BILL ANALYSIS                                                                                                                                                                                                    �



                                                                     AB 360
                                                                     Page  1


        ASSEMBLY THIRD READING
        AB 360 (Brownley)
        As Amended  April 6, 2011
        Majority vote 

         EDUCATION           7-3                                          
         
         ----------------------------------------------------------------- 
        |Ayes:|Brownley, Ammiano,        |     |                          |
        |     |Buchanan, Butler, Carter, |     |                          |
        |     |Eng, Williams             |     |                          |
        |     |                          |     |                          |
        |-----+--------------------------+-----+--------------------------|
        |Nays:|Norby, Halderman, Wagner  |     |                          |
        |     |                          |     |                          |
         ----------------------------------------------------------------- 
         SUMMARY  :  Requires charter schools to comply with the same conflict 
        of interest requirements as school districts, commencing July 1, 
        2012.  Specifically,  this bill  : 

        1)Declares charter schools are subject to all of the following:


           a)   The Ralph M. Brown Act (Brown Act), except that a charter 
             school operated by an entity governed by the Bagley-Keene Open 
             Meeting Act (BKOMA) is subject to that Act;



           b)   The California Public Records Act (CPRA);



           c)   Article 4 (commencing with Section 1090) of Chapter 1 of 
             Division 4 of Title 1 of the Government Code; and,



           d)   The Political Reform Act of 1974 (PRA).



        2)Specifies a member of the governing body of a charter school shall 
          abstain from voting on all matters affecting his or her own 
          employment and personnel matters that uniquely affect a member's 







                                                                     AB 360
                                                                     Page  2


          relative; specifies a person who is disqualified by the California 
          Constitution or laws of the state from holding a civil office 
          shall not serve on the governing body of a charter school; and, 
          specifies this measure does not prohibit an employee of a charter 
          school from serving as a member of the governing body of that 
          charter school.



        3)Specifies that if a charter school governing body engages in 
          activities that are not related to the operation of the charter 
          school, this bill does not make those unrelated activities subject 
          to the Brown Act, the BKOMA, or the CPRA; and, prohibits a meeting 
          of the charter school governing body to discuss items related to 
          the charter school to also include discussion of any item 
          regarding an activity that is not related to the charter school.


        4)Specifies that a charter school governing body may meet within the 
          boundaries of the county or counties in which one or more of the 
          school's facilities are located provided that proper notices 
          pursuant to the Brown Act and the BKOMA are posted within the 
          boundaries of each of the counties in which any of the school's 
          facilities is located; specifies a charter school may also meet in 
          a county contiguous to the county where one or more of the 
          school's facilities are located, if at least 10% of the pupils who 
          are enrolled in the school reside in that contiguous county; and, 
          specifies a nonclassroom based charter school that does not have a 
          facility may meet within the boundaries of the county in which the 
          greatest number of pupils who are enrolled in the school reside.


        5)Authorizes a charter school governing body to hold closed sessions 
          to consider a matter regarding pupil discipline.


        6)Specifies for purposes of the PRA, the jurisdiction of a charter 
          school shall be the county or counties in which the school's 
          facility or facilities are located; the jurisdiction for a 
          nonclassroom based charter school that does not have a facility 
          shall be the physical boundaries of the county or counties where 
          at least 10% of the pupils who are enrolled in the school reside 
          or, if at least 10% of the pupils do not reside in a single 
          county, the county in which the greatest number of pupils who are 
          enrolled in the school reside.







                                                                     AB 360
                                                                     Page  3




        7)Declares that a statement of economic interest that is filed by a 
          designated person at a charter school after the required deadline 
          pursuant to the PRA shall not be the sole basis for revocation of 
          a charter.


        8)Defines for purposes of this measure, "facility" to mean a charter 
          school campus, resource center, meeting space, or satellite 
          facility.


         EXISTING LAW  pertaining to charter schools: 

        1)Provides no specific requirement for charter school governing 
          board conflict of interest policies.

        2)Deems charter schools as school districts for the purposes of 
          receiving state education funds.  
         
