Item No.
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: OFFICE OF THE CITY MANAGER
BY: MARIA ALICIA DUARTE, CMC, CITY CLERK
BY: JOHN M. FUNK, CITY ATTORNEY
DATE: NOVEMBER 12, 2024
SUBJECT: RESOLUTION OF INTENTION TO TRANSITION TO EITHER A FIVE
DISTRICT ELECTION SYSTEM OR A FOUR DISTRICT ELECTION SYSTEM
WITH AN AT-LARGE ELECTED MAYOR
EXECUTIVE SUMMARY
The City Council will consider whether to adopt a resolution declaring the City of Downey’s intent to transition from the current election system consisting of four individual districts and one at-large district to an election system consisting of either five individual districts or four districts plus an at-large mayoral district, in furtherance of the California Voting Rights Act.
RECOMMENDATION
That the City Council:
Consider whether to adopt a resolution declaring the City’s intent to transition from the current election system consisting of four individual districts and one at-large district to an election system consisting of either five individual districts or four districts plus an at-large mayoral district, in furtherance of the California Voting Rights Act.
BACKGROUND
The City of Downey elects its five-member City Council through a mixed election system combining four individual districts and one at-large district. For each of the individual districts (Districts 1 through 4), each council candidate must reside in the district they represent and only voters within that district may vote for that district’s councilmember.
District 5, however, is an at-large district comprised of the entire City. This means that a council candidate for District 5 may reside anywhere in the City’s jurisdictional boundaries and voters residing anywhere in the City may vote for that councilmember. The council districts are geographically defined in Section 1305 of the City Charter, and the four individual districts are updated following each decennial census, in accordance with the Charter.
RESOLUTION OF INTENTION TO TRANSITION TO EITHER A FIVE DISTRICT ELECTION SYSTEM
OR A FOUR DISTRICT ELECTION SYSTEM WITH AN AT-LARGE ELECTED MAYOR NOVEMBER 12, 2024
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The City’s Mayor is not directly elected. Like many cities, the Mayor, as well as the Mayor Pro Tem, are selected annually by and among the members of the City Council to serve for a period of one year.
On October 3, 2024, on behalf of a potential plaintiff, the City received a letter from the law firm of Sarega Law, APC, alleging that the City’s election system violates the California Voting Rights Act (CVRA) because it contains an at-large voting district. (Attachment A). In the letter, Mr. Sarega demanded that the City voluntarily transition to a complete by-district system in compliance with the CVRA and threatened litigation in the absence of such a transition.
DISCUSSION
The California Voting Rights Act became law in 2003 and is codified at California Elections Code sections 14025 through 14032. The CVRA is intended to prevent the disenfranchisement of protected classes, meaning a class of voters who are members of a race, color, or language minority group.
Operative Elements of the CVRA
The CVRA was enacted in part to provide minority groups in California with tools to prevent dilution of votes in at-large election systems and is considerably more expansive than its national counterpart, the Federal Voting Rights Act of 1965. Under the CVRA, an at-large method of election may not be imposed or applied in a manner that impairs the ability of a protected class to elect candidates of its choice or its ability to influence the outcome of an election, as a result of the dilution or the abridgement of the rights of voters who are members of a protected class. Any voter who is a member of a protected class and resides in the respective jurisdiction may bring an action against the jurisdiction for violation of the CVRA.
The CVRA considers a method of election to be at-large when it combines at-large elections with district-based elections (like Downey’s). The CVRA does not mandate the abolition of all at-large election systems but makes the use of at-large election systems more susceptible to legal challenge. The most common legal remedy for an alleged CVRA violation is to change from an at-large system to a by-district election system. However, as noted in more detail below, in Downey’s case there are two potential options to comply with the CVRA.
In order to succeed in a CVRA lawsuit, a plaintiff is not required to show that the public agency has a discriminatory intent, or that minority voters live in a geographically compact area of the jurisdiction and suffer vote dilution. Instead, a violation of the CVRA may be established by showing that “racially polarized voting” and “vote dilution” have occurred as a result of an at-large voting system.
