Florida Ethics Update: Commission on Ethics Determinations— August 2026 Meeting

FEI Florida Ethics News Update: Commission on Ethics Determinations—August 2026 Meeting

September 3, 2026

FCOE Meeting August 2026
Photo: The Florida Channel

During its August 28, 2026, meeting in Tallahassee, the Florida Commission on Ethics (Commission), the constitutionally created State agency responsible for interpreting and enforcing Florida’s governmental ethics laws, considered a focused agenda involving ethics complaints filed against public officials, financial-disclosure filing extensions and fines, administrative rulemaking, 2027 Legislative Recommendations, and the selection of Commission leadership. The materials provided for the meeting also included the Executive Director’s report on pending litigation, finances, and outstanding penalty matters.

 

Commission Highlights

  • Jeremy M. Rodgers was elected Chair and Jon M. Philipson Vice Chair for the 2026-2027 term beginning September 3, 2026.
  • The Commission dismissed certain allegations in the ethics complaint against then-former House member and current State Senator Randall Fine, while leaving other allegations for a public hearing.
  • The Commission considered amendments to its rules in Chapter 34-8, Florida Administrative Code (F.A.C.), updating financial-disclosure instructions and statutory citations for the 2026 calendar year.
  • The Commission continued development of its 2027 Legislative Recommendations, including whistle-blower protections for ethics complainants, a public records exemption for Commission members and staff, and Form 10 modernization.
  • The Commission took action on 38 additional ethics complaint matters, 15 of which were probable cause hearings, and 23 of which were dismissed for lacking legal sufficiency.

Public Session

Commission Selects New Chair and Vice Chair

The Commission elected Jeremy M. Rodgers as Chair for the 2026-2027 term beginning September 3, 2026, and elected Jon M. Philipson as Vice Chair. Rodgers, appointed by Governor Ron DeSantis in 2025 and reappointed in August 2026, has a background in technology, cybersecurity, local government, and military service. Philipson, also appointed in 2025, is a Tampa-based attorney whose practice includes business litigation, arbitration, and antitrust law.

Jeremy M. Rodgers
Jon M. Philipson
Jon M. Philipson

Source: Commission on Ethics press release dated September 2, 2026

Commission Dismisses Certain Allegations in Randall Fine Complaint; Remaining Allegations Proceed for Adjudication

During the meeting the Commission considered and approved a draft order dismissing certain allegations in Complaint No. 22-079 filed against former Florida House of Representatives member and current U.S. Representative for Florida’s 6th Congressional District, Randall “Randy” Fine concerning alleged conduct which occurred while he served in the Florida House. The Commission previously found probable cause in April 2023 concerning the ethics complaint filed by former member of the Brevard County School Board, Jennifer Jenkins—that the Fine’s conduct could violate the constitutional prohibition against abuse of office to obtain a disproportionate benefit and the statutory prohibition against misuse of public position.

 

After that probable cause determination, Florida law was amended to require allegations in an ethics complaint to be based on personal knowledge or information other than hearsay. Applying that newer standard and its discretionary dismissal authority, the Commission dismissed allegations which it believed were not supported by personal knowledge or non-hearsay information. Those dismissed allegations included claims that Fine encouraged a West Melbourne City Council member to criticize the Jenkins and her participation in a City-sponsored fundraiser for Special Olympics, urged a council member not to follow the City Attorney’s advice on a public-records request, and hired a private investigator to surveil Jenkins and publicize falsehoods about the investigator’s findings.

 

The public hearing will now focus on the complaint allegations the Commission concluded appeared to satisfy the current legal sufficiency standard: that Fine posted allegedly disparaging and false comments concerning Jenkins on a City Councilman’s social media post; that he told a City Council member and the West Melbourne Mayor that he would veto or reduce legislative funding for a City project and/or the Special Olympics because of Jenkins’ participation in a City fundraiser; and that he failed to respond to Jenkins’ public-records request for communications involving himself and a City Council member, as well as communications between Fine and the Mayor of Melbourne.

Ethics Note: The order does not decide whether the remaining allegations are true or establish an ethics violation. It instead narrows the issues that may proceed to a public hearing (which is a trial before an Administrative Law Judge) under the new complaint-sufficiency standard contained in Section 112.324(1)(a), Florida Statutes (F.S).

Source: Complaint No. 22-079 meeting materials and draft “Public Report and Order Dismissing Certain Allegations in Complaint”.

