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95-21556 Reso ... r' . ... RESOLUTION NO. 95-21556 A RESOLUTION OF THE MAYOR AND CITY COMMISSION OF THE CITY OF MIAMI BEACH, FLORIDA APPROVING PROCEDURES FOR CONDUCfING QUASI-JUDICIAL HEARINGS. WHEREAS, the City of Miami Beach City Commission, Planning Board, Board of Adjustment, Design Review Board, and Historic Preservation Board conduct quasi-judicial hearings on site specific applications for development approval; and WHEREAS, quasi-judicial hearings must be conducted in a manner that accords due process to all parties; and WHEREAS, judicial authorities detennined that off-the-record communications between interested persons and members of quasi-judicial boards are improper; and WHEREAS, the City Commission of the City of Miami Beach desires to adopt rules of procedure to govern the conduct of quasi-judicial hearings. NOW, THEREFORE, BE IT RESOLVED BY THE MAYOR AND CITY COMMISSION OF THE CITY OF MIAMI BEACH, FLORIDA: Section I: The Quasi-Judicial Procedures which are attached as Appendix 1 are approved as the procedures for the conduct of hearings before all boards of the City. Section 2: PASSED and ADOPTED this This Resolution shall take effect immediately at ArrEST: 1L~ ~.. \S.vr-- ITY CLERK .::quuijud... FORM APPROVED Lepl Dept. By -:r-c..;> Date 'f. 1\. a.~- ,. '. OFFICE OF THE CITY ATTORNEY ~~ tlJIdomi 1JelUA F L o R D A CITY ATTORNEY POBOX 0 MIAMI BEACH, FLORIDA 331 '9-2032 TELEPHONE 1305} 673-7470 TELECOPY (305) 673-7002 LAURENCE FEINGOLD COMMISSION MEMORANDUM No..3.l.La::9.-5 RE: MAYOR SEYMOUR GELBER MEMBERS OF THE CITY 2 OM SION LAURENCE FEINGOLD CITYATIO~EY ~ QUASI-JUDICIAL PROCEDURES TO: FROM: DATE: APRIL 19. 1995 Our office has prepared quasi-judicial procedures which we recommend that the City Commission adopt for all City Boards. The Planing Board, Board of Adjustment, Design Review Board, Historic Preservation Board and at times, the City Commission, sit in a quasi-judicial capacity when hearing site-specific development applications. These hearings include both de novo hearings and appeals heard on matters as provided in the Zoning Ordinance. It is essential that these hearings are held in a fair and impartial manner on the merits of the application. To further this goal, we have prepared the attached procedures to guide these Boards. In addition, recent judicial authority bas held that ex-parte communication is presumptively prejudicial to a party, as recently expressed in Jennin~s v. Dade County. 589 So. 2d 1337 (Fla 3d DCA 1991). The attached procedures also provide guides to assure that improper ex-parte communication does not occur. RECOMMEND A nON The office of the City Attorney recommends the adoption of these Quasi-Judicial Procedures to be used in the review of all site-specific development applications. LF:jm Enclosure l::m:quajud.CDIIl AGENDA ITEM OATE 1700 CONVENTION CENTER DRIVE - FOURTH FLOOR - MIAMI BEACH. FLORIDA 33139 QUASI-JUDICIAL PROCEDURES I. Purpose It is the purpose of these roles to provide a fair, open and impartial procedure for the consideration by members of the City Commission, the Board of Adjustment, Planning Board, Design Review Board, and Historic Preservation Board of quasi-judicial matters in the course of quasi-judicial proceedings. II. Definitions A. Applicant - an individual , corporation or other authorized legal entity filing an application or an appeal which initiates a quasi-judicial proceeding, including City staff and the City Commission and Boards. B. Application (matter) - an application for a site-specific land use plan amendment, rezoning, variance, conditional use permit, design review approval, or other request for a quasi-judicial proceeding or appeal as authorized by the City's Zoning Ordinance. C. City Staff - an employee of the City of Miami Beach. D. Ex-parte communication - any written or oral communication with members which may directly or indirectly influence the disposition of an application, other than those made on the record during a pubic hearing. E. Member - a City Commissioner or a member of the Board of Adjustment, Planning Board, Design Review Board or Historic Preservation Board. m. Ex-Parte Communication Members are prohibited from discussing matters with applicants. interested parties, lobbyists, other members or any other third party. A. Written communications - all written communications received by a member relevant to a pending