HomeMy WebLinkAboutCOM 0461.003 2004-2006 "`•v Lincoln S.T. Ashida
Harry Kim Corporation Counsel
Mayor ,j
Gerald Takase
:;~r,.• Assistant Corporation
Counsel
COUNTY OF HAWAII
OFFICE OF THE CORPORATION COUNSEL
101 Aupuni Street, Suite 325 Hilo, Hawaii 96720-0262 (808) 961-8251 Fax 1808) 961-8622
November 7, 2005
~norable Stacy K. Higa
Honorable Virginia Isbell
Honorable Fred Holschuh
Honorable James Arakaki
Honorable Pete Hoffman
Honorable Donald Ikeda
Honorable K. Angel Pilago
Honorable Gary Safarik
Hawaii County Council
25 Aupuni St.
Hilo, HI 96720
Dear Council Members:
RE: Board of Ethics Petition filed by Roger Christie
Our office received the enclosed Board of Ethics petition filed by Roger
Christie against each of you.
In the very near future, you will each receive a letter from the Board of
Ethics, asking whether you wish to submit a written response to the charge(s).
Based upon a determination by our office that the subject actions taken by
you at the meeting of the Hawaii County Council on October 18, 2005, were
within the course and scope of your responsibilities, and that you were following
the guidance and advice of counsel, our office is willing to provide legal
representation for you in the defense of this Board of Ethics petition.
If you wish to utilize the services of our office, please contact me
immediately, and we will arrange to have an attorney from our Litigation Division
assigned to assist you. Of course, you are free to either represent yourself, or
seek private counsel at your own expense, if you so choose. This decision is
completely up to you.
In order to avoid any actual or potential conflict of interest, and in order to
eliminate any appearance of impropriety, our office will arrange to have an
Comm No. ~/•3
Hawaii County is an Equal Opportunity Employer and Provider Ref. To:
Raf. CPat~
Honorable Stacy K. Higa
Honorable Virginia Isbell
Honorable Fred Holschuh
Honorable James Arakaki
Honorable Pete Hoffman
Honorable Donald Ikeda
Honorable K. Angel Pilago
Honorable Gary Safarik
Hawaii County Council
November 7, 2005
Page 2
attorney from a neighbor island Corporation Counsel or County Attorney office
specially assigned to represent the Hawaii County Board of Ethics in this matter.
Given the deadline established by rule for responding to the Board of
Ethics, I humbly seek your prompt response to this letter.
Very truly yours,
LINCOLN S. T. ASHIDA
Corporation Counsel
Encl.
c: Gerald A. Takase, Assistant Corporation Counsel (w/ encl.)
Joseph K. Kamelameha, Deputy Corporation Counsel (w/ encl.)
Katherine A. Garson, Deputy Corporation Counsel (w/ encl.)
S: Boards/BOE/Christie re legal fees/Letter to Council members 11-7-05ILSAnv
r._ J
PETITION NO. 7 O ~ = ~ ,3
Board of Ethics
101 Aupuni Street, Ste. 325, Hilo, Hawaii 96720
/P~E~TI~TQIO,N
NAME OF PETITIONER:4~~~C/~~ `~Yi IC..b ST~~ Date:
~M' Residence Ph: g~
ADDRESS: ~ LU~f Business Ph:
-NIL15 7Z1
STAEnTSEMENT OF THE NATURE OF PETITIONER'S ,IN{TEREST, INC ING ASONS F9
THh?~JY~I
a w~ ifs A21 PfYI~
It1J,~P6~ ~ O~ dSG
~ e~ natt~IPm in an ~vi~ r~~~, i~~~• t~, .QD.~
SPECIFIC PROVISION ON CODE OF ETHICS IN QUESTIO _
8Y1 2- 8.3 ,b2 ~ 2- S~ I . ~ ~'~~~IYID~A~VY~ C~'~f IY~~il~d.
COMPLETE STATEMENT OF FACTS: MIC~~~'1 C.DYhM_ ~ ~ ~p~
~1~ f~n~ntt~m®i~, mIDyYL~P~-~~,...~l~,~t~~J",
~t~,kA~ka,+l a,~d -N9~?~ v~ ~01+~,~z.+ ~ rr~srt~
STATEMENT O HE POSITION OR CONTENT N OF T PETITIO R:
>m~~ an ~~a~ ~ tx~i~-rP~fia ~S .~J_
Signature
ANY PETITION WHICH DOES NOT SUBSTANTIALLY COMPLY WITH THE FOREGOING
REQUIREMENTS MAY BE REJECTED. IN ADDITION, THE BOARD MAY, FOR GOOD CAUSE,
REJECT ANY PETITION.
