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HomeMy WebLinkAbout990 BarronIn Re: JOHN W. BARRON STATE ETHICS COMMISSION 308 FINANCE BUILDING HARRISBURG, PENNSYLVANIA 17120 Before: Daneen E. Reese, Chair Austin M. Lee, Vice Chair Roy W. Wilt Allan M. Kluger John R. Showers Rev. Joseph G. Quinn Boyd E. Wolff File Docket: 91 -031 -C Date Decided: 12/7/95 Date Mailed: 12/15/95 The Investigative Division of the State Ethics Commission conducted an investigation regarding a possible violation of the State Ethics Law, Act 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 deemed waived. The record is complete. 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 §2.38. The files in this case will remain confidential in accordance with Section 8(a) of Act 170 of 1978. 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. Section 9(e) of Act 170 of 1978. Confidentiality does not preclude discussing this case with an attorney at law. Barron, 91 -031 -C Page 2 I . ALLEGATION: That John Barron, Coroner for Cambria County, violated the following provisions of the State Ethics Act (Act 170 of 1978), when he selected and utilized his personal residence as Cambria County Coroner's Office and was compensated therefore in excess of $500 per year. II. FINDINGS (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. 5403(a). (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. §403(c). 1. A signed, sworn Complaint was received by the Investigative Division of the State Ethics Commission on May 10, 1991, alleging that Respondent, John W. Barron, violated the provisions of the Public Official and Employee Ethics Law. 2. Upon review of the Complaint by the Director of Investigations of the Investigative Division of the State Ethics Commission, a recommendation was made to the Executive Director of the State Ethics Commission to commence a preliminary inquiry. Barron, 91 -031 -C Page 3 3. On May 23, 1991, the Executive Director of the State Ethics Commission authorized commencement of a preliminary inquiry regarding the allegations that Respondent, John W. Barron, violated the Ethics Act, Act 170 of 1978. 4. Upon completion of the preliminary inquiry, the matter was reviewed by the Executive Director of the State Ethics Commission. 5. On November 6, 1991, 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. Said letter outlined the nature and scope of the allegations and further delineated the applicable sections of the Ethics Law in question. 6. The full investigation was then commenced at the direction of the Executive Director. 7. On November 7, 1995, the Investigative Division of the State Ethics Commission issued an Investigative Complaint and Findings Report to the Respondent. 8. John Barron served in the Cambria County Coroner's Office from July 11, 1977, through March, 1993. a. Barron became attached to the Cambria County Coroner's Office in 1977, assisting Coroner Joseph Govekar in the identification of victims of a severe flood in the Johnstown area. b. He was subsequently appointed Chief Deputy Coroner by Coroner Govekar. c. Barron was appointed Acting Coroner in 1978, by Governor Schapp upon the death of Coroner Govekar. d. Barron was elected to the office of Coroner in 1979, and began serving his first term in 1980. e. Barron resigned as Cambria County Coroner in order to run for election to the position of District Magistrate, an effort which was successful. 9. Cambria County did not provide for a Coroner's Office in a county building until 1992. a. It was an established past practice that the coroner maintain the Coroner's Office in his home. Barron, 91 -031 -C Page 4 10. During the years that Barron worked for Govekar, the Coroner's Office was located in Govekar's personal residence: a. Cambria County did not reimburse Govekar for the use of his personal residence. 11. In 1978, as acting coroner, Barron moved the Coroner's Office to his personal home. a. Barron changed his personal residence several times during his tenure as coroner, leading to the relocation of the Cambria County Coroner's Office to these new residences. 12. Cambria County supplied and /or reimbursed the Coroner's Office with the following: a. Mileage reimbursement for use of personal vehicles until the county purchased a vehicle in mid 1980's; 1. Prior to the county purchasing a vehicle for the Coroner's Office, there were numerous occasions where it was necessary for Barron to transport decomposing bodies in his personal vehicle. b. Separate telephone line installation, payment of telephone bills, and in the late 1980's, an answering service; c. A used copier in the mid- 1980's which subsequently broke down; d. A computer in 1989/1990 to replace the one purchased by Barron in 1983/1984; e. Regularly used forms, such as Field Slips; f. Two used file cabinets. 