Minnesota

Campaign Finance and

Public Disclosure Board
Date: January 26, 2015
To:

Board Members

From: Jeff Sigurdson

Assistant Director
Re:

Telephone: 651-539-1189

Advisory Opinion 439

The request for Advisory Opinion 439 was received and accepted by the Executive Director on
January 22, 2015. The request was submitted on behalf of Senator Tomassoni by Michael
Ahern, the senators legal counsel.
Senator Tomassoni has accepted the position of Executive Director for an association that is
represented at the legislature by a lobbyist. The request asks if this employment will create a
conflict of interest for the Senator.
The draft opinion provides that a conflict of interest does not exist. Under the provisions of
Chapter 10A a conflict of interest occurs from a specific decision or action that meets certain
criteria. A conflict of interest is not created by a legislators employment or occupation. As
drafted this opinion is consistent with prior advisory opinions issued to members of the
legislature on this subject.
Please contact me if you have questions or changes that you would like incorporated into the
draft.
Attachments:
Draft Advisory Opinion 439
Request letter dated January 21, 2015
Attachments provided with the request

State of Minnesota

Campaign Finance and Public Disclosure Board

Suite 190, Centennial Building. 658 Cedar Street. St. Paul, MN 55155-1603
THIS ADVISORY OPINION IS PUBLIC DATA
pursuant to a consent for release of information
provided by the requester
Issued to:

RE:

Senator David Tomassoni

75 Rev. Dr. Martin Luther King Jr. Blvd.
Capitol, Room G-9
St. Paul, MN 55155-1606

Potential Conflict of Interest for a Member of the Legislature

ADVISORY OPINION 439
SUMMARY

Employment by a member of the legislature as the executive director of an association that is

represented by a lobbyist does not in itself create a conflict of interest. An official action or
decision by the legislator may create a conflict of interest under specific circumstances.
FACTS
As a State Senator, and therefore a public official as defined in Minnesota Statutes Chapter
10A, you authorized your legal counsel to request on your behalf an advisory opinion from the
Campaign Finance and Public Disclosure Board (the Board) based on the following facts that
were provided in the letter requesting the advisory opinion and in documentation provided with
the request.
1. You have been hired as the Executive Director of the Range Association of
Municipalities and Schools (RAMS).
2. As a result, RAMS is now for you an associated business as defined in Minnesota
Statutes section 10A.01, subdivision 5, because the association will be
compensating you more than $50 a month.
3. RAMS is a voluntary association of political subdivisions that has been represented
by a lobbyist registered with the Board since 1991. Therefore RAMS is a principal
as defined in Minnesota Statutes section 10A.01, subdivision 33.
4. You have provided with your request a copy of an agreement between you and
RAMS that details your duties as Executive Director. The agreement specifically
states that you will not be a lobbyist for RAMS, that you will not be involved with the
hiring of a lobbyist for the association, and that the lobbyist will not report to the
position of Executive Director.
5. You are aware of prior advisory opinions issued by the Board that considered
potential conflicts of interest for a member of the Minnesota legislature and the

requirements when a conflict of interest exists. 1 In particular you note that Advisory
Opinion 325 considered a potential conflict of interest and concluded that the
occupation or profession of a legislator does not in itself create a conflict of interest.
Based upon prior Board opinions and the provisions of Chapter 10A you and your
legal counsel have concluded that a conflict of interest did not occur when you
accepted the position of Executive Director of RAMS. However, you are also aware
that an advisory opinion issued by the Board provides safe harbor only to the
individual or association that requested the opinion. Therefore, you have asked to
the Board for an advisory opinion specific to the facts of this situation.
ISSUE
Will employment as Executive Director of RAMS create a conflict of interest, as defined in
Minnesota Statutes section 10A.07, with your service as a State Senator?
OPINION
The only conflict of interest provision within the jurisdiction of the Campaign finance and
Public Disclosure Board is Minnesota Statutes section 10A.07. No employment relationship,
in itself, will give rise to a conflict of interest under this statute. Instead, the statute requires
that public officials evaluate the decisions they are required to make and the actions they are
required to take as a part of their official duties and to determine if a conflict of interest exists.
To determine if there is a conflict of interest a public official must consider two criteria, both
of which are established by Minnesota Statutes section 10A.07. First, will the official action
substantially benefit either the public officials personal financial interests or the financial
interests of an associated business? If the answer is yes then the second criteria is whether
the benefit will be greater for the public official or the official's associated business than the
affect on other members of the same business classification, profession, or occupation. Only
when both conditions are true does the public official face a conflict of interest.
Under the statute a legislator who finds that an action will create a conflict of interest must
prepare a written statement describing the matter requiring the official's action or decision
and the conflict of interest and deliver the notice to the presiding officer of the legislative
body in which the official serves. If there is not time for a written statement, the legislator
should orally inform the legislative body of the potential conflict. A legislator may be
excused from taking part in an action or decision that creates a conflict of interest.
Hypothetically, a specific issue or appropriation before the Senate could benefit RAMS in a
way that will create a conflict of interest for you. But accepting employment with RAMS
does not create a conflict of interest with the position of State Senator under the provisions of
Chapter 10A.

