2017, 10-31 Study Session M1NlJTFS
SPOKANE VALLEY COUNCIL MEETl (i
STUDY SESSION
Spokane Valley City Hall Council Chambers
Spokane Valley,Washington
October 31, 2017
Attendance:
Councilmembcrs Staff
Rod Higgins, Mayor Mark Calhoun, City Manager
Arne Woodard,Deputy Mayor John Hohman, Deputy City Manager
Caleb Collier, Counci]rncnaber Cary Driskell, City Attorney
Pam I laley,Councilmember Mike Stone, Parks & Recreation Director
Mike Munch, Councilmember Chelsie Taylor,Finance Director
Ed Pace, Councilmember Erik Lamb, Deputy City Attorney
Sam Wood, Councilmember Ryan Kipp,Traffic Engineer
Ray Wright, Senior Tntl]lic Engineer
Carolbelle Branch_ Public Information Officer
Christine Bainbridge, City Clerk
Mayor Higgins called the meeting to order at 6:00 p.m.
ROLL CALL: City Clerk Bainbridge called the roll, all Coruicilmernl ers were present
ACTION"ION ITEM:
1. Second Reading Proposed Ord nanee 17-011, Property Tax ChuLsie Taylor
After C ity Clerk Bainbridge read the ordinance title, it was moved by fepuiy Mayor Woodard andseconded
to approve Ordinance 417-011 levying regular property taxes for 2018.After Finance Director'layTaylor went
over the background of levying regular property taxes, and that this ordinance, as in several prior years,
does not increase the property taxes by 1% as permitted by law; Mayor I iiggins invited public comment
Mr. Tony La7..anis said the thinks we have enough taxes and he hopes Council says no to this. There were
no other public comments,and Counci I member Pace explained that a yes vote on this ordinance means not
increasing taxes, and said he is happy to vote yes. Vote by Acclwnation; In Favor.' Unanimous. Oppose •
None_ Motion carried
NON-ACTION ITEMS:
2. Legislative Agenda Update— Mark Calhoun,Cary Driskell__Erik Lamb
City Manager Calhoun :said drat this topic has been heard twice previously; and at an earlier October
meeting,there was Council consensus to add two additional items and to bring that redraft back to Council
for continued review and discussion.He said one item was to support the continued prohibition of marijuana
home-growing and retention of local authority, and the second itein was to protect parental rights regarding
decisions regarding their children. Mr. Calhoun said that our legal staff has drafted the language on those
two issues, which was reviewed by our lobbyists at Gordon Thomas Honeywell, and then reviewed by the
local delegation;and he explained that tonight's draft legislative agenda is an amalgamation of those of oits.
Concerning added item to "Suppoit Continued Prohibition of Recreational Marijuana I Tome Growing,"
Deputy City Attorney Lamb mentioned that he did not include language about having the power to prohibit
as when he discussed this item with our legislators, they felt it weakened our argument, Councilmember
Munch mentioned about us not getting the funding we were supposed to get and that we wanted to fix that
bctorc moving to home growing, and Mr. Lamb said he included those issues in our comments to the slate,
and the legislators seemed to convey a very precise argument.
Council Sturdy Session_ 10-3]-X117 Page I 4)13
Approycd by Cwineil; 11-H-2017
City Attorney Driskcll read the added item concerning "Protecting Parental Rights Regarding Decisions
Involving their Children,"and said he received another letter from the Center for Justice,which Mr.Driskcll
distributed to Couneilnietrlbers; and said that if we were to look forward to having an ordinance,that would
potentially violate state law. Mr. Driskell said Council has every right, however, to include this on their
legislative agenda, which is currently scheduled to come before Council for a motion at the November 14
meeting. Councilmember 1 taley asked how much money has been spent so far researching this, and Mr.
Driskell said that he spent about twenty-one and a half hours, and Mr, J.amb spent about six and a half
hours,so an estimate would he$2400. There was Council consensus to move this forward to the November
14 Council agenda far a motion consideration, Mr. Calhoun added that he will also be setting up a meeting
with the local legislators for some time in December.
3. 8°`and McDonald Update Ryan.Kipp,John l lohman
Mr. Holtman explained that we wanted to look at this problem intersection °nee niore and review what
chaugcs have occurred; said that since our last discussion of this topic, there have been no serious crashes
there that would generate a police call and/or police report; and added that tonight staff will discuss speed
limits. Mr. Kipp went through the PowerPoint explaining staff's recommended action plan; i.e. to reduce
the speed limit to 30 miles-per-hour on 8th between Pines and Sullivan; said we will continue monitoring
the intersection; he went over the speed limit process, including that section of the City's Code as well as
[he slue statutes and administrative policies and the MU7'CD(Manual on Uniform Traffic Control Devices)
guidelines,and roadway characteristics. 'There was discussion about the different speed limits on different
parts of 8" and that it is confusing to citizens; the idea of making the entire road 25 mph; comments about
what the neighbors would support, and finally comment from Mr, l lohman that we must follow guidelines
for setting speed limits, and cannot set limits based on citizen preference, as we need to aim for falling
within five miles of that 85'1'percentile. Councilniember Pace said he would still like a community meeting
with traffic, police and residents on that strec t as well as intersecting streets. Councilmember Wood
questioned the street classification, and Mr. Hohman said that would be a separate topic of discussion as
we are not proposing any change to road classification.There was Council consensus to move forward with
the 30 miles-per-hour and to bring forward a resolution amending the master speed limit schedule to reflect
that change. It was mentioned that resolution is scheduled for the November 14th Council meeting.
