HomeMy WebLinkAbout95-522-S ConfidentialSTATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
May 2, 1995
Re: Simultaneous Service, Public Official /Employee,
Township, Councilman, Roadmaster.
This responds to your letter of March 14, 1995,
requested confidential supplemental advice from the
Commission.
Issue: Whether the Public
presents any prohibition or
first class township with a
serving or being employed as
95 -522 -S
First Class
in which you
State Ethics
Official and Employee Ethics Law
restrictions upon a councilman of a
Plan C form of government from also
a township roadmaster
Facts: As the Solicitor for A, a First Class Township with a Plan
C form of government under Act 62 of 1972, you seek a supplemental
advisory opinion to Advice 95 -522. The facts as stated in Advice
95 -522 are assumed to be applicable here. Assuming the township
created the position of roadmaster, you ask whether 8 can serve as
a salaried township roadmaster when the Township Administrative
Code authorizes a council "to appoint individuals as non-
professional advisors and liaisons, and to set their compensation
as council sees fit." Assuming that he can serve as roadmaster,
you further ask whether he would be required to abstain from
deliberating and /or voting on his own appointment.
Discussion: It is initially noted that pursuant to Sections 7(10)
and 7(11) of the Ethics Law, 65 P.S. § 5407(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.
Confidential Advice, 95 -522 -S
May 2, 1995
Page 2
As a councilman for A, B is a public official as that term is
defined under the Ethics Law, and hence he is 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.
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.
As to the question posed regarding whether a first class
councilman may serve as roadmaster or participate in or vote for
his own appointment, the Ethics Law would impose the same
restrictions and prohibitions as those set forth in Advice 95 -522
which is incorporated by reference and excerpted in part below.
Confidential Advice, 95 -522 -S
May 2, 1995
Page 3
The Commission has held that a public official may receive
only that compensation which is specifically authorized in law. To
the extent that a public official receives compensation or money
which is not specifically authorized in law, the Commission has
found that the receipt of such money or such compensation by that
public official /employee serving in that position is a financial
gain or private pecuniary benefit contrary to Section 3(a) of the
Ethics Law. See, Hagen, Order No. 554 -R wherein the Commission
determined that a First Class Township Commissioner violated
Section 3(a) of the Ethics Law when he received various forms of
compensation that were not specifically authorized in the First
Class Township Code. In addition, the Commission has held that
public officials who receive compensation from employment that is
not specifically authorized in the respective municipal code
constitutes the receipt of compensation other than provided by law
or a private pecuniary benefit, contrary to Section 3(a) of the
Ethics Law. See, Painter, Order No. 861, affirmed in part,
Rebottini et al v. SEC, Pa. Commw. Ct. , 634 A.2d 743 (1993).
Therefore, in light of the above, you are advised that a township
councilman may not receive compensation as to a position of
employment in a First Class Township where the Township Code does
not specifically authorize such positions of employment.
Parenthetically, it must be noted that the references to the
Second Class Township Code are immaterial to the situation of the
First Class Township. Not only does the Second Class Township
specifically authorize positions of employment for township
supervisors but the Code also provides for a Board of Auditors
which is a separate independent body that sets and approves the
compensation for the Supervisors who are employees. While it is
true that a first class township may have auditors, these
individuals have no parallel oversight function as of the auditors
in second class townships. The General Assembly structured that
oversight function in the Second Class Township to be consistent
with the longstanding common law rule that a public official may
not set his own compensation nor may a public official participate
in financial matters that he has a direct or indirect interest. To
create or serve in such position in a first class township, the
councilman would be setting his own salary for a position which is
not specifically authorized and for which there is no independent
fiscal oversight.
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 councilman for a First Class Township, the
individual is a public official subject to the provisions of the
Confidential Advice, 95- 522 -S
May 2, 1995
Page 4
Ethics Law. Section 3(a) of the Ethics Law prohibits a counciima*+
of a First Class Township from serving and obtaining compensation
as to a created position of employment in a First Class Township.
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,
Vincent . Dopko
Chief Counsel