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HomeMy WebLinkAbout949 ColonelloIn Re: Francis Colonello Before: STATE ETHICS COMMISSION 308 FINANCE BUILDING HARRISBURG, PENNSYLVANIA 17120 File Docket: 94- 012 -C2 Date Decided: 12/15/94 Date Mailed: 12/27/94 James M. Howley, Chair Daneen E. Reese, Vice Chair Roy W. Wilt Austin M. Lee Allan M. Kluger The Investigative Division of the State Ethics Commission conducted an investigation regarding a possible violation of the State Ethics Law, Act 9 of 1989, P.L. 26, 65 P.S. §401 et seq. 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 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). Any person who violates confidentiality of the Ethics Law 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). Confidentiality does not preclude discussing this case with an attorney at law. Colonello, 94- 012 -C2 Page 2 I. ALLEGATION: That Francis Colonello, in his capacity as a public official /public employee, a Commissioner for Wilkins Township, Allegheny County, violated the following provisions of the State Ethics Act (Act 9 of 1989) when he submitted for reimbursement and accepted payment for expenses to attend annual conventions of the Pennsylvania State Association of Township Commissioners which were in excess of actual expenses incurred. Section 3. Restricted Activities (a) No public official or public employee shall engage in conduct that constitutes a conflict of interest. 65 P.S. §403(a). Section 2. Definitions "Conflict" or "conflict of interest." Use by a public official or public employee of the authority of his office or employment or any confidential information received through his holding public office or employment for the private pecuniary benefit of himself, a member of his immediate family or a business with which he or a member of his immediate family is associated. "Conflict" or "conflict of interest" does not include an action having a de minimis economic impact or which affects to the same degree a class consisting of the general public or a subclass consisting of an industry, occupation or other group which includes the public official or public employee, a member of his immediate family or a business with which he or a member of his immediate family is associated. 65 P.S. §402. II. FINDINGS: 1. A signed, sworn Complaint was received by the Investigative Division of the State Ethics Commission on February 7, 1994, alleging that Respondent, Francis Colonello, violated provisions of the Ethics Law. a. The Complaint was docketed on February 9, 1994. 2. The Complaint was reviewed by the Director of Investigations and a recommendation was made to the Executive Director of the State Ethics Commission to commence a preliminary inquiry. Colonello, 94- 012 -C2 Page 3 3. A preliminary inquiry was initiated on February 9, 1994. 4. The preliminary inquiry was completed within sixty days. 5. Upon completion of the preliminary inquiry, the matter was reviewed by the Executive Director of the State Ethics Commission. 6. On April 8, 1994, a letter was forwarded to Respondent by the Executive Director of the State Ethics Commission informing Respondent of the fact that a Complaint against him was received by the Investigative Division of the State Ethics Commission and that a full investigation was being commenced. a. The letter outlined the nature and scope of the allegation being investigated and further delineated the applicable sections of the Ethics Law. b. Said letter was forwarded return receipt requested and received by Respondent on April 13, 1994. 7. The full investigation was commenced at the direction of the Executive Director of the State Ethics Commission. 8. Letters were forwarded to the Respondent and Complainant in this matter advising each as to the general status of the instant investigation on the following dates: a. July 11, 1994. 9. Francis Colonello has served as a Township Commissioner for Wilkins Township, Allegheny County, since 1989. 10 Wilkins Township is a First Class Township and is a member of the Pennsylvania State Association of Township Commissioners (PSATC). 11. Section 620 of the First Class Township Code which was adopted in 1965 authorized the formation of a State Association of Township Commissioners. a. The association holds annual meetings or conventions at a designated time and place within the Commonwealth, for the purpose of discussing various questions and subjects pertaining to the duties of township commissioners, and for the purpose of devising uniform, economical and efficient methods of administering the affairs of townships. b. The township commissioners and not more than three other officers of the township designated by the township Colonello, 94- 012 -C2 Page 4 commissioners may attend the annual meeting. 