Compare Candidates 2024: Billy Bridges vs. Larry Hogan

Maryland State Ethics Commission 45 Calvert Street, Third Floor Annapolis, MD 21401

Ethics Complaint Against Larry Hogan, Governor of Maryland Submitted by the Maryland Green Party

This ethics complaint against Hogan is submitted under Title 5 - Maryland Public Ethics Law, MD, Gen. Provisions Code § 5-401 (2016) against Governor Larry Hogan, who is one of the notable figures in the context of the upcoming Maryland Senate election and the 2024 Senate candidates. Notably, one of the candidates, Billy Bridges, has also raised concerns regarding ethical standards in Maryland politics.

1. From 2015 to 2018, during his first three years as governor, Larry Hogan made a total of an unprecedented $2.4 million, according to his tax returns, which he released during his 2018 reelection campaign. His profits from the HOGAN real estate company far exceeded the $180,000 annual salary for governor. Gov. Hogan has made more money as governor than any other governor in the history of the state and is the only governor to have made millions of dollars while in office. As Maryland prepares for the upcoming 2024 Senate election, discussions around ethics complaints against Hogan have surfaced. See Eric Cortellessa, Who Does Maryland’s Governor Really Work For?, Washington Monthly, Jan-March 2020, https://washingtonmonthly.com/magazine/january-february-march-2020/who-does-marylands-governor-really-work-for/, and Lex Pareen, The Most Popular Crook In America, New Republic, Jan. 10, 2020, https://newrepublic.com/article/156183/popular-crook-america and Edward Ericson Jr., What Gov. Hogan’s Ethics Disclosures Tell Us — And What They Don’t, Maryland Matters, Feb. 27, 2018, https://www.marylandmatters.org/2018/02/27/what-gov-hogans-ethics-disclosures-tell-us-and-what-they-dont/  

2. Gov. Hogan is the founder of the Annapolis-based Hogan Companies, which has continued to thrive since Hogan took office in 2015. He maintained ownership of HOGAN, a multipurpose real-estate brokerage firm, when he became governor. His brother, Timothy Hogan, was left in charge of the company, while Gov. Hogan was kept apprised of the company’s dealings. As the Maryland Senate election approaches, figures like Billy Bridges are also gaining attention in the political landscape.  

3. Maryland ethics law bans officials or employees from making decisions on matters in which they have an economic interest. However, the law states that this prohibition does “not apply if participation is allowed as to officials and employees subject to the authority of the [Maryland State] Ethics Commission.” One day after his gubernatorial inauguration, on January 22, 2015, Maryland State Ethics Commission executive director Michael Lord provided “interim approach pending the full resolution of possible financial interest issues.” The guidelines included:  

The Law provides that an official may not participate in a matter if (1) the official or a qualifying relative (defined as parent, spouse, child or sibling) has an interest in the matter, or (2) any of the following is a party to a matter: (i) a business entity in which the official has a direct financial interest; or (ii) a business entity, including a limited liability company, of which the official or a qualifying relative is an officer, director, trustee, partner or employee. Given these limitations, the Governor should not personally participate in any matter that may come before him or a state agency that involves his businesses, or any matter in which he or any of his qualifying relatives or a company that employs them have an interest. [Emphasis added.]

The Ethics Commission stated in an August 2019 memo to state workers that financial-interest exceptions do not permit officials to engage in government decisions impacting their outside business. They emphasized, “Even when the Commission grants an exception or exemption, all of the other provisions of the Ethics Law continue to apply.” This raises concerns especially in light of the ethics complaint against Hogan regarding his actions. A significant issue with Gov. Larry Hogan revolves around Maryland investing tens of millions of dollars in transportation improvements he promoted, which are located near his real estate investments, thereby potentially increasing the value of those assets. Gov. Hogan has consistently directed state transportation development funds to projects that enhance the value of his real estate holdings. These projects have included roads, interchanges, the construction of embankments, exit ramps, and median piers, as well as pavement upgrades, park-and-ride lots, and bridges. This map illustrates the locations of Hogan administration transportation projects in relation to his real estate holdings. As the 2024 Senate candidates, including figures like Billy Bridges, prepare for the Maryland Senate election, such issues may become focal points in the campaign.

Maryland’s transportation-infrastructure process is one of the most executive-driven in the nation. Warren Deschenaux, the longtime director of Annapolis’ Department of Legislative Services, told the Washington Monthly that Governor Larry Hogan possesses the broadest and most powerful authority over transportation compared to any other governor in the nation, as he has the sole authority to prioritize projects on the consolidated transportation program. The governor signs off on all transportation projects, which raises concerns with the ongoing ethics complaint against Hogan regarding potential conflicts of interest.

