Christopher Silva v. Local Finance Board

CourtNew Jersey Superior Court Appellate Division
DecidedApril 8, 2026
DocketA-0590-24
StatusUnpublished

This text of Christopher Silva v. Local Finance Board (Christopher Silva 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
Christopher Silva v. Local Finance Board, (N.J. Ct. App. 2026).

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-0590-24

CHRISTOPHER SILVA,

Petitioner-Appellant,

v.

LOCAL FINANCE BOARD,

Respondent-Respondent. __________________________

Argued March 11, 2026 – Decided April 8, 2026

Before Judges Paganelli and Jacobs.

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

Elliott J. Almanza argued the cause for appellant (Goldenberg, Mackler, Sayegh, Mintz, Pfeffer, Bonchi & Gill, attorneys; Elliott J. Almanza, of counsel and on the briefs).

Zachary L. Aboff, Deputy Attorney General, argued the cause for respondent (Jennifer Davenport, Attorney General, attorney; Donna Arons, Assistant Attorney General, of counsel; Zachary L. Aboff, on the brief).

PER CURIAM Petitioner Christopher Silva appeals from an October 16, 2024 final

agency decision from the New Jersey Department of Community Affairs, Local

Finance Board (Board), which revoked a notice of violation (NOV) and found

he did not violate the Local Government Ethics Law (LGEL), N.J.S.A. 40A:9-

22.1 to -22.5. We affirm.

In March 2022, the Board notified Silva, then Mayor of Mullica Township

(Township), it was investigating a complaint that had been filed regarding his

votes on ordinances and resolutions involving the Township Police Department

when his son-in-law was employed by the police department. In addition, the

Board informed Silva the complaint alleged he had failed to recuse himself

during two Township committee meetings concerning the police department and

that he had met with the Police Benevolent Association.

In response, on April 5, 2022, Silva's counsel, among other arguments,

asserted that:

After . . . Silva was elected, he approached the municipal attorney [(the attorney)] . . . to provide a legal opinion on what [he] could vote on and what he could not, as he was sensitive to the appearance of a potential conflict. In response to . . . Silva's request, [the attorney] provided a legal opinion that . . . Silva refrain from voting on any economic issues that would benefit [his son-in-law] but [he] could vote on any other police matter. . . .

A-0590-24 2 In 2018, [the attorney] . . . modif[ied] her legal opinion. [The attorney]'s new opinion . . . was that . . . Silva could participate in police matters where it did not financially impact his son-in-law. . . . Silva has continued to follow this opinion until the present.

On August 24, 2022, the Board issued a NOV determining Silva had

committed nine violations under N.J.S.A. 40A:9-22.5(d)1 and imposed a fine of

$100 per violation. However, the Board waived the fine because Silva

"reasonably relied on the advice of" the attorney.

Silva requested an administrative hearing. The Administrative Law Judge

(ALJ) issued an initial decision, finding Silva had relied on "advice given to him

1 N.J.S.A. 40A:9-22.5(d) provides that:

Local government officers or employees under the jurisdiction of the . . . Board shall comply with the following provisions:

....

d. No local government officer or employee shall act in his official capacity in any matter where he, a member of his immediate family, or a business organization in which he has an interest, has a direct or indirect financial or personal involvement that might reasonably be expected to impair his objectivity or independence of judgment[.]

A-0590-24 3 by the . . . [attorney] and acted accordingly." The ALJ concluded Silva's "acts

to vote for the [o]rdinance[s] and in participation in discussions [we]re nothing

more than ministerial acts and ha[d] not violated [N.J.S.A. 40A:9-22.5(d)]

because there simply was no exercise of judgment to potentially impair Silva's

judgment" and "Silva's conduct in voting on the [o]rdinances . . . or

participati[ng] in the discussions . . . ha[d] no direct or indirect financial or

personal involvement that might reasonably impair his objectivity or

independence of judgment in violation of N.J.S.A. 40A:9-22.5(d)."

