HomeMy WebLinkAbout817 SitekIn Re: Benjamin J. Sitek
STATE ETHICS COMMISSION
30$ FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
: File Docket:
: Date Decided:
. Date Mailed:
91- 007 -C2
December 4, 1291
December 11, 1991
Before: Dennis C. Harrington,
James M. Howley
Daneen E. Reese
Roy W. Wilt
Austin M. Lee
James P. Gallagher
Allan M. Kluger
The State Ethics Commission received a complaint regarding a
possible violation of the State Ethics Act, Act 9 of 1989, 65 P.S.
401 et. seq. Written notice, of the specific allegation(s) was served
at the commencement of the investigation. A Findings Report was
issued and served, upon completion of the investigation, which
constituted the Complaint by the Investigation Division. An Answer
was filed and a hearing was waived. A Consent Order was submitted by
the parties to the Commission for consideration which was
subsequently approved. This adjudication of the Commission is hereby
issued which sets forth the individual Allegations, Findings of Fact,
Discussion, Conclusions of Law and Order.
Chair
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 S2.38.
The files in this case will remain confidential in accordance
with Act 9 of 1989, 65 P.S. 408(h) 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 Franklin Township, Erie County,
violated the following section of the Public Officials and
Employees Ethics Law, when you were compensated as a township
roadmaster without being appointed to the position; and when you
received compensation not related to the duties of roadmaster or
laborer:
Section 3. Restricted Activities
(a) No public official or public employee
shall engage in conduct that constitutes a
conflict of interest. 65 P.S. S403(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 or his immediate family or a
business with which he or a member of his
immediate family is associated. 65 P.S. 5402.
II. FINDIIIGS :
1. Benjamin Sitek serves as a Township Supervisor, in Franklin
Township, Erie County, Pennsylvania.
a. He has served in this position since January 1986.
b. He has served as a supervisor /employee for
Franklin Township since 1986.
2. Reorganizational meeting minutes of the Franklin Township
supervisors indicate the following action was taken relative
to the hiring of Benjamin Sitek as a road laborer:
a. January 6, 1986:
Sitek, 91- 007 -C2
Page 3
Motion by Herbert Netzler, seconded by John
Sachar, to appoint Benjamin Sitek as Summer
Assistant Superintendent.
Vote: Netzler, Sachar - Yes
Abstained: Sitek
Present: Sitek, Netzler and Sachar
Motion by Herbert Netzler, seconded by John
Sachar, to appoint Benjamin Sitek as equipment
operator and laborer.
Vote: Netzler, Sachar - Yes
Abstained: Sitek
b. January 5, 1987:
Motion by Benjamin Sitek, seconded by Herbert
Netzler, to appoint the following persons as
equipment operators: John Sachar, Benjamin Sitek,
Herbert Netzler, Paul Pieper, Lawrence Pieper,
David Henderson, Ed Warhola, Ron Walter, Jeff
Carter, John Bardo, Richard Gould and Robert
Lewandowski.
Vote: Unanimous
Present: Sachar, Sitek and Netzler
c. January 4, 1988:
Motion by Herbert Netzler, seconded by Wayne
Cousin, to appoint as laborers and equipment
operators Benjamin Sitek, Wayne Cousin, Jeff
Carter, Richard Gould, Paul Pieper, Victor Kalicy,
Randy Hammond, Dennis Swift, David Henderson and
William Barry.
Vote: Unanimous
Present: Sitek, Netzler and Cousin
d. January 3, 1989:
Equipment Operators and Laborers: Motion by Ben
Sitek, seconded by Herbert Netzler, to appoint as
equipment operator and laborer: Ben Sitek, Wayne
Cousin, Jeff Carter, Rick Gould, Paul Pieper, Vic
Sitek, 91- 007 -C2
Page 4
Kalicy, Randy Hammond, Dennis Swift, David
Henderson, William Barry and Steven Burt.
Vote: Unanimous
Present: Sitek, Cousin and Netzler
e. January 2, 1990:
Equipment Operators and Laborers - Herb Netzler
moved to appoint Paul Pieper, Jeff Carter, Richard
Gould with Dave Henderson, Don Perry and Ray
Swift appointed to plow snow when needed. Ben
Sitek seconded, motion carried.
