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Minutes / 11-08-99~ ~ MINUTES OF THE REGULAR MEETING OF THE ATLANTIC BEACH CITY COMMISSION HELD IN CITY HALL, 800 SEMINOLE ROAD AT 7:15 PM ON MONDAY, NOVEMBER 08, 1999 PRESENT: John Meserve, Mayor Richard Beaver Mike Borno Theo Mitchelson Dezmond Waters, Commissioners AND: Maureen King, City Clerk Alan C. Jensen, City Attorney James Hanson, City Manager The meeting was called to order by Mayor Meserve at 7:15 p.m. The Invocation was offered by Commissioner Beaver followed by the Pledge of Allegiance to the Flag. 1. Approval of the minutes of the Regular Meeting held November 2, 1999 Motion: Approve minutes as presented. The Mayor asked for corrections or amendments to the minutes. There were none, and the minutes were unanimously approved as prepared. 2. Courtesy of the Floor to Visitors: A. Steven Roberts of 795 Plaza stated that over the past few years several accidents had occurred where either his house, car or fence had been damaged by drunk drivers running through the intersection of Royal Palms and Plaza and into his yard. As a deterrent to future accidents, Mr. Roberts requested that either a stop light or speed bumps be installed at the intersection. Mayor Meserve referred the request to City Manager Hanson and Public Safety Director Thompson. B. Jim Dipietro of 785 Plaza, the next door neighbor of Mr. Roberts, distributed photographs of the most recent accident which occurred at Mr. Roberts' home and also requested that speed bumps be installed at the intersection. Mr. and Mrs. Dipietro disagreed with the city's removal of the cross in Howell Park. V V O O T T E E s s M S O E T C I O Y O N E N COMMISSIONERS N D S O BEAVER X BORNO X X MITCHELSON X X WATERS X MESERVE X Minutes Page 2- November 8, 1999 Commissioner Waters requested that the city investigate other safety options, such as a steel barrier, before installing speed bumps. C. J.P. Marchioli of 414 Sherry Drive complained about speeding on Sherry Drive. D. Sally Clemons of 1638 Park Terrace West spoke concerning, Resolution 99-29 pertaining to the City Attorney's contract. She believed the Charter was ambiguous concerning his' position and duties and felt the Commission should delay its vote on this matter until the November 22, 1999 meeting. E. Stephen Kuti of 1132 Linkside Drive suggested that the Commission receive input and discuss technical matters during the first meeting of the month and vote on the mattex the second meeting of the month. He felt this would allow the Commission time to address citizen inquires concerning technical matters. F. Nancy White of 1729 Seminole Road complained of speeding on Seminole Road. G. Lorin Mock, Chief of Operations, Jacksonville Fire and Rescue Department Mayor Meserve stated that he had requested that a representative from the Jacksonville Fire and Rescue Department be present to address public comments concerning the recent house fire on Beach Avenue Lorin Mock, Chief of Operations for the Jacksonville Fire and Rescue Department, reported to the City Commission regarding a recent fire at a home on Beach Avenue. The fire was apparently caused by faulty wiring to an electrical fixture in the garage, and caused extensive damage to the home. Chief Mock stated that the response time to the fire was four minutes from the time the call was received and dispatched by the city. He indicated that construction in the area impeded ingress to the site of the fire, but it was not a significant problem. Chief Mock indicated that the firefighters did not try to use or unwrap a new fire hydrant, and they were able to connect to two other fire hydrants which provided adequate water pressure to fight the fire. Commissioner Borno pointed out that water lines and fire hydrants were being replaced in the area as part of the city's on-going project to upgrade its water system. OMMISSIONERS M O T I O N S E C O N D Y E S N O C Minutes Page 3- November 8, 1999 Commissioner Waters praised the fire department for preventing the fire from spreading to the adjacent dwelling and stated that in the future, the city should carefully consider granting variances which would allow such close construction. 3. Unfinished Business from Previous Meeting There was no unfinished business. 4. Consent Agenda: A. Acknowledge receipt of monthly reports from Building, Code Enforcement, Occupational License and Recreation Departments (City Manager) B. Acknowledge receipt of Public Works Department Project Status Report (City Manager) Commissioner Waters requested that Item C be removed from the Consent Agenda for discussion. Motion: Approve Consent Agenda Items A and B as presented. There was no discussion and the motion carried unanimously. C. Authorize the purchase of two replacement trucks for Public Works under State Contract Bid No. 99-07-0913 at a cost of $28,045.00 and two replacement trucks for Public Works under State Contract Bid No. 97-05-0915 at a cost of $33,222.00 (City Manager) Motion: Authorize the purchase of two replacement trucks for Public Works under State Contract Bid No. 99-07-0913 at a cost of $28,045.00 and two replacement trucks for Public Works under State Contract Bid No. 97-05-0915 at a cost of $33,222.00. City Manager Hanson briefly explained the request and pointed out that the State Contract prices were lower than quotes obtained from local dealers. Commissioner Waters inquired as to the need for a four wheel drive vehicle and Public Works Director Kosoy explained that it was needed to go on the beach and other rough terrain areas of the city. There being no further discussion, the motion carried unanimously. OMMISSIONERS M O T I O N S E C O N D Y E S N O BEAVER X X BORNO X X MITCHELSON X WATERS X MESERVE X BEAVER X BORNO~? X X MITCHELSON X WATERS X X MESERVE X Minutes Page 4- November 8, 1999 5. Committee Reports: There were no Committee Reports. 6. - ~ Action on Resolutions: A. Resolution No. 99-29 A RESOLUTION OF THE CITY OF ATLANTIC BEACH APPOINTING ALAN C. JENSEN AS CITY ATTORNEY, FIXING HIS DUTIES AND RATE OF COMPENSATION, AND PROVIDING AN EFFECTIVE DATE (City Commission) Motion: Adopt Resolution No. 99-29. Commissioner Borno felt the following language should be retained in Section 2 of the document: "and shall provide written legal opinions on any matters when requested by any member of the City Commission". Commissioner Borno felt that this service should be included as part of the monthly retainer fee paid to City Attorney Jensen. Amendment to the motion: Retain in Section 2 of the Resolution approving the City Attorney Contract document: "and shall provide written legal opinions on any matters when requested by any member of the City Commission". A brief discussion concerning payment for providing written legal opinions ensued. City Attorney Jensen felt the work was covered under Section 3 of the contract. After further discussion, the amendment and second were withdrawn. There being no further discussion, the motion carried unanimously. Motion: The effective date of the City Attorney Contract to be December 1,1999. There was no discussion and the motion carried unanimously. 7. Action on Ordinances: A. Ordinance No. 58-99-27 Introduction and First Reading AN ORDINANCE OF THE CITY OF ATLANTIC BEACH, FLORIDA, AMENDING CHAPTER 2, ADMINISTRATION, ARTICLE VI, EMPLOYEE BENEFITS, DIVISION 3, OMMISSIONERS M O T I O N S E C 0 N D Y E S N O BEAVER X BORNO X X MITCHELSON X WATERS X X MESERVE X BoRNO x MITCHELSON X BEAVER X BORNO X X MITCHELSON X WATERS X MESERVE X X Minutes Page 5- November 8, 1999 RETIREMENT SYSTEM, PROVIDING FOR THE TERMINATION OF FIREFIGHTER RELATED PROVISIONS, PROCEDURES AND BENEFITS; PROVIDING THAT SUCH TERMINATION SHALL - ~ COMPLY WITH CHAPTER 175, FLORIDA STATUTES; PROVIDING FOR A SAVINGS CLAUSE; PROVIDING FOR SEVERABILITY AND PROVIDING FOR AN EFFECTIVE DATE (City Manager) Mayor Meserve read Ordinance No. 58-99-27 by title only. Motion: Approve Passage of Ordinance No. 58-99-27 on first reading. City Manager Hanson explained that adoption of the ordinance allowed the Pension Board to transfer funds in accordance with Florida Statute 175.361, but it did not resolve the dollar amount to be transferred to the City of Jacksonville Police and Fire Pension Fund, which was still in question. Commissioner Mitchelson inquired as to the dollar amount to be transferred. Human Resource Director Foster explained in detail the guidelines for disbursement of the funds as listed in his memo dated November 2, 1999 which is attached and made part of this official record as Attachment A. Mayor Meserve suggested that this issue, as well as that of Sherry Drive, be worked out during further discussion with the City of Jacksonville. Mayor Meserve indicated that the final reading and public hearing would be held November 22, 1999. There was no more discussion and the motion carried unanimously. 