HomeMy WebLinkAbout81-576 SnipesSTATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
June 11, 1981
ADVICE OF COUNSEL
Samuel M. Snipes 81 -576
48 South Main Street
P.O. Box 354
Yardley, PA 19067
RE: Conflicts of Interest, Township Police, Township Code
Enforcement Officer
Dear Mr. Snipes:
This responds to your letter of February 26, 1981, in
which you, the Solicitor of Falls Township, requested an opinion
from the Ethics Commission.
Issue: In your letter you request advice whether the Ethics
Act prohibits a police officer from remaining on active duty
while running for the office of District Justice and whether
the Act prevents a code enforcement officer from running for
the office of Supervisor while remaining on active duty.
Facts: You informed us that you are the Solicitor for Falls
Township, Bucks County. Falls is a second class township. One
of its police officers desires to run for a position as a
district justice. The Township code enforcement officer seeks
a Supervisor's post. The Township Board of Supervisors wishes
to require each of these individuals to take a leave of absence
during their campaign.
Discussion: Initially, we note that the jurisdiction and
authority of the Ethics Commission is strictly circumscribed by
the Ethics Act, 65 P.S. §401 et seq. This Advice is limited to
the effect of the Act on the situation you describe and will
not discuss the impact of other statutes or case law. Man erial
or policy decisions remain, of course, at the discretion of the
Supervisors.
The Ethics Act does not proscribe public employees from
running for political office. There is nothing in the statute
that requires a public employee to take a leave of absence
while runnin,g for a political office. The Act does, however,
impose certain restrictions on the conduct of candidates for
public office and public officials.
Samuel M. Snipes
June 11, 1981
Page 2
Specifically, the Act provides that no person shall offer
or give to a candidate for public office and no candidate for
public office shall accept anything of value, including a
political contribution, based on any understanding that the
vote or official acts or udgment of the candidate for public
office would be influenced Hereby. 65 P.S. §403(b). The
police officer and the code officer must not accept anything of
value based on any understanding that their current duties or
their services as either District Justice or Supervisor would
be influenced thereby. This prohibition is directed at the
conduct of candidates for office but does not prevent a public
employee from seeking public office. n
As a District Justice and a Supervisor the two individuals
you mention would be public officials with the meaning of the
Ethics Act, 65 P.S. §402. The Act states that no public
official or employee shall use his public office or confiden-
tial information received through holding public office to
obtain financial gain for himself, his immediate family or a
business with which he is associated. 65 P.S. 4.03(a). The
policeman may not use his status as a police officer or his
post, if elected as a District Justice or confidential infor-
mation obtained in either position to obtain financial gain.
Similarly, the code enforcement officer may not use his position
as enforcement officer, if elected, or as Supervisor or confi-
dential information to obtain financial gain.
Section 3(b) of the Act prohibits a public official or
employee from accepting anything of value based on any under-
standing that his official acts would be influenced thereby.
65 P.S. §403(b). The prohibition applies to all offices held,
thus the policeman and enforcement officer may not accept
anything of value based on any understanding that their acts as
police officer or enforcement officer or as District Justice or
Supervisor, if elected, would be influenced thereby.
Further, Section 3(c) provides that no public official or
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 is awarded in an open and
public process. 65 P.S. §4.03(c). Therefore, the requirements
of Section 3(c) apply to contracts with all the governmental
bodies with which a person is associated. The police officer
would be deemed associated with two governmental bodies - the
Township police department and if elected the District
Justice's Office. The code enforcement officer would be deemed
associated with the Township as an enforcement officer and if
elected, as a Supervisor.
Samuel M. Snipes
June 11, 1981
Page 3
Conclusion: The above discussion only addresses the require-
ments of the Ethics Act. The Act does not require a public
employee to take a leave of absence before seeking a public
office. A police officer and a Township code enforcement
officer need not take a leave of absence before running for
public office as a District Justice and Township Supervisor
respectively.
The statute proscribes acceptance by a candidate for
public office of anything of value based on any understanding
that an official action would be influenced thereby.
Persons holding two public positions must observe the
Ethics Act in both positions, as a police officer and a District
Justice, if elected, or as a code enforcement officer and, if
elected, as a Township Supervisor. No ublic official or
employee should use any of his public office(s) or confidential
information received through public office(s) to obtain
financial gain. Nor may tie public official or employee accept
anything of value based on any understanding that any official
act would be influenced thereby.
The public official, his immediate family, or a business
in which he or a member of his immediate family is a director,
officer or holder of stock valued at greater than 5% of the
equity at fair market value may contract with any governmental
body with which the official is associated only if the contract,
valued at more than $500, is awarded through an open and public
process.
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 tacts 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
Si cerely,
Z ee/4-.4'52
ra . M r stianson
General C. nsel