HomeMy WebLinkAboutRes 0598 - Payment for Participation in Litigation Against Federal Unemployment Compensation
does resolve as follows:
Approved as to Form:
WASHINGTON
RESOLUTION NO. 598
A RESOLUTION OF THE CITY OF TUKWILA, WASHINGTON,
AUTHORIZING PAYMENT FOR PARTICIPATION IN PENDING
LITIGATION AGAINST FEDERAL UNEMPLOYMENT COMPENSATION
AMENDMENTS OF 1976, PUBLIC LAW NO. 94 -566.
ATTEST:
Mayor U
COUNCIL ACTION
MEETING DATE AGFNDA
TYPE ITEM
WHEREAS, a lawsuit is being prepared to challenge the constitutionality
and applicability of new amendments applying the Federal Unemployment Compensation
Act to states and local governments, and
WHEREAS, the City Council, in the best interest of the employees,
wish to participate in this lawsuit;
NOW, THEREFORE, the City Council of the City of Tukwila, Washington,
The Tukwila City Council authorizes payment of $250.00
to NIMLO Federal Unemployment Compensation Tax
Litigation Trust Fund for participation in the lawsuit
as a plaintiff in litigation attacking the constitutionality
of the Federal Unemployment Compensation Amendments.
PASSED BY THE CITY COUNCIL OF THE CITY OF TUKWILA, WASHINGTON,
at a regular meeting thereof, this 15th day of August 1977
F. A. LESOURD
WOOLVIN PATTEN
DONALD D. FLEMING
GEORGE M. HARTUNG, JR.
LEON C. MISTEREK
DWAYNE E. COPPLE
THOMAS O. McLAUGHLIN
PETER LESOURD
JOHN F. COLGROVE
C. DEAN LITTLE
LAWRENCE E. HARD
RODNEY J. WALDBAUM
Hon. Edgar D. Bauch
Mayor, City of Tukwila
Tukwila City Hall
14475 59th Ave. So.
Tukwila, WA 98188
Dear Ed:
LEH:rc
Enc.
LESOURD, PATTEN, FLEMING HARTUNG
ATTORNEYS AT LAW
13 00 SEATTLE TO W E R
SEATTLE, WASHINGTON 98101
(206) 624 -1040
July 14, 19 RECEIVED
CITY OF TUKWILAOF TUKWILA
OFFICE OF THE MAYOR
JUL 2 0 1877
Are you aware that there is a lawsuit being pre-
pared to challenge the constitutionality and applicability
of new amendments applying the Federal Unemployment
Compensation. Act to states and local governments?
If Tukwila is interested in being a party to that
lawsuit, it must make a minimum contribution of $250.
The various NIMLO flyers which I have received on this
subject indicate that Tukwila will not be entitled to
enjoy the benefits of the case if you are not a named
party.
I am enclosing a copy of the flyer so that you can
review it. If you wish to participate, it is necessary
to contact the NIMLO headquarters in Washington, D. C.
Very truly yours,
LOOURD, PATTEN,
FUMING HARTUNG
Lawrenc' I 'Hard
COL NC CC R_
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COUNSEL
STEPHEN F. CHADWICK
1894 -1975
NATIONAL INS'ITUTE OF
MUNICIPAL LAW OFFICERS
PRESIDENT
CONARD B. MATTOX, JR.
City Attorney
Richmond, Virginia
1st VICE PRESIDENT
THOMAS EMMET WALSH
City Attorney
Spartanburg, South Carolina
2nd VICE PRESIDENT
SAMUEL GORLICK
City A_..
Burbank, California
3rd VICE PRESIDENT
AARON A. WILSON
City Attorney
Kansas City, Missouri
TREASURER
IENRY W. UNDERHILL, JR.
City Attorney
Charlotte, North Carolina
GENERAL COUNSEL
CHARLES S. RHYNE
Washington, D.C.
TRUSTEES,
EUGENE N. COLLINS
City Attorney
Chattanooga, Tennessee
JOHN DEKKER
City Attorney
Within, Kansas
BURT PINES
City Attorney
Los Angeles, California
'AMES B. BRENNAN
City Attorney
Nilwaukee, Wisconsin
WALDO F. BALES
City Attorney
Tulsa, Oklahoma
BERNARD RICHLAND
Corporation Counsel
New York, New York
WILLIAM R. QUINLAN
Corporation Counsel
Chicago, Illinois
S.G. JOHNDROE, JR.