IF THE PETITIONER IS THE PERSON WITH THE ETHICS PROBLEM, PLEASE COMPLETE
THE FOLLOWING:
, DO HEREBY REQUEST AN OPEN~CLOSED HEARING.
Signature
Hawaii County Council-23 Page 2 October 18, 2005
9:00 A.M.: STATEMENTS FROM THE PUBLIC ON PETITIONS, MEMORIALS,
COMMUNICATIONS, CERTIFICATES OF MERIT AND EXPRESSIONS OF CONDOLENCE
PETITIONS, MEMORIALS, COMMUNICATIONS, CERTIFICATES OF MERIT AND
EXPRESSIONS OF CONDOLENCE
Comm. 461: PETITION FOR I&fPEACHMENT (SEEKING THE A~IPEACHMENT OF THE
MAYORAND EIGHT SITTING HAWA[`I COUNTY COUNCIL MEMBERSI
From Corporation Counsel Lincoln S. T. Ashida, dated September 28', 2005, -
- recomme~ing this matter be agendized for the purpose of establishing prior to the
conclusion of the Circuit Court case, the "ground rules" and process for hearing,
considering, and v_ot_ing apon the reimbursement of legal expenses at the end of the
impeachment case. - -
Waived: FC
9:00 A.M.: STATEMENTS FROM THE PUBLIC ON ORDER OF RESOLUTIONS
ORDER OF RESOLUTIONS
Res. 169-05 Authorizes the Acceptance of a Donation of a Two Man Lifeguazd Tower to the
(Draft 2): Department of Parke and Recreation for Use at Onelcahakaha Beach Park
{Donated by Aloha Machine and Weldiag Company, with an estimated total value
of $30,000, to be used by the East Hawaii Water Safety Officers for lifeguard
surveillance.}
Re: Comm. 445.1
Intr. by: Ms. Isbell
Approve: FC-t5T
Res. 170-05: Authorizes the Council's Process for Procuring as Independent Auditor(s), Pursuant
to Section 10-13, Hawaii County Charter, and Authorizes the Payment of Funds in
Future Fiscal Years on a Multi-Year (4 years) Contract. {Recommends the Council
proceed with the issuance of a Request For Proposals (RFP), evaluation, award, and
execution of the contract in order to secure an audit finm to conduct a limited
general audit for the next four fiscal years commencing June 30, 2006, through
June 30, 2009. }
Re: Cornm.451
Intr. by: Ms. Isbell
Approve: FC-160
Section 2-83. Fair treatment.
(a) Officers and employees of the County, while discharging their duties and
dealing with the public, shall adhere to the following precepts:
(1) All public property and equipment are to be treated as a public trust
and are not to be used in a proprietary manner or for personal
purposes without proper consent.
(2) No person in a supervisory capacity shall engage in personal or
business relationships with subordinates, which might intimidate
said subordinates in the discharge of their officiat duties.
(3) All persons shall be treated in a courteous, fair and impartial
manner.
(b) No officer or employee shall use or attempt to use the officer's or
employee's official position to secure or grant unwarranted privileges,
exemptions, advantages, contracts, or treatment, for oneself or others;
including but not limited to the following:
(1) Seeking other employment or contract for services for oneself by
the use or attempted use of the officer's or employee's office or
position.
(2) Accepting, receiving, or soliciting compensation or other
consideration for the performance of the officer's or employee's
official duties or responsibilities except as provided by law.
(3) Using county time, equipment or other facilities for private business
or campaign purposes.
(4) Soliciting, selling, or otherwise engaging in a substantial financial
transaction with a subordinate or a person or business whom the
officer or employee inspects or supervises in the officer's or
employee's official capacity.
(5) Using county property or personnel for other than a public activity
or purpose.
