HomeMy WebLinkAbout87-642 HowellMr. Walter H. Howell
477 Bantel Street
Johnstown, PA 15905
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PA 17120
TELEPHONE: (717) 783 -1610
December 10, 1987
ADVICE OF COUNSEL
87 - 642
Re: Conflict of Interest, Township Supervisor, Furloughed Policeman, Voting
on Private Employers Bills and Police Matters
Dear Mr. Howell:
This responds to your letter of November 17, 1987, in which you requested
advice from the State Ethics Commission.
Issue: What restrictions the State Ethics Act imposes upon a township
supervisor as to participation, voting and approving bills relative to his
private employer and as to police matters that come before the township board
when said township supervisor is a furloughed township policeman.
Facts: In your letter you state that on November 9, 1987, the Upper Yoder
Township Vacancy Board appointed you to fill the remaining two year term of
township supervisor. You further state that you would like documentation
regarding your voting power in light of the fact that you have been a
furloughed township policeman for the past several years but have not severed
your right to be recalled; you state that it is your belief that as long as
your vote does not benefit you, should you be recalled, that it would be
permissible for you to vote on police matters. Furthermore, you state that
you are currently employed by Hunt Oil, Inc., with which the township does
business. In this regard, you state that you receive no commission on sales
or bonuses and ask how you should vote regarding the approval of bills from
Hunt Oil. You conclude by requesting advice as to the proper and ethical
manner in which to handle these situations under the State Ethics Act.
Discussion: As a township supervisor, you are a "public official" as that
term is defined in the Ethics Act. 65 P.S. §402. As such, you are subject to
the provisions of the State Ethics Act and the restrictions therein are
applicable to you.
Mr. Walter H. Howell
December 10, 1987
Page 2
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 no public official may use his
office or confidential information to obtain a gain other than compensation
provided for by law .
Under this provision, the Ethics Commission has determined that the use
of office by a public official to obtain a gain or benefit for himself which
is not provided for in law constitutes a "fianancial gain other than
compensation provided by law." See McCutcheon v. State Ethics Commission,
77 Pa. Commw. 529 (1983). See also Yocabet v. State Ethics Commission,
Pa. Commw. (1987) filed on September 18, 1987 at 834 C.D. 1986.
Of course, under this provision, you may not use your public position to
secure any financial gain for yourself or for your private employer, Hunt Oil,
Inc.
It is further provided in Section 3(b) of the Ethics Act:
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).
Specifically, the Ethics Act provides that no public official may use his
public office or confidential information received through his holding public
office to obtain financial gain for himself or a business with which he is
associated and no public official may receive anything of value, including the
promise of future employment, on the understanding that his official conduct
Mr. Walter H. Howell
December 10, 1987
Page 3
will be influenced thereby. See Section 3(a) and (b) of the Ethics Act, 65
P.S. 403(a) and (b). It is assumed that such a situation does not exist here.
Reference is made 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.
Reference must also be made to Section 3(d) of the Ethics Act which
allows the Commission to review other areas of conflicts of interests.
Generally, the types of activities encompassed by this particular provision
are generally determined through a review of the intent of the State Ethics
Act. Generally, the State Ethics Act was promulgated in order to ensure the
public that the interests of their officials do not conflict with the public
trust or create the appearance of a conflict of interest.
Under Section 3(d), you, as township supervisor, may not participate nor
be involved in any township matter concerning the police department in light
of your status as a furloughed policeman subject to possible recall. You must
note your abstention of public record and the reason for that abstention as to
any police matters that come before the townhip.
Section 3(d) of the Ethics Act would also have application regarding
voting on bills of Hunt Oil, Inc., which would be presented to the township.
The Commission has held that if payment of bills submitted by an official's
employer amounts to concurrence in payment of a pre - fixed, undisputed amount,
the official - employee may vote to pay the employer's bill as presented. See
Stewart, 79 -070. If, however, the payment to one's employer would be subject
to the discretion of the official-employee or otherwise subject to question,
dispute or adjustment, the official should similarly abstain from
participating, including voting, in the Board's decision to pay the amount in
question. See Reid, 82 -520 and Sheehan, 82 -556. See also Krushinski, No.
168.
In the present case, if the Board has discretion as to the amount to be
paid to Hunt Oil, Inc., and the price of a particular item purchased within
the general contract price is not pre -set within the contract -bid price, then
discretion is vested with the Board as to the payment. You may not
participate in the exercise of the Board's discretionary payments to Hunt Oil,
Inc., in such a circumstance without giving rise to an appearance of a
conflict with the public trust. If the bills submitted are pre - ordained or
pre -set by the general contract and if the Board does not decide in advance to
purchase a particular item, the payment of a bill would be considered routine
and not subject to your or the Board's discretion. You could participate in
such a decision of the Board. If the Board does act to approve a particular
purchase prior to the purchase, you should abstain similarly as in the
situation where the price has not been pre - determined by the annual
bid-contract.
Mr. Walter H. Howell
December 10, 1987
Page 4
Lastly. the Ethics Commission has only addressed your question relative
to the Ethics Act; it has not considered the applicability of any other
statute, code, ordinance, regulation or any other code of conduct other than
the Ethics Act. Specifically, the Commission has not addressed the questions
of whether the above activities are permissible under the Township Code.
Conclusion: As a township supervisor, you are a "public official" subject to
the provisions of the State Ethics Act. Under the facts and circumstances
outlined above, the Ethics Act requires that you neither participate nor vote
nor be involved in any police matters that would come before the township
board. In this regard, you must note your abstention of public record and the
reason for that abstention. Further, as to voting on bills of you private
employer, Hunt Oil, Inc., the Ethics Act would not prohibit you from
concurring as to payment of a pre -fixed undisputed amount but would require
you to abstain from participating or voting when the bill is subject to
question, dispute or adjustment or subject to discretion. Lastly, the Ethics
Commission has only addressed your question under the Ethics Act but has not
considered the applicability of any other statute, code, ordinance, regulation
or other code of conduct or the 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 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,
Vincent J. Dopko
General Counsel