HomeMy WebLinkAbout986 BrinkSTATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
In Re: Donald C. Brink File Docket: 94- 036 -C2
Date Decided: 10/26/95
Date Mailed: 11/8/95
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
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 seg.
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 public hearing was held at the request of respondent. 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 thirty 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 thirty 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).
Brink, 94- 036 -C2
Page 2
I. ALLEGATION:
That Donald Brink, a public official /public employee, in his
capacity as a Commissioner for Pike County violated provisions of
the State Ethics Act (Act 9 of 1989) when he participated in the
award of a snow removal contract to a company which sub- contracted
to utilize vehicles owned by him.
65 P.S. §403(a).
65 P.S. §403(f).
Section 3. Restricted Activities
(a) No public official or public
employee shall engage in conduct that
constitutes a conflict of interest.
Section 3. Restricted activities
(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 the
governmental body with which the public
official or public employee is associated or
any subcontract valued at $500 or more with
any person who has been awarded a contract
with the governmental body with which the
public official or public employee is
associated, unless the contract has been
awarded through an open and public process,
including prior public notice and subsequent
public disclosure of all proposals considered
and contracts awarded. In such a case, the
public official or public employee shall not
have any supervisory or overall responsibility
for the implementation or administration of
the contract. Any contract or subcontract
made in violation of this subsection shall be
voidable by a court of competent jurisdiction
if the suit is commenced within 90 days of the
making of the contract or subcontract.
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
Brink, 94- 036 -C2
Page 3
65 P.S. §402.
II. FINDINGS:
A. PLEADINGS:
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.
1. On August 25, 1994, a letter was forwarded to Donald C. Brink,
by the Executive Director of the State Ethics Commission
informing him that a complaint against him was received by the
Investigative Division and that a full investigation was being
commenced.
a. Said letter was forwarded by certified mail, No. P 016
239 421, return receipt requested.
b. The domestic return receipt bore the signature of Joan
Brink, with a delivery date of August 29, 1994.
2. The investigative complaint' was mailed to the Respondent's
Counsel on February 21, 1995.
3. Donald C. Brink served as a Pike County Commissioner from 1983
to 1987 and from January of 1992 to the present.
a. Brink served as Chairman of the Pike County Board of
Commissioners from January of 1994 to December of 1994.
4. The property on which Brink Excavating is located is owned by
Donald C. Brink and his wife, Joan.
a. The company maintains an office in Brink's residence at
that location.
5. The company telephone, number 717 - 296 -7650, is located in the
residence of Donald C. and Joan Brink.
Brink, 94- 036 -C2
Page 4
6. Records on file at the Department of State, Corporation
Bureau, indicate Brink Excavating Company, a.k.a. Brink
Incorporated, is a registered corporation in the Commonwealth
of Pennsylvania.
a. Brink Incorporated was incorporated on September 29,
1978, by Donald Brink, R.D. #1, Box 305 [sic], Milford,
PA.
7. Stock certificates in the possession of John Klemeyer,
attorney for Dennis Brink, reflect a stock certificate in the
name of Dennis Brink, for 50 shares and a stock certificate in
the name of Joan Brink, for 50 shares.
a. Dennis Brink is the son of Donald Brink.
b. Joan Brink is the wife of Donald Brink.
8. Dennis Brink and Donald Brink assert that ownership of Brink,
Inc., was transferred to Dennis and Joan Brink in 1991.
a. No changes were recorded with the Commonwealth of
Pennsylvania, Bureau of Corporation.
b. No money was exchanged in this transaction.
9. The equipment, including the trucks, front end loader,
bulldozer and tractor trailer used by Brink Excavating are
owned by Donald C. Brink.
10. Dennis Brink and Donald Brink assert that Brink, Inc., pays
$1,500.00 per month to Donald Brink for the use of equipment
including trucks and a front end loader.
11. Statements of Financial Interest filed by Donald C. Brink on
January 22, 1992 for the calendar year 1991, on January 22,
1993 for the calendar year 1992, and on May 1, 1994 for the
calendar year 1993, contain the following information:
a. In Section 8, Occupation or Profession, Brink lists
"Contractor ".
b. In Section 11, Direct or Indirect Sources of Income,
Brink lists "Brink Excavating, RD 1, Box 315, Milford, PA
18337."
c. In Section 14, Office, Directorship, or Employment In Any
Business Brink lists "Brink Excavating" with Position
Held "Part Owner ".
d. Under Business Interests Transferred to Immediate Family
Member Brink states "None ".
Brink, 94- 036 -C2
Page 5
12. As to the policy of the Pike County Commissioners to make
purchases or to contract for services:
a. All purchases or contracts ranging from $4,000 to $10,000
are made only after obtaining 3 telephonic price quotes.
b. All purchases or contracts exceeding $10,000 are made
through the bidding process.
13. In the calendar years 1993 and 1994 Jagger Asphalt Paving was
selected by Commissioner Brink to remove snow from County
property.
a. Brink did not ascertain the cost of the snow removal
prior to the contract being awarded.
14. The agreement entered into between Brink and Jagger was not
awarded through the use of telephone price quotes or the
bidding process.
15. Brink arranged with the Delaware River Joint Toll Bridge
Commission and the US Park Service for permission to dump the
snow on Bridge Commission and Park Service property.
16. Jagger Asphalt Paving, PO Box 1006, Dingmans Ferry, PA 18328,
Phone 717 - 828 -9447, is owned by Ronald Jagger, RR #1, Box
134C, Birchwood Lakes, Dingmans Ferry, PA.
17. Brink has known Ronald Jagger for approximately 30 years.
a. Brink and Jagger have had prior business relationships.
18. Jagger submitted the following invoices to Pike County for
snow removal:
1993
a. Undated
Snow Removal Load and Haul Off
February 25, 1993
6 1/2 hrs back hoe
6 1 /2 hrs truck #1
6 1/2 hrs truck #2
March 3, 1993
4 1 /2 hrs back hoe
4 / hrs truck #1
@ 65.00 $422.50
@ 50.00 $325.00
@ 50.00 $325.00
@ 65.00 $292.50
@ 50.00 $225.00
$1590.00
Brink, 94- 036 -C2
Page 6
(The invoice contained the handwritten notation "OK
DCB ".)
b. Undated
Snow Removal Co Complex
March 15, 1993
March 16, 1993
January, 10, 1994
14 hrs backhoe @ 65.00 $910.00
14 hrs truck #1 @ 50.00 $700.00
10 % hrs truck #2 @ 50.00 $525.00
6 % hrs labor @ 12.00 $ 78.00
6 hrs backhoe @ 65.00 $390.00
6 hrs truck #1 @ 50.00 $300.00
6 hrs truck #2 @ 50.00 $300.00
$3,203.00
(The invoice contained the handwritten notation "OK
DCB ".)
