HomeMy WebLinkAbout88-586 BrownMr. Burrell A. Brown
Attorney and Counsellor at Law
616 Miller Avenue, Suite 202
Clairton, Pennsylvania 15025
Dear Mr. Brown:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
June 14, 1988
' b -586
Re: Conflict of Interest, School Board Members, hiring member of
Board of Control as Superintendent
This responds to you letter of May 8, 1988, in which you
requested advice from the State Ethics Commission.
Issue: You ask whether the State Ethics Act presents any
restrictions or prohibition upon the members of a school board
from hiring a member of the Board of Control as a superintendent
to the school district.
Facts: You state that you have been retained by the three
members of the Clairton School Board, hereinafter Board,
regarding a potential contract between Dr. Donald Boyer and the
Board. You then state that in 1984 Clairton was declared a
Distress Community and a Board of Control was appointed for the
Clairton School District to manage its fiscal affairs. You note
that the Board of Control was composed of Dr. Donald Boyer
(Chairman), and Robert Nicholas and Dennis Juran. You then state
that Dr. Boyer is currently holding a full -time position as
Director of Budget and Management with the Pennsylvania
Department of Education. After stating that Mary Ann Nobers was
removed from her position as Superintendent of the District in
December 1987, you advise that in January 1988 at the
recommendation of Dr. Boyer the Board of Control entered into a
contract with the Pennsylvania School Board Association to
institute a search for a superintendent for the Clairton School
District. You advise that the search, which cost $5,000,resulted
Burrell A. Brown, Esquire
June 14, 1988
Page 2
in the submission of 42 candidate applications. You then state
that Dr. Boyer offered to fill the position at a salary of
$62,000 which is $10,000 over the current salary. After stating
that Dr. Boyer submitted no application or resume for the
position, you express your belief that Dr. Boyer still maintains
the position of Director of Budget and Management with
Pennsylvania Department of Education. You then state that the
transfer of authority from the Board of Control to the School
Board will officially occur on June 13, 1988 as per an order of
court and that the elected school board is contemplating voting
on the hiring of Dr. Boyer at a special meeting on May 26, 1988.
You conclude by requesting advice as to whether the proposed
employment of Dr. Boyer by the board would violate Section 3(e)
and (g) of the Ethics Act.
Discussion: At the outset it must be noted that the State
Ethics Commission may only address your question within the
purview of the Ethics Act. The applicability of any other
statute, code, ordinance, regulation or other code of conduct
other than the ethics act cannot be considered in that they do
not involve an interpretation of the Ethics Act. Thus this
advice cannot address the applicability of the school code for
the above reason.
Secondly, this advice may only address the propriety of the
proposed conduct of the three school board members and not that
of Dr. Boyer. The authority of the Ethics Commission to issue
an opinion /advice regarding a person's duty under the Ethics Act
is limited by statute to those persons who make requests
relative to their own duties; the State Ethics Commission cannot
issue an opinion /advice to a third party concerning the duties of
some other person under the Ethics Act. 65 P.S. 5407(9)(i).
As members of the Clairton School Board, the three members
are public officials within the definition of that term as set
forth in the Ethics Act. Weaver Opinion, 85 -014; 65 P.S. S402;
51 Pa. Code S1.1. As such, their conduct is subject to the
provisions of the Ethics Act.
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
Burrell A. Brown, Esquire
June 14, 1988
Page 3
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(&).
Section 3(a) basically provides that a public official or
employee may not use his public office or confidential
information to obtain a financial gain other than compensation
as provided for by law for himself or a member of his immediate
family or a business with which he is associated. 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 or a member of his immediate family which is not provides
for in law constitutes a "financial gain other than compensation
provided for by law." These determinations have been appealed tr
the Commonwealth Court of Pennsylvania which has affirmed the
Orders of the Commission. See McCutcheon v. State Ethics
Commission, 77 Pa. Commw. 529 (1983). See also Yocabet v. State
Ethics Commission, Pa. Commw. , 531 A.2d 536 (1987).
Thus, under this provision, a public official may not use his
public position to secure benefits for himself or a member of his
immediate family which are not provided for by law. Domalakes,
Opinion 85 -010; likewise, the receipt of private financial gain
or benefit through use of office is not permitted under this
section, Huff, Opinion 84 -015.
Under Section 3(a) quoted above, there does not appear to be
any prohibition on the three school board members regarding the
hiring of Dr. Boyer for the position of superintendent. It is
assumed that Dr. Boyer is not a member of the immediate family of
any of the three members of the Board. Thus since the three
members of the Board would not be receiving any financial gain
for themselves or a member of their immediate family, there is no
prohibition under Section 3(a) of the Ethics Act for them to hire
Dr. Boyer to the position of superintendent.
As noted above, since you only represent the three members
of the Board and ask advice under the Ethics Act on their behalf,
this advice does not address the question of the propriety of Dr.
Boyer's conduct regarding seeking the position of superintendent
with the school district when he served as a member of the Board
of Control. 65 P.S. 407(9)(i).
•
Burrell A. Brown, Esquire
June 14, 1988
Page 4
Conclusion: As members of the Clairton School District, the
three members are public officials subject to the provisions of
the Ethics Act. There is no prohibition under the Ethics Act for
these three individuals to hire Dr. Boyer as superintendent for
the school district. Specifically not addressed in this advice
is the propriety of Dr. Boyer's conduct in seeking the position
of Superintendent to the Clairton School District when he served
as member of the Board of Control.
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.
such.
This letter is a public record and will be made available as
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 .former 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