4. HAWK Signal Use Instructional Video—Ryan Kipp, John Hohman
Deputy City Manager. Hohman said this instructional video is a cooperative effort with us and the Library
to inform members of the public about the HAWK signal,as there have been concerns about this signal and
how it works. Mr. Kipp noted there was no charge for putting this video together,and he extended thanks
to members of the Library District,and to our Public information Officer Ms.Branch for their part in putting
this video together. After the video was played, Mr. Hohman said it is our intention to have this on our
website and to direct people to t if they have questions about the operation of the signal, Councilmember-
Collier asked if we have any data on auto versus pedestrian, and Mr. K ipp said he would have to research
that.
5, Spokane Valley Official Newspaper—Chris Bainbridge, Cary Driskell
After City Attorney Driskell and City Clerk Bainbridge went over the history and information concerning
the City's official newspaper, alter which there was Council consensus to stay with the status quo and not
make any changes.
fo_ Advance Agenda —Mayor I lions
Couneilmennber Munch said he realizes there is not much we can do about protestor conditions, and he
suggested removing that from the pending list on the Advance Agenda. Council agreed. Councilmember
Pace asked for an analysis of 4th Avenue to include hearing from fire, police and our traffic engineer, and
to have that same request for 8th Avenue, and to also have meetings with residents and neighbors,
Council Study Session° 10-31-2017 Page 2 of 3
Approved by Council: 11-14-2017
7. Information Only
The (a)Ele'lion bright Council Meetings was briefly mentioned during the City Manager Comments; and
the (4) Department Quarterly Reports were f-or information only and were not reported or discussed.
$. Council Check-in Mayor Higgins
Deputy Mayor Woodard presented Mayor I liggins with a vest for further protection of the Mayor.
9. City Manager Comments—Mark Calhoun
City Manager Calhoun mentioned the Election Night CouncillMieeting..s memo in the Information Only
section of tonight's agenda; said next Tuesday is an election day and the Council meeting for that night has
been cancelled; he said we met East year on election tright and it stirred some controversy among some
people_ Mr_ Calhoun said the memo sets out the Council meeting history on election nights, and when
election nights are held in odd years, Council has never met; but when election nights are held in even
years, Council has met, even during presidential elections, He noted this will be brought up annually.
It was moved by Deputy Mayor Woodard, seconded(end unanimously agreed to adjourn, The meeting
adjourned at 6:51 p.m.
1
•f_ err
.
ATTE'T` I R ig `
•
Christine Bainbridge, City Clerk
1
Council Study Session: 10-31.2017 Page 3 of 3
Approved by Council: 11-14-2017
Cary Driskell
From: Rick Eichstaedt <ricke@cforjustice.org>
Sent: Tuesday, October 31, 2017 4:33 PM
To: mayor/councilrnembers
Cc: Cary Driskell
Subject: Follow to Letter from CenterforJustice re "Parental Rights" Ordinance
Attachments: Re Recall of Pepper_pdf: Follow-up to Letter re Parental Rights Ordrnance_pdf
Please find attached a follow-up (and attachment) to the letter sent by the Center for Justice
last week regarding the "'parental rights"' ordinance.
Rick Eichstaedt
Attorney
35 West Main, Suite 300
Spokane, Washington 99201
Phone: (509) 835-5211
Fax; (509) 835-3867
This e-mail message is intended only for named recipient, It contains information that may be confidential, privileged,
attorney work product, or otherwise exempt from disclosure under applicable law. If you have received this message in
error, are not a named recipient, or are not the employee or agent responsible for delivering this message to a named
recipient, be advised that any review, disclosure, use, dissemination, distribution, or reproduction of this message or its
contents is strictly prohibited. Please notify us immediately that you have received this message in error, and delete the
message, Thank you.
1 hi nk li?fo re you prink.
1
CENTER TOR JUSTICE
EmrowERLNGPEOPLE&COh4 uN1LIES
October 31, 2017
Spokane Valley City C(auncil
11.707 E. Sprague Av, Ste 106
Spokane Valley, WA 99206
RE: Additional Information regarding Proposed "Parental Rights" Ordinance
Dear Council Members:
This letter is a follow-up to the letter sent last week regarding the proposed "Parental Rights"
Ordinance.
I am attaching a copy of a Washington Supreme Court decided on October 26 that found that the
failure of a City of Black Diamond Council member to heed advice of the city attorney was grounds
for recall,
Thank you for consideration of this letter.