RESOLUTION OF INTENTION TO TRANSITION TO EITHER A FIVE DISTRICT ELECTION SYSTEM
OR A FOUR DISTRICT ELECTION SYSTEM WITH AN AT-LARGE ELECTED MAYOR NOVEMBER 12, 2024
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Racially polarized voting occurs when there is a difference in the choice of candidates who are preferred by voters in a protected class and the choice of candidates who are preferred by voters in the balance of the electorate. This difference can be demonstrated by a review of voting patterns showing that the protected class votes differently from the majority and is unable to elect the candidates of their choice or to influence elections for any candidate or ballot measure. Vote dilution occurs when the votes of the members of the protected class are outweighed or “diluted” by the votes of the majority of the electorate.
Unlike the Federal Voting Rights Act, the CVRA does not require a plaintiff to establish discriminatory intent, historical discrimination, or that minority voters live in a geographically compact area of the City. This significantly eases the burden of proving a violation of California law, as opposed to federal law. Additionally, the CVRA allows plaintiffs to recover reasonable attorney's fees and costs.
Safe Harbor Provisions of the CVRA
The California Legislature has enacted "safe harbor" provisions intended to protect cities from expensive lawsuits and settlements. These provisions allow a city to adopt a resolution outlining its intention to transition from at-large to by-district elections within 45 days of receiving a notice alleging violation of the CVRA. During this period, a potential plaintiff may not file a CVRA lawsuit. If a city adopts such a resolution, a plaintiff is further barred from filing a lawsuit for at least 90 days following the passage of the resolution (and possibly an additional 90 or more) in order to permit the orderly transition to by- district elections and to allow for public input into that process as required by law.
Where this procedure for transitioning is invoked, in addition to barring litigation, any recovery of attorney’s fees and costs by a potential plaintiff is capped at a current amount of $36,000.
Finally, local legislative bodies are authorized to adopt an ordinance requiring members of the legislative body to be elected all by-district or by-district with an elected mayor, without voter approval, if the change in the method of election is being made in furtherance of the CVRA. This is true as well for charter cities, for which a charter amendment would ordinarily be necessary to effect this change.
Experience of Other Cities Facing CVRA Challenges
Public agencies throughout California have faced CVRA lawsuits in recent years, each beginning with demand letters similar to the one received by the City. To date, no agency has successfully defended a CVRA lawsuit. Judgments and settlements in excess of $100,000 have been common. The largest settlement so far has been the City of Palmdale, which settled its ongoing litigation for $4.7 million. The City of Modesto settled for $3 million, and the cities of Highland, Anaheim, and Whittier all settled for
RESOLUTION OF INTENTION TO TRANSITION TO EITHER A FIVE DISTRICT ELECTION SYSTEM
OR A FOUR DISTRICT ELECTION SYSTEM WITH AN AT-LARGE ELECTED MAYOR NOVEMBER 12, 2024
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approximately $1 million. The City of Santa Monica is currently litigating a CVRA lawsuit.
The case was appealed to the California Supreme Court and has been remanded to the lower court for further proceedings. At this point, the outcome is uncertain. Plaintiffs in that case (through their attorney) most recently claimed they will seek $22 million in attorney’s fees and costs from the city should they prevail in their lawsuit. Given the low burden of proof for plaintiffs, the low probability of litigation success, and the potential for high attorney’s fees, a large majority of agencies have voluntarily transitioned from at- large elections to district-based elections rather than engage in CVRA litigation.
Action Options for Council Consideration
1. Commence Procedure to Transition to CVRA Compliant Elections
The decision to transition to an elections system that is compliant with the CVRA using the above safe harbor provisions triggers the following timeline.
A. Resolution of Intention to Transition
The transition procedure is formally commenced by adopting the attached Resolution of Intention to Transition (Attachment B). Under the provisions of the CVRA, litigation challenging the City’s election system may not be filed within 45 days of the date of receipt of the letter from Mr. Sarega. The 45th day will be November 18, 2024. If the City Council adopts the attached Resolution by then, litigation will be further stayed for 90 or more days to permit the orderly transition to either a five district election system or a four district election system with an at-large elected Mayor (a “4+1” system). The Resolution declares only the intent to transition to either system because the specific choice must be reserved for the public hearing process described below.
