HomeMy WebLinkAbout2024-05 Charter Amendments to Sections C-9, C-10, and C-17AN ORDINANCE OF THE CITY OF OCOEE, FLORIDA,
PROPOSING i AMENDMENTS ! THE, CITY OF !
CHARTER
CONFIRMaS THAT
COMMISSION! TO INTERPRET AND
ENFORCE THE PROVISIONS OF THE CHARTER, AND
PROVIDING FOR JUDICIAL REVIEW; AND
i TO CONFIRM OR ESTABLISHTHAT
COMMISSION HAS AUTHORITY TO INTERPRET AND
ADJUDGE THE QUALIFICATIONS 1 ELIGIBILITY OF
CANDIDATES 'THE COMMISSION,ESTABLISH
PROCEDURAL RULES TO PROVIDE I DUE
PROCESS ! ANY AFFECTED PARTIES,1 PROVIDE
FOR JUDICIAL REVIEW; AND
CONFIRMA COMMISSION
WHO RE SIGNS FROMTHEIR OFFICE CANNOT
THEREAFTER SEEK ELL' CTION TO ANY PART OF THE
SAME TERM OF !M WHICH THE, MEMBER
RESIGNED;1
PROVIDING A FORM OF BALLOT FOR THE PROPOSED
AMENDMENTS AT
ELECTION AFTER DATE OF
ORDINANCE, ON NOVE MBER 5,2024 OR AS OTHERWISE
SET BY THE CITY COMMISSION; DIRECTING
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BY VOTERSi 1• DEPARTMENT OF
1 PROVIDING FOR CONFLICTS,
SEVE RABILITY,AND AN DATE.
WHEREAS, Article V111, § 2 of the Constitution of the State of Florida and Chapter 166,
Florida Statutes, vests the City of Ocoee (the "City") with broad Home Rule authority to conduct
municipal government, and exercise any power for municipal purposes except as otherwise
prohibited by law; and
WHEREAS section C-10 of the City Charter states that the City Commission "shall be the
judge of the election and qualifications of its members"; and
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WHEREAS, the City Commission interprets section C-10 to mean that the City
Commission has authority to not only judge the election and qualifications of its elected members
but judge the eligibility and qualifications of those seeking to become a member of the City
Commission through an election; and
WHEREAS, the Chatter Review Commission appointed on April 18, 2023, interpreted the
City Commission to have such authority under section C- 10, and proposed no changes to section C-
10 for the ballot at the next general city election, on March 19, 2024;
WHEREAS, in an Order Granting Emergency Motion for Temporary Injunction entered on
December 7, 2023, an Orange County Circuit Judge in case of Oliver v. Sibbitt (Case No. 2023-CA-
017123-0) held, "The City Charter does not give the City the right to judge the qualifications of
candidates. Instead, Section C-10 of the Ocoee City Charter states, '[t]he City Commission shall be
the judge of the election and qualifications of its members and of the grounds for forfeiture of their
office...' (emphasis added [by the court]). It is clear Plaintiff is not a member of the City
Commission and therefore the City Commission is not the judge of his qualifications as a
candidate."
