Virginia Inspector General Report: State Department of Education Director of Equity and Community Engagement improperly used ‘state resource to establish a consulting business’

On Sept. 10, 2019, the Office of the Virginia Inspector General received a hotline complaint. The complaint alleged that the Virginia Department of Education’s director of equity and community engagement, Leah Dozier-Walker, was “using state resource to establish a consulting business,” in Allegation #1 with “similar services” to the ones the director “performed in the individual’s state government position,” according to a redacted summary report released under the Freedom of Information Act. Allegation #2 was that the business wasn’t reported in the statement of economic interest and that “state time” was being used for the business without Dozier-Walker signing a form for an approved outside business. 

The report concluded that Allegation #1, alleging an unethical consulting business, was “sustained,” and Allegation #2 was “largely substantiated.”

Between Jan. 1, 2019, and February 2020, Dozier-Walker’s salary increased from $88,300 to $102,219. 

She had registered two websites in her name: LeahDozier.com and LeadingImpactNow.com. She had registered LeahDozier.com on March 29, 2019, and LeadingImpactNow.com on July 2, 2019. 

The summary report said “both of these sites are closely linked together.” 

Furthermore, the duties in her Employee Work Profile, a formal description of her job, “were either identical or nearly identical to the consulting services listed on the websites.” One of the websites had a disclaimer, stating: “In accordance with my strict adherence to ethics requirements, I will not accept any work that conflicts with my obligations to the Commonwealth of Virginia.” But the report said, “It is debatable whether this disclaimer is sufficient or would negate any appearance of conflict of interest.”

A month later, on Sunday, Aug. 25, 2019, she incorporated Leading Impact No., LLC with the Virginia State Corporate Commission. The next day, during “state time,” the report said, Dozier-Walker posted a tweet at 1:54 p.m., stating she “started new job at Leading Impact Now (Owner and Founder).” A half an hour later, at 2:26 p.m., she requested an Authorization for Outside Employment Form, acknowledging receipt of the form at 3:33 p.m. But she hadn’t filed the form by January 2020.

The next month, in early September 2019, Dozier-Walker “apparently paid an outside firm to draft a prototype logo.” A staffer in her office “was asked to proof it and make suggestions,” which the staffer did “while on the job” for about an hour.

During staff interviews, the report said, an allegation emerged that Dozier-Walker was “never around” the office, creating challenges about the office’s work. According to a review of how her time and attendance between Jan. 1, 2019, through early September 2019, with 95.5 hours were “unexplained exceptions.” 

In late 2019, Dozier-Walker’s job was reorganized, with communications, website and constituent services assigned to another director. 

That winter, on Jan. 31, 2020, she filed a Statement of Economic Interest, answering “no” to questions about whether she got income from an outside business and owned a business of more than $5,000 in value. The investigator said it “cannot be readily determined” if the equity director responded accurately. 

“In reviewing both websites,” the report said, “it is clear that Ms. Dozier-Walker has posted a number of pictures, documents and at least one video that was created by VDOE. Some photos show Ms. Dozier-Walker at various conferences while working in an official capacity of VDOE.”

Some of the photos included “‘Virginia is for Learners’ apparel that is a modification of the Virginia Tourism Corporation’s “Virginia is for Lovers” brand.”

The report said: “There is no record of permission granted for using this brand in a commercial setting. Additionally, it is unlikely that the Virginia Tourism Corporation would allow the branded ‘Virginia is for Learners’ in a for-profit business. Finally, this type of usage may be a copyright violation and subject VDOE and/or Ms. Dozier-Walker to unfavorable legal consequences.”