HomeMy WebLinkAbout1988 Board of Ethics Meeting Minutes - January-June BOARD OF ETHICS
MONDAY - JANUARY 25 , 1988
The Board of Ethics met in regular session on Monday, January 25 , 1988
at 2 : 00 P.M. in the City Council Chambers - 10th floor - City Hall .
Present: John Mertz , Donald Cook, Stephen Lowney, City Attorney, Al Knot,
Rita M. Bauman - City Clerk
Absent; None
The meeting was called to order by John Mertz at 2 : 15 P.M.
The minutes of the Meeting of June 23 , 1987 were recommended for approval
by John Mertz Seconded by Donald Cook - Carried - minutes were approved.
Old Business - None .
New Business - Election of Officers for the Year 1988 .
Motion by Donald Cook that John Mertz be nominated as Chairman for the
year 1988 - Motion seconded by Al Knot - There being no other nomination
for Chairman the motion carried.
Motion by Pita M. Bauman that Donald Cook be nominated for Vice-Chairman
for the year 1988 - motion seconded by John Mertz - there being no other
nomination for Vice-Chairman - Motion Carried.
Reports of Officers - City Attorney Al Knot presented a letter (attached)
from Harold Leeman Jr. to the Board asking that the Board review the
post election primary statement for the Lindeman for City Council
Campaign Committee relative mis-use of funds and ask for an opinion on
this matter - discussion was held and a motion made by John Mertz that
Board Member Stephen Lowney look into this matter and report back to
the Board at the next meeting.
There being no further reports or business a motion was made by John
Mertz that the next Board of Ethics meeting be held on Monday,February
22 , 1988 at 2 : 00 P.M. - Motion seconded by Don Cook - Motion Carried.
Motion by John Mertz that the meeting stand adjourned = Motion seconded
by Stephen Lowney - Motion Carried.
Meeting adjourned at 2 : 40 P .M.
Respectfully submitted:
122. �
Rita M. Bauman
Secretary
October 8, 41�19 9-7
, Y ;.,.ERK
P - ( 3E ?H 7
Council President Tony Benavides
and City Councilmembers
10th Floor, City Hall
Lansing, MI 48933
Dear President Benavides and Councilmembers:
I request that you ask the Board of Ethics to review the post-election primary statement
of the Lindemann For City Council Campaign Committee. After review of this statement
(located at the County Clerk's Office in Mason) I would hope the Board of Ethics would
render an opinion announcing that it was wrong for the councilman from the First Ward to
have made a loan from a taxpayer supported account which is called in government
circles the "Office Holder Expense Account." The loan of $154.00 from a taxpayer
supported account to one's campaign is truly disappointing to all citizens of Lansing and
especially those from the First Ward.
In closing I would hope that the Board of Ethics would crack down hard on the misuse of
taxpayers dollars by elected officials.
Sincerely,
Harold J. Leeman Jr.
529 N. Francis
Lansing, MI 48912
REFERRED TO THE .
CITY ATTORNEY
BOARD OF ETHICS
MONDAY - FEBRUARY 22 , 1988
The Boand ob Ethica met in regutan zezzion on Monday, Febnuany 22 ,
1988 at 2 : 00 P. M . in the City Councit Consenence Room - 70.th 6toor
City Hatt .
PRESENT: Donatd Cook, Stephen Lowney, John Mentz , Metvin McWtttiamz -
Ch.Le� A-6zistant City Attorney, Rita M. Bauman - City Cterfz
ABSENT: None
The meeting waz caned to onden by the ChaiAman-John Mentz at 2 : 10 P. M.
Motion by Donatd Cook that the m.Lnutez ob the meeting of January 25 ,
1988 be approved - zeconded by John Mentz .
OLD BUSINESS - Stephen Lowney pazzed a memorandum to each BovLd Members
in neaand to hi,5 netvew o� the regeurt o6 Hanotd Leeman
Jn. on the port election pnimany statement o� the Lindemann
bon Council campaign Committee neganding a .Loan of $ 154 . 00
6nom the "obb.Lce hotden expense account" .
Much dtscus.6ion was held on thi.6 matters pertaining to the
wondi ng in the City Chanter, ordinance, and State Law
coven.Lng this area.
John Mentz made a motion that the Boand of Ethics does
not have jun.Lsdiction oven this matter and that Stephen
Lowney draw up an opinion which wilt be Jonwanded on to
the other members o6 the Boand bon reivew and signing .
The signed opinion wilt then . be �mwanded on to Harotd
Leeman Jn.
NEW BUSINESS : Don Cook rifted ij there were any other otd tettens around
The Ctenfz neptyed that there were none that she was aware
0� .
Motion by Don Cook that thin meeting stand adjourned-seconded by Stephen
Lowney.
Motion by John Mertz that the next Board of Ethicz meeting be held on
Monday, June 6 , 1988 - Seconded by Rita M. Bauman.
Meeting adjounned at 2 : 35 P. M .
Respect6utty submitted:
Rita M . Bauman
Secnetany
MEMORANDUM
TO: MEMBERS OF LANSING BOARD OF ETHICS
FROM: STEPHEN J . LOWNEY
RE : OCTOBER 8 , 1987 LETTER FROM HAROLD J. LEEMAN, JR .
