HomeMy WebLinkAbout95-500 JonesSTATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
January 3, 1995
Robert E. Jones
Commissioner
County of Fayette
Office of the County Commissioners
Court House
Uniontown, PA 15401
Re: Conflict, Public Official /Employee, County Commissioner,
Member of County Retirement Board, Early Retirement Incentive
Program, Participation By Public Official /Employee.
Dear Mr. Jones:
95 -500
This responds to your letters of November 30, 1994 and
December 8, 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 county commissioner
who is a member of the county retirement board with regard to
approving an early retirement incentive program where he would
qualify to take advantage of such an early retirement incentive and
would benefit from same.
Facts: After noting prior Advice of Counsel No. 94 -594 issued
August 22, 1994 to James Green, Chairman of the Butler County Board
of Commissioners, and noting a prior telephone conversation with a
staff member of the Commission, you request an advisory as to your
own situation. You are one of three Fayette County Commissioners,
and you are one of five members of the County Retirement Board.
You state that you may have to vote on an issue of approving an
early retirement incentive program in both of your capacities as a
Commissioner and as a member of the Retirement Board. There is no
early retirement incentive program in place at this time.
Procedurally, the County Commissioners would vote first as to
the proposed early retirement incentive program. The next step
would be to have the five member Retirement Board approve the plan.
Jones, Robert E., 95 -500
January 3, 1995
Page 2
Two of the three County Commissioners -- including you -- are
eligible tea take advantage of the early retirement should it be
approved. You state that both of you are showing possible
consideration of early retirement. Three of the five members of
the Retirement Board -- including you -- would be eligible to take
advantage of the early retirement if it is approved. You state
that all three of you show an interest in this early retirement
program. You are interested in what avenues can be followed to
alleviate possible conflicts, yet you state that you want to be
able to make a decision on what is best for all.
You state that as to each of these Boards, if the Members who
would be eligible to participate in the plan, including you,
exclude yourselves because of a conflict, the plan could not be
adopted. You ask whether you may disclose and yet vote for the
plan if otherwise it could not be passed.
As to the County Commissioners, you ask whether, if the one
Commissioner who would not qualify to participate in the early
retirement incentive program would vote in favor of the program,
you could disclose and vote in favor of the program. You further
ask whether, if the one Commissioner who does not qualify to
participate in the program votes against the program, the other two
who would be eligible -- including yourself -- could make a
disclosure and vote in favor of the program.
Based upon all of the above, you request an advisory from the
State Ethics Commission.
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 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.
It is further initially noted that your inquiry may only be
addressed with regard to your own, proposed conduct. To the extent
you have inquired regarding the propriety of the proposed conduct
of others, your inquiry is a third party request which cannot and
will not be addressed.
As a County Commissioner for Fayette County and as a member of
the Retirement Board for Fayette County, Pennsylvania, you are a
public official as that term is defined under the Ethics Law, and
Jones, Robert E., 95 -500
January 3, 1995
Page 3
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.
"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.
"Contract." An agreement or arrangement
for the acquisition, use or disposal by the
Commonwealth or a political subdivision of
consulting or other services or of supplies,
materials, equipment, land or other personal
or real property. "Contract" shall not mean
an agreement or arrangement between the State
or political subdivision as one party and a
public official or public employee as the
other party, concerning his expense,
Jones, Robert E., 95 -500
January 3, 1995
Page 4
reimbursement, salary, wage, retirement or
other benefit, tenure or other matters in
consideration of his current public employment
with the Commonwealth or a political
subdivision.
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
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
Jones, Robert E., 95 -500
January 3, 1995
Page 5
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.
The State Ethics Commission must observe the stated purpose of
the Ethics Law which is to strengthen the faith and confidence of
people in their government by assuring the public that the
financial interests of the holders of or candidates for public
office do not present a conflict with the public trust.
It is initially noted that Section 3(f) of the Ethics Law
which pertains to contracts between a public official /public
employee and his governmental body would not apply to your inquiry
given that the above definition of "contract" specifically excludes
agreements or arrangements for retirement from current public
service.
The propriety of the proposed conduct will now be addressed
under Section 3(a) of the Ethics Law. A recognized concern arises
where a public program, funded with public monies and administered
through a public agency, political subdivision, or governmental
body is available to and is controlled by public officials or
employees of that agency or governmental body. Public concern and
criticism may arise if a public official or public employee who
serves a governmental body receives benefits under a program of
this nature.
