In an opinion issued Friday, the commission stated that "it is difficult to find a conflict of interest" because the three men paid what they thought was a fair price for the tickets and any disciplinary action "would be entirely inappropriate."
Despite INVESCO's offer of free admission to the April tournament and free accommodations, the county officials each paid $100 for their tickets and $100 a day for their food and lodging, the opinion stated.
A limited number of the highly coveted $100 tickets are sold to an exclusive list of ticket holders and the waiting list to become a ticket holder closed out in 1978, according to tournament officials.
Tickets can be scalped for as much as $8,000, Golf Digest Senior Editor Mike O'Malley estimated.
Because scalping is illegal it would be "an inappropriate measure" of the tickets' value and since Masters tickets are "reportedly difficult or impossible to obtain on the open market" the only value that can be assigned them is their face value of $100, the commission's opinion stated.
"From the beginning I didn't think I really did anything wrong," Snook said.
Davis said he had no comment. Shoop could not be reached.
INVESCO's contract expires Aug. 2, county officials said. The company was paid more than $100,000 in the past year, according to county Purchasing Agent Karen Luther.
Bids have come in for the next contract but Luther said no information about them would be divulged until the matter is brought before the County Commissioners, which is likely to happen Tuesday.
Snook, Shoop and Davis have disqualified themselves "in every respect from the process of awarding the contract," the Ethics Commission opinion stated.
Snook said Thursday he didn't know if he would vote on the contract.
"If people think I should abstain then that's fine," he said.
Even assuming the tickets were worth more than what the officials paid the county's process of awarding contracts "so insulates the recommendation to the Board of County Commissioners from undue influence that any conflict becomes a mere technicality with no real impact on the final decision," the opinion stated.
Bids are reviewed by a committee the majority of whose members are not affiliated with the county, according to the opinion.
Ordinarily, Shoop is the chair of the coordinating committee and Davis would participate as head of the department requesting the contract, the opinion stated.
The real problem is the "appearance of impropriety," according to the commission.
"In view of the harsh public spotlight under which county officials and employees operate, it may be better practice in the future to seek an advisory opinion and an exception or modification" from the ordinance in advance, the commission advised.
"The scrutiny which these three have undergone as a result of this trip will likely serve as a strong disincentive to other county officials and employees in the future," the opinion concluded.
In addition to Kaylor, who is an attorney, the Ethics Commission consists of attorney Catherine Drummond, Smithsburg Mayor Mildred "Mickey" Myers, William Dorsey and former Registrar of Wills Marvin Toms.