HomeMy WebLinkAbout89-012 Davis1989.
Dear Mr. Davis:
I. Issue:
III. Discussion:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
OPINION OF THE COMMISSION
Before: Helena G. Hughes, Chair
W. Thomas Andrews
G. Sieber Pancoast
Dennis C. Harrington
Michael J. Washo
Date Decided: July 28, 1989
Date Mailed: AuguRt 8, 1989
Mr. Philip E. Davis 89 -012
RD #6, Box 1516
Mount Pleasant, PA 15666
Re: Conflict, School Director, Voting on Wage Increase for School
Police, Father, Immediate Family
This Opinion is issued in response to your request of June 28,
Whether a school board member under the Public Official and
Public Employees Ethics Law may vote in a requested wage increase by
the school police when the member's father is a school district
policeman.
II. Factual Basis for Determination:
You are a Director of the Mount Pleasant Area School District
wherein your father is a member of the school police. A wage increase
has been requested by the school police who are part -time employees of
the District. You request advice as to whether it would be proper for
you to vote on the requested wage increase.
As a School Director of Mount Pleasant Area School District, you
are a public official as that term is defined under the Public
Official and Employee Ethics Law of June 26, 1989, Act 9 of 1989.
Accordingly, you are subject to the provisions of the Ethics Law and
the restrictions therein are applicable to you.
Mr. Philip E. Davis
Page 2
Section 3(a) of the Ethics Law provides:
Section 3. Restricted Activities.
(a) No public official or public employee
shall engage in conduct that constitutes a
conflict of interest.
The term "conflict" is defined in the Ethics Law as follows;
Section 2. Definitions.
"Conflict or conflict of interest." Use by a
public official or public employee of the
authority of his office or employment or any
confidential information received through his
holding public office or employment for the
private pecuniary benefit of himself, a member of
his immediate family or a business with which he
or a member of his immediate family is associated.
"Conflict" or "conflict of interest" does not
include an action having a de minimis economic
impact or which affects to the same degree a class
consisting of the general public or a subclass
consisting of an industry, occupation or other
group which includes the public official or public
employee, a member or his immediate family or a
business with which he or a member of his
immediate family is associated.
In addition, the terms, "Authority of Office or Employment" and
"Immediate Family" are defined as follows:
Section 2. Definitions.
"Authority of office or employment." The
actual power provided by law, the exercise of
which is necessary to the performance of duties
and responsibilities unique to a particular public
office or position of public employment.
"Immediate family." A parent, spouse,
child, brother or sister.
In addition, Sections 3(b) and 3(c) of the Ethics Law provide in
part that no person shall offer to a public official /employee anything
of monetary value or no public official /employee shall solicit or
accept any thing of monetary value based upon the understanding that
the vote, official action, or judgement of the public
official /employee would be influenced thereby.
Mr. Philip E. Davis
Page 3
Although it is clear under the Ethics Law that your father is a
member of your "immediate family ", it is necessary to review your
proposed conduct to determine whether your voting would constitute a
conflict under the Ethics Law.
An exclusion exists within the definition of conflict regarding
use of the authority of office which affects to the same degree a
class or sub -class consisting of an occupation which would include a
member of the public official's immediate family.
In the instant matter, your father is a member of the school
police of the school district. However, in order for the exclusion
within the definition of conflict to apply, it is necessary that your
father be part of a sub -class of school police, that is, there must be
more than one school policeman. In addition, your father could not be
affected any differently from any of the other school police. Subject
to the above two qualifications, the Ethics Law would not preclude you
from voting on the wage increase request. Our result reflects the
legislative intent that a public official does not have a conflict as
to himself, a member of his immediate family on basis with which he is
associated when he, a member of his family or the business is not
affected any differently from the class or sub- class.
Lastly, the propriety of the proposed conduct has only been
addressed under the Ethics Law; the applicability of any other
statute, code, ordinance, regulation or other code of conduct other
than the Ethics Law has not been considered in that they do not
involve an interpretation of the Ethics Act.
IV. Conclusion:
As a school director for the Mount Pleasant Area School District,
you are a "public official" subject to the provision of the Ethics
Law.
The Ethics Law does not preclude you from voting on a wage
request for the school police, of which your father is a member,
provided there are more than one policeman in the class and provided
your father is affected to the same degree as all other school police
as to the wage request. Lastly, the propriety of the proposed conduct
has only been addressed under the Ethics Law.
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.
Mr. Philip E. Davis
Page 4
such.
This letter is a public record and will be made available as
Finally, any person may request the Commission to reconsider its
Opinion. The reconsideration request must be received 'at this
Commission within fifteen days of the mailing date of this Opinion.
The person requesting reconsideration should present a detailed
explanation setting forth the reasons why the Opinion requires
reconsideration.
By th= Commission,
lena G. Hughes
Chairman