B. Public Hearings Prior to Drawing of District Maps
Before drawing a districting map, the City must hold at least two public hearings over a period of no more than 30 days. The public must be invited to provide input regarding the districts’ composition. Typically, when a city adopts district-based elections, it must prepare and adopt a map outlining the new geographical boundaries of the electoral districts. These first two public hearings are intended for the City Council to solicit pre- map input from the public that would be considered in any draft maps prepared and presented to the Council and the public at later hearings.
Downey’s circumstances are unique, however. The City is already divided into four electoral districts, pursuant to a legally complaint redistricting map based upon the 2020 Census adopted by the City Council on April 12, 2022.
State law allows a city to comply with the CVRA either by adopting an entirely by-district electoral system or a “by district with an elective mayor” system without being required to
RESOLUTION OF INTENTION TO TRANSITION TO EITHER A FIVE DISTRICT ELECTION SYSTEM
OR A FOUR DISTRICT ELECTION SYSTEM WITH AN AT-LARGE ELECTED MAYOR NOVEMBER 12, 2024
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submit the ordinance to the voters for approval. Such an ordinance must include a declaration that the change in the method of electing members of the legislative body is being made in furtherance of the purposes of the CVRA.
This means that two possibilities exist for compliance with the CVRA, both of which are reserved for consideration in the hearing process:
• Transition to a five-district electoral system. This would change District 5 from its current Citywide geography into a discrete portion of the City like current Districts 1 through 4.
• Transition to a “4+1” electoral system that retains Districts 1 through 4 with their current geography and changes the District 5 Council seat into an at-large Mayoral seat.
During the two “pre-map” hearings, City Staff will be seeking direction from the City Council as to whether it wishes to consider a five-district system or a “4+1” system as outlined above. This is significant because the former option will require the City to retain the services of a demographic expert to prepare a proposed map or maps that re-divide the City into five districts from the current four. With the 4+1 option, no such map(s) will be necessary because an at-large Mayor would be elected on a Citywide basis as District 5 is currently. The City’s current four-district map would remain in effect and govern City Councilmember elections until adjusted by the 2030 Census.
C. District Map Drawing
If the City Council wishes to consider a five-district system and not a 4+1 system, a demographic expert must be retained to prepare a proposed map or maps. The demographer will prepare draft maps with five districts that are nearly equal in total population, using the data from the most recent census (2020). The districts must be prepared in compliance with specific state and federal requirements, including consideration of contiguity, compactness, communities of interest and natural geographic boundaries.
As noted above, if the City Council only wishes to consider a 4+1 system, a demographic expert would not be needed to prepare maps that re-divide the City into five districts.
D. Timing and Sequence of Elections
State law is clear that no change in the electoral method may shorten or affect the current term of an incumbent Councilmember, each of whom shall continue to serve for the duration of their term of office. This means that no term of any current council member will be abbreviated by any transition in the City’s election system that may be made.
RESOLUTION OF INTENTION TO TRANSITION TO EITHER A FIVE DISTRICT ELECTION SYSTEM
OR A FOUR DISTRICT ELECTION SYSTEM WITH AN AT-LARGE ELECTED MAYOR NOVEMBER 12, 2024
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With a 4+1 system, the ordinance making this transition would fix the new at-large Mayoral office to commence upon the expiration of the current District 5 term in November 2028. The timing of elections for District 1 through 4 would remain unaffected. Another question the Council will need to consider is whether to set the Mayoral term at two or four years. Either option is available under state law. Charter amendments that are mayor-specific, including mayoral term limits possibly, will also need to be approved by the voters because the City Charter does not currently have such provisions. The first time at which Charter amendments could be considered by the voters is June 2026.
If the Council wishes to consider a five-district system, election timing and sequencing will also need to be considered. Changing the City from four to five districts may result in significant geographical changes to the existing districts and the current terms of incumbents will have to be considered in how new district elections would be timed and sequenced. The change to five districts could take place in the November 2026 elections or later.
E. Public Hearings for Map Consideration
If the City Council wishes to consider the five district option, after the draft maps have been prepared, the City must publish and make them available to the public. The City must also show the terms of office and the potential sequence of the elections. The Council must then hold at least two additional public hearings over a period of no more than 45 days during which the public will be invited to provide input regarding the draft maps and sequence of elections.
If the City Council wishes only to consider a 4+1 option, the Council should still conduct these public hearings, even though no maps will have been prepared by a demographer.
The Council need not change its mind if it has previously directed to follow a 4+1 approach but the venue must be made available for public input.
