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HomeMy WebLinkAbout87-569 FeeseMr. Brett 0. Feese, Esquire 433 Market Street P.O. Box 7 Williamsport, PA 17703 Dear Mr. Feese: STATE ETHICS COMMISSION 308 FINANCE BUILDING P.O. BOX 11470 HARRISBURG, PA 17108 -1470 TELEPHONE (717) 783 -1610 May 19, 1987 ADVICE OF COUNSEL 87 -569 Re: Public Official, Participating, Matter Involving Church In Which Official Is Member This responds to your letter of May 5, 1987, wherein you requested the advice of the State Ethics Commission. Facts: You advise that you currently serve as solicitor for Montoursville Borough in Lycoming County, Pennsylvania. On behalf of one of the members of borough council, Donald Peace, you have requested the advice of the State Ethics Commission in relation to the foregoing situation. On June 8, 1987, you advise that the borough will hold a public hearing to consider an amendment to its zoning ordinance. A church, which is located in the borough, requested that the borough amend its current zoning ordinance to change the designated use of a particular parcel of ground to permit the establishment of churches. If the zoning amendment is passed, the church will purchase the entire commercial /industrial zoned area. Mr. Peace, who is a member of borough council, is also a member of the church that requested the amendment to the zoning ordinance. You advise that Mr. Peace is not an officer or official of that church. Mr. Peace is a member of the congregation and in this respect you indicate that he would not be receiving any benefit of a personal nature in relation to this situation. You have requested, however, the advice of the State Ethics Commission because you advise that the issue is one that may create some controversy. Discussion: As a member of borough council, the individual involved in this situation is clearly a public official as that term is defined in the State Ethics Act. 65 P.S. §402. As such, his conduct must conform to the requirements of the Ethics Act. Domalakes, 85 -010. Generally, the Ethics Act provides as follows: Mr. Brett 0. Feese May 19, 1987 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). Within the above provision of law, as can be seen, no public official may use his position in order to obtain a financial gain for himself or a business with which he is associated. Business with which one is associated is defined in the Act 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. In the instant situation, it is clear that Mr. Peace is not associated with the church, even if it were to be considered a business, and that he is neither an employee, stockholder, owner or officer thereof. As such, the above provision of the State Ethics Act would not appear to prevent Mr. Peace's participation in this matter. Additionally, and we note for the sake of being complete, the Ethics Act permits this Commission to address other areas of possible conflicts of interest. Generally, the Act was promulgated in order to ensure the public that the financial interests of their officials do not conflict with the public trust. 65 P.S. §401. In the instant situation, there does not appear to be any financial interest, on behalf of Mr. Peace, which would be affected by his participation in this matter. Generally, public officials are called upon on occasion to particpate in matters that may to some extent effect them as a citizen of the community. This type of indirect interest, however, is not the type that was invisioned as being adverse. This Commission, in the past, has reviewed a similar issue and has determined that a township supervisor who was a member and not an officer of a civic organization would not violate the State Ethics Act by participating in a matter regarding the rezoning of property owned by that civic organization. See, Martin No. 41; Bircker No. 42. Mr. Brett 0. Feese May 19, 1987 Page 3 Conclusion: The State Ethics Act would not prohibit the participation of a borough council member in a matter involving a zoning ordinance for a church of which he is a member. The individual is not an officer in the religious organization and further has no financial interest which would be affected by the instant matter. As such, the State Ethics Act would present no prohibitions upon his participation in this matter. 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. Sinc ohn J nti o Actin General Counsel