Loading...
HomeMy WebLinkAbout978 JoinesSTATE ETHICS COMMISSION 308 FINANCE BUILDING HARRISBURG, PENNSYLVANIA 17120 In Re: Lynn Joines File Docket: 94- 015 -C2 Date Decided: 05/19/95 Date Mailed: 05/24/95 Before: Daneen E. Reese, Chair Austin M. Lee, Vice Chair Roy W. Wilt John R. Showers 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 et sea. Written notice of the specific allegation(s) was served at the commencement of the investigation. A Findings Report was issued and served upon completion of the investigation which constituted the Complaint by the Investigation Division. An Answer was 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 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). Any person who violates confidentiality of the Ethics Law is guilty of a misdemeanor subject to a fine of not more than $1,000 or imprisonment for not more than one year, 65 P.S. §409(e). Confidentiality does not preclude discussing this case with an attorney at law. Joines, 94- 015 -C2 Page 2 I. ALLEGATION: That Lynn Joines, a public official /public employee in his capacity as a supervisor for Jackson Township, Susquehanna County, violated provisions of the State Ethics Act (Act 9 of 1989) when his company, Pickering Farm Equipment, contracted with the township without an open and public process and when he failed to file Statements of Financial Interests for the 1991 and 1992 calendar years. Section 3. Restricted Activities (a) No public official or public employee shall engage in conduct that constitutes a conflict of interest. 65 P.S. §403(a). (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. 65 P.S. §403(f). Section 4. Statement of financial interests required to be filed (a) Each public official of the Commonwealth shall file a statement of financial interests for the preceding calendar year with the commission no later than May 1 of each year that he holds such a position and Joines, 94- 015 -C2 Page 3 II. FINDINGS: of the year after he leaves such a position. Each public employee and public official of the Commonwealth shall file a statement of financial interests for the preceding calendar year with the department, agency, body or bureau in which he is employed or to which he is appointed or elected no later than May 1 of each year that he holds such a position and of the year after he leaves such a position. Any other public employee or public official shall file a statement of financial interests with the governing authority of the political subdivision by which he is employed or within which he is appointed or elected no later than May 1 of each year that he holds such a position and of the year after he leaves such a position. Persons who are full -time or part -time solicitors for political subdivisions are required to file under this section. 65 P.S. §404(a). Section 2. Definitions "Conflict" or "conflict of interest." Use by a public official or public employee of the authority of his office or employment or any confidential information received through his holding public office or employment for the private pecuniary benefit of himself, a member of his immediate family or a business with which he or a member of his immediate family is associated. "Conflict" or "conflict of interest" does not include an action having a de minimis economic impact or which affects to the same degree a class consisting of the general public or a subclass consisting of an industry, occupation or other group which includes the public official or public employee, a member of his immediate family or a business with which he or a member of his immediate family is associated. 