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HomeMy WebLinkAbout906 TaylorSTATE ETHICS COMMISSION 308 FINANCE BUILDING HARRISBURG, PENNSYLVANIA 17120 In Re: Frank J. Taylor File Docket: 93- 013 -C2 Date Decided: December 7, 1993 Date Mailed: December 10, 1993 Before: James M. Howley, Chair Daneen E. Reese, Vice Chair Dennis C. Harrington Roy W. Wilt Austin M. Lee Allan M. Kluger Joseph W. Marshall, III The State Ethics Commission received a complaint regarding a possible violation of the State Ethics Act, Act 9 of 1989, 65 P.S. §401 et sea. 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 not filed and a hearing was waived. A consent agreement 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 §21.29(b). The files in this case will remain confidential in accordance with Act 9 of 1989, 65 P.S. §408(h) 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). Taylor, 93- 013 -C2 Page 2 I. ALLEGATION: That Frank Taylor, as a public official /public employee, in his position as Chief of Police of Emmaus Borough, Lehigh County, violated the following provisions of the State Ethics Act (Act 9 of 1989), when Emmaus Borough contracted with Rob's Gun and Ammo, a business owned by his brother, Robert Taylor, to supply weapons and ammunition to the Borough Police Department without an open and public process. Section 3. Restricted Activities (a) No public official or public employee shall engage in conduct that constitutes a conflict of interest. (f) 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_ 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 P.S. SS403(a), (f). 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 Tavlor, 93- 013 -C2 Page 3 65 P.S. §402. 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 r ^tuber of his immediate family or a business with. which he or- a member of his immediate family is asso II. FINDINGS: 1. Frank J. Taylor has been a member of the Emmaus Borough Police Department from November 13, 1971 to the present. 2. Taylor has served as the Emmaus Borough Police Chief from 1986 to the present. 3. Robert C. Taylor was the sole owner Rob's Guns and Ammo at 35 E. Market Street,-Shamokin, PA, from June of 1989 to December of 1992, when the business closed. 4. Robert C. Taylor is the brother of Frank J. Taylor. 5. In November of 1990, Chief Taylor appeared before the Emmaus Borough Council,_at the annual budget hearing,,and requested funding to purchase fifteen, 9 millimeter handguns to replace the 357 magnum revolvers then being used by the officers of his department. 6. Council- agreed to fund the purchase of 5 weapons a year, for 3 years, fora total of 15 guns. 7. Council approved the 1991 annual budget, at the December 17, 1990 council meeting, which included an allocation of $3,000 for the purchase of 5 new weapons for that year. 8. In November of 1990 Emmaus Borough Detective Glen Dilcher solicited price quotes for the purchase of 15 Smith and Wesson, Model 4006, 40 caliber handguns. 9. Detective Dilcher contacted three gun dealers to obtain the quotes. - 10. The following price quotes were obtained by Dilcher: Taylor, 93- 013 -C2 Page 4 Gun w /ns Clip Pouch Holster Total 11. The above information was recorded on a sheet of paper without a date or the name of the person contacted for the quote. 12. Chief Taylor followed up on the quotes by contacting the above referenced dealers and obtaining the amount the dealers were willing to pay for the trade in of the 357 magnums that the Borough was replacing. 13. The following information listing trade -in and might sight (NS) cost was added by Chief Taylor: Gun w /ns Clip Pouch Holster Total Trade in All sights Total Hausman's Guns $ 481.00 $ 24.00 $ 19.00 Hausman's $ 481.00 $ 24.00 $ 19.00 $ - Guns $ 524.00 $ $ 150.00 $ installed by S &W $50.00 $ 374.00 $ Larry's Guns $ 445.00 $ 23.00 $ 18.95 $ 65.00 $ 524.00 $ 551.95 Larry's $ 445.00 $ 23.00 $ 18.95 $ 65.00 551.95 150.00 Rob's Guns $ 465.00 $ 20.00 $ 18.00 $ 60.00 $ 563.00 Guns Rob's Guns $ 465.00 $ 20.00 $ 18.00 $ 60.00 $ 563.00 $ 175.00 401.95 $ 388.00 14. The above information was recorded on a sheet of paper titled "From The Desk of Chief Taylor ". 