DATE : FEBRUARY 22, 1988
-------------------------------------------------------------------
In a letter dated October 8, 1987, Harold J. Leeman,
Jr . , asked the Lansing Board of Ethics to review the
post-election primary statement of the Lindeman For City Council
Campaign Committee regarding a loan of $154. 00 from Mr .
Lindeman ' s "Officeholder Expense Account" .
Upon review, it appears this issue is not within the
jurisdiction of the City Board of Ethics . The "Officeholder
Expense Account" referred to by Mr. Leeman is not created under
City ordinance but appears to be an account created under State
law pursuant to the Campaign Finance Act (1976 PA 388 ; MCLA
169 . 201 et . seq . ) . Section 25 of the Act requires a committee
supporting a candidate to file a Campaign Statement. Section 15
of the Act provides that the Secretary of State has the
responsibility for determining whether there has been a violation
of the Act . If the Secretary of State determines a violation has
occurred , it can refer the matter to the Attorney General for
enforcement .
In view of the foregoing, it is my conclusion that the
Lansing Board of Ethics is without jurisdiction in this matter.
Any alleged violation in connection with the loan from the
Officeholder Expense Account appears to be more appropriately
under the jurisdiction of the Secretary of State .
.. : •.,".. .. � '. ., P.�: v r'',c�.a y:.�'` ....,
a
MINUTES
BOA -OF`ETHICS
LANSING BO
Monday, March 13, 1989 - 2 p.m.
313 -South-Washington
Lansing, Michigan
The meeting was called'toorder at approximately 2:10 p.m.
ROLL CALL: = ',
Donn Mertz, Chairman
Donald Cook, Vice-Chairman
Steve Lowney
Rita Bauman
Alvan Knot
A quorum was present.
GUESTS:
Jean Tubbs, Candidate for Lansing City Clerk
Chris`Goliernbewski Lansing State Journal
SECRETARY'S REPORT:
Approval of Minutes: The following minutes were approved unanimously
by the Board for filing. Special Meeting of 10/27/88, 10/26/88 and
---�► 2/27(D 81
Correspondence Received and Sent Since Last Meeting: Letter was
received from Ms. Jean Tubbs asking-fore an opinion from the Board.
Disclosure of Conflicts Filed Since Last Meeting: None.
Inquiries and Complaints Received Since Last Meeting: Letter received
from Councilmember Patrick Lindemann regarding Councilmember Sid
Worthington's alleged use of Staff for personal gain.
Next meeting Date: March 27, 1989 at 2 p.m.
CITY ATTORNEY'S REPORT:
Disclosures of Conflicts Filed Since Last Meeting: None.
Current Legal Developments of Interest: Request for opinion relative to a
person who is serving on the City's Historic District Commission and
possible conflict regarding contracting with the City through his
occupation.
J
CHAIRMAN'S REPORT:
Meeting Goals and Timetables: Today's agenda.
Impleme ntadon of Revised Disclosure Form:, Has been submitted to Rita.
Memos will be sent to-all persons who have filed a disclosure to date.
SUBCOMMITTEE REPORTS:
Drafting Committee: Disclosure Review Form. Timetable - review by
,n next week for Board consideration.
COMMITTEE OF THE WHOLE:
CLOSED SESSION: Opinions 7, 8 9 and 10 were reviewed and discussion
took place.
OLD BUSINESS:
Advisory Opinion No. 7 - Recusal of City Attorney. Motion made to
approve Draft #2 as submitted. Carried 5-0. (Attached) Ms. Bauman is to
forward a signed copy of this opinion to Councilmember Lindemann.
Advisory Opinion No. 8 - Contacts with Other City Officials. Ms. Bauman
moved to approve Draft #3 of Opinion #8 as presented. Carried 5-0.
(Attached) Ms. Bauman is to forward a signed copy of this opinion to the
} City Council President and Members, including the Physical Development
Committee and Mr. Tubbs.
Advisory Opinion No. 9 - Use of Private Resources for Public Benefit.
Mr. Lowney moved to approve as drafted. Mr. Cook supported. Carried
5-0. (Attached)
Advisory Opinion No. 10 - Sale of Pere Marquette Surplus. Awaiting for
information to be received from Mr. Al Tubbs.,
i
! _ 2
777777
r ..
l J
NEW BUSINESS (Open Session):
Discussion: Mayor's.Service on Board of Governors for City Club. Mr.
Knot is in the process of obtaining the details and will not make a
recommendation until all information is received. A meeting has been
scheduled with the Mayor to discuss this matter. Mr. Knot will make a
report at the next Board meeting.
Con
�b .- flicts Arising f
rom Candidacy o
iscussion f J. Tubbs. Chair stated
that the Attomey,General may want to address the question of whether a
possible conflict exists when an elected.official is employed by the City and
his/het spouse is also ernplo,�ed by the City as a Department Head. A legal
opinion will be prepared on this matter. Mr Knot, stated that after
discussing this matter with Rita Bauman, City Clerk, and with Mr. Tubbs,
at least on the surface there does not seem to be toproblem -be submitted at at t are
pretty much autonomous from each
March 27 meeting.
u Letter from Councilmember Lindemann regarding Use of Stafp-Time. It
was the consensus of the Board that Mr. Lindemann be invited to attend the
next meeting to discuss this matter so the Board can make a determination
as to whether this matter warrants.further investigation. Letter to be sent
to Mr. Lindemann from the Chair.
