted for "discussion", the board cannot take action by d voting on the matter discussed. However, if a matter i.s posted for discussion and voting, the board may do either, both, or none. The Act does have an exception to the 72 hour posting requirement for "emergency" items or items involving "urgent public necessity". Despite wishful thinking to the contrary, an emergency does not occur simply because someone forgot to put something on the pjsted agenda. An "emergency" or "urgent public necessity" is limited to "imminent threats to public health and safety" or "reasonably unforeseeable situations requiring immediate action by i the governmental, body." If you have to ask whether an item is an emergency or not, it probably isn't. Suffice it to say that most boards will rarely have any matter that qualifies for the emergency exception. If an emergency item is added, the notice shall clearly identify the emergency or urgent public necessity. A public meeting, as required by the Act is not the same as a public hearing. The Open Meetings Act does not mean that the public has to be allowed to speak at a meeting. it merely insures that all. meetings and discussions, except in limited circumstances, will be "open" for the public to attend, listen, and observe. A Page 6 i ti public hearing means public comment will he received from those wishing to speak on the subject matter posted for a public hearing. The board may determine when public comment is to be allowed on a particular matter, except when another law or ordinance requires the board to hold a public hearing. In any case, the board can determine the manner in which the public hearing will be held. Hoards sometimes invite those present to continent on a matter I ~ on the agenda which was not posted as a "public hearing." Although it would seem laudatory to invite comment on matters before the board from those present, a person who relies on the posted agenda i l to determine whether to attend for the purpose of making comments, r may be misled by the practice. Although this procedure may not clearly violate the Open Meetings Act, we would recommend that boards consider following a policy that will allow the staff to f indicate on the posted agenda when persons in attendance may be heard. If a board is always willing to listen to those attending on any matter before the hoard, it would be simple enough to post notice of that fact on every agenda. 2. closed meetings. If your board is not an advisory board, the open meetings act requires you to post an agenda giving advance notice of the meeting and to have an open meeting at which the public may hear all discussion, unless the Act allows the matter to be discussed in The idea behind the Act is that the public has a closed meeting. a right to complete access to the processes of the government, except when a discussion of the issue would pose potential harm or Page 7 1 1 prejudice tez--tb.e entity. (We emphasize the "entity" because it is the City's interest that is at issue - The member's individual preferences or circumstances are immaterial.) Generally, most exceptions of the Act allowing closed sessions would not apply to most board matters. A few boards may have reason to utilize the exception for discussions involving the purchase, exchange, lease or value of real property, but even then they may do so only if an open discussions would prejudice the negotiating position of the governmental body. A closed session may only be used for discussion of thk,.mattart the board must still make the final decision or vote on the matter in an open meeting. Where the Act allows a closed meeting, the notice requirements of the Act also apply to the closed session. The posted agenda should reasonably inform the public of the subjects to be discussed in the closed session. There are several other requirements that apply to closed meetings. if you are absolutely sure a closed meeting of the board is necessary, we suggest you consult this i office prior to posting the notice. Conflicts of Interest. A conflict of interest exists when a public official is presented with a matter for consideration in which the official has some personal interest that has the potential of influencing the official in the exercise of independent judgment. Conflicts of interest may be divided into two categories, statutory and common law. The first involves conflicts that are defined by statutes the Page 8 second are *nflicts that have been defined by court decision. Hoard members are currently subject to provisions regulating conflicts of interest under state law and the city's charter. A. State LAW. Chapter 171 of the Local Government Code applies to all public