BEFORE THE CITY OF MAYSVILLE ETHICS BOARD

STATE OF GEORGIA

COMPLAINT AGAINST COUNCILMEMBER RICHARD PRESLEY

1. Name and address of person filing the complaint ________________________________

2. Name and address of the party against whom the complaint is being filed. 

City of Maysville Councilmember and Mayor Richard Presley

FORMAL COMPLAINT OF OFFICIAL MISCONDUCT, OATH BREACH, ABUSE OF POWER, 

AND SUBVERSION OF CONSTITUTIONAL GOVERNANCE

TO: * The City of Maysville Ethics Board & City Clerk

• Georgia Government Transparency and Campaign Finance Commission (O.C.G.A. § 

21-5-1 et seq.)

• City Council & Municipal Governance Review Board

• Georgia Municipal Association

• Attorney General Chris Carr

DATE: ____________________________________

I. PRELIMINARY STATEMENT

This complaint is formally submitted regarding a systematic, multi-year pattern of official 

misconduct, physical assault and intimidation, financial mismanagement, failure of 

executive oversight, statutory audit non-compliance, public utility neglect, Open Meetings 

Act violations, unauthorized deployment of municipal surveillance technology, making 

deceptive public statements on the record regarding legal authorization, and subversion of 

legislative independence by Richard Presley in his official capacity as Mayor of the City of 

Maysville, Georgia.

Under City Charter Section 2.14(a), elected officials are statutory "trustees and servants of 

the residents of the city and shall act in a fiduciary capacity for the benefit of such 

residents." Furthermore, under the City of Maysville Code of Ethics (Ordinance No. 2006-

001) and O.C.G.A. § 16-10-1, the Mayor is bound by oath to uphold state laws, ensure public 

safety, protect municipal finances, protect public privacy and property rights, and maintain 

open government standards without self-interest, gross negligence, deceptive 

misrepresentations, or abuse of executive power. The extensive documentary and digital record—consisting of police incident reports, video 

recordings of municipal meetings, formal state financial audit findings, Georgia Campaign 

Finance reports, Flock Safety Memorandum of Understanding (MOU) contracts, water 

testing logs, official council transcripts, municipal clerk records, and recorded public 

proceedings—establishes twenty-one (21) distinct counts of executive misconduct.

II. STATEMENT OF FACTS & SPECIFIC COUNTS

Count 1: Tacit Ratification and Participation in an Unlawful Voting Alliance (Subversion 

of Legislative Independence)

• Applicable Legal Grounds: City Charter Section 2.14(a); City Code of Ethics 

(Ordinance No. 2006-001); O.C.G.A. § 16-10-1.

• Statement of Fact: During the July 30, 2026 public council meeting, Councilmember 

Steve Boswell publicly admitted on the record to the existence of a pre-arranged, 

coordinated voting alliance between himself, Councilmember Richard Parr, and 

Mayor Richard Presley. Mayor Presley was present during these disclosures and 

failed to dispute, deny, or halt the statements. By cultivating, participating in, and 

tacitly ratifying an executive-controlled voting block, Mayor Presley destroyed the 

legislative independence required of the council under City Charter Section 2.14, 

converting the governing body into an illegal rubber-stamp mechanism.

Count 2: Physical Battery and Assault of a Citizen (Incident Date: February 27, 2024)

• Applicable Legal Grounds: O.C.G.A. § 16-5-23 (Simple Battery); City Charter Section 

2.14; City Code of Ethics; O.C.G.A. § 16-10-1.

• Statement of Fact: On February 27, 2024, following a City Council meeting, Mayor 

Presley confronted resident Luis Lopez on the steps of City Hall (4 Homer Street) 

after Mr. Lopez exercised his First Amendment rights during public comment. As 

documented in Maysville Police Department Incident Report (Case #2024-03-0331) 

and witnessed by Councilmembers Amanda Farley and Brodriche Jackson, Mayor 

Presley approached Mr. Lopez aggressively, stated he "will not let me embarrass him 

and his family," and struck Mr. Lopez three times in the chest with an open hand until 

an intervening police officer physically separated them. Count 3: Workplace Violence and Physical Intimidation of an Elected Official (Incident 

Date: May 22, 2024)

• Applicable Legal Grounds: O.C.G.A. § 16-5-20 (Simple Assault); O.C.G.A. § 16-10-1; 

City Charter Section 2.14.

