Police Department and Human Resources
www.santa-ana.gov/pd
Item # 26
City of Santa Ana
20 Civic Center Plaza, Santa Ana, CA 92701
Staff Report
September 15, 2026
TOPIC: Outside Employment
AGENDA TITLE
Ordinance Amending Section 9-16 of the Santa Ana Municipal Code to Prohibit All City of Santa Ana Employees from Outside Employment Regarding Civil Immigration Enforcement and to Make Other Minor Revisions
RECOMMENDED ACTION
Introduce for first reading an Ordinance of the City Council of the City of Santa Ana, California Amending Section 9-16 of the Santa Ana Municipal Code to Update and Prohibit City Employees from Engaging in Outside Employment Involving Civil Immigration Enforcement, Including with or on Behalf of U.S. Federal Immigration and Customs Enforcement;
ORDINANCE NO. NS-XXXX entitled AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF SANTA ANA, CALIFORNIA, AMENDING SECTION 9-16 OF THE SANTA ANA
MUNICIPAL CODE TO PROHIBIT CITY EMPLOYEES FROM ENGAGING IN
SECONDARY EMPLOYMENT INVOLVING CIVIL IMMIGRATION ENFORCEMENT, INCLUDING WITH OR ON BEHALF OF U.S. FEDERAL IMMIGRATION AND CUSTOMS
ENFORCEMENT
GOVERNMENT CODE §84308 APPLIES: No
DISCUSSION
In December 2016, the Santa Ana City Council adopted Resolution No. 2016-086 and Ordinance No. NS-2908, declaring Santa Ana a sanctuary city and generally prohibiting the use of City resources or personnel to assist with federal civil immigration enforcement, except as required by law.
In 2017, California enacted Senate Bill 54, the California Values Act, which similarly limits the use of state and local law-enforcement resources for federal civil immigration enforcement while allowing specified cooperation involving judicial warrants, qualifying criminal histories, and certain criminal task forces.
Outside Employment Ordinance Amendment
September 15, 2026
At its May 19, 2026 meeting, the City Council considered separate City Councilmember requests concerning secondary employment involving civil immigration enforcement.
Following Council discussion, the City Council directed staff to prepare an ordinance codifying a prohibition on immigration-related secondary (i.e., outside) employment for all City of Santa Ana employees.
The City Council further directed staff to develop clear definitions narrowly limiting the prohibition to secondary employment involving immigration-enforcement activities. The Council clarified that the ordinance should not prohibit service in the United States Armed Forces, including reserve service, or categorically prohibit employment with agencies operating under the United States Department of Homeland Security. Rather, the ordinance should apply based on whether an employee’s outside employment duties involve immigration-enforcement activities, such as arresting, detaining, transporting, or deporting individuals pursuant to civil immigration laws.
The proposed ordinance makes modifications to Section 9-16 of the Municipal Code regarding outside employment to reference current City and Santa Ana Police Department policies which contain details regarding applying for approval of outside employment, approval, and appeal process for outside employment and adds a prohibition on outside employment involving civil immigration enforcement for all City employees as directed by the City Council.
ENVIRONMENTAL IMPACT
Pursuant to the California Environmental Quality Act (CEQA) and state CEQA guidelines, the adoption of this ordinance is not subject to the requirements of CEQA pursuant to Guidelines Sections 15060(c)(2) because the activity will not result in a direct or reasonably foreseeable indirect physical change in the environment and 15060(c)(3) because the activity is not a project as defined in Section 15378 of the CEQA Guidelines, California Code of Regulations, Title 14, Chapter 3, because it has no potential for resulting in physical change to the environment, directly or indirectly and so is not a project. The Ordinance Amendment is further not subject to CEQA as an organizational and administrative activity of government under Guidelines Section 15378(b)(5).
FISCAL IMPACT
There is no fiscal impact associated with this action.
EXHIBIT(S)
1. Ordinance amendment
Submitted by: Robert Rodriguez, Police Chief, and
Lori Schnaider, Executive Director of Human Resources
Approved by: Alvaro Nuñez, City Manager