Minutes 7-1-25
MINUTES OF THE OPEN SESSION
OF THE RHODE ISLAND ETHICS COMMISSION
July 1, 2025
The Rhode Island Ethics Commission held its 10th meeting of 2025 at 9:00 a.m. at the Rhode Island Ethics Commission conference room, located at 40 Fountain Street, 8th Floor, Providence, Rhode Island, on Tuesday, July 1, 2025, pursuant to the notice published at the Commission offices, the State House Library, and electronically with the Rhode Island Secretary of State.
The following Commissioners were present:
Lauren E. Jones, Chair Frank J. Cenerini
Holly J. Susi, Vice Chair Scott P. Rabideau
Dr. Michael Browner, Jr. Hugo L. Ricci, Jr.
Christopher P. Callahan
The following Commissioners were not present: Emma L. Peterson and Matthew D. Strauss.
Also present were Herbert F. DeSimone, Jr., Commission Legal Counsel; Jason Gramitt, Commission Executive Director; Katherine D’Arezzo, Senior Staff Attorney; Lynne M. Radiches, Staff Attorney/Education Coordinator; Staff Attorneys Teresa Giusti and Teodora Popova Papa; and Commission Investigators Peter J. Mancini and Kevin Santurri.
At 9:00 a.m., the Chair opened the meeting.
The first order of business was:
Approval of minutes of the Open Session held on June 10, 2025.
Upon motion made by Commissioner Callahan and duly seconded by Commissioner Susi, it was unanimously
VOTED: To approve the minutes of the Open Session held on June 10, 2025.
The next order of business was:
Director’s Report: Status report and updates.
a.) Complaints and investigations pending
There are five complaints pending. Executive Director Gramitt informed that the depositions scheduled in the Thorsen matter for June 20, 2025, in Pennsylvania were canceled at the last minute due to the witnesses obtaining counsel who requested additional time to prepare. In response to Chair Jones, Executive Director Gramitt stated that both witnesses have been served with subpoenas and are required to testify. Executive Director Gramitt informed that the subpoenaed documents have been produced.
Executive Director Gramitt informed that a new complaint was filed and is scheduled for initial determination today in executive session. With respect to In re: Heidi Weston Rogers, the investigation has concluded and respective counsel are discussing possible adjudication dates in October or November. In the matter of In re: Jason Licciardi, the investigation is concluding and a probable cause hearing will be scheduled for the next meeting.
b.) Advisory opinions pending
There are seven advisory opinions pending, four of which have been noticed for today’s meeting.
c.) Access to Public Records Act requests since last meeting
There were five APRA requests received since the last meeting, four of which were granted within one business day. The fifth request was emailed directly to a Commission investigator who was on vacation, and it was granted within two business days. Four requests related to advisory opinions and one related to a meeting video.
d.) Financial disclosure
Executive Director Gramitt informed that there are only eight remaining non-filers, which brings the compliance rate to 99.81%. He informed that seven non-filers are municipal officials, and one is a charter school board member. Executive Director Gramitt acknowledged the hard work of the Commission investigators in locating and calling all the non-filers.
e.) General office administration
Executive Director Gramitt informed that the next meeting will be held on July 29, 2025.
The next order of business was:
Advisory Opinions.
The advisory opinions were based on draft advisory opinions prepared by Commission Staff for review by the Commission and were scheduled as items on the Open Session Agenda for this date.
The first advisory opinion was that of:
Robert Runge, the grants administrator and unhoused coordinator for the City of Pawtucket, requests an advisory opinion regarding whether he is prohibited by the Code of Ethics from accepting an appointment to the board of directors of the Blackstone Valley Advocacy Center, a private domestic violence center, given that the center applies for and receives Emergency Solutions Grants funding from the City of Pawtucket.
Staff Attorney Popova Papa presented the Commission Staff recommendation. The Petitioner was present. Upon motion made by Commissioner Ricci and duly seconded by Commissioner Rabideau it was unanimously
VOTED: To issue an advisory opinion to Robert Runge, the grants administrator and unhoused coordinator for the City of Pawtucket.
The next advisory opinion was that of:
Thomas J. Cronin, Esq., who was recently nominated to become the Town of Coventry’s Municipal Court Judge, and who is an attorney in private practice, requests an advisory opinion regarding whether, upon his appointment to the position, he would be prohibited by the Code of Ethics from representing clients before the Coventry Town Council, Planning Board, Zoning Board, and Probate Court.
