HomeMy WebLinkAbout90-549 JonesDear Mr. Jones:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
May 17, 1990
Mr. William T. Jones, Esquire 90 -549
Law Offices of
Levy & Preate
Fourth Floor
Scranton Electric Building
Scranton, PA 18503
Re: Conflict, Public Official /Employee, Borough Councilmember,
Vote, Business With Which He Is Associated.
This responds to your letters of February 23. and April 3,
1990, in which you requested advice from the State Ethics
Commission.
Issue: You ask whether the Public Official and Employee Ethics
Law presents any prohibition or restrictions upon a borough
councilmember from voting or participating on matters concerning
a business with which he is associated or from companies that
compete with the business with which he is associated.
Facts: As the solicitor for Taylor Borough and on behalf of the
President of Council Harry Armstrong, you seek an advisory
opinion regarding the conduct of Mr. Armstrong who is an employee
of Amity Lumber. You note that Mr. Amity also operates
additional businesses that are located or do business with the
Borough of Taylor. You then pose four questions and ask whether
a conflict would arise under any of those circumstances. First,
you inquire as to whether a councilmember may vote on matters
that either directly or indirectly impact upon his employer or
other companies that would be related or affiliated with his
employer. Second, assuming that the councilmember could not vote
in the first situation, you seek advise as to whether he may vote
on matters that would indirectly impact upon their employers as
well as the general community such as voting on a borough wide
zoning ordinance. Third, since Mr. Armstrong has been
continually employed by the same employer, you inquire as to
whether that continuous employment would negate the need for him
to abstain as to voting on matters directly related to that
Mr. William T. Jones
Page 2
employer. Lastly, you pose the hypothetical of two
councilmembers employed by two different competing companies and
as whether they may vote on a matter which would be detrimental
to the employer of the other councilmember.
Discussion: As Councilmember for Taylor Borough, Harry Armstrong
is a public official as that term is defined under the Ethics
Law, and hence he is subject to the provisions of that law.
Section 3(a) of the Ethics Law provides:
Section 3. Restricted Activities
(a) No public official or public
employee shall engage in conduct that
constitutes a conflict of interest.
The following terms are defined in the Ethics Law as
follows:
Section 2. Definitions.
"Conflict or conflict of interest." Use
by a public official or public employee of
the authority of his office or employment or
any confidential information received through
his holding public office or employment for
the private pecuniary benefit of himself, a
member of his immediate family or a business
with which he or a member of his immediate
family is associated. "Conflict" or
"conflict of interest" does not include an
action having a de minimis economic impact or .
which affects to the same degree a class
consisting of the general public or a
subclass consisting of an industry,
occupation or other group which includes the
public official or public employee, a member
or his immediate family or a business with
which he or a member of his immediate family
is associated.
"Authority of office or employment."
The actual power provided by law, the
exercise of which is necessary to the
performance of duties and responsibilities
unique to a particular public office or
position of public employment.
Mr. William T. Jones
Page 3
"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 has a
financial interest.
Section 3(a) restricts a public official /employee from using
confidential information or the authority of public office to
obtain a private pecuniary benefit for himself, a member, of his
immediate family or business with which he or a member of his
immediate family is associated.
In addition, Sections 3(b) and 3(c) of the Ethics Law
provide in part that no person shall offer to a public
official /employee anything of monetary value and no public
official /employee shall solicit or accept any thing of monetary
value based upon the understanding that the vote, official
action, or judgement of the public official /employee would be
influenced thereby. Reference is made to these provisions of the
law not to imply that there has or will be any transgression
thereof but merely to provide a complete response to the question
presented.
Section 3(f) of the Ethics Law provides:
Section 3. Restricted activities.
(f) No public official or public
employee or his spouse or child or any
business in which the person or his spouse or
child is associated shall enter into any
contract valued at $500 or more with the
governmental body with which the public
official or public employee is associated or
any subcontract valued at $500 or more with
any person who has been awarded a contract
with the governmental body with which the
public official or public employee is
associated, 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. In such a
case, the public official or public employee
shall not have any supervisory or overall
responsibility for the implementation or
administration of the contract. Any contract
or subcontract made in violation of this
subsection shall be voidable by a court of
competent jurisdiction if the suit is
Mr. William T. Jones
Page 4
commenced within 90 days of the making of the
contract or subcontract.
Where contracting is otherwise allowed or where there
appears to be no expressed prohibition to such contracting,
Section 3(f) requires that an open and public process must be
used in all situations where a public official / employee is
otherwise appropriately contracting with his own governmental
body in an amount of $500.00 or more. This open and public
process would require:
(1) prior public notice of the employment or
contracting possibility;
sufficient time for a reasonable
competitor /applicant to be able to
present an application or proposal;
public disclosure of all applications
considered and;
(4) public disclosure of the contract awarded and
offered and accepted.
Section 3(f) of the Ethics Law also requires that the public
official /employee may not have any supervisory or overall
responsibility as to the implementation or administration of the
contract.
and prudent
prepare and
or proposals
Section 3(j) of the Ethics Law provides as follows:
Section 3. Restricted activities.
