HomeMy WebLinkAboutCOM 0573.004 2002-2004 `OJNSV oR
Barry Kim Uacoln S.T. Ashlda
Mayor ;a Corporation Counrel
' Gerald lgkase
eTlf~•Qi•Nr,.1~~,, A.•airtant Corporation Coanrel
(t~~Ixnfg ~ ~ttfuttii
OFFICE OF THE CORPORATION COUNSEL
101 Aupuni Stree4 Suia 323 • Hilo, Hawau %720.4262 • (808) %1.8251 • FAX (808) %1.8622
May 4, 2004
MEMORANDUM ~ ?
- _
TO: James Arakaki, Chairman, and Members
Hawaii County Council ~
FR: Bobby Jean Leithead-Todd ~
Deputy Corporation Counsel
c..~
RE: Council Authority to Appoint and Employ Staff Exempt From Civil Service
Corp. Counsel File No. WRK 04-7391
QUESTION PRESENTED: What current and future staff positions in the legislative
branch of the County of Hawaii, the County Council, are exempt civil service positions
under the Hawaii Revised Statutes and which positions are civil service?
SHORT ANSWER: Under Section 46-32 of the Hawaii Revised Statutes, all positions,
including the County Clerk, the Deputy County Clerk and the Legislative Auditor, are
civil service exempt with the exception of those employees employed in positions which
aze non-legislative such as elections clerks and machine room personnel.
INTRODUCTION
The County Council is currently considering a Charter amendment to create a
sepazate Office of the County Auditor. The Council would appoint the Auditor. Under
the language of the current draft of Bill 255, the Auditor would have the authority to
appoint necessary staff to fulfill the office's mission of conducting audits and reporting to
the Council. The question has been raised whether such employees would be exempt
from civil service and the position classification plan. Additionally, the civil service
Comm. No. 573•
Ref. To: Meae~ W
Ref. Uate AP~ ~~4
status of the Deputy County Clerk, the current Legislative Auditor and other staff
positions has been called into question.
THE CONSITUTIONAL FRAMEWORK
Article VIII, section 2 of the state constitution was amended in 1968 to grant
"home mle" to the counties. The provision reads:
LOCAL SELF-GOVERNMENT; CHARTER
Section 2. Each political subdivision shall have the power
to frame and adopt a charter for its own self-government
within such limits and under such procedures as maybe
provided by general law. Such procedures, however, shall
not require the approval of a charter by a legislative body.
Charter provisions with respect to a political
subdivision's executive, legislative and administrative
structure and organization shall be superior to statutory
provisions, subject to the authority of the legislature to
enact laws general laws allocating and reallocating powers
and functions.
A law may qualify as a general law even though it
is applicable to one or more counties by reason of the
provisions of this section.
Under this provision of the constitution, the county has the power to enact charter
provisions concerning the "stmcture and organization" of the county government. Such
charter provisions aze superior to conflicting state statutes but are still subject to the
authority of the legislature to enact general laws allocating and reallocating powers and
functions. Under this section of the constitution, the county has the authority to structure
and organize county government through its charter. A charter amendment to create a
sepazate Office of the County Auditor is related to the structure and organization of the
county.
However, the constitutional protection afforded county governments against
legislative intrusion is far from total. The constitution did not grant to local authorities
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complete home rule. A political subdivision may not adopt provisions in its charter,
which are repugnant to existing or future laws in the areas of personnel and procedure.
HGEA v. County of Maui, 59 Haw. 65, 85 (1978). The constitutional provisions
regazding county local self-govemment did not grant the authority to the counties to
adopt charter provisions on civil service that would conflict with state statutes.
The Hawaii Supreme Court has noted that the framers of the constitution
intended that the final authority on civil service laws and compensation matters would
remain with the legislature. In HGEA v. County of Maui, the Supreme Court reviewed
sections of the Maui charter that provided that the staff of the Maui office of the
Corporation Counsel should be exempt from civil service. The court held that any
conflict between the provisions of the charter and the HRS would render those provisions
nugatory. HGEA at 88. Personnel matters such as civil service and compensation
matters remain subject to the control of the state legislature. City & County of Honolulu
v. Ariyoshi, 67 Haw. 412, reconsideration denied, 67 Haw. 682 (1984). Therefore, state
civil service statutes govern whether county employees, and specifically, employees of
the legislative branch of Hawaii County aze civil service or exempt.
