HomeMy WebLinkAbout88-605 BonassiSTATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
July 11, 1988
John R. Bonassi, Mayor 88 -605
Borough of Green Tree
Office of the Mayor
978 Greentree Road
Pittsburgh, PA 15220
Re: Conflict of Interest, Borough Mayor, Employment with Firm
which Contracts with Borough
Dear Mayor Bonassi:
This responds to your letter of June 3, 1988, in which you
requested advice from the State Ethics Commission.
Issue: Whether the State Ethics Act presents any prohibition or
restrictions upon a borough mayor regarding his employment with
a firm that contracts with the borough.
Facts: You state that you are the Mayor of Greentree and that a
matter of concern arose which prompted you to request an opinion
from the Borough of Greentree's former solicitor. You then
enclose photocopies of such materials as portions of the Annual
Report of this Commission, numerous newspaper clippings, minutes
of portions of various meetings of the Green Tree Borough
Council, news letters and finally, the Borough of Green Tree's
solicitors opinion dated May 31, 1988. Since you do not provide
any facts or background information in your letter of June 3,
1988, the May 31, 1988 solicitor's opinion will be utilized as a
factual basis for issuing this advice.; It is therein stated that
Williams- Trebilcock- Whitehead, hereinafter WTW, was one of nine
architectural firms that submitted proposals to the Borough
Council and WTW was appointed through a motion which was
unanimously adopted by Council. After the contract between the
Borough of Green Tree and WTW was executed, it is stated that
you were contacted by WTW regarding possible employment. After
advising Council in writing that you accepted WTW's offer, you
John R. Bonassi, Mayor
July 11, 1988
Page 2
began said employment. A May 31, 1988, opinion letter states
that you did not participate in any vote regarding the retention
of WTW as architects for the borough building project. Since you
do not set forth any specific question under the Ethics Act in
your June 3, 1988 letter, it will be assumed that you are seeking
advice as to the propriety of your employment with WTW in light
of its existing contractual relationship with the Borough.
Discussion: As the Mayor for Green Tree 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 51.1. As such, you are subject to the
provisions of the State Ethics Act.
The Act does, however, provide 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 public office or any confidential information in order to
obtain a financial gain for himself or a member of his immediate
family or a business with which he is associated. The Act defines
business with which one is associated as follows:
Section 2. Definitions.
"Business with which he is associated." Any business
in which the person or a member of the person's
immediate family is a director, officer, owner,
employee or holder of stock. 65 P.S. 402.
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 "financial gain other than compensation provided for by law."
These determinations have been appeal to 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 Yacobet v. State Ethics Commission, Pa.
Commw. , 531 A.2d 536 (1987). Of course, under this
provision, a public official may not use public office to secure
any financial gain for himself or for a business with which he is
associated. See Domalakes, Opinion 85 -010. Since it is stated
John R. Bonassi, Mayor
July 11, 1988
Page 3
that the discussions and the motions and the vote and the
execution of the contract occurred prior to the offer of your
employment and since you as mayor were in a non - voting situation,
it does not appear under these facts and circumstances that
Section 3(a) of the Ethics Act has been implicated.
Section 3(b) of the Ethics Act provides:
(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 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 a
public official or employee must observe, a public official or
employee must neither offer nor accept anything of value on the
understanding or with the intention that his judgment would be
influenced thereby. It is assumed such a situation does not
exist here. This Section is referenced 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.
In addition to the foregoing, the State Ethics Act provides
as follows:
Section 3(c) of the Ethics Act provides:
(c) No public official or public employee or
a member of his immediate family or any
business in which the person or a member of
the person's immediate family is a director,
officer, owner or holder of stock exceeding
5% of the equity at fair market value of the
business shall enter into any contract valued
at $500 or more with a governmental body
unless the contract has been awarded through
an open and public process, including prior
public notice and subsequent public
disclosure of all proposals considered and
John R. Bonassi, Mayor
July 11, 1988
Page 4
contracts awarded. Any contract made in
violation of this subsection shall be
voidable by a court of competent jurisdiction
if the suit is commenced within 90 days of
making of the contract. 65 P.S. 403(c).
In relation to the above provision of law, the State Ethics
Commission has generally determined that this provision is a
procedure to be used when a public official or employee
contracts with his own governmental body in excess of $500.
Bryan, Opinion 80 -014; Lynch, Opinion 79 -047. The Commission,
however, has also determined that the above provision of law is
not a general authorization for a public official to contract
with his own governmental body where such is otherwise prohibited
by law. The above provision of law clearly is intended to be a
procedure to be utilized where contracting is otherwise allowed
by law. For example, if a particular business transaction was
prohibited under Section 3(a) of the State Ethics Act, this
particular code prohibits a public official from being interested
in a contract, this provision would not allow that interest.
Parenthetically, where contracting is otherwise allowed or
where there appears to be no expressed prohibitions to such
contracting, the above particular provision of law would require
that an additional procedure, the open and public process, must
be used in all situations where a public official is otherwise
appropriately contracting with his own governmental body in
excess of $500. This open and public process would require:
(1)
prior public notice of the employment or
contracting possibility;
(2) sufficient time for a reasonable and prudent
competitor /applicant to be able to prepare
and present an application or proposal;
public disclosure of all applications or
proposals considered and;
(4) public disclosure of the contract awarded and
offered and accepted. See, Cantor, 82 -004.
^
Under Section 3(c) of the Ethics Act, if you hold one of the
enumerated position of director, officer, owner or holder of
stock exceeding 5% of the equity of the fair market value of WTW,
then Section 3(c) would be implicated and you would be required
to follow the procedures outlined above.
(3)
John R. Bonassi, Mayor
July 11, 1988
Page 5
Section 3. Restricted activities.
(d) Other areas of possible conflict shall be
addressed by the commission pursuant to paragraph
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 their 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.
Under Section 3(d) of the Ethics Act, if any matter
concerning WTW comes before the Borough, you may not participate
in that matter nor may you vote to break a tie on any matter that
would be before Borough Council concerning WTW. You would have
to note your abstention publicly together with the reason for
that abstention.
(
Lastly, the propriety of the proposed conduct has only been
addressed under the Ethics Act; the applicability of any other
statute, code, ordinance, regulation or other code of conduct
other than the Ethics Act has not been considered in that they do
not involve an interpretation of the Ethics Act. Specifically
not addressed in this advice is the applicability of the Borough
Code in that that does not involve an interpretation of the
Ethics Act.
Conclusion: As a Mayor for Green Tree Borough you are a public
official subject to the provisions of the State Ethics Act.
Subject to the qualifications and limitations as noted above, you
may simultaneously serve as mayor of Green Tree Borough and be
employed by WTW Architectural Firm. Lastly, the propriety of the
proposed conduct has only been addressed under the Ethics Act.
John R. Bonassi, Mayor
July 11, 1988
Page 6
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.
Si
Vincent J. Dopk ,
General Counsel