HomeMy WebLinkAbout86-579 LaubeMr. F. H. Lauhe
328 Fifth Street
Freeport, PA 16229
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
July 1, 1986
ADVICE OF COUNSEL
86 - 579
Re: Statement of Financial Interests, Members, Municipal Parking Authority
Dear Mr. Laube:
This responds to your letter of May 29, 1986, wherein you requested the
advice of the State Ethics Commission.
Issue: Whether members of a municipal parking authority are required to file
Statements of Financial Interests within the purview of the State Ethics Act.
Facts: You have requested the advice of the State Ethics Commission as a
member of the Freeport Parking Authority. The parking authority consists of
five memhers who operate the authority on a volunteer basis. You indicate
that the group is advisory in nature and generally has been empowered to help
overcome a parking problem in your community. The members of the board are
not compensated. The memhers of the hoard are appointed by the Freeport
Rorough Council. You advise that the authority is not involved in acquiring,
selling, or renting property. The parking authority was created in 1980
pursuant to a Parking Authority Law. 53 P.S. .5343.
Discussion: As you are probably aware, the State Ethics Commission has
recently determined that appointed /non- compensated memhers of municipal
authorities are puhlic officials within the purview of the State Ethics Act
and, thereby, required to file Statements of Financial Interests in accordance
with the Act. Dice, 85 -021. Generally, the Commission's determination in
that matter was based upon the definition of puhlic official which provides
as follows:
Mr. F. H. Laube
July 1, 1986
Page 2
Section 2. Definitions.
"Public official ." Any elected or appointed official i n
the Executive, Legislative or Judicial Branch of the State
or any political subdivision thereof, provided that it
shall not include members of advisory boards that have no
authority to expend public funds other than reimbursement
for personal expense, or to otherwise exercise the power
of the State or any political subdivision thereof.
"Public official" shall not include any appointed official
who receives no compensation other than reimbursement for
actual expenses. 65 P.S. 402.
As originally promulgated, the above definition exempted from Ethics Act
coverage members of municipal authorities who were appointed and not
compensated. The Supreme Court of Pennsylvania, however, has subsequently
ruled that the above definition is unconstitutional insofar as it exempted
appointed /non - compensated officials. The result reached by the Supreme Court,
in its decision, was to excise that exemption from the statutory language of
the State Ethics Act. Therefore, the Commission's determination in the Dice
opinion was based upon the fact that the definition of public official must be
read without the above exemption. See, Snider v. Thornburgh, 469 Pa. 159, 436
A.2d 593, (1981).
The Commission's opinion in Dice, however, was strictly limited to
authorities created under the Municipal Authorities Act of 1945. 53 P.S. §301
et. seq. In the instant situation, the authority on which you serve was not
created under that particular provision of law. The authority on which you
serve was created under the Parking Authority Act of 1947. 53 P.S. §341. The
Commission, to -date, has not expanded the filing requirement to other boards,
commissions and authorities whose members are appointed and non - compensated.
The Commission, however, in the Dice opinion did indicate that the Commission
would, in the future, promulgate rules and regulations to implement the
Supreme Court's Snider decision and to act as guidelines regarding what other
boards, commissions and authorites may be covered by the State Ethics Act.
Pending the promulgation of those regulations, however, the Commission has not
extended the filing requirement to other boards and commissions that may now
be covered. As such, at the current time, members of the Freeport Parking
Authority are not required to file Statements of Financial Interests in
accordance with the Act. You are advised that the Commission is currently in
the process of publishing the proposed rules and regulations in the
Pennsylvania Bulletin. These proposed regulations may effect your board and
may result in the requirement that the members of your authority file
Statements of Financial Interests. As such, you should be aware of the
Mr. F. H. Laube
July 1, 1986
Page 3
promulgation of such rules and regulations as the proposed notice in the
Pennsylvania Bulletin will provide for a thirty day period for public comment.
You may wish to offer your comment to the proposed rules and regulations that
appear in the Pennsylvania Bulletin. These proposals will appear prior to the
final adoption of the rules and regulations by the Commission. Your borough
solicitor should be able to keep you advised as to these developments.
Conclusion: Members of a borough parking authority, created under the Parking
Authority Law of 1947, are not at the current time required to file Statements
of Financial Interests in accordance with the State Ethics Act. Rules and
regulations that may change this particular result will be published in the
near future and you should be kept advise as to future developments.
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 truthful ly 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.
JJC /sfd
Si ncerely,
ontiYro
General Counsel