741 Colonel Ledyard Highway

Ledyard, CT 06339

TOWN OF LEDYARD

Administration Committee

Meeting Minutes

http://www.ledyardct.org

Chairman S. Naomi

Rodriguez

Special Meeting Please Note Time 5:00 p.m.

Wednesday, May 14, 2025

5:00 PM

Town Hall Annex- Hybrid Format

In -Person: Council Chambers, Town Hall Annex Building

Remote Participation: Information Noted Below:

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659490

CALL TO ORDER

the Meeting was called to order by Councilor Buhle at 5:08 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

Kevin Dombrowski

Jessica Buhle

Present:

April Brunelle

Excused:

S. Naomi Rodriguez Town Council Chairman

Deborah EdwardsResident

Roxanne Maher Administrative Assistant

III.

APPROVAL OF MINUTES

MOTION to approve the Administration Committee Minutes of April 9, 2025

Moved by Councilor Dombrowski, seconded by Councilor Buhle

VOTE:

2- 0 Approved and so declared

APPROVED AND SO DECLARED

Kevin Dombrowski

RESULT:

MOVER:

Jessica Buhle

SECONDER:

IV.

BUSINESS OF THE MEETING

Discussion and possible action to create an Ethics Commission for the Town of Ledyard.

Councilor Buhle stated the purpose of tonight’s meeting was to focus on reviewing

and editing the proposed “Ordinance to Establish an Ethics Commission for the

Town of Ledyard”. She stated that she and Councilor Dombrowski each

independently reviewed the proposed Ordinance that Councilor Garcia-Irizarry spent

many hours working to draft.

· Confidentiality - Councilor Dombrowski stated that his biggest concern with the

September 9, 2024 draft Ordinance was the confidentiality aspect; and how the

complaints would be handled. He stated as currently written “All hearings shall be

open to the public and recorded”, as determined by the Ethics Commission. He

stated that he would assume the hearing would be conducted after the “Investigation

of Probable Cause” had been completed. However, he stated the proposed

Ordinance stated that the Commission would determine if a “violation of the code

occurred”. However, he stated that this should still be at the confidentiality level but

that the initial draft ordinance said that “it shall be open to the public”.

Councilor Dombrowski went on to state that his objection was not the Ethics

Commission, noting that it was the way the proposed Ethics Commission Ordinance

was worded. He stated that it looked like it was finger pointing, because it did not

keep matters confidential. He addressed the importance for the members of the Ethics

Commission to feel safe in discussing the claims and in making their determinations

based on the facts; without having every meeting open to the public.

Councilor Buhle stated that she understood Councilor Dombrowski’s concerns and

that she agreed with comments regarding confidentiality, and the importance to

review claims and to hear evidence in executive session, noting that there may be

some false claims. She stated you know how word of mouth goes, and that she did

not want people getting tried in the court public opinion, just because somebody

made an accusation. She noted in the past year and a half that she has served on the

Town Council that she had heard comments that was misinformation and that she has

told people that they had misinformation.

Chairman Rodriguez stated that she has heard comments about the Town Council

paying for things that the Town Council did not pay for, noting that they of that it was

paid by out of our pocket. Therefore, she stated if a false accusation comes, then

confidentially, they could provide a bank statement or other source to prove that the

accusation was false.

Councilor Buhle stated that she understood their determination to make sure that the

work of the Ethics Commission does not result in the misinformation that they

discussed this evening. However, she stated that she also wanted to make sure they

were setting up a process that would protect the town for decades to come, with

perhaps some changes in the future, because she could not know where they would be

1- years from now. She went on to state that the biggest deterrent in establishing and

Ethics Commission was trusting that the volunteer Commission Members would

make the right choices. She stated what they do not need was a group of people

making comments, or coming to the meetings to snicker in the background, or make

comments such as “Oh, that's a lie”. She stated that she did not know whether they

had residents that would do that. However, she stated the proposed Ordinance needed

to be written to make sure they were following ethical procedures and making sure

that what they were doing would not destroy someone’s reputation over a complaint.

She stated that they could watch people go through an entire trial and be found not

guilty, but that some people would say “yeah, okay”. She stated that she did not want

to destroy somebody's livelihood or somebody's business or career over an ethical

complaint.

