HomeMy WebLinkAbout88-674 SerraDear Mr. Serra:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
December 29, 1988
Vincent J. Serra, Chief 88 -674
German Township Police
R.D. 1, Box 287
McClellandtown, PA 15458
Re: Simultaneous Service, Police Chief and Township
Secretary /Treasurer
This responds to your undated - letter received by the State
Ethics Commission on December 27, 1988 in which you requested
advice.
Issue: Whether the State Ethics Act imposes any prohibition or
restriction upon a police chief from also serving or being
employed as a township secretary /treasurer.
Facts: You state that you are currently the Chief of Police of
German Township, a township of the second class located in
Fayette County. You then advise that you will be appointed
township secretary /treasurer in addition to being Police Chief on
January 1, 1989. You conclude by requesting advice from the
Ethics Commission as to whether it would be a conflict for you to
hold both of these positions.
Discussion: As a Police Chief for German Township, you are a
"public employee" as that term is defined in the Ethics Act. 65
P.S. 402; 51 Pa. Code 1.1. As such, your conduct is subject to
the provisions of the Ethics Act and the restrictions therein are
applicable to you.
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
Vincent J. Serra, Chief
December 29, 1988
Page 2
his holding public office to o b t a i n
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
has determined that use of office by a public official to obtain
a 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 financial 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 personal advantage; Huff,
Opinion 84 -015.
However, as outlined above, there does not appear to be a
real possibility of any financial gain or inherent conflict
arising if you were to serve both as a public employee and as
township secretary /treasurer. Basically, the Ethics Act does not
state that it is inherently incompatible for a public employee to
serve or be employed as a township secretary /treasurer. The main
prohibition under the Ethics Act and Opinions of the Ethics
Commission is that one may not serve the interests of two
persons, groups, or entities whose interests may be adverse. See
Alfano Opinion, 80 -007. In the situation outlined above, you
would not be serving entities with interests which are adverse to
each other.
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
Vincent J. Serra, Chief
December 29, 1988
Page 3
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 must
be observed, a public employee must neither offer nor accept
anything of value on the understanding or with the intention that
the public his judgment would be influenced thereby. It is
assumed such a situation does not exist here. Reference to this
Section is added 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.
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).
However, under Section 3(d) of the State Ethics Act, the
State Ethics Commission may address other areas of possible
conflict of interest. 65 P.S. 403(d). The parameters of the
types of activities encompassed by this provision of law may
generally be determined by reviewing the purpose and intent of
the Ethics Act. The Ethics Act was promulgated in order to
ensure that the financial interests of public employee do not
conflict with the public trust or create the appearance of a
conflict with the public trust.
Although the Ethics Act would not preclude you from
simultaneously serving as police chief and township
secretary /treasurer, you could not in your position of police
chief use public office as a means of advancing your candidacy or
alternatively as a means of eliminating any potential competitors
for the position of township secretary /treasurer. See Pepper,
Opinion 87 -008. It is expressly assumed that the foregoing has
not occurred. Additionally, while you are on duty as a Police
Chief, you could not during that time period also perform your
services as township secretary /treasurer. Conversely, when you
are performing your duties as township secretary /treasurer, that
must be at times when you are not on duty as Chief of Police.
See Forbes, Order 681. Finally, under Sections 3(a) and 3(d) of
the Ethics Act, in the event that you would be called upon in one
official capacity to review the actions you perform in your
other official capacity, you must abstain in so doing and note
your abstention of public record together with the reason for
your abstention.
Vincent J. Serra, Chief
December 29, 1988
Page 4
Lastly, it must be noted that the propriety of your proposed
conduct has only been addressed under the Ethics Act; the
applicability of any other statute, code, ordinance, regulation
or other code of conduct has not been addressed in this advice.
Conclusion: As a Police Chief for German Township, you are
a "public employee" subject to the provisions of the State Ethics
Act. As a public employee, you may, consistent with Section 3(a)
of the Ethics Act, simultaneously serve in the positions of
Police Chief and township secretary /treasurer, subject to the
qualifications and limitations noted above. Lastly, the
propriety of the proposed course of 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 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 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 J. Dopko
General Counsel