Daniel T.

Warren

West Seneca, New York 14224-1235

716-

May 15, 2025

New York State Commission on Judicial Conduct

400 Andrews Street, Suite 700
Rochester, NY 14604

RE: Judicial Ethics Complaint against Chelsea MacDonald as Justice of the West
Seneca Town Court, Erie County, New York

Former West Seneca Town Justice Jeffrey Harrington was elected to the Erie County
Family Court on November 4, 2024. Judge Harrington’s resigned as West Seneca Town Justice
which was accepted by the Town Board of the Town of West Seneca, New York on December 2,
2024. On December 2, 2024, Paula Newcomb was appointed West Seneca Town Justice. Paula
Newcomb circulated a designating petitions to run for the position of West Seneca Town Justice
on the Republican and Conservative Party, and such was filed in the Offices of the Erie County
Board of Elections on March 31, 2025. On April 1, 2025, Paula Newcomb filed a declination of
such nominations in the Offices of the Erie County Board of Elections. On April 7, 2025,
Chelsea MacDonald was nominated to fill the vacancy of Paula Newcomb as candidate on the
Republican and Conservative lines by the Committees to Fill Vacancies. On April 14, 2025,
Chelsea MacDonald was appointed to the position of West Seneca Town Justice by the Town
Board of the Town of West Seneca, New York. Prior to April 14, 2025, there was no public
announcement that the Town Board was considering applications to fill the seat being vacated by
Mrs. Newcomb which precluded other interested parties from being considered.

There will be a primary on the Republican and Conservative Party lines between Chelsea
MacDonald and another judicial candidate on June 24, 2025.

According to the records of the Office of Court Administration, Chelsea MacDonald was
admitted to the bar and licensed to practice law in the State of New York. She was admitted to
the bar on January 11, 2023, and according to her registration she is employed by the Law
Offices of Ralph Lorigo (See Exhibit “A” attached hereto). Ralph Lorigo is currently the
Chairman of the Erie County Conservative Party. This law firm represents many clients before
the various boards of the Town of West Seneca relating to zoning and planning as well as before
the Code Enforcement Officer of the Town. There is at least the potential for a client of her
employer, the Law Offices of Ralph Lorigo will appear Town Justice MacDonald. It Should be
noted that the other sitting Justice in the Town of West Seneca, Jon Minear, is also an employee
of the Law Offices of Ralph Lorigo.

On Sunday, April 27, 2025, West Seneca Town Justice Chelsea MacDonald posted a
picture on her political campaign Facebook of herself on the bench in the Town of West Seneca
courtroom wearing a judicial robe. (See
https://www.facebook.com/profile.php?id=61575303447018 (last accessed 5/14/2025) and
https://www.facebook.com/share/p/1FyEq3NTdL/ (last accessed 5/14/2025); and Exhibit “B”
attached hereto)). Also, on the official Facebook page of the West Seneca Republican Party
posted on April 26, 2025, there is a picture of West Seneca Town Justice, and candidate for
judicial office, Chelsea Macdonald in a judicial robe in front of the bench of the West Seneca
Town Court room ( See https://www.facebook.com/share/p/1HryAPHPyz/ (last accessed
5/14/2025) ); and Exhibit “C” attached hereto). Again, in a post on the official Facebook page of
the West Seneca Republican Party posted on May 1, 2025, there is a picture of West Seneca
Town Justice, and candidate for judicial office, Chelsea Macdonald in a judicial robe in front of
the bench of the West Seneca Town Court room ( See
https://www.facebook.com/share/p/1BqHXz3SvF/ (last accessed 5/14/2025) ); and Exhibit “D”
attached hereto)).

