HomeMy WebLinkAbout88-662 LukeJohn R. Luke, Esquire
Three Gateway Center
22nd Floor, North Wing
Pittsburgh, PA 15222
Dear Mr. Luke:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
December 8, 1988
-662
Re: Conflict of Interest, Township Supervisors, Voting oz.
Proposed Settlement of Litigation Instituted by. Former
Employee Against Township and Supervisors Individually
This responds to your letter of November 2, 1988, in which
you requested advice from the State Ethics Commission.
WTr the State Ethics Act presents any prohibition or
upon second class township sup ~visors in vi
appro " -e a proposed settlement of litigation instituted by a
former employee against the township and against the individual
supervisors.
Facts: You state that a township has been sued by a former
employee who has been suspended from duties for a period n 30
days relating to keeping accurate time of work. You then state
that the employee has indicated that the conditions were
intolerable, has treated the suspension as a dismissal and s
sued the municipality and the public officials individually
charging conspiracy and improper dismissal. You then advise that
the insurance carrier who insures the municipality has suggested
a settlement with the former employee wherein the insurance
company would pay part of the damage and the municipality would
pay the balance. After stating that the elected officials of the
municipality are also involved in the suit as individual
defendants, you inquiry as to whether these individuals may vote
to effect the settlement and authorize payment of a portion of
municipal funds which would exculpate the public officials. You
restate the above inquiry that since the public officials have
an inter93t in the outcome, may they vote on behalf of the
municipality rcgi ding the possible settlement of this
John R. Luke, Esquire:
December 8, 1988
Page 2
litigation. In a telephonic communication on November 22, 1988,
you advise that you represent these municipal officials, the
municipality operates under Home Rule and you contemplate
resolving this matter by having these public officials abstain.
You further advise that only the public officials who were
elected after this incident would vote on these matters and you
conclude by asking whether they would have a conflict.
Discussion: As members of the Home Rule Municipality, these
individuals are public officials as that term is defined under
the Ethics Act. 65 P.S. §402; 51 Pa. Code S1.1.
Section 3(a) of the Ethics Act provides:
F ^- 3. t' f—t cted 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).
Under Section 3(a) quoted above, the State Ethics Commission
determined that use of office by a public official to obtain
c financial gain for himself or a member of his immediate family
or a business with which he is associated which is not provided
for in law transgresses the above provision of law. Thus, use of
office by a public official to obtain a gain which is
not authorized as part of his compensation is prohibited by
Section 3(a): Hoak /McCutcheon, Orders No. 128, 129, affirmed
McCutcheon v. State Ethics Commission, 77 Pa. Commw. Ct. 529, 466
A.2d 283 (1983); Yacobet, Order No. 412 -R, affirmed Yacobet v.
State Ethics Commission, 109 Pa. Commw. Ct. 432, 531 A.2d 536
(1987). Similarly, Section 3(a) of the Ethics Act would prohibit
a public official /employee from using public office to advance
his own interests; Koslow, Order 458 -R, affirmed Koslow v. State
Ethics Commission, Pa. Commw. Ct. , 540 A.2d 1374 (1988).
Likewise, a public official /employee may not use the status or
position of public office for his own person,1 advantage; Huff,
Opinion 84 -015.
In the instant matter, since the public officials whose
conduct is in question will abstain as to the vote to settle the
litigation, the precise question under the Ethics Act is whether
their abstention in the matter would he implicated under Section
3(a). The Ethics Commis. pion has ruled that an abstention by a
John R. Luke, Esquire
December 8, 1988
Page 3
public official does not constitute a use of office under the
Ethics . pct, Therefore, if only the officials who took office
after Vie above incident voted and the public officials who are
the suLje:t of the litigation would abstain at the public
meeting, as well as noting their abstention of public record
together with reason for their abstention, Section 3(a) of the
Ethics Act world not be implicated under these facts and
circumstances.
Lastly, the propriety of the proposed conduct has only been
addre.37....x under the Ethics Act; the applicability of any ')the::
s v'ltnte,, cods, ordinance, regulation or other code of conftct
oth» than the Ethics Act has not been considered in that thy do
an _ rater 'reL - ion o f thc C_ ..^t.
.- ,n�1usion: As Home Rule Charter officials, these individuals
( 7Ar tun) is officials subject to the provisions of the State
;..:ics Act. Under the facts and circumstances outlined above,
E., t r ��n 3(a) of the Ethics Act would not be implicated when
public officials who are the subject of a law suit against thy:
municipality and themselves individually would abstain relative
to a possible settlement of that litigation. 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 co.2. e1.':
defense in any enforcement proceeding initiated by th,:
Commission, and evidence of good faith conduct in any other civil
or criminal proceeding, providing the requestor has disclos
truthfully all the material facts and committed tha ac .s
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 seivice of this
Advice pursuant to 51 Pa. Code §2.12.
ncereiy,
Vincent \7. Dopko,
General Counsel