5.12. SR 12-19-1994
rei ~\)
( II
!fil
ITEM 5.12.
MEMORANDUM
River TO:
Mayor & City Council
SUBJECT:
Pat Klaers, City AdNI.li~st~ator
December 19, 1994 ..~
Consider Revised City Conflict of
Interest Ordinance
FROM:
DATE:
Attached for your review is some information from the City Attorney on the
changes in our City Conflict of Interest Ordinance. Also attached is the
proposed ordinance for your consideration.
.
In September, two different proposals were reviewed by the Council. One
proposal closely mirrored state law while the other proposal, the one being
recommended for approval, went slightly beyond the state law minimums.
When this topic was discussed in September, the City Council requested
input from our Planning Commission, Park and Recreation Commission,
Library Board and Utilities Commission on the proposed changes in the City
Conflict of Interest Ordinance. Most of the feedback that I received from
Commissions, or individual members of Commissions, was in support of
Option #1.
Recommendation
Staff recommends approval of the proposed ordinance revising our City
Conflict of Interest policy.
council:confoint
.
13065 Orono Parkway. P.O. Box 490. Elk River, MN 55330. (612) 441-7420. Fax: (612) 441-7425
.
.
.
....
DEe 1 5 199~
MEMORANDUM
LARKIN, HOFFMAN, DALY & LINDGREN, LTD.
Attorneys at Law
1500 Norwest Financial Center
7900 Xerxes Avenue South
Bloomington, Minnesota 55431
Telephone: (612) 835-3800
FAX: (612) 896-3333
TO:
Mayor Henry A. Duitsman and
Members of the City Council
Peter Beck, City Attorney
December 14, 1994
Conflict of Interest Ordinance
Open Meeting Law
Excess Liability Insurance
FROM:
DATE:
RE:
Conflict of Interest Ordinance
Earlier this year I prepared, at Council direction, two
alternative amendments to the City's Conflict of Interest
Ordinance. The Council had directed me to prepare an ordinance
which would bring the City's policy generally into closer
conformance with state conflict of interest laws applicable to
municipalities. Council indicated a preference for the more
comprehensive of the two alternatives I had prepared. It is my
understanding that the other City Commissions which have reviewed
the proposed ordinance have concurred. Therefore, the attached
ordinance is ready for Council adoption at its meeting of
December 19, 1994, if the Council so desires.
I also prepared, earlier this year, a draft memorandum to members
of the City Council, members of City Commissions and City
department heads outlining the City's conflict of interest
policy. If the Conflict of Interest Ordinance is adopted by the
Council on December 19, 1994, I will update and circulate this
memorandum to all Commissioners and department heads.
Open Meeting Law
I recommend that the memorandum on the City's Conflict of
Interest policy be expanded to include a few paragraphs on the
state's open meeting law. I have met with most of the City
Commissions over the past year to discuss the requirements of the
open meeting law, and have found a certain amount of
misunderstanding regarding these requirements. I think it would
be helpful for people to have a written document to refer to in
the future.
.
.
.
..
I am also recommending that the City purchase so-called "open
meeting law insurance" from the League of Minnesota Cities
Insurance Trust. The Minnesota Supreme Court has recently
confirmed that a suit against city officials alleging a violation
of the open meeting law is not a claim covered under the Trust's
general policy. The Trust offers open meeting law coverage at a
fairly nominal amount. This coverage protects City officials
against the possibility of incurring attorneys' fees defending an
open meeting law suit. If the Council elects to purchase this
coverage, I will mention that fact in my memorandum.
Excess Liability Insurance
Lori has asked me to discuss with the Council whether the City
should purchase "excess liability insurance" from the Trust.
Minnesota law puts a limit on the tort liability of
municipalities (currently $200,000 per claim and $600,000 for all
claims arising out of the same occurrence). Excess liability
insurance provides coverage in excess of these tort liability
limits.
The League offers two types of excess liability insurance. The
first type does not waive the statutory tort liability limits for
claims which are covered by the statutory limits, but provides
excess liability coverage for claims which may not be covered by
the tort liability limits. For instance, dram shop claims, civil
rights claims, and certain federal employment law claims may not
be covered by the state tort liability limits.
The second type of excess liability insurance offered by the
League waives the tort liability limits of Minnesota law. The
purpose of this policy is to provide the opportunity for
plaintiffs to obtain more than the statutory maximum in damages.
It is my understanding Lori has some information for the Council
on the cost of this excess liability insurance. I will leave to
the Council the decision of whether the benefit received is
sufficient to off-set the cost. However, in my discussions with
people at the League of Cities, they indicate that they have very
seldom had claims that have gone into excess liability coverage.
I will be at the Council meeting on December 19, 1994, and will
be happy to answer questions from the Council on any of the three
topics discussed in this memo.
2 .
PKB:JM9s
.
.
.
..
