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HomeMy WebLinkAboutCity of Pasedena Res - Violence Eradication LAW OFFICES OF BEST, BEST & KRIEI March 11, 1994 MEMORANDUM TO: Bruce Altman, City Manager City of Palm Desert FROM: Dave Erwin, City Attorney RE: Proposed Pasadena Resolution re Violence Eradication Bruce: Attached is a memo which has been prepared by one of our associates in the Riverside Office regarding the above matter. This is for your information, consideration and review. DJE/vcd attachment cc: Capt. Bloomquist, Sheriff 's Office, w/attachment CITY C '?fvCIL ACTION: APPRS t r r.' •DFNIED RECEIVED ti OTHE Q — n,4 r CYC &D MEETING L AYES: p,ju-\,`f — NOES: AB S ENT: A(1 ABSTAIN: Y1C5Y VERIFIED 131-': lt� ( Lt Original on File wit City Clerk' s Office DJE48753 MEMORANDUM TO: Dave Erwin FROM: Elise Traynum DATE: March 10, 1994 RE: PROPOSED RESOLUTION SUBMITTED BY THE CITY OF PASADENA - ERADICATING RAMPANT VIOLENCE INTRODUCTION AND SUMMARY OF FINDINGS Pursuant to your request, the following is a brief discussion regarding the above-referenced resolution. Given the universal problems of the perpetration of violent street crimes suffered in many cities throughout the United States, Pasadena' s resolution is commendable. Palm Desert by use of its police power may desire to enact such legislation as requested by Pasadena if its problems are similar to Pasadena ' s. Certainly, it may establish a committee or coalition to review crime within its boundaries. However, as will be summarized below, Palm Desert should make its own findings based on the status of crime within its jurisdiction. In addition, prior to adopting the Pasadena resolution, or one similar, the Council must decide whether it wants to take such an aggressive position on "gun control, " or in fact, whether it wants to take a position on "gun control" at all. This memorandum discusses cities police powers, preemption, California and federal regulation of firearms and EKT207028 Senate Bill 1607, "The Violent Crime Control and Law Enforcement Act of 1993 . " POWERS OF MUNICIPALITIES The California Constitution empowers cities to make and enforce within their jurisdictions all local, police, sanitary and other ordinances and regulations not in conflict with the general state law. (California Constitution Article XI § 7. ) The governmental powers of a city embrace such matters as the making and enforcing of police regulations, prevention of crime, preservation of public health, prevention of fires, caring for the poor, and education of the young. (Chafor v. Long Beach (1971) 174 C. 478 . ) It has been said that the police power granted to cities is of the same general character as that familiarly exercised by the state legislature. (Re-application of Iverson (1926) 199 C. 582 . ) Ordinances enacted by a city pursuant to its police power will ordinarily be upheld by the courts if they reasonably relate to promoting the public health, safety, comfort and welfare, and if the means adopted to accomplish that promotion are reasonably appropriate to that purpose. Sunset Amusement Co. v. Board of Police Commis. (1970) 7 Ca1. 3d 64 . Cities have the authority to enact police regulations if there is no general law on a particular matter. (Ex parte Daniels (1912) 183 C. 636 . ) Cities enact its laws by ordinance and resolution. An ordinance in its primary and usual sense means a local law. It prescribes a rule of conduct prospective in operation, applicable EKT207028 -2- generally to persons and things subject to the jurisdiction of the city. Oakland v. Oakland Water Front Co. (1897) 118 C. 160. It is adopted with the legal formality of a statute. (McPherson v. Richards (1933) 134 CA 462 . ) On the other had, a resolution is something less formal. It is the expression of the opinion of the legislative body concerning some administrative matter. Ordinarily, it is of temporary character. By adopting the Pasadena resolution, Palm Desert is expressing its opinion and policy regarding violent street crime. PREEMPTION Article XI, Section 7 of the California Constitution-1/ grants cities the authority to legislate provided that such laws and regulations do not conflict with general statewide laws. To determine whether there is a conflict with general statewide laws, one must ask whether the state has "occupied" a field of law. If yes, local regulation is precluded. Cities may enact regulations that supplement general state law only if the state has not fully occupied the field. Thus, there must be only partial state occupation or none at all. (James v. Myers (1945) 68 Cal.App. 2d 443 . See also 30 Ops. Cal. Atty. Gen. 69 (1957) , 24 Ops. Cal. Atty. Gen. 107 (1954) . ) A local law is invalid to the extent that it is in conflict with or to the extent that it duplicates state law. (Chavez v. Sergeant (1959) 52 Cal. 2d 162 , 176. ) 1/ Article XI Section 7 states in its entirety as follows: "A county or city may make and enforce within its limits all local, police, sanitary, and