matter shall be turned over to the Secretary or Clerk of the Board, and the Office of the City Attorney, entered into the official file and transmitted to the applicant. The communication shall also be disclosed at the next public hearing on the matter. B. Oral Communications - when a member determines that an oral communication relates to a pending matter, the member shall immediately tenninate the communication. The member shall reduce any conversation to writing, identifying the party, date, time, place and content of the conversation, and transmit the APPENDIX 1 infonnation to the Secretary or Clerk of the Board, the Office of the City Attorney, and the applicant. The communication sball also be'disclosed at the next public hearing on the matter. C. Communication with City staff-members may discuss matters with City staff for the purpose of clarifying procedures relating to any hearing. D. View of Property - members may visit sites which are the subject of a pending matter. However, communications with applicants, owners, surrounding property owners, or third parties are prohibited. IV. Quasi-Judicial Proceedings A. Legal Representation - 1. Applicants - Applicants may be represented by legal counsel. 2. Board _ the Board or City Commission shall be represented by the City Attorney's Office. 3. Staff - staff may be represented by outside counsel when appearing before the Board or City Commission during an appeal of any matter or when appe8rlng as an applicant. B. Participants at Hearings All who testify on any matter must sign in and be sworn by the presiding officer. All persons testifying subject themselves to cross-examination. Each person, other than salaried members of City staff, who address the Board shall give the following information. (a) Name; (b) Address; (c) Whether they speak for themselves, a group of persons, or a third party; if the person says that they represent an organization, they shall also indicate whether the view expressed by the speaker represents an established policy of the organization approved by the board or governing counsel; and (d) Whether there is compensation by the persons or persons on 2 whose behalf they speak; and (e) Whether they or any member of their immediate family has a personal financial interest in the pending matter. C. Conduct of Hearini - the order of hearing shall be as follows: 1. The Chair shall read a preliminary statement once at the beginning of the quasi-judicial public hearing agenda, announce the particular agenda item, and open the public hearing. The Chair shall conduct the meeting and all questions shall be through the Chair. 2. The applicant, witnesses, staff, and all participants asking to speak shall be sworn excluding attorneys, unless they testify. 3. The Board shall decide any parliamentary objections and objections to evidentiary matters with the advice of the City Attorney. 4. The staff shall present its report, offer it into evidence, and have it made part of the record. . 5. The applicant shall present its case. 6. Participants in support of the application shall present their testimony and any evidence. 7. Opposition shall have the right to cross-examine individual speakers. 8. The Board may ask questions of any speaker. After the presentation in favor of the matter, the hearing shall proceed as follows: 9. Participants in opposition to the application shall present their testimony and evidence. 10. The Applicant shall have the right to cross-examine individual speakers. 11. The Board may ask questions of any speaker. 12. Rebuttal by staff, if requested. Staff shall be subject to cross-examination. 13. Any other member of the public may testify and present evidence, and are 3 o/IIqip..... subject to cross-examination. 14. Rebuttal by the Applicant, ifany. IS. The Chair closes the public hearing. The Board shall discuss the matter and render a decision (no further presentations or testimony shall be pennitted). Following the final disposition of the application, all evidence admitted at the hearing, the application file, all staff reports, and the adopted order promulgating the decision of the Commission shall be maintained in a separate file constituting the record of the application. The record shall be kept in the custody of the appropriate staff at all times during the pendency of the application. The record will be made available to the public for inspection upon request at any time during nonnal business hours. All quasi- judicial hearings shall be recorded. A court reporter may be retained and paid for by any person to take down the proceedings. Any person may order and pay for a transcript of the proceedings. Any such retained court reporter shall identify himselflherself to the clerk. 