HomeMy WebLinkAboutMemo Re City Attorney Update for 2020 final
To: Board of Ethics
Fr: Greg Sullivan, City Attorney
Date: December 4, 2020
RE: City Attorney Update for December 9, 2020 Meeting
Attached to this memorandum please find several emails related to opinions and advice that has
been provided by the City Attorney’s Office over the past year. These include:
• City-County Pedestrian Traffic Safety Committee conflicts of interest (November 16,
2020);
• Post-employment activities for a former city official (November 2, 2020);
• Conflicts with City Commissioner’s private and financial interests (Commissioner
Cunningham and Run Dog Run/Cottonwood Enterprises) (August 18, 2020)
• General statement to members of City Boards regarding obligations upon a conflict of
interest (August 7, 2020)
• Conflicts of interest for members of the Trails, Open Space, and Parks Bond Committee
related to funding requests for a shared use pathway along the Frontage Road (January 2,
2020)
During our update we will also briefly discuss other conflict of interest issues. These include city
board members acting in their official capacity on matters where they have a private interest, city
commissioner recusals, staff questions related to working on land use projects near where they
live, how city employees handle private entities suggestions of gifts for action taken, city
employees’ involvement in decisions on contracts with their former employers, etc.
In addition we will provide a overview of a training conducted by our office and the city clerk
this past October for staff who serve as liaisons to the various city boards. A component of that
training involved ethics issues especially conflicts of interest.
From:Greg Sullivan
To:Taylor Lonsdale; John Vandelinder
Cc:Mitch Reister; Anna Rosenberry; Jeff Mihelich; Chuck Winn; Karen Stambaugh; Anna Saverud; Tim Cooper;
Michael Wallner; Mike Maas; Shawn Kohtz
Subject:Conflicts and the PTSC
Date:Monday, November 16, 2020 1:54:00 PM
HI Taylor and John.
Here’s my guidance on the ethics situation you described regarding members of the Pedestrian &
Traffic Safety Committee (PTSC). You may share this with the PTSC as you determine appropriate. I
copied Commissioner Wallner as he is the commission liaison to the PTSC.
Your question is whether and to what extent members of the PTSC can represent or appear on
behalf of a separate entity before the PTSC in a matter that is under the PTSC jurisdiction and which
also is advocated for by an organization which they are a director. You specifically asked about PTSC
members Marilee Brown and Ralph Zimmer in their capacity as members of the board of directors
for the Gallatin Alliance for Pathways (“GAP”). You also inquired about Jason Delmue, a member of
the City’s Bozeman Area Bicycle Advisory Board (the “Bike Board”).
The PTSC was created by an “inter-local cooperative agreement” in December of 1976. The parties
to the agreement include the Bozeman High School District and School District NO. 7, Gallatin
County, and the City. The members of the PTSC consist of individuals appointed by the governing
bodies of the school district, county and city, and two members selected by the appointed board
members. Mr. Zimmer is appointed by the Gallatin County Commission. Marilee Brown is appointed
by the other board members to an “at-large” position.
The PTSC is charged with “consider[ing[ pedestrian-traffic safety, establish[ing] priorities, and []
mak[ing] such recommendations to the governing bodies consistent with said priorities which will
promote public safety and in their opinion reduce traffic deaths, injuries, and property losses
resulting from traffic accidents.” The agreement also lists three goals. From these provision it is clear
the work of the committee is foremost to benefit the safety of the public.
Individuals who are members of inter-governmental boards appointed by the Bozeman City
Commission are subject to City’s Code of Ethics. All officials of local advisory boards in Montana are
subject to statutory provisions regarding ethics, as appropriate. Your question asks, for Mr. Zimmer
and Ms. Brown, whether individuals who are not appointed directly by the Bozeman City
Commission to the PTSC have conflicts of interests between their role on the PTSC and their role as
directors of GAP in regards to the frontage road pathway. The City’s Code of Ethics does not apply to
members of inter-governmental boards or committees that are appointed by another governing
body. As for Marilee Brown, I recognize she is appointed in part by vote of those who are appointed
by the Bozeman City Commission. Again, it is not clear from the 1976 agreement whether Ms. Brown
is subject to the City’s Code of Ethics. Absent a specific provision in the cooperative agreement I
determine neither Mr. Zimmer nor Ms. Brown are subject to the City’s Code of Ethics.