Issued: February 3, 2015

___________________________________
George A. Beck, Chair
Campaign Finance and Public Disclosure Board

See Advisory Opinions 237, 264, 325, 355, and 368. Advisory opinions are available for viewing
at www.cfboard.state.mn.us/ao/index.html .

Cited Statutes and Administrative Rules

10A.01 Definitions.
Subd. 5. Associated business. "Associated business" means an association, corporation,
partnership, limited liability company, limited liability partnership, or other organized legal
entity from which the individual receives compensation in excess of $50, except for actual
and reasonable expenses, in any month as a director, officer, owner, member, partner,
employer or employee, or whose securities the individual holds worth more than $2,500 at
fair market value.
10A.07 Conflicts of Interest.
Subdivision 1. Disclosure of potential conflicts. A public official or a local official
elected to or appointed by a metropolitan governmental unit who in the discharge of official
duties would be required to take an action or make a decision that would substantially affect
the official's financial interests or those of an associated business, unless the effect on the
official is
no greater than on other members of the official's business classification, profession, or
occupation, must take the following actions:
(1) prepare a written statement describing the matter requiring action or decision and
the nature of the potential conflict of interest;
(2) deliver copies of the statement to the official's immediate superior, if any; and
(3) if a member of the legislature or of the governing body of a metropolitan
governmental unit, deliver a copy of the statement to the presiding officer of the body of
service.
If a potential conflict of interest presents itself and there is insufficient time to comply
with clauses (1) to (3), the public or local official must orally inform the superior or the official
body of service or committee of the body of the potential conflict.
Subd. 2. Required actions. If the official is not a member of the legislature or of the
governing body of a metropolitan governmental unit, the superior must assign the matter, if
possible, to another employee who does not have a potential conflict of interest. If there is no
immediate superior, the official must abstain, if possible, in a manner prescribed by the board
from influence over the action or decision in question. If the official is a member of the
legislature, the house of service may, at the member's request, excuse the member from
taking part in the action or decision in question. If the official is not permitted or is otherwise
unable to abstain from action in connection with the matter, the official must file a statement
describing the potential conflict and the action taken. A public official must file the statement
with the board and a local official must file the statement with the governing body of the
official's political subdivision. The statement must be filed within a week of the action taken.
Subd. 3. Interest in contract; local officials. This section does not apply to a local
official with respect to a matter governed by sections 471.87 and 471.88.
Subd. 4. Exception; judges. Notwithstanding subdivisions 1 and 2, a public official
who is a district court judge, an appeals court judge, or a Supreme Court justice is not
required to comply with the provisions of this section.

( _W

DORSEY'"
MICHAEL J. AHERN
Partner
(612) 340-2881
FAX (612) 340-2643
ahern.michael@dorsey.com

January 21, 2015

The Honorable George Beck

Chair
Minnesota Campaign Finance and Public
Disclosure Board
190 Centennial Office Building
658 Cedar Street
St. Paul, Minnesota 55155-1603
Re:

Request for Advisory Opinion Regarding Sen. David Tomassoni's Position as

Executive Director of the Range Association of Municipalities and Schools

Dear Judge Beck:

Please accept this request from Senator David Tomassoni for an advisory opinion
regarding his position as Executive Director of the Range Association of Municipalities and
Schools ("RAMS"). Sen. Tomassoni would like to confirm with an advisory opinion from the
Campaign Finance and Public Disclosure Board ("CFPDB") that his recent acceptance of the
RAMS position does not in itself create a conflict of interest within the meaning of Minn. Stat.
10A.07.
FACTS