65 P.S. §402. 1. On February 14, 1994, the Investigative Division of the State Ethics Commission requested own - motion approval for an investigation regarding allegations that Lynn Joines violated provisions of the State Ethics Act (Act 9 of 1989). 2. The Executive Director of the State Ethics Commission approved the own- motion request for an investigation on February 14, Joines, 94- 015 -C2 Page 4 1994. 3. At the direction of the Executive Director, the Investigative Division initiated a preliminary inquiry on February 14, 1994. 4. The preliminary inquiry was completed within sixty days. 5. On April 18, 1994, a letter was forwarded to Lynn Joines, 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 016 239 409. b. The domestic return receipt bore the signature of Lynn D. Joines, with a delivery date of April 21, 1994. 6. The full investigation was commenced at the direction of the Executive Director of the State Ethics Commission. 7. On August 22, 1994, the Executive Director of the State Ethics Commission filed an application for a ninety day extension of time to complete the Investigation. 8. The Commission issued an order on September 12, 1994, granting the ninety day extension. 9. On November 22, 1994, the Executive Director of the State Ethics Commission filed an application for a second ninety day extension of time to complete the investigation. 10. The Commission issued an order on December 18, 1994, granting the second extension. 11. The Investigative Complaint was mailed to the Respondent on April 11, 1995. 12. Lynn D. Joines served as a supervisor for Jackson Township, Susquehanna County, from January of 1980 to September 14, 1993 when he resigned the position. a. Joines served as Jackson Township Roadmaster from 1980 to 1987. b. Joines served as Chairman of the from 1987 to 1993. 13. Pickering Farm Equipment was owned by from 1957 to 1987. Board of Supervisors Raymond C. Pickering Joines, 94- 015 -C2 Page 5 14. Joines was employed by Pickering Farm Equipment from 1970 to 1987. 15. Joines purchased Pickering Farm Equipment in January of 1987 and has owned the company since that time. a. Joines owns one hundred percent (100 %) of the business. b. Pickering Farm Equipment's business address is RD #2, Box 87, Thompson, PA 18465. 16. Jackson Township officials have purchased materials such as calcium, assorted hardware items, grease, oil, and batteries from Pickering Farm Equipment, from 1957 to the present, and had Pickering Farm Equipment repair Township equipment during that time period. a. Pickering Farm Equipment is the only major supplier located in the township. b. Other vendors offering similar services are located approximately forty (40) miles from Jackson Township. 17. Jackson Township records confirm the following purchases were made from Pickering Farm Equipment during the period from July 1, 1989, to August, 1993. Pickering Date Amount Township Amount Date Invoice # Check# 11657 08/10/89 $ 33.76 9414 07/26/89 $ 43.03 11097 07/19/89 $ 5.00 11020 07/17/89 $ 71.87 13331 11/07/89 $ 4.04 13454 11/24/89 $ 85.00 3281 11/04/89 $ 624.14 12812 10/23/89 $ 110.00 12379 09/20/89 $ 31.53 13322 11/29/89 $ 13.44 13298 02/05/90 $3,982.50 13500 02/05/90 $1,248.00 13779 03/14/90 $ 4.32 13834 03/20/90 $ 200.00 13115 03/22/90 $ 88.00 13869 03/23/90 $ 18.00 14573 05/07/90 $ 93.44 14157 05/30/90 $ 21.87 3458 06/09/90 $ 59.60 16037 07/11/90 $ 33.75 15480 06/22/90 $ 14.20 4000 $ 226.10 11/06/89 • n 0 4021 n 4031 3633 3632 4037 4065 4078 4094 II 4108 4123 n n n n $ 868.15 12/04/89 0 n n n n n n N $ 13.44 12/28/89 $3,982.50 02/05/90 $1,248.00 02/05/90 $ 4.32 04/02/90 $ 306.80 05/07/90 n n n n $ 85.69 06/06/90 $ 81.47 07/02/90 11 n $ 33.75 08/06/90 $ 126.08 09/03/90 Jones, 94- 015 -C2 Page 6 16821 08/14/90 $ 99.00 16877 08/16/90 $ 12.88 17931 10/23/90 $ 11.36 17995 11/16/90 $ 225.00 3661 11/16/90 $ 60.88 18098 12/03/90 $2,080.00 18567 03/20/91 $ 17.45 18867 03/21/91 $ 205.61 3986 07/02/91 $ 417.81 205415 07/23/91 $ 3.86 19908 07/23/91 $ 8.52 205961 08/01/91 $ 14.61 205882 07/26/91 $ 56.45 206590 09/12/91 $ 35.49 207157 11/04/91 $ 328.00 207211 11/12/91 $ 205.87 207226 11/14/91 $ 201.76 207370 12/07/91 $ 46.80 207635 01/20/92 $ 450.00 207511 01/21/92 $ 9.41 207716 01/31/92 $ 22.00 207751 02/07/92 $ 70.06 208045 03/25/92 $ 18.00 207942 03/30/92 $ 203.28 208469 05/01/92 $ 65.00 208500 05/16/92 $ 240.00 208131 04/03/92 $ 55.48 210171 06/29/92 $ 6.75 210423 07/06/92 $ 2,600.00 210236 07/06/92 $ 16.71 4274 07/06/92 $ 322.00 210441 07/06/92 $ 150.00 210798 07/21/92 $ 11.95 210909 08/21/92 $ 71.28 211638 08/27/92 $ 65.70 211910 09/14/92 $ 121.77 212195 10/02/92 $ 60.85 212459 10/07/92 $ 10.96 4374 10/30/92 $ 943.98 212623 11/30/92 $ 9.01 4394 11/24/92 $ 402.82 213245 01/14/93 $ 20.40 213173 01/26/93 $ 216.95 213256 02/19/93 $ 117.45 213595 04/20/93 $ 190.00 214033 04/20/93 $ 24.00 214233 05/03/93 $ 244.95 214313 05/07/93 $ 26.70 214417 05/14/93 $ 81.00 214472 06/08/93 $ 580.00 216006 07/12/93 $ 26.77 n n n n n n 4179 $ 297.24 12/27/90 a n n 11 n It 3771 $2,080.00 12/03/90 4219 $ 223.06 06/03/91 n n n 4257 $ 417.81 08/05/91 4284 $ 83.64 09/04/91 n n n n n n n n n 3959 $ 363.49 11/04/91 n n n 4324 $ 454.43 12/26/91 n n n n n n 4335 $ 763.34 04/13/92 n n n n n It n n n n n n n n n 4117 $3,455.94 07/06/92 n n n n n n n n n n n n n n 0 n n n n It 0 4167 $ 270.00 10/05/92 n It n n n 0 n n n 418 $ 60.85 11/02/92 4209 $ 954.90 12/07/92 n It • 4233 $ 411.86 12/22/92 n It n 4290 $ 237.35 03/01/93 n n n 4323 $ 117.45 04/08/93 4355 $ 460.74 06/07/93 n n n n n n 4371 $ 107.70 07/05/93 n n n 4384 $ 580.00 08/02/93 4394 $ 297.01 09/13/93 216184 215761 216426 Pickering Invoice # 11657 9414 11097 11020 13331 13454 3281 12812 12379 13322 13298 13500 13779 13834 13115 13869 14573 14157 3458 16037 15480 Joines, 94- 015 -C2 Page 7 07/19/93 $ 07/26/93 $ 08/05/93 $ 37.90 59.79 172.55 " " 18. In 1989, 1990, 1991, and 1992 the payee on the checks was listed as "Pickering Farm Equipment ". a. The checks contained the endorsement "Pay to the order of the Grange National Bank of Susquehanna County, New Milford, PA 031312754 For Deposit Only Pickering Farm Equipment ". 19. In 1993 the payee on the checks was listed as the "Farm Plan ". a. The checks contained the endorsement "Credit To Acct of Named Payee Absence of Endorsement Guaranteed NED Bank, N.A. 55 Lockbox 55" 20. The "Farm Plan" was a financial plan Farm Equipment received payments. 21. Joines took the following action meetings in reference to the approval Farm Equipment: Township Date Check# Of Supervisors Meeting 4000 11/06/89 4031 3633 3632 4037 4065 " n 4094 " " 11 4078 4108 4123 It " " 12/04/89 " " 1 " 12/28/89 02/05/90 02/05/90 04/02/90 05/07/90 t 1, 06/06/90 07/02/90 08/06/90 09/03/90 through which Pickering at Township Supervisor of payments to Pickering Joines Present And Voted To Approve Payment Yes Yes Yes Yes Yes Yes Yes No Yes Yes Yes Yes Joins Signed Check Yes Yes Yes Yes Yes No Yes Yes Yes Yes Joines, 94- 015 -C2 Page 8 16821 n " 16877 " to 17931 4179 01/07/91 Yes Yes 17995 " " 3661 0 n 18098 3771 12/03/90 Yes Yes 18567 4219 06/03/91 Yes Yes 18867 " " 3986 4257 08/04/91 Yes Yes 205415 4284 09/09/91 Yes Yes 19908 " " 205961 n n 205882 " " 