(cj Nothing herein shall be construed to prohibit an officer from introducing
bills and resolutions, serving on committees or from making statements or
taking action in the exercise of the officer's legislative functions. Every
officer shall file a full and complete public disclosure of the nature and
extent of the interest or transaction which the officer believes may be
affected by legislative action.
(1975 C.C., c. 2, art. 8, sec. 5; Am. 2002, Ord. No. 02-109, secs. 3 and 4.)
Section 2-84. Conflicts of interests.
(a) No officer or employee shall take any official action directly affecting:
(1) A business or other undertaking in which that officer or employee
has a substantial financial interest;
(2) A private undertaking in which the officer or employee is engaged
as legal counsel, advisor, consultant, or representative, or other
agency capacity; or
(3) A business or undertaking in which the employee knows or has
reason to know that a brother, a sister, a parent, an emancipated
~!.~,._.,~s
Lincoln S.T. Ashida
Harry Kim Corporation Counsel
Mayor •,I
Gerald Takase
Assistant Corporation
Counsel
COUNTY OF HAWAII
OFFICE OF THE CORPORATION COUNSEL
t01 Auvuni Sveet, Suite 325 Hilo, Hawaii 9g72o-4282 (808)961-8251 pax (808) 867-8622
September 28, 2005
Corporation Counsel Published Opinion No. 2005-06
Honorable Harry Kim
Mayor, County of Hawaii
25 Aupuni St.
Hilo, HI 96720
Honorable Stacy K. Higa, Chairman, and Members of the
Hawaii County Council
County of Hawaii
25 Aupuni St.
Hilo, HI 96720
Dear Mayor Kim, Chairman Higa, and Council Members:
RE: Petition for Impeachment
Our Entry No.: WRK 05-10404
We received a copy of the enclosed documents authored by Roger
Christie, seeking the impeachment of the Mayor and eight sitting Hawaii County
Council members. We understand from a communication received from County
Clerk Constance Kiriu dated September 12, 2005 (enclosed, with Petition Audit
Worksheets omitted), that her office has received a petition signed by over 1 DO
qualified electors, as required by County law.'
Article XII, Chapter 2, Section 12-2.2, of the Hawaii County Charter
(2000) (hereinafter "Charter"), provides as follows:
Impeachment of Elected Officers. Any elected officer or officer
appointed to a vacancy in any elected office may be impeached for
malfeasance, misfeasance, nonfeasance, or maladministration in office.
The circuit court shall be a court of impeachment for the trial of any such
Our office has opined that "qualified electors" are the equivalent of "registered voters' Thus,
the Clerk has verified that at least 104 signatories of the Petition for Impeachment were
registered voters of the County of Hawai i. See discussion of this definition, inlra.
Hawaii County is an Equal Opportunity Employer and Provider
Honorable Harry Kim
Honorable Stacy K. Higa and Members of the
Hawaii County CounciV
September 2H, 2005
Page 2
officer who may be charged on any of the foregoing grounds. The charge
shall be set forth in detail in writing in a verified petition for impeachment
signed not less than one hundred (100) qualified electors of the county.
The court shall sit without a jury and shall proceed according to the form
required for the trial of all civil cases.
If the court sustains the charge, the officer shall be deemed removed from
office and the office declared vacant under this charter.
Article XI, Chapter 2, Section 6-2.3, of the Charter provides in pertinent
part as follows:
The corporation counsel shall represent the county in all civil legal
proceedings and shall perform all other services incident to the office as
may be required by law. The corporation counsel shall, however, be
prohibited from representing any elected officer in impeachment
proceedings. (Emphasis supplied).
Since the Corporation Counsel is prohibited by law from representing
elected officials in impeachment proceedings, the purpose of this communication
is simply to present (1) an analysis of the definition of "qualified elector," (2) an
analysis of the question of whether special counsel may be hired to represent the
Mayor and Council Members, pursuant to Article XI, Chapter 2, Section 6-2.5 of
the Charter, and (3) a recommendation to the Hawaii County Council to
establish a reimbursement hearing process prior to the conclusion of the Circuit
Court case. Further, this letter will serve to provide you information as to what
may be expected in upcoming legal proceedings relative to this case.
A summary of our letter is as follows:
1. A "qualified elector" is the equivalent of a "registered voter." In other
words, in order to be a "qualified electol' under our Charter, the
individual must be registered to vote.
