HomeMy WebLinkAbout93-589 HookEdward E. Hook
R.D. #1, Box 47
Glenville Road
Cochranville, PA 19330
Dear Mr. Hook:
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
August 2, 1993
93 -589
Re: Conflict, Public Official /Employee, Candidate for Township
Supervisor, Immediate Family, Spouse, Candidate for Township
Tax Collector.
This responds to your letter of July 14, 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 candidate for
township supervisor when that candidate's spouse is a candidate for
township tax collector.
Facts: You are the Republican candidate for Supervisor of Upper
Oxford Township, Chester County. In the primary election, you were
unopposed on the Republican ticket and there were no Democratic
candidates. Your wife was the successful write -in Democratic
candidate for Tax Collector of Upper Oxford Township.
You were informed that there is no interaction between
offices. You state that after the primary election, the Chairman of
the Board of Supervisors suggested that you verify with this
Commission whether you and your wife could hold the respective
offices at the same time. Based on the above, you request an
advisory from the State Ethics Commission.
Discussion: It is initially noted that pursuant to Sections 7(10)
and 7(11) of the Ethics Law, 65 P.S. SS407(10), (11), advisories
are issued to the requestor based upon the facts which the
requestor has submitted. In issuing the advisory based upon the
facts which the requestor has submitted, the Commission does not
engage in an independent investigation of the facts, nor does it
speculate as to facts which have not been submitted. It is the
August 2, 1993
Page 2
burden of the requestor to truthfully disclose all of the materials
facts relevant to the inquiry. 65 P.S. 55407(10), (11). An
advisory only affords a defense to the extent the requestor has
truthfully disclosed all of the material facts.
As a Supervisor for Upper Oxford Township, Chester County, you
will become a public official as that term is defined under the
Ethics Law, and hence you will be 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.
August 2, 1993
Page 3
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.
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) from conflict
under the Ethics Law, then in that event participation is
permissible provided the disclosure requirements noted above are
followed. See, Mlakar, Advice 91- 523 -S.
August 2, 1993
Page 4
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.
In applying the above provisions of the Ethics Law to the
circumstances which you have submitted, a public official /public
employee under Section 3(a) of the Ethics Law 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.
There is no specific prohibition in the Ethics Law which would
preclude you from holding the position as Supervisor for Upper
Oxford Township merely because your wife is Tax Collector for that
same Township.
However, it is clear that you would be subject to the
restriction of the Ethics Law such that if a conflict of interest,
as defined above, would arise as to a particular matter, you would
be required to abstain from any participation in that matter and
must observe the disclosure requirements of Section 3(j) set forth
above. You would have a conflict of interest as to any matter
before you in your capacity as a Township Supervisor where the use
of the authority of your public employment or confidential
information received by holding your public position would result
in a private pecuniary benefit for you, your wife, or any other
member of your immediate, or a business with which you or a member
of your immediate family is associated. An example of such a
conflict would involve the consideration by the Board of
Supervisors as to the amount or rate of compensation which the Tax
Collector would receive for tax collection.
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 Township Code.
Conclusion: As Township Supervisor for Upper Oxford Township,
Chester County, you will be a public official subject to the
provisions of the Ethics Law. The Ethics Law would not preclude
August 2, 1993
Page 5
you from seeking and holding the office of Township Supervisor
while your wife holds the position of Tax Collector for the same
township. As a public official, you are subject to the
restrictions of Section 3(a) of the Ethics Law and therefore, you
may not use the authority of public office or confidential
information obtained through holding such public office for your
own private pecuniary benefit, or the private pecuniary benefit of
a member of your immediate family, or a business with which you or
a member of your immediate family is associated. In each instance
of a conflict of interest, 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.
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 %13.2(h).
cerely,
Vincent J. opko
Chief Counsel