2016-4012 Ordinance ORDINANCE NO. 2016-4012
AN ORDINANCE OF THE MAYOR AND CITY COMMISSION OF
MIAMI BEACH, FLORIDA, AMENDING CHAPTER 2 OF THE
CODE OF THE CITY OF MIAMI BEACH, ENTITLED
"ADMINISTRATION," ARTICLE VI, "PROCUREMENT,"
DIVISION 3, "CONTRACT PROCEDURES," BY CREATING
SECTION 2-376, ENTITLED "FAIR CHANCE REQUIREMENT
FOR CITY CONTRACTORS," AND AMENDING CHAPTER 62,
"HUMAN RELATIONS," BY CREATING ARTICLE V, TO BE
ENTITLED THE "FAIR CHANCE ORDINANCE," TO PROVIDE
REGULATIONS REGARDING THE CONSIDERATION BY THE
CITY AND BY CITY CONTRACTORS OF THE CRIMINAL
HISTORY OF APPLICANTS FOR EMPLOYMENT, AND TO
PROVIDE LIMITING PROVISIONS; AND PROVIDING FOR
REPEALER, SEVERABILITY, CODIFICATION, AND AN
EFFECTIVE DATE.
WHEREAS, people with criminal records suffer from pervasive discrimination in many
areas of life, including employment, housing, education, and eligibility for many forms of social
service benefits; and
WHEREAS, members of racial minorities are arrested, convicted, and incarcerated in
numbers disproportionate to their representation in the population as a whole; and
WHEREAS, as recognized in the Harvard Public Health Review, the "[r]outine exclusion
of people with criminal records from the workforce has drastic consequences for individuals,
families, and the economy. Job discrimination against those with criminal histories fuels poverty,
recidivism and ultimately poor health in vulnerable populations"; and
WHEREAS, "ban the box" policies and laws prohibit employers from asking questions
about an applicant's criminal history upon initial contact, and require employers to make
individualized assessments about the relevance of a prior offense to the job; and
WHEREAS, according to the National Employment Law Project ("NELP"), research
indicates that "personal contact with an applicant reduces the negative effect of a criminal
record on the employment decision"; and
WHEREAS, this Ordinance integrates U.S. Equal Employment Opportunity Commission
("EEOC") guidance on arrest and conviction guidelines, which guidance requires employers to
consider (1) the nature and gravity of the offense or conduct; (2) the time that has passed since
the offense or conduct and/or completion of the sentence; and (3) the nature of the job held or
sought; and
WHEREAS, according to NELP, over 100 cities and counties nationwide, and a total of
21 states, have adopted "ban the box" policies; and
WHEREAS, in Florida, the following local governments have adopted "ban the box"
policies: Miami-Dade County, Clearwater, Daytona Beach, Fort Myers, Gainesville, Jacksonville,
Orlando, Pompano Beach, St. Petersburg, Tampa, and Tallahassee; and
WHEREAS, the Mayor and City Commission desire to encourage the employment of
individuals who have been previously arrested and/or convicted; and
WHEREAS, pursuant to Ordinance No. 2016-3996, which was enacted pursuant to
Section 166.0442, Florida Statutes, the City is required to conduct background screening
investigations for (1) any position of City employment, whether paid, unpaid, or contractual, and
(2) any City contractor, employee of a City contractor, or City vendor who has direct contact with
individual members of the public or access to any public facility or publicly operated facility; and
WHEREAS, the City is currently not required to include on its employment applications
"the box" (i.e., the question of whether an applicant has a criminal history), which can intimidate
applicants and preclude them from applying for a City employment position; and
WHEREAS, "banning the box" would demonstrate the City's intent to support applicants
in their efforts to find employment; and
WHEREAS, the Mayor and City Commission desire to adopt the following Code
amendments.
NOW THEREFORE, BE IT ORDAINED BY THE MAYOR AND CITY COMMISSION OF
THE CITY OF MIAMI BEACH, FLORIDA, AS FOLLOWS:
SECTION 1. Division 3 of Article VI of Chapter 2 of the Code of the City o f Miami Beach is
hereby amended as follows:
CHAPTER 2
ADMINISTRATION
ARTICLE VI. — PROCUREMENT
* * *
DIVISION 3. —CONTRACT PROCEDURES
* * *
Section 2-376. Fair chance requirement for city contractors; waiver.
Fair chance re.uirement. Be•innin. on December 1, 2016} the cit shall not
enter into a contract, resulting from a competitive solicitation issued pursuant to
this article, with a business unless the business certifies in writing that the
business has adopted and employs written policies, practices, and standards that
are consistent with the city's Fair Chance Ordinance, set forth in article V of
chapter 62 of this Code.
