HomeMy WebLinkAbout07 RESOLUTION 21-78 CONFIRMING THE CITY COUNCIL'S INTENTION TO TRANSITION TO DISTRICT ELECTIONSDocuSign Envelope ID: BEAB79AE-6671-4387-B359-8ACA1E87A2DA
" 0',AGENDA REPORT
MEETING DATE
TO:
FROM:
SUBJECT:
SUMMARY
SEPTEMBER 7, 2021
MATTHEW S. WEST, CITY MANAGER
DAVID E. KENDIG, CITY ATTORNEY
Agenda Item
DS
Reviewed:��
City Manager
Finance Director N/A
RESOLUTION 21-78 CONFIRMING THE CITY COUNCIL'S
INTENTION TO TRANSITION FROM AT -LARGE TO DISTRICT
ELECTIONS AND REJECTING MALDEF'S CONDITIONS FOR
EXTENDING THE PUBLIC OUTREACH PERIOD
On August 3, 2021, the City Council adopted Resolution No. 21-64 declaring its intention
to transition from at -large to district elections within a 90 -day Safe Harbor period pursuant
to the Elections Code and authorized the City Manager to approve and execute an
agreement with Mexican American Legal Defense and Education Fund (MALDEF) to
extend by an additional 90 days the deadline to adopt an ordinance establishing district -
based elections to provide additional time to conduct public outreach, encourage public
participation, and receive public input.
Unexpectedly, on August 16, 2021, MALDEF conditioned agreeing to the extension upon
terms that raise significant issues of compliance with State and Federal law. Despite
having had numerous conversations with MALDEF over the past several months
regarding the City's utilization of an extension agreement, including the attached email
dated July 29, 2021, MALDEF previously made no mention of the extension being subject
to additional material demands (see attached email).
RECOMMENDATION
It is recommended that the City Council take the following action:
Adopt Resolution 21-78, "A RESOLUTION OF CITY COUNCIL OF THE
CITY OF TUSTIN, CALIFORNIA, CONFIRMING ITS INTENTION TO
TRANSITION FROM AT -LARGE TO DISTRICT -BASED ELECTIONS
PURSUANT TO CALIFORNIA ELECTIONS CODE 10010(e)(3)(A) AND
REJECTING MALDEF'S CONDITIONS FOR EXTENDING THE PUBLIC
OUTREACH PERIOD."
DocuSign Envelope ID: BEAB79AE-6671-4387-B359-8ACA1E87A2DA
Agenda Report — Resolution Confirming Intent to Transition to District Elections and
Rejecting MALDEF's Conditions for Extending the public outreach period
September 7, 2021
Page 2
FISCAL IMPACT
Significant staff time will be required to transition to district -based elections and to
administer the process including the need for at least several public hearings.
Transitioning to district -based elections also involves the services of a demographer.
Additionally, the City will be required to reimburse MALDEF for its documented costs, up
to $30,000. However, such expenses would likely be significantly lower than the costs of
litigating the threatened lawsuit if district -based elections are not established before the
end of the "90 -day Safe Harbor" period on November 1, 2021.
BACKGROUND
The City currently utilizes an at -large election system where voters citywide select each
of the five City Council Members. By contrast, a district -based election system is one in
which a city is physically divided into separate districts, each with one council member
who resides in the district and is chosen solely by the voters residing in that district.
MALDEF's Demand to Convert to District Elections.
On June 23, 2020, the City received a letter from the Mexican American Legal Defense
and Education Fund (MALDEF) in Sacramento, California. The letter asserts that the
"lack of success of Latino candidates results from the inability of Latino voters to elect
candidates of choice due to racially polarized voting among the electorate, and that
continued use of at -large elections therefore violates" the California Voting Rights Act
(CVRA). The letter demands that the City convert to district -based elections and
threatens litigation if the City declines to voluntarily convert to district -based elections.
The California Voting Rights Act Imposes Significant Costs of Litigating
The CVRA, codified as Elections Code sections 14025 et seq., became law on January
1, 2003. The declared purpose of the CVRA is to prevent the disenfranchisement of
protected classes, which are broadly defined to include members of a race, color, or
language minority group. Any voter who resides in a city and is a member of a protected
class may file a lawsuit for a violation of the CVRA. To succeed, the plaintiff must only
show that, as a result of an at -large election, "racially polarized voting" has occurred.
