HomeMy WebLinkAbout87-628 WassonDavid B. Wasson, Esquire
1706 Fifth Avenue
Arnold, PA 15068
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PA 17120
TELEPHONE: (717) 783 -1610
November 17, 1987
ADVICE OF COUNSEL
87 -628
Re: Conflict of Interest, Township Supervisor, Retiree, Benefits
Dear Mr. Wasson:
This responds to the letter of October 14, 1987, in which you requested
advice from the State Ethics Commission.
Issue: You ask whether the Ethics Act imposes any prohibition upon township
supervisors who wish to approve Blue Cross /Blue Shield premiums for a retiring
supervisor for a period of two years after he leaves public service.
Facts: You state that, as the solicitor for Washington Township, you
represent both the township supervisors as well as Mr. H. Rugh Joyner who will
be retiring as a supervisor on the first Monday in January, 1988. You further
state that Mr. Joyner has served as an elected township supervisor for 24
years and that Mr. Joyner has received the Blue Cross /Blue Shield benefits as
an elected township supervisor and a township roadmaster, which positions he
will hold until his retirement. It is further noted by you that the township
supervisors have established employee benefits for retiring road employees for
a period of two years after retirement. You state that Mr. Joyner did not
receive the benefit of the two year Blue Cross /Blue Shield extension because
he was serving as an elected working supervisor and, as such, the Blue
Cross /Blue Shield premiums were paid by the township for an elected working
supervisor. You conclude by asking whether the Township Board of Supervisors
can properly pay, as a retirement employee benefit, the Blue Cross /Blue Shield
premiums for Mr. Joyner for a period of two years after his retirement as a
township supervisor and roadmaster.
David B. Wasson, Esquire
November 17, 1987
Page 2
Discussion: As a second class township supervisor for Washington Township,
Mr. Joyner and the other supervisors are "public officials" as that term is
defined in the Ethics Act. Accordingly, their conduct is subject to the
provisions of the Ethics Act and the restrictions therein are applicable to
them.
In the instant situation, two separate questions must be addressed
relative to the propriety of the proposal to pay the health insurance premiums
for a two year period after a working township supervisor retires. The first
question concerns whether the township board, exclusive of the supervisor who
is retiring, may vote to award the two year retirement benefit to the retiring
township supervisor. The second question is whether the retiring working
township supervisor may accept the two year retirement benefit.
Section 3(a) of the Ethics Act provides:
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).
Section 3(a) basically provides that a public official may not use his
office to obtain a gain other than compensation as provided for by law for
himself or a member of his immediate family.
In this regard, Mr. Joyner could neither vote nor participate in the
matter as to whether the other township supervisors could vote to award Blue
Cross /Blue Shield coverage for Mr. Joyner following the two years after his
retirement as a working township supervisor. This Commission has determined
that the voting of a public official to give himself a benefit or gain which
is not provided for in law constitutes a use of public office to obtain a
financial gain which is not compensation provided for by law. See McCutcheon
v. State Ethics Commission, 77 Pa. Commw. 529 (1983). Thus, if Mr. Joyner
participated or voted regarding the payment of Blue Cross /Blue Shield premiums
for a period of two years after he would retire, the receipt by him of those
benefits would be a gain which would be compensation other than provided for
by law and his voting would have been a use of public office to obtain the
benefits. See Yocabet v. State Ethics Commission, Pa. Commw. ,
A.2d , filed at 834 C.D. 1986, by Commonwealth Court on September 18, 1987.
However, if Mr. Joyner did not participate in this matter and the other
township supervisors would vote to provide the health coverage for the first
David B. Wasson, Esquire
November 17, 1987
Page 3
two years of retirement, the receipt of those benefits would not be prohibited
under the Ethics Act because Mr. Joyner would be receiving those benefits at a
time when he no longer would be a public official.
Similarly, regarding the remaining township supervisors, exclusive of Mr.
Joyner, if those supervisors were to vote to provide this two year health care
coverage for Mr. Joyner following his retirement as a working township
supervisor, Section 3(a) of the Ethics Act would not prohibit those
supervisors from voting to award this benefit to a former working
supervisor /public official since those remaining supervisors would not be
using their public office to obtain a gain for themselves but rather for some
third party. It is assumed, for the purpose of this advice, that Mr. Joyner
is not a member of the immediate family of any of the other township
supervisors .
Therefore, under Section 3(a) of the Ethics Act, if Mr. Joyner would
abstain from participating and voting relative to the matter of health care
coverage for a period of two years after his retirement, which abstention
should be publicly noted and recorded together with the reason for that
abstention, the Ethics Act would not prohibit Mr. Joyner from receiving those
benefits nor would the Act prohibit the other supervisors from voting on that
benefit for Mr. Joyner.
Section 3(b) of the Ethics Act provides:
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).
Under Section 3(b) of the Ethics Act cited above, which the supervisors
must observe, they must neither offer nor accept anything of value based on
the understanding or with the intention that their official judgment would be
influenced thereby. It is assumed that such a situation does not exist here.
Reference to this Section is added not to indicate that any such activity has
been or will be undertaken but in an effort to provide a complete response to
your inquiry.
David B. Wasson, Esquire
November 17, 1987
Page 4
Lastly, this Commission has only addressed your question under the Ethics
Act; it has not considered the applicability of any other statute, code,
regulation or ordinance or any other code of conduct other than the Ethics
Act. Specifically, not addressed in this advice is the question of whether
the township supervisors, excluding Mr. Joyner, may provide this retirement
benefit under the Second Class Township Code. Advice regarding the propriety
of this activity under the Second Class Township Code must be addressed by the
township solicitor since that would not involve any interpretation of the
State Ethics Act.
Conclusion: As township supervisors, Mr. Joyner and the other supervisors are
"public officials" subject to the Ethics Act. As to Mr. Joyner, if he
abstains from participating and voting relative to the two year retirement
benefit of having paid Blue Cross /Blue Shield premiums and notes his
abstention of public record and the reasons for that abstention, the Ethics
Act would not prohibit Mr. Joyner from receiving those benefits. Further, the
Ethics Act would not prohibit the other township supervisors, excluding Mr.
Joyner, from awarding the retirement benefit of having Blue Cross Blue/Shield
premiums paid for two years after retirement since those individuals would not
be using their public office to obtain a gain for themselves or members of
their immediate family. Lastly, it is noted that this advice has only
interpreted the Ethics Act and has not considered the applicability of any
other statute, code, ordinance, regulation or other code of conduct and
specifically has not addressed the Second Class Township 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 requester 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,
Vincent . Dopko
General Counsel