HomeMy WebLinkAbout96-525 MillerDear Mr. Miller:
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
March 5, 1996
John R. Miller, Jr., Esquire
Miller, Kistler, Campbell, Miller & Williams, Inc.
124 North Allegheny Street
Bellefonte, PA 16823
96 -525
Re: Conflict, Public Official /Employee, School Board, Member, Second Class
Township, Solicitor, University Amusement Tax, Impact Fee.
This responds to your letter of February 12, 1996 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 school board member who is also the solicitor for a
township within the school district boundaries.
Facts: You are the Solicitor for the State College Area School District (School
District) in Centre County and are requesting an advisory on behalf of Louis T. Glantz
(Glantz) who is a member of the State College Area School Board (School Board). On
January 19, 1996, Glantz was appointed Solicitor for the College Township Council.
The School District is composed of six municipalities - the Townships of College,
Harris, Halfmoon, Patton and Ferguson, and the Borough of State College. You state
that it had been your opinion that there was no conflict of interest regarding a member
of the School Board acting as Solicitor for a Township within the boundaries of the
School District. However, certain circumstances have recently arisen which prompted
this advisory request.
College Township is currently considering adoption of an amusement tax which
would tax admissions to the activities of Pennsylvania State University which is
located within the Township. The University has an agreement with the School
District, Centre County, State College Borough and College Township which provides
for the University to pay impact fees to these municipalities, including the School
District. An article recently appeared in the local newspaper regarding the amusement
tax and made reference that such an action may adversely affect the agreement with
the University, which would impact on the School District. The article specifically
mentioned that Glantz, in addition to being the Township Solicitor, was also a member
of the School Board.
Miller /Glantz, 96 -525
March 5, 1996
Page 2
You indicate that Glantz is not handling the legal matters relating to the levying
of the amusement tax by the township, rather special counsel has been 6ppointed to
handle that matter.
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.
As a Member of the School Board for the State College Area, Glantz 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.
"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 anything of monetary value and no
public official /employee shall solicit or accept anything of monetary value based upon
Miller/Glantz, 96 -525
March 5, 1996
Page 3
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 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.
In applying the provisions of Section 3(a) of the Ethics Law to the instant
matter, the fact that Glantz is a member of the School Board and Solicitor for College
Township does not per se create a conflict. In order to establish a conflict, there
would have to be a use of authority of office to obtain a private pecuniary benefit for
Glantz himself, a member of his immediate family or a business with which he or a
member of his immediate family is associated. An example of such a conflict would
be if Glantz advocated, participated and voted in awarding a contract to his law firm,
Miller /Glantz, 96 -525
March 5, 1996
Page 4
the business with which he is associated. Contrariwise, the possibility that College
Township, of which Glantz is Solicitor, may take action which could have a negative
impact upon the School District of which Glantz is a board member would not
constitute a conflict under the Ethics Law in that there is no showing under the
proffered facts of any private pecuniary benefit inuring to either Glantz, an immediate
family member or a business with which he or an immediate family member is
associated.
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 respective municipal code.
Conclusion: As a School Board Member for the State College Area, Glantz is a
public official subject to the provisions of the Ethics Law. Under Section 3(a) of the
Ethics Law, Glantz as Solicitor for a municipality would not have a conflict as to
matters which will impact upon a school district of which he is a board member unless
there is a use of authority of office to obtain a private pecuniary benefit for himself,
a member of his immediate family or a business with which he or a member of his
immediate family is associated. 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.
This letter is a public record and will be made available as such.
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 actuaily received
at the Commission within thirty (30) days of the date of this Advice
pursuant to 51 Pa. Code §13.2M). 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 thirty (30) days may result in the dismissal of
the appeal
cerely,
Vincent
Chief Counsel