"Racially polarized voting" means there is a difference between the choice of candidates
preferred by voters in a protected class and candidates preferred by voters in the
remainder of the voting population. If the plaintiff prevails in litigation, the CVRA allows
for the recovery of significant attorneys' fees and expert witness fees. On the other hand,
DocuSign Envelope ID: BEAB79AE-6671-4387-B359-8ACA1E87A2DA
Agenda Report — Resolution Confirming Intent to Transition to District Elections and
Rejecting MALDEF's Conditions for Extending the Public Outreach Period
September 7, 2021
Page 3
even if the city that is sued prevails in the lawsuit, it cannot recover either attorneys' fees
or costs.
Consequently, cities throughout the State have increasingly faced legal challenges to
their at -large election systems. Nearly all have settled claims out of court by voluntarily
transitioning to district -based elections. Those cities that have attempted to defend their
existing at -large election systems have incurred significant legal costs. Staff is unaware
of any city that has prevailed in a lawsuit defending an at -large election system after a
claim is filed pursuant to the current version of the CVRA.
A "Safe Harbor" If A Resolution of Intention to Transition to Districts is Adopted.
On September 28, 2016, the Governor signed into law AB 350, which enacted Elections
Code section 10010. That legislation established a "safe harbor" from CVRA litigation for
cities. Once a city receives a demand letter, it has a period of protection' from litigation
to assess its situation. If within 45 days a jurisdiction adopts a resolution of intention to
transition to district elections, the jurisdiction has an additional 90 days to complete the
districting process.
In Tustin's case, the CVRA safe harbor period of protection for completing the districting
process runs until November 1, 2021, which is 90 days from August 3, 2021, the date the
City Council adopted Resolution No. 21-64. If within that period, the City Council
completes the districting process and adopts and ordinance to transition from at -large to
district -based elections, then a CVRA lawsuit could not be filed. And under AB 350, the
City's liability would be capped at $30,000.
Setting District Boundaries
Prior to adopting an ordinance actually establishing district -based elections, the City
Council is required to establish district boundaries and the sequencing of district elections.
California Elections Code section 10010 sets forth the City Council public hearing process
for establishing district boundaries and the sequencing of district elections. This process
requires a series of noticed public hearings during which the public has a right to provide
input on proposed district boundaries. Specifically, Elections Code 10010(a)(1) requires
the City must hold at least two "clean slate" hearings at which the public can provide input
on district boundaries before any maps are prepared. Thereafter, the City must hold at
least two more public hearings to consider draft maps. Finally, the City must hold a public
Ordinarily the period of protection is a 45 -day period from receipt of the demand letter. However,
due to the Governor's COVID-related emergency orders, that period of protection has been effectively
extended to August 14, 2021.
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Agenda Report — Resolution Confirming Intent to Transition to District Elections and
Rejecting MALDEF's Conditions for Extending the Public Outreach Period
September 7, 2021
Page 4
hearing at which the map is adopted and the sequencing of district elections is
established. The map and sequencing would be approved by City ordinance.
The creation and approval of voting district maps is intended to be a transparent public
process. Voting district maps must be prepared in compliance with certain State and
federal requirements. Of import is Elections Code 10010(b), which provides that, in
determining the sequence of the district elections, the City Council shall give special
consideration to the purposes of the CVRA and it shall take into account the preferences
expressed by members of the districts. The districting process must also include
consideration of communities of interest, natural geographic boundaries, and the "one-
person, one vote" standard, which requires all voting districts be as nearly equal in
population as possible. Finally, Federal caselaw prohibits drawing districts with race as
a predominate factor.
Ordinance Transitioning to District -Based Elections
Transitioning to district -based elections is effectuated by the City Council enacting an
ordinance pursuant to Government Code section 34886, provided that the ordinance
includes a declaration that it is being adopted to further the purposes of the CVRA. Under
this method, the City Council would need to determine whether it wants to have a mayor
elected at -large, with the remaining seats chosen through a district -based election
process (with four, six, or eight voting districts). If the City Council chooses not to have a
mayor elected at -large, it has the option of establishing five, seven, or nine voting
districts.2
These decisions will be made by the City Council based on information from the public
hearings, and other appropriate considerations as early as the first public hearing on this
matter.
Authorization for an Agreement to Extend the 90 -Day Deadline
California Elections Code section 10010(e)(3)(c)(i) allows the City and MALDEF to enter
into a written agreement to extend that 90 day period of protection for up to an additional
90 days (increasing the period of protection from 90 days up to as much as 180 days).
This would provide additional time to conduct public outreach, encourage public
participation, and receive public input during the districting process. Such an agreement
and the additional time it affords would also enable the City and its demographer to review
and analyze additional official population data anticipated to be released in late
September/early October before engaging in the public hearings on draft proposed district
maps.
