HomeMy WebLinkAbout93-516 WhelanJohn J. Whelan, Esquire
Doyle, Whelan & Doyle
First Pennsylvania Building
20 Garrett Road, Suite 210
Upper Darby, PA 19082
Dear Mr. Whelan:
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 23, 1993
93 -516
Re: Conflict, Public Official /Employee, Borough Council Member,
Employee, Director, Municipal Authority, Borough's Delegation
of Sewage Fee Collection to Authority.
This responds to your letter of December 21, 1992, 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 borough council
member who also serves on the board of directors or as an employee
of a municipal sewage /water authority to which the borough will be
turning over a sewage pump station, with regard to a motion to have
the authority also collect the sewer fees.
Facts: As Solicitor for the Borough of Eddystone, you seek an
advisory from the State Ethics Commission on behalf of Mr. Robert
J. Howat, Council President and an employee of the Delaware County
Regional Water Quality Control Authority ( "DELCORA "), and on behalf
of Mr. Joseph Getz, a Borough Council Member and a Member of the
Board of Directors for DELCORA. DELCORA is a Pennsylvania
Municipal Authority that services the Delaware County area in
regard mainly to sewer treatment facilities and other water quality
control. You state that it is your understanding that Mr. Howat
receives an hourly wage for his services at the DELCORA plant, and
that Mr. Getz also receives a salary for his services.
The Borough of Eddystone is in the process of completing a
sewage pump station which is expected to be turned over to DELCORA
in the next few weeks. Recently a motion was made by a Council
Member to also have DELCORA collect the sewer fees in lieu of
having the municipality do same by way of taxation. An issue was
raised as to whether Mr. Getz and Mr. Howat would have a potential
John J. Whelan, Esquire
February 23, 1993
Page 2
conflict of interest due to their connection with DELCORA, in
regard to voting on the motion. You state that out of an abundance
of caution, both of these Council Members abstained from said vote.
However, they believe that they should be permitted to vote since,
among other reasons, their salaries that are received from DELCORA
are not dependent upon this type of motion.
You further state that although there does not appear to be
case law to guide you on the exclusionary language under the
definition of "conflict" or "conflict of interest" pertaining to
subclasses, you believe that exclusion would be applicable to the
instant situation.
Based upon all of the above, you request an advisory as to
whether these two Council Members may vote on the motion pertaining
to DELCORA.
Discussion: Mr. Robert J. Howat, as President of Council for the
Borough of Eddystone, and Mr. Joseph Getz, a Member of Council for
the Borough of Eddystone and a Member of the Board of Directors of
DELCORA, are public officials as that term is defined under the
Ethics Law, and hence each is 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
John J. Whelan, Esquire
February 23, 1993
Page 3
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." Any corporation,
partnership, sole proprietorship, firm,
enterprise, franchise, association,
organization, self- employed individual,
holding company, joint stock company,
receivership, trust or any legal entity
organized for profit.
"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.
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(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 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
John J. Whelan, Esquire
February 23, 1993
Page 4
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 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
circumstances which you have submitted, pursuant to 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 the public official /public
employee himself, any member of his immediate family, or a business
with which he or a member of his immediate family is associated.
It is noted that as a governmental body, DELCORA would not be
within the definition of "business with which associated." Thus,
in this case, the potential bases for conflicts of interests would
involve private pecuniary benefits to these Council Members
themselves or members of their immediate families.
Thus, for example, if a motion were to be made before Borough
Council to turn over the pump station which would necessitate more
hours of work and /or overtime for Mr. Howat, Mr. Howat would have
a conflict of interest. The use of the authority of his office
would result in a private pecuniary benefit to him.
Similarly, if Members of the Board of Directors would receive
additional compensation from the appointing authority based upon
John J. Whelan, Esquire
February 23, 1993
Page 5
some action to be taken, such as taking over the sewage pump
station and /or collecting the sewer fees, Mr. Getz would have a
conflict of interest. The use of the authority of his office as a
Borough Council Member would result in a private pecuniary benefit
to him as a Member of the Board of Directors of DELCORA.
In each instance of a conflict• of interest, the public
official would be required to abstain and to fully satisfy the
disclosure requirements of Section 3(j).
With regard to your suggestion that the exclusionary language
under the definition of "conflict" or "conflict of interest" which
applies to qualifying subclasses, would be applicable in this case,
the facts which you have submitted simply do not reveal a basis for
a subclass exclusion.
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 and /or the
Municipality Authorities Act.
Conclusion: Robert J. Howat, as President of Borough Council for
the Borough of Eddystone, and Joseph Getz, as a Member of the
Borough Council for the Borough of Eddystone and a Member of the
Board of Directors of the Delaware County Regional Water Quality
Control Authority ( "DELCORA "), are public officials subject to the
provisions of the Ethics Law. Under Section 3(a) of the Ethics
Law, matters before Borough Council pertaining to DELCORA, where
Mr. Howat is an employee and Mr. Getz is on the Board of Directors,
and from which each receives compensation, would pose a conflict of
interest where the use of authority of office as a Borough Council
Member would result in a private pecuniary benefit to these
individuals or members of their immediate families. In each
instance of a conflict of interest, the public official would be
required to abstain and to fully satisfy the disclosure
requirements of Section 3(j). 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.
such.
This letter is a public record and will be made available as
John J. Whelan, Esquire
February 23, 1993
Page 6
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