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HomeMy WebLinkAbout1501 McCallisterIn Re: Edward McCallister, Respondent File Docket: X -ref: Date Decided: Date Mailed: Before: Louis W. Fryman, Chair John J. Bolger, Vice Chair Donald M. McCurdy Paul M. Henry Raquel K. Bergen Nicholas A. Colafella 07 -059 Order No. 1501 12/4/08 12/19/08 This is a final adjudication of the State Ethics Commission. Procedurally, the Investigative Division of the State Ethics Commission conducted an investigation regarding a possible violation of the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1101 et seq., by the above -named Respondent. At the commencement of its investigation, the Investigative Division served upon Respondent written notice of the specific allegations. Upon completion of its investigation, the Investigative Division issued and served upon Respondent a Findings Report identified as an "Investigative Complaint." An Answer was filed and a hearing was requested. A Stipulation of Findings and a Consent Agreement waiving an evidentiary hearing were subsequently submitted by the parties to the Commission for consideration. The Stipulated Findings are set forth as the Findings in this Order. The Consent Agreement has been approved. This adjudication of the State Ethics Commission is issued under the Ethics Act and will be made available as a public document thirty days after the mailing date noted above. However, reconsideration may be requested. Any reconsideration request must be received at this Commission within thirty days of the mailing date and must include a detailed explanation of the reasons as to why reconsideration should be granted in conformity with 51 Pa. Code § 21.29(b). A request for reconsideration will not affect the finality of this adjudication but will defer its public release pending action on the request by the Commission. The files in this case will remain confidential in accordance with the Ethics Act. McCallister, 07 -059 Page 2 I. ALLEGATIONS: That Edward McCallister, a public official /public employee, in his capacity as a Member of the Steel Valley School District Board of Directors, violated Sections 1103(a) and 1104(a) of the State Ethics Act (Act 93 of 1998), 65 Pa.C.S. § §1103(a) and 1104(a), when he used the authority of his public position for the private pecuniary gain of a member of his immediate family by participating in board discussions and actions resulting in the hiring of his brother to various positions with the school district including but not limited to the following: Social Studies Department Head, Girl's Basketball Coach, Intramurals Director, Equipment manager, Middle School Academic Challenges and District Athletic Director; when he participated in discussions of the Board to make the Athletic Director a full -time position at the time when his brother held the position; and when he failed to file Statements of Financial Interests for the 2001 and 2002 calendar years. II. FINDINGS: 1. Edward McCallister has served as a Member of the Steel Valley School District (hereafter SVSD) Board of Directors since December 3, 2001. a. McCallister served as the Vice - President of the Board from December 6, 2004, until December 5, 2005. 2. SVSD is governed by a nine member board of directors. a. SVSD holds one workshop meeting and one legislative meeting each month on the third and fourth Tuesday of the month respectively. 1. Voting occurs only at the legislative meeting. b. Occasional special meetings are held as necessary. 3. Voting at SVSD meetings occurs via general voice vote after a motion has been properly made and seconded. a. Each individual board member's vote, including abstentions or objections cast, is recorded in the meeting minutes. b. Minutes of all meetings held are approved for accuracy by the board at subsequent board meetings. 4. The SVSD board of directors generally receives informational packets every Friday regarding situations, issues, events, etc. which have occurred at the district during the prior week. a. The packets are organized and compiled by the Superintendent's office. b. The regular meeting agenda, bill lists, prior month's minutes and various reports, correspondence, newspaper articles, etc. are included in the packet generally received the Friday prior to the workshop meeting. 5. The SVSD board of directors votes to approve the payment of district expenses under the "Financial Management" portion of each regular meeting. a. Various expenses are voted on and approved in one encompassing motion, including, among others, General Fund hand checks or Payroll Funding Transfers. McCallister, 07 -059 Page 3 1 Approval of General Fund hand checks and Payroll Funding Transfers represents approval of all wages /salaries issued to district staff in their primary and supplemental employment (if applicable) with the district for the month(s) specified in the minutes. aa. SVSD previously transferred payroll funds via approval and issuance of a general fund check noted on the General Fund hand check listing prior to utilizing automated Payroll Funding Transfers. 6. Signature authority over SVSD accounts rests with the board president, board vice - president, and district business manager (a /k/a board secretary). a. SVSD checks require the signature of two of the three authorized signatories. 1. Checks routinely bear the signatures of the board president and business manager. b. Checks issued are generated by the district with the required signatures already printed or have the required signatures affixed via facsimile stamps. 7 Various supplemental positions exist at SVSD in addition to administrative, teaching, support, and custodial positions. a. Existing supplemental positions are set forth via the Collective Bargaining Agreement between the Steel Valley Education Association and SVSD. 8. Individuals approved by the board for supplemental contracts with the district receive specific wages /salaries for their service in their respective positions. a. Wages /salaries received for each existing supplemental position are specified in the Collective Bargaining Agreement for each effective year of the Agreement. b. Individuals approved for supplemental positions submit supplemental salary payment requests for each supplemental contract to the Payroll Office indicating the desired schedule of payment. 9. Collective Bargaining Agreements in effect from 2002 through 2006 and 2006 through 2011 address the issue of supplemental contracts under Article XXIV, Miscellaneous Provisions, Section H. Per Section H of the Collective Bargaining Agreement, the district is to make one annual posting of all supplemental positions which it considers to be vacant or which will not necessarily be filled with the incumbent. 1. The board is to take public action naming the successful candidate for all posted positions. b. The incumbent is retained for all non - posted positions. 10. Supplemental positions provided for via the Collective Bargaining Agreement include both athletic (i.e., coaching) positions and general activities positions. a. 11. The school board generally approves one listing for supplemental activity positions McCallister, 07 -059 Page 4 and three listings for supplemental athletic positions each school year. a. Postings for supplemental athletic positions represent positions for the fall, winter, and spring sports seasons. b. All listings for existing supplemental positions (both posted and non - posted) and the proposed individuals to fill said positions are ultimately approved via formal vote by the SVSD school board. 12. SVSD maintains an Athletic /Activities Director position (hereafter AD position) to organize and administer all interscholastic athletic programs and district supported student activities. a. Primary responsibilities documented in the job description include, among others, recommending to the superintendent staff needs, preferred candidates for vacant positions, and renewal or non - renewal of all personnel related to areas of responsibility. 13. Identification of vacant positions at SVSD normally occurs via employee e-mail, posting in faculty lounges, and employee paychecks. a. Postings may also occur via various out -of- district mediums (i.e, newspapers) if no interest in the positions is expressed by district employees. b. Vacant positions are posted in -house at the district for approximately two weeks prior to out -of- district postings occurring. 14. Individuals interested in applying for vacant supplemental positions in the district are to express their interest in writing within two weeks of the posting. a. Letters of interest are to be submitted to the AD or the applicable building principal for the position in question. 15. Interviews conducted for supplemental positions are conducted by the AD and the applicable building principal at a minimum. 