ORDINANCE NO. 94 -
CITY OF ELK RIVER
AN ORDINANCE AMENDING SECTION 218.08(9) OF THE ELK
RIVER CITY CODE OF ORDINANCES REGARDING THE CITY'S
CONFLICT OF INTEREST POLICY
The City Council of the City of Elk River does hereby ordain as
follows:
Section 1. Section 218.08(9) of the Elk River Code of
Ordinances is amended to read as follows:
218.08(9) Conflict of Interest.
a. Introduction. The credibility of local government rests
heavily upon the confidence which citizens have in public
officials and employees to render fair and impartial services
to all citizens without regard to personal interest and/or
political influence. Thus, City officials and employees must
scrupulously avoid any activity which suggests a conflict of
interest between their private interests and City
responsibilities. Officials and employees of the City, or
their family members, shall not engage or have financial
interest in any business or other activity which could
reasonably lead to a conflict of interest with the official's
or employee's primary City responsibilities. "Family members"
of an official or employee shall be deemed to be the official
or employee's spouse, parents, children, siblings, brothers-in-
law, and sisters-in-law and the lineal descendants of any of
them. Examples of activities which are not in accordance with
this policy include, but are not limited to the following:
(1) Entering into any sale, lease or contract in
violation of Minnesota Statutes, Section 471.87-
471. 89;
(2) Acceptance by a local official of any gift from an
interested person in violation of Minnesota Statutes
Section 471.895;
(3) Activities which require the official or employee to
interpret City codes, ordinances, or regulations when
such activity involves matters with which the
official or employee has business and/or family ties;
(4) Consulting activities carried out within the City if
such consulting involves talents or skills primarily
related to the official's or employee's City work
responsibilities;
.
(5) Using an official's or employee's authority,
influence or City position for the purpose of private
or personal financial gain;
(6) The use of city time, facilities, equipment, or
supplies for the purpose of private or personal
financial gain;
(7) Entering into a business transaction when it involves
using confidential information gained in the course
of employment;
(8) Accepting other employment or public office where it
will affect the official's or employee's independence
of judgment or require use of confidential
information gained as a result of City duties;
(9) Conducting personal business while working regularly
scheduled hours; and
(10) Accepting rebates or procuring any financial gain
through the bidding process or employment of outside
personnel.
.
Any official or employee engaging in any activity involving
either an actual or potential conflict of interest or having
knowledge of such activity by another official or employee
shall promptly report the activity to the City Administrator
or, if such activity be by the City Administrator, to the
Mayor. The City Administrator or Mayor shall investigate the
matter and make a determination as to whether or not an actual
or potential conflict exists. If the City Administrator or
Mayor determines a conflict exists, it shall be presumed that
the continuation of the practice would be injurious to the
effectiveness of the official or employee in carrying out
his/her duties and responsibilities. In such cases the
official or employee shall immediately terminate the
conflicting activity or be subject to termination of employment
or removal from office.
b. Officials. For the purposes of this Section 218.08(9),
the term "official" shall include all elected and appointed
officials of the City including, but not limited to, the City
Council, the Economic Development Authority, and the members
of the Boards and Commissions established by Chapter II of
the City Code of Ordinances. "Employee" shall include any
individual employed by the City on a full or part-time basis.
c. Elections. No elected official shall require, either
directly or indirectly, any employees of the City to campaign
on his/her behalf as a condition to employment. No employee
shall use City time or resources in promoting or advocating
the election of any individual.
.
.
.
.
d. ApPlicability. Nothing in this policy is intended to
violate, supersede, or conflict with any applicable state or
federal law regarding conflicts of interest in public
employment or disclosure requirements.
Section 2. This ordinance shall be effective upon adoption and
publication, according to law.
Passed and adopted by the City Council of the City of Elk
River, this ____ day of , 1994.
Henry A. Duitsman, Mayor
Attest:
Sandra Thackeray, City Clerk
PKB:JH6s
.
.
.
MEMORANDUM
LARKIN, HOFFMAN, DALY & LINDGREN, LTD.
Attorneys at Law
1500 Norwest Financial Center
7900 Xerxes Avenue South
Bloomington, Minnesota 55431
Telephone: (612) 835-3800
FAX: (612) 896-3333
TO:
Mayor Henry A. Duitsman and
Members of the City Council
Peter Beck, City Attorney
September 12, 1994
Conflict of Interest Ordinance
FROM:
DATE:
RE:
Earlier this year the City Council directed me to amend the
City's Conflict of Interest Ordinance to eliminate certain
sections which were too broad and to generally bring the
ordinance into closer conformance with the state conflict of
interest laws applicable to municipalities. In response to this
direction I have prepared, and attach for Council review and
consideration, two possible revisions of the Conflict of Interest
Ordinance.
In Option 1 (attached Exhibit A) I have tried to address the City
Council's concerns with the existing ordinance, while still
maintaining a conflict of interest policy that applies to all
City officials and employees. Option 2 (attached Exhibit C)
simply incorporates the applicable state laws, which apply only
to "public officials" and "local officials" as those terms are
defined in state statutes. Option 2 would not apply to all
employees.
I am recommending the Council adopt Option 1, with further
revisions if deemed necessary after Council review and
discussion. I believe that this option addresses the concerns
which the City Council had earlier this year, while still
maintaining a comprehensive conflict of interest policy
applicable to all City employees, consistent with the Council's
action in early 1993 when the existing ordinance was adopted.
Attached to this memo please find the following exhibits:
Exhibit ;I B
Exhibit t A
Option 1
Option 1 in "redlined" format, showing changes
from the existing ordinance
.
.
.
#
Exhibit C
Option 2
Exhibit D
Draft memo for distribution to all City
commissions and departments outlining the
City's Conflict of Interest Ordinance
(Option 1) and applicable state laws. This
memo could be distributed following Council
action on an Ordinance amendment. I will
revise this memo as necessary if the Council
selects Option 2.
I will be at the Council meeting on September 26, 1994, to answer
any questions you may have about the proposed Conflict of
Interest Ordinance amendments. In the meantime, please feel free
to call me with any questions.
PKB:JH4s
.
.
.
