HomeMy WebLinkAbout82-602 HinishMr. Howard C. Hinish
Bedford County Commissioner
203 South Juliana Street
Bedford, PA 15522
Dear Mr. Hinish:
RE: Expenses; Abstention; Discretion
Mailing Address:
STATE ETHICS COMMISSION
P.O. BOX 1 179
HARRISBURG, PA 17108
TELEPHONE: (717) 783 -1610
December 21, 1982
ADVICE OF COUNSEL
82 - 602
This responds to your letter of September 10, 1982, at which time you, as
a Bedford County Commissioner, requested advice from the State Ethics
Commission.
Issue: You ask whether, as a Bedford County Commissioner, you may vote, as
one of three Commissioners, to pay expenses incurred by you.
Facts: One of the three Bedford County Commissioners has refused to approve
expenditures incurred by you as a result of you attending several functions
concerning Bedford County. The sum of these expenditures is $101.20. While
one Commissioner refuses to approve paying you your expenses, the other
Commissioner would approve the reimbursement. You, as the third Commissioner,
would like to cast a vote in favor of payment but you are concerned about the
legality or propriety of such an action.
Discussion: The State Ethics Act, 65 P.S. §401 et seq., requires that the
conduct of public officials "present neither a conflict nor the appearance of
a conflict with the public trust." In this regard, it is clear that your
ability to vote in this matter is of a limited nature.
As the Commission understands the facts as presented, the matter at hand
may be separated into three distinct questions;
(1) Whether commissioners are routinely reimbursed for expenses
arising out of official duties;
(2) Whether the expenses herein were incurred as a result of official
business; and
(3) Given (1) and (2) whether those expenditures shall be reimbursed
with your participation.
State Ethics Commission • 308 Finance Building • Harrisburg, Pennsylvania
Mr. Howard C. Hinish
December 21, 1982
Page 2
With regard to the first question, whether commissioners are to be
reimbursed for official expenses, if the answer to that question is not a
routine "yes ", then you may not participate in that decision. Your inability
to engage in this particular area of discussion stems from Section 3(a) and
Section 1 of the Ethics Act, which provide that a public official may not use
his public office to procure financial gain other than that provided by law.
If, however, it is routine to reimburse Commissioners for official
expenditures and such reimbursement is not subject to discretion, the question
becomes whether the expenditures herein were incurred as a result of official
business. If it is not clear that your expenditures were incurred as a result
of official business or if there is an initial determination to be made as to
whether such expenses were incurred as part of your official duties and are
thus properly reimburseable, you may not participate in the decision for the
same reasons given for question (1). We cannot make any definitive ruling on
this point with respect to the particular expenses referred to in your request
as this appears to be a question to be properly addressed to the Commissioners
themselves. If these expenses are not clearly, considered "official" by
policy or past practice or other directive, there appears to be a degree of
discretion involved in whether or not to reimburse.
Only if Commissioners may be reimbursed for official expenses and your
expenses were without question or discretionary judgment permitted as to the
fact of reimbursement, the amount thereof, or as to whether they were incurred
as a result of official business, can you vote upon whether to reimburse
yourself. Where questions (1) and (2) are clearly of a non - discretionary
nature as to whether reimbursement is appropriate and the amount thereof, you
may vote because the basic questions are ministerial.
In its Opinion in Stewart, 79 -070, the Commission considered the question
of whether certain school board directors should abstain from voting on
uncontested bill payments to the employer of a director. Finding that the
routine payment of bills was not in dispute, the Commission imposed no
limitation on the directors in that regard.
Conclusion: Where it is routine to reimburse Commissioners for official
expenses and where such expenses without question -- as set forth in general
County practice, policy or procedures and the amounts thereof are to have been
incurred in the pursuit of official business, you, as a Commissioner, may vote
on whether to approve routine reimbursements to yourself. You may not,
however, vote on the questions of whether your expenditures were incurred as a
result of official business and thus routinely or properly reimbursible or to
Mr. Howard C. Hinish
December 21, 1982
Page 3
set the amount thereof unless the action is not subject to any exercise of
your discretion. It seems that a general policy or procedure on the question
of what expenses are considered official and, therefore, reimburseable can or
should be developed so that the questions of reimbursement may be made clear
and ministerial.
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 will be scheduled and a formal
Opinion from the Commission will be issued. Any such appeal must be made, in
writing, to the Commission within 15 days of service of this Advice pursuant
to 51 Pa. Code 2.12.
CW /rdp
Sincerely,
Sandra S. C istianson
General Counsel