HomeMy WebLinkAbout86-574 GatesSamuel K. Gates, Esquire
250 York Street
Hanover, PA 17331
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
June 19, 1986
ADVICE OF COUNSEL
86 -574
Re: Township Supervisor, Participation Group, Life and Health Insurane
Programs
Dear Mr. Gates:
This responds to your letter of June 5, 1986, wherein you requested the
advice of the State Ethics Commission.
Issue: Whether a township supervisor in a township of the second class, may
participate in a group, life and health insurance program obtained by the
township.
Facts: You currently serve as Solicitor for Jackson Township. In this
capacity, you have requested the advice of the State Ethics Commission in
relation to the above issue. You have advised that the township police
officers, through arbitration, were awarded life insurance and health
insurance benefits. The police force is not of sufficient size to qualify for
a group rate. You indicate, however, if the township supervisors and other
employees were included in the plan, a group rate could be obtained for the
entire township. You advise that you are aware of the various opinions in
relation to a township supervisor's participation in township insurance
programs. You have questioned, however, the ability of a township supervisor,
who is not otherwise an employee of the township, to participate in the group
insurance plan of the township if he reimburses the township for his portion
of the insurance premiums.
Discussion: A township supervisor, in a township of the second class, is
clearly a public official as that term is defined in the State Ethics Act. 65
P.S. .5402. As such, his conduct must conform to the requirements of the Act.
Sowers, 80 -050; Welz, 86 -001.
Samuel K. Gates, Esquire
June 19, 1986
Page 2
Generally, the State 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).
This Commission, on a number of occasions, has previously determined that
within the above provision of law, a township supervisor, in a township of the
second class, may only receive that compensation which is provided for in the
Second Class Township Code. See, McCutcheon v. State Ethics Commission, 77
Pa. Commw. Ct. 529, 466 A.2d 283, (1982). The Township Code generally
provides for a maximum statutory compensation for township supervisors who
serve only in that position. 53 P.S. 65. Additionally, while a township
supervisor may be employed in other capacities by the township, such as
laborer, roadmaster, secretary, treasurer, the compensation to be provided to
a supervisor, who serves in such a position, may only be fixed by the township
board of auditors.
In relation to the foregoing, this Commission has previously determined
that health, medical, and pension benefits are a form of compensation which
may only be awarded to a township supervisor as provided for above. See,
Krane, 84 -001; Cowie, 84 -010. As a result, a township supervisor, who serves
only in that capacity, and is not otherwise employed by the township, may not
receive at the township's expense, health and life insurance benefits. See,
Glova, No. 423 -R ; Hunt, No.384 -R. This position has been uniformly upheld by
a number of judicial decisions. Conrad v. Exeter Township, 27 D & C 3d 253,
(1983); In Re: Auditors Report of Muncy Creek Township, 16 Lycoming Rep.
159, (1985); Synoski v. Hazel Township, Pa. Commw. Ct. , 500 A.2d 1282,
(1985).
While it is clear from the above provisions of law that the township
supervisors involved herein, may not receive, at the township's expense, the
health benefit set forth in your letter, to date there is no case and no
Commission opinion which has indicated that a township supervisor may not
otherwise participate in a group rate program obtained by the township if the
supervisor pays for the premiums for his participation in such program.
Previous advices of this Commission have indicated that the State Ethics Act
would not appear to prohibit this type of activity. See, Krane, 84 -001;
Siffin, 86 -502. As a result, it is advised that at the current time, there is
no prohibition to a township supervisor's participation in a health and life
insurance program obtained by the township if the township supervisor
Samuel K. Gates, Esquire
June 19, 1986
Page 3
reimburses the township for the premiums expended on his behalf. It is
advised that if the supervisors, in question, do participate in the program as
set forth herein, that the procedures for their participation and
reimbursement to the township be formulated prior to their actual
participation in the program. Additionally, it is advised that the fact that
the supervi sors wi 11 be partici pati ng i n the pl an and the fact that they
will be reimbursing the township for their share of the premiums, be publicly
set forth during a township meeting and appropriately recorded in the township
mi nutes.
Conclusion: A township supervisor is a public official within the purview of
the State Ethics Act. As such, a supervisor may not receive, at the
township's expense, health and life insurance benefits if said supervisor only
serves in the supervisory capacity. There is no prohibition at the current
time' upon a supervisor's participation in a group rate program obtained by the
township if the township supervisor reimburses the township for premiums
relating to his coverage. The procedures for the supervisor's participation
in the program and his reimbursement in the township be established prior to
the effective date of the program. Additionally, it is advised that the
supervisor's participation in the program and the fact that he will be
reimbursing the township, therefore, be set forth publicly and appropriately
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.
Si nce
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Gene Counsel