TOTAL FOR 1993 $4,793.00
1221
a. Date: January 12, 1994
Snow Removal Load and Haul Off Co. Complex
January 9, 1994
6 hrs truck #1
6 hrs truck #2
6 hrs loader
9 V hrs truck #1
9 % hrs truck #2
9 % hrs loader
[7] hrs labor
@ 50.00 $300.00
@ 50.00 $300.00
@ 65.00 $390.00
@ 50.00 $475.00
@ 50.00 $475.00
@ 65.00 $617.50
@ 12.00 $ 84.00
$2,641.50
(The invoice contained the handwritten notation "Centra
T. Quinn ".)
Brink, 94- 036 -C2
Page 7
b. Date: January 26, 1994
Snow Removal Load and Haul Off Co. Complex
January 18, 1994
January 19, 1994
January 21, 1994
5 hrs truck #1
5 hrs loader
5 hrs labor
10 hrs truck #1
10 hrs truck #2
10 hrs loader
10 hrs truck #1
5 hrs truck #2
10 hrs loader
c. Date: February 14, 1994
Snow Removal Load and Haul Off Co. Complex
Sanding January 29 & 30th
February 6, 1994
9 hrs loader
8 hrs truck #1
6 hrs truck #2
@ 50.00 $250.00
@ 65.00 $325.00
@ 12.00 $ 60.00
@ 50.00 $500.00
@ 50.00 $500.00
@ 65.00 $650.00
@ 50.00 $500.00
@ 50.00 $250.00
@ 65.00 $650.00
$3,685.00
$235.00
@ 65.00 $585.00
@ 50.00 $400.00
@ 50.00 $300.00
$1,520.00
d. Date: February 22, 1994
Snow Removal Load and Haul Off Co. Complex
February 16, 1994
6 % hrs loader @ 65.00 $422.50
6 % hrs truck #1 @ 50.00 $325.00
February 17, 1994
7 hrs loader @ 65.00 $455.00
7 hrs truck #1 @ 50.00 $350.00
Brink, 94- 036 -C2
Page 8
e. Date: March 8, 1994
Snow Removal Load and Haul Off Co. Complex
March 5, 1994
March 6, 1994
a. 11295 - 3/11/93
b. 11621 - 4/1/93
c. 15966 - 1/20/94
d. 16202 - 2/3/94
e. 16464 - 2/17/94
f. 16657 - 3/3/94
6 hrs loader
6 hrs truck #1
No Date
No Date
1/12/94
1/26/94
2/14/94
2/22/94
$1,552.50
@ 65.00 $390.00
@ 50.00 $300.00
1 hr loader push off dump site $ 65.00
6 1 / hrs loader @ 65.00 $422.50
6 1 /2 hrs truck #1 @ 50.00 $325.00
$1,502.50
TOTAL FOR 1994 $10,901.50
19. Jagger was paid a total of $4793.00 in 1993 and $10,901.50 in
1994 by Pike County for the snow removal work.
20. Centra T. Quinn held the position of Clerk to the County
Commissioners from 1958 to 1994.
a. Quinn's signature on the invoices indicate her
involvement in the bill paying process for the County.
b. Quinn was not involved in hiring Jagger Asphalt Paving to
remove the snow.
21. Truck #2 referred to on Jagger Asphalt Company's invoices is
owned by Donald C. Brink.
a. Truck #2 has a license plate No. 91010 CB.
b. This vehicle is registered to Donald C. Brink.
22. Pike County records confirm the following County checks were
used to compensate Ronald Jagger for the snow removal work:
Check Number Jagger Invoice Date
And Date
Brink, 94- 036 -C2
Page 9
g. 16850 - 3/10/94 3/08/94
23. Pike County records and minutes of Commissioners meetings
indicate Commissioner Brink took the following action in
reference to the approval of payments of Jagger Asphalt
Company bills:
Date Check Action Taken By Signature
Approved Number Amount Commissioner Brink On Check
3/11/93 11295 $ 1,590.00 2nd Motion, Voted Yes
4/01/93 11621 $ 3,203.00 2nd Motion, Voted Yes
1/20/94 15966 $ 2,641.50 Voted Yes
2/03/94 16202 $ 3,685.00 Voted Yes
2/17/94 16464 $ 1,520.00 Voted Yes
3/10/94 16657 $ 1,552.50 Voted Yes
3/10/94 16850 $ 1,502.50 Voted Yes
TOTAL $15,694.50
24. Listings of bills are presented to the County Commissioners
prior to the Commissioners meeting along with a cover letter
which the Commissioners signed, indicating their approval of
payment of the bills.
a. Brink received these lists prior to taking action in
regards to the bills.
25. Jagger billed Pike County as follows:
a. November 24, 1993
Parking Lot as per contract $3,500.00
(DB Centra Quinn)
b. November 24, 1993
Haul away debris from storage
shed area $ 150.00
26. Payment for services outlined above were made as follows:
pate
Check No. Amount Brink Action Signature on Check
12/2/93 15177 $3,650.00 2nd Motion, Voted Yes
27. The checks made payable to Jagger Asphalt Paving were
deposited into Jagger's account at the LA Bank of Lake Ariel.
28. LA Bank of Lake Ariel records indicate that on March 6, 1994,
Ronald Jagger, owner of Jagger Asphalt Paving, wrote check
number 2543, from the company's account, number 762276114, in
Brink, 94- 036 -C2
Page 10
the amount of $3,500.00, to Brink Incorporated.
29. Check Number 2543 contained the endorsement "Brink Inc" and
was deposited in Brink Incorporated's account at the Mellon
bank.
30. Jagger Asphalt Paving used Brink Excavating as a subcontractor
on three other occasions during 1992, 1993 and 1994.
31. Brink Excavating submitted invoices for payment to Jagger
Asphalt Paving for the work performed on those 3 occasions.
32. There were no invoices prepared by Brink Excavating for Jagger
Asphalt Paving's use of Brink's truck when used for the snow
removal from Tioga [sic] County property.
B. STIPULATIONS:
33. On June 27, 1994, the Investigative Division of the State
Ethics Commission received a signed, sworn complaint alleging
that Donald C. Brink violated provisions of the State Ethics
Act.
34. Upon review of the complaint by the Director of Investigations
a recommendation was made to the Executive Director to
commence a preliminary inquiry.
35. At the direction of the Executive Director, the Investigation
Division initiated a preliminary inquiry on June 28, 1994.
36. The preliminary inquiry was completed within sixty days.
37. The full investigation was commenced at the direction of the
Executive Director of the State Ethics Commission.
38. Joan Brink would testify that Dennis Brink told her that he
had lent a truck to Ronald Jagger but did not tell her the
purpose for which he lent the truck to him.
39. James Lighty is a general contractor who, since 1990, has
employed Brink, Inc. to do excavating work.
a. Lighty was involved with representatives of Brink, Inc.
as to his jobs.
b. Lighty had no involvement with Donald Brink.
c. Based upon Mr. Lighty's observations as to his
corporation's employing Brink, Inc., since 1990, Lighty
has never contacted Donald Brink, and all of his contacts
have been with Dennis Brink.
Brink, 94- 036 -C2
Page 11
C. TESTIMONY:
(1) Lighty has never seen Donald Brink on any job site.
(2) Lighty has never seen Donald Brink operating in any
supervisory capacity of Brink, Inc.
(3) All bills forwarded by Mr. Lighty's corporation to
Brink, Inc., were addressed to Brink, Inc.
(4) All invoices received for work done since 1990 were
from Brink, Inc.
(5) To the best of Lighty's knowledge, information and
belief based upon his business dealings with Dennis
Brink, Dennis Brink is the President and controls
the corporation.