2. County government funds may not be used at the outset to pay for or
subsidize the legal defense of the Mayor and Council Members.
However, upon conclusion of the case, if there is a determination that
the County officers acted in good faith and within the course and scope
of their duty and were furthering a public purpose, and that public
purpose was the corpus of the impeachment charge, reimbursement of
legal expenses may be available, subject to the approval of the Hawaii
County Council.
Honorable Harry Kim
Honorable Stacy K. Higa and Members of the
Hawaii County Council
September 28, 2005
Page 3
3. The Council is encouraged to establish a procedure for hearing and
determining whether legal expenses may be reimbursed to the Mayor
and the affected Council Members. This process should be
established prior to the conclusion of the Circuit Court case.
"Qua/iFed Electors"
The aforecited Charter provision provides that 100 "qualified electors"
must sign the petition for impeachment. What is a "qualified elector?" Is it
synonymous with a "registered voter?" Our research concludes a "qualified
elector" is the equivalent of a "registered voter," and that both terms are used
interchangeably in our Charter.
Our laws instruct us that in construing the meaning of words and phrases
in our statutes, deference must be given to the intent of the legislative body that
created the statute. Koolau Agr. Co., Ltd. v. Commission of Water Resource
Management, 83 Hawaii 484, 927 P.2d 1367 (1996}.
In our Charter, the term "qualified elector" appears in six (6) sections.Z
The term "registered voterr appears in four (4) sections 3 The terms "qualified
elector" and "registered voter„ appear in many of the same sections, and there is
limited distinction between both phrases.
Interestingly, Article XII, Chapter 1, Section 12-1.1 of the Charter, relating
to the recall of elected officers by the voters, provides in pertinent part the
method of recall as follows (emphasis supplied):
(a) A petition demanding recall of an official elected at-large, or by
voters of the entire county, as the case may be, shall be signed by
qualified voters equal to or greater than twenty-five percent of the
total number of persons who registered in the last general election.
(b) A petition demanding recall of a district councilmember shall be
signed by qualified voters equal to or greater than twenty-five
~ Section 3-3, relating to the qualifications of a candidate for the Hawaii County Council; Section
5-1.2, relating to the qualifications of a candidate for the office of the Mayor; Section 9-2, relating
to the qualifications of a candidate for the office of the Prosecutor; Section 12-2.1, relating to
impeachment proceedings Section 13-1, relating to a vacancy in otrice upon a finding that the
officer was not a "qualified elector;" and Section 15-1, relating to Charter amendments being
initiated by "qualified electors "
~ Section 3-3, relating to the qualifications of a candidate for the Hawai i County Council; Section
6-4.3, relating to the qualifications of a candidate for the Hawai i County Planning Commission;
Section 6-10.2, relating to the qualifications of a candidate for the Hawaii County Board of
Appeals; and Section 15-1, relating to Charter amendments.
Honorable Harry Kim
Honorable Stacy K. Higa and Members of the
Hawaii County Council
September 28, 2005
Page 4
percent of the total number of persons who registered in the last
general election.
(c) The term "qualified voter„ means a person who is registered to vote
in the county on the day that the clerk begins the examination to
determine the sufficiency of the signatures on the petition.
There is limited case law in Hawaii concerning the definition of "qualified
electors." One case of interest, however, is In re Chung, 44 Hawaii 220, 352
P.2d 846 (1960), wherein our conclusions are supported.
In Chung, the Supreme Court of Hawaii examined whether the Clerk of
the City and County of Honolulu had standing to appeal a decision by the Board
of Registration of Electors for the City and County of Honolulu. In that case, the
Clerk refused to register a citizen, claiming that a criminal conviction from Japan
effectively disqualified him from voting in a territorial election, pursuant to the
Hawaiian Organic Act, 48 U.S.C.A. Section 590.
The Court was confronted with the task of defining "qualified elector," and
stated as follows:
It is to be noted that the provision quoted above (relating to the Session
Laws of Hawaii, which transferred the duties of registration to the
respective county clerks) gave the right of challenge to "any qualified
elector," whereas under Section 47 (of the Revised Laws of Hawaii) the
person who had the right of challenge was "any legal voter." We think that
both expressions have the same meaning, and there is no significance in
the mentioned change of language.