206590 3959 11/04/91 Yes Yes 207157 " " 207211 4324 12/26/91 Yes Yes 207226 " " 207370 n " 207635 4335 04/13/92 Yes Yes 207511 " " 207716 n n 207751 n n' 208045 " " 207942 n " 208469 4117 07/06/92 Yes Yes 208500 " " 208131 n n 210171 n n 210423 " " 210236 " " 4274 " n 210441 " " 210798 4167 10/05/92 Yes Yes 210909 " " 211638 n n 211910 " " 212195 4184 11/02/92 Yes Yes 212459 4209 12/07/92 4374 " " 212623 4233 12/22/92 Yes Yes 4394 " " 213245 4290 03/01/93 Yes Yes 213173 n n 213256 4323 04/08/93 Yes Yes 213595 4355 06/07/93 Yes Yes 214033 " 214233 " " 214313 4371 07/05/93 Yes Yes 214417 n " 214472 4384 08/02/93 Yes Yes 216006 4394 09/13/93 Yes Yes 216184 215761 216426 Joines, 94- 015 -C2 Page 9 " 11 " n " u 22. Invoices presented by Joines indicate he was involved in the following business transactions with Jackson Township and made the following profit on items sold to Jackson Township: Pickering Township Amount of Cost To Pickering Profit Invoice # Check# Bill /Payment For Materials 1989 11657 4000 $ 33.76 $ 26.3E 9414 " $ 43.03 $ 7.40 11097 ■ $ 26.41 $ 16.62 11020 " $ 5.00 $ 3.60 $ 6.58 11021 " $ 71.87 $ 55.29 1 102 " $ 61.5 $ 23.65 $ 17.03 $ 6.62 $ 16.6 13009 " $ 250.00 $ 183.54 $ 5.69 66.46 13331 4021 $ 4'10 $ 1.59 13454 " $ 4.04 $ 2.91 $ 5 . 12812 " $ 85.00 $ 80.00 $ 4 3281 " $ 110.00 $ 85.59 24.41 12379 " $ 6 31.53 $ 522.71 $120.82 $ 13322 4031 $ 13.44 $ 9.68 3.76 $ 3.76 TOTAL: $1,301.15 $1,020.54 $280.61 1990 13298 3633 $3,982.50 $3,645.00 13500 3632 $1,248.00 $337.50 13779 4037 $1,171.20 $ 76.80 $ 4.32 $ 3.12 $ 1.20 13834 4065 $ 200.00 $ 191.81 $ 8.19 13115 " $ 88.80 13869 " $ 67.86 $ 20.94 14573 4078 $ 18.00 $ 13.70 $ 4.30 14157 4094 $ 93.44 $ 71.27 $ 22.17 1 418 " $ 21.87 $ 17.26 $ 4.61 $ 59.60 $ 56.77 $ 2.83 16037 4108 $ 33.75 $ 24.33 $ 9.42 15480 4123 $ 14.20 $ 10.06 $ 4.14 16821 $ 99.00 16877 " $ 87.63 $ 11.37 $ 12.88 $ 10.57 $ 2.31 17931 4179 $ 11.36 $ 9.56 $ 1.80 17995 " $ 225.00 3661 n $ 196.50 $ 28.50 6 " $ 60.88 $ 47.97 $ 12.91 36 18 08 " $ 16.67 $ 14.04 $ 2.63 $ 425.16 $ 378.45 $ 46.71 18098 3771 $2,080.00 $2,050.00 $ 30.00 Joines, 94- 015 -C2 Page 10 TOTAL: $8,695.43 $8,067.10 $628.33 1991 18567 4219 $ 17.45 $ 13.76 $ 3.69 18867 " $ 205.61 $ 161.15 $ 44.46 3986 4257 $ 417.81 $ 369.07 $ 48.74 205415 4284 $ 3.86 $ 2.78 $ 1.08 19908 n $ 8.52 $ 6.96 $ 1.56 205961 " $ 14.61 $ 13.88 $ .73 205882 " $ 56.65 $ 43.70 $ 12.95 206590 3959 $ 35.49 $ 26.32 $ 9.17 207157 " $ 328.00 $ 300.36 $ 27.64 207211 4324 $ 205.87 $ 192.05 $ 13.82 207226 " $ 201.76 $ 168.88 $ 32.88 207370 " $ 46.80 $ 38.38 $ 8.42 TOTAL: $1,542.43 $1,337.29 $205.14 1992 207635 4335 $ 450.00 $ 345.00 $105.00 207511 " $ 9.91 $ 7.14 $ 2.77 207716 " $ 22.00 $ 15.84 $ 6.16 207751 " $ 70.06 $ 48.67. $ 21.39 208045 u $ 18.00 $ 12.96 $ 5.04 207942 " $ 203.28 $ 165.86 $ 37.42 208469 4117 $ 65.00 $ 65.00 $ 00.00 208500 " $ 240.00 $ 193.46 $ 46.54 208131 " $ 55.48 $ 42.97 $ 12.51 210171 " $ 6.75 $ 4.74 $ 2.01 210423 " $2,600.00 $2,400.50 $199.50 210236 " $ 16.71 $ 13.78 $ 2.93 4274 " $ 322.00 $ 257.60 $ 64.40 210441 " $ 150.00 $ 108.00 $ 42.00 210798 4167 $ 11.95 $ 10.70 $ 1.25 210909 " $ 71.28 $ 68.22 $ 3.06 211638 " $ 65.20 $ 48.70 $ 16.50 211910 " $ 121.77 $ 87.68 $ 34.09 212195 4184 $ 60.85 $ 42.35 $ 18.50 212459 4209 $ 10.96 $ 9.01 $ 1.95 4374 " $ 943.98 $ 779.40 $164.58 212623 4233 $ 9.01 $ 7.69 $ 1.32 4394 " $ 402.85 $ 342.15 $ 60.70 TOTAL: $5,927.04 $5,077.42 $849.62 1993 213245 4290 $ 20.40 $ 14.69 $ 5.71 213173 " $ 216.95 $ 196.00 $ 20.95 Joines, 94- 015 -C2 Page 11 213256 4323 $ 117.45 $ 107.92 $ 9.53 213595 4355 $ 190.00 214033 " $ 24.00 $ 173.00 $ 17.00 $ 19.20 $ 4.80 214233 " $ 244.95 $ 176.37 $ 68.58 214313 4371 $ 26.70 $ 21.90 $ 4.80 214417 n $ 81.00 $ 63.18 $ 17.82 214472 4384 $ 580.73 $ 438.13 $142.60 216006 4394 $ 26.77 $ 22.14 $ 4.63 216184 " $ 37.90 215761 " $ 59.79 $ 25.00 $ 12.90 $ 45.99 $ 13.80 216426 " $ 172.55 4585 " $ 315.21 $ 145.12 $ 27.43 $ 249.09 $ 66.12 TOTAL: $2,114.40 $1,697.73 $416.67 23 The following totals were determined from Pickering Farm Equipment records: Year Total Amount of Total Cost To Bills /Payments Pickering For Materials Total Profit 1989 $2,969.94 $2,520.49 $ 280.61 1990 $8,695.43 $8,067.10 $ 628.33 1991 $1,542.43 $1,337.29 $ 205.14 1992 $5,927.04 $5,077.42 1993 $2,114.40 $1,697.73 $ 4 16.67 $ 416.67 Total $21,249.24 $18,700.03 $2,380.37 24. Purchases made in excess of $500.00 as outlined below were not made through an open and public process. a. These were purchases of calcium which Joines arranged to have "drop- shipped" to the township and repairs to township equipment. b. Calcium Purchases: Invoice No. Date Amount 13298 02/05/90 $3,982.50 13500 02/05/90 $1,248.00 18098 12/03/90 $2,080.00 210423 07/06/92 $2,600.00 c. Invoice No. 4374, dated 10/30/92, in an amount of $943.98 was for repairs to township equipment as follows: Labor: 26 hrs ON 28.00 /hr = $728.00 Outside Labor Calibration = $ 99.98 Joines, 94- 015 -C2 Page 12 Parts TOTAL = $116.00 $943.98 25. The repair to the township equipment as outlined in Finding 24(c) was done to avoid the cost of transporting the equipment approximately forty (40) miles to the nearest dealer. a. Joines believed he saved the township money by performing the repairs. 26. The Supervisors discussed the purchases and knew Joines owned Pickering Farm Equipment but the issue of a possible conflict of interest was never discussed. 27. Jackson Township was advised by the Department of Auditor General, Bureau of Audits that the practice of making purchases from a company owned by a township supervisor would violate provisions of the Second Class Township Code. a. This information was provided during an audit exit conference occurring on May 4, 1992. b. Lynn Joines did not attend this exit conference. 28. Statements of Financial Interests on file with Jackson Township confirm the following filings for Lynn Joines: a. Statement of Financial Interests filed February 1, 1993, for the 1992 calendar year. b. Statement of Financial Interests filed January 6, 1992, for the 1991 calendar year. 29. Joines did not file a Statement of Financial Interests for the 1993 calendar year as a former public official. III. DISCUSSION: As a supervisor for Jackson Township, Susquehanna County, Lynn Joines, hereinafter Joines, was 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 Joines, 94- 015 -C2 Page 13 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 part that no public official /employee or spouse or child or business with which he or the spouse or child is associated may enter into a contract with his governmental body valued at five hundred dollars or more or any subcontract valued at five hundred dollars or more with any person who has been awarded a contract with the governmental body with which the public official /employee is associated unless the contract is awarded through an open and public process including prior public notice and subsequent public disclosure. Section 4 (a) of the Ethics Law quoted above requires that each public official /employee must file a Statement of Financial Interests for the preceding calendar year of the year in which he is employed or served and for the year after he leaves such position. There are two issues before us. The