HomeMy WebLinkAbout85-570A&B MackoMichael J. Macko, Esquire
Memorial Boulevard & 8th Avenue
Connellsville, PA 15425
Mailing Address
State Ethics Commission
308 Finance Building
P. 0. Box 11 470
Harrisburg, Pa. 17108 -1470
August 8, 1985
ADVICE OF COUNSEL
Re: Grant Program Participation; Relatives of Borough Officials
Dear Mr. Macko:
85 - 570 - A
This advice responds in part, to your letter of July 19, 1985, wherein
you requested the advice of the State Ethics Commission. I note that the
question presented was in reference to eighteen different individuals. In
order to expedite your request, two separate advices will be issued. The
first advice will concern potential participants who are not public employees
or borough officials.
Issue: Whether relatives of borough officials may participate in a
Rehabilitation Grant Program.
Facts: As solicitor for the Borough of Vanderbilt, Fayette County,
Pennsylvania, you have asked whether certain individuals may participate in a
Grant Rehabilitation Program.
The program involved in this matter is a $750,000 Small Communities
Program Grant which the borough received through the Department of Community
Affairs. Gaydos Chambers Associates, a development consultant firm, was
employed by the borough to administer this program.
The procedures for the implementation of this program are as follows:
Program Activity
Preparation of grant pre - application
and final application procure SCP
funds.
Preparation of Program Guidelines
Approval of Program Guidelines
Responsible Entity
Gaydos Chambers Associates
Gaydos Chambers Associates
Vanderbilt Borough Council
State Ethics Commission • 308 Finance Building • Harrisburg, Pennsylvania
Michael J. Macko, Esq.
August 8, 1985
Page 2
Preparation of Program Forms
Acceptance of Applicant Intake forms
and Verification of Income Eligibility
Establishment of Income Figures
for Program Participation
Prioritization of Applicants for
Assistance through the program
Implementation of inspection bidding
and contracting procedures for the
homeowners participating in the program
NAME
John Addi s
Dale Addis
Beverly Stevenson
Lance Winterhalter
Ronald Addis
Ellen Addis
Ronald Addis, Jr.
Gaydos Chambers Associates
Gaydos Chambers Associates
Department of Housing and
Urban Development (section 8
Program)
Gaydos Chambers Associates
Gaydos Chambers Associates
In addition to the above, Gaydos Chambers Associates prepares and
forwards cost of payment forms to DCA in order to obtain the allocated funds.
The funds are then forwarded to the borough for distribution. The funds are
distributed by the borough treasurer and this distribution requires the
signature of one of the borough councilmen. The borough treasurer is paid a
fee by Gaydos Chambers Associates for the distribution of these funds.
Information has also been received that the income guidelines are set by HUD
under Section 8 program and any person providing documentation that their
income meets these income guidelines is considered eligible for aid. The
income verification and intake process is conducted by Gaydos Chambers
Associates. Gaydos Chambers has indicated that there is enough money in the
program budget to do every income eligible person in Vanderbilt so that the
inclusion of the mayor, council, appointed persons, and their respective
relatives will not preclude other residents from receiving SCP aid. A rating
system developed by Gaydos Chambers Associates is in use to prioritize the
persons assisted by the program.
You asked whether the following individuals may participate in the
program:
RELATIONSHIP TO BOROUGH OFFICIAL
Son of Mayor
Son of Mayor
Daughter of Councilman Isaac Lockette
Elected School Board Member representing
the Connellsville Area School District
and brother -in -law of Councilman
Jack Washabaugh
Brother of Mayor
Mother of Mayor
Nephew of Mayor
Michael J. Macko, Esq.
August 8, 1985
Page 3
Pat Orlando
Arthur Cumberland
Mossie Evans
Earl Dowden
Dale Arison
Uncle of the President of Borough Council
Brother -in -law of the Appointed Borough
Treasurer
Sister of Councilman's wife's grandfather
Grandfather of husband of appointed
Borough Secretary
Cousin of Councilman's wife
You have expressed your concern that the borough wishes to avoid even
the appearance of a conflict of interest in this matter.
Discussion: Initially, we should note that under the Ethics Act our
jurisdiction is limited to rulings under the Ethics Act. Thus, we cannot and
do not, in this Advice, address the propriety of or answer any questions
related to the propriety of your conduct in light of any other code, statute
(federal or state), or regulation.
