Florida Ethics Update: Commission on Ethics Determinations—November 2025 Meeting
November 20, 2025
During its meeting on Friday, November 14, 2025, the Florida Commission on Ethics (Commission), the constitutionally created independent agency tasked with interpreting and enforcing the State’s governmental ethics laws, took action via Zoom on a myriad of matters involving the Code of Ethics for Public Officers and Employees (Florida Code of Ethics) and the “Sunshine Amendment” to the State constitution (Art. II, s. 8, Fla. Const.).
Public Session
Ethics Complaint Settlement
The Commission considered and approved the settlement (referred to as “Joint Stipulation”) of an ethics complaint brought against a member of the Board of Fire Commissioners for Cedar Hammock Fire Control District, John Stevens, and the Commission’s attorney (referred to as “Advocate”) wherein he was found to have misused the official resources of his office while campaigning for re-election when he used the District’s email lists to send out an e-Blast campaign email thanking supporters. In light of this violation, the Commission will recommend that a civil penalty of $1,000 be imposed by the Governor.
Dismissal of Certain Allegations of Ethics Complaint Against Former Mayor of Boca Raton Due to Lack of Personal Knowledge by Complainant
The Commission considered a draft recommendation to dismiss certain allegations of a complaint filed against former Boca Raton Mayor, Susan Haynie, which had been investigated and probable cause had been found indicating that while Mayor Haynie had violated Florida’s financial disclosure law, voting conflicts law, conflicting employment or contractual relationship provision, and misused her official position. While the matter was pending an administrative trial at the Division of Administrative Hearings (DOAH) a new law went into effect in 2024 which requires that all ethics complaints must be based on “personal knowledge or information other than hearsay.”
At Friday’s meeting the Commission retroactively applied the new complaint standard to the allegations and determined that only the possible violations of the financial disclosure law (involving filing inaccurate disclosures in 2012, 2013, 2014, 2015, and 2016) met the heightened compliant requirement. As such, the Commission voted to dismiss all other allegations in the complaint as they were not based on personal knowledge or information other than hearsay as the Complainant learned of the alleged unethical conduct of the Mayor solely through news articles. However, the financial disclosure allegations in the complaint will move forward with a public trail or settlement.
Dismissal of Ethics Complaint Involving Former Member of the Polk County School Board
At the meeting the Commission also approved the dismissal of an ethics complaint filed against former member of the Polk County School Board, Lori Cunningham. The complaint alleged that she had a prohibited conflicting contractual relationship when a company that she owned sold mandatory school uniforms to two charter schools within the District. Although the Commission at its January 2024 meeting had found probable cause indicating that a prohibited conflict of interest existed concerning these business dealings—further information obtained by the Commission’s attorney in preparation for the administrative trail at DOAH indicated that Cunningham “was not in a position to favor her private interests over her public responsibilities to the School District” as the School Board had only limited regulatory authority over the charter schools and parents at issue.
Adoption of Ethics Opinion Advising a Former State Attorney Concerning Application of Post Employment Restrictions
The Commission adopted a formal opinion advising a former State Attorney, Dave Aronberg, now practicing law in his newly established private law firm, that he would not be prohibited by Florida’s post-public-employment or ‘revolving door’ laws from representing criminal defendants in cases prosecuted by the State Attorney’s Office where he previously served, as long as the cases were initiated after he left office.
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