44 Haw. at 223.
The Chung court further explained its reasoning as follows:
In a strictly literal sense, the words "any legal voter' mean a person who
has met all of the conditions precedent to the exercise of suffrage,
including registration.
44 Haw. at 225.
? • f
While this appeal is not concerned with the application of the words "any
legal voter," as used in Section 11-23 (of the Revised Laws of Hawaii
1955), to a person whose right to be or remain registered as a voter is in
Honorable Harry Kim
Honorable Stacy K. Higa and Members of the
Hawaii County Council
September 28, 2005
Page 5
question, we shall briefly touch upon it in order to round out our
consideration of the meaning of those words. As we noted earlier in this
opinion, such person does not come within the literal meaning of those
wards. But, clearly under every concept of an orderly judicial process, if
any person ought to have the right to appeal from an adverse board ruling
to this court, it is the person ruled against by the board with respect to his
right to be or remain registered as a voter. We think that the right of
appeal of such person may be preserved by interpreting those words to
mean any person who claims the right to be registered as a legal voter.°
44 Haw. at 227-228.
Finally, the minutes of the Charter Commission from June 12, 1979, reveal
that this very question was raised before the County commission. The following
exchange occurred between Charter Commissioner Matsuo Yanaga and Charter
Commission Counsel Stuart Oda:
MR. YANAGA: Mr. Chairman. Stuart, or the qualified electors of the
county, I think someplace I read in the minutes that the County Clerk Rudy
Legaspi recommended that along with your signature, you get your home
address, your social security number and all that son: of thing. I don't
know for what purpose. What is the reason for this?
MR. ODA: That is for verification purposes. In case you have to contact
the individual. By qualified elector is meant a person has to be a
registered voter. Let's say a person signs John Doe as one of the one-
hundred and there is no registered Jahn Doe with any address. That is
not verified, so that is out. If there is a John Doe, address Kea'au,
Hawai' i, P.O. Box 927, or whatever it is, that can be traced, right? There
may be some attempt made. You have to be qualified. The coordination
has to be made with the County Clerk's registered list of voters.
(Emphasis supplied}.
Based on the seemingly interchangeable use of the terms "qualified
electors" and "registered voter* throughout our Charter, the majority opinion and
reasoning found in /n re Chung, supra, the above-cited Charter Commission
minutes, and the lack of legal authority to the contrary, it is our considered
opinion that a "qualified elector" is a "registered vote' for purposes of thane
referenced sections of the Hawaii County Charter {2000).
`There is atwo-member dissent which argues the terms "qualified elector and "registered voter"
are distinguishable.
Honorable Harry Kim
Honorable Stacy K. Higa and Members of the
Hawaii County Council
September 28, 2005
Page 6
It consequently follows that in order for an impeachment action pursuant
to Article XII, Chapter 2, Section 12-2.1 of the Charter to be valid, the petition for
impeachment must be signed by at least one hundred (100) registered voters of
the County of Hawaii.
Hiring Special Counsel or payment of legal expenses
A recurring question raised by elected officials around the country is who
pays for legal expenses incurred when the official is required to legally defend
him/herself in lawsuits or other quasi-judicial actions, based upon challenges to
the official's actions taken within the course and scope of their office.
State and County statutory law is silent on this issue, and provides no
guidance on whether elected officials are afforded the right of representation paid
for with public funds. Similarly, there is limited case law relative to this narrow
issue.
One thing, however, is clear. Our Charter provides in no uncertain terms
that the Corporation Counsel is prohibited from representing any official in
impeachment proceedings. In our opinion, this presupposes that the use of
public funds for this purpose is likewise generally prohibited.
Article VI, Chapter 2, Section 6-2.5, of Charter, which provides for the
hiring of special counsel, provides in pertinent part as follows:
The council may, by two-thirds vote of its entire membership, authorize the
employment of special counsel for any special matter presenting a real
necessity for such employment. Any such authorization shall specify the
compensation, if any, to be paid for said services.
However, upon closer examination of the present case, this is really not a
"special counsel" issue. This is because the use of special counsel presupposes
that the government wilt pay for the legal fees and expenses incurred by the
government official who acted within the course and scope of their duties.s
e We note this office issu€d a letter dated August 31, 1999, to then Council Chair James Arakaki,
wherein it was suggested that the special counsel procedure was available, even though the
Charter specifically provided that the Corporation Counsel was prohibited from representing
County officers in impeachment proceedings. Although we do not presently vacate that opinion,
we do express concern that the use of special counsel presupposes that the County officer was
acting within the course and scope of his duty, and was furthering a public purpose, while acting
in good faith. These facts have not yet been conclusively proven in the present case.
