After Nevada Commission on Ethics censured city council member based on his failure to recuse himself, pursuant to the Nevada Ethics in Government Law, from voting on a matter due to potential conflict of interest, council member petitioned for judicial review. The District Court denied the petition, and council member appealed. The Nevada Supreme Court reversed. Certiorari was granted, and the United States Supreme Court reversed and remanded.
On remand, the Nevada Supreme Court held that:
- Ethics in Government Law’s recusal provision was not void for vagueness;
- Application of Law’s recusal provision for conflicts of interest to city council member did not violate member’s due process rights; and
- Conflict of interest recusal provisions did not violate city council member’s right of association.