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number of scandals; prohibit officials from being identified with or soliciting <br />for any charity, directly or indirectly <br />12. Non-functioning ethics commissions - this is the norm; for how to overcome <br />this obstacle, see the Checklist of Ethics Commission Activities above <br />13. Back� - the erosion of ethics prograins by local legislative bodies; can be <br />overcome by language in the charter or ethics code preventing this <br />14. SLAPP suits - harassment suits and ethics complaints against complainant or <br />ethics commission; can be partially overcome by not allowing complainants to <br />withdraw complaints (so that threatening them cannot work), providing legal <br />fees for complainants who are sued, and treating contributions to legal defense <br />funds as gifts <br />15. Com�lainant �enalties and legal fees - often the highest penalty in an ethics <br />code is for those who file "false or frivolous" complaints; this causes no <br />complaints to be filed; can be o� ercome by allowing an ethics commission to <br />initiate investigations without a formal complaint, and the public dismissal of <br />baseless complaints, instead of a penalty imposed on the complainant <br />16. Local government attorne� - by giving overly lebal ethics advice and advice in <br />the interest of the official rather than the public, government attorneys are <br />partially responsible for a large percentage of ethical misconduct; can be <br />overcome by bivinb an ethics coinmission a monopoly over ethics advice <br />For a Glossary of Terms, see the glossar� in my book Local Governnment Ethics 1'ro�rams. <br />29 <br />