How to Hold Public Officials Accountable for Their Ethics Violations and Conflicts of Interest
Here's a plan for citizens to file complaints and to demand that action be taken for ethics violations and conflicts of interest situations.
When elected officials take campaign donations from developers or unions and then vote on those same donors’ projects or contracts, it can undermine trust even if it’s legal.
Here’s a step‑by‑step plan for citizens to shine a light on political relationships, file complaints, and demand action.
The Steps to Holding Public Officials Accountable
1) Understand the ethics rules and references
Nevada’s ethics law (NRS 281A.420) requires public officers, including city council members and commissioners, to disclose conflicts and, when their “independence of judgment” is materially affected by a private commitment, to abstain from voting.
The Nevada Commission on Ethics publishes plain‑English guidance on Disclosure & Abstention that shows what must be said on the record and when abstention is required.
Reno’s Administrative Code 2.20 (Code of Ethics) bars acquiring interests affected by city contracts/transactions and requires ethical conduct by public officials and appointees.
Why this matters: Citing specific statutes/sections in complaints creates a clean record for any follow‑on action.
2) Build a verifiable “donation → vote → paid work” record
Create a matrix for each official that lines up:
Who donated (developer/union, principals, PACs), amount, and date (from campaign reports).
What matter was voted on (agenda item #, project name, union contract, date, motion, vote).
What private work existed (law firm or consulting engagements, dates, matter if public).
Then flag potential triggers under NRS 281A.420: (a) “pecuniary interest,” (b) “gift or loan,” or (c) “commitment in a private capacity” (e.g., client, employer, business partner). Note any on-the-record disclosure (exact words) and whether you abstained from voting.
3) Use the right venue for accountability
Nevada Commission on Ethics (NCOE): File a complaint when you believe disclosure/abstention duties were breached. The Commission has already handled Reno matters involving union contract votes and disclosures, so it is the proper forum for this fact pattern.
City of Reno – Code Enforcement/Ethics & City Attorney: Cite Admin Code 2.20 and request written opinions or guidance to the body about future recusals. Ask the clerk to add a standing agenda cue for disclosure/abstention before each item.
Lobbyist compliance: Ensure developer/union representatives who appear are registered city lobbyists and wearing badges (RMC 2.22). If not, request enforcement; this helps surface relationships before votes.
4) Calibrate expectations about “donations = automatic recusal”
Across the U.S., campaign contributions alone rarely force recusal unless they meet statutory thresholds or create a “commitment in a private capacity” (e.g., current client/employer). In Nevada, the key is whether the official’s independence of judgment is materially affected, which may be the case when the donor is also a current client.
Tailor your arguments to those 281A.420 triggers, not just the fact of a donation.
5) Put clean asks on the record at meetings
Before a vote on a developer/union item:
Cite NRS 281A.420 and request a specific, on‑the‑record disclosure naming the relationship (client/employer, retainer, recent paid work, sponsorships).
If a private commitment exists, ask the official to abstain and have counsel confirm on the microphone.
Ask the chair to sequence disclosures before deliberation — the Commission training recommends that timing.
6) File better, tighter complaints (when warranted)
A strong NCOE complaint typically includes:
A short timeline with citations to meeting videos/minutes (time stamps help).
Screenshots of Form C&E (campaign) entries matching the agenda item dates.
Any engagement letters, bios, firm webpages, or docket entries showing the private client relationship (for the “commitment in a private capacity” prong).
The exact disclosure (or absence) and the vote taken.
NCOE complaints are investigated confidentially; adjudicatory deliberations are not under the Open Meeting Law. Be patient and precise.
7) Push for structural fixes (policy, not personalities)
City policy update: Amend Reno’s ethics code or council rules to require:
Written pre‑meeting disclosure forms for any item involving a donor above a dollar threshold in the past 12–24 months.
Per‑item recusal checklists (the Commission recommends check processes).
Cooling‑off window: Adopt a local policy (by resolution) that if a party is a current client or employer, the official must abstain.
Lobbying sunlight: Require the clerk to publish a lobbyist–item cross‑reference for each agenda.
8) Organize community voice around “process integrity,” not outcomes
Even when the neighborhood dislikes a project, focus your remarks on whether the process met disclosure/abstention rules and whether the public could trust the deliberation. That resonates with the Commission’s framework and avoids turning a legal matter into a land‑use referendum.
9) Document patterns for media and future remedies
Keep a public log that lists, for each meeting:
The item, the interested party, any donation, any disclosure, and the vote.
Whether the party’s representative was a registered lobbyist.
This “sunlight dashboard” often prompts better behavior without a complaint.
10) Be precise when naming individuals
Some matters are already on record (e.g., the Ethics Commission’s prior findings and actions related to union‑contract votes and disclosures involving Councilmember Reese). When you reference those, cite them exactly and stick to what’s public and adjudicated; treat anything else as an allegation until there’s a formal outcome.
Power, Influence, and Donations: Inside Devon Reese’s Rise in Reno Politics
Here’s the Bottom Line
You don’t need to be a lawyer to hold officials accountable. By staying organized, using the correct language, and documenting what you see, you can help restore trust in local government. It’s time to get organized and hold officials accountable.
Do you have a story to tell? Write to me at: mike@mikesrenoreport.com
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