HomeMy WebLinkAbout88-515 CoulterJames P. Coulter, Esquire
128 West Diamond Street
Butter, PA 16001
Dear Mr. Coulter:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PA 17120
TELEPHONE: 1717) 783 -1610
February 24, 1988
ADVICE OF COUNSEL
88 -515
Re: Conflict of Interest, County Commissioner, Son Contracting with County
Nursing Home
This responds to your letter of January 19, 1988, in which you requested
advice from the State Ethics Commission.
Issue: Whether the State Ethics Act imposes any prohibition or restriction
upon a county commissioner whose son operates a business which sells meat to
a county nursing home.
Facts: You state that you represent Robert J. Thompson who is a newly elected
county commissioner in Butler County, Pennsylvania, and who is the former
owner of a business known as "Thompson's Market" until said business was sold
to Mr. Thompson's son at an arm's length sale approximately three or four
years ago. You further state that Mr. Thompson's son, who is neither a minor
nor dependent, continues to operate the business which has been selling meat
to the Sunnyview Home, a nursing home that is operated by Butler County. You
further state that Commissioner Thompson has no interest in his son's business
either as an owner, shareholder, officer or director or otherwise. You
conclude by requesting advice as to whether it would be appropriate under the
Ethics Act for Commissioner Thompson to vote to approve a contract for the
purchase of meat by the Sunnyview Home from Thompson's Market which is now
owned and operated by his son.
Discussion: As a county commissioner for Butler County, Robert J. Thompson is
a "public official" as that term is defined in the Ethics Act. 65 P.S. §402;
51 Pa. Code §1.1. As such, his conduct is subject to the provisions of the
Ethics Act and the restrictions therein are applicable to him.
Section 3(a) of the Ethics Act provides:
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, p
member of his immediate family, or a business witn which
he is associated. 65 P.S. 403(a).
James P. Coulter, Esquire
February 24, 1988
Page 2
Section 3(a) basically provides that a public official may not use his
public office or confidential information to obtain a financial gain other
than compensation as provided for by law for himself or a member of his
immediate family. Under this provision, the Ethics Commission has determined
that the use of office by a public official to obtain a gain or benefit for
himself or a member of his immediate family which is not provided for in law
constitutes a "financial gain other than compensation provided for by law."
These determinations have been appealed to the Commonwealth Court of
Pennsylvania which has affirmed the Orders of the Commission. See McCutcheon
v. State Ethics Commission, 77 Pa. Commw. 529 (1983). See also Yocabet v.
State Ethics Commission, Pa. Comm. , 531 A.2d 536 (1987). Of course,
under this provision, a public official may not use his public position to
secure any financial gain for himself or his immediate family unless it is
provided for by law. Domalakes, 85 -010.
The term "immediate family" is defined under the State Ethics Act as
follows:
Section 2. Definitions.
"Immediate family." A spouse residing in the person's
household and minor dependent children. 65 P.S. 402.
Since Commissioner Thompson's son is both of majority and is not a
dependent, his son is not a member of Commissioner Thompson's "immediate
family" as that term is defined under the State Ethics Act. Thus, since
Commissioner Thompson's son is not a member of his immediate family, Section
3(a) of the Ethics Act would not prohibit him from voting to approve a
contract for the purchase of meat for the county nursing home from his son's
business.
Section 2. Definitions.
"Business with which he is associated." Any business in
which the person or a member of the person's immediate
family is a director, officer, owner, employee or holder
of stock. 65 P.S. 402.
Since Commissioner Thompson has no interest in his son's business, as
either an owner, shareholder or officer, the above definition would not be
implicated.
Section 3(d) of the Ethics Act provide:
Section 3. Restricted activities.
(d) Other areas of possible conflict shall be addressed by
the commission pursuant to paragraph (9) of section 7.
65 P.S. 403(d).
James P. Coulter, Esquire
February 24, 1988
Page 3
The parameters of the activities encompassed by the above provision of
the law generally are determined through the review and intent and purpose of
the Ethics Act. The Ethics Act was promulgated in order to insure the public
that the financial interest of their officials do not conflict with the public
trust and do not create a conflict of interest or the appearance of a
conflict.
In relation to the above cited sections of law, the Commission has
determined that the definitional limitations applicable to these Sections of
the Act are not relevant to questions addressed under Section 3(d). Leete
Opinion, 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
Opi nion, 83 -012.
Thus, for example, the Commission has determined that a public official
may not participate in the employment selection process where the official's
adult son is an applicant. See O'Reilly Opinion, 83 -012.
Likewise, in Leete Opinion, 82 -005, the Commission concluded that a
county commissioner could not sit on a salary board and vote the salary of
her brother as Director of the county planning agency without engaging in
conduct which would appear to conflict with the public trust. See also Lewis
Advice, 85 -558; Ceraso Advice, 85 -575.
Thus, although there is no prohibiton under Section 3(a) of the Ethics
Act for Commissioner Thompson voting to approve this contract for his son's
business, he must abstain under Section 3(d) so that there is not an
appearance of a conflict of interests.
Lastly, the propriety of the proposed conduct has only been addressed
under the Ethics Act; the applicability of any other statute, code,
regulation, or ordinance or other code of conduct has not been considered.
Specifically not addressed in this advice is the applicability of the County
Code.
Conclusion: As a County Commissioner for Butler County, Robert J. Thompson is
a public official subject to the provisions of the Ethics Act. Although
Section 3(a) of the Ethics Act would not prohibit Commissioner Thompson from
voting to approve a contract for the purchase of meat for a county nursing
home from a business which is wholly owned and operated by his son, under
Section 3(d) of the Ethics Act, he must abstain from voting so that there is
not an appearance of a conflict. Lastly, the propriety of the proposed
conduct has only been addressed under the Ethics Act.
James P. Coulter, Esquire
February 24, 1988
Page 4
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 w i l l 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 cerely,
V� ncent Dopko
General Counsel