· Governing State Statutes - Chairman Rodriguez requested clarification regarding the

state statute Councilor Dombrowski was referring to. Councilor Dombrowski stated

that CGS Chapter 10; Section 7-148(c)(10)(B) “Investigation Conducted Prior to

Probable Cause, Finding Shall be Confidential, except at the Request of the

Respondent”. He stated although he was paraphrasing that it essentially stated: “If the

investigation is confidential, the allegation is blatant. Any information supplied to or

received from the office of State ethics will not be disclosed during the investigation

to any third party” He stated that this was the State Statute they should be following.

He also noted that the CGS Chapter 90 “Municipal Powers” Section 7- 1-148 was

also helpful.

Councilor Buhle stated in reading other town’s Ethic Commission Ordinances that

she found Middlebury’s Code of Ethic easy to read. She suggested using the

language from Middlebury for their definition of “Financial Interest”. She stated that

they all own property in this town and they all have things going on. Therefore, she

stated it was hard to find the balance between what was overstepping; or what was

just running a business, etc. She noted the following language:

· Financial Interest: No member of the Board of Selectmen or any other officer or

employee of the Town shall be financially interested, directly or indirectly, either as

principal, surety, officer, partner or otherwise, except as a minority stockholder or

except as a director in a corporation, in any contract with sales to or purchases from

the Town. The provisions of this section shall not apply to any contract awarded to

the lowest responsible bidder after public advertisement.”

· Disclosure of Interest - Councilor Buhle noted in reading another town’s Ethics

Commission that their Disclosure of Interest stated the following: Any officer,

official, or employee who has a private financial interest in any action, legislative or

otherwise, by any town agency, or who is a member of, or participates in discussion

with, or gives an official. Gives an official opinion to such town agencies, shall

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

interest. This section shall not apply to contracts awarded to the lowest responsible

bidder. After public advertisement, unpaid appointed officials, during a declared state

of emergency. Matters requiring disclosure to or approval by a court, the town

attorney, town engineer, or similar official, who is participating in the offering. An

opinion on behalf of said agency, and whose financial interest is merely being paid

for such services.

Councilor Buhle went on to note that it also included a Part B that stated the

following: Every elected official, including justices of the peace, shallon or before

January 1st each year file a Disclosure of Interest Form to be prepared by the town

attorney, a statement under oath containing the following information:

ü All real estate, located within the town of Ledyard, owned by such elected

official, are held under release for a term exceeding 5 years, excluding power of

his or her principal residence.

ü The names of any firm proprietorship, proprietorship, partnership, or corporation,

which such elective official is an employee, or which such elected official holds

at least a 5% interest in which firm proprietorship, furniture, corporation, or

limited liability corporation has sold or supplied goods in its for services in

excess of $10,000 per year, to the town of Ledyard, during the 2-years

immediately preceding such an official election in office.

ü Declare any income, fee, salary, or wages, directly or indirectly received by such

elected official from the town or its political subdivisions during the 2-years

immediately preceding such an election.

Councilor Buhle stated that there were more things listed; and that these were just

ideas that the Committee would discuss. She noted that she would forward the

language to the Administrative Assistant Roxanne Maher.

Councilor Dombrowski explained that currently under the Town Charter; Chapter III;

Section 1 states the following:

“No member of the Town Council shall, during his term of office, except as

provided in Section 2 of this chapter, hold or accept any position, office or

employment under the government of the Town of Ledyard or any political

subdivision thereof which is filled by appointment by the Mayor, Town

Council, or any board or commission created by ordinance, Charter, or

statute. No person holding any elected office under this Charter or

provisions of any ordinance or of the General Statutes shall, except as

provided in Section 2 of this chapter, be a member of the Town Council

during his continuance in such office.”

Councilor Dombrowski stated that other towns may not already have this type of

provision. He noted as an example a Ledyard Police Officer could not serve on the

Town Council or on any other Town Committee/Commission/Board. Councilor

Buhle stated that there may be parts from other towns Ethics Ordinances that were

reasonable and made sense for Ledyard to include in their Ordinance and that other

things may not make sense.