15. In December of 1990 the contract for the purchase of 15 Smith and Wesson, Model 4006, 40 caliber handguns was awarded to Rob's Guns and Ammo of Shamokin, PA, by Chief Taylor. a. The purchase was for fifteen guns immediately, even though Borough had only approved funds for five guns each year. b. Chief Frank J. Taylor made the final decision to purchase the Guns from Rob's Guns and Ammo. 16. Robert C. Taylor presented a bill, undated, addressed to Chief Frank J. Taylor, stating the order for leather goods, totaling $1,169.75, will be ordered at a later date. 17. The bill stated the pistols, and 15 extra magazines at a cost of $300.00, would be ordered upon the receipt of a purchase order and it would take 120 - 150 days for delivery. Taylor, 93- 013 -C2 Page 5 18. The bill also stated that Rob's would pay $175, per weapon, for the twelve, 357 magnums the Borough intended to trade -in and Rob's would sell the weapons back to individual officers for $185. 19. The total amount of the bill was $7,049.25 less the $1,169.25 that would be charged at a later date for the leather goods. 20. The Borough's copy of the bill was stamped with the number "011318" which was applied by the Borough Treasurer and is used to enter the bill into the computer when a purchase order was not issued for the contract. a. The number "01131$" indicates the bill was entered into the Borough's computer on December 17, 1990. 21. The _Borough's copy of the bill contains the handwritten notation "410.220 Chief T. $5,880.00 ". a. Code 410.220 indicates the payment was to be made from the Police Department's allocation for operating expenses and supplies. b. The initials "Chief T. $5,880." indicates Chief Taylor approved payment of the bill. c. The amount of $5,880 equaled the $7,049.25 minus the $1,169.25 for the leather goods. 22. The bill was presented for payment, to the Borough Treasurer, on or before December 17, 1990. 23. Borough Council, at the December 17, 1990 meeting, was presented with a computer printout which listed the vendor, the amount of the bill, the code showing the allocation from which the bill was to be paid, . and the amount of money remaining in the allocated fund. a. Borough Council approved payment of the bill. b. Borough Council members did not see the bill from Rob's Guns and Ammo and were not aware that the bill was for 15 Smith and Wesson, Model 4006, 40 caliber guns. 24. Borough Treasurer Paul E. Riegel prepared Emmaus Borough check #012045, dated December 17, 1990, made payable to Rob's Guns and Ammo, in the amount of $6,149.25. a. The check was endorsed by Robert C. Taylor and deposited into Rob's Guns and Ammo account at the Union National Bank of Mount Carmel on December 24, 1990. Taylor, 93- 013 -C2 Page 6 b. The check included payment for the guns ($5,880) and a bill from Rob's Guns and Ammo, dated 12/12/90, for 15 Safariland double mag pouches which cost $269.25. 25. The guns were not delivered to the Borough until May of 1991. a. Payment was made approximately five months prior to delivery of the guns. 26. The Borough policy, at the time of the purchase, was not to pay for a purchase until the items were delivered. 27. Rob's Guns and Ammo purchased the guns Shooters Supplies, Ldbanon, PA, for $7,169 magazines from the same company for $292.50. from Shirk's amounted to $7,493.85 with charges. 28. Rob's Guns and Ammo purchased the 15 Safariland double mag pouches from Jerry's Sport Center, Forest City, PA, for $249.75. from Ron Shirk's .25, and the extra Rob's total bill the COD and UPS 29. On 2/15/91 Rob ' s Guns and Ammo submitted a bill to the Borough of Emmaus, totaling $900.00, for 15 Safariland holsters. 30. The Borough's copy of the bill contained the stamped number "011825" and the handwritten notation "410.220 Chief T." 31. Code 410.220 indicates the payment was to made from the Police Department's allocation for operating expenses and supplies. 32. The initials "Chief T." indicates Chief Taylor approved payment of the bill. 33. Borough Council, at the March 7, 1991 meeting, was presented with a computer printout which listed the vendor, the amount of the bill, the code showing the allocation from which the bill was to be paid, and the amount of money remaining in the allocated fund. 34. Borough Council approved payment of the bill. 35. Borough Treasurer Paul E. Riegel prepared Emmaus Borough check #012634, dated 3/7/91, made payable to Rob's Guns and Ammo, in the amount of $900.00. 