City Attorney
Fort Worth, Texas
J. LAMAR SHELLEY
City Attorney
Mesa, Arizona
BENJAMIN L. BROWN
City Solicitor
Baltimore, Maryland
JOHN W. WITT
City Attorney
San Diego, California
ROY D. BATES
City Attorney
Columbia, South Carolina
839 17th STREET, N.W.
WASHINGTON, D.C. 20006 [2021 347 -7996
July 1, 1977
Memorandum to All Participants in Litigation:
As of this date, the total amount received for the Litigation
Trust Fund is $1,418,722.45.
As of this date, the total amount received and pledged for the
Litigation Trust Fund is $1,644,379.00
As of this date, there are 480 Cities, Counties and States who
have agreed to be parties to the litigation.
Under the authority conferred by the Trustees at their June 20
42nd ANNUAL CONFERENCE
WILLIAMSBURG, VIRGINIA
Lc AL
REPORT ON STATUS OF AMENDMENTS APPLYING FEDERAL UNEMPLOYMENT COMPENSATION
ACT TO STATES, CITIES, COUNTIES AND OTHER POLITICAL SUBDIVISIONS.
We thought you would like a report on developments to date in
connection with the litigation to attack the constitutionality of the
amendments adopted by Congress applying the Federal Unemployment
Compensation law to States, Cities and Counties by requiring that States
impose the same taxes upon themselves, their Cities, their Counties
and their other political subdivisions as they now impose upon private
business.
The amendments, in effect, preempt the whole field of unemploy-
ment compensation thus nullifying all State or local legislation and
replacing it with Federal legislation and Federal regulation and Federal
taxation. There is an enormous penalty imposed in that all private
industry in any State failing to adopt a law approved by the Secretary
of Labor will lose the current deductibility on Federal taxes they pay
for unemployment compensation.
You have received the pamphlet outlining some of the impacts of
these amendments to the States and their political subdivisions and our
research and study of impact continues. Drafts of briefs on all con-
stitutional issues are being prepared and those parts of the complaint
that can now be written are being prepared.
The Officers and Trustees of NIMLO, who are the Trustees of the
Litigation Fund, met in Washington on June 20, 1977 and adopted the
enclosed Resolution which is self explanatory.
MEMORANDUM
July 1, 1977
Page Two
meeting, the Operations Committee has authorized the return to Cities under
25,000 in population who have paid more than the $.05 per capita formula a
total of $180,000.00
The Firm of Rhyne and Rhyne, which has been employed to plan and carry
out the litigation, has a substantial team of lawyers working on the litigation.
In addition, that Firm has made recommendations to the Operations Committee for
authority to employ various additional experts, the intention being to provide
the best possible preparation and presentation of this matter to the Courts.
Based upon the handling for local governments by Rhyne and Rhyne
of some 20 other cases which could be placed in the massive category because
they had a large number of participants, such as National League of Cities v.
Usery, natural gas rates, antitrust cases against General Electric ana Westinghouse
an d others, it is estimated that the team of lawyers working on this litigation
will complete their effort about the latter part of October or the first part
of November. The litigation will be filed at the earliest possible time and
should the research and drafting be completed earlier, the complaint will be
filed earlier. One must stress that this case is one of the most complex and
difficult ever to be filed, so the greatest care must be taken to present the
strongest attack against the legislation that can be prepared. The Team is
experienced in this type of litigation and will do its utmost to present the
strongest complaint, motions and briefs that can be developed.
Because the litigation is much more complex than the salary issue that
was involved in National League of Cities v. Usery, and that case took 6 months
to prepare, it is believed. that the time estimate given above is fairly accurate.
It is also believed that based upon the foreseeable costs all of the
participants will receive a refund upon the expenses which they have advanced.
Other than the refunds based on the $.05 per capita, the Trustees do not feel
that now is the time to make additional refunds, although they recognize that
the Litigation Trust Fund is much larger than was anticipated at the outset.
Further, new participants are joining daily as anew deadline for joining of
August 1, 1977 has been set.
