741 Colonel Ledyard Highway

Ledyard, CT 06339

TOWN OF LEDYARD

Administration Committee

Meeting Minutes

http://www.ledyardct.org

Chairman Gary St. Vil

Regular Meeting

Wednesday, September 10, 2025

5:30 PM

Town Hall Annex- Hybrid Format

In -Person: Council Chambers, Town Hall Annex Building

Remote Participation: Information Noted Below:

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901865

CALL TO ORDER

the Meeting was called to order by Councilor Buhle at 5:30 p.m. at the Council Chambers Town

Hall Annex Building.

Councilor Buhle welcomed all to the Hybrid Meeting. She stated for the Town Council

Administration Committee and members of the Public who were participating via video

conference that the remote meeting information was available on the Agenda that was

posted on the Town’s Website - Granicus-Legistar Meeting Portal.

II.

ROLL CALL

Gary St. Vil Town Council Chairman

Carmen Garcia-IrizarryTown Councilor

Bill Barnes Town Councilor

Tim RyanTown Councilor

Fred Allyn, IIMI ayor

Christine DiasHuman Resources Director

Patricia RileyTown Clerk

M. Dave Schroder, Jr Resident

Joanne KelleyResident

Eric Treaster Resident

Whit Irwin Resident

Deborah EdwardsResident

Sharon PealerResident

Jay PealeRr esident

Dan Pealer Resident

Jeff Ellingberg Resident

Anne Roberts-Pierson Resident

Steve MungerResident

Angeal Cassidy Resident

Wendy HelleksonResident

Allyssa Siegel-Miles Resident

Roxanne Maher Administrative Assistant

Kevin Dombrowski

Jessica Buhle

Present:

April Brunelle

In addition, the following were present:

Gary St. Vil Town Council Chairman

Carmen Garcia-IrizarryTown Councilor

Bill Barnes Town Councilor

Tim RyanTown Councilor

Fred Allyn, IIMI ayor

Christine DiasHuman Resources Director

Patricia RileyTown Clerk

M. Dave Schroder, Jr Resident

Joanne KelleyResident

Eric Treaster Resident

Whit Irwin Resident

Deborah EdwardsResident

Sharon PealerResident

Jay PealeRr esident

Dan Pealer Resident

Jeff Eilenberger Resident

Anne Roberts-Pierson Resident

Steve MungerResident

Angela Cassidy Resident

Wendy HelleksonResident

Alyssa Siegel-Miles Resident

Roxanne Maher Administrative Assistant

III.

RESIDENTS & PROPERTY OWNERS COMMENTS

Mr. Whit Irwin, 2 Winfield Way, Ledyard, noted tonight’s Administration Committee

Agenda included a motion to create an Ethics Commission for the Town of Ledyard.

He stated that he was present this evening to expressed his opposition to the draft

Ordinance. He stated that he opposed this idea as much as he opposed flying Third

Party Flags that this Town Council considered within the last year. He stated creating

an Ethics Commission was a horrible idea stating that they were bloating the

government even more, commenting that thanks to this Town Council his taxes were

even more this year than they were. He stated in reading the proposed “Ordinance

Establishing a Code of Ethics and Ethics Commission for the Town of Ledyard”

dated September 8, 2025 that they were creating more paperwork and requirements,

noting that it was a burdensome processes, and more work for the town, pointing out

that this Town Council already cut some of the staff’s pay. He stated when a proposal

to Establish an Ethics Commission was previously brought before the Town Council

it was resoundly rejected, and therefore, they should not consider it again. He stated

while he was serving on the Town Council there was at least one occasion, when it

was brought up by one person, who was no longer here. He went on to state that it

was also mentioned that there was a lot of hard work that went into it drafting the

proposed Ordinance. However, he stated that he would stipulate that a lot of hard

work does not make it a good idea. He stated a lot of hard work that went into

bombing World Trade Center in 2001, noting that the 24th Anniversary was

tomorrow. He stated that he would think that most people would not think that was a

good idea either. He stated that he wanted to be On the Record that Establishing an

Ethics Commission f or the Town of Ledyard was a horrible idea and that it they

should Vote it down; commenting that it was making more Big Government. Mr.

Irwin stated that during the last 20-years that Ledyard had two cases. Therefore, he

stated Establishing a Code of Ethics and Ethics Commission was a solution looking

for a problem. Thank you.

Mr. Jeff Eilenberger, 2 Village Drive, Ledyard, stated that he echoed Mr. Irwin’s

comments. He stated he did not know if anybody here remembered Hugh Hefner, and

the Spruce Goose which was a massive, wooden flying boat that flew only once in

1947 and was now on display at the Evergreen Aviation & Space Museum, in

Minnville, Oregon. He stated a lot of work went into Spruce Goose, noting that he

thought the Spruce Goose had a total flight of about 15 seconds, noting that Howard

Hughes was the wrong guy. He stated that he reviewed the proposed “Ordinance

Establishing a Code of Ethics and Ethics Commission for the Town of Ledyard”

dated September 8, 2025; and that what he sees was that they would be creating a lot

of attorney fees. He noted an Ethics Complaint in Montville that occurred in 2011 in

which they spent $18,000 on two Ethics Cases. He stated that Ledyard does not have

that kind of money to spend, noting that some say that would never happen. He stated

that he was totally against Establishing an Ethics Commission stating that it was not

wanted or needed. Thank you,

not needed. It's wanted.

Mr. Steve Munger, 12 Nutmeg Drive, Ledyard, thanked their elected officials for their

dedication, even though most of the time he though they were going in the wrong

direction, noting that he understands that serving their community takes some of

their personal time away from your family, and therefore, he always respected them.

He stated although he did not do a lot of research on the proposed “Ordinance

Establishing a Code of Ethics and Ethics Commission for the Town of Ledyard”

dated September 8, 2025; that he would support the comments made by the previous

two speakers. He stated the Town already have documents in place that allows the

Town Council to pursue the same exact thing they were trying to accomplish with the

establishing of an Ethics Commission that was going to cost the town money.

Therefore, he questioned the reason they do not just follow the procedures and

policies already in place and save the town some money. He stated that this Town

Council should stop dividing the community on every stupid thing that comes up. He

concluded his comments by stating “Be careful what your wish for”. Thank you.

Mr. Milton Dave Schroeder, Jr., 290 Whalehead Road, Gales Ferry, stated that he was

going to take a bit longer than the allotted three-minute limit, noting that Angela

Cassidy and Leanne Berry have conceded their three-minutes to him, if they were

allowed to do so, noting that he would keep his comments to under nine-minutes.

Councilor Buhle asked the Mr. Schroeder keep his comments as short as possible,

especially if he was going to read exactly what he already submitted in writing this

evening, noting that his written communication as part of the public record. Mr.

Schroeder stated that he would not be reading the written comments he submitted to

the Town Council prior to tonight’s meeting.

Mr. Schroeder thanked the Administration Committee for the opportunity to speak.