36. The check was endorsed by Robert C. Taylor and deposited into Rob's Guns and Ammo account at the Union National Bank of Mount Carmel on March 13, 1991. 37. Rob's Guns and Ammo purchased the Safariland holsters from Taylor, 93- 013 -C2 Page 7 Jerry's Sport' 38. The twelve 357 Guns and Ammo, Name Kenneth Landau Dwayne Scholl Harley E. Gonsar Robert Bendas Joel Stover Michael Frazier Dean Seibert Mark Sebasovich Police Cadet Scott Acker Detective Glen Dilcher Detective William Kennedy Barry Barto Total Profit s Center for $1,016.50. magnums taken as trade -ins to the following people: Amount Paid By Customer $ 250.00 $ 250.00 $ 250.00 $ 275.00 $ 250.00 $ . 250.00 $ 250.00 250.00 $ 185.00 $ 185.00 $ 185.00 $ 250.00 $2,830.00 were sold, by Rob's Amount Paid To Borough 175.00 175.00 175.00 175.00 175.00 175.00 175.00 175.00 175.00 175.00 175.00 175.00 $ 2,100.00 $ 730.00 39. Borough Council was not aware Police Chief Taylor purchased the. 15 Smith and Wesson, 40 caliber weapons, the extra magazines, and the leather goods until the summer of 1991 when Mayor Robert Bastian investigated the accidental firing of one of the weapons. 40. Chief Taylor did not inform Borough Council until November 1991 that Rob's Guns and Ammo was owned by his brother, Robert C. Taylor. 41.. In the fall of 1992, Chief Taylor directed Detective Dilcher to obtain prior quotes for the purchase of sighting equipment. 42. Detective Dilcher obtained quotes of $519.00 from US Calvary and $511.64 from Rob's Guns and Ammo. 43. In November of 1992 Rob's Guns and Ammo submitted a bill to the Borough of Emmaus for the purchase of sighting equipment. 44. Borough Council, through Borough Manager Fosselman, informed Chief Taylor that the bill would not be paid. 45. Chief Taylor submitted a memo to Police Committee Chairman John Shafer, dated November 16, 1992, stating that he obtained price quotes from Rob's Guns and Ammo ($511.64), and from US Calvary $519.00, asking whether the bill would be paid and if he should refrain from making purchases from Rob's in the Taylor, 93- 013 -C2 Page 8 future. 46. On 12/15/92 Rob's Guns and Ammo resubmitted a bill to the Borough of Emmaus, totaling $511.64, for sighting equipment. 47. The Borough's copy of the bill contained the handwritten notation "Laura this was approved by pay ". 48. Borough Treasurer Laura G. Rieder prepared Borough check #017616, dated 12/17/92, in the amount of $511.64. 49. The check was stamped with the endorsement "Rob's Guns and Ammo" and deposited into Rob's Guns and Ammo account at the Guaranty National Bank of Shamokin. 50. Rob's Guns and Ammo purchased the sighting equipment from Jerry's Sporting Center for $443.90. a. The profit to Rob's was $67.74. 51. There was no public disclosure, prior to the purchase, that the police department was making the purchase from Rob's Guns and Ammo. 52. The Emmaus Borough Police Department made a number of other purchases from Rob's Guns and Ammo which included the following: Date of Purchase Description Amount 10/04/90 Ammunition $ 467.25 02/07/91 Ammunition $ 23.10 12/16/91 Ammunition $ 400.85 04/09/92 Ammunition $ 98.00 09/21/92 Ammunition $ 240.00 53. Each copy of Rob's Guns and Ammo invoices, on file in the Borough, for the above purchases, contains the handwritten notation indicating it was approved for payment by Chief Taylor. 54. The total cost to Rob's Guns and Ammo for the materials sold to the Borough was as follows. 40 Cal. Guns $ 7,201.35 (With UPS and COD) Magazines $ 292.50 Pouches $ 249.75 Holsters $ 1,016.50 Sighting Equipment $ 443.90 Total $ 9,204.00 Taylor, 93- 013 -C2 Page 9 55. The total amount in funds and trade -in merchandise received by Rob's Guns and Ammo from the Borough of Emmaus was as follows. a. Check Number Date Amount 012045 12/17/90 $ 6,149.25 012634 03/07/91 $ 900.00 017616 12/17/92 $ 511.64 b. Twelve 357 Magnum guns traded -in at X175.00 each $ 2,100.00 Total $ 9,660.89 56. The total profit to Rob's Guns and Ammo as a result of the above transactions was $456.89 (9,660.89 - $9,204.00). 57. Rob's Guns and Ammo also made a profit of $730 on the re -sale of the twelve guns traded -in by the Borough. ($2,830 - $2,100, see finding 38)., 58. The total profit realized by Rob's Guns and Ammo equaled $1,186.89. ($730.00 + $456.89). 