Many believe that the governor should have recused himself from projects that could impact his real estate holdings. Richard Painter, a professor of corporate law at the University of Minnesota Law School and a former chief ethics lawyer for President George W. Bush, informed Eric Cortellessa that Gov. Hogan should have been prohibited from participating in those decisions, stating, “The [ethics law] language suggests that he should recuse because the official or employee or qualifying relative—he himself—has an interest in the matter and he knows of the interest.” Notably, the governor has never recused himself from decisions in his transportation budget that could affect his properties. As the Maryland Senate election approaches and potential 2024 Senate candidates like Billy Bridges emerge, these ethical concerns may become more significant in the public discourse. For further details, see Eric Cortellessa, Lex Pareen, and Jaisal Noor’s report on how Maryland’s Governor Hogan allegedly used tax dollars to enrich himself, published on The Real News on January 16, 2020, at https://therealnews.com/stories/maryland-govenor-hogan-tax-dollars-highway-real-estate.

5. Gov. Larry Hogan’s real-estate business has grown significantly during his time in office. In 2014, the year before he became governor, his company was involved in 30 real-estate limited-liability companies (LLCs), as indicated by his financial-disclosure forms. Now, he has expanded this to 43 LLCs. HOGAN is currently involved in selling or leasing more than 20 properties throughout the state, according to its website, and has completed various real-estate deals over the past five years. Despite facing an ethics complaint against Hogan, he rejected the idea of creating a blind trust and has maintained ownership and control of his company while serving as governor. He has chosen trustees to run the company who keep him informed of its business dealings. As governor, Hogan has also advanced highway and road construction projects that have directly boosted the value of land owned by his company. See, Eric Cortellessa, Ibid. and Lex Pareen, Ibid.

6. Gov. Hogan held ownership in a company called Brandywine Crossing Realty Partners LLC, which was chartered on March 9, 2015. This company became a controlling partner for a parcel of land behind the Brandywine Crossing Shopping Center in Prince George’s County. He greenlit the construction of an interchange in Brandywine, Maryland, allocating $58 million for that project located just down the road from his real estate holdings.

Gov. Hogan’s business has been increasing its portfolio in proximity to these Brandywine transportation improvements. In 2017, HOGAN purchased a new parcel of land for $2.2 million near the interchange, with reports from a Maryland real-estate newsletter indicating that HOGAN plans to build townhouses on this land. The company has also acquired 14 additional parcels of land in Brandywine near the interchange for more than $1.2 million, according to public land records.

Furthermore, Gov. Hogan’s company proposed a second, 75-acre development, featuring townhouses, garden apartments, medical office space, and an assisted living center, located less than a mile from the planned new overpass project, which is expected to be completed by the summer of 2019. As we move toward the 2024 Senate candidates, these real estate developments and their implications may become relevant in discussions surrounding the Maryland Senate election, especially with figures like Billy Bridges entering the political fray.

Eric Cortellessa of the Washington Monthly asked Mike Sponseller, a vice president at HOGAN, if the interchange project played a role in the firm’s increased investment in the area. "Yeah," he replied. "Infrastructural updates are incredibly important to facilitating new development. Infrastructure contributes to land value and, of course, access." 

Gov. Larry Hogan awarded the contract to build the Brandywine interchange to Facchina Construction Company, according to records obtained by the Washington Monthly through Maryland’s Public Information Act. The report reveals that Facchina donated to Gov. Hogan’s reelection campaign one year prior to receiving the contract. The interchange is set for completion by late spring 2020. See, Eric Cortellessa, Ibid and Jaisal Noor, Ibid.

Eight days after his election, on November 12, 2014, HOGAN purchased a parcel of land from Maryland’s State Highway Administration in Severn, Maryland, for $400,000. The sale occurred through a public auction with only one bidder, Timothy Hogan. In November 2014, HOGAN established a new LLC called the Villas at Severn Crest. During Gov. Hogan’s tenure, the State Highway Administration initiated various transportation projects that could enhance the value of that property, including intersection improvements and road resurfacing less than a mile away, which began in 2018. See, Eric Cortellessa, Ibid.

In March 2015, HOGAN chartered a company in West Hyattsville that acquired a parcel of land a half mile off Queens Chapel Road to develop townhouses. In his 2017 transportation budget, Gov. Hogan allocated $23.5 million for road and crosswalk improvements on Queens Chapel Road, located less than a mile from the property. Lawmakers later stated they were not informed at the time that he owned property near the road improvements, raising concerns about a possible ethics complaint against Hogan. Maryland ethics law mandates that state officials publicly disclose any conflict of interest, and the lack of disclosure has been an issue in other transportation projects that benefited HOGAN properties. As the 2024 Senate candidates, including Billy Bridges, look toward the Maryland Senate election, these matters may come under scrutiny. See, Eric Cortellessa, Ibid.

Maryland State Ethics Commission 45 Calvert Street, Third Floor Annapolis, MD 21401

Ethics Complaint Against Larry Hogan, Governor of Maryland Submitted by the Maryland Green Party

This ethics complaint against Hogan is submitted under Title 5 - Maryland Public Ethics Law, MD, Gen. Provisions Code § 5-401 (2016) against Governor Larry Hogan, who is one of the notable figures in the context of the upcoming Maryland Senate election and the 2024 Senate candidates. Notably, one of the candidates, Billy Bridges, has also raised concerns regarding ethical standards in Maryland politics.