HomeMy WebLinkAbout2008 City Attorney Ethics Opinions MEMORANDUM
TO: Chairperson,Bozeman Board of Ethics
C/O Stacy Ulman, Bozeman City Clerk
FROM: Paul J. Luwe,Bozeman City Attorney
DATE: July 29,2008
RE: 2008 City Attorney Ethic Opinions
Bozeman Municipal Code §2.01.160A,requires that when a City Attorney renders an opinion,
the City Attorney submit a written summary of the opinions to the Ethics Board for the Board's
information. Therefore, in accordance with the foregoing Bozeman Municipal Code provisions,
the following City Attorney Ethics Opinions were issued from January 1, 2008 to August 1,
2008:
FORMAL ETHICS OPINION 08-001(issued May 21,2008): Did Commissioner Eric Bryson
have a conflict of interest that precluded him from taking official action on the conditional use
permit submitted by Alcohol and Drug Services of Gallatin County(ADSGC)for the halfway
house to be located at 119 South Church? HELD: Commissioner Bryson did not have a conflict
of interest that precluded him from participating and voting on the conditional use permit
submitted by ADSGC for the halfway house.
FORMAL ETHICS OPINION 08-002 (issued May 26,20M. Did the special invitation from
Ted's Montana Grill for special VIP dinner constitute a prohibitive gift? HELD: The acceptance
of a complimentary dinner provided to the recipient because of his or her position does constitute
a prohibitive gift. If the recipient pays fair market value for the dinner,then there would be no
violation.
FORMAL ETHICS OPINION 08-003 (issued June 9,2008): Did Commissioner Jeff Rupp
have a conflict of interest that precluded him from participating in deliberations concerning
Streamline that was being considered by the City Commission on June 9,2008? And, if he did
have a conflict of interest, could he participate as a citizen of Bozeman rather than as a City
Commissioner? HELD: Commissioner Rupp did have a conflict of interest that precluded him
from participating as a City Commissioner on Streamline. Further held, that he could testify as a
citizen if he disclosed his conflict of interest.
I have enclosed a copy of the formal opinions. If you have any questions,please feel free to give
me a call. I can be contacted at pjljaaQaol.com or by calling 570-8983
cc: (without enclosures)
Chris Kukalski, City Manager
Tim Cooper,Assistant City Attorney
Kaaren Jacobson, Mayor
City Commission
Formal Ethics Opinion 08-003
TO: Commissioner Jeff Rupp
DATE: June 9, 2008
RE: Conflict of Interest-Streamline
QUESTIONS
Do you have a conflict of interest that precludes you from participating in the
deliberations concerning Streamline this Monday's agenda? If you do have a conflict of
interest,can you participate as citizen?
ANSWERS
You do have a conflict of interest that precludes you from participating as a City
Commissioner on Streamline. However, you can testify as a citizen if you disclose your
conflict of interest.
DISCUSSION
On Monday June 9"',the agenda lists a"Special Presentation—State of the Public Transit
Address/Update on the Streamline Bus System (Lisa Ballard, Streamline Coordinator,
and David Kack, Chairman of the GALAVAN/Streamline Advisory Board)." In addition
to this meeting,there will likely be follow-up meetings involving Streamline. However,
this Monday's meeting is only a special presentation and no specific official action is
expected. You are the Chief Executive Officer for Human Resource Development
Council (HRDC)for Southwest Montana located in Bozeman and under the HRDC
allocation plan,the Streamline initiative is charged 10%to pay your salary. You believe
you may have a conflict of interest due to your position as CEO of HRDC. However,you
would like to answer questions in your personal capacity should questions arise about
HRDC and Streamline,and believe you have the right to exercise your rights as a citizen.
The I977 Legislature enacted a set of standards governing the conduct of all public
officials. MCA § 2-2-101 to -132. These statutes "set forth a code of ethics prohibiting
conflict between public duty and private interest as required by the constitution of
Montana.... [and recognize] that some actions are conflicts per se between public duty
and private interest while other actions may or may not pose such conflicts depending
upon the surrounding circumstances."MCA § 2-2-101. Thus, "it is necessary to look at
each particular transaction or relationship in conjunction with the surrounding
circumstances." See 37 Mont. Att'y Gen. Op. 104 (1993)and City Attorney Formal
Opinion 08-001 (2008). The Bozeman Municipal Code (BMC)is generally more
restrictive than state statute.See City Attorney Formal Opinion 08-002 (2008).