8. Miscellaneous Business: A. Selection of Mayor Pro Tempore (Mayor) Motion: Appoint Commissioner Rick Beaver as Mayor Pro Tempore. There was no discussion and the motion carried unanimously. B. Public Hearing and action on an application for aUse-by- OMMISSIONERS M O T I O N S E C O N D Y E S N O BEAVER X BORNO X X MITCHELSON X WATERS X MESERVE X BEAVER X BORNO X X MITCHELSON X WATERS X X MESERVE X Minutes Page 6- November 8, 1999 Exception filed by Gerardo Gonzalez to operate a the and stone business at 20 West 3'd Street, on property described as Lots 1- 3, Block 27, Section H, Atlantic Beach, Zoned CG (City Manager) Motion: Grant Use-by-Exception filed by Gerardo Gonzalez to operated a the and stone business at 20 West 3'd Street on property described as Lots 1-3, Block 27, Section H, Atlantic Beach Zoned CG as recommended by the Community Development Board. (The Community Development Board recommended approval with the conditions that five parking spaces be provided for this use, that no outside storage be permitted, that delivery truck traffic avoid the nearby residential neighborhood, and that the exception be granted to the applicant only and for this location only). Mayor Meserve opened the public hearing and no one spoke for or against the request. The public hearing was closed. There was no discussion and the motion carried unanimously. C. Authorize the City Attorney to draft an ordinance closing city parks to the public between sunset and sunrise (City Manager) Motion: Authorize the City Attorney to draft an ordinance closing city parks to the public between sunset and sunrise. City Manager Hanson explained the need for the ordinance and stated that exceptions to the times would be made for parks with lighted courts. There was no discussion and the motion carried unanimously. D. Authorize the Mayor to sign the Certificate of Acceptance of Subgrant Award for Jordan Park Community Center II (City Manager) Motion: Authorize the Mayor to sign the Certificate of Acceptance of Subgrant Award for Jordan Park Community Center II. City Manager Hanson provided background information for the request. There was no discussion and the motion carried unanimously. OMMISSIONERS M O T I O N S E C O N D Y E S N O BEAVER X X BORNO X X MITCHELSON X WATERS X MESERVE X BEAVER X X BoxNO x x MITCHELSON X WATERS X MESERVE X BEAVER X X BoRNO x x MITCHELSON X ATERS X ESERVE X Minutes Page 7- November 8, 1999 E. Authorize staff to apply for an Emergency Management, Preparedness, and Assistance Grant, and authorize the Mayor to sign the related paperwork (City Manager) =Motion: Authorize staff to apply for an Emergency Management Preparedness and Assistance Grant, and authorize the Mayor to sign the related paperwork. There was no discussion and the motion carried unanimously. F. Authorize expenditure of $2,587.32 to Decision One Corporation for essential computer equipment maintenance for one year (City Manager) Motion: Authorize the expenditure of $2,587.32 to Decision One Corporation for essential computer equipment maintenance for one year. There was no discussion and the motion carried unanimously. G. Approve Change Order in the amount of $14,375.00 for additional work in the Water Systems Improvement Project bid under Bid No. 9899-26 (City Manager) Motion: Approve Change Order in the amount of $14,375.00 for additional work in the Water Systems Improvement Project bid under Bid No. 9899-26. Commissioner Waters inquired if someone from staff had inspected the area. Public Works Director Kosoy indicated that the City Inspector Ernie Beadle had inspected the site and found the water table to be higher in that particular area. There being no further discussion, the motion carried unanimously. H. Authorize staff to negotiate a contract with Smith & Gillespie fora Sewer Master Plan, and if unable to negotiate a satisfactory contract, to negotiate with the next most qualified firm (City Manager) Motion: Authorize staff to negotiate a contract with Smith & Gillespie for a Sewer Master Plan, and if unable to negotiate a satisfactory contract, to negotiate with the next most qualified OMMISSIONERS M O T I O N S E C O N D Y E S N O BEAVER X BORNO X X MITCHELSON X X WATERS X MESERVE X BEAVER X X BORNO X X MITCHELSON X WATERS X MESERVE X BEAVER X BORNO X X MITCHELSON X WATERS X X MESERVE X BEAVER X BoRNO x MITCHELSON X X WATERS X MESERVE X Minutes Page 8- November 8, 1999 firm. City Manager Hanson explained that the City followed the requirements of the Consultants Competitive Negotiations Act and selected the top three firms°to perform the required services. Commissioner Waters inquired why staff could not produce the Sewer Master Plan. City Manager Hanson responded that an outside engineer had the required expertise, as well as the capability to produce Geographic Information Systems (GIS) maps and software for the city. He further indicated that the Master Plan would also include a Ten Year Capital Improvement Plan. Mayor Meserve viewed the Ten Year Capital Improvement Program as a first step to obtaining long range plans for all departments. Commissioner Mitchelson concurred with the need for long range plans. There being no further discussion, the motion carried unanimously. 9. City Manager Reports: City Manager Hanson • Reported that the landscape plans for the flyover had been delivered and would be available to the Commission, the Atlantic Beach Beautification Committee and the Mayport Road Beautification Group. He requested Commission comments on the landscaping by November 19t". He pointed out the city would be maintaining the landscaping. • Reported that Glegg Rees, a long time employee of the Public Works Department, had passed away. 10. Reports and/or requests from City Commissioners and City Attorney City Attorney Jensen • Distributed copies of his research into case law concerning the cross in Howell Park. A copy of this case law is attached and made part of this official record as Attachment B. Commissioner Waters OMMISSIONERS M O T I O N S E C O N D Y E S N O Minutes Page 9- November 8, 1999 Inquired if "No Truck" signs could be placed in the Town Center area since large delivery trucks had damaged the new curb. Public Safety Director Thompson indicated that state law did not } allow the city to limit the types of delivery vehicles that use the streets in a particular area., but he would look into the damage issue. Announced that the next meeting of the Town Center Project Oversight Committee would be held on Tuesday, November 9`" at 6:00 p.m. at the Sea Turtle Inn and invited Mayor Meserve to attend. Commissioner Mitchelson Reminded the Commissioners that a letter had been sent to the Jacksonville Transportation Authority (JTA) expressing the city's concerns relating to the Mayport Road/Atlantic Boulevard flyover and inquired if a meeting would be scheduled to address those concerns. Mayor Meserve responded that Roger Sharp of the JTA would be attending a meeting of the Mayport Road Beautification Group on November 15`h at which time those concerns would possibly be addressed. Commented that Carolyn Woods, a resident of the city and a landscape architect, had designed the landscape plans for Mayport Road. A brief discussion concerning high maintenance plants ensued and a set of plans was given to Commissioner Beaver for his review and input. Commissioner Borno With reference to the cross in Howell Park, Commissioner Borno stated he had heard that unless you were a resident of the State of Florida for six months, you could not bring suit. He inquired if this was correct. Commissioner Beaver OMMISSIONERS M O T I O N S E C O N D Y E S N O Minutes Page 10- November 8, 1999 • Requested further discussion on Mr. Kuti's request and stated that he also felt additional time was needed to review certain agenda items. • ~ ~ Noted that the Dagley property was visible from the Tide Views Preserve and requested that the City Manager prepare a report on the history of the property. • Indicated that the had observed the Atlantic Beach fire trucks on San Pablo Road on several occasions and inquired if the City of Jacksonville had increased its service area and if the Atlantic Beach station was a first responder to that area. • Indicated he would like the City Manager to contact the appropriate people concerning opening the Plaza Road entrance to the Atlantic Beach Post Office for residents' use. Mayor Meserve • Reminded everyone of the Tree Lighting Ceremony on December 4rh • Announced that the Mayport Waterfront Partnership would meet at 8:00 a.m. on Tuesday, November 9`h There being no further discussion or business to come before the Commission, the Mayor declared the meeting adjourned at 8:55 p.m. John Meserve Mayor /Presiding Officer ATTEST: Maureen King Certified Municipal Clerk OMMISSIONERS M O T I O N S E C O N D Y E S N 0 n f _ ATTACHMENT A NOVEMBER 8, 1999 COMMISSION MEETING CITY OF ATLANTIC BEACH CITY. COMMISSION MEETING STAFF REPORT AGENDA ITEM: First reading of Ordinance to terminate the firefighter provisions of the City's Pension Plan. SUBMITTED BY: George Foster, Human Resource Manager DATE: November 2, 1999 BACKGROUND: On October 11, 1999, the City Commission completed the first reading of Ordinance 58-99-26 changing the City's Pension Plan to delete references to Fire employees and establishing separate General employee and Police employee pension plans. The public hearing and final reading for this ordinance is pending an actuarial cost impact statement and State of Florida, Division of Retirement, review and approval. The attached ordinance has been prepared by the Pension Board law firm of Sugarman and Susskind and, once finalized, will allow the Pension Board to transfer appropriate funds in accordance with Florida Statute 175.361 (attached) to the City of Jacksonville Police & Fire Pension Fund. The City of Atlantic Beach entered into an agreement to contract Fire Services from the City of Jacksonville effective June 1, 1999. This agreement stated that all assets and liabilities of the Atlantic Beach Fire Department pension Plan existing as of the date of the merger, (approximately 1.5 million dollars) shall be transferred on the date of the merger to the Jacksonville Police & Fire Pension Fund. BUDGET: The current assets within the Atlantic Beach Fire Pension Fund are invested within equities and/or bonds; therefore, the market value of the Atlantic Beach Fire Pension Fund varies on a day to day basis. i~ r ~ The Atlantic Beach Pension Board is.required to disperse funds in accordance the specific guidelines of FS 175.361 with any "surplus" assets being returned to the City of Atlantic Beach, less return to _ „ the state of the state's contributions, i.e., FS 175 funds. Therefore, the Pension Board may not be able to provide the City of Jacksonville with all assets of the Fire Pension Fund. Since FS177.361 does not allow surplus funds to be sent to the City of Jacksonville, the City of Atlantic Beach may have a legal obligation to pay to the City of Jacksonville the difference between what is allowed by FS 177.361 and "all funds." Although this amount fluctuates based upon market conditions, it maybe approximately $150,000.00 to $250,000.00. RECOMMENDATION: That the City Commission: 1. Conduct a first reading of the attached ordinance. 