HomeMy WebLinkAbout92-523Mr. Charles M. Marks, Sr.
C.M. Marks, Inc.
2041-A Ewings Mill Road
Coraopolis, PA 15108
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
February 6, 1992
92 - 523
Re: Conflict, Public Official /Employee, Private Employment or
Business, Board Member, Municipal Authority, Township,
Utility Contractor, Installation of Utilities in the
Township.
Dear Mr. Marks:
This responds to your letter of December 12, 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 board member of a
municipal authority of a township with regard to installing
utilities in the township in a private capacity as a utility
contractor.
Facts: Noting a prior telephone conversation with this
Commission, you seek an advisory from the State Ethics Commission
in your capacity as a Board Member of the Municipal Authority of
the Township of Robinson. Your term of office expires December
31, 1992. You have been a utility contraci,or for the past twenty
years, and you would like to start installing utilities again.
You state that you would not consider taking such action unless
you are sure you would not be violating any State Ethics Laws.
You state that you were given an opinion that if you followed
guidelines set by this Commission you could be eligible to
participate in the bidding process. The jobs in question would
be in the Township of Robinson.
Discussion: As a Board Member of the Municipal Authority of the
Township of Robinson, Pennsylvania, 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.
Mr. Charles M. Marks
February 6, 1992
Page 2
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 no 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.
"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.
"Contract." An agreement or arrangement
for the acquisition, use or disposal by the
Commonwealth or a political subdivision of
Mr. Charles M. Marks
February 6, 1992
Page 3
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 anything 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 been 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
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 $503 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
Mr. Charles M. Marks
February 6, 1992
Page 4
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 emoloyment or contracting
possibility;
(2) sufficient time for a reasonable and prudent
competitor /applicant to be able to prepare and present
an application or proposal;
(3) public disclosure of all applications or proposals
considered and;
(4) public disclosure of the contract awarded and offered
and accepted.
Section 3(f) of the Ethics Law also requires that the public
official /employee may not have any :,upervisory 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 activitiA3.
(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
Mr. Charles M. Marks
February 6, 1992
Page 5
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 and to publicly disclose the
abstention and the reasons for same, both orally and by filing a
written memorandum to that effect with the person recording the
minutes or supervisor.
In applying the above provisions of the Ethics Law to the
facts which you have submitted, it is initially noted that your
request for advice is very general, and so this Advice responding
to your inquiry must also be very general.
Under Section 3(a) of the Ethics Law, a public
official /public employee is prohibited from using the authority
of public office /employment or confidential information received
by holding such a public position 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.
We note that Section 3(a) of the Ethics Law does not
prohibit public officials /employees from outside business
activities or employment; however, the public official /employee
may not use the authority of office for the advancement of his
own private pecuniary benefit or that of a business with which he
Mr. Charles M. Marks
February 6, 1992
Page 6
is associated. Pancoe, Opinion 89 -011. Section 3(a) would also
specifically prohibit the use of confidential information
received by holding public office /public employment for such a
prohibited private pecuniary benefit. A public official /public
employee may not use the authority of his public position, or
any confidential information received by holding such a position,
either as a means of obtaining or advancing an opportunity for
business or employment in a private capacity, or as a means of
attempting to eliminate any potential competitors who would be
competing for such private business opportunities or employment.
See Wall, Advice 90 -567 (Citing Pepper, Opinion 87 -008). The
Ethics Law would restrict the use of authority of office to
obtain any business in a private capacity; any utilization of
confidential information gained through public position; and /or
participating in discussions, reviews, or recommendations on
matters which relate to the business /private employer which may
come before the governmental body. A public official /employee
must exercise caution so that his private business activities do
not conflict with his public duties. Crisci, Opinion 89 -013.
Thus, a public official /employee could not perform private
business using governmental facilities or personnel. In
particular, the governmental telephones, postage, staff,
equipment, research materials, personnel or any other property
could not be used as a means, in whole or part, to carry out
private business activities. In addition, the public
official /employee could not during government working hours,
solicit or promote such business activity. Pancoe, supra.
In the event that you or your private employer or business
would have a matter pending before the Municipal Authority of the
Township of Robinson as your governmental body or if you as part
of such official duties must participate, review or pass upon
such a matter, a conflict would exist. Miller, Opinion 89 -024.
In such instances, it would be necessary that you be removed from
that process.
In each instance of a conflict of interest, you would be
required to abstain from any participation of any nature
whatsoever in the matter and to satisfy the disclosure
requirements of Section 3(j) set forth above.
As for the restrictions of Section 3(f) of the Ethics Law,
during your term of office you and /or any business with which you
are associated would be required to observe those restrictions
for any contracts with the Municipal Authority of the Township of
Robinson, where the value of the contract is $500 or more.
Upon termination of public service, you would become a
"former public official" subject to Section 3(g) of the Public
Mr. Charles M. Marks
February 6, 1992
Page 7
Official and Employee Ethics Law. Section 3(g) of the Ethics Act
provides that:
Section 4. Restricted activities
(g) No former public official or public
employee shall represent a person, with
promised or actual compensation, on any
matter before the governmental body with
which he has been associated for one year
after he leaves that body. 65 P.S. 5403(g).
Section 3(g) would place new restrictions upon you in your
future status as a "former public official," which would preclude
you from representing a "person" - including but not limited to
yourself and any business with which you are associated - before
the municipal authority of the Township of Robinson, for promised
or actual compensation, for one year following termination of
your public service. It is recommended that you seek further
advice from this Commission regarding the restrictions of Section
3(g) as they would apply to you based upon your factual
circumstances when you leave office.
Lastly, 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 Act has not been con3idered in that they do
not involve an interpretation of the Ethics Law. However, it is
recommended that you seek the advice of legal counsel as to any
applicability of the following provision of the Municipality
Authorities Act:
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 liability 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. §312D.
Mr. Charles M. Marks
February 6, 1992
Page 8
Conclusion: As a Board Member of the Municipal Authority of the
Township of Robinson, you are a public official subject to the
provisions of the Ethics Law. Section 3(a) of the Ethics Law
would not preclude you from outside employment /business activity
as a utility contractor subject to the restrictions and
qualifications noted above. In the event that you and /or your
employer /business has matters pending before the Municipal
Authority of the Township of Robinson as your governmental body,
then you may not participate in such matters and the disclosure
requirements of Section 3(j) of the Ethics Law as outlined above
must be satisfied. The restrictions of Section 3(f) must be
fully satisfied where applicable. Upon termination of service
with the Municipal Authority of the Township of Robinson, you
would become a "former public official" subject to Section 3(g)
of the Ethics Law. It is recommend that you seek further advice
from this Commission as to the restrictions of Section 3(g) as
they would apply to you upon the termination of your public
office. Lastly, the propriety of the proposed conduct has only
been addressed under the Ethics Law.
Further, should service be terminated, as outlined above,
the Ethics Law also requires that a Statement of Financial
Interests be filed for the year following termination of service.
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 §2.12.
Sincerely,.+
Vincent J. Dopko
Chief Counsel