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HomeMy WebLinkAbout09 SOLICITATION ORDINANCE NO. 1412Agenda Item Reviewed: AGENDA REPORT City Manager Finance Director MEETING DATE: MAY 15, 2012 TO: JEFFREY C. PARKER, CITY MANAGER FROM: SCOTT M. JORDAN, CHIEF OF POLICE SUBJECT: PROPOSED ORDINANCE REGULATING VARIOUS FORMS OF SOLICITATION ON CERTAIN PUBLIC RIGHTS OF WAY AND PRIVATE PROPERTY AND ACTS OF TRESPASS ON PRIVATE COMMERCIAL PROPERTY SUMMARY On Tuesday, May 1" 2012, staff from the Police Department presented to the City Council a proposed ordinance regulating various forms of solicitation on certain public rights-of-way and private property and acts of trespass on private commercial property. Based upon the Council's direction, and after careful review of current City Code provisions, staff revised the proposed ordinance to remove portions regulating residential door-to-door solicitation. As directed by Council, the revised ordinance would not impose any new permit costs or Livescan requirements on non-profits soliciting in residential areas. RECOMMENDATION Have the first reading, by title only, of the attached Ordinance No. 1412 (Attachment No. 2) adding to and amending various sections of the City of Tustin City Code relating to the regulation of solicitation activity, acts of trespass on private commercial property, and acts of skateboarding on private commercial property within the City of Tustin. FISCAL IMPACT As noted in the May 1, 2012, Agenda Report regarding this proposed ordinance, costs associated with "No Solicitation" signage of segments of the public rights of way will be the responsibility of the City. The cost of 20 signs will be $840.00. BACKGROUND/DISCUSSION During the initial staff presentation on the proposed Ordinance No. 1412, City Council gave staff direction to revise the portion of the ordinance pertaining to residential door- to-door solicitation, particularly as it relates to the permit requirements. Specifically, the Council wished to avoid the anticipated permitting costs and burdens related to Livescan for non-profit organizations such as Girl Scouts. Proposed Ordinance Regulating Various Forms of Solicitation May 15, 2012 Page 2 of 2 With that direction in mind, Staff and the City Attorney reviewed the existing City Code and concluded that an already-existing ordinance which specifically requires a permit for charitable organization solicitors addresses the issue in a manner consistent with the Council's direction. (See Tustin City Code section 2513(f), a copy of which is attached as Attachment 5 for reference.) After discussion between PD staff and the City Attorney, it was determined the recommended course of action would be: to retain the existing permit requirement for charitable solicitation in Section 2513(f), which does not impose Livescan or other burdensome costs on non- profit entities; • to remove the proposed residential door-to-door permit requirements (e.g., sections 5810-5816) from the proposed ordinance, and • to recommend approval of the remainder of the proposed ordinance. SCOTT M. JORDAN Chief of Police Attachment No. 1 Attachment No. 2 Attachment No. 3 Attachment No. 4 Attachment No. 5 Attachment No. 6 CHARLIE CELANO Captain May 1, 2012 Agenda Report — Proposed Ordinance Regulating Various Forms of Solicitation Consolidated Solicitation and Trespass Ordinance (Ordinance No. 1412) [as revised] City Attorney Legal Opinion City of Orange Ordinance — Title 9, Chapter 9.37 Solicitation from Public and Private Property Tustin City Code section 2513(f) Redline version of Ordinance 1412, highlighting revisions since the version considered by the Council on May 1, 2012, ATTACHMENT 1 Agenda Item Reviewed: AGENDA IV' P 0 R T City Manager Finance Director MEETING DATE: MAY 1, 2012 TO: JEFFREY C. PARKER, CITY MANAGER FROM: SCOTT M. JORDAN, CHIEF OF POLICE SUBJECT: PROPOSED ORDINANCE REGULATING VARIOUS FORMS OF SOLICITATION ON CERTAIN PUBLIC RIGHTS OF WAY AND PRIVATE PROPERTY AND ACTS OF TRESPASS ON PRIVATE COMMERCIAL PROPERTY �111[j LIJ I k", The Police Department has received a growing number of complaints from private property owners concerning adverse impacts arising from a variety of solicitation activities at and upon commercial properties. Complaints concerning overnight trespass on commercial properties and unwanted acts of skateboarding on private property have become numerous. Police Department staff has worked with the City Attorney's Office to develop a proposed ordinance to address these issues. This ordinance amends the Tustin City Code by establishing regulations which: prohibit solicitation activity at those public rights of way where street parking is prohibited; requires a solicitor's permit for solicitors conducting commercial or charitable solicitation in residential areas of the city; prohibits solicitation activity on commercial property wherein the property owner has posted a "no solicitor's sign". In addition, the ordinance prohibits trespass on commercial properties during non-business hours and prohibits skateboarding on commercial properties. RECOMMENDATION Have the first reading, by title only, of the attached Ordinance No. 1412 adding to and amending various sections of the City of Tustin City Code relating to the regulation of solicitation activity, acts of trespass on private commercial property, and acts of skateboarding on private commercial property within the City of Tustin. FISCAL IMPACT Costs associated with the signage of the public rights of way will be the responsibility of the City of Tustin. The cost of 20 signs will be $840.00. Proposed Ordinance Regulating Various Forms of Solicitation May 1, 2012 Page 2 of 7 BACKGROUND/DISCUSSION The City of Tustin has experienced various negative impacts created by solicitation in public rights of way, solicitation on commercial property, residential door-to-door solicitation, trespassing on the exterior premises of private business property during non-business hours and skateboarding on private commercial property. Over time, the Police Department has received numerous complaints from private property owners regarding these impacts as further explained in this report. These issues have negatively impacted the quality of life for residents in the community, local business owners, and property owners. These negative impacts also adversely affect the safety of vehicular and pedestrian traffic. Members of the Police Department staff have worked with the City Attorney's Office to develop specific ordinance regulations addressing these areas of concern. The City Attorney provided an opinion discussing the legal aspects of the proposed ordinance, which is attached to this report. This report presents proposed amendments and additions to City of Tustin ordinances related to both solicitation activity and trespass. The first three topics are in regards to solicitation and encompass: • Solicitation in the public right of way; • Solicitation on privately owned commercial properties; and • Residential door-to-door solicitation. The latter two topics are in regards to trespassing and include: • Trespassing on commercial properties during non-business hours; and • Regulation of skateboarding on private property. ARTICLE 5, CHAPTER 8 — SOLICITATION ACTIVITIES Overview of Proposed Ordinance Amendments Regulating Solicitation 1. Regulation of Solicitation Activity on Certain Areas of Public Rights of Way Staff is recommending that Tustin City Code be amended to prohibit all forms of solicitation at those particular street locations with prohibited "on street parking". This specific prohibition is set forth in Section 5802(b). As amended, Section 5802(b) will provide that it is unlawful for any person, while standing in any portion of a public sidewalk or driveway, to conduct solicitations of any person in an automobile traveling on any street with designated prohibited Parking. Legislative findings supporting the regulations are found in Section 5800. Individuals who solicit motorists from public rights of way often do so specifically from center medians and sidewalks adjacent to streets where there is no on-street parking. Proposed Ordinance Regulating Various Forms of Solicitation May 1, 2012 Page 3 of 7 Such conduct creates significant traffic hazards. These traffic hazards include vehicles unnecessarily stopping in traffic lanes, vehicles forced to make sudden stops, congestion in and around driveway aprons, individuals entering traffic lanes in an attempt to contact vehicle occupants, and individuals standing in front of vehicles to prevent the vehicles from proceeding forward. In addition, individuals attempting to attract the attention of occupants in a vehicle often use aggressive tactics such as loud whistling, shouting, waving arms, jumping around, and converging upon vehicles. This distracts a motorist's attention away from his primary duty of safely operating a motor vehicle. Examples of highly traveled streets with prohibited parking involving traffic related hazards arising from solicitation activity include: • Irvine Boulevard where it intersects with the 55 fwy (35 to 40 mph) • Red Hill Avenue between the 1-5 fwy and San Juan (35 to 40 mph) • El Camino Real between Orange Street and Red Hill Avenue (35 to 40 mph • Jamboree Boulevard between the 5 fwy and Irvine Boulevard (40 to 45 mph from fwy to El Camino Real — and 45 to 50 mph from Bryan Avenue to Irvine Boulevard) The above intersections and streets service a high level of vehicular traffic and often have increased congestion during peak traffic flow hours. Peak traffic hours are between 7:00 am and 7:00 pm during the day. In 2010 the Red Hill, El Camino, and Jamboree locations were reviewed and a speed limit increase of 5 mph was implemented, as noted above. In addition, Red Hill Avenue and El Camino Real in particular, service a very high level of pedestrian traffic. The close proximity of the high school also creates an increased volume of pedestrian traffic at the start and finish of the school day. The public streets with prohibited parking within the scope of this ordinance regulation comprise a small percentage of surface streets within the City. The Police Department often responds to these locations for service calls related to individuals engaged in various acts of solicitation, including those peak traffic hours. In 2011, the Tustin Police Department responded to over 45 citizen generated complaint calls specifically related to solicitation activity in the public right of way. All of the calls involved the locations noted above. In addition, a portion of those calls specified a concern that such activity was creating a traffic hazard. During the past several years, the Police Department has responded to many calls for service where property managers, business owners, employees, and customers have had numerous complaints related to vehicular and pedestrian traffic hazards. These hazards have included individuals trespassing into center medians and approaching vehicles for purposes of solicitation. Proposed Ordinance Regulating Various Forms of Solicitation May 1, 2012 Page 4 of 7 Business owners