Present: Netzler, Cousin and Sitek
1) The minutes do not reflect that Sitek
was approved by the Board of
Supervisors to be employed by the Road
Department during 1990.
f. January 7, 1991:
Ben Sitek moved to appoint David Henderson as
Superintendent. David Henderson seconded, motion
carried. (One Nay - Herbert Netzler)
Equipment Operators and Laborers: Henderson moved
to appoint Jeff Carter, Richard Gould, Raymond
Swift, Herbert Netzler, David Henderson, Benjamin
Sitek, John Conrad, Wayne Cousin, Donald. Perry,
John Sachar, Paul Pieper and Lawrence Pieper as
equipment operators and laborers. Ben Sitek
seconded, motion carried.
Present: Henderson, Sitek and Netzler
g. January 24, 1991:
"After the Pledge of Allegiance ", affirmation of
the Organizational Meeting was as followed:
Henderson asked if Attorney Schroeck had an
affirmation motion ready. None was ready so
H. Rubinfield suggest we do everything that was
done at the January 7, 1991 meeting ".
Roadmaster: "Sitek referred to the January 7th
minutes and stated that he wasn't going to reread
his statement. Sitek moved to appoint Dave
Henderson as roadmaster ". Dave Henderson
Sitek, 91- 007 -C2
Page 5
Present: Henderson, Sitek and Netzler
3. Benjamin Sitek's daily time cards indicate that he worked
460.5 hours during 1990.
a. Sitek was compensated at a rate of $8.00 per
hour.
b. W -2 Wage and Tax Records indicate Sitek received
$3,794.00 compensation during 1990.
4. Benjamin Sitek's time cards for 1990 indicate the following
break down of hours worked and duties performed:
Date
seconded, motion carried. (One Nay - Herbert
Netzler)
Equipment Operators and Laborers: "Henderson
moved to approve Jeff Carter, Richard Gould,
Raymond Swift, Herbert Netzler, David Henderson,
Benjamin Sitek, John Conrad, Wayne Cousin, Ronald
Barry, John Sachar, Paul Pieper, Lawrence Pieper,
Ed Warhola as equipment operators and laborers.
Sitek seconded, motion carried ".
Hours Road Building Other
1/5/90 3.5 3.5
1/8/90 8
1/11/90 5.5
1/29/90 5
1/31/90 3
2/12/90 4 4
2/13/90 3 3
2/22/90 7
3/14/90 7.5 7.5
3/16/90 8 8
3/20/90 8 3
3/23/90 4
3/19/90 8 8
3/22/90 2 2
3/26/90 7 7
3/28/90 7.5 7.5
8
5
3
5
4
5.5 Surplus
7 Surplus
Sitek, 91- 007 -C2
Page 6
Date Hours Road Building Other
3/29/90 8.5 8.5
3/30/90 6 6
9/4/90 3 3
9/5/90 5 5
9/6/90 5 5
9/7/90 7 7 Census
9/9/90 6 6 Census
9/10/90 7 5 2 Census
9/14/90 6.5 6.5
9/17/90 6.5 6.5
9/18/90 6.5 6.5
9/19/90 6.5 6.5
9/20/90 6 6
9/24/90 6.5 6.5
9/25/90 6.5 6.5
9/26/90 4 4
9/27/90 8 8
9/28/90 6 6
10/1/90 3 3
10/8/90 8 8
10/9/90 8 8
10/10/90 7 7
10/11/90 7 7
10/15/90 10 10
10/17/90 8 8
10/18/90 9 9
10/10/90 7.5 7.5
10/22/90 8 8
10/23/90 8 8
10/24/90 8 8
10/31/90 6 6
11/2/90 7 7
11 /5/90 7 7
Sitek, 91-007-C2
Page 7
D to our two d Building , ther
11/6/90 7 7
11/7/90 8 8
11/8/90 4 4
11/12/90 7 7
11/13/90 3 3
11/14/90 8 8
12/3/90 8 8
12/4/90 7 7
12/5/90 7 7
12/6/90 4 4
12/7/90 7.5 7.5
12/12/90 6.5 6.5
12/13/90 7 7
12/14/90 8.5 8.5
12/17/90 6 6
12/18/90 9 9
12/19/90 5 5
12/20/90 11 11
12/21/90 4 4
12/22/90 8.5 8.5
12/27/90 3.5 3.5
,12/28/90 4 4
12/31/90 4 4 12.5 Surplus
TOTALS: 460.5 74.5 358.5 15.0 Census
5. Franklin Township records indicate Sitek received
compensation for the following:
a. Building Repairs /Renovations - 358.5 Hours
b. Conducting a Census Survey - 15 Hours
c. Trips to the Surplus Store - 12.5 Hours
d. Compensation for the work listed in Finding No. 5
(a, b and c) was at a rate of $8.00 per hour.
