HomeMy WebLinkAbout99-504 SlavenMichael Slaven
4140 Henderson Rd.
Hickory, PA 15340
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
(717) 783 -1610
1- 800 - 932 -0936
ADVICE OF COUNSEL
February 4, 1999
99 -504
Re: Conflict; Simultaneous Service; Emergency Medical Technician; Compensation;
Firefighter; Chief; Volunteer Fire Company; Township.
Dear Mr. Slaven:
This responds to your letter of December 17, 1998, by which you requested
advice from the State Ethics Commission.
Issue: Whether the Ethics Act imposes any prohibition or restrictions upon an
Emergency Medical Technician /paid firefighter from simultaneously serving or being
employed as the chief of a volunteer fire company.
Facts: You are a paid Emergency Medical Technician ( "EMT ") /firefighter with the
Mount Pleasant Township Volunteer Fire Company, Inc. ( "Fire Company "), located in
Mount Pleasant Township ( "Township "), Washington County.
In the 1998 calendar year, the Township appropriated funds for paying
firefighters and emergency medical technicians. The Township funding was not given
to the Fire Company, but rather paychecks were issued by the Township to the
individuals as if they were Township employees. These individuals receive W -2 forms
from the Township. You presume that the same process will be used in future years.
You have recently been elected Chief of the Fire Company. As Chief, you are
responsible for training and operations. You are not an officer or a director of the
incorporated Fire Company, nor are you responsible for "corporate governance."
You ask for an advisory from the State Ethics Commission as to whether you
may receive compensation as an EMT /firefighter while simultaneously serving as Chief
of the Fire Company.
Discussion: As the Chief of the Mount Pleasant Township Volunteer Fire
Company, Inc. ( "Fire Company "), you are a "public employee" as that term is defined
in the Public Official and Employee Ethics Act ( "Ethics Act ") and hence you are subject
to the provisions of the Ethics Act. 65 Pa.C.S. §1102; 51 Pa. Code §11.1.
Sections 1 103(a) and 1 103(j) of the Ethics Act provide:
FAX : (717) 787 -0806 • Web Site: www.ethics.state.pa.us • e -mail: sec@state.pa.us
Slaved, 99 -504
February 4, 1999
Page 2
(j) Voting conflict. - -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 Pa.C.S. §§1103(a), (j).
Section 1103. Restricted activities.
(a) Conflict of interest. - -No public official or public
employee shall engage in conduct that constitutes a conflict
of interest.
The following terms that pertain to conflicts of interest under the Ethics
defined as follows:
Section 1102. 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. The term 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
Act are
Slaven, 99 -504
February 4, 1999
Page 3
65 Pa.C.S. §1102.
to the performance of duties and responsibilities unique to
a particular public office or position of public employment.
Under Section 1 103(a) of the Ethics Act, 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, a member of his immediate family, or a
business with which he or a member of his immediate family is associated.
In applying the above provisions of the Ethics Act 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.
6, §2.
Where simultaneous service would place the public official /public employee in
a continual state of conflict, such as where in one position he would be accounting to
himself in another position on a continual basis, there would be an inherent conflict
(See, Johnson, Opinion 86 -004). Where an inherent conflict would exist, it would
appear to be impossible, as a practical matter, for the public official /public employee
to function in the conflicting positions without running afoul of Section 1 103(a).
Absent a statutorily - declared incompatibility or an inherent conflict under
Section 1 103(a), the Ethics Act would not preclude an individual from simultaneously
serving in more than one position, but in each instance of a conflict of interest, the
individual would be required to abstain and to satisfy the disclosure requirements of
Section 1 103(j) as set forth above.
In this case, based upon the limited facts which have been submitted, there is
no statutory incompatibility as an EMT /paid firefighter and Chief of the Mount Pleasant
Township Volunteer Fire Company, Inc.
As to the issue of whether an inherent conflict exists, no facts are provided,
other than that you are responsible for training and operations, regarding your duties
as the Fire Chief vis -a -vis the EMT's and firefighters. An inherent conflict may exist
depending upon what your duties and responsibilities are as Fire Chief. If you have
supervisory duties as to the EMT's and firefighters, you would have a conflict as to
yourself in your other position of EMT and paid firefighter. For example, you could not
as Fire Chief review or approve your own time sheets, could not do a performance
evaluation review of yourself, could not approve any expense reimbursement claims
submitted by yourself, nor take any type of action where you as Fire Chief would be
reviewing or passing upon what you do as an EMT or firefighter.
If you have such responsibilities as Chief, not only would you have a conflict as
to matters involving yourself as EMT /firefighter, but you would have conflicts in
certain instances as to the other EMT's /firefighters. For example, if you were required
to furlough one or more EMT's /firefighters, you would have a conflict because a
furlough of some other EMT /firefighter would ensure the continuation of your own
position as EMT /firefighter. See, Pepper, Opinion No. 87 -007.
The above is illustrative of conflicts that would arise if you as Fire Chief have
such supervisory responsibilities over the EMT's /firefighters. If you do have such
responsibilities over EMT's and firefighters, including yourself, it is difficult to conceive
how you could function as a practical matter in the position of Fire Chief. Since the
submitted facts are general in nature as to the structure of the Fire Company as well
Slaven, 99 -504
February 4, 1999
Page 4
as the duties and responsibilities of the Fire Chief, the above response can only be
generalized.
This Advice is limited to addressing the applicability of Section 1 103(a) of the
Ethics Act. It is expressly assumed that there has been no use of authority of office
for a private pecuniary benefit as prohibited by Section 1 103(a) of the Ethics Act.
Further, you are advised that Sections 1103(b) and 1 103(c) of the Ethics Act provide
in part that no person shall offer to a public official /public employee and no public
official /public employee shall solicit or accept anything of monetary value based upon
the understanding that the vote, official action, or judgment of the public official /public
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.
Lastly, the propriety of the proposed conduct has only been addressed under the
Ethics Act.
Conclusion: As the Chief of the Mount Pleasant Township Volunteer Fire
Company, Inc., you are a "public employee" subject to the provisions of the Ethics
Act. You may, consistent with Section 1103(a) of the Ethics Act, simultaneously serve
in the positions of EMT /paid firefighter and Chief, conditioned upon the assumption
that no inherent conflict exists between your duties and responsibilities as Fire Chief
vis -a -vis your position and others as EMT's and firefighters. Lastly, the propriety of the
proposed course of conduct has only been addressed under the Ethics Act.
Pursuant to Section 1107(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 . opko
Chief Counsel