40. Donald G. Quick is a part -time police officer in Milford, Pike
County.
a. On 1/21/94, Quick was on regular duty patrol from 8:00
p.m. to 4:00 a.m. of the following morning.
(1) Quick worked with Police Chief Gary Williams whose
shift was from 4:00 p.m. to 12:00 midnight.
(2) At some point after 8:50 p.m., Williams and Quick
were patrolling near the Pike County Courthouse.
(a) Quick observed snow removal operations in the
courthouse parking areas.
(b) An old red International Dump Truck, which
Quick believed was owned by Brink, was used in
the snow removal operation.
[1] The dump truck had a Jagger Construction
placard.
[2] A license check indicated that the truck
was registered as owned by Brink or Brink
Construction.
[3] Exhibits 13A -E are photographs which
Quick took of the dump truck on the
evening of 1/21/94.
[4] The truck's Pennsylvania license tag
number is 91010 -CB.
Brink, 94- 036 -C2
Page 12
(c) A Case Backhoe was also being used in the snow
removal operation.
41. Gary Williams is the Milford Police Chief having served in
that capacity since June, 1988.
a. Williams has known Donald Brink, his wife, Joan Brink,
and his son, Dennis Brink, for approximately 25 years.
b. Williams has known Robert Raser for more than five years.
c. During the evening of 1/21/94, Williams was on duty with
Corporal Quick.
(1) While on patrol, Williams observed snow removal
operations at the courthouse.
(a) Williams saw a backhoe and a dump truck with a
Jagger decal on the doors.
[1] The dump truck was recognized by Williams
as a Brink truck.
[2] A few days earlier, Williams had observed
the truck without the decals on the
doors.
[3] A license check indicated that the truck
was owned by Brink.
[4] The backhoe was operated by Robert Raser.
42. Harry Forbes is a Milford resident and businessman.
a. Forbes is currently a Milford Township Supervisor.
b. During the evening of 1/21/94, Forbes met with Chief
Williams and Corporal Quick and discussed the snow
removal operation at the County offices.
(1) Forbes observed a backhoe and a red Brink dump
truck which had a Jagger sign on the door.
(2) Forbes observed that Raser was operating the
backhoe.
(3) On several subsequent occasions, Forbes observed
snow removal operations at the courthouse with the
same dump truck and backhoe.
(a) On one such occasion after January 21, 1994,
during the daytime, Forbes observed Donald
Brink, 94- 036 -C2
Page 13
Brink and Raser behind the courthouse when
snow was being removed using the Brink dump
truck.
[1] The Brink truck bore the Jagger sign at
that time.
43. Sally Thomson is a Pike County Commissioner, having served in
that capacity since January, 1992.
a. A county commissioner oversees the operation,
administration and functioning of the county.
(1) Pike County bills are reviewed at public meetings
and paid as a group of bills.
(2) Pike County contracts of $4,000 or more require at
least three telephonic bids.
(3) Pike County contracts of $10,000 or more require
bid solicitation with specifications.
(4) For Pike County contracts under $4,000, the
criteria are to consider the service and the
availability of people to do the job.
(5) For snow removal, maintenance and similar matters
reliance was placed upon Brink to arrange such
matters.
(a) Brink would review such matters and report to
the County Board of Commissioners.
(b) As to any emergency service, Brink would take
care of such matters.
(c) Brink was in charge of snow removal and
maintenance matters.
(d) Thomson never contacted Jagger.
(e) Thomson was not aware of any instance where
Commissioner Jonas contacted Jagger.
(f) The only involvement of Thomson in snow
removal was voting on the bills.
(g) Both Thomson and Jonas voted to pay the bills
of Jagger.
(h) Brink had the responsibility to insure that
the work was done as to contracts.
Brink, 94- 036 -C2
Page 14
44. Margaret Jonas has been a Pike County Commissioner for the
last eight years.
a. The County Commissioners run the daily business of the
County.
b. There are contracting requirements for the County.
(1) Contracts of $10,000.00 or more must be advertised
for bid.
(2) Contracts between $4,000.00 and $10,000.00 require
obtaining three telephonic proposals.
(3) Contracts below $4,000.00 are dealt with in
executive sessions or workshops.
(4) For snow removal, the Commissioners will have a
discussion and Brink will hire the contractor.
(a) Brink oversees the work..
(b) Brink reports to the Commissioners.
(5) Bills for services rendered are provided to the
Commissioners who vote to approve such bills.
c. Jonas was aware that Jagger was hired to remove snow from
the County property.
d. Jonas voted with the unanimous board to pay Jagger's
bills.
e. Jonas was not aware that Brink's truck was used in the
snow removal operations for the County.
45. Joan Brink is the spouse of Donald Brink.
a. Joan Brink is the secretary /treasurer of Brink, Inc.
(1) Brink, Inc. was incorporated in 1978 but was not
activated until about 1990/91.
(2) The Articles of Incorporation were signed by Donald
Brink.
(a) Donald Brink was the sole incorporator.
(b) The corporation had the authority to issue 100
shares.
(c) 100 shares were subscribed to Donald Brink.
Brink, 94- 036 -C2
Page 15
(3) As of 2/17/95, Dennis Brink and Joan Brink are both
registered as holding 50 shares each of Brink, Inc.
(4) Brink, Inc.'s business checking account was
established on 9/04/90.
(a) Donald Brink had signature authority on the
account until February 17, 1995.
(b) Effective 2/17/95, a new signature card was
executed for the account, listing Dennis Brink
as president and Joan Brink as
secretary /treasurer.
El] This change occurred on the same day that
stock certificates were issued to
register 50 shares each to Joan and
Dennis Brink.
(c) Joan Brink stated that she and Dennis Brink
were the sole owners of Brink, Inc. since its
activation in 1990.
(5) Raser was an employee of Brink, Inc.
(a) From 1/94 to 6/94, Raser was paid for 40 hours
each week.
(6) Various telephone directories for 1993 - 1996 have
a listing for Donald Brink, Contractor at Brink,
Inc.'s telephone number, 296 -7650.
(7) Brink, Inc., leases trucks from Donald Brink at
$1,500.00 per month.
(a) The insurance, licensing and registration fees
for the trucks are paid by Brink, Inc.
(b) Checks dated 9/30/94, 11/30/94, and 05/31/94
to Brink are only in the amount of $1,000.00.
(8) The 1990 through 1992 corporate income tax returns
for Brink, Inc. list Joan and Dennis Brink as each
holding 50% of the common stock of Brink, Inc.
(a) The rental payments received by Donald Brink
are reported on the joint personal income tax
return of Donald and Joan Brink.
(9) For Brink, Inc., Joan Brink does the bookkeeping
and Dennis Brink makes all the business contacts.
Brink, 94- 036 -C2
Page 16
(10) Brink has not signed any checks of Brink, Inc.
(11) John Klemeyer is the attorney for Brink, Inc.
(a) In 1990 Joan Brink went to Kleymeyer's office
and asked him to issue the shares of stock to
Joan and Dennis Brink.
(12) Brink, Inc. stores equipment on the tract of land
where Joan and Donald Brink have their home.
(13) Joan Brink states that Donald Brink has no
involvement with the operation and management of
Brink, Inc.
(14) Brink, Inc.'s normal business activity does not
include renting or leasing equipment to others.
46. Ronald Jagger is a businessman in the asphalt paving business.
a. Jagger has done snow removal work for Pike County.