I note that county appointees to City boards, such as the planning board, are subject to the City’s
Code of Ethics as the board is a city board.
Notwithstanding the above, the City Code of Ethics provisions regarding conflicts of interest can be
helpful in understanding best practices for members of the PTSC in terms of addressing any potential
conflicts between their duties and obligations on behalf of the public as members of the PTSC and
their private role as directors of GAP.
The City’s Code of Ethics is based in the Bozeman City Charter which states, “The use of public office
for private gain is prohibited.” Bozeman Charter, Sec. 7.01. This section places an obligation on the
Bozeman City Commission to implement this prohibition through the adoption of an ordinance; the
Commission has done so through the Code of Ethics. This section of the Charter also clearly indicates
the prohibition of using public office for private gain applies to “acting in an official capacity on
matters in which the official has a private financial interest clearly separate from that of the general
public…” and also “appearances by officials before other city agencies on behalf of private interests.”
The Code of Ethics implements these Charter provisions at Chpt. 2, Art. 3, Div. 4, BMC, specifically
under 2.03.490 (Standards of Conduct) and 2.03.520 (Conflict of Interest). I believe both of these
provisions should be considered by members of the PTSC and act as guidance.
The Standards of Conduct provision in the Code of Ethics specifically states, “No official shall act in a
private capacity on matters acted upon as an official.” 2.03.490.A, BMC. Next, the Conflict of Interest
provisions in the Code of Ethics has a number of provisions that should be considered. Most
importantly, 2.03.520.F, BMC, states,
No official whether paid or unpaid, shall represent or appear on behalf of any individual or
entity in transaction or matter of concern to the agency on which that official serves, either
before that agency or any other agency of the city, or before the city commission, or take
any appellate proceedings from any action of such agency or the commission. Such
representation may be made by the official's associate or partner, provided no reference to
the participation of the involved official is made except for certification or other required
identification on prepared documents. The involved official shall not engage in deliberations
concerning a transaction or matter represented by an associate or partner, shall disqualify
himself/herself from acting on the transaction or matter, and shall not communicate about
such matter with any person who will participate in the action to be taken on such
transaction or matter.
The above provision prohibits an official from representing or appearing on behalf of an entity in a
transaction or matter of concern to the agency on which that official serves. As noted, I recognize
Mr. Zimmer and Ms. Brown are not appointed by the Bozeman City Commission. I suggest, however,
this prohibition could guide them in establishing practices for how to address their responsibilities
and obligations as members of the PTSC in relation to their responsibilities and obligations as
directors of GAP. In doing so, Mr. Zimmer and Ms. Brown should consider the following practices:
1. Refrain from taking part in any discussion at PTSC that involves a project advocated for or
sponsored by GAP. If a project which is advocated for by GAP comes before PTSC in terms of
seeking support, financial or otherwise, the representation of GAP should be conducted by a
different member of GAP.
2. Disclose on the record of the PTSC that they are directors for GAP and recuse themselves
from any participation in the discussion of the project or request. This includes refraining
from answering questions posed by other PTSC members related to the project. PTSC
members may direct any such question to a GAP representative not holding a PTSC position.
I also point out the Montana Code of Ethics (Title 2, Chpt. 2, Part 1, MCA) indicates “the holding of
public office is a public trust” and that “a public officer shall carry out the individual’s duties for the
benefit of the people of the state.” 2-2-103(1), MCA. In addition, 2-2-121(2)(e), MCA, states, “A
public officer [] may not perform an official act directly and substantially affecting to its economic
benefit a business or other undertaking in which the officer [] either has a substantial financial
interest or is engaged as counsel, consultant, representative, or agent…” Moreover, 2-2-121(5),
MCA, states, “A public officer [] may not participate in a proceeding when an organization [] of which
the public officer [] is an officer or director is: (b) attempting to influence a local, state, or federal
proceeding in which the public officer or public employee represents the state or local government.”
I provide the foregoing as additional examples of ethics rules that should provide guidance to
appointed members of advisory boards created pursuant to inter-local agreement to which the city
of Bozeman is a party. In addressing how these statutes apply, I encourage board members to
consult the legal counsel for the organizations which appointed them.