13. As Coroner, Barron personally supplied items for the office necessary to perform his duties, including, but not limited to the following: Desk, chairs, telephone, file cabinets, computer, computer table, paper, pens /pencils, rubber gloves, needles and syringes. 14. The Coroner's Office had to be accessible at all times to the Deputy Coroners who were supplied with keys, and when applicable, security access codes. a. The functions of the Coroner's Office required the office to be accessible 24 hours a day, 365 days a year. Barron, 91 -031 -C Page 5 b. Barron had two full -time employees in the positions of Chief Deputy and Deputy. 15. By necessity, the Coroner's Office was the central point of investigation often facilitating meetings of law enforcement personnel and /or families of deceased. a. Meetings took place at varying times during the day and night. b. Meetings often necessitated the use of additional areas of the Coroner's home. 16. In approximately 1980, after being elected to the Office of Coroner, Barron first asked the Cambria County Commissioners to provide space for the Coroner's Office. a. Barron had not made the request in 1978 or 1979, because he only held the position of Acting Coroner. b. Barron made his request at the Annual Budget session. c. The commissioners did not provide the Coroner's Office with space. 17. Barron continued to request office space for the Coroner's Office each year after 1980 at the budget sessions with the commissioners. a. Barron believed it was the responsibility of the Commissioners to provide space, and not his responsibility to find space. 18. Barron regularly attended the Annual Conventions of the Pennsylvania State Coroner's Association, and had served as President and Vice- President. a. The subject of reimbursement for use of a coroner's home was the Coroner's Office was raised at a convention. 19 Robert Weinert, Solicitor for the Pennsylvania State Coroner's Association, advised the members that it was appropriate to request reimbursement from their respective county commissioners for the expenses incurred in maintaining the Coroner's Office in their respective homes. a. Expenses specifically named by Weinert included fuel, equipment, telephone, insurance, furniture, light, and janitorial services. Barron, 91 -031 -C Page 6 b. This advice preceded Barron's request for reimbursement. c. Weinert issued an advisory letter to the Warren County Coroner, Ronald W. Simonsen, on September 26, 1980, wherein he opined that the county, rather than the coroner, should pay the office expenses of the Coroner's Office. 20. In response to questions from members of the State Coroner's Association, Weinert issued advice that the average monthly reimbursements to Coroners by counties was $250 -$300, to the following: a. December 11, 1987, to Forest County Coroner, James Haslet. b. October 4, 1988, to Venango County Coroner, Edward Gabrys. c. Barron became aware of this advice through his involvement with the Association. 21. In 1981 the Cambria County Commissioners offered to reimburse Barron in the amount of $200.00 per month to defray his expenses. a. This was in lieu of providing office space. b. The Commissioners preferred to keep the Coroner's Office in the coroner's home as had been past practice. 22. Barron based his acceptance of the County Commissioner's offer to reimburse him for expenses of the Coroner's Office, on Advice given by the State Coroner's Association Solicitor, Robert Weinert. a. The commissioners requested the opinion of the County Solicitor before approving the reimbursement. 23. Minutes of the March 26, 1981, meeting of the Cambria County Commissioners reflect the following in regard to the approval of payments to Coroner John Barron for office rental: "Motion by Joseph P. Roberts to approve payment in the amount of $200 per month to Coroner John Barron for office rental, effective January 1, 1981." "Motion seconded by W. Donald Templeton and carried unanimously." Present: W. Donald Templeton, Joseph P. Roberts. Barron, 91 -031 -C Page 7 24. In 1984, the Cambria County Commissioners raised the amount of the reimbursement paid to Barron from $200 to $400 per month. a. The reimbursement remained the same through 1992, when the Coroner's Office was moved to a separate facility. 25. The January 5, 1984, minutes of the Cambria County Commissioner's meeting reflect the following approval of an increase in rent for the Coroner's Office. "Motion by Ron Stephenson to approve an increase in the rental of the Coroner's Office to $400 per month, effective January 1, 1984." "Motion seconded by T.T. Metzger, Jr., and carried unanimously." Present: Joseph P. Roberts; Ron Stephenson; T.T. Metzger, Jr. 26. In 1992, the Cambria County Commissioners provided space for the Coroner's Office in a Johnstown Office building that also housed the County Domestic Relations Office. 