,
EXHIBIT A
ORDINANCE NO. 94~ -
Option 1
CITY OF ELK RIVER
AN ORDINANCE AMENDING SECTION 218.08(9) OF THE ELK
RIVER CITY CODE OF ORDINANCES REGARDING THE CITY'S
CONFLICT OF INTEREST POLICY
The City Council of the City of Elk River does hereby ordain as
follows:
Section 1. Section 218.08(9) of the Elk River Code of
Ordinances is amended to read as follows:
218.08(9) Conflict of Interest.
a. Introduction. The credibility of local government rests
heavily upon the confidence which citizens have in public
officials and employees to render fair and impartial services
to all citizens without regard to personal interest and/or
political influence. Thus, City officials and employees must
scrupulously avoid any activity which suggests a conflict of
interest between their private interests and City
responsibilities. Officials and employees of the City, or
their family members, shall not engage or have financial
interest in any business or other activity which could
reasonably lead to a conflict of interest with the official's
or employee's primary City responsibilities. "Family members"
of an official or employee shall be deemed to be the official
or employee's spouse, parents, children, siblings, brothers-in-
law, and sisters-in-law and the lineal descendants of any of
them. Examples of activities which are not in accordance with
this policy include, but are not limited to the following:
(1) Entering into any sale, lease or contract in
violation of Minnesota Statutes, Section 471.87-
471.89;
(2) Acceptance by a local official of any gift from an
interested person in violation of Minnesota Statutes
Section 471.895;
+xt IIa-ving an interest in any business which has contacts
or other direct dealing ~ith the City,
(~3) Activities which require the official or employee to
interpret City codes, ordinances, or regulations when
such activity involves matters with which the
official or employee has business and/or family ties;
(~4) Consulting activities carried out within the City if
such consulting involves talents or skills primarily
related to the official's or employee's City work
responsibilities;
.
(45) Using an official's or employee's authority,
influence or City position for the purpose of private
or personal financial gain;
(56) The use of city time, facilities, equipment, or
supplies for the purpose of private or personal
financial gain;
+trt Receipt or acceptance of any compensation or other
considerations from anyone other than the City for
the performance of an act which the official or
employee would be required or expected to perform in
the regular course of his/her City employment, or as
a part of his/her duties as an official or employee.
Compensation does not include awards, plaques or
momentos recognizing the official's or employee's
contribution in their area or to a charitable
organization, honoraria or other expenses in
conjunction ~ith a presentation or demonstration in
the employee's field of expertise or
scholarships/financial grants for schools,
(7) Entering into a business transaction when it involves
using confidential information gained in the course
of employment; or is with an individual or entity
that has contacts or other direct dealings with the
City,
.
(8) Accepting other employment or public office where it
will affect the official's or employee's independence
of judgment or require use of confidential
information gained as a result of City duties;
~ Acting as an agent or representative for another in
any matter pending before the City or Council, except
in the proper discharge of duties. For example, an
official or employee should not appear before City
Council on behalf of a third party and seek to use
their position or influence to sway the Council,
(9T&) Conducting personal business while working regularly
scheduled hours; and
(lOT) Accepting rebates or procuring any financial gain
through the bidding process or employment of outside
personnel., and
+Trt Acceptance of any gift (other than a campaign
contribution) with a value of ~100 or more from any
individual, corporation or other entity that is or
may become a supplier of goods or services to the
City.
.
.
.
.
Any official or employee engaging in any activity involving
either an actual or potential conflict of interest or having
knowledge of such activity by another official or employee
shall promptly report the activity to the City Administrator
or, if such activity be by the City Administrator, to the
Mayor. The City Administrator or Mayor shall investigate the
matter and make a determination as to whether or not an actual
or potential conflict exists. If the City Administrator or
Mayor determines a conflict exists, it shall be presumed that
the continuation of the practice would be injurious to the
effectiveness of the official or employee in carrying out
his/her duties and responsibilities. In such cases the
official or employee shall immediately terminate the
conflicting activity or be subject to termination of employment
or removal from office.
b. Officials. For the purposes of this Section 218.08(9),
the term "official" shall include all elected and appointed
officials of the City including, but not limited to, the City
Council, the Economic Development Authority, and the members
of the Boards and Commissions established by Chapter II of
the City Code of Ordinances. "Employee" shall include any
individual employed by the City on a full or part-time basis.
c. Elections. No elected official shall require, either
directly or indirectly, any employees of the City to campaign
on his/her behalf as a condition to employment. No employee
shall use City time or resources in promoting or advocating
the election of any individual.
d. Applicability. Nothing in this policy is intended to
violate, supersede, or conflict with any applicable state or
federal law regarding conflicts of interest in public
employment or disclosure requirements. such as those set
forth in Minn. Stat. Chapter lOA.
Section 2. This ordinance shall be effective upon adoption and
publication, according to law.
Passed and adopted by the City Council of the City of Elk
River, this ____ day of , 1994~.
Henry A. Duitsman, Mayor
Attest:
Sandra Thackeray, City Clerk
PKB:HZ1s
.
.
.
ORDINANCE NO. 94 -
EXHIBIT B
REDLn~iNG
CLEARED
CITY OF ELK RIVER
AN ORDINANCE AMENDING SECTION 218.08(9) OF THE ELK
RIVER CITY CODE OF ORDINANCES REGARDING THE CITY'S
CONFLICT OF INTEREST POLICY
The City Council of the City of Elk River does hereby ordain as
follows:
Section 1. Section 218.08(9) of the Elk River Code of
Ordinances is amended to read as follows:
218.08(9) Conflict of Interest.
a. Introduction. The credibility of local government rests
heavily upon the confidence which citizens have in public
officials and employees to render fair and impartial services
to all citizens without regard to personal interest and/or
political influence. Thus, City officials and employees must
scrupulously avoid any activity which suggests a conflict of
interest between their private interests and City
responsibilities. Officials and employees of the City, or
their family members, shall not engage or have financial
interest in any business or other activity which could
reasonably lead to a conflict of interest with the official's
or employee's primary City responsibilities. "Family members"
of an official or employee shall be deemed to be the official
or employee's spouse, parents, children, siblings, brothers-in-
law, and sisters-in-law and the lineal descendants of any of
them. Examples of activities which are not in accordance with
this policy include, but are not limited to the following:
(1) Entering into any sale, lease or contract in
violation of Minnesota Statutes, Section 471.87-
471. 89;
(2) Acceptance by a local official of any gift from an
interested person in violation of Minnesota Statutes
Section 471.895;
(3) Activities which require the official or employee to
interpret City codes, ordinances, or regulations when
such activity involves matters with which the
official or employee has business and/or family ties;
(4) Consulting activities carried out within the City if
such consulting involves talents or skills primarily
related to the official's or employee's City work
responsibilities;
.