Honorable Harry Kim
Honorable Stacy K. Higa and Members of the
Hawaii County Council
September 28, 2005
Page 7
The more accurate and germane question is whether there is a legally
recognized basis for the payment (or reimbursement) of legal expenses, even
though the Corporation Counsel is statutorily prohibited from representing the
County officers.
Generally, no compensation can be recovered by the attorney or agent
who represented the government official, where there was no authority to employ
him or her, or when the employment was not validly effected, or when there is no
provision in the law for compensation. Cahn v. Town of Hunnington, 29 N.Y.2d
451, 328 N.Y.S.2d 672, 278 N.E.2d 908 (1972). Further, attorneys' fees cannot
be recovered byway or reimbursement of a municipal offcer, where the attorney
was employed to protect the private interest of the officer in his or her office and
no public benefit inured to the municipality's benefit. Matthews v. City ofAtlantic
City, 196 N.J. Super. 145, 481 A.2d 842 (Law Div. 1984), iudament affd, 196
N.J. Super. 338, 482 A.2d 530 (App. Div. 1984).
However, a municipality may indemnify its officials only where expenses
are incurred in the performance of official duties or in defense of actions
challenging official acts. Matthews v. City of Atlantic City, supra. Further, the
fact that the public official is involved in the suit is not dispositive of the issue,
rather it is the subject matter of the underlying suit that determines whether the
public must bear the burden of the expense. Matthews v. City ofAt/antic City,
supra.
Thus, both an examination of the merits of the alleged malfeasance by the
County's officers, and an examination of the outcome of the impeachment action
itself is necessary in order to properly evaluate the County's responsibility in
paying for attorneys' fees, per the above-cited Matthews opinion.
With respect to the merits of the alleged malfeasance, no question the
corpus of the impeachment claim lies with the continued funding of the County's
marijuana eradication program, and the alleged failure of the Council to perform
the mandatory program review as required by the Charter. As Mr. Christie points
out in his moving papers:
The obvious solution to ending the ongoing colossal failure of the (sic)
'war on drugs' on this island is to cause the trial for impeachment of Mayor
Harry Kim and~ight of the nine County Council members immediately.
Why? Because the Mayor proposed, and the Council funded an increase
in marijuana eradication grants for last fiscal year. They agreed to
maintain those increased funds for this fiscal year with knowledge that
there has never been a "mandatory program review" (a specialized,
"mandatory" audit) of the controversial program. Zero. These elected
Honorable Harry Kim
Honorable Stacy K. Higa and Members of the
Hawaii County Council
September 28, 2005
Page 8
officials also know that there is at least one scientific study that links their
marijuana eradication program, island poverty and the (sic) 'ice' epidemic,
yet they continue to gamble with our lives. (sic) 'Malfeasance' in office? I
think so.
Again, whether these claims are meritorious or not is for the Circuit Court
to decide, and our office offers no opinion. We simply point out what is
abundantly clear: That Mr. Christie's claims of malfeasance are matters clearly
within the course and scope of the duties of the County officials.
An examination of the outcome of the Circuit Court proceeding is also
necessary. Irrespective of the outcome of the case (whether Mr. Christie is
successful in the impeachment of the Mayor and/or any of the Council members
or not), an examination of the facts developed in the Circuit Court case is
necessary. Questions such as whether the County officers acted within the
course and scope of their responsibility, whether they adequately performed their
Charter-mandated tasks, and whether there is any evidence of wanton neglect
would be critical and diapositive in our analysis and conclusion of whether legal
expenses may be reimbursed.
An enlightening case is Maui County Council v. Thompson, 84 Hawaii
105, 929 P.2d 1355 (1996), reconsideration denied 84 Hawaii 496, 936 P.2d 191
(January 29, 1997). In that case, the Maui County Council sued the Maui County
Finance Director, Corporation Counsel, and then Mayor Linda Lingle, alleging
that the administration wrongfully exceeded their authority by unilaterally hiring
special counsel to defend them in a wrongful termination case. The Maui Circuit
Court initially dismissed this lawsuit.