ADJOURNMENT:
i
3:25 P.M.
k
Respectfully submitted,
# FRANCESCA DONETH
Recording Secretary
SIGNED:
f
_ JOHN MERTZ, CHAIR
h
{4
3
I
Patrick E. Lindemann
First Ward City°Councilmember
city of Lansing
March 8, 1999
Mr. clan Mertz, Chairperson
Board cyf ethics
518 Hollister Building
Lansing, MI 48933
Re: Councilmember Worthington's Unethical Utilization of Staff Time
D-6ar JMr. Mertz:
For the past several months, the question of a code of conduct within an
L<<�ical standard has been the subject of a great deal of discussion and has
caused consternation among local elected officials in the Lansing area. There
appears to be agreement within the Lansing City Council that a clear
definition of ethical standards is nonexistent and that, although the
membership of that elected body is desirous of exemplary behavior, it may
inadvertently violate an unclear guideline and find itself guilty of unethical
behavior, Specific behx,.,iors may require examination in order to reach
clarification and to establish specific standards.
It has recently come to my attention that a Lansing city councilmember, who
is currently a student at Cooley Lav,7 School, has utilized staff time and public
resources for his personal gain. The estimated abuse well exceeds one
thousand dollars of public funds.
FollcFwing established City Council protocol in matters of complaints involving
staff, in December, 1988, a written complaint regarding this matter was filed
-v,7ith then-Vice President Louis Adado. Mr. Adado informed the that he had
subsequently instructed the staff to cease any personal work for individual
councilmembers on city time or involving city resources. After those
instructions were issued, the aforementioned councilmember presented
additional personal work to council staff, and when staff refused his request,
as instructed, the councilrnember then requested that staff perform his
request "on their own time."
FAWse'. 02L ?919 recycletz Paper
I also; requested of Mr. Adado an investigation into the total extent. of the
alleged abuse of staff time and city resources by the councilmember. Mr.
Adado informed me that there was insufficient. time in'his tenure as Vice
President to perform an investigation and suggested that the request be
forwarded to his successor after the first of the year. I agreed to honor his
request and forwarded the written complaint to Mr. Tony Benavides, the
newly-lected Vice President in charge of staff. Pursuant. to Mr. Benavides'
instruction; please consider this letter a formal request for a full
investigation into the alleged ethical misconduct of a Lansing City
Councilmember, in using public resources for his personal gain, by the
Lansing Board of Ethics, as cited in the COMPILED LAWS OF MICHIGAN,
STAND1,1RDS OF CONDUCT FOR PUBLIC OFFICERS AND EMPLOYEES, 15.342.
Standards Imposed, Sec. 2. (3):
A public officer or employee shall use personnel
resources, property, and funds under the officer or
employee's officiwl care and control iudiciously and
solely in ac, ordance with prescribed constitutional,
statutory, and regulatory procedures and not for
personal gain or benefit.
In advance, thank: you for your prompt attention to and expeditious
resolution of this matter.
erely, '
atric
ink m
Lansing City Co:runcilrnernber
cc Lansing Board of Ethics
Lansing City Council
Lansing City Council Staff
pdnzecl Oil INTO, recycle&gapr
DRAFT 2
ADVISORY OPINION NO. 7
SUBJECT: RECUSAL OF THE CITY ATTORNEY FROM THE BOARD OF ETHICS
DATED: March 13 , 1989
A Councilmember has asked for a Board of Ethics opinion
whether the City Attorney must recuse himself from serving as a
member of the Board of Ethics if he has been consulted by a
Councilmember concerning an issue before the Board involving that
same Councilmember.
Section 5-502.1 of the City Charter specifically names the
City Attorney as a member of the Board of Ethics . Section 5-502 .5
provides for replacement of a member of the Board of Ethics if he
or she is involved in any issue before the Board. Using the usual
dictionary meanings of the word "involved" , it is the opinion of
the Board of Ethics that unless the City Attorney is the focus of
the investigation, he or she must participate in the investigation
and any resulting opinion. Consultation by a Councilmember
concerning a matter in which the Councilmember has or may have a
conflict of interest is considered to be for the personal interest
of the Councilmember not City business . This does not mean that
Councilmembers may not make inquiries of the City Attorney
concerning matters in which they might have a conflict of interest.
It means that any such consultation, regardless when it occurs,
does not require the City Attorney to recuse himself from sitting
as a member of the Board. The Board of Ethics is the only body in
City government that is empowered to render advisory opinions with
respect to the meaning and interpretation of those provisions of
the Charter and other laws establishing standards of conduct for
officers and employees of the City of Lansing. The Board' s
advisory opinions are only issued by a quorum of the Board at a
duly noticed public meeting. The personal opinion of any member
of the Board outside such a meeting is not binding on the Board
when acting as a body, any more than the personal opinion of a
Councilmember outside a Council meeting binds the rest of the City
Council acting as a body in a Council meeting. Only the Chairman
is designated by the Board of Ethics to serve as spokesman for the
Board.
THE LANSING BOARD OF ETHICS
RITA BAUMAN, City Clerk JOHN F. MERTZ , Chairman
The City Attorney did not
participate in this decision DONALD COOK, Vice-Chairman
STEPHEN J. LOWNEY, Public Member
DRAFT 3
ADVISORY OPINION NO. 8
SUBJECT: CONTACTS BETWEEN A COUNCILMEMBER WITH A CONFLICT AND
OTHER CITY OFFICERS
DATED: March 13 , 1989
A Councilmember has asked for a Board of Ethics opinion
whether the City Municipal Planning And Development Director
properly discussed sale of city-owned property with another
Councilmember who had a private financial interest in the outcome
of the sale proposal.
