HomeMy WebLinkAbout93-600 WaiteDear Mr. Waite:
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
September 15, 1993
Clyde W. Waite, Esquire
Stief, Waite, Gross, Sagoskin & Gilman
The Barnsley Building
547 East Washington Avenue
P.O. Box 274
Newtown, PA 18940 -0274
93 -600
Re: Conflict, Public Official /Employee, Township Council, Use of
Authority of Office or Employment, Vote for Post - Employment
Contract, Payment to Township Employees and Officials for
Attendance at Court - related Matters after Termination of
Public Service.
This responds to your letter of August 19, 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 Township Council from
implementing a program whereby former Officials and Employees would
receive compensation for travel expenses and lost wages fors
attendance at Court - related matters on behalf of the Township.
Facts: You are Solicitor for Bristol Township, Bucks County. Over
the past several years, township employees and elected officials
have been required to appear at court hearings, administrative
hearings and pre -trial matters on behalf of the Township, after the
employees' or officials' employment or term of office with the
Township has ended. When these individuals are called by the
Township to appear, they lose time from work, to their financial
detriment. Accordingly, the Township Council wishes to implement
a new program which will provide compensation to these individuals
for their appearances. The Township Council passed a resolution
authorizing you to seek this advisory. A copy of the resolution
was enclosed with your letter and is incorporated herein by
reference. Based upon the above, you request an advisory as to
whether there are any conflicts of interest under the State Ethics
Waite, 93 -600
September 15, 1993
Page 2
Law regarding the proposed plan as it relates to former township
employees and elected officials.
Discussion: Before responding to your request, three points must
be made. First, it is noted that pursuant to Sections 7(10) and
7(11) of the Ethics Law, 65 P.S. §5407(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 burden of the
requestor to truthfully disclose all of the materials facts
relevant to the inquiry. 65 P.S. §S407(10), (11). An advisory
only affords a defense to the extent the requestor has truthfully
disclosed all of the material facts.
Second, it is further noted that your request for advice may
only be addressed with regard to prospective conduct. A reading of
Sections 7(10) and 7(11) of the Ethics Law makes it clear that an
opinion or advice may be given only as to prospective (future)
conduct. If the activity in question has already occurred, the
Commission may not issue an opinion or advice but any person may
then submit a signed and sworn complaint which will be investigated
by the Commission if there are allegations of Ethics Law violations
by a person who is subject to the Ethics Law.
Third, this Commission does not have the statutory
jurisdiction to rule upon a governmental body's wisdom or judgement
in decisions as to whether and in what amount such compensation may
be given to public employees and officials. The Commission has
noted its concern that due consideration be given to the
appropriate utilization of tax revenues, in accordance with the
public trust. See, e.q., Means, Opinion 90 -007 at 5 -6.
As Council Members for Bristol Township, the Members are
"public officials" as that term is defined under the Ethics Law,
and hence they 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.
Waite, 93 -600
September 15, 1993
Page 3
65 P.S. §402.
"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
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.
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
Waite, 93 -600
September 15, 1993
Page 4
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.
In applying the above provisions of the Ethics Law to the
facts which you have submitted, Section 3(a) of the Ethics Law
prohibits a public official /public employee from using the
authority of public office /public employment or confidential
information received by holding such a public position for the
private pecuniary benefit of the public official /public employee
himself, a member of his immediate family, or a business with which
he or a member of his immediate family is associated. Section 3(a)
would prohibit the Bristol Township Council Members from using the
status of their respective positions, the authority of their
office, or any confidential information received by being in their
Waite, 93 -600
September 15, 1993
Page 5
positions of public office as a means of structuring an opportunity
for additional compensation for themselves.
Subject to all of the conditions, qualifications and
restrictions noted above, the Ethics Law would not preclude the
Bristol Township Council from implementing the reimbursement
proposal as to former public officials and employees.
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.
However, even though it is beyond the scope of the Ethics Law
and this Advice of Counsel to make determinations as to the
Township Code, it should be noted that the Township Code may
prohibit the proposed conduct. In the publication of the
Pennsylvania State Association of Township Supervisors,
Pennsylvania Township News, the July 1989 Question and Answer
feature presented a question as to whether a township could keep a
retired employee on the township hospitalization insurance, even if
the former employee reimburses the township for the cost of the
coverage. The response was that except in those cases that come
under the federal COBRA law, the Township Code prohibits anyone
other than active township employees and township supervisors to be
included in the township plan. Once the employee retires and thus
severs the employer - employee relationship, that person may not
participate in the township plan, even at that person's own
expense. Accordingly, it is suggested that the Bristol Township
Council seek the advice of the solicitor or private counsel
regarding the application of the Township Code to the proposed
conduct.
Conclusion: Members of Bristol Township Council are public
officials subject to the provisions of the Ethics Law. Subject to
the conditions, qualifications, and restrictions noted above, the
Ethics Law would not prohibit the Township Council from
implementing a reimbursement plan for former employees and
officials for attending Court- related matters on behalf of the
Township. 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.
Waite, 93 -600
September 15, 1993
Page 6
This letter is a public record and will be made available as
such.
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 writincr and must be received at
the Commission within 15 days of the date of this Advice pursuant
to 51 Pa. Code 513.2(h).
*ncerely,
Vincent J. J Dopko
Chief Counsel