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City Clerk File No. 502C'I`A c«ni~ FrcF R-~'F#~ so2-MnnrN~,~ OFFICE OF THE CITY ATTORNEY F L O R i~Pr~s MURRAY H. DUBBIN ''""°" '~' s~ n'~" City Attorney D A LETTER TO COMMISSION Telephone: Telecopy: February 24, 2005 TO: Mayor David Dermer Members of the City Commission and Jorge M. Gonzalez, City Manager ~~1 ' _ FROM: Murray H. Dubbin, City Attomey,J~ SUBJECT: Sunshine Law: State Attorney's Office Close out Memo (305)673-7470 (305)673-7002 As you recall, within the past month both the SunPost and Miami Herald publications reported that a complaint had been filed with the State Attorney's Office Public Corruption Unit regarding alleged violations of the Sunshine Law by certain City of Miami Beach appointed public officials- specifically, the complaint focused on a meeting of the City's Transportation and Parking Committee, Finance and Citywide Projects Committee, as well as the Miami Beach Transportation Management Association, Inc. Attached is the Public Corruption Unit's memorandum closing out its investigation of this matter, concluding that "there is no evidence of an intentional violation of the Sunshine Law" by City personnel, and finding that "any possible violation" had effectively been cured by the City. Accordingly, no further action need be taken by the State Attorney's Office, and this matter is resolved. c: Robert Parcher, City Clerk 1700 Convention Center Drive -- Fourth Floor --Miami Beach, Florida 33139 ~FF~yj%;i ~.~ OeDC[ or rrl[ 9rwr[ ATrO[wn Y.M1FNCRIMfi FERNANDE2 RUNDLE '~~,~c t C~~>~:~6 f~ ~ E~[V[MRI JVOICIAL CIIICVR Or FLOIIIO/~ .-_-~ LOAMMI FIGUEREDO PUBLIC CORRUPr1O PnosecurloN UN1r :LOSE OUT MEMO ELIMINARY INQUIRY ~ r I'' F`~ ~~~' ° . ; t7: I ~ ~ • 305)Sp-0662 E. R. GRAXAM BUIlO1Nfi 1350 N. W. 12TIAVENU[ ~; ~ L ~ il 30E)5g7-0100 aossq]-0]]2FAx E-MAn.:LwmmlFlp :`..°e"n1Ogi.m'u'sAO~om ILIC CORRUPTION UNIT ' , / ~;,`~`., i " r IC.-~. A.S.A.: J~ltnefte'~~~dirr~ ~ J [NVESTIGATION #: /~~ / 64-05-11 DATE: January 26, 2005 /7/;, DATE: Division Chief, PC Unit JOSE J. ARROJO Chie Assistant DATE: \ S ~ J S SUBJECT(S): Miami Beach Parking and Transportation EMPLOYMENT: Committee Miami Beach Finance and Citywide Projects Committee Miami Beach Transportation Management Association, Inc. INVESTIGATOR: AGENCY: PHONE: CRIME Sunshine Violations ALLEGATION: STATUTE 286.011 CONCLUSION: DEGREE misdemeanor The City of Miami Beach Transportation and Parking Committee had a meeting scheduled for January 3, 2005, and the Finance and Citywide Projects Committee had a meeting scheduled for January 6, 2005. Neither meeting was properly noticed due to a clerical oversight. The lack of notice was not discovered until after the January 3r4 meeting. Deputy City Attorney Jean Olin immediately took action and declared the meeting's actions null and void. The meeting was rescheduled for January 31, 2005, with notice. No business was dealt with at the January 6`h meeting, because the notice problem had been discovered, and the meeting was rescheduled for January 27, 2005, with notice. The clerical issue has been corrected and City personnel are aware of the need to notice committee meetings. Poease Recyde 0674 - F:WC-Close Out MemoslMiami Beuh Slmshine Vialation.DOCSASoF The iNiami Beach Transportation Management Association, Inc. (TMA) is a private, non-profit, corporation which contracted with 'he City of Miami Beach to operate the Electrowave bus. The TMA is not required, as a private entity, to give public notice of its meetings unless it is involved in the public decision making process by virtue of being delegated a governmental function. The increased awareness of notice requirements generated by the aforementioned public committees caused Assistant City Manager Robert Middaugh, who was to attend the TMA meeting, and TMA officials to contact Deputy City Attorney Jean Olin, who advised the TMA that meetings held to deal with any governmental function the TMA has contracted to perform must have adequate public notice. Appropriately, a TMA meeting that was to include such a discussion was canceled and will be rescheduled. I spoke with Miami Beach City Clerk Bob Parcher and reviewed the notice procedures. The City of Miami Beach Clerk has an intemal a-mail address to which the liaison for each committee is to send information on scheduled meetings. The information concerning the meetings is placed in the Miami Herald Neighbors section on Thursdays. In order to meet publishing deadlines, the information must be received at the internal a-mail address by noon on Mondays. In the case of the Transportation and Parking Committee, the secretary for the committee did not sent the necessary information to the internal a-mail address. (That secretary is no longer employed by the by the City of Miami Beach.) In the case of the Finance and Citywide Projects Committee, the information was received after the Monday noon deadline. Attempts were made to publish the meeting as an "emergency" meeting and flyers were placed around Miami Beach City Hall. Mr. Parcher has clarified the term "emergency" and has made his staff aware that a delay in notice is not an emergency. Additionally, Mr. Parcher believes that any meeting held on a tme emergency basis should contain in the record a reason why the meeting was an emergency. There is also a place on the Miami Beach website for noticing meetings and a special designation for new notices. I also spoke with Deputy City Attomey Jean Olin, who confirmed the above information. She also provided copies of the tapes from the Transportation and Parking Committee meeting, and the Commission Memorandum of the Finance and Citywide Projects Committee meeting, the only action being to reschedule the meeting with adequate notice. There is no evidence of an intentional violation of the Sunshine Law by any of the aforementioned committees. Any violations of the Sunshine Law that may have occurred appear to have been inadvertent. Prompt and appropriate action was taken by the Deputy City Attomey and her staff to remedy any possible violation. Members of the committees involved in this inquiry have been apprised of the requirements of the Florida Sunshine Law. This matter is now closed. cc: Jose J. Arrojo Please Recycle 0611 - F1PC- Cbae Out MemoaUlismi Beach Sumhine Violation.DaISASoF