It is undisputed that the administration officers involved had
no private financial interest in the proposed sale of city-owned
land. It is also undisputed that the department involved followed
all the normal procedures for land use planning and sale of excess
city-owned land. All of the contacts with the department were
initiated by the Councilmember or his partner. The Councilmember
did not disclose his interest in the transaction in writing in
advance of the contacts with the department, as required by state
law and the City Charter. Identification as a realtor involved in
the sale at the start of the contacts was not disclosure to the
public. The applicable Statute, Charter and Ordinance provisions
are intended to regulate the conduct of those who have a personal
interest which conflicts with the public interest. They do not
place the burden of compliance on other City officials without such
a conflict of interest.
Respectfully Submitted,
THE LANSING BOARD OF ETHICS
RITA BAUMAN, City Clerk JOHN F. MERTZ , Chairman
ALVAN P. KNOT, City Attorney DONALD COOK, Vice-Chairman
STEPHEN J. LOWNEY, Public Member
DRAFT 3
ADVISORY OPINION NO. 9
SUBJECT: USE OF PRIVATE RESOURCES FOR PUBLIC BENEFIT
DATED: March 13 , 1989
A Councilmember has asked for a Board of Ethics opinion
whether the City properly accepted the use of private resources to
accomplish a public benefit.
It is undisputable that the private resources were used for
a public benefit. This was determined by a Circuit Court ruling,
which may not be collaterally questioned by this body. It is also
undisputed that the citizen that donated the resources did not
receive any benefit, other than that received by other members of
the general public, from any city official. Title to the property
was retained by the City. The citizen was assessed the normal
amount for the benefits which accrued to his property from the City
action. The Board of Ethics does not have jurisdiction to question
the conduct of private citizens, but if it did, it would commend
the citizen involved here. There is no allegation or proof that
any member of City government received any private benefit from the
resources donated, or varied the normal procedures for land
acquisition. There was no violation of the rules of ethics by any
member of City government involved in the acquisition of the
property based on the facts submitted by the Councilmember who made
the inquiry.
Respectfully Submitted,
THE LANSING BOARD OF ETHICS
RITA BAUMAN, City Clerk JOHN F. MERTZ , Chairman
ALVAN P. KNOT, City Attorney DONALD COOK, Vice-Chairman
STEPHEN J. LOWNEY, Public Member
CITY OF LANSING
BOARD OF ETHICS
TO: OFFICERS AND EMPLOYEES WHO FILED DISCLOSURES OF CONFLICTS OF
INTEREST PRIOR TO MARCH 1 , 1989
The Board of Ethics has attempted to review a disclosure of
a conflict of interest filed by you. Your disclosure contains
insufficient information to allow such review, however. To assist
you to make the full disclosure required by law, the Board of
Ethics has adopted a revised form for use in disclosing conflicts.
While you are not required to use this specific form, any
disclosure you file must contain the information called for in it.
Enclosed is a copy of your original filing, along with a blank form
with instructions, which you are requested to complete and resubmit
to the City Clerk as soon as possible.
If your disclosure pertains to a contract with the City, it
must contain the information required by MCL 15 . 323 (c) . To the
extent it pertains to other government decisions, it must meet
Charter requirements for a full and complete disclosure. "Blanket
disclosures" do not comply with either state law or local charter
and ordinance requirements. Officers and employees are required
to file a separate disclosure for each specific transaction
involving an actual or potential conflict of interest before any
dealing with the City takes place. A disclosure must also indicate
how the officer or employee intends to resolve the disclosed
conflict.
Your cooperation in promptly completing and returning the
enclosed form will be appreciated.
THE LANSING BOARD OF ETHICS
CITY OF LANSING
AFFIDAVIT OF DISCLOSURE
OF
CONFLICT OF INTEREST
TO: [ ] CITY CLERK
[ ] CITY ATTORNEY
[ ] MAYOR
[ ] CITY COUNCIL PRESIDENT
[ ] , DEPARTMENT HEAD
STATE OF MICHIGAN)
COUNTY OF )
(Name) being duly sworn,
says under oath:
1 . I am an elected or appointed officer or employee of the
City of Lansing, holding the position of (Title)
in the
Department. This position is: [ ] Fulltime [ ] Parttime ( less than
25 hours/wk) [ ] Unpaid.
