Settlement  Disposition Agreement in the Matter of Tara Sullivan

Date:	01/09/2024
Organization:	State Ethics Commission
Docket Number:	24-0001
Location:	Boston, MA
Referenced Sources:	G.L. c. 268A, the Conflict of Interest Law, as Amended by c. 194, Acts of 2011

Disposition Agreement

The State Ethics Commission (“Commission”) and Tara Sullivan (“Sullivan”) 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 May 18, 2023, the Commission initiated a preliminary inquiry, pursuant to G.L. c. 268B, § 4(a), into possible violations of the conflict of interest law, G.L. c. 268A, by Sullivan. On November 17, 2023, the Commission concluded its inquiry and found reasonable cause to believe that Sullivan violated G.L. c. 268A, § 19.

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

Findings of Fact

1. Sullivan was at all relevant times the elected Town Clerk for the Town of Blackstone.  Sullivan was first elected Town Clerk in 2019.
2. As Town Clerk, Sullivan was responsible for administering state and local elections.
3. As Town Clerk, Sullivan hired election workers to assist with administering elections.
4. Sullivan, as Town Clerk, assigned election workers’ hours and duties.
5. As Town Clerk, Sullivan reviewed election workers’ timesheets and approved their pay.

Hiring her Mother

6. In February 2020, Sullivan, as Town Clerk, hired her mother as an election worker.
7. In 2020 through 2022, Sullivan, as Town Clerk, assigned her mother to duties as an election clerk, as an election warden, and to assist with vote-by-mail processing, which carried higher pay rates than the minimum wage earned by election workers who did not perform such additional duties.
8. In 2020, the Town paid Sullivan’s mother $2,895.18 for 199.11 hours of work, the second-highest number of hours worked by all paid Town election workers.
9. In 2021, the Town paid Sullivan’s mother $202.25 for 14.75 hours of work, consistent with hours worked by other paid Town election workers in a year with only one town-wide election.
10. In 2022, the Town paid Sullivan’s mother $1,244.64 for 78.25 hours of work, the highest number of hours worked by all paid Town election workers.
11. Sullivan reviewed each of her mother’s timesheets and approved her pay.
12. In total, the Town paid Sullivan’s mother $4,342.07 for election work between 2020 and 2022.

Hiring her Sister

13. In 2020, Sullivan also hired her sister as an election worker.
14. In 2020, the Town paid Sullivan’s sister $634.32 for 49.75 hours of work.
15. In 2022, the Town paid Sullivan’s sister $409.69 for 28.75 hours of work.
16. In 2020 and 2022, Sullivan’s sister was paid the minimum wage earned by election workers who did not perform additional duties.
17. Sullivan reviewed each of her sister’s timesheets and approved her pay.
18. In total, the Town paid Sullivan’s sister $1,044.01 for election work in 2020 and 2022.

Conclusions of Law

19. General Laws chapter 268A, § 19 prohibits a municipal employee from participating as such an employee in a particular matter in which to their knowledge they or their immediate family member has a financial interest.
20. As Blackstone Town Clerk, Sullivan was, at all relevant times, a municipal employee as defined by G.L. c. 268A, § 1(g).
21. Sullivan’s mother and sister are both members of her immediate family as defined by G.L. c. 268A, § 1(e). 
22. Sullivan’s decisions to hire her mother and her sister for paid election work positions, to assign their duties and corresponding rates of pay, and to approve their pay, were each particular matters in which her immediate family members had a financial interest.
23. When Sullivan participated as Town Clerk in each of the particular matters as described above, she knew her mother and/or her sister had a financial interest in the particular matters.
24. Therefore, by, as Blackstone Town Clerk, hiring her mother and her sister to perform paid election work to the Town of Blackstone, assigning their duties and corresponding rates of pay, and approving their pay, Sullivan violated § 19.

Disposition

In view of the foregoing violations of G.L. c. 268A by Sullivan, 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 Sullivan:

(1)       that Sullivan pay to the Commonwealth of Massachusetts, with such payment to be delivered to the Commission, the sum of $5,000 as a civil penalty for violating G.L. c. 268A, § 19; and

(2)       that Sullivan 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, Sullivan 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