HomeMy WebLinkAbout86-508 GrovesMr. William C. Groves, Secretary
Cumherland Township Supervisors
100 Municipal Road
Carmichaels, Pennsylvania 15320
Dear Mr. Groves:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
January 31, 1986
ADVICE OF COUNSEL
86 - 508
Re: Township Supervisor, Trucking Contract, Conflict of Interest
This responds to your letter of December 28, 1985, wherein you requested
the advice of the State Ethics Commission.
Issue: Whether the State Ethics Act presents any restrictions regarding the
award of a trucking contract by a township to a company with which one of the
township supervisors has a business relationship.
Facts: You currently serve as a member of the board of township supervisors
in Cumherland Township, Greene County, Pennsylvania. You are the secretary of
the township board of supervisors. You advise that you are half owner of a
trucking company, Bailey Trucking P.U.C. Inc. You indicate that Cumherland
Township does not have enough bottom ash for the winter. Mr. Ralph Burwell is
engaged in the ash hauling husiness. You advised that when Mr. Rurwell is not
hauling ash, he hauls coal for Bailey Trucking Inc. under a lease arrangement.
You also advised that when Mr. Rurwell has a large ash haul your company,
Bailey Trucking, provides trucking services for him. According to your
letter, only certain haulers are permitted to haul ash from Hatfield Power
Station. All of these trucks that are permitted to haul from the power plant
have at one time worked for Railey Trucking. Rased upon your husiness
relationship with Mr. Rurwell, you now request the advice of the Ethics
Commission regarding the potential contract hetween Mr. Rurwell and Cumherland
Township. Specifically, you ask whether any restrictions would be placed upon
this arrangement.
Discussion: As a township supervisor you are a public official as that term
is defined in the State Ethics Act. 65 P.S. X402. As such, your conduct must
conform to the requirements of the Act. Sowers, 80 -050.
Mr. William C. Groves
January 31, 1986
Page 2
Your letter does not specifically indicate what, if any function, Rai ley
Trucking will play in relation to the contract hetween the township and tlr.
Burwell. As a result, we will review this matter under two specific factual
situations. First, we will assume that the contract will be specifcally
between the township and Mr. Burwell's company. First, we will assume that
Bailey Trucking will perform no services in relation to this contract and will
receive no henefits therefor. Secondly, we will review this matter under the
assumption that Bailey Trucking will provide services to Burwell in the form
of hauling ashes from the power plant. We will assume, for this purpose, that
your company will act more or less as a sub- contractor to Mr. Burwell and that
your company will be compensated for this service.
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 business with which
he is associated. 65 P.S. 403(a).
Within this provision of law, you may not use your public position in order to
obtain any financial gain for yourself or for a business with which you are
associated. You may not use confidential information obtained in your public
position for similar purposes. A business with one is associated is defined
in the Act as follows:
Section 2. Definitions.
"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.
According to the facts that have been provided, it appears as though you are
not associated with Mr. Burwel l's company within the definition of the
foregoing provision. You are not an officer, owner, or employee of that
company. Under the first factual situation, there would be no prohibition on
a township's award of the hauling contract to Mr. Rurwel l . If Bailey P.U.C.
Inc. is performing no service in relation to this contract and if your company
will receive no benefits therefrom, Section 3(a) of the Act will present no
prohibition upon the award of this contract.
Mr. William C. Groves
January 31, 1985
Page 3
Similarly, the Ethics Act provides as follows:
Section 3. Restricted activities.
(c) No puhlic 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 puhlic
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).
Within this provision of the law, it is clear that no puhlic official, member
of his immediate family or business in which the person or a member of his
immediate family is an officer, director, or owner of greater than 5% of the
equity at fair market value may contract in an amount in excess of $500 with a
governmental body unless the contract has been awarded through an open and
public process. Howard, 79 -044. This Commission has previously determined
that this provision of the law would only apply to contracts between a public
official and his own governmental body. See Bryan, 80 -014; Lynch, 79 -047. In
a situation where the public official is attempting to contract with his own
governmental body the open and public process must be employed. That process
would include prior public notice of the employment or contracting
possibility; sufficient time for a reasonable and prudent competitor or
applicant to be able to prepare and present an application or proposal; public
disclosure of all applications or proposals considered and public disclosure
of the contract awarded or offered and accepted. See Fields, 82-006; Cantor,
82 -004. Under the factual situation as outlined above, it is clear that you
are not an owner of Mr. Burwell's company and that under the first factual
situation where Bailey P.U.C. could be providing no services and receiving no
compensation. Thus, there would be no 3(c) prohibition or restrictions upon
Mr. Burwell's contract with the township.
