HomeMy WebLinkAbout93-521 CowdenDear Mr. Cowden:
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
March 3, 1993
James L. Cowden, Esquire 93 -521
Strokoff & Cowden, P.C.
132 State Street
P.O. Box 11903
Harrisburg, PA 17108
Re: Conflict, Public Official /Employee, Borough Council Member,
Business with which Associated, Fire Company, Chief.
This responds to your letter of January 20, 1993, 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 as chief of a fire company within the
borough, with regard to matters pertaining to the fire company.
Facts: You request an advisory from the State Ethics Commission on
behalf of Mr. Herman Himes, who was recently appointed to the
Highspire Borough Council to fill a vacancy. Mr. Himes also serves
as Chief of the Citizens Fire Company No. 1 in Highspire, which is
a volunteer fire company located within the Borough.
You state that a relationship exists between the fire company
and the Borough which is partially statutory and partially
voluntary, and which results in the Borough providing certain
financial support to the fire company. As a Borough Council
Member, Mr. Himes will be called upon to participate in decision
making concerning the Borough budget and other appropriations and
actions that would benefit the fire company. At the same time, Mr.
Himes receives certain perquisites of office from the fire company.
You set forth the following background information:
Citizens Fire Company has been located
within the Borough for many years. Because it
is a voluntary company, the Borough is
required by statute to provide workmen's
James L. Cowden, Esquire
March 3, 1993
Page 2
compensation coverage for volunteer firemen,
including the Chief. The Borough has also
traditionally made an appropriation to the
fire company in its annual budget. For
example, the 1993 budget provides for an
appropriation for fire protection of
$37,326.00, payable to either the fire company
or for the exclusive benefit of the company or
its volunteer firemen. This includes the
following entries:
1. $12,000.00 toward payment of the fire
company's insurance costs;
2. $3,726.00 for payment of workmen's
compensation coverage;
3. $14,100.00 toward the operating expenses
of the fire company; and
4. $7,500.00 to an escrow account toward the
purchase of a new fire truck planned for
1995.
Borough Council also passes through to the
fire company state funds that are restricted
for distribution to firemen's relief
associations.
Several miscellaneous matters normally
come up before Council each year that would
benefit the fire company. For example, the
fire company raises a large part of its
revenues from an annual carnival. Borough
Council normally authorizes the Borough
Highway Department to provide labor in setting
up carnival stands. Council is sometimes
called upon specifically to authorize police
overtime for security at the carnival. In the
past year, Council was asked to pay the cost
of Hepatitis B vaccinations for volunteer
firemen and ambulance drivers.
As chief of Citizens Fire Company,
Councilman Himes receives the use of a truck
as well as $75.00 per month toward his vehicle
expenses. The chief uses the truck almost all
the time for personal as well as fire company
business, because he needs a vehicle in which
to respond to any emergency call. The $75.00
James L. Cowden, Esquire
March 3, 1993
Page 3
per month that he receives is used to pay for
vehicle expenses, including gasoline and the
service charges on a telephone in the truck
that is absolutely necessary to his efficient
performance as fire chief. These expenses are
not specifically accounted for, however. The
Chief draws no salary or wages whatsoever, and
has no pecuniary interest in the fire company,
which is a non - profit corporation.
Letter of January 20, 1993, at 1 -2.
You perceive the following issues as arising under the Ethics
Law as a result of Council Member Himes' service as fire chief:
1. May Mr. Himes participate in discussions and votes on
matters that indirectly affect the fire company, such as
the entire General Fund budget for the Borough?
2. May Mr. Himes participate in Council committee meetings
at which the appropriations to the fire department are
discussed and recommended to Council?
3. May Mr. Himes participate in discussions and voting upon,
specific matters that come before Council that affect
only the fire company, such as the authorization of
police overtime, at Borough expense, to patrol the
firemen's carnival?
Based upon the above, you request an advisory from the State
Ethics Commission.
Discussion: As a Member of Council for Highspire Borough,
Pennsylvania, Mr. Herman Himes is a public official as that term is
defined under the Ethics Law, and hence he 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
James L. Cowden, Esquire
March 3, 1993
Page 4
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.
"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
James L. Cowden, Esquire
March 3, 1993
Page 5
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 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 the event that the required abstention results in the
inability of the governmental body to take action because a
majority is- unattainable due to the abstention(s), then in that
event participation is permissible provided the disclosure
requirements noted above are followed. See, Mlakar, Advice 91-523 -
S.
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.