2. [ ] I , and/or [ ] my (Relationship)
a member of my immediate family as defined in Ordinance 290 . 02 (i) ,
and/or [ ] (Name) a
business with which I am associated as defined in Ordinance
290 . 02 (b) , ( c) and (d) :
(Select the option or options that apply)
[ ] a. may receive a financial benefit of more than a de
minimus nature which is distinguishable from the benefits to the
person as a member of the public or as a member of a broad segment
of the public, from a decision I would otherwise make or
participate in as an officer or employee. The decision involved
is described as follows:
5
The financial benefit will be received by the following
persons in the following amounts :
[ ] b. intend to have business dealings with the City of
Lansing, either directly or indirectly. The business dealings are
specifically described in detail as follows ( include names of each
party, the duration of the dealings , the financial consideration
between the parties, the governmental facilities or services
involved, the nature and degree of assignment of government
employees for fulfillment of dealings, and the nature of any
pecuniary interest) :
( ] c. may derive income or benefits, either directly or
indirectly, in addition to official remuneration, as a result of
Council action. The action involved is described as follows:
The income or benefits, in addition to official remuneration, that
will be derived, either directly or indirectly, is described as
follows:
6
[ ] d. may derive income or benefits, either directly or
indirectly, in addition to official remuneration, as a result of
a contract with the City. The contract is specifically described
in detail as follows (include names of each party, the duration of
the dealings, the financial consideration between the parties, the
governmental facilities or services involved, the nature and degree
of assignment of government employees for fulfillment of the
contract, and the nature of any pecuniary interest) :
[ ] e. have a conflict between a personal interest and the
public interest as defined by state law, the Lansing City Charter,
or ordinance. The personal interest that conflicts with the public
interest is described as follows :
The public interest that the personal interest conflicts with is
described as follows:
7
3 . I have attached additional detail on the reverse of this
form or on attached sheets , including copies of all relevant
documents, memos, resolutions, and contracts.
4 . (Select One) [ ] I will not make or participate in the
making of the affected decision and/or governmental decisions
concerning the contract and/or governmental decisions concerning
the business dealings and/or governmental decisions concerning the
conflict, OR
[ ] Despite the conflict of interest, I am able to make or
participate in the making of the affected decision and/or
governmental decisions concerning the contract and/or governmental
decisions concerning the business dealings and/or governmental
decisions concerning the conflict, fairly, objectively, and in the
public interest because:
5. I hereby certify that this disclosure is complete and
accurate to the best of my knowledge, information and belief.
6 . I hereby certify that I have not solicited or entered
into any agreement with the City of Lansing prior to filing this
affidavit.
8
The foregoing Affidavit of Disclosure of Conflict of Interest
was executed on the day of , 19
Subscribed and sworn before me the day of ,
19
Notary Public/
Deputy Clerk
County, Michigan
My Commission Expires:
FOR CITY CLERK/CITY ATTORNEY USAGE
DATE FILED:
COPIES SENT TO: [ ] Mayor
[ ] City Council President
[ ] Department Head
[ ] Board of Ethics
ON:
BY:
FOR BOARD OF ETHICS USAGE
REVIEWED:
[ ] Approved w/o Comment
[ ] Approved w/Comment, See Opinion
[ ] Not Approved:
[ ] Returned For Additional Information On
[ ] Prohibited Activity, See
[ ] Other
9
CITY OF LANSING
AFFIDAVIT OF DISCLOSURE
OF
CONFLICTS OF INTEREST
(Adopted 2/27/89 )
NOTICE
THIS FORM IS AUTHORIZED FOR USE FOR ALL DISCLOSURES
OF CONFLICTS OF INTEREST. IT REPLACES THE ONE PAGE FORM
PREVIOUSLY DISTRIBUTED BY THE CITY CLERK 'S OFFICE.
THE INFORMATION SUPPLIED IN THIS FORM MUST BE GIVEN
UNDER OATH. THERE MAY BE EMPLOYMENT, CIVIL AND/OR
CRIMINAL SANCTIONS IMPOSED UPON ANYONE MAKING A FALSE OR
MISLEADING OATH OR STATEMENT ON THIS FORM.
INSTRUCTIONS FOR COMPLETING AFFIDAVIT
1. Question 1 asks for identifying information.
2 . Question 2 asks for details of the conflict of interest.
Choose the alternative or alternatives that describe your
situation, and complete the applicable section( s) completely.
Incomplete information will delay review of your filing by the
Board of Ethics.
3 . Questions 3 to 6 apply in all cases.
4 . The completed form should be dated and executed, and your
signature notarized.
5 . Disclosures of financial conflicts of interest should be
filed with the City Clerk. Disclosures of nonfinancial conflicts
of interest should be filed with the City Attorney. Two copies of
your Affidavit should also be supplied to the City Clerk or the
City Attorney so that it can also be sent, as appropriate, to the
Mayor or City Council President and your Department Head, if
applicable.
6 . After filing, your form will be reviewed by the Board of
Ethics for completeness and conformity to state law, the charter,
and any applicable ordinances. You will be advised if any
additional information or if further action is required.
Generally, the review will occur within 2-4 weeks of your filing.
If speedier review is required, please indicate the date your
review is needed by and your reasons for the request, in a separate
letter filed with your affidavit.
1
COMMONLY ASKED QUESTIONS
ABOUT DISCLOSING CONFLICTS OF INTEREST
1. Why do I have to fill out this form?
Both state law and local charter provisions require timely,
full and complete disclosure, in writing, of actual and potential
conflicts of interest. These provisions have been in effect since
the mid and late 1970s.
2. When is an officer or employee required to file an Affidavit
of Disclosure?
As soon as a conflict exists, an officer or employee must
promptly file an Affidavit of Disclosure with the City Clerk or the
City Attorney, but in no event less than 10 days before any meeting
of any governing body at which the matter will be discussed or
considered. Where an officer or employee serves on a governing
body responsible for approval of the matter in which there is a
conflict, the disclosure must be made at the same time as the
filing with the City Clerk, to the governing body (the Council
President, in the case of Councilmembers) and be included in the
public record of the proceedings .