Waiver. The city commission, upon written recommendation of the city manager,
may by resolution adopted by five-sevenths vote of the city commission waive
the requirements of this section if the city commission finds such waiver to be in
the best interest of the city, and provided such waiver is consistent with state and
federal law.
SECTION 2. Article V of Chapter 62 of the Code of the City of Miami Beach is hereby created
as follows:
CHAPTER 62
HUMAN RELATIONS
ARTICLE V. — FAIR CHANCE ORDINANCE
Section 62-200. — Legislative intent.
The employment of people with criminal records ensures healthier, safer communities,
and reduces recidivism. The city hereby declares that it is in the interest of the health,
safety, and welfare of the residents, visitors, and employees of Miami Beach to
encourage the employment of individuals who have been previously arrested and/or
convicted. People with criminal records suffer from pervasive discrimination in many
areas of life, including employment, housing, education, and eligibility for social service
benefits.
Section 62-201. — Definitions.
Applicant means any person considered for, or who requests to be considered for,
employment or transfer to another employment position, by the city.
Employment means any occupation, vocation, job, or work for pay, including temporary
or seasonal work, contracted work, contingent work, and work through the services of a
temporary or other employment agency; or any form of vocational or educational training
with or without pay.
Section 62-202. —Consideration by the city of conviction history in employment.
(a) The city shall not inquire about an applicant's criminal history and will not seek an
applicant's authorization to conduct a criminal history background check unless and until
the applicant is given a conditional offer of employment.
The city shall not advertise positions with a statement that an individual with a criminal
record may not apply for the position or place on the application that a person with a
criminal record may not apply, unless a criminal record would, pursuant to state or
federal law, preclude the applicant from obtaining the position.
If, after making a conditional offer of employment to an applicant, the city, (i) in
compliance with section 78-2 of this Code and state and federal law, conducts a criminal,
history background check, and (ii) determines that the applicant has been convicted of a,
crime, the city shall consider the following factors when determining whether the,
conviction disqualifies the applicant for the position:
LU The nature and gravity of the offense or conduct;
1_2_1 The time that has passed since the offense, conduct, and/or completion of the
sentence;
(3) The nature of the job held or sought; and
01 Whether, pursuant to state or federal law, the applicant's criminal record would
preclude the applicant from obtaining the position.
Loll The city shall not use or access the following records as a basis for declining to make an
offer of employment or for withdrawing the conditional offer of employment:
al Records of arrest not followed by a valid conviction, as long as the criminal case is
not currently pending;
gl Sealed, dismissed, or expunged convictions;
j Misdemeanor convictions where no jail sentence can be imposed; and
Non-criminal infractions.
If the city determines that the finalist's criminal history is cause for potential withdrawal of
the conditional offer of employment, the finalist will be notified and given an opportunity
to respond within five (5) business days of notification of cause for potential withdrawal.
if If, after review of additional information submitted by the finalist, the city determines that
the applicant's criminal history is disqualifying and a cause for withdrawal of a
conditional offer of employment, the applicant will be provided with a written letter of
rejection.
The city's selection and hiring decisions are final and are not subject to appeal.
Section 62-203. — Limiting provisions.
j No individual provision of this article shall apply to the extent that any such provision
conflicts with federal, state, or county law.
j This article shall not a••I to the hirin• of buildin• ins•ectors code corn•fiance officers
law enforcement officers, police complaint officers, police dispatchers, Of fire fighters
fire inspectors.
Nothing in this article requires the city to hire an applicant with a criminal record, nor
limits the city's ability to select the most qualified applicant for a position.
Loll Nothing in this article prohibits the city from denying employment based on a criminal
conviction determined in accordance with the practices outlined in section 62-202 to be
relevant to the position sought.
Nothing in this-article creates a cause of action for any applicant with regard to hiring or
selection for employment.
SECTION 3. REPEALER.
All ordinances or parts of ordinances in conflict herewith are hereby repealed.
SECTION 4. SEVERABILITY.
If any section, subsection, clause, or provision of this Ordinance is held invalid, the
remainder shall not be affected by such invalidity.
SECTION 5. CODIFICATION.
It is the intention of the Mayor and City Commission of the City of Miami Beach, and it is
hereby ordained that the provisions of this Ordinance shall become and be made part of the
Code of the City of Miami Beach, Florida. The sections of this Ordinance may be renumbered or
relettered to accomplish such intention, and the word "ordinance" may be changed to "section,"
"article," or other appropriate word.
