HomeMy WebLinkAbout80-736 MihalikJohn A. Mihalik, Esquire
Hummel, James & Mihalik
29 East Main Street
Bloomsburg, PA 17815
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
December 17, 1980
ADVICE OF COUNSEL
RE: Planning Commission, Zoning Officer
Dear Mr. Mihalik:
80 -736
This responds to your letter of September 9, 1980 in
which you requested an Opinion from the Ethics Commission.
Issue: You request Advice as to whether a member of a Plan-
ning Commission can also serve as the Zoning Officer of a
municipality.
Facts: You informed us that a member of a Planning Commis-
sion was considering serving as the local Zoning Officer.
Discussion: In pertinent part, Section 2 of the Ethics Act
defines a public employee as:
"Any indidual employed by the
Commonwealth or a political sub-
division who is responsible for
taking or recommending official
action of a non - ministerial
nature with regard to:
(1) contracting or procurement;
(2) administering or monitoring
grants or subsidies;
(3) planning or zoning
(4) inspecting, licensing,
regulating or auditing any
person; or
(5) any other activity where the
official action has an econo-
impact of greater than a de
minimus nature on the interests
of any person." 65 P.S. §402.
John A. Mihalik, Esquire
December 17, 1980
Page 2
In Simmons, 79 -056 the Commission interpreted this
definition to mean that a zoning officer is a public employee
because he is employed by a political subdivision of the
Commonwealth who is responsible for taking or recommending
non - ministerial official action with regard to zoning.
According to 53 P.S. §10202 members of planning commis-
sions are appointed and serve without compensation. Munici-
pal employees may serve as members of a planning commission
without losing their powers or compensation. The Ethics Act,
65 P.S. §401 et. seq., provides that a "public official"
shall not include any appointed official who receives no
compensation other than reimbursement for actual expenses.
Previous decisions of the Commission clearly state that
" uncompensated appointed officials such as members of a plan -
ning commission... are not covered by the Act." Coughlin,
76 -063.
Members of planning commissions recommend various plans
including zoning ordinances to the creating municipality. 53
P.S. §10209.1. The duty of a zoning officer is to administer
the zoning ordinance adopted by the municipality. 53 P.S.
§614. Thus while a zoning officer sitting on a planning
commission may have some influence on recommended measures it
is his duty to enforce, while it is the municipality that
actually approves the measures.
TL.e Commission has held that the Ethics Act does not
prohibit simultaneous representation of more than one poli-
tical subdivion. King, 79 -034. Analogously, the Act does
not prohibit an individual from serving a municipality in
more than one capacity. Given the duties of the zoning
officer and the Planning Commission, which as described above
are separate and distinct, we see no reason to preclude
holding such positions simultaneously.
Conclusion: Thus, while the zoning officer is a public
employee, there is no per se prohibition from him also
serving as a member of a Planning Commission.
Pursuant to Section 7(9)(ii), this Advice is a complete
defense in any enforcement proceeding initiated by the Commis-
sion, 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 avail-
able as such.
John A. Mihalik, Esquire
December 17, 1980
Page 3
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 may be scheduled and a formal Opinion from the
Commission will be issued. You should make such a request or
indicate your disapproval of this Advice within the next 30
days.
SW /rdp
Sincerely,
p i
andra S. Ch''stianson
General Cou sel