The central issue in the complaint is whether the governor should have recused himself or disclosed potential conflicts of interest in relation to transportation projects near property owned and developed by his real estate firm, which is run by his brother Timothy Hogan and under the control of a trust managed by several current and former executives of the firm.

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The complaint alleges the real estate firm profited when the Hogan administration advanced an interchange project in southern Prince George’s County in 2015. It says the governor’s administration fast-tracked the Brandywine Crossing project before the state’s ethics commission granted him an exception from state conflict-of-interest laws, which say officials may not have a financial interest in “an entity subject to the authority of that official . . . or of the governmental unit with which the official . . . is affiliated.”

Larry Hogan acknowledged to the ethics commission that his business would necessarily have contact with agencies he is charged with overseeing, such as the State Highway Administration.

He secured the exception from this prohibition based on both his pledge to avoid certain pitfalls — such as conferring with his firm’s executives about business decisions or using his public office to advantage the business — and the creation of the trust.

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The ethics complaint is based largely on reporting in a January article in Washington Monthly. It alleges that Hogan, who took office in early 2015, benefited from highway decisions by his administration — including for projects near Brandywine Crossing — before he created the trust and received the exception late that year.

Hogan spokesman Michael Ricci dismissed the complaint as the work of “an activist group peddling delusions.” He said the governor’s agreement with the ethics commission “goes further than Maryland’s ethics laws and has been followed to the letter.”

A state lawmaker this year filed a bill that would force Hogan to disclose more information to General Assembly leaders. It also would require future governors to divest from their private businesses or place those businesses in a blind trust that is not managed by family members.

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Craig Holman, who works on ethics issues for Public Citizen, said he filed the complaint in part because President Trump’s conduct in office appeared to be normalizing unethical behavior by politicians who retain private business interests after entering public service.