He stated that tonight he wanted to focus on Exhibit 5, “SCHROEDER - Proposed

Changes CoE 9_10_2025.” He stated because the Committee had the text already in

front of them, that he would not read his Exhibit 5 and instead he would explain why

his proposed changes were necessary - and why the draft Ordinance dated September

8, 2025 was not ready for adoption.

Mr. Schroeder proceeded by noting the following:

· Section 3. Applicability - covering town attorneys. As written, the Code does not

clearly apply to town attorneys. Yet they play a central role in advising and shaping

decisions. Because they serve as contractors, not employees, they fall through the

cracks unless we make this explicit. That loophole undermines accountability at the

very core of government. A simple phrase fixes this: include town attorneys as

covered contractors. Norwich does this; Ledyard should too.

· Section 4. Definitions - clarity around “contractor.” Right now, “contractor” is

undefined. That leaves open the question of who the Code actually covers. Norwich

solved this years ago by writing a clear, comprehensive definition into its ordinance.

Ledyard should borrow that language. Without it, we are left with ambiguity and

loopholes that will be exploited.

· Section 5. Conflict of Interest - consistency. The draft mentions officers and

employees, but not contractors. That omission means attorneys and other contract

staff would not be bound by conflict-of-interest rules. It’s a glaring oversight. This

isn’t a minor drafting detail. It’s the difference between a Code that actually applies

across the board and one that leaves powerful actors untouched.

· Section 7.1. Membership - protecting independence. Section 7.1 allows each political

party to hold two seats on a five-member Commission. At first glance that seems fair.

But combine it with the four-vote requirement for probable cause, and suddenly each

party has a built-in veto. That structure guarantees deadlock in any politically

sensitive case. Two votes alone can kill an investigation before it starts. Ask yourself:

how does the public trust a Commission that can’t even begin an investigation

because of partisan vetoes? They won’t. And perception matters just as much as

outcome. There are better models. One option is limiting each party to one seat,

requiring the majority of Commissioners to be independents or unaffiliated. Another

option is Norwich’s approach: five Page 1 of 3 regular members, four alternates, no

special partisan entitlements. That has worked there for decades.

· Section 7.3. Authority and Duties - the heart of the Commission. Section 7.3 is

framed so narrowly it reads as though the Commission has no real role. It lists

consulting the Town Attorney, requesting advisory opinions - but nowhere does it

clearly say the Commission can receive, investigate, and adjudicate complaints. That

omission creates a structural problem: what is this Commission even for, if not to

investigate? The ordinance must say it, clearly and explicitly. And one more point:

the draft states the Commission can only consult with an attorney if authorized by the

Town Council. That undermines independence. An Ethics Commission must be free

to seek outside counsel without political permission. Otherwise, you’ve hobbled it at

the start.

· Section 7.4. Filing of Complaints. The language in 7.4 could be misread to carve out

complaints that involve management of town employees. Yes, employment issues

should remain with management - but when violations of the public trust are alleged,

the Ethics Commission must have authority to investigate. A clarifying clause makes

that distinction cleanly.

· Section 7.5. Probable Cause - the danger of requiring four votes. Section 7.5 requires

four votes to find probable cause. That is too high. Why? Because combined with the

partisan membership rules, it gives each party veto power. It effectively creates two

tiers of accountability: some people can never be investigated, no matter the

evidence. Worse, it risks flipping the burden of proof. If only four votes are required

both to establish probable cause and to find a violation, then respondents are

essentially guilty until proven innocent. That is not how justice works. A simple

majority is the fair and workable standard. Anything else erodes legitimacy.

· Section 7.7. Final Decisions - aligning with the Charter.

Councilor Dombrowski stated that Mr. Schroeder’s time was up.

Mr. Schroeder stated he was almost done with his comments and proceed noting the

following:

· Finally, Section 7.7 should be corrected to align with the Town Charter. The Ethics

Commission should make findings and recommendations; discipline or removal rests

with the Council or the Mayor. That division of authority is already written into the

Charter. The ordinance must reflect it. Closing. At its core, an ethics code is about

protecting public trust. People need to know their government operates impartially,

that public office isn’t being used for personal gain, and that Page 2 of 3 the rules

apply equally to everyone - attorneys, employees, contractors, and elected officials

alike. This draft does not achieve that. It is too narrow, too politicized, and too weak.

Other towns have functioning Codes of Ethics that have stood for decades. We

should use those models instead of adopting a flawed ordinance that will fail the first

time it is tested. Commissioners - you’ve had over a year to refine this draft. It is still

not there. If these deficiencies are not addressed, the Town Council should reject it

outright and demand a workable code. The people of Ledyard deserve a Commission

that is independent, fair, and strong enough to hold everyone accountable. Mr.

Schroeder stated that anything less was unacceptable.

Ms. Joanne Kelley, 12 Thames View Pentway, Ledyard, stated that she did not plan to

speak this evening. However, she stated in listening to residents’ comments that she did

not understand how anybody could be against having Code of Ethics or an Ethics

Commission. She noted as a Realtor for thirty-years that they work in a field where

they operate under a very rigorous code of ethics; and she noted that nobody has

anything to fear from it. She stated when a complaint was made against somebody,

and they were in-fact found guilty of violating the code of ethics that 90% of the time

it was a simple misunderstanding of what the rules were that established the Code of

Ethics. She stated having a Code of Ethics would just give everybody a framework

under which they all understand that they were going to work under. She stated in a

small town like Ledyard that it was almost impossible for town government to do

business where there were not going to be some elements of Conflicts of Interest

where people's interests overlap. She stated having a Code of Ethics was mainly

about transparency and letting the residents know when there were conflicts of

interest.

Ms. Kelley went on to note that recently the Planning & Zoning Commission held a

Public Hearing regarding the Cashman’s Application for a development at the former

Dow Chemical/Styrenics Site in Gales Ferry. She stated a member of the Planning &

Zoning Commission had a direct Conflict of Interest because he had a job in which

he was paid to promote the interests of the Applicant. She stated eventually the

Commission Member recused himself, but that it took a little bit of an effort, noting

that she believed the Attorney had to recuse themselves as well, because there was

another Attorney within his Law Firm that also represented the Applicant. Therefore,

she stated that having a Code of Ethics and Ethics Commission would help with these

types of things, noting as she previously said that most of the time when there was a

violation, even when there was a guilty finding it was just a question of education,

stating that it may only require a letter of admonition. She stated that she though that

people were envisioning that this was going to be like people would be drawn and

quartered if they make a mistake. However, she stated that was not the purpose at all,

noting that it was about the Establishing a Code of Ethics as a framework rather than

the enforcement, although they would have to have enforcement. Therefore, she

stated that she just did not understand how anybody could be against this proposal,

noting that she was a volunteer; she sits on the professional standards committee, she

sits on the hearing panels for the Board of Realtors, and it's all volunteer, and there

was no money involved, stating that nobody gets paid for that. Thank you.