27. It is Barron's opinion that the decision to provide space for the Coroner's Office was predicated on three things: a. Conemaugh Hospital had been certified as a Trauma Center which significantly increased the workload of the Cambria County Coroner's Office. b. The County Controller questioned the "rent" payments to Barron. The form of payment was subsequently changed to an "administrative fee." c. The commissioners became aware of the Ethics Commission investigation of the "rent" payments made to Barron for the use of his home as the Coroner's Office. 28. By way of letter dated November 20, 1991, Attorney Robert Weinert, Solicitor for the Pennsylvania State Coroner's Association, provided as follows: a. The practice of the County Commissioners compensating the Coroner for the use of his home, is and has been followed in approximately 80% of the counties since the adoption of the County Code in 1955 and before. b. According to Section 508, the County Commissioners are required to provide space to the Coroner, however, the space does not have to be provided in the County Courthouse or the County Seat. Barron, 91 -031 -C Page 8 c. The Coroner is not using the authority of his in order to secure pecuniary benefits, the County Commissioners are extending him the benefits as they are mandated to do under the law. 29. The County Code specifies the county offices which are required to be maintained in a county building, courthouse or other buildings at the County Seat. a. The County Commissioners are responsible for furnishing the office space. b. The Coroner's Office was not required to be maintained at the County Seat. 30. Section 405 of the County Code- Location of Offices, Records and Papers, states the following: a. The commissioners, Auditors, Controller, Treasurer, Sheriff, Recorder of Deeds, Prothonotary, Clerk of Courts of Quarter Sessions and oyer and terminer, Clerk of Orphans Court, Register of Wills, Recorder of Deeds and District Attorney shall keep their respective offices, and all public records and papers belonging thereto at the County Seat, and in such buildings as may be erected or appropriated for such purpose .... b. The county commissioners shall furnish each of such officers with an office in the county building, courthouse or other building at the county seat. 31. The County Code assigns responsibility for providing office space, equipment and supplies to the county. a. Section 508(a) states that the commissioners are to designate space for offices not required to be kept in the county courthouse or county seat. b. Section 508(b) states that the county shall incur the cost of supplying all items specified in Section 508(a) to the offices not specified in Section 405. 32. Section 508 of the County Code states, in part, the following: a. Office furniture, stationary, etc., (a) the County Commissioners, at the cost of the county, shall purchase and provide the office furniture, equipment and supplies, blank books, blanks, dockets, books for records, stationery, postage, fuel, light and Barron, 91 -031 -C Page 9 janitor and telephone service, required for, each of the county officers whose offices are located in the county buildings or at such other places at the County Seat as may be designated by the commissioners, and all supplies used by the public in connection with such offices. [emphasis added] (b) The County Commissioners, at the cost of the county, shall purchase and provide all of the same items as needed for each of the county officers whose offices are not required by law to be kept and maintained in county buildings or at the County Seat. 33. Barron was paid "rent" by Cambria County for use of his home, to provide space for the Coroner's Office in 1981, 1982 and 1983, in the amount of $200 per month. a. Barron received payments totaling $2,400.00 per year in 1981, 1982 and 1983. b. Barron received total payments in the amount of $7,200.00 during this time period. 34. Barron was paid "rent" by Cambria County for use of his home, to provide space for the Coroner's Office from 1984, through March, 1991, in the amount of $400 per month. a. These payments were made to help defray the costs of operating the Coroner's Office. b. Barron received a total of $4,800 per year. c. Barron received total payments in the amount of $34,800 during this time period 35. The word "rent" was chosen by the county commissioners, not by Barron. a. Rent included use of the physical space as well as other expenses incurred by Barron to maintain the office. 