Sincerely,
CENTER FOR JUSTICE
Rick Eichstaedt
Executive Director/Senior Attorney
Cc: Spokane Valley City Attorney
35 W NIA IN, Snj BOO • SPOli:AN3 , wA 00201 . 509,835,52. I - wwW.CFORJUSII<-'r.<rx.c
/if-1-CE\ This opinion was Med far record
IN CLERKS OFFICE
SOPKEIE Cir STATE OFyLAEINIRE at , L rr"1onakbeji, f i 7
014,44A4 C9 4111 IAAAArri „
cHtEFAtrace .."� SUSAN L.' RRLN
SUI
IN THE UPI ME COURT OF THE TATE
SUPREME �� �
NO. 94574-8 RE THE MATTER OF RECALL
CHARGES AGAINST CITY OF BLACK
DIAMOND COUNCIL MEMBER B1C
PATRICIA PEPPER
Filed OCT 2 5 2017
GORDONMcCLO , J.—Robbin. Taylor filed a statement of charges
seeking recall of Black Diamond City council member Patricia Pepper, The superior
court ruled that four of those charges were factually and legally sufficient to support
a recall petition. Pepper appeals. We affirm the trial court's decision with regard to
the first thj.•co charges, but reverse with regard to the fourth charge.
FACTS
In. November r 2015, Pepper defeated opponent Ron Taylor husband of
Robbin Taylor) in an election for Black Diamond City Council in King County.
Clerk's Papers P) at.273, Black Diamond is anon-charter--code city with a mayor-
city council form of government. CP at 287-88. The current mayor is Carol Benson.
CP at 140. There are five seats on the city council, held by Pepper, Erika Morgan,
Brian Weber, Tamie Deady, and Janie Edelman. Id, Pepper "ran on a platform of
In re ,Recall of Patricia Pepper,No. 94574-8
change consistent with two other council inembers and opposed the two other
council members who campaigned for the 'status quo'." CP at 271.
Beginning in January 2016, a chasm developed with Mayor Benson and
council members Deady and Edelman on one side, and a majority of the city
council—Pepper, Morgan, and Weber—on the other. See CP at 128. Disputes
occurred, primarily regarding proposed changes to the council rules of procedure set
forth in Council Resolution 16-1069 (R-1069), which were supported by Pepper,
Morgan, and Weber. Id. Pepper, Morgan, and Weber tended to vote as a block. CP
at 271, Specific disputes included whether the mayor or the council had the authority
to hire and fire the city attorney, CP at 103; whether the council was approving
minutes for council meetings, CP at 18.; who had the right to control city council
meetings and agendas, CP at 16; whether the council had the ability to modify or
breach city contracts entered into by former council members,ers, CP at 19; and whether
council members could miss meetings without consequences, among other issues,
CP at 17. Several council conflicts revolved around "Master Development Review
Team" " IDRT contracts for two large development projects planned in Black
Diamond that had been approved by Mayor Benson and former council members.
CP at 14, 113-19.
The bulk of the conflicts arose as follows: Pepper, Morgan, and Weber voted
to enact 8-1069. CP at 51. R-1069 provided several amendments to the council
2
In re Recall of Patricia Pepper, No, 94574-s
rules of procedure. CP at 52-81, Mayor Benson and council members Deady and
Edelman opposed the changes to the rules. See CP at 51, 128. Under the advice of.
then city attorney Carol Morris, Mayor Benson refused to enforce R-1069. CP at
128,
After Pepper, Morgan, and Weber passed R-1069, they voted to fire attorney
Morris. See CP at 128-29. Mayor Benson hired emergency interim city attorney
Yvonne Ward, See CP at 129. Ward submitted two memoranda to the council,
concluding that R-1069 violated the Black Diamond Municipal Code (BDMC and
the Open Public Meetings Act (OPMA), chapter 42.30 RCW, CP at 121-38. The
council had also received advice from prior city attorney Morris and from the city's
risk management pool that the resolution could create liability for the city if council
members violated the OPMA. CP at 37, 45-47, 155-56, The concern centered on
the provisions in R-1069 that mandated a minimum of three council members (a
majority of the council) for each standing committee, rather than two, CP at 122-
25. Pepper had also received legal advice from an outside law firm indicating that
these committees could trigger OPMA requirements, given that a majority of the
council would be attending those committee meetings. CP at 100.
Upon passing R-1069, Pepper and a majority of the council made decisions to
alter contracts regarding the MDRT, CP at 236-37. Ultimately, the council's
decision to enact R-1069 and revisit the MDRT contracts, among other actions, led
3
In re Recall of Patricia Pepper, No. 94574-8
to a lawsuit: M► T contractor CCD Black Diamond Partners LLC (Oakpointe) filed
suit against the city and council members Pepper, Morgan, and Weber. CP at 158-
89. The suit alleged violations of the OPMA, which has led to litigation and costs
for the city; the case is ongoing. Id.; Verbatim Record of Proceedings (May JO,
2017) (VRP) at 57.