Mayor Fred Allyn, III, 362 Colonel Ledyard Highway, stated that he wanted to point

out the following:

· The Connecticut General Statutes identifies Code of Ethics, issues.

· The Town Charter Chapter III; Section 9 (page 11) - The power of investigation is

vested with the Town Council.- Mayor Allyn questioned the reason the Town

Council would want to relegate that authorization to another group of volunteers.

· Town Council has a Fraud Policy that covers a lot. Mayor Allyn noted on two

occasions the Town Council Investigated Tax Collector Yvonne Bell and Water

Pollution Control Authority Executive Assistant Cindy Cross who both embezzled

money. He stated in both cases the Town Council followed the process, and both

employees were prosecuted, served time, and the Town was made whole.

· Town Employee Handbook covers the following:

ü Conflict of Interest (page 20)

ü Outside employment (page 21)

ü Nepotism (page 20)

ü Appendix 8 covers the use of town vehicles.

Mayor Allyn continued by addressing the proposed the proposed “Ordinance

Establishing a Code of Ethics and Ethics Commission for the Town of Ledyard”

dated September 8, 2025; specifically Section 7; Subsection 8 “Penalties for

Violations of the Code of Ethics” in which they list the following Penalties:

ü Suspension without pay.

ü Demotion

ü Termination of employment

ü And/or removal from elected or appointed office;

Mayor Allyn stated that all of these Penalties directly go to against the town’s

collective bargaining agreements, stating that the Town would lose all of these cases

every time; as well as lose tens of thousands of dollars. He also stated that they

cannot removal of an elected official, explaining that here is no recall in the State of

Connecticut. Therefore, he stated the proposed “Ordinance Establishing a Code of

Ethics and Ethics Commission for the Town of Ledyard” dated September 8, 2025

was riddled with issues.

Mayor Allyn went on to state that he did not understand why the Administration

Committee had the Town Attorney review the draft Ordnance and provide his legal

recommendations to only to go back and make changes to the draft he provided. He

stated the Town spent $4,000 for the legal review; and it seemed like they were b ack

to the drawing board. He stated in looking at the proposed Ordnance that 99% of

what the Administration Committee was trying to cover already existed in the

documents he mentioned this evening. He stated that he did not know who has

looked at the Employee Handbook, stating that many of these things were covered,

noting that the Employee Handbook was on the town’s website. Thank you.

Ms. Patricia Riley, Ledyard Town Clerk, stated that she was present this evening to

address some of the issues she had with the proposed “Ordinance Establishing a

Code of Ethics and Ethics Commission for the Town of Ledyard” dated September 8,

2025 because of the Town Clerk’s involvement in the process regarding the filing of

Ethics Complaints and other associated work. She stated that no one from the

Administration Committee contacted her to discuss all of the Town Clerk’s

responsibilities provided in the proposed Ordinance.

Ms. Riley continued by addressing the following concerns:

· Freedom of Information Act (FOIA) concerns

ü Ordinance stated that Ethic Issues were not a matter of public record - Ms. Riley

stated that the proposed Ordinance names the Town Clerk as the person to receive

the Ethics Complaints. She would have like to have the opportunity to research

this with FOIA, the State of Connecticut and other towns if the Town Clerks were

doing this work.

ü Ethic Commission Member emails - Ms. Riley questioned whether the volunteers

who were serving on the Ethics Commission would be specifically told that they

could only use a town email account, noting that some people may use their

personal email address. She questioned what would happen to the paperwork if

they resign off from the Ethics Commission or their term ended.

ü Storing of the Ethic Complaints and Associated Documentation - Ms. Riley

questioned where she was supposed to store these records in her office so that

they were away from other staff, including the Assistant Town Clerk, if she, as

the Town Clerk, was the only one authorized to receive these documents.

ü Five-day turnaround time provided in the proposed Ordinance - Ms. Riley

questioned what would happen if she was on vacation for a week and they have a

weekend involved. Her five-days to provide the notification would be up. Then

someone could file an Ethics Complaint on her because she did not meet the

required timeline. She stated that she was not comfortable with being in that

position, because the Assistant Town Clerk could not take the paperwork. She

stated that it did not seem reasonable that the Assistant Town Clerk could not

receive the documentation. However, she stated if the Assistant Town Clerk

could take in the documentation that she would be privy to the information as

well, and then where was the confidential level here.

ü Records Retention Laws - Ms. Riley noted that the State Library has specific

record retention schedules.

ü What if someone files an Ethics Commission complaint on a member of the

Ethics Commission,. She questioned whether there was a process for that. there

was not a process for how to handle that.

ü Section 6 “Disclosure of Interests Required” stated that all Town Council

Members, Counselors, Board of Education Members, and the Mayor shall file

each year before or on January 1st a form to be prepared by the by the Town

Attorney, a statement under oath containing all of their financial interests, etc.

Ms. Riley questioned who was going to give that oath. Would it be a Conflict of

Interest for her to administer the Oath, if all of this was going through the Town

Clerk’s Office. She stated that this was something the Administration Committee

may want to think about, noting that perhaps the Forms should be Notarized

elsewhere before the Form is submitted to the Town Clerk’s Office.

ü Workflow - Ms. Riley stated that no one really understands the workflow. She

stated the Town Clerk’s Office was a two- person office. She stated that she

worked almost every single night. Therefore, she stated to have all of this work

fall under my office, without the Assistant Town Clerk involved it was not

realistic or reasonable.

Ms. Riley stated the proposed “Ordinance Establishing a Code of Ethics and

Ethics Commission for the Town of Ledyard” dated September 8, 2025 seemed

like a lot of unnecessary work when the Town Charter stated that all the Town

employees were under the Mayor; and the Board of Education employees and

Superintendent were under Board of Education, and the elected officials are under

the Town Council. She stated that it would only make sense for Ethics

Complaints to go to the proper Department or or Officials, and not through the

Town Clerk's Office to to create that.

Ms. Riley stated questioned whether the Administration Committee looked at

Code of Ethics in other towns such as Montville. She stated that these were just

some things that she thought the Administration Committee should look at before

they decided to move forward with the proposal as presented in the draft dated

September 8, 2025. Thank you.

Ms. Wendy Hellekson, 14 L Lakeside Drive, Ledyard, stated that she was not

planning on speaking tonight, but in hearing all these comments and concerns that

she wanted to say that as a governing body that it was extremely important to have

an Ethics Commission. She noted that the United States Supreme Court has no ethics

over it right now, and they were catching a lot of heat, and there were a lot of

conflicts of interest, and there was no redress for it, noting that was problematic. She

stated that she was a teacher and that she they had extremely strong ethics they

needed to follow. She also noted that she knew that Real Estate Agents have strong

ethics, stating that both of her parents worked in jobs where they had to follow ethics

things. She stated that she was extremely concerned that people in town would not

have want to have an Ethics Board to oversee and to make sure that everybody was

doing the right thing, regardless of party, regardless of who you are. She stated that it

was extremely important to make sure that things are running smoothly and correctly.