As for the Bike Board and Mr. Delmue, the City’s Code of Ethics directly applies as the Bike Board is a
City board. As such, the provisions in the City’s Code of Ethics I reference above are applicable to Mr.
Delmue in his role on the Bike Board.
Given the inter-local nature of the PTSC, I recommend the PTSC consider adopting rules of
procedure for its members in relation to standards of conduct and ethical practices.
Please let me know if you have any questions,
Greg
Greg Sullivan
City Attorney
City of Bozeman
PO Box 1230
Bozeman, MT 59771-1230
121 North Rouse Ave.
406-582-2309
gsullivan@bozeman.net
From:Greg Sullivan
To:Chris Naumann
Cc:Jeff Mihelich; Brit Fontenot; Anna Rosenberry; Kristin Donald
Subject:RE: Consult request
Date:Monday, November 2, 2020 3:27:00 PM
Attachments:image001.pngimage003.pngimage004.pngimage007.png
Hi Chris.
Here’s my opinion on your situation.
First, I am not issuing you an opinion on the implications of 2-2-201, MCA. I suggest you talk with an
attorney that would represent your interests and/or legal counsel for your future employer.
The following is based on 2.02.560, BMC. This provision of the city of Bozeman’s code of ethics
prohibits a former public servant from “making a formal or informal appearance before, or
negotiating with any decision maker regarding a transaction or matter which was under the former
public servant’s direct responsibility or which the former public servant participated personally or
substantially.” That section also prohibits a former public servant from “representing or appearing
on behalf of an individual or entity other than the city in connection with any transaction or matter
which was under the former public servant’s direct responsibility or which the former public servant
participated personally and substantially as a public servant.”
The code of ethics defines a public servant as “officials, members of the parking commission and
library board and employees [of the city].” Officials is defined by the code of ethics as “officers and
members of the city’s agencies, whether elected or appointed, whether paid or unpaid, etc.”
Employee is defined as “individuals employed by the city and its agencies.” I determine you are a
public servant in your employment as the executive director of the Downtown Bozeman Partnership
(the “Partnership”) as that entity is comprised of three separate entities, two of which are city of
Bozeman entities: the Downtown Urban Renewal District and the Downtown Business Improvement
District.
You asked whether in your new role as an employee of Sanderson Stewart you may participate in
work that is subject to a contract between the Partnership and Sanderson Stewart and which also
includes the city. As I understand, the current professional services agreement with Sanderson
Stewart is a contract wherein either the Partnership, for the downtown area, or city staff for the
other urban renewal districts, request Sanderson Stewart perform professional services through the
issuance of task orders. You specifically asked if the above cited section of the city’s code of ethics
prohibits you from (i) working for Sanderson Stewart on task orders issued in the downtown area; or
(ii) prohibits you from working for Sanderson Stewart on task orders issued for the other urban
renewal districts.
I determine 2.02.560, BMC prohibits you, for a period of 12 months following the date you no longer
work for the Partnership, from participating in any task order issued under the contract with
Sanderson Stewart for the downtown area. As you have indicated you have done no work on behalf
of the city in the other urban renewal districts; as such, I determine this section of the ethics code
does not prohibit you from working on current or future task orders issued by other city staff for
work under the contract outside of the downtown area.
Please know that if any task order currently issued by city staff or any future task order has any
overlap with or direct connection to the downtown area you will be prohibited, for the appropriate
12 month period, from working on the task order.
Please also recognize the provisions of 2.02.570, BMC, allow you to conduct such activities if you file
the notice required by those sections. Please note that this section does not provide the ability to
overcome the issues raised in 2-2-201, MCA.
Let me know if you have any additional questions.
Greg
From: Chris Naumann <chris@downtownbozeman.org>
Sent: Tuesday, October 27, 2020 4:47 PM
To: Greg Sullivan <gsullivan@BOZEMAN.NET>
Subject: RE: Consult request
Greg,
My previous email attached the original URD Term Contract PSA.
Attached here is the most recent Task Order I issued via the URD Term Contract.
Let me know if you need any additional documents.
Thanks in advance for your time.