12. Section 622 of the First Class Township Code which was amended on January 28, 1988, authorized the payment of expenses incurred by the delegates be paid for by the townships when attending the annual meetings of the State Association. 13. Each commissioner or delegate attending the annual meeting of the State Association shall be allowed expenses which shall be limited to the registration fee, mileage for use of personal vehicle or reimbursement of actual transportation expense going to and returning from such meetings, plus all other actual expenses that the township commissioners may have agreed to pay. 14. Every commissioner or delegate attending the annual meeting shall submit an itemized account of expenses incurred. 15. The PSATC has held their annual conventions at the Mount Airy Lodge in Mount Pocono, Pennsylvania since at least 1989. 16. The Wilkins Township Board of Commissioners has annually authorized members of the board to attend annual PSATC conventions. 17. Francis Colonello attended the PSATC Conventions from 1991 through 1993 as a Wilkins Township Commissioner. 18. Colonello traveled in the same vehicle with Wilkins Township Commissioner Victor Dinzeo when he attended the PSATC Conventions in 1991, 1992, and 1993. a. In 1991, Colonello used his own personal vehicle. b. In 1992, Colonello traveled to the convention in Dinzeo's personal vehicle. 19. In 1993, Colonello traveled with Dinzeo in a vehicle supplied by #1 Cochran Automotive, an automobile dealership located near Monroeville. a. Arrangements to obtain the vehicle were made by Dinzeo who is a personal friend of the owner of the dealership. b. #1 Cochran Automotive did not charge either Colonello or Dinzeo for the use of the vehicle. c. The vehicle loaned to Dinzeo was a customized full size conversion van with a 33 gallon gas tank. When the van was given to Dinzeo it had a full tank of gas. Colonello, 94- 012 -C2 Page 5 d. Colonello was unaware of any arrangement between Cochran and Dinzeo. 20. Records of Wilkins Township reflect the following expense vouchers submitted by Colonello for attendance at PSATC Conventions from 1991 through 1993: a. 1991 Departure 06/16/91 Return 06/19/91 Total mileage Hotel expenses Daily expenses 06/16/91 Porters & Hellman $2.00 Limo and taxis $6.95 Total $8.95 Total daily expenses Total expenses b. 1992 Departure 06/21/92 Return 06/24/92 Per Diem 3 days up to $160.00 = Total mileage - 730 miles @ $.28 per mile Registration fee for conference Total Total advance payment (Registration fee and $25.00 room deposit) Total expenses c . 1993 Departure 06/13/93 Return 06/16/93 Total mileage - 730 miles @ $.28 per mile Hotel expense Daily expenses (Turnpike fees) 640 miles @ $ .275 per mile = $176.00 $425.00 06/19/91 Meals $10.00 Porters & Bellmen 2.00 Limo, taxis 6.95 Maid 5.00 Total $23.95 $ 32.90 $633.90 $480.00 $204.40 $100.00 $784.40 $125 00 $659.40 $204.40 $425.00 $ 13.90 $643.30 Total expenses 21. Colonello's expense vouchers contain his signature for each Colonello, 94- 012 -C2 Page 6 year certifying that the expenses he had listed were proper and actual expenses incurred. 22. Minutes of the Wilkins Township Commissioner meetings reflect Colonello approved the payment of bills which included his convention expenses as follows: Meeting Date Check # Amount Action 23. The total mileage reimbursement received by Colonello for his attendance at PSATC Conventions is as follows: a. b. c . 06/10/91 07282 $625.57 Voted Yes 06/09/92 00358 $659.40 Voted Yes 06/08/93 00140 $629.40 Absent 1991 - $176.00 (see Finding 20a) 1992 - $204.40 (see Finding 20b) 1993 - $204.40 (see Finding 20c) Total: $584.80 24. Colonello was entitled to receive mileage reimbursements in the amount of $176.00 for his attendance at the 1991 PSATC Convention. 25. Colonello was not entitled to receive mileage reimbursements for his attendance at the 1992 and 1993 PSATC Conventions. a. Colonello did not have any out of pocket expenses for mileage to and from either convention. b. Colonello was paid $204.40 in 1992 and $204.40 in 1993 for mileage. (See Findings 20b, 20c). 26. Colonello received a financial gain of $408.80 for mileage reimbursements he was not entitled to for his attendance at the 1992 and 1993 PSATC Conventions. 27. No reimbursement was made to Wilkins Township by Colonello for the mileage payments he received for 1992 and 1993. 28. Colonello believed that he was entitled to receive mileage reimbursement when not using his personal vehicle. a. Colonello believed he was entitled to receive mileage reimbursement on the basis that he was a first time public official and had received similar expense reimbursements over his many years as a union official in the private sector. 