4 LA OPINIONS DIV. TEL:904-922-3969 Oct 19.94 ~;::l1 NU.UUl ;.,,~ ,~.-.r" ii~~. ;~~~.~,.. ~. ..~ '~" ~~:''''A ""; . ..,- .~ ~~...~. STATE OF FLORIDA OPJ'JOS o. ~aJf.T 0..._10 ROBBBT A. BUTTBSWORTS 94-71 August: 19. 1994 Tbe Honorable Truman O. Scarborough, Jr. Chairman, Brevard County Commission 400 South Street First Floor, suite lA .. Titusville. Florida 32780-7698 Dear.commi~sioner Scarborough: On behalf of the Brevard County Board of County commissionere, you ask .ubst~ntially the following questione: 1. If a county commissioner engages in ex parte communication regarding a rezoning. must he or she abstain fro~ participating ~n the rezoning proceeding and/or disclose the communication on t.he record? 2" Is viewing the property for which rezoning has been requested an eX parte communication? 3. Maya board of county commissioners review a request to rezone county-owned property in order to bring the property into compliance with the county's comprehensive plan. without violating a legal or echical constraint? 4" If so, are conferences with planning and zoning staff outside the review proceeding considered ex parte communicat~on.? 5" Are conferenc~s wit.h staff of the city department initiating the rezoning request considered ex parte communicat.ions? 6. Does consideration of a county-initiated rezoning request for county-owned property create a conflict of interest under section 112.3143, Florida Statutes? LA OPINIONS DIV. TEL:904-922-3969 Oct 19.94 t:$:":J~ ~U.UV1 I........, 94- 71 The Honorable Truman G. scarborOugh. Jr. ._g. TwO In 8UII\ t 1. Proof of an ex parte communication cre.te. a re~utt.ble pre.umption that a decision 1a prejudiced" However, nothing require8 _ county commi..ioner who ha. engaged in an ex parte communication to abstain from voting on a request for rezoning or to disclos. such communication on the record. 2. Vi.wing the subject property would not be ex parte communication, if there 1s no communication between one of the parties anq the county commissioner. . 3. A county commission is not precluded from reviewing rezoning requests for county-owned property in order to bring euch property intO compliance with the county's . comprehenslveplan. Such determinations with findings of fact and a record of the proceedings, however. would be subject to judicial review. 4. While discussions between the county commission and t~e planning and zoning staff would not automatically mandate reversal of the commission'S rezoning decision. any allegation of prejudice resulting from ex parte . communications in a quasi-judicial proceeding would be groundS for judicial review. In order to assure fairness to all parties. any communicatiOD with the planning and zoning staff ahould be docUlllented and placed oD the record in order for all partie. to have an opportunity to respond. 5. In light of the involvement of staff me~rs of a department .requesting a zoning change in the proceedings. contact with the staff outside the quasi- judicial proceeding could result in an allegation of . ex parte communication. Such communication, therefore. .hould. be d.ieclo.ed to all interested parties and . placed on the record during the proceeding to allow such parties to x:.espond. 6. The de~er1l\ination of whether consideration of a county-initiated rezoning request for county-owned property would constitute a conflict of intereat in violation of section 112.3143, Florida Sta~utes. is ~ithin the jurisdiction of the Florida commission on ..d. TEL:904-922-39&9 Oct 19.94 8:~j NO.UUl r.v" _A OPINIONS DIV. The Honorable Truman G. Scarborough, Jr. page Three 94-71 Eth~c.. It would appear. however, that the prohibition 1n section 112.3143, Florida Statut.., relat.. to thoa.' inetance. where the vote of a public officer would r..ult in a. -special private gain- to .uch officer and would not prohibit the consideration of rezoning county-owned property. QUAA~i..nn nn.e In light of the decisions nadl!!! C^unt:.y' and a , the que.tion has arisen whether a county commissioner who participates in ex parte communication regarding the rezoning of property must recuse himself from voting on the issue or make the ex parte communication known on che record. In ~enn1n9., the Third pi.trict Court of Appeal decermined that proof of an ex parte communication by a quasi-judicial officer"create. a rebuttable presumption of prejudice unless proven otherwise by competent evidence by the officer. Subeequently, the Fifth District Court of Appeal. in s~yder. determined that considera- tion of a rezoning request is quasi-judicial in nature and require. appropriate due procesa to the party reque.ting the rezoning.' Taken together, these cases en sur. that the landowner will receive due. process in a proceeding for the rezoning of private property.