SECTION 6. EFFECTIVE DATE
This Ordinance shall take effect on the a/ day of 1/14' , 2016.
PASSED AND ADOPTED this 1/ day of Ma' , 2016.
ATTEST:
PhilZ(7 �'/ l}a Ma
Rafa E. Granado
City Clerk
, y
(Sponsored by Commissioner Michael Grieco)
APPROVED AS TO
FORM & LANGUAGE
Underline denotes additions & R E ELUTION
denotes deletions 3,,,� a,.; 5 (174(4
Double underline denotes additions after First Reading .--.--
denotes deletions after First Reading City Attorney Date
1,,on 1401
* :INCORP ORATED:
F:\ATTO\KALN\ORDINANCES\Ban the Box 2nd readinio \. c �I (0f,
•°/-1 61'
MIAMI BEACH
OFFICE OF THE CITY ATTORNEY
RAULJ. AGUILA, CITY ATTORNEY COMMISSION MEMORANDUM
To: Mayor Philip Levine Date: May 11, 2016
Members of the City Commission
From: Raul J. Aguil • k-
City Attorne
Subject: AN ORDINANCE OF THE MAYOR AND CITY COMMISSION OF MIAMI
BEACH, FLORIDA, AMENDING CHAPTER 2 OF THE CODE OF THE CITY
OF MIAMI BEACH, ENTITLED "ADMINISTRATION," ARTICLE VI,
"PROCUREMENT," DIVISION 3, "CONTRACT PROCEDURES," BY
CREATING SECTION 2-376, ENTITLED "FAIR CHANCE REQUIREMENT
FOR CITY CONTRACTORS," AND AMENDING CHAPTER 62, "HUMAN
RELATIONS," BY CREATING ARTICLE V, TO BE ENTITLED THE "FAIR
CHANCE ORDINANCE," TO PROVIDE REGULATIONS REGARDING THE
CONSIDERATION BY THE CITY AND BY CITY CONTRACTORS OF THE
CRIMINAL HISTORY OF APPLICANTS FOR EMPLOYMENT, AND TO
PROVIDE LIMITING PROVISIONS; AND PROVIDING FOR REPEALER,
SEVERABILITY, CODIFICATION, AND AN EFFECTIVE DATE.
A. Introduction and Summary
Pursuant to the request of Commissioner Michael Grieco, the attached "Fair Chance" or "Ban
the Box" Ordinance is submitted for consideration by the Mayor and City Commission. The
Ordinance amends Chapter 62 of the City Code, entitled "Human Relations," and the City's
Procurement Code, at Chapter 2, Article VI.
In summary, the proposed Fair Chance Ordinance would prohibit the City, as an employer, from
inquiring about an applicant's criminal history until the applicant is given a conditional offer of
employment. The City would also be prohibited from (i) advertising employment positions with a
statement that an individual with a criminal record may not apply for the position, and (ii) placing
• a statement on an employment application that a person with a criminal record may not apply
for the position.
Currently, the City does not conduct a criminal background check of applicants for employment,
until an applicant is given a conditional offer of employment. Additionally, City employment
applications do not inquire into an applicant's criminal history. To that extent, the Ordinance
would codify what is already a City policy.
Agenda Item R S C_
Date S-l I- Ls
Fair Chance Ordinance
May 11, 2016
Page 2
B. Policy
People with criminal records suffer from pervasive discrimination in many areas of life, including
employment, housing, education, and eligibility for many forms of social service benefits. The
"[r]outine exclusion of people with criminal records from the workforce has drastic
consequences for individuals, families, and the economy," and "fuels poverty, recidivism, and
ultimately poor health in vulnerable populations."'
"Ban the box" or "fair chance" policies and laws prohibit employers from asking questions about
an applicant's criminal history upon initial contact, and require employers to make individualized
assessments about the relevance of a prior offense to the job. According to the National
Employment Law Project, research indicates that "personal contact with an applicant reduces
the negative effect of a criminal record on the employment decision."2
For instance, a 2009 study conducted in New York City found "a significant effect of a criminal
record on employment outcomes, and one that appears substantially larger for African
Americans."3 However, "[e]mployment prospects improve significantly for applicants who have a
chance to interact with the hiring manager, and more so among those who elicit sympathetic
responses in the course of those interactions.i4
In Florida, the following local governments have adopted "ban the box" policies: Miami-Dade
County, Clearwater, Daytona Beach, Fort Myers, Gainesville, Jacksonville, Orlando, Pompano
Beach, St. Petersburg, Tampa, and Tallahassee.