(1) Jagger testified that he was called by the
Commissioner's Office to remove snow at the Pike
County complex in February and March, 1993.
(2) From January through March, 1994, Jagger also
performed snow removal operations for Pike County.
(a) Jagger asserts that he borrowed a Brink, Inc.
truck for the snow removal.
(b) Exhibit 8 consists of bills for Jagger's work
for the Pike County Commissioners from
February 25, 1993 through March 6, 1994.
(1) The bills reflect snow removal operations
on 14 days.
(2) The Brink truck is indicated on the bills
as Truck #2.
(3) The Brink truck was used on 8 of the 14
days of snow removal, specifically:
2/25/93; 3/15/93; 3/16/93; 1/9/94;
1/10/94; 1/19/94; 1/21/94; and 2/6/94.
c. Exhibit 10 reflects checks by Jagger in payment to Brink,
Inc. for the usage of Brink, Inc. equipment on jobs.
(1) Check #2543 dated 3/06/94 from Jagger to Brink,
Inc. is in the amount of $3,500.00.
Brink, 94- 036 -C2
Page 17
(a) Jagger claims the check was for the usage of a
Brink, Inc. truck that Jagger borrowed and
used at different times on jobs including the
snow removal work.
[1] Jagger states that he has no invoices
from Brink, Inc. for the truck usage but
he does have invoices from Brink, Inc.
for all other transactions.
d. Brink gave Jagger instructions as to the snow removal
process at the Pike County Courthouse property.
e. As to the snow removal operation at the Pike County
Courthouse, Jagger asserts that Raser helped him one time
by driving a backhoe.
(1) Jagger testified that he gave Raser coffee money.
f. Jagger asserts that Raser was not an employee on loan
from Brink, Inc.
g .
j.
There have been business dealings between Jagger and
Brink, Inc.
(1) Jagger states his business dealings were with
Dennis Brink.
h. The front end loader Jagger used for the County snow
removal was his own.
i. Jagger testified that he decided on the amount of the
check he would give Brink, Inc. for the "borrowed" truck.
Jagger asserts that Brink, Inc. was not a subcontractor
of Jagger for the county snow removal operation.
k. Jagger claims that he put the Jagger Asphalt sign on the
Brink, Inc. truck so that he would be permitted to dump
the county snow in the designated location.
1. Jagger states that he talked to Dennis Brink, not Donald
Brink, about "borrowing" the truck.
m. Jagger testified that he "borrowed" the truck from Dennis
Brink on a few occasions prior to 1993, based upon the
relationship Jagger had with Dennis Brink.
47. John H. Klemeyer is an attorney and partner in the firm of
Beecher, Wagner, Rose and Klemeyer.
a. Brink, Inc. is a client of the firm.
Brink, 94- 036 -C2
Page 18
b. Klemeyer handled the incorporation of Brink, Inc. in the
1970's but was not involved in the activation of the
corporation in 1990.
(1) Share certificates of Brink, Inc. were issued on
2/17/95.
(a) To Klemeyer's knowledge, these were the only
shares ever issued.
(b) These share certificates were issued for
original shares rather than shares transferred
from a prior owner.
(c) No shares were issued to Donald Brink.
(2) Only 100 shares of Brink, Inc. were authorized.
c. In the legal opinion of Klemeyer, an incorporator does
not have to be a shareholder.
d. When Klemeyer incorporated Brink, Inc., he was advised by
Brink not to activate the corporation.
48. James McGrath is a special investigator for the State Ethics
Commission.
a. Dennis Brink and Jagger were interviewed by McGrath on
2/14/95.
(1) Three days after these interviews, Brink, Inc.
stocks were issued in the names of Joan and Dennis
Brink and the corporate checking account signature
cards were changed to eliminate Donald Brink as an
authorized signatory.
49. Robert E. Raser is a salaried employee of Brink, Inc.
a. Raser states that he helped Jagger with snow removal at
the County complex on only one occasion.
(1) Raser asserts that he did the work on his own time
and was not compensated by Brink, inc.
(2) Regarding the snow removal operations at the Pike
County Courthouse on 1/21/94, Raser testified that
he volunteered his time and did not work for Jagger
but that Jagger "tucked a couple dollars in . . .
[his] work shirt that night."
50. Dennis Lee Brink is the president of Brink, Inc.
Brink, 94- 036 -C2
Page 19
a. Respondent's Exhibit 3 reflects that in 1990, Dennis and
Joan Brink were each 50% shareholders of Brink, Inc.
b. Dennis Brink states that his father, Donald Brink, has
had no involvement with Brink, Inc. since 1990.
c. Brink, Inc. stores equipment on property owned by Donald
and Joan Brink.
d. Dennis Brink asserts that Jagger "wanted to borrow a
truck" at a point in time during the winter of 1993/94.
g.
(1) Dennis Brink claims that there was no lease of the
truck to Jagger.
(2) Dennis Brink states that Jagger borrowed a truck on
one occasion prior to 1993.
(3) Dennis Brink states that when Raser assisted Jagger
in snow removal from County property, he did not do
such as a Brink, Inc. employee.
(4) Dennis Brink testified that he did not request a
payment from Jagger for the use of the truck.
e. Jagger gave a check in the amount of $3,500.00 to Dennis
Brink for Jagger's use of the truck.
(1) Dennis Brink claims the $3,500.00 was an "after the
fact" payment by Jagger because Jagger "used the
truck more than he anticipated."
(2) Dennis Brink testified that he did not submit any
invoice from Brink, Inc. to Jagger for the use of
the truck.
f. Brink, Inc. pays Donald Brink $1,500.00 per month rental
for Brink's trucks.
(1) There is no written lease agreement as to the
trucks.
Brink, Inc. normally would charge $60.00 an hour for
trucking which would include both the use of the truck
and an operator.
h. Exhibit 15A reflect that Dennis Brink received 50 shares
of Brink, Inc. on 2/17/95.
i. Dennis Brink states that when he became president of
Brink, Inc. in 1990, Donald Brink retained ownership of
the trucks and did not transfer them to Brink, Inc. due
Brink, 94- 036 -C2
Page 20
j•
g.
to tax considerations.
Dennis Brink states that Brink, Inc. does not normally
lease vehicles to others to use.
k. The normal business operation of Brink, Inc. is
excavation.
(1) Brink, Inc. does work for general contractors in
Pike County.
51. Donald Brink (Brink) is a Pike County Commissioner.
a. When Brink's term expires at the end of 1995, he will not
seek reelection.
b. Brink is the spouse of Joan Brink and the father of
Dennis Brink.
c. Brink testified as follows as to Statements of Financial
Interests (FIS's) that he filed for calendar years 1991,
1992 and 1993:
(1) Although he listed himself as a contractor, he was
not a contractor.
(2) Section 8, which lists Brink's occupation as
contractor and Section 14, which lists Brink as
part owner of Brink Excavating, are inaccurate.
(3) Brink does not know why Sections 8 and 14 were
inaccurate.
(4) Brink signed the FIS's subject to statutory
penalties for unsworn falsification to authorities.
d. As to Brink, Inc., Brink states he received rental income
from equipment he leases to Brink, Inc.
e. Brink organized Brink, Inc.
