As required by the Local Government Ethics Law, Woodlynne Borough (Camden County) Councilwoman Sharon Earley and her husband, Planning Board Member Robert Earley, both filed Financial Disclosure Statements (FDSs) in 2017.  These filings are intended to disclose basic information regarding public officials’ and their family members’ sources of income, business interests and real estate holdings.  Their purpose is to inform the public of the sources of the public officials’ income so that the public can detect and report conflicts of interest (e.g. a zoning board member voting on an variance application filed by his or her spouse’s employer).

But, both Earleys claimed on their FDS forms to have had no sources of income in 2016, earned or unearned, that were in excess of $2,000.  Both also claimed not to have had interests in any business organizations.  The only thing the Earleys disclosed on their forms was ownership of their Cedar Avenue home.  While, I suppose that it’s possible for a married couple who are homeowners in New Jersey to not have a source of income greater than $2,000, it seems very unlikely given that the property taxes on the home are more than $2,000.

After reviewing the Earleys’ FDS forms, I decided to dig a bit deeper.  I found that, including the Earleys, five Woodlynne Borough Council members who served in 2017 and four 2017 Planning Board members likewise claimed that their households lacked a $2,000 or greater source of income during 2016.

It seems to me that at least some of these officials really do have sources of income greater than $2,000 but would prefer not to report them.  Failure to report, however, is against the law.  Below is the text of complaint I filed yesterday against all nine officials with the Local Finance Board–the state agency that enforces the ethics law.  The Board will conduct an investigation (which generally takes 2 to 3 years) and has the power to levy fines of between $100 and $500 if it finds that the ethics law has been broken.  The complaint names all nine officials and provides links to each official’s 2017 FDS filing.
February 12, 2018

Patricia Parkin McNamara
Local Finance Board
101 S Broad St – PO Box 803
Trenton, NJ 08625-0803
(via e-mail only to [email protected])

Dear Ms. McNamara:

We intend this e-mail to be our complaint against the following nine (9) Local Government Officers (LGOs) serving Woodlynne Borough (Camden County) who all held office in 2017 (Note that each name contains a live link to that LGO’s 2017 Financial Disclosure Statement (FDS)):

Joseph Chukwueke, Council Member 
Sharon Earley, Council Member 
Alphonso Thomas, Council Member 
Gwendolyn Torres, Council Member 
William Valle, Council Member 
Amy Earley, Planning Board Member 
Robert Earley, Planning Board Member 
Noble Kelly, Planning Board Member 
Devy D. Robinson, Planning Board Member 

1. State the point of the Local Government Ethics Law (LGEL) alleged to be violated. 

N.J.S.A. 40A:9-22.6 which requires each LGO to file an annual Financial Disclosure Statement (FDS).

2. State the name(s) and title(s) of the parties involved in the action and against whom the complaint is filed. 

Complainants are John Paff and the New Jersey Libertarian Party and Respondents are Joseph Chukwueke, Sharon Earley, Alphonso Thomas, Gwendolyn Torres, William Valle, Amy Earley, Robert Earley, Noble Kelly and Devy D. Robinson.

3. Set forth in detail the pertinent facts surrounding the alleged violative action. 

Each Respondent is required to disclose on his or her FDS “each source of income, earned or unearned, which [he or she] received in excess of $2,000.”  Knowing the source of officials’ income is important because it helps the public detect conflicts of interest that might otherwise go unnoticed.  For example, if an applicant before the Planning Board employs and pays a Planning Board member’s spouse more than $2,000 per year, a member of the public so informed could call attention to a conflict of interest if that Planning Board member attempted to vote on the application.  In each of these nine (9) cases, however, the LGO stated that neither the LGO nor any members of the LGO’s immediate family had any sources of income in 2016 from which more than $2,000 was received.  While it is perhaps possible for an individual or family to live in New Jersey and have no single source of income of greater than $2,000, it is highly unlikely that five of the seven members of the Mayor and Council and four members of the Planning Board all have no sources of income from which more than $2,000 is derived.  Further, Chukwueke and his wife, Sharon and Robert Earley, Valle and his wife, and Robinson and her husband all report ownership of real estate.  It is general knowledge that real estate taxes in New Jersey would require a source of income in excess of $2,000 to pay.  Complainants allege that each of these nine LGOs and their immediate family members have sources of income in excess of $2,000 but have chosen not to disclose those sources. 

4. Indicate whether the complaint concerns the complainant in any way and what, if any, relationship the complainant has to the subject of the complaint. 

Complainants have no interest in or relationship to this complaint greater than any other citizen or organization who wishes for all government officers and employees to comply fully with the Local Government Ethics Law. 

5. Indicate any other action previously taken in an attempt to resolve the issue and indicate whether the issue is the subject of pending litigation elsewhere. 

No other action has been taken previously in an attempt to resolve this issue and, as far as we know, this issue is not the subject of any pending litigation. 

Thank you for your attention to this matter. I ask that you please acknowledge your receipt of this complaint within 30 days.


/s/ John Paff, Chairman
New Jersey Libertarian Party’s
Open Government Advocacy Project
Voice: 732-873-1251
e-mail: [email protected]

Chairman of the New Jersey Libertarian Party's Open Government Advocacy Project. Please send all comments to [email protected]