Sitek, 91- 007 -C2
Page 8
6. Due to an illness, Sitek was unable to do much work on the
roads in 1990.
7. Repairs and renovations to the township building included
the building of an addition, cement, electrical heating and
finishing work.
a. All township employees were utilized to some
degree on this project.
b. The majority of the work was performed by
Supervisors Henderson and Sitek.
c. Renovations occurred during the months of October,
November and December 1990.
8. Township auditors believed that this sort of work should
have been handled by the hired township employees on days
which the weather did not permit them to be out working on
the roads.
9. During November of 1990, full time Road Department
employees, Paul Pieper, Jeff Carter and Rick Gould, were
laid off to save the township money. While Carter, Gould
and Pieper were laid off, Supervisors Henderson and Sitek
continued to work renovating the township building.
a. Neither Henderson nor Sitek were out performing
any physical labor on the roads at this time.
10. Franklin Township daily time sheets indicates Sitek worked
on a township census on the following dates:
a. September 6,.1990 - 6 Hours
b. September 7, 1990 - 7 Hours
c. September 10, 1990 - 2 Hours
11. Minutes of the Franklin Township Board of Supervisors
indicate the following relative to a census count:
a. September 11, 1990:
Old Business Census - "Henderson reported that
since he was put in charge of the census in
January, he hasn't had anything to do with it
until the count came back. It has and shows 500
homes, 34 vacants. We show 494 homes and 33
vacants, but the head count is off. Challenges
must be made by next Wednesday, September 19 ".
Sitek, 91- 007 -C2
Page 9
b. September 27, 1990:
"Henderson reported that the Challenge was filed
on time. We estimated the head count at 1,510
while the census count was 1,412. We had an 80%
return on the survey cards ".
12. Franklin Township time cards indicate Sitek was compensated
for trips to the Surplus Store on two occasions.
a. January 11, 1990 - 5.5 Hours
b. February 22, 1990 - 7.0 Hours
13. Franklin Township auditor minutes are unavailable as said
records were lost.
a. Minutes for 1991 indicate that the rate of
compensation for supervisors in 1990 was
$8.00 /hour.
14. The lack of reference to Mr. Sitek's appointment in 1990 may
be due to clerical error.
15. Statements of Financial Interests on file with Franklin
Township include the following filings for Sitek:
a. Calendar Year: Not Listed
Filed: 3/26/86 on SEC Form 1/87
Position: Franklin Township Supervisor
Occupation: Retired
Direct /Indirect Sources of Income: Franklin
Township
All Other Financial Interests: None
b. Calendar Year: 1985
Filed: 4/10/86
Position: Franklin Township Supervisor
Occupation: Retired
Direct /Indirect Sources of Income: Franklin
Township
Sitek, 91-007-C2
Page 10
All Other Financial Interests: None
c. Calendar Year: Not Listed
Filed: 3/18/87 on SEC Form 1/89
Direct /Indirect Sources of Income: None
A11 Other Financial Interests: None
d. Calendar Year: 1987
Filed: 4/8/88
Position: Franklin Township Supervisor
Occupation: Retired
Direct /Indirect Sources of Income: Franklin
Township
All Other Financial Interests: None
e. Calendar Year: Unlisted
Filed: 3/28/89
Position: Franklin Township Supervisor
All Categories of Financial Interests: None
f. Calendar Year: Not Listed
Filed: March 13, 1990 on SEC Form 1/90
Position: Franklin Township Supervisor
Occupation: Retired
All Sources of Financial Interest: None
g. Calendar Year: Not Listed
Filed: 1/23/91 on SEC Form 1/90
Position: Franklin Township Supervisor
Occupation: Retired
All Categories of Financial Interests: None
Sitek, 91- 007 -C2
Page 11
III. pISCtJSSION:
h. Calendar Year: 1991
Filed: 3/6/91 on SEC Form 1/87
Position: Candidate Franklin Township Supervisor
Occupation: Retired
All Categories of Financial Interests: None
As a Supervisor for Franklin Township, Erie County, Benjamin J.
Sitek, hereinafter Sitek, 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 as
follows:
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
Sitek, 91- 007 -C2
Page 12
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 or his immediate family or a
business with which he or a member of his
immediate family is associated. 65 P.S. §402.
The issue before us in this case is whether Sitek violated Section
3(a) of the Ethics Law regarding his receipt of compensation as a
roadmaster without being appointed to that position and also his
receipt of compensation for performing duties that did not relate to
the position of roadmaster or laborer.