(1) Brink asserts he has no stock or ownership interest
in Brink, Inc.
f. Brink states that during the winters of 1993 and 1994, he
did not know that Jagger was using a truck owned by Brink
that was leased to Brink, Inc. for removing snow from
Pike County property.
Brink testified that Jagger was hired by the county
commissioner's office to remove snow from county
property.
Drink, 94- 036 -C2
Page 21
h. Brink states that during the Spring of 1994, he was not
aware that Jagger issued a check to Brink, Inc. for the
use of a truck "borrowed" from Brink, Inc.
i. Brink received $1,500.00 per month from Brink, Inc. which
business is operated out of Brink's home.
The bank signature card for the corporate account of
Brink, Inc., dated 9/04/90, lists Brink as a current
customer.
52. Edward Schafer is a public accountant in Matamoras,
Pennsylvania.
a. Schafer has been an accountant for 25 years and renders
services such as completing corporate and individual tax
returns, financial statements and payroll processing
reports.
b. In July, 1990, Schafer was contacted to reactivate Brink,
Inc.
c. The SS -4 application for a Federal employer ID number
lists Joan Brink as the secretary /treasurer of Brink,
Inc.
d. In a workman's compensation insurance audit of Brink,
Inc. prepared by Schafer (Respondent's Exhibit 2), Joan
Brink is listed as secretary /treasurer and Dennis Brink
is listed as president of Brink, Inc.
e. As to the application for a Pennsylvania unemployment
number prepared by Schafer's office (Respondent's Exhibit
3), Dennis and Joan Brink are listed as each owning 50%
of Brink, Inc.
f. Respondent's Exhibits 4 through 6 are the 1990 through
1993 corporate federal income tax returns of Brink, Inc.
(1) On the 1990 - 1992 returns, Dennis and Joan Brink
are listed as the owners of the corporation, with
each owning 50% of the stock.
(2) The tax returns were filled out by Schafer's office
and filed with the IRS.
(3) The 1993 U.S. Corporate Tax Return for Brink, Inc.
(Respondent's Exhibit 7) does not list any names on
Schedule E.
(4) Schafer states that Brink was not involved in the
preparation of these returns.
Brink, 94- 036 -C2
Page 22
g.
Schafer is not aware of any involvement of Brink in
Brink, Inc. from July, 1990 to the present.
h. According to Schafer, Brink has not received any
dividends, salary or wages from Brink, Inc.
(1) The only income to Brink from Brink, Inc. which was
reported was for his rental of equipment to the
corporation.
i. The rent Brink, Inc. pays to Brink is reflected on line
16 of the corporate tax returns.
(1) Shafer states that the rental income was to be
$2,000.00 per month, not $1,500.00 per month.
Brink, Inc. paid for the insurance on the equipment owned
by Brink.
D. DOCUMENTS:
53. The Statements of Financial Interests (FIS's) of Brink for the
calendar years 1991 -93, Exhibit 5, reflect "Brink Excavating,
RD 1, Box 315, Milford, PA 18337" as a direct or indirect
source of income in block 11.
a. In block 14, labeled "Office, Directorship or Employment
in any business," "Brink Excavating" is listed as the
business entity and "Part Owner" is indicated as the
position held.
b. For block 8 as to Brink's Occupation or Profession,
"Contractor" is listed.
54. Exhibit 6 consists of copies of official records from the
Commonwealth of Pennsylvania, Department of Transportation.
a. Pennsylvania license tag number 91010CB is registered as
covering a 1973 International Truck owned by Donald
Brink, Box 315, Milford, PA 18337.
55. Exhibit 8 consists of photocopies of invoices from Jagger
Asphalt Paving to the Pike County Commissioners.
a. Invoice number 11295 lists a total charge in the amount
of $1590 for snow removal for the County on February 25,
1993 and March 3, 1993.
(1) Truck #2 is billed for 6 -1/2 hours at $50.00 per
hour for a total of $325.00 on February 25, 1993.
Brink, 94- 036 -C2
Page 23
b. Invoice number 11621 reflects a total charge in the
amount of $3,203 for snow removal at the County complex
on March 15, 1993 and March 16, 1993.
c. Two invoices both numbered 15177 and dated November 24,
1993, do not involve snow removal services.
d. Invoice number 15966 dated January 12, 1994 reflects a
total charge in the amount of $2,641.50 for snow removal
and hauling on January 9, 1994 and January 10, 1994.
(1) Truck #2 is billed for 6 hours at $50.00 per hour
for a total of $300.00 on January 9, 1994, and for
9 -1/2 hours at $50.00 per hour for a total of
$475.00 on January 10, 1994.
e. Invoice number 16202 dated January 26, 1994, lists a
total charge in the amount of $3,685 for snow removal and
hauling at the County complex on January 18, 1994,
January 19, 1994 and January 21, 1994.
g-
(1) Truck #2 is billed for 10 -1/2 hours at $50.00 per
hour for a total of $525.00 on March 15, 1993, and
for 6 hours at $50.00 per hour for a total of
$300.00 on March 16, 1993.
(1) Truck #2 is billed for 10 hours at $50.00 per hour
for a total of $500.00 on January 19, 1994, and for
5 hours at $50.00 per hour for a total of $250.00
on January 21, 1994.
f. Invoice number 16464 dated February 14, 1994 reflects a
charge in the amount of $1,520 for sanding, snow removal
and hauling at the County complex on January 29, 1994,
January 30, 1994 and February 6, 1994.
(1) Truck #2 is billed for 6 hours at $50.00 per hour
for a total of $300.00 on February 6, 1994.
Invoice number 16657 dated February 22, 1994, reflects a
total charge of $1,552.50 for snow removal and hauling at
the County complex on February 16, 1994 and February 17,
1994.
(1) There is no indication of any use of Truck #2 on
this invoice.
h. Invoice number 16850 dated March 8, 1994, lists a total
charge in the amount of $1,502.50 for snow removal and
hauling at the County complex on March 5, 1994 and March
6, 1994.
Brink, 94- 036 -C2
Page 24
(1) There is no indication of any use of Truck #2 on
this invoice.
56. Exhibit 10 are photocopies of three invoices from Brink,
Inc. Excavating to Jagger Asphalt Paving and four checks
issued by Jagger Asphalt Paving to Brink, Inc.
a. Brink, Inc. invoice
references a job site
dozer, truck and labor
17, 1992 in the total
dated November
of Wild Acres,
on November 16,
amount of $1,050
30, 1992, which
bills Jagger for
1992 and November
.00.
(1) Check number 1970 dated December 22, 1992
issued by Jagger Asphalt Paving payable to
Brink, Inc. is in the amount of $1,050.00.
b. Brink, Inc. invoice dated August 7, 1993, which
references a job site of School Route 739, bills Jagger
for a dozer and labor on August 6, 1993 and August 7,
1993 in the total amount of $1,775.00.
(1) Check number 2235 dated August 7, 1993 issued
by Jagger Asphalt Paving payable to Brink,
Inc. is in the amount of $1,775.00.
c. Brink, Inc. invoice dated April 27,
references a job site of Driveway -Gold Rey
Jagger for machines and installing culvert
driveway on April 26, 1994 and April 27
total amount of $2,000.00.