(5) Using an official's or employee's authority,
influence or City position for the purpose of private
or personal financial gain;
(6) The use of city time, facilities, equipment, or
supplies for the purpose of private or personal
financial gain;
(7) Entering into a business transaction when it involves
using confidential information gained in the course
of employment;
(8) Accepting other employment or public office where it
will affect the official's or employee's independence
of judgment or require use of confidential
information gained as a result of City duties;
(9) Conducting personal business while working regularly
scheduled hours; and
(10) Accepting rebates or procuring any financial gain
through the bidding process or employment of outside
personnel.
.
Any official or employee engaging in any activity involving
either an actual or potential conflict of interest or having
knowledge of such activity by another official or employee
shall promptly report the activity to the City Administrator
or, if such activity be by the City Administrator, to the
Mayor. The City Administrator or Mayor shall investigate the
matter and make a determination as to whether or not an actual
or potential conflict exists. If the City Administrator or
Mayor determines a conflict exists, it shall be presumed that
the continuation of the practice would be injurious to the
effectiveness of the official or employee in carrying out
his/her duties and responsibilities. In such cases the
official or employee shall immediately terminate the
conflicting activity or be subject to termination of employment
or removal from office.
b. Officials. For the purposes of this Section 218.08(9),
the term "official" shall include all elected and appointed
officials of the City including, but not limited to, the City
Council, the Economic Development Authority, and the members
of the Boards and Commissions established by Chapter II of
the City Code of Ordinances. "Employee" shall include any
individual employed by the City on a full or part-time basis.
c. Elections. No elected official shall require, either
directly or indirectly, any employees of the City to campaign
on his/her behalf as a condition to employment. No employee
shall use City time or resources in promoting or advocating
the election of any individual.
.
.
.
.
d. Applicability. Nothing in this policy is intended to
violate, supersede, or conflict with any applicable state or
federal law regarding conflicts of interest in public
employment or disclosure requirements.
Section 2. This ordinance shall be effective upon adoption and
publication, according to law.
Passed and adopted by the City Council of the City of Elk
River, this ____ day of , 1994.
Henry A. Duitsman, Mayor
Attest:
Sandra Thackeray, City Clerk
PKB:JH6s
.
.
.
EXH1BIT C
ORDINANCE NO. 94 -
Option 2
CITY OF ELK RIVER
AN ORDINANCE AMENDING SECTION 218.08(9) OF THE ELK
RIVER CITY CODE OF ORDINANCES REGARDING THE CITY'S
CONFLICT OF INTEREST POLICY
The City Council of the City of Elk River does hereby ordain as
follows:
Section 1. Section 218.08(9) of the Elk River Code of
Ordinances is amended to read as follows:
218.08(9) Conflict of Interest.
a. Prohibition. Officials of the City shall not engage in
any activity which is in violation of state conflict of
interest laws, including:
(1) Entering into any sale, lease or contract in
violation of Minnesota Statutes, Section 471.87-
471.89; or
(2) Acceptance by a local official of any gift from an
interested person in violation of Minnesota Statutes
Section 471.895.
Any official engaging in any activity involving either an
actual or potential violation of state conflict of interest
law, or having knowledge of such activity by another official,
shall promptly report the activity to the City Administrator
or, if such activity be by the City Administrator, to the
Mayor. The City Administrator or Mayor shall investigate the
matter and make a determination as to whether or not violation
of state law has occurred. If the City Administrator or Mayor
determines that a violation of state law has occurred, the City
Administrator or Mayor shall notify the appropriate law
enforcement officials.
b. Elections. No elected official shall require, either
directly or indirectly, any employees of the City to campaign
on his/her behalf as a condition to employment. No employee
shall use City time or resources in promoting or advocating
the election of any individual.
c. Applicability. Nothing in this policy is intended to
violate, supersede, or conflict with any applicable state or
federal law regarding conflicts of interest in public
employment or disclosure requirements.
.
.
.
Section 2. This ordinance shall be effective upon adoption and
publication, according to law.
Passed and adopted by the City Council of the City of Elk
River, this ____ day of , 1994.
Attest:
Sandra Thackeray, City Clerk
PKB:JH7s
Henry A. Duitsman, Mayor
.
.
.
EXHIBIT D
MEMORANDUM
LARKIN, HOFFMAN, DALY & LINDGREN, LTD.
Attorneys at Law
1500 Norwest Financial Center
7900 Xerxes Avenue South
Bloomington, Minnesota 55431
Telephone: (612) 835-3800
FAX: (612) 896-3333
TO:
Mayor Henry A. Duitsman
Members of the City Council
Members of the Economic Development Authority
Members of the Housing and Redevelopment Authority
Members of the Planning Commission
Members of the Park and Recreation Commission
Elk River Municipal Utility Commissioners
City of Elk River Department Heads
Peter Beck, City Attorney
, 1994
City of Elk River Conflict of Interest Policy
FROM:
DATE:
RE:
Attached for your review are copies of Section 218.08(9) of the
Elk River Code of Ordinances and Minnesota Statutes Sections
471.87-471.895. These ordinance and statutory provisions set
forth the conflict of interest standards applicable in the City
of Elk River.
