HomeMy WebLinkAboutAgenda Report - January 20, 1993 (54). os
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CITY OF LODI COUNCIL' COMMUNICATION
AGENDA TITLE: Report on procedure for Payment of Claims
MEETING DATE: January 20, 1993
PREPARED BY: City Manager
RECOMMENDED ACTION: None required. Information only.
BACKGROUND INFORMATION: At the regular meeting of December 16, 1992 and
January 6, 1993, Councilmember Davenport questioned
the manner in which City bills and payroll is mads.
The City Attorney has prepared memos addressing this issue and they are
attached (Exhibit A and B).
In an effort to determine what is the generally accepted practice in some other
area public agencies, I contacted 10 such agencies. The cities of Tracy,
Manteca and Escalon follow a practice identical to the City of Lodi. The
others: Stockton, Ripon, Lathrop, Galt, Modesto, Merced and the County of San
Joaquin do not put the item on the agenda.
In addition to unnecessarily inconveniencing vendors, many of them local, who
do business with the City of Lodi by making them wait up to two to three weeks
longer for their payment, the City would also lose a considerable portion of
its vendor discounts. Some vendors give percentage discounts if they receive
payment within a specified period. This loss would be in the area of $3,500 -
$4,500 annually.
The February 2, 1993 "Shirtsleeve" topic will be a review of various City
Council procedural policies. The Council may wish to discuss how this item is
to be addressed in the future.
FUNDING: None required
TAP:br
Respectfully submitted,
Thomas A. Peterson
City Manager
Attachments
00/TXTA.07A
APPROVED:
THOMAS A PETERSON recyclea paper
` City Manager
U-1
CITY OF LODI
MEMORANDUM FROM THE OFFICE OF THE CITY ATTORNEY
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To: The Honorable Mayor and Council Members
City Manager
Finance Director
From: Bob MCNatt, City Attorney
Date: January 7, 1993
Subject: CONSENT CALENDAR ITEM: "CLAIMS"
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N 131
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SITUATION
On the "Consent" calendar portion of each City Council meeting agenda is an
iL--m denominated "Claims". Under this item, the Council is asked to ratify
payments previously made for such expenses as payroll, bulk electric power
purchases, etc. Concerns have been expressed by Councilmember Davenport
that because the Council does not approve these payments in advance, but
only ratifies them afterward, the methodology may be illegal. A staff
response on this matter has been requested by the Council.
ANALYSIS
Limits on and grants of authority regarding municipal financial affairs are
found in various places throughout California law. The cornerstone of
municipal authority is Article 11, Section 7 of the California Constitution
which grants general authority to cities for all "municipal affairs"; this
has been interpreted to include fiscal policies (Cramer v. San Diego 330
P.2d 235).
other examples of provisions covering municipal fiscal matters include
California Constitution Article 13A(1) [limits on property taxes],
California Constitution Article 16, Section 18 [debt limits], and Chapter 4
of Division 3 of the California Government Code (commencing with Section
37200) covering municipal financial powers generally.
The r..-st relevant statute on this topic is Government Code Section 37208
(cop;, attached) which addresses payments for the type of claims at issue
here.. This statute clearly provides that payment of claims for payroll and
items "conforming to a budget approved by ... the legislative body need not
be audited by the legislative body 2rior to Payment" (emphasis added).
Although I don't believe the City Clerk usually "certifies" that the claims
conform to an approved budget as referred to in subsection (b) of this
statute, our situation may simply be an example of a past Council's
exercise of its discretion to modify the statutory plan.
Under subsection (c) of this statute, the Council could choose to "ratify"
the payments (i.e., approve after the fact) once a year in the form of an
audited comprehensive financial report and dispense entirely with having
the "Claims" item on each Council agenda. In fact, the City Council now
OV.
Honorable City Cou:.-Al Members,
City Manager and Finance Director
January 7, 1993
Page Two
receives such an annual audit report which includes all the same items
previously presented under "Claims". It appears this would satisfy the
criteria in subsection (c).
CONCLUSIONS AND OPINIONS
It is my opinion that the City,s present "claims" procedures are legal. I
suspect that this item has appeared on the agenda for as long as anyone can
recall because some previous Council wanted frequent updates on City
expenditures.
Zt does not appear the City is required to have a "Claims" item on each
agenda. In doing so, the City appears to be acting within its discretion.
