Settlement  Disposition Agreement in the Matter of Raymond Turcotte

Date:	05/05/2026
Organization:	State Ethics Commission
Docket Number:	26-0006
Location:	Boston
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 Raymond Turcotte (“Turcotte”) 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 October 19, 2023, 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. On November 20, 2025, the Commission concluded its inquiry and found reasonable cause to believe that Turcotte violated G.L. c. 268A, §§ 23(b)(2)(ii), 23(b)(4), and 23(c)(2). 

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

Use of DOC Cell Phone and Vehicle

Findings of Fact

1. Turcotte was the Director of Special Operations for the Department of Correction (“DOC”). Turcotte’s shift hours were Monday through Friday, 7 a.m. to 3 p.m., and his office was located at DOC headquarters Milford.
2. In 2022, Turcotte’s base pay as Director of Special Operations was approximately $140,000.
3. Turcotte had a DOC-issued cell phone and DOC-paid cell phone plan. 
4. The monthly cost of a comparable cell phone and cell phone plan would exceed $50.
5. In 2022 through January 2023, Turcotte used his DOC-issued cell phone and DOC-paid cell phone plan for his personal purposes, including to communicate, via calls and texts, with family and other persons who had no professional connection to the DOC.
6. In December 2022 through January 2023, Turcotte used his DOC-issued cell phone and DOC-paid cell phone plan to make or receive over 300 calls to his girlfriend.
7. Nearly six hours of phone time for these calls occurred during Turcotte’s DOC work shift when Turcotte submitted for regular pay.
8. DOC rules prohibit DOC personnel from making or receiving personal telephone calls while on duty absent supervisory approval. 
9. DOC rules state that DOC equipment is for official use only and not for personal gain. 
10. The DOC issued Turcotte a pick-up truck for Turcotte’s use in his official DOC duties, part of which included being available to respond to DOC-related issues at any time.
11. Turcotte had permission from the DOC and the state Operational Services Division to garage this vehicle at his home.
12. In 2022, Turcotte used this DOC-issued vehicle for personal reasons, during his DOC shift and after hours. 
13. The cost of obtaining a comparable vehicle for comparable use and periods of time would well exceed $50.
14. DOC and state Operational Services Division policies specify that state vehicles, even those which employees may garage at their homes, are for official use only and not for personal use.

Conclusions of Law

15. Section 23(b)(2)(ii) of the conflict of interest law prohibits a state employee from knowingly, or with reason to know, using, or attempting to use, his official position to secure, for himself or others, unwarranted privileges or exemptions which are of substantial value and which are not properly available to similarly situated individuals.
16. As an employee of the DOC, Turcotte was a state employee.
17. As Turcotte knew or had reason to know, state employees are prohibited from using state resources, including equipment like cell phones and cell phone plans or their state work time, for their personal purposes, private benefit, or self-enrichment.  Such use of state resources for personal gain is an unwarranted privilege not properly available to other similarly situated state employees. 
18. Turcotte’s personal use of his DOC-issued cell phone, cell phone plan, and state time were of substantial value. 
19. Therefore, by using his DOC-issued cell phone and DOC-paid cell phone plan for his personal purposes, including to make or receive over 300 calls with his girlfriend in a two-month period, using nearly six hours of his regular DOC work time, Turcotte knowingly or with reason to know used his official position to secure for himself an unwarranted privilege of substantial value not properly available to similarly situated individuals including other DOC employees, thereby violating section 23(b)(2)(ii).
20. Similarly, as Turcotte knew or had reason to know, state employees who are provided with a state vehicle for official state business are not permitted to use that vehicle for their personal purposes or private gain. Such use is an unwarranted privilege not properly available to other similarly situated state employees. 
21. Turcotte’s personal use of his DOC-issued vehicle was of substantial value.
22. Therefore, by using his DOC-issued vehicle for personal purposes in 2022, Turcotte knowingly or with reason to know used his official position to secure for himself an unwarranted privilege not properly available to similarly situated state employees, thereby violating section 23(b)(2)(ii). 

Use of DOC position and confidential information to get his daughter a DOC job

Findings of Fact

23. In 2022, Turcotte obtained the interview questions for a dispatcher position within the Central Transportation Unit of the DOC from a colleague and then texted the questions to his daughter, along with suggested answers he devised.
24. At the time of his daughter’s interview, there were nine applicants for two available dispatcher positions.
25. When he shared the DOC interview questions and suggested answers with his daughter, Turcotte understood that the DOC would use the questions in the interviews of the candidates, including his daughter, as part of the hiring process to fill the dispatcher position.
26. The DOC subsequently hired Turcotte’s daughter for one of the dispatcher positions, at a salary of $41,690.

