HomeMy WebLinkAbout92-515-SDear Mr. Biondo:
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
May 6, 1992
Dennis R. Biondo, Esquire 92 -515 -S
Jack Hickton & Associates
701 Washington Road
Mt. Lebanon, PA 15228 -1909
Re: Conflict, Public Official /Employee, Borough Council Member,
Business with which Associated, Clients, Supplemental Advice.
This responds to your letter of March 19, 1992, in which you
requested supplemental advice from the State Ethics Commission.
Issue: Whether the Public Official and Employee Ethics Law
presents any prohibition or restrictions upon a borough council
member employed by a firm which serves private clients, including
the borough engineer, which do business with the borough and
receive regular payments from the borough, with regard to the
borough's payment of bills to those clients, and with regard to the
authorization of work pertaining to a road repair /reconstruction
project which would result in paid work for the borough engineer.
Facts: Following a letter of request of December 9, 1991, Advice
of Counsel 92 -515 was issued which is incorporated herein by
reference. That Advice concluded that in his capacity as a Borough
Council Member for the Borough of Castle Shannon in Allegheny
County, Pennsylvania, Mr. Regis J. Zezulewicz, Jr. would have a
conflict of interest as to any matter involving his private
employer, Coordinated Group of Companies, Inc. (CGC), and /or any of
its clients, including but not limited to L. Robert Kimball &
Associates (the Borough Engineer), HDH Group, Inc., and Blue
Cross /Blue Shield. You were advised that in each instance of a
conflict of interest, Mr. Zezulewicz would be required to abstain
from any participation of any nature whatsoever and to publicly
announce his abstention and the reasons for same, both orally and
in a written memorandum filed with the secretary recording the
minutes. Finally, the Advice concluded that Mr. Zezulewicz could
not use any Borough facilities to further the business interests of
CGC and /or any of its clients.
By letter dated March 19, 1992, you have requested a
Dennis R. Biondo, Esquire
May 6, 1992
Page 2
supplemental advisory regarding Advice of Counsel 92 -515.
Your supplementary request notes that since the issuance of
Advice 92 -515, several issues have arisen related to specific
factual circumstances, causing confusion and uncertainty for Mr.
Zezulewicz and other Council Members.
The Borough is in the midst of an extensive road
reconstruction project of major importance to the Borough,
involving most of the roads within the Borough. You state that
input, deliberation and action will be "expected" of all Council
Members. The project will require an assessment of the condition
of all Borough roads by the Borough Engineer, L. Robert Kimball &
Associates (LRKA) with LRKA then making reports and recommendations
to Council for repairs and /or reconstruction of those roads.
Council expects to deliberate and act to do such repair/
reconstruction work by advertising for bids from construction firms
to do the required work and by entering into contracts for that
purpose. Throughout this process, Members of Council will receive
information from LRKA and in all likelihood will request the
Engineer to provide additional information, recommendations, and
the like, to prepare plans and specifications for the
repair /reconstruction work, and to oversee and inspect that work as
it is being performed by the entities which are contracted to do
the work. Throughout this process, the Engineer will be requested
to perform certain work for the Borough for which it will submit a
bill and expect payment. You note that LRKA was appointed as the
Borough Engineer by Council at the beginning of this year and a
contract was entered into between the Borough and LRKA specifying
the methods and rates of payments, although you have not provided
a copy of said contract to this Commission.
You state that two questions arise. First, you ask whether
Mr. Zezulewicz is required to abstain from voting or participating
in deliberations regarding the road repair /reconstruction project
merely because every time any such work is authorized, LRKA will be
involved in preparing specifications, inspections, and the like.
As to this inquiry, you urge that the prior Advice not be
interpreted to prevent Mr. Zezulewicz from participating in such
matters. You state that the primary purpose of such action would
be unrelated to LRKA and the engineering involvement would only be
incidental to the main work being performed, specifically road
repair /reconstruction. You state that the same issue arises with
many other projects which the Borough or any other municipality
would undertake. Many, if not all, of the public works projects of
any municipality require the involvement of the municipal engineer.
To prevent Mr. Zezulewicz from acting in these circumstances, you
state, would effectively prevent him from representing his
constituency, the residents of Castle Shannon, with regard to vital
and important issues within the Borough.
Dennis R. Biondo, Esquire
May 6, 1992
Page 3
Your second inquiry involves the payment of bills. On a
monthly basis, the Borough receives a bill for services rendered by
LRRA. Borough Council is required to vote to pay all bills. LRRA
was appointed as Borough Engineer at the beginning of the year,
with Mr. Zezulewicz abstaining, and a contract was entered into
detailing the rate of compensation. Therefore, you state that
action of Council in authorizing payment of the bills, including
those of LRRA, although necessary, is rather ministerial as opposed
to an action requiring an exercise of discretion on the part of the
individual Council Members. The work has already been performed by
LRRA at a rate of compensation that was previously established by
contract. You state that as a practical matter, the only action
taken by individual Members of Council with regard to the payment
of the bills is to question the accuracy or necessity of the work
performed. It is your opinion that to require Mr. Zezulewicz to
abstain from that action would severely restrict his ability to
perform one of the functions which he was elected to do,
specifically to protect the municipal finances.
You state that although you have framed the above questions as
relating to LRKA, the same questions are presented with regard to
HDH Group, Inc. (HDH), and to a lesser extent, Blue Cross /Blue
Shield. When an issue arises regarding insurance coverage or
liability, HDH might be requested to provide information or
recommendations although, generally, the only payments made to HDH
are for liability insurance coverage. The decision to purchase
insurance from HDH would have previously been made with only
periodic payment of premiums throughout the term of the policy
purchased from HDH. You state that a broad reading of Advice 92-
515 would require that Mr. Zezulewicz abstain from voting to "pay
the bills" when such a bill is included among them.