Thank you.

Mr. Tim Ryan, 62 Inchcliffe Drive, Gales Ferry, Town Councilor, attending

remotely via Zoom, stated like many others this evening that he was not planning on

speak on the proposed “Ordinance Establishing a Code of Ethics and Ethics

Commission for the Town of Ledyard” dated September 8, 2025. However, he stated

that he would echo a lot of the concerns that have been voiced already. He stated in

reviewing the proposal that it smacks of a solution looking for a problem. He noted

as the Mayor had stated, the town already have a number of documents, policies and

procedures that handle Ethics Concerns, concerns the chief among them were:

Connecticut General Statues; Town Charter; Employee Handbook, and their Fraud

Policy. He stated that Ledyard has not had any issues that these documents were not

able to address. He stated with that being said, that he did not want people to think

that he was not concerned about having ethics. However, he was merely saying that

the Town of Ledyard already had policies, procedures, and processes in place to

address those concerns. He stated if they were going to be forming an Ethics

Commission that it would require town resources and recurring expenses in the

town’s annual budget. He stated aside from fact that he did not feel that an Ethics

Commission was a necessary activity; that it seemed unwise for the Administration

Committee to disregard any comments or edits the Town Attorney provided in his

red line edited draft Ordinance. He stated the Town Attorney’s job was to protect the

town from liability; stating that was what the Town Attorney gets paid to do. He

stated that he also had concerns that the Town Clerk was not involved in process to

draft the proposed Ordinance, especially because of the required involvement of the

Town Clerk’s Office. He stated this was major misstep and needed to be corrected

before anything happens. Thank you.

Ms. Deborah Edwards, 30 Bluff Road - West, Gales Ferry, attending remotely via

Zoom, stated that she was in-favor of moving forward with the proposed “Ordinance

Establishing a Code of Ethics and Ethics Commission for the Town of Ledyard”

dated September 8, 2025. She stated during the past year that she has spoken a

couple of times on this subject. She stated although many of the issues were covered,

that not everything was addressed in the proposed Ordinance. She noted as Ms.

Kelley mentioned earlier this evening, there have been things going on in meetings

for a year and a half. She stated that they have been being told that there have never

been any problems; and now they were hearing well okay, there have been problems

in past years; but they were addressed. She stated without the proper Guidelines and a

Procedure to follow that many people would not know where to go first. She stated

that she thought having a Code of Ethics and Ethics Commission would be helpful

for anybody taking on an elected or an employee role, or even as a volunteer to know

that they have something to look at to know what is expected of them and what they

should steer clear from, noting that it would be like a handbook for the protection of

all. She stated that everybody has some kind of personal story they can relay noting

that she has been reading and hearing some of them. However, she stated if the town

had a Code of Ethics; Ethics Commission and Complaint Forms that they could look

up on the town website that it would help somebody if they really have a complaint,

noting that she was not talking about neighborhood gossip or confrontations because

somebody did not get their way. She stated that having a Code of Ethics and an

Ethics Commission was not going to create more confrontation. Thank you.

Ms. Angela Cassidy, 62 Hurlbut Drive, Gales Ferry, stated that they were not trying

to reinvent the wheel, noting that all the towns around Ledyard have Ethics

Commissions commenting that it was not abnormal. She stated that Ledyard does

have some issues with how the Code of Ethics was written; or how the Commission

it would be operating. However, she stated that this should be a group effort to come

together and create a system that worked for the town. She stated that this should not

be a partisan issue; this should be something that everybody wanted to protect, their

Town Councilors protect their government, and most of all to protect their citizens.

That's all.

Councilor Buhle thanked all the residents for their comments.

IV.

PRESENTATIONS / INFORMATIONAL ITEMS

None.

APPROVAL OF MINUTES

MOTION to approve the Administration Committee Meeting Minutes of August 6, 2025

APPROVED AND SO DECLARED

Kevin Dombrowski

RESULT:

MOVER:

April Brunelle

SECONDER:

Councilor Buhle stated without objection and in the interest of managing their time that

she would like to change the order of tonight’s business to address New Business before

getting into Old Business and their discussion regarding the proposed “An Ordinance

Establishing a Town of Ledyard Code Of Ethics” . The Administration Committee

agreed to address New Business before Old Business this evening.

VII. NEW BUSINESS

MOTION to approve the proposed revisions to the Library Administrative Assistant & Head

of Technical Services job description as presented in the draft dated September 2025.

RECOMMENDED FOR APPROVAL

April Brunelle

RESULT:

MOVER:

Kevin Dombrowski

SECONDER:

Dombrowski, Buhle and Brunelle

AYE:

MOTION to approve the proposed revisions to the Library Technician I – Youth Services job

description as presented in the draft dated September 2025.

RECOMMENDED FOR APPROVAL

Kevin Dombrowski

RESULT:

MOVER:

April Brunelle

SECONDER:

Buhle and Brunelle

Dombrowski

AYE:

NAY:

MOTION to reappoint the following members the Inland Wetland & Water Courses

Commission for a two (2) year term ending October 31, 2027:

Mr. Michael Marelli (D) 4 Lee Brook Drive 193 Iron Street, Ledyard

Mr. Justin DeBrodt (U) 5 Erins Way, Ledyard.

RECOMMENDED FOR APPROVAL

April Brunelle

RESULT:

MOVER:

Kevin Dombrowski

SECONDER:

Dombrowski, Buhle and Brunelle

AYE:

MOTION to appoint Mr. James Thompson (D) 6 Pennywise Lane, Ledyard, to the Inland

Wetland & Water Courses Commission to complete a two (2) year term ending October 31,

2026 filling a vacancy left by Ms. Lynmarie Thopmpson.

RECOMMENDED FOR APPROVAL

Kevin Dombrowski

RESULT:

MOVER:

April Brunelle

SECONDER:

Dombrowski, Buhle and Brunelle

AYE:

MOTION to reappoint the following members to the Library Commission for a two (2) year

term ending November 7, 2027:

Mr. John Bolduc (U) 14 Monticello Drive, Gales Ferry

Ms. Ellin M. Grenger (D) 15 Bittersweet Drive, Gales Ferry

Ms. Cynthina Wright (D) 6 Larule Leaf Drive, Gales Ferry

Ms. Elizabeth Rumery (D) 2 Bluff Road, Gales Ferry.

RECOMMENDED FOR APPROVAL

April Brunelle

RESULT:

MOVER:

Kevin Dombrowski

SECONDER:

Dombrowski, Buhle and Brunelle

AYE:

Any New Business proper to come before the Committee

None.

VI.

OLD BUSINESS

Discussion and possible action to review and consider text amendments to the proposed “An

Ordinance Establishing a Town of Ledyard Code of Ethics And Ethics Commission” in

preparation to present at a Public Hearing.

