HomeMy WebLinkAbout94-644 HrivnakSTATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
December 9, 1994
Richard A. Hrivnak
603 Memorial Drive
New Kensington, PA 15068 94 -644
Re: Conflict, Public Official /Employee, Borough Council Member,
Use of Authority of Office or Confidential Information,
Immediate Family, Father, Appointment of Immediate Family
Member to Non - compensated Advisory Board.
Dear Mr. Hrivnak:
This responds to your letter of November 23, 1994 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 borough council
member with regard to voting for the reappointment of his father to
a non - compensated position on the borough's planning commission.
Facts: As an elected Member of Council for the Borough of Plum,
you request an advisory from the State Ethics Commission. On
January 9, 1995 the Borough Council will appoint individuals to
serve on several non - compensated advisory boards and commissions.
Your father, Richard W. Hrivnak, currently serves as Chairman of
the Borough Planning Commission and has applied for reappointment.
He receives no compensation in his current position as a Member of
the Commission.
You ask whether the Ethics Law would place any restrictions
upon you with regard to voting for the reappointment of your father
to a non - compensated position as a Member of the Borough Planning
Commission. You note that it is your opinion that this would not
constitute a conflict of interest because neither you nor your
father would derive any pecuniary benefit from his reappointment.
Nevertheless, you seek an advisory from the State Ethics Commission
so that you may act ethically and in a legal manner.
Discussion: It is initially noted that pursuant to Sections 7(10)
and 7(11) of the Ethics Law, 65 P.S. § §407(10), (11), advisories
Hrivnak, Richard A., 94 -644
December 9, 1994
Page 2
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.
Before addressing your specific inquiry, it is noted that you
have represented that your father serves as Chairman of the Borough
Planning Commission and that he receives no compensation in his
current position as a Member of the Commission. You have further
represented that your father would not derive any pecuniary benefit
from his reappointment. This Advice is conditioned upon the
assumption that not only is your father not compensated as a Member
of the Borough Planning Commission, but that he also is not
compensated as its Chairman.
As a Council Member for the Borough of Plum, 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.
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
Hrivnak, Richard A., 94 -644
December 9, 1994
Page 3
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. 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
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
Hrivnak, Richard A., 94 -644
December 9, 1994
Page 4
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
circumstances which you have submitted, 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.
Your father is a member of your immediate family, as that term is
defined in the Ethics Law and as set forth above.
Section 3(a) of the Ethics Law would not preclude your voting
to reappoint your father to a non - compensated position on the
Borough Planning Commission because there would be no private
pecuniary benefit resulting from such official action.
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.
Conclusion: As a Borough Council Member for the Borough of Plum,
you are a public official subject to the provisions of the Ethics
Law. Section 3(a) of the Ethics Law would not preclude you from
Hrivnak, Richard A., 94 -644
December 9, 1994
Page 5
voting for the reappointment of your father to a non - compensated
position on the Borough Planning Commission. 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.
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. Dopko
Chief Counsel