other ordinances and regulations not in conflict with general laws. " EKT207028 -3- There are three tests to determine whether a subject has been preempted by the Legislature: (1) Whether the subject matter has been so fully and completely covered by general law as to indicate that it has become exclusively a matter of state concern; (2) whether the subject matter has been partially covered by general law couched in such terms as to indicate clearly that a paramount state concern will not tolerate further or addition local action; or (3) whether the subject matter has been partially covered by general law, and the subject is of such a nature that the adverse effect of a local ordinance on the transient citizens of the state outweighs the possible benefit to the municipality. (Yuen v. Municipal Court (1975) 52 Cal.App. 3d 351. ) By applying the Yuen elements, we can determine whether the proposed resolution is preempted by state (and federal) law. Theo operative statute s for comparison are Penal p Code Sections 12001 et seq. and the Second Amendment of the United States Constitution. As discussed below, such laws preempt any local regulation of guns. GUN CONTROL The possession, use or transfer of firearms is extensively regulated by statute at California Penal Code Section 12001 et seq. The courts have held that the enactment of such statutes is a proper exercise of the state' s police power. (Galavan v. Superior Court of San Francisco (1969) 70 C. 2d 851. ) Further, the Second Amendment of the federal Constitution provides that "the right of the people to keep and bear arms shall EKT207028 -4- not be infringed, "2/ applies only to the exercise of power by the federal government, and, since the state constitution contains no provision on the subject, the state legislature is free to deal with this issue. (Re-application of Ramirez (1924) 193 C. 633 . ) In other words, the state legislature, in the absence of federal provisions is free to regulate the manner of bearing arms, although it lacks the power entirely to destroy the right to bear arms guaranteed to all people. (People v. Seale (1969) 274 CA 2d 107 . ) Government Code Section 53071 expressly preempts local regulations of guns: "The legislature has provided that it is its intention to occupy the whole field of regulation of the registration or licensing of firearms, as encompassed in the Penal Code, and that such provisions shall be exclusive of all local regulations, relating to such registration or licensing, by any political subdivision. " (Government Code Section 53071. ) California courts have interpreted Government Code Section 53071 to invalidate city ordinances regulating ownership and possession of firearms. Sippel v. Nelder (1972) 24 C.A. 3d 173 ; Olsen v. McGillicuddy (1971) 15 C.A. 3d 897 . The Attorney General of our state has, also, opined that a California city does not have the legislative authority to prohibit the possession of handguns within the city. 65 Ops. Atty. Gen. 457 (1992) . 2/ U. S. Constitution Second Amendment. EKT207028 -5- The Pasadena resolution seeks the repeal of Sections 53071. The intent, to allow each city (or, maybe, the federal government) to regulate guns within its boundaries. Accordingly, the existing right to bear arms provided in the United States Constitution and the extensive state regulation regarding the possession carrying and use of firearms constitutes the ball court upon which the proposed Pasadena resolution must play. In my opinion this is an appropriate matter for the state legislature to review. THE PASADENA RESOLUTION Paragraph 1 of the resolution requests that the Attorney General opine on the sale of ammunition; paragraph 2 requests that the City Council support SB 1607 , proposed legislation restricting the manufacture, transfer and possession of certain semi-automatic assault weapons and large capacity ammunition feeding devices; and, paragraph 3 requires that the City (in association with the Coalition for Nonviolent City, a group yet to form) petition state and federal legislative bodies to enact more stringent gun control measures including the repeal of the preemption statute in the Government Code. (i. e. , Section 15071. ) As you can see the brunt of the Pasadena resolution is to control guns within cities and the sale of ammunition to operate guns. The question is, does the City Council want to take such an aggressive position on gun control. Senate Bill 1607 authored by Senator Biden is entitled the "Violent Crime Control and Law Enforcement Act of 1993 . " The EKT207028 -6- • bill is 468 pages long. It deals with the death penalty, habeas corpus reform, enhanced penalties for crimes perpetrated with guns, obstruction of justice, youth violence, including increased penalties for drug trafficking, and criminal street gangs, terrorism, sexual violence and child abuse, victims ' rights, prisons, rural crime, drug control in general, drunk driving, motor vehicle theft prevention, protection for