HomeMy WebLinkAbout85-019 UrickDear Mr. Urick:
I. Issue:
II. Factual Basis for Determination:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
September 12, 1985
OPINION OF THE COMMISSION
Richard Urick, Esquire 85 -019
23rd & Davidson Streets
Aliquippa, PA 15001
Re: Public Official, Acceptance of Prize, Municipal Authority Supplier
This responds to your request of July 31, 1985, wherein you requested the
opinion of the State Ethics Commission.
Whether the General Manager of a Municipal Authority may personally
accept a prize for which he became eligible as a result of purchasing
Authority supplies from the sponsor of a contest.
You represent the General Manager of a Municipal Authority. This person
purchased a supply of pens to be used by employees of the Authority. Payment
was to be made upon delivery of the merchandise. Upon receipt of the pens,
the General Manager signed the receipt and paid approximately $180.00 from the
Authority's petty cash fund. Soon thereafter the supplier notified the
General Manager, in writing, that he was a prize winner in a Giveaway that the
supplier had sponsored. You indicate that the individuals "eligible" in the
Giveaway had to first make a purchase through the supplier. Initially, the
General Manager was told he was eligible to receive one of five prizes.
Later, he was notified he was the grand prize winner of $20,000.00
worth of home entertainment equipment and that he had nine (9) months to claim
his prize. To date, the General Manager has not made any claim to the prize.
The supplier of the merchandise does not have any specific rules and
regulations regarding the Giveaway except to the extent that the person who
Septemberr12, 1 98g y ui re
Page 2
places the order and/or remits payment upon delivery and signs the C.O.D.
receipt, becomes an "eligible contestant." You seek the opinion of the
Commission as to whether this person may within the parameters of the law
personally accept this prize.
III. Discussion:
The General Manager of the Municipal Authority is a public employee as
that term is defined in the State Ethics Act. 65 P.S. §401 et. seq. As such,
his conduct must conform to the requirements thereof. Beck, et. al. 80 -013;
Forney v. State Ethics Commission, 425 A.2d 66, (1981).
The Ethics Act provides as follows:
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).
(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).
We have previously determined that a public official who uses his position to
obtain or otherwise accept financial gain, other than compensation provided by
law, violates Section 3(a) of the Act. Sowers, 80 -050; Huff, 84 -015;
Domalakes, 85 -010.
We also note that Section 3(b) above, prohibits the acceptance of
anything of value by a public official based upon an understanding that the
official's decisions may be influenced thereby. While it does not appear as
though this has occurred at this point in time, there is no doubt that such an
offer to a public official may be viewed as an inducement to foster more
purchases in the future by that official. Trotta, 85 -002.
Richard Urick, Esquire
September 12, 1985
Page 3
In reference to Section 3(a) of the Act, this person became eligible for
this prize only as a result of his public position and purchases made in that
position. This prize is financial gain that will be obtained by this person
in and through his public office and it is not compensation provided by law.
We, therefore, believe that this individual would be using his public office
in violation of Section 3(a) and that he may not, therefore, personally accept
this prize.
The conclusion we reach herein, is also a result of Section 403(d) of the
Ethics Act. Pursuant to that provision, the Ethics Commission is empowered to
address other areas of possible conflict. 65 P.S. §403(d). Fritzinger,
80 -008. Such a conflict may exist where an individual represents one or more
adverse interests, Alfano, 80 -007, or where an individual serves in positions
that are incompatib a or conflicting or where a public official accepts
financial gain in and obtained through their public position other than their
compensation. Domalakes, 85 -010. The intent of the Ethics Act in this
respect is clear.
In this situation, this person's eligibility in the contest was
occasioned only by the purchases he made as a public official using public
funds. There is no indication that this person would have entered this
contest in his private capacity or if he has even frequented this business
apart from his official capacity.
Additionally, there are no rules or regulations for this contest and,
therefore, there is no way of determining how this person was selected, who
else may have participated and if any minimum purchase was required.
In light of these factors, if this person were to now accept this prize,
we believe that a conflict of interest would be created under §403(d) and §401
of the Ethics Act as well as Section 403(a) as previously noted.
With the foregoing in mind, we note that there is no per se prohibition
upon this person accepting this prize on behalf of and for the use of the
Authority. See Rosenfeld, 82 -010. We do, however, caution that if accepted,
the Authority's dealing with this company in the future must be conducted in
accordance with approriate legal Authority. We also note that when and if the
Authority decides to accept this gift, such acceptance should be publicly
disclosed. Likewise, the Authority should determine for itself that this
contest, was in fact, bona fide. Verification of the true "chance" nature of
the contest avoids the probability of future Ethics Act violations. We must
note that in the event that additional questions arise in the Authority's
future dealing with this supplier, the Authority may wish to seek the further
advice of this Commission.
Richard Urick, Esquire
September 12, 1985
Page 4
IV. Conclusion:
The General Manager of a Municipal Authority who has won a prize from a
business with which the Authority deals, may not under the circumstances here
present, personally accept such prize. Such a benefit must inure to the
Authority. Additionally, while there is no per se prohibition on the
Authority's acceptance of this prize, the Authority must first determine the
nature of the contest as outlined above. If after these facts are determined,
the Authority elects to accept the prize, all relevant factors must be
publicly disclosed.
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.
JJC /sfb
By the Commission,
HE : RT B. CONNER
Chai rman