16. Recommendation of individuals to be appointed into supplemental athletic /activity positions are made by the AD to the applicable building principal and from the building principal to the Superintendent for eventual recommendation to the school board for approval. 17. Recommendations to the board are made via memorandum and attachments which are included in the Friday informational packets issued prior to the monthly workshop meeting. a. Attachments accompanying the memorandum list each supplemental position and the individual recommended for the position. 18. Appointment /approval of individuals to supplemental positions occurs via vote by the school board during the Personnel Management portion of legislative meetings. a. The school board typically votes on many personnel issues at once via one all inclusive vote. 19. Shawn McCallister is Edward McCallister's brother. McCallister, 07 -059 Page 5 a. Shawn McCallister was employed as a full time teacher with SVSD from July 11, 1991, through June 30, 2005. 20. The AD position vacancy was posted throughout SVSD subsequent to the previous AD's notice of resignation. a. The previous AD's notice of resignation was accepted by the school board at the March 14, 2005, regular meeting. 21. Shawn McCallister expressed his interest in the AD position in writing to Dr. William Kinavey, Assistant Superintendent (at that time), after the vacancy was posted. a. A total of four individuals applied for /expressed interest in the vacant AD position. 22. Interviews for the AD position were conducted by Kinavey, Senior High Principal Nancy Hines, and Middle School Principal John Ackerman. a. Shawn McCallister was selected as the top candidate by the interview team. 23. SVSD Solicitor Donald Fetsko provided a written legal opinion dated April 20, 2005, to Edward McCallister, the school board, then Superintendent Dr. Alex Warren, and then board Secretary Michael Bichko regarding a potential conflict regarding Shawn McCallister's appointment to the AD position. a. Fetsko issued the opinion in response to Ducar's request as the president of the school board. 1. Ducar indicated to Fetsko that Shawn McCallister had either made application or intended to make application for the AD position. 2. Ducar requested that Fetsko render a legal opinion on Edward McCallister's ability to vote for Shawn McCallister's potential appointment to the vacant AD position. 24. Fetsko's opinion stated that McCallister could vote for his brother if the school board was unable to elect a person to the position due to a tie vote or the inability to secure five votes for any one candidate. a. The opinion stated that McCallister could vote under 65 Pa C.S.A. § 1103(j) of the State Ethics Act if the procedure outlined in said section was followed. 25. At the May 23, 2005, regular school board meeting, a motion was made by board member Beth Cannon, seconded by board member Colleen Fedor, to approve various items under "Personnel Management." a. Included in the motion was the approval of Shawn McCallister to the supplemental position of AD at a salary of $7,761.93 effective at the beginning of the 2005 -2006 school year. 26. The motion to appoint Shawn McCallister to the AD position resulted in an initial 4- 3-1 vote. a. Eight board members were present at the May 23, 2005, meeting. b. McCallister abstained from the initial vote regarding the appointment of his brother to the AD position. McCallister, 07 -059 Page 6 27. Section 508 of the Pennsylvania Public School Code sets forth instances which require the affirmative vote of a majority of all the members of the school board regardless of the number of board members actually in attendance including, but not limited to, the following: a. Entering into contracts of any kind, including contracts for the purchase of fuel or any supplies, where the amount involved exceeds one hundred dollars. 28. The initial motion to appoint Shawn McCallister as the AD failed due to a lack of the required number of affirmative votes. a. Per Section 508 of the Public School Code, five affirmative votes were required to appoint Shawn McCallister to the AD position. 1. The vote taken involved entering into a contract with Shawn McCallister to provide services as AD in an amount exceeding $100.00. 29. Subsequent to the initial vote, Fetsko advised that a majority of the entire board was required to fill the position and that Edward McCallister was subsequently permitted to vote in order for a decision to be reached regarding Shawn McCallister's appointment. a. A motion was subsequently made by board member Keith O'Toole, seconded by Cannon, to reconsider the appointment of Shawn McCallister to the supplemental position of AD at a salary of $7,761.93 effective at the beginning of the 2005 -2006 school year. 30. A second motion to appoint Shawn McCallister into the AD position passed via 5 -3 vote upon reconsideration during the May 23, 2005, meeting. a. McCallister voted in favor of appointing his brother to the AD position, per the advice of Solicitor Fetsko. b. McCallister's vote was the deciding vote on his brother's appointment. 31. No specific salary was established for the AD position in association with the position's temporary full time status. a. The salary for the position was considered supplemental as listed in the applicable Collective Bargaining Agreement. 32. Shawn McCallister performed the duties and responsibilities of the AD position on a temporary full time basis during the 2005 -2006 school year. a. Shawn McCallister taught no classes at SVSD during the 2005 -2006 school year. b. SVSD employed a long -term substitute teacher during the 2005 -2006 school year to teach Shawn McCallister's Middle School Social Studies classes. 33. Although Shawn McCallister taught no classes during the 2005 -2006 school year, Shawn McCallister continued to receive his teacher's salary under the applicable Collective Bargaining Agreement. McCallister, 07 -059 Page 7 a. Shawn McCallister received the supplemental salary associated with the AD position as listed in the applicable Collective Bargaining Agreement in addition to his teacher's salary during the 2005 -2006 school year. 34. Shawn McCallister was not considered an administrator in his AD position. a. Shawn McCallister was considered a professional employee covered by the Collective Bargaining Agreement. 1. Shawn McCallister was required to work one hundred ninety days during the 2005 -2006 school year including one hundred eighty student days, four clerical days, and six in- service days. b. Shawn McCallister was not required to work during the summer months as district administrators were. 35. No formal board action was taken at the start of the 2006 -2007 school year regarding the status of the AD position. a. Shawn McCallister was the incumbent for the position. 36. Although no formal action was taken by the board at that time, the issue regarding the status of the AD position was occasionally discussed by the board in executive sessions. a. McCallister participated in discussions regarding the AD position to at least the same extent as other board members present. 37. The meeting packet issued to the SVSD board members the Friday before the October 17, 2006, workshop meeting included a proposal titled "Athletic /Activities Director." a. The proposal is dated October 13, 2006. b. The proposal was prepared by Kinavey. 38. Information in the proposal included a description of the request presented, relevant facts, a recommendation for action, and an attachment. a. The description of the request included the following information: 1. In 2004 -2005 the AD position was half -time AD and half -time teacher. 2. In 2005 -2006 the AD position was made temporary full -time. 3. Duties and responsibilities had been added to the position since becoming full -time, such as coordinating facility rentals and fundraising requests, operating the school store, and monitoring all events. 4. Kinavey's recommendation [was] to change the status of the AD position from temporary to a permanent, full -time position within the collective bargaining agreement. b. The attachment to the proposal consisted of correspondence from the Steel Valley Education Association (SVEA) President Drew Vautier. McCallister, 07 -059 Page 8 1 In the correspondence, Vautier requested that the school board consider making the AD position a professional position belonging to the bargaining unit represented by the SVEA. aa. Vautier indicated that the bargaining unit felt the position should be incorporated into the bargaining unit as a permanent position which would allow the district to resolve the parallel issue of the long term substitute in the Middle School Social Studies position. 