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Last modified
4/1/2024 8:42:27 AM
Creation date
7/10/2023 11:04:22 AM
Metadata
2023-366
Fields
Template:
Opinion Item
Opinion Type
Advisory Opinion
Docket Number
2023-366
Requesting Party
Rory Bellina
Parties Involved
Adam Campo
CRC Logistic Services, Inc.
Agency at Issue
City of Kenner
Decision Date
7/7/2023
Law
La. R.S. 42:1121(B)(1)
La. R.S. 42:1121(C)
Caption
The Code of Governmental Ethics prohibits CRC Logistic Services, Inc., for a period of two years following Adam Campo's resignation, from assisting another person for compensation in a transaction in which Adam Campo participated while employed by the City of Kenner.
Ethics Subject Matters
Post Employment
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during the term of his public employment on a contractual basis, regardless of the parties to the <br /> contract, to, for, or on behalf of the agency with which he was formerly employed. <br /> La. &S. 42:1121(C): No legal entity in which a former public servant is an employee shall, for a <br /> period of two years following the termination of her public service, assist another person, for <br /> compensation, in a transaction,or in an appearance in connection with a transaction in which such <br /> public servant at any time participated during her public service and involving the agency by which <br /> she was formerly employed. <br /> La. R.S.42:1102(2)(a)(vi)defines"agency"for public servants of political subdivisions,including <br /> public employees of municipalities, to mean the agency in which the public servant serves. <br /> La. R.S. 42:1102(16) defines "person" to mean an individual or legal entity, other than a <br /> governmental entity,or an agency thereof. <br /> ANALYSIS&c CONCLUSION <br /> As an employee of the City of Kenner,Adam Campo was a public employee pursuant to La. R.S. <br /> 42:1102(18) and (19). Mr. Campo's agency for purposes of the Code was the City of Kenner <br /> pursuant to La. R.S. 42:1102(2)(a)(vi). <br /> The Board concluded, and instructed me to inform you, that La. R.S. 42:1121(C) prohibits CRC, <br /> for a period of two years following Adam Campo's resignation, from assisting another person for <br /> compensation in a transaction in which Adam Campo participated while employed by the City of <br /> Kenner. La. R.S. 42:1102(16)defines"person"to include any individual or legal entity, other than <br /> a governmental entity. <br /> However, the Code does not prohibit CRC from entering into a transaction directly with the City <br /> of Kenner to purchase commercial property.Additionally, the Code does not prohibit CRC from <br /> entering into future contracts to provide services directly to the City of Kenner, since the City of <br /> Kenner is a governmental entity. <br /> The Board further advised that La. R.S.42:1121(B)(1)prohibits Adam Campo,for a period of two <br /> years following his resignation, from assisting CRC in any transaction in which he participated <br /> while he was employed by the City of Kenner. The Code does not prohibit Adam Campo from <br /> providing services for CRC unrelated to those transactions in which he participated while he was <br /> employed by the City of Kenner. <br /> This advisory opinion is based solely on the facts as set forth herein. Changes to the facts as <br /> presented may result in a different application of the provisions of the Code of Governmental <br /> Ethics. The Board issues no opinion as to past conduct and or to laws other than the Code of <br /> Governmental Ethics, the Campaign Finance Disclosure Act, the Lobbyist Disclosure Acts, and <br /> the conflict of interest provisions contained in the Louisiana Gaming Control Law. <br /> If you have any questions,please contact me at (800) 842-6630 or(225) 219-5600. <br /> Page 2 of 3 (BD 2023366) <br />
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