HomeMy WebLinkAbout89-529 ElliottSTATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
April 18, 1989
Diane V. Elliott, Esquire 89-529
561 East Market Street
P.O. Box 1306
Bethlehem, PA 18018
Re: Simultaneous Service, First Class Township Civil Service
Commissioner and Democratic Committeewoman
Dear Ms. Elliott:
This responds to your letter of March 14, 1989, in which you
requested advice from the State Ethics Commission.
Issue: Whether the State Ethics Act imposes any prohibition or
restriction upon a first class township civil service
commissioner from also serving or being employed as a political
committee person.
Facts: You advise that you have recently been appointed to fill
a vacancy as the Democratic committeewomen for the First Ward in
Bethlehem Township, Northampton County, and were subsequently to
appointed to fill a vacancy on the Bethlehem Township Civil
Service Commission. You then quote a portion of the First Class
Township Code, §627 which states, in part:
"No (civil service) commissioner shall at the same time
hold an elective or appointed office under the United
States government, the commonwealth of Pennsylvania, or
any political subdivision of the Commonwealth..."
After expressing your belief that the position of Democratic
committeewoman does not fall within any of the categories as set
forth in Section 627 of the First Class Township Code, you
conclude by requesting an opinion as to whether your position as
Democratic committeewoman would be prohibited by the First Class
Township Code.
Diane V. Elliott, Esquire
April 17, 1989
Page 2
Discussion: It is assumed for purposes of this advice that you
as a First Class Township Civil Service Commissioner are a
"public official" under the Ethics Act and the regulations of
this Commission. 65 P.S. 5402; 51 Pa. Code 51.1.
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. 5403(a).
Under Section 3(a) quoted above, the State Ethics Commission
has determined that use of office by a public official /employee
to obtain a financial gain for himself or a member of his
immediate family or a business with which he is associated which
is not provided for in law transgresses the above provision of
law. Thus, use of office by a public official /employee to obtain
a financial gain which is not authorized as part of his
compensation is prohibited by Section 3(a): Hoak /McCutcheon,
Orders No. 128, 129, affirmed McCutcheon v. State Ethics
Commission, 77 Pa. Commw. Ct. 529, 466 A.2d 283 (1983); Yacobet,
Order No. 412 -R, affirmed Yacobet v. State Ethics Commission, 109
Pa. Commw. Ct. 432, 531 A.2d 536 (1987). Similarly, Section 3(a)
of the Ethics Act would prohibit a public official /employee from
using public office to advance his own interests; Koslow, Order
458 -R, affirmed Koslow v. State Ethics Commission, Pa. Commw.
Ct. , 540 A.2d 1374 (1988). Likewise, a public
official /employee may not use the status or position of public
office for his own personal advantage; Huff, Opinion 84 -015.
However, as outlined above, there does not appear to be a
real possibility of any financial gain or inherent conflict
arising if you were to serve both as a public official /employee
and as a political committeeperson. Basically, the Ethics Act
does not state that it is inherently incompatible for a public
official /employee to serve or be employed as a political
committeeperson. The main prohibition under the Ethics Act and
Opinions of the Ethics Commission is that one may not serve the
interests of two persons, groups, or entities whose interests may
be adverse. See Alfano Opinion, 80 -007. In the situation
outlined above, you as a public official would not be serving
entities with interests which are adverse to each other.
Diane V. Elliott, Esquire
April 17, 1989
Page 3
Section 3(b) of the Ethics Act provides:
(b) No person shall offer or give to a public
official or public employee or candidate for
public office or a member of his immediate
family or a business with which he is
associated, and no public official or public
employee or candidate for public office shall
solicit or accept, anything of value,
including a gift, loan, political
contribution, reward, or promise of future
employment based on any understanding that
the vote, official action, or judgment of the
public employee or candidate for public
office would be influenced thereby. 65 P.S.
403(b).
Under Section 3(b) of the Ethics Act cited above, which must
be observed, a public official must neither offer nor accept
anything of value on the understanding or with the intention that
the public official's judgment would be influenced thereby. It
is assumed such a situation does not exist here. Reference to
this Section is added not to indicate that any such activity has
been or will be undertaken but in an effort to provide a complete
response to your inquiry.
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).
However, under Section 3(d) of the State Ethics Act, the
State Ethics Commission may address other areas of possible
conflict of interest. 65 P.S. §403(d). The parameters of the
types of activities encompassed by this provision of law may
generally be determined by reviewing the purpose and intent of
the Ethics Act. The Ethics Act was promulgated in order to
ensure that the financial interests of public officials do not
conflict with the public trust or create the appearance of a
conflict with the public trust.
Although you have requested an opinion as to whether your
retaining your position as Democratic committeewoman in
Bethlehem Township is prohibited by Section 627 of the First
Township Code, that question may not be addressed in this advice
since the scope of this advisory opinion only relates to the
propriety of your conduct under the Ethics Act. Additionally,
the question of the propriety of serving as a civil s < ?rvice
Diane V. Elliott, Esquire
April 17, 1989
Page 4
commissioner, traditionally a non political position, and also
holding a political committeeperson position has similarly not
been treated outside of the confines of the Ethics Act. Thus,
the propriety of your proposed conduct has only been addressed
under the Ethics Act; the applicability of any other statute,
code, ordinance, regulation or other code of conduct has not been
addressed in this advice.
Conclusion: Assuming a First Class Township Civil Service
Commissioner is a "public official" under the Ethics Act, then
Section 3(e) of the Ethics Act would not restrict you from
simultaneously serving in the positions of First Class Township
Civil Service Commissioner and Democratic Committeewoman.
Lastly, the propriety of the proposed course of conduct has only
been addressed under the Ethics Act.
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
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 S2.12.
such.
Sincerely,
y ' 1 RIB,, �� �� ✓�
Vincent J. Dopko,
General Counsel