59. None of the purchases made by the Borough from Rob's Guns and Ammo, were made with prior public notice and public bidding. '60 Frank Taylor did not file a memorandum with Emmaus Borough indicating his relationship to the owner of Rob's Guns and Ammo. 61. Frank Taylor did not intentionally or knowingly violate the Ethics Act. 62. Without contesting the findings of the Investigative Division, and in lieu of a hearing, Frank Taylor agrees to make restitution in the total sum of $1,186.89. III. DISCUSSION: As Chief of Police of Emmaus Borough, Frank J. Taylor, hereinafter Taylor, is a public official as that term is defined under Act 9 of 1989. 65 P.S. §402. As such, his conduct is ,subject to the provisions of the Ethics Law and the restrictions therein are applicable to him. Initially, it is noted that Section 9 of Act 9 of June 26, 1989 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 Taylor, 93- 013 -C2 Page 10 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 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 after the effective date of Act 9 (June 26, 1989), we must apply the provisions of Act 9 to determine whether the Ethics Act was violated. Under Section 3(a) of Act 9 of 1989 quoted above, a public official /employee shall not engage in conduct that constitutes a conflict of interest. In addition, Section 3(f) of Act 9 of 1989 specifically provides in part that no public official /employee or spouse or child or business with which he or the spouse or child is associated may enter into a contract with his governmental body valued at five hundred dollars or more or any subcontract valued at five hundred dollars or more with any person who has been awarded a contract with the governmental body with which the public official /employee is associated unless the contract is awarded through an open and public process including prior public notice and subsequent public disclosure. The issues before us are whether Taylor violated Section 3(a) or 3(f) of Act 9 of 1989 regarding the allegation that he, as Police Chief of Emmaus Borough, contracted with Rob's Guns and Ammo, a business owned by his brother, to supply weapons, ammunition, and holsters to the Borough Police Department when the contract was in excess of $500.00 and was not awarded through an open and public process. Taylor has been a member of the Emmaus Borough Police Department since November, 1971 and has been Police Chief since 1986 to the present. Robert C. Taylor, the brother of Police Chief Taylor, was the sole owner. of Rob's Guns and Ammo from June, 1989 to December, 1992 when the business was closed. When Taylor appeared before Borough Council in November, 1990 to request the purchase of fifteen 9 millimeter handguns, Council agreed to fund the purchase of five weapons a year over a three year period. In the 1991 annual budget, Council approved an allocation of $3,000.00 for the purchase of five guns for that year. In November, 1990, a Borough detective solicited price quotes for the purchase of fifteen Smith & Wesson 40 caliber handguns. Taylor, 93- 013 -C2 Page 11 Three gun dealers were contacted who supplied quotes. Rob's Guns and Ammo was the highest quote. Thereafter, Taylor contacted the dealers regarding their willingness to trade the current Borough .357 Magnums as part of the purchase of the new handguns. As to the three quotes received, after crediting an amount for the trades, the price quote of Rob's Guns and Ammo was in the middle. Taylor made the decision in December, 1990 to contract with Rob's Guns and Ammo to purchase fifteen Smith & Wesson 40 caliber handguns even though the Borough had only approved funds for five 9 millimeter guns per year over a three year period. A separate bill was presented to Taylor for accompanying leather goods totalling $1,169.75. The total bill of $7,049.25 included the guns, extra bullet magazines and a credit for the handguns that would be traded but did not include a credit for the leather goods which would be charged at later time. The bill of $5,680.00 ($7,049.25 - $1,169.75) was submitted to the Borough for payment with Taylor's initials on the bill indicating his approval for payment. At a December 17, 1990 meeting, Borough Council approved the bill from Rob's Guns and Ammo-as part of a computer print out of a bill list. Borough Council Members did not see the actual bill from Rob's Guns and Ammo and did not know that fifteen 40 caliber rather