The City of Elk River's policy is to enforce the state conflict
of interest laws applicable to municipal officials, and to apply
a similar standard to all City of Elk River officials and
employees. Following is a summary of the applicable state laws
and the City's ordinance.
Contracts
Minnesota Statutes Section 471.87 prohibits any public official
who is authorized to take part in the making of a sale, lease, or
contract to voluntarily have a personal financial interest in the
transaction or to personally benefit financially from it.
Violation of this prohibition is a gross misdemeanor.
This statute applies to all kinds of contracts, formal or
informal, for goods, real estate or services, whether the City is
the buyer or seller. This statute applies only to persons
authorized to take part in the making of contracts. In Elk
River, this would include members of the City Council, the EDA,
the HRA and Elk River Municipal Utilities, because each of these
.
.
bodies is authorized to enter into contracts. The statute
prohibits these persons from being paid employees of the City,
entering into any contract with the City, holding stock in a
corporation which enters into a contract with the City, or being
a subcontractor under a contract with the City.
In addition to Minnesota Statutes Section 471.87, the City
Council Members are also subject to Minnesota Statutes Section
412.311, which provides that, "no member of a City Council shall
be directly or indirectly interested in any contract made by the
Council. II This provision is somewhat broader than that in
Section 471.87, and requires that City Council Members be
particularly circumspect about conflict of interest situations
regarding contracts.
Minnesota Statutes Section 471.88 sets forth some exceptions to
Section 471.87, and authorizes the City Council, by unanimous
vote, to contract for goods or services with one of its
interested officials under certain circumstances, including:
1. The designation of a bank or savings association as an
authorized depository for public funds and as a source
of borrowing. However, the official who has an interest
in the bank or savings association must disclose that
interest when the bank or savings association is first
designated, or when the official is elected, and that
disclosure must be entered in the minutes of the City
Council.
2. The designation of an official newspaper or the
publication of official matters in the newspaper, when
the newspaper is the only one complying with statutory
requirements for designating the official newspaper.
3. A contract with a cooperative association of which the
official is a shareholder or stockholder but not an
officer or director.
4. A contract for which competitive bids are not required.
The League of Cities has interpreted this provision as
meaning a contract under the competitive bidding
threshold of Minnesota Statutes Section 471.345
($25,000) .
5. A contract with a Volunteer Fire Department for the
payment of compensation to its members or for the
payment of retirement benefits to members.
6. When an EDA Commissioner is employed by a bank engaged
in making loans or performing trust services involving
real or personal property affected by any plan of the
EDA if the Commissioner discloses the nature of the
loans or trust services of which the Commissioner has
personal knowledge, which disclosure shall be entered
into the minutes of the EDA.
2.
.
7. A public officer may rent space in a public facility at
a rate commensurate with that paid by other members of
the public.
8. Local officials may apply for a County HRA loan or
grant.
Minnesota Statutes Section 471.881 provides that the exceptions
set forth above apply not withstanding the provisions of any
other statute and Section 471.89 sets forth the procedures to
follow when a contract is void.
Gifts
Minnesota Statutes Section 471.895 addresses gifts to public
officials. This is the statute adopted by the 1994 legislature
which has triggered so much discussion.
The prohibition in this statute reads as follows:
An interested person may not give a gift or request another
to give a gift to a local official. A local official may
not accept a gift from an interested person.
.
"Gift" is defined to mean money, real or personal property, a
service, a loan, a forbearance or forgiveness of indebtedness, or
a promise of future employment, that is given and received
without the giver receiving consideration of equal or greater
value in return.
"Interested person" is defined to mean a person or a
representative of a person or association that has a direct
financial interest in a decision that a local official is
authorized to make.
"Local official" is defined to mean an elected or appointed
official of a county or city or of an agency, authority or
instrumentality of a county or city.
Following are some thoughts on some of the key terms in this
statute:
Who is an "interested person"?
An interested person is one that has "a direct financial
interest" in a decision that a local official is authorized
to make. Commentators have suggested that a direct
financial interest is not the general interest that every
taxpayer has in the decisions of a local official, but is
the more immediate and personal interest that one has in a
decision that affects one differently from others, such as a
tax abatement or assessment on a particular parcel.
3.
.
.
Who is a "local official"?
Members of the Elk River City Council and all members of
appointed Council Commissions (including the EDA, HRA,
Planning Commission, Park and Recreation Commission, Elk
River Municipal Utilities, etc.) are local officials. The
commentators have suggested that appointed staff members are
also "local officials," if they have significant
responsibility for making decisions. However, not every
person who works for the City is an "official." Officials
are those who have significant responsibility for making
decisions, not those who simply carry out the orders of
others.
What is a "gift"?
Virtually anything of any value is going to be considered a
"gift" under this statute, including:
(a) money, including honoraria;
(b) real or personal property, including food and
beverages, entertainment tickets, etc.;
(c) services, including free travel and lodging;
(d) a loan, forbearance or forgiveness of indebtedness;
and
(e) a promise of future employment.
To be a gift, the item of value must be given and received
without the giver receiving consideration of equal or
greater value in return. The commentators are suggesting
that this language will allow local officials and interested
persons to, for instance, take turns picking up the check
for meals or other items of equal value.