39. Kinavey's proposal regarding the AD position was discussed in Executive Session at the October 17, 2006, board of director's workshop meeting. a. The subject of the AD position dominated the discussion held during the Executive Session. b. McCallister was present at the October 17, 2006, workshop meeting. c. McCallister participated in the discussions regarding making the position a full -time, permanent position. d. McCallister was a supporter of making the athletic director position permanent and full time. e. The discussions McCallister participated in did not pertain to the individual that would hold the possible permanent full -time position, but the status of the position. 40. At the October 24, 2006, regular meeting of the SVSD board of directors, a motion was made by McCallister, seconded by board member Brian Heddleston, to approve eighteen separate and individual items under the Personnel Management section of the meeting via one encompassing vote. a. Included in the Personnel Management section of the meeting under Item 6.4 was, "Change the status of the position of Athletic /Activities Director from temporary to a permanent full -time position within the collective bargaining agreement effective immediately." 41. The vote to approve the items documented in the Personnel Management section of the meeting, including the status change of the AD position to permanent full -time and its inclusion in the Collective Bargaining Agreement, passed via a 5 -3 -1 vote. a. McCallister voted in favor of the motion. 1. McCallister cast the deciding vote regarding the motion. 2. McCallister voted in favor of the motion at a time when Shawn McCallister occupied the temporary full -time Athletic Director position. b. Tim McCallister abstained from voting on the motion. 1. Tim McCallister is Shawn McCallister's cousin. 42. The AD position at SVSD has been a full -time permanent position since October 24, 2006. a. Shawn McCallister has served as the full -time permanent AD since October McCallister, 07 -059 Page 9 24, 2006. b. Shawn McCallister has not taught any classes at SVSD since becoming the full time permanent AD. 43. McCallister participated in votes as a member of the SVSD board of directors in appointing Shawn McCallister, his brother, to the position of AD for the 2005/2006, 2006/2007, and 2007/2008 school years as shown below: Meeting For School McCallister McCallister's Final Vote Date Year Present Vote 05/23/05 2005 -2006 Yes Yes 5 -3 N/A 2006 -2007 N/A N/A N/A 08/28/07 2007 -2008 No N/A 5 -0 a. The vote documented for the May 23, 2005, meeting represents the second vote taken on the issue per instructions by Solicitor Fetzko. b. No official motion /vote is documented in SVSD minutes regarding the appointment of Shawn McCallister to the AD position for the 2006 -2007 school year. c. McCallister did not participate in the vote to appoint Shawn McCallister as the AD for the 2007 -2008 school year. 44. Shawn McCallister's salary as the SVSD AD was established by the Collective Bargaining Agreement in effect for the 2005 -2006 and 2006 -2007 school years respectively as shown below: School Year Supplemental Salary (Gross) 2005 -2006 $7,761.03 2006 -2007 $8,149.08 Total $15,910.11 a. Shawn McCallister's salary as the AD is supplemental to that of his salary as a professional employee under the Collective Bargaining Agreement. 45. Shawn McCallister submitted supplemental salary payroll requests to the SVSD Business Office on September 7, 2005, for the 2005 -2006 school year and on August 28, 2006, for the 2006 -2007 school year in relation to his supplemental salary as the AD. a. Shawn McCallister requested that the supplemental salaries be split into equal payments over the course of the nine month academic school year for each year. 1. Shawn McCallister received eight payments of $431.17 from September 23, 2005, through December 30, 2005, and ten payments of $431.14 from January 1, 2006, through May 19, 2006, for the 2005- 2006 school year. aa. Checks issued to Shawn McCallister representative of the AD supplemental salary and other supplemental salaries were separate and apart from Shawn McCallister's regular payroll Meeting Date Position School Year McCallister Present McCallister's Vote Final Vote 08/11/03 Social Studies Department Head 2003/2004 Yes Yes 9 -0 10/13/03 7 "' Grade Girls Basketball Coach 2003/2004 Yes Yes 9 -0 09/20/04 Middle School Academic Challenges 2004/2005 Yes Yes 7 -0 McCallister, 07 -059 Page 10 checks. 2. Shawn McCallister received seventeen payments of $479.35 from October 6, 2006, through May 18, 2007, and one payment of $479.48 in June 2007 for the 2006 -2007 school year. aa. Checks issued to Shawn McCallister representative of the AD supplemental salary and other supplemental salaries were included within Shawn McCallister's regular payroll checks on all but two occasions during the 2006 -2007 school year. 46. In addition to serving as the district AD, Shawn McCallister was also appointed to the following supplemental positions, at a minimum, spanning the time frame of the 2002/2003 through 2006/2007 school years as shown below: a. Middle School Student Gov. Sponsor: 2002/2003 b. Girls Varsity Basketball Coach: 2002/2003 c. Seventh Grade Girls Basketball Coach: 2003/2004 d. Middle School Academic Challenges Sponsor: 2002/2003 through 2004/2005 1. Shawn McCallister was initially appointed as the Middle School Academic Challenges Sponsor for the 2005/2006 school year also but resigned the position prior to receiving the established salary. e. Social Studies Dept. Head: 2002/2003 through 2004/2005 f. Boys Varsity Basketball Coach: 2003/2004 through 2006/2007 g. Equipment Manager: 2006/2007 h. Intramurals Director: 2002/2003 through 2006/2007 1. Although appointed to the Intramurals Director position for the 2004/2005 school year, no record of payment to Shawn McCallister was noted. All additional supplemental positions to which Shawn McCallister was appointed were ultimately presented to the school board of directors for formal approval with the exception of Equipment Manager for the 2005/2006 school year. aa. Shawn McCallister informally began serving as the Equipment Manager in January 2006 but received no salary in the position until the beginning of the 2006/2007 school year. 47. Edward McCallister was present at SVSD school board meetings and participated in votes to approve Shawn McCallister's appointment to various supplemental contract positions on six separate occasions as shown below: Meeting Date Position School Year McCallister Present McCallister's Vote Final Vote 09/16/02 Intramural Director 2002/2003 Yes Abstained 5 -2 -1 09/16/02 Middle School Student Government 2002/2003 Yes Abstained 5 -2 -1 10/14/02 Girls Varsity Basketball Coach 2002/2003 Yes Abstained 5 -0 -1 06/09/03 Boys Varsity Basketball Coach 2003/2004 Yes Abstained 8 -0 -1 09/15/03 Intramural Director 2003/2004 Yes Abstained 7 -0 -1 09/15/03 Middle School Academic Challenges 2003/2004 Yes Abstained 7 -0 -1 08/09/04 7 "' Grade Girls Basketball Coach 2004/2005 Yes Abstained 7 -0 -1 08/09/04 Social Studies Department Head 2004/2005 Yes Abstained 7 -0 -1 12/05/06 Boys Varsity Basketball Coach 2006/2007 Yes Abstained 7 -0 -1 Meeting Date Position School Year McCallister Present McCallister's Vote Final Vote 09/19/05 Intramural Director 2005/2006 Yes Yes 7 -0 07/25/06 Equipment Manager 2006/2007 Yes Yes 9 -0 09/26/06 Intramural Director 2006/2007 Yes Yes 8 -0 McCallister, 07 -059 Page 11 48. McCallister was aware of the requirement to abstain from votes regarding the appointment of Shawn McCallister to supplemental contract positions. a. SVSD school board meeting minutes document McCallister abstaining from votes to appoint Shawn McCallister to supplemental contract positions as shown below: b. Aware of the need to abstain from voting regarding the appointment of Shawn McCallister to supplemental contract positions, McCallister did vote on six occasions to appoint lists of individuals to supplemental positions. Included in these lists were the appointments of Shawn McCallister to the above six (6) supplemental positions. 49. Shawn McCallister's salaries in the supplemental contract positions were established within the Collective Bargaining Agreement in effect for each applicable year that the positions were held as noted in the chart below: Position Social Studies Department Head 7 "' Grade Girls Basketball Coach Middle School Academic Challenges Intramural Director Equipment Manager Intramural Director Total School Year Supplemental Salary 2003/2004 2003/2004 2004/2005 2005/2006 2006/2007 2006/2007 (Gross) $1,759.50 1,966.50 267.81 1,663.08 2,910.38 1, 746.23 $10,313.50 a. Shawn McCallister's salaries in his supplemental contract positions were separate and apart from his salary as a professional employee under the Collective Bargaining Agreement. b. Information presented in the chart above is limited to those instances where McCallister took official action and was one of the unanimous votes to appoint Shawn McCallister to the supplemental positions noted. 