HomeMy WebLinkAbout94-576 ConfidentialSTATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
June 21, 1994
94 -576
Re: Conflict, Public Official /Employee, Borough, Council Member,
Medical Insurance, Borough Paid Medical Insurance.
This responds to your letter of May 23, 1994 in which you
requested confidential 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 from voting to award himself and his dependents borough paid
medical insurance.
Facts: As Solicitor for A Borough, you have been asked by Borough
Council Member B to make an advisory request regarding an amendment
to the Pennsylvania Borough Code which was effective on December
16, 1992 and which permitted Boroughs to appropriate monies from
the Borough treasury for medical insurance for the Mayor, Members
of Council and their dependents. 53 P.S. 546202(37). You inquire
as to whether the Ethics Law would prohibit a sitting Member of
Council from voting on a resolution or ordinance which would
authorize the Borough to provide paid medical insurance for the
Mayor or Councilmembers and secondly, if adopted, whether the
sitting Members of Council could take advantage of the paid medical
insurance.
Discussion: It is initially noted that pursuant to Sections 7(10)
and 7(11) of the Ethics Law, 65 P.S. S §407(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 material
facts relevant to the inquiry. 65 P.S. § §407(10), (11). An
advisory only affords a defense to the extent the requestor has
truthfully disclosed all of the material facts.
Confidential Advice, 94 -576
June 21, 1994
Page 2
As Council Member for A Borough, B 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
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.
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
Confidential Advice, 94 -576
June 21, 1994
Page 3
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.
The Commission has determined if a particular statutory
enactment prohibits an official from receiving a particular
benefit, then that official's receipt of such a prohibited benefit,
through the authority of public office, would also be a use of the
authority of office contrary to Section 3(a) of the Ethics Law. In
this respect, this Commission has been called upon, on various
occasions, to determine whether a specific pecuniary benefit or
financial gain is prohibited by law. Thus, in Means, Opinion 90-
007, the Commission held that Second Class Township Supervisors who
work limited hours would not be precluded from receiving paid life
insurance benefits under the Second Class Township Code on the
theory that if a given pecuniary benefit is authorized in law, the
receipt of such pecuniary benefit would not be private and would
Confidential Advice, 94 -576
June 21, 1994
Page 4
not be contrary to Section 3(a) of the Ethics Law
In the instant matter, the 1992 amendment to the Borough Code
authorizes the Borough to provide paid medical insurance coverage
for the Mayor, Council and their dependents. Based upon the
statutory authorization in the Borough Code, B would not be
prohibited from participating or voting in favor of an ordinance to
provide paid medical insurance coverage to himself as a Council
Member or to his dependents nor would the Ethics Law preclude B as
a sitting member of Council from receiving the paid medical
insurance. See Williamson, Advice 88 -523.
Parenthetically, it should be noted in Means, supra
that the Commission referenced the Preamble of the Ethics Law which
recites that public office is a public trust and suggested that the
better practice of the public officials would be to forego such
benefits which would have to be paid from tax revenues.
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 or the Constitution
of the Commonwealth of Pennsylvania.
Conclusion: A Borough Council Member is a public official subject
to provisions of the Ethics Law. Section 3(a) of the Ethics Law
does not prohibit a Council Member from voting or accepting paid
medical insurance for himself or his dependents when such paid
medical insurance is provided by the Pennsylvania Borough Code.
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 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.
Confidential Advice, 94 -576
June 21, 1994
Page 5
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.
cerely,
Vincent \) Dopko
Chief Counsel