HomeMy WebLinkAbout92-008 ConfidentialI. ISSUE:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
OPINION OF THE COMMISSION
Before: James M. Howley, Chair
Daneen E. Reese, Vice Chair
Dennis C. Harrington
Roy W. Wilt
Austin M. Lee
Allan M. Kluger
DATE DECIDED: December 10, 1992
DATE MAILED: December 16, 1992
92 -008
Re: Conflict, Simultaneous Service, Incompatibility, Compensation,
Private Pecuniary Benefit, Constable, Borough, Borough Council
Member.
This Opinion is issued in response to your confidential
advisory request dated June 10, 1992.
Whether the Public Official and Employee Ethics Law imposes
any prohibition or restrictions upon an individual from
simultaneously serving as a borough council member and as a
constable elected within the same borough.
II. FACTUAL BASIS FOR DETERMINATION:
As the Solicitor for the Borough of A, Pennsylvania, you
request an advisory from this Commission regarding the status of a
current member of Borough Council who was elected to Council and as
a Constable in November 1991 and is currently holding both offices.
The Council Member specifically requests a confidential advisory as
to whether he may hold both positions under the Ethics Law.
After referencing and enclosing a photocopy of the
Pennsylvania Supreme Court decision of May 19, 1992 in MacElree v.
Learree, No. 13 E.D. Appeal Docket 1991), you interpret that
decision to mean that Section 10 of the Ethics Law, 65 P.S. §410,
permitted that constable to hold any elective office in a political
party, but not in any other governmental office.
Confidential Opinion 92 -008
December 16, 1992
Page 2
You assert that Legree is distinguishable from the instant
matter because Legree was a council member for the City of
Coatesville, a third class city, and that both the Third Class City
Code and Coatesville City Ordinance prohibited a council person
from also being a constable; in the instant matter, neither the
Borough Code nor the ordinances of the Borough of A prohibit a
council member from also being a constable. You conclude that,
consistent with the interpretation of the Pennsylvania Supreme
Court, Section 10 appears to permit a constable to be involved in
the elective process of any political party but does not appear to
explicitly prohibit a borough council person from holding any other
governmental office such as constable.
By subsequent letters dated September 18, 1992, and October
26, 1992, you have supplied the following additional facts.
After citing Section 1104 of the Borough Code in part and
asserting that a constable does not serve on a board, commission,
bureau or other agency created by or for a borough, you state that
the position of constable is not a borough position created or
authorized by statute. You argue that Section 1104 is intended to
apply to borough created boards and commissions such as zoning
hearing boards, civil service commissions, planning commissions,
recreation boards and the like. Since a constable serves and has
authority to take action in the entire Commonwealth of
Pennsylvania, you believe that a constable is not encompassed
within the purview of any borough office and is not created by the
Borough.
You have submitted a copy of House Bill No. 2574 which was
enacted in 1992. That Act serves to explain the many duties that
a constable may undertake, and establishes an advisory board known
as the Constable Education and Training Board within the
Pennsylvania Commission on Crime and Delinquency of the
Commonwealth. Section 1.4 of that Act authorizes the Board, with
the review and approval of that Commission, to perform many
functions including administration, training, certification of
qualifications and implementation of a constable's duties. The
funding for such activities comes from the general fund of the
State Treasury. You conclude that the legislation produces a
Commonwealth administered program and a Commonwealth office.
You offer further support for your contention that Section
1104 of the Borough Code does not prohibit a borough council member
from also acting as a constable by referencing the case of
Rosenwald v. Barbieri, 501 Pa. 563, 462 A.2d 644 (1983). After
performing an extenstive review of the status of a constable, the
Pennsylvania Supreme Court found that a constable neither acts on
behalf of nor under the control of the municipality. Since a
constable was not an employee of that municipality, the
Confidential Opinion 92 -008
December 16, 1992
Page 3
municipality has no authority to control the constable's activities
regardless of which magisterial district he is working. The Court
further stated that a constable is not paid by the municipality nor
does the First Class Township Code include the constable as an
elected officer of the township.
