HomeMy WebLinkAbout806 RankinIn re: Richard Rankin
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
: File Docket: 89 -018 -C
: Date Decided: July 12, 1991
: Date Mailed: July 16, 1991
Before: Robert W. Brown, Chair
Dennis C. Harrington, Vice Chair
James M. Howley
Daneen E. Reese
Roy W. Wilt
Austin M. Lee
The State Ethics Commission received a complaint regarding a
possible violation of the State Ethics Act, No. 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 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, however, does not affect the finality of this
adjudication. A reconsideration request must be received at this
Commission within fifteen days of issuance and must include a detailed
explanation of the reasons as to why reconsideration should be granted
in conformity with 51 Pa. Code 52.38.
The files in this case will remain confidential in accordance
with Section 8(a) of Act 170 of 1978 during the fifteen day period and
no one unless the right to challenge this Order is waived, may violate
confidentiality by releasing, discussing or circulating this Order.
However, confidentiality does not preclude discussing this case with
an attorney at law.
Any person who violates confidentiality of the Ethics Act is
guilty of a misdemeanor subject to a fine of not more than $1,000 or
imprisonment for not more than one year, 65 P.S. 409(e).
I. ALLEGATION:
That you, a Supervisor for Limestone Township, Clarion County,
violated the following provisions of the State Ethics At (Act 170
of 1978), when you used your position to obtain business as
private contractor to construct a road and then used your position
to withhold approval of the road until you were paid as a private
contractor:
II. FINDINGS:
Section 3. Restricted Activities.
(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).
Section 3. Restricted activities.
(b) No person shall offer or give
to a public official or public employee
or candidate for public office or a
member of his immediate family or a
business with which he is associated,
and no public official or public
employee or candidate for public office
shall solicit or accept, anything of
value, including a gift, loan, political
contribution, reward, or promise of
future employment based on any
understanding that the vote, official
action, or judgment of the public
official or public employee or
candidate for public office would be
influenced thereby. 65 P.S. §403(b).
1. Richard C. Rankin serves as a Limestone Township
Supervisor.
a. He has served in this position for approximately
seventeen (17) years.
b. His term of office will expire on December 31,
1991. He has not sought re- election.
2. Richard C. Rankin is a Principle in Rankin & Son,
Excavating, R.D. #1, Fairmount City, Pennsylvania.
Rankin, 89. -018 -C
Page 3
a. Rankin & Son is engaged in excavating and
construction type activities.
b. Rankin has been in the excavating business since
1979.
3. Lew Maul was an individual with certain property located in
Limestone Township.
4. In 1986, Lew Maul was interested in having a portion of a
township road, number 523, relocated.
a. This road traversed a 175 acre farm owned by
Maul.
b. The road would be moved to another part of the
farm further from the dwelling situated thereon.
5. Minutes of the Limestone Township Supervisor's meetings
indicated that on May 6, 1986, Lew Maul discussed the
possibility of relocating a portion of township road,
number 523, with the supervisors.
a. Supervisors Richard Rankin, James Henry and
Thomas Aaron were present.
6. On or about June 3, 1986, Lew Maul filed a petition with the
Limestone Township Supervisors for permission to re- locate
township road, number 523, to a different location.
7. On June 24, 1986, an agreement was executed between
Limestone Township and Lew Maul whereby:
a. Lew Maul agrees to assume all costs associated
with the relocation of township road, number 523.
b. Lew Maul agrees that the new road will be
constructed in accord with certain
specifications.
c. The township, upon completion of the new road,
agrees to vacate the prior road upon payment of
all costs associated with the relocation.
d. Lew Maul agrees to convey a right -of -way to the
township for the new road.
e. The agreement is signed by Lew Maul and Township
Supervisors, Richard Rankin, H. Thomas Aaron and
Jacob D. Henry and Secretary Robert Stahlman.
Rankin, 89 -018 -C
Page 4
8. During the May 1986 meeting of the township supervisors,
when the road relocation was first discussed, Mr. Rankin and
Mr. Maul discussed the possibility of Rankin submitting a
bid on the road construction project.
