HomeMy WebLinkAbout86-614 Wasson• David R.'Wasson, Esquire
1706 Fifth Avenue
Arnold, PA 15068
Dear Mr. Wasson:
Mallon Address
STATE ETHICS COMMISSION
P.O. BOX 1 179
HARRISBURG, PA 17108
TELEPHONE: (717) 783 -1610
Uctoher 2n, 1986
ADVICE OF COUNSEL
86 -614
o.
Re: Simultaneous Service, Township Zoning Officer, Political Party
Committeeman
— This responds to your request for the advice of the State Ethics
Commission.
Issue: Whether the Fthics Act presents any prohihitions upon a township
zoning officer simultaneously serving as a political party committeeperson.
Facts: You currently represent Allegheny Township in Westmoreland County,
Pennsylvania and, in that respect, you have requested the advice of the State
Ethics Commission. The township supervisors, in Allegheny Township, have
recently appointed a man to hold the position.•of township zoning officer
pursuant to the Pennsylvania's Municipalities Planning Code'. The man who was
appointed to serve in this position also holds the elected position of
democratic committeeman and he is Chairman of the Allegheny Township
Democratic Committee. You have requested the advice of the State Ethics
Commission regarding the propriety of this individual holding these positions
especially in light of certain restrictions that are set forth in the
Municipalities Planning Code.
Discussion: At the outset, it must he noted that after a close review of your
request for advice, it appears as though the question'you have presented and
the response that Aou seek is one that relates to an interpretation of the
Municipalities Planning Code rather than the State Ethics Act. However, we
have addressed the question that you have presented within the purview of the
State Ethics Act. We note, in this respect, that this Commission does not
have jurisdiction to interpret other codes or provisions of law unless those
codes or provisions of law somehow relate to the State Ethics Act.
Generally, the State Fthics Act provides as follows:
State Ethics Commission • 308 Finance Building • Harrisburg, Pennsylvania
David B. Wasson, Esquire
October 20, 1986
Page 2
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).
The above provision of the State Ethics Act is generally the primary
restricted activity set forth in the State Ethics Act. Within the above
provision this Commission has, on a number of occasions, reviewed simultaneous
service in different positions by one individual. The case most analogous to
the situation that you have presented was reviewed by the Commission in
Blumling, No. 388. In that situation, the Commission was confronted with a
s'i'tuation where a township commissioner, in a first class township, appointed
himself to the position of zoning officer in the township. The Commission, in
reviewing that matter, noted that the Municipalities Planning Code provided
for the appointment of a zoning officer who may not hold any other elected
office in the municipality. 53 P.S. §10614. This provision was noted
specifically as it related to the State Ethics Act. The State Ethics •
Act provides that no public official may use his public position in order to
obtain a financial gain other than the compensation that is provided for by
law. In the case noted above, the Commission found that the township
commissioner had first used his position by Appointing himself to the position
of zoning officer in the municipality. The Commission also found that he had
received a financial gain that was not provided for by law. In fact, by compensation as a zoning hearing officer, when such would have been
strictly prohibitied by statute, he, in fact, received a financial gain that
was completely prohibited by law. He had received this through the use of his
public office and, therefore, the Commission determined that a violation of
Section 3(a) of the State Ethics Act had occurred.
t
In the instant situation, the individual who has been appointed to the
position of zoning hearing officer is not a township'supervisor and did not
participate in his own appointment to that position. Thus, it is clear, that
this individual did not use his public position in order to obtain a financial
gain other than the compensation provided for by law. As such, there would
appear to be no implication of the State Ethics Act in this situation. Of
course, while the Ethics Act presents no per se prohibition upon such
simultaneous service, the State Ethics Act would require that as zoning
hearing officer, this individual who is serving in a public position may not
use that position in order to obtain a financial gain for himself, for a
member of his immediate family or for a business in which he is associated.
Additionally, the individual, in this capacity, should not engage in any other
conflict of interest. 65 P.S. §403(d). In this respect, if, as zoning
hearing officer, this individual is called to act upon matters wherein he may
have a private or personal interests, he should abstain from participating in
such matters. See, Alfano, 80 -007.
David B. Wasson, Esquire
October 20, 1986
Page 3
In relation to his position of party committeeperson, this Commission
has, in the past, determined that persons who are appointed or elected to
political party positions such as committee persons, are not covered by,the
State Ethics Act and that this conclusion applies to all levels of party
officials. See, Lovette, 79 -051. Thus, in this position, the individual
would not be subject to the terms or restrictions of the State Ethics Act.
Thus, under the State Ethics Act, no prohibitions would appear to be
applicable other than those cited above. In this respect, it is realized that
this Commission has not addressed the primary question which you have
requested. This Commission, however, does not believe that it has the
jurisdiction to answer the question as to whether the office of party
committeeperson is one of 'a county or municipal level. That question is one
that requires an interpretation solely of the municipal codes in question and
not the State Ethics Act.
Conclusion: The State Ethics Act would not prohibit a township zoning officer
from serving as a party committeeperson. This individual may not use his
position as a zoning officer in order to obtain a financial gain for himself,
a member of his immediate family or a business which he is associated.
Additionally, this individual should avoid any conflict of interest that `
develops in relation to his position as a party committeeperson.
Finally, this Commission may not address questions that solely relate to
the interpretation of other municipal codes without impacting upon the State
Ethics Act.
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,
ohn J. ino
Gen Counsel