RI Ethics Commission Complaint
Rhode Island Ethics Commission
40 Fountain Street
Providence, RI 02903

Phone: 401-222-3790
Fax: 401-222-3382

 

COMPLAINT

Complainant is Wilbur W. Jennings, Jr., the Democratic Ward 8 Committee Chairman who resides at 115 Sinclair Street in Providence.

Respondent is David N. Cicilline, whose elected office is Mayor of Providence.

Complainant alleges that David N. Cicilline, during an election in which Cicilline was running for re-election, did:
1. Disrupt and interfere with voting at a polling place
2. Attempt to disenfranchise the rights of an elderly minority couple
3. Misused the Providence police power by ordering (Jennings’) removal for his own purposes in violation of Jennings rights under the RI Constitution and State Election Law and the rights of voters to hear from the Democratic ward committee chairman outside the polls.
4.  Misused and abused the power of his office as Mayor to challenge and attempt to intimidate and discredit a precinct warden, inside a polling place, on election day, during an election who was properly and lawfully executing the duties of his position.

FACTS:
1.  During the election on November 7th, at the Reservoir Fire Station polling place, an elderly couple, known to Wilbur W. Jennings as voters who live in that ward and were eligible to vote appeared at the polls and claimed they could not vote without assistance.

2.  The disability voting machine were not working, so Jennings approached the poll warden, Ed Hooks and asked how to go about assisting the senior citizens with voting as they requested.

3.  The warden agreed this was permitted, explained the procedure and provided an affidavit to be filled out by the couple and by Jennings as the person assisting.

4.  Mayor David N. Cicilline was at the polling place and objected, claiming that Jennings would be "voting FOR the person." 

5.  When Warden Hooks began to explain the procedure again for the Mayor, Cicilline challenged him loudly to the growing crowd.  He then demanded Jennings not proceed with assisting.  When Jennings told Cicilline that he would help the people anyway, Cicilline loudly told Jennings and the growing crowd of onlookers that he would contest the election if Jennings did this, and he would have Jennings arrested.

6.  Cicilline repeated the arrest threat loudly a number of times and that he would challenge the election a second time while inside the polling place in the presence of people voting in the Local, State and Federal Election.

7.  Cicilline and Jennings went outside and the conversation concluded with Jennings continuing to say that people could be assisted in voting.  Representative Slater concurred with Jennings when directly and publicly asked by Jennings during this time but was separate and apart from the crowd gathered.

8.  Jennings went over to the other side of the polling entrance to speak with someone, was lawfully 50 feet from the poll, and had not yet re-entered the poll when Providence Police arrived.

9.  The officer spoke first with the Mayor, then went over to Jennings and told him to leave or he would be arrested.

10.  Jennings asked what he had done wrong, but was told aggressively that he would be arrested if he did not leave.

11.  Jennings departed without having assisted anyone vote at the poll that day.

12.  The Providence Journal reported the incident and questioned the Mayor at that time.  The article is posted at www.digitalgurune.com/jennings/mayor.

13.  The Republican Watcher supplied a statement under oath for the State Police and media.  A copy is also posted online at the link above and attached hereto.

 

WHEREFORE:
Complainant requests the Rhode Island Ethics Commission make findings and sanctions as they find just and meet and take any actions they deem appropriate.

Complainant also suggests the Commission review the following suggested conclusions and make findings of these or any part thereof, or any they might make sua sponte, imposing whatever sanctions or remedy the commission has the power to impose.

1. That the actions of Mayor David N. Cicilline violates the Rhode Island Constitution which requires that public officials and employees "adhere to the highest standards of ethical conduct, respect the public trust and the rights of all persons, be open, accountable and responsive, avoid the appearance of impropriety and not use their position for private gain or advantage." (R.I. Const. art. III, sec. 7).

2. Mayor David N. Cicilline, a city candidate for re-election used the power of his elected office in an attempt to influence a Federal, State and local election by using the police power under his control.

3. Mayor David N. Cicilline, a city candidate for re-election used the power of his elected office in an attempt to intimidate and /or disenfranchise voters during a Federal, State and local election on election day by using the police power under his control.

4. Mayor David N. Cicilline, a city candidate for re-election both individually and using the power of his elected office attempted to disrupt and interfere with the electoral process during a Federal and State election inside the polling place on election day using the police power under his control.

5.  Mayor David N. Cicilline, a city candidate for re-election used his position as a licensed member of the bar association, and the elected power of his office to challenge and attempt to discredit a precinct warden who was properly and lawfully executing the duties of his position.

6.  Mayor David N. Cicilline, a city candidate for re-election used his position as an attorney, and the elected power of his office to challenge and discredit a precinct warden who was properly and lawfully executing the duties of his position.

7. That Jennings right to be present at the poll was violated by this Mayor who used the police power to remove him in order to influence the election.

8.  That removing a poll worker without cause and without authority could influence the result in other elections.

9. That Mayor Cicilline  by intimidation, preventing voting by those lawfully there to do so, and being disorderly in a poll during a federal, state and local election where he did not belong and had no authority implies an authority he does not have.

10. That the Providence Police officer, except for his duties to enforce criminal law, election law violations observed by him, or to quell a disturbance observed directly by him, had no authority to interfere, threaten, arrest, detain or disenfranchise any voter at a polling place. 

 

Signed and Dated this 28th of December, 2006.

 

Wilbur W. Jennings Jr.
115 Sinclair Avenue
Providence, Rhode Island 02907
Tel:  401-461-3617
Cell: 401-595-9216

 

State of Rhode Island
County of Providence

Wherefore appeared Wilbur W. Jennings Jr. before me who states the foregoing complaint to be true and correct to the best of his knowledge and belief under penalty of perjury.

Subscribed and sworn to before me in_________________________, Rhode Island on

the__________ day of ________________,

__________________________
Notary & Commission date.