However, on appeal, the Supreme Court of Hawaii vacated the Circuit
Court's order of dismissal, and found that Mayor Lingle and her co-defendants
had in fact violated Maui County law in the unilateral hiring of special counsel to
defend them. The Supreme Court summarized its decision as follows:
And it is true, as a matter of policy, that "public indemnification of public
officials serves in part to encourage public service." Howard v. Town of
Burlington, 399 Mass. 585, 506 N.E.2d 102, 106 (1987). But this case is
not about whether public officials should be reimbursed, but about which
branch of government has the power to decide that question.
Municipalities often reimburse officials for legal fees incurred in defending
themselves from claims brought against them in their individual capacities.
But there is no legal or moral duty to reimburse unless the disputed action
affects the public interest, relates to the employee's official duties, and the
Honorable Harry Kim
Honorable Stacy K. Higa and Members of the
Hawaii County Council
September 28, 2005
Page 9
official was acting in good faith. (Citations omitted; emphasis in original
text).
84 Hawaii at 108.
With respect to the seminal question of whether public officials should be
reimbursed, the Hawaii Supreme Court in Thompson, as we have similarly
opined presently, recognized both the appropriateness of reimbursing public
officials for legal expenses, and the relevant criteria to consider prior to making
such a decision:
It has {ong been the law in this and other jurisdictions that "[i]t is within the
discretionary power of a municipality to indemnify one of its officers
against liability incurred by reason of any act done by him while in the
bona fide discharge of his official duties, and the municipality has the right
to employ counsel to defend the officer or to appropriate funds for the
necessary expenses incurred by him in such defense "
However, a municipality is under no legal obligation to do so, even for
actions within the scope of official duties:
"It would seem to be wisest to leave the indemnification of the officer to
the discretion of those who represent the interest of the city, that, on the
one hand, they should not be without the power to indemnify a meritorious
officer, acting in good faith, for the consequences of his conduct, and, on
the other hand, they should not be obliged to protect every officer, though
acting in good faith, under circumstances which seem to them to indicate
a blamable want of care and caution." (Citations omitted throughout)
84 Hawaii at 107.
Thus, the above passage espouses the need to examine the Circuit Court
record after this case is concluded, to determine whether there is any evidence to
suggest "blamable want of care and caution" on the part of any of the accused
County officers. If there is no such evidence in the Circuit Court case,
reimbursement of legal expenses may be justified, subject to Hawaii County
Council approval.e
e We are mindful of the etlSical implications of Council Members voting on whether to reimburse
themselves for legal expenses incurred. Nonetheless, our Charter and the mandate of Maui
County Council v. Thompson, supra, require this process. Hearing the matter in an open, public
meeting, and allowing public input would provide some safeguards against impropriety. We also
suggest as an option, as this office suggested in a letter dated August 31, 1999, to then Council
Chairman James Arakaki, that the matter be presented to the Hawai i County Board of Ethics for
their consideration. See further discussion of this issue, infra.
Honorable Harry Kim
Honorable Stacy K. Higa and Members of the
Hawaii County Council
September 28, 2005
Page 10
The initiation of an Impeachment Petition with the Circuit Court
Our laws provide that the Third Circuit Court presides as a court of original
jurisdiction over impeachment trials. The Court hears the case without a jury.
The Court follows the Hawaii Rules of Civil Procedure, which govern the process
of civil trials in Hawaii State courts.
Generally, an action is commenced by the filing of a complaint or petition.
Enclosed for reference purposes is a copy of Mr. Christie's petition filed in 1999,
seeking the impeachment of former Mayor Stephen Yamashiro and six Council
Members.
Since the Corporation Counsel will not be representing the Mayor and
Council, it is important that you immediately consult your attorney upon service of
a complaint or petition upon you, or take the necessary action to answer the
pleading within the statutorily mandated time.
After the parties are served, you may expect the case to be brought
forward by Mr. Christie, for a hearing before the Circuit Court.
Again, the Mayor and affected Council Members are urged to consult their
private attorneys or other legal representative.
Establishing a process for reimbursement prior to the conclusion of the
Circuit Court case
As discussed in footnote 6, ante, there are ethical implications if the
Council is called upon to vote upon the reimbursement of legal expenses for its
own members.