The statute makes exceptions for the following:
(a) campaign contributions;
(b) services to assist in the performance of official
duties including, but not limited to, providing advice,
consultation, information and communication in
connection with legislation and services to
constituents;
(c) services of insignificant monetary value. However, the
value is measured by its value to the recipient (local
official) rather than to the giver. Commentators have
indicated that this exception should be narrowly
construed.
4.
(d) plaques or mementos recognizing service;
.
(e) trinkets or mementos of insignificant value, such as
pins, pens, cups and calendars, etc.;
(f) informational material of unexceptional value, such as
newspapers, pamphlets, brochures, etc.;
(g) food or beverages given in connection with a speech;
(h) the law does also not apply to gifts given by a family
member, nor to gifts given to groups that are not
related to the recipient's position as a public
official, but given for some other reason.
Violation of Minnesota Statutes Section 471.895 is a misdemeanor.
Therefore, all City officials and employees should be very
careful about complying with its requirements.
City Policy
The City Conflict of Interest Ordinance incorporates the state
laws outlined above, and also:
.
1. Sets forth a city conflict of interest policy. This
policy provides that officials and employees of the
City, or their family members, shall not engage or have
financial interest in a business or other activity which
could reasonably lead to a conflict of interest with the
officials or employees' primary city responsibilities.
2. Sets forth eight examples of activities which are not in
accordance with this policy. This list is not intended
to be comprehensive, but only illustrative of the types
of activities which are not in accordance with the
policy.
3. Applies this policy to City officials and all employees
of the City. This is broader than the state laws, which
cover only public officials and "local officials."
Violation of the City's Conflict of Interest Policy is not made a
criminal violation by the Ordinance but is, pursuant to the terms
of the ordinance, grounds for termination of employment or
removal from office.
Conclusion
.
The city and state requirements and policies regarding conflicts
of interest can be complex and difficult to apply to specific
situations. This memorandum and attachments are intended to
provide each of you with the laws themselves and some general
guidance. I encourage each of you to consult me if you have
questions about the application of these statutes and this
ordinance to a specific situation.
5.
~,e.'~..~~
r~rk~~t
~" ,,~- !.3
~..l ~~
~ [
PKB:JH5s
.
.....
.
.
471.86 MUNICIPAL RIGHTS, POWERS, DUTIES
1184
it. If judgment is rendered against the firefighter, such governmental
appropriate money from any funds available to pay such jud
for the payment thereof pursuant to law.
Subd. 3. Application. The obligation 0 Ion shall not apply in any case
where such firefighter is fully indem . nst claims for such damages and for such
expenses by contract with an this section shall not be construed to waive any
existing immunity acc law to municipalities or governmental subdivisions
from claims for sustained as the result of the negligence of its officers, agents
or servant exercise or performance of governmental or public functions.
ry: 1951 c 183 s 1-3; 1957 c 199 s 1; 1973 c 123 art 5 s 7; 1977 c 429 s 63; 1986
471.87 PUBLIC OFFICERS, INTEREST IN CONTRACT; PENALTY.
Exceptas authorized in section 471.88, a public officer who is authorized to take
part in any manner in making any sale, lease, or contract in official capacity shall not
voluntarily have a personal financial interest in that sale, lease, or contract or personally
benefit financially therefrom. Every public officer who violates this provision is guilty
of a gross misdemeanor.
History: 1951 c 379 s 1; 1955 c 41 s 1; 1986 c 444
471.88 MS -1957
[Repealed, 1961 c 651 s 2]
471.88 EXCEPTIONS.
Subdivision I. The governing body of any port authority, seaway port authority,
economic development authority, town, school district, hospital district, county, or
city, by unanimous vote, may contract for goods or services with an interested officer
of the governmental unit in any of the following cases.
Subd. 2. In the designation of a bank or savings association in which the officer
is interested as an authorized depository for public funds and as a source of borrowing,
no restriction shall apply to the deposit or borrowing of any funds or the designation
of a depository by such authority or governmental unit in any bank or savings associa-
tion in which a member of an authority or officer of a governmental unit shall have an
interest if such deposited funds are protected in accordance with chapter 118; provided,
however, that any member or officer having such an interest shall disclose that the
member is a director or employee of the bank or savings association, which disclosure
shall be entered upon the minutes of the authority or governmental unit, such disclo-
sure shall be made when such bank or savings association is first designated as a deposi-
tory or as a Source of borrowing, or when such member or officer is elected whichever
is later, and such disclosure shall serve as notice of such interest and need not be made
with each successive transaction;
Subd. 3. The designation of an official newspaper, or publication of official matters
therein, in which the officer is interested when it is the only newspaper complying with
statutory or charter requirements relating to the designation or publication;
Subd. 4. A contract with a cooperative association of which the officer is a share-
holder or stockholder but not an officer or manager;
Subd. 5. A contract for which competitive bids are not required by law.
Subd. 6. A contract with a volunteer fire department for the payment of compensa-
tion to its members or for the payment of retirement benefits to these members;
Subd. 7. A contract with a municipal band for the payment of compensation to
its members;
Subd. 8. [Repealed, 1992 c 380 s 8]
Subd. 9. When a port authority commissioner or economic development autho~ty
commissioner is engaged in or employed by a firm engaged in the business of import 109
or exporting or general trade, it shall be lawful for the authority to do business with the
1185
MUNICIPAL RIGHTS, POWERS, DUTIES 471.89
.
commissioner or the commissioner's employer provided that in the fixing of any rates
affecting shippers or users of the terminal facility, said commissioner shall not vote
thereon.
Subd. 10. When a seaway port authority commissioner is engaged in or employed
by a firm engaged in the business of importing or exporting or general trade, it shall be
lawful for the authority to do business with the commissioner or the commissioner's
employer provided that in the fixing of any rates affecting shippers or users of the termi-
nal facility, said commissioner shall not take part in the determination of, except to tes-
tify, nor vote thereon.
