HomeMy WebLinkAbout84-639 ReidMs. Helen W. Reid
P.O. Box 252
Nottingham, PA 19362
Dear Ms. Reid:
L::.i iA iii !.:.... .._ . .
!i it : l "t _: i'. Build
December 28, 1984
ADVICE OF COUNSEL
Re: Township Ordinance, Mobile Home Court
This responds to your letter of December
advice from the State Ethics Commission.
84 -639
20, 1984, in which you requested
Issue: You ask whether, you as a supervisor, may vote on a proposed amendment
to a zoning ordinance for the Township you serve under certain circumstances.
Facts: You indicate that you currently as a supervisor in West Nottingham
Township, hereinafter the Township. The Township adopted an ordinance in 1983
and recently, an amendment has been proposed to that ordinance concerning
mobile homes to be placed on private lots. You indicate that the Township has
a separate ordinance pertaining to mobile home parks.
Further, you indicate that you hold a real estate salesman license and
that your son owns a mobile home court and selles mobile homes within the
Township.
A vote on a proposed amendment is to be taken on January 8, 1985 and you
question whether there would be any conflict in your participating in the
Township's decisions and votes with respect to this proposed amendment under
the circumstances outlined above.
Discussion: As an elected supervisor in the Township you are, of course, a
"public official" as that term is defined in the State Ethics Act. See
Section 2, State Ethics Act, 65 P. S. 402. As a public official your conduct
must conform to the provisions of the State Ethics Act. The most pertinent
provision of the State Ethics Act in light of the question presented above is
Section 3(a) of the Ethics Act which states as follows:
Ms. Helen Reid
December 28, 1984
Page 2
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. 403(a).
Of course, under this provision, you may not use your public position as
a supervisor to secure any financial gain for yourself, a member of your
immediate family or a business in which you are associated. Incidently, the
definition of the term "immediate family" includes only a spouse living in
your household and minor dependent children. On the facts as set forth above
and information which is logically deduced from those facts, we will assume
that your son is not a minor dependent child. However, if you use your real
estate license independently or as an employee of any business, that business
would he considered to be one with which you are "associated" as defined in
the State Ethics Act. See Section 2 of the State Ethics Act, 65 P. S. 403
(a). Thus, you could not use your public office or cast any votes as a public
official which would have the effect of benefitting yourself or any business
with which you are employed or associated.
In the circumstances outlined above, however, there does not appear to be
a real possibility that there would be any financial gain to yourself or a
business by which you are employed or with which you are associated if you
were to vote on the proposed amendment. Likewise, the provisions of Section
3(a) of the Ethics Act would not even be applicable to the situation of your
son who is involved in a mobile court or as a mobile home salesman
because he is not within the definition of "immediate family" as set forth
above. In any event, even with respect to your son there does not appear to
be any direct financial gain or specific benefit that he, as a mobile home
court operator or salesman would derive from this particular amendment to the
Township zoning ordinance.
Basically, the Commission has required abstention by a public official
where the public official, a member of the officials immediate family or
business with which they are associated has a direct, immediate, or particular
interest in the matter which would be subject to the official's vote. See
Krier, 84 -002. For example, where the question to be presented to the public
iallaal for his consideration or vote directly and individually impacts upon
his or her spouse, the Commission has required abstention. See Leete, 82 -005.
Ms. Helen Reid
December 28, 1984
Page 3
However, in the present case no facts have been presented which would indicate
that you, as an individual or because of your possession of a real estate
license, would be benefitted directly or individually or even impacted any
more than any other member of the public or the Township by the proposed
amendment. Accordingly, you could participate in the Township's decisions
relating to this proposed amendment and would not be subject to any
restriction or required to absten from same under the Ethics Act.
Conclusion: Under the circumstances set forth above, Section 3(a) of the
Ethics Act would not prohibit you from participating in the final vote on the
proposed amendment. Thus, as a supervisor within the Township you may
participate in the Township's decisions and votes with respect to this
proposed amendment.
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 /sfd
Sincerely,
Sandra S. Christianson
General Counsel