Staff Attorney Popova Papa presented the Commission Staff recommendation. The Petitioner was present. In response to Commissioner Callahan, Staff Attorney Popova Papa explained that if a member of the town council were going to appear before the Petitioner in a legal matter, the council member would be required first to seek an advisory opinion allowing him to appear. She also explained that the Petitioner would recuse and the probate court judge would serve in the Petitioner’s place in that matter. Commissioner Cenerini provided an example of a council member receiving a speeding ticket and being required to appear before the Petitioner as Municipal Court Judge, in which case the Petitioner would recuse. The Petitioner stated that the Coventry police department has the discretion to send moving violation matters to the traffic tribunal or the municipal court. In response to Commissioner Callahan, the Petitioner explained that the municipal court has concurrent jurisdiction over infractions with the district court and the traffic tribunal and that the charging party has the discretion to decide in which court to bring the charges. Chair Jones noted his concern with the Petitioner appearing before the town council with another attorney and his/her client(s), given that the town council has appointed the Petitioner to the municipal court. Chair Jones further noted that the other attorney may feel at a disadvantage and that the matter might not be handled neutrally. Chair Jones stated that his concern does not change his opinion in this matter. Upon motion made by Commissioner Browner and duly seconded by Commissioner Cenerini, it was unanimously
VOTED: To issue an advisory opinion to Thomas J. Cronin, Esq., who was recently nominated to become the Town of Coventry’s Municipal Court Judge, and who is an attorney in private practice.
The next advisory opinion was that of:
Priscilla Glucksman, the administrator of the Office of Child Support Services, a division of the Department of Human Services, requests an advisory opinion regarding whether the proposed alternate chain of command policy will sufficiently insulate her from potential conflicts of interest arising out of her position, given the recent hiring of the Petitioner’s daughter as a child support enforcement agent in the same division.
Staff Attorney Radiches presented the Commission Staff recommendation. The Petitioner was present. In response to Commissioner Ricci, the Petitioner stated that she served in the legal department at the Office of Child Support Services until she became the administrator within the last month or two. She explained that child support enforcement agents follow a type of step ladder for salary increases. In further response to Commissioner Ricci, the Petitioner stated that because the agency is part of Title D of the Social Security Act, it is federally funded. She clarified that the associate director is the head of the agency. Upon motion made by Commissioner Ricci and duly seconded by Commissioner Browner, it was unanimously
VOTED: To issue an advisory opinion to Priscilla Glucksman, the administrator of the Office of Child Support Services, a division of the Department of Human Services.
The final advisory opinion was that of:
Dylan Chase, the superintendent of the New Shoreham Water Pollution Control Facility, who in his private capacity owns and operates Block Island Septic Services, LLC, requests an advisory opinion regarding whether he is prohibited by the Code of Ethics from providing services in his private capacity to customers within the town’s sewer district, given that there are few qualified technicians available to accommodate the needs of those customers.
Staff Attorney Radiches presented the Commission Staff recommendation. The Petitioner was present via video link. The Petitioner addressed the Commission and stated that while he understands and agrees with the literal prohibitions under the Code of Ethics, he remains concerned with the practical application of those prohibitions to the situations he encounters, some of which impact the ecosystem and public health. He described an emergency matter that recently arose that could have been avoided with proper maintenance. He inquired whether the Commission might grant a conditional allowance for him to perform this work until a service provider could be found. Chair Jones requested that Staff Attorney Radiches address the Petitioner’s concern. Staff Attorney Radiches commended the Petitioner for his sincerity and willingness to do the right thing. She noted that the 38 homeowners within the sewer district that are required by municipal ordinance to have service contracts in place prior to receiving permission from the Petitioner for sewer connection to the town should be contacting their service providers to enforce those contracts. Staff Attorney Radiches expressed concern over the liability to which the Petitioner and the Town could be exposed if the Petitioner performs a service at one of the 38 homes that eventually goes wrong. She also expressed concern that if the Petitioner is allowed to do this, the Town may not be pressed to look for someone else to perform the work.
Commissioner Cenerini noted that in the documents provided, the New Shoreham Town Council has represented that it would waive any conflict in this situation and allow the Petitioner to perform various maintenance services through his LLC within the sewer district, subject to the Ethics Commission’s approval of such work. In response to Commissioner Cenerini, Staff Attorney Radiches noted that it was the Sewer Commission that voted to approve the waiver of any conflict on the part of the Petitioner. She further noted that there are individuals to respond in emergencies, some of which could be avoided with proper maintenance. In response to Commissioner Ricci, the Petitioner informed that the Town has an emergency response system in place. He noted, however, that the response is reactive rather than proactive which is not sufficient to protect wetlands and other ecosystems. The Petitioner stated that if he were allowed to respond in his private capacity through his LLC, he would do so proactively. He explained that the service providers who were initially responsible for the septic systems under contracts with the homeowners are no longer responding. He commented that he is seeking the Commission’s approval in this matter in the interest of the common good.
