HomeMy WebLinkAbout83-625 CerasoJoseph W. Ceraso, Esquire
618 Wallace Street
P.O. Box 66, Park Station
Vandergrift, PA 15690 -0866
Dear Mr. Ceraso:
Mailing Address
STATE ETHICS COMMISSION
P.O. BOX 1179
HARRISBURG, PA 17108
TELEPHONE: (717) 783 -1610
December 12, 1983
ADVICE OF COUNSEL
83 -625
RE: Kiski Vally Water Pollution Control Authority, Borough Office
This responds to your letter of November 21, 1983, in which you, as
Solicitor for an Authority, requested advice from the State Ethics
Commission.
Issue: You ask whether there is a conflict of interest when a board member of
a municipal authority serves as a borough official under certain
circumstances.
Facts: As Solicitor for the Kiski Valley Water Pollution Control Authority,
hereinafter the Authority. You state that the Authority was created pursuant
to the Municipality Authorities Act of May 18, 1945, for the purpose of
operating a sewer system and a sewage treatment plant. The Authority was
created by 13 municipalities each of which appoints one member to the
governing board of the authority for a five year term.
At the recent municipal election one of the members who is currently
serving as a member of the Board of the Authority was elected as a member of
the Council in a Borough which is one of the 13 municipalities served by the
Authority. This member of the Authority Board has a term which expires on the
first Monday of January, 1987. As a member of Borough Council, he has been
elected to a term of office of four years beginning on the first Monday of
January, 1984.
State Ethics Commission • 308 Finance Building • Harrisburg, Pennsylvania
Joseph W. Ceraso, Esquire
December 12, 1983
Page 2
Discussion: As a member of Borough Council the individual about whose conduct
you inquire, as Solicitor, will be considered a "public official" es that term
is defined in the State Ethics Act. As a member of the Authority, there is
some question as to whether this individual is also a "public official" as
that term is defined in the Ethics Act., This question arises due to the fact
that you have provided no information upon which to determine whether the
individual in question, when serving as a member of the Authority's Board, is
compensated or not compensated, except for reimbursement fcv actual expenses.
If the individual is not compensated for his service as e member of the Board
of the Authority, he may or may not, in that capacity, be considered a "public
official" depending on the final interpretation and application of the ruling
in Snider v. Thornburgh, 436 A.2d 593, 469 Pa. 159 (1981).
Even given this decision as set forth above, the State Ethics Commission
has not finally determined whether uncompensated me,nbers of an authority
should be considered within the definition of 'public official" as that term
has been defined in the Act and interpreted by the courts. Notwithstanding
this ambiguity, however, and even assuming that this individual might be a
"public official" in both his capacities as a member of Borough Council and a
member of the Board of the Authority, there is nothing in the Ethics Act which
would indicate that it would be inherently inconsistent or incompatible for
this individual to serve in both capacities simultaneously.
Essentially, the Ethics Act requires that a "public official" must
conduct himself in a manner which gives rise to neither a conflict of interest
nor the appearance of a conflict of interest with the public trust. The
Commission has indicated that a conflict would arise when an individual is
serving entities which have interests which aee adverse to one another, See
Alfano, 80 -007. In the situation which you present the interests of the
Borough and the Authority are not adverse to each other. Accordingly, there
is no requirement under the Ethics Act that ,his individual must resign from,
or refuse, one of the two post in order to comply with the provisions of the
Ethics Act.
However, if such an individual continues to serve in both posts, there
may be restrictions placed upon his conduct vis -a -vis his ability as a member
of Borough Council to take or recommend actions or to participate in decisions
of the Borough relative to the Authority. Specifically, this individual
should, as a member of Borough Council, abstain from participating in
discussions and decisions of the Borough relative to such matters of interest
to the Authority as may be presented to the Borough, including, but not
limited to, the appointment or re- appointment of the Borough's representative
on the Board of.the Authority. These problems or decisions which may require
abstention, however, can be dealt with on a case -by -case basis and do not
require that the individual in question resign from his position as either
member of Borough Council or the Board of the Authority.
Joseph W. Ceraso, Esquire
December 12, 1983
Page 3
Conclusion: There is no inherent imcompatibility, under the provisions of the
State Ethics Act, if the member of Borough Council as outlined above were to
continue to serve as a member of the Board of the Authority. Such an
individual, however, as a member of Borough Council, may be required to
abstain from participating in discussions and decisions of the Borough Council
relative to matters of interest of the Authority which may be presented to the
Borough for discussion or decision. These circumstances can be handled on a
case -by -case basis as they may arise in the future. If the individual in
question is required to abstain as outlined above, the reasons for this
abstention should be placed on the public record.
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.
Sincerely,
Sandra S. hristianson
General Counsel
SSC /rdp -