Chris Naumann
Executive Director
Downtown Bozeman Partnership
222 East Main Street #302 | Bozeman MT 59715
406-586-4008 | www.downtownbozeman.org
The Downtown Business Improvement District and Downtown Urban Renewal District are City of Bozeman entities
administered by the Downtown Bozeman Partnership. City of Bozeman emails are subject to the Right to Know
provisions of Montana’s Constitution (Art. II, Sect. 9) and may be considered a “public record” pursuant to Title 2,
Chpt. 6, Montana Code Annotated. As such, this email, its sender and receiver, and the contents may be available
for public disclosure and will be retained pursuant to the City’s record retention policies. Emails that contain
confidential information such as information related to individual privacy may be protected from disclosure under
law.
From: Chris Naumann
Sent: Tuesday, October 27, 2020 3:01 PM
To: Greg Sullivan <gsullivan@BOZEMAN.NET>
Subject: RE: Consult request
Attached is the PSA in question...
Chris Naumann
Executive Director
Downtown Bozeman Partnership
222 East Main Street #302 | Bozeman MT 59715
406-586-4008 | www.downtownbozeman.org
The Downtown Business Improvement District and Downtown Urban Renewal District are City of Bozeman entities
administered by the Downtown Bozeman Partnership. City of Bozeman emails are subject to the Right to Know
provisions of Montana’s Constitution (Art. II, Sect. 9) and may be considered a “public record” pursuant to Title 2,
Chpt. 6, Montana Code Annotated. As such, this email, its sender and receiver, and the contents may be available
for public disclosure and will be retained pursuant to the City’s record retention policies. Emails that contain
confidential information such as information related to individual privacy may be protected from disclosure under
law.
From: Greg Sullivan <gsullivan@BOZEMAN.NET>
Sent: Tuesday, October 27, 2020 10:21 AM
To: Chris Naumann <chris@downtownbozeman.org>
Subject: RE: Consult request
Phone. .
From: Chris Naumann <chris@downtownbozeman.org>
Sent: Tuesday, October 27, 2020 9:21 AM
To: Greg Sullivan <gsullivan@BOZEMAN.NET>
Subject: RE: Consult request
Yes, sir.
Your office, my office, or phone?
Any of the above work for me.
Chris Naumann
Executive Director
Downtown Bozeman Partnership
222 East Main Street #302 | Bozeman MT 59715
406-586-4008 | www.downtownbozeman.org
The Downtown Business Improvement District and Downtown Urban Renewal District are City of Bozeman entities
administered by the Downtown Bozeman Partnership. City of Bozeman emails are subject to the Right to Know
provisions of Montana’s Constitution (Art. II, Sect. 9) and may be considered a “public record” pursuant to Title 2,
Chpt. 6, Montana Code Annotated. As such, this email, its sender and receiver, and the contents may be available
for public disclosure and will be retained pursuant to the City’s record retention policies. Emails that contain
confidential information such as information related to individual privacy may be protected from disclosure under
law.
From: Greg Sullivan <gsullivan@BOZEMAN.NET>
Sent: Tuesday, October 27, 2020 8:58 AM
To: Chris Naumann <chris@downtownbozeman.org>
Subject: RE: Consult request
Hey.
How about 4pm today?
g
From: Chris Naumann <chris@downtownbozeman.org>
Sent: Monday, October 26, 2020 1:04 PM
To: Greg Sullivan <gsullivan@BOZEMAN.NET>
Subject: Consult request
Greg,
I am hoping you would be willing to meet with me to discuss Sec. 2.03.560. – “Post
employment/service activities” as it may relate to my new job.
If so, I am willing to meet in person or via the phone at your convenience this week or next
(but not a big rush as my last day of work is 12/18/20).
Thanks.
Chris Naumann
Executive Director
Downtown Bozeman Partnership
222 East Main Street #302 | Bozeman MT 59715
406-586-4008 | www.downtownbozeman.org
The Downtown Business Improvement District and Downtown Urban Renewal District are City of Bozeman entities
administered by the Downtown Bozeman Partnership. City of Bozeman emails are subject to the Right to Know
provisions of Montana’s Constitution (Art. II, Sect. 9) and may be considered a “public record” pursuant to Title 2,
Chpt. 6, Montana Code Annotated. As such, this email, its sender and receiver, and the contents may be available
for public disclosure and will be retained pursuant to the City’s record retention policies. Emails that contain
confidential information such as information related to individual privacy may be protected from disclosure under
law.