50. Shawn McCallister submitted supplemental salary payroll requests to the SVSD Business office requesting payment in relation to his supplemental contract Check Number Check Date Check Amount (Net) Disposition Reason Issued 011428* 11/07/03 $1,435.70 Negotiated: Acct # 32318014 7 "' Grade Girls Basketball Coach 012097 12/05/03 1,733.66 Negotiated: Acct # 32318014 Intramurals Director/ Middle School Academic Cing/ Boys Varsity Basketball/ Social Studies Dept. Head 016076 05/21/04 1,284.48 Negotiated: Acct # 32318014 Intramurals Director/ Middle School Academic Cing/ Social Studies Dept. Head 024764 05/06/05 216.10 Negotiated: Acct # 32318014 Middle School Academic Cing 028087 09/23/05 347.91 Negotiated: Acct # 32318014 Athletic Director 028434 10/07/05 347.91 Negotiated: Acct # 32318014 Athletic Director 028794 10/21 /05 347.91 Negotiated: Acct # 32318014 Athletic Director 029164 11/04/05 347.91 Negotiated: Acct # 32318014 Athletic Director 029503 11/18/05 347.91 Negotiated: Acct # 32318014 Athletic Director 029877 12/02/05 2,713.99 Negotiated: Acct # 32318014 Boys Varsity Basketball/ Intramurals Director/ Athletic Director 030248 12/16/05 347.91 Negotiated: Acct # 32318014 Athletic Director Position - School Year Submission Date Pymt Schedule Pymt Amount(s) 2 p $879.75 Total {Gross) $1,759.50 Social Studies Department Head -03/04 Unknown* 1/2 Dec & 1/2 May 7 "' Grade Girls Basketball Coach -03/04 10/21/03 Lump Sum $1,966.50 $1,966.50 Middle School Academic Challenges -04/05 10/11/04 Lump Sum $267.81 $267.81 Intramural Director -05/06 10/10/05 1 / Dec & 1 / May 2 (a, $831.54 $1,663.08 Equipment Manager -06/07 08/28/06 Equal Payments 18 @ $153.18 1 (a, $153.14 $2,910.38 Intramural Director -06/07 09/27/06 1 / Dec & 1 / May 1 $873.12 1 A $873.11 $1,746.23 McCallister, 07 -059 Page 12 positions as follows: * No supplemental salary payroll request form could be located for Shawn McCallister's Social Studies Department Head position regarding the 2003/2004 school year. a. Checks issued to Shawn McCallister during the time period of November 7, 2003, through October 6, 2006, and on November 3, 2006, as payment for supplemental positions held were issued separate and apart from Shawn McCallister's regular payroll checks. 1. Checks issued to Shawn McCallister at times represented payment for multiple supplemental positions held. b. Checks issued to Shawn McCallister during the time period of October 20, 2006, through June 1, 2007, represented payment of Shawn McCallister's regular payroll as well as any supplemental contract payment due at that time. 51. By participating in the unanimous votes to appoint Shawn McCallister to various supplemental positions at SVSD, McCallister's actions contributed to Shawn McCallister's receipt of at least forty -two checks wholly or in part representative of supplemental salaries due as shown below: Check Number Check Date Check Amount (Net) Disposition Reason Issued 030619 12/30/05 347.91 Negotiated: Acct # 32318014 Athletic Director 030974 01/13/06 347.91 Negotiated: Acct # 32318014 Athletic Director 031334 01/27/06 347.91 Negotiated: Acct # 32318014 Athletic Director 031752 02/10/06 2,243.98 Negotiated: Acct # 32318014 Boys Varsity Basketball/ Athletic Director 032125 02/24/06 347.91 Negotiated: Acct # 32318014 Athletic Director 032518 03/10/06 347.91 Negotiated: Acct # 24432014 Athletic Director 032880 03/24/06 347.91 Negotiated: Acct # 24432014 Athletic Director 033250 04/07/06 347.91 Negotiated: Acct # 24432014 Athletic Director 033603 04/21/06 347.91 Negotiated: Acct # 24432014 Athletic Director 033999 05/05/06 937.56 Negotiated: Acct # 24432014 Intramurals Director/ Athletic Director 034385 05/19/06 347.88 Negotiated: Acct # 24432014 Athletic Director 037322 09/22/06 123.60 Negotiated: Acct # 24432014 Equipment Manager 037710 10/06/06 495.36 Negotiated: Acct # 24432014 Equi Manager/ Athletic Director 38066 10/20/06 2,420.61 Negotiated: Acct # 24432014 Equipment Manag Athletic Director/ Regular Salary 38197 11/03/06 123.60 Negotiated: Acct # 24432014 Equipmen Manager 38198 11/03/06 2,332.44 Negotiated: Acct # 24432014 Athletic D Regular Salary 38316 11/17/06 2,420.61 Negotiated: Acct # 24432014 Athletic Director/ Regular Salary/ Equipment Manager 38446 12/01/06 2,923.33 Negotiated: Acct # 24432014 Athletic Director/ Regular Salary/ Equipment Manager/ Intramurals Director 38551 12/15/06 4,096.66 Negotiated: Acct # 24432014 Athletic Director/ Regular Salary/ Equipment Manager/ Boys Varsity Basketball 38656 12/29/06 2,422.20 Negotiated: Acct # 24432014 Athletic Director/ Regular Salary/ Equipment Manager 38763 01/12/07 2,380.62 Negotiated: Acct # 24432014 Athletic Director/ Regular Salary/ Equipment Manager 38872 01/26/07 2,432.62 Negotiated: Acct # 24432014 Athletic Director/ Regular Salary/ Equipment Manager 38986 02/09/07 2,432.62 Negotiated: Acct # 24432014 Athletic Director/ Regular Salary/ Equipment Manager 39082 02/23/07 4,116.73 Negotiated: Acct # 24432014 Athletic Director/ Regular Salary/ Equipment Manager/ Boys Varsity Basketball 39197 03/09/07 2,432.62 Negotiated: Acct # 24432014 Athletic Director/ Regular Salary/ Equipment Manager 39303 03/23/07 2,432.62 Negotiated: Acct # 24432014 Athletic Director/ McCallister, 07 -059 Page 13 Check Number Check Date Check Amount (Net) Disposition Reason Issued Final Vote Reason Issued 011428* 11/07/03 Regular Salary/ Equipme Manager 39420 04/05/07 2,432.62 Negotiated: Acct # 24432014 Athletic Director/ Regular Salary/ Equipment Manager 39531 04/20/07 2,432.62 Negotiated: Acct # 24432014 Athletic Director/ Regular Salary/ Equipment Manager 39619 05/04/07 2,432.62 Negotiated: Acct # 24432014 Athletic Director/ Regular Salary/ Equipment Manager 39708 05/18/07 2,935.24 Negotiated: Acct # 24432014 Athletic Director/ Regular Salary/ Equipment Manager/ Intramurals Director 39883 06/01/07 2,156.75 Negotiated: Acct # 24432014 Athletic Director/ Regular Salary/ Equipment Manager Check Number Check Date Check Amount Meeting Date McCallister Vote Final Vote Reason Issued 011428* 11/07/03 $1,435.70 01/12/04 No (Not Present) 7 -0 7 "' Grade Girls Basketball Coach 012097 12/05/03 1,733.66 02/09/04 No (Not Present) 7 -0 Intramurals Director/ Middle School Academic Cing/ Boys Varsity Basketball/ Social Studies Dept. Head McCallister, 07 -059 Page 14 * Extra $35.00 included in check total for work performed at athletic function a. Account numbers xxxx8014 and xxxx2014 represent personal accounts maintained at Tri Boro Federal Credit Union over which Shawn McCallister holds signature authority. 52. McCallister was one of the unanimous votes to approve General Fund Hand Checks or Payroll Funding Transfers during the "Financial Management" section of SVSD meetings authorizing the issuance of payroll, including checks representing wholly or in part, supplemental salaries to Shawn McCallister, as follows: b. Shawn McCallister's signature appears on the reverse of each check issued along with micro numbers associated with Shawn McCallister's accounts at Tri Boro Federal Credit Union with the exception of check numbers 033250 and 39303. 1. Micro numbers 3231807 and 2443200 are associated with account numbers xxxx8014 and xxxx2014 respectively. 2. Check numbers 033250 and 39303 each bear a deposit stamp in the endorsement section of each check along with micro number xxxx2014. Check Number Check Date Check Amount Meeting Date McCallister Vote Final Vote Reason Issued 016076 05/21/04 1,284.48 06/21/04 No (Not Present) 6 -0 Intramurals Director/ Middle School Academic Cing/ Social Studies Dept. Head 024764 05/06/05 216.10 06/27/05 No (Not Present) 6 -0 Middle School Academic Cing 028087 09/23/05 347.91 10/10/05 No (Not Present) None Recorded Athletic Director 028434 10/07/05 347.91 11/14/05 No (Not Present) 7 -0 Athletic Director 028794 10/21/05 347.91 11/14/05 No (Not Present) 7 -0 Athletic Director 029164 11/04/05 347.91 12/05/05 Yes 6 -0 Athletic Director 029503 11/18/05 347.91 12/05/05 Yes 6 -0 Athletic Director 029877 12/02/05 2,713.99 01/24/06 No (Not Present) 6 -0 Boys Varsity Basketball/ Intramurals Director/ Athletic Director 030248 12/16/05 347.91 01/24/06 No (Not Present) 6 -0 Athletic Director 030619 12/30/05 347.91 01/24/06 No (Not Present) 6 -0 Athletic Director 030974 01/13/06 347.91 02/28/06 Yes 8 -0 Athletic Director 031334 01/27/06 347.91 02/28/06 Yes 8 -0 Athletic Director 031752 02/10/06 2,243.98 03/28/06 Yes 6 -0 Boys Varsity Basketball/ Athletic Director 032125 02/24/06 347.91 03/28/06 Yes 6 -0 Athletic Director 032518 03/10/06 347.91 04/25/06 Yes 8 -0 Athletic Director 032880 03/24/06 347.91 04/25/06 Yes 8 -0 Athletic Director 033250 04/07/06 347.91 05/23/06 Yes 8 -0 Athletic Director 033603 04/21/06 347.91 05/23/06 Yes 8 -0 Athletic Director 033999 05/05/06 937.56 06/29/06 Yes 8 -0 Intramurals Director/ Athletic Director 034385 05/19/06 347.88 06/29/06 Yes 8 -0 Athletic Director 037322 09/22/06 123.60 10/24/06 Yes 9 -0 Equipment Manager 037710 10/06/06 495.36 12/05/06 Yes 8 -0 Equipment Manager/ Athletic Director 38066 10/20/06 2,420.61 12/05/06 