2. Establish November 22, 1999 as the date for a final reading. ATTACHMENTS: 1. Proposed Ordinance 2. FS175.361 REVIEWED BY CITY MANAGER: ORDINANCE NO. 58-99-27 AN ORDINANCE OF THE CITY OF ATLANTIC BEACH, FLORIDA, AMENDING CHAPTER 2, ADMINISTRATION, ARTICLE VI, EMPLOYEE BENEFITS, DIVISION 3, RETIREMENT SYSTEM, PROVIDING FOR THE TERMINATION OFFIItEFIGHTERRELATED PROVISIONS, - PROCEDURES AND BENEFITS; PROVIDING THAT SUCH TERMINATION SHALL COMPLY WITH CHAPTER 175, FLORIDA STATUTES; PROVIDING FOR A SAVINGS CLAUSE; . PROVIDING FOR SEVERABILITY AND PROVIDING FOR AN EFFECTIVE DATE. WHEREAS, the City of Atlantic Beach, Florida has entered into an agreement to contract for Fire Services from the City of Jacksonville, Florida effective June 1, 1999; and WHEREAS, the City of Atlantic Beach, Florida has agreed to transfer all active, retired and vested Firefighters and necessary retirement system assets, liabilities and obligations to the City of Jackson~711e, Florida; and WHEREAS, the City ofJacksonville, Florida has accepted City ofAtlantic BeachFirefighters as members of the City of Jacksonville Police & Fire Pension Fund with full rights and benefits in accordance with Chapter 121 City ofJacksonville Ordinance code by enactment of Ordinance 1999- 472-E and in accordance with Resolutions 95-944-256 and 98-1006; and WHEREAS, the City of Jacksonville, Florida has agreed to establish asub-account for all retired and vested City of Atlantic Beach Firefighters to ensure that their rights in effect on the date of the merger are protected in accordance with the terms of the prior Atlantic Beach Pension Plan; and WHEREAS, the City of Atlantic Beach, Florida must comply with Chapter 175 ofthe Florida Statutes in executing said agreement: t NOW THEREFORE, BE IT ENACTED BY THE CITY COMMISSION ON BEHALF OF THE PEOPLE OF THE CITY OF ATLANTIC BEACH FLORIDA, AS FOLLOWS Section 1. All Firefighter related benefits provided in the City of Atlantic Beach Code of Ordinances, Chapter 2, Administration, Article VI, Division 3, Employer Benefits, Retirement System shall terminate and no longer be of any force or effect effective 1 June 1999. The firefighter provision of the pension plan shall terminate in accordance with Florida Statutes § 175.361 as applicable. Section 2. The provisions adopted herein shall prevail over any existing sections of the Atlantic Beach Code to the extent said existing sections contrary or inconsistent herewith. Section 3. If any section, sentence, clause, word, or phase, of this ordinance is held unconstitutional or invalid by a court of competent jurisdiction, then said holding in no way affects the validity of any remaining portions of this Ordinance. Section 4. This Ordinance shall take effect immediately upon its final passage and adoption. PASSED by the City Commission on first reading this day of PASSED by the City Commission on second and final reading this 1999. ATTEST: City Clerk Approved as to form and correctness: Mayor day of 1999. City Attorney Florida House of Representatives - 1999 CS/HS 261 Florida House of Representativestf 1999. ~ CS/HS 261 688-101-99 68B-101-99 ;'' 1 1 governmental units, services, or functions as provided in 2 2 chapter 121, or upon written notice by the municipality or 3 3 special fire control district to the board of trustees that 4 4 contributions under the plan are being permanently 5 5 discontinued, the rights of all employees to benefits accrued G 6 to the date of such termination and the amounts credited to "i 7 the employees' accounts are nonforfeitable.The fund shall be 9 8 apportioned and distributed in accordance with the following y 9 procedures: 10 ~ 10 (1) The board of trustees shall determine the date of 11 11 distribution and the asset value to be distributed, after 12 12 taking into account the expenses of such distribution. 13 13 (2) The board of trustees shall determine the method la 14 of distribution of the asset value, that is, whether 15 15 distribution shall be by payment in. cash, by the maintenance 16 16 of another or substituted trust fund, by the purchase of 17 17 insured annuities, or otherwise, for each firefighter entitled 1B 18 to benefits under the plan as specified in subsection (3). 19 19 (3) The board of trustees shall. apportion the asset 20 20 value as of the date of termination in the manner set forth in 21 21 this subsection, on the basis that the amount required to 22 22 provide any given retirement income. shall mean the actuarially 23 23 computed single-sum value of such retirement income, except 24 175.361 Termination of plan and distribution of 24 that if the method of distribution determined under subsection 25 fund.--For any municipality, special fire control district, 25 (2) involves the purchase of an insured annuity, the amount 26 chapter plan, local law municipality, local law special fire 26 required to provide the given retirement income shall mean the 2~ control district, or local law plan under this chapter, the 27 single premium payable for such annuity. 28 plan may be terminated by the municipality or special fire 28 (a) Apportionment shall 'first be made in respect of 29 control district. Upon termination of the plan by the 29 each retired firefighter receiving a retirement income 30 municipality or special fire control district for any reason JO hereunder on such date, each person receiving a retirement 31 or because of a transfer, merger, or consolidation of 31 income on such date on account of a retired (but since • .... 55 5 6 CODING:Words :_~~**.* are deletions; words underlined are .additions. COD ZHC:Words atrrekerr are deletions; words underlined are additions. Florida )louse of Representatives - 1999 688-101-99 CS/HB 261 Florida House of Representatives - 1999 • 688-101-99 r <r decFased) firefighter, and each firefighter who has, by such data, become eliyible Car normal retirement but has not yet retired, in the amount required to provide such•retirement incr~ma, pro•ided that, if such asset value is less than the aggre~~ata of such amcunts, such amounts shall be prapr~rtianately reduced so that the aggragate_of such reduced amounts will be equal to such asset value. (L•) If there is any asset value remaining attar the ap~~cllonmant undar paragraph (a), apportionment shall next be made in respect of each fire[ighter in the service o[ the municipality oc special Eire control district on such date who has completed at least 10 years of credited service, in why haz-rentrrbntad-to the fira[ighters' pension trust Cund for at least 10 years, and who 1s not entitled to an apportionment under paragraph (a), in the amount required to provide khe actuarial equivalent of the accrued normal retirement income, based on the firefighter's credited service and earnings to such data, and each former participant then entitled to a benefit undar the provisions of s. 175.211 tithe has not by such date reached his or liar normal retiremant data, in the amount required to provide the actuarial equivalent of the accrued normal retirement income to which he or she is entitled under s. 175.211; provided that, if such remaining asset value is lass than the aggregate of the amounts apportioned hereunder, suc)i latter amounts shall be proportionately reduced so that the aggregate of such reduced amounts will be equal to such remaining asseC value. (c) If there is any asset value after the apportionments undar paragraphs (a) and (b); apportionment shall lastly be made in respect of each firefighter in the service of the municipality or special fire control district 57 IODING:Words st rickerr are dilations; words underlined are additions. CS/HB 261 1 on such date who is not entitled to art apportionment under 2 paragraphs (a) and (b) in the amounC equal to the 3 firefighter's total contributions to the plan to date of 4 termination; provided that, if such remaining asset value is 5 less than the aggregate of the amounts apportioned hereunder, 6 such latter amounts shall be proportionately raduced so that 7 the aggregate o[ such reduced amounts will be equal to such e remaining asset value. 