Ethics Chief Gets Permanent Appointment; Case Overview Shows Agency's Vital Role

Friday, February 24, 2017

A week ago today, on Feb. 17, the Massachusetts State Ethics Commission announced the appointment of David A. Wilson as its executive director, where he’s responsible for administering and enforcing the state’s conflict of interest and financial disclosure laws.

A graduate of Columbia University School of Law and Brandeis University in Waltham, Wilson is kind of a fixture of Massachusetts government, having been an attorney on the Ethics Commission staff for three decades.  For the past eight months, he’d been serving as the commission’s acting executive director.  He needs no warm-up for this big role.
The commission is composed of five members, three appointed by the governor and one each appointed by the secretary of state and attorney general.  All of the current commissioners are attorneys, and three of them are retired judges: Barbara Dortch-Okara, Regina Quinlan and David Mills. (The non-judge lawyer-members are Thomas Sartory and Maria Krokidas.
Wilson’s appointment, I thought, was a good occasion to look at the product of the commission.  So I went to the agency web site -- http://www.mass.gov/ethics/ --and I downloaded and printed the 14 cases it resolved during calendar year 2015, the last year for which such information is publicly available. 
What follows are abridged versions, or summaries, of those cases.  The verbiage has been taken for the most part entirely from the 2015 commission records.  I’ve added only the sub-heads above each case and a word or two here and there to clarify the subject matter:
Conflict of Interest in Salisbury
The commission approved a Disposition Agreement in which Henry Richenburg, a member of the Salisbury Board of Selectmen, admitted to violating the conflict of interest law by his actions as selectman in connection with the board’s consideration and approval of an application for a license to operate a poultry business submitted by Richenburg’s son-in-law.  Richenburg paid a $2,500 civil penalty. 
Richenburg participated as a selectman in the decisions to table the application and then to approve the application.  Richenburg also signed the license along with the other selectmen.  At the time he participated in these matters, Richenburg knew that both he and his daughter had a financial interest in the proposed poultry business.
Problematical Hiring in Oak Bluffs
The commission voted to find reasonable cause to believe that John Rose, Chief of the Oak Bluffs Fire-Emergency Medical Services Department, violated section 19 of the conflict of interest law by participating in the hiring and supervision of his immediate family members.  The commission chose to resolve this through the issuance of a Public Education Letter rather than an adjudicatory hearing because the commission recognized that in certain areas of public service, such as fire and police departments, there is a strong family tradition in which many members of the same family pursue the same type of employment and frequently work together or for each other. 
Non-Posted Job in Rutland
The commission approved a Disposition Agreement in which Rutland Department of Public Works Superintendent Gary Kellaher admitted to violating the conflict of interest law by hiring his son into a seasonal DPW position without posting the position.  Kellaher paid a $2,500 civil penalty. 
Family Hiring in Somerset
The commission voted to find reasonable cause to believe that Somerset Recreation Commission members Maryellen Aspden, James Pereira, Raymond Frizado and Richard Silvia violated the conflict of interest law by requesting that the Recreation Department Director hire their family members for summer jobs with the department and/or by approving the summer jobs lists in 2012 and 2013 that included those family members or others with whom they had private relationships.  The commission chose to resolve the matter by issuing a Public Education Letter rather than through an adjudicatory hearing in order to provide other public employees in similar positions and circumstances with a clearer understanding of how to comply with the conflict of interest law. 
Self-Sanctioned Salary Hike in Cambridge
The commission approved a Disposition Agreement in which Joseph Tulimieri, the former Executive Director of the Cambridge Redevelopment Authority (CRA), admitted to violating the conflict of interest law by increasing his own compensation on five separate occasions.  Tulimieri paid a $37,500 civil penalty and was also required to make restitution to the CRA in the amount of $21,245.  Tulimieri served as the CRA executive director from 1978 until January 1, 2011. 
Improper Financial Interest in Methuen 
The commission approved a Disposition Agreement in which Joyce Campagnone, a Methuen City Councilor who is also a full-time paid employee of the Greater Lawrence Sanitary District, admitted to violating the conflict of interest law by having a prohibited financial interest in a municipal contract.  Campagnone paid a $1,000 civil penalty for the violation and made restitution to the City of Methuen in the amount of $4,000. 
A Trooper’s Out-of-Bounds Help for Family Member  
The commission voted to find reasonable cause to believe that Massachusetts State Police Trooper Seth Peterson violated the conflict of interest law by: (a) using his position to intervene with a tow company to have a family member’s tow charge reduced, and to deprive the tow company of work to which it would have been entitled, and (b) participating in an inspection of the tow company, which ultimately resulted in the temporary removal of the company from the regional State Police tow lists.  The commission chose to resolve the matter by issuing a Public Education Letter rather than through an adjudicatory hearing because the State Police took disciplinary action against Peterson, imposing a forfeiture of 15 vacation days, at a cost to Peterson of approximately $5,500. 
A Sheriff’s Misplaced Displeasure 
