HomeMy WebLinkAbout95-615 ConfidentialSTATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
November 7, 1995
95 -615
Re: Conflict, Public Official /Employee, Contracting with
Governmental Body, School Director, Sale of Land to School
District.
This responds to your letters of September 14, September 22,
and October 3, 1995 in which you requested confidential advice from
the State Ethics Commission.
Issue: Whether the Public Official and Employee Ethics Law
presents any prohibition or restrictions upon a school director
with regard to his prospective sale of real estate to the school
board.
Facts: As Solicitor for School District A, you request a
confidential advisory on behalf of Mr. B, who is a Member of the
School Board.
Mr. B owns property adjacent to the school property, which
property the Board is interested in purchasing. Mr. B is
interested in selling the property, and he has the property listed
for sale with a local realtor. The value of the property exceeds
$500.00.
You state that Mr. B and the Board wish to proceed properly.
Mr. B would refrain from all discussions with any other Board
Member and his real estate agent would conduct all negotiations
with the Board. You also state that Mr. B would abstain from
voting should an agreement be reached.
On behalf of Mr. B, you ask what other precautions should be
taken to effectuate the proposed sale.
Discussion: It is initially noted that pursuant to Sections 7(10)
CONFIDENTIAL LEGAL ADVICE 95 -615
November 7, 1995
Page 2
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.
As a School Director for School District A, Mr. 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.
65 P.S. §403(a).
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
CONFIDENTIAL LEGAL ADVICE 95 -615
November 7, 1995
Page 3
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,
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.
65 P.S. §402 (Emphasis added).
Sections 3(b) and 3(c) of the Ethics Law, 65 P.S. §§ 403(b),
(c), 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.
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
CONFIDENTIAL LEGAL ADVICE 95 -615
November 7, 1995
Page 4
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.
65 P.S. §403(f).
Section 403(j) of the Ethics Law provides:
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.
65 P.S. §403(j).
Under Section 3(a) of the Ethics Law quoted above, a public
official may not use the authority of office or confidential
information to obtain a private pecuniary benefit for himself, a
CONFIDENTIAL LEGAL ADVICE 95 -615
November 7, 1995
Page 5
member of his immediate family or a business with which he is or a
member of his immediate family is associated.
Generally, the Ethics Law places no per se prohibition upon a
public official or business with which he is associated from
contracting with his governmental body. Pancoe, Opinion 89 -011.
However, under Section 3(a) of the Ethics Law, the public official
may not participate or vote on matters involving the contract, and
he must satisfy the requirements of Section 3(j) of the Ethics Law,
such that the reasons for the abstention must be publicly announced
as well as be set forth in a written memorandum to that effect
filed with the secretary recording the minutes.
Therefore, under Section 3(a) of the Ethics Law itself, Mr. B
would not be precluded from contracting with the School District
which is his governmental body but he could not participate or vote
as to the matter of the contract and he would have to comply with
the disclosure requirements of Section 3(j) of the Ethics Law.
As for Section 3(f) of the Ethics Law, the State Ethics
Commission has generally determined that its requirements for an
open and public process must be observed in all situations where a
public official is otherwise appropriately contracting with his own
governmental body in an amount of $500 or more. This open and
public process would require:
(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 application or proposal;
(3) public disclosure of all applications or
proposals considered and;
(4) public disclosure of the contract awarded and
offered and accepted.
Further, Section 3(f) requires that the public official could
not have supervisory or overall responsibility as to the
implementation or administration of the contract.
Parenthetically, although the contracting in question would
not be prohibited under the Ethics Law provided the requirements of
Sections 3(a), (f) and (j) are satisfied, a problem may exist as to
such contracting under the Public School Code which provides as
follows:
No school director shall, during the term
[f]or which he was elected or appointed, as a
CONFIDENTIAL LEGAL ADVICE 95 -615
November 7, 1995
Page 6
24 P.S. §3 -324.
such.
private person engage in any business
transaction with the school district in which
he is elected or appointed . . . .
Since such contracting may be prohibited by the above quoted
provision of the Public School Code, it is suggested that Mr. B
obtain legal advice in that regard.
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. Specifically not
addressed in this advice is the applicability of the Public School
Code, although it is recommended that Mr. B obtain legal advice as
to its applicability.
Conclusion: As a School Director for School District A, Mr. B is
a public official subject to the provisions of the Ethics Law.
Under Section 3(a) of the Ethics Law, a public official /employee or
a "business with which - -- associated" may contract with the
governmental body but may not vote or participate in the matter of
the contract and must observe the disclosure requirements of
Section 3(j) outlined above. Furthermore, if the contract is $500
or more, the open and public process as outlined above must be
accomplished. The public official /employee may not have any
supervisory or overall responsibilities as to the contract.
Lastly, the propriety of the proposed conduct has only been
addressed under the Ethics Law. Due to the possible application of
the Public School Code in this matter, it is suggested that Mr. B
obtain legal advice in that regard.
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.
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.
CONFIDENTIAL LEGAL ADVICE 95 -615
November 7, 1995
Page 7
Any such appeal must be in writing and must be
actually received at the Commission within thirty (30)
days of the date of this Advice pursuant to 51 Pa. Code
§13.2(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 wi thin thirty (30) days
may result in the dismissal of the appeal.
cerely,
Vincent J. Dopko
Chief Counsel