Dallas: Where Ethics Go to Die

On November 28, 2023, I walked into the Dallas City Secretary’s office with four witness affidavits and a USB drive containing evidence of ethics violations by three City Environmental Commissioners.

The City Secretary’s office was confused. They turned me, a licensed attorney trying to turn in evidence of ethics violations, away. 

While I overcame this snafu in a return trip to City Hall, over 14 months later, the City’s Inspector General’s office did the exact same thing again. On February 18, 2025, City-employed investigators turned me, my clients, and our evidence away. The blip of a reason that we received after a supposed 64 week “investigation” was that our allegations were “unsubstantiated” due to a lack of “definitive testimony or sufficient documentation.”  

In 2024, according to Quarterly Reports, the City’s Inspector General’s office received 412 ethics complaints, closed out 471 ethics complaints, and only sent 2 of the 471 ethics complaints it processed onto a formal hearing before the Ethics Advisory Commission.

In 2024, 6 out of 15 seats on the Ethics Advisory Commission were vacant, and 2 out of the Commission’s 4 regularly scheduled meetings were cancelled.

The Ethics Advisory Commission is the only body empowered to actually provide Dallas residents due process on their ethics complaints. The Ethics Advisory Commission has the power to weigh evidence, witness testimony and credibility in a public hearing, and make open and public determinations as to whether City officials violated the Ethics Code. 

“Justice delayed is Justice denied” is not an adequate description for a City Ethics process that allows only .04% of all ethics complaints filed to ever see the light of day in a public hearing. Or for a City Ethics process that took over 14 months to let my client’s well-supported ethics complaints die on the bureaucratic vine.

What do I mean by well-supported ethics complaints? 

As one simple example, we submitted two sworn affidavits confirming that an Environmental Commissioner, while representing the City at a public event, gave the middle finger to two environmental advocates.

This was not “definitive testimony” according to the City.  

The City never required the accused Commissioner to swear under oath that she did not flip off my clients. 

In the old days, justice was determined by witness counting. Under that archaic standard, the sworn testimony of two witnesses warrants not just a hearing but a guilty verdict when stacked up to exactly zero witnesses denying the allegation under oath. 

In Dallas, how many witnesses are required for an ethics complaint to be “substantiated”? Three? Five? Ten? 

The public will never know. The City’s investigation standards (if any exist) are hidden behind closed doors.

This was not the most serious issue we presented. We had video recordings of a Commissioner behaving badly, a threatening letter a Commissioner submitted to the employer of one of my clients, and police reports, police body camera footage, and a court transcript documenting abuse of power.  

But even this was not enough for the City to allow the Ethics Advisory Commission to decide whether these Commissioners violated their ethic obligations.

We knew the City’s process was a joke from day one. 6 weeks after I turned our USB drive into City Hall, I received an e-mail asking for the drive. The City didn’t know it already had our evidence. It took 6.5 months for the City to ask to interview my clients, and then required my clients to sign gag orders agreeing not to speak directly with the Ethics Advisory Commission about their complaints during the investigation. The City then closed out our complaints without a hearing without providing us any process to appeal that decision.

In 2023, the City ran a contest to name its Ethics Hotline, choosing the “Speak Up Line” as the winner. The “Speak Into The Void” line would be more accurate. If you call, there is a 99.96% chance your ethics complaint will be closed without a hearing, and there won’t be anything you can do about it.