When clients of lobbyist and former Concord mayor Jim Bouley come before the Legislature, state Sen. Tara Reardon files a form to the legislative Ethics Committee indicating a potential conflict with her husband’s work — and then proceeds as she would on any other bill.
Reardon has disclosed her husband’s professional interest on 15 bills in her first term as a senator, but decided to vote on each one. Because her husband isn’t paid based on the outcome of a bill, she said that even if legislation benefits his clients, her votes wouldn’t directly bring money to her household.
During her campaign, an opponent raised questions about Reardon’s ability to fully represent Concord, Bow and Hopkinton because of a new ethics law that required legislators to recuse themselves from bills where they have a financial conflict of interest, but Reardon said she’s satisfied with how she’s navigated it.
“I’m really confident about the way that I am meeting the law and the application that it has to me, and I think I’m firmly within the four corners of what is required there,” Reardon said.
By contrast, Barry Faulkner plays it safe. The Democratic state representative from Swanzey is a lawyer for the firm representing Gordon-Darby Inc. in a high-profile lawsuit over state lawmakers’ decision to end mandatory car inspections.
Faulkner isn’t working on the case, nor has he kept close tabs on it. But when a few fellow Democrats filed a bill in January to reinstate mandatory car inspections, Faulkner recused himself. He believed the bill could have benefited his firm’s client.
“It’s not a direct personal interest to me, but I feel you’ve got to err on the safe side,” Faulkner said. “Why make that a potential issue?”
The recusal law, passed in 2024, sought to formalize what lawmakers can and can’t do — but the result was murky. Reardon, Faulkner and others have spent the past two years trying to make sense of the requirement that some say fails to draw a clear line in the sand.
The Legislature is taking a magnifying glass to its own rules once again. Some want to make the ethics law more stringent. Others have pushed to loosen it by narrowing what counts as a conflict of interest, almost reversing the law to the way it was before: an honor code expectation.
To recuse or not to recuse
Fifty-three state lawmakers have filed 76 so-called “declarations of intent” — forms required when a lawmaker discloses an interest in a bill, financial or otherwise — according to records from the Ethics Committee, a group of current and former lawmakers who offer advice and rulings on ethical questions and disputes.
That’s not a large number, given the size of the Legislature and the volume of bills that are voted on each year. Usually, at least a thousand pieces of legislation are considered.
Most of the time, lawmakers either recuse themselves or elect not to participate when disclosing a personal interest in a bill. That was the outcome of 56 declarations of intent; lawmakers filed their interest but participated on 19, with 14 of those being Reardon’s. One of Reardon’s forms did not list an intent. (A searchable database of legislators’ declarations of intent for the 2025 and 2026 sessions can be found at the end of this story.)
It can be a tricky line to walk for a citizen legislature. Where members make only $100 each year, many have other jobs outside of Concord.
Those who recuse themselves often do so when a bill could affect their business or one run by a household member: One state representative who owns a driver’s education school, for example, stepped back from a bill that would waive the course requirement if a parent provides equivalent training. Others choose not to vote when a bill could affect their personal costs, like one to more heavily tax second homes or another to repeal the tax exemption for solar panels.
Others who have potential conflicts don’t fill out the forms at all.
Those who spoke to the Monitor said they worry more about the perception of a conflict than any actual one — but it’s better to be safe than sorry.
State Sen. Daniel Innis, a Republican from Bradford, recently took himself out of the picture on a bill that regulates how farmers like himself sell and label eggs. He thought the proposed changes could impact him, perhaps financially, and wanted to avoid questions over his motivations. He did not vote on it.
“You need to look at it from the point of view of the public. Could a large enough number of the public perceive that there’s a conflict if I participate in this bill?” Innis said. “And if the answer to that is yes, by all means, step aside, skip the vote and do the right thing.”
The same was true for state Sen. Keith Murphy, a Manchester Republican who owns a restaurant and bar. When a colleague accused him of having a conflict of interest on a liquor licensing bill that could’ve benefited his competitors, Murphy chose not to participate in the vote.
“I’ve elected to avoid the mere shadow of impropriety,” he wrote on the disclosure form.
Not everyone recuses, and it depends heavily on the bill and the potential impact. State Sen. Howard Pearl, a Loudon Republican, filed an intent form but still participated in two bills that dealt with massage therapy regulations. Though his wife is a massage therapist, he determined the legislation wouldn’t directly affect their financial interests.
Reardon’s practices
Reardon has filed 15 declarations of intent during her term as a senator, more than any other lawmaker.
Each time, she’s chosen to vote on the bills, which range from brew pub licenses to car inspections to gambling.
Her votes don’t necessarily align with her husband’s interests. For example, Reardon voted with most of the Senate last year to kill legislation that would repeal car inspections. Bouley’s client, the NH Automobile Dealers Association, lobbied against the bill.