first is whether Joines violated Section 3(a) of Act 9 of 1989, the conflict provision, or Section 3(f), the contracting provision, as to the allegation that his company, Pickering Farm Equipment, contracted with the township without an open and public process. The second issue is whether Joines violated Section 4(a), the Financial Interests Statement (FIS) filing requirement, by failing to file FIS's for the 1991 and 1992 calendar years. Joines served as a Supervisor in Jackson Township, Susquehanna County, from January 1980 through September 1993. In a private capacity, Joines has been the owner of Pickering Farm Equipment since January of 1987. Jackson Township has utilized Pickering Farm Equipment to purchase various materials and for repair services from 1957 to the present. Pickering Farm Equipment is the only major supplier located in the township in that other vendors Joines, 94- 015 -C2 Page 14 providing similar services are located approximately forty miles away. The various purchases that the township made from Pickering Farm Equipment between July 1989 and August 1993 are delineated in Fact Finding 17. The actions taken by Joines as a Supervisor relative to Pickering Farm Equipment invoices, such as voting to approve those payments and signing checks, are set forth in Fact Finding 21. The profit that Pickering Farm Equipment made as to the various sales to Jackson Township for the five year period are delineated in Fact Finding 22 with the yearly totals set forth in Fact Finding 23. The total profit for the five years in issue amounted to $2,380.37. Fact Finding 23. The township purchases from Pickering Farm Equipment which were in excess of $500.00 and which were not awarded through an open and public process are listed in Fact Finding 24. Parenthetically, one particular repair of township equipment (Fact Finding 24c) was done by Pickering Farm Equipment in order to avoid the cost of transporting the equipment forty miles to the nearest dealer. Although the supervisors discussed purchases with Joines and knew that Joines owned Pickering Farm Equipment, the issue of a possible conflict of interest was never discussed. The Auditor General of the Commonwealth of Pennsylvania advised Jackson Township that purchasing goods and services from a company owned by a township supervisor was contrary to the Second Class Township Code. Lastly, as to the FIS filings of Joines, there are FIS's on file for Joines at the township for the calendar years 1991 and 1992; however, Joines did not file an FIS for the calendar year 1993 as a former public official. In applying the provisions of the Ethics Law, we find violations of Section 3(a) and 3(f) of Act 9 of 1989. As to Section 3(a) of Act 9 of 1989, it is clear that Joines used the authority of office by voting to approve the payments of invoices and by signing checks for Pickering Farm Equipment. Juliante, Order 809. That use of authority resulted in a private pecuniary benefit consisting of the profit received by Pickering Farm Equipment. The private pecuniary benefit inured to a business with which Joines is associated. The term business with which associated is defined as follows under Act 9 of 1989: 65 P.S. §402. "Business with which he is associated." Any business in which the person or a member of the person's immediate family is a director, officer, owner, employee or has a financial interest. Joines, 94- 015 -C2 Page 15 Since Joines was the owner of Pickering Farm Equipment, it is clear that Pickering Farm Equipment is a business with which he is associated. Thus, a violation of Section 3(a) of