Financial Disclosure Extension Requests Granted

The Commission granted three requests for extensions of time to file annual financial disclosures after finding “good cause” pursuant to Section 112.3151, F.S.

 

Default Final Orders on Unpaid Financial Disclosure Fines

The Commission’s meeting materials included proposed default final orders for individuals who had not timely appealed or paid automatic financial-disclosure fines. The sample final order explains that late filing can generate an automatic fine of $25 per day, up to $1,500, and that failure to timely appeal waives the filer’s entitlement to an appeal. Depending on the filer’s current public status, unpaid final fines may be referred for salary withholding, collection, or wage garnishment. The packet included lists of active fined filers ready for collection and supporting proposed orders.

Ethics Note: Automatic financial-disclosure fines are distinct from civil penalties imposed after an ethics violation. They arise from late filing required financial transparency documents and are governed by the financial disclosure statutes and Commission rules.

Source: Financial Disclosure Fines packet dated August 13, 2026

Rulemaking: Chapter 34-8 Financial Disclosure Instructions

The Commission considered amendments to the financial disclosure instructions incorporated by reference into Chapter 34-8, F.A.C. The principal changes were intended to update the instructions for the 2026 calendar year and correct statutory citations in the instructions for CE Forms 6, 6F, 6X, 1, 1F, 1X, and related forms. The materials explain that the changes are primarily technical and instructional rather than substantive changes to the underlying disclosure obligations.

Source: August 13, 2026 memorandum regarding amendments to Chapter 34-8 and accompanying proposed rule materials.

 

2027 Legislative Recommendations

Each year the Commission develops a list of recommendations for legislation in an effort to improve Florida’s Code of Ethics and its enforcement. At Friday’s meeting the Commission continued its discussion of recommendations for the 2027 Legislative Session. The August memorandum asked members not only to decide which recommendations to advance, but also whether the Commission should actively lobby for selected proposals and whether a Commissioner should serve as legislative liaison.

 

Legislative items carried forward for recommendation in 2027 
 
  • Whistle-blower protection for ethics complainants, aimed at protecting persons who file valid ethics complaints from retaliatory employment or personnel actions.
 
  • A public records exemption for the identifying information (such as their home addresses and phone numbers) of Commission members and staff. During the meeting, the Commission’s Executive Director, Kerrie Stillman, explained that a need for greater security protections, including hardening the Commission’s office and pursuit of the public records exemption, was necessary following an increase in threats and harassment aimed at their agency. Stillman explained “Commission staff sometimes receive hostile communications from members of the public, as well as ethics Complainants who are upset about the outcome of complaints they have filed.”
 
  • Also recommended as a technical correction was the modernization of the Form 10, used to annually disclose gifts from governmental entities, direct support organizations, and honorarium event related expenses. The recommendation seeks an update to the statute requiring its use including updating its filing location and related instructions now that Forms 1 and 6 are filed electronically.
 

Ethics Note: Legislative recommendations made by the Commission do not change Florida law. Any proposal ultimately must be introduced, passed by the Legislature, and become law through the ordinary legislative process.

Source: August 13, 2026 memorandum, “Part 2 of Discussion of Legislative Plan and Recommendations for 2027.”

Executive Session

During its closed session meeting (wherein confidential and exempt matters are addressed) the Commission took action on 38 matters. In a Press Release issued on Sept 2, 2026, the Commission made the following findings.

 

Ethics Complaints Considered for Probable Cause

 

During the Executive Session meeting, 15 ethics complaints were considered for probable cause.

 

Probable Cause Found Against former Florida House of Representatives Member and Current U.S. Representative for Florida’s 6th Congressional District, Randall “Randy” Fine Involving Alleged Gifts

The Commission considered three consolidated complaints against former Florida House of Representatives member and current U.S. Representative, Randall “Randy” Fine, concerning alleged conduct which occurred while he served as a member of the Florida House. The Commission found probable cause on an allegation that then-Representative Fine accepted gifts in excess of $100 from a prohibited source and probable cause that he accepted prohibited gifts from a political committee. No probable cause was found on an allegation that he failed to accurately report assets and sources of income on his 2023 Form 6, “Full and Public Disclosure of Financial Interests.”

 

Probable Cause Found Against Former Citrus County Commissioner

The Commission considered three complaints filed against Ruthie Davis Schlabach, former Citrus County Commissioner. The Commission found probable cause to believe Schlabach violated the post-officeholding ethics restriction when she represented another person or entity before her former board within two years of leaving office. The Commission found no probable cause that she violated the Constitutional post office holding prohibition by lobbying, for compensation, her former Commission on an issue of policy within six years of leaving her position.

