HomeMy WebLinkAbout96-602 TobinMarlene C. Tobin
127 Alexander Drive
McMurray, PA 15317
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
October 24, 1996
96 -602
Re: Conflict, Public Official /Employee, School Board, Member, Volunteer Video
Production Producer; Public Access Station, School Board Meetings.
Dear Ms. Tobin:
This responds to your letter of September 24, 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 as to her uncompensated and
voluntary production of videotaped school board meetings for airing on a public access
station.
Facts: As a Member of the School Board in Peters Township, Washington
County, Pennsylvania, you request an advisory from the State Ethics Commission.
You have been a School Board Member since December, 1995. For two years
before you were elected, you were the volunteer video production producer of "Gavel
to Gavel School Board Meetings," a videotaped show of the School Board Meetings
that was and continues to be aired on the local public access station.
You state that in the more than three years that you have been producing this
show, you have received no compensation for your services. You state that you have
always done this as a public service to the community and not as a representative of
the School Board or School District, or as an assistant — paid or otherwise — for
anyone else.
You state that in order to air a production on the Peters Township public access
station, one must call the community TV station, ask permission to use the publicly
owned equipment and then return the video to the station for airing. You state that
the project and the full production of the show, including the video rights, were and
still are yours alone. You set up the equipment, videotape the meeting, remove the
equipment, add titles to the tape and deliver it to the station. You take full
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October 24, 1996
Page 2
responsibility for the content of the show, the quality of the production and the editing
rights.
Since your election to the School Board, you have continued performing this
service for the community. You set the camera, start it, and then take your place at
the Board table. When the meeting is over, you shut off the camera and return the
equipment and videotape to the station as you did before you were on the Board.
You state that several Board Members and some community members have now
implied that this constitutes a conflict of interest and that you must stop producing the
School Board meetings for TV. A community group is claiming that you are editing the
videotapes, and it is trying to stop you from continuing. You state that although
editing is not the issue, you have never edited any meeting.
It is your belief that it would not be a conflict under the Ethics Law for you to
continue producing the aforesaid show while serving on the School Board, given that
no compensation is involved and both jobs are performed as a volunteer community
service. You state that the School Board Solicitor agrees with your view but would
like a written advisory from this Commission.
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 in Peters Township, you are a public official
as that term is defined under the Ethics Law, and hence you are 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
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October 24, 1996
Page 3
"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.
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
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October 24, 1996
Page 4
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, pursuant to Section 3(a) of the Ethics Law, a public official /public
employee is prohibited from using the authority of public office /employment or
confidential information received by holding such a public position for the private
pecuniary benefit of the public official /public employee himself, any member of his
immediate family, or a business with which he or a member of his immediate family
is associated. A prohibited private pecuniary benefit is an essential element for finding
a Section 3(a) violation. Based upon the facts which you have submitted, wherein you
have specifically stated that your services as video production producer are strictly
voluntary and uncompensated, there would be no private pecuniary benefit involved
and consequently, Section 3(a) would not restrict your continuing to provide such
services while serving as a School Board Member.
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 School Code.
Conclusion: As a Member of the School Board in Peters Township, you are a
public official subject to the provisions of the Ethics Law. Section 3(a) of the Ethics
Law would not restrict you as to your uncompensated and voluntary production of
videotaped School Board meetings for airing on a public access station because there
would be no private pecuniary benefit involved. 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
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October 24, 1996
Page 5
the Commission within thirty (30) days may result in the dismissal of
the appeal.
' cerely,
Vincent "Dopko
Chief Counsel