HomeMy WebLinkAbout91-527 ConfidentialSTATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
March 29, 1991
91 -527
Re: Conflict, Public Official /Employee, Municipal Authority,
Municipal Authority Member, Solicitor, Business with Which
Associated.
This responds to your letters of February 22, 1991, February
28, 1991, and March 1, 1991, in which you requested confidential
advice from the State Ethics Commission.
Issue: Whether the Public Official and Employee Ethics Law
presents any prohibition or restrictions upon you as the
Solicitor for a Municipal Authority, or upon a Municipal
Authority member, with regard to the Authority's soliciting local
banks for a line of credit sufficient to meet expenses related to
constructing a sewer system until federal grant and PENNVEST loan
funds become available, where you are also the attorney and a
director of a local bank, and where the Municipal Authority
member is an employee of a local construction corporation which
may bid on the job.
Facts: As the solicitor for a Municipal Authority which proposes
to construct a sewer system, you are seeking the advice of the
State Ethics Commission on your own behalf and with regard to an
Authority member who has authorized you to inquire on his behalf.
The financing for the sewer system involves federal grants and
PENNVEST loans, but because the Authority will not receive either
the grant or loan funds for several months after the project has
commenced, it will be necessary for the Authority to secure
interim local financing. The Authority proposes to solicit
local banks for a line of credit sufficient to meet expenses
until the federal grant and PENNVEST loan funds become available.
In addition to being the solicitor for the Municipal Authority,
you are also the attorney and a director of a local bank. You
have posed the following specific inquiries regarding your own
situation:
1. Whether your position as director and attorney for the
bank would disqualify the bank from bidding for the
interim financing?
Page 2
2. In the event that the bank wanted to compete for this
loan, what your position should be as solicitor for the
Authority?
3. Whether the bank could offer a loan if you abstained as
a director from participating in any action taken by
the bank?
Turning to the member of the Authority who has authorized
you to inquire on his behalf, Member A, you state that he is an
employee of a local construction corporation. You note that
Member A has indicated this employment on the statements which he
has filed under the Ethics Law. As an employee of the local
construction corporation, Member A is involved in estimating
contracts and he is a Project Manager. He also participates in a
recently instituted employee stock purchase plan. The stock is
offered as a bonus, and as an employee of the construction
corporation, Member A has recently received a few shares in the
corporation. The stock which Member A has received is far less
than one percent of the stock outstanding, which is principally
held by family members. Member A's employer may bid on the job
for the municipal Authority. You have posed the following
specific inquiries with regard to Member A's position:
1. Assuming that the Authority will ask for public bids on the
utility project, what should Member A's position be in the
event that his employer enters a bid on all or a part of the
project?
2. Must Member A take action prior to bid opening?
3. What position should Member A take if his employer is the
low bidder?
4. Would Member A be able to remain on the Authority in the
event that his employer entered a bid?
5. What would Member A's position be if his employer was the
low bidder, and what would his position be if his employer
was not the low bidder?
6. If Member A's employer was the low bidder, could he maintain
his Authority membership by not participating in the awards
of the contracts?
Discussion: It is initially noted that your questions are only
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
Page 3
not addressed herein is the applicability of the Municipality
Authorities Act.
As the Solicitor for a Municipal Authority, you are a public
employee as that term is defined under the Ethics Law, and hence
you are subject to the provisions of that law. As a member of a
Municipal Authority, Member A is a public official as that term
is defined under the Ethics Law and thus he is also 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.
Page 4
"Immediate family." A parent, spouse,
child, brother or sister.
"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.
"Financial interest." Any financial
interest in a legal entity engaged in
business for profit which comprises more
than 5% of the equity of the business or more
than 5% of the assets of the economic
interest in indebtedness.
