HomeMy WebLinkAbout94-650 AllenRichard A. Allen
Tax Collector
Borough of West Mifflin
4733 Greensprings Avenue
West Mifflin, PA 15122
Dear Mr. Allen:
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
December 22, 1994
94 -650
Re: Conflict, Public Official /Employee, Tax Collector, Tax
Reduction Refunds, Clerical Expenses, Reimbursement to Tax
Collector.
This responds to your letter of December 7, 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 tax collector from
receiving reimbursement from the borough and school district to pay
additional clerical expenses in processing refunds as to tax
reductions resulting from appealed assessments.
Facts: As to the Allegheny County 1994 Reassessment Program, an
unusual situation exists where many of West Mifflin's residents who
appealed their assessments have received reductions from the County
after their 1994 taxes were paid. You are now receiving change
authorizations from the County and are expecting 800 more which
will need to be processed by the tax collector's office before the
Borough and School District can make refunds to the taxpayers who
are not waiting patiently. You normally process 25 -50 changes in
an entire year and are able to handle that volume during your
regular part -time schedule. You seek to have four clerks work
full -time for a few weeks to complete this unexpected work quickly.
However, the tax collector's office budget is not sufficient for
this additional payroll. You inquire as to whether it would be
violative of the Ethics Law if the Borough and School District paid
for additional clerical expenses by reimbursing the Tax Collector.
You note that if the funds are not provided to cover this
additional cost, you would have to complete the work during normal
work hours which could run well into 1995 before the refunds can be
Allen, Richard A., 94 -650
December 22, 1994
Page 2
made. Since the taxpayers are already becoming impatient, you seek
an advisory opinion on this matter as quickly as possible.
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
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 4n 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.
As Tax Collector for the Borough of West Mifflin, 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
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.
Allen, Richard A., 94 -650
December 22, 1994
Page 3
"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
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.
Generally, as to Section 3(a) of the Ethics Law, the
Commission has determined that the receipt of any financial gain
which is not authorized in law by a public official or public
employee through public office is considered to be a private
pecuniary benefit contrary to Section 3(a) of the Ethics Law, Act
9 of 1989. See Weber, Opinion 94 -005, Hessinger, Order 931, Allen,
Order 612 -R.
In Allen v. State Ethics Commission, filed at 1790 C.D. 1988
on April 20, 1989, Commonwealth Court, in affirming a decision of
the Commission which ruled that the charging of tax certification
fees by a tax collector which was not authorized in law was
violative of the Ethics Law, noted:
However, this absence of statutory authorization does not
per se preclude a borough tax collector such as
Petitioner from charging a fee for tax certifications.
Section 1202(1) of the Borough Code, 53 P.S. §46202(1),
provides that a borough may, by ordinance, "prescribe
reasonable fees for the services of [its] officers . . ."
Clearly then , a tax certification fee may be established
by borough ordinance."
Allen v. State Ethics Commission at page 3.
In light of the above precedent, you are advised that if the
Borough and School District do authorize payment for additional
clerical expenses, such authorization for additional employees in
the Tax Collector's office would not be prohibited by the Ethics
Law. It is expressly assumed that all of the authorized funds
would be for and limited in use to the four clerks who would work
on a full -time temporary basis.
Allen, Richard A., 94 -650
December 22, 1994
Page 4
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 respective municipal codes.
Conclusion: As Tax Collector for the Borough of West Mifflin, you
are a public official subject to the provisions of the Ethics Law.
Section 3(a) of the Ethics Law would not prohibit a borough and
school district from authorizing a payment for additional full -time
temporary clerical expenses in the tax collector's office subject
to the restrictions and qualifications noted above. 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.
cerely,
k A
Vincent J."Dopko
Chief Counsel