HomeMy WebLinkAbout81-599 PrattRalph D. Pratt, Member
House of Representatives
Commonwealth. of Pennsylvania
328 Main Capitol Building
Harrisburg, PA 1712 :.'
RE: Position as Solicitor
Dear Representative Pratt:
Mailing Address:
STATE ETHICS COMMISSION
P.G. BOX 1179
HARRISBURG, PA 17108
TEI_ErHONE: (717) 783 -1610
August 11, 1981
ADVICE Oh' COUNSEL
81-599
This responds to your communication of July 9, 1981 in
which you requested advice of the Ethics Commission.
Issue: You inquire as to whether there is a conflict of
interest if a State Legislator were to accept and assume the
position of Solicitor for a second class township in
Pennsylvania
Facts: You currently serve as a member of the House of
Representatives serving the 10th Legislative District. You
have been offered the position as Solicitor for the Township
of Shenango in Lawrence County, Pennsylvania. This Township
is not part of your Legislative District.
Discussion: The Ethics Act defines a "public official" as
any elected official within the Legislative Branch. Obviously,
you are a "public official" within the purview of the Ethics
Act.
However, the statute does not require that public
officials refrain from all other professional or business.
ventures. Indeed, the State Ethics Commission has held that
an individual may serve as Solicitor for more than one
political entity simultaneously. King, 79 -034. Simulta-
neous service would be prohibited only if a "conflict of
interest" existed. The Ethics Commission has defined
State Ethics Commission • 308 Finance Building • Harrisburg, Pennsylvania
Ralph D. Pratt, Member
August 11, 1981
Page 2
"conflict of interest" as existing when an individual .
represents two or more persons whose interests are adverse
to each other. Alfano, 80 -007. There does not appear to be
a per se conflict between the interests of the Township of
Shenango which you would serve as solicitor and the
interests of the House of Representatives or your consti-
tutents who you serve as a member.
Accordingly, there is no per se conflict of interest
present for a member of the Legislature, such as yourself,
to serve in the position as Solicitor for this second class
township.
Of course, the Ethics Act does impose some general
requirements on any person serving in public office. There
requirements include the prohibition against use of public
office or confidential information received through the
holding of public office to obtain financial gain for one'-,
self or one's immediate family. 65 P.S. 403(a).. in
addition, no one may give or offer to any public official
any thing of value, including the promise of future employ-
ment, based on the understanding that his official actions
would be influenced thereby. 65 P.S. 403(c). These require-
ments are mentioned as general requirements and your conduct
as a member of the Hcuse as well as an official (Solicitor)
of the Township of Shenango should be guided by these
concerns.
In addition, any Financial Interest Statement which you
would be required to file should reflect your income in excess
of $500, if such is received from the Township of Shenango,
as Solicitor. Until the Supreme Court determines whether
Solicitors are required to file Financial Interest State-
ments you would not be required to file a Financial Interest
Statement with the Township of Shenango should you accept
the solicitorship which has been offered.
Conclusion: A member of the House of Representatives is not
prohibited under the Ethics Act, per se, from accepting a
position as Solicitor for a township of the second class.
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.
Ralph D. Pratt, Member
August 11, 1981
Page 3
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.
SSC /rdp
cc: Matthew J. Ryan, Speaker
House of Representatives
Sincerely,
Sandra S. ristianson
General C unsel