The Palm Beach County Commission on Ethics (COE) took the following actions at its monthly public meeting held on February 1, 2018.

Vice Chair Clevis Headley and Commissioner Judy Pierman were recognized for their service on the COE. This meeting was their last as COE commissioners. 

Executive Director Mark Bannon presented the COE’s annual report.

Two complaints were heard in executive session. The complete files are published on the COE website at:


C17-045After considering the investigative report, probable cause recommendation, and statements of the COE advocate, the COE found probable cause did not exist and dismissed the complaint.

C17-046After considering the investigative report, probable cause recommendation, and negotiated settlement between the COE advocate and respondent, the COE issued a letter of instruction finding the violation was unintentional, inadvertent, or insubstantial and dismissed the complaint.


One advisory opinion was approved. The full opinion is published and available at:

RQO 17-027: The town administrator for the town of Lake Clarke Shores asked if it would violate the contractual relationship section of the Palm Beach County Code of Ethics if the town enters into a new or modified contract with Achieve Agency, the outside business or employer of Town Council member John Studdard, to update and host the town’s website?

The COE opined as follows: The code prohibits Mr. Studdard, as a town official, and Achieve Agency, as his outside employer or business, from entering into any contract or other transaction for goods or services with the town, unless an exception applies. Because this contract will not be awarded through a sealed bid/low bid process, Achieve Agency is not the sole source of supply of the goods or services needed, and the website services would not constitute an emergency purchase, none of those exceptions apply.

However, Section 2-443(e)(4) provides an exception when the total amount of the contracts or transactions in the aggregate between an official’s outside business or employer and the municipality does not exceed $500 per calendar year. Therefore, if the total amount of Achieve Agency’s contracts or transactions with the town does not exceed $500, in the aggregate, then the contract between the town and Achieve Agency would not be prohibited.


A detailed explanation of all agenda items is available at

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