MOTION to recommend the Town Council adopt a proposed “An Ordinance

Establishing a Town of Ledyard Code of Ethics and Ethics Commission” as presented

in the draft dated September 8 10, 2025.

DRAFT: 09/8 10/2025

Ordinance # ______________

AN ORDINANCE ESTABLISHING A TOWN OF LEDYARD

CODE OF ETHICS AND ETHICS COMMISSION

Be it ordained by the Town Council of the Town of Ledyard:

Section 1. Authority

In accordance with Chapter III of the Town Charter, there is hereby established a

Town of Ledyard Code of Ethics and Ethics Commission.

Section 2. Declaration of Policy and Purpose

The trust of the public is essential for government to function effectively. The

proper operation of the Town government requires that Town officials, and Town

employees be independent, impartial, and responsible to the people; that

governmental decisions and policies be made in the proper channels of governmental

structure; that public office and employment not be used for personal gain; and that

the public has confidence in the integrity of its government.

Therefore, herewith is an established Code of Ethics for all Town officials and

Town employees. The purpose of this code is to establish standards of ethical

conduct for all such officials and employees, and for those who serve or conduct

business with the Town of Ledyard, to assist those parties under the jurisdiction of

the Ethics Commission by establishing guidelines for their conduct in order to

maintain a tradition of responsible and effective public service; and to establish rules

of procedure to be followed by the Ethics Commission in receiving, adjudicating, and

reporting on alleged violations of the Code of Ethics.

Section 3. Applicability

The Code of Ethics shall apply to all Town officials, including members of the Board

of Education, and all Town and Board of Education employees.

Section 4. Definitions

As used in this ordinance, the following words or phrases shall have the meanings

indicated:

1. “Complainant” means any person who signs a complaint under penalties of false

statement alleging a violation of this Code.

2. “Confidential Information” means information acquired by a Town official or Town

employee in the course of and by reason of performing an individual’s official duties

and which is not a matter of public record or public knowledge.

3. “Financial Interest” means:

a. any interest that has a monetary value of more than one hundred dollars ($100.00)

in any calendar year and is not common to the other citizens of the Town;

b. pecuniary or material benefit accruing to a Town official or Town employee,

spouse or minor child of an official or employee of the Town as a result of a

contract, transaction, zoning decision or other matter which is, or may be, the

subject of an official act or action by or with the Town of Ledyard except for such

contracts of transactions which by their terms and by the substance of their

provisions confer the opportunity and right to realize the accrual of similar

benefits to all persons and/or property similarly situated;

c. shall be deemed to exist if any Town official, Town employee, immediate family

of a Town official or employee might, directly or indirectly, derive financial gain

or suffer loss from any purchase, contract, transaction, zoning decision, or other

matter involving any such Town office, board, commission, authority or

committee, and shall also be deemed to exist if a business or professional

enterprise in which the Town official or employee has any financial interest as

owner, member, partner, officer, employee or stockholder or has any other form

of participation which will be affected by the outcome of the matter under

consideration.

4. “Gift” means anything of economic value in excess of one hundred dollars

($100.00), including but not limited to entertainment, food, beverage, travel, and

lodging. A gift does not include:

a. A political contribution that is otherwise reported in accordance with the law.

b. Services provided by persons volunteering their time.

c. A commercially reasonable loan that is made on terms not more favorable than

loans made in the ordinary course of business.

d. A gift received from a member of a person’s immediate family or fiancé.

e. Goods or services which are provided to the municipality and facilitate

government actions or functions.

f. A certificate, plaque, or other ceremonial award.

g. A rebate or discount on the price of anything of value made in the ordinary course

of business, without regard to that person’s status.

h. Printed or recorded information germane to municipal action or functions.

i. An honorary degree

j. Costs associated with attending a conference or business meeting and/or the

registration or entrance fee to attend such conference or business meeting in

which the Town official or Town employee participates in his or her official

capacity.

k. Any gift provided to a Town Official or Town Employee or to an immediate

family member of a Town Official or Town Employee for the celebration of a

major life event provided any such gift provided to an individual does not exceed

one thousand dollars ($1,000.00) in value. A major life event shall include, but

not be limited to, a ceremony commemorating an individual’s induction into

religious adulthood such as a confirmation or bar mitzvah; a wedding; a funeral;

the birth or adoption of a child; and retirement from public service or Town

employment.

5. “Immediate family” means spouse, fiancé, child, parent, grandchild, brother, sister,

grandparent, niece, nephew, daughter-in-law, son-in-law, mother-in-law,

father-in-law, sister-in-law, brother-in-law, or anyone living in the same household.

6. “Respondent” means any person accused of violating this Code.

7. “Town Official” means any person holding elective or appointive office in the

government of the Town, including members of the Board of Education.

8. “Town Employee” means any person receiving a salary, wages, or stipend from the

Town or the Board of Education for services rendered, whether full-time or part-time.

Section 5. Conflict of Interest Provisions

1. A Town official, Town employee, or any member of his or her immediate family

shall not engage in or participate in any business or transaction, nor have an interest,

direct or indirect, which is incompatible with the proper discharge of that person or

persons’ independent judgement or action in the performance of that person or

persons’ official duties.

2. A Town official or any member of his or her immediate family shall not have a

financial interest in any contract or purchase order for any supplies, materials,

equipment or contractual services furnished to or used by the board, agency or

commission of which that person is an elected or appointed member.

3. A Town employee or any member of his or her immediate family shall not have a

financial interest in any contract or purchase order for any supplies, materials,

equipment, or contractual services that is within the purview of such Town employee.

4. The Mayor of the Town of Ledyard and members of the Town Council of the Town

of Ledyard, members of the Board of Education of the Town of Ledyard, and any

members of their immediate family shall not have a financial interest in any contract

or purchase order for any supplies, materials, equipment, or contractual services

furnished to or used by the Town of Ledyard.

5. A Town official or employee shall refrain from voting upon or otherwise

participating in any matter on behalf of the municipality if he or she, a member of his

or her immediate family, or a business with which the person is associated has a

financial or personal interest in the transaction or contract, including but not limited

to the sale of real state, material, supplies, or services to the municipality. If such

participation is within the scope of the Town official’s or Town employee’s

responsibility, he or she shall be required to provide written disclosure, that sets forth

in detail the nature and extent of such interest.

6. A Town official or Town employee shall not accept or receive, directly or indirectly,

from any person or business to which any contract or purchase order may be awarded

by the Town of Ledyard or any of its boards, agencies, or commissions any money,

rebate, or gifts, or any promise, obligation, or contract for future reward or

compensation.

7. No Town officials or employees shall accept a gift or engage in private employment

or render services when the gift, employment, or services are incompatible with the

proper discharge of the official duties of the Town official or Town employee, or

could tend to impair independence of judgement or action by the Town official or

Town employee, in the performance of his or her official duties. If a prohibited gift

is offered to a Town official or a Town employee, he or she shall refuse it, return it,

or pay the donor the market value of the gift.

