HomeMy WebLinkAbout19 WitmyerSTATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
ORDER OF THE COMMISSION
January 29, 1981
No. 19
Mr. James G. Witmyer, Vice- Chairman,
Mr. J. Lloyd Rohrer, Vice - Chairman,
Mr. Richard I. Hoffer, Secretary - Treasurer, 1979,
Warwick Township
1542 E. Newport Road
Lititz, PA 17543
Re: Complaint Nos. 80- 31(8 -8) Witmyer; 80- 30(7- 8).Rohrer;
and 80- 27(4 -8) Hoffer
Dear Messrs. Witmyer, Rohrer and Hoffer:
The State Ethics Commission has received a complaint
regarding you and possible violations of the Ethics Act, Act
170 of 1978. You were previously advised of this by our
letter of November 4, 1980. The Commission has now com-
pleted its investigation into these allegations and finds
that in some respects an appearance of a conflict of in-
terest existed as to activities in 1978 and 1979.
The individual allegation and findings on which our
conclusion is based is:
A. Allegation: That Warwick Township Supervisors Witmyer
and Rohrer accepted gifts of $750 from 1976 through
1979 from Mr. Richard I. Hoffer and did not report
this on their Financial Interest Statements.
B. Findings:
1. Mr. Witmyer and Mr. Rohrer were elected as Super-
visors in Warwick Township in 1976 and presently serve
in those offices.
2. Mr. Witmyer and Mr. Rohrer did receive $750 from
Mr. Hoffer each year from 1976 to 1979.
3. Mr. Hoffer was Secretary - Treasurer (1979) of the
Township.
4. As Secretary - Treasurer, Mr. Hoffer was paid approxi-
mately $3,750 per year as established by the Township
Auditors.
titbsrs. ti nonrer Hotter
January 29, 198_
Page -2-
5. Mr. Hoffer gave Mr. Witmyer and Mr. Rohrer $750.00
each in recognition of the amount of time they spend
on Township business.
6. Mr. Hoffer has provided this amount ($750.00) to
other Supervisors, without distinction as to political
party or any understanding that any vote to appoint or
re- appoint Mr. Hoffer as Secretary- Treasurer or other
official action of Mr. Witmyer and /or Mr. Rohrer was
to be influenced thereby.
7. Mr. Witmyer reported that he had received "income"
from Mr. Hoffer on his Financial Interest Statement
filed covering the calendar year 1979. This report
did not indicate the amount or circumstances of this
"income ".
8. Mr. Rohrer did not report any money received from
Mr. Hoffer on his Financial Interest Statement covering
the calendar year 1979.
9. Neither Mr. Witmyer nor Mr. Rohrer received any
money from Mr. Hoffer during the calendar year 1980.
C. Discussion: Our investigation has failed to reveal any
actual violation of the Ethics Act in relation to the
"gifts" given by Mr. Hoffer to Mr. Witmyer or Mr. Rohrer.
There is, in particular, no evidence that this was given
with the understanding that the vote, official action or
judgment of either Mr. Witmyer or Mr. Rohrer was to be
influenced thereby. Thus, no violation of Section 3(b)
of the Ethics Act, per se, exists.
However, the Commission must address these cases with a
view to what might constitute an appearance of a conflict of
interest, as well. Reviewed in the 1ight, we must conclude
that the activity of Mr. Hoffer in 1 the $750.00
gifts in 1978 and 1979 constitute an appearance of a conflict
of interest. The public might well perceive this exchange
as one designed to secure the favor of the Supervisors on
the appointment or re- appointment of Mr. Hoffer as Secretary- -
Treasurer. This exchange would not have occurred, but for
the fact that Mr. Witmyer and Mr. Rohrer were Supervisors
and the public's impression that such "gifts" appear to be
improper is easily apparent.
Indeed, Section 3(a) of the Ethics Act prohibits a
public official from using his office to secure financial
gain beyond the compensation allowed by law. Using the
analysis outlined above, it appears that Supervisors Witmyer
and Rohrer having received this "gift" only because they
hold office, passively received financial gain above and
beyond the compensation allowed by law by virtue of their
office. On this basis, an appearance of an activity prohibited
by the Ethics Act can be found.
lessrs. Witmyer_ Rohrer & Hoffer
January 29, 19
Page 3 _
In any event, the $750.00 should have been reported on
the Financial Interest Statements of these officials. Mr.
Witmyer incorrectly reported this as "income" rather than a
"gift ". This is significant because the main purpose of the
Act in requiring disclosure of "gifts" was to identify the
source, amount and circumstances of the gift. Mr. Rohrer
did not report this amount at all. These deficiencies
should be corrected.
Finally we note that as to "gifts" received or given
prior to January 1, 1979, the general effective date of the
Ethics Act, we have no jurisdiction to review these allegations.
D. Conclusion: An appearance of the existence of a
prohibited activity or conflict of interest exists
in that Mr. Hoffer because of the fact that they
serve in public office, gave Mr. Witmyer and
Mr. Rohrer $750.00 each while serving as elected
Supervisors in Warwick Township, which amount was
beyond the amount authorized them by law.
There is no violation of the Ethics Act, per se,
since this amount was not given or accepted with the
understanding that the official vote, action, etc.
of Mr. Witmyer and /or Mr. Rohrer was to be influenced
thereby.
Because this practice has ceased as of 1980,
no penalties should be imposed. Mr. Rohrer and
Mr. Witmyer should, however, amend their Financial
Interest Statements to disclose receipt of this
amount as a gift and identify the source, amount
and circumstances of the gift. This practice
should not be be re- instituted.
All files in this case will remain confidential. However,
this Order is final and will become available as a public
document within 15 days unless you file documentation with
the Commission which justifies reconsideration and /or challenges
pertinent factual findings made herein.
Sincerely yours,
PJS /jc
�/
aul J. 1th
Chairma