Last minute disclosures , except in an unusual circumstances,
do not comply with state law or the Charter. However, in the event
the issue unavoidably arises for the first time at a particular
meeting, the governing body may determine by vote of an affirmative
majority of disinterested members if a conflict exists which
requires or permits a member to be excused from voting. At the
very least, the nature of the conflict and the reasons for excusal
or nonexcusal from voting should always appear in the record of the
meeting. An Affidavit of Disclosure must then be filed as soon as
practible after the meeting.
3. Does a person have to file an Affidavit of Disclosure on each
transaction in which they are or may be in conflict, or may the
Affidavit be generic in nature?
An officer or employee must file an Affidavit of Disclosure
on each separate transaction that involves a financial conflict.
4. What level of detail satisfies the requirement to fully
disclose a conflict of interest?
State law, the Charter and Conflict of Interest Ordinance
require complete and specific details in order to satisfy the
requirement of a full disclosure. The form is designed so that if
2
fully completed, it will satisfy the disclosure requirement in most
cases .
5. Is the purpose of the Affidavit of Disclosure to serve notice
that I am unable to speak or vote on a matter, or does it simply
serve as notice to other parties in the decision making process
that I have a self interest as opposed to a public one?
Both. In the appropriate case, it also notifies a governing
body (and the public) , on the record, why the officer or employee
with the conflict believes he or she can, in light of the conflict,
make or participate in making a decision on the matter fairly,
objectively, and in the public interest.
6. Is the filing of an Affidavit of Disclosure required even if
I have already been excused from voting or participating in the
decision of the matter?
Yes .
7. What standards of conduct apply if I have a conflict of
interest?
When there is a conflict of interest relative to a public
contract, state law sets the standards of conduct which apply.
Officers and employees who contemplate being a party to a contract
with the City are referred to MCL 15. 321 et seq. , entitled,
"Contracts Of Public Servants With Public Entities" . As a general
rule, state law prohibits a full time officer or employee from
having direct business dealings with the City. Volunteer and part
time officers and employees may, if state law is complied with,
have business dealings with the City. Violation of the state
statute is a misdemeanor.
In all other cases, Chapter 5 of the Charter and Chapter 290
of the Code of Ordinances supply the applicable rules . Copies of
the Charter and Ordinance are available from the City Clerk.
Any officer or employee may seek an advisory opinion from the
Board of Ethics based on the facts of their specific situation, if
they are uncertain about what rules apply to them, or about what
they are required to do to resolve a conflict of interest.
8. Who am I allowed to communicate with about this matter, once
I have filed an Affidavit of Disclosure?
If you have a conflict of interest, whether or not you have
filed an Affidavit of Disclosure, you may not officially or
3
unofficially participate in the discussion or consideration of the
item in conflict in any way, shape, or form, either directly or
indirectly, either in furtherance of your public responsibilities
or of your private interests, at any stage of the consideration of
the matter in which you have a conflict, except in compliance with
State law or Ordinance 290 .
9. Does being excused from voting or late filing of an Affidavit
of Disclosure absolve any prior actions I may have taken on behalf
of the matter in which I have a conflict of interest?
No.
4
I I
I
LANSING
� : i t o f - 11
�:. • 1. c y
•• 1,. I N T E R 0 F F I CE C 0 M M U N I CAT I ON �..:�••�-
a
TO: Councilmember James Blair
FROM: Rita M. Bauman - City Clerk DATE: 3/14/89
SUBJECT: Opinions adopted by the Board of Ethics
Attached are opinions #7,8 and 9 as adopted by the
City of Lansing Board of Ethics at their meeting of
Monday, March 13, 1989.
- n ny7 -
MAR 1 41989
DRAFT 2
ADVISORY OPINION NO. 7
SUBJECT: RECUSAL OF THE CITY ATTORNEY FROM THE BOARD OF ETHICS
DATED: March 13 , 1989
A Councilmember has asked for a Board of Ethics opinion
whether the City Attorney must recuse himself from serving as a
member of the Board of Ethics if he has been consulted by a
Councilmember concerning an issue before the Board involving that
same Councilmember.
Section 5-502. 1 of the City Charter specifically names the
City Attorney as a member of the Board of Ethics . Section 5-502. 5
provides for replacement of a member of the Board of Ethics if he
or she is involved in any issue before the Board. Using the usual
dictionary meanings of the word "involved" , it is the opinion of
the Board of Ethics that unless the City Attorney is the focus of
the investigation, he or she must participate in the investigation
and any resulting opinion. Consultation by a Councilmember
concerning a matter in which the Councilmember has or may have a
conflict of interest is considered to be for the personal interest
of the Councilmember not City business . This does not mean that
Councilmembers may not make inquiries of the City Attorney
concerning matters in which they might have a conflict of interest.
It means that any such consultation, regardless when it occurs,
does not require the City Attorney to recuse himself from sitting
as a member of the Board. The Board of Ethics is the only body in
City government that is empowered to render advisory opinions with
respect to the meaning and interpretation of those provisions of
the Charter and other laws establishing standards of conduct for
officers and employees of the City of Lansing. The Board' s
advisory opinions are only issued by a quorum of the Board at a
duly noticed public meeting. The personal opinion of any member
of the Board outside such a meeting is not binding on the Board
when acting as a body, any more than the personal opinion of a
Councilmember outside a Council meeting binds the rest of the City
Council acting as a body in a Council meeting. Only the Chairman
is designated by the Board of Ethics to serve as spokesman for the
Board.