I am aware of some cities which do = customarily put such items on
Council agendas at all, choosing instead to approve the once -annual
financial audit. Conversely, I have been told that some cities choose to
have the Council approve all warrants beforehand. I offer no opinion as to
the desirability of any of these approaches.
Respectfully submitted,
BOB MCNATT
City Attorney
BM:vc
attachment
cc: City Clerk
CCCLAIMS/TXTA.OIV
ANMENT
riNANCIIAL POWEM § 37210
Title 4
Div. 3
§ 37208. Payroll warrants or checks; warrants or checks in payment of
budgeted demands; audit; ratification and approval
(a) Payroll warrants or checks need not be audited by the legislative body
i prior to payment. Payrolls shall be presented to the legislative body for
ratification and approval at the first meeting after delivery of the payroll
warrants or checks.
(b) Warrants or checks drawn in payment of demands certified or ap.
as not Inval-
proved by the city clerk as conforming to a budget approved by ordinance or
payment of
resolution of the legislative body need not be audited by the legislative body
y for miscel.
prior to payment.
lorse (1934)
(c) Notwithstanding subdivisions (a) and (b), budgeted payrolls and de-
mands paid by warrants or checks may be presented to the legislative body
for ratification and approval in the form of an audited comprehensive annual
financial report.
time and
(Added by Stats.1949, c. 79, V. 154, § 1. Amended by Stats.1959, c. 1775. p. 4259.1 1;
Stats.1970, c. 261, p. 525. § 2; Stats.1980, c. 770, p. 2286, § 2; StaL&1986. c. 982, § 14.)
id mayor of
rent for mis.
curred In the
cies, in addi.
-ed expenses,
:o valid ordi-
.ch payments
claimed ex.
Fcation. AI-
icisco (1975)
; or attend -
hall certify
employees.
Historical Note
The 1959 amendment added the second para.
graph in its present form except as modified by
the subsequent three amendments.
The 1970 amendment, In the first sentence of
the second paragraph, inserted "or resolution".
The 1980 amendment inserted "or checks"
throughout the section; and, in the second
sentence of the second paragraph, substituted
"warrants' for'warrant".
The 1986 amendment inserted subdivision
designations: deleted the second sentence of
subd. (b) which provided: 'Budgeted demands
paid by warrant prior to audit by the legislative
body shall be presented to the legislative body
for ratification and approval at the first meet-
ing after delivery of the warrants."t and added
subd. (c).
Derivatlow See Derivation under 137206.
Fnrms
See West's California Code Forms, Government.
§ 37209. Transfer of city clerk's duties to director of finance; ordinance
The duties imposed upon the city clerk by this article may be transferred to
a director of finance when such office has been established and the powers
and duties thereof defined by ordinance. Such an ordinance shall require the
execution by the director of finance of the bond required of the city clerk by
Section 36518 of this Code.
(Added by Stats.1955, c. 1754, p. 3242, § 1.)
Library References
Municipal Corporations 0-170. Sovereign Immunity study. 5 Cal. L. Rev.
CJS. Municipal Corporations § 545. Comm. Reports 299, 421 (1963).
§ 37210. Newly Incorporated cities; Issuance of temporary nonnegotia-
ble notes; repayment
Newly incorporated cities that have not received revenues from property
taxes may issue temporary non-negotiable notes bearing interest at a rate not
exceeding 6 percent per annum to pay lawfully Incurred current expenses and
699
CITY OF LODI
MEMORANDUM FROM THE OFFICE OF THE CITY ATTORNEY
To: The Honorable Mayor and Council Members
City Manager
Finance Director
From: Bob McNatt, City Attorney
Date: January 13, 1993
Subject: CONSENT CALENDAR "CLAIMS" PROCEDURES
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This is intended as a supplement to my memo of January 7, 1993 on the above
topic. A question has been raised as to the effect of Government Code
Section 37202 (attached) on the situation. Although reasonable minds could
differ as to the effect of this statute, I don't believe it changes my
overall conclusion that Lodi's handling of consent calendar claims items is
proper.
The specific language contained in Section 37202 which raises the question
states "... the legislative body shall approve or reject demands only after
such demands have been audited ..." (emphasis added). If that was all the
statute said, I would probably agree that State law might require prior
approval of all City expenditures or payment of "demands".
However, the Section begins by stating "[e]xcept as provided in Section
37208 ..." In my memo of January 7, 1993, it was concluded that Lodi is in
compliance under Section 37208. One of the distinctions between these two
statutes is that Section 37202 does not refer to payment of demands under a
previously -adopted budget. When these two statutes area read together, I
believe the logical conclusion is that cities have an option of how they
choose to pay their bills.