than five 9 millimeter guns were purchased. The Borough Treasurer subsequently prepared and issued a check on December 17, 1990 payable to Rob's Guns and Ammo in the amount of $6,149.25. The check represented the $5,880.00, as payment for the guns plus fifteen double mag pouches which cost $269.25. Even though the Borough policy was not to pay for items until they were actually received, the guns in this case were not delivered to the Borough until May of 1991. On February 15, 1991, Rob's Guns and Ammo submitted a bill to Emmaus Borough totalling $900.00 for fifteen handgun holsters. The bill again contained the initials of Chief Taylor indicating his approval for payment. At a March 7, 1991 Borough Council meeting, the bill was presented as part of a computer print out and was approved for payment by Council. Thereafter, the Borough Treasurer issued a check on March 7, 1991 payable to Rob's Guns and Ammo in the amount of $900.00. Borough Council purchased the fifteen until the summer of 19 discharged. Further, that Rob's Guns and brother. was not aware that Police Chief Taylor 40 caliber guns, magazines and leather goods 91 when one of the fire arms was accidentally Council was not aware until November of 1991 Ammo was owned by Police Chief Taylor's In the fall of 1992, after Chief Taylor directed that price quotes be obtained for gun sighting equipment, two quotes were received with the lower quote being from Rob's Guns and Ammo. Thereafter, in November, 1992, Rob's Guns and Ammo submitted a bill Taylor, 93- 013 -C2 Page 12 to Emmaus Borough for the purchase of sighting equipment. Borough Council advised Chief Taylor that the bill would not be paid. Thereafter, on December 15, 1992, Rob's Guns and Ammo resubmitted the bill, totalling $511.64. The Borough's copy contained a handwritten notation "Laura this was approved by pay ". The record provides no insight as to who authored the handwritten notation. The Borough Treasurer prepared a check dated December 17, 1992 in the amount of $511.54 payable to Rob's Guns and Ammo. As to the above, to re was never any public disclosure, prior to purchase, that the Police Department was buying from Rob's Guns and Ammo. There were also sundry purchases of ammunition over an approximate two year period from Rob's Guns and Ammo with the invoices containing the handwritten notation that it was approved for payment by Police Chief Taylor. The record reflects that Rob's Guns and Ammo made a total profit of $1,186.89 from the foregoing transactions based upon a profit of $730.00 on the resale of the guns that were traded in by the Borough plus a $456.89 profit on the transaction of the sale of the new guns, ammunition and holsters. Although none of the above purchases from Rob's Guns and Ammo was made with prior public notice and public bidding, there is no evidence of record that Police Chief Taylor intentionally or knowingly violated the Ethics Law as to these activities. In applying the provisions of the Ethics Law to the above facts, we find a violation of Section 3(a) but not Section 3(f) of Act 9 of 1989. As to Section 3(a), Police Chief Taylor used the authority of his office because it was he who made.the decision to purchase the fifteen Smith & Wesson handguns. We are cognizant of the fact that Police Chief Taylor initially sought and obtained authorization from Borough Council for the purchase of the guns. However, there are two reasons why that authorization is unavailing as a defense. First, what Chief Taylor purchased was beyond the scope of the authorization given by Council. Council authorized Chief Taylor to purchase five 9 millimeter guns a year over a three year period. Chief Taylor, however, purchased fifteen 40 caliber guns in a one year period. Such action was taken solely by Taylor. Second, even if we were to assume that there was a valid Borough authorization in this case, that authorization would not form a basis for allowing Taylor to violate the Ethics Law by awarding the contract to his brother's business. Therefore, the actions by Taylor in this case constituted a use of authority of office on his part. Juliante, Order No. 809. The use of authority of office of Taylor resulted in a private pecuniary benefit amounting to the $1,186.89 of profit made by Rob's Guns and Ammo. Lastly, the private pecuniary benefit inured to a business with which a member of Taylor's immediate family was Taylor, 93- 013 -C2 Page 13 associated. "Immediate family" is defined under Act 9 of 1989 as follows: Section 2. Definitions "Immediate family." A parent, spouse, child, brother or sister. 