8. To avoid even the appearance of impropriety or creation of a situation that would be

contrary to the declared policy and purpose of this Code, a Town official or a Town

employee, not otherwise restrained by the Code, shall exercise care when appearing

before other Agencies and shall disclose whether he or she is appearing in his or her

official capacity or as a private citizen.

9. A Town official or employee who have a financial or personal interest in any

transactions or contract with the Town, including but not limited to the sale of real

estate, materials, supplies, or services to the Town, on which that person or persons

may be called upon to act in that persons official capacity shall not vote or otherwise

participate in the transaction on behalf of the Town. The Town official or employee

shall declare on the record that he or she has or have a conflict of interest.

10. No Town official or Town employee shall solicit or accept a gift from any person or

business entity which is interested directly or indirectly in any business transaction or

pending matter that is within the purview of such Town official or Town employee.

11. Town officials and Town employees shall not use Town owned vehicles, equipment,

facilities, materials, or property for personal convenience or profit.

12. No Town official or Town employee shall disclose or use confidential information

acquired in the course of and by reason of his or her official duties for personal or

financial gain or for the personal or financial gain of a member of his or her

immediate family.

13. No Town official or Town employee may directly hire or supervise a member of his

or her immediate family or participate in influencing the appointment or hiring of his

or her immediate family.

14. No former Town official shall represent anyone before any Town agency, board,

commission, council, or committee in which he or she was formerly an elected or

appointed member for a period of one (1) year following the end of such former

member’s service on such agency, board, commission, council, or committee.

15. No former Town employee shall represent anyone before any Town agency or

department for which he or she was formerly employed for a period of one (1) year

following the end of such former employee’s employment with the Town.

Section 6. Disclosure of Interests Required

1. Any Town official or Town employee who has a private financial interest in any

action, legislative or otherwise, by any Town agency and who is a member of,

participates in discussion with or give an official opinion to such Town agency shall

disclose on the written records of such agency the true nature and extent of such

interest. This section shall not apply to:

a. Contracts awarded to the lowest responsible bidder after public advertisement.

b. Unpaid appointed officials during a declared state of emergency.

c. Matters requiring disclosure to or approval by a court.

d. The Town Attorney, Town Engineer, or similar Official, who is participating in

or offering an opinion on behalf of said agency, and whose financial interest is

merely in being paid for such services.

2. All Town Councilors, Board of Education members, and the Mayor shall, on or

before January 1st each year, file with the Town Clerk, on a form to be prepared by

the Town Attorney, a statement, under oath, containing the following information:

a. All real estate located within the Town of Ledyard owned by such elected official

or held under a lease for a term exceeding five years, excluding, however, his or

her principal residence. The foregoing shall also apply to real estate owned or

leased, as aforesaid, by a corporation, trust or partnership in which any such

elected official is the legal or equitable holder of at least 5% of the legal or

equitable interest in said corporation, trust, or partnership.

b. The names of any firm, proprietorship, partnership, or corporation of which said

elected official is an employee or in which such elected official holds at least a

five (5) percent interest, and which firm, proprietorship, partnership, corporation,

or limited liability corporation has sold or supplied goods or services in excess of

ten thousand dollars ($10,000) per annum to the Town of Ledyard during the two

years immediately preceding such official’s election to office.

c. Any income, fees, salary, or wages directly or indirectly, received by such official

from the Town of Ledyard or its political subdivisions during the two years

immediate proceeding such official’s election to public office.

Section 7. Establishment of an Ethics Commission

1. Membership

The Ethics Commission shall be comprised of five (5) regular members and two (2)

alternate members. All members of the Ethics Commission shall be electors of the

Town.

a. No more than two (2) Regular Members may be affiliated with any one political

party. Both Alternate Members may not be affiliated with the same political

party. At least one Regular Member shall be registered as an unaffiliated.

b. No regular member or alternate member of the Ethics Commission shall:

i. Be a Town official or Town employee of the Town of Ledyard or be a

member of the immediate family of any Town official;

ii. Have held any elected Town or State office for a period of one (1) year prior

to being appointed to the Ethics Commission.

iii. Be a member of a Town committee or commission.

iv. Serve as a member of another Town agency, board, commission, council, or

committee.

v. Have been employed by the Town for a period of one (1) year prior to being

appointed to the Ethics Commission.

vi. Have any financial interest in matters before the Town or the Board of

Education;

vii. Have been found in violation of any federal, state, municipal, or professional

Code of Ethics.

2. Terms of Appointment

a. Members shall be appointed by the Town Council for a term of three (3) years

and shall serve until their successor has qualified or is removed by the Town

Council.

b. In making the original appointments under this ordinance, the Town Council shall

designate two (2) regular members to serve for three (3) years; two (2) regular

members to serve for two (2) years; one (1) regular member to serve for (1) year;

one (1) alternate member to serve for three (3) years; and one (1) alternate member

to serve for two (2) years. Thereafter, vacancies shall be filled for a three (3) year

term.

c. Inaugural members shall be eligible to serve two (2) additional three (3) year term

beyond his or her initial appointment.

d. Any vacancy on the Ethics Commission, other than by expiration of term, shall be

filled for the unexpired portion of the term by the Town Council.

e. The Town Council may remove members for cause and fill the vacancy in

accordance with the Town Charter. Cause for removal shall include, but is not

limited to, an unexcused absence from three (3) consecutive meetings. It shall be

the responsibility of the Chairman of the Ethics Commission to notify the Town

Council when a member has not properly performed his or her duties.

f. Within thirty (30) days of the appointment of the Ethics Commission, an

organizational meeting shall be held at which members shall choose a Chairman,

Vice-Chairman, and a Secretary.

3. Authority/Duties

The Town of Ledyard Ethics Commission shall be authorized to perform the

following:

a. To consult with the Town Attorney or another attorney hired by the Ethics

Commission if so authorized by the Town Council.

b. To request that the Town Attorney provide advisory opinions.

4. Filing of Complaints

A complaint alleging any violation of the Code of Ethics shall be made on a form

prescribed by the Ethics Commission and signed under penalty of false statement.

The form shall be delivered to the Town Clerk who shall transmit a copy of the

complaint to the Chairperson of the Ethics Commission and the respondent within

five (5) days of receipt of the complaint. The Ethics Commission shall also notify the

respondent that it will conduct a probable cause determination and invite the

respondent to provide any information the respondent deems relevant to the Ethics

Commission’s determination of probable cause.

No complaint may be made under the Code of Ethics unless it is filed with the Ethics

Commission within three (3) years after the violation alleged in the complaint has

been committed.

The Complaint shall include:

a. Name of the person accused (respondent)

b. Name of the person filing the complaint.

c. The specific acts alleged to constitute a violation of the Code of Ethics and when

said actions occurred.