1.
Sen. Tomassoni is a Minnesota State Senator first elected to the Senate in 2000.
Sen. Tomassoni represents Minnesota Senate District 06. District 06 includes, among others,
the cities of Chisholm, Eveleth, Gilbert, Hibbing, Nashwauk, and Virginia. Much of
Sen. Tomassoni's district includes the Iron Range.
2.
On January 1, 2015, Sen. Tomassoni began a position as the Executive Director
of RAMS. His employment agreement ("Agreement") is attached to this letter as Exhibit A;
attached as Exhibit Bis a copy of RAMS's Constitution and By-Laws. RAMS helps promote
economic development and the general welfare on the Iron Range by bringing "an areawide
approach to problems which demand coordinated and cooperative actions and which are
common to the [Iron Range)." See Minn. Stat. 471.58. Sen. Tomassoni's salary will be
$6,500 per month. Exhibit A at 2. Pursuant to the Agreement, Sen. Tomassoni will take a leave
of absence from his position as Executive Director during the legislative session. Id. During the
leave of absence, Sen. Tomassoni will not receive compensation from RAMS or accrue paidtime off. Id.

DORSEY & WHITNEY LLP WWW.DORSEY.COM T 612.340.2600 F 612.340.2868

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( W

Judge Beck
January 21, 2015
Page 2

DORSEY'"

3.
The Agreement expressly provides that Sen. Tomassoni will not be a lobbyist for
RAMS. Id. at 1. The contract makes clear that a RAMS lobbyist will not be under the
supervision or control of Sen. Tomassoni. Sen. Tomassoni will have no role in hiring or
supervising the lobbyist. Id. The RAMS Executive Committee ("Executive Committee") will
select a lobbyist, with approval from RAMS's Board of Directors ("Board"). Id. The lobbyist will
be directly accountable to the Board and not the Executive Director. Id.
4.
Under the Agreement, Sen. Tomassoni is subordinate to the Board and the
Executive Committee. The Board hired Sen. Tomassoni, and Sen. Tomassoni must perform the
services the Board assigns. Id. The Executive Committee has authority to renew or renegotiate
the Agreement. Id. at 4. And the Board has the authority to discipline or terminate
Sen. Tomassoni. Id. at 3-4.
5.
As Executive Director of RAMS, Sen. Tomassoni's job duties involve
coordinating and seeking common ground among a diverse assortment of Range municipalities
and school districts. Aside from coordinating the efforts of Range schools and cities on
common problems, the Executive Director is charged with developing a cooperative approach
among RAMS members on economic development initiatives. This task requires regular
meetings with city, school, and township officials, as well as outreach and dialogue with area
businesses and other organizations. Duties also include preparing budgets, managing the
financial affairs of the organization, publishing a newsletter, and reporting on issues and
developments that impact RAMS members. Attachment A at 1; Attachment Bat art. VII, 6.
6.
RAMS is funded in part by appropriations from the taconite production tax.
RAMS receives three tenths of one cent per taxable ton of taconite under the taconite
production tax. Minn. Stat. 298.28, subd. 8. RAMS is also funded through voluntary
membership dues paid by cities and school districts. Minn. Stat. 471.58 authorizes cities and
school districts to pay these dues.
APPLICABLE LAW
I.

Senator Tomassoni's Position as Executive Director Does Not Violate Conflict of Interest
Statutes and Is Consistent with Advisory Opinion Precedent.

Under Minn. Stat. 10A.07, a conflict exists when "a public official ... in the discharge
of official duties would be required to take an action or make a decision that would substantially
affect the official's financial interests or those of an associated business, unless the effect on the
official is no greater than on other members of the official's business classification, profession,
or occupation." Minn. Stat. 1OA.07, subd. 1. A legislator is, by definition, a public official.
Minn. Stat. 1OA.01, subd. 35. An "associated business" is a business from which the
individual receives compensation as an employee in excess of $50 a month. Id., subd. 5.
In prior advisory opinions interpreting Minn. Stat. 1OA.07, the CFPDB has stated that
"[t]he occupation or profession of a legislator does not in itself create a conflict of interest."
Campaign Fin. & Pub. Disclosure Bd., Advisory Op. No. 325 at 1 (Feb. 20, 2001 ). A specific
vote, action, or decision by a legislator, however, may create a conflict of interest under Minn.
Stat. 10A.07. The CFPDB has advised that Minn. Stat. 10A.07 "does not try to preempt
potential conflicts of interest by preventing the members of certain occupations or professions

DOR SEY & WHITNEY LLP

( W DORSEY'"

Judge Beck
January 21, 2015
Page 3

from serving in the legislature." Advisory Op. No. 325 at 2. Rather, a legislator employed in a
position with the potential to create a conflict of interest "will need to make the same specific
evaluations of potential conflicts of interests when acting on legislation that a legislator
employed in any other profession must make." Id.
II.