Generally, depending upon the circumstances in a given case,
James L. Cowden, Esquire
March 3, 1993
Page 6
a fire company may be viewed as part of a governmental body such as
a borough, or as a private entity meeting the definition of
"business" as set forth in the Ethics Law and above. If a fire
company is part of the governmental body in which the public
official /public employee in question serves, it may generally be
said that a private pecuniary benefit to the fire company alone
would not present a conflict of interest for the public official.
Only if there were additional circumstances, such as if the public
official /public employee or a member of his immediate family would
also derive a private pecuniary benefit, could there be a conflict
of interest. If, on the other hand, the fire company is a
"business," there is the potential for a conflict of interest based
upon a private pecuniary benefit to the fire company, because the
fire company is then an entity separate from the governmental body.
The issue is whether the fire company is a "business with which
[the public official /public employee] is associated," as that term
is defined in the Ethics Law. That definition would include any
business of which the public official/ public employee or a member
of his immediate family is a director, officer, owner, employee, or
has a financial interest.
In this case, the facts which you have submitted are somewhat
unclear as to the fire company's link with the Borough. It is
clear that the Borough is contributing funds towards expenses of
the fire company, but it is unclear as to whether those payments
are targeted toward specific operating expenses, such as the
Chief's truck and related expenses, or whether the funds are
contributions to the fire company which itself then determines how
the funds shall be allocated. However, based upon the totality of
the facts submitted, it would appear that the Citizens Fire Company
No. 1 of Highspire, a non - profit corporation and volunteer fire
company located within the Borough of Highspire, would be a
"business" as opposed to part of the governmental body of the
Borough itself. Thus, the Citizens Fire Company No. 1 of Highspire
would by definition be a business with which Mr. Himes is
associated, given his role as Chief of the fire company.
Pursuant to Section 3(a) of the Ethics Law, Council Member
Himes would have a conflict of interest as to any matter before the
Borough Council where the use of authority 'of office or
confidential information received by holding that public position
would result in a private pecuniary benefit for the Council Member
himself, any member of his immediate family, or any business with
which he or a member of his immediate family is associated
including but not limited to the fire company. Such matters would
include but not be limited to funding for the fire company.
Turning to your specific inquiries, you first ask whether
Council Member Himes may participate and vote on matters indirectly
affecting the fire company, such as the entire General Fund budget
James L. Cowden, Esquire
March 3, 1993
Page 7
for the Borough. To the extent such participation or vote would
financially benefit Himes and /or decide allocations to the fire
company, a conflict of interest would exist. However, if fire
company matters were to be considered separately -- with Council
Member Himes abstaining and making the necessary disclosures -- and
then merely be included on the budget as previously determined
items, the conflict would not exist.
As for your second inquiry, you ask whether Council Member
Rimes may participate at Council committee meetings at which the
appropriations to the fire department are discussed and recommended
to Council. In that Council Member Himes has a conflict, such
participation would be prohibited as a use of authority of office.
You are advised that the use of authority of office is more than
the mere mechanics of voting, and encompasses all of the tasks
needed to perform the functions of a given position. See,
Juliante, Order No. 809.
Finally, as for your third specific inquiry, you ask whether
Council Member Himes may participate in discussions and votes upon
specific matters that come before Council affecting only the fire
company, such as the authorization of police overtime, at Borough
expense, to patrol the firemen's carnival. A conflict would exist
because participation or voting in such matters would constitute
the use of authority of office for the private pecuniary benefit of
the fire company, in that, by having the services provided at
Borough expense, the fire company would not be required to pay for
them.
In each instance of a conflict of interest, Mr. Himes would be
required to abstain fully and to fully satisfy the disclosure
requirements of Section 3(j) as set forth above.
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 Member of Council for the Borough of Highspire,
Pennsylvania, Mr. Herman Himes is a public official subject to the
provisions of the Ethics Law. The Citizens Fire Company No. .1 of
Highspire, which Council Member Himes serves as Chief, is a
business with which he is associated. Council Member Himes may not
use the authority of office or confidential information received by
holding such public position for the private pecuniary benefit of
the Council Member himself, any member of his immediate family, or
any business with which he or a member of his immediate family is
associated, including but not limited to the said fire company.
such.
James L. Cowden, Esquire
March 3, 1993
Page 8
Such conflicts of interest would include but would not be limited
to funding for the fire company, or the authorization of police
overtime, at Borough expense, to patrol the firemen's carnival. In
each instance of a conflict of interest, Council Member Mimes must
abstain fully, and the disclosure requirements of Section 3(j) as
set forth above must be fully satisfied. 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 §2.12.
i ncerely,
(4-c'4\‘
Vincent J. Dopko
Chief Counsel