Subd. II. When a commissioner of any public housing, port authority, or eco-
nomic development authority is employed by a bank engaged in making loans or per-
forming trust services involving real or personal property affected by any plan or such
housing or port authority, no restriction shall apply to any such loans made or trust ser-
vices performed by said bank if the commissioner shall disclose the nature of such loans
or trust services of which the commissioner has personal knowledge, which disclosure
shall be entered upon the minutes of such authority.-
Subd. 12. An officer of a government unit may contract with the unit to provide
construction materials or services, or both, by sealed bid process iftl1e unit has a popu-
lation of 1,000 or les.s according to the last federal census. The officer may not vote on
the question of the contract when it comes before the governing body for consideration.
Subd. 13. A public officer may rent space in a public facility at a rate commensu-
rate with that paid by other members of the public.
Subd. 14. Housing and redevelopment authority. When a county or multicounty
housing and redevelopment authority administers a loan or grant program for individ-
ual residential property owners within the geographical boundaries of a government
unit by an agreement entered into by the government unit and the housing and redevel-
opment authority, an officer of the government unit may apply for a loan or grant from
the housing and redevelopment authority. If an officer applies for a loan or grant, the
officer must disclose as part of the official minutes of a public meeting of the govern-
mental unit that the officer has applied for a loan or grant.
Subd. 15. Franchise agreement. When a home rule charter or statutory city and a
utility enter into a franchise agreement or a contract for the provision of utility services
to the city, a city council member who is an employee of the utility is not precluded
from continuing to serve as a city council member during the term of the franchise
agreement or contract if the council member abstains from voting on any official action
relating to the franchise agreement or contract and discloses the member's reason for
the abstention in the official minutes of the council meeting.
History: 1961 c 651 s 1; 1965 c 806 s 1-4; 1969 c 26 s 1; 1973 c 123 art 5 s 7; 1977
c 55 s 1-3; 1978 c 651 s 1; i979 c 20 s 1; 1986 c 399 art 2 s 38-40; 1986 c 400 s 38-40;
1986 c 444; ISp1986 c 3 art 2 s 41; 1991 c 65 s 1,2; 1992 c 380 s 7; 1992 c 522 s 42,43
471.881 EXCEPTIONS; APPLICATION.
The exceptions provided in section 471.88 shall apply notwithstanding the provi-
sions of any other statute or city charter. .
History: 1967 c 18 s 1
471.89 CONTRACT, WHEN VOID.
Subdivision 1. Procedure followed. A contract made pursuant to section 471.88,
Subdivision 5, is void unless the procedure prescribed by subdivisions 2 and 3 is fol-
lowed.
S.ubd. 2. Resolution by governing body. Except in an emergency making such proce-
dure Impracticable, the governing body of the governmental unit shall authorize the
~ontract in advance of its performance by adopting a resolution setting out the essential
acts and determining that the contract price is as low as or lower than the price at which
the commodity or services could be obtained elsewhere. In case of an emergency when
.
....
.
.
471.89 MUNICIPAL RIGHTS, POWERS, DUTIES
1186
the contract cannot be authorized in advance, payment of the claims shall be autho-
rized by a like resolution in which the facts of the emergency are also stated.
Subd. 3. Claims, affidavits filed. Before such a claim is paid, the interested officer
shall file with the clerk of the governing body an affidavit stating:
(a) The name of the officer and the office held by the officer;
(b) ~n itemization of the commodity or services furnished;
(c) The contract price;
(d) The reasonable value;
(e) The interest of the officer in the contract; and
(f) That to the best of the officer's knowledge and belief the contract price is as low
as, or lower than, the price at which the commodity or services could be obtained from
other sources.
History: 1951 c 379 s 3; 1965 c 45 s 64-66; 1967 c 125 s 1,2; 1978 c 651 s 2,3; 1986
c 444
.
may,
in the re
Subd.
its governing
Subd. 3. St
assume and shall
city in the joint ente .
tion of said hospital.
History: 1951 c 49
90 STATUTORY CITIES, HOSPITAL; TRANSFER TO COUNTY.
bdivision 1. Authorization. When duly authorized by unanimous vote of its gov-
ody any statutory city owning real estate and a hospital building situated
equipment jointly with the county in which said statutory city is located,
inal consideration or without consideration, transfer its title and interest
e, hospital building, and equipment to said county.
ty may accept. Said county, when authorized by a majority vote of
may, accept such grant and conveyance.
city obligations not assumed by county. Such county does not
liable for any part of the obligations incurred by said statutory
of the statutory city and county in the construction or opera-
471.91 AIR TRAVEL AC
The governing body of any
the first class is authorized to ent .
engaged in carrying passengers on s
lishment of an air travel account for a . "
conditions as may be necessary and pr '
employees of the city or county, and to
exceeding $500 to the credit of such accoun .',
History: 1951 c 630 s 1
the first class or any county containing a city of
a contract with any airline company regularly
flights in interstate commerce for the estab-
city or county, subject to such terms and
facilitate air travel by the officers and
with the airline company a sum not
471.92 DANGEROUS EXCAVATIONS; MAINT
Subdivision 1. The governing body of any county:'
maintenance or abandonment of open wells, cesspools,
catch basins and may provide penalties for the violation the ..
or abandonment of any such installation so as to endanger tn
able number of persons, may be defined as a public nuisance a
the laws relating to public nuisances.
Subd. 2. The abatement of any such nuisance may include suit
installation or surrounding the same with a suitable protective fence.