Generally, the Ethics Commission in the past, has issued a number of
opinions and advices regarding a public official's participation in grant
programs. See, Toohey, 83 -003; Balaban, 85 -004; Coploff, 83 -005. These
opinions set forth the guidelines applicable in such a situation.
With regard to this matter, we note that none of the individuals
specified in this advice are borough officials. Therefore, the opinions cited
above would not be applicable to these individuals.
Additionally, as these individuals are not public officials or public
employees they are not generally within the jurisdiction of the Ethics
Commission and the Commission may not prohibit them from participating in the
program.
The Commission, however, does have jurisdiction over the public officials
of the borough who are related to these individuals. As such, these officials
should be aware of portions of the Ethics Act that are applicable to them.
The Ethics Act provices that:
Section 3. Restricted activities.
(a) No public official or public employee shall use his
public office or any confidential information received
through his holding public office to obtain financial gain
other than compensation provided by law for himself, a
member of his immediate family, or a business with which
he is associated. 65 P.S. 403(a).
Michael J. Macko, Esq.
August 8, 1985
Page 4
Additionally, the Act defines member of ones immediate family as
follows:
Section 2. Definitions.
"Immediate family." A spouse residing in the person's
household and minor dependent children. 65 P.S. 402.
The Ethics Commission, is also empowered to address other areas of
possible conflict pursuant to Section 3(d). 65 P.S. §403(d). Fritzinger,
80 -008; Yaw, 85 -011. The parameters of the type of activity encompassed by
this provision are generally reviewed in light of the preamble to the Ethics
Act which enunciates the legislative intent of the Act. A public official or
employee, pursuant to this provision, is to ensure that their personal
financial interests present neither a conflict nor the appearance of a
conflict with the public trust. 65 P.S. §401. Such a conflict may exist
where an individual represents one or more adverse interests, Alfano, 80 -007.
Nelson, 85 -009, or where such an official or employee accepts compensation to
which he is not entitled. Domalakes, 85 -010.
In situations such as the one presented herein, the Commission has
determined that the definitional limitations applicable to Section 3(a) of the
Act are not relevant to questions addressed under the above provision. Leete,
82 -005. As such, the Commission has placed restrictions upon various actions
of public officials and employees when acting upon matters that involve
relatives outside of the previously cited definition. O'Reilly, 83 -012;
Lewis, 85 -558.
Thus, while the individuals identified herein may participate in the
program, the borough officials should not participate to any extent in the
application process, or granting of funds to their respective relatives.
Additionally, all of the records and information pertaining to this process
should be open for public inspection.
We note that with repsect to three of the previously specified
individuals, we do not believe that any of the above restrictions apply.
Specifically, the relationships between the borough officials and Mossie
Evans, Earl Dowden and Dale Arison are so remote so as not to warrant these
restrictions.
Also, we note that Arthur Cumberland is the brother -in -law of David Brady
the borough treasurer. As noted previously, the treasurer receives a fee for
his role in the administering of the program. We believe that an appearance
of a conflict exists if the treasurer were to receive a fee in relation to
processing Mr. Cumberland's funds. Thus, unless the treasurer foregoes this
fee and otherwise abstains from participating in this particular application a _
violation of the Ethics Act may occur.
Michael J. Macko, Esq.
August 8, 1985
Page 5
Additionally, it is noted that under certain circumstances where a
relative of a public official or employee participates in a grant program for
which the officer has official responsibilities, the Commission has ruled that
the official may have to abstain from decisions regarding others who were also
applying for the same funds.
Generally, this determination was made where there were limited funds
available for distribution and where only a few of the many applicants would
be securing approval. The Commissions ruling was grounded upon the concept
that an official under such circumstances could effectively deny all
applications, other than the one in which he is interested, thereby insuring
the availability of funds for the project in which he was interested.
Coploff, 83 -005. We reference to this situation not to imply any improper
motivation but merely to supply a complete response to your question. We will
assume that this particular situation does not exist in relation to your
request.
Conclusion: There is no prohibition under the Ethics Act, upon the
individuals specified herein participating in the Grant Rehabilitation
Program. The borough officials must conform to the requirements of the Ethics
Act as set forth.