After noting that the Borough Code does not include a
constable as an elected officer of the borough, you conclude that
the Supreme Court has held that a constable is an independent
contractor and not an employee of the Commonwealth, the judiciary,
the municipality or the county in which he works.
Due to the uncertainty of the law in this area, the Council
Member seeks the instant advisory.
III. DISCUSSION:
As a Council Member for the Borough of A, the Council Member
is a "public official" as that term is defined in the Ethics Law
and hence is subject to the provisions of the Ethics Law. 65 P.S.
§402; 51 Pa. Code §1.1. The individual's status as a constable
shall be discussed below.
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 following terms are defined under the Ethics Law:
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
Confidential Opinion 92 -008
December 16, 1992
Page 4
employee, a member of his immediate family or
a business with which he or a member of his
immediate family is associated.
"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.
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 and no public official /employee shall
solicit or accept anything of monetary value based upon the
understanding that the vote, official action, or judgment of the
public official /employee would be influenced thereby.
Before applying the above provisions of the Ethics Law to the
question of the individual's simultaneous service as a Borough
Council Member and as a Borough Constable, two points must
initially be discussed.
First, this Opinion addresses your inquiry with regard to
prospective conduct only. A reading of Sections 7(10) and (11) of
the Ethics Act makes it clear that an opinion /advice may be given
only as to prospective (future) conduct.
Second, we must address the question of whether a constable
is, in that capacity, a "public official" as defined in the Ethics
Law and subject to the Ethics Law.
This Commission has previously administratively excluded
constables from coverage under the Ethics Law, considering them to
be part of the judiciary over which the Commission has no
jurisdiction. This policy made sense under the Pennsylvania
Constitution, which provides in pertinent part:
(c) The Supreme Court shall have the
power to prescribe general rules governing
practice, procedure and the conduct of all
courts, justices of the peace and all officers
serving process or enforcing orders, judgments
or decrees of any court or justice of the
peace. . . .
Pennsylvania Constitution, Article V, Section 10(c). Constables
are elected officials who serve process and execute orders for
district justices (formerly "justices of the peace "). Therefore,
it had appeared that constables were subject to regulation by the
Confidential Opinion 92 -008
December 16, 1992
Page 5
Supreme Court and were therefore beyond the jurisdiction of this
Commission under the "separation of powers" doctrine.
Nevertheless, the Supreme Court of Pennsylvania has decisively
concluded that constables are not part of the judicial branch..
In a 1983 case, Rosenwald v. Barbieri, 501 Pa. 563, 462 A.2d
644 (1983), U.S. cert. den. in 104 S.Ct. 1279, 465 U.S. 1024, the
Pennsylvania Supreme Court held that a constable is "related staff"
of the Courts as defined by the Rules of Judicial Administration,
who aids the judicial process but is not supervised by the courts.
Rosenwald, supra, 501 Pa. at , 462 A.2d at 647; In Re: Act 147
of 1990, 598 A.2d 985, 987 (1991) (Citing Rosenwald, supra).
Thereafter, the General Assembly enacted Act 147 of 1990 which
provided for regulation of constables by the judiciary. (Former 42
Pa.C.S. §2941 et seg.).
In 1991, the Supreme Court declared Act 147 of 1990 to be
unconstitutional, invalid and unenforceable. In Re: Act 147 of
1990, 598 A.2d 985 (1991). Citing Article V, Section 2 of the
Pennsylvania Constitution, the Supreme Court stated that it is the
supreme authority of the judicial branch, and that legislation
infringing on that authority over courts is invalid. The Court
decisively determined that constables are not within the judicial
branch:
As a peace officer, and as a process server, a
constable belongs analytically to the
executive branch of government, even though
his lob is obviously related to the courts.
It is the constable's job to enforce the law
and carry it out, just as the same is the job
of district attorneys, sheriffs, and the
police generally. Act 147 is unconstitutional
and violates the separation of powers doctrine
in our Constitution because it attempts to
place constables within the judicial branch of
government and under the supervisory authority
of the judicial branch. . . At most,
constables are "related staff" under the Rules
of Judicial Administration. They cannot,
however, be made part of the judicial branch
under our Constitution. See, Rosenwald,
supra.
