HomeMy WebLinkAbout84-520 PaparelliMr. Joseph D. Paparelli, Esquire
Court House Square
148 Adams Avenue
Scranton, Pennsylvania 18503
Dear Mr. Paparelli:
Mading Address
STATE ETHICS COMMISSION
P.O. BOX 1 179
HARRISBURG, PA 17108
TELEPHONE: 1717) 783 -1610
February 2, 1984
ADVICE OF COUNSEL
84 -520
RE: Valley View School District; Non - Profit Sports Organization
This responds to your letter of November 17, 1983, in which you, as
Attorney for Mr. Louis Vitella, requested advice from the State Ethics
Commission.
Issue: You ask what restrictions are imposed upon Mr. Vitella as a result of
his concurrent service as a School Board member who does chairs a non - profit
organization which sponsors a holiday basketball tournament.
Facts: Mr. Vitella was recently elected to the School Board of the Valley
View School District, and was sworn in as School Director during the first
week of December. Mr. Vitella also holds the position of Chairman of a
non - profit organization which runs a holiday basketball tournament featuring
several school districts, including the Valley View School District. In this
regard, some of Mr. Vitella self- imposed duties'include attending all games so
as to be available to work out immediate problems, arranging for staffing the
tournament, contracting various schools to facilitate their participation in
the tournament, and obtaining sponsors for production and operation of the
tournament.
You indicate that Mr. Vitella, in addition to the time and energy he
spends on the tournament, also incurs out of pocket expenses for which he is
not reimbursed. He does, however, receive a fee of $50 for his services. You
note that, at the time this School District committed itself to participating
in the tournament, Mr. Vitella was not yet a member of the School Board.
State Ethics Commission • 308 Finance Building • Harrisburg, Pennsylvania
Mr. Joseph D. Paparelli, Esquire
February 2, 1984
Page 2
Mr. Vitella is concerned that his continued receipt of the 550 fee
constitutes a conflict of interest between his position as Chairman of the
Tournament and School Board Director for the Valley View School District, a
participant in the Tournament. You indicate that he would like to continue in
both capacities, and that he would abstain from any school board vote
regarding the tournament.
Discussion: As an elected Director in the Valley School District, Mr. Vitella
comes within the def inition of "public official" as that term is defined in
the Ethics Act. See 65 P.S. 402. As such, his conduct must conform to the
requirements of the Ethics Act. One of the pertinent provisions of the Ethics
Act is Section 3(c), which states:
(c) No public official or public employee or a member of
his immediate family or any business in which the person
or a member of the person's immediate family is a
director, officer, owner or holder of stock exceeding 5%
of the equity at fair market value of the business shall
enter into any contract valued at $500 or more with a
governmental body unless the contract has been awarded
through an open and public process, including prior public
notice and subsequent public disclosure of all proposals
considered and contracts awarded. Any contract made in
violation of this subsection shall be voidable by a court
of competent jurisdiction if the suit is commenced within
90 days of making of the contract. 65 P.S. 403(c).
While the provisions of Section 3(c) of the Ethics Act regulate, to some
degree, the conduct of a public official and a business in which he serves as
an officer, or in this case a Chairman, we must determine first and foremost,
whether the non- profit organization which Mr. Vitella serves is a "business"
as that term is defined in the Ethics Act. A "business" is defined in the
Ethics Act as follows:
"Business." Any corporation, partnership, sole
proprietorship, firm, enterprise, franchise, association,
organization, self - employed individual, holding company,
joint stock company, receivership, trust or any legal
entity organized for profit. 65 P.s. 40
From this definition, it is clear that Mr. Vitella's organization,
because it is not an entity organized for profit, cannot be considered a
"business" as that term is used in the Ethics Act or in Section 3(c) in
particular. Thus, the requirements of Section 3(c) would not be applicable if
the District does or wishes to contract with the organization. It is also
important to note that, in this case, Mr. Vitella does not receive an excess
of $500, and thus his "contract" with the School District would not come under
the requirements of Section 3(c) open and public process.
Mr. Joseph D. Paparelli, Esquire
February 2, 1984
Page 3
Although Section 3(c) of the Ethics Act is not applicable to this
situation, there are other provisions of the Ethics Act that must be reviewed
in order to guide Mr. Vitella's conduct under the Act. Specifically, the
provisions of Section 3(a) as set forth below, should be reviewed:
(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).
Section 3(a) of the Ethics Act applies to Mr. Vitella's conduct as a
public official vis -a -vis a "busines with which he is associated" as that term
is defined in the Ethics Act as follows:
"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.
The sports organization as set forth above, is a non - profit entity and
should not be considered a "business" in general, and thus, Section 3(a) would
not be applicable.
However, we must also consider that the general purpose of the Ethics Act
as set forth in Section 1 of the Act, is to insure that the financial
interests of the holders of or candidates for public office present neither a
conflict nor the appearance of a conflict with the public trust. Even if the
sports organization is not an entity organized for profit and may not be a
"business" with which Mr. Vitella is "associated" as defined in the Ethics
Act, it is clear that if the organization continues to exist and provides
services to the School District, Mr. Vitella would have a financial interest,
though minimal, in this outcome because of his status as Chairman of the
organization. Accordingly, even though the organization is not a "business ",
Mr. Vitella would be in a position, as a School Board Director, to influence
the Valley View School District's decisions to continue, renew, or
re- negotiate any contract with the organization. Such a continuation,
renewal, or re- negotiation might have an effect upon Mr. Vitella's status as
Chairman, his reimbursement, or possibly as an employee of the organization.
Therefore, under the requirement of Section 1 of the Ethics Act which does not
appear to be restricted in its application by reference to a "business" as is
Section 3(c) or Section 3(a), we must conclude that Mr. Vitella should not
partici pate in any of the School District's decisions vis -a -vis the sports
organization. See Grove, 83 -013, where the Commission indicated the fact that
a corporation is a non - profit entity does not preclude the possibility that an
official may be required, under Section 1 of the Ethics Act, to abstain from
participating in those discretionary decisions and matters presented by the
organization to the entity on which the official serves.
Mr. Joseph D. Paparelli, Esquire
February 2, 1984
Page 4
Thus, in this case, in order to achieve the goal of assuring the public
that the financial interests of public officials present neither a conflict
nor an appearance of a conflict with the public trust, Mr. Vitella should not
participate in the decisions of the School District, discussions of the
District, or official action of the District with respect to the sports
organization or the tournament. Otherwise, there are no restrictions under
the Ethics Act in his continuing to serve as Chairman of the sports
organization while at the same time serving as a School Board Director.
With regard to your specific question of whether the $50 fee which Mr.
Vitella receives for his services vis -a -vis the sports organization presents a
problem, there is no problem with his accepting same as long as as Mr. Vitella
abstains from any school district decision to award him the fee.
Conclusion: Because the sports organization is a non - profit entity, neither
Section 3(a) or Section 3(c) of the Ethics Act would be applicable or restrict
or preclude Mr. Vitella from continuing his role with the sports organization.
However, Mr. Vitella should abstain from official votes, discussions, etc. on
the District's decisions relative to the sports organization and tournament,
in order to comply with Section 1 of the Ethics Act. There are no other
restrictions under the Ethics Act upon Mr. Vitella's receiving a fee for his
services, or upon Mr. Vitella's concurrent service as Chairman of the sports
organization and as a School Board Director for the Valley View School
District.
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.
CW /rdp
Sincerely,
Sandra S. Chri
General Couns
i an son