and managers expressed frustration because they continue to receive significant customer complaints relating to vehicle and pedestrian violations. The City of Orange conducted its own study of similar pedestrian and vehicular safety issues arising from solicitation activity on its major thoroughfares, which prohibit on street parking. That study concluded that various forms of solicitation engaging vehicle drivers should be prohibited from those particular streets, in order to better promote vehicular and pedestrian safety. A copy of this study is on file and available for inspection at the office of the City Clerk. The primary goal of regulating solicitation activity in these public rights of way is to reduce driver distraction, thereby minimizing the potential of traffic collisions. Such a prohibition will assist in reducing the number of potential hazards which arise from the above noted solicitation activity. It is additionally noted there are no Vehicle Code provisions which directly relate to the public safety hazards arising from solicitation activity on sidewalks on the types of specific streets discussed in this report, or referred to in the draft ordinance. The ordinance is limited in scope, restricting solicitation on a small percentage of street/sidewalk area, thereby allowing ample opportunity for solicitors on numerous other streets. More specifically, the City's traffic engineer has calculated that the percentage of streets/sidewalks subject to the solicitation restrictions of the proposed ordinance amount to approximately only 1.3% of the total mileage of streets/sidewalks within the entire City. 2. Regulation of Solicitation on Commercial Private Property Staff is recommending that the Tustin City Code be amended to address complaints from commercial property owners concerning various forms of unwanted forms of solicitation activity occurring on their property. At present, the Tustin City Code does not address the issue of unauthorized persons conducting various forms solicitation on private commercial property. There is a provision of the Penal Code which very generally addresses trespass by persons on private property. However, the Penal Code provision is generally not suitable to address private owner complaints over transitory solicitation acts at strip malls or larger sized shopping centers. In addition, technical First Amendment issues exist with respect to the application of the Penal Code prohibition of trespass on private property for certain larger sized commercial properties which have qualified for First Amendment activity (e.g., petition gathering) under case law decisions. The City Attorney's Office has advised that a more efficacious approach to the issue is to adopt a provision which essentially prohibits various forms of unwanted solicitation on private commercial property wherein the owner has posted a "No Solicitors Sign". Such Proposed Ordinance Regulating Various Forms of Solicitation May 1, 2012 Page 5 of 7 municipal ordinances have been used in other cities and have been supported by legal case decisions as noted in the attached City Attorney opinion. Under this approach, a commercial property owner would post a "No Solicitors Sign" consistent with the signing requirements provided in the ordinance. (Section 5818(b).) Once the sign is posted, an owner would advise an unwanted solicitor to leave the property. Special signing requirements are provided for larger shopping center properties to comply with technical First Amendment requirements. (Section 5818(c)(1).) Any commercial property owner complying with the signing requirements of the ordinance could request the City to assist in the enforcement of a posted "No Solicitors" sign if a violator refused to leave the property upon request by the owner. If a violation occurred, or continued to occur, the property owner could call the Police Department for assistance. At that point, a solicitor could be cited for a violation. The recommended ordinance provision is based upon the following factual background: In 2011, Tustin Police Department responded to approximately 250 documented community generated calls for service where the complaints were related to financial solicitation, employment solicitation, product sales, distribution of literature, and soliciting for signatures. It has been reported that solicitors have been aggressive towards customers; they have been known to follow customers to their vehicles and have been abusive towards patrons. In addition, the location of where they conduct solicitation, their set-up, and/or conduct often interferes with business operations. In addition, Chapter 8 of Article 5 of the municipal code has been drafted to incorporate and consolidate all of the city's regulations governing various forms of solicitation which are now found at Part I (Regulation of solicitation in public rights of way), Part 11 (Regulation of commercial and charitable solicitation), and Part III (Regulation of aggressive solicitation) of this draft ordinance. 3. Regulation of Residential Solicitation Staff is recommending that Tustin City Codes 5810 - 5818 be added to Chapter 8 of Article 5 of the Municipal Code for the purpose of promoting the public health, safety, and welfare of residents and property owners from fraud, misrepresentation, robbery, theft, and other criminal acts which can arise from unregulated solicitation. The Tustin Police Department has found that persons and organizations have been visiting and continue to visit private residential properties for the purposes of soliciting goods, wares, merchandise, services, funds or contributions. In 2011, the Tustin Police Department responded to over 60 calls for service relating to subjects soliciting door to door in residential communities. Proposed Ordinance Regulating Various Forms of Solicitation May 1, 2012 Page 6 of 7 In recent years there have been many documented cases in California and throughout the nation where residents were victims of heinous crimes including rape, robbery, and murder in which the perpetrators were persons claiming to be solicitors and committed the crimes in the victim's place of residence. As such, unregulated residential solicitation provides opportunity and a guise for the criminal element in society. This regulation requires solicitors to obtain a permit prior to soliciting within residential communities in the City. The permit process requires each person over the age of 18, who desires to solicit in residential locations, to submit an application along with a receipt of submission of livescan fingerprints. The fingerprint process queries a national database and will provide details on any criminal activity related to the subject, which have occurred in any of the 50 states. The Finance Department will continue to process the applications but the applications must be approved by the Police Department prior to the issuance of the permit. Concurrently with the second reading and adoption of Ordinance No. 1412, staff will recommend the adoption of a Resolution establishing the application fee, which is based on the actual time used by personnel to process the application. CHAPTER 3, ARTICLE 6, PART V — TRESPASS ON PRIVATE COMMERCIAL PROPERTY 4. Regulation of Tresr)assina on Commercial Properties During Non-Business Hours Staff is recommending that Tustin City Code section 6350 be added to Chapter 3 of Article 6 of the Tustin City Code for the purpose of prohibiting any person from trespassing upon private commercial property during non-business hours. This section provides for a signing approach wherein a private commercial property owner may sign the property to prohibit a person's presence on the property during non-business hours. The signage would meet size and content requirements under Section (c). This ordinance addition is based upon the following: the Tustin Police Department has received complaints on an annual basis related to subjects sleeping, camping, or being on private commercial property during non-business hours. On several occasions, employees have arrived at work and encountered a subject sleeping in a conspicuous location on the property or blocking the entrance to the building. There have also been many complaints where specific locations on the property emit a strong odor of human waste and an abundance of trash being left behind on the property. Oftentimes, the same subjects are contacted under the same circumstances at different locations in the City. The City of Tustin does not currently have a City Code provision governing trespass activity on commercial property and the Penal Code does not provide suitable options, allowing for necessary enforcement by Police Department personnel. Proposed Ordinance Regulating Various Forms of Solicitation May 1, 2012 Page 7 of 7 In 2011, Tustin Police officers responded to over 15 documented calls for service related to the matters indicated in the above paragraph. The goal of this ordinance is to increase safety in the community and minimize the decay of property caused by human waste and litter. This will reduce the negative effects on the local business complexes, reduce repeat calls for service, and hold those, who are in violation, accountable for their actions. CHAPTER 3, OF ARTICLE 5, PART IV — SKATEBOARD REGULATIONS 5. Regulation of Skateboarding on Private Property Staff is recommending that the City Code be amended to prohibit skateboarding on any commercial property which has been signed to prohibit such activity. Section 5343(a) of the Code would be amended to prohibit any person from skateboarding on any commercial property where the property owner has posted appropriate signage as specified in the ordinance. (See Section 3 of the ordinance.) The basis for this recommendation is as follows: Over the years, the Tustin Police Department has received hundreds of complaints regarding subjects skateboarding on private property. In 2011, the Tustin Police Department responded to over 50 citizen- generated complaints related to skateboarders. Many businesses and property owners complain because of the damage it causes to the property. Currently, the City does not have a City Code provision that regulates skateboarding on private commercial property. An officer's response is only a short-term resolution since the violators often return at another time or move to another property within the City. Creating an ordinance that regulates this behavior will provide enforcement as an option when responding to such complaints. It is our goal to assist property/business owners to protect their property and hold violators accountable for their actions. SCOTT M. JOWAN Chief of Police; I/ CH RLIE CELANO Captain Attachment 1: Consolidated Solicitation anc 1412) Attachment 2: City Attorney Legal Opinion Attachment 3: City of Orange Ordinance — Public and Private Property Trespass Ordinance (Ordinance No. Title 9, Chapter 9.37 Solicitation from AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF TUSTIN AMENDING VARIOUS SECTIONS OF THE TUSTIN CITY CODE RELATING TO THE REGULATION OF SOLICITATION ACTIVITY AND ACTS OF TRESPASS OCCURING ON