HomeMy WebLinkAbout84-511 StillwagonMr. William C. Stiliwagon, Esquire
319 South Maple Avenue
Greensburg, Pennsylvania 15601
Madmg Address
STATE ETHICS COMMISSION
P.O. BOX 1179
HARRISBURG, PA 17108
TELEPHONE: (717) 783 -1610
January 18, 1984
ADVICE OF COUNSEL
RE: Simultaneous Service, Planning Commission, Auditor
Dear Mr. Stiliwagon:
84 - 511
This responds to your letter of January 3, 1984, in which you requested
advice from the State Ethics Commission.
Issue: You ask whether an individual may serve as a member of the local
Township Planning Commission and as an Auditor within the Township and if so,
what restrictions are placed upon his conduct pursuant to the Ethics Act.
Facts: You indicate that you represent an individual who at the present time
is a member of the local Township Planning Commission, hereinafter the
Planning Commission. In the last municipal election this individual was also
elected as Auditor within the same Township. You indicate that while he is
paid as an Auditor, his work on the Planning Commission is performed without
pay.
The Planning Commission, however, does receive some funds from the
Township to operate the Planning Commission. These funds, however, are faily
limited. The post of Auditor, to which this individual was elected, of
course, would be responsible for auditing the Township records and books and
this would include an audit of the Planning Commission's books or records
relating to same.
You indicate that you have concluded and we have preliminarily indicated
that this member of the Planning Commission who has recently been elected as
Auditor should not participate in any audit of the Planning Commission's books
and there should be no intermingling of activities of the member of the
Planning Commission who is also the Auditor. You indicate that you have
opined this individual should remove himself from any audit of the Township
Planning Commission's books and that this should resolve the potential for any
conflict in the above circumstances.
State Ethics Commission • 308 Finance Building • Harrisburg, Pennsylvania
Mr. William C. Stillwagon, Esquire
January 18, 1984
Page 2
Discussion: As an Auditor who has been recently elected to this position
within the Township, your client is a "public official" es that term is
defined in the State Ethics Act. See Section 2 of the Ethics Act, 65 P.S.
402. As such his conduct as an Auditor must conform to Lhe requirements of
the State Ethics Act.
He must insure that his conduct presents neither a conflict nor the
appearance of a conflict of the public trust as required by the Ethics Act.
Previous rulings of the Commission indicate that as a general rule a public
official may not review, approve, or inspect any activity in which he might be
interested as an individual. For example,, the Commission has concluded that a
zoning officer who is also a developer could not issue permits to himself.
See Simmons, 79 -056. Similarly, the Commission has concluded that a developer
who is also elected to be a Township Supervisor could not inspect or approve
his own work as a developer. See Sowers, 80 -050. With respect to auditing,
there are rulings that indicate that an Auditor may not audit the Township
books where the spouse of the Auditor serves as a Supervisor. See Restivo,
80 -518 and Detweiler, 81 -648.
Thus, in the circumstances that you outlined it is apparent that this
individual as an elected Auditor, may not audit or approve (including the
power to disapprove and cite in his audit report, for example) the books of
the Township Planning Commission where he has served as a member. However,
assuming that this Auditor can withdraw from participating in any audit of the
Township's Planning Commission books, thereby avoiding any conflict of
interest or appearance of a conflict of interest with the public trust, he may
serve simultaneously in these two positions.
Conclusion: The Ethics Act does not contain any provision which would hold
that this individual cannot simultaneously serve as an elected Auditor and a
member of the Planning Commission within the same Township. However, in his
capacity as Auditor, this individual's conduct vis -a -vis the auditing of the •
books of the Township Planning Commission should be governed by 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.
Mr. William C. Stillwagon, Esquire
January 1R, 19R4
Page 3
SSC /rdp
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.
Sincerely,
Sandra S. Christianson
General Counsel