Price v. Bd. of Ethics and Gov't Accountability

CourtDistrict of Columbia Court of Appeals
DecidedNovember 10, 2022
Docket20-CV-527
StatusPublished

This text of Price v. Bd. of Ethics and Gov't Accountability (Price v. Bd. of Ethics and Gov't Accountability) is published on Counsel Stack Legal Research, covering District of Columbia Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Price v. Bd. of Ethics and Gov't Accountability, (D.C. 2022).

Opinion

Notice: This opinion is subject to formal revision before publication in the Atlantic and Maryland Reporters. Users are requested to notify the Clerk of the Court of any formal errors so that corrections may be made before the bound volumes go to press.

DISTRICT OF COLUMBIA COURT OF APPEALS

No. 20-CV-527

GERREN PRICE, APPELLANT,

V.

BOARD OF ETHICS AND GOVERNMENT ACCOUNTABILITY, APPELLEE.

Appeal from the Superior Court of the District of Columbia (CAP5346-19)

(Hon. Shana Frost Matini, Associate Judge)

(Submitted October 5, 2021 Decided November 10, 2022)

Erik James Williams for appellant.

Karl A. Racine, Attorney General for the District of Columbia, with whom Loren L. AliKhan, Solicitor General (at the time of submission), Caroline S. Van Zile, Principal Deputy Solicitor General (at the time of submission), Carl J. Schifferle, Deputy Solicitor General, and Stacy L. Anderson, Senior Assistant Attorney General, were on the brief for appellee.

Before BLACKBURNE-RIGSBY, Chief Judge, and EASTERLY and MCLEESE, Associate Judges.

BLACKBURNE-RIGSBY, Chief Judge: Appellant Gerren Price appeals the trial

court’s order affirming the Board of Ethics and Government Accountability’s

(“BEGA”) determination that Mr. Price violated the District’s Code of Conduct 2

(“Code of Conduct”). BEGA determined that as a supervisory public official for the

District of Columbia Mr. Price improperly “advanced” the resume of his sister-in-

law for a position within his agency and failed to submit a written notice of recusal.

See 6-B D.C.M.R. § 1806.3 (2014); 6-B D.C.M.R. § 1806.6 (2014). 1 Mr. Price

argues in this appeal that 1) BEGA’s decision lacked evidentiary support; 2) BEGA

incorrectly interpreted the term “advance” in its regulations; and 3) his actions did

not amount to a “hiring decision.” We agree and reverse the trial court’s order and

conclude that Mr. Price’s conduct did not fall within a reasonable definition of

“advance” and “hiring decision” under the regulation because his actions were

ministerial and non-preferential and no one involved in the actual hiring decision

was aware of Mr. Price’s relationship to the applicant. We further vacate the

associated fine totaling $1,500 and restitution in the amount of $26,182.10 assessed

by BEGA.

1 6-B D.C.M.R. § 1806 was updated with no substantive changes, effective January 31, 2020. We will refer to the numeration found in the 2014 version of 6-B D.C.M.R. § 1806, as the 2020 regulation appears to contain a typo, where § 1806.1 is repeated. 3

I. Factual & Procedural Background

At the time of the alleged violations, Mr. Price was the Deputy Director of the

Office of Youth Programs (“OYP”) for the District of Columbia Department of

Employment Services (“DOES”). OYP is responsible for administering the District

of Columbia’s Summer Youth Employment Program (“SYEP”). In early 2015,

SYEP was expanded to include a new age group of young adults between the ages

of twenty-two and twenty-four. The expansion required OYP to hire temporary case

managers on short notice. To facilitate the urgent hiring, a DOES Human Resources

Manager solicited Mr. Price’s assistance in advertising and filling the new positions.

On June 22, 2015, Mr. Price distributed an email to all OYP staff, with the

subject line “URGENT – Job Opportunity.” The email informed recipients that

DOES was hiring case managers and provided the requirements for the applicants.

In addition, all resumes were to be emailed to Mr. Price before 5:00 p.m. the next

day, per the direction of the DOES Human Resources Manager. Approximately

three hours after Mr. Price sent the email, Desiree Ward, Mr. Price’s sister-in-law,

responded with the subject line “Desiree Ward-Resume,” and included as an

attachment her resume. Mr. Price responded to the email, “Thank you, Ms. Ward. I 4

will forward your resume to our HR Department for consideration. You will hear

from us soon.”

