LTC 069-2024 TOWN OF BAY HARBOR ISLANDS RESOLUTION 2364M IA M I BEACH
OFFICE OF THE CITY CLERK
No.
069-2024 LETTER TO COMMISSION
TO:
FROM:
DATE:
SUBJECT:
Mayor Steven Meiner and Membersi?f the Cit Commission
Rafael E. Granado, City Clerk 1
February 26, 2024 /
TOWN OF BAY HARBOR ISLANDS RESOLUTION 2364
Attached for your information is Resolution No. 2364, adopted by the Mayor and the Town
Council of the Town of Bay Harbor Islands on February 21, 2024.
A RESO LUTION OF THE TOW N OF BAY HARBOR ISLANDS, FLORIDA,
AUTHO RIZING PARTICIPATIO N IN LITIGATIO N SEEKING A
DECLARATION THAT THE PROVISIO NS OF SECTIO N 112.144(1)(d),
FLORIDA STATUTES, THAT REQUIRE MUNICIPAL ELECTED
OFFICIALS TO FILE FORM 6 FINANCIAL DISCLOSURE FORMS IS
UNCO NSTITUTIO NAL AND INVALID; PROVIDING FOR
INCO RPO RA TIO N OF RECITALS AND AN EFFECTIVE DATE.
The Town of Bay Harbor Islands Clerk has requested that a copy of this resolution be pro vided to
the Miami Beach Mayor and Commissioners.
If you have any questions, please contact the Office of the City Clerk at 305.673. 7 411.
REG/le
Attachment
F:\CLER\$ALL\LILIA\L TC's - Transmittal's\Bay Harbor\Resolution 2364 Town of Bay Harbor lslands.docx
R E S O L U T IO N N O . 2 3 6 4
A R E S O L U T IO N O F T H E T O W N O F B A Y H A R B O R IS L A N D S , F L O R ID A ,
A U T H O R IZ IN G P A R T IC I P A T IO N IN LI T IG A T IO N S E E K IN G A
D E C L A R A T IO N T H A T T H E P R O V IS IO N S O F S E C T IO N 1 1 2 .1 4 4 (1 ){d ),
F L O R I D A S T A T U T E S , T H A T R E Q U I R E M U N IC I P A L E L E C T E D
O F F IC IA L S T O F I L E F O R M 6 F IN A N C IA L D IS C L O S U R E F O R M S IS
U N C O N S T IT U T IO N A L A N D IN V A LI D ; P R O V ID IN G F O R
IN C O R P O R A T IO N O F R E C IT A L S A N D A N E F F E C T IV E D A T E .
W H E R E A S , since 1976, Article II, Section 8 of the Florida Constitution has
required that all elected State constitutional officers file a full and public disclosure of their
financial interests, which is done through a state-adopted form ("Form 6") that requires,
among other things, the disclosure of the specific amounts of an official's net worth,
income and asset values; and
WHEREAS, historically, municipal elected officials have been required to make a
more limited financial disclosure that is done through a different state-adopted form
("Form 1") that requires, among other things, the disclosure of information related to
sources of income, real property, intangible personal property liabilities and interests in
specified businesses, but does not include the specific amounts of an official's net worth,
income and asset values; and
WHEREAS, the Mayor and all current elected members of The Town of Bay
Harbor Islands (the "Town Elected Officials") were elected by the voters of the Town
subject to and in reliance upon Florida law that required them to annually file Form 1 (not
Form 6) financial disclosures forms; and
W H E R E A S , although the State Legislature has the power in the Florida
Constitution to require that additional public officers file a full and public disclosure of their
financial interests, it must do so consistent with other constitutional limitations; and
WHEREAS, in 1980, the voters of Florida amended the Florida Constitution by
adopting Article 1, Section 23, the "Right to Privacy," which states that "[e]very natural
person has the right to be let alone and free from governmental intrusion into the person's
private life except as otherwise provided herein"; and
WHEREAS, because the right of privacy is a fundamental right within Florida's
constitution, the Florida Supreme Court has consistently required that any law intruding
on the right is presumptively unconstitutional and must be justified by a "compelling state
interest" which the law serves or protects through the "least restrictive means;" and
WHEREAS, the First Amendment to the United States Constitution, and Article 1,
Section 4 of the Florida Constitution, protects the freedom of speech, which includes the
right to choose what to say and what not to say, any impairment of which must be justified
by a "compelling state interest" which the law serves or protects through the "least
restrictive means;" and
WHEREAS, during the 2023 legislative session, Senate Bill 774 was passed and
codified at Law of Florida 2023-09, amending Fla. Stat. § 112.3144, to change the
financial disclosure requirements and now require that all elected municipal mayors and
elected members of the governing board file a Form 6 financial disclosure, which is
substantially more burdensome and personally intrusive than the Form 1; and\
W H E R E A S , the imposition of the Form 6 disclosure requirements at the municipal
