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The Board concluded, and instructed me to inform you, that the Code of Governmental <br /> Ethics would not prohibit Mr. Williams from continuing to participate as a landlord in the <br /> Section 8 program, under his existing HAP Contract with the Housing Authority, <br /> pursuant to the terms and conditions in place at the time he married Ms. Robinson. <br /> However, Mr. Williams would be prohibited from entering into new 12-month lease <br /> agreement and corresponding HAP Contract with the Housing Authority, requesting a <br /> rent increase, or continuing as a landlord if the payment terms change for any reason. La. <br /> R.S. 42:1113 prohibits a public servant, a member of her immediate family, or a legal <br /> entity of which she has a controlling interest from bidding on or entering into any <br /> contract, subcontract, or other transaction that is under the supervision or jurisdiction of <br /> her agency. Mr. Williams entered into the lease agreement and HAP Contract prior to his <br /> marriage to Ms. Robinson, both of which automatically renew on a month-to-month <br /> basis. Therefore, it would not present a violation of the Code if Mr. Williams continues <br /> to participate as a landlord in the Section 8 program, under his existing HAP Contract <br /> with the Housing Authority, pursuant to the terms and conditions in place at the time he <br /> married Ms. Robinson. However, Mr. Williams would be prohibited from entering into <br /> new 12-month lease agreement and corresponding HAP Contract with the Housing <br /> Authority, requesting a rent increase, or continuing as a landlord if the payment terms <br /> change for any reason. Additionally, Mr. Williams would be required to disclose the <br /> income that he receives from the Housing Authority and the tenant, pursuant to La. R.S. <br /> 42:1114. <br /> The Board further concluded, and instructed me to inform you, that the Code of <br /> Governmental Ethics would prohibit Ms. Robinson from participating in any matter <br /> involving the tenant residing in Mr. Williams' unit. La. R.S. 42:1112B(1) prohibits a <br /> public servant from participating in a transaction involving the governmental entity in <br /> which, to her actual knowledge, any member of her immediate family has a substantial <br /> economic interest. In accordance with La. R.S. 42:1112C and Chapter 14 of the <br /> Administrative Rules for the Board of Ethics, a disqualification plan that completely <br /> removes Ms. Robinson from any responsibility regarding the tenant residing in Mr. <br /> Williams' unit must be submitted to the Board for approval. A copy of Chapter 14 of the <br /> Administrative Rules for the Board of Ethics is enclosed. <br /> This advisory opinion is based solely on the facts as set forth herein. Changes to the facts <br /> as presented may result in a different application of the provisions of the Code of <br /> Governmental Ethics. The Board issues no opinion as to past conduct or as to laws other <br /> than the Code of Governmental Ethics, the Campaign Finance Disclosure Act, the <br /> Lobbyist Disclosure Act, and conflict of interest provisions in the gaming laws. If you <br /> have any questions, please contact me at (800) 842-6630 or (225) 219-5600. <br /> Sincerely, <br /> LOUISIANA BOARD OF ETHICS <br /> • <br /> Vivian Haley Will' s <br /> For the Board <br />