(j) Where voting conflicts are not
otherwise addressed by the Constitution of
Pennsylvania or by any law, rule, regulation,
order or ordinance, the following procedure
shall be employed. Any public official or
public employee, who in the discharge of his
official duties, would be required to vote on
a matter that would result in a conflict of
interest shall abstain from voting and, prior
to the vote being taken, publicly announce
and disclose the nature of his interest as a
public record in a written memorandum filed
with the person responsible for recording the
minutes of the meeting at which the vote is
taken, provided that whenever a governing
body would be unable to take any action on a
matter before it because the number of
Mr. William T. Jones
Page 5
members of the body required to abstain from
voting under the provisions of this section
makes the majority or other legally required
vote of approval unattainable, then such
members shall be permitted to vote if
disclosures are made as otherwise .provided
herein. In the case of a three- member
governing body of a political subdivision,
where one member has abstained from voting as
a result of a conflict of interest, and the
remaining two members of the governing body
have cast opposing votes, the member who has
abstained shall be permitted to vote to break
the tie vote if disclosure is made as
otherwise provided herein.
If a conflict exists, Section 3(j) requires the public
official /employee to abstain as well as file a written memorandum
to that effect with the person recording the minutes or his
supervisor.
In this case since Mr. Armstrong is employed by Amity
Lumber, such would be a business with which he is associated.
Accordingly, Mr. Armstrong could not vote on matters that would
directly or indirectly affect his employer and Section 3(j) of
the Ethics Law would require him to note his abstention of public
record as well as file a written memorandum to that effect with
the secretary recording the minutes. As to your second inquiry
regarding voting on matters having an indirect impact, the
definition of conflict does have an exclusion whereby a public
official may vote on matters having a de minimus economic impact
or which affects to the same degree a class consisting of the
general public or subclass consisting of an occupation industry
or group which would include the public official or business with
which he is associated. Thus, the restrictions of Section 3(a)
could extend to an indirect impact unless the matter was of a de
minimus economic impact or affected to the same degree a class
or subclass. As to your example, the councilmember would not be
precluded from voting on a borough wide ordinance. However, if
the matter was limited in impact to only a part of the borough
which would include his employer or himself or member of his
immediate family, then in that instance he would be , precluded
from voting. Concerning your third inquiry as to whether Mr.
Armstrong's continuous employment would negate the necessity of
abstention, Section 3(a) of the Ethics Law is explicit in that
abstention is required in all situations involving conflicts,
that is, the use of authority of office to obtain a private
pecuniary benefit for the public official, member of his
immediate family or business with which he is associated.
Therefore, in those instances, it would be necessary for Mr.
Mr. William T. Jones
Page 6
Armstrong to continue to abstain as to matters involving Amity
Lumber that would be before Taylor Borough Council.
The fourth inquiry you pose concerns a matter of a
councilmember voting in a situation as to a company which would
compete with the business with which he is associated. Normally,
Section 3(a) of the Ethics Law would not restrict the
councilmember from voting as to a competing company since it
should not be a business with which he is associated as that term
is defined under the Ethics Law. However, if the situation
exists that the voting aaainst a competitor would have the effect
of insuring that the business with which the public official is
associated would obtain a contract or pecuniary benefit, then in
that instance the individual must abstain and observe the
requirements of Section 3(j) noted above. In Pepper Opinion 87-
008, the Commission specifically held that public officials must
not only abstain from participation in voting as to matters
wherein they have a personal financial interest but also in
cases where their negative vote would in turn advance their own
personal financial interest. Accordingly, the councilmember
could vote on a matter of a competing company unless the effect
of casting a negative vote as to that company would insure a
benefit to the business with which he is associated.
Lastly, the propriety of the proposed conduct has only been
addressed under the Ethics Law; the applicability of any other
statute, code, ordinance, regulation or other code of conduct
other than the Ethics Law has not been considered in that they do
not involve an interpretation of the Ethics Law. Specifically
not addressed herein is the applicability of the respective
municipal code.
Conclusion: As Councilmember for Taylor Borough, Harry
Armstrong is a public official subject to the provisions of the
Ethics Law. Section 3(a) of the Ethics Law restricts a public
official from voting or participating on matters involving
himself, a member of his immediate family or business with which
he is associated. Section 3(j) of the Ethics Law would require
him to abstain and publicly announce the reason for his
abstention as well as file a written memorandum to that effect
with the secretary recording the minutes. In addition, the
public official could not vote on matters involving a company
competing with the business with which he is associated if he
would be casting a negative vote against the competing company
which would insure a pecuniary benefit for the business with
which he is associated. Lastly, the propriety of the proposed
conduct has only been addressed under the Ethics Law.
Pursuant to Section 7(9)(ii), this Advice is a complete
defense in any enforcement proceeding initiated by the
Mr. William T. Jones
Page 7
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 in writing
and must be received at the Commission within 15 days of the date
of this Advice pursuant to 51 Pa. Code 2.12.
Sigcerely,
Vincent Dopko,
Chief Counsel