• Statement of Fact: On May 22, 2024, inside City Hall, Mayor Presley engaged in an 

aggressive administrative dispute with Councilmember Brodriche Jackson. As 

documented in Maysville Police Department Incident Report (Case #2024-05-0912), 

when Councilmember Jackson attempted to exit the room to de-escalate, Mayor 

Presley pursued him, blocked the doorway, and physically laid hands on 

Councilmember Jackson’s shoulder to prevent his departure until ordered to stop. 

The Police Chief directly witnessed the altercation and initiated the police report.

Count 4: Gross Failure of Executive Oversight Regarding Alleged Embezzlement of 

$19,000+ by Former City Clerk Jessica Daniels & Refusal to Pursue a Forensic Audit

• Applicable Legal Grounds: City Charter Section 2.14(a) (Fiduciary Duty); O.C.G.A. § 

36-81-3; City Code of Ethics (Ordinance No. 2006-001); O.C.G.A. § 16-10-1 (Violation 

of Oath).

• Statement of Fact: Mayor Presley failed to perform baseline executive supervision, 

implement mandatory internal financial controls, or conduct routine administrative 

audits over the City Clerk's office, directly creating an environment that allowed 

former City Clerk Jessica Daniels to allegedly steal and embezzle over $19,000.00 in 

municipal public funds (a matter currently pending legal adjudication prior to 

conviction). As chief executive officer charged with supervising municipal 

administration and safeguarding public funds, Mayor Presley’s complete absence of 

oversight allowed multi-thousand-dollar irregularities to occur undetected over an 

extended period. Furthermore, despite public demands and clear evidence of 

severe financial misappropriation, Mayor Presley has failed and refused to initiate or 

pursue an independent forensic audit to account for the stolen funds or determine 

the full extent of the municipal treasury's vulnerability, constituting a direct breach 

of his statutory fiduciary duty under City Charter Section 2.14. Count 5: Unlawful Deployment of Flock Surveillance Cameras Without Public Hearing 

and Surrender of Public Image Rights to Private Vendor

• Applicable Legal Grounds: City Charter Section 2.14(a); City Code of Ethics 

(Ordinance No. 2006-001); O.C.G.A. § 36-30-2; O.C.G.A. § 50-14-1 et seq. (Open 

Governance).

• Statement of Fact: Mayor Presley authorized and executed the deployment of Flock 

Safety automated license plate recognition (ALPR) surveillance camera technology 

across municipal jurisdiction without conducting a formal public hearing, providing 

prior public notice, or allowing public comment from constituents regarding the civil 

liberties and privacy impacts of local surveillance. Furthermore, the Memorandum 

of Understanding (MOU) executed under Mayor Presley’s executive direction 

explicitly surrenders and transfers all image rights, data usage ownership, and 

proprietary controls over captured public visual data directly to Flock Safety (a 

private third-party corporate entity). Surrendering public image data captured within 

municipal rights-of-way to a private corporate entity without public hearing or 

legislative protections constitutes an arbitrary abuse of executive power and a direct 

violation of the fiduciary duties codified in City Charter Section 2.14.

Count 6: Unlawful Interfund Borrowing & Misuse of Referendum-Restricted 

TSPLOST/SPLOST Funds (Audit Finding 2024-6)

• Applicable Legal Grounds: O.C.G.A. § 48-8-121 (Use of Special Sales Tax Proceeds); 

O.C.G.A. § 48-8-110 et seq.; City Charter Section 2.14.

• Statement of Fact: Official municipal audit records (Audit Finding 2024-6) confirm 

that under Mayor Presley's executive supervision, the city engaged in unauthorized 

interfund transactions wherein the TSPLOST Fund maintained an improper interfund 

balance owed to the SPLOST Fund. Under Georgia law, SPLOST and TSPLOST 

revenue is strictly restricted by voter referendum and cannot be borrowed or 

transferred to fund separate accounts or offset operational deficits. This improper 

handling required corrective auditor intervention and delayed fund transfers through 

April 2025, violating statutory referendum mandates and fiduciary principles.

Count 7: Systemic Failure to Implement Segregation of Duties & Internal Accounting 

Controls (Audit Finding 2024-1) • Applicable Legal Grounds: O.C.G.A. § 36-81-3; City Charter Section 2.14; City Code 

of Ethics.

• Statement of Fact: Official state audit findings (Finding 2024-1) document a long-

standing, uncorrected operational failure regarding inadequate segregation of 

duties within municipal accounting, cash handling, and recordkeeping procedures. 

Mayor Presley failed to establish or enforce basic internal control checks, leaving 

financial intake, ledger entries, and bank reconciliations without executive 

oversight, directly exposing the municipal treasury to loss, error, and alleged 

employee embezzlement.