- In J_nn1ngs, the court considered the effect of an ex parte communication upon a decision by a county commiesion in a qua8i- judicial proceeding upholding the granting of a zoning variance. It was alleged that prior to the commission'S action, a lobbyist for the peti~ioning party, registered a. required by a county ordinance, engaged in ex parte communications with .orne or all of the county commi8sioners. In rejecting the county's conten- tion that an ex parte communication doe. not deny due process where the substance of ~he communication wae di.coverable by the complaining party in time to rebut it on. the record. the court concluded that.~he allegation of prejudice resulting from' ex parte con~act with the decision-makers in a quasi-judicial proceeding state. a cause of action. The court stated that upon proof that an ex parte communication has occurred, there is a presumption of prejudice. The burden is then placed upon the party ~ho initiated ~he ex parte communica- tion to show that no prejudice resulted from the contact.- Thus, the county commission should adhere to procedures tha~ guarantee a -fair. open and impartial hearing.- I 1 \ .R OPINIONS OIV. TEL:904-922-3969 Oct 19.94 tj:::>,) NO.VVl r ...,oJ 94-71 The Hono~able Truman G. scarborough, Jr. Page Four 1 am not aware of, nor have you dlr~cted my attention to. any statutory provision that requires a co~i8.ion meeber to recu.. himaelf or berself from .. proceeding in which the member has engaged in ex parte coftllllunications. While there is no statute that direct8 -a commie.ion ~mber to di8close an e~ part~com- municatlon, it would be advisable to place the e~istence'.nd content of such communication on the record. and to allow the aggrieved party the opportunity for rebuttal.' such measure. would appear to provide due process protection for any party who bas been presumptivelY prejudiced by the ex parte communication. Inherent in the prohibition against -ex parte- communlcation i_ communication between the decision-maker in a judicial or qua.i~judicial proceeding and one of the parties in tbe prO- cee~ng.'While the independent viewing of subject property by a commissioner may be outside tbe quasi-judicial proceeding, it doe8 not appear that such action would constitute an ex parte communication tbat would create a presumption of prejudice. {)tIes!":" t)ft Two The county commis.ion is the body posse..ing the authority to review the rezoning of property within the county." AnY zoning or rezoning by the county commi..ion, however, must conform witb tbe county's c~prehen.ive plan.' This would appear to have equal. application to county-owned property.' Thus. the county commission would be bound to review the request for rezoning of its own property in order to bring sucb property intO compliance with the county'. comprehensive plan. While generally a governmental unit'. proper~y i. no~ subject to ite own zoning regulations when the governmental unit 1s acting in a goVerntnental capaci~y," i~ has been rec09t\izec1 1Jy the S\lpreme Court of Florida that zoning variations to accommodate county or municipal facility purpo8e~ should either bave been anticipated in zoning ordinances before construction or operation of such facilities i. commenced or, if this has not been done, construct iQn should not be under- taken thereof until after due modification or change therefor is made in existing zoning ordinances." Accordingly, it would appear that the county commission would properlY review a request for the rezoning of county-owned property in order to bring it into compliance with the county'. comprehensive plan. cn.t~At: i 01'\ Thre..& . ~ - . , ,"... .~.- .-_."