HomeMy WebLinkAbout97-592 TiffanySTATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
July 15, 1997
Robert F. Tiffany
PO Box 45 97-592
South Montrose, PA 18843
Re: Simultaneous Service, Township Municipal Authority, Part-time Employee, Board
Member.
Dear Mr. Tiffany:
This responds to your letter of June 10, 1997, by which you requested advice
from the State Ethics Commission.
Issue: Whether the Public Official and Employee Ethics Law imposes any
prohibition or restrictions upon a Member of a Township Municipal Authority from also
serving as an employee of the Authority.
Facts: You presently work part -time for the Bridgewater Township Municipal
Authority (BTMA). You have also been asked to become a Member of BTMA's Board
of Directors. You state that there have been problems in the past with Board Members
having conflicts of interest. You request an advisory from this Commission so that
you may avoid any conflict of interest problems.
Discussion: If you would be appointed to the Bridgewater Township Municipal
Authority (BTMA), you would in that position be a "public official" as that term is
defined in the Ethics Law and hence you would be subject to the provisions of the
Ethics Law. 65 P.S. §402; 51 Pa. Code §11.1.
Sections 3(a) and 3(j) of the Ethics Law provide:
Section 3. Restricted Activities.
(a) No public official or public employee shall
engage in conduct that constitutes a conflict of interest.
(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
Tiffany, 97 -592
July 15, 1997
Page 2
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(a), (j).
The following terms that pertain to conflicts of interest under the Ethics Law are
defined 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 applying the above provisions of the Ethics Law to the question of
simultaneous service, it is initially noted that the General Assembly has the
constitutional power to declare by law which offices are incompatible. Pa. Const. Art.
Tiffany, 97 -592
July 15, 1997
Page 3
6, §2. There does not appear to be any statutorily - declared incompatibility precluding
simultaneous service in the positions in question.
Turning to the question of conflict of interest, the State Ethics Commission has
held that Section 3(a) of the Ethics Law would not prohibit a municipal authority board
member from simultaneously serving in a compensated position of employment with
the authority on which he serves. Swick /Aman, Opinion No. 91 -006. However,
pursuant to Section 3(a) of the Ethics Law, the Authority Member /Authority employee
would be prohibited from using the authority of his public position or confidential
information received by holding such position for a prohibited private pecuniary benefit.
Thus, for example, the authority board member could not use the authority of office
by participating in matters concerning his own authority employment such as salary
raises, his job performance, etc. J , Koslow, Order 458 -R, affirmed Koslow v. State
Ethics Commission, 540 A.2d 1374 (Pa. Commw. Ct. 1988).
Based upon the facts which have been submitted, your proposed simultaneous
service as a BTMA Board Member and as a part-time employee of BTMA would be
permitted within the parameters of Section 3(a). In each instance of a conflict of
interest, you would be required to abstain and to satisfy the disclosure requirements
of Section 3(j) as set forth above.
Lastly, the propriety of the proposed conduct has only been addressed under the
Ethics Law.
Conclusion: If you would be appointed to the Bridgewater Township Municipal
Authority (BTMA), you would in that position be a "public official" subject to the
provisions of the Ethics Law. You may, consistent with Section 3(a) of the Ethics
Law, simultaneously serve as a BTMA Board Member and as a part-time employee of
BTMA, subject to the restrictions, conditions and qualifications set forth above.
Lastly, the propriety of the proposed course of 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 § la 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
Tiffany, 97 -592
July 15, 1997
Page 4
the Commission within thirty (30) days may result in the dismissal of
the appeal.
cerely,
Vincent J. Dopko
Chief Counsel