Advisory Opinion No. 98-60

Re: Colonel Lawrence Campion


The Petitioner, a Colonel in the East Greenwich Police Department, a municipal employee position, and President of the Rhode Island Police Chiefs’ Association (“Association”), which is comprised of persons serving in municipal appointed positions and/or municipal employee positions, requests an advisory opinion on behalf of the members of the Association as to whether a private company may host and pay for a dinner for its members at which a presentation would be made about products and services provided by the company, and 2) whether the Association may accept a laptop computer from this company as a gift.


1) It is the opinion of the Ethics Commission that members of the Rhode Island Police Chiefs’ Association (“Association”), who serve in municipal appointed positions and/or municipal employee positions, may accept a dinner from a private company provided that it is within the $200 per person limit recognized in General Commission Advisory 5 (Regarding Meals). In General Commission Advisory 5, the Commission opined that an official would not violate the Code by accepting an occasional meal as part of a social gathering. The Commission warned, however, that "caution must be given ... where the cost or the value of the meal rises to the point of being more than nominal (for instance where a public official is invited to a $200 a plate dinner), or where such occasions become so frequent or numerous as to become of more than nominal value in the aggregate, (such as a $5 lunch every week)."

Also, public officials and employees may not accept a gift, including a meal, with the understanding or expectation that their official action or judgment would be influenced. See R.I. Gen. Laws § 36-14-5(g). Therefore, while a member of the Association may accept the dinner without violating provisions of the Code of Ethics, it may be prudent for that member to seek a separate advisory opinion from this Commission if and when they take public action on a future matter that involves the company that hosted and paid for the dinner. That admonition is particularly relevant here where it appears the company will use the dinner as a promotional device for its products and services.

2) Finally, the members of the Association are municipal appointed officials and/or municipal employees. The Association itself, however, is not a public agency. It is a professional association. Therefore, the Association may accept the gift of a laptop computer from the private company so long as it is for the use of the Association, and belongs to the Association, and will not be for the principal, private use of a public official or employee.

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