HomeMy WebLinkAbout83-537 BrownMs. Linda L. Brown
North & South Shenango
Joint Municipal Authority
RR #1, Box 12A
Jamestown, PA 16134
Mailing Address.
STATE ETHICS COMMISSION
P.O. BOX 1 179
HARRISBURG, PA 17108
TELEPIjONE: (717) 783 -1610
April 12, 1983
ADVICE OF COUNSEL
fir 531
State Ethics Commission • 308 Finance Building • Harrisburg, Pennsylvania
RE: Joint Muniicipal Authority; Board Member; General Manager; Abstention
Dear Ms. Brown:
This responds to your letters of January 27 and February 5, 1983, in
which you requested advice from the State Ethics Commission.
Issue: You ask what your duties, as an unpaid secretary of the Board of the
North and South Shenango Joint Municipal Authority and as a compensated
General Manager for the Authrority, are with regard to the Ethics Act.
Facts: The North and South Shenango Joint Municipal Authority is governed by
a six member Board. Three members are appointed by North Shenango Township
and three by South Shenango Township.
You, the Secretary of the Board, were appointed in May, 1981 and served
without compensation until May 1, 1982. At that time the Board appointed you
as General Manager and placed you on salary, while also retaining you as the
uncompensated Secretary of the Board.
As General Manager, you can recommend procurement and repair of items for
the plant and system. As Secretary of the Board, you have one vote in six
with regard to the payment of invoices.
You have filed a Statement of Financial Interests with your local
political subdivision, that is, the North and South Shenango Joint Municipal
Authority, and are concerned about your duties under the State Ethics Act.
Ms. Linda L. Brown
April 12, 1983
Page 2
Discussion: As Secretary of the Board, you may or may not be requied to file
a Financial Interest Statement with the State Ethics Commission. The decision
in Snider v. Thornburgh, Pa. , 436 A.2d 593 (1981) has apparently
altered the definition of public ficial" by removing the exclusion which
thereto applied to appointed non - compensated officials. Although the
Commission has not yet completed its review of the decision, it should be
noted that the thrust of Commission policy in recent years has been toward a
broad, but fair interpretation of the coverage of the Act, with a
corresponding reduction of exemptions from the need to file Statements of
Financial Interest. The Commission's decision in Bert, 80 -013, and Corapi,
81 -644, which found "coverage" under the Ethics Act as to redevelopment
authorities, and the Commonwealth Court's decision in
Forney v. State Ethic Commission, Pa. Cmwlth. , 425 A.2d 66 (1980),
which did the same for municipal authorities, are examples of this trend.
While these rulings did not answer the specific question of appointed,
non- compensated board members filing, they do indicate the basic thrust that
"coverage" is favored over exemption. At this point in time, however, as an
uncompensated Board member you are under no obligation to file with the Ethics
Commission until new regulations are promulgated or take effect. In that
event you will be fully instructed as to your duties and responsibilities in
sufficient time to comply with them.
However, whether or not you are a public official as an uncompensated
Board member, you, in your capacity as the compensated General Manager for the
Authority, are a public employee within the definition of that term under the
Ethics Act. See 65 P.S. 402. As a public employee, you are subject to the
provisions of the Ethics Act.
The Ethics Act requires you to avoid conflicts of interest or even the
appearance of a conflict of interest with the public trust. See 65 P.S. 401
and 403. In its opinion in Alfano, 80 -007, the Commission indicated that
serving or holding two positions would constitute a conflict of interest only
where the individual in such service would represent the interests of two or
more persons whose interests are adverse to one another. In your situtation
we cannot discern any per se conflict of interest, and you do not violate the
Ethics Act by holding the positions of uncompensated secretary of the board
and compensated general manager.
Of course, should you as secretary of the board be required to vote on
matters placed before the Board by you as general manager, you should abstain
from such participation, discussion or votes while you continue to hold both
positions.
Ms. Linda L. Brown
April 12, 1983
Page 3
In addition, we note that Sections 3(a) and (b) of the Ethics Act must be
observed. These Sections provide that no public employee may use his public
office to obtain financial gain other than compensation provided by law for
himself or accept any thing of value, including the promise of future
employment, based on the understanding that his official conduct would be
influenced thereby. We present these cautions only as guides for future
conduct so that you may be aware of these provisions of the Ethics Act.
Conclusion: While you may o r may not be required to file a Financial Interest
Statement with the State Ethics Commission as an uncompensated member of the
Board of the North and South Shenango Joint Municipal Authority in your
capacity as compensated general manager to the Authority, you are a public
official and so must file a Statement of Financial Interests. As a Board
member, you must abstain from participation in matters set before the Board by
you in your capacity as general manager, and your future conduct must be
guided by the cautions expressed in this Advice and contained in the Ethis
Act. We note this request does not raise any questions as to the employment
process by which you were selected as General Manager and this Advice,
therefore, does not address the application of Section 3(c) of the Ethics Act
to this case.
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.
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 cf service of this Advice pursuant
to 51 Pa. Code 2.12.
CW /rdp
This letter is a public record and will be made available as such.
Sincerely,
LAS va4 /
Sandra S. Christ) nson
General Counsel/