9. On or about June 26, 1986, two days after the execution of
the agreement between the township and Lew Maul, Richard
Rankin and Mr. Maul entered into an agreement whereby Rankin
& Son Excavating would perform the road construction.
10. The road construction was subsequently completed by Richard
Rankin.
11. A fee dispute arose between Richard Rankin and Lew Maul
regarding the amount of money to be paid to Mr. Rankin by
Mr. Maul for the construction services that were rendered.
12. Mr. Maul contended that:
a. Mr. Rankin agreed to do the project for $3,000.
b. During the project, the parties agreed that
Mr. Rankin was allowed to remove topsoil from the
site.
c. In return, Mr. Rankin agreed to reduce the $3,000
cost by an amount equal to $50.00 per truckload of
topsoil removal.
d. Mr. Rankin removed 38 truckloads of topsoil, and
the fee should have been reduced by that amount.
13. Mr. Rankin contended that:
a. The figure of $3,000 for the project was only an
approximate estimate based upon the assumption
that only 8 inches of topsoil would have to be
removed during construction.
b. It was agreed that the $3,000 payment would be
reduced by $45.00 for each load of topsoil
removed less the cost of removal and hauling.
c. Twenty -nine (29) loads of topsoil were removed.
d. Additional costs were incurred by Mr. Rankin,
because 36 inches of topsoil had to be removed.
e. The actual cost of the project was $6,216.00 less
$1,305.00 (29 loads of topsoil at $45.00 per
load).
Rankin, 89 -018 -C
Page 5
f. The $3,500 was a compromise figure.
14. Mr. Maul refused to pay the $3,500 to Mr. Rankin.
15. In order to complete the relocation of township road,
number 523, the Limestone Township Supervisors were
required to pass an ordinance authorizing such relocation
through the filing of a petition in the County Court of
Common Pleas.
16. On October 3, 1986, the Limestone Township supervisors met
to consider such an ordinance.
17. Minutes of the Limestone Township Supervisors meeting for
October 3, 1986 indicate the following:
Present: Richard Rankin, James Henry, Thomas Aaron
Mr. Pope read the proposed Township Ordinance 13 -86
which he had prepared and advertised. After the
reading, H. T. Aaron made a motion to adopt the
ordinance, and it was seconded by J. D. Henry, with no
discussion. A vote was called for by the solicitor.
The motion received no affirmative votes.
A lengthy discussion followed between Lew Maul, who was
present, and the supervisors and the solicitor trying
to resolve problems relative to adopting the Ordinance
13 -86. Hilton Reed was also present. A motion was
made by H. T. Aaron to retract the original motion.
Retraction of the seconding was made by J. D. Henry.
More discussion of the matter followed, and after what
appeared to a be resolution of the problems, a motion
was made to adopt Ordinance 13 -86 by H. T. Aaron and
seconded by J. D. Henry. The Chair called for a vote
which passed unanimously.
18. During the meeting of October 3, 1986, Mr. Rankin made a
comment that he should be paid first before the
consideration of the ordinance.
19. Kent Pope, the Township Solicitor, was concerned that if the
township took over the road prior to payment of the bill,
the township could be subject to a mechanics lien if
Mr. Rankin sued.
a. Rankin did not advise Pope or publicly state that
he would sue the township.
20. Mr. Maul offered to place $3,500 in escrow with the
Rankin, 89 -018 -C
Page 6
solicitor pending resolution of the fee dispute.
a. This offer was refused by Township Solicitor,
Kent Pope.
21. Mr. Maul, subsequently, left the meeting to discuss the
matter with another individual and when he returned he paid
Mr. Rankin $3,500 by check.
22. After payment, the township passed the ordinance.
23. Throughout the period that this matter was before the Board
of the Limestone Township Supervisors, Rankin abided by the
instructions and counsel of Kent Pope, Limestone Township
Solicitor.
