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HomeMy WebLinkAbout81-559 PowellMary S. Powell LeBoeuf Township Secretary Waterford, PA 16441 Dear Ms. Powell: STATE ETHICS COMMISSION 308 FINANCE BUILDING HARRISBURG, PENNSYLVANIA 17120 April 24, 1981 ADVICE OF COUNSEL RE: Supervisors, Conflict of Interest 81 -559 This responds to your letter of April 2, 1981, in which you, as Secretary- Treasurer of LeBouef Township, requested an opinion from the Ethics Commission. Issue: You requested advice as to whether the Township may purchase gasoline from a fuel supplier who has two of the Township Supervisors as customers. Facts: You informed us that LeBoeuf Township desires to buy gasoline from a local fuel supplier. Two of the three Township Supervisors are customers of the supplier. Discussion: The Ethics Act, 65 P.S. §401 et se q., defines public official as "Any elected or appointed official in the Executive, Legislative or Judicial Branch of the State or a political subdivision thereof..." 65 P.S. §402. Township Supervisors are obviously public officials within the meaning of the Act and must govern their conduct in office by the provisions of the Act. The Ethics Act does not, however, prohibit the Township from buying gasoline from a fuel supplier who also serves two Supervisors. The statute forbids the Supervisors in question from using their public office or any confidential information received through holding public office to obtain financial gain for themselves, their immediate families or businesses with which they are associated. 65 P.S. §403(a). Thus, the Super- visors may not use their office or confidential information received through holding their office to obtain, for example, a lower price from the fuel supplier on their personal purchases. The Supervisors and the fuel suppliers should also note that Section 3(b) of the Act provides as follows: Mary S. Powell April 24, 1981 Page 2 "No person shall offer or give to a public official... or a member of his immediate family or a business with which he is associated, and no public official... 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...would be influenced thereby." 65 P.S. §403(b). Accordingly, the fuel supplier may not offer, nor may the Supervisors accept anything of value, including, for example, any rebate or discount not available to the general public, based on any understanding that an official action of the Supervisors would be influenced thereby. Conclusion: Township Supervisors are public officials subject to the Ethics Act. The Act does not prohibit the Township from buying gasoline from a fuel supplier who also sells fuel to two Township Supervisors. The Supervisors may not use their office or confidential information recevied through holding office to obtain financial gain for themselves, their immediate families or businesses with which they are associated. The Supervisors may not accept, nor the fuel supplier offer, anything of value based on any understanding that the Supervisors' official actions would be influenced t:iereby. 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 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, 94 andra S. General C unsel tianson