Commissioner Callahan queried whether the Town could contract for periodic services with the Petitioner or whether the R.I. Department of Environmental Management could be involved. Staff Attorney Radiches concurred with the Commission’s concerns but explained that the solution to these issues does not rest with the Petitioner but with the Town. In response to Chair Jones, Commissioner Rabideau stated that he has done work in his private capacity on Block Island. He commented that the Petitioner still may service the 1,200 wastewater systems outside the sewer district. Commissioner Rabideau suggested that the Sewer Commission could establish a program in which the Town could contract with any interested homeowner within the sewer district for maintenance services that would be provided by the Petitioner for a stipend thereby avoiding any conflicts. In response to Commissioner Ricci, the Petitioner stated that if the Commission issues the instant advisory opinion, the Town likely will continue to respond to emergencies until someone fills the role. In response to Commissioner Cenerini, Legal Counsel DeSimone informed that the Commission may agree to amend the opinion to allow the Petitioner to perform this work, but he recommended that the Commission continue the matter to the next meeting allowing Staff Attorney Radiches to propose new language. He concurred with Commissioner Rabideau’s suggestion that the Sewer Commission could establish a program by which the Town could offer preventative maintenance contracts, for a fee, to owners within the sewer district, and the Petitioner would perform the work in his public role under those contracts and receive additional compensation from the Town for this work. Legal Counsel DeSimone noted that this type of arrangement would remove the potential for any conflicts. The Petitioner informed that there is a similar arrangement in the Town for grease traps.
The consensus among the Commissioners was that it is the Town’s responsibility to fashion a remedy to address this issue. In response to Chair Jones, the Petitioner stated this opinion will assist him in addressing this issue with the town council or sewer commission. Staff Attorney Radiches commented that this advisory opinion could prompt the Town to follow up with another advisory opinion request, as necessary. Executive Director Gramitt informed that the video of this meeting will be available on the Commission’s website should any member of the town council or sewer commission wish to review it. Upon motion made by Commissioner Rabideau and duly seconded by Commissioner Susi, it was unanimously
VOTED: To issue an advisory opinion to Dylan Chase, the superintendent of the New Shoreham Water Pollution Control Facility, who in his private capacity owns and operates Block Island Septic Services, LLC.
At 10:20 a.m., upon motion made by Commissioner Callahan and duly seconded by Commissioner Cenerini, it was unanimously
VOTED: To go into Executive Session, to wit:
a.) Motion to approve minutes of Executive Session held on June 10, 2025, pursuant to R.I. Gen. Laws § 42-46-5(a)(2) & (4).
b.) In re: Robert L. Lombardo, Complaint No. 2025-3, pursuant to R.I. Gen. Laws § 42-46-5(a)(2) & (4).
c.) Motion to return to Open Session.
At 10:34 a.m., the Commission reconvened in Open Session.
The next order of business was:
Motion to seal minutes of July 1, 2025, Executive Session.
Upon motion made by Commissioner Callahan and duly seconded by Commissioner Cenerini, it was unanimously
VOTED: To seal the minutes of Executive Session held on July 1, 2025.
The next order of business was:
Report on actions taken in Executive Session.
Chair Jones reported that the Commission took the following actions in Executive Session:
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Unanimously voted (7-0) to approve the minutes of the Executive Session held on June 10, 2025.
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Unanimously voted (7-0) in the matter of In re: Robert L. Lombardo, Complaint No. 2025-3, to initially determine that the Complaint states facts that, if true, are sufficient to constitute violations of the Code of Ethics and to authorize a full investigation.
An Initial Determination is a preliminary vote that should not be construed as an opinion regarding the truth of the facts alleged in the complaint but is merely a vote to conduct an investigation into the allegations raised.
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Unanimously voted (7-0) to return to Open Session.
The next order of business was:
New Business proposed for future Commission agendas and
general comments from the Commission.
There were none.
At 10:36 a.m., upon motion made by Commissioner Browner and duly seconded by Commissioner Rabideau, it was unanimously
VOTED: To adjourn the meeting.
Respectfully submitted,
___________________________
Jason Gramitt
Executive Director