Settlement  Disposition Agreement in the Matter of Bridget Baker

Date:	03/25/2025
Organization:	State Ethics Commission
Docket Number:	25-0001
Location:	Boston, MA
Referenced Sources:	G.L. c. 268A, the Conflict of Interest Law, as Amended by c. 248, Acts of 2024

Disposition Agreement

The State Ethics Commission (“Commission”) and Bridget Baker^[1] (“Baker”) enter into this Disposition Agreement pursuant to Section 3 of the Commission’s Enforcement Procedures. This Agreement constitutes a consented-to final order enforceable in the Superior Court, pursuant to G.L. c. 268B, § 4(j).

On February 15, 2024, the Commission initiated, pursuant to G.L. c. 268B, § 4(a), a preliminary inquiry into possible violations of the conflict of interest law, G.L. c. 268A, by Baker. On December 19, 2024, the Commission concluded its inquiry and found reasonable cause to believe that Baker violated G.L. c. 268A, § 23(b)(3).

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

Findings of Fact

1. At all relevant times, Baker was a Mental Health Counselor at the Student Wellness Center at Bristol Community College (“BCC”), an educational institution of the Commonwealth. 
2. The Student Wellness Center offers short-term mental health counseling and referral services.
3. Baker’s appointing authority was the BCC Director of Student Wellness.
4. For periods of time between 2019 through 2022, Baker provided mental health counseling and other services to a BCC student (“Student/Client”) through the BCC Student Wellness Center.
5. In or about June 2020, Baker hired the Student/Client to work on a book Baker was writing. The Student/Client’s services included comprehensive photo editing and formatting the book’s layout for publishing.
6. On July 23, 2020, the same day Baker emailed the Student/Client to reschedule a meeting to edit her book, Baker sent an email upon the Student’s request to one of the Student/Client’s BCC professors requesting an extension for the Student/Client on a research paper and other work. Baker wrote:

My name is Dr. Bridget Arrow, I am a Senior Mental Health Counselor at Bristol Community College. I am writing to respectfully request an extension of 4-school days for [Student/Client] … to submit [Student/Client’s] . . . research paper and to work out a time . . . [to] coordinate with you to present [Student/Client’s] project.

Please know that this request comes to you from my constituency of Mental Health Counseling and Wellness, and as such the reasons for making this request must remain confidential. According to college policy, we are advised to work with students who have documented reasons for requesting extensions and this falls under those auspices.

7. While working on the book, Baker and the Student/Client developed a personal friendship. Baker gave the Student/Client gifts, was asked to officiate the Student/Client’s wedding, and visited wedding venues with the Student/Client. Baker did not officiate the Student/Client’s wedding.
8. In or about August 2020, Baker hired the Student/Client to design and maintain her “Arrow Books” website.
9. In February 2021, Baker wrote an affidavit on BCC letterhead, which she had notarized, for submission to a federal agency in support of the Student/Client’s efforts to attain a certificate of citizenship in the United States.
10. In 2022, Baker hired the Student/Client to design and maintain her “Arrow Wellness” website.
11. Baker wrote a letter to a Massachusetts court in support of the Student/Client securing a restraining order.
12. The letter, dated December 17, 2022, was on BCC letterhead and cited Baker’s counseling relationship with the Student/Client.
13.  Baker did not disclose her commercial and personal relationships with the Student/Client to her appointing authority.

Conclusions of Law

14. Section 23(b)(3) of G.L. c. 268A prohibits a municipal employee from, knowingly, or with reason to know, acting in a manner which would cause a reasonable person, having knowledge of the relevant circumstances, to conclude that any person can improperly influence or unduly enjoy her favor in the performance of her official duties, or that she is likely to act or fail to act as a result of kinship, rank, position or undue influence of any party or person. The section further provides that it shall be unreasonable to so conclude if the employee has disclosed in writing to her appointing authority the facts which would otherwise lead to such a conclusion.
15. As a BCC Mental Health Counselor, Baker was a state employee as defined by G.L. c. 268A, § 1(q).
16. As set forth above, Baker had commercial and personal relationships with the Student/Client.
17. While having commercial and personal relationships with the Student/Client, Baker took official actions as a Mental Health Counselor by seeking an extension on classwork, drafting a letter to a Massachusetts court and drafting an affidavit to a federal agency, all on the Student/Client’s behalf.
18. A reasonable person with knowledge of the relevant circumstances stated above in the Findings of Fact would conclude that the Student/Client could improperly influence or unduly enjoy Baker’s favor in the performance of her official duties as a Mental Health Counselor, both in providing counseling services and in seeking additional benefits, including a classwork extension, drafting a court letter and an affidavit on the Student/Client’s behalf.
19. Baker did not make a written disclosure of the relevant facts to her BCC appointing authority prior to taking official action as to the Student/Client. Had Baker disclosed the relevant facts, her appointing authority could have assigned a different counselor to provide services to the Student/Client.  
20. Therefore, by, as described above, knowingly or with reason to know, acting in a manner which would cause a reasonable person with knowledge of the relevant circumstances to conclude that the Student/Client could improperly influence or unduly enjoy Baker’s favor in the performance of her official duties as a Mental Health Counselor or that Baker was likely to act or fail to act as a result of undue influence of the Student/Client, Baker violated § 23(b)(3).

Disposition

In view of the foregoing violation of G.L. c. 268A by Baker, the Commission has determined that the public interest would be served by the disposition of this matter without further enforcement proceedings, on the following terms and conditions agreed to by Baker:

1.     that Baker pay to the Commonwealth of Massachusetts, with such payment to be delivered to the Commission, the sum of $4,000 as a civil penalty for violating G.L. c. 268A, § 23(b)(3); and
2.     that Baker waive all rights to contest, in this or any other administrative or judicial proceeding to which the Commission is or may be a party, the findings of fact, conclusions of law and terms and conditions contained in this Agreement.

By signing below, Baker acknowledges that she has personally read this Disposition Agreement, that it is a public document, and that she agrees to its terms and conditions.

STATE ETHICS COMMISSION

^[1] Bridget Baker is also known as Bridget Arrow Baker, Bridget Arrow and Birgit Arrow.