HomeMy WebLinkAbout82-540 KunkleMr. Mark A. Kunkle
11 Carverton Road
Trucksville, PA 18708
Dear Mr. Kunkle:
Mailing Address
STATE ETHICS COMMISSION
P.O. BOX 1 179
HARRISBURG, PA 17108
TELEPHONE: (717) 783 -1610
May 10, 1982
ADVICE OF COUNSEL
RE: Constables, Financial Interest Statements
82 - 540
This responds to your letter of October 16, 1980, in which you, as
Township Manager of Kingston Township, requested an opinion from the Ethics
Commission.
Issue: Your communication poses two questions, one, whether an employee of an
engineering firm employed by the Township may serve as a constable; and two,
whether an appointed constable must file a Statement of Financial Interest.
Facts: You informed us that Kingston Township, a home rule municipality, is
considering the appointment of a constable. One of the candidates for the
position is an employee of an engineering firm. This firm has done and will
do work for Kingston Township.
Discussion: The Ethics Act as codified at 65 P.S. Section 401 et seq. defines
public official as Any elected or appointed official in the Execuuive,
Legislative or Judicial Branch of ... a political subdivision ... 65 P.S.
Section 402. Because the constable of Kingston Township will hold an
appointed position in the Judicial Branch or a political subdivision, the
constable is subject to the Ethics Act unless some other circumstances
intervene.
As explained by the S recher, 82 -532 ruling (copy attached) at the
present time the State Et ics Commission is not requiring financial filings
from incumbent constables (elected or appointed). This ruling applies to the
second question you raise if the appointee is an incumbent to be
re- appointed.
This ruling does not effect the requirement that non - incumbent
"candidates" for the post of constable are, in the Commission's estimation,
required to file Financial Interest Statements as candidates for that office.
Thus, a non - incumbent who is not currently serving as part of the "judicial
system" would still be required to file a Statement of Financial Interest as
mandated by the Act, 65 P.S. §404(c). The information that must be provided
is specified in 65 P.S. §405. The Financial Interest Statement is f }hed
accor to the Regulations promulgated by the Ethics Commission.
Regulations 51 Pa. Code 4.3 provide that:
State Ethics Commission • 308 Finance Building • Harrisburg, Pennsylvania
Mr. Mark A. Kunkle
.day 10, 1982
Page 2
(c) Any person appointed i:,s ar official not subject to
confirmation in any governing body other than those
specified in subsection (b) of this section shall file a
Statement of Financial Interests only with his governing
body by May 1 of the year appointed or within 15 days if
appointed after May 1.
Thus, the potential constable who is not an incumbent must file a
Financial Interest Statement with the governmental body that will appoint the
constable, the Board of Supervisors.
However, even assuming the constable you appoint would be within the
purview of the Ethics Act, there is nothing inherently inconsistent with this
same person also being employed as an employee of the Township's engineering
firm . The Act does not, in general, prohibit one person from holding two
posts in one governmental unit, see Dissinger, 79 -015; Coon, 79 -016; Hock,
79 -017. It does not forbid a public official from acting as a constable while
doing work as an engineer for the Township.
As a public official a constable has certain duties under the Ethics Act.
The constable must not use his office or confidential information obtained by
his holding public office to obtain financial gain for himself, his immediate
family or a business with which he is associated. 65 P.S. §403(a). Thus, the
constable cannot use his office or confidential information to benefit his
employer, the engineering firm.
Conclusion: Pending the Supreme Court's determination in the Kremer case, the
Ethics Commission, at its discretion, will apply the same policy to incumbent
constables as it is currently applying to incumbent members of the judiciary
itself. Thus, incumbent constables, elected or appointed as incumbents or
candidates for re- election or re- appointment need not file Financial Interest
Statements at this time. A non - incumbent candidate for election or
appointment, however, must file a Financial Interest Statement.
There is no inherent prohibition against a constable being appointed who
is also an employee of the Township's engineering firm.
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.
Mr. Mark A. Kunkle
May 10, 1982
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
Sincerely,
Sandra S. Chri ianson
General Counsel
P.S. I apologize for the long delay in responding. We tried
several times from April 26 - May 6, 1982 to contact you by
phone to explain this delay. Basically, pending Court cases and
the need to analyze and apply Court rulings caused us to "hold"
responding.
On the question of the appointment of the person subject to your
original request, assuming he was a non - incumbent and did receive
the appointment, our delay in responding compels me to conclude
that this particular person need not retroactively file a Financial
Interest Statement. This Advice will operate prospectively only.