Recently, Eston “Dusty” Melton, a prominent local lobbyist, expressed his opinion that the Miami-Dade Commission on Ethics “dropped the ball” in dismissing an ethics complaint against Donald Trump for engaging in unregistered lobbying on his offer to manage the Crandon Park golf course. (Ethics Commission dropped the ball on lobbying violation, Aug. 11)
Melton is entitled to his opinion, but he is not entitled to his own facts or law on the subject. He concedes that the discussion initiated by Trump while playing golf with Mayor Carlos Gimenez was not lobbying, only an informal preliminary conversation. Melton incorrectly asserts that follow-up correspondence between Trump and the county, and his submission of the offer, constituted lobbying.
Trump’s first letter outlined the offer and requested that the mayor “advise as to the next steps that we should take to move the process forward.” This was not “lobbying” either by county standards or state law.
Asking, “What do I do next?” is not lobbying.
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Trump’s next letter, containing his unsolicited proposal, was addressed to Parks Director Jack Kardys, pursuant to a county ordinance outlining a procedure which contains no requirement that one register as a lobbyist to begin the process.
The Ethics Commission finding that the submission of a proposal initiating a county process is not lobbying is consistent with state law as well as common sense. Any citizen should be able to submit a proposal to a government agency. Does it make sense to force anyone with a proposal for an innovative environmental or transit solution to be a registered lobbyist before submitting it to the county?
Of course not.
Notwithstanding Trump’s fame or financial resources, he should be treated no differently than “Joe Citizen.”
The Ethics Commission did its job in finding probable cause that Ed Russo, Trump’s representative, failed to register as a lobbyist when he communicated months later with county personnel about the proposal.
Melton, as he has done on past occasions, has every right to question whether his competitors have adhered to the law. However, he would better serve his allies and clients if he took the time to understand the law.
The Ethics Commission staff provides regular instruction and education, including lobbyist ethics training. We also answer questions from anyone concerning difficult-to-understand legal provisions and our interpretation of them.
The Ethics Commission board is independent of any other government authority. It includes distinguished professionals of proven integrity, carefully reviews staff recommendations, and is no rubber stamp.
Joseph Centorino, executive director, Miami-Dade Commission on Ethics and Public Trust