HomeMy WebLinkAbout83-003 TooheyJohn S. Toohey, Esquire
North Church Street Extension
Box 5775
Mount Pleasant, PA 15666
II. Factual Basis for Determination:
III. Applicable Laws:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
March 3, 1983
OPINION OF THE COMMISSION
RE: Rehabilitation Program, Councilmen Participation
Dear Mr. Toohey:
I. Issue:
83 -003
You inquire as to whether the Ethics Act prohibits or places any
restraints upon the participation by a councilman in a rehabilitation program
administered by the Borough.
You serve as solicitor for the Borough of Scottsdale, hereinafter, the
Borough. The Borough is a direct grantee of funds for their Housing
Rehabilitation Program which is funded in part with grants from the Department
of Community Affairs (DCA) and in part from the U. S. Department of Housing
and Urban Development (HUD). Two councilmen hereinafter, the Councilmen,
within the Borough apparently qualify for participation in the program and are
located in the designated "target" areas for rehabilitation purposes.
The Councilmen intend to apply for these grants. The Borough's grant
program would not require a contract to be made between the Councilman and the
Borough. If the grant is made it would involve an expenditure of money by the
Borough and the Councilmen would benefit from the contract.
The law to be applied to this question is as follows::
Section 1. Purpose
The Legislature hereby declares that public office is a
public trust and that any effort to realize personal
financial gain through public office other than
compensation provided by law is a violation of that trust.
In order to strengthen the faith and confidence of the
people of the State in their government, the Legislature
further declares that the people have a right to be
assured that the financial interests of holders of or
John S. Toohey, Esquire
March 1, 1982
Page 2
candidates for public office present neither a conflict
nor the appearance of a conflict with the public trust.
Because public confidence in government can best be
sustained by assuring the people of the impartiality and
honesty of public officials, this act shall be liberally
construed to promote complete disclosure. 65 P.S. 401.
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. 403(a)
(c) No public official or public employee or a member of
his immediate family or any business in which the person
or a member of the person's immediate family is a
director, officer, owner or holder of stock exceeding 5%
of the equity at fair market value of the business shall
enter into any contract valued at $500 or more with a
governmental body 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. Any contract made in
violation of this subsection shall be voidable by a court
of competent jurisdiction if the suit is commenced within
90 days of making of the contract. 65 P.S. 403(c).
(e) No former official or public employee shall represent
a person, with or without compensation, on any matter
before the governmental body with which he has been
associated for one year after he leaves that body.
65 P.S. 403(e).
Borough Code, 53 P.S. 46404:
No Borough Official ... shall be interested in any
appreciable degree, either directly or indirectly in any
... contract entered into or expenditure money-made by the
Borough ... involving the expenditure ... of more than
$1000 in any calendar year
John S. Toohey, Esquire
March 1, 1982
Page 3
IV. Discussion:
As elected Councilmen, the two individuals in question, are "public
officials" as defined by the Ethics Act. 65 P.S. 402. As public officials,
these Borough Councilmen must insure that their conduct conforms to the
requirements of the Act and presents neither a conflict nor the appearance of
a conflict with the public trust.
The first question you raise is whether the Councilmen in question must
conform their conduct exclusively to the requirements of the Ethics Act or
whether the requirements of the Borough Code, cited above, remain 4pplicable.
Specifically, is there any "conflict of law" between the requirements of the
Ethics Act and the Borough Code? These two sections do not, in our
estimation, conflict. The Borough Code would prohibit an indirect interest in
a contract, while the Section 3(c) of the Ethics Act requires an open and
public process to be applied where a contract is made directly between the
governmental body on which the Councilmen serve (Borough Council) and the
Councilmen. The'two sections of law do not conflict; each can be complied
with and, therefore, there is no need to apply the "conflict of law"
provisions of Section 12 of the Ethics Act even if this provision were to be
said to supercede and preclude the application of the Borough Code. See 65
P.S. 412.
We must apply the provisions of the Ethics Act and render our opinion in
relation to those provisions. We do not review or make any comment as to the
interpretation of the Borough Code. Such interpretation is not within our
jurisdiction. In relation to Section 3(c) of the Ethics Act, as noted above,
there is no contract in this case between the Borough and the Councilmen.
Thus, the provisions of Section 3(c) of the Ethics Act which would require an
open and public process before any contract between the Councilmen and the
Borough can be awarded are inapplicable.
The Ethics Act also requires that no public official may use his public
office to obtain financial gain for himself, a member of his immediate family
or business with which he is associated to an extent other than the
compensation allowed by law. See Section 3(a) of the Ethics Act, 65 P.S.