- .. - ,. . LA OPINIONS DIV. TEL:904-922-39&9 Oct 19.94 8:54 NO.UUl r.vU - 94-11 The Honorable Truman G. scarborough, Jr- .ag- rive A8 reflecte4 in the court'. discussion in ~"ningA, -(elx parte communication. are inherently improper and are anathema to quaei- judicial proceeding.. ,u Tbe ~..i "a. cour< fur<ber ..a<.d <lla< _tq)ua.i-1udicial officers should avoid all sucb contacts wbere tbey are Identifiable _.11 While discussions witb the planning and zoning etaff would not automatically mandate reversal of a county commission'. rezoning decision. any allegation of prejudice resulting from ex'parte communications in ~be ~asi-judicial proceeding would state a cau.e of action for ju4icial review of tbe commission'. action. In order to assure fairnesS to all partie., any ex parte commu- nication witb tbe planning and zoning staff should be documented and placed on <be record in order for all par<ie. <0 have an opportunity to respond. Q1)~.t': "-^ft ~o~ Oiven tbat tbe staff members of a county department requesting a zoning cbange for county-owned property w~uld most likely be advocates for tbe requested change, contact witb tbe staff outside. the quasi-judicial proceeding could be considered ex part. communica<ion. TOe 30"01.a. cour< .e< for<b <be following criteria that should be considered in determining whether such communication is prejudicial: (w)betber, a8 a result of improper ex parte communications, the agency'. decisionmaking process was irrevocably tainted 80 a8 to make tbe ultimate j~dgment of the agency unfair, eitber as to an innocent party or to tbe public intereat tbat the agency was obliged to protect. In making this determination, a number of considerations may be relevants .the gravitY of the ex parte communications; whether the con~.ctS may have influenced the agency's ultimate decision' whether the party malting the improper contacts benefited from tbe agency's ultimate decision, whether the contents of the co~nication. were unknown to opposing parties, who tberefore had no opportunity to respond; and whether vacation of tbe agenCY's decision and remand for new proceedings would serve a useful purpoee. Since the principal concerns of the court are the integrity of the process and the fairneSS of the result, mechanical rules have little nt,~.t: inn Vi v..a i I I I I ! ! I I I LA OPINIONS DIV. TEL:904-922-3969 Oct 19.94 8:54 No.OOl P.07 The Honorable Truman o. ScarbOrough, Jr. page Six 94-71 place in a judicial decision whether to vacat. a voidable agency proceeding. Instead, ~y luch decision must of necessitY be an exercise of equitable diecre- tion." Accordingly, should communication occur between the county commission and staff of a county department requesting · rezoning of county property, such communication should be disclosed to all interested partie. and placed on the record during the proceeding to allow the parties to respond. . ~teg~4nn ~ix The determination of whether consideration of a rezoning request for county-owned property would constitute a conflict of inter.st in violation of 8ectiO~ 112.3143, Florida Statutes, ia within the jurisdiction of the Florida commission on Ethics.1' It would appear, however, that the prohibition in section 112.3143, Florida Statutes, relates to those instances where the vote of a public officer would result in a -special private gain- to such officer. It would appear, therefore, that absent an allegation or showing of private gain. to ~ county commiesioner.s a result of voting for the rezoning of county-owned property for the purpoae of bringing it into compliance with the county's .. c ve plan, there would be no conflict of interest pursuant to ction 112.3143, Florida Statutes. J aob.rt ~. ~ttorn.Y ~/tgk I Butterworth General ---------------_.--~-~------------------------------------------- 1 58' So. 2d 1337 (Fl.. 3d DCA 1991) . 595 So. 2d 65 (Fla. 5th DCA 19'1). a J Saa, ~enninQ. at 1343, acknowledging that the granting of zoning variances and special exceptions or permits i8 a quaei- judicia1 action, citing w~19reen Co v. pn'k Cnnnty, 524 So. 24 1119, 1120 (Fla. 2d DCA 1988). . Jenninq- at 1345. .A OPINIONS DIV. TEL:904-922-39G9 Oct 19.94 8:54 No.OOl P.OS The Honorable Tr\lman G. scarborough, Jr. Page Seven 91-71 , ct...., eection 120.66(2), Fla. St.at. (Un). . BAA, Black's LaW Dictionary (5th ed. 1979), p. 517, defining -[o)x parteW a. -[al judicial proceeding, order, injunction, etC., . . . when it is taken or granted at the instanCe and for the benefit of one party only, and without notice to, or contestation by, any person