You are correct that you have a conflict of interest that precludes you from taking official
action. The conflict is prohibited by MCA §§ 2-2-105,2-2-121(5),and BMC 2.01.040G,
t
and 2.01.070.See also Mont. Att'y Gen. Letter of Advice to Ms. Linda McCulloch,
Superintendent of Public Instruction, dated 28 October 2003. This letter of advice opined
that an OPI office employee's position on board of directors of a non-profit corporation
fall within the definition of private interest and there could be a conflict of interest as OPI
administered grant funds that flowed to the non-profit organization. This letter of advice
relied upon 38 Mont. Gen Att'y Op. 190 (1979) opined that a County Commissioner
breached a fiduciary duty under MCA § 2-2-125(2)(b) by acting officially to award
county contracts to an organization he sat on as a voting member of the board.
The pertinent part of these provisions read:
MCA § 2-2-105. Ethical requirements for public officers and public
employees.
(2) Except as provided in subsection (4), a public officer or public
employee may not acquire an interest in any business or undertakiny, that
the officer or employee has reason to believe maybe directly and
substantially affected to its economic benefit by official action to be taken
by the officer's or employee's agency.
(4) When a public employee who is a member of a quasi-judicial
board or commission or of a board, commission, or committee with
rulemaking authority is required to take official action on a matter as to
which the public employee has a conflict created by a personal or private
interest that would directly give rise to an appearance of impropriety as to
the public employec's influence, benefit, or detriment in regard to the
matter, the public employee shall disclose the interest creating the conflict
prior to participating in the official action.
MCA § 2-2-121. Rules of conduct for public officers and public
employees.
(5) A public officer or public employee may not participate in a
proceeding when an organization. other than an organization or
association of local government officials, of which the public officer or
public employee is an officer or director is:
(a) involved in a proceeding before the employing agency that is within
the scope of the public officer's or public employee's job duties; or
(b) attempting to influence a local, state, or federal proceeding in which
the public officer or public employee represents the state or local
government.
Official action under MCA§2-2-105 is defined as"vote,decision,recommendation,approval.
disapproval,or other action,including inaction,that involves the use of discretionary authority.
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BMC § 2.01.040 Standards of Conduct
G. No official shall act in a private capacity on matters acted upon as an
official.
SYIC § 2.01.070 Conflict of Interest
A. No official or employee shall engage in any employment or
business which conflicts with the proper discharge of his official
duties.
B. No official or employee shall have a financial or personal interest,
tangibly or intangibly, in any transaction with the City as to which
he has the power to take or influence official action unless full
public disclosure is made. If an official or employee has any
tangible or intangible financial or personal interest in the outcome
of any matter coming before the agency of which he is a member
or by which he is employed, such official or employee shall
publicly disclose on the record of the agency, or to his superior or
other appropriate authority, the existence of such financial or
personal interest. An official or employee having such a financial
or personal interest shall not engage in deliberations concerning
the matter, shall disqualify himself from acting on the matter. and
shall not communicate about such matter with any person who will
participate in the action to be taken on such matter.
C. No employee, whether paid or unpaid, shall represent or appear on
behalf of any individual or entity before any agency of the city, or
take any appellate proceedings from any action of such agency,
either personally or through an associate or partner.
D. No official, whether paid or unpaid, shall represent or appear on
behalf of any individual or entity in any action or proceeding of
concern to the agency on which that official serves. either before
that agency or any other agency of the city, or before the Citv
Commission, or take any appellate proceedings from any action of
such agency or the Commission. Such representation may be
made by an 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 matter represented by an associate or partner. shall
disqualify himself from acting on the matter, and shall not
communicate about such matter with any person who will
participate in the action to be taken on such matter.
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E. Nothing in this section shall be interpreted or construed to prohibit
any official or employee from exercising his legal rights as to his
own personal interests in a matter pending before the City or iany
of its agencies, or to prohibit an official or employee from
testifying as a witness in any administrative or judicial proceeding
However, no official or employee who represents his own personal
interest before an agency of which he is a member, or a member of
an agency to which the matter may be appealed, shall participate in
the decision of that agency or the appellate agency.