1994, which
Fernino, bills
pipe for a new
, 1994 in the
(1) Check number 2606 dated April 27, 1994 issued
by Jagger Asphalt Paving payable to Brink,
Inc. is in the amount of $2,000.00.
d. Check number 2543 dated March 6, 1994 issued by Jagger
Asphalt Paving payable to Brink, Inc. is in the amount of
$3,500.00.
(1) There is no corresponding invoice of record
from Brink, Inc. to Jagger Asphalt Paving.
57. Exhibit 12 A is a photocopy of the minutes of the March 11,
1993 meeting of the Board of the Pike County Commissioners
which reflect, in part, a motion, seconded by Brink, to
approve the payment of county bills in the amount of
$115,429.04 which motion passed unanimously with Thomson,
Brink and Jonas voting.
a. The county bills list includes a payment to Jagger
Asphalt & Paving in the amount of $1,590.00 by check
number 011295 dated March 11, 1993.
Brim, 94- 036 -C2
Page 25
b. Exhibit 12 A, page 5 is a photocopy of the negotiated
check from Pike County to Jagger Asphalt and Paving,
which check is co- endorsed by Brink, Jonas and Thomson as
County Commissioners.
58. Exhibit 12 B is a photocopy of the minutes of the April 1,
1993 meeting of the Board of the Pike County Commissioners
which reflect, in part, a motion, seconded by Brink, to
approve the payment of county bills in the amount of
$127,560.85 which motion passed unanimously with Thomson,
Brink and Jonas voting.
a. The county bills list includes a payment to Jagger
Asphalt & Paving in the amount of $3,203.00 by check
number 011621 dated April 1, 1993.
b. Exhibit 12 B, page 4 is a photocopy of the negotiated
check from Pike County to Jagger Asphalt and Paving,
which check is co- endorsed by Brink, Jonas and Thomson as
County Commissioners.
59. Exhibit 12 C is a photocopy of the minutes of the December 2,
1993 meeting of the Board of the Pike County Commissioners
which reflect, in part, a motion, seconded by Brink, to
approve the payment of county bills in the amount of
$113,259.88 which motion passed unanimously with Thomson,
Brink and Jonas voting.
a. The county bills list includes a payment to Jagger
Asphalt & Paving in the amount of $3,650.00 by check
number 015177 dated December 2, 1993.
b. Exhibit 12 C, page 4 is a photocopy of the negotiated
check from Pike County to Jagger Asphalt and Paving,
which check is co- endorsed by Brink, Jonas and Thomson as
County Commissioners.
60. Exhibit 12 D is a photocopy of the minutes of the January 20,
1994 meeting of the Board of the Pike County Commissioners
which reflect, in part, a motion to approve the payment of
county bills in the amount of $28,740.10 which motion passed
unanimously with Thomson, Brink and Jonas voting.
a. The county bills list includes a payment to Jagger
Asphalt & Paving in the amount of $2,641.50 by check
number 015966 dated January 20, 1994.
b. Exhibit 12 D, page 4 is a photocopy of the negotiated
check from Pike County to Jagger Asphalt and Paving,
which check is co- endorsed by Brink, Jonas and Thomson as
County Commissioners.
Brink, 94- 036 -C2
Page 26
61. Exhibit 12 E is a photocopy of the minutes of the February 3,
1994 meeting of the Board of the Pike County Commissioners
which reflect, in part, a motion to approve the payment of
county bills in the amount of $66,937.75 which motion passed
unanimously with Thomson, Brink and Jonas voting.
a. The county bills list includes a payment to Jagger
Asphalt & Paving in the amount of $3,685.00 by check
number 016202 dated February 3, 1994.
b. Exhibit 12 E, page 4 is a photocopy of the negotiated
check from Pike County to Jagger Asphalt and Paving,
which check is co- endorsed by Brink, Jonas and Thomson as
County Commissioners.
62. Exhibit 12 F is a photocopy of the minutes of the February 17,
1994 meeting of the Board of the Pike County Commissioners
which reflect, in part, a motion to approve the payment of
county bills in the amount of $106,574.03 which motion passed
unanimously with Thomson, Brink and Jonas voting.
a. The county bills list includes a payment to Jagger
Asphalt & Paving in the amount of $1,520.00 by check
number 016464 dated February 17, 1994.
b. Exhibit 12 F, page 4 is a photocopy of the negotiated
check from Pike County to Jagger Asphalt and Paving,
which check is co- endorsed by Brink, Jonas and Thomson as
County Commissioners.
63. Exhibit 12 G is a photocopy of the minutes of the March 10,
1994 meeting of the Board of the Pike County Commissioners
which reflect, in part, a motion to approve the payment of
county bills in the amount of $172,013.73 which motion passed
unanimously with Thomson, Brink and Jonas voting.
a. The county bills list includes a payment to Jagger
Asphalt & Paving in the amount of $1,552.50 by check
number 016657 dated March 3, 1994.
b. Exhibit 12 G, page 4 is a photocopy of the negotiated
check from Pike County to Jagger Asphalt and Paving,
which check is co- endorsed by Brink, Jonas and Thomson as
County Commissioners.
c. The county bills list includes a payment to Jagger
Asphalt & Paving in the amount of $1,502.50 by check
number 016850 dated March 10, 1994.
d. Exhibit 12 G, page 7 is a photocopy of the negotiated
check from Pike County to Jagger Asphalt and Paving,
which check is co- endorsed by Brink, Jonas and Thomson as
Brink, 94- 036 -C2
Page 27
County Commissioners.
64. The total payments received by Jagger Asphalt and Paving from
Pike County as to snow removal, sanding and hauling was •
$15,694.50.
65. Exhibit 13 consists of a group of photographs of a red dump
truck with license plate 91010 -CB and bearing a "Jagger
Asphalt Paving" logo on the cab door.
66. Exhibit 14 is a photocopy of the Certificate of Incorporation
and the Articles of Incorporation for Brink, Inc.
a. The Articles of Incorporation were signed by Brink on
September 29, 1978.
b. Brink, Inc. had the authority to issue 100 shares no par
value common stock with a full stated capital of
$1,000.00.
c. Brink was the sole incorporator.
d. All 100 shares were subscribed to Brink.
67. Exhibit 15 A is a photocopy of two share certificates
reflecting Dennis Brink and Joan Brink as registered share
holders with fifty shares each of Brink, Inc.
a. The share certificates were signed on February 17, 1995
by Joan Brink as Secretary /Treasurer and Dennis Brink as
President.
68. Exhibit 15 B consists of photocopies of a group of checks
issued by Brink, Inc. payable to Joan Brink, Brink, Dennis
Brink, Robert Raser, Justin Brink and other individuals.
69. Exhibit 16 A consists of photocopies of documents pertaining
to Brink, Inc.'s bank account No. 868 -443 -7 in Mellon Bank.
a. A signature card dated September 4, 1990 lists Joan
Brink, Dennis Brink, and Donald Brink as authorized
signatories.
b. A signature card effective February 17, 1995 lists Dennis
Brink as President and Joan Brink as Secretary /Treasurer,
and lists Joan Brink and Dennis Brink, but not Donald
Brink, as authorized signatories.
70. Exhibit 20 consists of photocopies of checks issued by Brink,
Inc. to payees including Brink, Greenwald Berk Agency and
Shoval -Mc Owen, Commonwealth of Pennsylvania, and Nationwide
Brink, 94- 036 -C2
Page 28
Mutual Insurance Company.
