HomeMy WebLinkAbout82-558 TorlidasWilliam L. Torlidas, P.H.D.
Superintendent
South Park School District
2178 Ridge Road
Library, PA 15129
Dear Superintendent Torlidas:
Mailing Address:
STATE ETHICS COMMISSION
P.O. BOX 1 179
HARRISBURG, PA 17108
TELEPHONE: (717) 783 -1610
June 29, 1982
ADVICE OF COUNSEL
82 -558
RE: School Directors, Union Negotiations, Abstention
This responds to your communication of May 6, 1982 in
which you requested advice from the State Ethics Commission.
Issue: You request information as to whether a possible
conflict is presented where members of a school board have
relatives on the school district faculty or as members of
the admininstative offices of the school district and are
requested to participate in contract negotiations between
the teachers union and the school board.
Facts: As superintendent for the South Park School Board
you indicate that one of the directors (Roy Bruno) has a
wife who is a member of the school district faculty.
Another school director (John Broglie) has a married
daughter and a son who are not living in his household but
who are serving the school district in the capacity of a
member of the faculty and a middle school principal respec-
tively. Neither of Mr. Broglie's children live with him or
are dependent upon him.
The South Park School Board is currently negotiating
with the teacher's union and is planning strategy sessions
in connection with these negotiations.
State Ethics Commission • 308 Finance Building • Harrisburg, Pennsylvania
William L. Torlidas, P.H.U.
June 25, 1982
Page 2
Discussion: School board directors are "public officials"
as defined by the Ethics Act, 65 P.S. 402. They are, therefore,
prohibited from using their public office to obtain financial
gain other than the compensation provided by law for themselves,
members of their immediate family or any business with which
they might be associated. See 63 P.S. 403(a). The Ethics
Act defines "immediate family" as a spouse living in the
official's household and minor dependent children. See 65
P.S. 401. Thus, the fact that Director Broglie has a son or
daughter who might be affected by the contract negotiations
does not per se present any problem under Section 3(a) of
the Ethics Act. However, Director Bruno would be in a
position under Section 3(a) of the Ethics Act to gain
financially (through his wife's salary and fringe benefit
increases) from his use of his vote for the benefit of
his "immediate family."
In addition, school directors would be bound by the
directive of the Ethics Act that they should avoid the
appearance of a conflict of interest with the public trust
as prohibited by Section 1 of the Ethics Act. See 65 P.S.
401. Under Section 1`it has generally been held that the
spouses of faculty members must not directly or indirectly
approve their spouse's particular contract or amendments
thereto. See Reid, 82 -520. In addition, the Commission has
indicated that where a particular wage or salary increase is
being suggested for a brother of a public official, abstention
is also required as to that particular vote. Leete, 82 -005.
Thus, each Director must likewise abstain from voting to
grant his spouse or children any form of individual benefit,
such as a sabatical'or pay rise or taking disciplinary
action involving his spouse or children as individuals.
There is, however, nothing that would prohibit the
board members from voting on contracts or other policy
measures that would affect faculty members or administrative
personnel as a group or as a whole and in which the only
benefit accrued by the member's spouse or children would be
that which would accrue to them in their capacity as
faculty /administration members. Stewart, 79 -070.
William L. Torlidas, P.H.D.
June 25, 1982
Page 3
Each board member should also be cautioned that Section
3(a) of the Ethics Act also prohibits the use of confidential
information by a public official to obtain financial gain
other than the compensation provided by law. Thus, neither
school director may pass along information of a confidential
nature -- obtained through strategy sessions -- to his
spouse or children so as to enhance those persons' positions
in the current contract negotiations. See Reid, supra.
Conclusion: The school board members in this instance,
within the confines of the Ethics Act, may participate in
all activities relating to their duties as directors,
including votes on collective bargaining agreements and
participating in strategy sessions associated with these
negotiations, but are required to abstain from taking any
action on any measure which relates specifically to a spouse
or child as individuals. A board member may not transmit
any information gained through a strategy or negotiation
session to a spouse or child if such information could be
used by the spouse or child to influence the negotiations or
which could be used to the financial benefit of the spouse
or the child.
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 /rdp
Sincerely,
n ra S.
General Couvsel
Mailing Address:
STATE ETHICS COMMISSION
P.O. BOX 1 179
HARRISBURG, PA 17108
TELEPHONE: (717) 783 -1610
October 1, 1982
' James Flaherty, Esquire
Baskin & Sears
10th Floor Frick Building
Pittsburgh, PA 15219
Re: South Park School District, Adivce No. 82 -558
Dear Mr. Flaherty:
• Addendum to Advice 82 -558
This responds to your letter of September 17, 1982, in which you
requested some further clarification of Advice No. 82 -558, originally issued
as set forth above. Your letter correctly expresses both the intent and
extent of the Advice originally issued. Specifically, any Advice rendered
under the provisions of the State Ethics Act, 65 P.S. 407 (9)(i), relates only
to the duties and responsibilities of an individual under "this act ", that is
Act 170 of 1978. As such, the conclusion set forth in Advice No. 82 -558
which discusses the duties and responsibilities of the School Directors is
confined to a discussion of and an articulation of those responsibilities as
contained in the State Ethics Act.
Further, that Advice did not and was not intended to discuss, apply to,
or supersede, any provisions of any other statute, including Act 195, 43 P.S.
1101.1801, in particular. As you request in your letter, this clarification
will be attached to and made a part of the Advice originally issued in this
case. Incidentally, given this clarification, I assume that it will no longer
be necessary for the Commission to reconsider the Advice originally issued as
you had requested in your letter of July 26, 1982. If you still wish the
entire Commission to consider this matter, please advise. Otherwise, with the
addition of this letter of clarification to Advice No. 82 -558, as set forth
above, we will consider this matter closed.
SSC /na
cc: Steven S. Russell, Esq.
te''td .1 tic CZa,2
andra S. Chr'stianson
General Coun el
State Ethics Commission • 308 Finance Building • Harrisburg, Pennsylvania