COMMERCIAL PROPERTIES City Attorney Summary This ordinance amends the Tustin City Code by establishing regulations which: prohibit solicitation activity at those public rights of way where street parking is prohibited; requires a solicitor's permit for solicitors conducting commercial or charitable solicitation in residential areas of the city; prohibits solicitation activity on commercial property wherein the property owner has posted a "no solicitor's sign". In addition, the ordinance prohibits trespass on commercial properties during non-business hours and prohibits skateboarding on commercial properties. The City Council of the City of Tustin hereby ordains as follows: SECTION I. Code Amendment Relating to Solicitation Activities Chapter 8 of Article 5, "Public Safety" is hereby amended in its entirety to read as follows: CHAPTER 8. REGULATION OF SOLICITATION ACTIVITY PART I. Regulation of Solicitation Activity in Public Rights of Way 5800 Findings and Intent The City Council finds that it is necessary to regulate the solicitation activity of pedestrians and motor vehicle occupants who utilize certain public rights of way based upon the following findings: (1) The City of Tustin has experienced negative secondary impacts arising out of solicitation activities of pedestrians and passing motorists who utilize certain public rights of way as documented in a Police Department report provided to the City Council. These impacts consist of traffic hazards caused by: the distraction of automobile drivers observing solicitation activity or otherwise stopping or slowing in traffic lanes; Ordinance No. 1412 Page 1 of 11 solicitors' physical obstruction of vehicular traffic flow by walking randomly into streets to solicit passing motorists. Additional problems emanating from this solicitation activity include littering, public urination, interference with pedestrian access to public sidewalks, and interference with on-site commercial business operations. These secondary impacts are found to be a nuisance condition requiring reasonable restrictions to mitigate potential impacts from such nuisance conditions. (2) The City Council takes notice of the fact that other local municipalities, such as the cities of Orange and Newport Beach, and nationwide have experienced similar impacts from solicitation in public rights of way aimed at passing motorists. The City of Orange conducted an extensive analysis of such impacts in a study and report to the City Council resulting in the enactment of an ordinance which establishes City of Orange regulations restricting solicitation activity at certain public rights of way. The Orange ordinance makes specific findings that solicitation on public rights of way, upon which vehicle parking is prohibited or restricted, causes significant traffic hazards. That analysis and ordinance provides a further factual basis to support the enactment of regulations restricting solicitation activity in certain public rights of way as further set forth in this chapter. 5801 Definitions As used in this Chapter, the following words and phrases shall have the following meanings: "Charitable solicitation activity" means commercial sales or requests for charitable contributions on behalf of a nonprofit organization, including e.g., patriotic, philanthropic, social services, welfare, benevolent, educational, religious, civil, or fraternal, either actual or purported. "Commercial property" means any real property held, owned, or controlled by private interests and which is zoned by the city for any form of business enterprise, including but not limited to, retail, office, commercial, or industrial, or recreational purpose. "Contribution" means the giving of anything of value, including money, property, or any type of financial assistance, or the pledging of anything of value, including money, property, or other type of financial assistance, or the purchasing or offering to purchase anything of value, including, but not limited to goods, services, books, real property, pamphlets, tickets, or subscriptions to publications. Ordinance No. 1412 Page 2 of 11 "Employment" shall mean services, industry or labor performed by a person for wages or other compensation or under contract of hire, whether written, oral, expressed or implied. "Occupants of motor vehicles" shall mean the driver and passengers of the vehicle. "Person" means any individual, firm, partnership, joint venture, association, social club, league, fraternal organization, joint stock company, estate, trust, corporation, or any other group acting as a unit. "Solicit", "solicitation", or "solicitation activity" shall mean and include, but not limited to any request, offer, enticement, or other action which announces the availability of employment, the sale of goods, services, or requests for funds, petition gathering; or any request, offer, enticement or action which seeks to purchase or sell goods, or to cause a contribution of money or other property to be made. As defined herein, a solicitation shall be deemed complete when made whether or not an actual transaction of any type is completed, or exchange of money, including charitable contributions, takes place. 5802 Prohibited Solicitation Activity (a) Solicitation Prohibited When Conducted From Sidewalks and Driveways Where Vehicle Parking Is Not Legally Permitted. It shall be unlawful for any person, while standing in any portion of a public sidewalk or driveway, to engage in solicitation activity with any person traveling in a vehicle along any public street or highway which has been designated by the City as a as a prohibited parking area or no parking zone. (b) Solicitation Prohibited When Conducted Within Public Streets and Medians. It shall be unlawful for any person while standing within any public street or highway or public median to engage in solicitation activity with any person in a vehicle in the public right of way, including but not limited to, a public street, highway, sidewalk, or driveway. (c) Prohibition Of Solicitation By Occupants Of Vehicles. It shall be unlawful for any occupant of a vehicle to engage in solicitation activity with a person who is within a public street or highway which has been designated by the City as a prohibited parking area or no parking zone. 5803 Posting of Signs The City shall post signs in the public right of way to notify the public of the prohibitions of Section 5802. Ordinance No. 1412 Page 3 of 11 PART III. Regulation of Residential Solicitation Activity RM991HUM 5817 Regulation of Solicitation in Residential Areas (a) Specific Requirements. No person shall solicit in any of the residential zoned areas of the City: 1 Between the hours of 6:00 p.m. and 8:00 a.m., unless done by appointment; 2. At any house, apartment, or other dwelling to which is affixed a sign indicating "No Solicitors" or similar indication that no solicitation is desired by the occupants thereof; 3. At any house, apartment, or other dwelling within a homeowner's association that maintains private streets where the homeowner's association has posted on each vehicular entry way to the property a notice in substantially the following form: "No Solicitors", or similar indication that no solicitation is permitted by occupants thereof. 4. By using profane or abusive language or making verbal threats, during the solicitation; 5. By stepping onto or over the threshold of a doorway, unless invited to do so by the occupant; 6. By placing hands, legs, or any portion of the solicitor's body in the doorway so that it reasonably appears that the door may not be closed, unless allowed to do so by the occupant; 7. By refusing to immediately leave the solicited premises when asked to do so by any occupant; or 8. By knowingly making false statements or misrepresentations about the purpose of the solicitation. (b) Receipts. Any person receiving money or anything of value in excess of five dollars ($5.00) from any contributor by means of a solicitation shall, upon request, give such contributor a written receipt showing the name and address of the solicitor, the date, and the amount received. (c) Compliance With State and City Charitable Laws. Prior to and while engaging in solicitation in any residential area of the City, every person shall fully comply with all applicable state laws, including the provisions of the California Charitable Disclosure Law as set forth in the California Business and Professions Ordinance No. 1412 Page 4 of 11 Code sections 17510 et seq. and the charitable solicitation permit requirements in Tustin City Code section 2513(f). 5818 Regulation of Solicitation Conducted on Commercial Property (a) Findings and Intent. The City has received a growing number of complaints from certain merchants and business patrons that solicitors have engaged in a variety of commercial and non-commercial solicitation activity on private commercial property without the owner's consent. This solicitation activity can have the effect of impeding the free movement of citizen patrons, and otherwise cause noise and physical obstruction which detracts from a conducive commercial environment. (b) Prohibition. It is unlawful for any person to solicit in or upon any commercial property within the City when such property is affixed with signage stating "NO SOLICITORS", or similar statement to the effect that solicitation is not permitted on the property, or is otherwise permitted only in restricted areas of the property. (c) Signage Requirements (1) Excepting commercial property containing communal areas, the property owner shall post a "No Solicitors" sign of a size not less than 22 inches by 17 inches, with lettering of at least one inch in height, at each vehicular entry point to the property. (2) For commercial property containing communal areas, the property owner shall post signs stating that: "Solicitation of any type is permitted only in designated areas of this Commercial Property. Violators are subject to prosecution pursuant to Tustin City Code section 5818(b). Contact the property manager for a permissible solicitation location." The signing shall be located at prominent entry point(s) of the property, and at such other locations which have been designated by the property owner as permissible solicitation locations. The size of the signs shall be not less than 22 inches by 17 inches with lettering of at least one inch in height. For purposes of this section, "communal areas" shall mean such areas set aside by the owner in which the public may engage in such matters as discourse, recreation, or entertainment separate and apart from commercial patronage occurring at business establishments. Examples of communal areas are seating areas, plazas, or large walking areas. Restaurant seating restricted to particular patronage does not constitute communal areas of the center. Ordinance No. 1412 Page 5 of 11 PART Ill. Prohibition of Aggressive Solicitation and Solicitation at Certain Locations 5830 Purpose and Intent The City Council finds that it is necessary to protect citizens from the fear and intimidation accompanying aggressive solicitation and all solicitation in certain confined areas. Aggressive solicitation may include approaching or following pedestrians, repetitive contact, or the intentional blocking of pedestrian and vehicular traffic. 