In the application of this Code of Ethics, care will be given to distinguish between

concerns of management of Town employees and violations of the public trust. The

daily management of employee performance is the responsibility of the Mayor or

School Superintendent in the case of the employees of Ledyard Public Schools.

Personnel policies should be the first guide in those areas where applicable.

Similarly, the routine activities of the Commission should be governed by its rules

and regulations.

5. Evaluation and Acknowledgement

a. Within sixty (60) business days of the receipt of a complaint, the Ethics

Commission shall review and determine whether there is probable cause that a

violation of the Code of Ethics has occurred. A finding of probable cause means

that based on a review of the available information the Ethics Commission

determines that reasonable grounds exist to believe that the respondent engaged

in prohibited conduct by the Code of Ethics. If the Ethics Commission does not

make a finding of probable cause, the complaint shall be dismissed and a copy of

its decision shall be mailed to both the complainant and the respondent. Unless

the Ethics Commission makes a finding of probable cause, a complaint alleging a

violation of this Code of Ethics shall be confidential except upon the request of

the respondent.

b. If the Ethics Commission makes a finding of probable cause which shall require

four (4) affirmative votes, it shall so advise both the complainant and the

respondent within ten (10) business days of its finding and begin a formal

investigation process.

6. Hearings

a. If the Ethics Commission decides that probable cause of a violation of the Code

of Ethics exists, it will conduct a public hearing to determine whether or not a

violation occurred in accordance with Uniform Administrative Procedure Act

(“UAPA”) (See Chapter 54 of the Connecticut General Statutes). At the hearing,

the respondent will have the right to be represented by legal counsel, to present

evidence and witnesses, and compel attendance of witnesses and the production

of books, documents, records, and papers, and to examine and cross-examine

witnesses, and inspect and copy relevant and material records, papers, and

documents not in such person’s possession. Hearings are not governed by the

legal rules of evidence, and any information relevant to the matter may be

considered. The Ethics Commission will respect the rules of privilege recognized

by the law. Not later than ten (10) days before the start of the hearing, the Ethics

Commission will provide the respondent with a list of its intended witnesses.

The Ethics Commission will make a record of the proceedings.

7. Final Decisions

a. Decisions by the Ethics Commission that a person is in violation of the Code of

Ethics must result from the concurring vote of four (4) of its members.

b. The Ethics Commission must render its decision within sixty (60) days of the

closing of the hearing.

c. Such finding and memorandum will be deemed to be final decision of the

commission for the purposes of the UAPA. The respondent may appeal to the

superior court in accordance with the provision of Section 4-183 of the

Connecticut General Statutes.

d. If the Ethics Commission determines that the Code of Ethics was violated, it will

provide the respondent, the Mayor, and the Ledyard Town Council with a copy of

its findings and memorandum within ten (10) days after its decision. It will also

advise the respondent of his or her right to appeal the decision pursuant to Section

4-183 of the Connecticut General Statutes.

8. Penalties for Violations of the Code of Ethics

A violation of the Code of Ethics may lead to any one or a combination of the

following penalties:

a. Order to cease and desist the violation;

b. Pay a civil penalty of up to the maximum amount permitted by State law;

c. Censure;

d. Suspension without pay;

e. Demotion;

f. Termination of employment and/or removal from elected or appointed office;

g. Restitution of any pecuniary benefits received because of the violation

committed;

Section 8. Severability

If any part of this Code or Ordinance shall be held by a court of competent

jurisdiction to be invalid, such holding shall not be deemed to invalidate the

remaining provisions hereof.

Adopted by the Ledyard Town Council on: ____________

________________________

Gary St. Vil, Chairman

Approve/Disapprove on: _____________

___________________________

Fred B. Allyn, III, Mayor

Moved by Councilor Buhle, seconded by Councilor Brunelle

Discussion: Councilor Buhle stated at the Administration Committee’s August 6,

2025 she asked the Administration Committee to review Attorney Matt Ritter’s July

14, 2025 recommended changes to the proposed draft “Ordinance Establishing a

Code of Ethics and Ethics Commission for the Town of Ledyard” and to provide

suggestions for discussion at tonight’s meeting. She stated that she has provided an

updated draft dated September 8, 2025 for tonight's review and discussion, noting

that where possible she adopted all of the town attorneys, changes noting that about

80% of the Attorney Ritter’s proposed changes were included in the September 8,

2025 draft, because they made sense and was worded better. if not. She stated that

Attorney Ritter put a lot of work into the draft and therefore, she stated that she kept

a large chunk, chunk of it.

Councilor Buhle went on to stat that right now she had seven towns Code of Ethics

on her computer. She stated the proposed Ordinance Establishing a Code of Ethics

and Ethics Commission for the Town of Ledyard” provide in the September 8, 2025

draft was an amalgamation of the following town’s Glastonbury, Stonington,

Norwich, New London, Seymour, Griswold, and Essex. She stated that Councilor

Garcia-Irizarry had started drafting the proposed Ethics Ordinance and that she

provided an exceptional framework, noting that this Administration Committee

continued to work on the proposed Ordinance, stating that they worked harder to

make sure that they were creating something that was not something that was written

by Artificial Intelligence (AI). She stated that the proposed “Ordinance Establishing

a Town of Ledyard Code of Ethics and Ethics Commission” was not written by their

imaginations. She stated it was written using chunks from other towns Ethics

Ordinances to come up with the draft Ordinance.

Councilor Buhle continued by addressing the following:

· Section 6 “Disclosure of Interest Required”

“Any Town official or Town employee who has a private financial interest in any

action, legislative or otherwise, by any Town agency and who is a member of,

participates in discussion with or give an official opinion to such Town agency shall

disclose on the written records of such agency the true nature and extent of such

interest. This section shall not apply to:………”(see above)

Councilor Buhle stated during her telephone conversation with Attorney Ritter that

although he stated that he would recommend removing Section 6; that it was not

illegal. She stated that Attorney Ritter questioned whether she really wanted to

require all town officials or town employees who had a private financial interest to

be required to disclose in writing the nature and extent of such interest, noting that

Attorney Ritter stated that they were going to have people that do not want to run for

office. She stated that her response was that she liked the provision and that she had

no problem with telling anyone about what businesses or property she owned; or if

she was a major shareholder of something; and that she was not afraid of disclosing

that. She noted that Attorney Ritter responded to her comments by stating; “Okay,

you can do and it’s not illegal legal. But you're probably going to dissuade people

from participating in government”; an that she responded stating” This only applies

to elected officials excluding the justices of the peace” . However, she stated when

she received Attorney Ritter’s July 14, 2025 edited draft Ordinance that he had struck

the provisions of Section 6 “Disclosure of Interest Required” She stated because she

thought it was important she added the text back into the proposed Ordinance.