2 Cal. Gov't Code § 34871.
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Agenda Report — Resolution Confirming Intent to Transition to District Elections and
Rejecting MALDEF's Conditions for Extending the Public Outreach Period
September 7, 2021
Page 5
At its meeting of August 3, 2021, the City Council authorized the City Manager to enter
into a 90 -day extension agreement with MALDEF.
MALDEF's Conditions to the 90-Dav Extension Reauest
On August 16, 2021, MALDEF proposed an extension agreement that would grant the
90 -day extension for completing the districting process conditioned upon, among other
provisions, the City's commitment to establish an electoral map that "shall not impair the
ability of the Latino community to elect candidates of its choice to the City Council, in
accordance with federal and state law" and that the "sequencing of the elections for the
districts shall be such that at least one electoral district that is intended to remedy Latino
vote dilution has a City Council seat up for election on November 8, 2022." After some
discussions, MALDEF agreed to remove the latter condition related to sequencing, but
continues to demand the former as a condition to agreeing to extend the 90 -day public
outreach period.
In sum, MALDEF is demanding that the City commit to establishing an electoral map that
"shall not impair the ability of the Latino community to elect candidates of its choice to the
City Council," which suggests or assumes that the City will draft at least one district using
the Latino race as a predominant factor, which is generally prohibited by Federal caselaw.
The condition would further commit the City to a specific outcome before the City Council
actually considers public input prior to drawing districts as required by subdivision (a) of
Elections Code 10010.
DISCUSSION
The City is committed to engaging in the districting process in compliance with all
applicable laws and encourages MALDEF to drop its demanded conditions on the
extension agreement, and to simply agree to extend the 90 -day term so that the City, the
public and MALDEF will have additional time to thoughtfully engage in public outreach
and education, public participation, and public input during the districting process.
However, if MALDEF continues to be unwilling to agree to the extension without the
unlawful demands, the City will proceed with implementing the required steps by
November 1, 2021. The attached Resolution No. 21-78 of Intent will re -affirm the City's
commitment to following the law and will reject MALDEF's proposal that the City should
disregard the CVRA's and Federal law requirements.
ATTACHMENTS
1. July 29, 2021 Email from MALDEF — Intent to enter into extension agreement
2. Resolution 21-78.
3. Extension Agreement Proposed by MALDEF on August 16, 2021.
4. Revised Agreement Proposed by the City on August 17, and August 27, 2021.
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David E. Kendig
From: Tanya Pellegrini <Tpellegrini@MALDEF.org>
Sent: Thursday, July 29, 2021 8:23 PM
To: David E. Kendig
Cc: Michael S. Daudt; Ernest Herrera
Subject: Re: Tustin District Elections
Attachments: image001.jpg; log o_24a83e77-8c70-415f-9dcc-6892f2286ea0.JPG
Hi David,
Thanks for speaking with me this afternoon. As discussed, we are open to a go -day extension under
Election Code Section loolo after the City Council votes to convert to single -member district
elections. However, an extension is premature at this time since the City Council has not yet voted to
adopt a resolution to convert to district elections. We would be happy to discuss the go -day extension
after the City Council passes a resolution of intent to convert to district elections.
Please feel free to contact me should you like to discuss this matter further. Thank you.
Sincerely,
Tanya G. Pellegrini (she/hers)
Staff Attorney
MALDEF
1512 14th Street
Sacramento, CA 95814
Ph (916) 444-3031
www.maldef.org<http://www.maldef.org/>
CONFIDENTIALITY NOTICE: This e-mail transmission from The Mexican American Legal Defense
& Educational Fund, and any documents, files or previous e-mail messages attached to it may contain
confidential information that is legally privileged. If you are not the intended recipient, or a person
responsible for delivering it to the intended recipient, you are hereby notified that any disclosure,
copying, distribution or use of any of the information contained in or attached to this transmission is
strictly prohibited. If you have received this transmission in error, please immediately notify us by
reply e-mail or by telephone at (916) 444-3031, and destroy the original transmission and its
attachments without reading or saving it in any manner.