Id., 598 A.2d at 990 (Emphasis added).
Therefore, this 1991 Supreme Court case decisively excludes
constables from the judicial branch and invalidates the prior
Confidential Opinion 92 -008
December 16, 1992
Page 6
rationale for excluding constables from coverage under the Ethics
Law.
We must therefore consider whether constables are "public
officials" as defined in the Ethics Law and subject to the Ethics
Law. The term "public official" is defined as follows:
65 P.S. §402.
Section 2. Definitions
"Public Official." Any person elected by
the public or elected or appointed by a
governmental body, or an appointed official in
the Executive, Legislative or Judicial Branch
of the State or any political subdivision
thereof, provided that it shall not include
members of advisory boards that have no
authority to expend public funds other than
reimbursement for personal expense, or to
otherwise exercise the power of the State or
any political subdivision thereof.
A constable is elected by the public, with vacancies being
filled by court appointment. 13 P.S. §1, et seq. The Supreme
Court has stated that a constable is an elected official. In Re:
Act 147 of 1990, 598 A.2d 985, 986 (1991) (Citing 13 P.S. §1, et
seq.). The Supreme Court has further stated its view that the
constable belongs in the executive branch of government. Id. at
990. Thus, the definition set forth in the Ethics Law clearly
would include a constable as an elected or appointed official in
the executive branch.
There is no exception which would apply. The statutory
definition's sole exception applies to members of advisory boards,
not constables. Nor do the Commission Regulations provide any
basis for excluding constables from this definition.
Our analysis of the status of constables under the Ethics Law
need go no further. There is no need to review the powers and
duties of constables, because the definition of "public official"
does not hinge upon them. Although powers and duties are reviewed
to determine status as a "public employee" they are not reviewed
for determining status as a "public official" (unless it is to see
whether a board is advisory). The definition of "public official"
applies to constables; there is no exception which would exclude
them; and the jurisdictional basis by which they have been
previously excluded as part of the judiciary has been invalidated.
Nevertheless, to fully understand the authority of a
Confidential Opinion 92 -008
December 16, 1992
Page 7
constable, it is helpful to review the Supreme Court's analysis of
the status of constables and the relevant statutory provisions
including those which set forth the duties and powers of
constables.
Constables are elected within political subdivisions,
specifically cities of the second and third classes, boroughs,
incorporated towns, and townships. 13 P.S. S1 et sect. A constable
may be removed from office by a court for being "unfit and
incompetent to discharge his official duties" from "habits of
intemperance or neglect of duty," or for acts of malfeasance or
misfeasance. 13 P.S. 531.
In the 1983 Supreme Court case discussed above, Rosenwald v.
Barbieri, 501 Pa. 563, 462 A.2d 644 (1983), U.S. cert. den. in 104
S.Ct. 1279, 465 U.S. 1024, the Pennsylvania Supreme Court held that
a constable for a first class township was not acting for or under
the control of the Commonwealth, and therefore was not an employee
of the Commonwealth. The Court held that the constable was not a
township employee because he was not acting on behalf of or under
the control of the township, could serve process in other
magisterial districts in the county, and was not paid by the
municipality. The Court further noted that the constable was not
among the enumerated elected officers of the township. The Court
decided that the constable was within the Rules of Judicial
Administration's definition of "related staff" of the Courts, who
aid the judicial process but are not supervised by the courts.
Rosenwald, supra, 501 Pa. at , 462 A.2d at 647.
In the 1991 Supreme Court case discussed above, the Supreme
Court stated that a constable is an elected official. In Re: Act
147 of 1990, 598 A.2d 985, 986 (1991) (Citing 13 P.S. 51, et seq.).