In 1999, in response to a request from the Hawaii County Council seeking
advice whether special counsel would be made available to Council Members
whose impeachment was sought, this office opined as follows:
There are some potential problems presented under the unique
circumstances of this case. While the County Council is the appropriate
body to determine if public funds should be expended and whether a
public purpose would be served by such expenditure under these
circumstances, six members of the Council are themselves subject to the
impeachment action. These members would have to vote then on a
matter of financial interest to themselves as individuals. Provisions of the
ethics code may apply. Section 2-83(d) provides that "[n)o officer or
employee shall...have a financial interest, direct or indirect, which might
reasonably tend to be incompatible with the proper discharge of his official
Honorable Harry Kim
Honorable Stacy K. Higa and Members of the
Hawaii County Council
September 28, 2005
Page 11
duties or to impair his independence of judgment in the performance of his
official duties..." Section 2-83(b) provides that "[njo officer or employee
shall use or attempt to use his official position to secure or grant
unwarranted privileges, exemptions, advantages, contracts or treatment,
for himself or others."
At the onset, we note that the aforecited Section 2-83(d) of the former
Ethics Gode was effectively repealed by the Hawaii County Council in 2002
(Ordinance 02-109).
Thus, the only provision of the present Ethics Code which raises concern
is Section 2-83(b), cited in pertinent part in the passage above.
However, a present conflict of laws is presented, since our laws also
provide that it is the Council and the Council alone who may authorize the
payment of legal expenses for County officials. Maui County Council v.
Thompson, supra, conclusively laid this issue to rest.
In the 1999 letter from this office, the following advisory was issued, which
we believe provides wise counsel today:
Section 14-3 of the Hawaii County Charter provides that:
"It shall be incumbent upon all employees or officers of the county to:
"(a) Make full disclosure in writing to the appointing authority or to the
council in the case of an elective officer, the possession or acquisition of
any interests, financial or otherwise as might reasonably tend to create a
conflict with the public interest. Any member of the council who knows of
a personal interest, direct or indirect, in any action proposed or pending
before the council shall disclose such interest prior to the taking of any
vote thereon.
"(b) File a copy of such disclosure with the county clerk which shall
become a matter of public record."
Should the Council determine to vote on an expenditure of funds for these
legal expenses, Council members affected should follow the disclosure
requirements of the code (Section 2-91.1[gj) and charter and further
should determine if they wish to ask the Ethics Board for an advisory
opinion on the propriety of voting on the issue. We believe it is likely that
since necessity dictates that only Council members can vote on the issue,
Honorable Harry Kim
Honorable Stacy K. Higa and Members of the
Hawaii County Council
September 28, 2005
Page 12
that it must be allowed. But the Ethics Code sets up the Ethics Board as
the body to make these determinations.
It is recommended that the Council consider agendizing the present
communication from our office, for the purpose of establishing prior to the
conclusion of the Circuit Court case, the "ground rules" and process for hearing,
considering, and voting upon the reimbursement of legal expenses at the end of
the impeachment case. This process will provide for transparency, and will allow
the public to weigh in at (1) the formative portions of the proposed process, and
(2) upon consideration of whether legal expenses should be reimbursed at the
conclusion of the case (assuming the impeachment effort is unsuccessful).
Although our laws do not provide for a specific process that cover this
unique situation, our proposed remedy seeks to reconcile and balance the
competing interests of (1) the legal requirement that the authority to grant
reimbursement remain with the Council, (2) the legal maxim that government
funds should be used to pay for legal expenses of government officials when
they have acted within the course and scope of their responsibility, in good faith,
and for a public purpose, in order to encourage persons to serve in public office,
and (3) ethical issues raised, by requiring the matter to evolve before a public
forum, allowing members of our community to weigh in on this important subject.
Please contact me if I may be of further assistance to you in answering
any other general questions regarding this matter.
Very truly yours,
~~i" "
LINCOLN S. T. ASHIDA
Corporation Counsel
Encls.
c: Honorable Constance Kiriu, County Clerk (w/ encls.)
Roger Christie (w/ encls.)
S: Depts/CCiLSA Misc.lletter to Mayor and Council re Christie impeachment 8-9-OS/LSAmr