From: Michael S. Daudt <mdaudt@wss-law.com>
Sent: Wednesday, July 28, 20216:18 PM
To: Tanya Pellegrini
Cc: David E. Kendig
Subject: FW: Tustin District Elections
Hello Tanya,
As you know, I am heading out of state tomorrow. In my absence, can you please contact City
Attorney David Kendig at your earliest convenience. David is working to finalize the City Council staff
report to go out tomorrow. He is cc'd on this email and can be reached via cell at (949) 310-2524•
DocuSign Envelope ID: BEAB79AE-6671-4387-B359-8ACA1E87A2DA
Thanks,
Michael
[cid:logo_24a83e77-8c7o-415f-9dcc-6892f2286eao.JPG]
Michael S. Daudt
Attorney at Law
555 Anton Boulevard, Suite 1200
Costa Mesa, California 92626
714-415-1059 • Fax: 714-415-1159
mdaudt@wss-law.com
www.wss-law.com<http://www.wss-law.com>
CONFIDENTIALITY NOTICE — This e-mail transmission, and any documents, files or previous e-
mail messages attached to it may contain information that is confidential or legally privileged. If you
are not the intended recipient, or a person responsible for delivering it to the intended recipient, you
are hereby notified that you must not read this transmission and that any disclosure, copying,
printing, distribution or use of any of the information contained in or attached to this transmission is
STRICTLY PROHIBITED. If you have received this transmission in error, please immediately notify
the sender by telephone at 714-415-1059 or return e-mail and delete the original transmission and its
attachments without reading or saving in any manner. Thank you.
From: Michael S. Daudt <mdaudt@wss-law.com>
Sent: Wednesday, July 28, 2021 12:04 PM
To: Tpellegrini@MALDEF.org
Subject: Tustin District Elections
Hi Tanya,
Sorry for missing your call. Per your voicemail, I'd appreciate your sending a sample template
agreement that could be modified for use in Tustin and presented to the City Council on Tuesday.
Even if we are unable to secure your client's signatures and approval of the agreement in advance of
the meeting, we would like to present a draft agreement in connection with the request for City
Manager authorization to execute an extension agreement that substantially complies with the
attached draft. Please let me know what you think.
Best,
Michael
[cid:imageool.jpg@o1D783DC.F2663FBo]
DocuSign Envelope ID: BEAB79AE-6671-4387-B359-8ACA1E87A2DA
Michael S. Daudt
Attorney at Law
555 Anton Boulevard, Suite 1200
Costa Mesa, California 92626
714-415-1059 • Fax: 714-415-1159
mdaudt@wss-law.com <mailto:mdaudt@wss-law.com>
www.wss-law.com<http://www.wss-law.com>
CONFIDENTIALITY NOTICE — This e-mail transmission, and any documents, files or previous e-
mail messages attached to it may contain information that is confidential or legally privileged. If you
are not the intended recipient, or a person responsible for delivering it to the intended recipient, you
are hereby notified that you must not read this transmission and that any disclosure, copying,
printing, distribution or use of any of the information contained in or attached to this transmission is
STRICTLY PROHIBITED. If you have received this transmission in error, please immediately notify
the sender by telephone at 714-415-1059 or return e-mail and delete the original transmission and its
attachments without reading or saving in any manner. Thank you.
This email has been scanned for spam and viruses by Proofpoint Essentials. Click
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RESOLUTION NO. 21-78
A RESOLUTION OF CITY COUNCIL OF THE CITY OF TUSTIN,
CALIFORNIA, CONFIRMING ITS INTENTION TO TRANSITION
FROM AT -LARGE TO DISTRICT -BASED ELECTIONS
PURSUANT TO CALIFORNIA ELECTIONS CODE
10010(e)(3)(A) AND REJECTING MALDEF'S CONDITIONS FOR
EXTENDING THE PUBLIC OUTREACH PERIOD
WHEREAS, members of the City Council of the City of Tustin ("City") are
currently elected in at -large elections, in which each Councilmember is elected by
all registered voters of the entire City; and
WHEREAS, Government Code Section 34886 authorizes the City Council
to adopt an ordinance to change its method of election from an at -large system to
a district -based system, in which each Councilmember is elected only by the voters
in the district in which the candidate resides; and
WHEREAS, on Tuesday June 23, 2020, the City received a letter from
Tanya G. Pellegrini, Staff Attorney for the Mexican American Legal Defense and
Education Fund ("MALDEF"), asserting that the City's at -large election system
violates the California Voting Rights Act ("CVRA") and threatening litigation if the
City declines to voluntarily change to a district -based election system for electing
Councilmembers; and
WHEREAS, the City denies its election system violates the CVRA or any
other provision of law and asserts the City's at -large election system is legal in all
respects and further denies any wrongdoing whatsoever regarding the way it has
conducted its City Council elections; and
WHEREAS, despite the foregoing, the City Council has concluded it is in
the public interest to begin the process of transitioning from at -large to district -
based elections due to the uncertainty of litigation to defend against a CVRA
lawsuit and the potentially extraordinary cost of such a lawsuit, even if the City
were to prevail; and
WHEREAS, on August 3, 2021, the City Council adopted Resolution No.