9 (d) In the event that there is asset value remaining 10 'after the full apportionment specified in .paragraphs (a), (b), 11 and (c), such excess shall be returned to the municipality or 12 special fire control district, less return to the state of the 13 state's contributions, provided Chat, if the excess is less 14 than the .total contributions made by the municipalfty or 15 special fire control district and the state to date of 16 termination of the plan, such excess shall be divided 17 proportionately to the total contributions made by the 18 municipality or special fire control district and the state. 19 (4) The board of trustees shall distribute, in 20 accordance with the manner of distribution determined under 21 subsection (2), the amounts apportioned under subsection (3). 22 23 If, after a period of 24 months after the date on which the 24 plan terminated or the date on which the board received 25 written notice that the contributions thereunder were being 26 permanently discontinued, the municipality or special fire 27 control district or the board of •trustees of the Cire.fighters' 28 pension trust fund affected has not complied with all the. 29 .provisions in this section, the division shall effect the 30 termination of the fund in accordance with this section. 31 58 CODYNG:Words stri-ckerr are deletions) words underlined are additions. r S r.~ .- ' a ATTACHMENT B NOVEMBER 8, 1999 COMMISSION MEETING ALAN C. J~.~~~ Attorney at Law 935 North Third Street Post Office Box 50457 Jacksonville Beach, Florida 32240-0457 Telephone (944) 2f16-2500 Facsimile (904) ?A6-9960 November 8, 1999 Mayor and City Commissioners City of Atlantic Beach 800 Seminole Road Atlantic Beach, FL 32233 Re: Cross in Howell Park Dear Mayor and Commissioners: The City of Atlantic Beach owns and maintains various parks. One of these, Howell Park, is located in the middle of a residential area. Sometime during the summer of this year, the City received a letter (Ex. A) from a resident objecting to a wooden cross (approximately eight to ten feet in height with asix-foot cross-tie) that had been erected in the park, apparently sometime earlier. The City researched the issue and was unable to determine who placed the cross in the park or when it was placed there. The City did determine that the cross was not owned and had not been installed by the City. On July 2, 1999, I wrote a brief memorandum (Ex. B) to the city manager, who had passed the resident's letter on to you. In that memorandum, I stated, in part: I do not believe there is anything to indicate that the cross has been used to support, aid, maintain or establish any religion or religious edifice, or that its purpose was to promote the participation by anyone in the affairs of any religious organization or sect. If my assumptions are correct, it would appear that the cross does not amount to the establishment of a religion in violation of the First Amendment of the United States Constitution, nor does it amount to any religious activity controlled, supported or influenced by the City of Atlantic Beach. On October 18, 1999, the City received a letter from Annie Laurie Gaylor of the Freedom From Religion Foundation, Inc. (Ex. C), in which Ms. Gaylor made a formal request that the cross be removed, stated that "[t]here is no instance of a cross erected Mayor and City Commissioners November 8, 1999 Page 2 on public property in this manner ever being permitted to stay on public property in any resolved legal dispute," and asserted that. "San Diego v. Poulson," 990 F.2d 1518 (9th. Cir. 19..), cert. denied sub nom. County of San Diego v. Murphy, 512 U.S. 1220 --~ (1994), represents "affirmations" by the Supreme Court of such cases. Ms. Gaylor also stated in her letter: The presence of this Christian symbol in your public park is a violation of the Establishment Clause, and of Art. I, Sect. 3 of the Florida Constitution. The fact that the city did not erect this cross does not mitigate the fact that it has endorsed the presence of the cross by refusing to remove the illegal symbol when requested. A similar practice in Alabama state parks where religionists had erected permanent crosses was nixed there by court decree. If someone rents the park for a wedding they can certainly erect a temporary cross, but they must remove it. It cannot be left there permanently. I have been requested to provide you with more extensive research on the issues raised by Ms. Gaylor. At the outset, I should point out that Ms. Gaylor's contention that the U.S. Supreme Court's denials of certiorari review in cases in which the placement of religious symbols on public property has been found to violate the Establishment Clause of the United States Constitution amount to "affirmations" of those decisions is incorrect. As you may know, the denial of certiorari review by the Supreme Court does not constitute an affirmance or even approval of the judgment. House v. Mayo, 324 U.S. 42 (1945) (denial of certiorari by Supreme Court imports no expression of opinion upon merits of issue appealed). The identical rule applies to the denial of certiorari review by Florida courts. See, Mystan Marine, Inc. v. Harrington, 339 So.2d 200 (F1a.1976) Knight, v. Munday Plastering Company, 220 So.2d 357 (F1a.1969); Southern Bell Tel. & Tel. Co. v. Bell, 116 So.2d 617 (Fla. 1959); Bevan v. Wanicka, 505 So.2d 1116 (Fla. 2d DCA 1987). I also note that Ms. Gaylor's citation of the case reported at 990 F.2d 1518 (9th Cir. 1993), cert. denied, ... U.S. ... (1994) as San Diego v. Poulson is incorrect. The correct case name is Ellis v. City of La Mesa. It is also noteworthy that the Ellis court decided that case, which involved two Latin crosses located in public parks, under the "No Preference Clause" of California's Constitution. The court specifically stated that it was "not commenting on whether such memorials [such as one of the crosses which Mayor and City Commissioners November 8, 1999 Page 3 was dedicated to veterans of World Wars I and II and the Korean War] violate the federal Constitution." .990 F.2d at 1528.. =, ;Having noted these specific errors in Ms. Gaylor's letter, I will now turn to a more general consideration of the overall merits of her contention that the cross must be removed even if it was not erected by the City. In order to evaluate the merits of Ms. Gaylor's claim, it is necessary to briefly review the controlling law under both the federal and Florida constitutions. The First Amendment to the U.S. Constitution -which applies to the states via the Fourteenth Amendment- provides that "Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; ..." The most definitive statement by the Supreme Court of the proper test to apply when the Establishment Clause is invoked to challenge either legislation or governmental practice is found in Lemon v. Kurtvnan, 403 U.S. 602 (1971), wherein the Supreme Court stated: In the absence of precisely stated constitutional. prohibitions, we must draw lines with reference to the three main evils against which the Establishment Clause was intended to afford protection: "sponsorship, financial support, and active involvement of the sovereign in . religious activity." Walz v. Tax Commission, 397 U.S. 664, 668, 90 S.Ct. 1409, 1411, 25 L.Ed.2d 697 (1970). Every analysis in this area must .begin with consideration of the cumulative criteria developed by the Court over many years. Three such tests may be gleaned from our cases. First, the statute must have a secular legislative purpose; second, its principal or primary effect must be one that neither advances nor inhibits religion, Board of Education v. Allen, 392 U.S. 236, 243, 88 S.Ct. 1923, 1926, 20 L.Ed.2d 1060 (1968); finally, the statute must not foster "an excessive government entanglement with religion." Walz, supra, at 674, 90 S.Ct. at 1414. 403 U.S. at 612-613. Where a governmental practice, rather than a statute, is at issue, the Lemon test is also applied. See, e.g., Lynch v. Donnelly, 465 U.S. 668 (1984) (Lemon test applied to government-sponsored holiday religious display). The continued validity of the Lemon factors in dealing with Establishment Clause issues has been recently confirmed in cases in which overt or perceived government conduct is Mayor and City Commissioners November 8, 1999 Page 4 not at issue, see, e.g., Agostini v. Felton, 521 U.S. 203 (1997); Lamb's G'hapel v. Center Moriches School District, 508 U.S. 384 (1993), despite the urging of several Justices that an "endorsement" test (which is a refinement of the "effect" prong of the '.Lemon test) be applied in all Establishment Clause cases, not only in those in which a government's speech or its grants of financial aid to religious organizations link that government with religious activity in such a way as to violate the Establishment Clause. See, Lynch v. Donnelly, 465 U.S. 668 (1984) (Justice O'Connor's concurrence); Capitol Square Review and Advisory Board v. Pipette, 515 U.S. 753 (1995) (concurrence by Justices O'Connor, Souter, and Breyer). See also, Adler v. Duval County School Board, 174 F.3d 1236 (11th Cir. 1999); Easley v. State, _So.2d , 24 Fla. L. Weekly D1826 (Fla. 4th DCA August 4, 1999); Guyer v. School Board of Alachua Cotcnty, 634 So.2d 806 (Fla. 1st DCA 1994). The closest, most instructive, and most recent Supreme Court decision