Article XVI, Section 1 of the Hawaii Constitution provides: "The employment
of persons in the civil service, as defined by law, or under the State, shall be governed by
the merit principle." However, the constitution does not "define the precise scope of the
civil service, i.e., the particular job positions that are within the civil service." Konno v.
County of Hawaii, 85 Hawaii 61, 70 (1997). This is left to various chapters of the
Hawaii Revised Statutes.
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THE STATUTORY FRAMEWORK
There are several different sections of the Hawaii Revised Statutes that govern
civil service and the classification of employees. Generally, civil service law is to be
found in Chapter 76 of the Hawaii Revised Statutes. Section 76-16 provides that all
positions within the various jurisdictions shall be civil service unless exempted through
section 76-16, or sections 46-33 and 76-77. Section 76-16 (b) (17) provides that
positions specifically exempted from Section 76-16 by any other law are exempt. Section
76-16 (c) also provides that the personnel director may exempt additional positions under
subsection (b), section 46-33 and 76-77, or any other law, if the reason for exempting the
position is for the same reason as a position is included in the list of specific exemptions
for that jurisdiction.
Section 76-77 provides the exemptions from civil service for the counties of
Hawaii, Maui and Kauai. There is no specific exemption within section 76-77 that
specifically lists exemptions for the County Clerk, Deputy County Clerk, Legislative
Auditor or for council staff. Instead, section 76-77 (10) provides that positions within the
county are exempt if they are specifically exempted from civil service by any other state
statute. The only reference to employees of the legislative branch of the county provides
in section 76-77 (9) that positions of "temporary election clerks in the office of the
county clerk employed during election periods" are exempt from civil service.
An exemption from civil service is granted to the legislative staff of the County
Council pursuant to Hawaii Revised Statutes Section 46-32. Hawaii Revised Statutes
Section 46-32 reads:
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Employees of council. Any other provision to the contrary
notwithstanding, the council of any county may appoint and employ
personnel, as it deems necessazy and prescribe their powers, duties and
compensation. All such personnel shall be exempt from the civil
service and the position classification plan. Nothing in this section shall
be deemed to affect the civil service or exempt status, salary range,
vacation, sick leave, service credit and other rights and privileges of any
incumbent as it existed on the day prior to May 9, 1977; provided that
subsequent changes may be made pursuant to applicable personnel laws.
(Emphasis added).
The other relevant state statute that addresses the classification of employees is to
be found in the collective bazgaining provisions of Chapter 89 of the Hawaii
Revised Statutes. The exclusions from collective bargaining found in Chapter 89
closely mirror positions that are exempted from civil service statutory provisions.
Section 89-6(f) provides that:
The following individuals shall not be included in any appropriate
bazgaining unit or be entitled to coverage under this chapter:
(1) Elected or appointed official;
(2) Member of any board or commission;
(3) Top-level managerial and administrative personnel, including the
depaztment head, deputy or assistant to a department head,
administrative officer, director, or chief of a state or county agency
or major division, and legal counsel;
(4) Secretary to top-level managerial and administrative personnel
under pazagraph (3);
(5) Individual concerned with confidential matters affecting employee-
employer relations;
(6) Part-time employee working less than twenty hours per week,
except part-time employees included in unit(s);
(7) Temporary employee of three months duration or less;
(8) Employee of the executive office of the governor or a household
employee at Washington Place;
(9) Employee of the executive office of the lieutenant governor;
(10) Employee of the executive office of the mayor;
(11) Staff of the legislative branch of the State;
(12) Staff of the legislative branches of the counties, except
employees of the clerks' offices of the counties;
(13) Any commissioned and enlisted personnel of the Hawaii national
guard;
s
(14) Inmate, kokua, patient, ward or student of a state institution;
(15) Student help;
(16) Staff of the Hawaii Labor Relations Boazd; or
(17) Employees of the Hawaii national guazd youth challenge
academy.
(Emphasis added).
THE CHARTER FRAMEWORK
The Hawaii County Charter divides the county into an executive and
legislative branch. Article III Section 3-1 of the Charter provides that the
"legislative powers of the county shall be vested in the county council. Its
primary function shall be legislation and public policy formation, as distinct and
separate from the executive administration of county govermnent."