F. Map Adoption
If the Council wishes to adopt a five district approach and selects a map, it would then adopt an ordinance providing for a five district system, approve the map, and begin implementing five district elections under the approved election sequence.
If the Council wishes to adopt a 4+1 approach with an at-large elected Mayor (either two- year or four-year term), it would then adopt an ordinance providing for a 4+1 system, no new map would need to be approved, and the at-large Mayoral election would commence at the end of the current District 5 term.
G. Attorney’s Fees
RESOLUTION OF INTENTION TO TRANSITION TO EITHER A FIVE DISTRICT ELECTION SYSTEM
OR A FOUR DISTRICT ELECTION SYSTEM WITH AN AT-LARGE ELECTED MAYOR NOVEMBER 12, 2024
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Should the Council ultimately adopt the ordinance establishing one of these approaches within the 90-day time frame (or longer by mutual agreement with Mr. Sarega), Mr. Sarega will be barred from filing a CVRA lawsuit against the City. However, he could, within 30 days of the adoption of the ordinance, demand reimbursement for the cost of the work product generated to support the original notice of violation. His demand must be made in writing and must be substantiated with financial documentation. The amount may not exceed approximately $36,000. (There is a $30,000 cap indexed for several years of inflation.)
2. Take No Responsive Action
If the council elects not to adopt the Resolution of Intention to Transition, the potential plaintiff identified by Mr. Sarega could file a formal lawsuit alleging violation of the CVRA.
If filed, the City would bear its own costs and face exposure to the claimant’s attorney’s fees, which would likely be significant.
CITY COUNCIL PRIORITIES
Efficiency & Adaptability
Public Engagement
FISCAL IMPACT
If the Council adopts the attached Resolution of Intention to Transition, and wishes to consider a five district approach, an expert demographer will be needed to prepare the maps. That cost will be approximately $50,000. These costs would not be incurred if a 4+1 approach is taken, but then Charter amendments will prove necessary at a cost of approximately $35,000 per amendment. Charter amendments would not be necessary with a five district approach.
In either event, the City could be responsible for attorney’s fees and costs for a maximum amount of approximately $36,000.
If the City Council decides not to move forward with the transition, and a CVRA lawsuit is filed against the City, the financial impact will be much greater and likely consistent with the experience of cities described above who have taken this approach.
ATTACHMENTS
Attachment A: Letter from Sarega Law, APC dated October 3, 2024 Attachment B: Resolution of Intention to Transition to Either a Five District Election System or a Four District Election System with an At-Large Mayor
2211 E Orangewood Ave #488
Anaheim, CA 92806
Phone: (714) 931-8386 Email: [email protected] www.saregalaw.com October 3, 2024
VIA EMAIL
Mario Trujillo, Mayor
City of Downey
11111 Brookshire Ave
Downey, CA 90241
RE: VIOLATION OF CALIFORNIA VOTING RIGHTS ACT
Dear Mayor Trujillo,
I have received complaints from voters in the City of Downey (“City”) regarding the system of election employed by the City. The City currently utilizes a mixed election system that includes by-district and at-large elections. The City attempts to claim it employs a by-district election system, but in reality it does not. Presumably the intent was to give the appearance that the City was complying with the CVRA; however, in reality, the City does not have a legal by-district election system. The current system of election is a violation of the California Voting Rights Act (“CVRA”) and the Voting Rights Act of 1965 (“FVRA”).
Under the CVRA, Election Code § 10010(d)(2) and § 14026(b) define “district-based elections” as “electing members to the governing body of a political subdivision in which the candidate must reside within an election district that is a divisible part of the political subdivision and is elected only by voters residing within that election district.” The CVRA requires that districts be a “divisible part of the political subdivision” meaning that each district must be a part that makes up the whole. District 5 in the City of Downey does not meet this criteria as it is not a divisible part of the political subdivision because it encompasses the entire political subdivision.
The City municipal code under Article II, Chapter 2, § 2103(a) states that council members shall be elected by districts pursuant to provisions of Government Code § 34870. Government Code § 34870 states that it applies to only cities, but the following section, § 34871 holds that if cities conduct by-district elections, those districts for council members must be either five, seven or nine districts. Only if there is an elective mayor, having the meaning of a directly elected mayor and not rotation as is the current practice in the City, can there be four, six, or eight districts. By not having an election system by which the mayor is directly elected, the City of Downey cannot create an at-large district for a council member as it would not comply with the requirement that there be five, seven, or nine districts that are a divisible part of the political subdivision.