It is clear that the Ethics Law, and in particular Section
3(a), was primarily designed to restrict the activity of a public
official or employee from using the authority of office for private
pecuniary benefit. However, as a general rule, the Ethics Law was
not enacted nor should it be interpreted to preclude public
officials or employees from participating in programs which might
otherwise be available to them. Wolff, Opinion 89 -030; Woodrina,
Opinion 90 -001.
In order to insure that a public official or employee is not
in a conflict when he seeks to participate in a program such as an
early retirement incentive program, he must observe the following:
Jones, Robert E., 95 -500
January 3, 1995
Page 6
1. play no role in establishing the terms and
conditions for the early retirement provision;
2. abstain from voting and other official action as to
the resolution for an early retirement provision
and as to the early retirement provision itself,
while publicly disclosing the reason for his
abstention as required by Section 3(j) of the
Ethics Law set forth above;
3. play no role in the process of selecting and
reviewing applicants for early retirement under the
early retirement incentive program;
4. use no confidential information acquired
during the holding of public office to apply
for participation in the early retirement
incentive program; and
5. have no involvement with the administration of the
program.
Through application of the above criteria, the State Ethics
Commission has sought to eliminate the possibility that a public
official /employee who is seeking to participate in such a program
would be in a position to insure that the program benefits would be
available for his own benefit. Thus, a public official or public
employee in such a situation should refrain from participating in
making decisions or recommendations about the program and regarding
distribution of the limited funds which might be available as a
result of such a program.
If you act in conformance with the above criteria, you may
apply for and participate in the benefits associated with the early
retirement incentive program.
However, you ask whether you may vote as to the early
retirement incentive program for Fayette County and participate in
it in light of the number of public officials who, pursuant to the
Ethics Law, may be abstaining from decisions as to the early
retirement incentive program. You are advised that the following
portion of Section 3(j) is dispositive of the issue:
Section 3. Restricted activities
(j) . 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
Jones, Robert E., 95 -500
January 3, 1995
Page 7
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.
65 P.S. §403(j).
In applying the above language to the facts which you have
presented, the County Board of Commissioners shall first be
considered. Given that it is a three member board, if you would
first abstain fully from any participation and meet the disclosure
requirements of Section 3(j) and the result would either be a
deadlock vote between the remaining two Commissioners or the
casting of a vote by only one Commissioner if the other
Commissioner was required to abstain under the Ethics Law as well,
you would then be permitted to vote. This Advice is expressly
conditioned upon your first abstaining and meeting the disclosures
as required by the Ethics Law.
As for the Fayette County Retirement Board, that Board
consists of five members. Therefore, the provision dealing with
three - member governing bodies which become deadlocked following an
abstention would be inapplicable to that Board. However, if the
number of members of the Retirement Board required to abstain from
voting pursuant to the Ethics Law would make the legally required
vote of approval unattainable, which in the case of a five member
board would be three or more members abstaining under the Ethics
Law, then again, conditioned upon the assumption that you would
first fully abstain and make the required disclosures, you would be
permitted to vote.
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 County Code or the County
Pension Law.
Conclusion: As a Fayette County Commissioner and a member of the
Retirement Board for Fayette County, you are a public official
Jones, Robert E., 95 -500
January 3, 1995
Page 8
subject to the provisions of the Ethics Law. Section 3(a) of the
Ethics Law would not preclude you from applying for early
retirement under an early retirement incentive program which may be
adopted for Members of the Fayette County employee retirement
system, provided you play no role in establishing the terms and
conditions of the early retirement provision; abstain from voting
and other official action as to the resolution for an early
retirement provision and as to the early retirement provision
itself, while publicly disclosing the reason for your abstention as
required by Section 3(j) of the Ethics Law set forth above; play no
role in the process of selecting and reviewing applicants for early
retirement under the early retirement incentive program; use no
confidential information acquired during the holding of public
office to apply for participation in the early retirement incentive
program; and finally have no involvement with the administration of
the program. If, in your capacity as a County Commissioner, you
abstain fully and make the disclosure required by Section 3(j) of
the Ethics Law as to the early retirement incentive program, and
the result is either that the remaining two Commissioners deadlock
or there is only one Commissioner to vote because the other
Commissioner also abstains pursuant to the Ethics Law, then you may
subsequently vote. If, in your capacity as a member of the Fayette
County Retirement Board, you first fully abstain and make the
required disclosures pursuant to Section 3(j) of the Ethics Law,
and the result is that the Board is unable to take any action
because three or more members of the Board required to abstain from
voting under the provisions of the Ethics Law makes the majority or
other legally required vote of approval unattainable, then you may
subsequently vote. 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
Jones, Robert E., 95 -500
January 3, 1995
Page 9
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.
i cerely,
Vincent
Chief Counsel