HomeMy WebLinkAbout88-004 GollaEdward B. Golla, Esquire
Nine West Pennsylvania Avenue
P.O. Box 184
Stewartstown, PA 17363
Dear Mr. Golla:
I. Issue:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
H..RRISEURG, PENNSYLVANIA 17120
O.'':NION OF THE COMMISSION
DATE DECIDED 6
DATE MAILED 6/24/88
II. Factual Basis for Determination:
88-004
Re: Conflict of Interest, Borough Councilman, Voting on
Matters as to the Borough Water /Sewer Authority,
Private Litigation against the Borough Water /Sewer
Authority
This opinion is issued in response to your requests of March
29, and April 4, 1988.
Whether the State Ethics Act imposes any restrictions or
prohibition upon a borough councilmember participating in or
voting on matters concerning a borough water /sewer authority when
the borough councilmen is involved in litigation with that
authority and the borough as to the requirement that he hook -up
to the authority water system.
You state that you represent Charles K. Herbert who has been
a member since 1982 of the Stewartstown Borough Council,
hereinafter Council. On April 9, 1984 a water system was
purchased from the General Water Works Company of Harrisburg and
is now currently owned by the Stewartstown Water /Sewer Authority
hereinafter Authority. Following the passage of a borough
ordinance which required a hook -up to the water system, Mr.
Herbert and twenty other citizens in Stewartstown Borough filed
suit in April, 1984 challenging the ordinance which prohibited
these landowners from continuing to use their private water
wells. You then state that Mr. Herbert has been advised by
Council that since he is one of the plaintiffs in the litigation,
he could not vote on any matter pertaining to the water system.
Based upon the above, you request an advisory opinion as to
whether Mr. Herbert would be preluded from voting on matters
Ed.. trd B. Go1,. Esc
Pa - ;e
involving the Authority provided , .d rat' :ers
directly with the litigation After noting thy
involvin7 the Authority regularly sppe , ;iT the 3o7i ugh
you, feel that a prohibition upon Mr. Ilerbert s pa :°tief.pation
would disenfranchise Mr. Herbert and his constituents.
Currently, you state that in March 7, 1933, `.he Vice President of
Council presented a motion to cancel a three year contract of
Robert Hunt, the Authority operator and replace saic contract,
with a one year contract with a 31% salary increase. You advise
that Mr. Herbert was told that he could not participate or vote
on the matter. You conclude by questioning whether Mr. Herbert
is precluded from voting on all matters or whether the conflict
would be limited merely to those matters which would relate to
the litigation that was commenced by Mr. Herbert and others
against the Borough and the Authority.
III. Discussion:
As a member of Stewartstown Borough Council, Mr. Herbert is
a "public official" as that term is defined under the Ethics Act.
65 P.S. §402; 51 Pa. Code X1.1; Rider, Order 490 -R. As such, his
conduct must conform to the provisions of the Ethics Act.
Section 3(a) of the Ethics Act provides:
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).
6ection 3(b) of the Ethics Act provides:
(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 future
employment based on any understanding that
Edward B. Golla, Esquire
Page 3
the vote, official action, or judgment of the
public official 1r public employee
candidate for public office mould be
influenced thereby. 65 P.S. 403(b).
The above quoted provisions of the Ethics Act provide that
no public official may use his public office or confidential
information received through his holding public office to obtain
financial gain for himself or a business with which he
associated and no public official may receive anything of value,
including the promise of future employment, on the understandLng
that his official conduct will be influenced thereby. See
Section 3(a) and (b) of the Ethics Act, 65 P.S. §403(a) and (b).
Section 3(d) of the Ethics Act also provides:
Section 3. Restricted activities.
(d) Other areas of possible conflict shall be
addressed by the commission pursuant to paragraph '9)
of Section 7. 65 P.S. 403(d).
