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2025-296
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Entry Properties
Last modified
10/17/2025 2:58:16 PM
Creation date
9/8/2025 10:38:39 AM
Metadata
2025-296
Fields
Template:
Opinion Item
Opinion Type
Advisory Opinion
Docket Number
2025-296
Requesting Party
Michele Steib
Parties Involved
Michele Steib
MSITT, LLC
Spears Global
Agency at Issue
Port of New Orleans
Decision Date
9/5/2025
Law
1111C(2)(d)
1121B
1121C
Caption
The Code of Ethics prohibits an employee of the Port of New Orleans and the enployee's company from rendering services to a vendor of the Port of New Orleans; and, from assisting a person within two years from the termination of the employee's employment for compensation in a transaction, or in an appearance in connection with a transaction, involving the Port of New Orleans in which the employee participated in while employed with the Port of New Orleans.
Ethics Subject Matters
Outside Employment
Post Employment
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ANALYSIS <br /> You are a public employee pursuant to La. R.S. 42:1102(18)(a) and a public servant pursuant to <br /> La. R.S. 42:1102(19). Your agency for purposes of the Code is the Port pursuant to La. R.S. <br /> 42:1102(2)(a)(vi). <br /> Outside Emplo i�nent <br /> La. R.S. 42:1111C(2)(d) prohibits you and your company, MSITT, LLC, from receiving <br /> compensation for or in consideration of services rendered, or to be rendered, to or for any person <br /> (individual or legal entity), during your public service unless such services are neither perfonned <br /> for nor compensated by any such person or from any officer, director, agent, or employee of any <br /> such person, if you know or reasonably should know that such person: (1) has or is seeking to <br /> obtain contractual or other business or financial relationships with your agency; (2) conducts <br /> operations or activities which are regulated by your agency; or, (3) has substantial economic <br /> interests which may be substantially affected by the performance or nonperformance of your <br /> official duties as a public employee. <br /> As such, you and your company are prohibited from providing compensated IT services through a <br /> private contract with Spears Global since it has a contractual relationship with ��our agency, the <br /> Port. <br /> Post-Emplo. i� <br /> La. R.S. 42:1121B(1) prohibits you, for two years following your retirement from public <br /> employment with the Port, from assisting another person (individual or legal entity), including <br /> your business, MSITT, LLC, for compensation in a transaction, or in an appearance in connection <br /> with a transaction, in which you participated at any time during your public employment and <br /> involving the Port. However, you are not prohibited from assisting another individual or legal <br /> entity for compensation in any transaction involving the Port in which you did not participate <br /> during your einployment with the Port. <br /> La. R.S. 42:1121B(1) also prohibits you, for two years following your retirement from public <br /> employment with the Port, from rendering any service, which you previously rendered to the Port <br /> during the term of your public employment, on a contractual basis to, for, or on behalf of your <br /> former agency, the Port, regardless of the parties to the contract. However, you are not prohibited <br /> from rendering new services that you have not previously rendered to the Port during your public <br /> employment, on a contractual basis to, for, or on behalf of the Port. <br /> Additionally, La. R.S. 42:1121C prohibits MSITT, LLC, for two years following your retirement <br /> froin public employment with the Port, from assisting another person, such as Spears Global, for <br /> compensation in a transaction, or in an appearance in connection with a transaction, in which you <br /> at any time participated during your public employment and involving the Port. However,MSITT, <br /> LLC is not prohibited from assisting another person for compensation in a transaction involving <br /> the Port in which you did not previously participate duling your employment with the Port. <br /> Page 3 of 4 (BD 2025-296) <br />
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