Christo Makropoulos v. Christopher Lugo, Edison Township Board of Education, Middlesex County, 10/13/26 (#409-26SEC)

409-26SEC
SEC Dkt. No. C90-24
Agency Dkt. No. 382-08-26
New Jersey Commissioner of Education
Final Decision
Christo Makropoulos,
Complainant,
v.
Christopher Lugo, Edison Township Board of Education,
Middlesex County,
Respondent.
The Commissioner has reviewed the record of this matter and the August 25, 2026 decision of the School
Ethics Commission (SEC). The SEC found that respondent Christopher Lugo, a member of the Eidson Township
Board of Education (Board), violated N.J.S.A. 18A:12-24.1(e) and N.J.S.A. 18A:12-24.1(f) of the School Ethics Act
(Act). The SEC recommended a penalty of reprimand for the violation. The SEC’s decision was forwarded to the
Commissioner for final determination on the recommended penalty pursuant to N.J.S.A. 18A:12-29(c).
Respondent neither filed exceptions to the recommended penalty nor instituted an appeal, pursuant to N.J.A.C.
6A:4-1 et seq., of the SEC’s underlying finding of violation.
Upon review, the Commissioner concurs with the penalty recommended by the SEC for respondent’s
actions. Accordingly, respondent is hereby reprimanded as a school official found to have violated the Act.
IT IS SO ORDERED.1
COMMISSIONER OF EDUCATION
Date of Decision: 	October 13, 2026
Date of Mailing: 	October 13, 2026
1 This decision may be appealed to the Appellate Division of the Superior Court pursuant to N.J.S.A. 18A:6-
9.1. Under N.J.Ct.R. 2:4-1(b), a notice of appeal must be filed with the Appellate Division within 45 days from the date of
mailing of this decision.

Before the School Ethics Commission
OAL Docket No.: EEC 15302-25
SEC Docket No.: C90-24
Final Decision
Christo Makropoulos,
Complainant
v.
Christopher Lugo,
Edison Township Board of Education, Middlesex County,
Respondent
I. 	Procedural History
The above-captioned matter arises from a Complaint that was filed with the School
Ethics 	Commission 	(Commission) 	on 	November 	7, 	2024, 	by 	Christo 	Makropoulos
(Complainant), alleging that Christopher Lugo (Respondent), a member of the Edison Township
Board of Education (Board), violated the School Ethics Act (Act), N.J.S.A. 18A:12-21 et seq.
More specifically, the Complaint averred that Respondent violated N.J.S.A. 18A:12-24.1(e) and
N.J.S.A. 18A:12-24.1(f) of the Code of Ethics for School Board Members (Code). Respondent
filed a Written Statement on January 2, 2025.
The Commission adopted a decision at its meeting on August 19, 2025, finding that there
are sufficient facts and circumstances pled in the Complaint and in the Written Statement to lead
a reasonable person to believe that the Act was violated as set forth in the Complaint. Based on
its finding of probable cause, the Commission voted to transmit the above-captioned matter to
the Office of Administrative Law (OAL) for a hearing where Complainant would carry the
burden to prove the allegations that Respondent violated N.J.S.A. 18A:12-24.1(e) and N.J.S.A.
18A:12-24.1(f).
At the OAL, the Administrative Law Judge (ALJ) conducted a hearing on March 11,
2026. Thereafter, the ALJ issued an Initial Decision on June 25, 2026, finding that Respondent
violated N.J.S.A. 18A:12-24.1(e) and N.J.S.A. 18A:12-24.1(f) and recommending a penalty of
reprimand. Neither party filed exceptions to the Initial Decision.
At its meeting on July 28, 2026, the Commission discussed the above-captioned matter,
and at its meeting on August 25, 2026, the Commission voted to adopt the Initial Decision’s
findings of fact, and the legal conclusions that Respondent violated N.J.S.A. 18A:12-24.1(e) and
N.J.S.A. 18A:12-24.1(f). The Commission also voted to adopt the recommended penalty of
reprimand.