in this area of law is Capitol Square Review and Advisory Board v. Pipette, 515 U.S. 753 (1995), wherein the Court considered whether the denial of an application of the Ku Klux Klan to place an unattended cross on Capitol Square, the Ohio Statehouse Plaza, during the Christmas season was supported by the Establishment Clause. In affirming the judgment of the district court requiring the issuance of the requested permit, the Court reviewed several of its pertinent prior decisions and held: Petitioners do not claim that their denial of respondents' application was based upon acontent-neutral time, place, or manner restriction. To the contrary, they concede-indeed it is the essence of their case-that the Board rejected the display precisely because its content was religious. Petitioners advance a single justification for closing Capitol Square to respondents' cross: the State's interest in avoiding official endorsement of Christianity, as required by the Establishment Clause. III. There is no doubt that compliance with the Establishment Clause is a state interest sufficiently compelling to justify content-based restrictions on speech. See Lamb's Chapel, supra, at 394-395; Widmar, supra, at 271. Whether that interest is implicated here, however, is a different question. And we do not write on a blank slate in answering it. We have twice previously addressed the combination of private religious expression, a forum available for public use, content-based regulation, and a Mayor and City Commissioners November 8, 1999 Page 5 State's interest in complying with the Establishment Clause. Both times, we have struck down the restriction on religious content. Lamb's Chapel, supra; Wtdmar, _ > supra. In Lamb's Chapel, a school district allowed private groups to use school facilities during off-hours for a variety of civic, social and recreational purposes, excluding, however, religious purposes. We held that even if school property during off-hours was not a public forum, the school district violated an applicant's free- speech rights by denying it use of the facilities solely because of the religious viewpoint of the program it wished to present. 508 U. S. at 390-395. We rejected the district's compelling-state-interest Establishment Clause defense (the same made here) because the school property was open to a wide variety of uses, the district was not directly sponsoring the religious group's activity, and "any benefit to religion or to the Church would have .been no more than incidental." Id., at 395. The Lamb's Chapel reasoning applies a fortiori here, where the property at issue is not a school but afull-fledged public forum. Lamb's Chapel followed naturally from our decision in Widmar, in which we examined a public university's exclusion of student religious groups from facilities available to other student groups. There also we addressed official discrimination against groups who wished to use a "generally open forum" for religious speech. 454 U. S., at 269. And there also the State claimed that its compelling interest in complying with the Establishment Clause justified the content-based restriction. We rejected the defense because the forum created by the State was open to a broad spectrum of groups and would provide only incidental benefit to religion. Id., at 274. We stated categorically that "an open forum in a public university does not confer any imprimatur of state approval on religious sects or practices." Ibid. Quite obviously, the factors that we considered determinative in Lamb's Chapel and Widmar exist here as well. The State did not sponsor respondents' expression, the expression was made on government property that had Mayor and City Commissioners November 8, 1999 Page 6 been opened to the public for speech, and permission was requested through the same application process .and on the. same terms required of other private groups. IV. Petitioners argue that one feature of the present case distinguishes it from Lamb's Chapel and Wtdmar: the forum's proximity to the seat of government, which, they contend, may produce the perception that the cross bears the State's approval. They urge us to apply the so-called "endorsement test," see, e.g., Allegheny County v. American Civil Liberties Union, Greater Pittsburgh Chapter, 492 U. S. 573 (1989); Lynch v. Donnelly, 465 U. S. 668 (1984), and to find that, because an observer might mistake private expression for officially endorsed religious expression, the State's content-based restriction is constitutional. We must note, to begin with, that it is not really an "endorsement test" of any sort, much less the "endorsement test" which appears in our more recent Establishment Clause jurisprudence, that petitioners urge upon us. "Endorsement" connotes an expression or demonstration of approval or support. The New Shorter Oxford English Dictionary 818 (1993); Webster's New Dictionary 845 (2d ed. 1950). Our cases have accordingly equated "endorsement" with "promotion" or "favoritism. " Allegheny County, stcpra, at 593 (citing cases). We find it peculiar to say that government "promotes" or "favors" a religious display by giving it the same access to a public forum that all other displays enjoy. And as a matter of Establishment Clause jurisprudence, we have consistently held that it is no violation for government to enact neutral policies that happen to benefit religion. See, e.g., Bowen v. Kendrick, 487 U. S. 589, 608 (1988); Witters v. Washington Dept. of Services for Blind, 474 U. S. 481, 486-489 (1986); Mueller v. Allen, 463 U. S. 388 (1983); McGowan v. Maryland, 366 U. S. 420 (1961). Where we have tested for endorsement of religion, the subject of the test was either expression by the government itself, Lynch, supra, or else government action alleged to discriminate in favor of private religious expression or activity, Board q i Mayor and City Commissioners November 8, 1999 Page 7 of Etl. of Kiryas Joel Village School Dist. v. Grumet, 512 U. S. 687, 708-710 (1994); Allegheny County, supra. The test petitioners propose, which would attribute to a r neutrally behaving government private religious expression, has no antecedent in our jurisprudence, and would better be called a "transferred endorsement" test. Petitioners rely heavily on Allegheny County and Lynch, but each is easily distinguished. In Allegheny Coacnty we held that the display of aprivately-sponsored creche on the "Grand Staircase" of the Allegheny County Courthouse violated the Establishment Clause. That staircase was not, however, open to all on an equal basis, so the County was favoring sectarian religious expression. 492 U. S., at 599-600, and n. 50 ("The Grand Staircase does not appear to be the kind of location in which all were free to place their displays"). We expressly distinguished that site from the kind of public forum at issue here, and made clear that if the staircase were available to all on the same terms, "the presence of the cache in that location for over six weeks would then not serve to associate the government with the creche." Ibid. (emphasis added). In Lynch we held that a city's display of a cache did not violate the Establishment Clause because, in context, the display did not endorse religion. 465 U. S., at 685-687. The opinion does assume, as petitioners contend, that the government's use of religious symbols is unconstitutional if it effectively endorses sectarian religious belief. But the case neither holds nor even remotely assumes that the government's neutral treatment of private religious expression can be unconstitutional. Petitioners argue that absence of perceived endorsement was material in Lamb's Chapel and Widmar. We did state in Lamb's Chapel that there was "no realistic danger that the community would think that the District was endorsing religion or any particular creed," 508 U. S., at 395. But that conclusion was not the result of empirical investigation; it followed directly, we thought, from the fact that the forum was open and the religious activity privately sponsored. See ibid. It is significant that we referred only to what would be thought by "the Mayor and City Commissioners November 8, 1999 Page 8 community"-not by outsiders or individual members of the community uninformed -about the school's practice. Surely some of the latter, hearing of religious ceremonies t on school premises, and not knowing of the premises' availability and use for all sorts of other private activities, might leap to the erroneous conclusion of state endorsement. But, we in effect said, given an open forum and private sponsorship, erroneous conclusions do not count. So also in Widmar. Once we determined that the benefit to religious groups from the public forum was incidental and shared by other groups, we categorically rejected the State's Establishment Clause defense. 