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Safra Working Papers

Dealing with Wheeling

"Wheeling" is a term I just discovered. The context is that NJ governor Chris Christie made a campaign promise to deal with "wheeling," and then failed to, according to a South Jersey Times editorial yesterday. Here's how the editorial describes the practice (many NJ local governments prohibit or limit contributions from their contractors):
It goes like this: Smith County has a fat consulting contract with Joe Blow Associates.

Dealings with Banks

According to a Washington Post article this weekend, U.S. Senators Conrad and Dodd were cleared by the Senate Select Committee on Ethics with respect to the senators' membership in Countrywide Financial's VIP mortgage program. The committee concluded that the senators were given special treatment, but that others were given similarly special treatment and that the senators did not benefit financially.

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Deception About Ethics Commission Approval and Another Problem with Ethics Self-Regulation

This week saw the opening of the trial of former New York state senate majority leader Joseph Bruno for honest services fraud. According to the assistant U.S. attorney presenting the case, as quoted in the Albany Times-Union, although a criminal trial, "this case is about conflicts of interest. It's about failure to disclose conflicts of interest, and it's about concealment of information that might have exposed conflicts of interest."

Decisions Regarding Lobbyists Sitting on Advisory Boards

I believe that the best solution to the problem of having lobbyists and others seeking special benefits from the government sitting on government advisory boards is to get rid of these advisory boards. Conflicts involving these boards are important because, although they are "merely advisory," their recommendations are often accepted, and their members are often selected (or seen to be selected) in order to reach a particular conclusion.

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Declaration of Policy, Purpose, and Obligations

This is the place to comment on, discuss, and share alternative content and language relating to the declarations of policy that can usually be found at the beginnning of municipal ethics codes. Most declarations are very short and often ignored, since they cannot be enforced. But they are important in showing the community why ethical conduct is more important than just being good and fair.

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Decriminalizing Ethics Codes

I'd like to follow up on what I said at the end of yesterday's blog entry, about jurisdictions that make ethics violations criminal and require a showing of guilt beyond a reasonable doubt and a showing of intentionality or recklessness or negligence. Here is the penalty provision in the Arizona Conduct of Office chapter, which applies equally to local governments (to see the entire chapter, click here and scroll down to Chapter 3):

Defending Officials: Misuse of Office and Who the Client Is

Misuse of government resources, nepotism, transparency, and the obligations of government attorneys are all issues in litigation over a village's secret use of a contaminated well for 20% of the village's water supply, according to an article in Sunday's Chicago Tribune.

Here a few questions that arise from this matter:

Defenses Against Charges of Bribery

U.S. Sen. Robert Menendez is to be indicted this week for bribery and failure to report gifts. Where there is an effective government ethics program, he would be easily found to have committed administrative government ethics violations. In a criminal case, the official has the edge (and he has already formed a legal defense fund, to obtain legal but inappropriate contributions from those seeking favors from him).

Definitions

Following Mark Davies, I have placed definitions not at the front of the Code, where they usually appear, but at the end of the Ethics Provisions section. The reasoning behind this choice is that definitions should not be as important as they often are. Often, definitions include significant content, so that officials and employees must read the definitions before they can know what they are required to do. It is better to have officials focus on the plain meaning of ethics provisions, knowing that no extra duties will be imposed in the definitions, that there are no traps hidden there.

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DeKalb County (GA) Grand Jury Report on Procurement-Related Misconduct

It all started with the indictment, on charges of bribery and theft, of a Fats, Oil & Grease inspector back in November 2010. It led to an 83-page grand jury report in August 2013, which set out the misconduct involving the DeKalb County (GA) Department of Watershed Management (DWM) procurement process, and made recommendations not only for indictments, but also for an improved ethics program.

Determining Whether Something Paid For Has Been Discounted and Is Therefore a Gift

My last blog post raised an interesting question. When an annual financial disclosure form (or, in some jurisdictions a special declaration of gifts received) requires the disclosure of all gifts from restricted sources, what are the expectations of an official who pays rent to a restricted source? How is the official expected to determine whether he has received a gift or not?

Detroit and the Loyalties of Local Government Attorneys

Loyalty is a virtue that is out of place in government, because loyalty is a personal virtue, a virtue that involves one's own personal interest and that of the person one is loyal to.

Loyalty is a particularly difficult issue for local government attorneys, because loyalty is essentially the principal virtue for attorneys. Attorneys' conflicts of interest involve interests that get in the way of complete loyalty to a client.

Detroit's Mayor Kilpatrick Piles His Unethical Behavior Skyscraper High

Detroit’s mayor Kwame M. Kilpatrick is the new poster boy for misuse of office, lack of transparency, and covering up unethical behavior. According to an article in the Detroit Free Press, it all began with an extramarital affair with his chief of staff, which he denied time and again (including on the witness stand), but finally admits to after the evidence is out.

Differing Views on Corruption and Campaign Finance

I keep thinking about the recent line of U.S. Supreme Court campaign finance cases that limit corruption to "quid pro quo" situations. A few months ago, I wrote a blog post explaining that the Court's picture of campaign finance as about political beliefs is not how things work at the local level, where politics is more about power and spoils than about beliefs. But the "quid pro quo" view of corruption is problematic in other ways.

Disappointing Report from Ethics Task Force in Phoenix

Phoenix has followed Chicago in taking a task force approach to ethics reform. As in Chicago, the mayor selected the task force. The Ethics Task Force, which according to an article in the Arizona Republic, consists of "prominent attorneys and judges," filed a report with the council on March 6. I have been unable to locate a copy of the report, but I did find a 5-page executive summary of the supposedly 20-page report (attached; see below).

Disclosure by Lawyer-Legislators

Two days ago, I wrote about a Louisiana lawyer-legislator who is arguing that disclosure rules should not apply to lawyers, because the practice of law is regulated by the state supreme court. The story behind an indictment in New Jersey this week makes a strong argument for applying disclosure rules to lawyers, as they are in California and North Carolina, only better.