In addition to the foregoing, the State Ethics Act also authorizes this
Commission to address other areas of possible conflict. 65 P.S. 6403(d).
Generally, such a conflict develops where a public official attempts to serve
one or more interests that are adverse. Alfano, 80 -007, Domalakes, 85 -010.
The types of activity that are encompassed by this provision of law are
generally determined through a review of the intent of the State Ethics Act.
That intent is to ensure that the financial interests of their public
officials do not conflict with the puhlic trust. 65 P.S. .401. Within this
provision of law, it is advised that even if the contract between Mr. Burwell
and the township does not involve Bailey Trucking and even if Bailey Trucking
Fir. William C. (;roves
January 31, 1q R6
Page 4
will provide no services for Mr. Burwell in relation to this contract, you
should abstain from participating in the township's decision and vote to award
this contract. This is particularly so, in that you have had business and
financial dealings with Mr. Burwell in the past which would most likely
continue in the future. Because of this financial relationship with Mr.
Burwell a conflict of interest could develop and that it could he perceived as
though you are awarding this contract to Mr. Burwell in order to secure future
private business transactions. You should, thus, abstain from participating
in the decision to award this contract even if Bailey P.II.C. has no
relationship to the contract.
In addition to the foregoing, we do note that the Act provides as
follows :
Section 3. Restricted activities.
(b) No person shall offer or give to a public official or
public employee or candidate for public office or a member
of his immediate family or a business with which he is
associated, and no public official or public employee or
candidate for public office shall solicit or accept,
anything of value, including a gift, loan, political
contribution, reward, or promise of future employment
based on any understanding that the vote, official action,
or judgment of the public official or public employee or
candidate for public office would be influenced thereby.
65 P.S. 403(b).
We make reference to this provision of the Act not to imply that there has
or will be any violation thereof, but in order to provide a complete response
to your question.
We now must review the current situation under the second factual
assumption. As noted previously, Section 3(a) of the Act would prohibit a
public official from using his public position in order to obtain any
financial gain for himself or a business with which he is associated.
Technically, you are not associated with Mr. Burwell's company as provided for
in the State Ethics Act, however, if your company will be hauling ashes under
Mr. Burwell's contract with the township, or if there is a reasonable
expectation that such will occur, you must not participate in the township's
decision to award this contract. This is so, in that such participation would
be a use of your public office to obtain a financial gain for your company, in
that you would be aware of the fact that your company would he receiving a
benefit from this contract. Thus, under the second factual situation, you may
not participate in the decision to award the contract. Additionally, you must
make known publicly your abstention, the reasons for the abstention and such
should be recorded in the appropriate township minutes. See Witmer, 83 -580.
Mr. Wil li am C. Groves
January 31, 1986
Page 5
In addition to the foregoing, it is further advised that if Bailey P.II.C.
will be operating in a sub- contractor basis for Mr. Burwell, or will otherwise
receive any benefit under Mr. Burwell's business relationship with the
township under both Section 3(c) and 3(d) of the State Ethics Act an open and
public process should be employed. As a result, the award of this contract
should he completed in accordance with the open and public process as
previously outlined in this advice. Also, as noted, you may not participate
in the award of this contract.
Conclusion: As a township supervisor you are a public official within the
purview of the State Ethic Act.
A. If your company will provide no services in relation to the
'township's contract for the hauling of ashes, no prohibitions are placed upon
the general award of this contract by the township. Because of your prior
business relationships and financial dealings with the contractor, you must
abstain from participating in the decision to award this contract and your
abstention and the reasons therefore, should be publicly announced, and
recorded.
B. In the event that your private company will participate in the
contract and in the event that you or your company will receive compensation
for such participation, the contract must be awarded through an open and
public process as defined in this advice. Additionally, you may not
participate in the award of that contract to any extent.
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.
Sincer
nt i no
Gen' . Counsel