DEAR DAWG: Our superintendent has a 50-yard line ticket to the Super Bowl, and we’re kind of wondering how that happened….

DEAR DAWG: The superintendent left work early today, in a buoyant, boisterous, almost giddy mood.  He’s on his way to Houston for the Super Bowl and he has let everyone within a three-county radius know that he will be sitting smack dab on the 50 yard line, about 20 rows up.  Just how much does something like that cost?  I don’t know, but I’m pretty sure that I would have to turn over my entire TRS account to get one of those prized ducats.  So how does our superintendent get so lucky? It turns out that he’s going to the game with some reps from the Acme Widget Company.  And it just so happens that the Acme Widget Company has a bid in on a major contract with our district that will be acted on by the board next month. Of course, the board will look for a recommendation from the superintendent about that. Hmmmm.  COINCIDENCE?  WE THINK NOT!

DEAR COINCIDENCE?  Hmmmm indeed! It sounds fishy!  But before you report your superintendent as a law breaker, find out who he sits with at the game.  It’s a violation of the Penal Code for certain public servants to accept gifts from vendors who have an interest in a pending contract.  But there is an exception for “food, lodging, transportation or entertainment accepted as a guest.”  So if the Acme folks are sitting right beside him, then we think he is a “guest,” and he is committing no crime.

However, he needs to report this.  A gift like this requires a “conflicts disclosure statement, as adopted by the Texas Ethics Commission.”  There is an exception if the gift is in the form of food, accepted as a guest. Otherwise, gifts have to be disclosed if the value exceeds $100.  We don’t know what Super Bowl tickets go for, but we think it’s a safe bet that they exceed $100.   Take a look at your policies at CHE and BBFA. It’s all spelled out there.