36. Records of the Cambria County Controller's Office include computer records of "rent" payments in the amount of $400.00 per month, made to John Barron for use of his home as the Coroner's Office between December, 1986, and February, 1991. Barron, 91 -031 -C Page 10 a. 1987 payments CHECK NUMBER 60278 61422 63021 64604 66004 67555 69046 70570 71895 73135 74369 75813 CHECK NUMBER 77174 78300 79841 81121 82452 84279 85560 86758 88322 89475 91004 92573 CHECK NUMBER 93691 95191 96355 97602 98793 100512 101655 103295 104529 105588 106341 107476 d. 1990 payments CHECK NUMBER were made as follows: DATE December 31, 1986 January 30, 1987 February 27, 1987 April 3, 1987 April 30, 1987 May 29, 1987 June 30, 1987 July 31, 1987 August 31, 1987 September 30, 1987 October 30, 1987 November 27, 1987 b. 1988 payments were made as follows: PATE December 31, 1987 January 29, 1988 February 29, 1988 March 31, 1988 April 29, 1988 May 31, 1988 June 30, 1988 July 25, 1988 August 26, 1988 September 26, 1988 October 28, 1988 November 28, 1988 c. 1989 payments were made as follows: PATE December 27, 1988 January 31, 1989 February 23, 1989 March 31, 1989 April 24, 1989 May 31, 1989 June 26, 1989 July 28, 1989 August 25, 1989 September 29, 1989 October 31, 1989 November 30, 1989 were made as follows: DATE Barron, 91 -031 -C Page 11 108822 January 1, 1990 109837 January 31,1990 110836 February 28, 1990 111805 March 30, 1990 113040 April 30, 1990 114086 May 25,1990 115187 June 30, 1990 116122 July 31, 1990 117019 August 31, 1990 117692 September 30, 1990 118578 October 31, 1990 119883 November 30, 1990 e. 1991 payments were made as follows: CHECK NUMBER PATE 120329 December 31, 1990 122324 January 31, 1991 123447 February 28, 1991 37. The April 11, 1991, minutes of the Cambria County Commissioner's meeting reflect the approval of a reimbursement in the amount of $400 per month to the Coroner for Administrative fees to be effective March 1, 1991. a. The motion was predicated by the concern raised by the County Controller over the terminology used in the existing payments to the Coroner. b. Payments up to this point in time had been termed "rent" as opposed to "administrative fee." 38. The April 11, 1991, minutes of the Cambria County Commissioners reflect the following motions regarding payments to the Coroner's Office. "Motion by Kathy L. Holtzman to rescind the resolution paying the Coroner's Office a rental fee in the amount of $400 per month." "Motion seconded by Ron Stephenson and carried unanimously." "Motion by Ron Stephenson to approve payment of a reimbursement in the amount of $400.00 per month to the Office of Coroner, for Administrative Fees, effective March 1, 1991." "Motion seconded by Kathy L. Holtzman and carried unanimously." Present: Joseph P. Roberts, Ron Stephenson, Kathy L. Holtzman. Barron, 91 -031 -C Page 12 Payment amended 39. Payments provided building f. to the Coroner's Office beginning April, 1991, was to read "Administrative Fee." discontinued in 1992, when the County Commissioners space for the Coroner's Office in a Johnstown 40. Cambria County issued 1099 Miscellaneous Income Statements to John Barron to account for the money paid to him in the form of rent. 41. The following Statements of Financial Interests were on file with the Cambria County Board of Elections for John Barron: a. Filing Date: March 8, 1991 For the Year: 1990 Source of Income: Cambria County and Johnstown VO -Tech Office, Directorship or Employment in any Business: AAA, Mid -State Johnstown- Advisor Board Real Estate Interests: Service rent for Coroner's Office, Cambria County, Ebensburg, PA All other Financial Interest categories: None b. Filing Date: April 17, 1990 For the Year: 1989 Source of Income: Cambria County & Vo -Tech School Office, Directorship or Employment: AAA - Director All other Financial Interest categories: None c. Filing Date: April 17, 1989 For the Year: 1988 Source of Income: Johnstown Vo -Tech & Cambria County Creditors: Moxham National Bank - Interest rate not listed. All other Financial Interest categories: None d. Filing Date: March. 16, 1988 For the Year: 1987 Source of Income: Municipal Police Training Academy, Vo -Tech & Cambria County Office, Directorship or Employment: Mid State Auto Club, AAA - Advisory Board Member All other Financial Interest categories: None e. Filing Date: February 19, 1987 For the Year: 1986 Source of Office or All other Position: Income: Vo -Tech Municipal Police Academy Directorship: Mid State Auto Club- Director Financial Interest Categories: None Coroner Filing Date: April 9, 1986 Barron, 91 -031 -C Page 13 For the Year: 1985 Source of Income: Vo -Tech School & Cambria County Office Directorship: Mid State Auto Club - Director All other Financial Interest categories: None g. Filing Date: April 21, 1985 For the Year: 1984 Source of Income: Cambria County & Johnstown Vo Tech Office or Directorship: Mid State Auto Club - Director All other Financial Interest categories: None 42. Barron reported the payments as "rent" on his Statement of Financial Interests filed for the year 1990. a. The change in reporting was caused by the County Controller's questioning of the payments. 