HomeMy WebLinkAbout99-534 AndrewsWilliam C. Andrews, Esquire
Maiello, Andrews & Price, LLP
One Churchill Park, McCrady & Rodi Rds.
3301 McCrady Rd.
Pittsburgh, PA 15235 -5137
Dear Mr. Andrews:
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
(717) 783 -1610
1- 800 - 932 -0936
ADVICE OF COUNSEL
April 1, 1999
FAX: (717) 787 - 0806 • Web Site: www.ethics.state.pa.us • e - mail: ethics @state.pa.us
99 -534
Re: Conflict; Public Official /Employee; School Board Member; School District;
Communications Company; Magazine; Service; No Cost
This responds to your letters of February 22 and March 9, 1999 by which you
requested advice from the State Ethics Commission.
Issue: Whether the Public Official and Employee Ethics Act ( "Ethics Act "), 65
Pa.C.S. §1101 sea., presents any prohibition or restrictions upon a school board
member as to a company she owns publishing information in a magazine on behalf of
the school district on whose board she serves, at no charge to the school district.
Facts: You are the Solicitor for a school district and have been authorized to
request an advisory on behalf of one the school board members.
The School Board Member in question owns a communications company which
is interested in publishing a community magazine for the three municipalities which
constitute the school district for which she is a Board Member. The School Board
Member intends to allow the school district to submit non -board related materials to
the magazine such as its newsletter or other pre - printed information, as well as event
listings, phone numbers, or other information such as news briefs and articles
regarding students or school initiatives, at no cost to the district.
You ask for an advisory from the State Ethics Commission as to whether the
aforementioned actions would constitute a conflict of interest for the School Board
Member.
Discussion: It is initially noted that pursuant to Sections 1107(10) and
1107(11) of the Ethics Act, 65 Pa.C.S. §§1107(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 Pa.C.S. §§1107(10), (11).
Andrews, 99 -534
April 1, 1999
Page 2
An advisory only affords a defense to the extent the requestor has truthfully disclosed
all of the material facts.
A School Board Member is a public official as that term is defined in the Ethics
Act, and hence is subject to the provisions of that Act.
Section 1 103(a) of the Ethics Act provides:
Section 1 103. Restricted activities.
(a) Conflict of interest. - -No public official or public
employee shall engage in conduct that constitutes a conflict
of interest.
65 Pa.C.S. §1103(a).
The following terms are defined in the Ethics Act 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
to the performance of duties and responsibilities unique to
a particular public office or position of public employment.
"Business." Any corporation, partnership, sole
proprietorship, firm, enterprise, franchise, association,
organization, self - employed individual, holding company,
joint stock company, receivership, trust or any legal entity
organized for profit.
"Business with which he is associated." Any
business in which the person or a member of the person's
immediate family is a director, officer, owner, employee or
has a financial interest.
"Financial interest." Any financial interest in a legal
entity engaged in business for profit which comprises more
than 5% of the equity of the business or more than 5% of
the assets of the economic interest in indebtedness.
Andrews, 99 -534
April 1, 1999
Page 3
Pursuant to Section 1103(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, any member of his immediate family, or
a business with which he or a member of his immediate family is associated.
Section 1 103(f) of the Ethics Act provides as follows:
Section 1103. Restricted activities.
(f) Contract. - -No public official or public employee or
his spouse or child or any business in which the person or
his spouse or child is associated shall enter into any
contract valued at $500 or more with the governmental
body with which the public official or public employee is
associated or any subcontract valued at $500 or more with
any person who has been awarded a contract with the
governmental body with which the public official or public
employee is associated, unless the contract has been
awarded through an open and public process, including prior
public notice and subsequent public disclosure of all
proposals, considered and contracts awarded. In such a
case, the public official or public employee shall not have
any supervisory or overall responsibility for the
implementation or administration of the contract. Any
contract or subcontract made in violation of this subsection
shall be voidable by a court of competent jurisdiction if the
suit is commenced within 90 days of the making of the
contract or subcontract.
65 Pa.C.S. §1103(f).
Section 1 103(f) does not operate to make contracting with the governmental
body permissible where it is otherwise prohibited. Rather, where a public official /public
employee, his spouse or child, or a business with which he, his spouse or child is
associated, is otherwise appropriately contracting with the governmental body, or
subcontracting with any person who has been awarded a contract with the
governmental body, in an amount of $500.00 or more, Section 1103(f) requires that
an "open and public process" be observed as to the contract with the governmental
body. Pursuant to Section 1103(f), an "open and public process" includes:
(1) prior public notice of the employment or contracting possibility;
(2) sufficient time for a reasonable and prudent competitor /applicant to be
able to prepare and present an application or proposal;
(3) public disclosure of all applications or proposals considered; and
(4) public disclosure of the contract awarded and offered and accepted.
Section 1103(f) of the Ethics Act also requires that the public official /employee
may not have any supervisory or overall responsibility as to the implementation or
administration of the contract with the governmental body.
Section 1 103(j) of the Ethics Act provides as follows:
Andrews, 99 -534
April 1, 1999
Page 4
Section 1103. Restricted activities.
(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(j).
In each instance of a conflict, Section 1103(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 Act, then voting is permissible provided
the disclosure requirements noted above are followed. See, Mlakar, Advice 91- 523 -S.
As to the questions posed, one of the necessary elements for a conflict is a
private pecuniary benefit. In this case, you have stated that the school director, who
owns a communications company, is willing to allow the school district to submit its
newsletter or pre - printed pieces for inclusion in the community magazine at no cost.
This would extend to other non -board related events or information of an educational
nature which would also be included at no cost.
Since you have represented factually that the school director would provide the
service for the school district at no cost, there would be no pecuniary benefit to the
school director or her business and hence, no conflict under Section 1 103(a).
Similarly, as to Section 1 103(f), based upon the factual representation that the
services by the school director and her company are at no cost, there would be no
contact and hence, Section 1103(f) would not be applicable.
Andrews, 99 -534
April 1, 1999
Page 5
The propriety of the proposed conduct has only been addressed under the Ethics
Act; the applicability of any other statute, code, ordinance, regulation or other code
of conduct other than the Ethics Act has not been considered in that they do not
involve an interpretation of the Ethics Act. Specifically not addressed herein is the
applicability of the Public School Code.
Conclusion: A School Board Member is a public official subject to the provisions
of the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. §1101 et
s g. Sections 1 103(a) and (f) of the Ethics Act would not prohibit a school director
or her company from publishing school board or non - school board educational related
matters in that there would be no conflict or contract based upon the factual
representation that such activity would be done at no cost. Lastly, the propriety of the
proposed conduct has only been addressed under the Ethics Act.
Pursuant to Section 1107(11), an 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, provided 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.
ncent . ' opko
Chief Counsel