"Contract." An agreement or arrangement
for the acquisition, use or disposal by the
Commonwealth or a political subdivision of
consulting or other services or of supplies,
materials, equipment, land or other personal
or real property. "Contract ". shall not mean
an agreement or arrangement between the State
or political subdivision as one party and a
public official or public employee as the
other party, concerning his expense,
reimbursement, salary, wage, retirement or
other benefit, tenure or other matters in
consideration of his current public
employment with the Commonwealth or a
political subdivision.
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
Page 5
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
commenced within 90 days of the making of the
contract or subcontract.
Parenthetically, where contracting is otherwise allowed or
where there appears to be no expressed prohibitions to such
contracting, the above particular provision of law would require
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;
(2) sufficient time for a reasonable
competitor /applicant to be able to
present an application or proposal;
(3) public disclosure of all applications
considered and;
and prudent
prepare and
or proposals
awarded and
(4) public disclosure of the contract
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.
Section 3(j) of the Ethics Law provides as follows:
Section 3. Restricted activities.
Page 6
(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.
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. The public official must also publicly announce the
nature of his interest.
We must review the specific questions you have presented
under the above provisions of the Ethics Law.
In response to your first specific inquiry, under the Ethics
Law, your position as director and attorney for the bank would
not disqualify the bank from bidding for the interim financing
even though you are also the solicitor for the Municipal
Authority. This is because the bank is not a public official or
public employee as those terms are defined in the Ethics Law.
Page 7
Your second specific inquiry asks what your position should
be as solicitor for the Authority in the event that the bank
wants to compete for this loan. As a solicitor for the Municipal
Authority, you are a public employee as that term is defined in
the Ethics Law, and you are subject to the requirements of
Section 4 of the Ethics Law regarding filing Financial Interests
Statements. You are also subject to the other provisions of the
Ethics Law. Spataro, Opinion 89 -009 at 4. See also, Maunus v.
Com., State Ethics Com., 544 A.2d 1324, 1326 (1988).
Being subject to Section 3(a) of the Ethics Law, you are
prohibited from engaging in conduct that constitutes a conflict
of interest. It seems fairly clear that these circumstances
would present a conflict of interest for you, and thus you would
have to completely remove yourself from any participation or
involvement with the local financing aspect of this project.
Your abstention must preclude any risk of disclosing confidential
information which could benefit the bank. You would also be
required to disclose the nature of your conflict in a written
memorandum filed with the Municipal Authority.
Your third inquiry may not be addressed from your
perspective as a director of the bank, because a bank director
per se is not considered a public official or employee subject to
Section 3(a) of the Ethics Law. Rather, it is in your capacity
as solicitor for the Municipal Authority that you are a public
employee subject to the provisions of the Ethics Law. It is only
from the perspective of your public employment that your
inquiries regarding your own situation may be addressed.
The questions which you have posed on behalf of Member A
first ask, assuming that the Authority will ask for public bids
on the utility project, what should Member A's position be in the
event that his employer enters a bid on all or part of the
project? It is clear that Member A is a "public official" and
that his employer is a "business with which he is associated" as
these terms are defined by the Ethics Law. Given that Member A's
employer may enter a bid on all or part of this project, the
circumstances present a clear conflict of interest for Member A.
Member A must remove himself entirely from any participation with
the sewer system project.
Member A's abstention
include his abstention from
the project, but would also
any confidential information
from this project would not only
any discussions and votes regarding
preclude him from gaining access to
regarding the project.
In Van Rensler, Opinion 90 -017, the Commission held that the
Ethics Law prohibited school board directors from participating
on a negotiating team with regard to a collective bargaining
agreement when members of their immediate family were school
Page 8
district employees represented by the bargaining units. The
Commission reasoned that by being part of the negotiating team
which is part of their public position, the school directors
would be necessarily privy to confidential information concerning
the bargaining units of which their family members are parts.