officials of local governmental entities, including board members, who exercise . ,asponsibilities beyond those that are advisory in nature." The law makes it unlawful for a local government official to "participate in a vote or decision on a , matter involving a business entity or real property in which the official has a substantial interest if it is reasonably foreseeable that an action on the matter would confer an economic benefit on the business entity." A person has a substantial interest in a business entit~y if: ! (1) the person owns to percent or more of the voting stock or shares or owns $5,000 or more of the fair market value of i the business entity; or (2) funds r_ zived by the person from the business entity ` exceed 10 percent of the person's gross income for the previous year. A person has a substantial interest in real property if the interest is an equitable or le4al ownership with a fair market ' value of $2,500 or more. If an official or any person related to the official in the first degree of affinity (by marriage) or consanguinity (by blood) does have a substantial interest in a business entity or real Page 9 4 or real property comes that entity property ana matter involving the official must do I before the board on which the official serves, two things- First, the official must, prior to the board voting on Secretary stating the the matter, file an affidavit with the city secretary nature and extent of the official's interest. The City has those forms available for that purpose- Secondly, the official must abstain from voting on the matter ~ (1) in the case of a substantial interest in a b4Sine39 ?.ht t t the action on the matter will have a special that is economic effect an the business entity blic distinguishable from the effect on the pus or i (2) in the case of a substantial interest ink pro ert it is reasonably foreseeable that an special economic action on the matter will have a distinguish- ; F roperty, effect on the value of the p able from its effect on the public* section prohibitions cf Chapter 1711 in addition to the p prohibitions for 212.017 of the same Code provides almost identical p lots of subdivided any official involved in the consideration of p person has a land. You will note that under this section, a "substantial interest" in a subdivided trac~heptractt or (1) the person acts as a developer stack or shares Of (2) owns ten percent or more of the voting a business entity that acts as a developer of the tracts or page 10 t (3) own§ ten percent or more of the fair market value of a business entity that acts as a developer of the tractf or (4) owns $5,000.00 or more of the fair market value of a business entity that acts as a developer of the tract. i B. Charter Provision. Section 14.04 of the City Charter reads as follows: I 1 No officer or employee of the City of Denton shall have a financial interest, direct or indirect, in any contract with the city, or be financially interested, directly or indirectly, in the sale to or by the city of any land, materials, supplies or service, except on behalf of the city as an officer l or employee. Any wilful violation of this section shall constitute malfeasance in office, and any officer or employee guilty thereof shall forfeit his office. This provision is based on the common law doctrine that municipal contracts in which officers have a pecuniary interest are void. The object of the rule is to insure to the government the strict fidelity on the part of those who represent and manage the affairs of government. The prohibition goes beyond the state law, J because it is not based on any quantification of an interest in a business or property. This does not mean that a public official cannot have any contract with the City. All officials who receive city utilities have a contract with the city, but they do not receive any benefit from those contracts beyond the benefit received by all utility customers. The common law doctrine prohibits an official from having an interest in any contract with the city in which the F.I -s 11 I r official rea4ives a direct or indirect benefit. It does not matter that the official is nqt in the position to influence the awarding 1 or making of the contract. Questions of conflicts of interest have so many potential variables that they must be determined on a case-by-case basis. The important point to recognize as a member of a board is whether a particular situation raises a potential conflict of interest. If i you are not sure, you should consult one of the attorneys in our I office. 