HomeMy WebLinkAbout141 GenoveseMrs. Betty Genovese
Chairperson, Planning Commission
of Covington Township
R.D. #1
Gouldsboro, PA 18424
are:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
July 22, 1982
ORDER OF THE COMMISSION
No. 141
Dear Mrs. Genovese: #81 -84 -C (2 -3)
The State Ethics Commission has received a complaint regarding you and a
possible violation of the Ethics Act (Act 170 of 1978). The Commission has
now completed its investigation into these allegations and will take no action
as to any violation of Act 170.
The individual allegations and findings on which our conclusion is based
I. Allegation:
1., That as chairperson of the Covington Township Planning Commission,
you supported or voted for all subdivision and zoning approvals for Eagle Lake
Corporation and said Corporation now rents property at the location of a new
Genovese family -owned restaruant.
2. That said Corporation is invited to all planning commission meetings
and work sessions.
II. 'indings:
1. You serve as chairperson of the Covington Township Planning
Commission. You have been a member of that commission for two years and
chairperson for the last year. You receive no compensation for this
position.
2. The planning commission is responsible for seeing that subdivision
plans submitted comply with all ordinances and regulations of the township.
These plans also must be approved by the county planning commission, the town-
ship engineer, and, finally, by the township supervisors.
3. You participated in planning commission decisions on subdivision
plans submitted by Eagle Lake Corporation (check this item with Gene - it
isn't clear in our investigation). These decisions were made prior to July,
1981.
4. The Eagle Lake Corporation rented office space in a restaurant which
you and your husband own. This was a temporary arrangement between June and
November of 1981. Eagle Lake Corporation still retains a front room which
they use as a reception area. There is no formal lease for these agreements.
Mrs. Betty Genovese
July 22, 1982
Page 2
5. These agreements were entered into after the planning commission had
completed action on Eagle Lake and you state there was no connection between
this rental and Eagle Lake's subdivision approvals.
6. /Eagle Lake representatives attend most planning commission meetings
and contribute to these meetings. Other persons also attend and contribute;
all official meetings of the planning commission are open to the public.
III. Discussion: The initial question to be answered in your case is whether
unpaid members of a planning commission are subject to the Ethics Act so that
their conduct would be subject to the requirements of the Ethics Act. To
answer this question we reviewed the definition of "public official" in the
Act which states:
"Public official." Any elected or 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. "Public official" shall not
include any appointed official who receives no
compensation other than reimbursement for actual
expenses. 65 P.S. 402
While appointed, non - compensated persons might be said to be clearly
excluded from coverage, this definition must also be reviewed in light of the
recent ruling in Snider v. Thornburgh, Pa. , 436 A.2d 593 (1981).
In this ruling, issued September 29, 1981, the Supreme Court appeared to alter
the definition of "public official" by removing the exclusion relating to
appointed, non - compensated persons. While this case related to school board
directors, it may affect the scope of the entire definition of "public
official" by including non - compensated appointed persons previously excluded
from the Ethics Act's definition of that term. The State Ethics Commission is
currently assessing the impact of this ruling and if appointed, non -
compensated persons other than school directors are to be affected by this
decision, regulations will be promulgated to implement this portion of the
Snider ruling.
Mrs. Betty Genovese
July 22, 1982
Page 3
In any event, even assuming that persons such as planning commission
members, previously excluded from the "public official" definition as it stood
prior to the September 29, 1981 Snider ruling will eventually, by regulations,
be held within the purview of this definition, we are unwilling to apply this
Snider ruling- retroactively to apply to and to affect your conduct during the
period when:�you were reviewing the Eagle Lake plans for approval. During this
period you were not covered by the Ethics Act and we will not censure your
conduct at this point when such action /conduct was undertaken at a point in
time when your inclusion within the definition of "public official" was not
clear.
We feel free to point out, however, that Section 1 of the Ethics Act
declares that "... the financial interests of holders of or candidates for
public office present neither a conflict nor the appearance of a conflict with
the public trust." Public officials and employees can avoid actual or
apparent conflicts of interest with Act 170 by either avoiding business
relationships with those they regulate, insuring that those business
relationships are publicly known, and abstaining from participation in any
matters which would affect the parties in that business relationship.
We suggest that if similar circumstances arrive in the future, you make a
public record of your relationship with the people submitting the subdivision
plans.
IV. Conclusion:
The State Ethics Commission will take no further action in this matter
light of the serious question of your inclusion within the coverage of the
Ethics Act at the time the conduct /action in question occurred. This conclu-
sion is not meant to condone or condemn your conduct. Should you clearly be
within the definition of "public official" as established by the Ethics Act or
existing or future regulations of the State Ethics Commission and should you
face a similar situation in the future, you should solicit the advice of the
State Ethics Commission in relation to conforming your conduct to the require-
ments of the Ethics Act and be generally guided by our discussion above.
Our files in this case will remain confidential in accordance with
Section 3(a) of the Ethics Act, 65 P.S. 408(a). 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 fctual findings. During this 15 -day period, no one,
including the Respondent unless he waives his right to challenge this Order,
may violate this confidentiality by releasing, discussing or ciculating this
Order.
Mrs. Betty Genovese
July 22, 1982
Page 4
PJS /rdp
Any person who violates the confidentiality of a Commission proceeding is
guilty to a misdemeanor and shall be fined not more than $1000 or imprisoned
for not more than one year or both, see 65 P.S. 409(e).
Sincerely,
Paul J. t:mith
Chairm