HomeMy WebLinkAbout86-584A HattenMr. Earl R. Hatton
Box 676, U.S.
Route 1 at Long Wood
Kennett Square, PA 19348
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PA 17120
TELEPHONE: (717) 783 -1610
December 8, 1987
ADVICE OF COUNSEL
86 -584A
Re: Conflict of Interest, Township Supervisor, Township Real Estate Sales
Agent, Voting on Zoning Ordinances
Dear Mr. Hatton:
This responds to your letter of November 9, 1987, wherein you requested
additional advice of the State Ethics Commission.
Issue: Whether a township supervisor, who is a real estate associate in the
township, may vote on zoning and subdivision ordinances.
Facts: You state that you are the Chairman of the Board of Supervisors in
Penn Township and are engaged in selling real estate. You state that you
requested an advice from the Commission which issued Advice of Counsel No.
86 -584, incorporated herein by reference.
Discussion: As a township supervisor, you are a "public official" as that
term is defined in the Ethics Act. 65 P.S. §402. As such, you are subject to
the provisions of the Ethics Act and the restrictions therein apply to you.
Section 3(a) of the Ethics Act provides:
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).
Mr. Earl R. Hatton
December 8, 1987
Page 2
Under this provision, the Ethics Commission has determined that the use
of office by a public official to obtain a gain or benefit for himself which
is not provided for in law constitutes a "financial gain other than
compensation provided for by law." See McCutcheon v. State Ethics Commission,
77 Pa. Commw. 529 (1983). See also Yocabet v. State Ethics Commission,
Pa. Commw. (1987) filed on September 18, 1987 at 834 C.D. 1986.
In the definitional section of the Ethics Act, "business with which he is
associated" is defined 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.
As previously noted, you are associated with O'Neill and Associates,
Realtors and, therefore, you may not use your public position in order to
obtain a financial gain for yourself or for the business with which you are
associated, O'Neill and Associates.
It is further provided in Section 3(b) of the Ethics Act:
Section 3. Restricted activities.
(b) No person shall offer or give to a public official or
public employee or candidate for public office or a member
of his immediate family or a business with which he is
associated, and no public official or public employee or
candidate for public office shall solicit or accept,
anything of value, including a gift, loan, political
contribution, reward, or promise of future employment
based on any understanding that the vote, official action,
or judgment of the public official or public employee or
candidate for public office would be influenced thereby.
65 P.S. 403(b).
Specifically, the Ethics Act provides that no public official may use his
public office, confidential information received through his holding public
office to obtain a financial gain for himself or a business with which he is
associated and no public official may receive anything of value, including the
promise of future employment, on the understanding that his official conduct
will be influenced thereby. See Section 3(a) and 3(b) of the Ethics Act, 65
P.S. §403(a) and (b).
Mr. Earl R. Hatton
December 8, 1987
Page 3
Reference must also be made to Section 3(d) of the Ethics Act which
allows the Commission to review other areas of conflicts of interests.
Generally, the types of activities encompassed by this particular provision
are generally determined through a review of the intent of the State Ethics
Act. Generally, the State Ethics Act was promulgated in order to insure the
public that the interest of their officials do not conflict with the public
trust or create the appearance of a conflict of interest.
In the instant situation, when matters concerning zoning and subdivision
ordinances, before you as township supervisor, under Section 3(d) of the
Ethics Act, you may not participate nor vote on these matters wherein any
individual has employed your services as a real estate broker or wherein there
are parcels of realty in which you are involved as a private individual or as
a real estate professional. As previously noted, you should neither vote nor
participate in the above situations nor as to any property or individuals with
whom you may be involved in the foreseeable future. Further, as was
previously noted, you should not represent any particular individual property
owner or developer before the Township Board of Supervisors. In these
situations, you must abstain from voting or participating and note your
abstention of public record together with the reason for your public
abstention.
Lastly, the Ethics Commission has only addressed your question under the
Ethics Act; it has not considered the applicability of any other statute,
code, ordinance, regulation or other code of conduct other than the Ethics
Act.
Conclusion: As a township supervisor, you are a "public official" subject to
the provisions of the State Ethics Act. Advice No. 86 -088, which was issued
on July 21, 1986 is incorporated herein by reference and the restrictions and
limitations set forth therein are applicable. As a township supervisor, you
may not use your official position to obtain work as a real estate broker, you
may not participate or vote on zoning and subdivision ordinances that relate
to particular parcel of property for which you are the listing agent or which
you individually own or which a particular individual has employed your
professional services and also as to any property or individuals with whom you
would be foreseeably involved in the future. The reason for your abstention
must be publicly noted and recorded in the appropriate township records.
Lastly, you should not represent any private clients before the Township Board
of Supervisors.
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.
Mr. Earl R. Hatton
December 8, 1987
Page 4
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,
Vincent J. Dopko
General Counsel