As I have previously said, I am unaware of any State law which reauires a
city to adopt an annual budget. in such circumstances, I assume that
Section 37202, which requires prior Council approval of all demands for
?terns which are not contained in a formal budget, would apply.
On the other hand, cities could choose under Section 37208 to ratify (after
the fact) payments made on demands which conform to a previously -adopted
budget. I believe this is the situation in Lodi.
T
Claims Procedures
January 13, 1993
Page Two
In summary, it is my opinion that if Lodi did not have an adopted budget,
the provisions of Section 37202 might apply and Council approval would be
required before demands could be paid. However, since to my knowledge all
the claims contained in the consent calendar for ratification are done
pursuant to an approved budget, Section 37208 would apply.
Respectfully submitted,
BOB MCNATT
City Attorney
BM:vc
attachment
cc: City Clerk
CCCLAIMS.2/TXTA.01V
§ 37202 CITY GOVERNMENT
Title 4
§ 37202. Demands; audit; submission; certification
Except as provided in Section 37208, the legislative body shall approve or
reject demands only after such demands have been audited in the manner
pres:ribed by ordinance or resolution. Such audited demands may be sub-
mitted separately or a register of audited demands may be submitted to the
legislative body for approval or rejection and shall have attached thereto the
affidavit of the officer submitting the demands certifying as to the accuracy of
the demands and the availability of funds for payment thereof.
(Added by Stats.1949, c. 79, p. 154, § t. Amended by Stats.195), c. 1248, p. 3095, § 1;
Stats.1970, c. 261, p. 525, § 1.)
Historical Note
As added in 1949, this section read:
'Tfte legislative body shall audit demands."
The 1951 amendment rewrote the section in
its present form, except as modified by the
1970 amendment.
The 1970 amendment substituted the excep-
tion at the beginning of the first sentence for
`The".
Derivation: See Derivation under § 37201.
iJbrary References
Municipal Corporations a-1012.
C.J.S. Municipal Corporations § 2177.
WESTIAW Electronic Research
See WFSTLAW Electronic Research Guide following the Preface.
Notes of Decisions
Actions and proceedings. In general 3
Demands, to general 1
Mandamus 4
Nature and effect of determination 2
1. Demands, In general
Under Municipal Corporation Act, § 864,
Stats.1683, pp. 266 et seq., declaring that all
"demands" against a city or town of the sixth
class shall be presented and audited by the
board of trustees. etc., though the term "de-
mands" was sufficiently broad to include
claims for torts as well as on contracts, yet the
purpose of the act being that the claim should
be audited, which could not apply to claims for
tons, the act did not require presentation of a
claim for damages for the maintenance of a
nuisance as a condition precedent to the plain-
tifrs right to sue thereon. Adams v. City of
Modesto (1901) 63 P. 1083, 131 C. 501.
2. Nature and effect of determination
Under a city ordinance authorizing the fire
superintendent to grant a fireman leave of air
Bence with pay during a sickness contracted
while on duty, the determination by the super
intendent that a fireman's sickness was so con
tracted is conclusive, and the auditing boar
has no discretion to disallow the fireman'
salary during such lease, though the pay roll r
made out and verified by fire chief must pass
through the hands of the auditing committee in
the ordinary course of business. Jackson v.
Wilde (1921) 198 P. 822, 52 C.A. 259.
A city is notprecluded, by its allowance of
bills pre-ented for rents accrued under a void
contract, from showing that such bilis were in
excess of Elie reasonable value of the property.
Higgins v. City of San Diego (1896) 45 P. 824.
118 C. 524, modified in other respects 50 P.
670. 118 C. 524.
The action of the trustees of a city on the
presentation of a claim which they have juris-
diction to hear and determine is a judicial act,
and, whether right or wrong, is binding on the
clerk. McConoughey v. Jackson (1894) 35 P.
863, 101 C. 265, 40 Am_St.R. 53.
3. Actions and proceedings, in general
The rejection of a claim egainst the city by
its board of examiners does not affect the right
of action against the city on the claim. San
Francisco Gas Co. v. City of San Francisco
(1856) 6 C. 190.
4. Mandamus
Where petitioner had been erroneously fined
d by city judge under a statute pro 'ding a penai-
s ty for a felony and fine and been paid into city
s treasury, in view of treasurer's restricted right
694