In Harvey v. County of Butte (1988) 203 Cal. App. 3d 714, the Court determined section 25203 provided the requisite authority for the board to contract for outside legal services for purposes of litigation. (Id. at p. 725.) Harvey concerned the Board's adoption of an ordinance restructuring the county counsel's office by replacing five deputy county counsels with two chief deputies and increasing the use of outside counsel for different matters, including litigation. One of the deposed deputies sued, claiming, among other things, the ordinance's authorization of using outside counsel for litigation services was ultra vires. (Id. at p. 719.) The Court determined the use of outside counsel for litigation was authorized by section 25203 so long as the board approved the contract by a two-thirds vote. (Harvey, supra, 203 Cal. App. 3d at p. 725.) As to matters other than litigation, we determined the board had authority to contract for outside legal services for those matters under section 31000. However, based on a historical review of the jurisprudence addressing public agencies hiring outside counsel and on the purposes behind the two statues, we concluded the authority to hire outside litigation counsel under section 25203 did not extend to all situations. (Ibid.) The Court wrote: "As to matters other than litigation, the policy adopted by the Board can be read as consistent with the provisions of section 31000, which authorizes contracts for special services 'with persons specially trained, experienced, expert and competent to perform the special services.' Sections 25203 and 31001 and its related statute, section 31000 presumably serve different functions. The principal purpose of an authorization for engaging 'special services' is to obtain services which are unavailable from public sources. (See, e.g., Jaynes, supra, 193 Cal. App. 2d 47.) Accordingly, it would appear that section 25203 is addressed to circumstances where litigation counsel services might be viewed as potentially available 'in house.'" (Harvey, supra, 203 Cal. App. 3d at p. 725.)