WHEREAS, the City Commission disagrees with the Circuit Judge's holding, but to
remove any doubt, the City Commission wishes for the City's voters to confirm the City
Commission's authority to interpret and enforce the City Chat -ter;
WHEREAS, the City Commission seeks to confirm or establish its authority to adjudge the
qualifications and eligibility of, not only its elected members, but also of candidates and persons
seeking to qualify as candidates for election to the City Commission;
WHEREAS, section C-17 of the City Charter (Filling of vacancies) states in relevant pail,
"The successor to the office of Mayor or Commissioner shall be elected at the next general city
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election if such election is to be held within twelve (12) months of the vacancy. If a general city
election will not be held within twelve (12) months, the successor shall be elected at a special
election which shall be called by the City Commission within ninety (90) days of the vacancy. The
successor shall serve for the unexpired term of the member who created the vacancy"; and
WHEREAS, Blaeks Law Dictionai3� (I Ot" ed. 2014) defines "successor" as "A person who
succeeds to the office, rights, responsibilities, or place of another; one who replaces or follows a
predecessor"; and
WHEREAS, "Florida courts have generally defined a successor as "he that followeth or
cometh in another's place" or, more recently, as one "who follows or takes the place another has
left and sustains the like part or character." Argonaut Ins. Co. v. Commercial Standard Ins. Co.,
380 So. 2d 1066, 1068 (Fla. 2d DCA 1980) (quoting Beatty v. Ross, I Fla. 198, 209 (1847)); and
WHEREAS, the City Commission interprets "the successor" and "the member who created
the vacancy," as used in section C- 17, as referring to two different people; and
WHEREAS, Florida's Resign -to -Run Act, § 99.012(b), Florida Statutes, requires an
"irrevocable" resignation by a member to run for another office; therefore, a member who creates
a vacancy by resignation must resign irrevocably and cannot thereafter seek election to any part of
"the unexpired term" from which the member resigned;
WHEREAS, the City Commission wishes for the City's voters to confirm the City
Commission's understanding that, under the Chat -ter, a member who resigns from their office
cannot thereafter seek election to any part of the same term of office from which the member
resigned; and
WHEREAS, Florida Statutes § 166.031(1) states in pertinent part, "The governing body of
a municipality may, by ordinance... submit to the electors of said municipality a proposed
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amendment to its charter .... The governing body of the municipality shall place the proposed
amendment contained in the ordinance ... to a vote of the electors at the next general election held
within the municipality or at a special election called for such purpose." Further, § 166.031(3)
states, "A municipality may amend its charter pursuant to this section notwithstanding any charter
provisions to the contrary," and
WHEREAS, pursuant to Florida Statutes § 166.031, the City Commission conducted
advertised public hearings and has adopted this Ordinance to submit the proposed Chat -ter
amendments set forth herein to the voters at the next general city election after the effective date
of this Ordinance, on November 5, 2024 or as otherwise set by the City Commission; and
WHEREAS, Florida Statutes § 166.03](2) states, "Upon adoption of an amendment to
the charter of a municipality by a majority of the electors voting in a referendum upon such
amendment, the governing body of said municipality shall have the amendment incorporated into
the charter and shall file the revised charter with the Department of State. All such amendments
are effective on the date specified therein or as otherwise provided in the charter."
SECTION 1. Recitals. The foregoing recitals are incorporated as if set forth at
length and are hereby made a part of this ordinance.
SECTION 2. Authority, The City Commission of the City of Ocoee has the
authority to adopt this Ordinance pursuant to its Home Rule and other powers set forth in Article
VIII of the Constitution of the State of Florida and Chapter 166, Florida Statutes, including
Florida Statutes §§ 166.021 and 166.031, as well as Chapter 5 of the City Code pertaining to
elections and C-13 and C-14 of the City Charter as "the legislative body of the city" to "adopt
any ordinances."
SECTION 3. Format of Proposed Amendments to the Charter. In the
proposed amendments to the Charter in the sections that follow, words that are stfiek-m are
deletions; words that are underlined are additions; and stars (***) indicate omitted sections and
subsections that do not represent Charter amendments.
SECTION 4. Proposed Amendment to § C-9 of the Charter ([City
Commission) created, composition, designation, election generally):
4.1 Text of the Amendment. The City shall submit the following proposed amendment
to § C-9 of the Charter to the qualified electors of the City of Ocoee:
§ C-9. [City Commission] created, composition, designation,
election generally.
There is hereby created a City Commission, to consist of five (5)
members, one (1) of whom shall be known and designated as the
"Mayor"; the other four (4) shall be known and designated as
"Commissioners." One (1) of the Commissioners shall also be
known and designated as "Mayor pro tem." The Mayor shall
represent the city at large, and the Commissioners shall each
represent the single -member district in which they reside. The
Mayor shall be elected by the electors of the city at large. Each of
the Commissioners shall be elected by the electors residing only in
the respective single -member district which he represents on the
City Commission. The Mayor pro tem shall be elected from
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among the Commissioners by the City Commission but shall
continue to represent the district in which such Commissioner
resides. The Mayor pro tem shall be elected at the first City
Commission meeting following the swearing in of the candidates
elected at each general city election (unless there is a runoff
election, in which case the Mayor pro tem shall be elected at the
first City Commission meeting following the swearing in of the
candidates elected at such runoff election) and shall serve as
Mayor pro tem until the successor is elected. The City
Commission shall hold office in the manner hereinafter provided
and shall constitute the governing body and authority of the City of
Ocoee with all the powers and privileges herein granted and
provided. The City Commission has the authority to interpret and
enforce the provisions of this Charter, which shall be binding
unless such interpretation and enforcement is held by a court of
competent jurisdiction, including after any appeals, to be clearly
erroneous, arbitrary, capricious, or otherwise unconstitutional.