454 U. S., at 274. What distinguishes Allegheny Coccnty and the dictum in Lynch from Widmar and Lamb's Chapel is the difference between government speech and private speech. "[T]here is a crucial difference between .government speech endorsing religion, which the Establishment Clause forbids, and private speech endorsing religion, which the Free Speech and Free Exercise Clauses protect." Mergens, 496 U. S., at 250 (O'Connor, 7., concurring). Petitioners assert, in effect, that that distinction disappears when the private speech is conducted too close to the symbols of government. But that, of course, must be merely a subpart of a more general principle: that the distinction disappears whenever private speech can be mistaken for government speech. That proposition cannot be accepted, at least where, as here, the government has not fostered or encouraged the mistake. Of course, giving sectarian religious speech preferential access to a forum close to the seat of government (or anywhere .else for that matter) would violate the Establishment Clause (as well as the Free Speech Clause, since it would involve content discrimination). And one can conceive of a case in which a governmental entity manipulates its administration of a public forum close to the seat of government (or within a government building) in such a manner that only certain religious groups take advantage of it, creating an impression of endorsement that is in fact accurate. But those situations, which involve governmental favoritism, 7 ~ Mayor and City Commissioners November 8, 1999 Page 9 do not exist here. Capitol Square is a genuinely public forum, is known to be a public forum, and has been widely used as a public forum for many, many years. _ _ Private religious speech cannot be subject to veto by those who see favoritism where there is none. The contrary view, most strongly espoused by 7USTICE STEVENS, post, at 806-$07, but endorsed by 7USTICE SOUTER and 7USTICE O' CONNOR as well, exiles private religious speech to a realm of less-protected expression heretofore inhabited only by sexually explicit displays and commercial speech. Young v. American Mini Theatres, Inc., 427 U. S. 50, 61, 70-71 (1976); Central Htcdson Gas & Electric Corp. v. Public Serv. Comm'n of N. Y., 447 U. S. 557 (1980). It will be a sad day when this Court casts piety in with pornography, and finds the First Amendment more hospitable to private expletives, see Cohen v. California, 403 U. S. 15, 26 (1971), than to private prayers. This .would be merely bizarre were religious speech simply as protected by the Constitution as other forms of private speech; but it is outright perverse when one considers that private religious expression receives preferential treatment under the Free Exercise Clause. It is no answer to say that the Establishment Clause tempers religious speech. By its terms that Clause applies only to the words and acts of government. It was never meant, and has never been read by this Court, to serve as an impediment to purely private religious speech connected to the State only through its occurrence in a public forum. Since petitioners' "transferred endorsement" principle cannot possibly be restricted to squares in front of state capitols, the Establishment Clause regime that it would usher in is most unappealing. To require (and permit) access by a religious group in Lamb's Chapel, it was sufficient that the group's activity was not in fact government sponsored, that the event was open to the public, and that the benefit of the facilities was shared by various organizations. Petitioners' rule would require school districts adopting similar policies in the future to guess whether some undetermined critical mass of the community might nonetheless perceive the district to be a Mayor and City Commissioners November S, 1999 Page 10 advocating a religious viewpoint. Similazly, . estate universities would be forced to reassess our statement that "an open forum in a public university does not confer any ~~ imprimatur of state approval on religious sects or practices." Widmar, 454 U. S., at 274. Whether it does would henceforth depend upon immediate appearances. Policy makers would find themselves in a vise between the Establishment Clause on one side and the Free Speech and Free Exercise Clauses on the other. Every proposed act of private, religious expression in a public forum would force officials to weigh a host of imponderables. How close to government is too close? What kind of building, and in what context, symbolizes state authority? If the State guessed wrong in one direction, it would be guilty of an Establishment Clause violation; if in the other, it would be liable for suppressing free exercise or free speech (a risk not run when the State restrains only its own expression). The "transferred endorsement" test would also disrupt the settled principle that policies providing incidental benefits to religion do not contravene the Establishment Clause. That principle is the basis for the constitutionality of a broad range of laws, not merely those that implicate free-speech issues, see, e.g., Witters v Washington Dept. of Servs. For Blind, 474 U.S. 481 (1986); Mcceller v. Allen, 463 U.S. 388 (1983). It has radical implications for our public policy to suggest that neutral laws are invalid whenever hypothetical observers may-even reasonably-confuse an incidental benefit to religion with state endorsement. If Ohio is concerned about misperceptions, nothing prevents it from requiring all private displays in the Square to be identified as such. That would be a content- neutral "manner" restriction which is assuredly constitutional. See Clark v. Community for Creative Non- Violence, 468 U. S. 288, 293 (1984). But the State may not, on the claim of misperception of official endorsement, ban all private religious speech from the public square, or discriminate against it by requiring religious speech alone to disclaim public sponsorship. x~** .c Mayor and City Commissioners November S, 1999 Page 11 Religious expression cannot violate the Establishment Clause where it (1) is purely private and (2) occurs in a traditional or designated public forum, publicly announced and open to all on equal terms. Those conditions are satisfied here, and therefore the State may not bar respondents' cross from Capitol Square. 515 U.S. at 761-70 (footnotes omitted and emphasis in original). As is suggested by the above-cited opinion, several specific factual inquiries are pertinent to the proper application of the Lemon test to a situation in which the symbol to be displayed in a public place is not owned by the government and is clearly sectarian. Those deemed most important by the Capitol Square court include the nature and use by the public of the forum in which the sectarian symbol was displayed and the ownership and/or maintenance of that sectarian symbol on governmental property. Related to these inquiries was a consideration of whether the community would view the location of the symbol on public property as constituting agovernment-sponsored or government-endorsed st<~ttement in favor of the religion represented by the symbol. The application of Capitol Sgtcare to the facts presented suggests that if Howell Park is open to the public, without discrimination, for all types of activities, whether secular or sectarian, and if the City is not involved with the maintenance of the cross (e. g. , painting or repair) and does not claim ownership or sponsorship thereof, the presence of the cross is unlikely to be found to violate the Establishment Clause. If, as in Capital Square, the city's policy allows private individuals generally to exercise "symbolic speech" in Howell Park or other parks by erecting structures having significance to religious or other privately-held beliefs, then the fact that this particular structure suggests belief in the Christian religion would not cause a reasonable observer to conclude that the government was favoring Christianity over other religions or belief systems. On the other hand, if the City generally prohibits the erection of structures on its parks by private citizens, then its tolerance of this cross might reasonably lead one to conclude that the government was providing its own sanction or approval (albeit informal and "unofficial") of Christianity. See, American Jewish Congress v. City of Beverly Hills, 90 F.3d 379 (9th Cir. 1996) (holding that city violated Establishment Clause by allowing private group to erect a menorah in a city-owned park, even though a sign stated that the menorah was not erected, maintained or financed by the city; this holding was based on the fact that the city's general policy was to prohibit erection of structures in public parks by private parties; the exception which was made for the menorah was arbitrary, and not made pursuant to any "neutral" provisions for allowing ~ ' .f Mayor and City Commissioners November 8, 1999 Page 12 structures to be built in accordance with well-defined ..standards; court distinguished Capital Square on ground that the. "public form" in-that case was generally open for use by private individuals and groups to express their beliefs). If the City is found to own (perhaps by virtue of the length of time the cross has remained undisturbed in the park) or to have maintained the cross, a violation of the Establishment Clause may be found, based upon the perceived endorsement by the City of the religion behind the symbol. Although I have found no cases directly on point, i.e., where a religious symbol has been placed on government property by an unknown party or parties and has remained there for a long period of time, I believe it is wise to consider how a court is likely to view an Establishment Clause challenge in the event the City is determined to own and/or maintain this cross. An illustrative case is Separation of Chtcrch and State Committee v. City of Eugene of Lane County, 93 F.3d 617 (9th