RENO CITY HALL FOR SALE...

Complaint

Issued to:
Nevada State Commission on Ethics

Submitted by:
Guy P. Felton III
Washington Stn. Box 50093
Reno, NV 89513

JULY 20, 1998
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NRS 281.240 Grant of authority to discharge duties of public office
unlawful; giving consideration for grant unlawful; penalties.

1. Every person holding or exercising any office under the laws or
constitution of this state, who shall, for any reward or gratuity paid,
or agreed to be paid, grant to another the right or authority to
discharge any of the duties of such office (except his lawful deputies),
shall be punished by a fine not exceeding $5,000, and shall be removed
from office.
[Note: "Gratuity - Something voluntarily given in return for a favor
or especially a service, hence, a bounty; a tip; a bribe."]

2. Every person who shall give, or make any agreement to give, any
reward or gratuity in consideration of such grant or authority, shall be
punished by a fine of not more than $5,000.

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

During the month of July 1998, Jeff Griffin, Mayor of Reno, did grant to
Ralph "Rusty" Humphries, talk show host on Reno's KKOH radio, the
authority to direct staff and resources of the City of Reno, to issue
"good will" proclamations in the name of the City of Reno, and to tour
the interior of the closed Mapes Hotel-Casino.

In return, and as compensation for his grant of authority to Mr.
Humphries, Jeff Griffin was given approximately two hours of air time on
Mr. Humphries' radio program. The market value of two hours of
advertising on KKOH during prime afternoon hours can be rated at $1,200
or more. Mr. Griffin is currently running for re-election to his
position as mayor.

Exchanging mayoral authority ... even minor instances of mayoral
authority ... for radio exposure during a campaign season is a clear
case of abuse of public power.

The foregoing actions were masked as a game in which Griffin and
Humphries swapped jobs for one day, 17 July 1998, a Friday.

Mr. Humphries and Mr. Griffin are friends. Neither person can deny this
fact. If he were to answer honestly, Mr. Griffin would admit that he
would never grant any of his authority to any critic of his for any
period of time. Mr. Griffin's act was discriminatory and pre-meditatedly
intended to add stature to Mr. Humphries' persona in the minds of
Humphries' listeners by anointing him as Mayor for a Day. Mr. Griffin is
on record as understanding the power of political influence, influence
which he has publicly admitted he is willing to use as he sees fit.

Mr. Humphries regularly demeans critics of Mr. Griffin (a controversial
public figure) on his program using tactics including at least one
threat of physical attack, yelling, name calling, and profanity.
Recorded documentation exists. On 13 July 1998, a Monday, Mr. Humphries
verbally attacked Reno Councilmember Candice Pierce on-air in a juvenile
and vicious manner. Ms. Pierce is recognized as not being dominated by
Mr. Griffin. (By contrast, other members of Reno's council are commonly
recognized as being dominated by Mr. Griffin.)

The City of Reno has no established policy permitting the mayor or other
municipal officer to play the game of swapping jobs with any other
person for any period of time.

The Reno City Council did not discuss nor make any mention of Griffin
swapping jobs with Humphries at any time in any public manner. Mr.
Griffin unilaterally decided to grant his mayoral role to Mr. Humphries
for one day.

During Griffin's appearance on Humphries' show, Griffin caused at least
one Reno Police Department command officer and at least one Reno Fire
Department command officer to also appear on said show. This can be
fairly interpreted as putting the public stature of Reno's fire and
police departments behind Mr. Griffin's re-election.

Mr. Humphries, acting as mayor, was permitted to visit the interior of
the Mapes. No ordinary citizen is commonly permitted to visit the
interior of the Mapes which is currently owned by the citizens of Reno.
The building has been closed for many years and is filled with "garbage"
and pigeon droppings, etc.; it is considered unsafe for humans due to
such factors as mold spores, etc. (This is not to say that it can not be
refurbished and made habitable ... as should be done.)

No value of city resources and staff time pertaining to the
Griffin-Humphries game has been announced. However, secretarial time,
community relations staff time, fire and police staff time, and city
hall office resources were committed to the Griffin-Humphries game ...
without any prior approval per due process or enabling legislation.
Unless a lower figure can be documented, the cost to Reno taxpayers for
the Griffin-Humphries game may be seen as at least $500. This figure can
be interpreted as public subsidation of Mr. Griffin's re-election
campaign.

Summary:

Mayor Griffin abused his mayoral powers by unilaterally granting
authority to Mr. Humphries to carry the title of Mayor for a Day and to
use City of Reno resources without lawful justification. In return, Mr.
Griffin received approximately two hours of free, friendly exposure on
Mr. Humphries' talk radio program DURING GRIFFIN'S CAMPAIGN FOR
RE-ELECTION.

Under the letter and spirit of NRS 281.240, Mayor Jeff Griffin should be
fined and removed from office.

Further, under the letter and spirit of NRS 281.240, Mr. Ralph "Rusty"
Humphries should be fined.

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