All participants are reminded that this litigation must go before a
single district Judge, as the three Judge statute for constitutional challenges
has been eliminated, then to the United States Court of Appeals and then on
to the Supreme Court of the United States. After that there might possibly be
re- argument in the Supreme Court as there was in Baker v. Carr, the "one-man,
one vote" case, and in National League of Cities v. Usery.
All expenditures for fees and expenses of all rendering services in
this litigation must be set forth in detail and approved by the Operations
Committee created in the Trustees' Resolution. A11 checks then must be signed
by both the President and Treasurer of NIMLO.
MEMORANDUM
July 1, 1977
Page Three
One of the elements of both our collection of the facts of impact,
and our presentation of this case to the Courts, is the fact that the re-
imbursement option is not a realistic one for States and Cities. Because
of the uncertainty on the budget process, the lack of a ceiling on unemploy-
ment costs under reimbursement, the threat of intrusive administration
by State and Federal governments into record keeping and other local activities,
and for other reasons, many Cities report that they will not elect the re-
imbursement option, but must pay the tax at the same rate as private employers
who can pass this on as a cost of doing business.
One of the deterrents to electing reimbursement is the rigidity of
the newly imposed Federal. rules. Under Federal law, States and Cities and
Counties cannot be treated any differently as employers than private industrial
employers. The impact of the minimal eligibility requirements for private
industry on public employment (seasonal workers, school employees, for example)
will be great. And it will effect greatly even those States and Cities already
covered under State unemployment laws not as rigid as this Federal requirement.
In this regard, the Federal Unemployment law affects local governments by
irrationally preempting State and local law, much as did the wage and hour laws
overturned in the Usery case.
Many States are passing the required State laws conforming to this
unconstitutionally rigid Federal rule with a "self- destruct" repealer to take
effect on the issuance of the injunction pendente lite we will request from the
Federal Court in which we file this case. Our current plan is to file in the
Federal District Court: in Washington, D. C. We will frame our injunction to
protect not only these jurisdictions, but also participants in States which will
have to repeal or suspend their coerced laws after the injunction. For both
groups of participants, we hope further to protect private Federal taxpayers from
the unconstitutional penalties attaching to failure of a State's law to conform
to the Federal rule.
CBM: nun
Enclosure
Should you have any questions, we would be very glad to answer them.
Sincerely,
e.
Conard B. Mattox,
NIMLO President
RESOLUTION
JUN. 2 0 1977
WHEREAS, the number of participants in the litigation to enjoin and have
declared unconstitutional the applicability of the new Amendments applying the
Federal Unemployment Compensation Act to States and local governments could not
be anticipated; and
WHEREAS, the computed billions in cost required under the Federal Act have
so shocked States, Cities, Counties and other local governments that the estimated
cost of the proposed litigation and the number of participants have both been
enormous;
WHEREAS, it is apparent to these Trustees, the Board of Trustees that operate
NIMLO, and who are Trustees of the NIMLO Litigation Trust Fund, created to pay for
the above described litigation, that the number of participants and the amounts
they have paid into or committed to said Fund is so great that a refund of a part
of said funds is a distinct possibility;
WHEREAS, the Trustees, have in mind that the litigation will be complex,
difficult and filled with uncertainties, as well as vigorously contested by the
United States Government and that said litigation must be most carefully, com-
pletely and expertly prepared and presented as it faces consideration by a United
States District Court, a United States Circuit Court of Appeals, the Supreme Court
of the United States with costs and the nature and extent of proceedings in each
Court being uncertain at this time;
WHEREAS, the Trustees have created an Operations Committee of the Trustees
(consisting of the President, First Vice President and Treasurer of NIMLO, and
the County Counsel of Los Angeles, California ex officio) which must approve each
dollar expended for services and costs in this -litigation and the Trustees have
instructed a most strict accountability;
WHEREAS, the NIMLO Litigation Trustees recognize that :hose jurisdictions
under 25,000 population which contributed $2,500 under the original contribution
formula to insure the viability of the proposed constitutional challenge to the
Federal Act should not be treated differently from the later joining jurisdictions
under 25,000 population which participate at the rate of $.05 per person of popu-
lation; and the Trustees further recognize that any other adjustments to contri-
butions received cannot accurately be made at this time when the costs of litigation
are not known or predictable;
NOW THEREFORE, BE IT RESOLVED that the NIMLO Litigation Trust Fund make an
immediate refund to each participating jurisdiction under 25,000 population of all
amounts contributed in excess of the larger of $.05 per person of population or
$250; and that a general refund pro rata to all participating jurisdictions be
deferred for future consideration by the NIMLO Litigation Trustees; and that at all
times the Trust Fund shall be maintained in a liquid, interest- bearing medium under
the exclusive control of the Operations Committee until disbursement is necessary;
BE IT FURTHER RESOLVED that this RESOLUTION be forwarded to each participating
City, County and State so that they may be assured that the funds they have con-
tributed to the Trust Fund will be expended and accounted for with the utmost of
care and responsibility.