Pursuant to Section 7(9)(ii), this Advice is a complete defense in any
enforcement proceeding initiated by the Commission, and evidence of good faith
conduct in any other civil or criminal proceeding, providing the requestor has
disclosed truthfully all the material facts and committed the acts complained
of in reliance on the Advice given.
This letter is a public record and will be made available as such.
Finally, if you disagree with this Advice or if you have any reason to
challenge same, you may request that the full Commission review this Advice. A
personal appearance before the Commission will be scheduled and a formal
Opinion from the Commission will be issued. Any such appeal must be made, in
writing, to the Commission within 15 days of service of this Advice pursuant
to 51 Pa. Code 2.12.
JJC /sfb
John J.
Gener Counsel
Michael J. Macko, Esquire
Memorial Boulevard & 8th Avenue
Connellsville, PA 15425
Dear Mr. Macko:
Madhng Address
State Ethics Commission
308 Finance Building
P. O. Box 1 1470
Harrisburg, Pa. 17108 -1470
August 22, 1985
ADVICE OF COUNSEL
85 -570 -B
Re: Grant Program Participation, Borough Officials and Employees
This completes our response to your letter of July 19, 1985, wherein you
requested the advice of the State Ethics Commission. As you are aware, Advice
No. 85 -570 -A was issued on August 8, 1985, in partial response to your
question.
Issue: Whether certain borough officials may participate in a Rehabilitation
Grant Program.
Facts: Although we have previously outlined the facts of this matter in our
prior advice, we will once again set forth the relevant considerations
involved herein.
As solicitor for the Borough of Vanderbilt, Fayette County, Pennsylvania,
you have asked whether certain individuals may participate in a Grant
Rehabilitation Program.
The program involved in this matter is a $750,000 Small Communities
Program Grant which the borough received through the Department of Community
Affairs. Gaydos Chambers Associates, a development consultant firm, was
employed by the borough to administer this program.
The procedures for the implementation of this program are as follows:
Program Activity
Preparation of grant pre - application
and final application procure SCP
funds.
Responsible Entity
Gaydos Chambers Associates
State Ethics Commission • 308 Finance Building • Harrisburg, Pennsylvania
Michael J. Macko, Esq.
August 22, 1985
Page 2
Preparation of Program Guidelines
Approval of Program Guidelines
Preparation of Program Forms
Acceptance of Applicant Intake forms
and Verification of Income Eligibility
Establishment of Income Figures
for Program Participation
Prioritization of Applicants for
Assistance through the program
Implementation of inspection bidding
and contracting procedures for the
homeowners participating in the program
Gaydos Chambers Associates
Vanderbilt Borough Council
Gaydos Chambers Associates
Gaydos Chambers Associates
Department of Housing and
Urban Development (section 8
Program)
Gaydos Chambers Associates
Gaydos Chambers Associates
In addition to the above, Gaydos Chambers Associates prepares and
forwards cost of payment forms to DCA in order to obtain the allocated funds.
The funds are then forwarded to the borough for distribution. The funds are
distributed by the borough treasurer and this distribution requires the
signature of one of the borough councilmen. The borough treasurer is paid a
fee by Gaydos Chambers Associates for the distribution of these funds.
Information has also been received that the income guidelines are set by HUD
under Section 8 program and any person providing documentation that their
income meets these income guidelines is considered eligible for aid. The
income verification and intake process is conducted by Gaydos Chambers
Associates. Gaydos Chambers has indicated that there is enough money in the
program budget to do every income eligible person in Vanderbilt so that the
inclusion of the mayor, council members, appointed officers, and their
respective relatives will not preclude other residents from receiving SCP aid.
A rating system developed by Gaydos Chambers Associates is in use to
prioritize the persons assisted by the program.
In addition to the foregoing, we have reviewed the guidelines that have
been established and approved by the council in relation to this program. We
note that these guidelines contain the following items:
1. The borough council is responsible for developing a list of approved
contractors to perform the necessary work.
2. The borough council must approve any deviations in the types of
materials used.
Michael J. Macko, Esq.
August 22, 1985
Page 3
3. Specific standards for all materials used will he developed by the
borough.
4. The borough is responsible for the ultimate approval of the
assistance.