Emphasis added.
State Statute allows participation if the proper disclosure is made. MCA § 2-2-131. See
also 40 Mont.Att'y Gen Op. 28 (1983) MCA § 2-2-13 1 reads:
MCA § 2-2-131. Disclosure. A public officer or public employee shall,
prior to acting in amanner that may impinge on public duty. including the
award of a permit, contract, or license. disclose the nature of the private
interest that creates the conflict. The public officer or public employee
shall make the disclosure in writing to the commissioner of political
practices, listing the amount of private interest. if any, the purpose and
duration of the person's services rendered, if any, and the compensation
received for the services or other information that is necessary to describe
the interest. If the public officer or public employee then performs the
official act involved. the officer or employee shall state for the record the
fact and summary nature of the interest disclosed at the time of performing
the act.
Emphasis added. However, the Bozeman Municipal Code is more restrictive than the
state statute where unlike state statute disclosure is required but participation is
prohibited. MCA § 2.01.070B & G.These two subsections provide that the official
"shall not engage in deliberations concerning the matter, shall disqualify himself from
acting on the matter, and shall not communicate about such matter with any person who
will participate in the action to be taken on such matter. " MCA § 2.01.070E attempts to
balance this prohibition with limited rights of testifying before the Commission. This
subsection provides that"[N]othing in this section shall be interpreted or construed to
prohibit any official or employee from exercising his legal rights as to his own personal
interests2 in a matter pending before the City or any of its agencies,or to prohibit an
' BMC §2.01.020 makes a distinction between financial interest and personal interest. In this
situation,you have a financial interest. The pertinent definitions read: "E."Financial interest"means
any ownership interest,contractual relationship,business relationship,or other interest which will
result in a monetary or other material benefit to an official or employee,either tangibly or intangibly,
which has a value of more than fifteen dollars,other than his or her duly authorized salary or
compensation for his services to the city,and which interest is not common to the interest of all other
citizens of the city. The following financial interest shall be imputed to be those of an official or an
employee of the city:that of a spouse or child of an official or employee;that of any prime
contractor or subcontractor of the city, in which the official or employee or any member of his or her
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official or employee from testifying as a witness in any administrative or judicial
proceeding. However, no official or employee who represents his own personal interest
... shall participate in the decision of that agency or the appellate agency."
You have indicated that you are not going to participate in the discussion or in any
deliberations at the Commission table. You are also plaiming to remove yourself from
the Commission table and sit in the audience. hi addition, I recommend you disclose
your conflict prior to sitting in the audience and limit yourself to testifying before the
Commission as a citizen. Although not required,I recommend that you not testify unless
the Commission has a particular question of you to avoid the appearance you are
participating in the discussion from the floor rather than the Commission table.
Pursuant to BMC y 2.01.160C,you may rely upon this formal opinion and if you act in
good faith in accordance with the provisions and findings of this opinion you will not be
subject to prosecution under the Bozeman Municipal Code. However, I am unable to
provide you immunity from prosecution under state law.
I hope you found this helpful. If you have any questions about this matter,please contact
me.
RWiulwe
btnittteedp
Bozeman City Attorney
immediate family has any direct or indirect interest as the proprietor,by ownership of stock or
partnership interest.
H."Personal interest"means any interest in the matter which would affect the action of the official or
employee other than a financial interest,and other than an interest because of membership in,or affiliation
with,but not employment by a social,fraternal,charitable,service,educational,religious,governmental,
health service,philanthropic,cultural,or similar nonprofit institution or organization. (emphasis added).
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Formal Ethics Opinion 08-002
TO: Chris Kukulski, City Manager
DATE: May 26, 2008
RE: Ted's Montana Grill Initiation
QUESTION
Does the special invitation from Ted's Montana Grill for the special VIP dinner constitute a
prohibited gift?
ANSWER
The acceptance of a complimentary dinner provided to the recipient because of his or her official
position does constitute a prohibited gift. If the recipient pays full market value for the dinner,
then there would be no violation.