71. Exhibit R -2 is a photocopy of a General Liability and /or
Workers Compensation Report for the insured, Brink, Inc., for
the audit period of August 1, 1990 to August 1, 1991.
a. Under payroll, the employees are listed as Dennis Brink,
Ora B. Hall, Chris Boyd, Donald Marks and Joan Brink.
72. Exhibit R -7 is a photocopy of a 1993 U.S. Corporation Income
Tax Return for Brink, Inc., which is signed by Joan Brink as
Secretary.
III. DISCUSSION:
As a Commissioner for Pike County, Donald C. Brink,
hereinafter "Brink," 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
under Act 9 of 1989 in the allegations.
In addition, Section 3(f) of Act 9 of 1989 specifically
provides in pertinent part that no public official /employee, his
spouse or child, or any business with which he or his spouse or
child is associated may enter into any subcontract valued at five
hundred dollars or more with any person who has been awarded a
contract with the governmental body, unless the contract is awarded
Brink, 94- 036 -C2
Page 29
through an open and public process including prior public notice
and subsequent public disclosure.
The allegation before us is that Brink, in his capacity as a
Pike County Commissioner, violated Section 3(a) of Act 9 of 1989,
the conflict provision, and Section 3(f) of Act 9 of 1989, the
contracting provision, when he participated in awarding a County
snow removal contract to a company which subcontracted to utilize
vehicles owned by him. We must apply the allegation to the facts
of record. The pertinent facts are as follows.
In 1978, Respondent Brink incorporated Brink, Inc. Attorney
John Klemeyer handled the incorporation. Brink was the sole
incorporator, and all of the 100 shares which the corporation had
the authority to issue were subscribed to him. However, Brink
advised Klemeyer not to activate the corporation at that time.
Brink, Inc. was not activated until 1990. Accountant Edward
Shafer testified that in the course of activating Brink, Inc. in
1990, he prepared various documents which are in evidence. These
documents list Brink's son, Dennis Brink, as President of Brink,
Inc.; Brink's wife, Joan Brink, as Secretary /Treasurer; and both
Dennis and Joan Brink as 50% shareholders of Brink, Inc. These
documents include Brink, Inc.'s registration of its account for
unemployment compensation taxes, which indicates that Brink, Inc.
was acquired as a "transfer /incorporation" from a predecessor
business in the name, "Donald C. Brink." The predecessor business
is purported to have been discontinued August 31, 1990.
Brink, Inc.'s corporate checking account was established on
September 4, 1990. Bank records indicate that there were three
authorized signatories for the account: Joan Brink, Dennis Brink,
and Donald Brink. Donald Brink remained an authorized signatory
for the Brink, Inc. bank account for more than four years,
specifically from September 4, 1990 until February 17, 1995. On
February 17, 1995 -- just three days after a Special Investigator
for the State Ethics Commission ( "SEC ") interviewed Dennis Brink
and Ronald Jagger (another witness in this case) -- the signature
card for the Brink, Inc. account was changed. The new signature
card lists Dennis Brink as President and Joan Brink as
Secretary /Treasurer. Donald Brink is no longer listed as an
authorized signatory.
Another change occurred on February 17, 1995: share
certificates were issued to Dennis Brink and Joan Brink,
designating each as a 50% shareholder of Brink, Inc. These share
certificates were issued for original shares rather than
transferred shares. Attorney Klemeyer testified that no shares had
ever been issued previously.
Brink, Inc. maintains its office in Brink's home, Brink,
Inc.'s telephone number is the same telephone number as Brink's,
Brin]t, 94- 036 -C2
Page 30
and the trucks and equipment used by Brink, Inc. are owned by
Brink. The trucks and equipment are purportedly "leased" to the
corporation through an unwritten lease agreement. They are stored
on the property where Brink's home is located.
Factually, it is uncontroverted that Brink, Inc. is a business
with which, at the very least, Brink's immediate family members,
his spouse and son, are associated. 65 P.S. §402. In this regard,
we note that although the parties have gone to great lengths as to
whether Brink himself has an interest in Brink, Inc., it is
sufficient under the Ethics Law that Brink, Inc. is a business with
which members of Brink's immediate family are associated.
Meanwhile, in his public capacity, Brink has twice served as
a Pike County Commissioner: from 1983 to 1987 and again from
January, 1992 to the present time. Parenthetically, on Brink's
Statements of Financial Interests for calendar years 1991 through
1993, Brink listed his occupation as "contractor" and stated that
he was part owner of Brink Excavating.
During the winters of 1993 and 1994 there were heavy snow
storms which necessitated the removal of snow from around the Pike
County Courthouse. Pike County Commissioners Sally Thomson and
Margaret Jonas relied upon the third Commissioner, Brink, to
arrange for snow removal. Although Pike County contracts of
$10,000 or more must be advertised for bids, and contracts between
$4,000 and $10,000 require obtaining three telephonic proposals,
contracts under $4,000 may be awarded based upon considerations of
the type of service and the availability of people to perform the
job.
For the winters of 1993 and 1994, Brink chose Jagger Asphalt
Paving to remove snow from the County property. Jagger Asphalt
Paving is owned by Ronald Jagger. Brink has known Jagger for
approximately thirty years. The work was not awarded through the
use of telephone price quotes or the bidding process. Brink did
not ascertain the cost of the snow removal before awarding
contracts to Jagger. However, from the record it appears that such
work was awarded on an as- needed basis, and the cost to the County
per snowfall was in each instance under $4,000.00. The total cost
to Pike County for Jagger's snow removal operations for the two
years was $15,694.50. Of this, $4,793.00 was attributable to the
winter of 1993 and $10,901.50 was attributable to the winter of
1994. The bills are itemized in detail in Findings 18 and 55.
The snow removal work occurred on fourteen days spanning the
two winters of 1993 and 1994. The evidence has established that
of those fourteen days, on the following eight days a red dump
truck owned by Donald Brink, and purportedly "leased" to Brink,
Inc., was used in the County snow removal operations: February 25,
1993, March 15, 1993, March 16, 1993, January 9, 1994, January 10,
1994, January 19, 1994, January 21, 1994, and February 6, 1994.
Brink, 94- 036 -C2
Page 31
For each of these dates, Pike County was billed by Jagger for the
use of the Brink truck. The total cost to the County for the Brink
truck's involvement in these operations was $2,975.00.
When Jagger was using it, the Brink truck had a Jagger Asphalt
and Paving logo placed on the side of the truck giving it the
appearance of a Jagger truck. Jagger testified that the logo was
necessary in order to dump snow in an authorized location. In at
least one of the snow removal operations at the County complex,
Jagger was assisted by Robert Raser, who is an employee of Brink,
Inc. Raser testified that he did the work on his own time and that
Jagger gave him coffee money for his efforts. Dennis Brink
testified that Raser's work with Jagger at the County Complex was
not done in his capacity as a Brink, Inc. employee.
As to the utilization by Jagger of the Brink truck, both
Jagger and Dennis Brink have testified that Jagger asked Dennis
Brink if he could borrow the truck and that Dennis Brink agreed.