ATTACHMENT A
2211 E Orangewood Ave #488
Anaheim, CA 92806
Phone: (714) 931-8386 Email: [email protected] www.saregalaw.com California considers election systems that have an at-large mayor and separate council districts to be by-district elections. The position of mayor is distinct from the position of council members not just in title, but distinct in its duties, obligations, and powers.
California Election Code § 21621(a), which applies to charter cities, states that cities using district- based elections shall adopt boundaries for “all” council districts that are substantially equal in population. Here again, the City has created a council member district, District 5, that is not equal in population to the other districts and certainly does not fall within the allowable deviation.
The FVRA requires that all districts in a by-district election system be of equal population. Here, the City of Downey has four districts that are within the 10% deviation allowed under the FVRA, but has created a fifth district that is outside of that deviation by including the entire population of the city, thus being of much greater population than the other four districts.
In summary, the current election system adopted by the City is not in compliance with the CVRA nor the FVRA. We therefore demand that the City covert its mixed election system to a district- based election system. Under the authority of Government Code § 34886, the City Council can effectuate that conversion by passage of a resolution, and we demand that it do so without delay.
We request your response to this demand by October 18, 2024. In the absence of a satisfactory response, my client will be forced to seek judicial relief in the form of an action to obtain an order converting the election system from mixed to by-district, together with other relief provided for in the CVRA, including an award of litigation and expert witness costs, and attorneys’ fees. The City can avoid the imposition of a judicially-mandated plan, including districts maps designed or approved by the Court, by taking appropriate action without the filing of litigation.
We look forward to your response.
Sincerely,
Andrew Sarega
Sarega Law, APC
cc: Roger Bradly, City Manager (via email)
Maria Alicia Durate, City Clerk (via email)
RESOLUTION NO. 24-8277
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF DOWNEY
DECLARING ITS INTENTION TO TRANSITION TO EITHER A FIVE
DISTRICT ELECTION SYSTEM OR A FOUR DISTRICT ELECTION
SYSTEM WITH AN AT-LARGE ELECTED MAYOR BY THE NOVEMBER
2028 GENERAL MUNICIPAL ELECTION PURSUANT TO CALIFORNIA
ELECTIONS CODE SECTION 10010(e)(3)(A)
WHEREAS, the City Council of the City of Downey is an elected legislative and deliberative public body serving the citizens of the City of Downey, a California charter city; and
WHEREAS, the Members of the City Council are elected in November of even- numbered years (November 2024, 2026, 2028 etc.); and
WHEREAS, the City presently has a “mixed” election system, whereby Districts 1 through 4 divide the City into geographical districts, each Council candidate must reside in the district he or she will represent, and only voters within a given district vote for that district’s Councilmember; District 5, however, is an “at large district” where a Council member/candidate for District 5 may reside anywhere within the City’s boundaries and is elected by the voters of the entire electorate to provide Citywide representation; and
WHEREAS, Downey does not currently have a directly elected Mayor but rather the City Council appoints the Mayor to serve annually; and
WHEREAS, in 2003, the California Voting Rights Act (“CVRA”) became law, and in an attempt to prevent the disenfranchisement of protected classes of persons, establishes a low bar for attorneys and other persons seeking to compel cities and other public entities to convert from at-large to by-district elections; and
WHEREAS, public agencies that have been sued under the CVRA have typically been forced to pay large sums to settle with plaintiffs’ attorneys; and
WHEREAS, on October 3, 2024, the City received a letter from the law firm of Sarega Law APC, alleging that the City’s current mixed election system contains an “at large” element in District 5 and therefore violates the CVRA, and demanding that the City change its election system; and
WHEREAS, the City Council desires to avoid the high costs and legal risks associated with a CVRA lawsuit; and
WHEREAS, the California Legislature adopted Elections Code section 10010 to limit the attorney’s fees that a prospective plaintiff may recover if a public agency adopts a resolution of intention to change its system of elections within 45 days of the receipt of a letter from that prospective plaintiff alleging a CVRA violation; and
ATTACHMENT B
Resolution No. 24-8277
WHEREAS, the City Council has determined that transition from its current “mixed” election system to either of the systems below would be in compliance with, and in furtherance of, the purposes of the CVRA:
(A) Transition to a five-district electoral system. This would change District 5 from its current Citywide geography into a discrete portion of the City like current Districts 1 through 4.