Yes 8 -0 Equipment Manager/ Athletic Director/ Regular Salary 38197 11/03/06 123.60 12/05/06 Yes 8 -0 Equipment Manager 38198 11/03/06 2,332.44 12/05/06 Yes 8 -0 Athletic Director/ Regular Salary 38316 11/17/06 2,420.61 12/05/06 Yes 8 -0 Athletic Director/ Regular Salary/ Equipment Manager 38446 12/01/06 2,923.33 01/23/07 Yes 8 -0 Athletic Director/ Regular Salary/ Equipment Manager/ Intramurals Director 38551 12/15/06 4,096.66 01/23/07 Yes 8 -0 Athletic Director/ Regular Salary/ Equipment Manager/ Boys Varsity Basketball 38656 12/29/06 2,422.20 01/23/07 Yes 8 -0 Athletic Director/ Regular Salary/ McCallister, 07 -059 Page 15 Check Number Check Date Check Amount Meeting Date McCallister Vote, Final Vote Reason Issued Equipment Manager 38763 01/12/07 2,380.62 02/27/07 Yes 7 -0 Athletic Director/ Regular Salary/ Equipment Manager 38872 01/26/07 2,432.62 02/27/07 Yes 7 -0 Athletic Director/ Regular Salary/ Equipment Manager 38986 02/09/07 2,432.62 03/27/07 Yes 9 -0 Athletic Director/ Regular Salary/ Equipment Manager 39082 02/23/07 4,116.73 03/27/07 Yes 9 -0 Athletic Director/ Regular Salary/ Equipment Manager/ Boys Varsity Basketball 39197 03/09/07 2,432.62 04/24/07 Yes 7 -0 Athletic Director/ Regular Salary/ Equipment Manager 39303 03/23/07 2,432.62 04/24/07 Yes 7 -0 Athletic Director/ Regular Salary/ Equipment Manager 39420 04/05/07 2,432.62 05/22/07 Yes 9 -0 Athletic Director/ Regular Salary/ Equipment Manager 39531 04/20/07 2,432.62 05/22/07 Yes 9 -0 Athletic Director/ Regular Salary/ Equipment Manager 39619 05/04/07 2,432.62 06/28/07 No (Not Present) 7 -0 Athletic Director/ Regular Salary/ Equipment Manager 39708 05/18/07 2,935.24 06/28/07 No (Not Present) 7 -0 Athletic Director/ Regular Salary/ Equipment Manager/ Intramurals Director 39883 06/01/07 2,156.75 08/28/07 No (Not Present) 5 -0 Athletic Director/ Regular Salary/ Equipment Manager McCallister, 07 -059 Page 16 Extra $35.00 included in check total for work performed at athletic function a. McCallister was one of the unanimous affirmative votes on twenty -nine out of forty -two possible occasions to approve General Fund Hand Checks or Payroll Funding Transfers resulting in the issuance of checks representing wholly or in part supplemental salaries due to Shawn McCallister. b. McCallister was not present to vote at the thirteen remaining school board meetings. 53. At the August 28, 2007, regular board meeting, the SVSD board of directors was presented with the 2007/2008 fall athletic supplemental register and the 2007/2008 activity supplemental appointment register for approval. a. Shawn McCallister was documented as the recommended appointee for the positions of AD, Equipment Manager, and Intramurals Director. Supplemental Position School Year Contract Salary (Grass) Social Studies Department Head 2003/2004 $1,75 9.50 7 "' Grade Girls Basketball Coach 2003/2004 1,966.50 Middle School Academic Challenges 2004/2005 267.81 McCallister, 07 -059 Page 17 b. The presentation of the registers for approval, among other items, is documented under the Personnel Management section of the minutes. c. Edward McCallister was not present at the August 28, 2007, meeting. 54. Prior to the vote to approve the items listed under "Personnel Management," board member Beth Cannon presented for consideration that the supplemental positions of Equipment Manager and Intramurals Director be responsibilities included within the full time AD position. a. No action was taken on Cannon's recommendation at the August 28, 2007, meeting. 55. Items presented under the Personnel Management section of the meeting, including the approval of the athletic and supplemental positions as presented, were approved via 5 -0 vote with the exception of Shawn McCallister's appointment as the AD, Equipment Manager, and Intramurals Director. a. The board voted 2 -2 -1 on Shawn McCallister's appointment as the AD and 1 -3 -1 on Shawn McCallister's appointment as the Equipment Manager and Intramurals Director. 1. Tim McCallister abstained from the vote to appoint Shawn McCallister as the AD, Equipment Manager, and Intramurals Director. 56. The SVSD board of directors subsequently heard a separate motion from board member Brian Heddleston, seconded by Tim McCallister, to appoint Shawn McCallister into the position of AD only at the August 28, 2007, meeting. a. The motion passed via 5 -0 vote. 57. Revisions to the job description of AD, among other items, were presented for approval under the Personnel Management section of the October 23, 2007, regular meeting of the SVSD board of directors. a. Revisions included adding language which effectively incorporated the duties of Equipment Manager and Intramurals Director into the full time AD position. b. The revisions were approved via 6 -1 -1 vote. 1. Edward McCallister abstained from the vote. a. No increase in salary for the AD position occurred as a result of incorporating the Equipment Manager and Intramurals Director into the AD position. 58. Shawn McCallister, Edward McCallister's brother, was paid approximately $26,223.61 (gross) as a result of his appointment to various supplemental contract positions with SVSD as shown below: Athletic /Activities Director 2005/2006 7,761.03 Intramural Director 2005/2006 1,663.08 Athletic /Activities Director 2006/2007 8,149.08 Equipment Manager 2006/2007 2,910.38 Intramural Director 2006/2007 1,746.23 Total $26,223.61 McCallister, 07 -059 Page 18 a. The vote by McCallister to appoint his brother to the AD position for the 2005/2006 school year was based on the advice of the SVSD Solicitor Donald Fetsko. b. No official motion /vote by McCallister is documented in SVSD minutes regarding the appointment of Shawn McCallister to the AD position for the 2006 -2007 school year. c. The total financial gain realized by Shawn McCallister as a result of his appointment to positions that his brother participated in, minus Sections (a) and (b) above, was $10,313.50. THE FOLLOWING FINDINGS RELATE TO ALLEGATIONS THAT McCALLISTER FAILED TO FILE STATEMENTS OF FINANCIAL INTERESTS IN HIS POSITION AS A SCHOOL BOARD MEMBER FOR CALENDAR YEARS 2001 AND 2002. 59. Statement of Financial Interests filing requirements for public officials and public employees are mandated by Section 1104 of the State Ethics Act. a. McCallister was required to file Statements of Financial Interests by May 1St annually in his position as a member of the SVSD Board of Directors. 60. A review of Statements of Financial interests on file with SVSD was conducted on April 27, 2007, and February 14, 2008. a. McCallister filed Statements of Financial Interests with SVSD for calendar years 2003 through 2006 as shown below: Calendar Year Signature Date 2003 05 -01 -05 2004 02 -14 -05 2005 03 -28 -06 1. McCallister's Statement of Financial Interests filed for calendar year 2003 is an amended form based on a previous Statement of Financial Interests Compliance Review conducted by the Commission's Administrative Division. 61. Review of available Statements of Financial Interests on file at SVSD revealed no Statements of Financial interests for McCallister regarding calendar year 2002. III. DISCUSSION: As a Member of the School Board ( "Board ") of the Steel Valley School District ( "School District ") since December 3, 2001, Respondent Edward McCallister (hereinafter also referred to as "Respondent," "Respondent McCallister," and "McCallister") has been a public official subject to the provisions of the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1101 et seq. McCallister, 07 -059 Page 19 The allegations are that Respondent violated Sections 1103(a) and 1104(a) of the Ethics Act: (1) when he, as a Member of the Board, used the authority of his public position for the private pecuniary gain of a member of his immediate family by participating in Board discussions and actions resulting in the hiring of his brother to various positions with the School District including but not limited to Social Studies Department Head, Girl's Basketball Coach, Intramurals Director, Equipment Manager, Middle School Academic Challenges Sponsor, and District Athletic Director; (2) when he participated in discussions of the Board to make the Athletic Director a full -time position at the time when his brother held the position; and (3) when he failed to file Statements of Financial Interests ( "SFIs ") for the 2001 and 2002 calendar years. Pursuant to Section 1103(a) of the Ethics Act, a public official /public employee is prohibited from engaging in conduct that constitutes a conflict of interest: § 1103. Restricted activities (a) Conflict of interest. —No public official or public employee shall engage in conduct that constitutes a conflict of interest. 