HomeMy WebLinkAbout91-604 HotchkissSTATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
December 17, 1991
Mr. David L. Hotchkiss, Esquire
Culbertson, Weiss, Schetroma and Schug 91 -604
911 Diamond Park
Meadville, PA 16335 -2693
Re: Conflict Purchase
Option ion Program, Participation by Public
Authority, Board Member, Sales by Members to Authority.
Official/Employee, Economic and Industrial Development
Dear Attorney Hotchkiss:
This responds to your letters of October 8, 1991 and October
22, 1991, in which you requested advice from the State Ethics
Commission.
Issue: Whether a Member of the Board of the Conneaut Valley
Economic and Industrial Development Authority under the Public
Official and Employee Ethics Law may participate in a purchase
option program administered by the said Authority.
Facts: As Solicitor for the Conneaut Valley Economic and
Industrial Development Authority ( "Authority"), which was formed
under the Industrial and Commercial Development Authority Law, 73
P.S. §371, you seek the advice of the State Ethics Commission on
behalf of Mr. Ross Graham, who is a Board Member of the
Authority. The Authority intends to acquire purchase options
for nominal consideration, as to real estate suitable for
industrial or .commercial development. The Authority intends to
create a register of such properties and to attempt to promote
the sale and development of these properties. You have submitted
a copy of the Real Estate Purchase Option Contract, a five -page
form contract, which is incorporated herein by reference.
The Authority's activities would primarily be in the nature
of the general promotion of the Conneaut Valley area, rather than
working for the sale of a particular piece of land. If a
developer should commit to purchase one of these properties, the
Authority will assign the purchase option for nominal
consideration to the developer, in consideration for the
1
David L. Hotchkiss
December 17, 1991
Page 2
developer's commitment to purchase from the owner at the option
price. In all cases, the sale price would exceed $500.00.
At this time, the Authority is interested in optioning land
owned by Mr. Ross Graham for commercial and /or industrial
development. You specifically pose the following question: "Is
a member of the Authority Board barred from granting a purchase
option to the Authority, pursuant to this program, by reason that
this could be a contract having a value in excess of $500.00, as
prohibited by 65 P.S. Section 403 ?"
Discussion: As a Board Member for the Authority, Mr. Ross Graham
is a "public official" as that term is defined in the Ethics Law
and hence he is subject to the provisions of that Law. 65 P.S.
5402; 51 Pa. Code §1.1.
Sections 3(a), 3(f) and 3(j) of the Ethics Law provide:
Section 3. Restricted Activities.
(a) No public official or public
employee shall engage in conduct that
constitutes a conflict of interest.
(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
David L. Hotchkiss
December 17, 1991
Page 3
commenced within 90 days of the making of the
contract or subcontract.
(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.
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 or 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.
David L. Hotchkiss
December 17, 1991
Page 4
The following terms are defined in the Ethics Law:
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 of 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.
Under the Ethics Law, we must observe the stated purpose of
that Act which is to strengthen the faith and confidence of
people in their government by assuring the public that the
financial interests of the holders of or candidates for public
office do not present a conflict with the public trust.
In applying the above quoted provisions of the Ethics Law to
the instant matter, we will first consider the provisions of
Section 3(f) of the Ethics Law. Since the Authority is the
government body with which Mr. Graham is associated, Section
3(f) would apply in this case. However, contrary to the
implication of the question which you have posed, Secton 3(f)
does not act as an absolute bar to contracting with one's
governmental body where the value of the contract exceeds
$500.00.
David L. Hotchkiss
December 17, 1991
Page 5
Rather, assuming that a contract or sub - contract would be
made between Mr. Graham and the Authority pursuant to the
provisions of this purchase option program, Section 3(f) of the
Ethics Law would impose the following requirements if the
contract or sub- contract is $500.00 or more:
1. prior public notice of the contract possibility;
2. public disclosure of applications and contracts
considered;
3. public disclosure of the award of the contracts; and
4. no supervisory or overall responsibility for the
implementation or administration of the contract or
sub - contract by the public official /employee.
We will now address the propriety of the proposed conduct
under Section 3(a) of the Ethics Law. In this review, we note
and recognize the concern that arises where a public program,
funded with public monies and administered through a public
agency, political subdivision, or governmental body is also
available to public officials or employees of that agency or
governmental body. We recognize the public concern and
criticism that may arise if a public "official or public employee
who serves a governmental body receives benefits under a program
of this nature.
