HomeMy WebLinkAbout95-512 AvrigianMason Avrigian, Jr.
150 Macklenburg Drive
Penllyn, PA 19422
Dear Mr. Avrigian:
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
February 3, 1995
95 -512
Re: Conflict, Public Official /Employee, Second Class Township,
Attorney, Supervisor, Law Firm, Business With Which
Associated, Solicitor.
This responds to your letter of January 6, 1995 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 an attorney from
becoming a second class township supervisor when the law firm with
which he is associated is solicitor for the township.
Facts: As a resident of Lower Gwynedd Township, a second class
township in Montgomery County, you are interested in running for
the position of Township Supervisor. Two of the five seats on the
Township Board will be open for election in 1995 with the primary
in May and the general election in November.
As an associate attorney in the law firm of Wisler,
Pearlstine, Talone, Craig, Garrity & Potash in Blue Bell,
Pennsylvania, James J. Garrity, who is one of the partners, is the
Solicitor for Lower Gwynedd Township having originally been
appointed in 1988 and reappointed up to and including 1995. If you
are elected, you inquire as to your status as an associate attorney
in the law firm which represents the Township. In particular, you
ask whether you would be prohibited from taking office or be
limited in your functions as a Supervisor and lastly whether
Garrity or the firm would be prohibited from continuing to serve as
Township Solicitor.
Discussion: As Supervisor for Lower Gwynedd Township, you would
become a public official as that term is defined under the Ethics
Law, and hence you would be subject to the provisions of that law.
ef
Avrigian, Jr., Mason, 95 -512
February 3, 1995
Page 2
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.
"Business with which he is associated."
Any business in which the person or a member
of the person's immediate family is a
director, officer, owner, employee or has a
financial interest.
"Financial interest." Any financial
interest in a legal entity engaged in business
for profit which comprises more than 5% of the
equity of the business or more than 5% of the
assets of the economic interest in
indebtedness.
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
Avrigian, Jr., Mason, 95 -512
February 3, 1995
Page 3
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(f) of the Ethics Law provides as follows:
Section 3. Restricted activities
(f) No public official or public
employee or his spouse or child or any
business in which the person or his spouse or
child is associated shall enter into any
contract valued at $500 or more with the
governmental body with which the public
official or public employee is associated or
any subcontract valued at $500 or more with
any person who has been awarded a contract
with the governmental body with which the
public official or public employee is
associated, unless the contract has been
awarded through an open and public process,
including prior public notice and subsequent
public disclosure of all proposals considered
and contracts awarded. In such a case, the
public official or public employee shall not
have any supervisory or overall responsibility
for the implementation or administration of
the contract. Any contract or subcontract
made in violation of this subsection shall be
voidable by a court of competent jurisdiction
if the suit is commenced within 90 days of the
making of the contract or subcontract.
Parenthetically, where contracting is otherwise allowed or
where there appears to be no expressed prohibitions to such
contracting, the above particular provision of the law would
require that an open and public process must be used in all
situations where a public official /employee is otherwise
appropriately contracting with his own governmental body, or
subcontracting with any person who has been awarded a contract with
the governmental body, in an amount of $500.00 or more. This open
and public process would require that the following be observed as
to the contract with the governmental body:
(1) prior public notice of the employment or contracting
possibility;
(2) sufficient time for a reasonable and prudent competitor/
applicant to be able to prepare and present an
Avrigian, Jr., Mason, 95 -512
February 3, 1995
Page 4
application or proposal;
(3) public disclosure of all applications or proposals
considered and;
(4) public disclosure of the contract awarded and offered and
accepted.
Section 3(f) of the Ethics Law also requires that the public
official /employee may not have any supervisory or overall
responsibility as to the implementation or administration of the
contract with the governmental body.
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
made as otherwise provided herein.
If a conflict exists, Section 3(j) requires the public
Avrigian, Jr., Mason, 95 -512
February 3, 1995
Page 5
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 applying the above provisions of the Ethics Law to the
questions you posed, you are advised that the Ethics Law would not
prohibit you from taking office as a township supervisor if you are
elected. The Ethics Law does not prohibit a public
official /employee from having outside business interests; however,
a conflict would arise whenever those private interests conflict
with the public interest. See Pancoe, Opinion 89 -011. Further,
whenever any private interest conflicts with the public interest,
the public interest is paramount. Crisci, Opinion 89 -013. If you
are elected Supervisor, the law firm in which you are an associate
would be a business with which you are associated as that term is
defined under the Ethics Law. Accordingly, you would have a
conflict as to any matter involving the law firm or any of its
clients. See Kannebecker, Opinion 92 -010 wherein the full
Commission opined upon the conflicts that a supervisor, who was an
attorney, had as to his law clients:
We believe that you would indeed have a conflict as to an
ongoing client or a client who is on a retainer even if
you would not represent the client as to a matter pending
before the Township. However, as to former or past
clients, we do not believe as a general rule that you
would have a conflict. Under certain circumstances, a
conflict could exist as to past clients; such would
depend upon factors like the number of prior
representations of any given client and the period of
time over which that occurred.
Kannebecker at 5.
Additionally, you would have a conflict in matters concerning
the appointment, retention, fees, salary, or any financial matter
as to the Township Solicitor which is currently the law firm in
which you are an associate. In such instances, you would have to
recuse yourself and observe the disclosure requirements of Section
3(j) of the Ethics Law noted above. As to whether your possible
service as a Township Supervisor would prevent Garrity or the firm
from continuing to serve as Solicitor to the Township, you are
advised that the Ethics Law would not prohibit Garrity or the firm
from serving as Solicitor, although you would have conflicts in the
areas noted above.
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
Avrigian, Jr., Mason, 95 -512
February 3, 1995
Page 6
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 Second Class Township Code or
the Rules of Professional Conduct.
Conclusion: As Supervisor for Lower Gwynedd Township, you would
become a public official subject to the provisions of the Ethics
Law. Although Section 3(a) of the Ethics Law would not prohibit
you as an attorney from becoming a Second Class Township Supervisor
when your law firm is Solicitor for the Township, you would have a
conflict as to matters involving your law firm, their clients and
issues concerning the appointment or financial matters as to the
Solicitor. In all such instances, you must recuse yourself and
observe the disclosure requirements of Section 3(j) outlined 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 FAS 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.
44)
Vincent X11. Do 7 ko
Chief Counsel