Memo-Administrative Citation Program
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DATE:
June 23, 2003
TO:
Chief Gerdes
FROM:
Lieutenant Goldstein
SUBJECT:
Administrative Citation Program
Per your request, I have had an opportunity to discuss the notion of an Administrative Citation
Program (ACP) with a number of individuals last week. I have directly talked with
representatives from the White Bear Lake Police Department, the Columbia Heights Police
Department, the City of Hopkins City Manager, Mr. Steve Mielke, along with Mr. Elliott
Knetsch and Mr. Joel Jamnik from our City Attorney's office. In speaking with these individuals
about the ACP, I have identified both positive and negative aspects for your consideration.
In reviewing this concept, I first spoke with Elliott Knetsch who provided me with a historical
overview of how this program was initiated. In 86 counties within the State of Minnesota, a
municipality is entitled to 1/3 of the fine revenue generated from a citation/charge. The rest of
the money goes to the county. However, in cases where the municipality's City Attorney
appears in court, the city will then receive 2/3 of the fine amount leaving the county with the
remaining 1/3. Yet, Hennepin County is unique and utilizes a different formula.
Several years ago, Hennepin County mandated that all of its municipalities were responsible for
paying their own prisoner's Hennepin County Workhouse costs. In response to that decision, the
county agreed to let its municipalities keep 100% of all (imposed) fine revenues. **However,
recently, in order to cover their administrative costs, the county has added a $5.00 per count
charge and a $10.00 to $15.00 flat fee to all of its citations/cases. These fees were in addition to
the legislated fines. Then, there are various surcharges that have been imposed by the State of
Minnesota that are again above and beyond the fine and county administrative fees.
According to Elliott there is no significant advantage to administering a program of this nature in
Hennepin County with respect to revenue generation alone. Elliott also cautioned against
potential double jeopardy issues despite the fact that the ACP is a civil action. If a municipality
offers an administrative hearing for contested citations, where quasi-testimony is heard in
relation to self-incrimination, that information might be censored if the case would move into
criminal court for a final disposition. While this has not yet been tested, it is a concern.
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Also, if a citation is written for speeding under the city ordinance using the ACP in lieu of the
traditional county citation, and the case ultimately ends up in criminal court, the court will not
certify the ordinance violation to the Department of Public Safety. With all ofthis in mind,
Elliott did indicate that the Hennepin County Judicial Bench would appreciate any mechanism
that would reduce its caseload. So, while he would not want this program to initially include
traffic violations, it might be a reasonable program for other miscellaneous city code violations.
I next spoke with Joel Jamnik after reading his memorandum that was addressed to you. Joel has
experience with this issue and offers a similar argument that was initially presented by Roger
Knutson via a previous email. Joel indicates that, "the Minnesota legislature has not offered any
expressed statutory authority to its municipalities for establishing an administrative enforcement
system. The only authorized mechanism is for liquor and tobacco license violations."
In conjunction with Joel's thoughts, he argues that while a number of municipalities have
incorporated this system e.g. Minnetonka, Roseville, Buffalo, Spring Lake Park, and Fergus
Falls, they are only doing so to enforce miscellaneous city code violations. Most municipalities
do not have the infrastructure in place to handle a large volume of cases that traffic violations
might cause. The City of Plymouth would need to create a process to manage this program and
would need to hire an impartial third party to hear any disputes. The violations would need to be
tracked and who would be responsible to collect unpaid fines? The City would have no authority
to issue warrants or assess out-of-city residents. Joel believes that the traditional criminal court
process is a better venue for traffic infractions.
Joel and Elliott agree that for cities outside of Hennepin County, there is a greater upside to this
program. For those municipalities that only receive 1/3 ofthe fine revenue, the cost benefit
might be in their favor to implement the ACP. While there is a cost to administer the project,
they might ultimately be money ahead in that they are receiving 100% of whatever fine is
collected versus the traditional 1/3.
It would appear that there are at least two local communities, outside of Hennepin County,
(White Bear Lake and Columbia Heights) who have authorized its police officers to issue
administrative citations for traffic infractions along with other city ordinance violations.