These individuals also testified that after Jagger finished using
the Brink truck, he made a voluntary, unsolicited payment of $3,500
for the truck which he "borrowed" from Brink, Inc. Dennis Brink
claimed that the $3,500 was an "after the fact" payment by Jagger
because Jagger "used the truck more than he anticipated." Jagger
testified that he "borrowed" a truck from Brink, Inc. on a few
other occasions prior to 1993, while Dennis Brink testified that
there was one such prior occasion.
There is no invoice of record from Brink, Inc. to Jagger for
Jagger's use of the "borrowed" truck for Pike County snow removal.
There are three other invoices of record establishing other
business dealings between Jagger and Brink, Inc. where Brink, Inc.
equipment and laborers were used by Jagger. On those three other
occasions, Brink, Inc. invoiced Jagger and Jagger made payment to
Brink, Inc. One of these invoices is for work in April, 1994, well
after the 1993 -1994 County snow removal operations. The other
invoices are the only evidence of the nature and extent of prior
business dealings between Brink, Inc. and Jagger. They indicate
that on one occasion, in November of 1992, Jagger was billed'by
Brink, Inc. for a bulldozer, truck and labor for two days work at
a job site designated "Wild Acres," and on the other occasion, in
August of 1993, Jagger was billed by Brink, Inc. for a bulldozer
and labor for two days work in preparing a driveway behind a
school. There is no evidence of any other prior business dealings
between Jagger and Brink, Inc., and there is specifically no
evidence of any prior business dealings between Jagger and Brink,
Inc. pertaining to snow removal work or work for Pike County.
Brink stated that
"leases" to Brink, Inc.
Pike County property.
Spring of 1994, he was
Brink, Inc. for the use
he did not know that his truck, which he
, was used by Jagger to remove snow from
Likewise, Brink claims that during the
not aware that Jagger issued a check to
of the "borrowed" Brink truck.
Brink, 94- 036 -C2
Page 32
There is the testimony of Harry Forbes that Brink was actually
at the County Complex while Jagger was using the Brink truck for
snow removal. However, Forbes testified that this incident was
after January 21, 1994. A review of the evidence reveals that
there was only one day of snow removal by Jagger after January 21,
1994 -- specifically February 6, 1994 -- such that there is no
evidence placing Brink on the scene during Jagger's use of the
Brink truck until the final day of Jagger's snow removal operations
for the County.
The Investigative Division has acknowledged that its case is
based upon circumstantial evidence.
It is clear that an administrative agency's findings may be
based upon circumstantial evidence if that evidence is sufficient
to meet the applicable burden of proof. See, Jones v. Unemployment
Compensation Board of Review, 127 Pa. Commw. 635, 562 A.2d 935
(1989). The Pennsylvania Supreme Court has stated:
When a party who has the burden of proof relies upon
circumstantial evidence and inferences reasonably
deducible therefrom, such evidence, in order to prevail,
must be adequate to establish the conclusion sought and
must so preponderate in favor of that conclusion as to
outweigh in the mind of the fact - finder any other
evidence and reasonable inferences therefrom which are
inconsistent therewith.
Smith v. Bell Telephone Company, 397 Pa. 134, 153 A.2d 477, 480
(1959) .
Under the Ethics Law, Act 9 of 1989, the standard of proof is
more stringent than the "substantial evidence" standard which
administrative agencies are ordinarily required to meet. A
violation of Act 9 of 1989 requires "clear and convincing proof."
65 P.S. §408(g). Clear and convincing proof is that which is ". .
. so clear and direct as to permit the trier of fact to reach a
clear conviction, without hesitancy, as to the truth of the facts
at issue." Matter of Pekarski, 536 Pa. 346, , 639 A.2d 759, 760
(Pa. 1994); see also, In Re: Matter of Sylvester, 521 Pa. 300, 555
A.2d 1202 (1989) and cases cited therein.
In its case and in its Brief, the Investigative Division has
highlighted numerous factual circumstances which could suggest that
there was a scheme among Brink, Dennis Brink, and Jagger, whereby
Brink would give the Pike County snow removal work to Jagger who
would then funnel a portion of the pecuniary benefit to Brink, Inc.
through the use of a purportedly "borrowed" truck.
We are cognizant of the inherent difficulty of proving a
scheme, particularly where the perpetrators concoct a story to
explain the circumstances. Respondent's proffered explanation for
Brink, 94- 036 -C2
Page 33
the circumstances in this case may be viewed by some to be
incredible, yet it is conceivable. We would not reject it out of
hand simply on the basis of the history of dealings between the
parties, because of record, there were only two prior dealings.
Neither had anything to do with snow removal work or Pike County,
and both involved the use of Brink equipment with an operator. Nor
would we simply assume that Brink knew that Jagger would use the
Brink truck for the County's snow removal. Even if Brink knew that
Jagger had the truck, he would not necessarily know how it would be
used by Jagger. In fact, the Brink truck was only used on eight of
the fourteen days that Jagger performed snow removal for the
County, and Brink has only been placed at the scene on the final
day. Finally, as for whether the business would be likely to loan
the truck, we would note that Respondent Brink and Jagger knew each
other for approximately thirty years, and that such an arrangement
between Brink's son and Jagger would not be inconceivable in light
of that relationship. The circumstantial evidence against the
Respondent is not "so clear and direct" as to allow us to reach a
clear conviction, without hesitancy, that the Brink truck was not
borrowed.
Furthermore, both as to Section 3(a) and Section 3(f), this
case hinges upon the key portion of the allegation which alleges a
subcontract. We note the following stringent principles of
contract law:
• • [T]he courts cannot construct a true contract,
regardless of the justness of doing so, unless there is
a manifestation of assent to the making of a promise. It
may therefore be said that the courts will neither make
a contract for the parties nor rewrite a contract that
the parties have themselves made, though it will enforce
obligations that ought, in justice, to be enforced quasi
contractually.
S. Williston, A Treatise on the Law of Contracts, 51.6 (4th Ed.
1990) .
Here, both Dennis Brink and Jagger, the alleged "parties,"
have vehemently denied that they entered into any subcontract. In
the absence of any evidence to establish the requisite
"manifestation of assent" by the alleged parties, we may not
conclude that there was a subcontract. Nor do we have the
judiciary's power to find a quasi subcontract.
Having applied the allegation to the facts of record, we are
constrained to find that there was no violation of either Section
3(a) or 3(f).
Brink, 94- 036 -C2
Page 34
IV. CONCLUSIONS OF LAW:
1. Donald C. Brink as a Pike County Commissioner is a public
official subject to the provisions of Act 9 of 1989.
2. Brink did not violate Section 3(a) or Section 3(f) of Act 9 of
1989 as to his participation in awarding a snow removal
contract to a company alleged to have subcontracted to utilize
vehicles owned by him based upon an insufficiency of evidence.
In Re: Donald C. Brink : File Docket: 94- 036 -C2
Date Decided: 10/26/95
. Date Mailed: 11/8/95
ORDER NO. 986
Donald C. Brink, as a Pike County Commissioner, did not violate
Section 3(a) or Section 3(f) of Act 9 of 1989 as to his
participation in awarding a snow removal contract to a company
alleged to have subcontracted to utilize vehicles owned by him
based upon an insufficiency of evidence.
BY THE COMMISSION,
Ausno etiA4_
DANEEN E. REESE, CHAIR
Commissioner Roy W. Wilt served as hearing officer and elected not
to participate in the final decision of this matter.