(B) Transition to a “4+1” electoral system that retains Districts 1 through 4 with their current geography and change the District 5 Council seat into an at-large Mayoral seat; and
WHEREAS, the City Council desires to declare its intention to adopt an ordinance pursuant to Government Code section 34886 and Elections Code section 10010 transitioning from its current “mixed” election system to one of the two options above by the 2028 general municipal election, establish specific steps it will undertake to facilitate this transition, and establish an estimated timeframe for doing so.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF DOWNEY
DOES HEREBY RESOLVE AS FOLLOWS:
SECTION 1. The City Council finds that all of the foregoing recitals are true and correct and are hereby incorporated and adopted as findings of the City Council as if fully set forth herein.
SECTION 2. Based upon the whole of the administrative record before it, the City Council hereby finds that this transition of election system is exempt from environmental review under the California Environmental Quality Act (“CEQA”) pursuant to State CEQA Guidelines sections 15061(b)(3), 15320, and 15378(b)(3). Adoption of this Resolution is an organizational and administrative activity of the City, does not have the potential to result in either a direct or reasonably foreseeable indirect physical change in the environment, and is therefore not a project for purposes of CEQA. State CEQA Guidelines sections 15061(b)(3) and 15378(b)(5). In the event adoption of this Resolution does constitute a project, it is categorically exempt under the Class 20 (Changes in the Organization of Local Governments) categorical exemption. State CEQA Guidelines section 15320.
SECTION 3. Intention to Transition to Alternate Election System. Prior to the November 2028 General Municipal Election, the City Council intends to adopt an ordinance, pursuant to Government Code section 34886, to transition its “mixed” election system for its City Council Members to either (i) a five district election system for Councilmembers or (ii) a four district election system for Councilmembers with an at-large elected Mayor.
SECTION 4. Instructions Related to Transition. Following the effective date of this Resolution, taking into consideration the time required for public outreach and input, and the timeframes established by the California Elections Code, the following actions shall be
Resolution No. 24-8277
taken by the City and the City Council in accordance with Elections Code section 10010(a):
A. Conduct public outreach, including to non-English-speaking communities, to explain the process and to encourage public participation;
B. Before drawing a draft map or maps of the proposed district boundaries, hold at least two public hearings at which the public is invited to provide input regarding the composition of the districts and to consider district boundaries as provided in Elections Code Section 10010;
C. After drawing a draft map or maps, publish the draft map(s) and the potential sequence of the district elections, and hold at least two public hearings at which the public is invited to provide input regarding the content of the draft map or maps and the proposed sequence of elections; and
D. Hold a public hearing at which the City Council will consider and adopt an ordinance establishing alternate elections as outlined above, including the adoption of a district boundary map and the sequence of the district elections, as necessary.
SECTION 5. If any provision or clause of this Resolution is held invalid, unconstitutional, or otherwise repealed by act of law, such invalidity shall not affect any other provisions or clauses of the same which can be given effect without the invalid provision, clause, or application. To this end, the provisions and clauses of this Resolution hereto are declared to be severable.
SECTION 6. This Resolution shall take effect immediately upon adoption.
SECTION 7. The City Clerk shall certify to the adoption of this Resolution.
APPROVED AND ADOPTED this ___ day of November, 2024.
_________________________
MARIO TRUJILLO
Mayor
ATTEST:
______________________________
MARIA ALICIA DUARTE, CMC
City Clerk
Resolution No. 24-8277
APPROVED AS TO FORM:
_______________________________
JOHN M. FUNK
City Attorney
I HEREBY CERTIFY that the foregoing Resolution was adopted by the City Council of the City of Downey at a Regular meeting held on the ____ day of November, 2024, by the following vote, to wit:
AYES: Council Members:
NOES: Council Members:
ABSENT: Council Members:
ABSTAIN: Council Members:
_____________________________
MARIA ALICIA DUARTE, CMC
City Clerk