 

No Probable Cause Found in Lee County Sheriffs Office Matters

The Commission found no probable cause to believe that Lee County Sheriff’s Office Commander Rob Casale, Chief James Rankine, Major Chris Reeves, Undersheriff John Holloway, Major Mark Shelly, or Chief Matthew Sands, misused their positions to benefit themselves or another person concerning their involvement with a traffic stop and arrest of an off-duty Deputy who had been pulled over for speeding and DUI.

 

Probable Cause Found Against Kissimmee Mayor

The Commission found probable cause to believe that Jackie Espinosa, Mayor of Kissimmee, had an employment or contractual relationship with an entity doing business with her agency when her business accepted grant money that was administered by her agency.

 

In another complaint filed against the Espinosa the Commission rejected the recommendation of its attorney (referred to as “Advocate”) and voted to find no probable cause that Espinosa failed to report a gift over $100 on a Form 9, “Quarterly Gift Disclosure,” because she had disclosed the gift on the wrong form, based on the advice of the City Attorney.

 

No Probable Cause Found Against Montverde Town Council Member

No probable cause was found to believe Bryan Rubio, Montverde Town Council Member, had a conflicting contractual relationship by simultaneously serving on his Homeowners Association Board of Directors, whose members occasionally appeared before the Town Council.

 

No Probable Cause Found Against Brevard County Code Enforcement Officer

The Commission found no probable cause to believe that Bill Amos, Brevard County Code Enforcement Officer, misused his position to benefit himself or another person when he indicated to a property owner with code violations that he knew someone who might be interested in purchasing the property.

 

Complaint Dismissed Due to Death of Former Orange City Vice-Mayor

A complaint filed against former Orange City Vice-Mayor, Alex Tiamson, was dismissed due to the fact that he died during the pendency of the investigation.

 

Ethics Complaints Considered for Legal Sufficiency

 

A substantial portion of every Commission meeting is devoted to reviewing newly filed complaints for legal sufficiency. Before any factual investigation begins, the Commission must determine whether a complaint alleges facts within its jurisdiction, states a potential violation of the ethics laws, and is based upon personal knowledge or other legally sufficient information rather than mere speculation or hearsay. During the meeting, the Commission reviewed and dismissed 23 complaints for failing to satisfy the statutory requirements necessary to proceed.

Ethics Note on Why Legal Sufficiency Matters: Legal sufficiency review serves as an important safeguard within Florida’s ethics enforcement system. It protects public officials from investigations based upon legally deficient allegations while preserving Commission resources for complaints that, if proven, would constitute violations of the ethics laws. Importantly, dismissal for legal insufficiency does not represent a determination that the underlying allegations are true or false; instead, it reflects only that the complaint, as filed, does not satisfy the threshold legal requirements established by statute.

 

At its meeting the Commission dismissed 23 complaints filed against the following public servants due to a lack of legal sufficiency: MICHAEL ILCZYSZYN, Cape Coral City Manager; CORINNE LAJOIE, Dania Beach Deputy Zoning and Planning Director; ASHLEE M. HOFBERGER, Escambia County Commissioner; REBECCA BAYS, Citrus County Commissioner; JEFF KINNARD, Citrus County Commissioner; HOLLY DAVIS, Citrus County Commissioner; JOHN TWOMEY, Long Lakes Ranch Community Development District Secretary; BRENDA HOLT, Gadsden County Commissioner; JOSHUA STREET, Panama City Commissioner; FABIOLA STUYVESANT, Altamonte Springs City Manager; LARIN LEWIS, St. Lucie County School District Human Resources employee and Notary Public; MICHAEL FULLER, Panama City Development Services Director; JOHN MEISEL, West Villages Improvement District Supervisor; JOHN ANTMANN, Seminole County Public Schools Human Resources Investigator; KELLY MASON, Collier County District School Board; DAVID GATTIS, Belleair Beach Mayor; GREG ST. JEAN, Collier County Code Enforcement Officer; JOHN MEISEL, West Villages Improvement District Supervisor; PAWEL SZESZKO, Beach Community Development District Supervisor; DAVID KLEIN, Lee Memorial Health System Board Member; VANESSA OLIVER, Member of the Florida House of Representatives; JENNA PERSONS-MULICKA, Former Member of the Florida House of Representatives and Lee County Supervisor of Elections; and WALTER GREEN, City of Dunnellon Mayor.