24. Mr. Maul, subsequently, filed a civil action in the Clarion
County Court of Common Pleas seeking to recover a portion of
the funds that had been paid to Mr. Rankin on October 3,
1986.
a. Maul has taken no action to proceed on this
matter.
25. As part of the complaint in said action, Mr. Maul in part
alleged as follows:
a. On or about October 3, 1986, the township
supervisors met to consider official completion of
the terms of the agreement of June 24, 1986.
b. At that meeting, defendant demanded payment from
plaintiff, contrary to the above agreements
between them, in the amount of $3,500.00.
c. The township supervisors refused to proceed with
the relocation of the township road unless
plaintiff paid defendant $3,500.00.
26. Mr. Rankin by way of answer to the civil complaint:
a. Admitted the allegation of 25 (a) above.
b. Admitted the allegation of 25 (b) above except to
the extent that the payment was contrary to the
agreement.
c. Admitted the allegation of 25 (c) above.
Rankin, 89 -018 -C
Page 7
III. DISCUSSION:
As a Limestone Township Supervisor, Richard C. Rankin, hereinafter
Rankin, is a public official as that term is defined in the Ethics
Act, 65 P.S. 402; 51 Pa. Code 1.1. As such, his conduct is subject to
the provisions of the Ethics Act and the restrictions therein are
applicable to him.
Initially, it is noted that Section 9 of Act 9 of June 26, 1989,
P.L. 26, 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 prior to the
effective date of Act 9 (June 26, 1989), we must apply the provisions
of Act 170 of 1978, P.L. 883, 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): Hoak /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
interests; Koslow v. State Ethics Commission, 116 Pa. Commw. Ct. 19,
540 A.2d 1374 (1988). Likewise, a public official /employee may not
use the status or position of public office for his own personal
advantage; Huff, Opinion 84 -015.
Under Section 3(b) of Act 170 of 1978 quoted above, this provision
of law prohibits a public official /employee from soliciting or
receiving anything of value based upon an understanding that his vote,
official action or judgment would be influenced thereby.
The issue before us is whether Rankin violated either Section 3(a)
or Section 3(b) of Act 170 regarding his withholding approval of a
township road until he was paid for his services as a private
Rankin, 89 -018 -C
Page 8
contractor in constructing the road.
Factually, an individual by the name of Lew Maul requested the
township to relocate a portion of township road, number 523, which
transversed his 175 acre farm. In particular, Maul sought to have the
road relocated so that it would be a further distance from the
dwelling that was situated on the farm. Following the filing by Maul
in June 1986 of a petition with the supervisors for relocating
township road number 523, an agreement was executed between Limestone
Township and Maul whereby Maul agreed to assume all costs associated
with the relocation of the road, agreed that the new road would be
constructed in accordance with certain specifications, agreed to
convey a right of way to the township for the new road and in turn the
township, upon completion of the new road, agreed to vacate the
existing road.
During the discussions regarding the road relocation, Rankin
approached Maul and asked Maul if he (Rankin) could bid on the road
construction project. Rankin is a principal in Rankin and Son,
Excavating which is a company engaged in excavating and construction
type activities. Two days after the execution of the agreement
between the Township and Maul, Maul and Rankin entered into an
agreement whereby Rankin and Son, Excavating would perform the road
construction which was subsequently completed. However, a fee dispute
arose between Rankin and Maul concerning the amount of money owed
Rankin for performing the construction services. Maul asserted that
the contract price was $3,000.00 which would be reduced by an amount
of $50.00 for every truckload of soil removed by Rankin which Maul
believed was 38 truckloads. However, Rankin asserts that the
•$3,000.00 figure was based upon an assumption that only 8 inches of
top soil would have to be removed during construction and that in fact
36 inches of top soil had to be removed. In addition, Rankin contends
that the payment would be reduced by an amount of $45.00 for each
truckload of topsoil removed less the cost of removal and hauling and
that only 29 loads were removed according to his calculation. Rankin
contends that the total cost of services amounted to $6,216.00 plus a
$1,305.00 credit for 29 loads of topsoil.