DISCUSSION
You requested my opinion on whether the special invitation for complimentary dinner sent to
several City employees and City officials constitute a prohibited gift under either state statute or
the Bozeman Municipal Code. Ted's Montana Grill sent out invitations to several City
employees and City officials to attend dinner at its establishment. The invitation has the
invitee's name on the top of the invitation. Ted Turner and George McKerrow, Jr. invite the
person to join them for their"special VIP dinner"to celebrate their first restaurant in Montana.
The stated purpose of the dinner is to allow for a sneak preview and complimentary dinner for
two at the new restaurant opening in Bozeman, and to assist the Grill in training prior to the
opening to the public. The Grill is donating beverage proceeds to the Greater Yellowstone
Coalition, the Sunrise Rotary Club, and the Bozeman Noon Rotary Club. The dinner is scheduled
for Thursday evening May 29t" from 5:30 to 8:30 P.M. I made a call to Chris Cornelius of Ted's
Montana Grill to inquiry how the invitee list was determined. He informed me that the list
consisted of influential members of the Community to include public officials.
The 1977 Legislature enacted a set of standards governing the conduct of all public officials.
MCA § 2-2-101 to -132. These statutes "set forth a code of ethics prohibiting conflict between
public duty and private interest as required by the constitution of Montana.... [and recognize]
that some actions are conflicts per se between public duty and private interest while other actions
may or may not pose such conflicts depending upon the surrounding circumstances."MCA § 2-
2-101. Thus, "it is necessary to look at each particular transaction or relationship in conjunction
with the surrounding circumstances." See 37 Mont. Att'y Gen. Op. 104 (1993) and City
Attorney Formal Opinion 08-001 (2008).
MCA § 2-2-104(1) enumerates certain actions which constitute a breach of fiduciary duty if
performed by a public officer. This section provides in its pertinent part:
1
2-2-104. Rules of conduct for public officers, legislators, and public
employees. (1) Proof of commission of any act enumerated in this section is
proof that the actor has breached the actor's public duty. A public officer,
legislator, or public employee may not:
(b) accept a gift of substantial value or a substantial economic benefit
tantamount to a gift:
(i) that would tend improperly to influence a reasonable person in the
person's position to depart from the faithful and impartial discharge of the
person's public duties; or
(ii) that the person knows or that a reasonable person in that position should
know under the circumstances is primarily for the purpose of rewarding the
person for official action taken.
Two requirements must be met before there is a violation of this statute: 1, acceptance of a gift of
substantial value or substantial economic benefit;and 2. the gift would tend to improperly
influence departure from faithful and impartial discharge of public duty; or the gift was given as
a reward for official action taken. The second requirement employs the "reasonable person'
standard. If there is no gift, then there is no need to consider the second requirement.
The term of'-gift"was not defined until 1995 when the legislature defined "gift of substantial
value". MCA § 2-2-102(3)reads:
(a) "Gift of substantial value"means a gift with a value of$50 or more for an
individual.
(b) The term does not include:
(i) a gift that is not used and that, within 30 days after receipt, is returned to
the donor or delivered to a charitable organization or the state and that is not
claimed as a charitable contribution for federal income tax purposes;
(ii) food and beverages consumed on the occasion when participation in a
charitable, civic, or community event bears a relationship to the public officer's
or public employee's office or employment or when the officer or employee is
in attendance in an official capacity;
(iii) educational material directly related to official governmental duties;
(iv) an award publicly presented in recognition of public service; or
(v) educational activity that:
(A) does not place or appear to place the recipient under obligation;
(B) clearly serves the public good; and
(C) is not lavish or extravagant.
The gift must be of a"$50 value or more for an individual." The invitation limits two guests per
invitation. The invitation may be a gift under this statute depending on the value of the dinners.
However,there is no need to determine value in this situation as the free dinner in the invitation
constitutes a prohibited gift under the Bozeman Municipal Code.
2
BMC § 2.01.090 states "No official or employee shall accept a gift, gratuity, or favor from any
person or entity, except as authorized by law.""Authorized by law" requires specific
authorization by statute, constitution, or ordinance. See Bozeman Daily Chronicle v. City of
Bozeman Police Department, 859 P.2d 435 (Mont. 1993) and Allstate Ins. Co. v. City of
Billings, 780 P.2d 186 (Mont. 1989). MCA § 2-2-104(1) is not a specific authorization. MCA §
2-2-104(1)prohibits receiving gifts of substantial value, but it does not specifically authorize the
receipt of gifts. Any implication of authorization created by the prohibition is contrary to the
intent of BMC § 2.01.090.