In other instances, she has voted with her party for more regulation on landfills, including for an amendment that would’ve increased local control over the siting process. Bouley represents North Country Environmental Services, also known as Casella Waste Systems, which has faced local opposition to its plans to expand its landfill in Bethlehem.
Other votes are less clear. On many of the 15 bills of interest, the Senate has taken voice votes, which don’t record each senator’s position. When roll-call votes are taken, Reardon tends to vote with her committee members and other Democrats.
Reardon said she and Bouley don’t often discuss State House issues, but they have disagreed before during their time in city government.
“I’ve been an elected official for nearly 30 years now, and people know me and what my thought process is,” Reardon said. “I don’t think any of them have ever for a minute thought that I do something because my husband told me to.”
According to the current ethics law, legislators should recuse themselves from any official legislative activity on a bill when they or a household member meets the standards of a three-point test: If they receive money from an organization, if they hold a position to “exercise substantial influence over the affairs of the organization” and if that organization lobbied on the bill.
Reardon said she interprets the “organization” to mean the one pushing for a specific outcome — one of her husband’s clients, she said, rather than his firm.
Bouley is a partner at the government affairs and public relations firm Dennehy & Bouley. Reardon argues that he falls into the classification of a contractor, along with attorneys, accountants and advisers, which the ethics law specifically lists as one of the circumstances that does not show “substantial influence.”
Bouley’s firm made nearly $1 million from its lobbying services for 23 different organizations in 2025, according to required financial reports submitted to the Secretary of State’s office.
Bouley is listed on 18 of those accounts. His clients include a Seacoast casino called The Brook ($66,000); Intralot Inc., the company that makes gambling equipment used in New Hampshire ($168,000); North Country Environmental Services ($60,000); and industry associations for healthcare, veterinarians and other groups like auto dealers.
Contracts and pay structure vary by the firm. Reardon said her husband is salaried, not paid per bill or outcome. If a client did offer him money based on getting a bill passed, she said she’d “absolutely” recuse herself.
“They don’t get paid on the outcome of any piece of legislation. They’re paid the same paycheck every week, and it never changes,” Reardon said.
Reardon said she files forms when her husband has lobbied on a bill, but she doesn’t look to see his position before she votes. She said she has not received any questions or complaints from constituents about her ethical practices since her opponent’s attack during the campaign.
She plans to run again and is banking on the rapport she’s built with voters throughout her decades in elected office.
“The voters will decide,” Reardon said. “If there’s an uproar about being transparent, then I’m happy to talk about it. And if the voters decided that that was a bridge too far for them, I guess I would not get reelected.”
Too strict, or not strict enough?
Lawmakers are reviewing the rules once again, intending to draw clearer ethical boundaries.
A Senate committee drafted changes to the law that would’ve limited what counts as a “direct benefit” when a law benefits the legislator or their household more than the general public, or if that benefit would be subject to the discretion of a third party. The same would be true for a “direct detriment,” according to the proposal.
“If the law would specifically single you out, that would be the classic case of a conflict of interest that we would expect the legislators to recuse themselves from,” Grant Bosse, the Senate’s deputy chief of staff, said at a hearing last month. “If you are voting on laws that affect the overall economy or an overall industry — and let’s say you have a tourism business and are voting on something that we think would bring a lot more tourists into the state of New Hampshire, and your business would thrive, and you’d make a lot of money — well, that’s not a direct benefit. You’re voting on improving the New Hampshire economy, whether you make a lot of money on that or not, rests on the decision of people from out of state to come here and give us their money.”
Any movement appears to be on hold, however, after the House Legislative Administration Committee unanimously sent the bill to an interim study on Wednesday, meaning lawmakers will review it further in the off-season, then decide whether to take action next year.
They were divided over the sticking points. The proposal would havve removed the “substantial” financial impact requirement, and some thought that could be too restrictive and result in too many conflicts and recusals.
Others thought the Senate’s version didn’t go far enough. State Rep. Alice Wade, a Democrat from Dover, took issue with the third-party provision.
“I think it was broad to the extent that you could make an argument that any financial impact is influenced by a third party,” Wade said before the vote, “including some that could be seen as very direct but interpreted through this language to not require recusal in a time where we already don’t have many recusals happening generally.”
As lawmakers move forward, several emphasized a balance of preserving the public’s trust while making the most of each lawmaker’s individual experience and expertise to shape different laws and policies.
Innis said the conversation around ethics is “somewhat subjective.” Where some see lawmakers’ proximity to certain bills as an issue, others might see value in their lived experience.
“We have to be careful in casting the net so broad that we lose significant voting blocs on every single thing,” he said.