Section 3-6(b) of the Charter provides for the appointment of a county
clerk. Section 3-6(b) reads:
The council shall appoint the county clerk which position shall be
exempt from civil service laws and classifications. The county
clerk shall:
(1) Be the clerk ofthe council.
(2) Be custodian of the county seal.
(3) Conduct all elections held within the county.
(4) Appoint the deputy county clerk and the
legislative auditor, with the approval of the
council, and such positions shall be exempt
from civil service laws and classifications.
(5) Perform such other functions as the council
may prescribe.
(6) Appoint necessary staff for which
appropriations have been made by the
council, subject to civil service laws and
classifications, and exercise the same power
with respect to the personnel of the clerk's
office as the department heads in the
executive branch.
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ANALYTICAL FRAMEWORK
Various provisions of the Hawaii Revised Statutes must be read to
determine whether a position should be civil service or exempt. In interpreting
statutes, the fundamental starting point is the language of the statute itself. Kovno
v. County ofHawai'i, 85 Hawaii 61, 71 (1997).
When the language of a statute is plain and unambiguous, there is an obligation to
give effect to its obvious meaning. "When construing a statute, our foremost obligation
is to ascertain and give effect to the intention of the legislature, which is to be obtained
primarily from the language contained in the statute itself. And we must read statutory
language in the context of the entire statute and construe it in a manner consistent with its
purpose." Kovno at 71.
However, when a statute is ambiguous, the meaning of the ambiguity may be
sought by examining the context, with which the ambiguous words, phrases, and
sentences may be compared, in order to ascertain their true meaning. HRS Section 1-
15(1). In order to ascertain the true meaning of the statute, a court would look to the
reason and spirit of the law and the cause which induced the legislature to enact it. HRS
Section 15-1(2); Ka Pa'akai O Ka Aina v. LUC, 94 Hawaii 31, 41 (2000). Thus, an
ambiguous statute can be interpreted by examining the legislative history of the statute.
Kovno at 71. Every construction which leads to an absurdity shall be rejected. HRS
Section 15-1(3). However, statutory construction should not render a statute a nullity or
create an absurd or unjust result. Kovno at 71.
A statute is ambiguous when there is doubt, doubleness of meaning, or
indistinctiveness or uncertainty of an expression used in a statute. A statute is ambiguous
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if it is capable of being understood by reasonably well-informed people in two or more
different ways. Konno at 71.
A three-step approach is used when interpreting statutes that appear to relate to
the same subject matter: first, legislative enactments are presumptively valid and should
be interpreted in such a manner as to give them effect; second, laws in pari materia shall
be construed with reference to each other; and third, where there is a plainly
irreconcilable conflict between a general and a specific statute concerning the same
subject matter, the specific will be favored, but where statutes simply overlap in (heir
application, effect will be given to both if possible. State v. Batson, 99 Hawaii 118
(2002). Laws in pari materia, or upon the same subject matter, shall be construed with
reference to each other; what is clear in one statute maybe called upon in aid to explain
what is doubtful in another. HRS Section 1-16. When a specific statute carves out an
exception to a general statute, the specific statute will not be controlled or nullified by the
general one, regardless of the priority of enactment. Cardenas v. Anzai, 311 F.3d 929
(Ninth Cir. 2002). Reference to other analogous statutes with similar language apd
dealing with similaz subject matter may be helpful in the interpretation of a doubtful
statute. Educators Ventures, Inc. v. Bundy, 3 Haw. App. 435 (1982).
Charter provisions regazding the filling of department head positions aze Superior
to state statutes. They are a matter of executive and administrative structure and
organization of the county. HGEA at 84. Such appointees serve at the pleasure of the
appointing authority. HGEA at 85. Charter provisions can give divisions or units of the
county departmental standing. HGEA at 85. However, a political subdivision may not
adopt provisions in its charter which are repugnant to existing or future laws in ttlpe areas
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of personnel and procedure. HGEA at 85. The final authority for all civil service and
compensation matters remains with the legislature. HGEA at 86. Any inconsistency
between a charter provision and state statutes on civil service would result in the'state
statute prevailing and render the charter provision nugatory. HGEA at 88.
