HomeMy WebLinkAbout84-506 FisherDaniel Fisher
Box 70, RD #3
Bellefonte, PA 16823
STATE ETHICS COMMISSION
P.O. BOX 1179
HARRISBURG, PA 17108
TELEPHONE: (717) 783 -1610
Ma.hng Address.
January 17, 1984
ADVICE OF COUNSEL
RE: Boggs Township, Auditor, Former Supervisor
Dear Mr. Fisher:
84 -506
This responds to the letter of Solicitor David A. Flood and your
communication with our office of January 5, 1984, in which you requested
advice from the State Ethics Commission.
Issue: You ask whether there are restrictions on your conduct as a newly
elected auditor and a former supervisor in the Township of Boggs, hereinafter
the Township.
Facts: Originally, Mr. Flood had written to us as Solicitor of the Township
and posed the question outlined above. He provided us with certain facts,
which you, in your telephone communication with us of January 5, 1984,
indicate should be adopted by us in a direct response to your authorization to
render advice to you about your conduct.
The facts as presented indicate that you had served as a Township
Supervisor until the expiration of your term on December 31, 1983. You have
also been elected as a Township Auditor to begin a term in 1984. The Township
Auditors have certain designated duties including auditing, settling, and
adjusting the accounts of the Supervisors, superintendents, roadmasters, the
treasurer, and tax collector of the Township. The Auditors, must also audit
the dockets, transcripts, and other official records of the Justice of the
Peace to determine the amount of fines and costs paid over or due to the
Township. Finally, the Auditors must also fix compensation for the
Supervisors serving as roadworkers and appointed as workers or roadmasters
under the provisions of the Second -Class Township Code, 53 P.S. 65545.
It should also he noted that you did not serve as a roadmaster,
superintendent, treasurer, or tax collector while serving in the office of
Township Supervisor, although, as a newly elected Auditor, it would seem that
you would hav? a legal obligation to audit these accounts according to the
information provided by Solicitor Flood.
State Ethics Commission • 308 FinancF Building • Harrisburg, Penncylv.3nik.
Daniel Fisher
January 17, 1984
Page 2
Discussion: As an elected Auditor within the Township you are a "public
official" as that term is defined in the State Ethics Act. See 65 P.S. 402.
As a "public official" your conduct must conform to the requirements of the
State Ethics Act.
The opinions of the State Ethics Commission clearly indicate that as a
general matter, a public official may not review, inspect, or approve his own
work especially where that inspection, review, or approval is beneficial to
the individual public official. See, for example, Simmons, 79 -056, where the
Commission held that a zoning officer, who also was a developer within the
Township, could not issue building permits to himself or his family or a
business with which he is associated; Sowers, 80 -050, where the Commission•
held that a developer who was also a Township Supervisor could not perform
inspections of his own work; Restivo, 80 -518, where the spouse - Auditor within
a Township could not audit the books of the Township Supervisor who was his
wife; and Oetweiler, 81 -648, which relying upon Restivo concluded that it was
an appearance of a conflict of interest for a spoL!se o1 a Township Supervisor
to serve as Auditor and to settle the books of the Township Supervisor.
Given the precedent of the Commission and the general conclusions reached
in their rulings, it is clear that as an Auditor, you may not audit, settle or
adjust the accounts of the Township Supervisors over which or in which you
played any part as a Supervisor. This is particularly obvious when it is
recognized that as an Auditor you have a responsibility to approve these books
but also to impose surcharges or recommend actions as Auditor that would be in
essence a disapproval of the actions of the Board of Township Supervisors on
which you sat.
However, while we must conclude that you may not audit those books in
which you as a Supervisor would be interested, there is no similar reservation
or prohibition against your serving as Auditor in general or, as Auditor,
auditing the dockets, transcripts, and other official records of the Justice
of the Peace, the tax collector, or any other books other than those relating
to the Supervisors over which you may have responsibility as Auditor.
Likewise, in your capacity as Auditor, we see no reason why you could not
perform the function of setting the salary of the Township Supervisors for the
current year In this function or action you would riot be affecting or
reviewing or recommending or declining to recommend action as to any activity
or actions in which you participated as a Supervisor.
Conclusion: The Ethics Act does not prohibit you, as a former Supervisor,
from acting as or assuming the responsibility of the elected Auditor except
insofar as you may attempt to or be required to audit, settle, or adjust the
accounts of the Board of Supervisors on which you sat. In this respect you
may not audit, settle, or adjust the accounts of the Board of Supervisors on
which you sat. Otherwise, you may undertake and perform all the functions
required of you as an elected Auditor, including the setting of salary of the
Township officials serving as roadworkers, roadmasters, or otherwise and to
audit the dockets, transcripts, and other official records of the Justice of
the Peace or tax collector.
Daniel Fisher
January 17, 1984
Page 3
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.
SSC /rdp
cc: David A. Flood, Esquire
Sincerely,
(-4WA r -- %j / /
/
/Sandra S. Chi stianson
General Counsel