5831 Aggressive Solicitation Prohibited No person shall solicit, ask or beg in an aggressive manner in any public place. 5832 All Solicitation Prohibited At Specified Locations (a) City Parking Structures. Any act of solicitation is prohibited in any City public parking lot or parking structure. (b) Restrooms. No person shall solicit, ask, or beg in any public restroom or within twenty five (25) feet of the entrance to a public restroom. (c) Banks and ATMs. No person shall solicit ask or beg within twenty five (25) feet of any entrance or exit of any bank, savings and loan association, credit union, or check cashing business during its business hours or within twenty five (25) feet of any automated teller machine during the time it is available for customers use. Provided, however, that when an automated teller machine is located within an automated teller machine facility, such distance shall be measured from the entrance or exit of the automated teller machine facility. Provided further that no person shall solicit, ask or beg within an automated teller machine facility where a reasonable person would or should know that he or she does not have the permission to do so from the owner or other person lawfully in possession of such facility. Nothing in this paragraph shall be construed to prohibit the lawful vending of goods and services within such areas. (d) A marked bus stop; (e) Public transportation vehicles or facilities. 5833 Definitions In construing the provisions of this Part, the following definitions shall apply: Ordinance No. 1412 Page 6 of 11 "Aggressive manner" shall mean any of the following: 1 Approaching or speaking to a person, or following a person before, during or after soliciting, asking or begging, if that conduct is intended or is likely to cause a reasonable person to: (i) fear bodily harm to oneself or to another, damage to loss of property, or (ii) otherwise be intimidated into giving money or other thing of value; 2. Intentionally blocking or interfering with the safe or free passage of a pedestrian or vehicle, by any means, or the blocking or interfering with pedestrian or vehicular access to any building, including unreasonably causing a pedestrian or vehicle operator to take evasive action to avoid physical contact or to gain entrance to a building; 3. Intentionally touching or causing physical contact with another person or an occupied vehicle without that person's consent in the course of such soliciting, asking, or begging; 4. Using violent or threatening gestures toward a person solicited either before, during, or after soliciting, asking, or begging; 5. Persisting in closely following or approaching a person, after the person has been solicited and informed the solicitor by words or conduct that such person does not want to be solicited or does not want to give money or any other thing of value to the solicitor; or 6. Using profane, offensive or abusive language which is inherently likely to provoke an immediate violent reaction, either before, during, or after solicitation. "Public place" shall mean a place to which the public or a substantial group of persons has access, and includes, but is not limited to, any street, highway, sidewalk, public parking lot, plaza, transportation facility, school, place of amusement, park, playground, and any doorway, entrance, hallway, lobby, and other portion of any business establishment, an apartment house, or hotel not constituting a room or apartment designed for actual residence. Ordinance No. 1412 Page 7 of 11 "Solicitation" shall have the same meaning set forth in Tustin City Code Section 5801. PART IV. Violations 5840 Misdemeanor/Infraction Any violation of the provisions of this chapter may be prosecuted as an infraction or misdemeanor pursuant to section 1121, of Part 11, of Chapter 1 of the Tustin City Code. Violations may also be punished by other penalty, citation, and administrative citation process provided for in Chapter 1 of Article 1. SECTION 11. Code Amendment Relating To Regulation of Trespassing Activities on Private Commercial Properties PART 5, entitled "Trespass on Private Commercial Property" is hereby added to Chapter 3, "Disorderly Conduct" of Article 6, "Public Welfare" to read as follows: PART 5 Trespass on Exterior Premises of Commercial Property 6350 Remaining on Exterior Premises When a Business is Closed (a) Findings and Intent. The City has received complaints from business owners that individuals enter upon and remain overnight on the exterior portion of their private commercial property without owner consent. This transient occupation leads to health and safety impacts on properties including urination and the leaving of waste and debris. This section is intended to prohibit such transient overnight occupation when owners post appropriate signage on their properties in accordance with this section. (b) Prohibition. It shall be unlawful for any person to remain upon the exterior premises of any private commercial property, including any parking area, when the business is closed, and the property is posted with at least one sign at a pedestrian entry point prohibiting the presence of any person on the property during non-business hours. "Private commercial property" means any real property held, owned, or controlled by private interests and which is zoned by the City for any form of business enterprise, including but not limited to, retail, office, commercial, industrial, or recreational purpose. (c) Signa-ge. The sign shall be a minimum size of 17 inches by 22 inches and shall state: Ordinance No. 1412 Page 8 of 11 I .. WIT AT 111111:011119 MUM 1 0 M Entrance to this property is limited to patrons only. It is a trespass and violation of law to remain on this property during non-business hours. (Tustin City Code section 6350(b)) Business Hours are: insert hours (d) Scope and Application. This section shall not apply to any person who has a bona fide intent to exercise an established constitutional right. SECTION 3. Code Amendment Relating to Skateboard Regulations Tustin City Code section 5343, "Skateboard Regulations", of Part 4, of Chapter 3, of Article 5 of the Tustin City Code is amended in its entirety to read as follows: 5343 Regulation of Skateboarding on Private Property, Designated Public Property, and City Streets. (a) Private Property. It shall be unlawful for any person to engage in skateboarding on any commercial property in the City in which the owner, lessee, or operator of such property has posted at least one sign stating: "SKATEBOADING IS PROHIBITED ON THIS PROPERTY PURSUANT TO TUSTIN CITY CODE SECTION 5343." The size of the sign shall be not less than 22 by 17 inches with lettering not less than one inch in height. The sign shall be posted in plain view in at least one (1) prominent location on the property. "Skateboarding" is defined to mean a board of any material which has wheels attached to it and which is propelled or moved by human movement, or mechanical power. "Private commercial property" shall have the same meaning as stated in Tustin City Code section 6350(b). (b) Public Property. It shall be unlawful for any person to engage in skateboarding in or on any city public parking structure, or on or within the City Civic Center/Library complex property. (c) Streets and Public Highways. It shall be unlawful for any person to skateboard on any City street or public highway within the City. This prohibition Ordinance No. 1412 Page 9 of 11 shall not extend to include city sidewalks. Skateboards shall yield the right of way to pedestrians at all times. SECTION 4. Severability. If any section, subsection, sentence, clause, or phrase of this ordinance is for any reason, held to be invalid or unenforceable, such decision shall not affect the validity or enforceability of the remaining portions of this ordinance. The City Council declares that it would have passed this ordinance, and each section, subsection, clause or phrase hereof, irrespective of the fact that any one or more sections, subsections, sentences, clauses, and phrases be declared invalid or unenforceable. SECTION 5. Repealer (a) Chapter 10 "Charitable and Commercial Solicitations", of Article 5 "Public Safety" of the Tustin City Code is hereby repealed in its entirety. (b) Chapter 11 "Prohibition Against Certain Forms of Aggressive Solicitation" of Article 5 "Public Safety" of the Tustin City Code is hereby repealed in its entirety. (c) Chapter 7, "Solicitation in Private Commercial Parking Areas", of Article 6, "Public Welfare" of the Tustin City Code is hereby repealed in its entirety. Ordinance No. 1412 Page 10 of 11 PASSED AND ADOPTED, at a regular meeting of the City Council of the City of Tustin on this 15th day of May, 2012. JOHN NIELSEN, MAYOR PAMELA STOKER, City Clerk STATE OF CALIFORNIA ) COUNTY OF ORANGE ss. CITY OF TUSTIN CERTIFICATION FOR ORDINANCE NO. 1412 PAMELA STOKER, City Clerk and ex-officio Clerk of the City Council of the City of Tustin, California, does hereby certify that the whole number of the members of the City Council of the City of Tustin is five; that the above and foregoing Ordinance No. 1412 was duly and regularly introduced and read at the regular meeting of the City Council held on the _ day of _, 2012, and was given its second reading, passed and adopted at a regular meeting of the City Council held on the _ day of 2012, by the following vote: COUNCILPERSONS AYES: COUNCILPERSONS NOES: COUNCILPERSONS ABSTAINED: COUNCILPERSONS ABSENT: PAMELA STOKER, City Clerk =011M M-6 Ordinance No. 1412 Page 11 of 11 ATTACHMENT 3 t yjAlvj WOODRUFF, SPRADLIN & SMART 555 ANTON BOULEVARD, SUITE 1200 COSTA MESA, CA 92626-7670 (714) 558-7000 DIRECT DIAL: (714) 415-1083 DIRECT FAX: (714) 415-1183 E-MAIL: dkendig@wss-law.com MEMORANDUM HAND DELIVERED TO: Jeffrey C. Parker, City Manager FROM: David E. Kendig DATE: April 17, 2012 RE: Legal Opinion Concerning Proposed Solicitation Ordinance In working with your office in updating various ordinance provisions relating to various forms of commercial and charitable solicitation activity, this opinion is provided to address the constitutional validity of the proposed solicitation ordinance amendments. The proposed ordinance addresses commercial solicitors in certain public rights of way, establishes a formal solicitor's permit requirement for commercial and charitable solicitors, regulates solicitors on private commercial properties, regulates itinerant trespassing and skateboarding on private property. The draft ordinance also consolidates all solicitor regulations into one chapter of the municipal Code. More specifically, the ordinance: (1) prohibits solicitation activity at those public rights of way wherein street parking is prohibited. [§§ 5800-5803]; (2) establishes a solicitor's permit requirement for solicitors conducting commercial or charitable solicitation activity in residential areas of the city; [§5811] (3) prohibits solicitation activity on commercial property