Former Holyoke Councilor Bartley Alleged Conflict of Interest Violations
Summary
The State Ethics Commission's Enforcement Division issued an Order to Show Cause against former Holyoke City Councilor David Bartley, alleging conflict of interest law violations. The Order alleges that Bartley represented private parties in four real estate matters involving the City of Holyoke between 2023 and 2025 while serving as a city councilor. The Order also alleges Bartley failed to complete the required State Ethics Commission online training program until 2025, violating the law's requirement that public employees complete training within 30 days of becoming a public employee and every two years thereafter.
“The conflict of interest law prohibits municipal employees from acting as agent or attorney for anyone other than the municipality, or doing paid work for anyone other than the municipality, in connection with matters in which the municipality is a party or has a direct and substantial interest.”
Massachusetts attorneys holding or seeking public office should audit their private practice for representations that intersect with their public employer's interests, particularly real estate matters involving municipalities. The Commission's enforcement action establishes that representing private parties in matters where the city is a party or has a direct and substantial interest can trigger civil penalties of up to $10,000 per violation. The Order also demonstrates that the ethics training requirement is independently enforceable—failing to complete training within the prescribed timeframe (30 days of becoming a public employee and every two years thereafter) is a separate violation even when no other conflict of interest conduct occurs.
What changed
The Enforcement Division filed an Order to Show Cause against former Holyoke City Councilor David Bartley following the Commission's finding of reasonable cause to believe he violated conflict of interest law. The Order specifically alleges Bartley, while serving as city councilor, represented private clients in real estate matters in which the City of Holyoke was a party or had a direct and substantial interest. The four incidents include representing heirs in a Housing Court matter involving the city, responding to an Attorney General demand letter on behalf of a property owner, representing a client in connection with a reverter clause waiver request, and communicating with city employees about State Sanitary Code violations. The Order also alleges Bartley failed to complete required ethics training until 2025 despite being a city councilor since 2012.
Municipal employees and officials in Massachusetts should be aware that representing private parties in matters where the municipality is a party or has a direct and substantial interest is prohibited by G.L. c. 268A, Section 17. Public officials engaged in private legal practice should audit their client matters for conflicts with their governmental role. The failure to complete required ethics training within prescribed timeframes is itself a separate violation, and civil penalties of up to $10,000 may be imposed per violation. A public hearing will be scheduled within 90 days of the Order.
Penalties
Up to $10,000 per violation
Archived snapshot
Apr 20, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
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- State Ethics Commission
Press Release
State Ethics Commission’s Enforcement Division Alleges Former Holyoke City Councilor David Bartley Violated Conflict of Interest Law
Commission found reasonable cause to believe Bartley represented private parties in real estate matters involving the city
For immediate release: 3/18/2026
- David A. Wilson, Executive Director
Boston — The State Ethics Commission’s Enforcement Division issued an Order to Show Cause today alleging that former Holyoke City Councilor David Bartley violated the conflict of interest law. The Order alleges that while serving as a city councilor, Bartley represented private parties in real estate matters involving the city and failed to comply with the law’s mandatory training and education requirements. By filing the Order, the Enforcement Division initiated an adjudicatory proceeding against Bartley.
The Order to Show Cause states that in 2023-2025, while he was a city councilor, Bartley represented his private law clients in four real estate matters in which the City of Holyoke was a party or had a direct and substantial interest. The Order alleges that:
- In 2023, while the Housing Court was considering the city’s petition to enforce the State Sanitary Code at a Holyoke property, Bartley, as attorney for the late owner’s heirs, communicated with the city’s attorney regarding a continuance of the petition and was paid by the heirs upon the sale of the property;
- After the city referred a Holyoke property to the Attorney General’s Office regarding State Sanitary Code violations, Bartley responded to a January 2024 demand letter from the Attorney General’s Office on behalf of the property owner;
- In February 2024, Bartley represented a client who had purchased a property from the city in 2019 which included a reverter clause allowing the city to take the property back if it was not developed within five years. As attorney for the property owner, Bartley communicated with a prospective buyer’s counsel in connection with a request for a waiver of the reverter clause; and
- From September 2024 until February 2025, Bartley represented a deceased Holyoke property owner’s heirs and, as their attorney, communicated with city employees concerning the condition of the property and State Sanitary Code violations. The conflict of interest law prohibits municipal employees from acting as agent or attorney for anyone other than the municipality, or doing paid work for anyone other than the municipality, in connection with matters in which the municipality is a party or has a direct and substantial interest. The Order alleges Bartley violated these prohibitions.
In addition, the Order alleges that Bartley, despite being a city councilor since 2012, did not complete the State Ethics Commission’s conflict of interest law online training program until 2025, and violated the law’s requirement that public employees complete the online training program within 30 days of becoming a public employee and every two years thereafter.
Pursuant to the Commission’s Enforcement Procedures, the Enforcement Division files an Order to Show Cause against a subject following the Commission’s finding of reasonable cause to believe the subject violated the conflict of interest law. Before filing the Order to Show Cause, the Enforcement Division gives the subject the opportunity to resolve the matter through a disposition agreement. The Commission will schedule a public hearing on the allegations against Bartley within 90 days.
The Commission is authorized to impose a civil penalty of up to $10,000 for each violation of the conflict of interest law.
The Commission encourages public employees to contact the Commission’s Legal Division at 617-371-9500 for free advice if they have any questions regarding how the conflict of interest law may apply to them.
Media Contact
Gerry Tuoti, Deputy Chief, Public Education and Communications Division
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Phone
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State Ethics Commission
The State Ethics Commission is an independent state agency that administers and enforces the provisions of the conflict of interest law and financial disclosure law.
Media Contact
Gerry Tuoti, Deputy Chief, Public Education and Communications Division
Phone
Online
Related
Order to Show Cause in the Matter of David Bartley
G.L. c. 268A, Section 17- Divided Loyalties Restriction for Municipal Employees
2026 State Ethics Commission Press Releases
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