elderly, consumer protection, computer crime, parental kidnapping and more. Senator Fienstein' s amendment to SB 1607, "Public Safety and Recreational Firearms Use Protection Act" restricts the manufacture, transfer and possession of certain semiautomatic assault weapons and large capacity ammunition feeding devices. Currently, California law prohibits the manufacture, sale, transfer, possession, distribution, transportation and importation into the state of certain semiautomatic assault weapons without a permit under the Roberti-Ross Assault Weapons Control Act of 1989 . Penal Code Section 12276 et seq. The Act does not place such restrictions on the use of such weapons which are primarily designed and intended for hunting, target practice or other legitimate sports or recreational activities. Penal Code Section 12275 . 5 Senator Fienstein's amendment mirrors California law. CONCLUSION The Pasadena resolution presents an opportunity for cities to take an aggressive stance in the eradication of violent street crime. A committee or coalition to study such problems and to create solutions is a positive approach. Moreover, the concerns EKT207028 -7- I have with adopting the resolution as presented is that it does not make findings stating the status of crime in Palm Desert, and, more importantly, it is establishing a city policy to aggressively seek "gun control" legislation on a federal and statewide basis, an issue that, usually, results in strenuous debate. ELISE K. TRAYNUM EKT207028 -8- INTEROFFICE MEMORANDUM City of Palm Desert TO: DAVID J. ERWIN, CITY ATTORNEY STEVE BLOOMQUIST, PALM DESERT POLICE CHIEF FROM: BRUCE A. ALTMAN, CITY MANAGER DATE: FEBRUARY 25, 1994 SUBJECT: CITY OF PASADENA RESOLUTION #7045 - ERADICATING RAMPANT VIOLENCE Attached is a letter from the City of Pasadena seeking this city's support of its Resolution #7045 dealing with the eradication of rampant violence. At its meeting of February 10, 1994, the Palm Desert City Council referred this matter to staff for a report and recommendation. Steve, would you review and comment on this request from the law enforcement standpoint. Dave, would you do the same from a legal standpoint. I would like to place this back on the City Council Agenda for March 10, 1994. Thank you for your assistance in this matter. BRUCE A. ALTMAN, CITY MANAGER BAA:srg:mpf OFPAs,i eilAj/ /.,0,49t/t9i/eAusor ONE HUNDRED NORTH GARFIELD AVENUE _.RATED - PASADENA, CALIFORNIA 91109 OFFICE OF THE MAYOR January 26 , 1994 FAXX(818)(818)4 1 1 405-3921 City Council of the City of Palm Desert 73-510 Fred Waring Drive Palm Desert, California 92260 RE . Pasadena Resolution #7045 - EradicaLin Rampant Violence Dear City Councilmembers : With each passing day, news magazines, newspapers, and other forms of mass media document the infestation of violence plaguing California cities, and cities across America. That kind of news is deeply troubling. But on a positive note, and in response to that violence, we are witnessing a rebirth of community activism. This time that activism is centered on eradicating violence. Here in the City of Pasadena, the residents are energized and determined to implement concrete actions to address this problem. As the Mayor of Pasadena, it has been personally heartening to see the community coalition which formed after the recent murder of three youngsters on Halloween night . The Pasadena Coalition for a Nonviolent City is an action-oriented grassroots movement . Its aim is "to reduce violence and its impact on Pasadena citizens and to create a secure, nurturing community for every resident, especially children and youth. " The task of the Coalition is to intervene directly in the immediate crisis of escalating violence, and also to address the structural and systemic causes of violence . On December 14, 1993 , one of the steps our City Council took was to adopt a Coalition-sponsored Resolution which focused on some of the contributors to the immediate crisis of violence, including the proliferation of awesome firepower on our streets . Resolution #7045 was adopted at a public meeting with lively public participation. Many of the points enumerated in the Resolution relate to legislative advocacy and community mobilization. Unless we are content with the bloody status quo, local communities must become engaged in this dialogue about the eradication of violence in our midst . City Councilmembers Page 2 January 26, 1994 This is a tough subject to talk about because crime and violence are complex issues . But we need to ask ourselves whether the "pat answers" really make sense anymore and whether we need to rethink all our assumptions about this issue. We also need to listen to one another and attack this issue from many different perspectives . To that end, I would encourage you to place this matter on your agenda and adopt similar Resolutions and action plans . Staff in the City Manager' s Office and the City Attorney' s Office are available to assist you with any question you may have concerning this Resolution. Please call those offices at (818) 405-4222 and 405-4141 respectively. As local leaders, we have a responsibility to initiate this dialogue on the eradication of violence. If we do not take action now, there is a very good chance that in a future we will live to see, our beloved cities will be unrecognizable. Thank you for your consideration of this Resolution. S ir�re , /RICK COLE Mayor Attachment r}T"Y CO'7 c.7 L -k: ^� !"