Cir. 1996), wherein the court held that the city's maintenance in a public park of a fifty-one foot Latin cross, which had been deeded to the city from private parties as a gift and had been designated as a war memorial, represented governmental endorsement of Christianity. Since 1970, the cross had been illuminated by the city for seven days during the Christmas season, five days during the Thanksgiving season, and on Memorial Day, Independence Day, and Veteran's Day. Similarly, in American Civil Liberties Union of New Jersey v. Schundler, 104 F.3d 1435 (3d Cir. 1997), the court considered whether the City of jersey City should be permitted to erect a display containing a creche and a menorah on the lawn in front of its city hall. This display had been erected and maintained by the city and had been displayed during the winter holidays for thirty years. The court read the plurality opinion in Capitol Square as indicating that "at least a majority of the Court would apply anendorsement-test to determine the constitutionality of agovernment-sponsored religious display on government property," 104 F.3d at 1444, and proceeded to hold that the display, which was owned and displayed by the city government on city government property, violated the Establishment Clause under that test. The court stated, in part: Under the endorsement test, a display violates the Establishment Clause if, in its particular setting, the display is "sufficiently likely to be perceived by adherents of the controlling denominations as an endorsement, and by non-adherents as a disapproval of their individual religious choices." Allegheny County, 492 U.S. at 597, 109 S.Ct. at 3103. In applying the endorsement test to ,. Mayor and City Commissioners November 8, 1999 Page 13 Jersey City's display, we must consider the particular effects of its display of a creche. One of the principles that emerges from the shifting pluralities of Allegheny County is that government erection of a creche creates an inherent risk of perceived endorsement. The cache, which depicts the event that lies at the very core of Christianity, is an unambiguous religious symbol. Indeed, Justice O'Connor in Allegheny County recognized that a creche is "the central religious symbol of the Christmas holiday." Id. at 627, 109 S.Ct. at 3119. A creche represents the Christian belief that Jesus was born to the Virgin Mary to lead humankind on a path toward salvation and redemption. Yet Jersey City would have us believe that the symbol of the crirche has achieved such alevel of secular status that it is religiously benign. We are not so persuaded. The mere fact that a religious symbol is pervasively displayed during the holiday season does not diminish its religious significance. A creche unambiguously represents a belief that is not universally shared by the citizens of this country. In fact, many citizens believe that Jesus may only be understood as a Hebrew prophet. For some devout observers of their respective faiths, it is heresy to ascribe a divine character or purpose to Jesus' life or death. Indeed, as Justice Brennan recognized in his dissent in Lynch, "[F]or Christians, that path [toward salvation and redemption] is exclusive, precious, and holy. But for those who do not share these beliefs, the symbolic reenactment of the birth of a divine being who has been miraculously incarnated as a man stands as a dramatic reminder of their differences with Christian faith." Lyncla, 465 U.S. at 708, 104 S.Ct. at 1378 (Brennan, J., dissenting). When government chooses to speak by erecting a creche on government property, the principles at the core of the Establishment Clause are clearly implicated. See Capitol Square, --- U.S. ---, 115 S. Ct. at 2448 ("In Allegheny County, we held that the display of a privately- sponsored creche on the 'Grand Staircase' of the Allegheny County Courthouse violated the Establishment Clause. That staircase vas not, however, open to all on an ,~ Mayor and City Commissioners November 8, 1999 Page 14 equal basis, so the County was. favoring sectarian religious expression. "). By erecting a cri3che itself, on .city property, a city sends a stronger message of endorsement of religion than .when it merely provides a forum for private religious speech. In the former context, the government is effectively conveying the message that "we celebrate the holiday season by recognizing the birth of Christ." As Justice O'Connor noted in Allegheny County, "[T]he display of religious symbols in public areas of core government buildings runs a special risk of making religion relevant, in reality or in public perception, to status in the political community. "Allegheny County, 492 U.S. at 626, 109 S.Ct. at 3119 (O'Connor, 7., concurring). Accordingly, we conclude that Jersey City's display of a creche on City Hall Plaza -- the.very seat of Jersey City government -- conveyed a message of religious endorsement. Further, we note that the expenditure of public funds to erect and maintain a religious display directly implicates the Establishment Clause. Jersey City's display was erected and maintained with public funds. If a city taxpayer objected to the religious display, he or she could not have opted out of contribution to the display, even if fundamentally repugnant to his or her own beliefs. Of course, taxpayers often exercise little control over how the government spends its money on a daily basis, but the Establishment Clause presents unique constraints on the expenditure of public funds for religious purposes. Most importantly, the Establishment Clause requires the government to remain neutral towards religion in its expenditure of public funds.. Here, Jersey City expressed a religious preference by erecting a religious display through the expenditure of taxpayer dollars. Moreover, by using taxpayer dollars to fund a display containing religious symbols, Jersey City has increased the risk that -the display's religious message will be attributed to the city and its taxpayers. In other words, Jersey City's use of public funds to erect and maintain its display increased the "risk of making religion relevant to status in [Jersey City's] political Mayor and City Commissioners November 8, 1999 Page 15 community.." Allegheny County, 492 U.S. at 626, 109 S.Ct. at 3119 (O'Connor, J., concurring). Jersey City's display of a creche was accompanied --.= by a menorah, a sign, and a Christmas Tree. Jersey City maintains that this context alters the message of endorsement conveyed by the display of the creche. We disagree. The menorah is a religious symbol. And when displayed with a creche, the menorah's religious significance is emphasized. Moreover, the token inclusion of the Christmas tree does little to mitigate the religious message of the creche and the menorah. Thus, the display cannot be viewed as anything but a constitutionally impermissible dual endorsement of Christianity and Judaism. Read together, Lynch, Allegheny County, and Capitol Sgacare emphasize the importance of perceived government endorsement of religion in Establishment Clause analysis. A comparison of Jersey City's display with the displays involved in Allegheny County and Lynch reinforces the conclusion that Jersey City's original display impermissibly endorsed religion. In Allegheny County, aprivately-owned nativity scene was displayed on the main staircase of the county courthouse, bounded by a wooden fence, poinsettias, and a plaque stating "This Display Donated by the Holy Name Society." Allegheny County, 492 U.S. at 580, 109 S.Ct. at 3094. Thus, even with a sign proclaiming private ownership of the display, the Court held that the display, in its context (on the grand staircase of the Allegheny County Courthouse), communicated state endorsement of religion. In Lynch,-the government-owned and maintained creche was part of a "winter wonderland" display and was situated in a privately-owned park not located near any visible seat of government. Because there were no external indicia of government sponsorship of the creche, the risk of perceived endorsement was significantly lessened. And in Capitol S2uare, the Court upheld the constitutionality of the display of aprivately-sponsored cross in a public square because the government was not "sponsoring" the speech. _~ r ~ ,t Mayor and City Commissioners November 8, 1999 Page 16 In this case, Jersey City not only owned and maintained .the cache but chose to erect it on City Hall Plaza-the very seat of Jersey City government. Moreover, the sign that accompanied the display proudly proclaimed that the display was sponsored by Jersey City. Like the cache in Allegheny County, the cache and the menorah were located prominently at the visible seat of government power. The City placed the display such that all visitors to City Hall were confronted with prominent religious symbols. The Establishment Clause prohibits the government, when speaking, from expressing favoritism towards a particular religion. By using the City Hall Plaza as a forum from which to communicate its endorsement of Christianity and Judaism, Jersey City violated the Establishment Clause. 