29. Mr. Colonello voluntarily made expense reimbursement to the Colonello, 94- 012 -C2 Page 7 Township in the amount of $408.80 by personal check number 994, following a contact with the State Ethics Commission. III. DISCUSSION: As a Commissioner for Wilkins Township, Allegheny County, Francis Colonello, hereinafter Colonello, 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 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. The term "conflict of interest" is defined above in the allegation. The issue before us is whether Colonello violated Section 3 (a) of Act 9 regarding the allegation that he submitted and received expense reimbursement payments in excess of the actual expenses incurred for attending the annual Pennsylvania State Association of Township Commissioners (PSATC) Conventions. Colonello has served a Wilkins Township Commissioner in Allegheny County since 1989 and has attended the annual PSATC Conventions for the years 1991 through 1993. The First Class Township Code (Code) does allow for the payments of expenses incurred by Township delegates who are attending annual meetings of PSATC. The expenses which are allowable are limited to the registration fee, mileage for use of a personal vehicle or reimbursement of actual transportation Colonello, 94- 012 -C2 Page 8 expenses plus any other actual expenses incurred by the township commissioner. For each attendance by Colonello at the annual PSATC Conventions in 1991 through 1993, he submitted and received expense reimbursements as set forth in Fact Finding 20. The focus of concern as to such reimbursement centers upon the mileage reimbursements. In this regard, Colonello did use his own personal vehicle in 1991 but in 1992 and 1993 Colonello travelled in Commissioner Dinzeo's vehicles. Although Colonello did have mileage expenses in 1991 due to the utilization of his own personal vehicle, Colonello did not have any mileage expenses in 1992 or 1993 since he rode with Dinzeo; nevertheless, Colonello submitted and received mileage reimbursements for 1992 and 1993. Both in 1992 and 1993 Colonello submitted and received mileage expense reimbursement in the amount of $204.40 which totaled $408.80 for the two years. Colonello believed that he was entitled to mileage reimbursement for the years 1992 and 1993 based upon his receipt of similar expense reimbursements during the years when he was a union official in the private sector. After contact was made by the (Investigative Division of the) Commission, Colonello voluntarily made reimbursement to the township in the amount of $408.80. In applying the provisions of Section 3(a) of Act 9 of 1989 to the instant matter we are guided by the principle found in many prior cases of this Commission that the receipt by a public official /employee of a financial gain which is not authorized in law constitutes a private pecuniary benefit in violation of Section 3(a) of Act 9 of 1989. Hessinger, Order 931. In the instant matter, the Code limits reimbursement to actual transportation expenses. Colonello did not have such actual transportation expenses in 1992 and 1993. Accordingly, the receipt of that pecuniary benefit is private and is violative of the Ethics Law. Confidential Opinion, 91 -001; Hagen, Order 554 -R. Restitution in this case is warranted; however, we note that Colonello has already voluntarily made restitution to the Township. Accordingly, based upon the totality of the facts and circumstances of this case, we will take no further action. IV. CONCLUSIONS OF LAW: 1. Francis Colonello as a Wilkins Township Supervisor, Allegheny County is a public official subject to the provisions of Act 9 of 1989. 2. A technical violation of Section 3(a) of Act 9 of 1989 occurred when Colonello received mileage reimbursements in Colonello, 94- 012 -C2 Page 9 1992 and 1993 for attending the PSATC Conventions which were not authorized in law so as to constitute a private pecuniary benefit. 3. The private pecuniary benefit received by Colonello as to the violation referred in paragraph 2 is $408.80. In Re: Francis Colonello File Docket: 94- 012 -C2 Date Decided: 12/15/94 Date Mailed: 12/27/94 ORDER NO. 949 1. A technical violation of Section 3(a) of Act 9 of 1989 occurred when Francis Colonello as a Wilkins Township Supervisor, Allegheny County, received mileage reimbursements in 1992 and 1993 in the total amount of $408.80 which were not authorized in law so as to constitute a private pecuniary benefit for attending the PSATC Conventions. 2. Since Colonello has made restitution in the amount of $408.80, this Commission will take no further action based upon the totality of facts and circumstances. BY THE COMMISSION, �sus� JAMES M. HOWLEY,