The following day, the Human Resources Manager emailed Mr. Price asking

him to “[p]lease send [] your employees ASAP,” because the manager needed to

submit finalized packets to the District’s Department of Human Resources the

following day. Mr. Price printed all fifty to sixty resumes he received, including Ms.

Ward’s resume, and gave them to his team to review for selection of ten to fifteen

applicants. Mr. Price did not inform anyone that Ms. Ward was a relative. His team

selected between ten and fifteen resumes, which included Ms. Ward’s resume, and

a member of his team then passed the resumes on to the Human Resources Manager.

Human Resources then began the hiring process. The Human Resources

Manager contacted Ms. Ward via email, sending her an application package to be

completed and returned. Ms. Ward returned her completed application, listing Mr.

Price as her brother-in-law. Ms. Ward was offered the position, accepted it, and

began working as a case manager on July 6, 2015.

In November of 2015, BEGA initiated an investigation into Mr. Price after

being notified via an anonymous email that he and Ms. Ward were relatives. 5

Following the investigation, Mr. Price was formally charged with three counts of

violating the District’s Code of Conduct: (1) Directly or Indirectly Making a Hiring

Decision Regarding a Position within his Own Agency with Respect to a Relative

(advancing sister-in-law’s resume through hiring process), 6-B D.C.M.R. § 1806.3;

(2) Directly or Indirectly Making a Hiring Decision Regarding a Position within his

Own Agency with Respect to a Relative (requesting an extension to the temporary

term of employment for his sister-in-law and four other case managers, and signing

off on recruitment of the five case managers to be promoted), 2 6-B D.C.M.R. §

1806.3; and (3) Failing to File a Written Recusal (when his sister-in-law’s

application first reached his desk), 6-B D.C.M.R. § 1806.6.

In relevant part, 6-B D.C.M.R. § 1806.3 states:

A public official may not directly or indirectly make a hiring decision regarding a position within his or her own agency with respect to a relative. Specifically, a public official may not appoint, employ, promote, evaluate, interview, or advance (or advocate for such actions) any individual who is a relative in an agency in which the public official serves or exercises jurisdiction or control.

2 This “hiring decision” was related to a form requesting personnel action, filed on November 7, 2015, seeking an eight-month extension of Ms. Ward’s term of service. Mr. Price’s name appeared on the form as the “Requested By”; however, the form was signed by OYP’s Associate Director and not Mr. Price. 6

(emphasis added). Regarding the reporting requirement, 6-B D.C.M.R. § 1806.6

states, “[w]hen the agency contemplates making a hiring decision concerning a

relative of a public official within the same agency, the public official must file a

written recusal, which shall be included in the relative’s official personnel file along

with the subject personnel action.”

BEGA held a two-day evidentiary hearing and following the hearing issued a

written Final Decision determining that violation one related to 6-B D.C.M.R. §

1806.3 and violation three regarding 6-B D.C.M.R. § 1806.6 were meritorious. 3

With respect to violation one, BEGA concluded that Mr. Price, a public official,

directly and indirectly participated in the hiring of his sister-in-law by “advancing”

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

Related

Peoples Drug Stores, Inc. v. District of Columbia
470 A.2d 751 (District of Columbia Court of Appeals, 1983)
McCamey v. District of Columbia Department of Employment Services
947 A.2d 1191 (District of Columbia Court of Appeals, 2008)
Expedia, Inc. v. District of Columbia
120 A.3d 623 (District of Columbia Court of Appeals, 2015)
Borden v. United States
593 U.S. 420 (Supreme Court, 2021)
Reyes v. District of Columbia Department of Employment Services
48 A.3d 159 (District of Columbia Court of Appeals, 2012)
Sparrow v. District of Columbia Office of Human Rights
74 A.3d 698 (District of Columbia Court of Appeals, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Price v. Bd. of Ethics and Gov't Accountability, Counsel Stack Legal Research, https://law.counselstack.com/opinion/price-v-bd-of-ethics-and-govt-accountability-dc-2022.