HomeMy WebLinkAbout94-556-S PawlushDaryl Pawlush
Chairman
Conyngham Township
Board of Supervisors
P.O. Box 1
Mocanaqua, PA 18655
Dear Mr. Pawlush:
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
June 2, 1994
Section 3(a) of the Ethics Law provides:
94 -556S
Re: Conflict, Public Official /Employee, Private Employment or
Business, Township, Supervisor, Sewer Project, Contract,
Business with which Associated, Supervisor Working on Sewer
Project, Supplemental Advice.
This responds to your letter of April 22, 1994, in which you
requested supplemental advice from the State Ethics Commission.
Issue: Whether a Second Class Township Supervisor is prohibited or
restricted by the Public Official and Employee Ethics Law from
working with, being employed by or associated with a business in a
private capacity in addition to public service where the business
has a contract with the township as to a sewer project.
Facts: By letter of March 21, 1994 you requested advice from the
State Ethics Commission as to four factual scenarios or issues and
on April 19, 1994, Advice of Counsel 94 -556 was issued which is
incorporated herein by reference. You now inquire as to whether
you may work on a sewer project as to which your firm has a contact
with the Board of Supervisors. Your firm will charge the Township
for the cost of your work, but you would abstain from voting on the
bills.
Discussion: As a Townshig Supervisor 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.
Pawlush, Daryl, 94 -556S
June 2, 1994
Page 2
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.
"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 or
will be any transgression thereof but merely to provide a complete
Pawlush, Daryl, 94-556S
June 2, 1994
Page 3
response to the question presented.
In applying the above provisions of the Ethics Law to the
instant matter, we note that Section 3(a) of the Ethics Law does
not prohibit public officials /employees from outside business
activities or employment; however, the public official /employee may
not use the authority of office for the advancement of his own
private pecuniary benefit or that of a business with which he is
associated. Pancoe, Opinion 89 -011. A public official /employee
must exercise caution so that his private business activities do
not conflict with his public duties. Crisci, Opinion 89 -013.
Thus, a public official /employee could not perform private business
using governmental facilities or personnel. In particular, the
governmental telephones, postage, staff, equipment, :research
materials, personnel or any other property could not be used as a
means, in whole or part, to carry out private business activities.
In addition, the public official /employee could not during
government working hours, solicit or promote such business
activity. Pancoe, supra. Similarly, Section 3(a) would expressly
prohibit the use of confidential information received by holding
public office/ employment for such a prohibited private pecuniary
benefit.
In the event that your private employer or business has a
matter pending before your governmental body or if you as part of
such official duties must participate, review or pass upon that
matter, a conflict would exist. Miller, Opinion 89 -024. In those
instances, it will be necessary that you be removed from that
process.
In such cases as noted above, Section 3(j) of the Ethics Law
would require not only that you abstain from participation but also
file a written memorandum to that effect with the person recording
the minutes.
In summary, the Ethics Law would restrict the following:
1. The use of authority of office to obtain any business in
a private capacity;
2. utilization of confidential information gained through
public position;
3. participating in discussions, reviews, or recommendations
on matters which relate to the business /private employer
which may come before the governmental body and in such
cases publicly announcing the relationship or advising
the supervisor as well as filing a written memorandum as
per the requirements of Section 3(j) of the Ethics Law.
Brooks, Opinion 89 -023.
Pawlush, Daryl, 94 -556S
June 2, 1994
Page 4
Section 3. Restricted activities.
(f) No public official or public
employee or his spouse or child or any
business in which the person or his spouse or
child is associated shall enter into any
contract valued at $500 or more with the
governmental body with which the public
official or public employee is associated or
any subcontract valued at $500 or more with
any person who has been awarded a contract
with the governmental body with which the
public official or public employee is
associated, unless the contract has been
awarded through an open and public process,
including prior public notice and subsequent
public disclosure of all proposals considered
and contracts awarded. In such a case, the
public official or public employee shall not
have any supervisory or overall responsibility
for the implementation or administration of
the contract. Any contract or subcontract
made in violation of this subsection shall be
voidable by a court of competent jurisdiction
if the suit is commenced within 90 days of the
making of the contract or subcontract.
