HomeMy WebLinkAbout93-537 GreenMichael J. Green
1016 Green Glen Drive
DuBois, PA 15801
Dear Mr. Green:
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STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
April 1, 1993
93 -537
Re: Conflict, Public Official /Employee, School Director, Immediate
Family Member, Spouse, Collective Bargaining Agreement,
Negotiating Team, Confidential Information, Contract, Vote.
This responds to your letter of March 9, 1993, in which you
requested advice from the State Ethics Commission.
Issue: Whether under the Public Official and Employee Ethics Law
a school director may participate as to a collective bargaining
agreement and /or be informed as to negotiations where no member of
his immediate family would be affected by the contract, or,
alternatively, where a member of his immediate family would be a
full -time teacher under the contract.
Facts: As a School Director for the DuBois Area School District,
you request an advisory as to the following two scenarios:
1. Your wife is a substitute teacher filling a position for
a person on leave for one year. Your wife, as of now,
will not have a teaching position next year. If the
School Board enters into contract talks with the
teachers' union for a contract whose term begins after
June 30, 1993, you ask whether you may participate in the
bargaining process and /or be informed as to details of
talks.
2. Under a different scenario, assuming your wife is a full -
time teacher with a contract, you ask what would be the
guidelines for your involvement in contract talks as a
School Director, and what you may be told about contract
talks.
Based upon the above, you request an advisory from the State
Michael J. Green
April 1, 1993
Page 2
Ethics Commission.
Discussion: As a School Director for the DuBois Area School
District, 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.
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
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.
"Immediate family." A parent, spouse,
child, brother or sister.
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
Michael J. Green
April 1, 1993
Page 3
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
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.
Michael J. Green
April 1, 1993
Page 4
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.
Under the first scenario which you have posed, Section 3(a) of
the Ethics Law would not apply to restrict your involvement in the
bargaining process or your access to information regarding
negotiations because your wife would not be affected by the
contract. Of course, this Advice is conditioned upon the
assumption that there would be no other immediate family member
affected by the contract either.
The second scenario which you have presented has previously
been considered by the State Ethics Commission in Van Rensler,
Opinion 90 -017. The issue in Van Rensler was whether the Ethics
Law prohibited school board directors from participating on a
negotiating team and voting on a collective bargaining agreement
when members of their immediate families were school district
employees represented by the bargaining units. The Commission
concluded that the Ethics Law would not restrict the school board
directors from voting on the finalized agreement, but that the
school board directors could not take part in the negotiations
leading to the finalized agreement. In reaching this conclusion,
the Commission held that the school board directors could vote on
the finalized agreement because of the exclusion in the definition
of "conflict or conflict of interest" which applies if the
immediate family member is a member of a subclass consisting of an
industry, occupation or other group containing more than one member
and the family member would be affected exactly as the other
members of the subclass. The Commission held that if these two
prerequisites for applying the exclusion were met, the school
directors could vote on the final collective bargaining agreement.
However, the Commission,held that the Ethics Law precluded the
participation of the directors in the negotiation process. Citing
prior opinions under former Act 170 of 1978, the Commission
recognized the underlying reasoning of those prior opinions with
the purpose of insuring that public officials are impartial and
that their interests are sufficiently separated from their
responsibility to the public. Van Rensler, Opinion 90 -017 at 4.
The Commission cited the definition of "conflict of interest" in
present Act 9 of 1989 as specifically prohibiting a public official
or employee from using confidential information obtained through
public office or employment for an immediate family member's
private pecuniary benefit. A school board director participating
Michael J. Green
April 1, 1993
Page 5
t
on the negotiating team would be privy to confidential information
relating to the family members' bargaining units. The risk of
disclosure of that information was held to preclude the school
board directors from participating in negotiations where family
members are part of the bargaining unit. In so holding, the
negotiation process would be free of any influence of such a school
board director and the potential for the use of confidential
information would be "minimized if not eliminated." Id. at 4 -5.
Thus, a fundamental basis for the Van Rensler Opinion was
precluding the use of confidential information obtained through the
public office as school board director to defeat the bargaining
process.
The above principles would similarly apply to preclude a
school director from accessing such confidential information even
if it would be at an executive session of the Board, or volunteered
by some other school director, rather than through participation on
the negotiating team itself. See, Russell, Advice 92 -610.
However, the school director would not transgress Section 3(a) of
the Ethics Law by having access to such information discussed in a
public session. Id.
The above principles would apply to you, and you would be
required to observe same under the second scenario which you have
posed.
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 School Code.
Conclusion: As a School Director for the DuBois Area School
District, you are a public official subject to the provisions of
the Ethics Law. Section 3(a) of the Ethics Law would not impose
restrictions upon you with regard to participating in the
collective bargaining process and /or receiving information as to
such bargaining relative to teacher negotiations where neither your
spouse nor any other member of your immediate family would be
affected by said contract. However, were your spouse or other
iirtediate family member to be a full -time teacher affected by the
contract, pursuant to Section 3(a) of the Ethics Law, you would
have a conflict of interest which would preclude your involvement
in contract negotiations and /or access to confidential information
pertaining to contract negotiations. Subject to the restrictions,
conditions and qualifications noted above, you could, however, vote
on the final contract proposal conditioned upon the assumption that
your spouse or other immediate family member would be a member of
a subclass affected by the contract and would be affected exactly
Michael J. Green
April 1, 1993
Page 6
as the other members of the subclass. 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
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
02. Af bt-