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Interpretative Opinion 96-03: Conflict of Interest

March 15, 1996
 

Turner D. Madden, Esq.
General Counsel
Washington Convention Center Authority
900-9th Street, NW
Washington, DC  20001

Re: Conflict of Interest

Dear Mr. Madden:

This responds to your request for an opinion indicating whether Convention Center Board Member, Mike Dickens, may participate in deliberations and voting on the selection of a team for the Program Manager contract for the new Convention Center.  You stated that JBG Properties, Inc., prime member of one of the six teams seeking the contract, is the property manager for a building leased by Hospitality Partners, the company of which Mr. Dickens is President.  You state that Hospitality Partners occupies only 4.35% of the space in the building managed by JBG properties; that Mr. Dickens did not know that JBG Properties was one of the bid partners for the Program Manager contract when the lease was negotiated; that the lease is and future leases will be at a fair market rate; and that Mr. Dickens’ role in the selection of the Program Manager contractor is limited and shared with the Technical Advisory Committee, the Convention Center Board and the “Control Board.”

  DC Code § 1-1461 and 18 U.S.C. § 208 prohibit a public official from taking official action on any matter in which he or she, or any business he or she is associated with, has a financial interest.

Based on the foregoing information, it is the opinion of the Office of Campaign Finance that Mr. Dickens has no conflicting financial interest in the selection of the Program Manager contractor.  Further, the fact that JBG Properties is the property manager for the building in which Hospitality Partners leases space does not create such a financial interest.  Accordingly, Mr. Dickens’ recusal from voting and deliberations on the Program Manager contract is not warranted.