Act 9 of 1989 occurred when Joines used the authority of office to obtain a private pecuniary benefit for Pickering Farm Equipment, a business with which he is associated, as to various sales made to Jackson Township. As to the certain transactions between Jackson Township and Pickering Farm Equipment, the record does reflect that certain contracts which were in excess of $500.00 were not awarded through an open and public process as required by Section 3(f) of the Ethics Law. Thus, a violation of Section 3(f) of Act 9 of 1989 occurred in that a business with which Joines is associated, Pickering Farm Equipment, contracted with Joines' governmental body, Jackson Township, where the contracts were in excess of $500.00 and were not awarded through and open and public process with prior public notice and subsequent public disclosure of all proposals considered and contracts awarded. Walsh, Order 955. The Ethics Law requires that public officials /employees annually file FIS's on or before May lst. In this case the record reflects that Joines did file Financial Interest Statements for the calendar years 1991 and 1992 and on that basis we find no violation of Section 4(a) of Act 9 of 1989. However, the findings also reflect that Joines did not file a FIS for the calendar year 1993 as a former public official. Although we may not find a violation for the failure to file for calendar year 1993 for the reason that this issue is not part of the allegation, we shall direct Joines to file within thirty days of the date of issuance of this Order an FIS for the 1993 calendar year. The original FIS should be filed with this Commission with a copy filed at Jackson Township. IV. CONCLUSIONS OF LAW: 1. Lynn Joines as a Jackson Township Supervisor, Susquehanna County, was a public official subject to the provisions of Act 9 of 1989. 2. Joines violated Section 3(a) of Act 9 of 1989 when he used the authority of office as to the approval and payment of invoices as to sales and services provided to the township by Pickering Farm Equipment, a business with which Joines is associated. 3. Joines violated Section 3(f) of Act 9 of 1989 when Pickering Farm Equipment, a business with which he is associated, entered into contracts with Jackson Township which were in excess of $500.00 and were not awarded through an open and public process. 4. Joines did not violate Section 4(a) of Act 9 of 1989 in that he filed Financial Interest Statements for the calendar years 1991 and 1992. In Re: Lynn Joines File Docket: 94- 015 -C2 : Date Decided: 05/19/95 . Date Mailed: 05/24/95 ORDER NO. 978 1. Lynn Joines as a Jackson Township Supervisor, Susquehanna County, violated Section 3(a) of Act 9 of 1989 when he used the authority of office as to the approval and payment of invoices as to sales and services provided to the township by Pickering Farm Equipment, a business with which Joines is associated. 2. Joiner violated Section 3(f) of Act 9 of 1989 when Pickering Farm Equipment, a business with which he is associated, entered into contracts with Jackson Township which were in excess of $500.00 and were not awarded through an open and public process. 3. Joines did not violate Section 4(a) of Act 9 of 1989 in that he filed Financial Interest Statements for the calendar years 1991 and 1992. a. Joines is directed within thirty days of the date of issuance of this Order to file a Financial Interest Statement for the calendar year 1993 as a former public official. The original FIS should be filed with this Commission with a copy filed at Jackson Township. BY THE COMMISSION, th DANEEN E. REESE, CHAIR