It is clear that the Ethics Law, and in particular Section
3(a), was primarily designed to restrict the activity of a public
official or employee from using the authority of office for
private pecuniary benefit. However, we believe that as a general
rule the Ethics Law was not enacted nor should it be interpreted
to preclude public officials or employees from participating in
programs which might otherwise be available to them as citizens.
Wolff, Opinion 89 -030; Woodrinq, Opinion 90 -001.
In order to insure that•a public official or employee is not
in a conflict when he seeks to participate in a program such as
the purchase option program under consideration, he must observe
the following:
1. play no role in establishing the criteria under which the
program is to operate, particularly with reference to the
structure or administration of the program;
David L. Hotchkiss
December 17, 1991
Page 6
2. play no role in establishing or implementing the criteria by
which selections for program participation are to be made;
3. play no role in the process of selecting and reviewing
applicants or in awarding real estate purchase option
contract(s);
4. use no confidential information acquired during the holding
of public office or public employment to apply for or to ,
obtain such real estate purchase option contract(s), and
5. abstain and publicly disclose the abstention and the reasons
for same, both orally and by filing a written memorandum
with the person responsible for recording the minutes,
pursuant to Section 3(j) of the Ethics Law, with the
abstention and disclosure requirements applying not only to
the application of the public official /employee himself, but
also as to similarly situated individuals with whom the
public official /employee might be competing for available
funds. In cases where Section 3(f) is applicable, the
public official /employee would be prohibited from any
supervisory or overall responsibility as to the contract or
program.
Through application of the above criteria, we seek to
eliminate the possibility that a public official/employee who is
seeking such funds or seeking to participate in these programs
would be in a position to insure that the program funds or the
program benefits would be available for his own benefit. Thus, a
public official or public employee in such a situation should
refrain from participating in making decisions or recommendations
about the program and regarding distribution of the limited funds
which might be available as a result of such a program.
It is clear that in order for Mr. Graham to be able to
participate in the Authority's purchase option program, he could
not have played any role in structuring the program or any
request for proposals. It is equally clear that Mr. Graham
could in no way use the authority of his office or confidential
information received by holding his office to effectuate the
exercise of any purchase option related to his real estate.
Expressly conditioned upon the assumption that Mr. Graham's
conduct would be in conformance with all of the above criteria,
Mr. Graham may apply for and participate in the benefits
associated with the real estate purchase option program.
David L. Hotchkiss
December 17, 1991
Page 7
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. However, a
serious concern is noted as to whether Mr. Graham's proposed
conduct in participating in the Authority's purchase option
program would transgress the Municipality Authorities
Act, 53 P.S. $301, et sea., and specifically the ,following
provision of that Act:
S 312. Competition in award of contracts
D. No member of the Authority or officer
or employe thereof shall either directly or
indirectly be a party to or be in any manner
interested in any contract or agreement with
the Authority for any matter, cause.or thing
whatsoever by reason whereof any lability or
indebtedness shall in any way be created
against such Authority. If any, contract or
agreement shall be made in violation of the
provisions of this section the same shall be
null and void and no action shall be
maintained thereon against such Authority.
53 P.S. §312(D). It is recommended that Mr. Graham seek the
advice of legal counsel as to his responsibilities in complying
with the Municipality Authorities Act.
Conclusion: As a Board Member for the Conneaut Valley Economic
and Industrial Development Authority ( "Authority "), Mr. Ross
Graham is a public official subject to the provisions of the
Ethics Law. Section 3(a) of the Ethics Law would not preclude
Mr. Graham from granting a real estate purchase option to the
Authority pursuant to its purchase option program provided Mr.
Graham played no role in establishing the criteria under which
the program would operate, played no role in implementing the
criteria for selecting applicants, did not in any way structure
the program or any request for proposals, played no role in
selecting or reviewing applicants, used no confidential
information and finally had no involvement with the
administration of the program. Mr. Graham would be required to
abstain from any matters before the Board pertaining to the
program, and the disclosure requirements of Section 3(j) noted
above must be observed. Mr. Graham could not use the authority
of his office or confidential information received by holding
office to effectuate the exercise of any option to purchase his
David L. Hotchkiss
December 17, 1991
Page 8
real estate. The requirements of Section 3(f) of the Ethics Law
noted above, to the extent applicable, must be observed. Lastly,
the propriety of the proposed conduct has only been addressed
under the Ethics Law. A serious concern has been noted as to
whether Mr. Graham's proposed granting of real estate purchase
option(s) to the Authority would transgress the Municipality
Authorities Act.
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 52.12.
ncerely,
Vincent J. Dopko
Chief Counsel