The Board filed exceptions to the ALJ's initial decision, and Silva

responded pursuant to N.J.A.C. 1:1-18.4(d). The Board, in its final agency

decision, found:

Silva met the four prerequisites to the reliance of counsel defense. Silva (1) received the advice prior to the action being taken; (2) relied on advice from someone who possessed authority to render advice for ethical issues; (3) gave all of the pertinent facts and circumstances to the [attorney] when seeking advice; and (4) complied with the advice received and did not shop for contrary advice. Hence, the Board h[e]ld[] that [Silva] did not violate N.J.S.A. 40A:9-22.5(d)[,] because he met the reliance of counsel defense.

[(Citations omitted).]

The Board ordered the August 2022 NOV be "revoked." Nevertheless,

the Board included within its decision "that had Silva not met the reliance on

A-0590-24 4 counsel defense, then the facts could have substantiated nine violations of

N.J.S.A. 40A:9-22.5(d)." The Board found the ALJ's legal analysis concerning

the statute was "inconsistent" with Board precedent and relevant case law and

Silva's acts were beyond "ministerial" as he had "exhibited discretion."

Silva appeals from the Board's final agency decision, contending a plain

reading of N.J.S.A. 40A:9-22.5(d), and the relevant case law, do not support the

Board's legal conclusion that he violated the statute; the record before the Board

lacked sufficient evidence to support its finding that he violated the statute; and

the administrative proceedings denied him due process.

The Board argues the appeal should be dismissed. It contends Silva lacks

standing to pursue an appeal because he is not "aggrieved" by the Board's final

agency decision. Instead, "Silva achieved a completely favorable outcome"

because "the [NOV] issued by the Board was revoked." Further, Silva cannot

"complain that he was aggrieved by the Board's reliance on the . . . advice of

counsel[] defense when he made this argument himself before the Board."

Moreover, the Board argues appeals "may not be taken from opinions"

and "the rationale underlying the action is not independently appealable,"

(quoting Price v. Hudson Heights Development, LLC, 417 N.J. Super. 462, 467

(App. Div. 2011)). The Board contends "[a] party 'who obtains the judgment

A-0590-24 5 sought, may not be heard to complain on appeal about the reasons or rationales

cited for the action.'" (Quoting Price, 417 N.J. Super. at 467).

Silva counters that he "was, in fact, aggrieved by the [Board's] final

agency decision." He states "[w]hereas the ALJ concluded that [he] did not

violate N.J.S.A. 40A:9-22.5(d) in the first place, the [Board] determined that

[his] conduct did constitute a statutory violation." Silva argues he "was found

to have violated the" LGEL and "[i]t is cold comfort that the violation was

excused based on an advice-of-counsel defense" because "this public document

finds that he acted unethically." (Emphasis omitted). Silva contends

"reputational harm clearly confers standing." (Citing Too Much Media, LLC v.

Hale, 413 N.J. Super. 135, 169 (App. Div.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Too Much Media, LLC v. Hale
993 A.2d 845 (New Jersey Superior Court App Division, 2010)
Zirger v. General Accident Insurance
676 A.2d 1065 (Supreme Court of New Jersey, 1996)
BANKERS TRUST CO. OF CALIFORNIA v. Delgado
787 A.2d 195 (New Jersey Superior Court App Division, 2001)
DEUTSCHE BANK NAT. v. Mitchell
27 A.3d 1229 (New Jersey Superior Court App Division, 2011)
New Jersey Civil Service Ass'n v. State
443 A.2d 1070 (Supreme Court of New Jersey, 1982)
In Re Dir. Div. of Abc
921 A.2d 1159 (New Jersey Superior Court App Division, 2007)
Too Much Media, LLC v. Hale
20 A.3d 364 (Supreme Court of New Jersey, 2011)
Price v. HUDSON HEIGHTS DEVELOP.
10 A.3d 232 (New Jersey Superior Court App Division, 2011)
Hon. Dana L. Redd v. Vance Bowman(073567)
121 A.3d 341 (Supreme Court of New Jersey, 2015)
Crescent Park Tenants Ass'n v. Realty Equities Corp.
275 A.2d 433 (Supreme Court of New Jersey, 1971)
Green v. Blackwell
32 N.J. Eq. 768 (Supreme Court of New Jersey, 1880)

Cite This Page — Counsel Stack

Bluebook (online)
Christopher Silva v. Local Finance Board, Counsel Stack Legal Research, https://law.counselstack.com/opinion/christopher-silva-v-local-finance-board-njsuperctappdiv-2026.