21-64 declaring its intention to transition from at -large to district elections within 90
days pursuant to Elections Code 10010(e)(3)(B); and
WHEREAS, in addition to approving Resolution No. 21-64, pursuant to
Elections Code 10010(e)(3)(C) the City Council on August 3, 2021, authorized the
City Manager to approve and execute an agreement with MALDEF to extend by
an additional 90 days the deadline to adopt an ordinance establishing district -
based elections to provide additional time to conduct public outreach, encourage
public participation, and receive public input; and
1600173.1
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WHEREAS, on August 16, 2021, MALDEF conditioned agreeing to the 90 -
day extension for completing the districting process upon, among other provisions,
the City's commitment to establishing an electoral map that "shall not impair the
ability of the Latino community to elect candidates of its choice to the City Council,
in accordance with federal and state law" (the "Election Condition"), and that the
"sequencing of the elections for the districts shall be such that at least one electoral
district that is intended to remedy Latino vote dilution has a City Council seat up
for election on November 8, 2022" (the "Sequencing Condition"); and
WHEREAS, Elections 10010(a)(1) requires the City to hold at least two
public hearings before drawing a draft map; and
WHEREAS, Elections 10010(b) requires the City that, in determining the
sequence of the district elections, the City Council shall give special consideration
to the purposes of the CVRA and it shall take into account the preferences
expressed by members of the districts; and
WHEREAS, Federal caselaw prohibits drawing districts with race as a
predominate factor; and
WHEREAS, MALDEF has since agreed to remove the Sequencing
Condition, but continues to demand upon the Election Condition as a condition to
agreeing to extend the 90 -day period to engage in conducting public outreach,
encouraging public participation, and receiving public input prior to the completion
of the districting process; and
WHEREAS, the City is committed to engaging in the districting process in
compliance with all applicable laws, including but not limited to the California and
Federal Constitutions, the Federal Voting Rights Act, 52 USC 10301, the CVRA,
Govt. Code 34886, and Elections Code 10010 and 21601;
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF TUSTIN
DOES RESOLVE AS FOLLOWS:
SECTION 1. The above recitals are true and correct and are incorporated
herein by reference.
SECTION 2. The City Council hereby confirms its intention to transition from
at -large to district -based elections and to do so in compliance with all applicable
state and federal laws and Constitutions;
SECTION 3. The City shall continue to utilize a demographer experienced
and qualified to assist the City in drafting a district map consistent with the CVRA,
the Federal Voting Rights Act, and the California and Federal Constitutions.
SECTION 4. City staff shall work with the demographer to provide a
detailed analysis of the City's current demographics and any other information or
data necessary to prepare a draft map that divides the City into voting districts in
2
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a manner consistent with the intent and purpose of the CVRA, the Federal Voting
Rights Act, and the California and Federal Constitutions.
SECTION 5. The City remains committed to engaging in the districting
process in compliance with all applicable laws, including but not limited to the
California and Federal Constitutions, the Federal Voting Rights Act, 52 USC
10301, the CVRA, Govt. Code 34886, and Elections Code 10010 and 21601.
SECTION 6. The City Council hereby rejects the demanded conditions
upon the districting process, such as the Election Condition and the Sequencing
Condition that have been demanded by MALDEF, as conditions upon extending
the 90 -day term for completing the districting process.
SECTION 7. The City Council encourages MALDEF to drop its demanded
conditions on the extension agreement and to simply agree to extend the 90 -day
term so that the City, the public and MALDEF will have additional time to
thoughtfully engage in public outreach and education, public participation, and
public input during the districting process.
SECTION 8. The City Clerk shall certify as to the adoption of this
Resolution.
PASSED AND ADOPTED by the City Council of the City of Tustin at a
regular meeting held on the 7t" day of September, 2021.