AND BE IT FURTHER RESOLVED that on behalf of NIMLO these Trustees express
their appreciation of the tremendous support they have received in considering
and carrying forward this difficult, complex and important litigation.
NIMLO PLANS WILLIAMSBURG CONFERENCE
Work Session Suggestions Invited
NIMLO WILL HOLD ITS 42nd Annual Conference October 30 November 2, 1977, in
historic Williamsburg, Virginia. Municipal attorneys from throughout the nation
will have the opportunity to meet and discuss important recent legal developments
affecting municipalities. Municipal attorneys and others attending NIMLO Confer-
ences indicate that one of the most valuable features of the Conference are the
Work Sessions, where they have the opportunity to listen to, question and talk
with municipal law experts who have faced similar problems. As the persons
who have the most immediate contact with practical municipal problems, municipal
attorneys are the most qualified experts on the legal issues facing America's
municipalities. Following is a partial and tentative list of topics to be covered
at the Work Sessions. NIMLO welcomes any comments on this list, as well as any
suggestions for speakers to discuss these or other topics.
CIVIL RIGHTS ACTIONS:
Municipal Immunity from Civil Rights Actions Arising from Zoning Enforcement.
Lack of Notice in Negligence Civil Rights Actions.
No Direct Cause of Action Against Municipalities under Fourteenth Amendment.
ELECTIONS, POLITICAL SIGNS:
Invalidity of Political Signs Restrictions.
Validity of At -Large Election Systems.
ENVIRONMENT, NOISE:
The Concorde and JFR. Airport.
Water Conservation Ordinances.
Enforcement of Pollution Nuisance Ordinances.
Noise Controls: Airports, Loudspeakers, Rock Concerts.
HEALTH, SAFETY AND MORALS:
Regulation of Newsracks.
Controlling Vandalism.
Regulation of Solicitation in Public Places.
Residential Parking Permit Systems.
Obscenity Ordinances and the Miller Test: Jury Instructions on
Community Standards.
-2-
HOUSING, URBAN DEVELOPMENT AND ZONING:
Validity of Pre -Sale Housing Inspections.
Prohibition of Residential 'For Sale' Signs: Linmark Associates v.
Township of Willingboro.
Downtown Redevelopment Financing.
State Convict Rehabilitation Centers in Residential Districts.
MUNICIPAL FEDERAL RELATIONS:
The Clean Air Act Cases.
Unemployment Compensation Legislation and Litigation.
Accommodating the Handicapped: Federal Regulations.
MUNICIPAL EMPLOYEES:
Local "Hatch Acts."
Residency Requirements.
Refusal to Withhold Union Dues.
MUNICIPAL GOVERNMENT, TAXATION AND FINANCE, SERVICES:
Sunshine Laws: Extent of Attorney Client Privilege for
Municipal Attorneys.
ConRail Tax Liability.
Due Process Requirements for Utilities Termination.
Each year at NIMLO's Conference, resolutions are adopted and presented to
the appropriate govern nental, quasi governmental, or private organization con-
cerned, especially to the Congress and the Federal Executive Branch. So that
NIMLO will present to its members the broadest possible subjects for consideration,
we ask you to offer your suggestions to be considered at the Conference.
NIMLO also solicits suggestions for its Distinguished Public Service Awards
for a Municipal Attorney and an Assistant Municipal Attorney.
Plan now to attend this important and informative Conference. A more
detailed program, as well as Conference registration materials, are being sent to
NIMLO members; for further information, contact NIMLO's Washington office.