HomeMy WebLinkAbout91-518 HardtMs. Joy A. Hardt
Cedar Ridge Road
Allison Park, PA 15101
Dear Ms. Hardt:
STATE ETHICS COMMISSION t
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
February 27, 1991
Re: Conflict, Public Official, Auditor, Candidate, Township Manager,
Voting, Salary.
This responds to your letter of January 23, 1991, 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 township auditor from
participating in the responsibility of setting "reasonable
compensation" for the township manager position when the auditor may be
a candidate for the township manager position.
Facts: As one of three elected auditors for the township of West Deer
which is a Second Class Township, Home Rule Community in Allegheny
County, you seek the advice of the State Ethics Commission. In the
November election, a referendum was passed by the voters of the
township to elect the township manager beginning with the 1991
election. The auditors have been charged with the responsibility of
setting "reasonable compensation" for the township manager position.
You indicate your belief that the compensation was to be officially set
by February 10. One of the three elected auditors is running in the
primary for the position of township manager and you are also
considering running for the position. You state your belief that two
of the three auditors may have a vested interest in the township
manager position. You inquire with regard to the propriety of your
potential candidacy for the township manager position while serving as
an elected auditor charged with the responsibility of setting the
compensation for that same position.
Discussion: As an elected auditor for the home rule charter township
of West Deer, you are a public official as that term is defined under
the Ethics Law, and hence you are subject to the provisions of that
law.
Section 3(a) of the Ethics Law provides:
91 -518
Ms. Joy A. Hardt
Page 2
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.
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
Ms. Joy A. Hardt
Page 3
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.
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 event that the required abstention results in the
inability of the governmental body to take action because a majority is
unattainable due to the abstention(s), then in that event participation
is permissible provided the disclosure requirements noted above are
followed.
Before addressing your particular inquiry, it is initially noted
that your inquiry may only be addressed under the Ethics Law; the
applicability of any other statute, code, ordinance, regulation or
other code of conduct other than the Ethics Act may not be considered
in that such would not involve an interpretation of the Ethics Law.
Secondly, this advice is directed to your proposed conduct only and
does not address the propriety of the proposed conduct of the other
auditor who is seeking election to the township manager position.
Section 7(10) and (11) of the Ethics Law limit the issuance of advisory
opinions to persons or their authorized representatives who may seek
advice relative to their own conduct. To the extent your inquiry
relates to the conduct of some other public official, it is considered
a third party request and as such cannot be addressed.
Ms. Joy A. Hardt
Page 4
In applying the provisions of Section 3(a) of the Ethics Law
above to the instant matter, the restriction of Section 3(a) is that a
public official may not use the authority of office or confidential
information received through holding public office to obtain a private
pecuniary benefit for himself., a member of his immediate family or a
business with which he or a member of his immediate family is
associated.
In this case it is clear that your participation or voting to set
the compensation for the township manager position would constitute a
conflict of interest under the Ethics Law. Your participation or vote
would be a use of the authority of your office. See, Krause, Advice
90 -530 at 2 -3. Furthermore, you would be using the authority of your
office to set the compensation for the position which you hope to hold.
If you are elected to the township manger position, your participation
or vote as an auditor in setting the compensation for the township
manger position would be a use of the authority of your office to
obtain a private pecuniary gain for yourself. You would, in essence,
have an impact upon fixing your own compensation. In this situation,
you clearly must divest yourself from any participation in the
township's actions in setting the compensation for the township manager
position.
In light of the above, Section 3(j) of the Ethics Law would
require you to publicly announce and disclose the nature of your
interests in a written memorandum filed with the secretary responsible
for recording the minutes of the meeting of the township auditors.
However, in the event that the remaining auditors split on their
vote after your abstention or are unable to take any action on the
matter because the number of auditors required to abstain from voting
make the majority or other legally required vote of approval
unattainable, then Section 3(j) would allow you to vote in either such
instance provided the disclosure requirements of Section 3(j) outlined
above are followed.
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.
Conclusion: As an elected auditor for the home rule charter township
of West Deer, you are a public official subject to the provisions of
the Ethics Law. Section 3(a) of the Ethics Law would preclude you as
an auditor for a Second Class Township, Home Rule community from
participating in any fashion or voting to set the salary of the
township manager position when you are a candidate for the township
manager position. Section 3(j) of the Ethics Law requires that you
Ms. Joy A. Hardt
Page 5
publicly announce and disclose at the next public meeting of the
auditors the nature of your interest in a written memorandum filed with
the secretary who keeps the minutes. In the event that a deadlock
would occur due to your abstention or should the number of auditors
required to abstain from voting under the provisions of Section 3(j)
make the majority or other legally required vote of approval
unattainable, Section 3(j) of the Ethics Law would allow you to vote
provided you comply with the disclosure requirements of Section 3(j) as
discussed 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.
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 52.12.
Sincerely,
Vincent . Dopko,
Chief Counsel