HomeMy WebLinkAboutCOM 0537.056 2004-2006 "+yy Lincoln S.T. Ashida
`p't-" ~ Corporation Counsel
Harry Kim '
Mayor
Gerald Takase
; Assistant Corporation
o:'M~"
• Counsel
COUNTY OF HAWAII
OFFICE OF THE CORPORATION COUNSEL
101 Aupuni Street, Suite 325 Hilo, Hawaii 96720-4262 • (808) 961-8251 • Faz (808) 961-8622
January 12, 2006
Honorable Stacy K. Higa and Members of the
Hawaii County Council
County of Hawaii
25 Aupuni St.
Hilo, HI 96720
Dear Chairman Higa and Members of the Council:
RE: Reconsideration of Agenda Items
Enclosed is an opinion dated January 10, 2006, from the State of Hawaii
Office of Information Practices (hereinafter "OIP"), opining that no Sunshine Law
violation occurred in the Hawaii County Council's action in reconsidering and
voting upon committee reorganization at the November 22, 2006, meeting of the
Council.
In the final substantive paragraph of the OIP opinion, they state as follows:
In keeping with the spirit of the Sunshine Law, however, we strongly recommend
that the Council, when faced with an issue clearly of great concern to those
present, make the possibility of reconsideration clear in order to avoid the
confusion and disenfranchisement that obviously resulted here.
The Council Chair (and respective Committee chairs) may wish to
consider adopting a practice whereby a simple verbal advisory be placed on the
record immediately after any matter is deferred during a meeting. The advisory
may include a clear representation that the matter may be reconsidered at a
latter portion of the meeting.'
This presupposes there is a legally recognized and permissible means to reconsider a matter.
In the case of the committee reorganization resolution, since the Council had not passed nor
defeated the resolution, reconsideration on the same day (November 22) was permissible. In
other words, what was reconsidered was the Council's earlier decision to defer the resolution.
Reconsideration on November 22 would not have been permissible had the Council formally
acted upon the merits of the resolution.
Comm. No. ~ 37• Sb
Ref. To;
Hawaii County is an Equal Opportunity Employer and Provider , - ^ ~~~F
Honorable Stacy K. Higa and Members of the
Hawaii County Council
January 12, 2006
Page 2
With respect to opinions from the OIP, they are advisory only. However,
as we have previously consistently advised the Council and all our County
clients, we advocate compliance with the spirit of the Sunshine Law, and urge
you to consider adopting the aforementioned practice.
Please contact me if you wish to discuss this matter further.
Very truly yours..
LINCOLN S. T. ASHIDA
Corporation Counsel
Encl.
S: Depls/Council/LSA Corresp./Letter re OIP opinion re reconsideration 1-12-06/LSAmr
Jan-10-2006 03:44pm From-OFFICE INFOR31,1TION PRACTICES 18085861412 T-54B P.002/004 F-365
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NO. 7 CAPITOI. DISTf11CT BUILDING
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MONOLU.U, XAWAI'190619
Telepnonr (BOB) SBb1400 FAX (808)58&1417
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January 10, 2006
y~A FAC~MIj~E NQ (808) 961-8622
The Honorable Lincoln S. T. Ashida
Corporation Council
County of Hawai i
101 Aupuni Street, Suite 325
Hilo, Hawaii 96720
Re: Reconsideration of Agenda Item (S RFO-C} 05-59) (S INVES 122005)
Dear Mr. Aahida:
This letter responds to your request to the Office of Information Practices
("O1P") for an opinion on whether the Hawai i County Council violated part I of
chapter 92, Hawaii Revised Statutes (the "Sunshine I.aw"), by reconsidering and
taking action on Resolution No. 207-05 in the afternoon session of its November 22,
2005 meeting. By this letter, we also respond to a request for an investigation into
this same matter made by Ms. Tiffany Edwards, a reporter for West Hawau Today.
We have reviewed the letter that you provided to certain Council members,
opining on the validity of the Council's actions on this matter under the Sunshine
Law, the Council's rules, and R,obert's Ru1QS of Order. Our opinion letter is limited
solely to the question of whether the Council's actions violated the Sunshine Law.