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II. 	Initial Decision
Based on documentary evidence and witness testimony, the ALJ issued the following
findings of fact:
1. Respondent is currently a member of the Edison Township Board of Education.
His term expires in 2027.
2. Respondent agreed to endorse two fellow Board members, Doug Schneider and
Brian Rivera during the 2024 election.
3. Respondent also agreed to endorse Manoj Jaitly for election to the Board.
4. Respondent is a District Committeeman, as is Manoj Jaitly.
5. Respondent did not prepare the letter or campaign flyer that contained the
endorsement but stands behind its content.
6. The flyer was distributed by the Edison Republican Organization.
7. Doug Schneider and Brian Rivera, in addition to being Board members, are
Democrats.
8. Respondent signed the letter using his title as a Board of Education Member
without 	providing 	a 	disclaimer 	indicating 	that 	his 	actions 	were 	not
representative of the official stance of the Edison School Board.
Initial Decision at 3.
Per the ALJ, Complainant asserted that it is reasonable and appropriate for the public to
construe Respondent’s comments as both an attempt to use his Board position to get more votes
for the endorsed candidates and that the Board is endorsing their candidacy as well. Ibid. The
ALJ noted that Respondent argues this was a one-time, “non-controversial, simple political
endorsement. . . . There was no connection to the Board of Education as a whole, nor was there
any implication that there was a formal [Board] endorsement” and “a reasonable observer would
not be misled to conclude that the flyer was a formal fully adapted [(sic)] Board of Education
endorsement.” Id. at 3-4.
According to the ALJ, the issue is whether Respondent violated N.J.S.A. 18A:12-24.1(e)
and N.J.S.A. 18A:12-24.1(f) of the Code by making personal promises or taking action that had
the potential to compromise the Board, or by taking action on behalf of a special interest group
that adheres to a particular political party. Id. at 4.
The ALJ found that Complainant argued that Respondent, in his role as a Board member,
“sought a benefit for others and acted on behalf of a political organization when he did not give a
written disclaimer indicating that he was endorsing these candidates as a private citizen rather
than as a [Board] member.” Id. at 7. Moreover, Respondent did not include a disclaimer, and
therefore, Respondent’s “endorsements, which were made in a letter distributed by the local
Republican organization and signed as a member of the [Board], would not have given the
audience an indication that he was speaking as a private citizen rather than as a Board member,
and the public could only construe [R]espondent’s endorsement as the Board’s approval or

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endorsement of these candidates, and as such, [R]espondent utilized his position for the gain of
the endorsed candidates by way of seeking to increase their voter pool.” Id. at 7-8.
The ALJ concluded that Respondent made a political endorsement of three candidates in
a letter distributed by the Edison Republican Organization for the upcoming Board election and
did not include a disclaimer about his comments, thus using his position on the Board to solicit
support and/or votes for the benefit of those three candidates, and in doing so, used the schools to
acquire a personal benefit, in violation of N.J.S.A. 18A:12-24.1(e) and N.J.S.A. 18A:12-24.1(f).
Id. at 8. The ALJ further concluded that a penalty of reprimand is warranted for Respondent’s
actions. Ibid.
III. 	Analysis
Upon a careful, thorough, and independent review of the record, the Commission adopts
the ALJ’s findings of fact and the legal conclusions that Respondent violated N.J.S.A. 18A:12-
24.1(e) and N.J.S.A. 18A:12-24.1(f) and adopts the recommended penalty of reprimand.
Pursuant to N.J.S.A. 18A:12-24.1(e), a board member must recognize that authority rests
with the board and a board member shall not make any personal promises nor take any private
action that may compromise the board. In accordance with N.J.A.C. 6A:28-6.4(a), factual
evidence of a violation of N.J.S.A. 18A:12-24.1(e) shall include evidence that Respondent made
personal promises or took action beyond the scope of his duties such that, by its nature, had the
potential to compromise the board. The Commission finds that when Respondent used his name
and title, without a disclaimer, on an endorsement for school board candidates that was
distributed by the Edison Republican Organization, his actions had the potential to compromise
the Board as it appeared as though the entire Board was endorsing the candidates. While the
Commission has long held that Board members do not give up their right to participate in
political activity, the Commission has warned that Board members must ensure that the activity
does not violate the Act. Therefore, Board members need to make it clear that they are speaking
on their own behalf and not as a Board member. Accordingly, the Commission agrees with the
ALJ that Respondent’s actions violated N.J.S.A. 18A:12-24.1(e).
N.J.S.A. 18A:12-24.1(f) requires a board member to refuse to surrender his independent
judgment to special interest or partisan political groups or to use the schools for personal gain or
for the gain of friends. Pursuant to N.J.A.C. 6A:28-6.4(a), factual evidence of N.J.S.A. 18A:12-
24.1(f) shall include evidence that Respondent took action on behalf of, or at the request of, a
special interest group or persons organized and voluntarily united in opinion and who adhere to a
particular political party or cause; or evidence that Respondent used the schools in order to
acquire some benefit for himself, a member of his immediate family or a friend. The
Commission agrees with the ALJ that when Respondent used his title, without a disclaimer, to
endorse school board candidates, he obtained a benefit for himself and for his friends. Therefore,
the Commission agrees with the ALJ that Respondent violated N.J.S.A. 18A:12-24.1(f).
As to the appropriate penalty, the Commission further agrees with the ALJ and adopts the
recommended penalty of reprimand for Respondent’s violations of N.J.S.A. 18A:12-24.1(e) and
N.J.S.A. 18A:12-24.1(f).

