Councilman Larry Rolling
Northshore Images In Stitches LLC
City of Covington
R. S. 42:1112
R. S. 42:1102(8) and (15)
Advisory opinion that the Code of Governmental Ethics prohibits a Covington Councilman, who has a 100% ownership interest in Northshore Images and Stitches LLC, from entering into transactions with the City of Covington or participating in matters in which his business would have a substantial economic interest. Further, the business of the councilman is not precluded from selling products with the city logo to employees of the city provided he employee uses his personal funds. Also, the councilman is precluded from providing compensated services to vendors who have contracts with the City.
Ethics Subject Matters
STATE OF LOUISIANA
o'pF ►ou' DEPARTMENT OF STATE CIVIL SERVICE
'A LOUISIANA BOARD OF ETHICS
„, _ P. O. BOX 4368
BATON ROUGE, LA 70821
\ O +Pfo _ ,p/ (225) 219 -5600
%, FAX: (225) 381 -7271
1- 800 - 842 -6630
October 28, 2011 www.ethics.state.la.us
Ms. Bonnie Champagne
Clerk to Council
P.O. Box 778
Covington, LA 70434
Re: Ethics Board Docket No. 2011 -1332
Dear Ms. Champagne:
The Louisiana Board of Ethics. at its October 20. 2011 meeting, considered your request for an
advisory opinion regarding Councilman, Larry Roiling, and his ownership interest in Northshore
Images In Stitches, LLC. You stated in your opinion request that Councilman Rolling was sworn
into office on July 1, 2011. You also stated that he owns a 100 percent interest in Northshore hnages
and Stitches, LLC - which is a business located in District D in the City limit of Covington. The
business has been open for the past 13 years and has conducted business with the City consisting of
producing and selling City of Covington logo merchandise.
Based upon these facts you requested the answer to a series of questions, and how the ethics laws
of the State of Louisiana will apply:
1.) Is itpermissible for Councilman Rolling, through his company, to sell products on which
the city logo is imprinted to the City of Covington and paid for with City of Covington funds?
Section 11 13A(1)(a) of the Louisiana Code of Ethics prohibits a public servant or legal entity in
which he owns a controlling interest from bidding on, entering into a contract, subcontract or any
other transaction under the supervision or jurisdiction of his agency. A "controlling interest” is
defined in Section 1102(8) of the Code as an interest in a company that exceeds 25 %. Since Mr.
Rolling has an 100% interest then the controlling interest is apparent. As councilman, Mr. Rolling's
agency is the City of Covington. As such. his business would be prohibited by the Code of Ethics
from entering into transactions with the City of Covington.
Further, Section 1112 of the Code prohibits a public servant from participating in transactions
involving his governmental entity in which he would have a substantial economic interest.
Section 1102(15) states that participate means to take part in or have or share responsibility for
action of a governmental entity or a proceeding, personally, as a public servant of the
governmental entity, through approval, disapproval. decision. recommendation. rendering of
advice. investigation or-failure to act or perform a duty. Thus, Councilman Rolling may not
participate in a matter in which his business would have a substantial economic interest.
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