level (a) represents an unwarranted intrusion into the privacy rights of municipal elected
officials, most of which receive little or no compensation for their service, (b)
unnecessarily risks the safety of such officials (making them targets of, among other
things, burglary, identity theft and extortion), and (c) will deter many otherwise qualified
and interested citizens from running for office; and
WHEREAS, in fact, over 100 municipal elected officials resigned from office prior
to December 31, 2023, as a result of the new disclosure requirements, disrupting the
ability of some local governments to operate for lack of a quorum; and
WHEREAS, the imposition of the intrusive Form 6 disclosure requirements at the
municipal level is not the least restrictive means of serving the governmental interests of
preventing abuse of the public trust, as demonstrated by, among other things, the lack of
such requirements at the municipal level in other states and at the federal level (even the
President of the United States and members of the U.S. Congress are not required to
make such extensive disclosures); and
WHEREAS, requiring that unpaid (or low paid) municipal elected officials disclose
their precise net worth, income and assets does not serve (let alone constitute the least
restrictive means of serving) any compelling interest - Form 1 disclosures constitutes
sufficient transparency to inform the public of potential conflicts; and
W H E R E A S , the imposition of new financial disclosure requirements upon
municipal elected officials who were elected without such requirements violates due
process, is fundamentally unfair and violates fundamental constitutional rights; and
WHEREAS, a group of municipalities and municipal elected officials filed two
lawsuits, one in State Court and one in Federal Court, on February 15, 2024, seeking a
declaration that the provisions of Section 112.3144(1)(d), Florida Statutes, that require
municipal elected officials to file Form 6 financial disclosure forms are unconstitutional
and invalid and should be enjoined (the "Lawsuits"); and
WHEREAS, the Town of Bay Harbor Islands believes it is in the best interest of
the citizens and residents of the Town to participate in the Lawsuits and urges other
municipalities and their elected officials to also participate as plaintiffs.
NOW, THEREFORE, BE IT RESOLVED BY THE TOWN COUNCIL OF THE TOWN OF
BAY HARBOR ISLANDS, FLORIDA AS FOLLOWS:
Section 1: That the foregoing "WHEREAS" clauses are ratified and confirmed
as being true and correct and are made a specific part of this Resolution.
Section 2: The Town of Bay Harbor Islands hereby authorizes the participation
of the Town, and any individual Member of the Town Council, who chooses to participate
as plaintiffs, in the Lawsuit.
S e c tio n 3 : Weiss Serota Helfman Cole + Bierman, PL (the "Firm") is hereby
retained to represent the Town in the Lawsuits. The Firm will charge the Town a flat fee,
inclusive of attorneys' fees and costs, of $10,000 to represent the Town and the individual
elected officials who chooses to participate as plaintiffs for the Lawsuits in the trial court.
The Town and elected officials recognize that such flat fee may be less than the actual
attorneys' fees and costs incurred, and that if the Town and elected officials prevail in the
Lawsuits, the Firm may apply with the Court for its actual reasonable attorneys' and costs
from the defendants. The filing of any appeals will be authorized by separate resolution
under the terms thereof. The Town and its elected officials also acknowledges that the
Firm will be representing other local governments and officials in this lawsuit and waives
any conflicts related to such representation. The Town further acknowledges that, from
time to time, the Firm may be called upon by client to represent them as to requests for
various approvals and as to other matters with respect to or involving the Town. The
Town hereby waives any potential conflict of interest in the Firm's representation of those
clients arising from its representation of the Town in the Lawsuit.
Section 4: The Town of Bay Harbor Islands invites and urges other local
governments and elected officials to join the Town as plaintiffs in the Lawsuit and to
coordinate their efforts with the Town.
Section 5: The Town Clerk is directed to distribute this Resolution to all local
governments in Miami-Dade County.
S e c t io n 6 : That the appropriate Town Officials are hereby authorized to do all
things necessary and expedient to carry out the aims of this Resolution.
Section 7: That this Resolution shall take effect immediately upon adoption.
PASSED AND ADOPTED this 21 d ay of February, 2024.