1 Finally, when a conflict does exist, we suggest you leave the room while the matter is being discussed. This procedure, which is i followed by the City Council, allows the other members to freely discuss and vote on the matter without being influenced by the presence of a member who has a personal interest in the matter. Personal Liability Personal liability is often a subject of concern by members or j prospective members of boards. Generally, the question of personal liability applies only to public officials. Members of advisory boards generally cannot be held liable because they do not carry out any governmental action. The concern about personal liability is generally exaggerated. All boards (other than the civil service commission) a_e charged with the responsibility of making decisions based on the written provisions of an ordinance. You will not be held personally liable for any decision you make as a board member if you do one thing - follow and apply the written ordinances you have been charged with administering. Page 12 v qr 1. T" 1. The re Faon for this is simple. Generally, an official is only exposed to personal liability for acts he knew or should have known were illegal or unconstitutional. The ordinances you are applying and admini.;tering has been reviewed by an attorney. An official may rely on that review to shield himself or herself from { liability. A public official who follows the written ordinances that are established to guide the official's discretion will not be ! I held liable for a decision. However, a board member who makes decisions on criteria other than the ordinances adopted for the official's quittance, does so at his or her own risk. l i Criminal Misconduct 1 There are a number of state penal laws that prohibit acts which improperly influence public employees. Two of the more pertinent statutes concern bribery and gifts. Bribery occurs when someone confers a benefit upon a public employee or official in j return for an official's decision or act. The law prohibiting gifts is similar to bribery, except the prohibited benefit is conferred without regard to any particular decision or act. A bribe or gift can be anything that could "reasonably be regarded as economic gain or economic advantage". For example, we were once asked if it would be illegal for councilmembers to accept a helicopter ride from a petitioner of a zoning change for the sole purpose of inspecting the property in question. The ride would be legal so long as it was given solely for that purpose, because the councilmembers received no economic advantage or gain. Page 13 r HoweveFO assume the ~ petitioner had promised a councilmember a helicopter ride to Aruba if the member would vote for the zoning change. Clearly, that would be bribery since the petitioner would be offering a benefit in exchange for the vote. Again, assume the same petitioner offered the same councilmember the same ride without discussing how the courcilmember should vote. If the offor is made because of the councilmember's official status, then it j could be a violation of the gift statute, because the member I received an economic benefit. The same would be true if the 1 helicopter ride had been given to a spouse of a councilmember because bribery includes conferring a benefit on the official or "any other person in whom the beneficiary is interested." What about gifts from friends or a token Christmas gift from some person who frequently appears before your board? 3ach i situat.`.on must be addressed on it par'cicular facts. The law has I several exceptions and nuances that we will not attempt to address. one simple way to approach the issue is to ask yourself the following question if you are offered a "gift". would the gift be offered if I were not a public official? If you cannot definitely answer "yes" to that question, we recommend you not accept the gift. Page 14 A ' ~1 r 1 1 SUBTITLE C. MATTERS AFFECTING PUBLIC OFFI- CERS AND EMPLOYEES OF MORE THAN ONE TYPE OF LOCAL GOVERNMENT i CHAPTER 171. REGULATION OF CONFLICTS OF INTER. EST OF OFFICERS OF MUNICIPALITIES, COUNTIES, AND CERTAIN OTHER LOCAL GOVERNMENT,,14 section 171.001, Deflnltlons, 171.002: Substantial Interest In Business Entity, 171.003, Prohibited Acts; Penalty,. „ 171.004, Affldavit Required, 171.003, Contract Authorized, 17 LOW. Voting on Budget. ` 17L007, No Limitation on Common Law Remedies. 171-008. Effect of Violation of Chapter. Library Remo" Municipal Corporation 4-231(3), CSS. Municipal Corporation 1991. WESTLAW Eledmok ttwarch See WF TUW Electronle Research Guldafoll"ns the Preface. 