Except as otherwise provided in this Charter, whenever this
Charter contains a reference to "all members of the City
Commission", such reference shall include the entire City
Commission and shall not be construed to include only those
members present and voting.
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42 Ballot Title and Questions. The ballot title and summary for the proposed
amendment to § C-9 of the Charter, set forth in Section 4 of this Ordinance, shall be set forth
below, and shall be followed by the words "yes" and "no":
Question #1
AME, NDMENT OF § C-9, OCOEE CITY CHARTER,
AUTHORIZING CITY COMMISSION TO INTERPRE T
►! EVFORCE CHARTER.
Section C-9 of the City of Ocoee's Charter shall be amended to
provide that the City Commission has authority to interpret and
enforce the City Charter subject to review of such decisions by a
court of competent jurisdiction.
Shall the above -described amendment be adopted?
YES
NO
SECTION 5. Proposed Amendment to § C-10 of the Charter (Judge of
qualifications):
5.1 Text of the Amendment. The City shall submit the following proposed
amendment to § C- 10 of the Charter to the qualified electors of the City of Ocoee:
§ C-10. Judge of qualifications.
The City Commission shall be the judge of the qualifications and
eligibility of candidates for the City Commission, the election and
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qualifications of its members, and of -the grounds for forfeiture of
their office under this Charter. and-f—For that these purposes, the
City Commission has shall have, to the extent permitted by
the power to censure, subpoena witnesses, administer oaths, and
require the production of evidence, and establish procedural rules
for implementing this section and ensuring due process, including
reasonable notice to affected parties. A member charged with
conduct constituting grounds for forfeiture of office shall be
entitled to a public hearing on demand. and notle-e- of sueh a
the eity at least seven (7) days prior to the hearing. Decisions
made by the City Commission under this section shall be subject to
review by the a courts of competent jurisdiction on a petition for
writ of certiorari. Nothing contained herein shall be construed to
deprive any candidate or member of the City Commission of st"
me 43et--s fight to due process under the Constitution and the laws
of the United States and the State of Florida.
5.2 Ballot Title and Questions. The ballot title and summary for the proposed
amendment to § C-10 of the Charter, set forth in Section 5 of this Ordinance, shall be set forth
below, and shall be followed by the words "yes" and "no":
Question #2
AMENDMENT OF § C-10, OCOEE CITY CHARTER, TO
AUTHORIZE, CITY COMMISSION TO JUDGE
CANDIDATE QUALIFICATIONS.
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Section C-10 of the City of Ocoee's Charter shall be amended to
provide that the City Commission has authority to judge the
qualifications and eligibility of candidates for the Commission,
establish procedural rules for C-10, including ensuring that notice
and due process is given to affected persons, and provide for
review of such decisions by a court of competent jurisdiction.
Shall the above -described amendment be adopted?
YES
NO
SECTION 6. Proposed amendment to § C-17 of the Charter (Filling of
6.1 Text of the Amendment. The City shall submit the following proposed
amendment to § C-I 7 of the Charter to the qualified electors of the City of Ocoee:
§ C-17. Vacancies; forfeiture of office; filling of vacancies.
A. Vacancies. The office of a member of the City Commission
shall become vacant upon the member's death, resignation,
forfeiture of office or removal from office in any manner
authorized by law.
C. Filling of vacancies.
1. Interim Members. If any vacancy, other than the Office of
Mayor, occurs in the City Commission, an eligible person shall be
selected by the City Commission within thirty (30) days of the
vacancy to serve until the successor is elected. If a vacancy occurs
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in the office of Mayor, the Mayor pro tem shall serve as an interim
Mayor until the successor is elected. The City Commission shall
appoint an interim Commissioner to fill the vacancy created by the
Mayor pro tem serving as Mayor; such interim Commissioner shall
serve until such time as a Mayor is elected. The Mayor pro tern
shall thereafter resume representation of his their single -member
district for the remainder of the term.
