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HomeMy WebLinkAbout80-509 CogginsTo: RE: FACTS: DISCUSSION: CONCLUSION: January 3, 1980 ADVICE OF CHIEF COUNSEL Ellen Marie Coggins Chief Counsel Department of Community Affairs Harrisburg, PA 17120 80 -509 Spouse of the Secretary of the Department of Community Affairs serving as a Commissioner in a first -class township. On December 31, 1979, Ellen Marie Coggins, Chief Counsel of the Department of Community Affairs, requested an opinion regarding the application of the Ethics Act to the husband of Acting Secretary Shirley Dennis. "Mr. Dennis is an elected Commissioner in Abington Township, Montgomery County. The Department of Community Affairs has entered into contractual agreements with the township on several occasions prior to her appointment. Since the Department administers a number of grant programs, it is probable that we will be executing additional contracts with the township in the future. Mr. Dennis would have no personal interest in any of the grants other than that of an elected official. Secretary Dennis, of course, as the head of the Department has the final say on any grant which is made." The question is what steps must be taken to insure compliance with the State Ethics Act. If Mr. Dennis were to take no part in any discussion involving a contract with the Department of Community Affairs, there would be no appearance of any conflict with the public trust. There is no appearance of a conflict with the public trust where one spouse is Secretary of the Department of Community Affairs and the other spouse is a commissioner of a first - class township where that commissioner of the first -class township takes no part in any discussion involving contracts with the Secretary's department. Ellen • .arie Coggins January 3, 1930 Page 2 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. 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. State Ethics Commission 308 Finance Building Harrisburg, PA 17120 (717) 733 -1619 DRn /rdp- 3 DAVID RITTENHOUSE TiiORPISOTT Chief Counsel