�4...0.,fir_'Y..Y�.-f� T - Original cra File `l1 Cle1A' s CWILLIA 11959.\1/14/94 RESOLUTION NO. 7045 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF PASADENA RELATED TO COMBATTING RAMPANT VIOLENCE IN THE COMMUNITY THROUGH JOINT EFFORTS AT THE LOCAL, STATE AND NATIONAL LEVELS WHEREAS, the City of Pasadena is committed to working towards improving community safety as a part of the Healthy Cities Project; and, WHEREAS, gun violence in Pasadena is a health, safety and economic issue costing lives and destroying the quality of life for residents ; and, WHEREAS , a recent escalation in acts of violence in the City, including the ambush murder of three teenagers on Halloween night, has highlighted the urgency of undertaking a multi-prong approach to combatting a situation which is poisoning the life of the community; and, WHEREAS , murderous violence is increasingly traumatizing the entire City; and WHEREAS, Pasadena Police Department records show that during calendar year 1993 , 27 murders occurred in the City of Pasadena, 24 of which were gun-related; and, WHEREAS , Pasadena Police Department records demonstrate that 34 incidents of drive-by shootings occurred during the same time period; and, WHEREAS , residents in all districts of the City are impacted by the easy availability of guns and ammunition, and the fear of becoming a random victim of violence at some time in the future; and, WHEREAS, the City believes an effective way to combat this problem is to mount a holistic approach to the eradication of violence within the community and mobilize residents to deal with this cancer in our midst; and, WHEREAS, the City desires to enact or support legislative efforts which offer hope of controlling the availability of guns and restore the average resident' s sense of security; NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Pasadena that the Council is committed to taking concrete actions to respond to the escalating threats to the community' s physical safety; will seek singly and jointly with other municipalities , or as a part of regional efforts, to enact legislative initiatives; and will support community action to abate the scourge of violence in the city. To these ends, the Council authorizes city staff to take the following actions : 1 . Request an opinion from the California Attorney General ' s Office as to whether a restriction on the sale of ammunition is preempted by statutory law; 2 . Communicate to Congressional representatives the Council ' s opposition to the production and possession of assault weapons and support of Senator Dianne Feinstein' s amendment, SB 1607, "Public Safety and Recreational Firearms Use Protection Act, " intended to restrict the manufacture, transfer and possession of certain semiautomatic assault weapons and large capacity ammunition feeding devices; 2 3 . Undertake efforts, in association with the Coalition for a Nonviolent City, to petition state and federal legislative bodies to enact more stringent gun control measures , including the repeal of the preemption statute in the Government Code; 4 . Work with the League of California Cities and county regional associations in developing a lobbying strategy on this issue to garner the support of other cities and county governmental bodies to advocate for legislative change at the state level . 5 . Circulate this Resolution to other California cities urging them to adopt similar measures . 6 . Take steps to work with the Coalition for a Non- violent City so that the City is joined in partnership with the Coalition in support of the holistic, preventive, anti-violence measures identified by the Coalition' s subcommittee working on alternatives and support for youth; and further, that the city commit a budget line of $250 , 000 as a resource pool to be drawn upon for initiatives that support youth. 3 r Adopted at the regular meeting of the City Council on the 14th day of December, 1993 , by the following vote: Action Item #1 AYES : Councilmembers Crowfoot, Holden, Paparian, Thomson, Vice Mayor Nack, Mayor Cole NOES : Councilmember Richard ABSENT: None Action Items #2 through 5 AYES : Councilmembers Crowfoot, Holden, Vice Mayor Nack, Mayor Cole NOES : Councilmembers Paparian, Richard, Thomson ABSENT: None Action Item #6 AYES : Councilmembers Crowfoot, Holden, Paparian, Thomson, Richard, Vice Mayor Nack, Mayor Cole NOES : None ABSENT: None Ma is S . Stewart, C ' y !•••- =-----.• • 4 APPROVED AS TO FORM: ; *Cg-T-Ar (1. . Carolyn illiams :A. • . JJ•,•�. Deputy City Attorney 4