wherein the property owner as posted appropriate "No Solicitors" signage. [§ 5818]; (4) prohibits trespass on commercial properties during non-business hours wherein the property owner has posted appropriate "No Trespass" signage. [§ 6350 of Section 2 of the Ordinance] (5) prohibits skateboarding on commercial properties wherein the property owner has posted appropriate "No Skateboarding" signage. [§ 5343 of Section 3 of the ordinance] (6) consolidates all solicitation regulations affecting solicitation activity into chapter 8 of the Municipal Code. 852037.1 Jeffrey C. Parker, City Manager April 17, 2012 Page 2 T. General Overview of the City's Police Power Supporting Municipal Regulation of Commercial and Charitable Solicitors. (a) Regulation of Solicitation Activity in Public Places. Municipal regulation of solicitation has long been recognized to be within each city's police power, Los Angeles Alliance for Survival v. City of Los Angeles (2000) 22 Cal. 4 352, 378. The municipal police power is set forth in Article XI, section 7 of the California Constitution which confers the power to "make and enforce all local police, sanitary, and other ordinances not in conflict with general laws." The police power is an elastic power. It allows cities to tailor regulations to suit the interests and needs of a "modem, enlightened and progressive community" even as those interests and needs change. Rancho La Costa v. County of San Diego (1980) 111 Cal. App. 3d 54, 60. Further, cities may adopt regulatory schemes affecting First Amendment rights to remove the potential for secondary adverse effects before they arise. Sundance Saloon, Inc. v. City of San Diego (1 989) 213 Cal. App. 3d 807, 821. However, solicitation activity involving elements of free speech activity is subject to First Amendment protection under the United States Constitution. Los Angeles Alliance far Survival et al. v. City of Los Angeles, supra; Acorn v. City of Phoenix (1 986) 798 F.2d 1260; Doucette v. City of Santa Monica, 955 (1997) F.Supp. 1192; Gaydi a Vaishnava Soc. v. San Francisco (1990) 952 F.2d 1059. Governmental regulations affecting speech activity located within traditional public places such as streets and sidewalks, including expressive activity intertwined with commercial conduct, are treated by case law decisions as "time, place, and manner" restrictions, and are subject to the following constitutional legal test: (i) Whether the regulation is content neutral; (ii) Whether it is narrowly tailored to serve a significant governmental interest; (iii) Whether it leaves open ample alternative channels of communication. If a government regulation affecting First Amendment speech activity is "content neutral", judicial decisions further provide that an "intermediate scrutiny" standard shall be applied to test the constitutional validity of the regulation. The intermediate scrutiny standard focuses in part upon whether the regulation is narrowly tailored to serve a significant governmental interest. A content neutral regulation need not necessarily utilize the least restrictive available means of regulation. Doucette v. City of Santa Monica., supra. A regulation is content neutral if it is justified without reference to the content of regulated speech, or otherwise is not enacted for the purpose of disagreement with the content of the expression. Cincinnati v. Discovery Network (1 993) 507 U.S. 41 0; Los Angeles Alliance for Survival et al, v. City of Los Angeles, supra. The following forms of solicitation have been held to receive First Amendment protection: speech activity involving social, economic, and political causes, various forms of commercial activity tied directly or indirectly to expressive activity, panhandling, and 852037.1 Jeffrey C. Parker, City Manager April 17, 2012 Page 3 solicitation for work. Gaudiya Vaishnava v. San Franciso., supra; Los Angeles For Survival et al. v. City of Los Angeles, supra. Several federal and state appellate decisions have upheld some forms of city regulation of solicitation conduct on public sidewalks where the public entity in question presented some form cogent evidence suggesting that the regulation served a beneficial public policy purpose and was narrowly tailored to achieving that public interest. (See Acorn v. City of Phoenix (1 986) 798 F. 2d 1260 [upholding a ban on aggressive solicitation within streets]; One World Family Now v. City of Honolulu (1 996) 76 F. 3d 1009 [upholding a city wide ban against the sale of vendor merchandise on public sidewalks]; Juan Xiloj-Itzep et al. City of Agoura Hills (1 994) 24 Cal. App. 4 620 [upholding a city prohibition against solicitation for work within public rights of way]. However, the Ninth Circuit Court of Appeals recently held in Comite De Jornales De Redondo Beach v. City of Redondo Beach (9th Cir. 2011) 657 F.3d 936 that a "day laborer" solicitation ordinance, prohibiting "solicitation of employment, business, or contributions" from passing motorists by sidewalk solicitors, to be a violation of the First Amendment. The Redondo Beach ordinance was a cfty-wide ban against all day laborer solicitation occurring on any city sidewalk. The Ninth Circuit reasoned that the ordinance did not meet the "narrowly drawn" legal standard because the ban was city wide, and the city offered no factual justification to justify such a broad legal prohibition. (b) Regulation of Solicitation Activity on Private Commercial Properties. Federal law decisions have supported narrowly drawn municipal ordinances which prohibit solicitation on private property when the private property owner has posted a "No Solicitors" sign. Project 80's, Inc. v. City of Pocatello (1 991) 942 F.2d 63 5; Watchtower Bible &Tract Society of N. Y v. Village of Stratton (536 U.S. 150 (2002); Van Nuys Publishing Co. v. City of Thousand Oaks (1971) 5 C.3d 817. No First Amendment rights are implicated in this factual context; that is, there is no First Amendment right under federal constitutional law to engage in "expressive activity" at, for example, a privately owned shopping centers. Hudgens v. NLRB (1976) 424 U.S. 507; Van, et al. v. Home Depot, USA (2007) 155 Cal. App. 4 1375. However, in California, the California Supreme Court has held in Pruneyard Shopping Center v. Robins (1979) 23 Cal.3d 899 that where larger sized commercial mall areas include significant "communal areas", First Amendment free speech protection is applicable to expressive activity, like petition gathering, even though it occurs on private property. In the Pruneyard case, the California Supreme Court found that a 23 acre shopping mall containing significant communal areas such as walkways, sitting areas, and plazas amounted to a functional equivalent of a traditional downtown center business district. Because the mall had become a quasi public forum, the Court held that the California Constitution required that the private property owner allow at least some limited opportunity for persons to, for example, collect petition signatures for social causes. Under the Pruneyard case holding, and subsequent case holdings, the property owner is free to adopt reasonable regulations restricting such expressive conduct to limited location(s) within the shopping center property. See Trader's Joe Co. v. Progressive Campaigns, Inc. (1 999) 73 Cal. App. 4 425; Albertson's Inc v. Young (2003) 107 Cal. App. 4 106; Van v. Home Depot (2003) 155 Cal. App. 4 th 1375. 852037.1 Jeffrey C. Parker, City Manager April 17, 2012 Page 4 11. The Proposed Tustin Ordinance. (a) Sidewalk Solicitation. Section 5802(b) of the proposed ordinance prohibits all forms of solicitation at just those street and sidewalk locations on which on-street parking is not allowed. The police department has presented evidence of traffic hazards which would arise at such locations. It is our opinion that the ordinance provision satisfies First Amendment constitutional requirements because: (1) the regulation is content-neutral on its face. It applies to all forms of solicitation. Further, it focuses simply on physical conduct which has the effect of endangering the safety of pedestrian and vehicular traffic; (2) the prohibition is narrowly tailored to advancing the governmental interest of citizenry safety in that it only applies to a small number of streets in the City, namely, those streets with prohibited on-street parking requirements. In those particular areas, danger to vehicular traffic and pedestrians arises from the slowing, or stopping, of vehicular movement due to solicitation activity as noted by the Police Department report; and (3) ample alternative opportunities for solicitation are available, such as the vast majority of sidewalk locations where on-street parking is not prohibited, door to door solicitation, newspaper and internet advertizing. It is further noted that the proposed ordinance is far less restrictive than the solicitation ordinance invalidated in the Comite De Jornaleros De Redondo Beach v. Redondo Beach case because that ordinance affected all commercial and residential streets throughout that city. (b) Licensing of Solicitors. Part 11 of the ordinance, specifically sections 5810-5816 establish a permit requirement which prohibits commercial and charitable solicitation in residential areas unless a solicitor's permit is first obtained from the City. The public safety purpose of this licensing requirement is to allow for an initial criminal background check on solicitors seeking to solicit commercial transactions, or requests for charitable donations, to reduce the threat of fraud and theft. Such licensing requirements are been consistently upheld by state and federal judicial decisions. Perlman v. Mun.Ct., (1979) 99 Cal. App. 3d 568, 577; Village of Schaumburg. v. Citizens for a Better Environment (1 980) 44 U.S. 620. (c) Solicitation On Private Property. Section 5818(b) of the ordinance permits the City of Tustin to enforce a trespass prohibition against unwanted solicitations of any type on private commercial properties. Section 5818(b) prohibits solicitation of any kind on private commercial property if the owner has posted a prescribed "No Solicitors" sign on the property. As noted above, case law has approved of this statutory approach. (Project 80's, Inc. v. City of Pocatello, supra.) Section 5818(c) also addresses the Pruneyard issue by providing that owners of larger sized commercial properties, which include the "communal" areas and activities described in the 852037.1 Jeffrey C. Parker, City Manager April 17, 2012 Page 5 Pruneyard case, may also post a "No Solicitors" sign, providing that the property owner has set aside an area of the property for First Amendment protected expressive activity. The signage requirements of section 5818(c)(2) reflect this approach by providing that solicitation activity is permitted only in designated areas of the property. The signage must state "contact the property manager for a permissible solicitation location". (d) Other provisions. The trespass prohibition on commercial properties during non- business hours, and restrictions against skateboarding on private property and certain public owned properties, fall well within the City's police power under the cases cited in the discussion Section L(a) above. Conclusion. The components of the proposed ordinance described above fall within the City's police powers under Article XI, Section 7 of the California Constitution. Further, they are consistent with First Amendment case law requirements discussed herein. I hope this proves helpful. If you have any questions, please do not hesitate to call me. Woodruff, Spradlin & Smart, APC By: David E. Kendig v City Attorney 852037.1 FAVO 141 Title 9 - PUBLIC PEACE, MORALS AND WELFARE Chapter 9.37 - SOLICITATION FROM PUBLIC AND PRIVATE PROPERTY Chapter 9.37 - SOLICITATION FROM PUBLIC AND PRIVATE PROPERTY Sections: 9.37 x;10 - eurLiose oft his Chapter, 9.317,020 - Definitions 937,030 - Prohibitions. 