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Flint Litigation Summaries, 12-2-15

To
Wayne Workman , Schafer, Suzanne K
The following information is per your request: Mays, et al v Governor, et al. This complaint was filed in United States District Court (Eastern District) as a class action and seeks equitable remedial relief and monetary (compensatory and punitive) damages. The claim is that named State officials, City of Flint officials, and former Emergency Managers violated the rights of plaintiffs afforded by the Due Process Clause of the Fourteenth Amendment by deciding to utilize the Flint River as the water source for City residents, thereby exposing them to lead and other toxins, Status: Filed on November 13, 2015. Natural Resources Defense Council, et al v Governor, State Treasurer, Flint RTAB, et al. The claim of this Notice of Intent to Sue in United States District Court is that named State and City officials are in continuing violation of federal Safe Drinking Water Act requirements (lead and copper rules) for having failed to monitor and control lead levels in the City’s drinking water and for having failed to assist certain Michigan schools with testing and remediation. Status: Not yet filed. Notice of Intent to Sue served to putative defendants on November 16, 2015. xxxEND_PAGE:treasury01_b26_3730_4111_006 Vandegrift, Drew (TREASURY)

RE: Professional Liability Insurance

Paul: That would not be my interpretation. You did not indicate how Meadowbrook staff reached the conclusion that governmental immunity no longer would apply to Darnell for acts taken by him while at the City of Flint. I will presume that they read § 20(1) of the Act to apply only to an Emergency Manager currently serving in the local government regarding which litigation arises and concluded it would not apply to Darnell since he no longer is Emergency Manager for the City of Flint. That conclusion may appear reasonable if § 20(1) is read in isolation. However, when read as a whole, § 20 is replete with instances where the term “Emergency Manager” refers to past as well as current occupants of that office. Section 20 was intended to remedy two shortcomings in Act 72: providing legal representation for Emergency Financial Managers while in office and after /eaving office. Section 20(2) was intended to address the former and § 20(5) to address the latter, which was of particular concern since two former Act 72 Emergency Financial Managers had been subjected to litigation after leaving office. With one exception, the Attorney General’s Office consistently took the position under Act 72 that it would not provide legal representation for Emergency Financial Managers because they were not State officials. Section 20(2) requires such representation, but only if litigation challenges: (a) the validity of the Act, (b) the authority of a State official or officer acting under the Act, or (c) the authority of an Emergency Manager and even then only if he or she was acting within the scope of his or her authority under the Act. If, hypothetically speaking, litigation were to be filed against Darnell for acts taken by him while at the City of Flint, the Attorney General’s Office would be obligated to provide legal representation only if such litigation involved (a) or (c); (b) would not apply because Emergency Managers are neither State officials or officers. As noted above, § 20(5) would address, again hypothetically speaking, litigation filed against Darnell for acts taken by him while at the City of Flint. If not covered by insurance, his litigation-related expenses, actual and anticipated, would be assessed against the City of Flint, if approved by the State Treasurer after determining that Darnell’s conduct had been within the scope of his authority and occurred on behalf of a local government while it was in receivership. See § 20(5)(a) and (b). Let me know should you have further questions. Fred

FW: Flint Budget Amendment

Importance: High Fred, | received a copy of your email from Wayne. xxxEND_PAGE:treasury01_b35_5648_6098_306 | understand the argument you are making. However, | wish to note that the Order 20, Section a (6) specifically states that the State Treasurer must approve any budget amendments to the two-year budget, which the City is operating under. lam preparing all of the paperwork to send to the State Treasurer on the assumption that the RTAB will approve this and recommend approval to the State Treasurer. If that occurs, | can have it submitted today. Regardless of the final determination on this, we will be prepared to act on either outcome. | just wanted to point out the Final Order provision prior to the meeting. If you wish to discuss further, let me know. Eric Cline | Department Manager | State of Michigan Michigan Department of Treasury | Local Government Financial Services Division | Fiscal Responsibility Section 430 W. Allegan Street, 3rd Floor | Lansing, MI 48922 Lansing Office (517) 338-2078 | Cell Phone (517) 243-8450 | Traverse City Office (231) 922-8228 E-mail cliner] @michigan.gov CONFIDENTIALITY NOTICE: This e-mail, and any attachments, 1s for the sole use of the intended recipient(s) and may contain information that is confidential and protected from disclosure under the law. Any unauthorized review, use, disclosure, or distribution is prohibited. If you are not the intended reciprent, please contact the sender by reply e-mail, and delete/destroy all copies of the onginal message and attachments Thank you.