15 P.S. §402. Since Rob's Guns and Ammo was owned by Robert Taylor who is the brother of Police Chief Taylor, it is that Rob's Guns and Ammo is a business with which a member of Taylor's immediate family is associated. Accordingly, Taylor violated Section 3(a) of Act 9 of 1989 when he used the authority of office to obtain a private pecuniary benefit for a member- of his immediate family through the purchase of handguns and other items for the Borough Police Department from Rob's Guns and Ammo. As to Section 3(f) of Act 9 of 1989, the record reflects that the 'contract in this case was in excess of $500.00 and was not awarded through an open and public process as required by the contracting provision of the Ethics Law. However, Section 3(f) is limited in its to the public official /employee, his spouse, child or a business in which the public official/ employee, his spouse or child is associated. In this case, the contracting was with a business with which Taylor's brother is associated. Accordingly, since Taylor's brother is not within the class of enumerated persons as to which Section 3(f) has application, we are constrained to find no violation of that provision of law. This Commission has the power to exercise its discretion to impose a treble penalty or restitution. This power is explicitly provided in Act 9 of 1989. 65 P.S. §407(13). In this case, we believe that restitution is appropriate and warranted as to the - profit made by Rob's Guns and Ammo. Since the profit amounted to $1,186.89, we order restitution by Taylor in that amount payable in a timely manner through this Commission to the order of Emmaus Borough. Compliance with the foregoing will result in the closing of this case with no further action. Non - compliance with the foregoing will result in the initiation of an order enforcement action. IV. CONCLUSIONS OF LAW: 1. Frank J. Taylor, as Police Chief of Emmaus Borough, is a public employee subject to the provisions of Act 9 of 1989. 2. Taylor violated Section 3(a) of Act 9 of 1989 when he used the authority of office to obtain a private pecuniary benefit for a business with which a member of his immediate family was Taylor, 93- 013 -C2 Page 14 associated consisting of the $1,186.89 in profit on a contract between the Borough and Rob's Guns and Ammo. 3. Taylor did not violate Section 3(f) of Act 9 of 1989 regarding contracting between the Borough and Taylor's brother in that the contracting was not awarded to the public official/ employee, spouse, child, or business with .. which the public official /employee, spouse or child was associated as required by Section 3(f) of Act 9 of 1989. The private pecuniary benefit as to the violation of Section 3(a) of Act 9 of 1989 amounted to $1,186.89. In Re: Frank J. Taylor File Docket: , _; -93- 013 -C2 : Date Decided: December 7, 1993 : Date Mailed: December 10, 1993 ORDER NO. 906 1. Frank J. Taylor, as Police Chief of Emmaus Borough, violated Section 3(a) of Act 9 of 1989 when he used the authority of office to obtain a private pecuniary benefit for a business with which a member of his immediate family was associated consisting of the .;1,186.89 in profit on a contract between the Borough and Rob's Guns and Ammo. 2. Taylor did not violate Section 3(f) of Act 9 of 1989 regarding contracting between the Borough and Taylor's brother in that the contracting was not awarded to the public official/ employee, spouse, child, or business with which the public official /employee, spouse or child was associated as required by Section 3(f) of Act 9 of 1989. 3. The private pecuniary benefit as to the violation of Section 3(a) of Act 9 of 1989 amounted to $1,186.89. 4. Taylor is ordered to make restitution of $1,186.89 in a timely manner payable through this Commission to the order of Emmaus Borough. 5. Failure to comply with the provision of Paragraph 4 will result in the initiation of an order enforcement action in Commonwealth Court. 6. Compliance with Paragraph 4 will result in the closing of this case with no further action. BY THE COMMISSION, JAMES M. HOWLEY,` tt