ATTEST:
ERICA N. YASUDA,
City Clerk
3
LETITIA CLARK,
Mayor
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STATE OF CALIFORNIA )
COUNTY OF ORANGE ) SS
CITY OF TUSTIN )
I, Erica N. Yasuda, City Clerk and ex -officio Clerk of the City Council of the City of
Tustin, California, do hereby certify that the whole number of the members of the City
Council is five; that the above and foregoing Resolution No. 21-64 was duly and
regularly passed and adopted at a regular meeting of the City Council held on the 7th
day of September, 2021 by the following vote:
COUNCILPERSONS AYES:
COUNCILPERSONS NOES:
COUNCILPERSONS ABSTAINED:
COUNCILPERSONS ABSENT:
ERICA N. YASUDA,
City Clerk
M
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AGREEMENT BETWEEN THE CITY OF TUSTIN AND MALDEF REGARDING
CALIFORNIA VOTING RIGHTS ACT DEMAND LETTER
This Agreement (the "Agreement") is entered into by and between the City of Tustin ("City"), a
California municipal corporation, and the Mexican American Legal Defense and Educational
Fund ("MALDEF"), a California non-profit organization as of , 2021. The City
and MALDEF may each be referred to here as a "Party" or collectively as the "Parties".
RECITALS
WHEREAS, the City is a California general -law city with a five -member city council, all five
councilmembers are elected at -large by the entire City; and
WHEREAS, on June 23, 2020, MALDEF sent a letter demanding the City comply with the
California Voting Rights Act (the "Demand Letter"); and
WHEREAS, the Demand Letter specifically demanded that the City convert its at -large city
council election system to a district -based election system; and
WHEREAS, the Tustin City Council adopted Resolution No. 21-64, Resolution of the City
Council of the City of Tustin Declaring its Intent to Transition from At -Large Elections to
District -Based Elections to Elections Code Section 10010(e)(3)(A), on August 3, 2021
("Resolution of Intent"); and
WHEREAS, the City's next regularly scheduled City Council election is scheduled for
November 8, 2022; and
WHEREAS, under Elections Code section 10010(e)(3)(B), MALDEF may not commence an
action to enforce the California Voting Rights Act ("CVRA") within 90 days of adoption of the
Resolution of Intent; and
WHEREAS, in order to provide additional time to conduct public outreach, encourage public
participation, and receive public input, the Parties desire to extend the time period in which an
action to enforce the CVRA may not be commenced by an additional 90 days.
NOW, THEREFORE, for good and valuable consideration, the receipt and sufficiency of
which are acknowledged, the Parties agree as follows.
1. Recitals. The Parties acknowledge that the foregoing recitals are true and correct and are
incorporated here by this reference.
2. Extension of Time. Under Elections Code section 10010(e)(3)(C)(i), the City and
MALDEF mutually agree to extend the time period described in Elections Code section
10010(e)(3)(B) by 90 days. In accordance with the terms of this Agreement, MALDEF shall not
commence an action against the City to enforce the CVRA before January 30, 2022.
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3. City Boundaries. The new City boundaries shall be established no later than six months
before November 8, 2022, which is the next regular election to elect members of the City
Council.
4. Electoral City Map. The intent of the Parties is that the electoral map shall not impair the
ability of the Latino community to elect candidates of its choice to the City Council, in
accordance with federal and state law. The electoral map shall include electoral districts in
which Latino voters have a meaningful opportunity to elect candidates of their choice, and the
map shall be drawn according to the most recently available decennial Census data, drawn in a
manner consistent with applicable law. The boundaries of the electoral district map shall be
drawn in accordance with criteria set forth in the following order of priority:
Districts shall contain reasonably equal total population;
ii. Districts shall comply with applicable federal and state law, including, without
limitation, the CVRA, the Constitution of the United States and of the State of
California, the federal Voting Rights Act of 1965, as amended, 52 U.S.C. §§
10301, et seq.;
iii. Districts shall be drawn to encourage geographic compactness and shall be
geographically contiguous by land, such that areas that meet only at the points of
adjoining corners and areas that are separated by another territory are not
contiguous; non -contiguity by water is permitted only if connected by bridge,
tunnel, or regular ferry service; and
iv. Districts shall be drawn with respect for the geographic integrity of any
neighborhood and any community of interest to the extent possible without
violating the requirements of any of the preceding provisions. The City shall look
to federal and state voting rights law for guidance on how to identify communities
of interest, including, e.g., Luna v. County ofKern, 291 F.Supp.3d 1088, 1110
(finding a community of interest existed where community shared concerns in the
areas of immigration, language, and culture); LULAC v. Perry, 548 U.S. 399, 432
(2006) (explaining that courts must look to "socio-economic status, education,
employment, health, and other characteristics."); Bush v. Vera, 517 U.S. 952, 964
(1996) (describing exemplary "manifestations of community of interest" as
including "shared ... institutions such as schools and churches"); Perez v. Abbott,
2017 WL 1406379, at *56-60 (W.D. Tex. Apr. 20, 2017) (identifying
communities of interest based on shared socioeconomic characteristics such as
high poverty levels, geography, lack of adequate employment opportunities,
health-related concerns, and certain regional challenges).