History: 1955 c 601 s 1,2; 1973 c 123 art 5 s 7
CE, ABANDONMENT.
r town may regulate the
s, recharging basins,
he use, maintenance
y of any consider-
ted pursuant to
.
471.924 COUNTY REGULATION OF PAWNBROKERS, SECOND
JUNK DEALERS.
Subdivision 1. Authority. For the purpose of promoting the health, safety,
as been assigned the use of a local government vehicle for
ent business on an extended basis, and the employee's pri-
ot the local government work station to which the employee is
; or
yee has been assigned the use of a local government vehicle for
overnment business away from the work station to which the
anently assigned, and the number of miles traveled, or the time
ct the business, will be minimized if the employee uses a local govern-
o travel to the employee's residence before or after traveling to the place
rnment business.
4. Exceptions. This section does not apply to public safety vehicles that are
leased by a political subdivision.
tory: 1993 c 315 s 16
... 471.88 EXCEPTIONS.
471.666 PERSONAL USE OF PUBLICLY OW
ITED.
Subdivision I. Definitions. For purposes 0
shall apply:
(a) "Local government vehicle" means
division of the state of Minnesota or loan
(b) "Political subdivision" means a
town, school district, metropolitan or re
of this state.
(c) "Local government employ
appointed or employed by apolitica
cal subdivisions.
Subd. 2. Restricted uses. A I
rized local government busines
use of the vehicle for local go\!'
be used for transportation t
except as provided in subd"
Subd. 3. Permitted us
ment employee to travel
(1) in connection
not wor:king;
(2) if the empl
authorized local g
mary place of wo
permanently as .
(3) if the
authorized I
employee i
needed to
ment ve
ofloca
S
471.631 REWARDS FOR INFORMATION ABOUT FELONS.
A home rule charter or statutory city may offer and pay a reward or fu
ment ofa reward offered by a nonprofit organization in an amount it deem
for information leading to the apprehension and charging or convicti
alleged to have committed a felony within the city's limits.
History: 1993 c 63 s 1
.
83
471.635 ZONING ORDINANCES.
Notwithstanding section' 471.633, a governmental subd'
reasonable, nondiscriminatory, and nonarbitrary zoning or
businesses where firearms are sold by a firearms dealer. For
a firearms dealer is a person who is federally licensed to s
tal subdivision is an entity described in sections 471.6
History: 1993 c 326 art 1 s 3; 1993 c 366 s 8
may regulate by
ces, the location of
rposes of this section,
rms and a governmen-
471.634.
AUTOMOBILES PROHIB-
section, the following definitions
Ie owned or leflsed by a political sub-
political subdivision.
ory or home rule charter city, county,
agency, or other special purpose district
.
"employee" means an individual who is
ivision, including all elected officials of politi-
overnment vehicle may be used only for autho-
ding personal use that is clearly incidental to the
ent business. A local government vehicle may not
om the residence of a local government employee,
3.
ocal government vehicle may be used by a local govern-
from the employee's residence:
ork-related activities during hours when the employee is
.
[For text ofsubds 1 to 15. see M.S.1992}
Subd. 16. School district. Notwithstanding subdivision 5, a school board member
471.88 MUNICIPAL RIGHTS, POWERS, DUTIES
84
.
may be newly employed or may continue to be employed by a school district as an
employee only if there is a reasonable expectation at the beginning of the fiscal year or
at the time the contract is entered into or extended that the amount to be earned by
that officer under that contract or employment relationship will not exceed $5,000 in
that fiscal year. Notwithstanding section 1 25. 1 2 or 125.17 or other law, if the officer
does not receive unanimous approval to continue in employment at a meeting at which
all board members are present, that employment is immediately terminated and that
officer has no further rights to employment while serving as a school board member in
the district.
History: 1993 c 224 art 9 s 43
-INSURANCE COVERAGE BY POLITICAL SUBDIVISION.
Subd. 5a. A home ru
fund or pool to discharge the bon
employees of the city. '
tory city may use a self-insurance revolving
rovided by state law for officers and
History: 1993 c 218 s I
.
.
.
.
-
.
Ch.377,. ~ 4
E
or to a
Oft
. deletions by itIikIout
.
1994 "imGUL.AR SESSION
'Ch. 379, ~ 1
. . (4) a plaque or similar memento recognizing indiVidual services in i field of specialty or to a
charitable cause; .. . . .
(5) a trinket or memento of insignificant value;
_ (6) informational material .of unexceptional value;. or
(7) food or a beverag.e given at a reception, meal, or meeting away from. the recipient's
place of work by an organization. before whom the recipient appears to make a speech or
answer questions as part of a program.
. (b) The prohibitions in this section do not apply if the gift is given:
(1) because of the recipient's membership in a group, a majority of whose members are not
local officials, and an equivalent gift is given to the. other members of the. group; or
. (2) by an interested person who is. a member of the family of the recipient, unless the gift is
given on behalf of someone who is not a member of that family.. .
Presented to the governor March 18, 1994.
. Approved March 22, 1994.
.
OKA COUNTY-'-LIBRARY SERVICE-CITY OF ANOKA
CHAPTER 378
H.F. No. 1956
1 government; authorizing the public library systems of the county of
Anoka to merge and the county to provide li~rary services for the, city.
Approved March 28, 1994.
WRIGHT COUNTY-SHELTE
FACILITY-TRANSFER TO
CHAPTER 379
H.F. No. 1955
AN ACT relating to Wright county; permitting the transfer of a sheltere
operator without bids or consideration.
.
BE IT ENACTED BY THE LEGISLATURE OF THE STATE - 0
Section 1. TRANSFER OF SHELTERED WORKSHOP FACILITY TO
Addlllons are Indicated by underline; deletions by ~
5