Likewise, with regard to Blue Cross /Blue Shield, you state
that the decision to provide medical benefits coverage for Borough
employees through the Municipal Employers Insurance Trust and Blue
Cross /Blue Shield is made annually or less often. The action of
paying that bill on a monthly basis would only be pro forma action,
you believe, unless there was a question regarding that particular
bill.
In summarizing your supplemental request, you state that
Advice 92 -515 obviously would prevent Mr. Zezulewicz from
participating in deliberations or voting to appoint LRRA or to
purchase insurance coverage from HDH or Blue Cross /Blue Shield.
However, you state that there is some question as to whether the
Advice would prevent Mr. Zezulewicz from participating in
deliberations or acting on matters under the circumstances which
you have set forth.
Based upon all of the above, you request a supplemental
Dennis R. Biondo, Esquire
May 6, 1992
Page 4
advisory.
Discussion: As a Borough Council Member for the Borough of Castle
Shannon ( "Borough ") in Allegheny County, Pennsylvania, Mr. Regis J.
Zezulewicz, Jr. is a public official as that term is defined under
the Ethics Law, and hence he is subject to the provisions of that
law.
The general provisions and restrictions of the Ethics Law
applicable to your supplemental inquiry have been fully set forth
in Advice 92 -515 and will not be repeated, but rather, the focus of
this supplemental Advice shall be directed toward the specific
issues which you have raised.
It is initially noted that the contract between the Borough
and LRKA has not been provided to this Commission, nor has there
been any explanation of the compensation arrangement for the
services of the Borough Engineer. This sort of arrangement varies
among municipalities. There may be a set salary encompassing
certain pre- authorized types of services, with extra services to be
additionally-authorized and compensated. On the other hand, it may
be that each item of work performed by the Borough Engineer must be
authorized by Council and is billed on an item -by -item basis.
First, you have asked whether Mr. Zezulewicz would be required
to abstain from voting or participating in deliberations regarding
the road repair /reconstruction project because every time any such
work is authorized, LRKA would be involved in preparing
specifications, inspections, and the like. The key to your
question lies in determining which "use of authority of office"
authorizes work to be done by the Borough Engineer. Mr. Zezulewicz
would have a conflict of interest in any matter before Council
which would authorize work to be done by LRKA. Thus, if a matter
before Council pertains purely to the road repair /reconstruction
work, and any related work by LRKA has been pre- authorized by the
Borough's contract with LRKA, there would not be a conflict of
interest for Mr. Zezulewicz, but if the matter in any way includes
authorization of LRKA to perform work for a fee, the conflict would
arise.
As to your second inquiry, involving the payment of bills, it
must initially be noted that you have erroneously characterized
Advice 92 -515 as precluding a vote to "pay the bills" when they
include a bill as to which there is a conflict. The restrictions
by the Ethics Law would apply only as to the bills for which there
is a conflict. It appears to be solely the choice of the Borough
to consider the bills together.
As to LRKA, HDH and /or Blue Cross /Blue Shield, prior precedent
of the Commission which would continue to apply under Act 9 of 1989
Dennis R. Biondo, Esquire
May 6, 1992
Page 5
holds that if payment of bills submitted by a public official/
public employee's employer amounts to concurrence and payment of a
pre- fixed, undisputed amount, the public official /public employee
may vote to pay the employer's bill as presented, but if such
payment would be subject to the discretion of the public
official /public employee or otherwise subject to question, dispute
or adjustment, there would be a conflict of interest and the public
official /public employee would be required to abstain from any
participation in the decision to pay the amount in question. See,
Krushinski, Order No. 168 at 4 (and authorities cited therein).
These same principles would likewise apply to situations where the
conflict of interest would arise as to paying bills to the
employer's client. Thus, if the Borough's payment of a bill to
LRKA, HDH and /or Blue Cross /Blue Shield is pre -fixed and
undisputed, Mr. Zezulewicz could participate in the vote. On the
other hand, if the payment would be subject to his discretion as a
Council Member or otherwise subject to question, dispute or
adjustment, Mr. Zezulewicz could not participate. Although you
characterize the payment of such bills to be ministerial, you have
acknowledged that at least as to LRKA, the Council's action with
regard to payment of bills would still be to question the accuracy
or necessity of the work performed, which would be sufficient for
the conflict of interest to arise for Mr. Zezulewicz.
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 Borough Code.
Conclusion: As a Borough Council Member for the Borough of
Castle Shannon in Allegheny County, Pennsylvania, Mr. Regis J.
Zezulewicz, Jr. is a public official subject to the provisions of
the Ethics Law. The restrictions set forth in Advice 92 -515 and
above must be followed. Mr. Zezulewicz would have a conflict of
interest as to any matter authorizing work to be performed by the
Borough Engineer for a fee. Mr. Zezulewicz would not have a
conflict of interest as to matters resulting automatically in work
for the Borough Engineer pursuant to predetermined contractual
duties of the Borough Engineer. Mr. Zezulewicz may vote with
regard to the Borough's payment of bills to his employer's clients
if such bills are of a pre - fixed, undisputed amount and would not
be subject to his discretion as a Council Member or otherwise
subject to question, dispute or adjustment. 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
Dennis R. Biondo, Esquire
May 6, 1992
Page 6
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,
Vincen J. Dopko
Chief Counsel