Summary
The Leelanau County Board of Commissioners' Conflict of Interest and Complaint Policy Committee held its first meeting on December 19, 2025, with Commissioners Alan Campbell (District 5), Gwenne Allgaier (District 6), and Steve Yoder (District 7) present. The committee elected Yoder as Chairman and spent the meeting reviewing the County's current Conflict of Interest Policy and Non-Union Personnel Policy with Administrator James Dyer and HR Manager Jen Kain. Discussion centered on whether to expand the conflict-of-interest policy to employees, develop a separate Code of Ethics, and redesign the complaint procedure, particularly for complaints against the Administrator. No formal votes were taken on policy changes; the committee reached consensus for Dyer and Kain to draft proposals for a future meeting.
Public Comments
No public comments were made during either public comment period on the agenda.
Other Business
The committee approved its agenda as written (Motion by Yoder, seconded by Allgaier; Ayes 3 - Yoder, Allgaier, Campbell; No 0) and elected Commissioner Steve Yoder as Committee Chairman (Motion by Allgaier, seconded by Campbell; Ayes 3 - Allgaier, Campbell, Yoder; No 0).
Extensive discussion addressed the origin of the committee's formation, referencing Administrator Dyer's prior board service with Peninsula Housing, Land Bank, and Brownfield entities, and a related property tax matter involving Mawby (described as saving approximately $18,000 a year in taxes through a nonprofit affordable-housing effort). Commissioner Allgaier defended Dyer's disclosures and stated there was never personal financial gain in those situations. Commissioner Campbell said the committee's purpose extends beyond any single incident.
The committee also discussed a proposed Code of Ethics modeled partly on City of Traverse City and Grand Traverse County policies, gift/food limits (a $200/day threshold was mentioned), and where conflict-of-interest declarations should appear on Board agendas (Campbell suggested placement after agenda approval; Yoder suggested after public comment).
For complaint procedures, extensive debate occurred over creating a three-member panel (proposed as bipartisan) to determine whether complaints - especially against the Administrator - warrant investigation and to select an investigator (options discussed included the Sheriff, HR professionals from other counties, or the County's retained firm Cohl, Stocker & Toskey, P.C.). Allgaier favored using Cohl, Stocker & Toskey; Campbell preferred a fully independent, non-County-affiliated investigator. Confidentiality of complainant identity was debated, with Dyer and Chief Deputy Clerk Jennifer Zywicki disagreeing on whether an accused elected official should be told who filed a complaint against them. No final decisions were reached on panel composition, investigator selection process, or disclosure rules.
Action Items
- Administrator Dyer and HR Manager Kain to draft a Conflict of Interest Policy addressing: what constitutes a conflict, who determines it, how it is finalized, and resulting actions.
- Dyer and Kain to draft a separate Code of Ethics policy applicable to non-union employees and Commissioners, incorporating elements from the City of Traverse City's policy as requested by Commissioner Campbell.
- Draft policies to be brought back to the committee for recommendation to legal counsel before a full Board vote.
- Complaint procedure draft to address a three-member panel process for complaints against the Administrator, including investigator selection and confidentiality/disclosure rules; next committee meeting to be scheduled once materials are ready.
- Ongoing tension noted regarding Administrator Dyer's past board involvement with Peninsula Housing/Land Bank/Brownfield and the related property tax matter, which several commissioners identified as the origin of this policy review.