91�37,040 - �Ex� 9,37,050 - Resource Center Re ula inns, 9.37 060 - Penalty, 9.37.010 - Purpose of this Chapter. Large congregations of day laborers at informal day labor sites have for many years, if not decades, blocked and obstructed the public's use of public rights-of-way, interfered with the use and enjoyment of private property by private property owners, created traffic hazards and have caused other negative impacts and therefore constitute a public nuisance. In addition, solicitations for the exchange of money, property or employment services directed from or toward motorists traveling on City streets impede the free flow of traffic and create traffic hazards on those streets where there is no on-street parking. It is the intent of this chapter to remove obstructions for the safe passage of motorists and pedestrians on the streets and sidewalks, to minimize the interference with the use and enjoyment of private property caused by solicitation, to encourage the use of the Resource Center and other hiring centers, and to encourage more formal and orderly alternative means for solicitation to minimize the negative secondary impacts. The City Council finds that regulations are needed to prohibit day laborer solicitation in public areas near the Resource Center and private property hiring centers to increase their utilization and to minimize negative secondary effects to nearby properties caused by day labor activity in and around formal hiring centers. The following regulations are content neutral and impose reasonable time, place and manner regulations on solicitation from public rights-of-way and commercial parking lots. (Ord. 19-07) 9.37.020 - Definitions. For purposes of this chapter the following definitions shall apply: A. CITY PROPERTY means and includes any City street, highway, sidewalk, easement or other City property that is not specifically designated for off-site soliciting activities. B. CITY STREET means all portions of a roadway used by motor vehicles for travel or parking, including any medians lying within such roadways. C. COMMERCIAL PARKING LOT means privately owned property that is designed or primarily used by customers of the property owner for parking, ingress and egress. D. DAY LABORER SOLICITATION means and includes any action by a person to announce his Orange, California, Code of Ordinances Page 1 of 3 Title 9 - PUBLIC PEACE, MORALS AND WELFARE Chapter 9.37 - SOLICITATION FROM PUBLIC AND PRIVATE PROPERTY availability for employment to persons operating motor vehicles or by a person operating a motor vehicle to offer employment to a pedestrian. E. SOLICITATION or SOLICIT means and includes any request, offer, enticement, or similar action by an individual to advertise or announce his availability for employment, to offer employment, to sell or purchase goods, property or services or to seek or make contributions of money or property, that is intended to consummate a physical exchange of money and/or property between a motorist and pedestrian or entry by a pedestrian into a vehicle. A solicitation shall constitute a violation of this chapter when made whether or not an actual employment, sale, purchase or contribution transaction is completed. F. PUBLIC RIGHT-OF-WAY means and includes any street, highway, driveway, parkway or sidewalk within the City limits. G. PROPERTY OWNER means the fee owner of the property, the property owner's authorized agent, any tenant in lawful possession of the property and/or the tenant's authorized agent. H. RESOURCE CENTER means the City's day labor hiring center located on McPherson Road in the City of Orange. (Ord. 19-07) 9.37.030 - Prohibitions. A. No person shall solicit from any public sidewalk that is immediately adjacent to any City street or highway upon which a motorist cannot legally park. B. No person shall, while operating a motor vehicle on or along a City street, solicit from the motor vehicle unless the motor vehicle is legally parked. C. No person shall, from a location on any private property engage in solicitation absent the express written permission of the property owner. 1. For this subsection, to become operative the property owner shall either notify the City's Police Department in writing that solicitation is not permitted on their property and the location of such property, orally inform a police officer that such permission has not been granted and request removal of solicitors and/or post a sign at each entrance to the property not less than eighteen (18) by twenty-four (24) inches in size with lettering not less than one inch in height and not to exceed six square feet which substantially provides as follows: It is a misdemeanor to engage in the solicitation for and of employment other than to perform the employment on or for the owner or occupants of the premises. The written no solicitation notice shall be effective until withdrawn in writing. The oral request for removal of solicitors shall be effective only for the day upon which it is given. D. No person shall solicit while stopped or standing in any through traffic lane, upon any street median or upon any driveway apron located within the public right-of-way. E. No person shall engage in day laborer solicitation on any public right-of-way that is immediately adjacent to any private property that has been issued a permit for a hiring center in accordance with Section 17.30.070 of this code. Orange, California, Code of Ordinances Page 2 of 3 Title 9 - PUBLIC PEACE, MORALS AND WELFARE Chapter 9.37 - SOLICITATION FROM PUBLIC AND PRIVATE PROPERTY F No person shall solicit from any public sidewalk in a manner that impedes pedestrian access to such public sidewalk. G. No person shall remain on any private property for the purpose of engaging in solicitation after they have been requested to leave by the private property owner. H. This chapter shall not be interpreted to relieve any person from obtaining a certificate of identification to engage in those solicitation activities governed by Chapter 5.66 of this code. (Ord. 19-07) 9.37.040 - Exceptions. A. A person may solicit from a commercial parking lot if such person has the express permission of the property owner. However, if a property owner permits five or more persons to congregate for the purpose of engaging in solicitation upon their private property, a permit issued by the City in accordance with Section 17.30.070 of this code must be obtained by the property owner. A person with the property owner's express written permission to engage in off-site solicitation shall not be liable for a violation of this chapter solely on the basis that the property owner has failed to obtain a permit. B. This chapter shall not apply to solicitations from private property to perform services that are provided upon the property from which the solicitation occurs or to sell or purchase goods from or to the subject property owner. C. This chapter shall not apply to conduct which solely involves the distribution of literature or to private property which is required by law to be open to the public for communicative purposes such as plaza areas and walkways of large shopping centers where the general public is invited to congregate. (Ord. 19-07) 9.37.050 - Resource Center Regulations. A. Persons engaged in the solicitation for employment may utilize the Resource Center for such solicitation provided that such persons abide by the rules and regulations established by the Resource Center. Persons who do not abide by such rules and regulations may be prohibited from using the Resource Center for a minimum period of three months and a maximum period of one year. B. Other than the Resource Center property, no person shall engage in any day laborer solicitation on any City property, which is located on McPherson Road between its intersection with Chapman Avenue to the south and its intersection with Spring Street to the north. No person shall engage in day laborer solicitation upon any property located within Grijalva Park or upon any public right-of-way immediately adjacent to Grijalva Park. This subsection shall only apply to those hours in which the Resource Center is open. (Ord. 19-07) 9.37.060 - Penalty. Any person violating the provisions of this chapter shall be guilty of a misdemeanor and upon conviction thereof shall be subject to fine of two hundred fifty dollars ($250.00) for the first offense, five hundred dollars ($500.00) for the second offense and one thousand dollars ($1,000.00) and imprisonment in the Orange County Jail for a term not exceeding three months for the third offense. Orange, California, Code of Ordinances Page 3 of 3 Title A' PUBLIC PEACE, MORALS AND WELFARE Chapter 9.37 - SOLICITATION FROM PUBLIC AND PRIVATE PROPERTY ([}rd. 19-07) Orange, California, Code ofOrdinances Page 4 of 3 FA V6VA T Tustin City Code section 2513 - Exemptions from Tax Payment (f) Charitable Solicitation Permits (1) No person shall solicit donations for charitable purposes within the City without first obtaining a permit from the Director for the particular solicitation and for the stated purposes and period provided therein. (2) A completed application for a permit to solicit donations for charitable purposes shall be filed with the Director prior to soliciting donations in the City and a permit issued for such solicitation. The application shall contain all of the following information: (a) The name and address of the person or organization; (b) The State Charitable Trust number;* (c) Name, address, telephone number, and birth date, along with any aliases used, of the individual in charge of the solicitation; (d) The purpose of the solicitation; (e) The type of donations to be solicited; (f) If the solicitation is for a special event, the nature of the event and the time and place of the event; (g) The anticipated beginning and ending dates of the solicitation; (h) Whether the solicitation is on behalf of an organization other than the applicant and if so, the name, address, and business telephone number of the other organization; (i) The method of solicitation to be utilized; 0) If paid solicitors are used, the total estimated cost of fundraising expenses; (k) The estimated percentage of the amount of donations which will be used for charitable purposes; (1) The names, residential addresses, and