Sitek has served as a Township Supervisor and as a Township
employee since January 1986. The reorganizational minutes for the
Franklin Township Supervisors reflect the following action for the
years 1986 through 1991: on January 6, 1986, Sitek abstained from two
motions which appointed him as summer assistant superintendent and as
equipment operator and laborer; on January 5, 1987, Sitek made and
voted in favor of a successful motion to appoint himself and others as
equipment operators; on January 4, 1988, Sitek voted in favor of a
successful motion which appointed himself and others as laborers and
equipment operators; on January 3, 1989, Sitek made and voted in
favor of a successful motion to appoint himself and others as
equipment operators and laborers; on January 2, 1990, Sitek seconded
and voted in favor of a successful motion to appoint others, not
including himself, for road work positions; on January 7, 1991, Sitek
seconded and voted in favor of a successful motion to appoint himself
and others to the positions of equipment operators and laborers, and
on January 24, 1991, Sitek seconded and voted in favor of a successful
motion to appoint himself and others as equipment operators and
laborers in the township.
During the 1990 calendar year, the time cards for Sitek reflect
that he worked 358.5 hours on building repairs and renovations, 15
hours doing census survey work and 12.5 hours as to trips to the
surplus store.
The minutes of the Franklin Township Auditors, with the exception
of the 1991 year which reflect an approval of a compensation rate for
supervisors in 1990 at $8.00 per hour, are unavailable in that those
records are lost. In addition, the record reflects that the omission
of Sitek's appointment in 1990 may have been due to a clerical error
(Fact Finding 14).
Sitek, 91- 007 -C2
Page 13
Finally, we note as to the Financial Interests Statements (FIS) on
file by Sitek at the township, several of the forms do not list the
particular calendar year for which the form is filed and several forms
do not list Franklin Township as a source of income for Sitek.
In applying the provisions of Section 3(a) of Act 9 of 1989 to the
allegation, we find that Sitek was appointed to a road position for
every year from 1986 through 1991 with the exception of 1990. As to
the 1990 calendar year, it is clear that such omission in the minutes
was a clerical error and, hence, we find as a matter of fact that
Sitek was likewise appointed to a road position for that year.
Accordingly, as to the portion of the allegation that Sitek violated
Section 3(a) by being compensated as a township roadmaster without
being appointed to that position, we find no violation based upon the
above.
Turning to the portion of the allegation that Sitek received
compensation not related to the duties of roadmaster or laborer, we do
note that in addition to performing building and road repairs and
other activities, Sitek also performed 15 hours of work conducting a
census survey. Since the particular activity of conducting a census
survey does not relate to the position of an employee /supervisor but
is part of the administrative duties of an elected supervisor, we find
a technical violation as to Sitek's activities of conducting the
census survey. However, given the totality of the facts and
circumstances in this case, we will take no further action.
As to Sitek's FIS's, in light of the above deficiencies, we direct
Sitek within thirty (30) days of issuance of this Order to correct the
deficiencies by amending his FIS's to designate specific calendar
years as well as listing Franklin Township as a source of income where
he failed to do so. Failure to correct the FIS deficiencies within
thirty (30) days of issuance of this Order will result in the referral
of this matter for an FIS enforcement action.
IV. CONCLUSIONS OF LAW:
1. Benjamin Sitek, as a Franklin Township Supervisor, is a
public official subject to the provisions of Act 9 of 1989.
2. Sitek did not violate Section 3(a) of Act 9 of 1989 by
receiving compensation as a township roadmaster since he was
appointed to a road position for the calendar years 1986
through 1991.
3. A technical violation occurred when Sitek received
compensation for conducting a census survey which did not
relate to his duties as an employee /supervisor.
In Re: Benjamin J. Sitek
: File Docket: 91- 007 -C2
: Date Decided: December 4,1991
: Date Mailed: December 11,1991
ORDER No. 817
1. Benjamin Sitek, as a Franklin Township Supervisor, did not
violate Section 3(a) of Act 9 of 1989 for receiving
compensation as a township supervisor since he was appointed
to a road position for the calendar years 1986 through 1991.
2. A technical violation occurred when Sitek received
compensation for conducting a census survey which did not
relate to his duties as an employee /supervisor.
3. Sitek is directed within thirty (30) days of issuance of
this Order to file amended Financial Interests Statements
with Franklin Township to correct the following
deficiencies:
a. To include the calendar year for which the FIS's
are being filed.
b. To list Franklin Township as a source of income.
4. Failure by Sitek to comply with the provisions of paragraph
3 will result in the referral of this matter for an FIS
enforcement action.
BY TIj COMMISSION,
DENNIS C. HARRINGTO , CHAIR