You have asked whether the following borough officials and employees may
participate in this program.
NAME
Martin Riggin
Jack Washabaugh
Ike Lockette
David Brady
Loretta Winterhalter
Ruth Ann Thomas
We note that we have also learned that Ms. Thomas is an employee of Gaydos
Chambers Associates. Once again, we note your concern that the borough
wishes to avoid even the appearance of a conflict of interest.
Discussion: Initially, we should note that under the Ethics Act our
jurisdiction is limited to rulings under the Ethics Act. Thus, we cannot and
do not in this Advice, address the propriety of or answer any questions
related to the propriety of the questioned conduct in light of any code,
statute (federal or state), regulations, etc. other than the Ethics Act.
The individuals involved herein are public officials or public employees
as these terms are defined in the State Ethics Act. 65 P.S. §401, et. seq.
Their conduct, therefore, must conform to the requirements thereof. Kilmer,
79 -037; Keith, No. 11.
The Ethics Act provides that:
POSITION
Councilman
Councilman
Councilman
Borough Treasurer
Borough Tax Collector; Mother -in -law of
Councilman
Borough Secretary; neice of Councilman
Section 3. Restricted activities.
(a) No public official or public employee shall use his
public office or any confidential information received
through his holding public office to obtain financial gain
other than compensation provided by law for himself, a
member of his immediate family, or a business with which
he is associated. 65 P.S. 403(a).
Michael J. Macko, Esq.
August 22, 1985
Page 4
Within this provision of law the Commission has on a number of occasions
reviewed the propriety of a public official participating in grant programs.
Toohey, 83 -003; Balaban, 83 -004; Coploff, 83 -005.
In these cases the Ethics Commission has indicated that a public official
or public employee or a business with which he is associated could participate
in rehabilitation or grant programs so long as that public official or public
employee:
1. played no role in establishing the criteria under which the program
at issue was to operate, particularly with reference to the structure
or administration of the program;
2. played no role in establishing or implementing the criteria by which
selections for program participation are to be or were made;
3. played no role in the process of selecting and reviewing applicants
or in awarding grants or funds;
4. used no confidential information acquired during the holding of
public office or public employment to apply for or to obtain such
funds, grants, etc.
Furthermore, the Commission's opinions indicate that if the body with
which the public employee or official is associated is in any way involved in
the administering of the grant program or selecting who, among the applicants
should receive assistance or funds, the public employee or official within the
governmental body who is making an application to participate in such a
program or to obtain such funds, must abstain from all discussions, votes or
recommendations on the applications or programs in which he or she is
interested. Additionally, such a public official or public employee should
also abstain from participating in matters before that governmental body which
he or she serves as to the applications of other individuals who may be
similarly situated and who are applying for funds or seeking to participate in
the program.
Essentially, the Commission sought to eliminate the possibility that a
public official or public employee who was seeking such funds or seeking to
participate in these grant programs would be in a position to insure the grant
funds or the program benefits would be available for his own benefit. Thus,
the Commission determined that a public official or public employee in such a
situation should refrain from participating in making decisions or
recommendations about the program and regarding distribution of the limited
funds which might be available as a result of such a program. The reason for
such abstentions must be placed on the public record.
Michael J. Macko, Esq.
August 22, 1985
Page 5
In addition to the previously cited sections, the Ethics Act further
provides that the Commission may address other areas of possible conflict.
F ri tzi nge r, 80 -008; Yaw, 85 -011. The parameters of the type of activities
encompassed by this provision are generally reviewed in light of the preamble
to the Act which enunciates the legislative intent of the Act. A public
official or employee, pursuant to this provision, is to ensure that their
personal financial interests present neither a conflict nor the appearance of
a conflict with the public trust. 65 P.S. §401.
Thus, we must now review the instant situation in light of the foregoing
principles in order to answer the question presented.
The members of the borough council have been, from the beginning of this
program, involved in implementing the procedures to be employed. The council
hired the Gaydos Chambers firm to administer the program. That firm is
ultimately responsible to the council. The guidelines for the program
specifically set forth that they "were formultated by the Vanderbilt Borough
Council... in an effort to develop an equitable framework for the
implementation of the borough's Small Communities Program... ". The Council
maintains ultimate approval on applications for assistance and also maintains
authority over various aspects of the program.
