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.

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Photo of Angelle Smith Baugh Angelle Smith Baugh

Angelle Smith Baugh is a special counsel in the firm’s White Collar Litigation and Election & Political Law practice groups.  Ms. Baugh’s practice includes defense against government investigations in civil and criminal matters before the Department of Justice, Federal Election Commission, and Congressional…

Angelle Smith Baugh is a special counsel in the firm’s White Collar Litigation and Election & Political Law practice groups.  Ms. Baugh’s practice includes defense against government investigations in civil and criminal matters before the Department of Justice, Federal Election Commission, and Congressional Ethics Committees.  She also provides ongoing political law advice, including federal and state ethics, election, and lobbying laws, to companies, trade associations, PACs, and high net-worth individuals.