171.001, 1kifiWtlons See, also, italfClted material following text of thiS section In this chapter, (1) "Local public official" means a member of the governing body or another officer, whether elected, appointed, paid, or unpaid, of any district (including a school district), county, municipality, precinct, central appmis- J al district, transit authority or district, or other local governtaental entity who exercises responsibilltles beyond those that are advtsory In nature, (2) "Business entity" means a sole proprietorship, partnership, firm, cor poration, holding company, joint-stock company, receiversldp, trust, or any other entity rmognlzed by law, Acts 1957, 70th Leg., ch. 149, ! 1, off, Sept, 1, 1987, An mditimi by Acts 1997, 7tltlt Us, ch. 659, 9 3 V.T.C.A. Covernmatt Cod's, § 311,031(e) protddes, to pan, that the read of a statute by, a code does not aj ect an am:endment of the sttatsutte by the sane legUlature which enacted the code and that the amendment is preserved and given effect as part of the code provlsfon. Section 3 of Acts 1987, 70th Leg„ ch. 659, amends subd I of § 1 of Vernon !t Ann,Civ,St. art. 988b (now, this sectionf without reference to 303 I § 171.00E OFFICERS k EMPLOYEES--,GENERALLY This a ths_repeal o said article by Acts 1987, 70th Leg., eh, 149, §49(l), As saomend subd. I of § I reads; "'Local ublie official' means a member of the governing body or another o~ficer, whether elected or appointed paid or unpaid, of any district (including a school distn'ct), county, city, precinct, central appraisal district, transit authority or district, or outer local govern. mental entity who exercises resrnsibilides beyond those that are advisory in nature, but does not include a board member of a higher education authority created under Chapter 53, Education Code, unless a vote, act, or participation by the board member as to the of fairs of a ' higher education authority would provide a financial benefit to a financial institution, school, college, or university constituting a source of income to the board member or being a business entity in which the board member has an interest distinguishable from financial benefit ' available to any other like financial institution or other scliool, college, or university whose students are el Is for a student loan available under Chapter 53, Education Code.' Htaerleal Noss Prior Um Acts 1981, 681h Lea., p. 4079, ch, 649, 1 1. Vemon's Inn.Clv,St, an. 9886, 0 1. f 171.9911 Abstsaw interest is RVAIaees Loft d:(a) For i ,:aw of this chapter, a person hu a substsetisi iafrewt in a besleue entity (1) the person owns 10 percent or coon of the voting stock or sham of the bushreu entity or ow= either 10 percent or more or $5,000 or more of the fair tnatket value of the business entity; or (2) funds rroeived by the paws from the buineas entity exceed io pueent of the person's ;roes iaoome for the previotu year, (b) A person has a substantial Interest in rat property if the interest is sn equitable or 14941 owtserebip with a fair market value of x2,500 or more, (c) A local public offldal is ootnklersd to here a substantial Interest unda this sectba If a PeMM mated to the of kW in the first do" by eoasanplaity or aqh* hu a substantial iota" undo this ucdom Amended by Acts 190, 71st Leg, rh. 1, 00(4) Off, Aeg, 21, 19M, 1 171.914. Pns►"W Ac* Fsaahy' (a) A loew puhl)e official commits an offense if the Official kaoahs91y: (1) Tioiatu Section 171,004; j (2) aft as surety for a business entity that has work, business, or a e ntreet wiW * goresnes ew ea ityi or (8) seta as surety on any official bond ragWM of an offloer of the 9orernm"W entity, (b) An of a" under this section Is a Close A misdemeanor, Amaded b7 Ads 19M, 71st Lee, ek 1, } WA off. Aug, era, 19M. I r I 171."4. Affidavit ant Aboteadoa Prow Voting Repiret (a) If a local pabbe official has a substantial interest to a baaiaw entity or to real Yl ( fate offfetal shall Me, before a vote or decision on any matter involving the b or the areal m tart property, as affidavit stating the eaters and eared of the torest parddpadon in the matter iC (1) to the ease of a eubatandal Interest In a business entity the actin on the matter will bete a special economic effect on the business entity that is dkdnguishabb from ~ the tiled on the publk; or (2) to tha dross of a substantial intarest in real property, it is rumnaby foreseeable that an action on the matter will have a special economic effect on the valw of the property, distinguishable from Its effect on the pubde. (b) The affidavit must be Mod with the official record keeps of the governmental entity, I (c) If a IocW public off clai is required to file and does fib an affidavit under Subsection (a), the official Is not required to abstain from &rther participation in the matter requiring the affidavit if a majority of the members of the governmental en of which the official is a member Is composed of