65 Pa.C.S. § 1103(a). The term "conflict of interest" is defined in the Ethics Act as follows: § 1102. Definitions "Conflict" or "conflict of interest." Use by a public official or public employee of the authority of his office or employment or any confidential information received through his holding public office or employment for the private pecuniary benefit of himself, a member of his immediate family or a business with which he or a member of his immediate family is associated. The term does not include an action having a de minimis economic impact or which affects to the same degree a class consisting of the general public or a subclass consisting of an industry, occupation or other group which includes the public official or public employee, a member of his immediate family or a business with which he or a member of his immediate family is associated. 65 Pa.C.S. § 1102. Section 1103(a) of the Ethics Act prohibits a public official /public employee from using the authority of public office /employment or confidential information received by holding such a public position for the private pecuniary benefit of the public official /public employee himself, any member of his immediate family, or a business with which he or a member of his immediate family is associated. Section 1104(a) of the Ethics Act provides that each public official /public employee must file a Statement of Financial Interests for the preceding calendar year, each year that he holds the position and the year after he leaves it. As noted above, the parties have submitted a Consent Agreement and Stipulation of Findings. The parties' Stipulated Findings are set forth above as the Findings of this Commission. We shall now summarize the relevant facts as contained therein. Respondent has served as a Member of the Board since December 3, 2001. The McCallister, 07 -059 Page 20 Board consists of nine Members. The Board formally votes to appoint /hire individuals to positions with the School District. In addition to administrative, teaching, support, and custodial positions, the Board fills various "supplemental positions," such as coaching and general activities positions. Individuals approved by the Board for supplemental contracts with the School District receive specific wages or salaries set forth in the Collective Bargaining Agreement for their service in such supplemental positions. At the Board's March 14, 2005, regular meeting, the Board accepted the resignation of the individual who was then serving as the School District's Athletic /Activities Director ( "AD "). The AD position vacancy was posted throughout the School District. Respondent's brother, Shawn McCallister, was one of four individuals who expressed interest in the vacant AD position. At the time, Shawn McCallister was employed as a teacher with the School District. Following interviews for the AD position, Shawn McCallister was selected as the top candidate by the interview team. At the request of the Board President, the School District Solicitor provided a written legal opinion as to Respondent's ability to vote for Shawn McCallister's potential appointment to the vacant AD position. In the legal opinion, dated April 20, 2005, the Solicitor stated that Respondent could vote to appoint his brother to the AD position if there was a tie vote of the Board or if there were not five votes for any one candidate. The Solicitor's opinion also stated that Respondent could vote if the procedures set forth in Section 1103(j) of the Ethics Act were followed. Five affirmative votes were required in order to appoint /hire Shawn McCallister to the School District's AD position. On May 23, 2005, at a regular meeting of the Board, the Board voted on two motions to appoint Shawn McCallister to the position of AD. The initial motion failed by a 4 -3 -1 vote. Respondent abstained from the initial vote to appoint his brother to the AD position. The Solicitor then advised that Respondent was permitted to vote on his brother's appointment to the AD position so that a final decision could be reached by the Board. After a second motion was made to appoint Shawn McCallister to the AD position, Respondent voted in favor of appointing his brother to the AD position. The second motion passed by a 5 -3 vote, with Respondent casting the deciding vote. At the time Shawn McCallister was appointed to the AD position, it was a temporary, full -time position. No specific salary was established for the AD position, but the salary was considered to be supplemental per the applicable Collective Bargaining Agreement. For the 2005 -2006 school year, Shawn McCallister performed the duties and responsibilities of the AD position on a temporary full -time basis. Shawn McCallister did not teach any classes at the School District during the 2005 -2006 school year, but he continued to receive his teacher's salary along with the supplemental salary associated with the AD position per the applicable Collective Bargaining Agreement. For the 2006 -2007 school year, Shawn McCallister was the incumbent for the AD position. No official motion /vote is documented in Board meeting minutes regarding the appointment of Shawn McCallister to the AD position for the 2006 -2007 school year. Although the Board did not take any formal action regarding the AD position at the beginning of the 2006 -2007 school year, the Board, including Respondent, occasionally discussed the status of the AD position at executive sessions. At the Board's October 17, 2006, workshop meeting, the then Assistant Superintendent presented a proposal to the Board to change the status of the AD position to a permanent, full -time position within the Collective Bargaining Agreement. Respondent participated in the Board discussions and supported the aforesaid proposal. The McCallister, 07 -059 Page 21 discussions in which Respondent participated did not specifically pertain to the particular individual who would be holding the possible permanent, full -time AD position, but rather, the status of the position. At the October 24, 2006, regular Board meeting, Respondent made a motion to approve multiple personnel items, including changing the status of the AD position from a temporary position to a permanent, full -time position within the Collective Bargaining Agreement effective immediately. (The Board typically votes on many personnel issues at once via one all- inclusive vote. Fact Finding 18 a.) Respondent's motion passed by a 5 -3- 1 vote. Respondent's vote in favor of the motion was the deciding vote. Respondent voted in favor of the motion at a time when Shawn McCallister occupied the AD position. The AD position has been a full -time permanent position since October 24, 2006. Respondent's brother, Shawn McCallister, has served as the full -time permanent AD since October 24, 2006, and has not taught any classes at the School District since that time. We note that Respondent was not present at the Board's meeting on August 28, 2007, and did not participate in the vote at that meeting to appoint Shawn McCallister to the AD position for the 2007 -2008 school year. Per the Collective Bargaining Agreements, Shawn McCallister's salary as the AD was $7,761.03 for the 2005 -2006 school year and $8,149.08 for the 2006 -2007 school year, for a total of $15,910.11. Such AD salary was supplemental to Shawn McCallister's salary as a professional employee under the Collective Bargaining Agreement. Respondent also voted to appoint his brother to the following supplemental contract positions: Social Studies Department Head for the 2003 -2004 school year; Seventh Grade Girls Basketball Coach for the 2003 -2004 school year; Middle School Academic Challenges Sponsor for the 2004 -2005 school year; Intramural Director for the 2005 -2006 and 2006 -2007 school years; and Equipment Manager for the 2006 -2007 school year. Shawn McCallister submitted supplementary salary payroll requests and received a total of $10,313.50 for serving in the aforesaid supplemental positions. Respondent was aware of the need to abstain from voting regarding the appointment of his brother to supplemental contract positions. Respondent abstained from voting to appoint his brother to various supplemental contract positions at six Board meetings between September 16, 2002, and December 5, 2006. Fact Finding 48 a. Per Paragraph 3 e of the Consent Agreement, the parties are in agreement that Respondent abstained from voting to appoint his brother to supplemental contract positions on nine different occasions between 2002 and 2004 and in 2006. Between December 5, 2005, and May 22, 2007, Respondent voted to approve twenty -nine checks issued to his brother that included payments for supplemental salaries. Respondent was not present at the remaining Board meetings when checks for supplemental salaries were approved for his brother. The parties have stipulated that as a result of Respondent's participation in votes to appoint Shawn McCallister to various supplemental positions within the School District, Shawn McCallister received a total financial gain of $10,313.50. As for Respondent's SFIs, Respondent was required to annually file an SFI