In relation to the above provision of law, the State Ethics
Commission has generally determined that this provision is a
procedure to be used when a public official or employee contracts
with his own governmental body in an amount of $500 or more. The
process must be open and public with prior public notice and
subsequent public disclosure. In addition, the public official/
employee may not have any supervisory or overall responsibility for
the implementation or administration of the contract.
Thus, the open and public process, must be used in all
situations where a public official is otherwise appropriately
contracting with his own governmental body in an amount of $500 or
more. This open and public process would require:
(1). prior public notice of the employment or
contracting possibility;
(2) sufficient time for a reasonable and prudent
competitor /applicant to be able to prepare and
present an application or proposal;
(3) public disclosure of all applications or
proposals considered and;
Pawlush, Daryl, 94 -556S
June 2, 1994
Page 5
(4) public disclosure of the contract awarded and
offered and accepted.
Further, Section 3(f) requires that the public official could
not have supervisory or overall responsibility as to the
implementation or administration of the contract.
Parenthetically, although the contracting in question would
not be prohibited under the Ethics Law provided the requirements of
Sections 3(a), (f) and (j) are satisfied, a problem may exist as to
such contracting under the respective code.
In the instant situation, the Second Class Township Code
provides as follows:
(f) Except as herein provided, no township
official, either elected or appointed, who
knows, or who by the exercise of reasonable
diligence, could know, shall be interested to
any appreciable degree, either directly or
indirectly, in any contract for the sale or
furnishing of any supplies or materials for
the use of the township, or for any work to be
done for such township involving the
expenditure by the township of more than three
hundred dollars ($300) in any year, but this
limitation shall not apply to cases where such
officer, or appointee of the township, is an
employee of the person, firm or corporation to
which the money is to be paid in a capacity
with no possible influence on the transaction,
and in which he cannot be possibly benefited
thereby, either financially or otherwise:
Provided, however, That in the case of a
supervisor, if he knows that he is within the
exception just mentioned, he shall so inform
the supervisors and shall refrain from voting
on the expenditures, or any ordinance relating
thereto, and shall in no manner participate
therein: Provided, further, That any such
official or appointee who shall knowingly
violate .his provision shall be subject to
surcharge to the extent of the damage shown to
be thereby sustained by the township, ouster
from office, and shall be guilty of a
misdemeanor, and upon conviction thereof,
shall be sentenced to pay a fine not exceeding
five hundred dollars ($500): Provided, That
in the case of the purchase of material for
the construction, reconstruction, maintenance
and improvement of roads and bridges, the
contract, which shall be in writing, and shall
be let only on standard specifications of the
Department of Transportation, and materials so
purchased shall only be used in accordance
with specifications of said department. 53
P.S. S65802(f).
Since such contracting may be prohibited by the above quoted
provision of the Code, but not under the Ethics Law, it is
suggested that advice in that regard be sought from the municipal
solicitor or from private counsel.
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 Second Class Township Code.
Conclusion: A Second Class Township Supervisor is a public
official subject to the provisions of the Ethics Law. Section 3(a)
of the Ethics Law would not preclude you from outside
employment /business activity subject to the restrictions and
qualifications as noted above. In the event that the
employer /business has matters pending before your governmental
body, then you could not participate in that matter and the
disclosure requirements of Section 3(j) of the Ethics Law as
outlined above must be satisfied. Due to the possible application
of the Second Class Township Code in this matter, it is suggested
that advice be obtained from the municipal solicitor or private
counsel in that regard. 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.
Pawlush, Daryl, 94 -556S
June 2, 1994
Page 6
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 appeal the Advice to the full
Commission. A personal appearance before the Commission will be
scheduled and a formal Opinion will be issued by the Commission.
Pawlush, Daryl, 94 -556S
June 2, 1994
Page 7
Any such appeal must be in writing and must be actually
received at the Commission within fifteen (15) days of the date of this
Advice pursuant to 51 Pa.Code §13.2(h). The appeal may be received
at the Commission by hand delivery, United States mail, delivery
service, or by FAX transmission (717- 787 - 0806). Failure to file such
an appeal at the Commission within fifteen (15) days may result in the
dismissal of the appeal.
incerely,
} wt9 , /`/1 04
Vincent . Dopko
Chief Counsel