City of Bozeman emails are subject to the Right to Know provisions of Montana’s
Constitution (Art. II, Sect. 9) and may be considered a “public record” pursuant to Title 2,Chpt. 6, Montana Code Annotated. As such, this email, its sender and receiver, and the
contents may be available for public disclosure and will be retained pursuant to the City’srecord retention policies. Emails that contain confidential information such as information
related to individual privacy may be protected from disclosure under law.
City of Bozeman emails are subject to the Right to Know provisions of Montana’s
Constitution (Art. II, Sect. 9) and may be considered a “public record” pursuant to Title 2,Chpt. 6, Montana Code Annotated. As such, this email, its sender and receiver, and the
contents may be available for public disclosure and will be retained pursuant to the City’srecord retention policies. Emails that contain confidential information such as information
related to individual privacy may be protected from disclosure under law.
From:Greg Sullivan
To:Jeff Mihelich
Subject:Commissioner Cunningham conflict issues x 2
Date:Tuesday, August 18, 2020 10:20:40 AM
Jeff,
Terry called me this morning to discuss two conflict issues. Writing this to keep you in the loop and
memorialize my conversation.
Briefly:
1. His company, Cottonwood Enterprises, is working on a mask promotion related to the
pandemic. His company has been fundraising and receiving funds from the state, the
hospital, etc. He is also scheduled to go before the Gallatin County Commission at a 1:30
work session soon to request county support. At some point, he will also seek the Board of
Health’s participation.
a. I told him he is not prevented from engaging in this including discussions with the
County. I advised him he must put on the record that he is doing the work in his
personal capacity and is not representing the City in the project.
b. I told him since the Board of Health is a agency created out of interlocal agreement
between the City and the County he should have an associate make the request and
follow 2.03.520.F, BMC (the City’s “sole practitioner” rule”). He indicated his wife,
Laura, will make the request to the BoH.
2. He also operates a non-profit called Run Dog Run – a group that advocates for expanding
non-human recreation (i.e. dog parks). He indicated his group has put in a request to the
UDC amendment website to have major developments that provide over five acres of
parkland be required to set aside a certain percentage for dog parks. I told him this will be a
direct conflict and he must recuse himself. Another with RDR can represent them before the
City – just not him. We went through the rule process.
g
Greg Sullivan
City Attorney
City of Bozeman
PO Box 1230
Bozeman, MT 59771-1230
121 North Rouse Ave.
406-582-2309
gsullivan@bozeman.net
From:Greg Sullivan
To:Addi Jadin; Alex Nordquest; Bob Risk; Brian Krueger; Brian LaMeres; Brit Fontenot; "Chris Naumann"; "EmilyCope"; Jessica Parks; John Vandelinder; Josh Waldo; Julie Hunter; Katherine Maines; Lacie Kloosterhof; MartinMatsen; Melanie Eubank; Mitchell Overton; Phillipe Gonzalez; Steve Crawford; Susan Gregory; Tanya Andreasen;Taylor Lonsdale; Tom Rogers
Cc:Jeff Mihelich; Chris Mehl; Cyndy Andrus; I-Ho Pomeroy; Terry Cunningham; Michael Wallner; Mike Maas; Kelley
Rischke; Karen Stambaugh; Tim Cooper; Anna Saverud
Subject:Ethical Considerations for City Board Members
Date:Friday, August 7, 2020 2:55:17 PM
Importance:High
All:
You are considered a staff liaison to a City board. Please forward this to your boards as soon as
possible.
Thanks,
g
To members of City of Bozeman Boards and Committees:
Please take a few minutes to read this email and please don’t hesitate to get in touch with me if you
have any questions.
Jeff Mihelich, Bozeman City Manager, requested I send you all a note reminding you of a board
member’s obligations under the City’s Code of Ethics regarding conflicts of interest. This email
addresses the Code’s provisions on conflicts of interest and provides information on best practices
for addressing conflicts. I also provide guidance on how to proceed when you wish to provide public
comment on that issue before the board upon which you serve, before another City board, or before
the City Commission.