in his capacity as a Board Member. No SFI for Respondent for calendar year 2002 was on file with the School District. The Stipulated Fact Findings do not include a Fact Finding as to Respondent's SFI for calendar year 2001. However, as noted below, based upon the Consent Agreement, the parties are in agreement that Respondent failed to file SFIs with the School District for both the 2001 and 2002 calendar years. McCallister, 07 -059 Page 22 Having highlighted the Stipulated Findings and issues before us, we shall now apply the Ethics Act to determine the proper disposition of this case. The parties' Consent Agreement sets forth a proposed resolution of the allegations as follows: 3. The Investigative Division will recommend the following in relation to the above allegations: a. That a violation of Section 1103(a) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1103(a), occurred when McCallister voted to appoint his brother to the following positions: Social Studies Department Head (2003), Girl's Basketball Coach (2003), Intramurals Director (2005 and 2006), Equipment Manager ( 2006), Middle School Academic Challenges (2004); and b. That a violation of Section 1103(a) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1103(a), occurred in relation to McCallister participating in discussions of the Board to make the Athletic Director a permanent full -time position at a time when his brother held the position of temporary full -time Athletic Director (2006); and c. That a technical violation of Section 1103(a) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1103(a), occurred when McCallister voted to approve the Supplemental Position salary paychecks for his brother (2003- 2007); and d. That an unintentional violation of Section 1103(a) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1103(a), occurred when McCallister voted to appoint his brother to the Athletic Director position on the advice of the School Board Solicitor (2005); and e. That no violation of Section 1103(a) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1103(a), occurred when McCallister abstained from voting to appoint his brother into Supplemental Contract Positions on nine (9) different occasions (2002 -2004, and 2006) due to the fact that he abstained; and f. That a technical violation of Section 1104(a) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1104(a), occurred in relation to McCallister's failure to file Statements of Financial Interests for the 2001 and 2002 calendar years. 4. McCallister agrees to make payment in the amount of $10,313.50 in settlement of this matter payable to the Commonwealth of Pennsylvania and forwarded to the Pennsylvania State Ethics Commission within thirty (30) days of the issuance of the final adjudication in this matter. The Investigative Division agrees to accept a payment plan of an initial payment of $5,000.00, eleven (11) McCallister, 07 -059 Page 23 payments of $442.79, and one (1) payment of $442.81. Said payments to begin within thirty (30) days of issuance of the final adjudication in this matter and each month thereafter. If McCallister has not already done so, he agrees to file Statements of Financial Interests for calendar years 2001 and 2002 with the Steel Valley School District with a copy of each forwarded to this Commission. 5. The Investigative Division will recommend that the State Ethics Commission take no further action in this matter; and make no specific recommendations to any law enforcement or other authority to take action in this matter. Such, however, does not prohibit the Commission from initiating appropriate enforcement actions in the event of Respondent's failure to comply with this agreement or the Commission's order or cooperating with any other authority who may so choose to review this matter further. Consent Agreement, at 2 -3. In considering the Consent Agreement, we agree with the parties that a violation of Section 1103(a) of the Ethics Act occurred when Respondent voted to appoint his brother, Shawn McCallister, to the compensated positions of Social Studies Department Head in 2003, Girl's Basketball Coach in 2003, Intramurals Director in 2005 and 2006, Equipment Manager in 2006, and Middle School Academic Challenges Sponsor in 2004. As Respondent's brother, Shawn McCallister is a member of Respondent's immediate family as that term is defined in the Ethics Act. But for the fact that Respondent was a Board Member, he would not have been in a position to vote to appoint his brother to the aforesaid supplemental positions. Per the Stipulated Findings, Respondent knew that he should abstain from voting to appoint his brother to supplemental contract positions. Such uses of authority of office resulted in a private financial gain to Shawn McCallister in the amount of $10,313.50. Accordingly, we hold that a violation of Section 1103(a) of the Ethics Act occurred when Respondent voted to appoint his brother to the positions of Social Studies Department Head in 2003, Girl's Basketball Coach in 2003, Intramurals Director in 2005 and 2006, Equipment Manager in 2006, and Middle School Academic Challenges Sponsor in 2004. Cf., Bayle, Order 1454; Martin, Order 1483. Turning to the second recommendation of the Consent Agreement, we accept the parties' recommendation for a finding that a violation of Section 1103(a) of the Ethics Act occurred when Respondent participated in discussions of the Board to make the temporary full -time AD position a permanent full -time position, at a time when Respondent's brother held the AD position. Respondent used the authority of his public office with respect to the change in status of the AD position. But for the fact that Respondent was a Board Member, he would not have been in a position to participate in the Board discussions at the October 17, 2006, workshop meeting, and to support a proposal to change the status of the AD position to a permanent, full -time position within the Collective Bargaining Agreement. Respondent further used the authority of his office at the October 24, 2006, Board meeting when he made the motion and cast the deciding vote to change the AD position from a temporary position to a permanent, full -time position within the Collective Bargaining Agreement. See, Fact Findings 40 -41 a. The Stipulated Findings do not quantify the private pecuniary benefit resulting to Shawn McCallister from this change. However, it is clear from the totality of the Stipulated Findings and Consent Agreement that the parties are in agreement that Shawn McCallister did receive a private pecuniary benefit as a result of the change in status of the AD position, and that such private pecuniary benefit was not de minimis. Accordingly, we hold that a violation of Section 1103(a) of the Ethics Act occurred in McCallister, 07 -059 Page 24 relation to Respondent participating in discussions /actions of the Board in 2006 to make the AD position a permanent full -time position at a time when his brother held the position of temporary full -time AD. We next consider the parties' recommendation that a technical violation of Section 1103(a) of the Ethics Act occurred when Respondent voted to approve the supplemental position salary paychecks for his brother between 2003 and 2007. We note that a legal issue could have existed as to the scope of the allegation and this particular recommendation. We further note that factually, Respondent's votes to approve supplemental position salary paychecks for his brother occurred between December 2005 and May 2007, and that Respondent did not participate in all such votes during the stated time period. Fact Finding 52. Given: (1) that the parties have entered into a comprehensive Consent Agreement with the benefit of legal counsel to assist them in weighing all relevant factual and legal considerations; and (2) the parties are in agreement that a finding of a violation of Section 1103(a) of the Ethics Act as contemplated by Paragraph 3 c of the Consent Agreement would be appropriate as part of an overall settlement of this case, we shall accept the parties' proposed disposition. We hold that a technical violation of Section 1103(a) of the Ethics Act occurred when Respondent voted to approve supplemental position salary paychecks for his brother between 2003 and 2007. Stoner, Order 1304. Turning to the fourth recommended violation, we agree that an unintentional violation of Section 1103(a) of the Ethics Act occurred when Respondent voted to appoint his brother to the AD position based upon the advice of the School Board Solicitor. Factually, at the May 23, 2005, Board meeting, Respondent used the authority of office when he cast the deciding vote to appoint his brother to the AD position. However, Respondent had initially abstained as to a similar motion that failed for lack of sufficient affirmative votes. Respondent participated in the vote as to the second motion after the Solicitor advised