During this time, Pepper was a member of council standing committees, CP
at 15-16. Allegations were made that Pepper, Morgan, and Weber held secret
council and standing committee meetings conducting city business in violation of
the OPMA, CP at 12-16.
PROCEDURAL HISTORY
On April 7, 2017, after approximately a year and a half of tensions, Robbin
Taylor filed a statement of charges with the King County Elections Division,
requesting Pepper's recall, CP at 7-22. On April 25, 2017, the King County
prosecutor's office initiated this case pursuant to RCW 29A.5 ,1.30 and prepared the
following ballot synopsis:
1. Pepper, as part of a council majority, violated the Washington. State
Open Public Meetings Act, chapter 42.30 RCW, by convening and
conducting closed meetings without public notice and by entering
into private agreements to prepare and approve legislation.
2. Pepper, as part of a council majority, hindered the city's ability to
receive legal advice by hiring and firing city attorneys.
4
In re Recall of Patricia Pepper, No. 94574-8
3. Pepper, as part of a council majority, refused to attend council
meetings and failed to approve minutes and enact necessary
legislation related to vacancies and comprehensive planning.
4, Pepper, as part of a council majority, failed to enact a 2017 budget
in violation of state law and instead enacted a temporary budget
containing illegal provisions, impairing the city's ability to provide
essential services.
5. Pepper conspired with two other council members to change Master
Development Review Team contracts resulting in threatened legal
action against the city, forcing the city into arbitration.
CP at 1-5.
On May 10, 2017, a hearing was held in King County Superior Court to
determine the legal and factual sufficiency of the recall charges and the adequacy of
the ballot synopsis. CP at 372-73. Robbin Taylor was represented by counsel,
Pepper proceeded pro se, and the prosecutor provided input regarding the ballot
synopsis language. Id, The court found the second allegation and a portionof the
third allegation (that Pepper "failed to enact necessary legislation related to
vacancies or comprehensive planning") legally and factually insufficient. Id But
the court ruled the remainder of the allegations in the ballot synopsis were factually
and legally sufficient. Id, Accordingly, the court modified the ballot synopsis
language as follows:
1. Pepper, as part of a council majority, violated the Washington State
Open Public Meetings Act, chapter 42.30 R W, by convening and
conducting closed meetings without public notice and by entering
into private agreements to prepare and approve legislation.
5
In re Recall of Patricia Pepper, No. 94574-5
2. Pepper, as part of a council majority, refused to attend council
meetings and failed to approve minutes,
3. Pepper, as part of a council majority, failed to enact a 2017 budget
in violation of state law and instead enacted a temporary budget
containing illegal provisions, impairing the city's ability to provide
essential services,
4. Pepper, as part of a council majority, improperly voted to change
Master Development Review Team contracts resulting in threatened
legal action against the city.
CP at 3 75.
Pepper filed a nod cc of appeal. CP at 384. Robbin Taylor does not challenge
the trial court's findings of insufficiency, so only the four modified charges listed
above are at issue.
ANAIsSIS
i. Standard of Review
Article 1, section 33 of the Washington State Constitution provides citizens
with a substantive right to recall an elected official.' A recall petition must be both
Specifically:
Every elective public officer in the state of Washington expect [except]
judges of courts of record is subject to recall and discharge by the legal voters •
of the states or of the political subdivision of the state, from which he was
elected whenever a petition demanding his recall, reciting that such officer
has committed some act or acts of malfeasance or misfeasance while in
office, or who has violated his oath of office, stating the matters complained
of, signed by the percentages of the qualified electors thereof, hereinafter
provided, the percentage required to be computed from the total number of
votes cast for all candidates for his said office to which he was elected at the
preceding election, is filed with the officer with whom a petition for
6
In re Recall of Patricia Pepper',No. 94574-8
legally and factually sufficient. Chandler v. Otto, 103 Wn.2d 268, 274, 693 P.2d 71
(1984). Additionally, "Mlle charge, taken as a whole . , must he specific enough
to give the elected official meaningful notice of the particular conduct challenged
and why it is grounds for recall." In re Recall of Eoldt, 187 Wn,2d 542, 549, 386
P.3d 1104 (2017) (citing In re Recall of West, 155 Wn.2d 659, 667, 121 P.3d 1190
(2005) (citing In re Recall of Lee, 122 \ `n,2d. 613, 618, 859 P.2d 1244 (1993))).
Notably, in recall cases, c01_urt8 do not consider the truth of the charges, only the
sufficiency, RCW 29A.56,140; in re Recall of Lindquist, 172 Wn.2d 120, 131-32,
258 P.3c1 9 (2011); West, 155 Wn.2d at 662, As we have repeatedly stated, "It is the
{voters, not the courts, who will ultimately act as the fact finders." West, 155 Wn.2d
at 662 (citing RCW 29A,56.140; In re Recall of'Vast, 144 Wn.2d.807, 813, 31 P.3d
677 (2001)).
