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HomeMy WebLinkAbout79-532 StuartTO: Henry L. Stuart, Esquire 1 -3 South Hanover Street Carlisle, PA 17013 RE: Township Solicitors FACTS: DISCUSSION: STATE ETHICS COMMISSION HARRISBURG, PA. September 26, 1979 ADVICE OF CHIEF COUNSEL Advice Number 79 -532 On September 5, 1979, Henry L. Stuart, Esquire, Solicitor for Penn Township, Cumberland County, Penn- sylvania inquired as to whether solicitors are public employees or public officials. He also inquired as to whether he must list each security where the dividends exceed $500, or whether a general statement that dividends from stocks exceed $500 is sufficient. The two issues before the Commission are whether a solicitor is subject to Act 170, and whether each security with dividends in excess of $500 must be listed. The Commission has already held in J. Michael King, 79 -34, attached hereto, that solicitors of second -class townships are "public employees" as that term is used in Act 170. Income is defined very broadly in Act 170, as follows: Any money or thing of value received, or to be received as a claim on future services, whether in the form of a fee, salary, expense, allowance, forbearance, forgiveness, interest, dividend, royalty, rent, capital gain or any other form of recompense or any combination thereof. Thus, any security where the dividends, interest, and capital gains exceed $500 shall be disclosed in the Financial Interest Statement. HENRY L. STUART, Esquire September 26, 1979 page 2 Pursuant to Sections 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. A personal appearance before the Commission and a formal opinion will be issued upon your request, if you feel this reply does not suffice. This letter is a public record and will be made available as such. CONCLUSION: Solicitcrs of a township are public employees as defined in Act 170. Securities where the dividend income, interest income, and capital gain exceed $500 must be disclosed on the Financial Interest Statement. David Rittenhouse Morrison Chief Counsel