Senator Tomassoni Will Make Full Disclosure if a Specific Conflict Arises and Recuse
Himself from Any Votes that Would Substantially Affect His Financial Interests or Those
of RAMS.

If a conflict of interest might exist, Senators must disclose it. Minn. Stat. 1 OA.07
subd. 1. Specifically, Senators must prepare a written statement describing "the matter
requiring action or decision" and "the nature of the potential conflict of interest." Id., subd. 1(1 ).
The written statement must then be delivered to the President of the Senate. Campaign Fin. &
Pub. Disclosure Bd., Advisory Opinion No. 237 at 3 (May 31, 1996). lfthere is not sufficient
time to prepare a written statement, the same information must be communicated orally. Id.
Senators may request to be excused from the vote or action presenting a conflict. Minn. Stat.
10A.07, subd. 2. The Senate may, in its discretion, excuse a Senator from the vote. See id.
If the Senate requires a Senator to participate in a vote that involves a conflict of interest, then
that Senator is required to file a written statement with the CFPDB within one week that
describes the action taken and the potential conflict of interest. Id.
Please be assured that Sen. Tomassoni intends to seek recusal from any votes that
would substantially affect his financial interests or those of RAMS as set forth in Minn. Stat.
10A.07.

CONCLUSION
Sen. Tomassoni does not believe that his acceptance of the position of Executive
Director of RAMS creates a conflict of interest in violation of Minn. Stat. 10A.07. The Board
has stated that this statute does not preempt conflicts of interest by categorically excluding
legislators from accepting certain positions. Advisory Op. No. 325 at 2. Accordingly, if
Sen. Tomassoni complies with the statutory disclosure and abstention provisions noted above,
in accordance with well settled precedent and law, we ask that the Board confirm that as the
Executive Director of RAMS he does not have a conflict of interest within the meaning of Minn.
Stat. 10A.07.
Senator Tomassoni consents to publication of his name and submitted attachments in
connection with the release of the opinion.

Sincerely yours,
DORSEY & WHITNEY LLP

Michael J. Ahern
Partner

DORSEY & WHITNEY LLP

Judge Beck
January 21, 2015
Page4

MJA:bb
Enclosures
cc:
Senator David Tomassoni

EXHIBIT A

RAMS EXECUTIVE DIRECTOR

RANGE ASSOCIATION OF MUNICIPALITIES AND SCHOOLS
EXECUTIVE DIRECTOR'S AGREEMENT

This agreement between the Range Association of Municipalities and Schools, hereinafter
referred to as "RAMS'', (the employer), and David Tomassoni, employed as Executive Director of
RAMS, is effective on the first day of January, 2015, when signed by both the President and Vice
President of RAMS, and David Tomassoni.
As Executive Director of RAMS, David Tomassoni will perform all duties as set forth in the
Constitution and By-Laws of RAMS, and agrees to perform the scope of services and duties as per the
written Job Description, which duties include but are not limited to the following :
1. Shall provide professional services to RAMS as assigned by the President and the Board of
Directors.
2. Shall employ temporary part-time staff when necessary to accomplish specific office functions.
3. The Executive Director will not be a lobbyist for RAMS. The Executive Committee will select a
lobbyist and the RAMS Board of Directors will approve the hire of the lobbyist and the lobbyist
will be accountable to the RAMS Board of Directors.
4. Shall meet with or direct staff to meet with city, school and township officials regularly to
ascertain issues and concerns that can best be addressed through RAMS, and will work to
maintain RAMS membership.
5. Shall meet with political entities, area corporations and other organizations to build cooperation
and credibility for RAMS.
6. Shall publish a newsletter on a regular basis, the frequency of which shall be determined by the
Executive Committee. The newsletter shall be published in addition to memos and updates sent
to RAMS board members.
7. Shall fulfill the duties of the Executive Director according to the RAMS By-Laws, report to the
membership indicating impacts that legislative and administrative acts have on members, and
shall do so in a nonpartisan manner in accordance with the RAMS motto - "One Range, One
Voice".