This court reviews the superior court decision in the recall action de novo, In
re Recall of Ward, 175 Wn.2d 429, 435, 282 P.3d 1093 (2012) (citing In re Recall
of T for-cl, 166 Wn.2c1 148, 154, 206 P.3d 1248 (2009)), but will "affirm the trial
court's factual conclusions so long as substantial evidence exists supporting the trial
nomination, or certificate for nomination, to such office must be filed under
the laws of this state, and the same officer shall call a special election as
provided by the general election laws of this state, and the result determined
as therein provided.
WASH. CONST. art, I, § 33.
in re Recall of Patricia Pepper,No. 94574-8
court's conclusions," In re Recall of Harrison, 144 Wn.2d 583, 587, 30 P.3d 474
(2001) (citing Miller v. City of Tacoma, 138 Wn.2d 318, 323, 979 P,2d 429 (1999)).
Importantly, recall statutes are construed in favor of the voter, and mere technical
violations will not block a petition. West, 155 Wn.2d at 663; .In re Recall of asham,
171 Wn.2d 503, 510, 257 P.3d 513 (2011). Voters should be left to "`draw
reasonable inferences from the facts; the fact that conclusions have been drawn by
the petitioner is not fatal to the sufficiency of the allegations.' Bolcit, 187 Wn2d. at
549 (quoting West, 155 Wn..2d at 665 (citing Chandler, 103 Wn.2d at 274)).
A. Legal Sufficiency
A recall petition is legally sufficient if it "'state[s] with specificity substantial
conduct clearly amounting to misfeasance, malfeasance or violation of the oath of
office' and there is no legal justification for the challenged conduct.2I (alteration
in original) (quoting Chandler, 103 Wn,2d at 274). The burden is on the petitioner
to identify the "'standard, law, or rule that would make the officer's conduct
wrongful, improper, or unlawful,"' In re Recall of Bolt, 177 Wn.2d 168, 181, 298
2 RCW 29A.56.110(1) defines "`misfeasance' and ""malfeasance"' as "any
wrongful conduct that affects, interrupts, or interferes with the performance of official
duty." Additionally, 'misfeasance"' also means "performance of a duty in an improper
manner," and "'malfeasance"' means "the commission of an unlawful act," RCW
29A.56.110(1.)(a)-(b). "'Violation of the oath of office' means `°ttxc neglect or knowing
failure by an elective public officer to perform faithfully a duty imposed by law," RCW
29A.56.110(2),
8
•
In re Recall of Patricia Pepper-, No. 94574-8
P,3d 710 (2013) (quoting In re Recall of Ackerson, 143 Wn,2d 366, 377, 20 P.3d
930 (2001)).
I. Factual Sufficiency
A recall petition must also be factually sufficient, A petition is factually
sufficient when the charges, taken as a whole, "'identify to the electors and to the
official being recalled acts or failure to act which without justification would
constitute a prima facie showing of rnisfeasaneo, malfeasance, or a violation of the
oath of office,' Ward, 175 Wn,2d at 435 (quoting Chandler, 103 Wn.2d at 274),
"in this context, 'prima facie' means that, accepting the allegations as true, the
charge on its face supports the conclusion that the official committed misfeasance,
malfeasance, or violation of the oath of office." In re Recall of Wade, 115 Wri.2d
544, 548, 799 13.2d 1179 (1990) (citing Teaford v, Howard, 104 Wn.2d 580, 586,
707 P.2d 1327 (1985)). Additionally, "[w1here commission of an unlawful act is
alleged, the petitioner must show facts indicating the official had knowledge of and
intent to commit an unlawful act." Boldt, 187 Wr .2d at 549 (citing Telfi rd, 166
Wn.2d at 158).
The individual making the charge must have knowledge of the alleged facts
on which the stated grounds for recall are based, RCW 9A.5 .11O; however, this
knowledge need not be firsthand, personal knowledge. In re Recall of Reed, 156
Wn.2d 53, 58, 124 P.3d 279 (2005) (citing Acicerson, 143 Wn.2d at 373; Lee, 122
9
In re Recall ol`Patricia Pepper, No, 94574-s
Wn,2ci at 617). But mere insinuations, speculation, or a belief that the charges are
trite, absent other evidence, is not enough. Chandler, 103 Wn.2d at 274; Reed, 156
Wn.2d at 58.
IL Charge 1: The violation of the OPMA charge is legally and factually
sufficient
Charge I states, "Pepper, as part of a council majority, violated the
Washington State Open Public Meetings Act, chapter 42.30 RCW, by convening
and conducting closed meetings without public notice and by entering into private
agreements to prepare and approve legislation." Cl' at 375.
