HomeMy WebLinkAbout81-512 SacavageRobert B. Sacavage
44 North Oak Street
Mount Carmel, PA 17851
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
February 4, 1981
ADVICE OF COUNSEL
81 -512
RE: Borough Council, Dual Employment, Municipal Authority
Dear Attorney Sacavage:
This responds to your letter of November 18, 1980, in
which you, as a Borough Solicitor, requested an opinion from
the Ethics Commission.
Issue: You request Advice as to whether a member of a borough
council may also serve as a member of a municipal authority in
the same borough.
Facts: You informed us that the President of your Borough
Council is employed by the Borough's Sewer Authority as a
laborer. The Sewer Authority is governed by a seven member
board appointed by the Borough Council. The Authority's super-
visor controls the labor crew of the Authority.
Discussion: The President of a Borough Council is clearly a
"public official" under the Ethics Act. Section 2 of the Act
states that a "public official" is an elected official of the
executive, legislative or judicial branch of the state or any
political subdivision thereof.
While the Act applies to the President of a Borough Council
there is no conflict of interest per se when a Council President
is employed as a laborer by the Borough Sewer Authority. A
conflict of interest exists when an individual represents two
or more persons whose interest is adverse to each other. See
Alfano, 80 -007. The Council President, as President, represents
the Council; but as a laborer for the Sewer Authority he does
not have such an antagonistic interest to the Council as to
create an inherent contlict of interest.
Section 1 of Act 170 provides, however, that public
officials shall not present "the appearance of a conflict with
the public trust." Therefore, the Council President should
refrain from voting on appointments of sewer authority members
as long as he is employed by the Sewer Authority to avoid the
Robert B. Sacavage
February 4, 1981
Page 2
appearance of a conflict of interest. The Borough Solicitor
has already advised the President to abstain from voting on any
matters concerning the Authority including appointments,
contracts or other matters directly or indirectly relating
thereto. This caution and direction by the Solicitor as to the
Council President's vote will surely comply with the letter and
spirit of the Ethics Act. The Council President should also
place the reason for his abstention on the public record.
Conclusion: There is no inherent conflict of interest in the
President of a Borough Council retaining employment as a laborer
with the Borough Sewer Authority.
To avoid the appearance of a conflict of interest the
Council President while employed by the Authority, should
refrain from voting on appointments to the Sewer Authority and
place the reason for the abstention on the public record. The
Borough Council President should follow the advice of the
Borough Solicitor and abstain from voting on Sewer Authority
contracts as well as appointments and matters directly or
indirectly relating thereto.
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 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 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
S ,jncerely,
an.ra S. ristianson
General C unsel