HomeMy WebLinkAbout88-608 HaluskaHornorable Edward J. Haluska
State Representative
House of Representatives
Commonwealth of Pennsylvania
P.O. Box 112
Main Capitol Building
Harrisburg, PA 17120 -0028
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
July 12, 1988
88 -608
Re: Conflict of Interest, State Representative, Leasing Space to
Pennsylvania Liquor Control Board
Dear Representative Haluska:
This responds to your letter of June 10, 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 a state representative from
leasing space to the Pennsylvania Liquor Control Board.
Facts: You state that you have been requested by General
Services to get a written opinion from the State Ethics
Commission concerning your lease of a store room to the
Pennsylvania Liquor Control Board, hereinafter LCB. You then
advise that when you first ran for public office eight years ago
you made an inquiry of the LCB as to the status of your lease
with them and was advised that since you had been renting for a
number of years prior to your election, the existence of that
lease would have no bearing upon your newly elected status. You
then state that for some unknown reason General Services now
questions the validity of such contracts and because of that you
request advice as to whether the rental of space (Patton Drug
Building) located at 463 Magee Avenue in Patton, might impact
upon the State Ethics Act.
Discussion: As the representative for the 73rd legislative
district, you are a public official within the definition of that
term as set forth in the Ethics Act and the regulations of this
Representative Edward J. Haluska
July 12, 1988
Page 2
Commission. 6
subject to the
5 P.S. §402; 51 Pa. Code §1.1. As such, you are
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 a 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
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(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
Representative Edward J. Haluska
July 12, 1988
Page 3
the vote, official action, or judgment of the
public employee or candidate for public
office would be influenced thereby. 65 P.S.
403(b).
Section 3(b) of the Ethics Act must be referenced in order
to provide a complete response to your inquiry. 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
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
Representative Edward J. Haluska
July 12, 1988
Page 4
by law. For example, if a particular business transaction were
prohibited under Section 3(a) of the State Ethics Act, then
Section 3(c) would not allow that contract.
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;
(3) 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 the above quoted provisions, Section 3(a) of the
Ethics Act would not preclude your from leasing the office space
to the LCB. See Goodman, Opinion 88 -001. It is assumed for
purposes of this advice that have not used public office or
confidential information to obtain the lease; in this regard, you
have stated that you were leasing the space to the LCB prior to
your election. Additionally, any matters relating to your lease
of the office space with LCB, whether that would involve
negotiating the terms of the lease, entering into the lease or
resolving any problems that might arise during the term of the
lease, could not be handled through your legislative office nor
could any of the staff, equipment, or supplies of your
legislative office be used relative to the foregoing. See,
Dorrance, Order 456. As to Section 3(c) of the Ethics Act, the
provisions of that Section would not appear to be applicable in
this situation since the LCB is not your "governmental body" as
that term is defined under the Ethics - Act.
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
Representative Edward J. Haluska
July 12, 1988
Page 5
not addressed in this advice is the applicability of the
Legislative Code of Ethics or the State Adverse Interest Act in
that they do not involve an interpretation of the State Ethics
Act.
Conclusion: As a Representative of the 73rd Legislative
District, you are a public official subject to the provisions of
the State Ethics Act. Subject to the limitations as outlined
above, you may, consistent with the Ethics Act, lease rental
space to the LCB. 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.
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