HomeMy WebLinkAbout94-590 CeraulDavid J. Ceraul, Esquire
22 Market Street
P.O. Box 19
Bangor, PA 18013
Dear Mr. Ceraul:
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
August 15, 1994
94 -590
Re: Simultaneous Service, Township Solicitor and Borough
Solicitor.
This responds to your letter of July 15, 1994, in which you
requested advice from the State Ethics Commission.
Issue: Whether the Public Official and Employee Ethics Law imposes
any prohibition or restrictions upon a solicitor from also serving
or being employed as a solicitor in another municipality.
Facts: As Solicitor for both the Township of Washington and the
Borough of Bangor, a conflict of interest question has arisen in
light of certain matters that are now pending with the Bangor
Municipal Authority (Authority), which owns and operates a sewage
system which serves both Bangor Borough, Roseto Borough and a small
portion of Washington Township.
The Authority has invited Washington Township to consider
designating certain sewer districts for ultimate hookup into the
Authority sewer plant. If amendments are made to the Washington
Township's Act 537 Plan with the Department of Environmental
Resources (DER) and if an intermunicipal agreement is entered
between Washington Township and Bangor Borough to implement said
plan, your office would be called upon to draft aft agreement to
address the various issues involved.
At a July 13, 1994 public meeting of the Washington Township
Board of Supervisors, Mrs. Carol Hummel, a Bangor Borough resident,
appeared before the Board and raised an issue of a perceived
conflict of interest on your part. Although you have previously
advised both Bangor Borough Council and the Washington Township
Board of Supervisors that you saw no conflict of interest at this
juncture, you have advised both bodies that you would definitely
step down if such a conflict would arise. You believe that it is
Ceraul, David J, Esquire, 94 -590
August 15, 1994
Page 2
prudent to contact the Ethics Commission to determine if there is
any violation of the Ethics Law or if in fact a conflict is
present.
You have been in contact with Mr. Jody Brogna, a Water Quality
specialist in DER with whom you discussed your involvement in this
matter. Neither Mr. Brogna nor legal counsel for DER, Barbara
Smith, perceive any conflict at this juncture. Given the serious
allegations that have been made at the public meeting of the
Washington Township Supervisors by the Bangor taxpayer, you believe
that it is appropriate to contact the Commission to request an
opinion at this time.
After noting that you have attempted to capsulize the factual
circumstances to their best of your ability, you seek commentary
from the Commission. You are willing to furnish any additional
facts and circumstances that may be required and have set forth the
names and addresses of the DER employees with whom you have
discussed this matter. As a postscript, you have included a copy
of Rule 1.7 of the Rules of Professional Conduct on which you have
done some brief research and have concluded that you are in
compliance with that rule.
Discussion: As Solicitor for Washington Township and Bangor
Borough, you are a "public official /employee" as that term is
defined in the Ethics Law and hence you are subject to the
provisions of the Ethics Law. 65 P.S. §402; 51 Pa. Code §11.1.
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 under the Ethics Law:
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
Ceraul, David J, Esquire, 94 -590
August 15, 1994
Page 3
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.
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
any thing of monetary value and no public official /employee shall
solicit or accept any thing of monetary value based upon the
understanding that the vote, official action, or judgment of the
public official /employee would be influenced thereby.
In applying the above provisions of the Ethics Law to the
question of simultaneous service, there does not appear to be any
real possibility of a private pecuniary benefit or inherent
conflict arising if you were to serve both as a public
official /employee — solicitor for the two municipalities.
Basically, the Ethics Law does not state that it is inherently
incompatible for a public official / employee to serve or be
employed as solicitors for two municipalities. The main
prohibition under the Ethics Law and Opinions of the Ethics
Commission is that one may not serve the interests of two persons,
groups, or entities whose interests may be inherently adverse.
Smith Opinion, 89 -010. In the situation outlined above, you would
not be serving entities with interests which are inherently adverse
to each other.
Turning to the question of conflict of interest, 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. Should a situation arise where the use of
authority of public office /employment or confidential information
received by holding the above public positions could result in a
prohibited private pecuniary benefit, a conflict of interest would
arise. In each instance of a conflict of interest, you would be
required to fully abstain and to publicly announce and disclose the
abstention and the reasons for same in a written memorandum filed
Ceraul, David J, Esquire, 94 -590
August 15, 1994
Page 4
with the appropriate person (supervisor or secretary who keeps the
minutes). If such a situation would arise, additional advice may
be sought from the Commission.
Lastly, 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 is the applicability of the Rules of Professional
Conduct.
Conclusion: As Solicitor for Washington Township and Bangor
Borough, you are a "public official /employee" subject to the
provisions of the Ethics Law. As a public official /employee, you
may, consistent with Section 3(a) of the Ethics Law, simultaneously
serve in the positions of solicitors for the two municipalities,
subject to the restrictions, conditions and qualifications set
forth above. Lastly, the propriety of the proposed course of
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.
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 513.2(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.
ncerely,
Vincent J..J Dopko
Chief Counsel