Id. at 4. The Commission held that these school directors could
not participate on the negotiating team, "due to the great
potential for accidental or inadvertent disclosure." Id. See
also, Mattie, Advice 91 -508 (School board director whose spouse
was a teacher and member of the employee bargaining unit would be
precluded from receiving financial information related to the
budget which information would impact upon the negotiating
process with the bargaining unit).
In this case, Member A as a public official would be
precluded from anv participation with regard to the sewer
project, from its very inception. A Municipal Authority member
participating as a member of the Authority even before the bid
opening, would be likely to be privy to confidential information
which could benefit a business planning to submit a bid to the
Authority. As in Van Rensler, supra, the risk of disclosure of
that information would preclude the Municipal Authority member
from participating even at the beginning stages of the sewer
project. Any such disclosure could defeat an open and public
bidding process.
As discussed generally above, where a public official such
as Member A is faced with a conflict of interests, he must not
only abstain but he must also comply with Section 3(j) of the
Ethics Law. Therefore, as a public official Member A would be
required not only to abstain entirely from any participation in
this project, but he would also be required to publicly announce
as well as disclose the nature of his interests as a public
record in a written memorandum filed with the person responsible
for recording the minutes. It should also be noted that under
these circumstances, Member A's conflict of interests would go
well beyond a mere voting conflict under Section 3(j).
In response to your second specific inquiry regarding this
Authority member, Member A would be required to take action prior
to bid opening - indeed, he must take action to remove himself
entirely from any participation with the sewer project from its
inception.
Furthermore, the restrictions of Section 3(f) set forth
above must be observed should Member A's employer wish to
contract with his governmental body.
In response to your third, fifth and sixth specific
inquiries regarding Member A, this member's position would be as
outlined above regardless of whether his employer is or is not
Page 9
the low bidder. It is additionally noted that Member A would be
precluded from having any supervisory or overall responsibility
for the implementation or administration of any contract between
his employer and the governmental body, pursuant to Section 3(f)
of the Ethics Law.
In response to your fourth and sixth specific inquiries
regarding Member A, his membership on the authority would not be
implicated conditioned upon his complying with the above
restrictions. The State Ethics Commission does not have the
authority to oust public officials from their positions,
however, in the event that the provisions of the Ethics Law are
violated, the Commission does refer such matters to appropriate
law enforcement or other officials as set forth in Section 7 of
the Ethics Law, 65 P.S. 5407.
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 Municipality
Authorities Act.
Conclusion: As a solicitor for a Municipal Authority, you are a
public employee subject to the provisions of the Ethics Law. As
a member of a Municipal Authority, Member A is a public official
subject to the provisions of the Ethics Law. Your position as a
director and attorney for a bank would not disqualify the bank
from bidding for interim local financing for the Municipal
Authority even though you are also the solicitor for the
Municipal Authority, because the bank is not a public official or
public employee as those terms are defined under the Ethics Law.
However, in your capacity as a public employee, you would be
required under the Ethics Law to remove yourself from any
participation or involvement with the local financing aspect of
the sewer project if the bank is to compete for this loan. Your
abstention must preclude any risk of disclosing confidential
information which could benefit the bank. You must also comply
with the disclosure requirements set forth above. Your third
inquiry, regarding your situation may not be addressed because it
is from your perspective as a bank director rather than as a
public employee. In his capacity as a public official, Member A
must remove himself entirely from any participation with the
sewer system project from its inception including but not
limited to discussions and votes. Member A may not have access
to any confidential information regarding the sewer project. The
restrictions of Section 3(f) of the Ethics Law set forth above
must be observed should Member A's employer contract with the
governmental body. Member A would be precluded from having any
supervisory or overall responsibility for the implementation or
Page 10
such.
administration of any contract between his employer . and the
governmental body. Member A's ability to remain a member of the
Municipal Authority would not be at issue as long as he complies
with the restrictions set forth 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
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,
/f/A4.7 : t -i j
Vincent J. Dopko,
Chief Counsel
^ LL
_ . ✓LC e': �'.: