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HomeMy WebLinkAbout821 DixonIn re: Thomas Dixon I. ALLEGATION: STATE ETHICS COMMISSION 308 FINANCE BUILDING HARRISBURG, PENNSYLVANIA 17120 : File Docket: . Date Decided: : Date Mailed: 88 -112 -C December 4,1991 December 11,1991 Chair Before: Dennis C. Harrington, James M. Howley Daneen E. Reese Roy W. Wilt Austin M. Lee James P. Gallagher Allan M. Kluger The State Ethics Commission received a complaint regarding a possible violation of the State Ethics Act, No. 170 -of 1978, P.L. 883. Written notice, of the specific allegation(s) was served at the commencement of the investigation. A Findings Report was issued and served, upon completion of the investigation, which constituted the Complaint by the Investigation Division. An Answer was filed and a hearing was waived. A Consent Order was submitted by the parties to the Commission for consideration which was subsequently approved. This adjudication of the Commission is hereby issued which sets forth the individual Allegations, Findings of Fact, Discussion, Conclusions of Law and Order. This adjudication is final and will be made available as a public document fifteen days after issuance. However, reconsideration may be requested which will defer public release of this adjudication pending action on the request by the Commission. A request for reconsideration, however, does not affect the finality of this adjudication. A reconsideration request must be received at this Commission within fifteen days of issuance and must include a detailed explanation of the reasons as to why reconsideration should be granted in conformity with 51 Pa. Code $2.38. The files in this case will remain confidential in accordance with Section 8(a) of Act 170 of 1978 during the fifteen day period and no one unless the right to challenge this Order is waived, may violate confidentiality by releasing, discussing or circulating this Order. However, confidentiality does not preclude discussing this case with an attorney at law. Any person who violates confidentiality of the Ethics Act is guilty of a misdemeanor subject to a fine of not more than $1,000 or imprisonment for not more than one year, 65 P.S. 409(e). Dixon, 88 -I12 -C Page 2 That you, Mayor of Wallaceton Borough, Clearfield County, violated the following provisions of the State Ethics Act when you contracted with the borough to construct an addition to the borough municipal building without an open and public process: Section 3. Restricted Activities. (a) No public official or public employee shall use his public office or any confidential information received through his holding public office to obtain financial gain other than compensation provided by law for himself, a member of his immediate family, or a business with which he is associated. 65 P.S. S403(a). Section 3(c) of the Ethics Act provides: (c) No public official or public employee or a member of his immediate-family or any business in which the person or a member of the person's immediate family is a director, officer, owner or holder of stock exceeding 5% of the equity at fair market value of the business shall enter into any contract valued at $500 or more with a governmental body 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. Any contract made in violation of this subsection shall be voidable by a court of competent jurisdiction if the suit is commenced within 90 days of making of the contract. 65 P.S. S403(c). II. FINDINGS: 1. Thomas Dixon serves as the Mayor of Wallaceton Borough. a. He has served in this position since 1966. 2. Thomas Dixon is the owner of the Joseph Dixon Contracting Company, Wallaceton. a. He has operated this entity since 1967. b. Said company was previously owned and operated by Thomas Dixon's father, Joseph Dixon. 3. Thomas Dixon also serves as the President of the Clearfield County Grange Mutual Fire Insurance Company. Dixon, 88 -112 -C Page 3 a. Thomas Dixon took over this insurance business from his father, Joseph Dixon, in 1966. b. Thomas Dixon receives a commission on all insurance he places. c. The Commission equals 15% premium, and Thomas Dixon check from the Clearfield Fire Insurance Company on a. That structure was a fire hall. a. Qecember 3, 1979: of the insurance receives his commission County Grange Mutual a quarterly basis. 4. Wallaceton Borough is served by a local fire department. a. The fire department is an entity separate and distinct from the borough. b. The borough does offer support to the fire department. 5. The borough acquired a parcel of property in 1963 and shortly thereafter the Wallaceton Fire Department built a structure on that property. b. The borough retained ownership of the property at that time. 6. Subsequent to the time when Wallaceton Borough acquired the property and the structure was constructed, the borough and the fire department began to consider renovating that facility. 7. In order to initiate the renovation of the fire department building, it was necessary for the borough to transfer ownership of the property to the department and to assist in obtaining financing for the project. 8. Minutes of the Wallaceton Area Borough Council indicate the following action was taken by council relative to renovating the fire hall, transferring the land and securing the financing: "Wallaceton Area Fire Company had a request for council to borrow $30,000.00 to complete the fire hall and Community Office Building. Richard Shuy made a motion to borrow the money but after some debate, it was decided to have the lawyer look Dixon, 88 -112 -C Page 4 into it . . . it was tabled until the next meeting when council would take action on it." b. Aril 7, 1980 "On the advice of the lawyer, council decided to call a special meeting concerning borrowing the money for the firemen to finish the addition." Present: Council - Nancy Hull, Harold Williams, Roger Shimmel and Richard Shuy; Mayor, Thomas Dixon c. April 14, 1980: "Council discussed the possible transfer of land originally transferred to the borough from Harbison - Walker Refractories to the fire company. The land transfer by Harbison - Walker was with the understanding the land would be restricted to public use only. Council said Harbison - Walker agreed that use by the fire company would conform to this restriction. The fire company wants to expand it's building." Present: Not listed. d. Mav 5, 1980: "There was some discussion about putting a borough office and water authority office in the fire hall, if they get the money to finish the building." "Roger Shimmel made a motion to have the deed transferred from the borough to the fire company. Richard Shuy seconded the motion; no vote was taken. Roger Shimmel told the secretary to call Lawyer Caifly to tell him to begin working on the deed." Present: Not listed. e. June 2, 1980: "Discussion took place on the deed being turned over to the fire company. Harold Williams made a motion, seconded by Roger Shimmel, that as of June 2, 1980, the deed be turned over to the fire department. Motion carried." Dixon, 88 -112 -C Page 5 f. August 4, 1980: "Roger Shimmel explained the agreement the fire company wants to have with council concerning the borrowing of money. Lawyer Caifly explained if the fireman would at any time not be able to make a payment, council would be responsible for that payment. He suggested borrowing enough money to put a roof on. Council should have a special meeting with the fireman to work this out. A special meeting has been advertised for August 13, 1980, Wallaceton Fire Hall at 7:30 pm." Present: Council - Nancy Hull, Roger Shimmel, Richard Shuy and Harold Williams; Mayor, Thomas Dixon g. "An amendment to the motion made by Harold Williams that the deed not be turned over to the fire department. Nancy Hull seconded it. No vote recorded." Present: Not listed. August 13, 1980: Special Meeting - "Lawyer Caifly suggested taking out a smaller loan to get the building under cover before the cold weather sets in. Roger Shimmel gave a report on what they would need the loan for and the amount of money the materials would cost. Harold Williams said to borrow $10,000.00. Roger Shimmel made a motion to borrow $11,000.00, using $10,000.00 for building supplies and keep a $1,000.00 on hand if they need it. Phillip Dixon seconded it, passed and carried." "The fire company is going to make a committee of four to take charge of this account, the duty of which is to sign checks." Present: Not listed. h. April 1981: Special Meeting - "A special meeting was called with the firemen to see if they could work out something concerning the loan. There was discussion on raising money." Dixon, 88 -112 -C • Page 6 Present: Phillip Dixon, Nancy Hull, Harold Williams and Mary Lou English i. June 6, 1983: "There was a discussion on having a building erected for council meetings and to store the files in. There will be a special meeting next Monday, June 13, 1983, at 7:30." j Present: Not listed. June 15, 1983: Special Meeting - "A special meeting was held concerning the erection of a building to house borough materials and to have the monthly meetings in. It was practically decided to put it in back of the fire hall." Present: Not listed. k. June 15, 1983: "Discussion occurred on the location of the perspective borough building, representative from North Central Planning will gladly meet with council to discuss the financial end of the building. A meeting will be held on July 20, 1983, 7:00 pm. Present: Not listed. 1. August 8, 1983: "A representative was present from North Central Planning concerning the loan for the new municipal building. There will be a special meeting August 15, to discuss the size of the building and its cost." Present: Not listed. M. August 15, 1983: "Representatives were present from the fire company, water authority and council to discuss the building. No definite plans were made. There will be another special meeting concerning the building on September 20, 1983." Dixon, 88 -112 -C Page 7 Present: Not listed. n. September 20. 1983 "In order to find out the exact amount of payments, Clearfield Bank & Trust requires that a set of plans for the building be drawn up." "Payments on a loan of $30,000.00 would be $276.04 per month for ten years through the Department of Community Affairs. In order to find out the exact amount of payments from Clearfield Bank & Trust Company for $40,000.00, we must have a set of plans for the building." P. q. Present: Not listed. o. October 19, 1983: Special Meeting - "A motion was made by Dottie Miller to lease the property to the fireman for 99 years. Harold Williams seconded it." No vote recorded. Present: Not listed. November 7, 1983: "Nick Fusco is working on plans for the addition on the fire hall." Present: Not listed. (1). The floor plans that are reflected in the minutes as being considered are for the existing building as it now stands. December 5, 1983: "President Phillip Dixon informed Council that the application for the loan has been sent in." Present: Not listed. r. January 1, 1984: "The addition for the fire hall was discussed. Nick Fusco is working on the floor plans. It was agreed upon to ask Larry Diehl to draw up plans for the labor and materials." Dixon, 88 -112 -C Page 8 Present: Not listed. s. February 6. 1984: "Phillip Dixon cannot get in contact with Gwen Almond; she is to call him concerning the loan and office plans for the addition." "A contract was to be made between the Water Authority and council concerning the monthly payment for the addition of the building." Present: Not listed. t. March 5, 1984: "The secretary is to advertise it in The Progress that the fire company is involved in the new addition to the fire hall. Council is not involved. Council is going to rent a space from the fire company after the building is done." "Phil Dixon is to call Denning Gearhart and have him add to the lease a binding statement concerning all three parties (Council, Fireman and Water Authority) concerning the monthly payments for the new addition." Present: Not listed. u.- June 4, 1984: "There will be a special meeting June 18, 1984 concerning the addition to the fire hall. Several things will have to be discussed before the application can be sent in. Tom Dixon is to come up with some prices for building supplies." "The 99 year lease cannot be found by (the) secretary." Present: Not listed. v. September 10. 1984: "More information was needed by Gwen Almond for our loan. Phillip Dixon is trying to get this information gathered up. Bill Siother called Dixon, 88- .112 -C Page 10 After five years: Wallaceton Borough - $120.00 Wallaceton Municipal Authority - $48.00 Wallaceton Fire Company - $62.00 It was noted that the borough will not pay the firemen for the first five years because of the loan. We will negotiate on the terms for the following five years." Present: Not listed. aa. February 4, 1984,: "Phil made a motion to give the fire company a donation of $10,000.00 for the new building. All in favor." "Regarding the Title Search for the new building, Denning Gearhart is to do the Title Search and the borough will receive the bill. It will cost $600.00." Present: Not listed. bb. August 5, 1985: "Ardell Hamer of the Wallaceton Water Authority was present to discuss the office space in the new building. Dottie Miller made a motion to leave the office space as it was shown on the original plans. Motion was seconded by Phillip Quick." Present: Council - Phillip Dixon, Mary Lou English, Phillip Quick, Dorothy Miller and Harold Williams; Mayor - Thomas Dixon cc. August 12, 1985: "Water Authority members were upset and wanted to know why they couldn't have their own office space. A discussion took place about the office space in the new building. It was agreed upon that if a problem should arise in the future, a suitable solution should be found. Present: Not listed. Dixon, 88 -112 -C Page 9 about the bank loan; he stated that it must be advertised a number of times." "Discussion on what to do about the money was tabled until next month." Present: Not listed. w. October 1, 1984: "Phillip Dixon received a letter from Denning Gearhart stating that he has run into some problems (with) the procedures according to the Department of Community Affairs concerning our loan. Mr. Gearhart's associate will be contacting Phil for more information next week. Tom Dixon is working on an estimate of materials for the addition." x. November 5, 1984: "Phillip Dixon read a letter from Denning Gearhart concerning the resolution on the addition to the fire hall. He then took a raised hand vote of council members concerning borrowing the money now. There were six yes's and zero no's. Motion passed and carried. Present: Not listed. Present: Not listed. December 3, 1984: "Loan papers for the new addition were signed by President Phillip Dixon and Secretary Lovie Havens." Present: Not listed. z. January 14. 1985: Special Meeting - "The following are approximate percentages for the first five years of the loan: Wallaceton Borough - 72 %, $24.00 Wallaceton Municipal Authority - 21 %, $100.00 Wallaceton Fire Company - 27 %, $130.27 Dixon, 88 -112 -C Page 12 hh. May 6, 1985: "Attorney Gearhart discussed the borrowing base for the loan. A loan addendum and agreement was then signed. Council also discussed going to the bank to sign for part of the loan. There was a problem with borrowing the entire $10,000.00 because of the DCA approval. Therefore, the bank decided to release $6,000.00 of the $10,000.00 until it was cleared by DCA." Present: Council - Phillip Dixon, Mary Lou English, Dorothy Miller, Phillip Quick and Harold Williams; Mayor - Thomas Dixon ii. January 6, 1986: "Council discussed the new building. It was decided to write a letter to Mr. Jae Chung stating that borough council feels the building is completed and suitable for occupancy." Present: Council - Phillip Dixon, Mary Lou English and Dorothy Miller; Mayor - Thomas Dixon jj. February 1_. 1986: "Council discussed the new building. The secretary is to write a letter to the Wallaceton Fire Company regarding the money. Also discussed was a door being put into the fire hall." Present: Council - Phillip Dixon, Dorothy Miller,' Mary Lou English and Bonnie Hansell; Mayor - Thomas Dixon kk. Undated - Special Meeting: This meeting occurred between March 3, 1986 and April 7, 1986. "This meeting was called to discuss the office space which was to be rented by the water authority. Council also discussed the cost of putting up a partition in the new office space." Present: Council - Mary Lou English, Phillip Dixon, Phillip Quick and Bonnie Hansell; Mayor - Thomas Dixon Dixon, 88 -112 -C Page 11 dd. October 7, 1985: "Members of the Wallaceton Fire Company were present to discuss the building. It was decided to have a meeting at the fire hall on October 8, 1985 to discuss the situation." Present: Council - Harold Williams, Dorothy Miller, Mary Lou English and Phillip Quick; Mayor - Thomas Dixon ee. October 8, 1985: "$4,000.00 from the bank will be discussed at the next council meeting." Present: Council - Harold Williams, Mary Lou English, Dorothy Miller and Phillip Quick; Mayor - Thomas Dixon ff. November 4, 1985: gg• "Harold Williams made a motion to turn the $4,000.00 over to the fire company. Phillip Quick seconded the motion. Present: Council - Phillip Dixon, Phillip Quick, Harold Williams and Mary Lou English; Mayor: Thomas Dixon April 23, 1985: "Borough Council members and Municipal Authority members attended the regular Wallaceton Fire Company meeting to discuss the Addendum and Agreement for the new building. The addendum was read aloud and all three parties discussed it. It was agreed that the percentages would be as follows: Wallaceton Borough - 52% Wallaceton Fire Company - 27% Wallaceton Municipal Authority - 21% The addendum was signed by all parties." Present: Council - Phil Dixon, Mary Lou English, Phillip Quick and Harold Williams; Mayor - Thomas Dixon Dixon, 88 -112 -C Page 13 11. March 3, 19(6: "Thomas Dixon submitted a check to the borough in the amount of $5,000.00 for a refund of excessive estimates. The money will go into the General Fund." Present: Council - Phillip Quick, Phillip Dixon, Mary Lou English, Dorothy Miller and Bonnie Mansell; Mayor - Thomas Dixon mm. April 7, 1986: "Wallaceton Fire Company gave a check to the borough in the amount of $2,000.00 for excessive estimates. This check will go into the General Fund." "Wallaceton Fire Company, Wallaceton Municipal Authority and attorneys Gearhart, Ireland and Morgan were present to discuss the office space in the building. The addendum and agreement were looked over by both parties; several members of each party looked at the new building addition. Wallaceton Water Authority made an offer to give $250.00 for materials towards a partition in the new office. A motion was made that the borough council accept the Water Authorities offer of $250.00 for building a partition." Present: Council Phillip Dixon, Bonnie Hansen, Mary Lou English and Phillip Quick; Mayor - Thomas Dixon nn. June 2, 1986: "Council discussed the agreement between the Water Authority and the fire department regarding a new partition." Present: Council - Phillip Dixon, Phillip Quick, Mary Lou English, Dorothy Miller and Bonnie Mansell; Mayor - Thomas Dixon oo. August 4. 1986: "Mary Lou English asked if the borough would share half of the payment for the building which is supposed to be shared between the fire company and the water authority. The secretary is to call the solicitor regarding this matter." Dixon, 88 -112 -C Page 14 Present: Council - Phillip Dixon, Phillip Quick, Mary Lou English, Dottie Miller and Bonnie Hansell; Mayor - Thomas Dixon pp. September 8. 1986: "Council discussed the agreement which Attorney Denning Gearhart was supposed to have done regarding the new partition. Council would like a letter sent to Denning Gearhart requesting he take immediate action on this matter." Present: Council - Phillip Dixon, Mary Lou English, Bonnie Hansell and Dorothy Miller; Mayor - Thomas Dixon 9. The borough did not solicit or otherwise publicly seek bids to conduct the construction project. a. Section 1402(a) of the Borough Code states in part that all contracts in excess of $4,000.00 should be awarded to the lowest responsible bidder after public notice in at least one local paper on at least three occasions. b. Section 1404 of the Borough Code states in part that no borough official either elected or appointed shall be interested to any appreciable degree either directly or indirectly in any purchase made or contact entered into involving a borough expenditure of more than $1,000.00 in any calendar year. In a case of councilman or mayor, he shall so inform council and shall refrain from voting on the expenditure. 10. Thomas Dixon submitted estimates for renovations of the Wallaceton Area Fire Company's building on July 2, 1984 and September 4, 1984. a. Estimate Date - July 2, 1984: Materials and Labor - $31,513.00 Plumbing /Electrical - 6,000.00 Interior Finishing - 12 Total $50,000.00 b. Estimate Date - September 4, 1984: Dixon, 88 -112 -C Page 15 Same dimensions and specifications as the bid listed in Finding 10(a): Bid Price - $35,000.00 No other bids were sought or received for this project. 11. Wallaceton Borough's share of the construction project totaled $10,000.00. 12. Financial records of Wallaceton Borough indicate that a $10,000.00 loan was taken out from the Clearfield County Bank & Trust Company, 11 North Second Street, Clearfield, PA 16830. a. $10,000.00 was deposited into Clearfield County Bank & Trust Company, Account No. 130 - 62006. Account No. 130 -62006 is Wallaceton Borough's checking account. Deposits were made as follows: 1) May 14, 1985 - $6,000.00 2) October 1, 1985 - $4,000.00 13. The fire department was to provide the remaining $25,000.00 cost of the project. a. The department obtained a loan from the Pennsylvania Emergency Management Agency, Volunteer Loan Assistance Program. b. The loan was obtained on 2/8/85. c. Conditions of the note are $25,000.00 at a 2% interest rate for ten years. Monthly payments are listed at $230.04. 14. Joseph Dixon Contracting performed the construction of the addition to the fire hall. a. Thomas Dixon became involved in the transaction because of the prior default of an individual and acted to negate the harm which would incur to Wallaceton Borough. b. The work was performed pursuant to customary practices and Dixon was aware of the availability of audit and other checks and balances for any improprieties. Dixon, 88 -112 -C Page 16 15. Wallaceton Borough Financial records indicate the following disbursements were made to Joseph Dixon Contracting: a. Check No. 1363 from Clearfield Bank & Trust Company, Account No. 130 - 62006, dated 4/14/85, for $6,000.00. b. Check No. 103 from the Pennsylvania Local Government Investment Trust Fund, Morris Drive, Box 1472, Valley Forge, PA 19482, Account No. 152403 -5, dated 5/13/85, for $2,000.00. c. Check No. 105 from the Pennsylvania Local Government Investment Trust Fund, dated 8/15/85, for $5,000.00. 16. The total disbursements to Thomas Dixon from the borough amounted to $13,000.00. 17. Records of Thomas Dixon and the Wallaceton Borough confirm the following refunds were made by Dixon to the borough: 6/11/85 - $8,000.00 3/3/86 - $5,000.00 Total refund made by Dixon to Wallaceton Borough was $13,000.00. This left a zero balance on the funds that were exchanged between Dixon and Wallaceton Borough. 18. Records of the Wallaceton Area Volunteer Fire Department indicates they received money from Wallaceton Borough as follows: 6/11/85 - $8,000.00 11/26/85 - 4,000.00 Total Received - $12,000.00 19. The fire department refunded the borough $2,000.00 on 3/11/86, leaving the total amount received from the borough at $10,000.00. 20. Wallaceton Ambulance or Fire Department records indicate the following disbursements were made to Thomas Dixon: 4/1/85 - $7,500.00 5/28/85 - $8,750.00 Dixon, 88 -112 -C Page 17 6/11/85 - $8,000.00 2/25/86 - $10,750.00 Total Payments to Dixon - $35,000.00 21. Monies were being transferred between Wallaceton Borough, Thomas Dixon and the Wallaceton Area Fire Department to cover Dixon's expenses until loan monies were received by the fire department. 22. Statements of Financial Interests on file with Wallaceton Borough Secretary include the following filings for Thomas Dixon: a. Calendar Year: 1986 Filed: 2/3/86 on SEC Form 7/84 Position: Mayor Occupation: Contractor Real Estate Interests: None Creditors: None Direct /Indirect Income: Clearfield County Grange Insurance, Joseph Dixon Contracting Office /Directorship in Any Business: Clearfield County Grange Mutual Insurance, President and Director Financial Interest in Any Business: None b. Calendar Year: Not Listed Filed: 2/2/87 on SEC Form 1/86 Position: Mayor Occupation: Contractor Real Estate Interests: None Creditors: None Direct /Indirect Sources of Income: Joseph H. Dixon Contracting Dixon, 88 -112 -C • Page 18 Office /Directorship in Any Business: Clearfield County Grange Mutual Fire Insurance Financial Interest in Any Business: None c. Calendar Year: Not Listed Filed: 10/3/88 on SEC Form 1/88 Position: Mayor Occupation: Contractor Real Estate Interests: None Creditors: None Direct /Indirect Sources of Income: Joseph H. Dixon Contracting Company Office /Directorship in Any Business: Clearfield County Grange Mutual Fire Insurance Financial Interests in Any Business: None d. Calendar Year: Not Listed Filed: 4/3/89 on SEC Form 1/89 Position: Mayor Occupation: Contractor Real Estate Interests: None Creditors: None Direct /Indirect Income: Joseph Dixon Contracting, Clearfield County, Grange Mutual Fire Insurance Office /Directorship in Any Business: Clearfield County, Grange Mutual Fire Insurance, Director Financial Interests in Any Business: None e. Calendar Year: 1990 Dixon, 88 -112 -C Page 19 Filed: 2/5/90 on SEC Form 1/90 Position: Mayor Occupation: Contractor Real Estate Interests: None Creditors: None Direct /Indirect Income: None Office /Directorship in Any Business: Clearfield County Grange Fire Insurance, President and Director Financial Interests in Any Business: None f. Calendar Year: 1991 Filed: 2/4/91 on SEC Form 1/91 Position: Mayor Occupation: Contractor Real Estate Interests: None Creditors: None Direct /Indirect Income: Dixon Contracting Office /Directorship in Any Business: Clearfield County Grange Mutual Fire Insurance, President, Director, Agent Financial Interest in Any Business: Dixon Contracting 23. The following information was not included on Statements of Financial Interests listed in Findings No. 22 (a, b, c, d and e). a. Calendar Year 1986 (See Findings 22(a)] Item #17: Financial Interest in Any Business - Joseph Dixon Contracting Company b. Calendar Year Not Listed [See Findings 22(b)] Dixon, 88 -112 -C • Page 20 III. DISCUSSION: Item #11: Direct /Indirect Sources of Income - Clearfield County Grange Fire Insurance Item #15: Financial Interest in Any Business - Joseph Dixon Contracting Company c. Calendar Year Not Listed [See Findings 22(c)] Item #11: Direct /Indirect Sources of Income - Clearfield County Grange Fire Insurance Item #15: Financial Interest in Any Business - Joseph Dixon Contracting Company d. Calendar Year Not Listed [See Findings 22(b)] Item #15: Financial Interest in Any Business - Joseph Dixon Contracting Company e. Calendar Year 1989 [See Findings 22(e)] Item #11: Direct /Indirect Source of Income - Joseph Dixon Contracting Company, Clearfield County Grange Mutual Fire Insurance Item #15: Financial Interest in Any Business - Joseph Dixon Contracting Company f. Calendar Year 1990 [See Finding 22(f)] Item #11: Direct /Indirect Sources of Income - Clearfield County Grange Fire Insurance As the Mayor of Wallaceton Borough, Thomas Dixon, hereinafter Dixon, is a public official as that term is defined in the Ethics Act, 65 P.S. 402; 51 Pa. Code 1.1. As such, his conduct is subject to the provisions of the Ethics Act and the restrictions therein are applicable to him. Initially, it is noted that Section 9 of Act 9 of June 26, 1989, P.L. 26, provides, in part, as follows: "This amendatory act shall not apply to violations committed prior to the effective date of this act, and causes of action initiated for such violations shall be governed by the prior law, which is continued in effect for that purpose as if this act were not in force. For the purposes of this section, a violation was Dixon, 88 -112 -C Page 21 committed prior to the effective date of this act if any elements of the violation occurred prior thereto." Since the occurrences in this case transpired prior to the effective date of Act 9 (June 26, 1989), we must apply the provisions of Act 170 of 1978, P.L. 883, to determine whether the Ethics Act was violated. Under Section 3(a), quoted above, this Commission has determined that use of office by a public official to obtain a financial gain for himself or a member of his immediate family or a business with which he is associated which is not provided for in law transgresses the above provision of law. Thus, use of office by a public official to obtain a financial gain which is not authorized as part of his compensation is prohibited by Section 3(a): Hoak /McCutcheon v. State, $thics Commission, 77 Pa. Commw. Ct. 529, 466 A.2d 283 (1983); Yacobet v. State Ethics Commission, 109 Pa. Commw. Ct. 432 531 A.2d 536 (1987). Similarly, Section 3(a) of the Ethics Act would prohibit a public official /employee from using public office to advance his own interests; Koslow v. State Ethics Commission, 116 Pa. Commw. Ct. 19, 540 A.2d 1374 (1988). Likewise, a public official /employee may not use the status or position of public office for his own personal advantage; Huff, Opinion 84 -015. As to Section 3(c) quoted above, this provision of Act 170 of 1978 specifically provides in part that a public official /employee, member of his immediate family or business with which he or a member of his immediate family is a director, officer, owner or holder of stock exceeding five percent of the equity of the business, may not contract with his governmental body in the amount of $500.00 or more, unless the contract has been awarded through an open and public process. The issue before us is whether Dixon violated either Section 3(a) 'or 3(c) of Act 170 of 1978 quoted above regarding the construction of an addition to the Borough Municipal Building. Dixon has served as the Mayor of Wallaceton Borough since 1966. In a private capacity, he is the owner of Joseph Dixon Contracting Company as well as the president of the Clearfield County Grange Municipal Fire Insurance Company. In the Borough of Wallaceton, the fire department, which is a separate entity from the borough, built its fire hall on borough property. When renovations were being considered for the fire department building, it was realized that it was necessary for the borough to transfer ownership to the fire department and to assist in obtaining financing. The following activity is reflected in the Wallaceton Borough Council minutes as to the fire department renovation project: on December 3, 1979, a request was made and subsequently tabled to borrow $30,000.00 to complete the fire hall and community office buildings; Dixon, 88 -112 -C Page 22 on April 7, 1980, a decision was made to call a special meeting concerning borrowing money to finish the addition; on April 14, 1980, discussions occurred regarding the possible transfer of land from the borough to the fire company; on May 5, 1980, discussions took place about utilizing part of the fire hall for borough and water authority offices followed by a motion to have the property transferred from the borough to the fire company on which no vote was taken; on June 2, 1980, discussions and a successful motion to deed the property to the fire company, which motion carried and was followed by an amendment to rescind the motion; on August 4, 1980, discussions that a special meeting should occur with the firemen to work out the borrowing of money; on August 13, 1980, a motion was carried, seconded by Phillip Dixon, to borrow $11,000.00 to get the fire building under cover before the cold weather set in; in April 1981, a special meeting occurred regarding loan and raising money; on June 6, 1983, discussions occurred involving utilization of the building for council meetings and storage of files; on June 15, 1983, a special meeting occurred concerning the construction of the building to house borough materials'and to hold borough monthly meetings; on June 15, 1983, discussions occurred regarding the location of the prospective borough building; on August 8, 1983, there was a notation for a special meeting to discuss the size and cost of the building; on August 15, 1983, discussions occurred but no definite plans were made other than to hold another special meeting; on September 20, 1983, discussions occurred regarding the drawing of plans so that the exact amount of loan payments could be made to the bank; on October 19, 1983, no vote was taken on a motion for a 99 year lease of the property to the fire department; on November 7, 1983, a notation indicated that plans are being prepared; on December 5, 1983, Phillip Dixon advised council that the loan application had been sent in; on January 1, 1984, the fire hall additions were discussed as well as requirements for labor and materials; on February 6, 1984, a notation reflects that Phillip Dixon was unable to contact an individual ' concerning the loan and plans for the addition; on March 5, 1984, a notation reflects advertising as to the new addition to the fire hall as well as Phillip Dixon calling an individual concerning binding provision in the lease between council, the firemen and the water authority; on June 4, 1984, an entry for a special meeting as to the fire hall as well as Dixon coming up with prices for building supplies; on September 10, 1984, a notation that Phillip Dixon and another individual were attempting to get information regarding the loan; on October 1, 1984, Phillip Dixon recounted receiving a letter from Gearhart concerning problems regarding DCA procedures for their loan; on November 5, 1984, following the reading of the letter from Gearhart by Phillip Dixon, there was a hand vote by council to borrow the money which passed unanimously; on December 3, 1984, the loan papers were signed by Phillip Dixon and secretary Lovie Havens; on January 14, 1985, a special meeting occurred regarding loan percentages; on February 4, 1985, Phillip Dixon made a successful motion to give the fire company a donation of $10,000.00; on August 5, 1985, discussions occurred regarding office space in the new building; Dixon, 88 -112 -C Page 23 on August 12, 1985, further discussion regarding water authority members' office space in the new building; on October 7, 1985, members of the fire company discussed the building; on October 8, 1985, a notation appeared for a future discussion of $4,000.00 from the bank regarding the project; on November 4, 1985, a motion was made and seconded to turn $4,000.00 over to the fire company; on April 23, 1985, council and authority members attended the fire company meeting to discuss the new building; on May 6, 1985, discussions occurred regarding the borrowing base for the loan as well as a potential problem for borrowing the entire sum of $10,000.00 from the bank; on January 6, 1986, council decided to write a letter to the effect that the building was completed and ready for occupancy; on February 3, 1986, discussions occurred by council concerning the new building and the writing of a letter to the fire company regarding monetary matters; in an undated special meeting in March or April on 1986, discussions ensued concerning the rental of office space by the water authority; on March 3, 1986, Dixon submitted a check to the borough in the amount of $5,000.00 for a refund of excessive estimates; on April 7, 1986, the fire company gave the borough a check in the amount of $2,000.00 for excessive estimates; on June 2, 1986, council discussed an agreement between the water authority and fire department concerning a new partition; on August 4, 1986, a council member inquired as to whether the borough would pay half of the payment for the building which is to be shared between the fire company and the water authority, and finally, on September 8, 1986, council discussed an agreement regarding the new partition. The borough did not solicit or otherwise publicly bid for the construction project and Dixon did submit an estimate for the renovations on July 2, 1984 in the amount of $50,000.00 which he subsequently re -bid in the amount of $35,000.00 on September 4, 1984. The borough's share of the construction project amounted to $10,000.00 which was borrowed from the Clearfield County Bank and Trust Company. The fire department was to provide the remaining $25,000.00 for the project. The work was performed by Dixon's'company, Joseph Dixon Contracting. Dixon received payments in the amount of $35,000.00 from either the Wallaceton Ambulance or Fire Department. Finally, we note that Dixon in filing his Statements of Financial Interests (FIS) had various deficiencies such as not listing the particular calendar year on the form, failing to list his financial interest in any business or direct or indirect sources of income as noted in Fact Finding 23. In applying the provisions of Section 3(a) of Act 170 of 1978 quoted above to the instant matter, we find no violation as to this particular section in that there is no evidence of any use of office on the part of Dixon. In particular, the actions that were taken concerning the fire department renovations were taken by the borough council and not by Dixon who is the Borough Mayor. Thus, without the requisite use of office, we find no violation as to Section 3(a) of Dixon, 88 -112 -C Page 24 Act 170 of 1978. However, as to Section 3(c) of the Ethics Act, we find a technical violation in that the contract was over $500.00 and was not put out for bids or awarded through an open and public process. Given the totality of the facts and circumstances in this case, we will take no further action. As to the FIS deficiencies, Dixon is directed within thirty (30) days of issuance of this Order to file amended Statements of Financial Interests correcting the deficiencies noted in Fact Finding 23. Failure to comply with the above with result in the referral of this matter for an FIS enforcement action. IV. CONCLUSIONS 1. Thomas public 1978. OF LAW: Dixon, as the Mayor of Wallaceton Borough, is a official subject to the provisions of Act 170 of 2. Dixon did not violate Section 3(a) of Act 170 of 1978 regarding the construction of an addition to the Borough Municipal Building in that there was no use of office on the part of Dixon. 3. A technical violation of Section 3(c) of Act 170 of 1978 occurred when a business with which Dixon was associated obtained a contract in excess of $500.00 to construct an addition to the borough municipal building which was not done through an open and public process. In re: Thomas Dixon : File Docket: 88 -112 -C : Date Decided: December 4.199, : Date Mailed: Dgcember 11.1991, ORDER No. 821 1. Thomas Dixon, as the Wallaceton Borough Mayor, did not violate Section 3(a) of Act 170 of 1978 regarding the construction of an addition to the Borough Municipal Building in that there was no use of office on the part of Dixon. 2. A technical violation of Section 3(c) of Act 170 of 1978 occurred when a business with which Dixon was associated obtained a contract in excess of $500.00 to construct an addition to the borough municipal building which was not done through an open and public process. 3. Dixon is directed within thirty (30) days of issuance of this Order to file amended Statements of Financial Interests (FIS) correcting the deficiencies noted in Fact Finding 23. 4. Failure of Dixon to comply with paragraph 3 will result in the referral of this matter for an FIS enforcement action. BY THE COMMISSION, e HARRINGTO CHAT DENNIS C. , R