Docket No.: 277


Date: December 24, 1984


This Disposition Agreement (Agreement) is entered into between
the State Ethics Commission (Commission) and William C. Lannon (Mr.
Lannon) pursuant to section 11 of the Commission's Enforcement
Procedures. This Agreement constitutes an assented to final
Commission order enforceable in Superior Court pursuant to General
Laws chapter 268B, s.4(d).

On September 11, 1984, the Commission initiated a preliminary
inquiry pursuant to G.L. c. 268B, s.4(d), into possible violations
of the conflict of interest law, G.L. c. 268A, involving Mr. Lannon, former Cambridge superintendent of schools. The Commission
concluded that preliminary inquiry and, on November 27, 1984, found
reasonable cause to believe that Mr. Lannon had violated chapter

The parties now agree to the following findings of fact and
conclusions of law:

1. Mr. Lannon was superintendent of schools for the city of
Cambridge from August 15,1975 to August 15, 1984. As such, he had
supervisory authority over

Page 209

Cambridge school personnel. As superintendent. Mr. Lannon was a
municipal employee within the meaning of G.L. c. 268A, s.1(g).

2. In the fall of 1978, Mr. Lannon asked a teacher subject to
his supervisory authority for a loan of $3,000. The teacher agreed
to loan the money to Mr. Lannon.

3. Some time later, Mr. Lannon's wife asked the same teacher
for an additional $2,000 loan, and the teacher again agreed. At or
about this time, a promissory note was entered into by Mr. Lannon
and the teacher. The terms set out in the note stated that the
$5,000 was to be repaid within five years and was subject to eight
percent annual interest. The interest was to be paid annually at
the end of each year.

4. On several occasions during the term of the loan, the teacher
approached Mr. Lannon regarding payments of the interest due. Mr.
Lannon made two partial payments totaling approximately $200, but
otherwise made no payments on the interest or principal.

5. While this loan was outstanding, the teacher applied for a
sabbatical leave. Following the review and approval of such an
application by a staff council, the superintendent of schools must
recommend to the school committee that such a leave should be
granted before the school committee will do so. Mr. Lannon
recommended that the teacher's application for a sabbatical be

6. In July of 1984, Mr. Lannon repaid the loan and paid the
interest due after the teacher filed a civil suit against him.

7. In early 1984, an employee of the Cambridge school system
subject to Mr. Lannon's authority offered to loan him $3,000 to pay
certain outstanding debts. Mr. Lannon accepted that offer. Mr.
Lannon has not repaid that loan.

8. Both individuals who made loans to Mr. Lannon stated that
they had developed a friendship with Mr. Lannon while subject to
his authority.

9. Section 23(paragraph 2)(3) prohibits a municipal employee
from engaging in conduct which gives reasonable basis for the
impression that anyone can improperly influence or unduly enjoy his
favor in the conduct of his official duties. By entering into loan
transactions with individuals subject to his authority as Cambridge
school superintendent, Mr. Lannon violated s.23(paragraph 2)(3).

10. In addition, by recommending that the Cambridge school
committee grant a sabbatical leave to a teacher at a time when he
was substantially in debt to that teacher, Mr. Lannon gave
reasonable basis for the impression that the teacher could
improperly influence or unduly enjoy his favor in the performance
of his official duties, in violation of s.23(paragraph 2)(3).

Based on the foregoing facts; the commission has determined that
the public interest would be served by the disposition of this
matter without further enforcement proceedings on the basis of the
following terms agreed to by Mr. Lannon:

1. that he pay to the Commission the sum of five hundred dollars
($500.00) as a civil penalty for the above described violations of
G.L. c. 268A, s.23(paragraph 2)(3); and

2. that he waive all rights to contest the findings of fact,
conclusions of law and terms and conditions contained in this
Agreement in this or any other related administrative or judicial
proceeding in which the Commission is a party.

End Of Decision