403(a). The fact that an individual is a "public official" does not generally
and automatically disqualify him from participating in programs which would
otherwise be available to hirn as a member of the general public. This Section
of the Ethics Act would, however, require that if and when a public official
is in a position to tailor the benefit program to specially benefit himself or
to influence the award of a grant to himself, a business with which he is
associated, or a member of his immediate family, he should in all cases
abstain from participating in the decision - making process related to such.
John S. Toohey, Esquire
March 1, 1982
Page 4
Thus, an individual Borough Councilman could apply for funds, so long as
he played no role in deciding who would get the funds, establishing the
criteria by which the program itself was to be operated and /or criteria by
which applications would be reviewed or actually granted, and used no
confidential information acquired during his holding of public office to apply
for or obtain such funds. Additionally, there should be no use of office so
as to "mold" or "tailor" the program to benefit the official.
In the present case the standards of the program appear to be established
to conform to [)CA and HUD requirements but if these individual Councilmembers
"molded" this program to their own benefit they could not then participate in
the program. In any event, it is clear that the Councilmen must remove
themselves from making any decisions (including discussions) on the;
distribution of the limited funds available. If a Councilman- applicant could
effectively deny all grant applications other than his own thereby making
funds available for his own home /project, the public perception of
impartiality would undoubtedly be impaired. See Reisinger, 82- 146 -C. Also,
in this same vein, the Councilmen- applicants should insure the widest possible
dissemination of the fact that they are applying for these funds, that the
public is allowed to comment on this process and that the reasons for
abstention as set forth above are placed on the public record.
Finally, you ask whether Section 3(e) of the Ethics Act would impose any
restrictions on an individual who might resign from public office and then
apply for grant funds. Section 3(e) of the Ethics Act requires that no public
official could represent a person with or without compensation on any matter
before the governmental body with which he had been associated within the
first year after he leaves public office. The Ethics Act does not and this
Commission has not been inclined to interpret the Act to restrict an
individual from representing his own personal interest except to acquire a
contract within the first year after he leaves governmental service. See
Lloyd, 80 -040. Where an individual is applying for funds for himself which
are generally available to the public and where he did not "mold" the program
to benefit himself individually or otherwise through his votes on other
applications insure the availahility of funds when he leaves office, it would
be inappropriate to limit his right to seek such funds for his personal
residence even within the first year after he leaves public office and even
with respect to the governmental body with which he was associated.
Accordingly, should the Councilmen in question resign and should they
seek grants to rehabilitate their own personal dwellings, an application could
be presented to the governmental body with which they had been associated
within the first year after they leave the Borough Council.
John S. Toohey, Esquire
March 1, 1982
Page 5
V. Conclusion:
Section 3(c) of the Ethics Act is inapplicable since the contract in
question would not be made between the Borough and the Borough Councilmen.
Section 3(c) of the Ethics Act does not conflict with the provisions of the
Borough Code in this respect and, therefore, should not be deemed to supersede
any provisions of the Borough Code. The directions as to abstention from
participating in the Borough's decisions on establishing the criteria for the
program so as to "mold" the program or to actually produce benefits for
oneself and as =to awarding grants /funds must be met to insure compliance with
Section 3(a) of the Ethics Act. A Councilman - applicant should disclose and
disseminate information as to his application and abstain as discussed
above for the entire fiscal year(s) associated with his applicatior4.
If the Councilman were to resign and to apply for funds under a program
which would otherwise be available to members of the general public, Section
3(e) of the Ethics Act would not prohibit presenting such an application to
the governmental body with which the Councilman had been associated, even
within the first year after he leaves public office where that application is
made with respect to the personal individual dwelling unit of the former
public official and where while in office, the official did not "mold" the
program so as to benefit himself individually or otherwise use his votes or
influence, while in office, to insure that funds would be available to him or
for his use upon leaving office.
Pursuant to Section 7(9)(i), this opinion is a complete defense in any
enforcement proceeding initiated by the Commission, and evidence of good faith
conduct in any civil or criminal proceeding, providing the requestor has
disclosed truthfully all the material facts and committed the acts complained
of in reliance of the advice given.
This letter is a public record and will be made available as such.
Finally, any person may request within 15 days of service of the opinion that
the Commission reconsider its opinion. The person requesting reconside-
ration should present a detailed explanation setting forth the reasons why the
opinion requires reconsideration.
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By the Commission,
PAUL J. ,SMITH
Chairman
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