HomeMy WebLinkAbout85-606 WolfMr. James R. Wolf 85 -606
Wolf Farms Inc.
R.D. #2
Stewartstown, PA 17363
RE: Member of Township Planning Commission, Real Estate Developer, Conflict
of Interest
Dear Mr. Wolf:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
December 18, 1985
ADVICE OF COUNSEL
This responds to your letter of Novemher 22, 1985, wherein you requested
the advice of the State Ethics Commission.
Issue: Whether a member of a township planning commission may, within the
purview of the State Ethics Act, submit to the planning commission a proposal
for the development of a tract of land.
Facts: You are currently a member of the Hopewell Township Planning
Commission. You have been on the commission for six years and you have heen
chairman of the commission for three years. In January or February of 1986
you, along with your brother, intend to introduce a plan to the commission for
the development of a residential project in the township. You now seek the
advice of the State Ethics Commission as to whether there is any conflict of
interest if you were to undertake this residential development project.
Discussion: For the purpose of this advice we will assume that you are a
public official within the purview of the State Ethics Act. See Dice, 85 -021;
Snider v. Thornburgh, 469 Pa. 159, 436 A.2d 593, (1981). Your conduct,
therefore, would be subject to the requirements of the Act.
Generally, the State Ethics Act provides as follows:
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 husiness with which
he is associated. 65 P.S. 403(a).
Mr. James R. Wolf
December 18, 1985
Page 2
Within this provision of law it is clear that a public official may not use
their public position in order to obtain any financial gain for themselves or
for a business with which they are associated. They may not use confidential
information for similar purposes. As a member of the planning commission,
therefore, you could not take any action or use any information that is
confidential in order to benefit yourself or the project. See Rudnitsky,
81 -525; Eckstine, 83 -571.
In addition to the foregoing provision of law, the Ethics Commission may
address areas of possible conflicts of interest on the part of public
officials and public employees. 65 P.S. , 5403(d). The Commission has
previously ruled that this section would operate to prevent such an official
or employee from representing interests that are adverse to the interests
represented his official capacity. See Allen, 79 -024; Fritzinger, 80 -008. It
is clear that under the foregoing factual s Tuation, you would be serving
adverse interests if you, as a member of the planning commission, were to
participate in the review, consideration and final disposition of a
development project that was submitted by you or an entity with which you are
associated. There's no doubt that in this situation you could not both serve
the public interests as a member of the planning commission and your own
private financial interests. As such, you would be required, as a member of
the planning commission, to abstain from any participation, review,
consideration, recommendation, or vote in relation to a residential
development project in which you are involved. Additionally, you may not
attempt to influence either directly or indirectly the other members of the
township planning commission or other officials of the township, such as the
township supervisors who have the final approval authority regarding the plan.
Additionally, it should be noted that in your private capacity as a member of
the real estate development project, you may be called upon to deal with
members or employees of the township planning commission. This, of course,
would present a sensitive situation in that you, as a private developer, would
have to represent your development project before the employees of the
planning commission as well as before the members of the planning commission
and the members of the township who appointed you to that commission. As
such, in order to avoid certain public perceptions regarding potential
conflicts of interests, you are advised that it would be the better practice
in this situation to not personally represent your development project before
the members and employees of the planning commission or any employee or
officer of the township. In this way you will remain completely detached from
the commission's consideration of your project and would not he either
directly or indirectly attempting to influence that commission's decisions.
It is also noted that your abstention from participation in this matter should
be noted publicly. The reason for this abstention should also be noted.
Mr. James R. Wolf
December 18, 1985
Page 3
Finally, this Commission has previously noted that in certain situations
where only limited development possibilities exist or where limited
development is permitted, the public official may not participate in the
consideration or decision of other developers who may be seeking to obtain the
same opportunity as the project with which the public official is associated.
The public official who participates and, for example, votes against another
developer's proposal could he perceived to have denied said proposals as to
open the way for the acceptance of his own proposal. See Eckstine, 83 -571;
Co Toff, 83 -005; and Resinger, 146C. Thus, if such a situation exists, you
s ou abstain from the consideration of proposals submitted by other
devel opers.
Conclusion: While the state Ethics Act presents no per se prohibition on your
submitting a development project for consideration to the township planning
commission for review, you as a public official may not participate, to any
extent, in the consideration or disposition of that project. Additionally,
you are advised that you should not represent your project before any township
official or employee. You should be particularly aware of the development of
any conflicts of interests and public perceptions regarding your activities as
a public official. In the event that other potential conflicts develop, you
should seek further advice of this Commission.
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 he 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.
JJC/ rdp
Sincely,
John J ontino
GerO.eral Counsel