HomeMy WebLinkAbout81-637 PetroneMailing Address.
STATE ETHICS COMMISSION
P.O. BOX 1 179
HARRISBURG, PA 17108
TELEPHONE: (717) 783 -1610
November 9, 1981
ADVICE OF COUNSEL
Representative Thomas C. Petrone
179 Steuben Street
P.O. Box 9557
Wabash Station
Pittsburgh, PA 15220
RE: Campaign, Home Office Use
Dear Representative Petrone:
81 -637
This responds to your communication of September
28, 1981 and subsequent telephone conversations with your
office in which you indicated that you requested advice
from the State Ethics Commission.
Issue: You ask our advice as to whether the Ethics Act
would preclude you as a candidate - incumbent member of the
House of Representatives from utilizing your home office
for campaign purposes, including the use of office tele-
phones.
Discussion: You indicate that next year will be a cam-
paign year for members of the House of Representatives,
and you raised the question of whether or not it is
appropriate, under the Ethics Act, for you to raise
campaign funds and conduct campaign matters from your
home office. You indicate that this potentially includes
the use of office telephones to conduct campaign matters.
The Ethics Act in Section 3(a), 65 P.S. 403(a),
indicates that no public official may use his "public
office ... to obtain financial gain other than the com-
pensation provided by law for himself or a member of
his immediate family or a business with which he is asso-
ciated." The Ethics Act also empowers the Ethics Commission
State Ethics Commission • 308 Finance Building • Harrisburg, Pennsylvania
Representative Thomas C. Petrone
November 9, 1981
Page 2
to address other areas of possible conflict such as the
question you present. In addition, Section 1 of the
Ethics Act states that people of the Commonwealth have
a right to be assured that the financial interests of a
public official present neither a conflict nor an appear-
ance of a conflict of interest with the public trust.
See 65 P.S. 401.
In interpreting these provisions the Ethics Commis-
sion has recently ruled that the use of a district office
for personal fund raising creates at least the appearance
of a conflict of interest between an official's personal
financial interest and his duties as a public official.
See Street, 81 -005. This ruling essentially points out
that use of a district office telephone number as contact
point by an independent group raising funds for a Senator's
personal use creates the appearance of a conflict of
interest and is prohibited by the Ethics Act. Similarly,
the use of a district office for a personal re- election
campaign use would be within the same category of pro-
hibited activities.
Conclusion: As a State Representative you are a public
official subject to the Ethics Act and the use of your
district office including the use of your telephone
number as a contact point for campaign fund raising pur-
poses or other campaign purposes would create at least
the appearance of a conflict of interest between your own
interests and the public interest. This would constitute
a use of public office for your personal, that is, political
gain and should not be undertaken.
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.
Representative Thomas C. Petrone
November 9, 1981
Page 3
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
Siicerely,
2837
cc: Matthew J. Ryan, Speaker
Henry G. Hager, President Pro Tempore
Sandra S. Christianson
General Counsel