Count 8: Unlawful Departmental Overexpenditures in Excess of Budget Appropriations 

(Audit Finding 2024-2)

• Applicable Legal Grounds: O.C.G.A. § 36-81-3 (Uniform Automated Information 

System / Budgetary Controls); City Charter Section 2.14.

• Statement of Fact: Official audit findings (Finding 2024-2) establish that Mayor 

Presley permitted municipal operating departments to execute expenditures in 

direct excess of legally adopted budget appropriations without proposing or 

securing formal City Council budget amendments. Operating departments outside 

legal appropriations violates Georgia municipal budget law and demonstrates a 

total failure of executive budgetary control.

Count 9: Material Financial Reporting Misstatements & General Ledger 

Reconciliations (Audit Finding 2024-4)

• Applicable Legal Grounds: O.C.G.A. § 36-81-3; City Charter Section 2.14.

• Statement of Fact: Official audit findings (Finding 2024-4) document severe 

inaccuracies in general ledger accounts under Mayor Presley’s executive 

administration, requiring significant audit adjustments to reconcile basic financial 

statements. Maintaining defective general ledgers prevents accurate financial 

reporting and breaches the executive's duty to maintain transparent municipal 

records. Count 10: Severe Operational Deficits and Financial Unviability in Proprietary 

Water/Sewer Utility Funds (Audit Finding 2024-5)

• Applicable Legal Grounds: City Charter Section 2.14; O.C.G.A. § 36-81-3.

• Statement of Fact: Official audit findings (Finding 2024-5) establish that Mayor 

Presley’s administration failed to manage municipal utility pricing, cost structures, 

and operational budgets, causing severe, ongoing operating deficits in the Water & 

Sewer Fund. Arbitrarily freezing utility rates without financial modeling generated an 

operational loss exceeding $50,000.00, depleting utility reserves and threatening 

essential municipal services.

Count 11: Chronic Failure to File Mandatory State Audits & Infrastructure Grant 

Forfeiture (Audit Finding 2024-3)

• Applicable Legal Grounds: O.C.G.A. § 36-81-7 (Annual Audit Filing Requirements); 

City Charter Section 2.14.

• Statement of Fact: Mayor Presley continuously failed to ensure the timely 

completion and submission of mandatory annual municipal financial audits to the 

Georgia Department of Audits and Accounts (cited formally in Audit Finding 2024-3). 

This chronic audit delinquency directly caused the City of Maysville to forfeit 

eligibility for state and federal infrastructure grants required to repair failing water 

utility systems.

Count 12: Chronic Inaction on Safe Drinking Water Act Violations & Raw Sewage Spills

• Applicable Legal Grounds: Safe Drinking Water Act (42 U.S.C. § 300f et seq.); 

Georgia Safe Drinking Water Act (O.C.G.A. § 12-5-170 et seq.); Georgia Water Quality 

Control Act (O.C.G.A. § 12-5-20 et seq.).

• Statement of Fact: Under Mayor Presley’s executive management, municipal water 

utilities suffered uncontained raw sewage spills into public areas and repeated 

violations of federal Maximum Contaminant Levels (MCL) for Haloacetic Acids 

(HAA5), exposing residents to carcinogenic disinfection byproducts without 

corrective remediation. Count 13: Constructive Exclusion of the Public via Unvouched Room Occupancy 

Capping

• Applicable Legal Grounds: O.C.G.A. § 50-14-1 et seq. (Georgia Open Meetings Act); 

City Charter Section 2.14.

• Statement of Fact: During the December 2, 2024 meeting (and subsequent dates in 

May and June 2026), Mayor Presley ordered the public entrance to council 

chambers capped and locked, turning away citizens. When challenged, Presley 

failed to cite a legal fire code capacity limit, executing an arbitrary de facto closure 

of a public meeting. The City Clerk later acknowledged: "we knew a lot of people 

were coming."

Count 14: Usurpation of Statutory Authority Regarding Occupancy Signs & Making 

False Public Statements Regarding Legal Counsel Consultation

• Applicable Legal Grounds: O.C.G.A. § 8-2-20 et seq. (State Minimum Standard 

Codes); O.C.G.A. § 16-10-1 (Violation of Oath); O.C.G.A. § 16-10-20 (False 

Statements); O.C.G.A. § 36-2-14; City Code of Ethics (Ordinance No. 2006-001).