The Council's agenda filed for the November 22 meeting lists as an agenda
item Resolution No. 207-05, which "[p)roposes to change the designations of the
Chair and Vice Chair of certain Council Committees." Based upon our
communications with you, we understand that the Council first considered the
resolution during the morning session of the meeting. After taking substantial
public testimony, the Council debated the matter, but then decided to postpone
action on the resolution. The primary purpose for postponement was concern over
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an-10-2006 03:44pm From-OFFICE INFORIOATION PRACTICES 18085661412 T-546 P.003/004 F-365
The Honorable Lincoln S. T. Ashida
January 10, 2006
Page 2
whether the designation of co-chairs for Council committees violates the Sunshine
Law.
Xou have informed us that you have reviewed the videotape of the meeting
and confirmed that no date was specified for reconsideration of the resolution, the
Council stating that it would consider the matter when OIP was able to provide as
opinion. You note a brief discussion by a Counal member alluding to the possibility
of receiving an OIP opinion by the end of the day, but state that "there was a
general sentiment that further discussion of the resolution would occur at a
subsequent meeting of the Council, and not on November 22, 2005." In the
afternoon session of the November 22 meeting, however, the Council reconsidered
its decision to postpone ite consideration of the resolution and took action on the
resolution.'
Based upon our communications and the material we have reviewed,
including various newspaper articles, we understand that the Council did take all
public testimony on the resolution during three and a half hours of the morning
session. However, the media and many members of the public did not attend the
afternoon session, believing that the Council had postponed consideration of the
resolution until the next Council meeting. Apparently, many who left believe that
the Council intentionally violated the Sunshine Law by acting on the resolution
after the public had left confident that the matter would not be decided at the
November 22 meeting.
The Sunshine Law requires a board to give public notice of any meeting to be
held. Haw. Rev. Stat. § 92-7(a) (Supp. 2004). The notice must include an agenda
"which lists all of the items to be considered at the forthcoming meeting[.]" No
provision in the Sunshine Law restricts consideration of agenda items to a certain
order or prohibits the reconsideration of an agenda item during the course of the
meeting. We thus generally recognize the ability of the Council to dictate the course
of discussion of agenda items, including taking agenda items out of order, recessing
discussion of an agenda item then returning to that discussion at a different point
during the meeting, and reconsidering items in accordance with its rules and the
meeting rules of general application.
It is our general opinion, therefore, that where proper notice has bees given,
the Sunshine Law allows an agenda item to be discussed and reconsidered at any
time during the course o>f the noticed meeting. Accordingly, we find that the
~ As this office has informed 1VI6. Edwards, OIP did provide the Council with an
informal opinion that afternoon on the issue of whether the use of co-chairs would 'violate
the Sunshine Law.
:,an-1D-206 ~3:44om Frcm-OFFICE INFORL~ATION PRACTICES 18085B81d12 T-54D P 004!004 F-366
The Honorable Lincoln S. T. Ashida
January 10, 2006
Page 3
Council's reconsideration and action on the resolution did not violate the Sunshine
Law?
We note, however, that the purpose of the Sunshine Law is to give the public
the opportunity to exercise its right to know and to scrutinize and participate in the
formation and conduct o1' public policy.~e, Haw. Rev. 3tat. 92-1 and 92-3 (1993);
Kaapu v. ~1oha ToH~~ DgveloBment Coro.. 74 Haw. 86$, 884, 846 P.2d 882 (1993).
And it is clear that many in attendance at the morning session were misled by the
Council's action postponing its consideration of the resolution and left believing that
they would have the opportunity to scrutinize the Council's action on the resolution
at the neat Council meeting. We understand that legitimate reasons existed for
reconsidering the matter in the afternoon session? Yn keeping with the spirit of the
Sunshine Law, however, we strongly recoxnnxend that the Council, when faced with
an issue clearly of great concern to those present, make the possibility of
reconsideration clear in order to avoid the confusion and disenfranchisement that
obviously resulted here.
We trust that this opinion responds to your request, and we will close this
matter with this letter. 13y copy of this letter to Ms. Edwards, we inform her of the
conclusion of our investigation regarding this matter and the closing of her related
file. Any questions regarding the foregoing maybe directed to this office.
Very_~(~T,,r~~uly Your~~j¢~~~
(:6ZYK4 ~i~'~ 1.
Cathy L. Takase
Staff Attorney
APP
Leslie 11. Kondo
Director
CLT:cIt
cc: Tiffany Edwards (via a-mail)
' We also premise this finding upon our understanding that the public was
given full opportunity to present testimony on the resolution during the morning session.
s For example, as correMly noted by ono Council member, consideration of the
resolution at the next Council meetizig would have required the Couadl to aQaia allow
public testimony on the resolution. Also, as noted above, the Council did receive the OIP
opinion sought.