HomeMy WebLinkAbout87-594 AngleSTATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PA 17120
TELEPHONE: (717) 783 -1610
July 6, 1987
ADVICE OF COUNSEL
Mr. Ronald L. Angle 87 -594
Box "A"
Portland, PA 18351
Re: Conflict of Interest, Township Supervisor, Purchase Of Land From Officer
In A Corporation Which Has'A Matter Before Township
Dear Mr. Angle:
This responds to your letter of June 17, 1987, wherein you requested the
advice of the State Ethics Commission.
Issue: Whether the Ethics Act presents any prohibitions upon a township
supervisor in purchasing property from an officer of a corporation that has a
matter pending before the township planning commission.
Facts: You advise that you are a township supervisor for Upper Mt. Bethel
Township. You state that you have purchased a piece of property in the
township from an individual who is an officer in a corporation that has a
matter pending before the township planning commission. The matter concerns
an application for a Planned Residential Development (townshouses),
hereinafter PRD, which is separate and apart from the property that you are
purchasing. Since you are not a member of the township planning commission,
you would not be voting on PRD. Lastly, you state that both you and the
seller have obtained written real estate appraisals which value the property
at less than the actual purchase price. You have requested the advice of the
State Ethics Commission as to whether there would be a conflict of interest in
your purchasing this property from an officer in a corporation that has a
separate matter, relating to PRD, pending before the planning commission.
Discussion: At the outset, it must be noted that the Ethics Commission may
only address your question within the purview of the Ethics Act. The
Commission may not and will not offer advice with respect to any duties or
obligations that may be imposed by other provisions of law.
As a township supervisor, you clearly would be a public official as that
term is defined in the State Ethics Act. 65 P.S. §402. This conclusion is
based upon your position, which when reviewed on an objective basis, indicates
clearly that you have the power to take or recommend official action of a
Mr. Ronald L. Angle
July 6, 1987
Page 2
non - ministerial nature with
inspecting or other activit
mi nimu s on the interests of
conform to the requirements
respect to contracting, procu
ies where the economic impact
another person. As such, you
of that law. Sowers, 80 -050;
repent, planning,
is greater than de
r conduct must
We lz , 86 -001.
Generally, the Ethics Act 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).
Within the above provision of law, no public official may use his
position in order to obtain a financial gain for any business with which he is
associated. Additionally, the official may not use confidential information
obtained in the public position for similar purposes.
In addition to the foregoing, this Commission may also address other
areas of possible conflicts of interest. 65 P.S. §403(d). The parameters of
the activities encompassed by this particular provision of the Act, are
determined through a review of the intent of the law. The Ethics Act was
enacted to ensure that the financial interest of a public official does not
conflict with the p u b l i c trust. Such conflict of interest would develop at
any time when the official attempts to serve one or more interests that are
adve rse.
This Commission, on at least one prior occassion, has addressed, by way
of an advice of counsel, an issue similar to the one presented herein. In
Hatton, 86 -584, the Commission determi ned that the Ethics Act would not
absolutely prohibit a township supervisor from also acting as a private real
estate broker in the sane township. The Commission noted that the supervisor
could not use his official position to: obtain work as a real estate broker,
participate in any matters that cane before the township board of supervisors
that related to a particular parcel of property for which he was a listing
agent and participate in any matter before the township board relative to a
particul ar individual who empl oyed his professional servi ces. The Commi ssion
also noted that the supervisor could not use his position to obtain private
clients for his real estate employer nor could he participate or vote in any
matter relating to a client or property with which he was involved. Lastly,
the supervisor could not represent ary clients before the township board.
Mr. Ronald L. Angle
July 6, 1987
Page 3
In the instant situation, it does not appear that the purchase of the
property by you for an amount in excess of the values set forth in two (2)
written appraisals from an individual who is an officer of a corporation that
has a matter before the townhip planning commission would constitute a
conflict of interest. It is noted that you are not a member of the township
planning commission and would not be voting upon the application of PRD. Of
course, you could not engage in any discussions, recommendations or
participation wi th the commi ssion regarding the appl i cation of PRD. Further,
you should abstain in any matter that the corporation might have before the
township board during the pendency of the purchase of the property by you from
the individual. You should also publicly note and have appropriately recorded
in the governmental body minutes that you are purchasing the property from the
individual who is a member of the corporation that has a matter before the
township planning commission. Thus, while the Ethics Act would not present a
per se prohibition upon, your purchase of the property in question, it is clear
that as a township supervisor your activities are governed by the provisions
of the Ethics Act. Accordingly, you should exercise caution to ensure that
you would have no involvement or participation in any matter that the
corporation might have with the township board pendi ng the purchase of the
property.
Conclusion: As a township supervisor, you are a public official and as such
are subject to the provisions of the Ethics Act. The Ethics Act imposes no
prohibition upon the purchase of the property, under the facts and
circumstances outlined above. Your conduct should conform to the requirements
of the Act as outlined above. Lastly, as indicated, you should note publicly
and appropriately record it in the governmental body's minutes that you are
purchasing the property in question from an individual who is a member of a
corporation that has an application before the township planning commission.
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 crimi nal proceedi ng, providing the requestor has
disclosed truthfully all the material facts and carat tted the acts complained
of in reliance on the Advice given.
This letter is a public record and will be made available as such.
Mr. Ronald L. Angle
July 6, 1987
Page 4
Finally , if you disagree with this Advi ce or if you have any reason to
chal lenge sane, you may request that the ful 1 Comm' ssion revi ev this Advi ce. A
personal appearance before the Commi ssion wi 11 be scheduled and a formal
Opinion from the Commission w i l l be issued. Any such appeal mast be made, in
writing, to the Commission within 15 days of service of this Advice pursuant
to 51 Pa. Code 2.12.
4
Si ncerely ,
Vincent J. Dopko
General Counsel