DISCUSSION
HRS section 76-77(10) provides that positions aze not within the civil service if
other state statutes specifically exempt them. The County Council relies upon HI)tS 46-32,
which provides a specific exemption for all personnel appointed and employed by the
Council. The language of HRS 46-32 seems clear. It provides that the County council
"may appoint and employ personnel, as it deems necessary and prescribe their dowers,
duties and compensation. All such personnel shall be exempt from the civil service
and the position classification plan:' (Emphasis added). This language wouldiseem to
indicate that all employees within the County Clerk's office; the election's offic@, the
machine room and the Legislative Auditor's office are exempt from civil service as they
aze employed in the legislative branch of the County of Hawaii.
However, HRS Section 46-32 should not be interpreted in a manner that would
make a nullity of the specific exemption for pazt-time election clerks found in HItS
section 76-77(9). If all employees employed in the legislative branch were civil (service
exempt, there would be no need for an exemption for "part-time" election clerks as they
would be included within the exemption of HRS section 46-32. When reading section
46-32 and section 76-77(9) together, there is an obvious ambiguity that must be
addressed. If a specific exemption is required for "part-time election clerks", the obvious
inference is that full-time election clerks must be civil service.
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The original provision in the state statutes regarding exempt positions was
enacted through Act 78 in 1969. The way the language of the bill read, only the
Honolulu City Council would have the authority to hire six additional employees with the
title of "research assistant." S.C. Rep. 730, S.B. No 1055 House Journal (1969).
In 1977 the legislature amended Chapter 46, Hawaii Revised Statutes, by adding
a new section to "allow county councils to appoint and employ personnel as necessary
and to prescribes their powers, duties and compensation." In its committee report, the
Public Employment and Government Operations Committee noted that the law in
existence at that time left some question as to whether "county legislative bodies, other
than the City & County of Honolulu, have the statutory authority to appoint and employ
exempt personnel." House Standing Committee Report No. 854, S.B. No. 416. At that
time HRS Section 62-53 provided that the "chairman and executive officer of the county
boazd of supervisors shall appoint all officers and employees of the county whose
election or appointment is not otherwise specially provided for by law." At the same
time language in Section 76-77 of the HRS provided that there was an exemption from
civil service "of positions in the office of the chairman of the board of supervisors." The
language of the HRS did not reflect the changes that had occurred in the structure of
county government after passage of county charters and the switch from a boazd of
supervisors to a mayor and council form of government. The new section 46-32 was to
help clarify the sepazation of the executive and legislative powers and "extend to the
legislative branch, the clear authority to employ personnel as it deems necessary." House
Standing Committee Report No. 854, S.B. No. 416.
to
The enactment of the broader language of section 46-32 extended to all four
county councils the authority to employ as many exempt employees as they deemed
necessary. The language in the committee report makes clear that the legislature clearly
intended to give the authority to employ as many as the council felt necessary and
definitely more than six.
The issue was debated on the floor of the House of Representatives where it was
clear that the representatives understood that the intent of the bill was to give county
councils the authority to hire additional employees similaz to the authority already
exercised by the state legislature. Representative Kunimura rose and addressed the
House saying:
"Since 1968, Mr. Speaker, all the counties in the State now enjoy a
Constitutional Charter and the Constitutional Charter separates it clearly -
the executive branch of the county government from the legislative
branch.
I wonder what kind of position we would be in if we had a limitation on
what kinds and types of people that the Legislature could employ.
Right now, because of the ambiguity, the Council is almost at the jeopazdy
or sometimes at the mercy of being hauled into court by the executive
branch of the county government.
Mr. Speaker, this bill cleazly spells out the authority granted to the County
Council to have employees that would support the efforts of the respective
Councils and also, Mr. Speaker, the proof is in the mazketplace. If any
Council in the State of Hawaii want to act like punch-drunk sailors and
hire one thousand people under their jurisdiction, they wouldn't be in
office too long. I am pretty sure that there are safeguards in our system of
government.
Therefore, I urge all members to vote for this bill."
The bill passed 49 to 2.
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During the same session that the legislature passed S.B. 416, Act 62 which
created section 46-32, it also passed H.B. 1353, Act 61. This bill amended the HRS
section 76-71 through 76-81 to reflect the changes that had occurred in the structure of
the county governments. House Standing Committee Report No. 574 noted that there
had been no amendments to Chapter 76 for ten yeazs. The report referred to the changes
that had occurred in county governmental structure and noted that the purpose of Bill
1353 was to reflect the division of county government into legislative and executive
branches. The legislature kept in place the language that gave an exemption to temporary
election clerks at the same time it gave express authority to county councils to hire
exempt employees as they "deemed necessary." HRS sections 46-32, 76-77(9) and 76-
77(10) have remained unchanged since 1977.
