California county had an unconstitutional code for decades. Was it fixed?
AI-generated summary reviewed by our newsroom.
- Placer County removed a residency clause that violated California's constitution.
- CEO Daniel Chatigny received a pay raise and contract extension through 2028.
- County charters may retain outdated laws invalid under current legal standards.
The Placer County Board of Supervisors amended its county code this month to remove a decades-old provision requiring the county executive officer to live within its jurisdiction because the code violated the state Constitution.
The county’s code, since at least 1976, has stated a county executive officer “shall maintain residence within the county of Placer during his or her appointment.” But that violates a law passed by state legislators in 1970 which forbid certain municipalities from mandating employees live within its jurisdiction. California voters approved an initiative in 1974, which amends the state Constitution, to ensure all local agencies followed this law.
It is not unheard of for local municipalities to have local codes on its books which violate the Constitution, said two California Constitutional law experts. Likely, cities and counties have archaic provisions, especially concerning rules around government structure, said Clark Kelso, a professor at the University of the Pacific’s McGeorge School of Law.
“It’s horrible,” said Michael Salerno, emeritus clinical professor at University of California Law at San Francisco, but he added, “it happens all the time.”
The Board of Supervisors approved amending the unconstitutional provision during an Aug. 5 meeting. Now, the county’s residency requirement says an “employee is required to reside within” 50 driving miles of the “principal county executive office located within the boundaries of the county seat at all times during his employment as County Executive Officer.”
Placer County Executive Officer Daniel Chatigny was appointed in May 2024 and served for about 15 months before the code was altered. He appears to live in Nevada County, where he worked for local county government for 13 years before joining Placer County in August 2019, according to public records and his LinkedIn page.
A county spokesperson maintained his appointment was not illegal because the residency provision was trumped by the state Constitution. The unconstitutional provision was listed in the county’s ordinances.
“At no point in his employment as the County CEO has Mr. Chatigny violated the terms of his contract,” said county spokesperson Chris Gray Garcia. “The code in question is illegal and could not be enforced at the time Mr. Chatigny was appointed as CEO and cannot be enforced now.”
Kelso said most counties called Placer County’s efforts to change the residency requirement as a county code clean-up effort.
“It’s not really a big problem, usually,” he said.
In the 60s and 70s, many counties and cities required its employees to live within its jurisdiction. But residents became more mobile and sensibilities changed, Kelso said.
The 1974 initiative, Proposition 5, said the Legislature banned the residency requirement in part because political machines attempted to keep tabs on government employees to ensure they register to vote with the “right party.”
Now, a city, county or district only requires a staff member to live within a “reasonable and specific distance of their place of employment or other designated location,” according to the state Constitution.
A raise for Placer County’s top leader
Alongside changing the residency requirement, the Placer County Board of Supervisors unanimously approved Tuesday a pay raise for its top leader based on an annual performance review.
Chatigny received a 9% raise, with his salary jumping to $311,334 from $285,147. Supervisors also voted to extend Chatigny’s contract by one year, until May 28, 2028. His three-year contract originally ended in 2027.
“He has well earned this increase,” said Supervisor Shanti Landon, who represents Lincoln, Sheridan and portions of west Roseville, during Tuesday’s meeting.
The county executive officer position — in charge of overseeing a $1.3 billion budget and about 2,600 number of employees — has seen repeated turnover after its former CEO was fired due to harassment in 2022.
The highest paid employee for Placer County last year was a sheriff’s captain, who made $432,987, according to the state controller’s office. Other positions making more money than Chatigny include the county’s director of health and human services, psychiatrist and another deputy sheriff, last year’s data showed.
Former CEO Todd Leopold had a workplace discrimination and harassment complaint filed against him, which prompted the Board of Supervisors to vote for his termination in June 2022. Leopold later resigned.
Leopold also faced increasing scrutiny after he drove a vehicle in March 2022 into an 18-year-old Inderkum High School student and killed him. Anthony Williams was wearing dark clothing and standing on a Rocklin road at night, according to previous Bee reporting.
The Placer County District Attorney’s Office ultimately declined to charge Leopold in the collision after prosecutors did not find evidence “of any criminal or wrongful intent,” according to previous Bee reporting.
The Placer County Board of Supervisors appointed Jane Christenson in November 2022. She announced her retirement, effective May 2024.
This story was originally published August 25, 2025 at 6:00 AM.
CORRECTION: This story and headline were updated to clarify the Placer Board of Supervisors updated its county code. Additionally, it was updated to clarify former CEO Todd Leopold resigned.