Councilor Buhle noted as an example that she was a small business owner in

Ledyard. She stated that her Photography LLC Business does not directly have her

name on the business, and for full disclosure that she does not receive any payment

from the Town. However, she questioned in accordance with the proposed Ethics

Commission Ordinance that if she completed the Disclosure Form on January 1st

would she be required to turn down a job for the town to hire her LLC Business to

take headshot photos of the whole town, even if she was not the photographer doing

the actual photography work. Councilor Dombrowski stated even without the

proposed Ethics Ordinance that Councilor Buhle’s LLC Photography Business could

not take the job. He explained that because she was an elected official that she could

not apply for a contract that would be a financial benefit to her because as an elected

official that she could not receive payment from the town. She stated that what

Councilor Dombrowski explained made sense.

Councilor Dombrowski stated that he would make the grand assumption that

everyone who was currently serving on the Town Council was following every

ethical guideline 100% regardless if they had an Ethics Commission or not.

· Gift: The Administration Committee discussed the definition of “Gift” under Section

3; subparagraph 7 and what would be considered a negligible monetary value. They

noted if someone received a baby blanket that was valued at $45 or a flower

arrangement that cost $125.00 for a death in the family that these types of things

would not be considered a “Monetary Gift” because the recipient would not be

financially benefiting from the fact that they received flowers. The “Gift” the

Ordinance was trying to address was something that would be a “kick-back or a

personal financial gain” for receiving a government service or favorable outcome

from the town. They noted examples of a Kick-back would be something such as: (1)

If do this for me I will get you Taylor Swift Concert Tickets; or (2) If you approve my

development application, I will give you Season Tickets to the Boston Celtics. The

Committee agreed that although they were not opposed to the definition of gift with a

monetary value of $100.00; that they would change the value to $25.00.

· Membership - The Administration Committee noted that the proposed Ordinance

Establishing an Ethics Commission was calling for five Regular Members and two

Alternate Members. Councilor Dombrowski suggested that they require that Minority

Representation apply separately to each of the subsets: Regular Members and

Alternate Members. He stated another words that they have a minority representation

among the five Regular Members and a minority representation among the two

Alternate Members. He noted as an example the Planning & Zoning Commission

which had both Regular Members and Alternate Members.

Councilor Buhle stated that she agreed with Councilor Dombrowski’s idea that the

two (Regular Members & Alternate Members) should be treated independently from

each other with regard to Minority Representation. She went on to note that

Glastonbury’s Ethics Commission’s Membership required that no more than 2

Regular Members may be affiliated with any one political party and that their

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

addition it required that at all times at least one Regular Member, and one Alternate

Member had to be unaffiliated. She stated that this type of minority membership

made sense, because by requiring that 2 members be Unaffiliated (1 Regular Member

and 1 Alternate Member) that it would take the DTC and RTC out of the nominating

process, noting that the unaffiliated applications would go through the Town Council

Office. The Committee noted that they agreed with breaking up the party afflation of

the Commission’s Members in the way that Glastonbury does it and that counting the

minority representation between the regular members and alternate members would

be a question for the Town Attorney.

Councilor Buhle suggested including term limits for the Ethics Commission. She

stated that Ledyard has been fortunate that they have some dedicated residents who

have served on Commissions for 25-years. However, she stated because of the

restrictions that she thought that it would be reasonable to include language that

stated after their initial 3-year appointment that the members of the Ethics

Commission could serve for an additional two-terms which would be a total of

9-years. Councilor Dombrowski stated that he would agree with including a term

limit provision.

· Distinguish between an Ethics Matter and Management of Town Employees -

Councilor Buhle suggested they include langue that would state that “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 superintendent. In the case of the employees of larger

public schools, the personnel policy shall be the first guide in those areas where

applicable. Similarly, the routine activities of the Commission shall be governed by

its rules and regulations. Councilor Dombrowski stated that the town has an

Employee Handbook - Personal Policies, and other guiding documents.

· Findings/Sanctions - Councilor Buhle suggested they changes the number of votes

regarding the findings of a violation be changed from 5 (unanimous) to 4 (majority).

Councilor Dombrowski stated that he would like to research the number of required

votes before they changed it.