The Court cited its holding in Rosenwald, supra, as stating that a
constable "is an independent contractor and is not an employee of
the Commonwealth, the judiciary, the township, or the county in
which he works," but is "related staff." Id. at 986 -987. The
Court stated that the constable is a police officer and "peace
officer." Id. at 990. Citing various precedents, mostly from other
states, the Court stated:
A constable is a known officer charged with
the conservation of the peace, and whose
business it is to arrest those who have
violated it. By statute in
Pennsylvania, a constable may also serve
process in some instances. See generally, 13
P.S. 5541 -46. . . . As a peace officer, and
as a process server, a constable belongs
analytically to the executive branch of
government, even though his job is obviously
Confidential Opinion 92 -008
December 16, 1992
Page 8
related to the courts. It is the constable's
job to enforce the law and carry it out, just
as the same is the job of district attorneys,
sheriffs, and the police generally.
In Re: Act 147 of Act 1990, 598 A.2d 985, 990 (Numerous citations
omitted).
Since constables are not to be considered part of the judicial
branch, the decisive consideration for purposes of the Ethics Law
is the fact that constables are elected officials. Characterizing
them as "independent contractors," police officers, peace officers,
etc., means nothing under the Ethics Law's definition of "public
official" which does not hinge upon the nature of the duties
performed.
Nevertheless, the various duties of a constable, set forth
below, include a significant degree of discretionary authority. A
constable has the following statutory powers /duties:
1. The power to appoint a deputy constable or constables in the
political subdivision in which he was elected, subject to
court approval, 13 P.S. SS21 -23.
2. The power to arrest without warrant, on view. 13 P.S. 545; 47
P.S. 5563; 32 P.S. 582. The offenses for which such arrest is
authorized include breach of the peace, vagrancy, riotous or
disorderly conduct, drunkenness, offenses against forest laws,
and any unlawful act which tends to imperil personal security
or property of citizens or which violates borough ordinances
punishable by fine or penalty.
3. The power to use borough and township lockups and city or
county prisons to temporarily detain prisoners, if deemed
necessary by the officer in charge. 61 P.S. 5798.
4. Serving summons, warrants, complaints, and other process for
matters before district justices, 13 P.S. 546; Pa.R.C.P.D.J.
Nos. 307, 506. In serving said process, the constable may
serve process throughout the county or elsewhere in the state,
as provided by law, 13 P.S. 546; Pa.R.C.P.D.J. No. 307.
5. Serving process in suits instituted in any Pennsylvania court
where the sheriff of any county is a party and there is no
coroner in commission to serve process, 13 P.S. 541.
6. Serving and executing orders of execution by levy issued by
the district justice upon tangible, non - perishable personal
property located within the county. Pa.R.C.P.D.J. Nos. 403,
405, 406. During this process:
Confidential Opinion 92 -008
December 16, 1992
Page 9
(a) If the defendant claims his statutory exemption in kind
or in cash, the constable, as executing officer,
respectively either: sets aside enough items specified
by the defendant -- as appraised by the constable -- for
meeting the exemption in kind; or sets aside from the
proceeds of the sale the cash equalling the statutory
exemption. Pa.R.C.P.D.J. Nos. 407, 408.
(b) If the defendant fails to claim his statutory exemption,
the executing officer chooses, appraises and sets aside
property in kind, or sets aside cash from the proceeds of
the sale for the exemption. Pa.R.C.P.D.J. No. 408.
(c) The defendant or any party in interest may appeal to the
district justice from any appraisal or designation of
property by the constable. Pa.R.C.P.D.J. No. 408.
(d) The constable, as executing officer, has the right to
peaceably or by force break into and enter the place
where the goods are contained for the purpose of manually
taking possession of or selling the property levied upon.
Pa.R.C.P.D.J. No. 411.
(e)
(f)
(g)
The constable, as executing officer, gives notice of the
sale. Pa.R.C.P.D.J. No. 412.
When selling personal property in execution, the
constable delivers bills of sale upon request,
Pa.R.C.P.D.J. No. 415, and may accept on account the
receipt of the plaintiff for any property sold to the
plaintiff. Pa.R.C.P.D.J. No. 414.
Following the sale, the constable prepares a proposed
schedule of distribution of the proceeds of sale and
ultimately distributes the proceeds in accordance with
said schedule unless written exceptions are filed with
the district justice. Pa.R.C.P.D.J. No. 416.
(h) The constable completes a "return" for his execution of
the order, providing specific information regarding
whether and how it was carried out. Pa.R.C.P.D.J. No.
419.
Serving and executing orders for possession of real property,
issued by the district justice. Pa.R.C.P.D.J. No. 516.
During this process:
(a) The constable, as executing officer, executes the order
by using such force as is necessary to enter upon the
property and eject the defendant or any unauthorized
Confidential Opinion 92 -008
December 16, 1992
Page 10
occupant, and to deliver the possession of the property
to the plaintiff or his agent. Pa.R.C.P.D.J. No. 519.
(b) The constable completes a "return" for his execution of
the order. Pa.R.C.P.D.J. No. 520.
8. Serving protection orders issued by the district justice under
the Protection from Abuse Act. Pa.R.C.P.D.J. No. 1209.
9. With the . authority of the Department of Transportation,
seizing driver's licenses which have been ordered to be
surrendered by a court, district attorney or by the
Department. 75 Pa.C.S. §1540(c).
10. The duty to take and keep any animal (other than dogs) found
running at large in a quarantined district established by the
Department of Agriculture for the prevention /suppression of
disease. 3 P.S. §353.
11. With regard to elections:
(a) Being present at the election district polling place
during each primary and election and while the votes are
being counted for the purpose of preserving the peace;
(b) Clearing any obstruction to the door of the polling place
which would prevent electors from approaching;
(c) Maintaining order and quelling any disturbance if such
arises;
(d) Serving written notices to persons who are elected.
25 P.S. §3047.
12. The County Code lists constables among peace officers and
directs peace officers to perform all duties authorized or
imposed on them by statute. 16 P.S. S1216. The Crimes Code's
definition of "peace officer" would also include constables.
18 Pa.C.S. §501. The powers /duties of the constable as a
"peace officer" are:
(a) The duty to report suspected child abuse. 23 Pa.C.S.
S6311(b).
(b) With regard to extradition proceedings, the power to
execute warrants of arrest throughout the Commonwealth,
42 Pa.C.S. S9128-9130, or to arrest a person without a
warrant based upon reasonable information that the
accused is charged in the courts of a state with a crime
Confidential Opinion 92 -008
December 16, 1992
Page 11
(c) The power to inspect files of fingerprints maintained by
district attorneys. 61 P.S. 52175(c).
(d) Taking a person believed to be severely mentally disabled
to a facility for an emergency examination, either upon
the issuance of a warrant by the county administrator or
upon personal observation of the conduct of the person
which would constitute reasonable grounds to believe he
is severely mentally disabled and needs immediate
treatment. In the latter instance, the peace officer
would make a written statement upon arrival at the
facility, stating the grounds for believing the person to
be in need of such examination. 50 P.S. §7302(a)(1),(2).
(e) Executing warrants of apprehension issued in military
courts - martial. 51 Pa.C.S. §5204.
Act 102 of 1992, approved July 9, 1992, prescribes the
constable's fees for his performance of the following specific
duties:
punishable by death or imprisonment for more than one
year, whereupon the peace officer must take the accused
before a judge or issuing authority and make a complaint
against him. 42 Pa.C.S. §9135.
(1) Serving a complaint, summons or
notice on suitor or tenant, either personally
or by leaving a copy;
(2) Levying goods, including schedule of
property levied upon and set aside;
(3) Advertising personal property to
public sale;
(4) Selling goods levied;
(5) Clerk hired at sale;
(6) Making return of not found or
nulla bona (no goods);
(7) Executing order of possession;
(8) Ejectment;
(9) Making return of service, other than
not found; and
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December 16, 1992
Page 12
(10) Providing courtroom security as
ordered.