· Section 8 Penalties for Violations of the Code of Ethics (f)

Termination of employment and/or removal from elected or appointed office;

Councilor Buhle noted Mayor Allyn’s comment that they could not terminate and/or

remove people from elected or appointed office. She stated that realizes that Mayor

Allyn was correct. She stated that if the Code of Ethics was violated that it could lead

to any or a combination of the penalties listed. She stated that was not to say that

every violation leads to that penalty, and that was not to say that was what that

penalty was for a Union employee, or a town employee with that situation. She stated

the language Termination of employment was included in Attorney Ritter red line

draft; but that he did strike the following language and/or removal from elected or

appointed office’ . Therefore, she was fine with removing this language from the

draft Ordinance.

Councilor Buhle stated so this was where they were at, noting that she was extremely

concerned that they were going to let perfect get in the way of good; and that if they

do not pass an Ethics Ordinance that in two-years from now they were going to wish

that they had. She stated that she did not write the proposed “so that we could

specifically attack one person in town or go after an opponent, or something like that.

She stated that was designed to protect the town in the future, noting that the

proposed Ordinance does fall in line with the Town Charter, pointing out that

Chapter IX, Section 6 Stated “The Town Council may buy ordinance, specify what is

or what is not, a conflict of interest for officials and employees of the town”.

Councilor Buhle stated based on questions she has received during the past

two-weeks she prepared a “Frequently Asked Questions and Answers Sheet for “An

Ordinance Establishing a Town of Ledyard Code of Ethics and Ethics Commission”.

She stated because of the number of residents that spoke this evening and because

they were under a time constraints, noting that the Town Council had a Special

Meeting scheduled for 6:30 p.m. following this meeting, that she would not review

them, but that they would be attached to the minutes of this meeting.

Frequently Asked Questions “An Ordinance Establishing a Town of Ledyard

Code of Ethics and Ethics Commission” Q&A

as written by Jessica Buhle

These are my responses and opinions on this ordinance, and I do not speak for the

Council or Administration Committee as a whole. I have received and heard these

questions several times and wanted to take the time to address them one by one in a

format that is conversational and easy to understand.

Q: Doesn’t the Town Charter cover us in these situations? Why do we need an

Ordinance and a Commission?

A: The Town Charter has provisions which cover Investigation and Conflicts of

Interest. The Charter does not outline specifically what constitutes a Conflict of

Interest, and also requires the Town Council to vote to perform an Investigation. I

personally feel that the Council would struggle to remain impartial against other

councilors or Town officials there may be speculation against. Creating a Code of

Ethics outlines what constitutes a Conflict of Interest in participation in the town, and

creates a nonpartisan Commission which can respond to any filed complaints. Per

Chapter 9, Section 6 of the Town Charter, “The Town Council may by ordinance

specify what is, or what is not, a conflict of interest for officials and employees of the

Town.” This ordinance falls in line with that language.

Q: Will this result in political weaponization to attack people anyone disagrees

with politically?

A: I believe this Code of Ethics is specific enough to outline what does and does not

constitute a breach of the Code of Ethics, and Complaints are filed under penalty of

false statement, so I do not believe frivolous complaints will be filed to weaponize

the Commission against anyone politically. In fact, as mentioned in the above

question, I believe the current system has more potential to be politically weaponized,

as current investigation requirements require a majority of the Council, a partisan

group.

Q: The Town Attorney recommended a different version. Why are you supporting

this version?

A: Where possible, we adopted all the Town Attorney’s recommendations. The

Town Attorney had removed provisions that we had considered important to the

submitted draft Ordinance (specifically section 6, which he had verbally advised me

was legally admissible). There are limited other sections which were modified or

re-added after verifying they were following Connecticut General Statutes. This

proposed draft incorporates most of the Town Attorney’s recommendations while

maintaining the provisions we felt would best protect the town.

Q: Will this cost us any money?

A: While legal and other fees may be incurred through investigations and legal

advisory, all commissioners are unpaid volunteers, and this Ordinance has the

potential to protect the towns’ reputation and integrity. Many Ethics Commissions

across the state meet very rarely and very rarely have complaints; I expect us to

follow a similar pattern.

Q: Who does this Ordinance apply to?

A: As it is written, this Ordinance applies to all Town officials, elected or appointed,

including all members of committees, commissions, and boards, and all Town

employees, including Board of Education members and employees. Some provisions,

such as the disclosure statement in Section 6, only apply to Town Councilors, Board

of Education members, and the Mayor.

Q: I am a volunteer or employee for the town. Should I be worried about someone

filing a false complaint against me?

A: The Ordinance as it is written only pertains to ethical misconduct relating to

financial benefit of the Respondent. As mentioned, complaints are filed under penalty

of false statement. The Ordinance cannot be used to file a complaint against someone

if they are unhappy with a decision or unhappy with the service they have received at

a town office or event. After a complaint is received, the process to determine

Probable Cause is entirely confidential, and any complaints that are unwarranted and

have no Probable Cause will be dismissed and remain confidential.

Q: We don’t need this. Why waste any time creating a commission?

A: We have low crime rates in Ledyard, but we have an excellent police department

to respond when we need them. I’ve never had a fire in my home (and fingers crossed

I don’t in the future), but I want Ledyard to have a great fire department. Most in this

town believe we have an ethical town government, but I want to make sure we have

ordinance in place to protect us from future unscrupulous behavior and to set the

standard for what our town considers financial benefit and conflict of interest. Al

MOTION to set a Public Hearing (Hybrid Format - Video Conference and In-Person) Public

Hearing date to be held on October 22, 2025 at 5:00 p.m. to be held in Council Chambers,

Town Hall Annex, 741 Colonel Ledyard Highway, Ledyard, Connecticut, to receive

comments and recommendations regarding a proposed “An Ordinance Establishing a Town

of Ledyard Code Of Ethics And Ethics Commission” ..

Moved by Councilor Buhle, seconded by Councilor Brunelle

Discussion: The Administration Committee agreed to change the date of the Public

Hearing from October 8, 2025 at 6:15 p.m. to September 24, 2025 at 5:00 p.m. as a

“friendly amendment”

In accordance with the Town Charter; Section 5

“Section 5. Public Hearing On, Publication Of, And Passage Of Ordinances

Unless otherwise required by State statutes, at least one public hearing, notice of

which shall be given at least five (5) days in advance by publication on the Town

Website and by posting a notice in a public place, shall be held by the Town Council

before any ordinance shall be passed”.

VOTE: 2 - 1 Approved and so declared

RECOMMENDED FOR APPROVAL

Jessica Buhle

RESULT:

MOVER:

April Brunelle

SECONDER:

Buhle and Brunelle

Dombrowski

AYE:

NAY:

Any Old Business proper to come before the Committee.

None.

ADJOURNMENT

Councilor Brunelle moved the meeting be adjourned, seconded by Councilor

Dombrowski.

VOTE: 3 - 0 Approved and so declared, the meeting was adjourned at 6:25 p.m.

Respectfully submitted,

Jessica Buhle

Committee Chairman

Administration Committee