The committee report further noted that the legislature was concerned over
language in the county charters referencing personnel administration. The report
indicated that it was important that the legislature "make clear its intent that state law is
to preempt county charter provisions and ordinances relative to personnel
administration." The committee's intent was to ensure that "public employees and
officers aze uniformly treated throughout the State." Language in Hawaii County
Charter, Article III, Section 3-6 (b), as to who shall be exempt or subject to civil service
is therefore preempted by the relevant state statutes.
Collective bazgaining was originally enacted in 1970 as Act 171. In 1970
positions excluded from collective bargaining were delineated in section 89-6(c):
No elected or appointed official, member of any board or
commission, representative of a public employer, including
the administrative officer, director, or chief of a state or
county department or agency, or any major division thereof
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as well as his deputy, first assistant, and any other top-level
managerial and administrative personnel, individual
concerned with confidential matters affecting employee-
employer relations, part time employee working less than
twenty hours per week, temporary employee of three
months duration or less, or any commissioned and enlisted
personnel of the Hawaii national guard, shall be included in
any appropriate bargaining unit or entitled to coverage
under this chapter.
In 1973 the language in this section was amended as follows:
No elected or appointed official, member of any board or
commission, representative of a public employer, including
the administrative officer, director, or chief of a State of
county department or agency, or any major division thereof
as well as his deputy, first assistant, and any other top-level
managerial and administrative personnel, individual
concemed with confidential matter affecting employee-
employer relations, part-time employee working less than
twenty hours per week, temporary employee of three
months duration or less, employee of the executive office
of the governor, household employee at Washington
Place, employee of the legislative branch of the State,
city and county of Honolulu and counties of Hawaii,
Maui and Kauai, employee of the executive office of the
lieutenant governor, inmate, kokua, patient, ward or
student of a state institution, student help, or any
commissioned and enlisted personnel of the Hawaii
national guard, shall be included in any appropriate
bazgaining unit or entitled to coverage under this chapter.
(Emphasis added).
One year prior to the amendments to civil service law, the legislature moved to
clarify provisions of the Chapter 89 because of confusion in the administration of the
collective bargaining law. Election clerks were initially considered to be part of the
legislative branch of govemment and excluded from collective bargaining. In 1976 the
section was amended to "except employees of the clerks' offices of said city and county
and counties." Senate Standing Committee Report No. 567-76 stated that the purpose of
the amendment was to "exclude the staff of Legislative Branch of the City and County of
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Honolulu and the counties of Hawaii, Maui and Kauai except the staff of the Clerks
Office of the City and County of Honolulu and to counties of Hawaii, Maui, and Kauai
from any collective bazgaining unit." The report went on to say that the "responsibility of
the Clerks Office is to handle elections and has no direct relationship to the Legislative
function."
The language of HRS section 89-6(f)(12) regarding collective bargaining
indicates that "staff of the legislative branch of the counties" is exempt from collective
bazgaining, but employees of the "clerks' offices of the counties is subject to collective
bargaining. When Section 89-6(f)(12) is read together with section 76-77 (9) it appears
that the legislature intended at a minimum that "election clerks" within the County
Clerk's office aze subject to civil service. The question is whether other employees are
also subject to civil service.
In Hawaii County, azguably all the employees that service the legislative needs
of the County Council are "within the clerk's office" and thereby included under the
collective bargaining provisions of Chapter 89. If one reads the statute to include all the
employees within the Hawaii County Clerk's office as subject to collective bargaining,
then the logical conclusion that they are all civil service follows. However, this would
lead to the absurd result of all the legislative staff of the County Council being subject to
civil service and collective bargaining, contrary to the clear intent of the exemption
provided by HRS 46-32. To interpret the statutes to mean that only the County Clerk is
exempt would lead to an absurd result. This interpretation would essentially gut the
intent of HRS section 46-32 and turn all the staff of the County Council into civil
servants. Additionally, it converts positions which had previously been civil service
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exempt at the time of the enactment of HRS Section 46-32, the Deputy Clerk and the
Legislative Auditor into civil servants. The cleaz language of HRS 46-32 states that
nothing "in this section shall be deemed to affect the civil service or exempt status, salary
range, vacation, sick leave, service credit and other rights and privileges of any
incumbent as it existed on the day prior to May 9, 1977." At the time of the enactment of
the statute, both positions were exempt.
