HomeMy WebLinkAbout88-598 FreedmanMr. Sidney Freedmen
205 South Elmer Avenue
Sayre, PA 18840
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
July 6 19P8
88 -59'
Re: Conflict of Interest, Councilmember, Vote on Rezoning,
Salability of Councilmember's Property Affected by Rezoning
De_ar Mr. Freedman:
This responds to you letter of May 26, 1988, in which you
requested advice from the State Ethics Commission.
I.:a3ue: You ask whether the State Ethics Act presents any
zesLrictions or prohibition upon a councilmember from voting
"gai ?.st the rezoning and hence relocation of a savings and loan
is :•c iation to a residential area when he has attempted to sell
his own property to that association and when that property is
currently listed for sale with a realtor.
Facts: You state that you are a member of the Borough Council of
Sayre and that approximately six to eight months ago you were
con by a Mr. Joseph Conroy who is the president of the Star
Savings and Loan Company regarding the possible purchase of your
property, the Sayre Theatre, as a site for a new Star Savings
Office. After stating that you submitted a proposal to Star
Savings which was rejected as too high, you advise that Star
Savings indicated that they would entertain a lower asking price,
but did not respond when you submitted a second proposal.
Thereafter you state you listed the :property with a local real
estate office which has made a proposal to Star to which there
has been no reply. You then state that in the interim Star
Savings negotiated with a local hospital authority for the
purchase of a parcel in a residential area. After noting that
there is heavy opposition from the people living in that
neighborhood, you then express a concern regarding your voting
on the rezoning of the area which would determine whether Star
Mr. Sidney F: ^eedman
July 6, 1982
Page 2
could relocate. You then state that you would like to vote on
the matter in light of the feelings of the people in the
neighborhood. However, you state that you would vote against the
project and are concerned that you might be accused of a conflict
based on an idea that if the rezoning did not go through, that
might force Star Savings to contact you again to sell the Sayre
Theatre to them. You state that at the last public meeting, Mr.
Conroy was in the audience and that you asked him publicly if
negotiations were pending regarding the purchase of the Sayre
Theatre to which he responded that there was nothing pending.
You conclude by requesting advice as to whether you can vote on
this matter and reiterate that you are not against Star Savings
because of some hope that you may be able to sell your property
to them but rather because you are against Star Savings locating
in a residential area.
Discussion: As a councilmember for Sayre Borough, you are a
public official within the definition of that term as set forth
in the Ethics Act and the regulations of this Commission. 65
P.S. §402; 51 Pa. Code §1.1. As such, you are 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
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 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 e gain or benefit for
himself or a member of his immediate family which is not provided
for in law constitutes a "financial gain other than compensation
provided for by law." These determinations have been appealed to
Mr. Sidiev Freedman
July 6, 198.E
Page 3
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.
Section 3. Restricted activities.
(d) Other areas of possible conflict shall be
addressed by the commission pursuant to paragraph (9)
of Section 7. 65 P.S. 403(d).
Under the above provision of law, the Ethics Commission,
however, is also empowered to address other areas of possible
conflict pursuant to Section 3(d). 65 P.S. §403(d). Fritzinger,
Opinion 80 -008; DeBenedictis, Opinion 86 -002. The parameters of
the type of activity encompassed by this provision are generally
reviewed in light of the preamble to the Ethics Act which
enunciates the legislative intent of the Act. The intent and
purpose of the Act is to strengthen the faith and confidence of_
the people in their government by assuring the public that the
financial interests of the holders of public office present
neither a conflict nor the appearance or a conflict with the
public trust. A public official or employee, pursuant to this
provision, is to ensure that his personal financial interests
present neither a conflict nor the appearance of a conflict with
the public trust. 65 P.S. §401. Such a conflict may exist
where an individual represents one or more adverse interests.
Alfano, Opinion 80 -007; where an individual serves in positions
that are incompatible or conflicting; Nelson, Opinion 85 -009, or
where such an official or employee accepts compensation to which
he is not entitled. Domalakes, Opinion supra.
Applying the facts of this case to the provisions of Section
3(a) and (d) of the Ethics Act quoted above, you should not vote
on the matter of the rezoning of this property to avoid a
conflict or the appearance of a conflict of interest. The
Commission has determined that it is inappropriate for a public
official to vote on a matter wherein he has a personal interest
even though his interest would be indirect in nature. See Welz,
Mr. Sidney Freedman
July u,, 1988
Page 4
Opinion, 86 -001. The Commission has also determined that a
negative vote in certain instances (voting against a competitor)
a use of office which may transgress Section 3(a) of the
thics Act. See Pepper, Opinion 87 -008. Although you express
your desire to vote on the rezoning in light of the opposition by .
t�a.e neighborhood, you also have a private or personal interest
this matter in light of the fact that you had prior negotiation
to sell your property, the Sayre Theatre, to the Star Savings any.'
you now have that property listed with a realtor. If you were to
vote against the rezoning, it can be argued that the result of
your action would enhance your prospects of enducing the Stas:
&.vings to renegotiate to purchase your property the Sayre°,
Theatre. In this regard it is noted that you have your property
listed with a realtor and hence the property is currently
available for sale and will continue to be available for sale
during the period of the listing contract. In light of the fact
that your vote could impact upon the salability of your property
to the Star Savings, you should not vote on the rezoning becausF
of the conflict of interest under 3(a) of the Ethics Act and thk
appearance of a conflict of interest under 3(d) of the Ethic;
Act. See Golla, Opinion 88 -004.
Lastly, the propriety of the proposed conduct has only been
addressed under the Ethics Act.
Conclusion: As a councilmember for Sayre, you are a public
official subject to the provisions of the State Ethics Act.
Under the facts and circumstances outlined above, you may not
under Sections 3(a) and (d) of the Ethics Act vote on the
rezoning of an area of property wherein the Star Savings and Load
Company is seeking to relocate when you have had negotiations to
sell your property, which is currently listed for sale with a
realtor, to Star Savings. Lastly, the propriety of the proposed
conduct has only been addressed under the Ethics Act.
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.
Mr. Sidney Freedman
July 6, 1988
Page 5
Finally, if you disagree with this Advice or if you have an
-
reason to challenge same, you may request that tin 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,
04)
Vincent J. Dopko,
General Counsel