BMC. § 2.01.090 was adopted by Ordinance 1240 in 1987. The minutes indicate that the
ordinance was to be more restrictive than state law. The Commission struck the language
"which has a value of more than$15" from the definition of"financial interest when it adopted
ordinance 1240. See 7 July 1987 Bozeman City Commission Minutes. In discussing possible
revision to this ordinance two years later, the Commission"concurred that the code of ethics as
set forth in the State statute is not adequate, noting a more restrictive code is desirable."See 25
September 1989 Bozeman City Commission Minutes. I previously opined that the receipt of
gifts of nominal value from a foreign dignitary was prohibited by this ordinance.See City
Attorney Opinion dated 21 June 1993,to Commissioner Vincent, subject: Receipt of Gifts. The
City Commission did not change this code provision after my opinion. The most recent
opportunity to amend this section of the ordinance came after the adoption of the charter, when
the Commission amended the ethics ordinance but did not amend the gift section. I must
conclude that the intent of BMC. § 2.01.090 is to prohibit gifts offered because of a recipient's
official position, regardless of the value of the gift.
In conclusion, it is my opinion the acceptance of a free dinner offered by Ted's Montana Grill
constitutes a prohibited gift under the Bozeman Ordinance. It is the free dinner that constitutes
the gift. If the recipient pays full market value for the dinner,then there would be no violation of
this provision.
Pursuant to BMC § 2.01.160C, an employee or official may rely upon this formal opinion and if
the employee or official acts in good faith in accordance with the provisions and findings of this
opinion then the employee or official will not be subject to prosecution under the Bozeman
Municipal Code. However, I am unable to provide the employee or official immunity-from
prosecution under state law,
I hope you found this helpful. If you have any questions about this matter, please contact me.
Respe ully Submitted
Paul . Luwe
Bozeman City Attorney
' Although the minutes refer to the definition of"financial interest"rather than to gifts,the deletion of value evinces
an intent to not employ the use of dollar values.
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Formal Ethics Opinion 08-001
TO: Commissioner Eric Bryson
DATE: May 21, 2008
RE: CUP for 119 S. Church Submitted by ADSGC
QUESTION
Do you have a conflict of interest that precludes you from taking official action on the
Conditional Use Permit submitted by Alcohol & Drug Services of Gallatin County
(ADSGC) for the halfway house to be located at 119 South Church?
ANSWER
You do not have a conflict of interest that precludes you from participating and voting on
the Conditional Use Permit referenced above.
DISCUSSION
You requested my opinion on whether you have a conflict of interest that precludes you
from participating and voting on the Conditional Use Permit submitted by Alcohol &
Drug Services of Gallatin County(ADSGC)for the halfway house to be located at 119
South Church. This opinion is prompted by your position as Director of Court Services
for Gallatin County. Conflict of interest issues are factual determinations and are
depended upon the particular facts of each situation.
Alcohol & Drug Services of Gallatin County (ADSGC) is a private non-profit
corporation and is licensed by the Montana Department of Public Health and Human
Services. Addictive and Mental Disorders Division. The 2007 Legislature provided
funding for the treatment of Chemical Dependency to the Department of Health and
Human Services (DHHS). DHHS issued requests for proposals for an eight site multi-
level residential treatment system to be operated across the state of Montana. Boyd
Andrew Community Services was awarded the contract. One of the eight sites is being
proposed at 119 South Church and will be operated by ADSGC. The site at Bozernan
will be a halfway house for up to eight male individuals. ADSGC has submitted an
application to the City for a conditional use permit for this residential facility.
Gallatin Court Services provides pre-trial,post-conviction, and specialty court services to
all levels of the court system in Gallatin County. You indicated that Court Services
cannot place an individual in this facility, although there may be participants involved in
your programs that reside there. You have no administrative responsibilities for the
funding or operation of the proposed residential facility. Moreover, you have not been
involved in the creation of this program. You are not an officer or board member of
ADSGC. As far as you know, there is no connection between the funding of your
program and contributions to ADSGC.
