Ethical Misconduct at the Department of the Interior

On January 28, 2017, President Trump signed Executive Order 13770: Ethics Commitments by Executive Branch Appointees. This order requires all appointed personnel of the executive branch to sign an ethical pledge that has the force of law. The sixth clause of the rule requires appointees to not “participate in any particular matter involving specific parties that are directly and substantially related to [their] former employer.” Doing so would create an opportunity for a perceived or actual conflict of interest because public managers are expected to act with the interest of the public in mind. Participating in agency matters that involve a former employer would introduce personal interests into a public agency’s operations and corruption is likely to result. As we saw in this module’s suggested video (“Integrity: Why is it Important?”), corruption is defined as mixing personal interests with one’s professional responsibilities to the public. A simple Google search revealed a current event that we can examine in this context.

In February 2019, the not-for-profit Campaign Legal Center issued a letter to the Inspector General of the Department of the Interior requesting that he open an ethics investigation into the alleged breach of EO 13770 for several high-ranking Department appointees. One of them is Doug Domenech, Assistant Secretary for Insular and International Affairs and former Senior White House Advisor to President Trump. Mr. Domenech signed his ethics pledge twice: initially after the order was issued and again upon his appointment to his current position in September 2017. Before his appointment, Mr. Domenech was employed by the Texas Public Policy Foundation, which is currently involved in litigation with the Interior Department. The Campaign Legal Center alleges that Mr. Domenech had several meetings with Texas Public Policy Foundation officials in his capacity as Assistant Secretary to discuss the issues being litigated, a clear violation of EO 13770.

Using Cooper’s (2012) responsible administrator framework, we can understand why Mr. Domenech’s actions were examples of ethical misconduct. A responsible administrator must have both “objective accountability for conduct and subjective congruence with one’s professional values” (Cooper, 2012, p. 6). In other words, responsibility means holding oneself accountable for their professional actions and must be able to explain them to stakeholders upon questioning. If Mr. Domenech is guilty of meeting with his former employer, he has not acted responsibly. By accepting his appointment (or his role, as Cooper describes it), Domenech has also taken the responsibility of behaving within ethical norms for that role. The public expects government officials to act in the public interest and not to further their own interests at the public’s expense.


Cooper, T. L. (2012). The Responsible Administrator: An Approach to Ethics for the Administrative Role (6th ed.). San Francisco: Jossey-Bass.

Originally posted as a discussion assignment in the “Administrative Ethics” course at the Rutgers School of Public Affairs and Administration.

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