The Judicial Campaign Ethics Handbook adopted by the Advisory Committee on Judicial
Ethics is clear that “the courthouse may not be used for political purposes,” Handbook 1 at Page
34, and “care must be taken to avoid using photographs that might convey the impression that
the courthouse is being used for political purposes and, in particular, to facilitate the candidacy of
a sitting judge.” Opinion 05-101 (2005) (holding that a judicial candidate “may not create an
appearance that they are improperly using ‘insider’ access or status to take campaign
photographs in restricted locations). In Opinion 05-101, the Committee explicitly took concern
of “the danger of a public perception of entanglement of the judiciary itself in the political
process” and “that danger is readily apparent . . . with respect to campaign pictures taken in the
courtroom and thereafter used in the campaign.” While the Committee recognized that it may not
be ethically improper to allow photographs to be taken in a courthouse library or chambers upon
permission of the respective administrative authority, that is not the case here. This picture was
clearly taken in the courtroom in which the Town of West Seneca Justices’ preside, and the
nameplate “Town Justice” additionally exemplifies that this is the exact area where the Judge
would be presiding from. Significantly, this picture was posted on the Judge’s Facebook page
promoting her election – an inherently political process.

Even if Judge MacDonald obtained permission, the photograph still does not comply with
the Judicial Campaign Ethics Handbook’s guidance. Judicial candidates who are incumbent
judges “are permitted to use photographs depicting them in judicial robes and taken in any public
place, or in chambers or the court library, provided that there is no indication of the official
nature of the location and administrative permission is obtained.” Handbook at Pages 34-5.
While Judge MacDonald may permissibly appear in robes to promote her candidacy, it is clear of
the official nature of the location through the large Town of West Seneca seal located on the wall
behind her in the picture.

Since Mrs. MacDonald did not circulate a designating petition and she was nominated as
a replacement together with the shortened time for her to get her campaign message out is quite
shortened and the above is intended to promote her campaign.

Further, guidance may be necessary given the potential for conflict between her
employment with the Law Offices of Ralph Lorigo and her position as a Justice of the West
Seneca Town Court.

Please do not hesitate to contact me if I can be of any further assistance in this matter. I
can be reached at 716- or @gmail.com .

Daniel T. Warren

1
https://www.nycourts.gov/legacyPDFs/ip/jcec/Judicial-Campaign-Ethics-Handbook.pdf
Exhibit “A”
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Attorney Detail Report as of 05/14/2025

Registration Number: 6020341

Name: CHELSEA A. MACDONALD
Business Name: THE LAW OFFICE OF RALPH C. LORIGO
Business Address: 101 SLADE AVE
WEST SENECA, NY 14224-2619
(Erie County)
Business Phone: (716) 856-4200
Email: cmacdonald@lorigo.com
Date Admitted: 01/11/2023
Appellate Division Department
of Admission: 4th
Law School: Western Michigan University Cooley Law School
Registration Status: Attorney - Currently Registered
Next Registration: Aug 2025

Disciplinary History

No record of discipline

The Detail Report above contains information that has been provided by the
attorney listed, with the exception of REGISTRATION STATUS, which is
generated from the OCA database. Every effort is made to insure the
information in the database is accurate and up-to-date.
The good standing of an attorney and/or any information regarding disciplinary
actions must be confirmed with the appropriate Appellate Division Department.
Information on how to contact the Appellate Divisions of the Supreme Court in
New York is available at www.nycourts.gov/courts.

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Chelsea MacDonald for West Seneca Town Justice's Post

Chelsea MacDonald for West Seneca Town Justice

April 28 at 4:21 AM ·

I’m honored to currently serve as Town Justice for the Town of West Seneca.
As a lifelong resident of West Seneca and a dedicated attorney, I understand how important fairness,
integrity, and respect are to our community. Every day, I am committed to ensuring our Town Court
remains a place where everyone is treated with dignity, transparency, and compassion.
With your support, I will continue working hard to uphold the values that make West Seneca such a
special place to call home.
Thank you for believing in me and in the importance of integrity, values, and dedication on the bench.
Exhibit “C”
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West Seneca Republican Committee's Post

West Seneca Republican Committee

April 26 at 12:24 PM ·

Judge Chelsea MacDonald is the ONLY candidate endorsed by the Conservatives and Republicans!
Vote Chelsea on June 24th 2025!

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Exhibit “D”
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West Seneca Republican Committee's Post

West Seneca Republican Committee

May 1 at 7:16 AM ·

West Seneca Conservatives and Republicans have a Primary June 24 2025!

Retain Judge Chelsea MacDonald!

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