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LlaOw:Lp~onLr STATE OF HAWAII
~Aaeaa.AloNA,~3. OFFICE OF INFORMATION PRACTICES
NO 1 CAPITOL DISTRICT BUILDING LESLIE H. gON00
uieTdurt wv~u'ee 230 SOUTH MOTEL STREET, SUIT[ 107 OiAeeroq
HONOLULU. HAWN'198817
Tabphogr (608)589.1400 FAX (8081388.1412
E-L1A1L: oipehawal.pov
WEBSITE; WWW~Inw9li.oW/qp
FAX TRANSMITTAL
DATE: December 6, 2004
T0: The Honorable Gary D. Safarik (FAX: 808-961-8912)
The Honorable Bob Jacobson (FAX: 808-961-8912)
The Honorable Lincoln S.T. Ashida (FAQ; 808-961-8622)
FROM: Les Kondo
TOTAL
NO OF PAGES: 4
RE: Commiliment to Vote
This office is transmitting a letter dated December 6; 2004 to Cottncilmembers
Safarik and Jacobson from the Office of Information Practices.
? Original is being mailed to you.
? Original will NOT be moiled :o you, unless requested
X
This message is intlmded only Por the use of the individual or entity to which it is addressed and
may contain information that h privileged or confidential. IP the reader o[ this message is not the intended
recipient, or the employee or agtm[ responsible for delivering the message to the Intended recipient, you are
hereby notified that any dissetnu6ation, distribution or copying of th[s Lrotumunication Is strictly prohibited. If
you have received this rnmtnunil:ation in error, please notify us immediate~v by telephone and return the
original to tts at the above address via the U.S. Postal Service. Thank you.
Comm. No.
Ref. To: reeedei
Ref. Uate fIN f,
Dec-06-2004 10:d87m from-OFFICE INFORIMTION PRACTICES I6085B61412 T-126 P.002/004 F-B91
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N0.1 CAPITOL 018TR1GT BWLpING
260 SOUTH HO7GL STREET, SURE 107
HONOLULU, MAWAI'I B68T3
7elepOOOa: (808) 586-t 600 FAX (BOB) $86-1417
E-MAIL: IXp®nAwall.pov
mvw.hawaii govlolp
December 6, 2004
VIA FACSIMILE - ~,6~-I-I 12
The Honorable Gary D. ;iafarik
The Honorable Bob Jacobson
County Council
County of Hawaii
25 Aupuni Street
Hilo, Hawaii 96720
Dear councilmembers Safarik and Jacobson:
I was asked by a reporter from the Hawaii Tribune Herald whether, outside
of a meeting, two councilmembers could commit to vote a certain way on a matter
that is Council business, i.e., a matter that is before the Council or that is
reasonably anticipated to come before the Council in the foreseeable future for
consideration. I advised the reporter that the Sunshine Law, part I of chapter 92,
HRS, does not allow councilmembers, outside of a Council meeting, to seek or make
any commitment to vote on a matter that is Council business.
From the Docemb6:r 3, 2004 edition of the Hawaii Tribune Herald, it appears
that my comments were conveyed to you. The Hawaii Tribune Herald reports that
both of you disagree with my interpretation of the statute. It also suggests that
both of you have discussed and agreed to vote to appoint Connie Kiriu and David
"Kimo" Frankel as the County Clerk and the Legislative Auditor, respectively, once
the Council, with the newly elected councilmembers, meets. In fact, the article
reports Councilmember :lafarik as saying that "the votes have been `confirmed and
reconfirmed' in one-on-one meetings[.]" I assume that the County Clerk and the
Legislative Auditor are appointed through Council action, i.e., by the vote of the
Council, and not at the sale discretion of the Council Chair.
Da-06-2004 1O:46am From-OFFICE INFOR4ATION PRACTICES 18065861412 T-127 P.OO3/O04 F-891
The Honorable Gary D. Safarick
The Honorable Bob Jacobson
December 6, 2004
Page 2
As you should know, the Sunshine Law generally requires, among other
things, that all discussions, deliberations, decisions and Actions of the Council
involving Council busine:sa be conducted at a properly noticed meeting. One of the
exceptions to that requirement allows two councilmembers to privately discuss
Council business outsidE~ of a meeting. See Haw. Rev. Stet. $92-2.6(a) (Supp. 2003).
Flowever, the permitted interaction gxnressly prohibits the couneilmembers from
making or seeking a coir~mitment to vote.
Accordingly, if, as the Hawaii Tribune Herald appears to indicate, you have
announced that Ms. Kiriu and Mr. Frankel will be appointed by the Council to be
the County Clerk and the Legislative Auditor, respectively, it appears that you have
discussed the appointments and have agreed to vote to appoint those individuals
once the newly elected equncilmembers assumed their positions. If that is the case,
your conduct appears to be contrary to the Sunshine Law.
Councilmember Ji~cobson is reported to have conveyed his belief that,
because the appointments are part of the Council's reorganization, councilmembers
are allowed to make commitments to vote a certain way outside of a meeting.
Councilmember Jacobson's belief, however, is wrong. While the statute allows two
or more councilmembers but less than a quorum of the Council to discuss, in
private, the selection of the Council's officers, there is no similar provision that
would allow councilmem~bers to conuzut to vote on any other type of Council
business. See Haw. Rev. Stet. § 92-2.5(c) (Supp. 2003).
Assuming, as the l~awaii Tribune Herald appears to report, that you did
decide upon Ms. Kiriu's a,.nd Mr, Frankel's appointments outside of a meeting, your
action should be re-done as part of a properly noticed meeting. I strongly
recommend that, when the matter is considered by the Council, you discuss,
deliberate and decide the appointments, to the extent possible, as if you had not
previously done so. In other words, it is my strong suggestion that, to rectify the
apparent Sunshine Law ,violation, you repeat, in detail, all of the discussions and
deliberations about the appointments that you may have had outside of a meeting
and that the Council not merely °rubber~stamp" the appointments that you had
decided upon during your earlier discussions. The public is entitled to participate
in the meeting, including offering testimony on the appointments, and to hear,
through the Council's public deliberation and vote, the Council's decision on the
appointments.
O~c-06-2904 10:4T~m From-OFFICE INFORMATION PRACTICES 18965661412 i-12T P.904/004 F-891
The Honorable Gary D. Safarick
The Honorable Bob Jacnbson
December 6, 2004
Page 3
If you have questions about whether your communication is allowed under
the Sunshine Law, I strongly suggest that you consult with your attorneys or this
office before engaging in the action. My office has also published a Sunshine Law
guide that may be helpful in guiding your compliance with Lhe statute. The
Sunshine Law guide is available through my office's website at www.hawaii.gov/oin.
If you have any q>.restions about the above, please do not hesitate to contact
me.
Very tri}1 yo ,
~r Leslie H. Ko 0
Director
LFIK:cy
cc: Tho Honorable Lincoln S. T. Ashida (via facsimile?