1
Specific conflicts of interests are addressed by examining the State Code of Conduct,
Title 2, Chapter 2,Part 1. These statutes"set forth a code of ethics prohibiting conflict
between public duty and private interest as required by the constitution of Montana."
MCA, §2-2-101. MCA § 2-2-I03 sets forth a public official's responsibility to act in the
public trust and for the benefit of the people of the state. MCA § 2-2-1041 covers
prohibitions and limitations on use of confidential information,acceptance of gifts and
benefits tantamount to a gift, and dual public employment. Your question does not
pertain to these prohibitions.
MCA § 2-2-1052 set forth ethical rules of conduct pertaining to acquiring a business or
undertaking that would be economically benefited by an official action or that would
cause economic detriment of a competing business or undertaking. You have no
involvement in a contract or business,and you have no personal interest in ADSGC nor
do you serve in any capacity within this nonprofit organization. The Attorney General
has opined that there is a conflict of interest where an individual has responsibility for
administering the disbursement of funds while also serving as a member of the receiving
organization of these Rinds. See 38 Mont. Att'y. Gen. Op. 55 (1979) and Letter of
Advice,28 October 2003,to Linda McCulloch. Although Gallatin County may provide
funding to ADSGC, you neither administer the disbursement of any funds nor serve on
any ADSGC's boards.
MCA§2-2-121' delineate acts that are breaches of public duty. Your situation does not
involve any of the delineated acts. I find no violation of the relevant statutory guidelines
found in Title 2,chapter 2,part 1,MCA,pertaining to the state standards of conduct.
Likewise,I found no violations of MCA§ 7-5-4109(1)4
Bozeman Municipal Code also provides for similar prohibitions as are found in state law,
but often are more restrictive than state law.5 However,under the facts presented I do not
find any violation of the relevant Bozeman Municipal Code provisions.
In conclusion,it is my opinion that you do not have a conflict of interest that precludes
you from participating and voting on the Conditional Use Permit for the halfway house to
be located at 119 South Church. Pursuant to BMC § 2.01.160C,you may rely upon this
formal opinion and if you act in good faith in accordance with the provisions and findings
of this opinion you will not be subject to prosecution under the Bozeman Municipal
Code. However, I am unable to provide you immunity from prosecution under state law.
I hope you found this helpful. If you have any questions about this matter,please contact
me.
Wubmitted
e
Bozeman City Attorney
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t 2-2-104. Rules of conduct for public officers,legislators,and public employees.(1)Proof of
commission of any act enumerated in this section is proof that the actor has breached the actor's public
duty.A public officer,legislator,or public employee may not:
(a) disclose or use confidential information acquired in the course of official duties in order to
further substantially the individual's personal economic interests;or
(b) accept a gift of substantial value or a substantial economic benefit tantamount to a gift:
(i) that would tend improperly to influence a reasonable person in the person's position to depart
from the faithful and impartial discharge of the person's public duties;or
(ii) that the person knows or that a reasonable person in that position should know under the
circumstances is primarily for the purpose of rewarding the person for official action taken.
(2) An economic benefit tantamount to a gift includes without limitation a loan at a rate of interest
substantially lower than the commercial rate then currently prevalent for similar loans and compensation
received for private services rendered at a rate substantially exceeding the fair market value of the services.
Campaign contributions reported as required by statute are not gifts or economic benefits tantamount to
gifts.
(3)(a) Except as provided in subsection(3)(b),a public officer,legislator,or public employee
may not receive salaries from two separate public employment positions that overlap for the hours being
compensated,unless:
(i) the public officer,legislator,or public employee reimburses the public entity from which the
employee is absent for the salary paid for performing the function from which the officer,legislator,or
employee is absent;or
(ii) the public officer's,legislator's,or public employee's salary from one employer is reduced by
the amount of salary received from the other public employer in order to avoid duplicate compensation for
the overlapping hours.
(b) Subsection(3)(a)does not prohibit:
(i) a public officer,legislator,or public employee fi•om receiving income from the use of accrued
leave or compensatory time during the period of overlapping employment;or
(ii) a public school teacher from receiving payment from a college or university for the
supervision of student teachers who are enrolled in a teacher education program at the college or university
if the supervision is performed concurrently with the school teacher's duties for a public school district.
