HomeMy WebLinkAbout86-527 SmithMr. Al Smith
P.O. Box 26
New Freedom, PA 17349
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
March 17, 1986
ADVICE OF COUNSEL
Re: Borough Councilmember, Voting, Zoning Ordinance
Dear Mr. Smith:
86 - 527
This responds to your letter of February 19, 1986, wherein you requested
the advice of the State Ethics Commission.
Issue: Whether a borough councilmemher may participate in the council's
consideration of a zoning ordinance that effects a business owned by a member
of the horough council.
Facts: You have advised that you are an elected member of the New Freedom
Borough Council, York County, Pennsylvania. You are also the president and
majority stockholder of AJS Incorporated, a Pennsylvania business corporation.
You have advised that in 1983, prior to your election to borough council, the
council voted to change the zoning of property owned by this corporation from
residential to village and directed the borough solicitor to advertise and
prepare appropriate ordinances. You further advise that for unknown reasons
the ordinance was not prepared at that time although the York County Planning
Commission and New Freedom Borough Planning Commission had recommended
approval of the zoning re- classification. In 1984, approximately one year
later, final passage of the ordinance was presented to the borough council and
was rejected by one vote. You indicate that the area to be re- classified has
been continuously used for business purposes for approximately forty years.
You have further advised that it is your belief that the original zoning
classification for this area, which is currently residential, was occasioned
by a mistake. The matter is now heing presented, once again, to the borough
council for reconsideration and you have requested the advice of the State
Ethics Commission as to whether you can participate in the borough's decision
to re -zone this particular property, which includes the parcel of land owned
by your business enterprise.
Mr. Al Smith
March 17, 1986
Page 2
Discussion: As an elected member of the borough council, you are a public
official as that term is defined in the State Ethics Act. 65 P.S. §402. As
such, your conduct must conform to the requirements of the State Ethics Act.
See Davis, 84 -012.
Generally, the Ethics Act provides as follows:
Section 3. Restricted activities.
(a) No public official or public employee shall use his
public office or any confidential information received
through his holding public office to obtain financial gain
other than compensation provided by law for himself, a
member of his immediate family, or a business with which
he is associated. 65 P.S. 403(a).
Within the above provision of law, no public official may use his public
position in order to obtain any financial gain for himself a member of his
family or a business with which he is associated. He may not use confidential
information obtained in his public position for similar purposes. The State
Ethics Act defines a business with which one is associated as follows:
Section 2. Definitions.
"Business with which he is associated." Any business in
which the person or a member of the person's immediate
family is a director, officer, owner, employee or holder
of stock. 65 P.S. 402.
Clearly, as owner of AJS Incorporated, you are associated with that
business within the purview of the State Ethics Act and, thus, you may not use
your public position as a borough councilmember in order to obtain any
financial gain or benefit for that corporation.
The Commission has, on a number of occasions, reviewed similar situations
involving a public official's participation in a zoning ordinance wherein he
has an interest. As such, the Commission has previously determined that
public officials may not participate or vote in a matter regarding a zoning
ordinance or a zoning re- classification if the classification would
specifically relate to property in which the public official has an interest.
See Hahalis, 83 -009; Alberstadt, 85 -526; Rudnitsky, 82 -552. There is no doubt
that in the instant situation you have a vested financial interest in the
continued operation of the AJS Incorporated Enterprise. The passage of a
borough ordinance would re- classify the use of the property on which this
enterprise is located as commercial. Thus, there is no doubt that the company
with which you are associated could continue to operate on this property if
the borough were to re- classify the zoning for this locale. As a result, you
have a vested interest of a financial nature in the borough's decision in this
Mr. Al Smith
March 17, 1986
Page 3
matter. Because of this interest as a public official, you may not
participate in the borough's consideration, discussion and vote in this
matter. We note that you have indicated your belief that the borough's
consideration of this matter is merely a continuation of that which was
initiated in 1983, a time when you did not serve as borough councilmember.
The fact, however, that the matter was initiated at a time prior to your
service from borough council and continued into a period of time when you now
serve as borough council does not alleviate the fact that you are now a public
official and may not participate in the matter wherein you have a vested
fi nanci al interest. The proposition that a publi c official may not
participate or otherwise vote on a matter wherein he has such an interests is
well established in the law. See Genkinger v. New Castle, 368 Pa. 547, 84
A.2d 303, (1951); Raynovich v. Romans, 450 Pa. 391, 299 A.2d 301, (1973);
Department of State v. Mount Joy Borough, 66 D & C 251, (1948).
As a result of the foregoing, you are advised that you must abstain from
all participation in the borough's consideration of the zoning ordinance in
this matter. Your abstention in this matter should be publicly noted and
recorded in appropriate borough minutes.
C. Conclusion: A borough councilmember may not participate in the borough's
consideration and decision on a zoning re- classification ordinance which
specifically effects property on which a corporation that is owned by the
borough councilmember is located. Said borough councilmember must abstain
from all participation in the matter and his abstention must be publicly noted
and recorded.
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.
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G eral Counsel