2. Successors. The successor to the office of Mayor or
Commissioner shall be elected at the next general city election if
such election is to be held within twelve (12) months of the
vacancy. If a general city election will not be held within twelve
(12) months, the successor shall be elected at a special election
which shall be called by the City Commission within ninety (90)
days of the vacancy. The successor shall serve for the unexpired
term of the member who created the vacancy. A member who
resigns from their office cannot thereafter seek election to any part
of the same term of office from which the member resigned. If all
members of the City Commission are removed at the same time,
the Governor of the State of Florida shall appoint an interim City
Commission that shall call a special election within ninety (90)
days of appointment.
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6.2 Ballot Title and Questions. The ballot title and summary for the proposed
amendment to § C- 10 of the Charter, set forth in Section 5 of this Ordinance, shall be set forth
below, and shall be followed by the words "yes" and "no":
W MW I MMIX
AMENDMENT OF § C-17, OCOEE CITY CHARTER,
PRE CLUDING RESIGNING MEMBER FROM ELECTION
TO SAME TERM
Section C-17 of the City of Ocoee's Charter shall be amended to
state that a member of the City Commission who resigns cannot
thereafter seek election to any part of the same term of office from
which the member resigned.
Shall the above -described amendment be adopted?
WE
Kel
SECTION 7. Miscellaneous.
7.1 Codification & Corrections. If the Charter amendment provided for in this
Ordinance receives affirmative votes from the majority of the votes cast, such amendment shall
be incorporated into the Charter of the City of Ocoee. Any section, paragraph number, letter
and/or any heading may be changed or modified as necessary to effectuate the foregoing.
Grammatical, typographical and similar like errors may be corrected, and additions, alterations,
and omissions not affecting the construction or meaning of this Ordinance or the Charter may be
freely made.
In the event it becomes necessary, as determined by the City Commission, to make any
modification to any ballot question, ballot summary, or to remove a proposed charter amendment
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from the ballot contained herein after adoption of this ordinance, the City Commission may
make such modification by resolution.
7.2 Directions to City Staff. City Staff, under direction of the City Manager, are
authorized to take such actions as are necessary and advisable to effect and carry out this
Ordinance and the Charter amendments and election provided for herein, including working with
the Orange County Supervisor of Elections to put the questions set forth herein on the ballot at
the next general city election after the effective date of this Ordinance, on November 5, 2024 or
as otherwise set by the City Commission. If the Chat -ter is amended by a majority vote of the
qualified electors of the City, the City Clerk shall file a copy of the revised Charter with the
Florida Department of State in accordance with § 166.031(2), Florida Statutes.
7.3 Severabili!yl. If any section, subsection, sentence, clause, phrase or portion of
this Ordinance is, for any reason, held invalid or unconstitutional by any court of competent
jurisdiction, such portion shall be deemed a separate, severed, distinct, and independent
provision, and such holding shall not affect the validity of the remaining portions of this
Ordinance.
7.4 Conflict. In the event of a conflict or conflicts between this Ordinance and any
other Ordinance or provision of law, this Ordinance controls to the extent of the conflict, as
allowable under the law.
7.5 Effective Date. This Ordinance shall become effective on March 20, 2024, or as
soon thereafter as this Ordinance is approved on a second reading. Any Charter amendment
provided for herein shall become effective immediately upon approval by the qualified voters of
the City of Ocoee and certification by the Orange County Supervisor of Elections or other
appropriate officer or entity.
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PASSED AND ADOPTED this —'—J'day of "WUY\ 2024.
Melanie Sibbitt, City Clerk
(SEAL)
FOR USE AND RELIANCE ONLY BY THE
CITY OF OCOEE, FLORIDA; APPROVED
AS TO FVRM AND LEGALITY
this 571� dayofj�JA,q-& 2024.
By:Q�L,j A
Richard S. Geller
City Attorney
APPROVED:
CITY OF OCOEE, FLORIDA
Rusty o is n �ayor
ADVERTISED _&JjUaqj EZ, 2024
READ FIRST TIME Rhuturq-2-0,
2023.
READ SECOND TIME AND ADOPTED
)a YCh 5 52024.
UNDER AGENDA ITEM NO. I I
S:\AKA\CLIENTS\Ocoee, City of\Charter Review - Elections 0164-27414\Ordinance to Amend C-9, C-10, and C-17\Ordinance for Ballot Qs
Amending C-9, C-10, and C-17 of the City Charter - rsg - I 824,doex
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