that he could do so in order for the Board to reach a final decision on the issue. The Solicitor's advice was contrary to this Commission's decision in Pavlovic, Opinion 02 -005 (Holding that the conditions of Section 1103(j) of the Ethics Act for voting despite a conflict would not be met when only one member of a five - member board would have a conflict of interest under the Ethics Act). Respondent acted based upon the legal advice that he received from the Solicitor. We therefore hold that an unintentional violation of Section 1103(a) of the Ethics Act occurred when Respondent voted on May 23, 2005, to appoint his brother to the AD position, based upon the advice of the School Board Solicitor. Cf., Kurtz, Order 1252. As for the fifth recommendation of the Consent Agreement, Respondent abstained from voting to appoint his brother to various supplemental contract positions at six Board meetings between September 16, 2002, and December 5, 2006. Fact Finding 48 a. Per Paragraph 3 e of the Consent Agreement, the parties are in agreement that Respondent abstained from voting to appoint his brother to supplemental contract positions on nine different occasions between 2002 and 2004 and in 2006. We therefore accept the parties' recommendation and hold that no violation of Section 1103(a) of the Ethics Act occurred when Respondent abstained from voting to appoint his brother to supplemental contract positions on nine different occasions between 2002 and 2004 and in 2006. Turning to the recommended technical violation of Section 1104(a) of the Ethics Act, Respondent was required to annually file an SFI in his capacity as a Board Member. McCallister, 07 -059 Page 25 Factually, no SFI for Respondent for calendar year 2002 was on file with the School District. The Stipulated Fact Findings do not include a Fact Finding as to Respondent's SFI for calendar year 2001. However, based upon the totality of the Stipulated Findings and Consent Agreement, the parties are in agreement that Respondent failed to file SFIs with the School District for both the 2001 and 2002 calendar years. Accordingly, we hold that a technical violation of Section 1104(a) of the Ethics Act occurred in relation to Respondent's failure to file SFIs for the 2001 and 2002 calendar years. As part of the Consent Agreement, Respondent has agreed to make payment in the amount of $10,313.50 in settlement of this matter as follows: an initial payment of $5,000.00, eleven payments of $442.79, and one payment of $442.81 with said payments to be made payable to the Commonwealth of Pennsylvania and forwarded to this Commission, and with said payments to begin by no later than the thirtieth (30th) day after the mailing date of this adjudication and Order and to be made each month thereafter. Additionally, to the extent he has not already done so, Respondent has agreed to file SFIs for calendar years 2001 and 2002 with the School District with a copy of each such filing forwarded to this Commission. We determine that the Consent Agreement submitted by the parties sets forth the proper disposition for this case, based upon our review as reflected in the above analysis and the totality of the facts and circumstances. Accordingly, per the Consent Agreement of the parties, Respondent McCallister is directed to make payment in the amount of $10,313.50 as follows: an initital payment of $5,000.00, eleven payments of $442.79, and one payment of $442.81, with said payments to be made payable to the Commonwealth of Pennsylvania and forwarded to this Commission, and with said payments to begin by no later than the thirtieth (30th) day after the mailing date of this adjudication and Order and to be made each month thereafter. To the extent he has not already done so, Respondent McCallister is directed to file SFIs for calendar years 2001 and 2002 with the School District by no later than the thirtieth (30 day after the mailing date of this adjudication and Order, and to forward a copy of each such filing to this Commission for compliance verification purposes. Compliance with the foregoing will result in the closing of this case with no further action by this Commission. Noncompliance will result in the institution of an order enforcement action. IV. CONCLUSIONS OF LAW: 1. As a Member of the School Board ( "Board ") of the Steel Valley School District ( "School District ") since December 3, 2001, Respondent Edward McCallister ( "McCallister ") has been a public official subject to the provisions of the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1101 et seq. 2. A violation of Section 1103(a) of the Ethics Act occurred when McCallister voted to appoint his brother to the following positions in the following years: Social Studies Department Head in 2003, Girl's Basketball Coach in 2003, Intramurals Director in 2005 and 2006, Equipment Manager in 2006, and Middle School Academic Challenges Sponsor in 2004. 3. A violation of Section 1103(a) of the Ethics Act occurred in relation to McCallister participating in discussions /actions of the Board in 2006 to make the Athletic /Activities Director ( "AD ") position a permanent full -time position at a time McCallister, 07 -059 Page 26 when his brother held the position of temporary full -time AD. 4. A technical violation of Section 1103(a) of the Ethics Act occurred when McCallister voted to approve supplemental position salary paychecks for his brother between 2003 and 2007. 5. An unintentional violation of Section 1103(a) of the Ethics Act occurred when McCallister voted on May 23, 2005, to appoint his brother to the AD position, based upon the advice of the School Board Solicitor. 6. No violation of Section 1103(a) of the Ethics Act occurred when McCallister abstained from voting to appoint his brother to supplemental contract positions on nine different occasions between 2002 and 2004 and in 2006. 7 A technical violation of Section 1104(a) of the Ethics Act occurred in relation to McCallister's failure to file Statements of Financial Interests for the 2001 and 2002 calendar years. In Re: Edward McCallister, Respondent ORDER NO. 1501 File Docket: 07 -059 Date Decided: 12/4/08 Date Mailed: 12/19/08 1 Edward McCallister ( "McCallister "), a public official in his capacity as a Member of the School Board ( "Board ") of the Steel Valley School District ( "School District ") since December 3, 2001, violated Section 1103(a) of the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1103(a), when he voted to appoint his brother to the following positions in the following years: Social Studies Department Head in 2003, Girl's Basketball Coach in 2003, Intramurals Director in 2005 and 2006, Equipment Manager in 2006, and Middle School Academic Challenges Sponsor in 2004. 2. A violation of Section 1103(a) of the Ethics Act occurred in relation to McCallister participating in discussions /actions of the Board in 2006 to make the Athletic /Activities Director ( "AD ") position a permanent full -time position at a time when his brother held the position of temporary full -time AD. 3. A technical violation of Section 1103(a) of the Ethics Act occurred when McCallister voted to approve supplemental position salary paychecks for his brother between 2003 and 2007. 4. An unintentional violation of Section 1103(a) of the Ethics Act occurred when McCallister voted on May 23, 2005, to appoint his brother to the AD position, based upon the advice of the School Board Solicitor. 5. No violation of Section 1103(a) of the Ethics Act occurred when McCallister abstained from voting to appoint his brother to supplemental contract positions on nine different occasions between 2002 and 2004 and in 2006. 6. A technical violation of Section 1104(a) of the Ethics Act occurred in relation to McCallister's failure to file Statements of Financial Interests ( "SFIs ") for the 2001 and 2002 calendar years. 7 Per the Consent Agreement of the parties, McCallister is directed to make payment in the amount of $10,313.50 as follows: an initial payment of $5,000.00, eleven payments of $442.79, and one payment of $442.81, with said payments to be made payable to the Commonwealth of Pennsylvania and forwarded to this Commission, and with said payments to begin by no later than the thirtieth (30 day after the mailing date of this Order and to be made each month thereafter. 8. To the extent McCallister has not already done so, McCallister is directed to file SFIs for calendar years 2001 and 2002 with the School District by no later than the thirtieth (30 day after the mailing date of this Order, and to forward a copy of each such filing to this Commission for compliance verification purposes. McCallister, 07 -059 Page 28 9. Compliance with Paragraphs 7 and 8 of this Order will result in the closing of this case with no further action by this Commission. a. Non - compliance will result in the institution of an order enforcement action. BY THE COMMISSION, Louis W. Fryman, Chair