5. Sequencing of Elections. The sequencing of the elections for the districts shall be such
that at least one electoral district that is intended to remedy Latino vote dilution has a City
Council seat up for election on November 8, 2022, which is the next regular election to elect
members of the City Council.
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6. CVRA. By entering into this Agreement, the City does not admit or concede that its
current at -large election system is in violation of the CVRA. Except as expressly provided for
herein, MALDEF does not waive any rights it may have under the CVRA.
7. Attorneys' Fees. If a party to this Agreement brings any action, including an action for
declaratory relief, to enforce or interpret the provisions of this Agreement, the prevailing party
shall be entitled to reasonable attorneys' fees, costs and expenses in addition to any other relief
to which that party may be entitled. The court may set such fees in the same action or in a
separate action brought for that purpose.
8. Amendments. The parties may amend this Agreement only by a writing signed by all the
parties.
9. Counterparts. This Agreement may be executed in multiple counterparts, each of which
shall be an original and all of which together shall constitute one agreement.
10. Construction of Agreement. Each party has had an equivalent opportunity to participate
in the drafting of the agreement and/or to consult with legal counsel. Therefore, the usual
construction of an agreement against the drafting party shall not apply.
11. No Third Party Beneficiaries. This Agreement is made solely for the benefit of the
parties, with no intent to benefit any third parties.
The Parties have executed this Agreement as of the Effective Date.
CITY OF TUSTIN MALDEF
Letitia Clark, Mayor Tanya Pellegrini, Staff Attorney
Approved as to Form:
David Kendig, Attorney for City of Tustin
DocuSign Envelope ID: BEAB79AE-6671-4387-B359-8ACA1E87A2DA
AGREEMENT BETWEEN THE CITY OF TUSTIN AND MALDEF REGARDING
CALIFORNIA VOTING RIGHTS ACT DEMAND LETTER
This Agreement (the "Agreement") is entered into by and between the City of Tustin ("City"), a
California municipal corporation, and the Mexican American Legal Defense and Educational
Fund ("MALDEF"), a California non-profit organization as of , 2021. The City
and MALDEF may each be referred to here as a "Party" or collectively as the "Parties".
RECITALS
WHEREAS, the City is a California general -law city with a five -member city council, all five
councilmembers are elected at -large by the entire City; and
WHEREAS, on June 23, 2020, MALDEF sent a letter demanding the City comply with the
California Voting Rights Act (the `Demand Letter")-, and
WHEREAS, the Demand Letter specifically demanded that the City convert its at -large city
council election system to a district -based election system; and
WHEREAS, the Tustin City Council adopted Resolution No. 21-64, A Resolution of the City
Council of the City of Tustin, California, Declaring Its Intention to Transition from At -Large
Elections to District -Based Elections Pursuant to California Elections Code 10010(e)(3)(A), on — Deleted: seetion
August 3, 2021 ("Resolution of Intent'), and
WHEREAS, the City's next regularly scheduled City Council election is scheduled for
November 8,2022-, and
WHEREAS, under Elections Code section 10010(e)(3)(B), MALDEF may not commence an
action to enforce the California Voting Rights Act, Elections Code 14025 et seg. ("CVRA")
within 90 days of adoption of the Resolution of Intent; and
WHEREAS, in order to provide additional time to conduct public outreach, encourage public
participation, and receive public input, the Parties desire to extend the time period in which an
action to enforce the CVRA may not be commenced by an additional 90 days.
NOW, THEREFORE, for good and valuable consideration, the receipt and sufficiency of
which are acknowledged, the Parties agree as follows.
1. Recitals. The Parties acknowledge that the foregoing recitals are true and correct and are
incorporated here by this reference.
2. Extension of Time. Under Elections Code section 10010(e)(3)(C)(i), the City and
MALDEF mutually agree to extend the time period described in Elections Code section
10010(e)(3)(B) by 90 days. In accordance with the terms of this Agreement, MALDEF shall not
commence an action against the City to enforce the CVRA on or before January 30, 2022.
1
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3. City District Boundaries. If the Council adopts an ordinance establishing district -based
(Commented [DEKl]:
elections. e new City district boundaries Ishall be established no later than six months before
Deleted: T
November 8, 2022, which is the next regular election to elect members of the City Council.