THE LANSINQ BOARD OF ETHICS
RITA BAUMAN, City Clerk JO F. MERTZ , irman
The City Attorney did not l ,�--
participate in this decision DONALD COOK, ice-Chairman
d4
STEP EN J /LOWNEY ublic Member
DRAFT 3
ADVISORY OPINION NO. 8
SUBJECT: CONTACTS BETWEEN A COUNCILMEMBER WITH A CONFLICT AND
OTHER CITY OFFICERS
DATED: March 13 , 1989
A Councilmember has asked for a Board of Ethics opinion
whether the City Municipal Planning And Development Director
properly • discussed sale of city-owned property with another
Councilmember who had a private financial interest in the outcome
of the sale proposal.
It is undisputed that the administration officers involved had
no private financial interest in the proposed sale of city-owned
land. It is also undisputed that the department involved followed
all the normal procedures for land use planning and sale of excess
city-owned land. All of the contacts with the department were
initiated by the Councilmember or his partner. The, Councilmember
did not disclose his interest in the transaction in writing in
advance of the contacts with the department, as required by state
law and the City Charter. Identification as a realtor involved in
the sale at the start of the contacts was not disclosure to the
public. The applicable Statute, Charter and Ordinance provisions
are intended to regulate the conduct of those who have a personal
interest which conflicts with the public interest. They do not
place the burden of compliance on other City officials without such
a conflict of interest.
Respectfully Submitted,
THE LANSIN BOARD OF ETHICS
RITA BAUMAN, City Clerk JOHL
TZ , h irman
CIL P.
. 9 -
ALVAN P. KNOT, City Attorney D ALD COOK, Vice-Chairman
S EP N J .'LOWNEY, ublic Member
DRAFT 3
ADVISORY OPINION NO. 9
SUBJECT: USE OF PRIVATE RESOURCES FOR PUBLIC BENEFIT
DATED: March 13, 1989
A Councilmember has asked for a Board of Ethics opinion
wheth.pr the City properly accepted the use of private 'resources to
accomplish a public benefit.
It is undisputable that the private resources were used for
a public benefit. This was determined by a Circuit Court ruling,
which may not be collaterally questioned by this body. It is also
undisputed that the citizen that donated the resources did not
receive any benefit, other than that received by other members of
the general public, from any city official. Title to the property
was retained by the City. The citizen was assessed the normal
amount for the benefits which accrued to his property from the City
action. The Board of Ethics does not have jurisdiction to question
the conduct of private citizens , but if it did, it would commend
the citizen involved here. There is no allegation or proof that
any member of City government received any private benefit from the
resources donated, or varied the normal procedures for land
acquisition. There was no violation of the rule-s of ethics by any
member of City government involved in the acquisition of the
property based on the facts submitted by the Councilmember who made
the inquiry.
Respectfully Submitted,
THE LANSING BOARD OF ETHICS
RITA BAUMAN, City Clerk JOH MERTZ , airman
ALVAN P. KNOT, City Attorney ?1 5ALD COOK, Vice-Chairman
1�,4 f)A 0
STEPH 1 J ./l�WNEY , P lic Member
MINUTES
LANSING CITY BOARD OF ETHICS
SPECIAL MEETING OF MONDAY, MAY 1, 1989
The meeting was called to order at 2 : 00 p.m. at the Foster
Building, 313 South Washington Square, Lansing, Michigan.
BOARD MEMBERS PRESENT:
John Mertz , Chair
Steve Lowney
Don Cook
Rita Bauman
Alvan P. Knot
OTHERS PRESENT:
Kathleen Frantz, Admn. Assistant to City Attorney
(as Recording Secretary)
AGENDA APPROVED AS SUBMITTED BY CLERK BAUMAN.
SECRETARY'S REPORT:
Correspondence Received and Sent:
None.
Affidavit of Disclosures filed:
David Hilliard Re: Full-time City employee wants to work
for Time Energy Systems, Inc. after his
regular hours with City. Mr. Knot is to
draft opinion regarding this matter and
submit Draft #1 at the next Board meeting.
Inquiries and Complaints Received Since Last Meeting: None
Next Meeting Date: May 22, 1989 @ 2:00 p.m. at the Foster
Building, 313 S. Washington Square, 3rd Floor Conference Room,
Lansing, Michigan.
-1-
CHAIRMAN'S REPORT:
OLD BUSINESS:
1 . Mr. Mertz provided the Board members with a copy of Draft
41 of a response letter to Mr. Lindemann' s letter of
March 8 , 1989 regarding City Councilmember Worthington
and use of Council Staff for personal business. The
letter was reviewed and discussion ensued regarding
revisions. Mr. Mertz will present the revised Draft #2
of the letter at the next Board of Ethics meeting.
2 . Mr. Knot provided the Board members with a letter to Alan
Tubbs in response to his inquiry regarding the candidacy
of his wife running for City Clerk. The members reviewed
said letter and all members signed same which indicated
to Mr. Tubbs no conflict existed if his wife ran for the
office of or became City Clerk.
3 . In regard to the Mayor' s City Club inquiry, Mr. Mertz
will draft a letter to the Mayor advising that no
conflict exists for the Mayor to serve on the Board of
Governors of the City Club.
NEW BUSINESS: None.
