| Request for an advisory opinion regarding whether the Code of Governmental Ethics ("Code") permits Benjamin Walker to write active shooter response plans and conduct training for Louisiana parishes while still employed with the Terrebonne Parish Office of Homeland Security and Emergency Preparedness. |
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Benjmain Walker is the Assistant Director at Terrebonne Parish Office of Homeland Security and Emergency Preparedness and has been for the last 13 years. He was trained by the Louisiana Governor's Office of Homeland Security and Emergency Preparedness in 2015 to assist local schools in developing active shooter response plans.Over the course of 5 years, Mr. Walker has developed a training program flyer, an active shooter vulnerability analysis checklist, an active shooter response plan template, a PowerPoint presentation, attendee review forms, emergency response maps, and lockdown drills.The products were developed with the encouragement of his supervisor, Earl Jues Jr., the Director of Terrebonne Homeland Security and Emergency Preparedness. Mr. Walker also conducted over 40 trainings with schools and businesses. His supervisor allowed him to conduct the trainings because no other organization offered active shooter training to schools and businesses. However, the provision of these trainings was not in his job description.Tracy Hilburn started a consulting business named Bayou State Grant Management LLC that does various parish, state, and federal granted-related work. Mr. Hilburn has asked Mr. Walker to assist him in seeking to write active shooter response plans and conduct active shooter training for Louisiana parishes. Mr. Walker asks whether this would result in a violation of the Code.Mr. Walker also may open a business with Mr. Hilburn to provide active shooter prevention equipment to parishes. He asks whether the Code would prohibit him from doing so. He also asks how the Code's post-employment restrictions would apply in that scenario.
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On December 8, 2023, the Board voted to defer this matter to allow staff time to gain additional information to properly advise.
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| Assigned Attorney: |
Mallory Guillot |
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