TERMS AND CONDITIONS OF EMPLOYMENT

a. COMPENSATION
For the duration of this contract the salary shall be $6,500 per month. During the Minnesota State
Legislative Session, the Executive Director will take a leave of absence and will not receive
monthly compensation or accrue PTO benefits from RAMS.
b. WORK SCHEDULE
The regular work week shall consist of 40 hours per week. To the extent practical, when not in
legislative session the Executive Director may work in or out of the office as needed to fulfill the
duties of the Executive Director and/or the mission of RAMS.
c. HOLIDAYS
The Executive Director will be paid for eight ( 8 ) holidays as established by the Board of
Directors:
New Year's Day, Memorial Day, Independence Day, Labor Day, Veterans Day, Thanksgiving
Day, Christmas Eve Day, Christmas Day
d. Paid Time Off- (Vacation & Sick Leave)
PTO shall be accrued at the following rates per years of service:
0 - 3 years

1.5 days (12 hours) per month or 18 working days per year

4 - 6 years

1.75 days (14 hours) per month or 21 working days per year

7 - 10 years

2 days (16 hours) per month or 24 working days per year

PTO may be used as earned, and accrued PTO should be used annually. A maximum of20 days
(160 hours) of PTO may be accrued (unless approved by the Executive Committee for
extraordinary reasons). Accrued PTO exceeding 160 hours in any calendar year will be forfeited.
PTO maybe be used in a minimum of two hour increments.
The Executive Committee shall approve the time in which vacation leave maybe taken.

e. MILITARY, PARENTAL AND FAMILY LEAVE

Leave shall be provided as required by the state and federal laws.
f.

JURY OR WITNESS DUTY

Regular compensation shall be earned when performing jury duty or when subpoenaed to testify
in a matter on behalf of RAMS.

g. MONTHLY CAR ALLOWANCE

No allowance given at the issuance of this contract.
A monthly car allowance may be added to future contracts.

h. HEALTH INSURANCE
No allowance given at the issuance of this contract.
A Health insurance rate may be added to future contracts.
L

CELL TELEPHONE ALLOWANCE

RAMS shall provide the Executive Director a cellular telephone or communication device and pay or
reimburse the monthly charges for RAMS business use of the Executive Directors cell telephone or
communication device.

J.

RESIGNATION
The Ex'ecutive Director is required to notify the RAMS Board of Directors in writing 90 days
prior to the effective date of his resignation in order to leave employment in good standing.

k. GRIEVANCE PROCEDURE
The grievance procedure shall cover disputes or disagreements regarding the terms and
conditions of employment, including discipline, termination and severance. A grievance
procedure shall consist of a four step process:
1. The grievance shall be presented in writing to the president of RAMS within 20 work days. If
not timely, the matter should be considered waived and not grieveable;
2. If the grievance is not resolved, it shall be heard by the Executive Committee of RAMS;
3. If not resolved by the Executive Committee, it shall be heard by the Board of Directors of
RAMS;
4. If unresolved after being heard by the RAMS Board of Directors, the grievance will proceed
to binding arbitration with an arbitrator selected by the State Bureau of Mediation Services.
Each party should equally share in the cost of Arbitration.

DISCIPLINE
The Executive Director shall be subject to disciplinary action including suspension without pay
or termination for failure to fulfill his duties and responsibilities or for any other conduct or behavior
which causes public embarrassment or casts RAMS in a negative light. The Executive Director may
demand a hearing before the Executive Committee or use the grievance procedure should such
disciplinary action occur.
TERM, RENEW AL AND RENEGOTIATION
This agreement shall continue in full force and effect beginning January 1, 2015, and shall
automatically terminate and conclude on December 31, 2016, unless revised, amended or re-negotiated
by the RAMS Executive Committee. Any modifications of or amendments or addendums to the
Agreement shall be binding only if the modifications, amendments, or addendum are in written form and
it is clearly stated that it is intended to be a modification of or an amendment or addendum to this
agreement. To be effective, the modifications, amendments, or addendum must be passed by the Board
of Directors and signed by both the President of RAMS and the Executive Director.
SAVINO CLAUSE
This agreement is subject to and shall be interpreted in accordance with the laws of the State of
Minnesota. In the event that any one or more of the provisions in this agreement should be determined to
be invalid, illegal, or unenforceable, the validity, legality and enforceability of the remaining provisions
contained in this agreement will not be affected or impaired in anyway.
This document is fully executed beginning on the first day of January 1, 2015.

RAMS President - Craig Pulford

RAMS Vice-President - Timothy S. Riordan

RAMS Executive Director - David Tomassoni

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