Such an interpretation also runs afoul of the language of the charter that has the
clerk appoint the deputy and legislative auditor "with the approval of the council."
Assuming, arguendo, that the charter provisions were superior to state laws on civil
service, the deputy clerk and legislative auditor positions would still be exempt. The
clerk with the consent of the council appoints these positions. As appointees, they serve
at the pleasure of the appointing authority, the county clerk, and their terms aze co-
terminus with the clerks. It is also important to note that in past salary ordinances passed
by the county council, the clerk, deputy clerk and legislative auditor were classified at the
same level as department heads and deputies of the administration and compensated
accordingly.
By examining the legislative history of these statutes, it is clear that the legislature
differentiated between "legislative staff' and staff handling elections and that it intended
that "elections clerks" would be civil service and subject to collective bazgaining, It is
also cleaz that the legislature intended that staff whose work had a direct relationship with
the legislative function of the councils would be excluded from collective bargaining and
civil service.
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The language, in Chapter 89 of the HRS, referring to the clerks' office w~s
apparently based on how the Clerk's Office of the City and County of Honolulu vas
structured. However, while the City and County's and County of Maui's Clerk's Office
is sepazate and apart from the "Council Services" section, neither Hawaii County nor
Kauai County are so structured.
In order to give effect to the provisions of HRS Section 46-32 and avoid ~n
absurd result, the nature of the actual duties of the employees should be reviewed. Using
an analysis geared to the "nature of the services" of the employees, those employes in
the Hawaii County Clerk's office who have no direct relationship to the Council'
legislative function should be classified as civil servants. Clearly the elections clerks,
except for the temporary clerks during election seasons, aze to be classified as civil
service. Similazly, the employees in the machine room, whose jobs aze to handle mail
and copying for the entire county, do not have a direct relationship to the legislative
function of the County Council and should be classified as civil service. Using tl~e same
analysis, the County Clerk, Deputy County Clerk and Legislative Auditor who directly
provide services to County Council related to its legislative function should be exempt.
Similarly, the council aides, assistant legislative auditors, budget analyst, and legislative
assistants should also be civil service exempt.
Additionally, consultation with civil servants employed by the Hawaii Co{~nty
Council in 1977 revealed that at the time of the enactment of HRS 46-32 all emplllbyees of
the County Council were civil service with the exception of the County Clerk, D~puty
County Clerk and the Legislative Auditor, who were appointed, exempt positions~~
Subsequent to enactment of HRS Section 46-32, existing employees were given t~e
I
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option of moving out of their civil service positions into appointed positions. Some
employees chose to do so, others did not.
This is consistent with the provisions in HRS Section 46-32 which stated that the
new law was not to "affect the civil service or exempt status, salary range, vacation, sick
leave, service credit and other rights and privileges of any incumbent as it existed on the
day prior to the effective date" of the new law. However, the law provided that
subsequent changes "maybe made pursuant to applicable personnel laws." A check with
Kauai County indicates that in some cases when an existing civil servant employed by
the county council retired, they were replaced with appointed staff.
The voters of Honolulu recently passed a charter amendment to create a
legislative auditor position. The staff is hired pursuant to merit principles but is not
subject to civil service. Similarly, the staff of the state legislative auditor is also exempt
from civil service. Both the Honolulu and the State legislative auditors have authority to
hire and fire their staff. Honolulu also provides for civil service exempt private
secretaries for the Clerk and Deputy Clerk. The secretaries and office manager in the
Office of Council Services (similar to the existing Hawaii County Legislative Auditor's
staff) were once civil service but were replaced with exempt positions as people retired.
CONCLUSION
Hawaii Revised Statutes Section 46-32 gives broad discretion to the County
Council to appoint and employ personnel, as it deems necessary. All such employees,
with the exception offull-time election clerks and personnel of the machine room shall be
exempt from civil service. If a charter amendment is passed to create an office of the
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County Auditor, so long as that position is within the legislative branch of the county,
both the auditor and the staff of the auditor's office shall be exempt from civil setvice.
BLT:pc
s:Depts\County CouncilU.,O re civil service status of council employees\ 5-4-04 BLTpc.doc
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