adversely int.erested.w ~ &cA. section 125.01(1) (h), F.S. (1993). authorizing counties to -[elstablish, coordinate, and enforce zonfng and such bu.i- ne.. regulations as are necessary for the protection of the public. - .. . BAa. section 163.3201, F.S. (1993). stating that t.he adopted comprehensive plans .hall be implemented, in part. by the adoption of and enforcement of appropriate local regulations. R~A a1AO, Op. Att'Y Gen. Fla. 79-88 (1979). in which th1e office concluded that all development undertaken after the adoption of a comprehensive plan must be in accordance with that plan; local governments should amend exieting zoning ordinancee to conform with the land-use' element. of such a co~prehen.ive plan; and Op. Att'y Gen. Fla. 79-40 (1979) (county adopting comprehensive plan mu.t adopt zoning, eubdivlsion planning. or other code. or regu- lations consiatent with such plan). . sac. Whit~ v. MetropolitAn Dad~ County, 563 So. 2d 117. 128 (Fla. 3d DCA 1990). in which the district court recognizee that the uee of county-owned property must comply with the master plan. its elements. and objectives) . " orange County v City of ~opka. 299 So. 2d 652, 654 (Fla. 4th ~ 19"") . II pAr~way Tower- ~pndnm;nitlm A99o~ia~inn v. Metrnpn\i~an n.de r...un~y. 295 So. 2d 295. 295-296 (Fla. 197.). d ,T...nninas at 1341. .' u .l4... ,. 685 F. 2d 5.7, 564-565 (D.C. ,. SAA, section 11.2.320. F.S. (19'3). creating the Commis8ion on Ethic8 a8 the guardian of the seandards of conduct for the off~cers and employees of the staee, and of a county. city. or other polieical subdivision of the seate. " ,\ I 1"'1.'. "192 MIMQIlANO\JM '0 Honorable Natacha S. Killan County Commml881oner OAfl, Karch 29, 1994 M/IC" Nev8paper Art.lcles Pertaining to Quasi- Judicial Hearings Robert L. ~rawch.ck Assist.ant County Attorney 'tOM, You have asked us to advise what a county commi8sioner should do when he or she has read one or more newspaper articl.s pertaining to an upcoming quasi-judiiial hearing. Your concern arises trom the rule in the Jennings case which prohibits ex-parte communications in quasi-judicial hearings. .;r~nninas held tha~ "ex-parte couunica~ions are inheren~ly improper and are anathema to quasi-judicial proceedings [and that} quasi-judicial officers should avoid all such contacts vhere they are identifiable." The court, however, "recognize[d) the reality that commlssipners are elected ofticia18 in which capacity they may ~navoidablY be the recipient. of unsolicited ex-parte communications regarding quasi-judicial matters they are to decide." Nevertheless, the ruling was that "(u)pon the aggrieved party's proof that an ex-parte contact occurred, its effect is presumed to be prejudicialaunles8 the defendant proves the contrary by competent evidence.1f While Jenninq. addressed solely due process rights, First Amendment rights, particularly freedom of the press, are of equally high priority. The reading of nevspaper articles may be the very kind of occurrence recognized by the court's reference to cert.ain unavoidable communications. eecause a nevspaper article, even though unsolicited, could fora the basis of a Jenninas-type lawsuit, ve suggest the fOllowing procedure. - - .- l~ennings v. Dade County, 589 50.2d 1337 (Fla.3d DCA 1991), on rehearing. a~ at 1347. All emphasis is supplied. Hon. Natacha s. Kill~., .County COmDlssloners Page No. 2 Karch 29, 1994 \' . . It a commissioner is in tact prejudiced by reading the article so that he or she cannot make an impartial decision based solely upon the record, the commissioner should not participate in the proceeding. If the commissioner Is not so prejudiced, the commissioner should attend the meeting, report the tact of the ex-parte communication on the record, and state that he or she can make an impartial decision based solely upon the evidence to be presented. As with other kinds at written ex-parte communications, we suggest that newspaper articles be placed into the record and that all parties be given an opportunity to address the material by way ot evidence and oral argument. Although there is no assurance that a hearing will not be subject to reversal by the courts, we believe that this procedure offers the best chance to negate any potential prejudice and minimizes the risk of a reversal by the courts. Pleas. advise if we can be of further assistance. ~~.-A'~ fi, art . Kra check Assistant County Attorney aLl<\eka cc: County co~ission -'- .....