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Interpretative Opinion 03-04: Conflict of Interest

April 25, 2003

Charlotte Brookins-Hudson
General Counsel
Council of the District of Columbia
1350 Pennsylvania Avenue, NW Suite 4
Washington, DC 20004

Re:  Conflict of Interest

This responds to your request for an opinion concerning whether a member of the council may use money from the constituent services fund to purchase shirts and lapel pins to issue as awards to outstanding constituents. You indicated that the ward number, display of the DC flag and the name of the Member of the Council will be embossed on the shirt.

As you correctly noted, DC Official Code §1-1104.03(a) states “the Mayor, the Chairman of the Council, and each member of the Council may establish citizen-service programs within the District of Columbia. …The Mayor, the Chairman of the Council, and each member of the Council shall file a quarterly report of all contributions received and monies expended in accordance with this subsection with the Director of Campaign Finance. No campaign activities shall be conducted nor shall campaign literature or paraphernalia be distributed as part of citizen-services programs conducted pursuant to this subsection.”

3 DCMR §3014 provides that “a citizen-services program shall encompass any activity or program which provides services to the residents of the District of Columbia; and promotes their general welfare, including but not limited to, charitable, scientific, educational, medical or recreational purposes”.

Based upon the information you have provided, the activity the Council Member intends to sponsor through the constituent services fund appears to be designed to promote the general welfare of the residents of the District of Columbia by acknowledging the accomplishments of outstanding constituents.  Thus, it does not appear to violate any of the prohibitions on the use of constituent service funds.