The Illusion of the Brown Act

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My first glance at the news this morning was a story about alleged legal violations by the City Council of the City of Costa Mesa of California’s requirements that government be conducted out in the open.  This story highlighted an increasing battle over the intent and purpose of the California’s open meeting laws. 

Attempting to end gamesmanship and “smoke filled back room deals,” California adopted an “open meeting law” called the Ralph M. Brown Act in 1953.  This act was in response to various local cities and public agencies that were pulling all sorts of stunts to avoid public scrutiny of their decisions.  My favorite involved a Southern California City that held a hearing on Catalina Island on a particularly controversial measure.  It proved difficult for the grass roots opposition to rally the troops to the island in time to oppose the measure which was passed with little audience.  The bigger problem was the “pre-meetings” held by public agencies where real discussion of measures took place behind closed doors with no public audience and no press coverage rendering the real “vote” little more than a meaningless charade.

The intent of the Brown Act was to require 1) adequate public notice and descriptions of decisions to be made by public agencies, 2) that the hearings actually take place within the jurisdiction of the public agency, and 3) that the discussion and consideration of matters be conducted out in front of the public at these properly noticed and properly located meetings.  Unfortunately the application of the Brown Act has grown as complicated as our tax code and I think that it should be scrapped and replaced with an updated act closing the many loopholes that have allowed an increasing amount of public business to take place outside of public scrutiny.

What are the problems with this seemingly simple and well intentioned Act?  Unfortunately they are legion and creative public agencies are finding new ways to “get around” them every day.

The “Committee”

The news out of Costa Mesa this morning is that the City Council had created a number of committees that have been meeting outside of public view.  Believe it or not, that is not automatically a violation of the Brown Act.  Committees are allowed to meet privately under exceptions to the Brown Act as long as they contain less than a majority of the elected board and are created for temporary or “ad hoc” recommendations.  The theory behind the committee exception is that if less than a majority is meeting and they are merely making recommendations to the rest of the elected board or council about non-recurring issues it is “no harm no foul.”  Needless to say some public agencies (like the accusations pending against Costa Mesa) have pushed these exception to (or beyond) the limits.

In Costa Mesa, the City Council created five two-member working groups this year: Economic Development; Sports and Recreation; Policies, Procedures and General Plan; Budget and Capital Improvements; and Motel Issues.  Councilman Jim Righeimer said the groups were temporary, not standing.  “The only one that had anything going on was Budget, and that final report is coming on the 17th” of May, Righeimer said.  Couple of problems with Mr. Righeimer’s statement, 1) none of those five committees sound either “ad hoc” or temporary – all are recurring ongoing issues, and 2) the fact that only one of those committee “has anything going on” is still more evidence that these are standing committees not brought together for a temporary purpose.

The Seriatim Meeting

Probably the biggest area of violation in the Brown Act is the “non-meeting meeting” much like the game telephone we played as kids.  One City Council member talks to another City Council member who talks to another and suddenly you have conducted the entire meeting outside of public view.  A common corollary to this violation is the City Manager or similar staff member talking to a majority of the City Council individually to “informally poll” their opinion.  Technology has also created new Brown Act problems as sending a series of emails out to various City Council members about pending business is another way of conducting secret meeting.  The email violations can even happen more easily and accidentally when conversations with one elected representative are attached to an email forwarded to another elected official – as soon as a majority has received the communication, you have a Brown Act problem.

I have witnessed this seriatim meeting first hand – when a city council hears a complex development or contract issue, asks no questions, has no discussion with the exception of mysterious comments when one council member turns to the other and says “remember that thing” and suddenly heads nod and a unanimous vote is made (real case I saw in person).  Some of the more diabolical methods of intentionally evading open meeting laws are only discovered through the stupidity of the perpetrators.  There was the infamous meeting where a City Council member was in an ongoing “live chat” with the applicant developer during the hearing (obviously allowing a major part of the discussion to take place outside of the public ear) that was only discovered when a reporter happened on to the live chat and reported it to the City Attorney.

The Inadequate Description

Obviously open meeting laws work if the public is properly informed about what is to be discussed.  A classic way to reduce public participation is for a public agency to give an inadequate or misleading description of what is being considered.  “Proposed Zone Change” without a description of the impacted property so that neighbors can evaluate a projects’ impact would be a classic example of this kind of violation. 

Inadequate or misleading descriptions are actually far less common than the violation of the committee or seriatim meeting rules for a simple reason – you can compare the language of the agenda and compare it to the action that is taken.  Much easier to prove that kind of violation than to prove that three city council members met in public.

The Recommendation

The above reflects only a small fraction of the problems with the Brown Act and erodes public confidence in the democratic system.  The Brown Act has been around for 57 years and needs more than a face lift, it should be replace wholesale with tighter provisions that reflect technological improvements that have been made since man went to space.

About Geoff Willis