This charge centers on alleged OPMA violations. As discussed above, Pepper,
as part of El majority of the council, voted to enact R-1069. That resolution contained
several amendments to the council rules of procedure, CP at 5181. Under the advice
of then city attorney Morris, the mayor reused to enforce R-1069. Subsequently, the
council majority, including Pepper, voted to fire Morris. See CP at 12.8- 9. The
mayor then hired emergency interim city attorney Yvonne Ward; Wardprovided
memoranda to the council, concluding that 8-1069 violated both the FJMC and the
OPMA. CP at 121-38. Morris and the city's risk management pool also advised the
council that the resolution could trigger OPMA liability. Cly at 37, 45-47, 155-56.
Their advice focused on the R-1069 provisions mandating a minimum of three
council members (a majority of the council) for each standing committee—instead
10
In re ]?i call of-Patricia.I'e p81., No. 94574-g
of the previous requirement of two. CP at 122-25. Pepper received similar legal
advice from an outside law firm. CP at 84-86.
The superior court found this charge legally and factually sufficient based on
(1) Ward's legal memoranda, (2) evidence that Pepper received legal advice
regarding the potential illegality of the conduct, and (3) evidence of OPMA
violations occurring after the legal advice was provided. VRP at 55-56.
Pepper, however, argues that
Mlle record is devoid of any evidence: 1 that Ms. Pepper attended
any non-public meeting at which a majority of Council members were
present, and/or (2) that Ms, Pepper knew her actions were contrary to
the OPMA, particularly where Ms. Pepper was acting in accordance
with legal advice given to the City concerning compliance with the
OPMA.
Br. of Appellant at 7.
We need not decide whether every single one of Robbin Taylor's factual
allegations suffices. Instead, the question is whether the charge as a whole should go
to the voters. And on this record, the answer is yes: key allegations supporting this
charge sufficed. We therefore agree with the trial court, CP at 381-82, that this
charge is legally and factually sufficient.
To be sure, Robbin Taylor relies largely on two legal memoranda (the Ward
memoranda, exs. 13, 14), and the allegations presented in these memoranda are
general,, the e-mails are not provided, and a referenced 40-page document is absent
from the record. 0? at 121-38. And while the recall petitioner need not always have
11
In re ,Recall o Parr{tcia Pepper, No. 94574-8
personal, firsthand knowledge of facts. alleged, there must be some basis for the
petitioner's belief that the allegations are true. See Lee, 122 n, d at 616-17,
In thiscase, however, these memoranda are not the only basis for the charge.
Robbin Taylor also provides other evidence, such as exhibit 3, CP at 29-31, This is
an c-mail that provides comments to proposed changes to the council rules of
procedure and asks, "[AIN we all still confirmed with resolve to knock [Edelman]
out of any chairmanship of any committee?" CP at 31 (formatting omitted), Robbin
Taylor also cites exhibit 8 in support of this charge. CP at 88. Exhibit 8 is an undated
document entitled "A Plan" that Pepper possessed during a council meeting. The
"Plan" contains a detailed list of action items to be accomplished with tasks assigned
to various people; it identifies Pepper, Morgan, and Weber by name; and it lists,
among other things, the "plan" to "Substitute the Agenda (On Pat's PC) Action:
Need agenda handouts."id. (formatting omitted). Robbin Taylor argues that exhibit
8 discusses items that constitute "'action.'" under the OPMA. Br, of Re-sp't at 16-18
(citing Wood v, Battle Ground Sch. hist., 107 Wn. App, 550, 558, 27 P.3d 1208
(2001)),
Construing the recall statute in favor of the voter and allowing the voters to
draw reasonable inferences from ail of these facts, we agree with the trial court that
this OPMA-related charge 1 is factually sufficient.
12
In re Recall ll of Patricia Pepper, No. 94574-8
Charge 1 is also legally sufficient. If Pepper did e-mail with both Morgan and
Weber (a majority of the council), as Robbin Taylor alleges, and if they did discuss
changes to council rules, as Robbin Taylor• alleges, such conduct would likely
constitute council "action" in violation of the OPMA. RCW 42.30.020(3) (defining
"action" for OPIVIA purposes as including, but not limited to, "receipt of public
testimony, deliberations, discussions, considerations, reviews, evaluations, and final
actions").
It is certainly true that this court has held that "the passive receipt of c-mails '
and other one-way forms of communication does not, by itself, amount to
participation in a meeting because such passive receipt of information does not
demonstrate the necessary intent to meet." Citizens All,for Prop Rights Legal Fu!u1
v. San Juan County, 1842 Wn.2d 428, 444, 359 P,3d 753 (2015). And the only specific
e-mail referenced in Ward's memoranda wassent by Morgan. But as discussed
above, Robbin Taylor also presented numerous other facts from which voters could
draw the inference that Pepper participated in OP1v1A violations,
Because Robbin Taylor specifically details alleged violations of the OPMA
and provides evidence of legal advice indicating knowledge of potential OPMA
violations, the trial court correctly ruled that charge I is legally sufficient.
13
In re Recall ofPafrkeia Pepper, No. 94574
III. Charge 2: The refusal to attend council meetings and failure to approve
meeting minutes charge is both legally and factually sufficient
Charge 2 states, "Pepper, as part of a council majority, refused to attend
council meetings and failed to approve minutes," CP at 375.