43. Barron reported the payments he received from Cambria County as income. a. Barron did not consider the payments as "rent ", and applied the funds toward the expenses of the Coroner's Office. b. The funds received from the County did not cover the expenses of the Coroner's Office, causing Barron to expend personal funds to cover office expenses. c. The payments were given to Barron by the commissioners in lieu of the office space that Barron repeatedly requested. II D ISCUS S ION: As Coroner for Cambria County, John W. Barron, hereinafter Barron, was a public official as defined under Act 170 of 1978. 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. Barron, 91 -031 -C Page 14 Since the occurrences in this case transpired before the effective date of Act 9 (June 26, 1989), we must apply the provisions of Act 170 of 1978 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): Moak /McCutcheon v. State Ethics 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 financial interests; Koslow v. State Ethics Commission, 116 Pa. Commw. Ct. 19, 540 A.2d 1374 (1988), allocatur denied, 520 Pa. 609, 553 A.2d 971 (1988). In addition, Section 3(c) of Act 170 of 1978 specifically provides in part that no public official or 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 at fair market value may enter into a contract with his governmental body valued at five hundred dollars or more unless the contract is awarded through an open and public process including prior public notice and subsequent public disclosure. We must determine whether John Barron, as Cambria County Coroner, violated either Section 3(a), the use of office provision, or Section 3(c), the contracting provision, of Act 170 of 1978 regarding the allegation that he solicited and utilized his personal residence as the Cambria County Coroner's Office for which he received compensation in excess of $500 per year. In Cambria County, it was an established practice for the Coroner to have the his office in his personal residence in that the County did not provide any office space. In 1978 when Barron became acting Coroner, he moved the Coroner's office into his personal home which office location changed every time Barron moved to another home. The Coroner's office had to be accessible at all times on a 24 hours a day, 365 days a year basis in that the Coroner's office was the central point of investigations. Cambria County supplied the Coroner's office with certain expenses or equipment: mileage reimbursement, separate telephone line installation with the payment of telephone bills and an answering service, a used copier, a computer, forms and two file cabinets. However, Barron personally supplied the following items for his office: desk, chairs, telephone, file cabinets, computer, Barron, 91 -031 -C Page 15 computer table, paper, pens /pencils, rubber gloves, needles and syringes. After Barron was elected to the Office of Coroner in 1980, he requested the County Commissioners, without success, to provide space for the Coroner's Office. Barron continued making such requests every year thereafter because he believed it was the County's responsibility to provide office space. When Barron attended the annual conventions of the Pennsylvania State Coroner's Association (PSCA), the subject of reimbursement to a coroner for the use of his home as a coroner's office was discussed. The PSCA Solicitor advised that it was appropriate for coroners to request reimbursement from their respective county commissioners for expenses incurred in maintaining coroner's offices in their homes. The Solicitor stated that reimbursable expenses included fuel, equipment, telephone, insurance, furniture, light, and janitorial services. The Solicitor issued a letter that the average monthly reimbursement to coroners was $250 -$300 as to the Forest and Venango Counties. In 1981, the Cambria County Commissioners offered to reimburse Barron $200 a month to defray his expenses in lieu of providing office space. The Commissioners preferred to keep the Coroner's Office in the Coroner's home. Barron accepted the monthly payment based upon the advice given by the PSCA Solicitor. In 1984, the Cambria County Commissioners raised the amount of reimbursement paid to Barron from $200 to $400 per month. That reimbursement remained at $400 per month until 1992 when the County Commissioners moved the Coroner's Office to a separate facility. Barron states that the County Commissioners in 1992 decided to provide space for the Coroner's Office for the following three reasons: the certification of a trauma center increased the workload of the Cambria County Coroner's