HomeMy WebLinkAbout84-013 BellSenator Clarence D. Bell
Senate of Pennsylvania
State Capitol
Harrisburg, PA 17120
RE: Bumper Stickers; Leased Car
Dear Senator Bell:
I. Issue:
II. Factual Basis for Determination:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
July 31, 1984
OPINION OF THE COMMISSION
84 -013
You ask whether you may display or place a bumper sticker on your
automobile.
You currently serve as a member of the Senate of the Commonwealth of
Pennsylvania. You indicate that you use a car that is paid for with state
funds either by way of mileage reimbursement or on a leasing formula.
Specifically, you state that payment for expenses associated with the
operation of a car for one round -trip per week is authorized to be paid from
the general funds of the Senate and the remainder of the costs for operating
your car on official business are paid from your accountable expense account.
You indicate that you lease a car and you are reimbursed at the rate of
20.5 cents per mile for the official use of your car. We do take notice of
the fact that the Senate does have a resolution which deals, in general with
the question of use of expense accounts. See Article XXXVI, Rules of the
Senate and Resolution No. 53, adopted July 1, 1981.
You ask, however, whether under these circumstances, you may affix, to
the car described above, a bumper sticker suggesting your own re- election or
the election of others. You state that the Senate has no specific regulations
or guidelines as to such stickers.
Senator Clarence D. Bell
July 31, 1984
Page 2
We will assume for purposes of this response that this car does not bear
the designation, as do cars supplied and maintained by the Department of
General Services such as "State Car -- For Official Use Only" and that this
car is used for personal purposes, i.e. other than for transportation related
to your official functions and duties as a Senator.
III. Applicable Law:
The law to he 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
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.
IV. Discussion:
(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.
As an elected Senator you are clearly a "public official" as that term is
defined in the Ethics Act, 65 P.S. 402. As such your conduct must conform to
the requirements of the Ethics Act. In performing your duties as Senator you
must, on occasion, travel. The Senate recognizes this need and provides
reimbursement for the travel- expenses associated with your position. The
question of the propriety of having your political advertising or that of
others on the vehicle which is used and for which reimbursement is sought is a
novel and difficult one.
Senator Clarence D. Bell
July 31, 1984
Page 3
We have ruled, for example, that a district office provided for a
Representative and paid for out of public funds may not be used as a campaign
headquarters. Cessar, 82 -002. But is a car, a mode of transportation,
substantively identical to the office facilities at issue in Cessar? Even if
so, would the affixation of a bumper sticker -- even one supporting your own
re - election -- be equivalent to the use of facilities proposed and reviewed in
Cessar?
We think not. The car in question here is not so identifiable as was the
facility in question in Cessar as for the official as opposed to the personal
or political use only. The car in question here can be and is used for other
than official trips. A member of the public, without checking the specific
dates, times and locations of trips for which reimbursement is eventually
sought, would not perceive that as to any particular time or date your car was
being used for personal versus official purposes.
We continue to believe that public officials must, to the highest degree
possible, assure the public that their financial interests present neither a .
conflict nor the appearance of a conflict with the public trust. However,
here, the perception of the public viewing a bumper sticker on a car which is
not identified or clearly identifiable as operating on official business (for
which reimbursement will be sought) or on a private trip, unrelated to your
duties as a Senator is necessarily different from the public's perception of a
re- election campaign being run from an office provided solely for public
purposes and paid for out of public funds.
The difference is not only one of kind, but of degree as well. We are
mindful of the de minimus nature of a bumper sticker versus the use of
district office telephone lines, for example. We believe that the public's
reaction to and rejection of the use of a publicly funded district office, as
a re- election nucleus is quite different in degree from the affixation of a
bumper sticker on your car. This is particularly true where the sticker would
support the election of someone other than yourself and the degree to which
you would be financially interested in or benefit from such support is not
articulated or apparent.
V. Conclusion: It would not be improper or violative of the Ethics Act for
you to affix a bumper sticker as described herein to your car.
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.
Senator Clarence D. Bell
July 31, 1984
Page 4
Finally, any person may request within 15 days of service of the opinion
that the Commission reconsider its opinion. The person requesting
reconsideration should present a detailed explanation setting forth the
reasons why the opinion requires reconsideration.
SSC /na
HERBE'T 'ONNER
Chairman