HomeMy WebLinkAbout87-548 SabatineSTATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108-1470
TELEPHONE (717) 783 -1610
April 27, 1987
ADVICE OF COUNSEL
Mr. Nicholas R. Sabatine, III, Esquire 87 -548
16 South Broadway
Wind Gap, PA 18091
Re: Borough Councilmember, Investment of Borough Funds, Interest in
Investment Company
Dear Mr. Sabatine:
This responds to your letter of March 26, 1987, wherein you requested the
advice of the State Ethics Commission.
Issue: Whether the State Ethics Act presents any prohibitions upon a member
of Borough Council receiving a commission as a result of the investment of
certain borough funds.
Facts: You currently serve as the solicitor to the borough of Roseto in
Northhampton County, Pennsylvania. You advise that a member of the borough
council is also an employee of a local investment company. Roseto borough is
currently considering investing certain borough pension fund monies. You have
requested the advice of the Commission regarding whether the State Ethics Act
would prohbit the receipt of commissions by a member of borough council
regarding the investment of these funds which are through an investment
company which employs the councilmember.
Discussion: As a member of the borough council, the individual involved in
the instant situation is clearly a public official as that term is defined in
the State Ethics Act. 65 P.S. §402; Davis, 84 -012; Domalakas, 85 -010. As
such, this individual's conduct must conform to the requirements of the State
Ethics Act. 65 P.S. §401 et. seq. While the Ethics Act contains various
restrictions regarding contracts between the business with which a public
official or a public employee is associated and the governmental body on which
the public offical or employee serves, the Ethics Act generally does not
totally prohibit a public official or employee or a member of his immediate
family from engaging in business activities or otherwise contracting with the
governmental body on which the official serves. Specifically, the Ethics Act
does provide as follows:
Mr. Nicholas R. Sabatine, III, Esquire
April 27, 1987
Page 2
Section 3. Restricted activities.
(c) No public official or public employee or a member of
his immediate family or any business in which the person
or a member of the person's immediate family is a
director, officer, owner or holder of stock exceeding 5%
of the equity at fair market value of the business shall
enter into any contract valued at $500 or more with a
governmental body unless the contract has been awarded
through an open and public process, including prior public
notice and subsequent public disclosure of all proposals
considered and contracts awarded. Any contract made in
violation of this subsection shall be voidable by a court
of competent jurisdiction if the suit is commenced within
90 days of making of the contract. 65 P.S. 403(c).
If in the instant situation, the borough councilmember involved is in fact the
owner of greater than 5% of the equity at fair market value of the business
that would be contracting with the borough for the investment of the pension
funds, the above provision of law would apply. In this respect, the above
provision would require that the open and public process be utilized. This
would require:
(1) prior public notice of the employement or contracting possibility;
(2) sufficient time for a reasonable and prudent competitor /applicant to
be able to prepare and present an application or proposal;
(3) public disclosure of all applications or proposals considered;
(4) public disclosure of the contract awarded or offered and accepted.
See, Cantor, 82 -004; Fields, 82 -006.
In addition to the foregoing, the Ethics Act furthers 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).
Mr. Nicholas R. Sabatine, III, Esquire
April 27, 1987
Page 3
The Ethics Act defines, business with which one is associated 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.
Within this provision of law, it is clear that the borough councilmember is
associated with the business that is seeking to contract with the borough for
the investment of the pension fund. As such, this borough councilmember may
not use, to any extent, his public position in order to obtain a financial
benefit for that entity. As such, the borough councilmember may not
participate to any extent in the solicitation of proposals, the discussions
and review of such proposals by borough council, and the final decisions by
borough council as to what contract should be accepted and awarded or where
borough funds should be invested. In addition to the foregoing it should be
noted, that Section 3(a) of the Ethics Act, as cited above, would also
prohibit a public official from receiving through his public position any
financial gain that is not part of the compensation provided by law. Thus, if
by law a public official is not entitled to receive certain compensation,
benefits or financial gain, then his receipt of this item, through his public
office, could be a violation of the State Ethics Act. See Domalakas, 85 -010;
Kalinyak, 86 -535. In this respect, the State Ethics Commission generally,
does not have the jurisdiction to address or interpret the provisions of other
municipal codes. However, there are situations were other codes must be
reviewed in order to determine if the provisions of the State Ethics Act are
implicated. In the instant situation, the borough code provides as follows:
PENALTY FOR PERSONAL INTEREST IN CONTRACTS OR PURCHASES.
Except as otherwise provided in this act, no borough
official either elected or appointed, who knows or who by
the exercise of reasonable diligence could know, shall be
interested to any appreciable degree either directly or
indirectly in any purchase made or contract entered into
or expenditure of money made by the borough or relating to
the business of the borough, involving the expenditure by
the borough of more than one thousand ($1,000) in any
calendar year, but this limitation shall not apply to
cases where such officer or appointee of the borough is an
employe of the person, firm or corporation to which the
money is to be paid in a capacity with no possible
influence on the transaction, and in which he cannot be
possibly benefited thereby either financially or
otherwise. 53 P.S. §46404.
Mr. Nicholas R. Sabatine, III, Esquire
April 27, 1987
Page 4
The above provision of law clearly appears to indicate that an elected or
appointed offical of a borough may not be interested either directly or
indirectly in any borough expenditure in excess of $1,000 in any calendar
year. If the above provision of law, would prohibit based upon the facts of
this situation a borough official from receiving that type of compensation or
benefit, then, within the Ethics Act, an official who receives a financial
gain knowingly in violation of that provision of the code, could be receiving
a financial gain other than the compensation provided for by law and which is
therefore not in accordance with the State Ethics Act. Thus, it is advised
that this provision of the borough code be considered if the borough
councilmember in question submits a bid to the borough or if his company does
so. See, Allen, 86 -518. In the instant situation, you have provided no
information relating the amount of expenditures which the borough will be
involved in each year. As such, no determination will be made under this
particular provision of the law. However, you, as solicitor, should consider
the above provision of law and it is suggested that you act in accordance
therewith.
Conclusion: The State Ethics Act presents no per se prohibitions of an
absolute nature on a public official contracting with his governmental body,
as a public official, a borough councilmember must observe the provisions of
the State Ethics Act as outlined above. As such, an individual must comply
with the open and public process requirements if applicable, and may not
participate in any matter relating to the award of a contract to a business
with which he is associated. Similarly, provisions of the specific codes
mentioned in the above outlined advice should be reviewed and the
applicability of such determined in relation to the instant situation.
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.
cerely,
ohn
ontino
Acti General Counsel