C. Green factors for considering arrest and conviction records in employment decisions
Under the proposed Ordinance, once the City gives an applicant a conditional offer of
employment, the City, in compliance with Section 78-2 of the City Code, and state and federal
law, shall conduct a criminal background check. If the City determines that the applicant has
been convicted of a crime, the City shall consider the following factors when determining
whether the conviction disqualifies the applicant for the position:
(i) The nature and gravity of the offense or conduct;
(ii) The time that has passed since the offense, conduct, and/or completion of the sentence;
(iii) The nature of the job held or sought; and
(iv) Whether, pursuant to state or federal law, the applicant's criminal record would preclude
the applicant from obtaining the position.
1 Sonali Saluja & Henry Rosen, Why public health practitioners should care about job prospects for
people with criminal records: Employment challenges and successful prison and jail reentry, 6 HARV. PUB.
HEALTH REV. (July 2015).
2 Fact Sheet: "Ban the Box" is a Fair Chance for Workers with Records, National Employment Law
Project, March 2016, http://www.nelp.org/content/uploads/Ban-the-Box-Fair-Chance-Fact-Sheet.pdf.
3 Devah Pager, Bruce Western, & Naomi Sugie, Sequencing disadvantage: Barriers to employment facing
young black and white men with criminal records, 623 ANNALS Ann.ACAD. POL. &Soc. SCI. 195-213 (May
2009).
4 Id.
Fair Chance Ordinance
May 11, 2016
Page 3
Factors (i) through (iii) are consistent with U.S. Equal Employment Opportunity Commission
("EEOC") guidance regarding the consideration of arrest and conviction records in employment
decisions under Title VII of the Civil Rights Act of 1964.5 These factors, known as the Green
factors, were first identified by the U.S. Circuit Court of Appeal for the Eighth Circuit in Green v.
Missouri Pacific Railroad. In Green, the Eighth Circuit held that it was discriminatory under Title
VII for an employer to "follow[] the policy of disqualifying for employment any applicant with a
conviction for any crime other than a minor traffic offense." 523 F.2d 1290, 1293 (8th Cir. 1975).
The court held that these factors should be applied to assess whether exclusion is job related
for the position in question and consistent with business necessity.
Upon consideration of these factors, the City shall determine whether to withdraw the
conditional offer of employment. If an offer is withdrawn, the finalist will be notified and given an
opportunity to respond within five (5) business days. If, after reviewing the additional
information, the City determines that the applicant's criminal history is disqualifying and a cause
for withdrawal of a conditional offer of employment, the applicant will be provided with a written
letter of rejection. The City's selection and hiring decisions are final and are not subject to
appeal.
D. Prohibitions and limiting provisions
Pursuant to the proposed Ordinance, the City shall not use or access the following records as a
basis for declining to make or for withdrawing an offer of employment:
(i) Records of arrest not followed by a valid conviction, as long as the criminal case is not
currently pending;
(ii) Sealed, dismissed, or expunged convictions;
(iii) Misdemeanor convictions where no jail sentence can be imposed; and
(iv) Non-criminal infractions.
Additionally, the proposed Ordinance would not apply to the extent that any of its provisions
conflict with federal, state, or county law. The Ordinance would also not apply to the hiring of
building inspectors, code compliance officers, law enforcement officers, police complaint
officers, police dispatchers, fire fighters, or fire inspectors.
E. Amendment to Procurement Code
The Ordinance amends the City's Procurement Code to require that the City shall not enter into
a contract, resulting from a competitive solicitation, with a business unless the business certifies
in writing that the business has adopted and employs written policies, practices, and standards
that are consistent with the City's Fair Chance Ordinance. This requirement may be waived by
5/7ths vote of the City Commission.
5 Equal Employment Opportunity Commission, EEOC Enforcement Guidance No. 915.002, Consideration
of Arrest and Conviction Records in Employment Decisions Under Title VII of the Civil Rights Act of 1964
(2012).
Fair Chance Ordinance
May 11, 2016
Page 4
F. Economic Impact
Pursuant to Section 5.02 of the City Charter, the City "shall consider the long-term economic
impact (at least 5 years) of proposed legislative actions." Based on the analysis of the Human
Resources and Procurement Departments, this Ordinance will not have an economic impact on
the City's resources.
RA/N K/sc
F:WTTO\KALN\COMMISSION MEMOS\Ban the Box Memo 2nd reading.docx
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