        EXISTING LAW  pertaining to school districts: 

        1)Specifies that Members of the Legislature, state, county, 
          district, and city officers or employees shall not be financially 
          interested in any contract made by them in their official 
          capacity, or by any body or board of which they are members.  
          (Government Code 1090)

        2)Requires members of school district governing boards and 
          designated employees of the school district to file statements of 
          financial interest according to the Political Reform Act.  
          (Government Code 87100 et. seq.)

        3)Requires a school district, or any board, commission or agency 
          thereof, or other local public agency to comply with the Brown 
          Act.  (Government Code 54950 et. seq.)

        4)Requires a school district to comply with the California Public 
          Records Act. (Government Code 6250 et. seq.)

         FISCAL EFFECT  :  This bill is keyed non-fiscal.

         COMMENTS  :  This bill requires charter school governing board members 
        to comply with substantially similar conflict of interest policies 







                                                                     AB 360
                                                                     Page  4


        by which school district governing board members currently abide.  
        Recent news reports of charter school board members engaging in 
        inappropriate financial mismanagement have highlighted the need for 
        charter school conflict of interest laws to be clarified.  
        Currently, these investigations can take many months to resolve 
        partly due to the fact that charter school governing board members 
        and designated employees do not consistently file an annual 
        statement of economic interest, which makes public any potential 
        conflicts of interest that individual may have in their official 
        capacity.  While charter schools are given more autonomy than public 
        schools, their governing boards have authority over public funds to 
        be used for the educational benefit of their students.  Charter 
        school governing boards should be held to the same conflict of 
        interest standards as school district governing boards.  

        This bill requires charter school boards to file statements of 
        economic interest according to the Political Reform Act; specifies 
        that charter school board members may  not  be financially interested 
        in any decision made by the board; requires charter schools to 
        comply with the California Public Records Act; and, requires charter 
        school boards to abide by the Brown Act or the Bagley-Keene Open 
        Meetings Act.  The bill also expressly authorizes charter school 
        employees to serve on a charter school governing board.

        The Brown Act:  The Brown Act governs meetings conducted by local 
        legislative bodies, such as boards of supervisors, city councils, 
        and school boards.  The Brown Act represents the Legislature's 
        determination of how the balance should be struck between public 
        access to meetings of multi-member public bodies and the need for 
        confidential candor, debate, and information gathering.  

        California Public Records Act (CPRA):  The CPRA was enacted in 1968 
        and according to the Attorney General, in enacting the CRPA, the 
        Legislature stated that access to information concerning the conduct 
        of the public's business is a fundamental and necessary right for 
        every person in the state.  Cases interpreting the CRPA also have 
        emphasized that its primary purpose is to give the public an 
        opportunity to monitor the functioning of their government.  

        Government Code 1090:  Government Code 1090 states that Members of 
        the Legislature, state, county, district, judicial district, and 
        city officers or employees shall not be financially interested in 
        any contract made by them in their official capacity, or by any body 
        or board of which they are members.  In a 1983 opinion the Attorney 
        General stated, "Section 1090 of the Government Code codifies the 







                                                                     AB 360
                                                                     Page  5


        common law prohibition and the general policy of this state against 
        public officials having a personal interest in contracts they make 
        in their official capacities.  Mindful of the ancient adage, that 
        'no man can serve two masters,' the section was enacted to ensure 
        that public officials 'making' official contracts not be distracted 
        by personal financial gain from exercising absolute loyalty and 
        undivided allegiance to the best interest of the entity which they 
        serve."


        Political Reform Act:  The Fair Political Practices Commission 
        (FPPC) was created by the Political Reform Act of 1974, a ballot 
        initiative passed by California voters as Proposition 9.  The FPPC 
        provides written and oral advice to public agencies and officials; 
        conducts seminars and training sessions; develops forms, manuals and 
        instructions; and receives and files statements of economic 
        interests from many state and local officials.  The FPPC 
        investigates alleged violations of the Political Reform Act, imposes 
        penalties when appropriate, and assists state and local agencies in 
        developing and enforcing conflict-of-interest codes.  School board 
        members are required to comply with the PRA, and in so, must file a 
        statement of economic interest, annually.

        Previous legislation:  AB 572 (Brownley) from 2010 was substantially 
        similar to this bill and was vetoed by the Governor.

         
          Analysis Prepared by  :    Chelsea Kelley / ED. / (916) 319-2087       
                       FN: 0000178