HomeMy WebLinkAbout87-508 KnafelcSTATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
January 16, 1987
ADVICE OF COUNSEL
Harry E. Knafelc, Esquire
664 Merchant Street
Ambridge, PA 15003
Re: Member, School Board, Subsequent Employment with School District
Dear Mr. Knafelc:
87 -508
This responds to your letter of January 6, 1987, wherein you requested
the advice of the State Ethics Commission.
Issue: Whether a school director may obtain employment within the school
district after he resigned his position as a member of that governmental
body.
Facts: You advise that you currently represent Dr. Bruno Razo who has been
appointed to fill an unexpired term on the Ambridge Area School District's
Board of Directors. You advise that the term, for which Mr. Razo was
appointed, will expire the first week of December 1987. You further advise
that Mr. Razo is a certified superintendent of schools in the Commonwealth of
Pennsylvania. Pursuant to this certification, Mr. Razo has requested advice
regarding whether he may be appointed as the superintendent of schools in the
Ambridge Area School District after the term for which he was appointed has
expired. You have requested the advice of the State Ethics Commission, on his
behalf, regarding any restrictions that will be placed upon him within the
purview of the State Ethics Act. We also note that you have referenced to the
School Code in your letter of request and have indicated that certain
prohibitions may exist under that provision of law.
Discussion: As a member of a school board, Mr. Razo would clearly be a public
official as that term is defined in the State Ethics Act. Jersey Shore Area
School District v. Bittner, 81 Pa. Commw. Ct. 30, 472 A.2d 1183, (1984);
Blaney, 84 -003. As such, Mr. Razo's conduct must conform to the requirements
of the State Ethics Act. At the outset, it should be noted that while you
have referenced to Section 324, 24 P.S. §3 -324, of the Public School Code of
1949, this Commission is not authorized to interpret or address that
particular provision of law. The Commission, generally, only interprets
provisions of the State Ethics Act. While there are occasions wherein the
Harry E. Knafelc, Esquire
January 16, 1987
Page 2
interpretation of other codes becomes necessary in order to make a
determination of duties and responsibilites under the Ethics Act, it does not
appear as though such an interpretation of the School Code is necessary in the
instant situation. As such, you are advised that any restrictions that are
outlined in the Public School Code, must be considered separate and apart from
those that are set forth pursuant to the provisions of the State Ethics Act.
Within the purview of the State Ethics Act, in relation to former public
officials which Mr. Razo would become upon the termination of his service as a
member of the Ambridge Area School Board, the.Act provides that:
Section 3. Restricted activities.
(e) No former official or public employee shall represent
a person, with or without compensation, on any matter
before the governmental body with which he has been
associated for one year after he leaves that body.
65 P.S. 403(e).
Generally, under this provision of law, a former public official would be
prohibited from representing a person or entity before his governmental body
for a period of one year after such employment is terminated.
In relation to this restriction, the Commission has determined that when
such a former official or employee obtains employment with another
governmental body or on a different level of government, the above restriction
would not be applicable. Hagen, 84 -019; Pinto, 84 -021. The Commission has
also determined that, when a public official or employee transfers positions
within a governmental system, they do not become a former governmental
employee or official. Gray, 83 -596; Cohen, 79 -045. In light of these
decisions, there would be no 3(e) restriction upon Mr. Razo's employment.
This is especically so in light of the fact that he, in his position of
employment as superintendent, would still be representing the school district
rather than any private interest.
In addition to the foregoing, however, we must also review the situation
in light of several other provisions of the State Ethics Act. Generally, the
Act provides that:
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).
Harry E. Knafelc, Esquire
January 16, 1987
Page 3
Within this provision of law, Mr. Razo would be prohibited from using his
current position as a school board member or any confidential information
obtained therefrom to obtain a financial gain other than the compensation
provided for by law. Thus, he could not, for example, vote or participate, to
any extent, in the school district's decision with regard to the position or
the compensation to be paid the school superintendent. In addition thereto,
if the position for which -Mr. Razo would apply was specially created or if
while he was a member of the school board, any other board action has been
taken specifically in relation to this particular position that inured to the
benefit of the employee who serves in that position, he either should not
participate in matters related to that position or he could be prohibited from
obtaining said position. This would be so not only under Section 403(a) above
but also under provisions of the Act which permits the State Ethics Commission
to address other areas of possible conflicts of interest. 65 P.S. §403(d).
The Ethics Act also provides that:
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).
We make reference to this provision of law not to imply that there has or
will be any implication thereof but merely to provide a complete response to
your request. In this respect, there may be no offer or acceptance of
anything of value to other board members in order to obtain said employment
based upon the understanding that the official decision, of Mr. Razo, would be
influenced thereby.
Finally, as noted above, the Commission may address other areas of
possible conflict. Within this provision of law, a public official must avoid
all potential conflicts of interest. 65 P.S. §401. Such a conflict arises
when the individual serves one or more interest that are adverse. Alfano,
80 -007. While the Commission can not envision every situation wherein such a
conflict may exist, you are cautioned as to this provision and in the event
that such a situation arises, you may want to seek further advice under the
Ethics Act. In any event, it is advised that Mr. Razo should proceed with
Harry E. Knafelc, Esquire
January 16, 1987
Page 4
caution in relation to his decisions as a board director in relation to the
position of superintendent and the individual currently serving in that
position. This is particular so, if he envisions, at some point in time,
applying for that position in the Ambridge Area School District. Teets,
85 -542.
Conclusion: The Ethics Act places no per se prohibition upon the subsequent
employment by a school board director as an employee of the school district.
As a public official, this individual must conform to the requirements of the
State Ethics Act as outlined above. Additionally, it is noted that this
advice does not address questions and interpretations which may arise under
the provisions of the Public School Code.
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,
n
on ino
Gen Counsel