day-time telephone numbers of all officers and directors of the applicant; (m) The names, business addresses, and day-time telephone numbers of all agents, volunteers, solicitors, promoters, and managers to be involved with the solicitation; In addition, the applicant shall provide the following documents, as they apply: (a) The articles of incorporation and bylaws of corporations and bylaws of unincorporated entities; (b) The Internal Revenue Service Notice of Tax-Exempt Status; (c) The notice from the California Attorney General Registrar of Charitable Trusts confirming registration in good standing or in the case of a religious corporation sole, a Certificate of Status of Domestic Corporation from the Secretary of the State; (d) A copy of the most recent periodic report filed with the Attorney General;* (e) A copy of the solicitation or sale for charitable purposes card which must be exhibited to prospective donors pursuant to Business and Professions Code Section 17510.3;* and (f) If the solicitation is for the benefit of an organization other than the applicant, a letter from such organization authorizing applicant's solicitation. Upon submittal of the application, the Director shall verify within five (5) working days as to whether the application is complete. If complete, a permit will be issued within five (5) working days, or the City will apply to the court for an order enjoining the applicant's solicitation. If the Director determines that the application is incomplete, the applicant shall be notified within five (5) working days of such determination, along with the specific reasons therefore. The permit is valid for six (6) months. *Not applicable to a corporation solely organized for religious purposes. (Ord, No, 1270, Sec, 1/. 4-21-03; Ord, No. 1366, Sec. 2, 111-17-09) ORDINANCE NO. 1412 AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF TUSTIN AMENDING VARIOUS SECTIONS OF THE TUSTIN CITY CODE RELATING TO THE REGULATION OF SOLICITATION ACTIVITY AND ACTS OF TRESPASS OCCURING ON COMMERCIAL PROPERTIES City Attorney Summary This ordinance amends the Tustin City Code by establishing regulations which: prohibit solicitation activity at those public rights of way where street parking is prohibited; requires a solicitor's permit for solicitors conducting commercial or charitable solicitation in residential areas of the city; prohibits solicitation activity on commercial property wherein the property owner has posted a "no solicitor's sign ". In addition, the ordinance prohibits trespass on commercial properties during non - business hours and prohibits skateboarding on commercial properties. THE CITY COUNCIL OF THE CITY OF TUSTIN HEREBY ORDAINS AS FOLLOWS: SECTION 1. Code Amendment Relating to Solicitation Activities. Chapter 8 of Article 5, "Public Safety" is hereby amended in its entirety to read as follows: "CHAPTER 8. REGULATION OF SOLICITATION ACTIVITY. PART 1. Regulation Of Solicitation Activity In Public Rights of Wa 5800 Findings and Intent. The City Council finds that it is necessary to regulate the solicitation activity of pedestrians and motor vehicle occupants who utilize certain public rights of way based upon the following findings: (1) The City of Tustin has experienced negative secondary impacts arising out of solicitation activities of pedestrians and passing motorists who utilize certain public rights of way as documented in a Police Department report provided to the City Council. These impacts consist of traffic hazards caused by: the distraction of automobile drivers observing solicitation activity or otherwise stopping or slowing in traffic lanes; solicitors' physical obstruction of vehicular traffic flow by walking randomly into streets to solicit passing motorists. Additional problems emanating from this solicitation activity include littering, public urination, interference with pedestrian access to public sidewalks, and interference with on -site commercial business operations. These secondary impacts are found to be a nuisance condition requiring reasonable restrictions to mitigate potential impacts from such nuisance conditions. (2) The City Council takes notice of the fact that other local municipalities, such as the cities of Orange and Newport Beach, and nationwide have experienced similar impacts from solicitation in public rights of way aimed at passing motorists. The City of Orange conducted an extensive analysis of such impacts in a study and report to the City Council resulting in the enactment of an ordinance which establishes City of Orange regulations restricting solicitation activity at certain public rights of way. The Orange ordinance makes specific findings that solicitation on public rights of way, upon which vehicle parking is prohibited or restricted, causes significant traffic hazards. That analysis and ordinance provides a further factual basis to support the enactment of regulations restricting solicitation activity in certain public rights of way as further set forth in this chapter. 5801 Definitions. As used in this Chapter, the following words and phrases shall have the following meanings: "Charitable solicitation activity" means commercial sales or requests for charitable contributions on behalf of a nonprofit organization, including e.g., patriotic, philanthropic, social services, welfare, benevolent, educational, religious, civil, or fraternal, either actual or purported. "Commercial property" means any real property held, owned, or controlled by private interests and which is zoned by the city for any form of business enterprise, including but not limited to, retail, office, commercial, or industrial, or recreational purpose. "Contribution" means the giving of anything of value, including money, property, or any type of financial assistance, or the pledging of anything of value, including money, property, or other type of financial assistance, or the purchasing or offering to purchase anything of value, including, but not limited to goods, services, books, real property, pamphlets, tickets, or subscriptions to publications. "Employment" shall mean services, industry or labor performed by a person for wages or other compensation or under contract of hire, whether written, oral, expressed or implied. "Occupants of motor vehicles" shall mean the driver and passengers of the vehicle. "Person" means any individmal, finn, portnership, joint ventuna, uaaociaUon, social dub, leaguo, fraternal nrgunizadon, joint stock company, estate, trust, corporation, or any other group acting as a unit. "Solicit", ^aoUcbadon^, or "solicitation activity shall moan and includo, but not limited to any roquesL, offer, enbnement, or other action which announces the availability of employment, the sale of goods, aemiceo, or requests for funds, petition gathering; or any request, offer, enticement or action which seeks 0n purchase or sell goods, orho cause a contribution of money or other property hnbemade. Aa defined herein, a solicitation shall be deemed complete when made whether or not an actual transaction of any type is comp|eted, or exchange of money, including charitable contributions, takes place. 5802- Prohibited Solicitation Activity. (a) Solicitation Prohibited When Conducted From Sidewalks and Driveways Where Vehicle Parking Is Not Legally Permitted. It shall be unlawful for any person, while standing in any portion of a public sidewalk or driveway, to engage in solicitation activity with any person traveling in a vehicle along any public street or highway which has been designated by the City as a as a prohibited parking area orno parking zone. (W Solicitation Prohibited When Conducted Within Public Streets and Medians.—It shall be unlawful for any person while standing within any public street or highway or public median to engage in solicitation activity with any person in a vehicle in the public right of way, including but not limited to, a public street, highway, sidewalk, ordriveway. (o) Prohibition Of Solicitation By Occupants Of Vehicles. It shall be unlawful for any occupant ofa vehicle to engage in solicitation activity with a person who is within a public street or highway which has been designated by the City aoo prohibited parking area orno parking zone. 5803- Posting ofSigns. 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Left: 0', First line: 0" 5817- Regulation Of So in Residential Areas. (a) Specific Requirements. No person shall solicit in any of the residential zoned areas of the City: 1 Between the hours of 6:00 p.m. and 8:00 a.m., unless dune by appointment; 2. At any house, apartment, or other dwe to which ia affixed asign indicating "No Solicitors" or similar indication that no solicitation is desired by the occupants thereof 3. At any houae, apartmant, or other dwelling within m homeowner's association that maintains private streets where the homeowner's association has posted on each vehicular entry way ho the property a notice |n substantially the following form: "No 8o|iuitom^, or similar indication that no solicitation is permitted by occupants thereof. 4. By using profane or abusive language or making verbal threats, during the solicitation; 5. By stepping onto or over the threshold of donnway, unless invited hud000by the occupant; & By placing hands, |ego, or any portion of the solicitor's body in the doorway so that it reasonably appears that the door may not be closed, unless allowed tod000by the occupant; 7. By refusing to immediately leave the solicited premises when asked hod000by any occupant; or 8. By knowingly making false statements or misrepresentations-about the purpose of the solicitation. (b) Receipts. Any person receiv mone or anything of value in excess of five dollars ($5.00) from any contributor by means nfa solicitation ahaU, upon request, give such contributor a written receipt showing the name and address of the solicitor, the date, and the amount received. (c) Compliance With State an�_ Charitable Laws. Prior to and while engaging in solicitation in any residential area of the City, every person shall fully comply with all applicable state laws, including the provisions of the California Charitable Disclosure Law as set forth in the California Business and Professions Code sections 17510 et seq. an d the ch aritable oficit .n un Tustin Citv Code ser; ion 2 5818 Regulation of Solicitation Conducted on Commercial Property. (a) Findings and Intent. The City has received a growing number of complaints from certain merchants and business patrons that solicitors have engaged in a variety of commercial and non - commercial solicitation activity on private commercial property without the owner's consent. This solicitation activity can have the effect of impeding the free movement of citizen patrons, and otherwise cause noise and physical obstruction which detracts from a conducive commercial environment. (b) Prohibition. It is unlawful for any person to solicit in or upon any commercial property within the City when such property is affixed with signage stating "NO SOLICITORS ", or similar statement to the effect that solicitation is not permitted on the property, or is otherwise permitted only in restricted areas of the property. (c) Sianage Requirements (1) Excepting commercial property containing communal areas, the property owner shall post a "No Solicitors" sign of a size not less than 22 inches by 17 inches, with lettering of at least one inch in height, at each vehicular entry point to the property. (2) For commercial property containing communal areas, the property owner shall post signs stating that: "Solicitation of any type is permitted only in designated areas of this Commercial Property. Violators are subject to prosecution pursuant to Tustin City Code section ;. =, �- Contact the property manager for a permissible solicitation location." The signing shall be located at prominent entry point(s) of the property, and at such other locations which have been designated by the property owner as permissible solicitation locations. The size of the signs shall be not less than 22 inches by 17 inches with lettering of at least one inch in height. For purposes of this section, "communal areas" shall mean such areas set aside by the owner in which the public may engage in such matters as discourse, recreation, or entertainment separate and apart from commercial patronag occurring at business establishments. Examples of communal areas are seating anaau, plazas. or large walking anseo. Restaurant seating restricted to particular patronage does not constitute communal areas of the center. PART Ill. Prohibition Of Aggressive Solicitation And Solicitation At Certain Locations. 