persons who are likewise required to~ asd who do file affWavits of similar interests on the same official aedon, I Amended by Acts 190, 71st Leg., do, 1, d 40(a), eft Aug, 23, 1890, § 171,098 Vot110g on 8104904 budW item spped ~ lfeally body of a to contract entity witth a names entity which a member of the governing body has a substantial intesast (b) Except se provided by Seetiou 111.004(c), the affected member may cot parddpttte in that separate vote. The member may vote on a final budget if (1) the member has complied with this chapter; aid (2) the matter in which the member is concerned has been m0hlo . Renumbered tmm } 111.009 and amosdod by Acts 19", 71st Lag., dL 1, § 18(0), WE Aug, 1, 119, II § 171.96L tf,1d ed of Vlolatlaa of Cmser The fbrdin g by a court of a vbbadon under this chapter doe not render an action of the governing body voidable unlm the measure that was the mbjeet of an aedw brvolvisg A conflict d interest woaid not have psased the gom%4 body without the vote of the person who doisted the ehapter. Renumbered Cram t 17.0" by Act 190, 71st Lg., do. L § 40(aX cif Aug. 29, 190. § 17L"7. Common Low lotwe}ted; Canalattve of Magi lpal Protisienr (a) 'ibis ehapter preempts the common law of confbet of intesasfs as appliid to local pubbie ofHeiais. (b) This chapter is eamala** of municipal charter provisions and munkipai ordinances donning said prohibiting conflicts of interests. Ameadsd by Arts 190, 71st leg., ck 1, ! 40(A off, Aug, 39, 190, § 171.04, R xu ~ as § 171A" by Acto 1"0, 71st Lag, da 1, § We), WE Aum § 171.00, Servlm o. Heard of Corporsdon for to Compeasatlon It shall be lawful for a local public official to save as a member of the board of directors of priwte, nonprofit corporations when such officials receive no compensation or other remuneration from the nonprofit corporation or other nonprofk entity. Added by Arta 190, 71st Leg„ eh 416, d 2 off. Aug. 28, 19%. r . T. Q.A. , LOCAL GOVERNXENT CODh2 §212-017 r ¢ 213.017. C=Md of later"k l'aahty (a) In this aeetio% " $WxbvkW tna" Means a tmad of land, as a wbohe, that is subdivided. The term does oft ms" an isdlykhW lot to a suhdWAW tract d land. (b) A puma has a subatantW interest in s subdivided trail if the peraw (1) has an egWW)h or fusel owmmWp istareet bi the ttad wi& a fair OMW nloe e j- of $$600 or mom (2) seta ae a developer of the tract; (3~ OWN i Ferant or Min of the V*tbs murk Or churns of or OWN tither 10 ' mon or $6.000 or Mors of the fak market rake *(a buhww w► t, that I (A) has w equitable or Is& owneyeb* jut~ la the anti WI& a hk swb* value of $2.500 or more; or M acts as a devehoper of the tut; or (U reaim In A calendar year funds from a bnalness entity destsibed by 9ubdlviehoa (3) that exceed 10 percent of the paeoa's Erm krooms for the provious pear. (c) A person also is cwrsidwd to bare a substsatW interest in a enbdivkW area if the the unnder 10 firlt u Subsection (b1, his s as anbbsib atW lowut in the trs~ W asotbee person wbo, (d) It a member of the municipal authority eesponeible for apprOving subetastW interest in a subdivided acct, the member @W fl* be o! is a rowordedews nffwl hs2 the approval of ► plat for the tract, an affidavit statla2 the nature ad wtrat of the Interest and shall abstain from further pwddpatioo in the matter. nw da&vk must be tiled with the munkipah secretary or cWL , (e) A member of the musk4W authority responsible for pWs commits as oKaw it the somber viobatM Snbsation (d). An o= under t subsectlos is a Class A midemessor. M The findlsff by a ooort of a violation of this ceetlon des MA reodsr voidable w } action of the musicip►I authority responsible for ►app vms plats unless the messum would Vat have pasted the municipal authority wfkhOnt the vote of the member who violated this eectioa Amended by Atw IM, net iK» ek ale, 1 3.01, off. Sept 1. 191e. I i 1 . I I 8 PEli1tL t;OT36 (voRMOIA 1990) Sl1 D PROVISIONe, Tls~ 36AI grtbwy kncwingiY offers, n comtr.its as offense If he lnuntlo"Uy or ens to accept to confer on another, or solicits, accepm or aR (a) A person confers, or agr , from another, consideration for the recipient's decision. Opinion, (1) any benefit of discretion as a public reComrneAdation, vote, or other exercise pa' official, or voter, recipiea is decision. vote, recom- m cial or adminis' benefit as consideration for the In a judi (Z) ea any dation, or other exercise of °fficiai discretion trative PrOc~ or ~ an benefit as consideration or a violation of a duty imposed by law (3) blic servant or party official. this section that a person whom on a Pu tion under efense fl prosau not us! fled to act is iheJurisdiction (b) It U no d or Influence WAS a ad office or he i~the thtoru~t he had not