HomeMy WebLinkAbout79-036 LevinNorman L. Levin, Esquire
Brugler &Levin
10 South Wayne Street
Lewistown, PA 17044
Dear Mr. Levin:
STATE ETHICS COMMISSION
HARRISBURG, PA.
July 9, 1979
79 -036
In your letter of February 15, 1979, you requested
an opinion from the State Ethics Commission concerning whether
School Directors and School Solicitors are covered by Act 170
of 1978.
Act 170 applies to "public officials" and "public
employees" of the Commonwealth or a political subdivision. The
Act does not define the term "political subdivision ". The
Statutory Construction Act, 1 Pa. C.S.A., Section 1991 (Supp.
1978) defines "political subdivision" as any "county, city,
borough, incorporated town, township, school district, vocational
school district and county institution district ".
It is the Commission's opinion that solicitors for
school districts are "public employees" of a "political subdivision ".
Section 4 of the Act requires "public officials" and "public
employees" to file statements of financial interests. Pursuant
to Section 4(a) of the Act, a public employee of a political sub-
division is required to "file a statement of financial interest
with the governing authority of the political subdivision by which
he is employed no later than May 1 of each year that he holds such
a position and of the year after he leaves such a position." The
effective date of Section 4(a) of the Act requires that each
candidate for public office "file a statement of financial interest
for the preceding calendar year with the Commission prior to filing
a petition to appear on the ballot for election as a public official."
Candidates for elective office between August 1, 1979 and January 1,
1980, must file financial disclosure statements at least 60 days
prior to the regular election or 15 days prior tt a special election.
Norman L. Levin, Esquire
July 9, 1979
Page Two
Thereafter, the statements
the Commission prior to fi
as noted above.
This letter is a
able as such.
State Ethics Commission
308 Finance Building
Harrisburg, PA 17120
(717) 783 -1610
of financial interest are filed with
ling a petition to appear on the ballot
public record and will be made avail-
Sincerely,
1Paul,/ . Smith
Chairman
UPDATE: A Pennsylvania Supreme Court ruling (436 A.2d 186) dealt with a similar factual determination. The court rul-
ing states that all part -time solicitors to political subdivisions are neither public employees nor public officials
within the scope of the Ethics Act. Consequently, the Ethics Commission has no jurisdiction over solicitors to
political subdivisions. The court ruling did not address this particular opinion, but the factual circumstances
may be applied to it. A case dealing with the question of application of this court ruling to school board solicitors
(Seelbaker) is pending.
UPDATE: School Directors — A Pennsylvania Supreme Court ruling upheld the fact that school directors are covered by
the Ethics Act, (170- 1978); and therefore required to file Financial Interest Statements. See 436 A.2d 593.
A subsequent suit has been filed in which questions of spousal privacy and disclosure are raised. The Common-
wealth Court (No. 273 C.D. 1981, filed 3/21/83) upheld the Ethics Act against these arguments by school direc-
tors and their spouses. This case is currently pending before the Pennsylvania Supreme Court and the lower
court has stayed its decision pending such appeal. The result is that with final disposition by the Supreme Court,
school directors need not provide spousal financial data on their Financial Interest Statement.