In order to effectuate the relocation of the township road, it was
necessary that the township pass an ordinance that would authorize
such relocation. When the township board of supervisors met in
October of 1986, the minutes reflect that motion to pass the ordinance
was made but failed to pass due to a lack of any affirmative votes.
Rankin made a comment that he should be paid first before the
ordinance should be given any consideration (Fact Finding 18). Maul
offered to place $3,500.00 in escrow pending resolution of the fee
dispute which offer was rejected. Thereafter, Maul proffered a check
in the amount of $3,500.00 to Rankin; after payment, the Township
passed the ordinance. In a civil law suit filed by Maul against
Rankin to recover a portion of the funds he paid, Maul averred that
Rankin demanded payment from Maul at the township meeting and that the
Rankin, 89 -018 -C
Page 9
payment was contrary to the agreement between them. Rankin in his
answer did admit that he demanded the payment at the meeting but
denied that the agreed upon amount was $3,500.00.
In applying the provisions of Section 3(a) and Section 3(b) of Act
170 quoted above, we find a violation of Section 3(a) of the Ethics
Act. Clearly the action of Rankin at the October 1986 meeting at the
board of supervisors was a use of office in that he offered commentary
to lobby against enacting the ordinance for the relocation of the
township road until he was paid for the services he performed for
Maul. The use of office resulted in a financial gain in that Maul
paid $3,500.00 to Rankin by check in order to get the ordinance
enacted. Lastly, the financial gain to Rankin individually or as a
principal in the business of Rankin and Son, Excavating is other than
compensation provided for by law since there is no provision in the
Second Class Township Code which would allow a supervisor to oppose an
action on an ordinance to serve payment for private services that were
performed for the proponent of the ordinance.
We do note that as to the solicitor, at all times during the
matter of the relocation of the township road, Rankin followed the
advice of the solicitor in any official action he took.
Given the totality of the facts and circumstances in this case, we
will take no further action.
As to the Section 3(b) allegation, we find no violation of Section
3(b) of the Ethics Act. Although Rankin did vocally oppose the
adoption of the ordinance until he was paid, the required element of
-showing that an "understanding" existed in this case is lacking. The
finding of a lack of an understanding is buttressed by the fact that
at that point in time Rankin and Maul were in an adversarial situation
given the dispute between them as to the amount of money which was
owing for the service performed by Rankin and Son, Excavating. As
stated above, we find no violation of Section 3(b) of the Ethics Act
based upon the foregoing facts.
IV. Conclusions of Law
1. Richard Rankin as a Limestone Township Supervisor is a
public official subject to the provisions of Act 170 of
1978.
2. Rankin violated Section 3(a) of Act 170 of 1978 when he used
his position as supervisor to withhold approval of an
ordinance authorizing a township road until he was paid as a
private contractor for providing services in constructing
the road.
3. Rankin did not violate Section 3(b) of the Ethics Act in
that no understanding existed as to Rankin regarding the
Rankin, 89 -018 -C
Page 10
withholding of approval as to an ordinance authorizing a
township road until he was paid as a private contractor for
providing services relative to the road construction.
Rankin, 89 -018 -C
Page 11
In re: Richard C. Rankin
File Docket: 89 -018 -C
: Date Decided: July 12, 1991
: Date Mailed: July 16. 1991,
ORDER No. 806
1. Richard Rankin as a Limestone Township Supervisor violated
Section 3(a) of Act 170 of 1978 when he used his position as
supervisor to withhold approval of an ordinance authorizing
a township road until he was paid as a private contractor
for providing services in constructing the road.
2. Rankin did not violate Section 3(b) of the Ethics Act in
that no understanding existed as to Rankin regarding the
withholding of approval as to an ordinance authorizing a
township road until he was paid as a private contractor for
providing services relative to the road construction.
3. Based upon the totality of the facts and circumstances in
this case, the Commission will take no further action.
BY THE COMMISSION,
ROBERT W. BROWN, CHAIR