Commented [osz]: Added this new section to address
the provisions of law addressing the two sections I
[�`
ecommend be deleted below.ncorporate
4. Compliance with Law. In implementing Resolution No. 21-64, the City will Proceed in
compliance with all applicable laws, including, but not limited to the California and Federal
Deleted: 4.-s Electoral City Man
Constitutions, the Federal Voting Rights Act, 52 USC 10301, the CORA, Govt. Code 21601,
Deleted: , The intent of the Parties is that the electoral map shall
not impair the ability ofthe Latino community to elect candidates of
Govt. Code 34886, and Elections Code 10010.
its choice to the City Council, in accordance with federal and state
law. The electoral map shall include electoral districts in which
Latino voters have a meaningful opportunity to elect candidates of
�5. CVRA. By entering into this Agreement, the City does not admit or concede that its
their choice, and the map shall be drawn according to the most
current at -large election system is in violation of the CVRA. Except as expressly for
recently available decennial Census data, drawn in a manner
provided
consistent with applicable law. The boundaries of the electoral
herein, MALDEF does not waive any rights it may have under the CVRA.
district map shall be drawn in accordance with criteria set forth in
the following order of priority:¶
Amendments. The parties may amend this Agreement only by a writing signed by all the
Districts shall contain reasonably equal total population;q
Districts shall comply with applicable federal and state law,
parties.
including, without limitation, the CVRA, the Constitution ofthe
United States and of the State of California, the federal Voting
may uns, each
7_ Counterparts. This Agreement be executed in multiple counterparts, of which
Rights Act of 1965, as amended, 52 U.S.C. §§ 10301, etseq.;q
. 11 g y 13 13
__.
Districts shall be drawn to encourage geographic compactness and
shall be an original and all of which together shall constitute one agreement.1
shall be geographically contiguous by lana, such that areas that meet
only at the points of adjoining comers and areas that are separated
by anomer territory are not contiguous; non -contiguity by water is
8. Construction of Agreement. Each party has had an equivalent opportunity to participate
permitted only ifeonnectedbybridge, tunnel, orregular ferry
in the drafting of the agreement and/or to consult with legal counsel. Therefore, the usual
service; and¶
Districts shall be drawn with respect for the geographic integrity of
construction of an agreement against the drafting party shall not apply. ��'
any neighborhood and any community of interestto the extent
possible without violating the requirements of any ofthe preceding
provisions. The City shall look to federal and state voting rights law
�. No Third_ Party Beneficiaries. This Agreement is made solely for the benefit ofthe
for guidance on how to identify communities ofinterest,including,
with n0 intent t0 benefit any third
e.g., Luna v. County ofxem, 291 E.Supp.3d 1088, 1110 (finding a
parties, parties.
community of interest existed where community shared concerns in
the areas of immigration, language, and culture); L ULAC v. Perry,
The Parties have executed this Agreement as of the Effective Date.
548 U.S. 399, (zoos (explaining mat courts must to
an
s scams, education, employment, health, and other
'. characteristics.'); Bush v. Vera, 517 U.S. 952, 964 (1996)
CITY OF ,)(,US,)(,](N MAL]D]H, F
(describing exemplary "manifestations of community of interest" as
including "shared ... institutions such as schools and churches');
Perez v. Abbott, 2017 WL 1406379, at *56-60 (W.D. Tex. Apr. 20,
2017) (identifying communities of interest based on shared
socioeconomic characteristics such as high poverty levels,
geography, lack of adequate employment opportunities, health-
S. West, City Mana er Tanya Pellegrim, Staff Attorneyrelated
Ie y____ g
related concerns, and certain regional challenges).q
k" � ___.
S.�Seauencine of Elections
Deleted:. The sequencing ofthe elections for the districts shall be
such that at least one electoral district that is intended to remedy
Approved as t0 Form:
Latino vote dilution has a City Council seat up for ele tion o
Deleted: 7. -> Atromevs' Fees
Deleted: , If a party to this Agreement brings any action,
David Kendig, LibLAttorney for City Tustin
including an action for declaratory relief, to enforce or interpret the
of
,I. provisions of this Agreement, the prevailing party shall be entitled to
reasonable attorneys' fees, costs and expenses in addition to 2
Deleted:9
'. Deleted: 10
(Deleted: 11
1 Commented[DEK6]: At its August 3 meeting, the Council
'. authorized the City Manager to approve the extension agreement
(Deleted: Letitia Clark, Mayor
Deleted: -�-�
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