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In speaking with Captain Beck from the White Bear Lake Police Department, their department
instituted this practice several years ago. They wanted to offer their officers another option for
traffic enforcement. The city created a fine schedule that closely mirrored the legislated fines
less any administrative fees and surcharges. Here, officers can issue citations using their adopted
city ordinance to enforce their city's traffic laws. For speeding citations, officers may use the
ACP only if the violation was no more than 10 mph over the posted limit. However, officers can
stop someone for 15 mph over and simply write 9 mph over the limit on the administrative
citation. Captain Beck advised that this program was not created to capture greater revenues. He
states that their department wanted another tool for its officers. Many times officers have
difficulty writing someone with a clean record a citation, knowing that the fine is high and that
the violation will go on their driving record. Here, officers have a method to mitigate the impact.
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Captain Beck believes that their program is a success and maintains that the ACP does have an
impact on one's driving behavior. He claims that their residents appreciate the program.
White Bear Lake has created an administrative hearing process and they have hired a retired
court clerk to hear the cases. on a weekly basis. Captain Beck indicated that very few cases are
heard and that most people pay the fine within the seven-day time frame. If the violator does not
pay the fine, the department will then issue the violator a county citation and the case is referred
to criminal court. Captain Beck stated that the program was well received by the officers and
they have clearly retained their discretion as to when the administrative citations are issued.
However, they cannot be issued in matters involving motor vehicle accidents.
I then spoke with Cheray Olson from the Columbia Heights Police Department. Ms. Olson is
their ACP coordinator. Ms. Olson stated that the city has had an ACP program in place for
several years and it was used for miscellaneous city code violations. However, in April 2003,
their city council authorized the police department to use the ACP for traffic infractions. The
city adopted a fine schedule and since this inception, the department has written over 500
citations using this new method. The city does not offer an administrative hearing. If a violator
does not pay within 30 days, or if they challenge the citation, a county tag is written (by a
volunteer) and it is submitted to the traditional county court process. The city offers no due
process; it simply refers people to criminal court.
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Ms. Olson indicated that the officers were indifferent to the notion. Those officers who typically
write several citations still do; and now they have another option to utilize. Ms. Olson has
created two databases, one for their finance department and another for the police department.
Officers have the ability to see if an individual has been offered an administrative citation in the
past via their mobile digital computers. Typically, violators only get one opportunity with the
ACP. Whereas in White Bear Lake, an additional $25.00 assessment is added to each
subsequent violation within the same 12 month period.
Ms. Olson clearly stated that the reason their city council adopted this practice was to increase
the city's ability to capture fine revenues. Ms. Olson advised that with the budget deficit and due
to the fact that their city was only eligible for a portion ofthe fine revenue, this option helps
alleviate those concerns.
During this study, I also spoke with City of Hopkins City Manager, Steve Mielke. Mr. Mielke
advised that he had assigned one of his staff members to study this program. He indicated that
they were taking a preliminary look at this possibility and that ifhis staff member had any useful
information for us, he would have that individual call me directly. As oftoday, I have not heard
from anyone.
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In reviewing this potential program, it would appear that there are some positive aspects to
consider. This system would reduce the amount of court cases heard by Hennepin County
Criminal Court. The City of Plymouth would be able to utilize this option for all city code
violations including traffic, if so desired. With this tool, police officers would be able to enforce
traffic violations with another option. Whether this would increase the number of citations
issued is unknown.
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The negative components do not necessarily out weigh the positive aspects, but they are
significant. Due to the current system in Hennepin County, we already receive 100% of all fine
revenue. This is always true, unless the judge mitigates the legislated fine to zero. With that, to
create, implement, and manage the ACP, there would be an undetermined cost. If we were to
provide an administrative hearing component, we would also need to hire a part-time hearing
officer. Despite the costs, and the time it would take to mange this ongoing opportunity, the City
still needs to work with the City Attorney's office to clarify the program's legality. Also, the
City would need to determine what type of long-term impact this program might have on those
State agencies that utilize the surcharges that are generated from our traditional criminal court
process.
Due to the context in which this program was described to be studied, I have not spoken with
those communities that have adopted this program for general city code violations only.
However, in speaking with Joel Jamnik, it would appear that these cities have found success with
their programs.
Attached you will find an email from Roger Knutson, a memorandum from Joel Jamnik, and
information from the cities of White Bear Lake and Columbia Heights. If you desire any other
information, please advise at your convenience.