A, ReAsal to attend council meetings
This charge also contains several subparts and multiple allegations. Robbin
Taylor argues in part that Pepper colluded with two other council members to
prevent meetings and thereby violated her duty as a council member. Br, of esp't
at 21. Pepper generally responds that she reasonably believed that nothing in the law
or council rules made her failure to attend council meetings illegal. Br. of Appellant
at 35.
Pepper's response does not answer Robbin Taylor's allegation, Robbin
Taylor's allegation did not depend on the notion that Pepper's failure to attend was
itself criminal or illegal, Instead, Robbin Taylor alleges that Pepper's actions
violated her duty as a council member, Robbin Taylor also alleges that Pepper
violated her duty as a council member when she colluded with two other council
members to prevent meetings from taking place. Pepper's assertionthat she
reasonably believed absences were legal does not answer this allegation and
therefore does not negate the intent element of a recall petition.
Itis undisputed that Robbin Taylor regularly attended council meetings and
can therefore assert personal knowledge of Pepper's attendance or absenteeism. Br.
14
In re Recall of Parricia Pepper•, No. 94574-
of Resp't at 20; CP at 274, 1n addition, Pepper never denied missing any of the
meetings listed in Robbin Taylor's brief. Further, as noted above, Robbin Taylor is
not arguing that absences justify recall, but rather that Pepper violated her duty as a
council member by preventing meetings from taking place, and that this justifies
recall, We agree with the trial court that this charge is factually sufficient.
This charge is also legally sufficient. RCW 29A.56.110, the recall statute,
does not require an act to be unlawful in order to form a legally sufficient basis for
recall. Instead, it says, "'Misfeasance' or 'malfeasance' in office means any
wrongful conduct that affects, interrupts, or interferes with the performance of
official duty . . . [, and] 'misfeasance' in office [additionally) means the performance
of a duty in an improper manner." RCW 9A,56.110(1)(a)-(b). This statute also
permits a recall petition to be based on "`[v]iolation of the oath ofoffice,' meaning
the "neglect or knowing failure . . . to perform faithfully a duty imposed by law,"
RCW 29A.56,110(2). Robbin Taylor alleges Pepper's actions arc a "violation of the
oath of office" because "{p]urposefully defeating quorums to obstruct the
functioning of the City is a neglect to perform faithfully her duties as a member of
the Black Diamond City Council." Br. of Rep't at 21. Based on a plain language
reading of RCW 29A.56,110, we affirm the trial court's ruling that this charge is
legally sufficient.
15
In pe Recall of Patricia Pepper,No. 94574-8
B. Failure to approve meeting inutes
Other portions of this charge are also sufficient, Forexample, Robbin Taylor
further alleged that Pepper, along with the majority of the council, failed to approve
city council meeting minutes. Although the fact that no minutes have been approved
for certain council meetings does not specifically point to Pepper, the audio
recording of the October 6, 2016 council. mcctin —cited by both parties—supports
this factual allegation,
This portion of the charge is also legally sufficient. RCW 42.32.030 states,
"[M]inutes of all regular and special meetings except executive sessions of such
boards; commissions, agencies or authorities shall be promptly recorded and such
records shall be open to public inspection." (Emphasis added.) A series of relevant
Washington laws and Black Diamond City Council Rules define additional
responsibilities regarding minutes, including:
s ROW 35 .12.110: "A journal of all proceedings shall be kept, which shall
be a public record,"
is Black Diamond City Council Rules of Procedure 2.3: "Minutes. The City
Clerk shall cause to be prepared action minutes of all of the Council
meetings, which meetings shall contain an account of all official actions of
the Council. . . . No changes shall be made to minutes except by motion
approved by a majority of the Council at a properly noticed meeting." (CP
at 57.)
• Black Diamond City Council Rules of Procedure 3.7: Approval of meeting
minutes is a routine consent agenda item unless a council member moves
to remove item from the consent agenda for separate discussion and action.
(CP at 60.)
16
In re Recall of Patricia Pepper,No. 94574-8
Further, meeting minutes, when drafted, must be approved unless separately taken
up and acted on outside the consent agenda process and, as noted above, this process
must occu° "promptly," RCW 42,32.030. The allegation of deliberate delay in
approving minutes, with no motion to amend per the statute, is legally sufficient.
Once again, we agree with the trial courtthat charge 2 is sufficient to go to
the voters.
IV. Charge 3: The failure to enact a budget charge is legally and factually
sufficient
Charge 3 provides, "Pepper, as party of a council majority, failed to enact a
2017 budget in violation of state law and instead enacted a temporary budget
containing illegal provisions, impairing the city's ability to provide essential
services." CP at 375.
Robbin Taylor alleges that Pepper and other majority members introduced a
substitute budget, without proper notice, at the December 22, 2016, council meeting.
