HomeMy WebLinkAbout81-634 HunterJames Oliver Hunter, Esquire
3209 Cathedral of Learning
Pittsburgh, PA 15260
Mailin Address
STATE ETHICS COMMISSION
P.O. BOX 1 179
HARRISBURG, PA 17108
TELEPHONE: (717) 783 -1610
November 2, 1981
ADVICE OF COUNSEL
81 - 634
RE: University of Pittsburgh Trustees, Employees, Appli-
cability of Ethics Act
Dear Mr. Hunter:
This responds to your letter of October 3, 1980 in
which you, Assistant Counsel to the University of Pitts-
burgh, requested an opinion from the Ethics Commission.
Issue: You requested advice as to whether the trustees
and employees of the University of Pittsburgh (herein-
after the University or Pitt) are subject to the Ethics
Act.
Facts: In your letter you state that the trustees of the
University are not compensated for their services. Em-
ployees of the University are compensated.
The University of Pittsburgh was a private educa-
tional institution until the enactment of the University
of Pittsburgh - Commonwealth Act, 24 P.S. Section 2510-
201 et seq. Pitt then became one of several state - related
educational institutions, 24 P.S. Section 5009. As a
state - related institution the composition of the Univer-
sity's Board of Trustees is regulated by statute. 24
P.S. Section 2501 -204.
Pitt's voting trustees are 36 in number. The Chan-
cellor of the Univeristy, the Governor, the Superintendent
State Ethics Commission • 308 Finance Building • Harrisburg, Pennsylvania
James Oliver Hunter, Esquire
November 2, 1981
Page 2
of Public Instruction and the Mayor of Pittsburgh are
trustees ex officio. Twelve trustees are designated
Commonwealth Trustees and four of these are appointed
by the Governor subject to Senate confirmation (24 P.S.
2510 -203); and the President pro Tempore of the Senate
and the Speaker of the House of Representatives each
appoint four Commonwealth Trustees. The remaining twenty -
four trustees are elected under the provisions of the
University's by -laws. Id.
Discussion: While a federal court has expressed the belief
that Pitt is an instrumentality of the state for purposes
of a sex discrimination suit brought pursuant to 42 U.S.C.
Section 1983, Braden v. University of Pittsburgh, 477
F.2d 1 (3rd Cir. 1973). on remand 392 F.Supp 118 (W.D.
PA 1975), aff'd case remanded 552 F.2d 948 (3rd Cir.
1977), that view is not conclusive. In McQuaide 80 -043,
the Ethics Commission held that definitions of the Ethics
Act did not extend coverage of the Ethics Act to the
trustees and employees of the Pennsylvania State Uni-
versity. That opinion is controlling on this question
of the interpretation of the Ethics Act.
The statute applies only to individuals "employed
by the Commonwealth or a political subdivision" or to
an "elected or appointed official in the Executive,
Legislative or Judicial Branch of the State or any
political subdivision." 65 P.S. Section 402. Pitt is
a state - related not a state -owned institution. Pitt
is not the Commonwealth by virtue of state ownership.
As a state - related university, Pitt is similar to Temple
University which has been held not even to constitute
"an agency" of the Commonwealth for a statutory purpose.
Mooney v. Temple University, 448 Pa. 424, 292 A.2d 395
(1972). The Commission reasoned that "weight must be
given to the conclusion that Penn State is not the
Commonwealth or even typically described or considered
an agency of the Commonwealth." McQuaide, 80 -043. Pitt
is similar to Penn State if not more unrelated, legally,
to the State, so that it too must be considered not part
of the Commonwealth, a Commonwealth agency or of a poli-
tical subdivision as set forth in the Ethics Act.
James Oliver Hunter, Esquire
November 2, 1981
Page 3
This conclusion is supported by another part of the
Commission's McQuaide Opinion. That decision gave great
weight to the fact that while Penn State received state
funds, its Board of Trustees was not controlled by the
state appointed officials. Pitt's Board of Trustees
has 12 state - appointed members and 24 chosen under Uni-
versity rules. Pitt too, is plainly not under state
control.
Thus, the trustees and employees of the University
of Pittsburgh are not generally within the definition of
"public official" and "public employee" as those terms
are used in the Ethics Act. See McQuaide, 80 -043.
However, those trustees appointed by the Govenor subject
to Senate confirmation must comply with Section 4(c) of
the Ethics Act which requires the filing of a Financial
Interest Statement at least ten days prior to any vote
on confirmation. Hollander, 80 -037.
Conclusion: The trustees and employees of the University
of Pittsburgh are generally not public officials or public
employees within the meaning of the Ethics Act. However,
this Advice has no effect of discharging any trustee's
duty to file a Financial Interest Statement by virtue of
other posts held or by application of Section 4(c) of the
Ethics Act as described above.
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.
SSC /lma
ni9F
Sincerely,
ndra S. hristianson
General Counsel