Flint Budget Amendment

Importance: High Wayne: Yesterday, Terry asked me the question whether the Flint resolution authorizing the use of $2.0 million of fund balance is subject to State Treasurer’s approval after receiving RTAB approval? I believe Terry’s question was triggered by the City’s Administrator indicating that such dual approval is required. 39 xxxEND_PAGE:treasury01_b35_5648_6098_307 Act 436 does not require approval by both an RTAB and the State Treasurer of an amendment to an EM’s two- year budget. What the Act does require is approval by the State Treasurer if receivership has been terminated, or RTAB approval under § 23(5)(c) of the Act if receivership has not been terminated. I base my conclusion on § 21 of the Act, which provides as follows: (1) Before the termination of receivership and the completion of the emergency manager's term, or if a transition advisory board is appointed under section 23, then before the transition advisory board is appointed, the emergency manager shal] adopt and implement a 2-year budget, including all contractual and employment agreements, for the local government commencing with the termination of receivership. (2) After the completion of the emergency manager's term and the termination of receivership, the governing body of the local government shall not amend the 2-year budget adopted under subsection (1) without the approval of the state treasurer, and shall not revise any order or ordinance implemented by the emergency manager during his or her term prior to 1 year after the termination of receivership. Emphasis supplied. This is the answer I will provide at the RTAB meeting today if the question is posed. So, I wanted to make sure we all are on the same page regarding this. That said, I am aware of nothing in the Act that would preclude the State Treasurer from adding his imprimatur to a budget amendment after RTAB disposition if he wished to do so. Fred 40 xxxEND_PAGE:treasury01_b35_5648_6098_308 Stanton, Terry A. (Ti reasury)

RE: Flint follow up

Tom and Wayne: This is as revised based upon additional notes from Eric. This is ready to go. Fred He ae Nee Summary from September 15, 2015, conference call between Treasury and City of Flint officials. The participants were: Tom Saxton, Wayne Workman, Fred Headen, and Eric Cline, from Treasury, and Dayne Walling, Natasha Henderson (City Administrator), Pete Bade (City Attorney), Tony Chubb (Assistant City Attorney), and Jody Lundquist (Finance Director) from the City. Issues discussed: e The City of Flint is involved in two lawsuits regarding water and sewer rates: Kincaid and Shears. Kincaid was decided by the Michigan Court of Appeals on June 11, 2015, The Court held that a 35 percent increase in water and sewer rates imposed by City officials on September 16, 2011, violated the City charter and that EM Mike Brown had no statutory authority to later ratify those rate increases in May of 2012. The Court of Appeals remanded the case to Genesee County Circuit Court. City officials intended to appeal the Court of Appeals Kincaid decision to the Michigan Supreme Court, but missed the filing deadline by one day. « Shears was decided by the Genesee County Circuit Court by a non-final order on August 17, 2015. Among other things, the Court enjoined City officials from any longer imposing the 35 increase in water and sewer rates; from disconnecting water or sewer service due to delinquent bills dating back to September 16, 2011; and from placing liens on property due to delinquent bills dating back to September 16, 2011. City officials have filed an appeal with the Michigan Court of Appeals seeking, among other things, a stay of the Genesee County Circuit Court injunction. e In the interim, City officials are complying with the Court’s order in Shears. City officials estimated that removal of the 35 percent increase in water and sewer rates from future bills will cost roughly $600,000 per month, or $7.2 million annually, Therefore, if the Court orders either refunds or credits against future water and sewer bills, retroactive to September 16, 2011, the cost would be roughly $28.8 million to date (i.¢., $600,000 per month times 48 months to date). The City Administrator indicated that City officials have not developed a plan to issue a refund of this magnitude because the City lacks sufficient funds to do so and they believe the City would be unable to operate at that point. e The City Administrator noted that the accounts receivable for water and sewer operations that are over 30 days old has increased from $7.8 million to $8.4 million since the Shears order. She also noted that, because xxxEND_PAGE:treasury01_b37_6553_6782_089 City officials are prohibited from disconnecting water or sewer service for non-payment, they expect this number to continue to increase. e The City Administrator noted that the measures taken to preserve funds within the water and sewer system to address these issues have delayed needed capital improvements, which has further exacerbated problems within the system. However, City officials cannot address capital needs without additional revenue. © The City Administrator brought up and stressed the importance of the State assistance sought by the Mayor in his September 14, 2015, letter to the Governor. The Mayor requested $30.0 million for infrastructure and capital improvements related to the City’s water and sewer system. Wayne indicated that the Mayor’s request had been received and promptly disseminated within Treasury and was being reviewed. However, he also indicated that, in his opinion, existing funding options were limited without additional legislative action. ae He He ok