(c) In order to determine compliance with this subsection(3),a public officer, legislator,or public
employee subject to this subsection(3)shall disclose the amounts received from the two separate public
employment positions to the commissioner of political practices.
2-2-105. Ethical requirements for public officers and public employees.(1)The requirements in this
section are intended as rules of conduct,and violations constitute a breach of the public trust and public
duty of office or employment in state or local government.
(2) Except as provided in subsection(4),a public officer or public employee may not acquire an
interest in any business or undertaking that the officer or employee has reason to believe may be directly
and substantially affected to its economic benefit by official action to be taken by the officer's or
employee's agency.
(3) A public officer or public employee may not,within 12 months following the voluntary
termination of office or employment,obtain employment in which the officer or employee will take direct
advantage,unavailable to others,of matters with which the officer or employee was directly involved
during a term of office or during employment.These matters are rules,other than rules of general
application,that the officer or employee actively helped to formulate and applications,claims,or contested
cases in the consideration of which the officer or employee was an active participant.
(4) When a public employee who is a member of a quasi-judicial board or commission or of a
board,commission,or committee with rulemaking authority is required to take official action on a matter
as to which the public employee has a conflict created by a personal or private interest that would directly
give rise to an appearance of impropriety as to the public employee's influence,benefit,or detriment in
regard to the matter,the public employee shall disclose the interest creating the conflict prior to
participating in the official action.
(5) A public officer or public employee may not perform an official act directly and substantially
affecting a business or other undertaking to its economic detriment when the officer or employee has a
substantial personal interest in a competing firm or undertaking.
3
3 2-2-121. Rules of conduct for public officers and public employees.(1)Proof of commission of any
act enumerated in subsection(2)is proof that the actor has breached a public duty.
(2) A public officer or a public employee may not:
(a) subject to subsection(7),use public time, facilities,equipment,supplies,personnel,or funds
for the officer's or employee's private business purposes;
(b) engage in a substantial financial transaction for the officer's or employee's private business
proposes with a person whom the officer or employee inspects or supervises in the course of official duties;
(c) assist any person for a fee or other compensation in obtaining a contract,claim, license,or
other economic benefit from the officer's or employee's agency;
(d) assist any person for a contingent fee in obtaining a contract,claim,license,or other economic
benefit from any agency;
(e) perform an official act directly and substantially affecting to its economic benefit a business or
other undertaking in which the officer or employee either has a substantial financial interest or is engaged
as counsel,consultant,representative,or agent;or
(f) solicit or accept employment,or engage in negotiations or meetings to consider employment,
with a person whom the officer or employee regulates in the course of official duties without first giving
written notification to the officer's or employee's supervisor and department director.
(3)(a) Except as provided in subsection(3)(b),a public officer or public employee may not use
public time,Facilities,equipment,supplies,personnel,or funds to solicit support for or opposition to any
political committee,the nomination or election of any person to public office,or the passage of a ballot
issue unless the use is:
(i) authorized by law;or
(ii) properly incidental to another activity required or authorized by law,such as the function of
an elected public officer,the officer's staff,or the legislative staff in the normal course of duties.
(b) As used in this subsection(3),"properly incidental to another activity required or authorized
by law"does not include any activities related to solicitation of support for or opposition to the nomination
or election of a person to public office or political committees organized to support or oppose a candidate
or candidates for public office. With respect to ballot issues,properly incidental activities are restricted to:
(i) the activities of a public officer,the public officer's staff,or legislative staff related to
determining the impact of passage or failure of a ballot issue on state or local government operations;
(ii) in the case of a school district,as defined in Title 20,chapter 6,compliance with the
requirements of law governing public meetings of the local board of trustees,including the resulting
dissemination of information by a board of trustees or a school superintendent or a designated employee in
a district with no superintendent in support of or opposition to a bond issue or levy submitted to the
electors.Public funds may not be expended for any form of commercial advertising in support of or
opposition to a bond issue or levy submitted to the electors.
(c) This subsection(3)is not intended to restrict the right of a public officer or public employee to
express personal political views.
(4) A candidate,as defined in 13-1-101(6)(a),may not use or permit the use of state funds for any
advertisement or public service announcement in a newspaper,on radio,or on television that contains the
candidate's name,picture,or voice except in the case of a state or national emergency and then only if the
announcement is reasonably necessary to the candidate's official functions.