These factors, in light of the previously mentioned standards, lead us to
conclude that the members of the borough council may not, within the framework
of the Ethics Act, participate in the program. They have played a role in
establishing the program guidelines; they hired the administrator of the
program, they have played a role in establishing and implementing the criteria
by which program selection are made and they will plan a role in the process
of reviewing and approving applicants. While we understand that the
administrative firm also played a major role in this process, this firm was
hired by the borough council and is ultimately responsible to that body.
Those members of the council who had reason to believe that they would
participate in the program would have had to abide by the aforementioned
standards in order to fall within our previous opinions.
The members of the council were responsible for and established this
program as public officials for the citizens of the borough. For these
officials to now participate in a program for which they are ultimately
responsible and which they have already established would run against the
intent and spirit of the law.
We must now turn to the remaining officials involved herein. With
relation to the borough tax collector, we see no reason why this official may
not participate in the program. This person apparently played no role in the
implementation of this program and appears to fall within the established
criteria. We do note that this official is also a relative of a member of
7.
Michael J. Macko, Esq.
August 22, 1985
Page 6
council. That member of council, pursuant to our prior advice, should abstain
from all participation in relation to any application presented by this
person.
A more difficult situation arises in relation to the two remaining
individuals.
The borough treasurer has not played any role in establishing this
program. The only role played by this person is that he disburses the funds
after approval. This appears to be a non - discretionary function and under
normal circumstances there would he no prohibition on this person
participating in the program. The treasurer, however, collects a fee from
Gaydos Chambers for this function. While we do not address under what
authority this official is receiving this financial gain, we do believe that
an appearance of a conflict could arise. The treasurer, an official of the
borough, is being paid by a private entity to disburse funds for a public
purpose. He has, thus, to some extent became associated with the firm that
has helped established and that administers the program. For this person to
participate in the program under these circumstances would create the type of
appearance that you indicate you wish to avoid.
We note that this official is obtaining financial gain other than his
compensation provided by law to carry out his official functions. Serious
public perceptions may develop from this situation. We do not address the
propriety of this receipt of financial gain and note that this advice does not
purport to authorize such situation.
Under these circumstances, we do not believe that this official may
participate in the program as long as this relationship exists. Were this
relationship not in existence, then we would not see any prohibition upon this
persons participation in the program.
We now turn to the final person involved herein. This person is the
borough secretary and is also an employee of Gaydos Chambers Associates. This
person, as a public employee, has access to information and personnel in the
governmental process. In addition, this person is employed by the company
that has a contract with the borough. This company and the borough are
responsible for administering the program and for evaluating and approving all
applicants. As an employee of both the borough and the firm the person
naturally has access not only to information regarding her own application but
to many others seeking funds. While we are not implying any wrongdoing by
this person, once again certain appearances are raised by this situation.
Michael J. Macko, Esq.
August 22, 1985
Page 7
In order to resolve this difficult situation, we believe that this
person, if she abstains from dealing with any Small Communities Program
applications in both her public and private positions, may participate in the
program. Once again we note that the councilman who is the uncle of this
person may not participate in any action relating to an application in which
she has an interest.
In relation to all of the officials who may participate in the program,
we reiterate that all applications, abstentions and records regarding these
individuals must meet with the open and public process requirements of our
prior advice.
Conclusion: The individuals involved herein are public officials and public
employees as defined in the State Ethics Act and, as such, they must comply
with the requirements of the Act as set forth in this Advice.
Pursuant to Section 7(9)(ii), this Advice is a complete defense in any
enforcement proceeding initiated by the Commission, and evidence of good faith
conduct in any other civil or criminal proceeding, providing the requestor has
disclosed truthfully all the material, facts and committed the acts complained
of in reliance on the Advice given.
JJC /sfb
This letter is a public record and will be made available as such.
Finally, if you disagree with this Advice or if you have any reason to
challenge same, you may request that the full Commission review this Advice. A
personal appearance before the Commission will be scheduled and a formal
Opinion from the Commission will be issued. Any such appeal must be made, in
writing, to the Commission within 15 days of service of this Advice pursuant
to 51 Pa. Code 2.12.
Si nc rely
John J ontino
General Counsel
GIL