HomeMy WebLinkAbout90-581 GobelDear Mr. Gobel:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
August 9, 1990
Mr. George S. Gobel, Esquire 90 -581
Solicitor for South Allegheny
620 West Fifth Avenue
McKeesport, PA 15131
Re: Conflict, Public Official /Employee, School Director,
Business with Which He is Associated, Investment Bonding
Firm, Client.
This responds to your letter of June 28, 1990, in which you
requested advice from the State Ethics Commission.
Issue: Whether the Public Official and Employee Ethics Law
presents any prohibition or restrictions upon a school director
as to participating or voting on the award of a contract to an
investment banking firm which is a client of a business with
which he is associated or a competing investment banking firm
which has also submitted a bid.
Facts: As the solicitor for the South Allegheny School District
and on behalf of Carl Rizzo who is a director, you seek advice
regarding an upcoming vote before the board of school directors
as to the selection of an investment banking firm. Carl Rizzo is
currently an officer, shareholder and employee of Paul C. Rizzo
and Associates, Inc. a Pennsylvania corporation which is
primarily a consultant engineering firm that from time to time
engages in business transactions with the investment banking firm
of Russell, Rea and Zappala, Inc. In such business transactions,
Paul C. Rizzo and Associates, Inc. provides services to Russell,
Rea and Zappala, Inc. for which they receive compensation. South
Allegheny School District has recently solicited proposals from
four investment banking firms to provide investment banking
services to the school district. One ,roposal was received from
Russell, Rea and Zappala, Inc. You inquire as to whether Mr.
Rizzo may vote on the motion to award the contract to the
investment banking firm of Russell, Rea and Zappala, Inc. In
addition, you inquire as to whether he may vote on a motion if
the contract is to be awarded to one of the other investment
banking firms instead of Russell, Rea and Zappala, Inc.
Mr. George S. Gobel
Page 2
Discussion: As a director for South Allegheny School District,
Carl Rizzo 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.
"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.
Mr. George S. Gobel
Page 3
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(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
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.
Mr. George S. Gobel
Page 4
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
supervisor.
In the instant matter, it is clear that Paul C. Rizzo and
Associates, Inc. is a business with which Carl Rizzo is
associated as that term is defined under the Ethics Law since he
is an officer, shareholder and employee of that firm. In
addition, the firm of Russell, Rea and Zappala, Inc. has or
continues to have business transactions with the firm of Paul C.
Rizzo and Associates, Inc. so that the firm of Russell, Rea and
Zappala, Inc. is either a client or party to contract(s) with the
firm of Paul C. Rizzo and Associates, Inc. Under Section 3(a)
quoted above, Carl Rizzo could not vote or participate on any
matter involving the firm of Paul C. Rizzo and Associates, Inc.
because that is a firm with which he is associated. In addition,
Mr. Rizzo could not vote on the motion for Russell, Rea and
Zappala, Inc. because of the business relationship between that
firm and Paul C. Rizzo and Associates, Inc. Thus, in Miller,
Opinion 89 -024, the Commission determined that a public official
who was employed by a private firm could not participate or take
action in any matters involving that firm or any plans or
projects in which that firm was involved as well as any matters
involving clients of the firm. Consequently, based upon Miller,
supra, you are advised that Paul Rizzo could not participate or
vote on a motion regarding contracting with the investment firm
of Russell, Rea and Zappala, Inc. In addition, he must abstain
and publicly set forth the reasons for his abstention as well as
file a written memorandum with the secretary recording the
minutes as per the requirements of Section 3(j) of the Ethics Law
quoted above.
As to your second inquiry of whether Carl Rizzo could vote
on a motion regarding the award of the contract to some
investment banking firm other than the firm of Russell, Rea and
Zappala, Inc., Section 3(a) of the Ethics Law would not restrict
such activity assuming that the other investment banking firm is
not a business with which the school director is associated and
assuming that ° the investment banking firm does - -not - rave a
business relationship with Mr. Rizzo or his business as per
Miller, Opinion, supra.
Parenthetically, it should be noted that in Pepper, Opinion
87 -008, the Commission determined that a public official could
not use public office to obtain a financial gain for himself and
conversely could not use the mechanism of a negative vote to
insure that any competitors for that financial gain would be
eliminated. It is not suggested that such action would be
Mr. George S. Gobel
Page 5
contemplated in this case, and the above is merely set forth to
provide a complete response to your inquiry.
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 or school code.
Conclusion: As Director for the school district, Carl Rizzo is a
public official subject to the provisions of the Ethics Law.
Under Section 3(a) of the Ethics Law, Carl Rizzo would be
prohibited from voting on a motion to award a contract to a
client or party who has a contract with the business with which
he is associated. The disclosure requirements of Section 3(j) of
the Ethics Law outlined above must be followed. Carl Rizzo would
not be precluded from voting on a motion to award the contract to
some other investment banking firm subject to the qualifications
noted above. Lastly, the propriety of the proposed conduct has
only been addressed under the Ethics Law.
Pursuant to Section 7(11), 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.
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 in writing
and must be received at the Commission within 15 days of the date
of this Advice pursuant to 51 Pa. Code S2.12.
incent 3` Dopko,
Chief Counsel