yet whether benefit is not for any other reaon+ tion under this section that the until niter (o) It is no defense to prosecu benefit is not solicited of *Cc p offered or conferred or that the ndation, vim, or other exercise of (1) the derision, opinion, recomme discretion has occ+urea' oc s to be a public servant, (Z) the Public servant a felony of the second degW- (d) An offense under this section is hoses to Ma IurU i Tnblle Sw"At by {unedoas or um 4 he solicits, 36'~ Gilt servant In as agency Performing ts regulatory (a) p ow or lnvesti ptions from a PersOA the Pub the serva public conductir►g insP oa regula y ~ ion, or investigation by a~pts, or agrees on, iv Hers conttntts ao knows to be su to servant or his Soucy, to an Soucy having cust'Ody of Pris' t from • ~SOn or avrees to accept off (b) A eenaa public sot servant a' be to his In his MAody or the custody o his Wrk on tigation nt knows to Soucy carrying or crimi nal li Agrees (a) AA public servant in an be civil sot iw accepts of t to ts an offes" if °Owni whom ~pba t wryhis agknows eacY beh ° , from a pion aiainst~ Pubes s , bauefit w"Pt any don is Pending or Conteerciso by on with contracw litigation servant who'ice d pecuniary i In ons of govwnment (d) A c a public or other any beneftt from purchases. WY ats c Wicits, acctPw or aRe" to wow commits an offense if he s° at knows is inhere ~ or °trs i nterested is any y likely to on involving Public serv' n person the contract, purchasei Payment, the exercise of his discretion. 'P T •4 (e) A employedPik servant who has judicial or adn9&stradve authority, who is by or in a tribunal having judicitl or administrative authority, or who participates In the enforcement of the tribunal's dxision, commits an offense If he solicits, accepts, or agrees to accept any beoef2t from a person the public servant knows is interested In or likely to become interested In any matter before the public servant or tribunal, (f) A public servant who is a member of or employed by the IegWsture or by an agency of the legislature commits an offense if be solicits, accep% or agrees to accept any bene$t from any person. (g) An offense under this section Is a Class A misdemesnor. I 36x09. tN[wdng Gift to lnWk mace l (a) A person commits on, offense if he offers, confers,, or yra to confer b ~bten~m on a public servant that he knows the public savant is prohibited &oxVdnM (b) An offense under this section is a Clap A misdemeanor. 1 ! 39,01. Offfetal Noscoudaet { (a) A public servant commits an offense if, with Intent to obtain a benefit or with intent to harm another, he fateotiocaily or , (1) violates a law relating to his office or employtor come into his plies any thing of value belonging to the government that has moody or possession by virtue of his aHioe or fit, (b) An offense under Subsection (axl) of this section Is a Clap A misda• meanor. (c) An offense under Subsection (a)E2) of this section It (l) a Clap C misdemeanor If the value of the use of the thing misapplied Is leas than 820, (2) a Clap 9 misdemeanor if the value of the use of the thing misapplied is 820 or more but less than 8200, (3) a Class A. misdememw if the value of the use of the thing misapplied is 8200 or more but less than 8730; (4) a himsy of the third degree if the value of the use of the thing miseppW Is 8790 or more but leas than $20,000, and ' (3) a Mony of the -IrM degree if the, value of the use of the thing misappW is 324,000 or neon, 1 1 3 39,03, Miwas of Off ew Information (a) A public servant comralta an offense w if, in reliance on Information to which he public, he:has access in his official capacity and which has not been made , (1) acquires or aids another to acquire a pecuniary Interest to any Property, transaction, or enterprise that may be affected by the information: or (2) speculates or aids another to speculate on the bads of the iaforma- don, (b) A Plb& servant Who is a judge, *rdes,, btwR it a I h*M Po*k or smpioyas Of as appsnW aoort esavaNs~ ` Inwffijily M the armor eattmt of a or ~ ANAWO *law "i6 or Ophdoi aeoa ,R" 7 protest uada siti0sbis ae ar p~rt9+fant is sv@WTM& of a y m Pr~ a its esisass as a *6 rseow, or aanoasienesot, to in psrkw at Wwr.4 1 basis. (c) A person commits an offense if, intent to harm with intent to obtain a benefit or with another, he intentionally or knowingly sohdts or receives from a public servant the result or content of a proposed or actual appellate Judicial decision or opinion prior to the rendition of judgment, when the Person knows that the content or result of such order or opinion has not been disclosed to the opposing party or parties. (d) An offense under this section is a felony of the third degree, I i y i