Conclusions of Law

Section 23(b)(2)(ii)

27. Having in advance the questions job applicants will be asked in their pre-employment interviews is akin to having in advance the questions which will be asked in a competitive examination to qualify for a position.  Both are unwarranted privileges not properly available to similarly situated job applicants, as Turcotte knew or had reason to know.
28. Turcotte used his position to obtain the dispatcher position interview questions from a colleague and to devise suggested responses.
29. Having questions in advance enabling one to perform well on an interview for a job worth over $40,000 annually is of substantial value.
30. Therefore, Turcotte violated section 23(b)(2)(ii) by, knowingly or with reason to know, using his official position to obtain the dispatcher interview questions and share them and suggested answers he devised with his daughter, thereby providing her with an unwarranted privilege of substantial value not properly available to similarly situated individuals.

Section 23(c)(2)

31. Section 23(c)(2) of the conflict of interest law prohibits a current or former state employee from knowingly, or with reason to know, improperly disclosing material or data within the exemptions to the definition of public records as defined by G.L. c. 4, §7, cl. 26, which were acquired by the state employee in the course of his official duties, or using such information to further his personal interest.
32. Subclause l of G.L. c. 4, § 7, cl. 26, exempts “questions and answers, scoring keys and sheets and other materials used to develop, administer or score a test, examination or assessment instrument; provided, however, that such materials are intended to be used for another test, examination or assessment instrument.”
33. The interview questions for the dispatcher position, which Turcotte obtained by requesting them of a DOC colleague and thereby in the course of his official duties, are material exempt from the definition of a public record because a job interview is a type of test or examination and the DOC intended to and did in fact use the questions for the hiring process to fill the dispatcher position.
34. Turcotte’s disclosure to his daughter, who had no official or proper need for the interview questions, was a public disclosure in violation of this section of the law.
35. Such disclosure also furthered Turcotte’s personal interest in wanting an advantage for his daughter.
36. Accordingly, by knowingly or with reason to know, improperly disclosing the dispatcher position interview questions, material or data within the exemptions to the definition of public records as defined by G.L. c. 4, §7, cl. 26 which were acquired by him in the course of his official duties, or using such information to further his personal interest, by disclosing the questions to his daughter, Turcotte violated section 23(c)(2).

Use of DOC position to secure DOC ammunition for his girlfriend

Findings of Fact

37. Turcotte gave his girlfriend, who had no DOC affiliation, two boxes of ammunition owned by the DOC which were assigned by the DOC Armory to Turcotte.
38. DOC ammunition is for DOC use only.
39. One of the two boxes of ammunition Turcotte gave his girlfriend bore a stamped lot number and a DOC Armory handwritten date and inventory number.  The lot number corresponded to a DOC ammunition order. When the DOC Armory distributes ammunition and accessories to DOC personnel, Armory personnel record the lot number, date, and inventory number in a log.
40. According to DOC invoices, the value of the marked box of ammunition was $162.70.
41. The DOC subsequently obtained the ammunition, unopened, from Turcotte’s girlfriend.

Conclusions of Law

42. As Turcotte knew or had reason to know, the DOC provided him with the DOC ammunition and accessories that he gave to his girlfriend for or because of his official position.
43. By giving the DOC ammunition and accessories to his girlfriend, a person unaffiliated with the DOC, Turcotte secured for her an unwarranted privilege not properly available to similarly situated individuals.
44. This unwarranted privilege was of substantial value as the marked box of ammunition alone was worth more than $50.
45. Therefore, Turcotte violated section 23(b)(2)(ii) by, knowingly or with reason to know, using his position to obtain the DOC ammunition and accessories and then giving them to his girlfriend, thereby providing her with an unwarranted privilege of substantial value not properly available to similarly situated individuals.

Receipt of DOC pay for hours he did not work

Findings of Fact

46. Turcotte did not report to his DOC job on either November 14, 2022 or December 8, 2022, yet he received his regular DOC pay for each day. 
47. On October 26, 2022, Turcotte arrived at his DOC office at Milford headquarters at 8:27 a.m., left at 10:47 a.m., and did not return for the rest of the workday.  Instead, Turcotte went to an eye doctor’s office, followed by the Marlborough Holiday Inn and Suites from 1:27 p.m. to 9:19 p.m.  He received eight hours of DOC regular pay for this day.
48. In total, Turcotte received approximately 16.5 hours of DOC regular pay for hours that he did not work over the three days of October 26, November 14, and December 8, 2022.
49. At all relevant times, Turcotte delegated his DOC timesheet reporting to another DOC staff member.
50. State employees are responsible for verifying and ensuring that their submitted timesheets are correct. 