• Statement of Fact: On May 18, 2026, and June 1, 2026, Mayor Presley posted or 

directed the posting of manufactured room occupancy signs in City Hall. Under 

Georgia law, the power to issue occupancy limits is vested exclusively in the 

certified building official or fire marshal, not the Mayor acting independently. 

Furthermore, video recording evidence confirms that during an open municipal 

meeting, Mayor Presley publicly claimed on the record that he had specifically 

consulted with City Attorney Doug Kidd regarding the installation and posting of the 

occupancy sign. During that same meeting, City Attorney Doug Kidd explicitly 

denied on the record that Mayor Presley had consulted with him or received legal 

authorization for the sign. Falsely claiming legal counsel approval on the public 

record to justify an unauthorized usurpation of regulatory authority constitutes a 

deliberate misrepresentation, abuse of executive authority, and breach of the City 

Code of Ethics. Count 15: Secret Backchannel Legal Consultations During Open Meetings (Incident 

Date: May 28, 2026)

• Applicable Legal Grounds: O.C.G.A. § 50-14-1(b)(1); O.C.G.A. § 50-14-4.

• Statement of Fact: During open legislative proceedings on May 28, 2026, Mayor 

Presley engaged in whispered, unrecorded side conversations with the City Attorney 

over a live microphone during active municipal debate, excluding the public from 

hearing the legal advice and context anchoring pending votes without formally 

moving to enter Executive Session.

Count 16: Unlawful Unilateral Meeting Adjournment and Agenda Alteration

• Applicable Legal Grounds: O.C.G.A. § 50-14-1; Maysville City Rules of Procedure; 

Charter Section 2.14.

• Statement of Fact: In May 2024, Mayor Presley unilaterally walked out and 

terminated an official meeting without a motion, second, or recorded vote of 

council adjournment. Additionally, he routinely altered posted meeting agendas 

without putting formal amendments to a council vote.

Count 17: Deceptive Statements and Active Concealment of Northern Data Project 

Scope

• Applicable Legal Grounds: O.C.G.A. § 16-10-20; City Code of Ethics; City Charter 

Section 2.14.

• Statement of Fact: Mayor Presley stated on the public record that the proposed 

Northern Data facility consisted of "just one large building," in direct contradiction to 

corporate filings, site plans, and the January 30, 2025 zoning motion authorizing two 

125,000 sq. ft. buildings (250,000 sq. ft. total). Furthermore, Presley withheld 

blueprints and site schematics from the public. Count 18: Unlawful Surrender of Municipal Due Diligence to Corporate Developers

• Applicable Legal Grounds: City Charter Section 2.14; City Code of Ethics.

• Statement of Fact: Mayor Presley failed to order independent hydrological, 

environmental, or electrical impact studies for the data center project, relying 

entirely on studies paid for by the developer (Northern Data). On May 15, 2026, 

Presley accepted pre-written corporate talking points and directives from Northern 

Data to read at public planning meetings.

Count 19: Violation of Americans with Disabilities Act (ADA) Public Access 

Requirements

• Applicable Legal Grounds: Americans with Disabilities Act (42 U.S.C. § 12132); 

O.C.G.A. § 50-14-1.

• Statement of Fact: Mayor Presley has maintained public council meetings in an 

upstairs chamber accessible only via an unreliable stairlift (which, while currently 

operational, remains highly unreliable), uneven pavement, and no compliant 

handicap ramp, structurally excluding mobility-impaired citizens from open 

government proceedings.

Count 20: Inaccurate and Non-Compliant Campaign Finance Disclosures (O.C.G.A. § 

21-5-34)

• Applicable Legal Grounds: O.C.G.A. § 21-5-34; Campaign Finance Commission 

Rules.

• Statement of Fact: Mayor Presley submitted state Campaign Contribution 

Disclosure Reports containing omitted candidate Filer IDs (2023 Report), shifting 

contact phone numbers across filings without explanation, and unverified personal 

campaign loan balances ($9,075). Count 21: Failure to Maintain Intergovernmental Agreements for Emergency Fire/EMS 

Coverage

• Applicable Legal Grounds: O.C.G.A. § 36-69-1 et seq.; City Charter Section 1.12 & 

Section 2.14.

• Statement of Fact: Mayor Presley failed to maintain, execute, and renew binding 

Intergovernmental Agreements (IGAs) with Jackson and Banks counties for 

seamless municipal Fire and EMS emergency dispatch and coverage across county-

line municipal boundaries, endangering resident safety and abandoning executive 

public safety duties.

III. LEGAL BASIS SUMMARY TABLE

Count Alleged Violation

Applicable Law / Statute /