The commission approved a Disposition Agreement in which Suffolk County Sheriff Steven Tompkins admitted to violating the conflict of interest law in 2013 by identifying himself as the sheriff when asking eight business owners in his district to take down his opponent’s campaign signs on display in their shops.  Tompkins paid a $2,500 civil penalty for the violation. 
Commission Withdraws After Care Coordinator Is Indicted
The commission issued an Order allowing a Joint Motion to dismiss the adjudicatory proceeding involving Kathryn Christopher, a former home care coordinator for the Town of Belmont Council on Aging (COA).  The commission’s Enforcement Division initiated the adjudicatory proceeding in July 2010 by issuing an Order to Show Cause (OTSC) alleging that Christopher repeatedly violated several sections of the conflict of interest law.  Specifically, the OTSC alleged that Christopher violated the conflict of interest law by:  (1) coordinating services for an elderly COA client and selecting herself to provide those services to the client for private compensation; (2) accessing the client’s funds and assets to pay for Christopher’s personal and family expenses; and (3) using those funds and assets for the benefit of herself and her family.  In allowing the Joint Motion and dismissing the proceeding, the commission stated that Christopher was criminally indicted in September 2011 for conduct that related to the actions alleged in the OTSC, and that the commission’s adjudicatory proceeding was stayed pending resolution of the criminal case.  In March 2015, Christopher was convicted of one criminal charge, obtaining a signature by false pretense, and was sentenced to a term of probation for 5 years. 
'Active Deception' in Blandford 
The commission issued a Final Order on Summary Decision and Civil Penalty concluding the adjudicatory proceeding involving Robert Nichols, a former member of the Board of Selectmen of the Town of Blandford. The commission found that Nichols violated section 19 because he participated as a selectman in choosing Berkshire Consulting to do work on a culvert, work in which he and Berkshire Consulting, his private employer, had a financial interest…The commission found that Nichols violated section 20 because he had a financial interest in the $12,150.50 that the Town paid to Berkshire Consulting under the contract.  The commission ruled that Nichols violated section 23(b)(2)(ii) by using his position as selectman to secure an unwarranted privilege of substantial value -- $12,150.50 -- for himself or others by misrepresenting the unavailability of Tighe and Bond (the town’s engineering consultant) to work on the project and by mischaracterizing his relationship with Berkshire Consulting to his fellow selectmen.  The commission ordered Nichols to pay civil penalties of:  $5,000 for violating section 19; $5,000 for violating section 20; and $2,500 for violating section 23(b)(2)(ii).  Although Nichols had reimbursed the town the $12,150.50 as the result of a different proceeding, the commission concluded, “Civil penalties are appropriate because Nichols accomplished his objective of directing town money to himself by means of active deception as well as concealment of facts of vital importance.”
Consultant Acted on Own Plans in Canton 
The commission issued a Decision and Order concluding the adjudicatory proceeding involving Robert Murphy, a former consultant to the Town of Canton Conservation Commission.  The commission found that Murphy violated sections 17(a) and 23(b)(3) of the conflict of interest law, and ordered Murphy to pay a civil penalty of $10,000…Murphy violated section 23(b)(3) when, as the town’s ConCom consultant, he knowingly or with reason to know, reviewed and acted on applications and plans submitted by a company he operated, M&M Engineering, on behalf of its private clients.  The commission ordered that Murphy pay a $5,000 civil penalty for violating section 17(a), and a $5,000 civil penalty for violating section 23(b)(3).
Commissioner Mixed Town, Private Business in Marshfield
The commission approved a Disposition Agreement in which Mark Stevenson, former chair of the Town of Marshfield Conservation Commission, admitted to violating the conflict of interest law by referring to his ConCom position and stating that there would not be any complications with a marine construction project while discussing his contracting company’s prospective bid on a construction project with project officials, and by participating as a ConCom member in an enforcement order issued for the project after his company did not receive the contract, without disclosing his company’s unsuccessful bid for work on the project.  Stevenson paid a $2,500 civil penalty for violating two sections of the law. 
Town Funds Subsidized Private Suit in Holland
On March 19, 2015, the commission voted to find reasonable cause to believe that Town of Holland Board of Selectmen members James Wettlaufer, Michael Kennedy, Christian Petersen and Lynn Arnold violated the conflict of interest law by authorizing the use of town funds to pay for town Highway Surveyor Brian Johnson’s private civil lawsuit against a local blogger.  The commission also voted to find reasonable cause to believe that Johnson violated the conflict of interest law by receiving payment of the legal fees in his private civil lawsuit.  Rather than authorizing adjudicatory proceedings, the commission chose to resolve the matter by issuing a Public Education Letter because the town has been reimbursed in full and there is a question as to whether the selectmen relied on advice of counsel.
Tainted Zoning Variance in Bridgewater
The commission approved a Disposition Agreement in which Thomas Snell, a member of the West Bridgewater Zoning Board of Appeals, admitted to violating the conflict of interest law by participating as a ZBA member in granting variances for two properties while knowing that he had a financial interest in those matters.  Snell paid a $6,500 civil penalty for violating the conflict of interest law.  Snell owns and operates Tom Snell Construction and Excavating, a sole proprietorship that performs excavation and demolition work for property owners and developers. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

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