Conclusions of Law

51. As Turcotte knew or had reason to know, it is an unwarranted privilege for a state employee to receive pay from a state agency for work time which he did not work, but instead used to attend to personal matters, without taking sick, vacation or other appropriate leave. 
52. Turcotte’s receipt of 16.5 hours of regular DOC pay for hours that he did not work and did not properly take leave was unwarranted and was not properly available to similarly situated DOC employees.
53. As a member of DOC management, Turcotte used his official position to delegate, and not correct, the improper use of 16.5 hours of regular pay for time which he used for personal affairs.
54. 16.5 hours of Turcotte’s 2022 base pay far exceeded $50 and was, thus, of substantial value. 
55. Therefore, by, in 2022, knowingly, or with reason to know, using his official DOC position to obtain for himself approximately 16.5 hours of regular DOC pay for time during which he was attending to personal affairs, without taking leave, and without ensuring the accuracy of his timesheets, an unwarranted privilege of substantial value not properly available to similarly situated individuals, Turcotte violated 23(b)(2)(ii). 

Receipt of MPTC pay for hours he did not work

Findings of Fact

56. In addition to his DOC job, in 2022 and early 2023, Turcotte contracted with the Municipal Police Training Committee (“MPTC”) to provide firearms instruction, including for MPTC Bridge Academy classes held at the range located at the DOC North Central Correctional Institution in Gardner (“Gardner Range”). 
57. The Bridge Academy was a temporary program which included a firearms component as part of a 200-hour training program designed to enable local officers who did not attend a full-time police academy to bridge the gap between reserve academy training and the requirements of the state’s 2022 police reform law.
58. Turcotte served as a Lead Firearms Instructor on certain nights and weekends in 2022 for the Bridge Academy at the Gardner Range.
59. As a contract employee, Turcotte received $50 per hour of instruction from the MPTC.
60. In 2022, MPTC paid Turcotte $37,920 in gross for instructing Bridge Academy classes at the Gardner Range.
61. Turcotte submitted for pay for each class he claimed he taught by completing and submitting an Instructor Assignment Sheet to the MPTC. 
62. Turcotte did not instruct, attend, or otherwise appear at the Gardner Range Bridge Academy class on October 26, 2022. 
63. Turcotte completed and submitted paperwork for that class, including an Instructor Assignment Sheet where he listed himself as working eight hours that day, to the MPTC. 
64. The MPTC paid Turcotte for eight hours for October 26, 2022 at $50 per hour.

Conclusions of Law

Section 23(b)(2)(ii)

65. As Turcotte knew or had reason to know, it is an unwarranted privilege for a state employee to receive pay from a state agency for workhours during which the employee is not working for the state agency, unless the employee is making appropriate use of the employee’s leave time.
66. Turcotte’s receipt of eight hours of MPTC pay for hours that he did not work was not properly available to similarly situated MPTC employees, including contractors like Turcotte.
67. Eight hours of Turcotte’s pay from the MPTC exceeded $50 and was therefore of substantial value.
68. Turcotte used his MPTC position to obtain an unwarranted privilege of substantial value for himself when he received eight hours of MPTC pay for October 26, 2022, valued at $50 per hour, when he did not work for the MPTC that day. 
69. Therefore, by, in 2022 knowingly or with reason to know, using his official MPTC position to obtain for himself eight hours of MPTC pay for time he did not work, an unwarranted privilege of substantial value not properly available to similarly situated individuals, Turcotte violated 23(b)(2)(ii).

Section 23(b)(4)

70. Section 23(b)(4) prohibits a state employee from knowingly, or with reason to know, presenting a false or fraudulent claim to his employer for any payment or benefit of substantial value.
71. The MPTC used the Instructor Assignment Sheet to determine when and for how many hours to pay its firearms instructors like Turcotte; thus, his completion and submission of the Instructor Assignment Sheet was a claim by Turcotte to his employer for payment.
72. Turcotte knowingly or with reason to know submitted a false or fraudulent Instructor Assignment Sheet to the MPTC for October 26, 2022 because he did not work for the MPTC that day even though he completed paperwork, including an instructor Assignment Sheet, indicating that he did work that day.
73. This false or fraudulent claim for payment by Turcotte was of substantial value at eight hours times $50 per hour.
74. Therefore, Turcotte violated section 23(b)(4) by knowingly or with reason to know, presenting a false or fraudulent claim to his employer, the MPTC, for any payment or benefit of substantial value.

Disposition

In view of the foregoing violations of G.L. c. 268A by Turcotte, 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 and conditions agreed to by Turcotte:

1. That Turcotte pay to the Commonwealth of Massachusetts, with such payment to be delivered to the Commission, the sum of $35,000 as a civil penalty for violating G.L. c. 268A, §§ 23(b)(2)(ii), 23(b)(4), and 23(c)(2); and
2. That Turcotte 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, Turcotte acknowledges that he has personally read this Disposition Agreement, that it is a public document, and that he agrees to all of the terms and conditions therein. 

^1   “Substantial value” is $50 or more.  930 CMR 5.05.