(5) A public officer or public employee may not participate in a proceeding when an organization,
other than an organization or association of local government officials,of which the public officer or public
employee is an officer or director is:
(a) involved in a proceeding before the employing agency that is within the scope of the public
officer's or public employee's job duties;or
(b) attempting to influence a local,state,or federal proceeding in which the public officer or
public employee represents the state or local government.
(6) A public officer or public employee may not engage in any activity,including lobbying,as
defined in 5-7-102,on behalf of an organization,other than an organization or association of local
government officials,of which the public officer or public employee is a member while performing the
public officer's or public employee's job duties.The provisions of this subsection do not prohibit a public
officer or public employee from performing charitable fundraising activities if approved by the public
officer's or public employee's supervisor or authorized by law.
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(7) A listing by a public officer or a public employee in the electronic directory provided for in
30-17-101 of any product created outside of work in a public agency is not in violation of subsection(2)(a)
of this section. The public officer or public employee may not make arrangements for the listing in the
electronic directory during work hours.
(8) A department head or a member of a quasi-judicial or rulemaking board may perform an
official act notwithstanding the provisions of subsection(2)(e) if participation is necessary to the
administration of a statute and if the person complies with the disclosure procedures under 2-2-131.
(9) Subsection(2)(d)does not apply to a member of a board,commission,council,or committee
unless the member is also a full-time public employee.
(10) Subsections(2)(b)and(2)(e)do not prevent a member of the governing body of local
government from performing an official act when the member's participation is necessary to obtain a
quorum or to otherwise enable the body to act.The member shall disclose the interest creating the
appearance of impropriety prior to performing the official act.
"7-5-4109. Control of conflict of interest.(1)The mayor, any member of the council,any city or town
officer,or any relative or employee of an enumerated officer may not be directly or indirectly interested in
the profits of any contract entered into by the council while the officer is or was in office.
s 2.01.040 Standards of Conduct
A. Officials and employees have an obligation to act morally and honestly in discharging their
responsibilities.
B. Officials and employees shall conduct themselves with propriety, discharge their duties
impartially and fairly, and make continuing efforts toward attaining and maintaining high
standards of conduct.
C. Each official or employee serving on a multimember agency is expected to devote the time
and effort necessary to the successful functioning of such agency.
D. No official or employee shall improperly use, directly or indirectly, his city position to
secure any financial interest or personal interest for himself or others.
E. No official or employee shall, for any reason, use or attempt to use his position to
improperly influence any other official or employee in the performance of his official
duties.
2.01.070 Conflict of Interest
A. No official or employee shall engage in any employment or business which conflicts with
the proper discharge of his official duties,
B. No official or employee shall have a financial or personal interest,tangibly or intangibly, in
any transaction with the City as to which he has the power to take or influence official
action unless full public disclosure is made. If an official or employee has any tangible or
intangible financial or personal interest in the outcome of any matter coming before the
agency of which he is a member or by which he is employed, such official or employee
shall publicly disclose on the record of the agency, or to his superior or other appropriate
authority, the existence of such financial or personal interest. An official or employee
having such a financial or personal interest shall not engage in deliberations concerning the
matter,shall disqualify himself fi•om acting on the matter,and shall not communicate about
such matter with any person who will participate in the action to be taken on such matter.
C. No employee,whether paid or unpaid,shall represent or appear on behalf of any individual
or entity before any agency of the city, or take any appellate proceedings fi-om any action
of such agency, either personally or through an associate or partner.
D. No official,whether paid or unpaid, shall represent or appear on behalf of any individual or
entity in any action or proceeding 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 an 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 matter represented by an associate or partner, shall disqualify
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himself from acting on the matter, and shall not communicate about such matter with any
person who will participate in the action to be taken on such matter.
E. Nothing in this section shall be interpreted or construed to prohibit any official or employee
from exercising his legal rights as to his own personal interests in a matter pending before
the City or any of its agencies, or to prohibit an official or employee from testifying as a
witness in any administrative or judicial proceeding. However, no official or employee
who represents his own personal interest before an agency of which he is a member, or a
member of an agency to which the matter may be appealed,shall participate in the decision
of that agency or the appellate agency.
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