· Conflict of Interest - Councilor Buhle noted that the Town Charter, Chapter IX;

Section 6 pertained to “Conflict of Interest”. However, she stated because the

proposed “Ordinance Establishing a Ethics Committee” included so much more

information than the Town Charter regarding Conflict of Interest and Disclosure that

she questioned whether the Town Charter would supersede the Ordinance or whether

the Ordinance would be in conflict with the Town Charter.

Chapter IX; Section 6 of the Town Charter “Conflict of Interest” stated the

following:

“Any elected or appointed officer or any employee of the Town who

has a financial interest or personal benefit, direct or indirect, in any

contract, transaction, or decision of any board or commission to

which the Town is a party, shall disclose publicly that interest to the

appropriate board or commission and the Town Council in advance of

discussion or action on the matter, which shall record such disclosure

upon the official record of its meetings. The Town Council may by

ordinance specify what is, or what is not, a conflict of interest for

officials and employees of the Town.

Willful violation by any such officer or employee of the provisions of

this section shall be grounds for his removal. Violation of this section

with the knowledge, express or implied, of any person or corporation

participating in such contract, transaction, or decision shall render

the same voidable by the Town Council, or by a court of competent

jurisdiction.”

Councilor Dombrowski provided an example of a Conflict of Interest, explaining

when former Councilor John Marshall was serving that his wife was the Animal

Control Officer. Therefore, he stated when the Town Council voted on the Police

Labor Contract that Councilor Marshall had to state his Conflict of Interest and

recuse himself from voting on the Police Contract. Councilor Buhle stated that this

was where she had questions especially if people were determining their own

conflicts, noting that it could

be hard for some people to determine; noting that some things were very obvious, but

other things may not be so obvious. Councilor Dombrowski stated that Ethics and

Conflict of Interest was about financial gain.

The Administration Committee continued by reviewing the proposed Ordinance,

discussing each of their suggested changes; and by consensus agreed to the language

and formatting changes as noted below in the draft dated May 14, 2024.

Councilor Buhle’s proposed changes were noted in pink italic font

Councilor Dombrowski’s proposed changes were noted in bule italic font

Councilor Buhle thanked Councilor Dombrowski for his input noting that she knew

that he had a lot of concerns, but that she felt that they were coming to the table. She

stated that she did not want to see the subject of an Ethics Commission to be

something that was passed on party lines, noting that she wanted the proposed

Ordinance Establishing an Ethics Commission to be something that could all agree

with, and that they all felt that it was going to benefit the town in the long run,

because that was what they were all here for.

Councilor Buhle continued by stating that she and Councilor Dombrowski would

both provide their marked-up drafts to Administrative Assistant Roxanne Maher to

incorporate their suggested revisions into the draft Ordinance for discussion and to

potentially finalize at their June11, 2025 meeting. She stated once the Committee

believed that they had their best and final draft Ordinance that they would forward

the document to the Town Attorney for their review and legal opinion and

recommendations to ensure that their Ethics Commission would comply with the

Connecticut General State Statutes.

CONTINUE

RESULT:

Discussion and possible action to draft a resolution establishing a Sustainable CT Ad-hoc

Committee.

Councilor Buhle noted the Administration Committee discussed a draft “Resolution

Supporting the Town’s Continued Participation in the Sustainable CT Municipal

Certification Program And Establishing A Sustainable CT Ad Hoc Committee” at their

April 9, 2025 meeting. She stated although Land Use Director/Town Planner Elizabeth

Burdick was not able to attend tonight’s meeting that she spoke with Ms. Burdick and

with others about the Sustainable CT Ad Hoc Committee and its members. She stated

that she agreed that the Committee should be comprised of town employees who could

meet during the day versus asking our volunteer Commission members to serve on

another Committee. She stated that they realize that their town employees were

already stretched very thin and this would allow them to meet during their workday.

She stated that she would continue to work on the Resolution to make the changes to

the membership for their June 11, 2025 meeting.

CONTINUE

RESULT:

ADJOURNMENT

Councilor Buhle moved the meeting be adjourned, seconded by Councilor Dombrowski.

VOTE:

2 - 0 Approved and so declared, the meeting was adjourned at 6:01 p.m.

Respectfully submitted,

Jessica Buhle

Committee Chairman

Administration Committee

DISCLAIMER: Although we try to be timely and accurate these are not official records of the

Town.