HomeMy WebLinkAbout95-508 LoprestiJames A. Lopresti
908 Marion Street
New Eagle, PA 15067
Dear Mr. Lopresti:
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
January 27, 1995
95 -508
Re: Simultaneous Service, Borough Councilmember and Municipal
Authority Board Member, Spouse as Borough Clerk.
This responds to your letter of December 29, 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 borough councilman from also
serving or being employed as a municipal authority board member and
from participating in matters involving his spouse as borough clerk
Facts: On the advice of the New Eagle Borough Solicitor, you are
writing to seek clarification on your voting privileges as a New
Eagle Borough Councilmember. On December 12, 1994, you were
appointed to fill a vacancy on the Borough Council. In addition,
you serve as Chairman of the Municipal Authority of the Borough of
New Eagle, an Authority as to which its members receive no
compensation. Your Solicitor has opined that you are allowed to
fill both positions. After noting that your wife is the Borough
Clerk, which is a compensated position for New Eagle Borough, you
request information that will help you understand your voting
rights as a Member of Council and the Authority.
Discussion: As a Municipal Authority Board Member and
Councilmember for New Eagle Borough, you are a "public official" 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
Lopresti, James A., 95 -508
January 27, 1995
Page 2
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
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 and as Borough Councilmember. Basically, the
Ethics Law does not state that it is inherently incompatible for a
public official/ employee to serve or be employed as Borough
Councilmember. 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
Lopresti, James A., 95 -508
January 27, 1995
Page 3
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
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.
Having noted that there would be no prohibition under the
Ethics Law for you serving as Borough Councilman and as Member of
the Borough Municipal Authority, for which you receive no
compensation, an issue does arise regarding your spouse's
employment as a Borough Clerk. As to matters involving the
financial interests of your spouse, such as salary, raise,
benefits, etc., you would have a conflict as a Borough Councilman
and would have to recuse yourself from such matters and observe the
disclosure requirements of Section 3(j), infra.
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
Lopresti, James A., 95 -508
January 27, 1995
Page 4
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.
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.
Conclusion: As a Municipal Authority Board Member and
Councilmember for New Eagle Borough Municipal Authority, you are a
"public official" 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 Borough
Councilman and Municipal Authority Board Member, subject to the
restrictions, conditions and qualifications set forth above. You
would have a conflict under Section 3(a) of the Ethics Law
regarding matters involving the financial interests of your spouse
as Borough Clerk; in such cases you would have to recuse yourself
and observe the disclosure requirements of Section 3(j) of the
Ethics Law as noted 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.
Lopresti, James A., 95 -508
January 27, 1995
Page 5
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,
Vincent 7. Dopko
Chief Counsel