(g) In criminal cases:
(1) Executing a warrant or effectuating
the payment of fines and costs by attempting
to execute a warrant;
(2) Taking custody of a defendant;
(3) Conveyance of defendant to or from
court;
(4) Attendance at arraignment or
hearing;
(5) Executing discharge;
(6) Executing commitment;
(7) Executing release;
(8) Making returns to the court;
(9) Holding a defendant while awaiting
the arrival of the district justice at his or
her office;
(10) Conveying defendants for
fingerprinting;
(11) Fingerprinting or overseeing the
fingerprinting of defendants at the direction
of the district justice;
(12) Providing courtroom security as
ordered; and
(13) Serving subpoenas.
Act 102 of 1992, Section 1.
Given that the Supreme Court has decisively ruled that
constables are not part of the judicial branch, we are convinced
and so conclude that constables are within the definition of
"public official" set forth in the Ethics Law, subject to the
Ethics Law.
One of the requirements of the Ethics Law is the requirement
Confidential Opinion 92 -008
December 16, 1992
Page 13
that a Statement of Financial Interests be filed each year that the
public official holds the position and in the year after leaving
such position. See, 65 P.S. §S404, 405. We would expect that the
Borough Council Member /Constable on whose behalf you have inquired
would not have filed a Statement of Financial Interests in his
capacity as a constable based upon the prior administrative policy
of this Commission. Based upon a constable's ability to perform
his duties at a local, county and /or state level, we determine that
a constable is a public official of the Commonwealth and shall file
the Statement of Financial Interests with this Commission. 65 P.S.
S404(a).
However, in light of the above changes in the laws of
Pennsylvania which warrant a finding that constables are now
covered, we will exercise our administrative discretion and direct
that the filings for constables begin on or before May 1, 1993 for
the 1992 calendar year. We believe such action is necessary and
appropriate given the change in filing status and the need for time
in the dissemination of this Opinion. The foregoing action is
consonant with delayed implementation for filing as to solicitors
in Powell, Opinion 89 -025 and for municipal authority members in
Dice, Opinion 85 -021.
We shall now address the question of simultaneous service as
a Borough Council Member and as a Constable elected within the same
Borough. Although we do not have jurisdiction to interpret the
Borough Code, it is necessary to review that law since it may
impact upon the Ethics Law. Spataro, Opinion 89 -009. The
following provisions of the Borough Code are pertinent:
§45801. Electors only to be eligible;
incompatibility.
Registered electors of the borough only
shall be eligible to elective borough offices.
All elected borough officers shall reside in
the borough from which elected and shall have
resided in the borough continuously for at
least one year before their election. A
school director shall not be eligible to an
elective borough office. No individual shall
at the same time hold more than one elective
borough office.
53 P.S. §45801 (Emphasis added).
Section 1104. Appointments; Incompatible Offices
Unless there is incompatibility in fact,
any elective or appointive officer of the
Confidential Opinion 92 -008
December 16, 1992
Page 14
borough shall be eligible to serve on any
board, commission, bureau or other agency
created by or for the borough, or any borough
office created or authorized by statute and
may accept appointments thereunder, but no
mayor or councilman shall receive compensation
therefor. No elected borough official of a
borough with a population of 3,000 or more may
serve as an employee of that borough. Where
there is no incompatibility in fact, and
subject to the foregoing provisions as to
compensation, appointees of council may hold
two or more appointive borough offices, but no
mayor or member of council may serve as
borough manager or as secretary - or treasurer.
No person holding the office of justice of the
peace may at the same time hold the office of
borough treasurer. The offices of secretary
and treasurer may be held by the same person
when so authorized by ordinance. Nothing
herein contained shall affect the eligibility
of any borough official to hold any other
public office or receive compensation
therefor. All appointments to be made by the
council or the corporate authorities shall be
made by a majority of the members of council
attending the meeting at which the appointment
is made, unless a different vote is required
by statute.
*
53 P.S. S46104 (Emphasis added).
Although Section 1104 above would appear at first blush to
allow a borough council member to hold any other borough office so
long as compensation is not received for the other office, Section
45801 states, "No individual shall at the same time hold more than
one elective borough office." Thus, if the office of constable
were a borough office, simultaneous service as a borough council
member and constable would be prohibited, with or without
compensation.