Br. of Resp't at 23. Additionally, Robbin Taylor contends that the substitute budget
contained illegal provisions and that Pepper attempted to force its adoption. Id. at
24. Robbin Taylor cites exhibit 20, a draft of the Black Diamond City Special
Council minutes for December 22, 2016, in support of this allegation. CP at 19, 191-
200. Robbin Taylor's evidence shows that the council eventually passed a
temporary, and later a final, budget—keeping all city services funded—but it did so
17
In re Recall ofPafricia Pepper, No. 94574-8
after the deadline provided in ROW 35A,33,070,3 Robbin Taylor alleges that Pepper
obstructed the norma] budget process and therefore violated ROW 35A.33.075.4
Robbin. Taylor argues that even though the council ultimately passed a budget,
Pepper's wrongful conduct in delaying that passage can still support a recall. Br, of
3 ROW 35A.33,070 provides:
The council shall meet on the day fixed by ROW 35A.33,060 for the purpose
of fixing the final budget of the city at the time and place designated in the
notice thereof. Any taxpayer may appear and be heard for or against any part
of the budget. The hearing may be continued from day to day but not later
than the twenty-fifth day prior to the commencement of the city's fiscal year.
RCW 35A.33.060 (the statute referenced in .070) requires that a "preliminary budget" be
made publicly available in advance of the meeting at which the council will "fix[] the final
budget.°' It also provides that the council will hold this meeting "on or before the first
Monday of the month next preceding the beginning of the ensuing fiscal year" ROW
35A.33.060.
4 RCW 35A33,075 states:
Following conclusion of the hearing, and prior to the beginning of the fiscal
year, the legislative body shall make such adjustments and changes as it
deems necessary or proper and after determining the allowance in each item,
department, classification and fund, and shall by ordinance, adopt the budget
in its final form and content. Appropriations shall be limited to the total
estimated revenues contained therein including the amount to be raised by ad
valorem taxes and the unencumbered fund balances estimated to be available
at the close of the current fiscal year. Such ordinances may adopt the final
budget by reference: PROVIDED, That the ordinance adopting such budget
shall set forth in summary form the totals of estimated revenues and
appropriations for each separate fund and the aggregate totals for all such
funds combined.
A complete copy of the final budget as adopted shall be transmitted to the
state auditor, and to the association of Washington cities.
18
In re Recall of Patricia Pepper,Nu, 94574-2
Resp't at 23 (citing In re Recall Charges Against Davis, 164 Wn.2d 362, 369-70,
193 P.3d 98 (2008)).
The trial court stated that "[tjhe evidence before the court is that Ms. Pepper
and her colleagues did not in fact pass a final budget by the deadline [imposed ink
RW 35A,33,015." R7' at 64. That court recognized that there was a factual
question about who bore responsibility for this failure—Pepper or the majority—but
concluded that the constitution places that decision in the hands of the voters, not
the court.
We agree with the trial court, As noted in Davis, 164 Wn.2d at 370, Pepper's
argument that everything worked out in the end is not a defense.'
V. Charge 4: The MDR]:T charge is insufficient
Charge 4 states, "Pepper, as party of a council majority, improperly voted to
change Master Development Review Team contracts resulting in threatened legal
action against the city." CP at 375.
The superior court ruled that this charge is sufficient. That court concluded
that once a developer's permit rights have vested under law, the city council
members cannot interfere with those rights merely because they do not think the
5 In Davis, the subject of the recall petition allegedly entered into a private,
unauthorized agreement to provide a severance package—the alleged unlawful conduct
was not "`cured,'" but the severance package was later voted down in a public meeting.
164 Wn.2x1 at 369. Despite the later vote, charges were sufficient as they alleged that the
subject's conduct had the `"potential effect of obligating the Port, Id.
19
In re Recall of Patricia Pepper,No. 94574-5
permits should have been issued, VRP at 65- . The superior court further held that.
Robbin Taylor had sufficient personal knowledge to support the charges. Id. at 66.
We agree with the superior court's legal conclusions about vested rights.
However, we find the evidence presented to support this charge insufficient, Robbin
Taylor fails to present the pertinent contract language that created the "vested permit
rights" acknowledged by the trial court or even the contract itself id, at 65. Pepper,
by contrast, provided a legal memorandum by attorney Jane Koler that approved the
council majority's conduct regarding the N1DRT. Br. of Appellant at 44, App. A-1.
That legal memorandum cites to the Oakpointe contract's relevant provisions and
concludes the contract does not give Oakpointe any final authority over the
composition of the. DRT. Id. Without providing the contract that allegedly created
the duty at issue in this charge, Robbin Taylor's fourth charge cannot be considered
legally sufficient.
CONCLUSION
We af ,ull in part and reverse in part. The first three charges of the Pepper
recall ballot synopsis are factually and legally sufficient. Charge 4, however, is
insufficient.6
fi Pepper filed a motion to supplement the record in our court; we deny that motion.
Pepper also moved for costs under RAP 14.2-14.3.Pepper,however,is not the substantially
prevailing party; her motion for costs is therefore denied.
20
In re Recall of Paan,is Pepper Na, 94574-S
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