PUBLIC COMMENT: None
ADJOURNMENT: APPROXIMATELY 3:20 P.M.
Submitted by:
Kathleen Frantz
Recording Secretary
-2-
MINUTES
LANSING CITY BOARD OF ETHICS
REGULAR MEETING ON MONDAY, MAY 22, 1989
The meeting was called to order at 2 : 15 p.m. at the Foster
Building, 313 South Washington Square, Lansing, Michigan.
BOARD MEMBERS PRESENT:
John Mertz , Chair
Don Cook
Rita Bauman
Alvan P. Knot
BOARD MEMBERS ABSENT:
Stephen Lowney
OTHERS PRESENT:
Kathleen Frantz, Admn. Assistant to City Attorney
(as Recording Secretary)
SECRETARY'S REPORT:
Correspondence Received and Sent: None.
Affidavit of Disclosures filed: None.
Inquiries and Complaints Received Since Last Meeting: None.
Next Meeting Date: June 19, 1989 @ 2:00 p.m. at the Foster
Building, 313 S. Washington Square, 3rd Floor Conference Room,
Lansing, Michigan.
CHAIRMAN'S REPORT:
OLD BUSINESS:
1 . AFFIDAVIT OF DISCLOSURE OF DAVID HILLIARD: Discussion
ensued regarding Mr. Hilliard' s disclosure wherein Mr.
Hilliard indicates he is a full-time employee of the City
of Lansing who would like to work on a contract basis for
Time Energy Systems providing maintenance on the heating
and cooling system at City Hall. John Mertz entertained
a motion that Al Knot prepare an opinion regarding this
matter. Motion made by Rita Bauman; Don Cook seconded
the motion; carried.
-1-
2 . AFFIDAVIT OF DISCLOSURE OF LARRY INGALLS: Discussion
ensued regarding Mr. Ingalls ' disclosure wherein Mr.
Ingalls advises that he is a full-time City employee and
inquires whether there is a conflict of interest if he
provides maintenance services to the Lansing Police
Department emergency helicopter on a contract basis after
his regular working hours. Mr. Mertz entertained a
motion that Al Knot prepare an opinion regarding this
matter. Rita Bauman moved that Al Knot prepare an
opinion; seconded by Don Cook; carried.
3 . AFFIDAVIT OF DISCLOSURE OF VIRGINIA SWANSON: Discussion
ensued regarding this affidavit wherein Ms. Swanson
indicates she is a full time employee of the City and
wishes to participate in the Urban Renewel Program.
Motion was made by Rita Bauman that Al Knot prepare an
opinion regarding this matter; seconded by Don Cook;
carried.
Mr. Mertz advised the Board members that the remaining
Disclosures be discussed at the next regular meeting on June
19, 1989 .
NEW BUSINESS: None.
PUBLIC COMMENT: None
ADJOURNMENT: APPROXIMATELY 2:30 P.M.
Submitted by:
Kathleen Frantz
Recording Secretary
-2-
BOARD OF ETHICS
MONDAY - JUNE o, 1988
The meeting of the Board of Ethics was called to order_ at 2:10 P.M. by Vice-Chairperson
Donald Cook.
Roll Call was taken:
Present Donald Cook, Stephen Lowney and Rita M. Bauman - City Clerk
Excused Absence - Al Knot, City Attorney and John Mertz.
Motion by Stephen Lowney that the minutes of the meeting of February_ 22, 1988 be
approved - seconded by Don Cook - Motion Carried.
Old Business: In regard to the letter from Harold Leeman vs Patrick Lindemann -
Stephen Lowney remarked that he would stop by the office of John
Mertz to pick up some former opinions in order to put some answer
in writing for Mr. Leeman.
Reports of City Officers - None
New Business - None
Seeing that there was nothing else to come before the Board.
Motion by Vice Chairperson Don Cook that this meeting stand adjourned - motion
seconded by Rita Bauman - Motion Carried.
The meeting adjourned at 2:17 P.M.
Respectfully submitted.
, .L,
Rita M. Bauman
Secretary
November 22, 1988
Mr . Harold J. Leeman , Jr .
529 North Francis
Lansing , Michigan 48912
Re : October 8 , 1987 Request - Advisory Opinion No . 4
Dear Mr . Leeman :
By letter dated October 8 , 1987 , you asked the Lansing
Board of Ethics to review the post-election primary statement of
the Lindemann for City Council Campaign Committee regarding a
loan of $154 . 00 from Mr . Lindemann ' s "Officeholder Expense
Account" .
Upon review, it appears that this issue is not within
the jurisdiction of the City Board of Ethics . The "Officeholder
7xpense Account" referred to by you is not created under City
Ordinance but appears to be an account created under State law
pursuant to the Campaign Finance Act ( 1976 PA 388 ; MCLA 169. 201
et . seq . ) . Section 15 of the Act provides that the Secretary of
State has the responsibility for determining whether there has
been a violation of the Act .
In view of the foregoing , it is our conclusion that the
Lansing Board of Ethics is without jurisdiction in this matter.
As was indicated to you by the Board in a recent
meeting , we apologize for the belated nature of this response .
Very truly yours ,
LANSING BOA�D OF ETHICS
J n F . Wirtz , a ^man
Dona &Cook , Vice-Ch, irman
a
Ste ahe J . Lod ey,'-"Publi/ ember
C� p -
Alvan P . Knot , City Attorney
Rita M. Bauman, City er