HomeMy WebLinkAbout96-532 WatersCharles A. Waters, Esquire
Steckel & Stopp
4331 Route 309
PO Box 216
Schnecksville, PA 18078 -0216
Re: Conflict, Public Official /Employee, Auditor, Township employee, Road Crew
Worker.
Dear Mr. Waters:
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
March 29, 1996
96 -532
This responds to your letter of February 27, 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 Township Auditor who is also a Township road crew
worker with regard to participating in the Township audit and /or the setting of
compensation for Township Supervisors.
Facts: As Solicitor for the Board of Supervisors of Weisenberg Township, a
township of the second class located in Lehigh County, Pennsylvania, you are seeking
an advisory opinion on behalf of Mr. Forrest D. Kistler (Kistler), who is a Weisenberg
Township Auditor.
Kistler is currently serving a six year term as Auditor, which term began on
January 1, 1996. Kistler has served as a Township Auditor for over forty years.
Kistler is also an employee of Weisenberg Township, having been hired in April, 1995
as a full -time township road crew worker. The Township Roads Department consists
of one working township supervisor /road foreman who supervises four full -time road
crew workers.
You pose the following questions as to Kistler's future conduct:
1. May Kistler participate in the auditing of the general financial affairs of
Weisenberg Township?
2. May Kistler participate in auditing the financial affairs of Weisenberg Township
as they specifically relate to the township road department?
3. May Kistler participate in auditing the Weisenberg Township records dealing
with his compensation as an employee of the township?
Waters /Kistler, 96 -532
March 29, 1996
Page 2
4. May Kistler participate in setting the compensation of Weisenberg Township
Supervisors as contemplated and authorized by the Second Class Township
Code?
Discussion: It is initially noted that pursuant to Sections 7(10) and 7(1 1) 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 an Auditor for Weisenberg Township, Kistler 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
the understanding that the vote, official action, or judgement of the public
Waters /Kistler, 96 -532
March 29, 1996
Page 3
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 above provisions of the Ethics Law to the circumstances which
you have submitted, there appears to be no statutorily declared incompatibility which
would preclude a second class township auditor from being employed by the township
which he serves. However, pursuant to Section 3(a) of the Ethics Law, a conflict of
interest would arise in each instance where the use of Kistler's authority of office or
the use of confidential information which he has access to by being in his office would
result in a private pecuniary benefit for himself.
Waters /Kistler, 96 -532
March 29, 1996
Page 4
Additionally, under the facts which have been submitted, Kistler is one of the
four full -time road crew workers who are supervised by the Township Supervisor /Road
Foreman. It is clear that at least this particular Supervisor would have direct
supervision over Kistler as a Township employee. Thus, in this case, conflicts will also
arise not only as to matters where Kistler himself would derive a private pecuniary
benefit, but also in matters where his boss, the Township Supervisor /Road Foreman,
or any other Supervisor who makes decisions as to Kistler's employment, would derive
a private pecuniary benefit. Bassi, Opinion 86- 007 -R; Woodrinq, Opinion 90 -001.
Kistler could not participate in auditing those portions of the books and accounts
of the Township which would involve the receipt of a pecuniary benefit by him, his
boss, or any other Supervisor who makes decisions as to Kistler's employment. In
each instance of a conflict of interest, Kistler would be required to abstain fully and to
publicly announce his abstention and the reasons for same, both orally at the public
meeting and in a written memorandum filed with the person recording the minutes.
Having set forth the above, your specific inquiries shall now be considered.
In response to your first specific inquiry, you are advised that Kistler may
participate in auditing the general financial affairs of Weisenberg Township only to the
extent that he can do so without participating in matters pertaining to himself, his
boss, the Township Supervisor /Road Foreman, and /or any other Supervisor who makes
decisions as to Kistler's employment. To the extent such matters can be segregated
so that Kistler may abstain and satisfy the disclosure requirements of Section 3(j)
when he has a conflict, Kistler may participate as to the other matters /individuals
which do not present a conflict.
As for your second specific inquiry, likewise, Kistler may participate in auditing
the financial affairs of Weisenberg Township as they relate to the Township Road
Department only to the extent that he can do so without participating in matters that
would result in a private pecuniary benefit to himself, his boss, the Township
Supervisor /Road Foreman, and /or any other Supervisor who makes decisions as to
Kistler's employment.
As for your third specific inquiry, Kistler may not participate in auditing the
Weisenberg Township records which deal with his own compensation as an employee
of the Township, or the compensation of his boss, the Township Supervisor /Road
Foreman, or any other Supervisor who makes decisions as to Kistler's employment.
Finally, as for your fourth specific inquiry, Kistler may not participate in setting
the compensation of his boss, the Township Supervisor /Road Foreman, and /or any
other Supervisor who makes decisions as to Kistler's employment with the Township.
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 Second Class Township Code.
Conclusion: As an Auditor for Weisenberg Township, Forrest D. Kistler (Kistler)
is a public official subject to the provisions of the Ethics Law. Given that Kistler is
employed as a road crew worker in the Township Roads Department, where he is
Waters /Kistler, 96 -532
March 29, 1996
Page 5
subject to the supervision of a working Township Supervisor /Road Foreman, pursuant
to Section 3(a) of the Ethics Law, Kistler would have a conflict of interest in any
matter before him as a Township Auditor where the use of the authority of his public
office or the use of confidential information to which he has access as a result of being
a Township Auditor, would result in a private pecuniary benefit for himself, his boss,
the Township Supervisor /Road Foreman, or any other Supervisor who makes decisions
as to Kistler's employment. In each instance of a conflict of interest, Kistler would be
required to abstain fully and to satisfy the disclosure requirements of Section 3(j) as
set forth above. Kistler may participate in auditing the general financial affairs of the
Township and specifically the records pertaining to the Township Roads Department
to the extent that he can do so without participating in matters that would result in a
private pecuniary benefit to himself, his boss, the Township Supervisor /Road Foreman,
or any other Supervisor who makes decisions as to Kistler's employment. Kistler may
not participate in auditing the Township records which deal with his own
compensation as an employee of the Township, or compensation to his boss, the
Township Supervisor /Road Foreman, or any other Supervisor who makes decisions as
to Kistler's employment. Kistler may not participate in setting the compensation of his
boss, the Township Supervisor /Road Foreman, or any other Supervisor who makes
decisions as to Kistler's employment with the 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.
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 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 within thirty (30) days may result in the dismissal of the
appeal.
erely,
Vincent Dopko
Chief Counsel