RE: Flint follow up

(am working on it right now. You should see a summary of my notes within 15 minutes. Eric Cline | Department Manager State of Michigan | Michigan Department of Treasury | Office of Fiscal Responsibility 430 W. Allegan Street, 3rd Floor | Lansing, MI 48922 Lansing Office (517) 335-2078 | Cell Phone (517) 243-8450 | Traverse City Office (231) 922-5228 E-mail cliner] ichigan.gov CONFIDENTIALITY NOTICE: This e-mail, and any attachments, is for the sole use of the intended recipient(s) and may contain information that is confidential and protected from disclosure under the law. Any unauthorized review, use, disclosure, or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail, and delete/destroy all copies of the onginal message and attachments Thank you.

RE: Flint follow up

Tom and Wayne: I did not take notes, but here is a summary as | recall it. Feel free to fill in missing items. Fred Peers Summary from September 15, 2015, conference call between Treasury and City of Flint officials. The participants were: Tom Saxton, Wayne Workman, Fred Headen, and Eric Cline, from Treasury, and Dayne Walling, Natasha Henderson (City Administrator), Pete Bade (City Attorney), Tony Chubb (Assistant City Attorney), and Jody Lundquist (Finance Director) from the City. Issues discussed: e The City of Flint is involved in two lawsuits regarding water and sewer rates: Kincaid and Shears. Kincaid was decided by the Michigan Court of Appeals on June 11, 2015. The Court heid that a 35 percent increase in water and sewer rates imposed by City officials on September 16, 2011, violated the City charter and that EM Mike Brown had no statutory authority to later ratify those rate increases in May of 2012. The Court of Appeals remanded the case to Genesee County Circuit Court. City officials intended to appeal the Court of Appeals Kincaid decision to the Michigan Supreme Court, but missed the filing deadline by one day. e Shears was decided by the Genesee County Circuit Court by a non-final order on August 17, 2015. Among other things, the Court enjoined City officials from any longer imposing the 35 increase in water and sewer rates; from disconnecting water or sewer service due to delinquent bills dating back to September 16, 2011; and from placing liens on property due to delinquent bills dating back to September 16, 2011. City officials have filed an appeal with the Michigan Court of Appeals seeking, among other things, a stay of the Genesee County Circuit Court injunction. * City officials estimated that removal of the 35 percent increase in water and sewer rates will cost roughly $600,000 per month. Therefore, if the Court orders either refunds or credits against future water and sewer bills retroactive to September 16, 2011, the cost would be roughly $28.8 million to ‘Hate (i.e., $600,000 per month times 48 months to date). e The City Administrator brought up and stressed the importance of the State assistance sought by the Mayor in his September 14, 2015, letter to the Governor. The Mayor requested $30.0 million for infrastructure and capital improvements related to the City’s water and sewer system. We RA

RE: Michigan Report, Friday, June 12, 2015

Wayne: The Court of Appeals drew a distinction between two actions taken by Mike Brown: first, the ratification by him of water and sewer rale increases proposed by the then City Finance Director (“Townsend”) and second, the initiation and implementation by Mike himself of separate, additional water and sewer rate increases. The Court struck down only the former action; it left the latter action in place. The Court concluded that the water and sewer rate increases proposed by Townsend violated charter provisions requiring “notice and publication to its residents thirty days prior and by not waiting to implement those rates 97 xxxEND_PAGE:treasury01_b30_4670_4718_34 until July | of the next fiscal year.” The Court also concluded that nothing in Act 4, under which Mike acted, nor in subsequently enacted Act 436, authorized an Emergency Manager to simply ratify the actions of someone else (i.e., Townsend). Had Mike initiated and implemented the initial set of water and sewer rate increases on his own, the outcome would have been different. “[H]owever, [the statute] d[id] not support the action taken by the EM to expressly ratify and confirm the increases recommended by Townsend.” As a bottom line, this decisions appears to have limited impact upon the authority of Emergency Managers. Fred

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