Office; the County Controller questioned the "rent" payments to Barron so that the designation of the payment was changed from "rent" to "administrative fees "; and the Commissioners became aware of this Commission's investigation of the "rent" payments made to Barron for the use of his home. The PSCA Solicitor, in a letter dated November 20, 1991, stated that county commissioners compensate the coroner for use of his home in 80% of the counties and that county commissioners under Section 508 of the County Code are required to provide space to the coroner which space does not have to be in the courthouse. The Solicitor opined that a coroner does not use the authority of office to secure a financial gain because the county commissioners in paying such expenses are providing benefits which are mandated by law. Barron, 91 -031 -C Page 16 Although the County Code does not require that the coroner's office be maintained at the county seat, Section 508 of the County Code does assign the responsibility for providing office space, equipment and supplies to the county. Section 508(a) states that the commissioners are to designate space for offices not required to be kept in the county courthouse and that the county shall incur the cost of supplying such office space, equipment and supplies. Although Barron was paid rent by Cambria County for the use of his home to provide space for the Coroner's office from 1984 through 1991, the term "rent" was chosen by the County Commissioners and not by Barron. In fact, on April 11, 1991, the minutes of the Cambria County Board of Commissioners reflect a change in terminology from "rent" to "administrative fees" relative to the monthly payments made to the Coroner. Such payments continued until 1992 when the County Commissioners provided space for the Coroner's Office in a Johnstown building. Lastly, since the funds received by Barron from the County did not cover the expenses of the Coroner's Office, Barron expended his own personal funds to cover office expenses. In applying the provisions of Section 3(a) of Act 170 of 1978 to the instant matter, we find no violation for the reason that Barron did not obtain a financial gain in this case. Since the record reflects that the funds received from the County did not cover the expenses of the Coroner's Office which caused Barron to expend his personal funds, he did not receive a financial gain but a loss. Accordingly, Barron did not violate Section 3(a) of Act 170 of 1978. In light of the above, we need not address the questions of whether there was a use of office by Barron or whether the expenses /reimbursements by the County were compensation provided for by law. As to Section 3(c) of Act 170 of 1978, we find no violation of the contracting provision. The facts of record make it clear that there was no contract in this case in that Barron was forced to utilize his personal home as a Coroner's Office since the County refused to provide space even though mandated by the County Code. The facts reflect that there was no agreement between Barron and the County to rent his home for the Coroner's Office. Barron requested office space from the County Commissioners who did not grant Barron's request but instead gave him expenses which were denominated as "rent ". Such "rent" was in reality expense reimbursements. The County Commissioners subsequently changed the designation from "rent" to "administrative fees ". Hence, under the particular facts of this case, there was no agreement or contract but merely the payment of expenses or reimbursements to Barron. Accordingly, there was no violation of Section 3(c) of Act 170 of 1978. Barron, 91 -031 -C Page 17 IV. CONCLUSIONS OF LAW: 1. John Barron, as the Coroner for Cambria County, was a public official subject to the provisions of Act 170 of 1978. 2. Barron did not violate Section 3(a) of Act 170 of 1978 regarding the utilization of his personal residence as the Cambria County Coroner's Office in that he did not obtain any financial gain. 3. Barron did not violate section 3(c) of Act•170 of 1978 as to the utilization of his personal residence as the Cambria County Coroner's Office in that there was no contract between Barron and the County. In Re: JOHN W. BARRON ORDER NO. 990 1. John Barron, as Cambria County Coroner,_ did not violate Section 3(a) of Act 170 of 1978 regarding the utilization of his personal residence as the Cambria County Coroner's Office in that he did not obtain any financial gain. 2. Barron did not violate section 3(c) of Act 170 of 1978 as to the utilization of his personal residence as the Cambria County Coroner's Office in that there was no contract between Barron and the County. File Docket: 91 -031 -C Date Decided: 12/7/95 Date Mailed: 12/15/95 BY THE COMMISSION, e&map/K) atag....i DANEEN E. REESE, CHAIR