104 F.3d at 1444-46 (footnotes omitted). See also, Freedom from Religion Foundation, Inc. v. State of Colorado, 872 P.2d 1256 (Colo. Ct. App. 1993) (held: monument containing Ten Commandments, given to state by private parties and placed in state park, directly west of capitol building, conveys essential religious message that would appear to reasonable observer to be endorsed and approved by state because of its content and location on property of state; state funds were used to clean monument). As the foregoing cases suggest, there is a reasonable possibility that if a court were to determine that the City in this case owns or maintains this cross on its property, a violation of the Establishment Clause may be found, based upon the perceived endorsement of the Christian religion by the City. With regard to Ms. Gaylor's contention that the presence of the cross in Howell Park constitutes a violation of art. I, § 3 of the Florida Constitution, I have found no Florida case law suggesting such a violation, provided that the City is not found to own or maintain the cross. This particular provision of the constitution states: § 3. Religious freedom There shall be no law respecting the establishment of religion or prohibiting or penalizing the free exercise thereof. Religious freedom shall not justify practices inconsistent with public morals, peace or safety. No revenue of the state or any political subdivision or agency thereof shall ever be taken from the public treasury directly or indirectly in aid of any church, sect, or Mayor and City Commissioners November 8, 1999 Page 17 religious denomination or in aid of any sectarian institution. =In considering the application of the foregoing provision, Florida courts follow the guidance provided by United States Supreme Court in decisions concerning the Establishment Clause. See, e.g., Silver Rose Entertainment, Inc v. Clay County, 646 So.2d 246, 248 (Fla. 1st DCA 1994), review denied, 658 So.2d 992 (Fla. 1995), cert. denied, --- U.S. ----, 116 S.Ct. 339, 133 L.Ed.2d 237 (1995) (holding that three Lemon issues must also be addressed in deciding constitutional question under art. I, § 3). Although the foregoing constitutional provision contains an additional prohibition of government authorization of the use of public moneys, "directly or indirectly in aid of any church, sect, or religious denomination or in aid of any sectarian institution," which is not found in the federal Establishment Clause, it is not clear that this additional prohibition actually provides any greater protection against the establishment of religion by state and local governments. As the court in Silver Rose Entertainment, Inc., noted: Government support of religion need not be monetary to offend article I, section 3 of the Florida Constitution. No less than its federal counterpart, the Florida provision "was intended to protect against sponsorship ...and active involvement of the sovereign in religious activity." Walz v. Tax Comm'n, 397 U.S. 664, 668, 90 S.Ct. 1409, 1411, 25 L.Ed.2d 697 (1970). 646 So.2d at 251. Thus, the conduct proscribed in the last clause is arguably implicit in the first clause of the first sentence of the section. Even so, the clause does explicitly require scrutiny of any expenditure of governmental funds by the City in the instant case for the maintenance of the Howell Park cross. Unfortunately, Florida case law appears to provide no additional guidance as to the resolution of the City's problem under Florida's "establishment clause," beyond that already discussed in the preceding portions of this letter. Although the foregoing discussion is by no means an exhaustive and comprehensive analysis of all case law pertinent to your inquiry under the Establishment Clause and the corresponding provision of Florida's constitution (such an undertaking would require significantly more time than already spent on this assignment), I hope that the cases I have selected provide you with a sufficient background and understanding of the current status of the law in this area to enable you to better determine how the City is likely to fare in the face of Ms. Gaylor's challenge, and whether there is a sufficient risk of .e ~ ~ ~ - ~ Mayor and City Commissioners November 8, .1999 Page 18 litigation with. Ms. Gaylor's organization so as to .warrant the removal of .the cross permanently from the park. Respectfully submitted, Alan C. en n City A ey ACJ/sky cc: James R. Hanson, City Manager Maureen King, City Clerk . ~ ~ ~ ,t Carol November 647 Beach Avenue Atlantic Beach FL 32233 Dear Ms. Shaughnessy, I am writing this letter to bring to your attention the existence of a religious symbol on public property. In Howell Park there is a cross in the middle of the clearing. This community is made up of people of many religions, including some who may feel uncomfortable with this religious symbol. There is a good chance that the existence of this symbol in a public park is a violation of federal law. I would appreciate it if you would investigate how it got there and why it remains standing year after year. Thank .you for your time. Sincerely, Carol November G~ • ..~ . ~'._s~. Est ~cv'^'a~ ~ EXHIBIT "A" ALAN C. J£NSEly A,ttarney at Law 935 North Third Street Post Of>ice Boz 50457 7acksonv,7ie Beach, Florida 32240-0457 Telephone (904) 246-2500 FAX r~MORANDUM DATE: TO: FROM: RE: July 2, 1999 Manager ty Attorney a David E. Thompson, City City of Atlantic Beach Alan C. 7ensen, Esq., Ci Cross in Howell Park Facsim~e {904) 2Ab.-99b0 You provided me with a copy of an undated letter from Carol November to Mayor Shaughnessy. I understand that Ms. November's questions are how the cross got in Howell Pazk and why it remains standing year after yeaz. I do not know the answers to these questions and it is my further understanding that you will make efforts to determine same. However, I am assuming that the City did not place the cross in Howell Park and therefore no public funds were used in connection therewith. I do not believe there is anything to indicate that the cross has been used to support, aid, maintain or establish any religion or religious edifice, or that its purpose was to promote the participation by anyone in the affairs of any religious organization or sect. If my assumptions aze correct, it would appear that the cross does not amount to the establishment of a religion in violation of the First Amendment of the United States Constitution, nor does it amount to any religious activity controlled, supported or influenced by the City of Atlantic Beach. I enclose a copy of Paul vs. Dade County, 202 So.2d 833, for your review. I have only conducted a preliminary review of Florida law, pending receipt of further informa- tion regazding the cross and how it got there. I will be more than happy to delve further into this matter and the federal law question, if and when it becomes necessary. I would appreciate you advising me accordingly. Enclosure ACJ/sky cc: Maureen King, City Clerk Mayor and City Commissioners EXHIBIT "B" .~, ~ RECpQ~T 1~ FREEDOM FROM REUGlON FOUNDATION 1999 P.O. Box 750 • Madison, WI 53701 • (608) 256-8900 October 15, 1999 Mayor Suzanne Shaughnessy `' Mayor-Elect John Meserve 800 Seminole Rd Atlantic Beach FL 32233 Dear Mayor Shaughnessy and Mayor-Elect Meserve: Our national organization, which works to uphold the constitutional principle of the separation of church and state, is writing on behalf of an Atlantic Beach taxpayer and complainant concerned about the lack of appropriate action by Atlantic Beach regarding the Howell Park cross. Specifically, the highly unsatisfactory advice of city attorney Alan Jensen is contested by our organization and our complainant. There is no instance of a cross erected on public property in this manner ever being permitted to stay on public property in any resolved legal dispute. In the only instances in which crosses on public land have been acted upon by the U. S . Supreme Court, that court has without deviation iet stand lower court rulings ordering removal of crosses from public landscapes. One of several recent such affirmations by the high court includes San Diego v Poulson, 990 F2d, 1518, 9th, Cert. denied 63 L.W. 3283 (Oct. 11, 1994) . Similarly the high court has affirmed all lower court rulings ordering removal of crosses from city or other government emblems. This is because, as is obvious to any reasonable observer, the cross stands for Christianity. Its prominent presence on public land signals illegal government preference and endorsement of one religion over another, and religion over nonreligion. The presence of this Christian symbol in your public park is a violation of the Establishment Clause, and of Art. I, Sect. 3 of the Florida Constitution. The fact that the city did not erect this cross does not mitigate the fact that it has endorsed the presence of the cross by refusing to remove the illegal symbol when requested. A similar practice in Alabama state parks where religionists had erected permanent crosses was nixed there by court decree. If someone rents the park for a wedding they can certainly erect a temporary cross, but they must remove it. It cannot be left there permanently. Mr. Jensen has not done his homework, and is leaving the city vulnerable to a legal challenge. t This is our formal request that the cross be removed immediately. May we hear from you immediately about this matter? Yours very truly FREEDOM FROM RELIGION FOUNDATION, INC. Annie Laurie Ga for Anne Nicol Cibylot; President Dan barker, Pu is elations Director Annie Laurie ayf ,Editor, Freethought T. .,-. r,n _ . ~ .a ~-- _ ~ .. - __ .,.,,. T r -..., ,... ~.