5830- Purpose and Intent. The City Council finds that bis necessary hn protect citizens from the fear and intimidation accompanying aggressive solicitation and all solicitation in certain confined areas. Aggressive solicitation may include approaching or following pedeathana, repetitive uontact, or the intentional blocking of pedestrian and vehicular traffic. 58%1- Aggressive Solicitation Prohibited. No person shall solicit, ask or beg in an aggressive manner in any public 5 83 2- All Solicitation Prohibited At Specified Locations. (a) City Parking Structures. Any act of solicitation ia prohibited inany City public parking lot m parking structure. (b) Resblooms. No person shall solicit, eok, or bag in any public rentroom or within twenty five (25) feet of the entrance to a public restmom. (c) Banks and ATMs. No person ohoU solicit ask or beg within twenty five (25) feet of any entrance or exit of any bank, savings and loan auaooiobun, credit union, or check cashing business during its business hours or within twenty five (25) feet of any automated teller machine during the time it is available for customers use. Pvovided, howevar, that when an automated teller machine is located within an automated teller machine facility, such distance shall be measured from the entrance or exit of the automated teller machine facility. Provided further that no person shall ao|icit, ask or bug within an automated teller machine facility where a reasonable person would or should know that heorshe does not have the permission to do so from the owner or other person lawfully in possession of such facility. Nothing in this paragraph shall be construed to prohibit the lawful vending of goods and services within such areas. (d) A marked bus stop; (e) Public transportation vehicles or facilities 5833 Definitions. In construing the provisions of this Part, the following definitions shall apply: "Aggressive manner" shall mean any of the following: Approaching or speaking to a person, or following a person before, during or after soliciting, asking or begging, if that conduct is intended or is likely to cause a reasonable person to: (i) fear bodily harm to oneself or to another, damage to loss of property, or (ii) otherwise be intimidated into giving money or other thing of value; 2. Intentionally blocking or interfering with the safe or free passage of a pedestrian or vehicle, by any means, or the blocking or interfering with pedestrian or vehicular access to any building, including unreasonably causing a pedestrian or vehicle operator to take evasive action to avoid physical contact or to gain entrance to a building; 3. Intentionally touching or causing physical contact with another person or an occupied vehicle without that person's consent in the course of such soliciting, asking, or begging; 4. Using violent or threatening gestures toward a person solicited either before, during, or after soliciting, asking, or begging; 5. Persisting in closely following or approaching a person, after the person has been solicited and informed the solicitor by words or conduct that such person does not want to be solicited or does not want to give money or any other thing of value to the solicitor; or 6. Using profane, offensive or abusive language which is inherently likely to provoke an immediate violent reaction, either before, during, or after solicitation. "Public place" shall mean a place to which the public or a substantial group of persons has access, and includes, but is not limited to, any street, highway, sidewalk, public parking lot, plaza, transportation facility, school, place of amusement, park, playground, and any doorway, entrance, hallway, lobby, and other portion of any business establishment, an apartment house, or hotel not constituting a room or apartment designed for actual residence. "Solicitation" shall have the same meaning set forth in Tustin City Code Section 5801. PART IV. Violations. 5840 Misdemeanor /Infraction. Any violation of the provisions of this chapter may be prosecuted as an infraction or misdemeanor pursuant to section 1121, of Part II, of Chapter 1 of the Tustin City Code. Violations may also be punished by other penalty, citation, and administrative citation process provided for in Chapter 1 of Article 1. SECTION 2. Code Amendment Relating To Regulation of Trespassing Activities on Private Commercial Properties. PART 5, entitled "Trespass on Private Commercial Property" is hereby added to Chapter 3, "Disorderly Conduct' of Article 6, "Public Welfare" to read as follows: "PART 5 Trespass On Exterior Premises Of Commercial Prope 6350 Remaining On Exterior Premises When A Business Is Closed. (a) Findings and Intent. The City has received complaints from business owners that individuals enter upon and remain overnight on the exterior portion of their private commercial property without owner consent. This transient occupation leads to health and safety impacts on properties including urination and the leaving of waste and debris. This section is intended to prohibit such transient overnight occupation when owners post appropriate signage on their properties in accordance with this section. (b) Prohibition. It shall be unlawful for any person to remain upon the exterior premises of any private commercial property, including any parking area, when the business is closed, and the property is posted with at least one sign at a pedestrian entry point prohibiting the presence of any person on the property during non- business hours. "Private commercial property" means any real property held, owned, orcontrolled by private interests and which is zoned bythe City for any form of bus enhaqzhoe, including but not limited to, reta office. commercial, industrial, or recreational purpose. (c) S�a The sign shall baa minimum size of17 inches by22 inches and shall state: "PRIVATE PROPERTY Entrance to this property is limbed to patrons only. bioo trespass and violation of law ho rema onthis property during non-business hours. (Tustin City Code section G Business Hours are: insert hours (d) Scope and Application. This section shall not apply to any person who has a bona fide intent to exercise an established constitutional right. SECTION 3. Code Amendment Relating To Skateboard Regulations. Tustin City Code section b343."Skateboard Rogulations".of Part 4.nf Chapter 3. of Article 5nf the Tustin City Code io amended in its entirety to read amfollows: 5343- Regulation of Skateboarding Oa Private Property, Designated Public Property, and City Streets. (a) Private Property. It shall be unlawful for any person to engage in skateboarding on any commercial property in the City in which the owner, lessee, or operator of such property has posted at least one sign stating: "SKATEBOAO|NG|S PROHIBITED ON THIS PROPERTY PURSUANT TO TUSTIN CITY CODE SECTION 5343." T size of the sign shall be not less than 22 by17inches with lettering not less than one inch inheight. The sign sha be posted in plain view inat least one (1) prominent location on the property. "Skateboarding" is defined to mean aboard of any material which has wheels attached to it and which is propelled or moved by human movement, or mechanical power. "Private commercial property" shall have the same meaning aa stated in Tustin City Code section G35Oi2b). (b) Public Property. It ahoU be unlawful for any person to engage in skateboarding in or on any city public parking otructure, or on or within the City Civic Center/Library complex property. (c) Streets and Public Highways. It shall be unlawful for any person to skateboard on any City street or public highway within the City. This prohibition shall not extend to include city sidewalks. Skateboards shall yield the right of way ho pedestrians et all times. SECTION 4. SeverabilityL If any nection, oubuection, eentance, olauoe, or phrase of this ordinance is for any reason, held to be invalid or unenforceable, such decision shall not affect the validity or enforceability of the remaining portions of this ordinance. The City Council declares that it would have puoead this ordinanoe, and each uoction, oubneotinn, c|ouea or phrase hereof, irrespective of the fact that any one or more msotiono, oubeectione, oonbsnman, u|auaeo, and phrases be declared invalid or unenforceable. SECTION 5. Repealer. (a) Chapter 10 "Charitable and Commercial Solicitations", of Article 5 "Public Safety" of the Tustin City Code iu hereby repealed in its entirety. (b) Chapter 11 "Prohibition Against Certain Forms of Aggressive Solicitation" of Article 5 "Public Safety" of the Tustin City Code is hereby repealed in its entirety. (c) Chapter 7, "Solicitation in Private Commercial Parking Areas", of Article 8. "Public Welfare" of the Tustin City Code is hereby repealed in its entirety. PASSED AND ADOPTED, ata regular meeting of the City Council of the City of Tustin on this __ day of 2012. JOHN N|ELSEN.MAYOR PAMELA STOKER, City Clerk STATE OF CALIFORNIA COUNTY OF ORANGE )aa. CITY DFTUST|N ) CERTIFICATION FOR ORDINANCE NO. 1412 PAMELA STOKER, City Clerk and ex-officio Clerk of the City Council of the City of Tustin, California, does hereby certify that the whole number of the members of the City Council of the City of Tustin is five; that the above and foregoing Ordinance No. 1412 was duly and regularly introduced and read at the regular meeting of the City Council held on the __.day of___. 2012. and was given its second reading, passed and adopted at a regular meeting of the City Council held on the __day of______ 2012, by the following vote: COUNC!LPERGONSAYES: COUNC|LPERSONSNOES: COUNC|LPERSONSABSTANED: COUNCILPERSONS ABSENT: PAMELA STOKER, City Clerk