Charles Cuccia v. Local Finance Board

CourtNew Jersey Superior Court Appellate Division
DecidedOctober 15, 2024
DocketA-2462-22
StatusUnpublished

This text of Charles Cuccia v. Local Finance Board (Charles Cuccia v. Local Finance Board) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Charles Cuccia v. Local Finance Board, (N.J. Ct. App. 2024).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-2462-22

CHARLES CUCCIA,

Petitioner-Appellant,

v.

LOCAL FINANCE BOARD,

Respondent-Respondent. _________________________

Submitted October 2, 2024 – Decided October 15, 2024

Before Judges Mayer and Puglisi.

On appeal from the New Jersey Department of Community Affairs, Local Finance Board.

Dorsey & Semrau, LLC, attorneys for appellant (Fred C. Semrau, of counsel; Edward R. Pasternak, on the briefs).

Matthew J. Platkin, Attorney General, attorney for respondent (Donna Arons, Assistant Attorney General, of counsel; Steven M. Gleeson, Deputy Attorney General, on the brief).

PER CURIAM Petitioner Charles Cuccia appeals from a March 29, 2023 final agency

decision issued by respondent Local Finance Board (Board), adopting the initial

decision of an Administrative Law Judge (ALJ), finding Cuccia violated the

Local Government Ethics Law (LGEL), N.J.S.A. 40A:9-22.1 to -22.25.

Specifically, the ALJ and Board found Cuccia violated N.J.S.A. 40A:9-22.5(a),

(c), (d), (e), (g), and (h), and assessed a $200 fine for each violation for a total

penalty of $1,200. We affirm.

The Board found Cuccia violated the foregoing subsections of the LGEL

by simultaneously holding the positions of Chief Financial Officer (CFO) for

the Borough of Lodi (Borough) and owner of Treasury Services, a financial

consulting business. While Cuccia served as the Borough's CFO, the Borough

contracted with Treasury Services to update and improve its financial audit

system and for other financial services.

The Board issued a November 7, 2018 notice of violation, alleging Cuccia

violated the LGEL. Upon receiving the violation notice, Cuccia requested a

hearing before the Office of Administrative Law. The matter was assigned to

an ALJ for a hearing as a contested case. Prior to the hearing date, the Board

filed a motion for summary decision under N.J.A.C. 1:1-12.5, which Cuccia

opposed.

A-2462-22 2 We presume the parties are familiar with the facts set forth in the ALJ's

comprehensive December 13, 2022 initial decision. We provide a summary to

give context to our opinion.

Cuccia owned and operated Treasury Services, a company providing

financial services to local governments. Cuccia's wife worked for Treasury

Services. In 2012, Cuccia, on behalf of Treasury Services, entered into contracts

with the Borough to support the Borough's Finance Department, including

implementing an upgraded uniform system for the management of the Borough's

accounts and accounting procedures. None of the contracts between Treasury

Services and the Borough were publicly bid. Cuccia claimed the contracts were

excluded from the public bid requirement because they were for professional

services.

The Borough also contracted with Treasury Services to "outsource the

municipal finance office operations" when the full-time CFO retired. Cuccia

became the Borough's part-time CFO in October 2012. The Borough renewed

Cuccia's contract for the CFO position every year from 2012 to 2018. During

his tenure as the Borough's CFO, Cuccia continued to contract with the Borough

A-2462-22 3 on behalf of Treasury Services. 1 Additionally, while Cuccia served as the

Borough's CFO, Treasury Services employed Cuccia's wife.

In his written decision, the ALJ granted the Board's motion for summary

decision. He determined the parties had no genuine disputes with respect to the

following facts: "Cuccia served simultaneously as CFO of Lodi, while also

serving as Finance Officer for Treasury Services, a company contracted to

provide financial services for Lodi" and "while serving as CFO, Cuccia

continued to acquire contracts from Lodi, without a competitive procurement

process, using information not generally available to the public ."

The ALJ first addressed Cuccia's violations of 40A:9-22.5(a), (d), (e), and

(h) to determine whether there was a disqualifying conflict of interest between

Cuccia simultaneously serving as the Borough's CFO and owner of Treasury

Services when the Borough contracted with Treasury Services. The ALJ noted

these subsections of the LGEL did not require intent to determine if an official

had a disqualifying conflict of interest. Relying on Grabowsky v. Twp. of

Montclair, 221 N.J. 536, 554 (2015), the ALJ stated that once a disqualifying

interest is found, "an inquiry into an official's motive is unnecessary."

1 The ALJ found the value of the contracts between the Borough and Treasury Services after Cuccia became the Borough's CFO totaled $601,958.32. A-2462-22 4 The ALJ specifically found Cuccia had:

[A] multitude of impermissible interests . . . [,] including direct pecuniary interest, an indirect pecuniary interest, and possibly even a direct personal interest. A direct pecuniary interest [arose] due to Cuccia's ownership of Treasury Services, and an indirect pecuniary interest [arose] due to Cuccia's wife's ownership of the same company. A direct personal interest also [arose] due to Treasury Service's employment of [the Borough Manager]'s daughter during all relevant times herein that Cuccia was both CFO of Lodi and owner and operator of Treasury Services.

The ALJ determined "[i]t [was] undisputed that Cuccia was involved in

contract proposals with Treasury Services, as he submitted the same to the

Borough for approval between 2012 and 2018. This conduct alone is enough to

determine that Cuccia was representing Treasury Services in matters brought

before Lodi officials." Thus, the ALJ granted summary decision in favor of the

Board as to subsections (a), (d), (e), and (h).

The ALJ then considered Cuccia's violation of N.J.S.A. 40A:9-22.5(c) and

(g), noting those subsections "deal[t] with intentional acts by officials to seek

'unwarranted privileges or advantages' or 'financial gain.'" The ALJ found it

"undisputed" that Cuccia used information not available to the public to acquire

contracts from Lodi while serving as its CFO. The ALJ further found Cuccia,

while serving as the Borough's CFO and owner of Treasury Services, "proposed

A-2462-22 5 contracts for financial services to the Borough" and "did not seek bids, quotes[,]

or any form of competition before accepting these contracts." The ALJ also

found Cuccia benefitted from information he obtained in his capacity as the

Borough's CFO to secure contracts between the Borough and Treasury Services.

He concluded Cuccia's conduct presented a perceived conflict between Cuccia's

private interests as the owner of Treasury Services and his public duties as the

Borough's CFO. Thus, the ALJ granted summary decision to the Board under

subsections (c) and (g).

In considering the appropriate penalty, the ALJ imposed the sum of $200

for each of Cuccia's violations of the LGEL. Because the ALJ found Cuccia

violated six different provisions of the LGEL, he assessed a total penalty of

$1,200.

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