This week, the New York Joint Commission on Public Ethics (JCOPE), which is refining New York’s ethics rules, found  itself debating whether a cup of coffee is an item of “nominal value.”

What constitutes an item of “nominal value” can be a challenging question, especially if it is not defined by a dollar amount.  A common rule of thumb in many jurisdictions, including New York, has been that “nominal value” is roughly equivalent to the cost of a cup of coffee.  But, knowing  where to draw the line can be a problem.

Some suggest JCOPE should define nominal value with a dollar amount, perhaps $5.  An old fashioned cup of joe may be 99 cents somewhere, but a venti gingerbread  latté with extra syrup is $5.35 at my local Starbucks.  Perhaps a cup of coffee is not so nominal after all.

Tags: ethics, gift rules, New York
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Photo of Angelle Smith Baugh Angelle Smith Baugh

Angelle Smith Baugh is of counsel in the firm’s Election and Political Law and White Collar Litigation practice groups. She has significant experience in broad-based crisis management, advising clients on legal and political matters presenting complex risks.

Angelle’s practice focuses on defending companies and individuals…

Angelle Smith Baugh is of counsel in the firm’s Election and Political Law and White Collar Litigation practice groups. She has significant experience in broad-based crisis management, advising clients on legal and political matters presenting complex risks.

Angelle’s practice focuses on defending companies and individuals in high-profile congressional investigations, as well as other criminal, civil, and internal investigations. She represents clients before House and Senate Committees, as well as in criminal and civil government investigations before the Public Integrity Section of the Department of Justice, Federal Election Commission, and the Office of Congressional Ethics.

She assists companies and executives responding to formal and informal inquiries from Congress and executive branch agencies for documents, information, and testimony. She has experience preparing CEOs and other senior executives to testify before challenging congressional oversight hearings.

Angelle also has experience and expertise navigating federal and state ethics laws, and provides ongoing political law advice to companies, trade associations, PACs, and individuals.

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