As you know, City board members, including those appointed to a city board by another entity, are
considered city officials under the City’s Code of Ethics and thus subject to its standards and
requirements, including the rules for conflicts of interest. Specifically, under 2.03.520.B, BMC, “No
official [] shall engage in any employment or business which conflicts with the proper discharge of
such official’s [] duties.” In addition, 2.03.520.C states, “No official [] shall take or influence official
action if the official [] has a financial or personal interest in a transaction or matter with the City.”
Financial and personal interests are defined by the Code of Ethics. See 2.03.470. Please review these
definitions.
In addition, the Code’s conflict of interest section at 2.03.520.F, establishes a prohibition on an
official representing or appearing on behalf of any individual or entity in a transaction or matter of
concern to the agency on which that official serves. This rule prohibits representation on behalf of a
person or entity before the board on which the official serves agency (the member’s own board or
committee) and also before the City Commission. The result is that a board member is prohibited
from representing an individual or an entity, be it a for-profit or not for profit group or organization,
on an issue before their board or the City Commission if the board on which they serve has
jurisdiction over the issue. This is the case regardless of whether the board’s role is advisory. This
section of the Code also provides a mechanism for how the individual or entity may be represented
at a City board or committee or City Commission meeting: “by the official’s associate or partner,
provided no reference to the participation of the involved official is made.”
When a conflict exists, the Code requires an official to take certain steps. Under both 2.03.520.F and
2.03.520.D, the official must publicly disclose on the record the existence of the conflict of interest
and refrain from engaging in deliberations and discussion with those who will act on the matter. The
best practice is for the official to place the nature of the conflict on the record, recuse from the
discussion, and leave the room. For meetings occurring by WebEx, I urge the official to log out of the
virtual meeting until the agenda item has concluded and the next agenda item is called.
The Code recognizes that at times an official must address their own personal interest before the
board upon which they sit. See 2.03.520.A. This is authorized. If a board member has a personal
interest (for example, a board member seeks a certificate of appropriateness for a remodel of their
personal residence), the official may appear on their own behalf. The Code, however, distinguishes
between an item that is clearly personal in nature from personal or financial interests that may arise
due to affiliation with a business or other entity, such as serving on a board or acting as an officer of
a non-profit organization. An ownership interest in a business entity, or membership on the board or
advisory committee of a group or organization, will, in most situations, create a personal or financial
interest establishing a conflict of interest.
The Code of Ethics contains a “Declaration of Policy.” 2.03.460, BMC. These policies, which form the
foundation for the specific rules in the Code, are critical to ensuring public trust in how City officials
(and employees) operate. To implement these policies, avoid the appearance of a conflict of
interest, and comply with the Code, full disclosure of a conflict of interest is appropriate.
When board members speak on their own behalf on items that are under their jurisdiction as a
board member before the City Commission or another board, they must put on the record the
capacity in which they are speaking. If, for example, a board member, speaks before the City
Commission on an item under the jurisdiction of the board upon which they serve and the board
member wishes to provide comment to the Commission separate from the recommendation of their
board, the board member must identify the board upon which they serve and indicate on the record
they are not speaking on behalf of the board but rather in their individual capacity. In another
example, if the board member desires to speak before the City Commission on a matter that is not
under the jurisdiction of the board upon which they serve, the board member must nonetheless
identify the board upon which they serve and indicate they are speaking on their own behalf and are
not speaking on behalf of their board. This later example requires disclosure of their role as a city
official even if the matter upon which they are speaking is personal in nature. The above does not
supersede the Code’s prohibition on representation as discussed above.
I recognize that at times the determination of what qualifies as a personal or financial interest may
be difficult to draw and that all of you are all members of this community interacting with
community organizations, friends, and family. It is precisely because of your involvement in the
community that you have volunteers to serve. Please remember the City provides resources to help
determine whether a relationship creates a conflict of interest requiring disclosure and recusal. I
encourage you to contact me directly at 582-2309 or by email. You may also contact your staff or
commission liaison to seek advice.