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IV. 	Decision
For all of the aforementioned reasons, the Commission adopts the Initial Decision’s
findings of fact and the legal conclusions that Respondent violated N.J.S.A. 18A:12-24.1(e) and
N.J.S.A. 18A:12-24.1(f) and adopts the recommended penalty of reprimand.
Pursuant to N.J.S.A. 18A:12-29(c), this decision shall be forwarded to the Commissioner
of Education for review of the Commission’s recommended penalty. The parties may either:
1) file exceptions to the recommended sanction; 2) file an appeal of the Commission’s finding of
a violation; or 3) file both exceptions to the recommended sanction together with an appeal of the
finding of a violation.
Parties taking exception to the recommended sanction of the Commission but not
disputing the Commission’s finding of a violation may file, within thirteen (13) days from the
date the Commission’s decision is forwarded to the Commissioner, written exceptions regarding
the recommended penalty to the Commissioner. The forwarding date shall be the mailing date to
the parties, as indicated below. Such exceptions must be forwarded to: Commissioner of
Education, c/o Office of Controversies and Disputes, P.O. Box 500, Trenton, New Jersey 08625,
marked 	“Attention: 	Comments 	on 	Ethics 	Commission 	Sanction,” 	as 	well 	as 	to
(ControversiesDisputesFilings@doe.nj.gov). A copy must also be sent to the Commission
(school.ethics@doe.nj.gov) and all other parties.
Parties seeking to appeal the Commission’s finding of violation must file an appeal
pursuant to the standards set forth at N.J.A.C. 6A:4:1 et seq. within thirty (30) days of the filing
date of the decision from which the appeal is taken. The filing date shall be three (3) days after
the date of mailing to the parties, as shown below. In such cases, the Commissioner’s review of
the 	Commission’s 	recommended 	sanction 	will 	be 	deferred 	and 	incorporated 	into 	the
Commissioner’s review of the finding of violation on appeal. Where a notice of appeal has been
filed on or before the due date for exceptions to the Commission’s recommended sanction
(thirteen (13) days from the date the decision is mailed by the Commission), exceptions need not
be filed by that date, but may be incorporated into the appellant’s briefs on appeal.
Dennis M. Roberts, Chairperson
Mailing Date: August 25, 2026

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Resolution Adopting Decision
in Connection with C90-24
Whereas, 	at 	its 	meeting 	on 	August 	19, 	2025, 	the 	School 	Ethics 	Commission
(Commission) voted to transmit the above-captioned matter to the Office of Administrative Law
(OAL) for a plenary hearing; and
Whereas, the Administrative Law Judge (ALJ) issued an Initial Decision dated June 25,
2026; and
Whereas, the ALJ found that Respondent violated N.J.S.A. 18A:12-24.1(e) and N.J.S.A.
18A:12-24.1(f), and recommended a penalty of reprimand; and
Whereas, the parties did not file exceptions to the Initial Decision; and
Whereas, at its meeting on July 28, 2026, the Commission reviewed the record in this
matter, and discussed adopting the ALJ’s findings of fact and the legal conclusions that
Respondent violated N.J.S.A. 18A:12-24.1(e) and N.J.S.A. 18A:12-24.1(f), and adopting the
recommended penalty of reprimand; and
Whereas, at its meeting on August 25, 2026, the Commission reviewed and voted to
approve the within decision as accurately memorializing its actions/findings from its meeting on
July 28, 2026; and
Now Therefore Be It Resolved, the Commission hereby adopts the within decision.
____________________________________
Dennis M. Roberts, Chairperson
I hereby certify that this Resolution was duly
adopted by the School Ethics Commission
at its meeting on August 25, 2026.
________________________________
Brigid C. Martens, Director
School Ethics Commission