Under the above provision of law, the Ethics Commission is
also empowered to address other areas of possible conflict. 65
P.S. §403(d). Fritzinger, Opinion 80 -008; DeBenedictis, Opinion
86 -002. The parameters of the type of activity encompassed by
this provision are generally reviewed in light of the Preamble to
the Ethics Act which enunciates the legislative intent of the
Act. The intent and purpose of the Act is to strengthen the
faith and confidence of the people in their government by
assuring the public that the financial interests of the holders
of public office present neither a conflict nor the appearance or
a conflict with the public trust. A public official or employee,
pursuant to this provision, is to ensure that their personal
financial interests present neither a conflict nor the appearance
of a conflict with the public trust. 65 P.S. §401. Such a
conflict may exist where an individual represents one or more
adverse interests, Alfano, Opinion 80 -007; where an individual
serves in positions that are incompatible or conflicting, Nelson,
Opinion 85 -009; or where such an official or employee accepts
compensation to which he is not entitled, Domalakes, Opinion 85-
010.
In the instant matter, it is clear that Mr. Herbert is in all
adversarial situation with the Authority in light of the fact
that Mr. Herbert and others have instituted a law suit as private
litigants against the Authority and the Borough. The foregoing
legal action is of a personal nature and is not related to any
Edward B. Golla, Esqui.:
Page 4
official action by Mr. Herbert Svzmanowski, upiniorr 87 -002.
The question. to be resolved is the extent to which Mr. Herbert's
activities must be restricted in light of this coi: l_ct of
interest.
Under the foregoing circumstances, since Mr. Herbert is
involved in personal litigation with the Water Authority, the
Ethics Act would require that he abstain from participating or
voting in all matters concerning the Water Authority. Although
at first blush it would appear that he should only be restricted
tc "those matters ... deal[ing] directly with the lit4gatioi.... ",
tha underlying fact remains that he is in an adverse position
w_th that Authority in light of the litigation. His conflict is
not limited to just those matters that directly relate to the
litigation. This Commission has determined that a public
official should not participate in matters where his interest can
be described as even indirect in nature. Welz, Opinion 86 -001
F it is very difficult if not impossible to say with
ce ..tainty that certain matters which may currently be perceive:,
as not having direct or indirect connection with the litigatirn
may in the future have such a connection. If Mr. Herbert were to
vote on something concerning the Water Authority which, aft€:.
1-1 fact, would impact upon the litigation, an ethics proh.i
could arise for Mr. Herbert. In that instance, the claim by L.
Herbert that he didn't think it was a problem at the time e
voted would be of no avail since the action would have a1rea4
occurred. Further, consider the question of the modification of
the three year contract with Robert Hunt to a one year contract
with a 31% salary increase; on its face the contract does not
appear to have even a remote interest with the litigation.
However, it is possible that at some future time Mr. Hunt may
become involved in that litigation in that he may be called upon
by Borough Council to make a recommendation as to the litigati -n
or to take or perform certain actions in relation thereto. Thus,
if Mr. Herbert were to vote on Mr. Hunt's contract ani salary,
such action would be a conflict. In this regard, it is noted
that Mr. Herbert admitted that at the present the heads of the
Sewer and Water Authority are combined into one coordinator
position.
The Preamble of the Ethics Act recites that public office is
a public trust and that in order to strengthen the faith and
confidence of the people in their government, the holders of
public office should not act in a fashion to create a conflict
nor the appearance of a conflict with the public trust. In this
case, it is necessary under the Ethics Act for Mr. Herbert to
recuse himself from participating or voting on matters with the
Authority until the final resolution of this law suit agai,
that Water Authority in light of the inherent conflict bet :aa
Edward B. Golla, Esquire
Page 5
his public position and his pwivpate interest in the litigation.
Mr. Herbert must note his abstention of public record together
with the reason for hi:- abstention.
IV. Conclusion:
As a member of the Borough Council of Stewartstown, Mr.
Herbert is a "public official" subject to the provisions of the
Ethics Act.
Under the Ethics Act, during the pendency of the litigation
against the Water Authority and the Borough, there is an inherent
conflict of interest between his activity as a councilmember in
voting on matters of the Borough Water Authority when he is a
private litigant against the Water Authority. In light of the
foregoing conflict, he may not vote in any matter involving the
Water Authority. He must note his abstention of public record
together with the reason therefor.
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 evidence of the advice given.
such.
This letter is a public record and will be made availabl ay
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.
By the Commission,
Vim► VC.1J.7
Joseph W. Marshall, III
Chairman