Thank you for your service,
Greg
Greg Sullivan
City Attorney
City of Bozeman
PO Box 1230
Bozeman, MT 59771-1230
121 North Rouse Ave.
406-582-2309
gsullivan@bozeman.net
From:Karen Stambaugh
To:Mitchell Overton; Addi Jadin
Cc:Greg Sullivan
Subject:CONFIDENTIAL ATTORNEY COMMUNICATION - TOP member conflict of interest analysis
Date:Thursday, January 2, 2020 3:50:28 PM
CONFIDENTIAL ATTORNEY COMMUNICATION – DO NOT FORWARD.
Hi Addi and Mitch – as we discussed, I’ve been looking at whether Tom Starner or Doug Chandler
have a conflict of interest, and if so, whether disclosure and recusal is required. Mitch – please
communicate the conclusion to Tom.
All city officials and employees are covered by the Code of Ethics, including citizen advisory board
members (“officials” means all officers and members of the city’s agencies; “agency” includes boards
and committees of the city. 2.03.740.A). Therefore, the Code of Ethics is applicable to Mr. Starner
and Mr. Chandler as Trails, Open Space, and Parks (TOP) Committee members.
There are five voting positions in the TOP committee, but one is currently vacant (an appointment is
on the agenda on 1/6). Mr. Starner occupies the “Real Estate” position. He is a broker at Gene Cook
Real Estate. He is the listing broker for the lots at Nelson Meadows Subdivision, a commercial
subdivision with lots actively listed. Mr. Chandler occupies the “Finance” position. He is the
President of Allied Engineering. They had some involvement in the Nelson Meadows subdivision –
they were not the engineers (it was Morrison-Maierle) but they did produce a geotechnical survey
for Barnard.
The TOP application proposes to fill in a section of the frontage trail that would eventually link
Bozeman to Belgrade adjacent to the Nelson Meadows subdivision. The proposed new trail sections
would connect to the trail section being installed by Nelson Meadows (see map at p. 3 of
application).
Per the Bozeman Ethics Code:
No official or employee shall take or influence official action if the official or employee has a
financial or personal interest in a transaction or matter with the city. 2.03.520.C.
No official or employee shall improperly use, directly or indirectly, the official or employee’s
city position to secure any financial interest or personal interest for said official, employee,
or others. 2.03.490.D.
If the official has a financial interest, when the matter comes before the board the official must (1)
publicly disclose on the record the existence of such financial interest, and (2) “shall not engage in
deliberations concerning the matter or transaction, shall be disqualified from acting on the matter or
transaction and shall not communicate about such matter or transaction with any person who will
participate in an action to be taken on such matter or transaction.” 2.03.520.D.
The PROST Plan considers trails “amenities” of the City. PROST at 7-31. It defines “amenity” as
“Aesthetic or other characteristics of a development that increase its desirability to a community or
its marketability to the public.” PROST at 12-1 (emphasis added).
Discussion
In order for this provision to apply here to Mr. Starner or Mr. Chandler, they must have a financial
interest in the TOP grant decision “which will result in a monetary or other material benefit … which
has a value of more than $15.00.” 2.03.470.A.6. The completion of the trail system along the
frontage road would likely increase the marketability of the subdivision as a desirable place to locate
a business. A completed trail system would improve accessibility to employees and customers of
the businesses who may wish to access the subdivision by foot or by bike.
Because Mr. Starner is actively selling the Nelson Meadows lots (presumably for a commission), and
the trail system would make the development more desirable/marketable, I believe he has a
“financial interest” under the Code and should recuse himself from further decisions on this TOP
application. This conflict of interest has been raised by GVLT members to Addi.
Whether Mr. Chandler has a financial interest is much less apparent. Allied did some work for
Barnard on the Nelson Meadows development application. The only identifiable financial interest
here is the hope of ongoing or future business from Barnard. However, if that were enough to
qualify as a “financial interest” under our Code, he would likely have to recuse himself from all TOP
applications that involve any engineering work. At most, he may want to disclose that Allied did
some work on Nelson Meadows, that Addi consulted with our office and we did not find he has a
conflict of interest. I do not think disclosure is strictly required.
Karen Stambaugh | Assistant City Attorney
City of Bozeman | 121 N. Rouse Ave. | Bozeman, MT 59715 | 406.582.2309
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