We are of the opinion that the elective office of constable is
not a borough office. In Rosenwald v. Barbieri, 501 Pa. 563, 462
A.2d 644 (1983), U.S. cert. den. in 104 S.Ct. 1279, 465 U.S. 1024,
the Pennsylvania Supreme Court impliedly rejected the notion that
a constable for a first class township would be a township official
by noting that the constable was not among the enumerated elected
officers of first class townships as forth in the First Class
Confidential Opinion 92 -008
December 16, 1992
Page 15
Township Code. Id., 501 Pa at
462 A.2d at 647 -648.
Similarly, with regard to boroughs, although the voters of a
borough elect a constable, 13 P.S. Si, et seq., constables are not
included among the enumerated elected officials of a borough. 53
P.S. 545806.
We would additionally note that in the Rosenwald case, supra,
in the course of its discussion concluding that the constable was
not a township employee, the Supreme Court noted that the constable
could serve process throughout the county, in areas which would not
include the township and would have nothing to do with the
township. Rosenwald, 501 Pa. at , 462 A.2d at 648.
Furthermore, the Court noted that the township did not have the
ability to control the constable's activities and that the
constable was not paid by the municipality but was compensated by
fees for his services. A review of the powers and duties of a
constable as set forth above demonstrates most clearly that the
constable may act at the direction of those who have nothing to do
with the borough -- such as the Governor, state and county
officials, and the military. These additional factors would
support our conclusion that a constable, although elected by
borough voters, is not an elected borough official.
This conclusion would alleviate any concerns under the
aforecited provisions of the Borough Code as to simultaneous
service as a borough council member and constable -- with or
without compensation.
In applying the provisions of the Ethics Law to the question
of simultaneous service, there does not appear to be any real
possibility of a private pecuniary benefit or inherent conflict
arising merely by virtue of the prospective simultaneous service as
a Borough Council Member and as a Constable elected within the
Borough. The Ethics Law does not state that it is inherently
incompatible for a borough council member to simultaneously serve
as such a constable. The main prohibition under the Ethics Law and
Opinions of the Ethics Commission is that one may not serve the
interests of two persons, groups, or entities whose interests may
be adverse. Smith Opinion, 89 -010. In the situation outlined
above, the Council Member would not be serving entities with
interests which are adverse to each other.
Finally, it is noted that the judicial decision which you have
cited to the Commission, MacElree v. Legree, (No. 13 E.D. Appeal
Docket 1991), issued by the Pennsylvania Supreme Court on May 19,
1992, would not be implicated in this case. Legree concerned
simultaneous service of a City Council Member as Constable for the
City where various statutory provisions as well as the City's Home
Rule Charter declared those positions to be incompatible. In this
Confidential Opinion 92 -008
December 16, 1992
Page 16
case, as distinguished from Lecrree, supra there is no statutory
incompatibility precluding the individual's simultaneous service as
a borough council member and as a constable elected within the
borough.
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 Act has not been considered in that they do not
involve an interpretation of the Ethics Law.
IV. CONCLUSION:
The Council Member for the Borough of A is a public official
subject to the provisions of the Ethics Law. In the capacity of
Constable, this individual is likewise a public official subject to
the provisions of the Ethics Law including the requirement to file
a Statement of Financial Interests. Statements of Financial
Interests will have to be filed on or before May 1, 1993 for the
calendar year 1992 and each year that a constable holds such a
position and the year after he leaves such a position. The Ethics
Law would not preclude the Borough Council Member's simultaneous
service, with or without compensation, as a Constable elected
within the same Borough. Lastly, the propriety of the proposed
conduct has only been addressed under the Ethics Law.
Pursuant to Section 7(10), the person who acts in good faith
on this opinion issued to him shall not be subject to criminal or
civil penalties for so acting provided the material facts are as
stated in the request.
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 the Commission,
AFtwe
James M. Howl
Chair