HomeMy WebLinkAbout249 BrownMs. Linda L. Brown
c/o Edward G. Shoemaker, Esq.
Adams, Shoemaker & McSorley
718 Frick Building
Pittsburgh, PA 15219
Re: 83 -102 -C
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
ORDER OF THE COMMISSION
November 1, 1983
Order No. 249
Dear Ms. Brown:
The State Ethics Commission has received a complaint regarding you and a
possible violation of Act 170 of 1978. The Commission has now completed its
investigation. The individual allegations, conclusions, and findings on which
those conclusions are based are as follows:
I. Allegation: That as a member of the North and South Shenango Joint
Municipal Authority you violated Section 3(a) or (b) of the Ethics Act, 65
P.S. 403(a) or ((b), in that your official action was influenced or you used
your office /vote to secure appointment as General Administrator of the
Authority by the Receiver thereof or by securing appointment as General
Manager of the Authority.
A. Findings:
1. a. You serve on the North and South Shenango Joint Municipal Authority,
hereinafter the Authority, having been appointed to same by the South Shenango
Township Supervisors on April 29, 1981.
b. You were appointed as Secretary for the Authority on May 5, 1981.
2. You serve without compensation except for reimbursement for actual
expenses in both capacities.
Ms. Linda Brown
Page 2
November 1, 1983
3. The Authority was formed in 1974 to provide sewage facilities for North
and South Shenango Townships and applied for the necessary permits, grants and
loans to construct a sewer system and treatment plant.
a. After completion of the design and construction work in 1979, however,
the integrity of the system was questioned because of problems experienced
both during and after construction.
b. Several engineering reports were made and a Court suit was instituted
by a citizens' group alleging among other things, negligent construction of
the system.
c. The United States Environmental Protection Agency (EPA), in a
"Construction Grants and Audit Task Force Report" issued in October, 1982
reviewed the Authority, its operation and the system.
d. In addition to reviewing and responding to questions relating to the
system's design, construction deficiencies, effectiveness, cost, etc., the
EPA reviewed the overall management of the project and recommended that proper
management of the Authority's financial management system, procedures,
accounts, etc. was needed and that a Manager to oversee complete operations
was also needed.
4. The Authority also entered into litigation against those it felt were
responsible for the problems which have arisen in connection with the design
and construction of the sewer system, against a Bank for problems associated
with rates, loans, instruments and documents between the Authority and the
Bank.
a. The Authority sought the protection of the Bankruptcy Court under
the federal bankruptcy laws.
b. The Bank instituted legal action designed to obtain involuntary
appointment of a Receiver for the Authority.
c. In relation to these legal actions a Settlement Agreement and Consent
Decree was filed in April, 1982 and approved by Order of Court (signed)
April 15, 1982. '
d. On April 4, 1982, the Authority approved this Consent Decree and you
voted for this Decree.
e. This Consent Decree included the agreement of the Authority to the
appointment of a Receiver who, among other duties, was required to give his
"prior approval to the hiring of any new employees."
Ms. Linda Brown
Page 3
b. The Receiver, as set forth above, No. 4(e) approved of your
appointment as required by the Consent Decree.
November 1, 1983
5. As recommended by EPA (see No. 3 above), the Authority decided to appoint
a Manager and on May 11, 1982 pursuant to Resolution No. 82 -2, you were
appointed to this post.
a. The Minutes of the Authority reflect the fact that you abstained on
the vote to appoint a Manager.
c. As Manager you were, by Resolution No. 82 -2, to be paid $220 per
week effective May 1, 1982.
B. Discussion: We must initially address the question of whether you are a
"public official" or "public employee" as those terms are defined in the
Ethics Act. In this analysis we turn to the conclusions reached in Advice of
Counsel No. 83 -537 issued to you dated April 12, 1983, which is incorporated
herein by reference. In that Advice it was correctly concluded tht as General
Manager you are a "public employee" subject to the restrictions of the Ethics
Act. However, the Allegation at issue here concerns your conduct as a member
of the Board of the Authority and thus we must ask whether, as a member of the
Authority, you are subject to the jurisdiction of the Ethics Act.
Addressing this question, Advice No. 83 -537 correctly concluded that as
an uncompensated (except for expense reimbursement) member of the Authority
Board, you are not a "public official" subject to the Ethics Act or the
restrictions contained in Section 3(a) or (b) thereof which apply to "public
officials." There is no evidence to suggest or support a conclusion that in
your role as Secretary to the Authority you otherwise fall within the
definition of "public employee" under the Ethics Act. Thus, your actions as an
Authority Board member and even when serving as Secretary for the Authority
are not technically subject to our scrutiny. Even if they were, we feel
compelled to state, however, that the fact that you voted to approve the
Consent Decree (No. 4 above) in April, 1982 and were approved by the Receiver
as Manager in May, 1982 are insufficient, standing alone to warrant a finding
that you were influenced in your vote by the possibility of employment as
Manager so as to violate Section 3(b) of the Ethics Act. Likewise, given that
you abstained on the question of appointment of the Manager we would, even if
the Ethics Act were applicable, be hard - pressed to find that you used your
public office for personal gain.
Ms. Linda Brown
Page 4
No public official or public employee or a member
of his immediate family or any business in which
the person or a member of the person's immediate
family is a director, officer, owner or holder of
stock exceeding 5% of the equity at fair market
value of the business shall enter into any
contract valued at $500 or more with a
governmental body unless the contract has been
awarded through an open and public process,
including prior public notice and subsequent
public diclosure of all proposals considered and
contracts awarded. Any contract made in
violation of this subsection shall be voidable
by a court of competent jurisdiction if the suit
is commenced within 90 days of making of the
contract. 65 P.S. 403(c).
November 1, 1983
C. Conclusion: As an uncompensated, appointed member of the Authority, you
are not a "public official" or "public employee" whose conduct as such is
subject to the Ethics Act. Therefore, it cannot be said that your conduct as
a "public official" or "public employee" violated the provisions of Section
3(a) or (b) of the Ethics Act.
II. Allegation: That your appointment as and contract to serve as General
Administrator or Manager for the Authority violated Section 3(c) of the Ethics
Act, 65 P. S. 403(c), in that no open and public process was undertaken.
A. Findings: In addition to Findings 1 -5 set forth above, which are
incorporated here as if fully set forth, we also find:
6. There did not appear to be any opportunity for others to apply for the
appointment to the post as Manager (No. 5, above) or publicly announced
opportunity for competitors for this post to apply for same.
B. Discussion: With respect to this Allegation, we again refer to Advice No.
83 -537 wherein it was concluded that there is no per se or inherent conflict
in serving as uncompensated member - Secretary for the Authority and General
Manager for the Authority. This is a correct statement. The question here,
however, is whether the contract of employment between the Authority and you
as manager violates Section 3(c) of the Ethics Act. Section 3(c) of the
Ethics Act states:
Ms. Linda Brown
Page 5
November 1, 1983
Clearly, if you were as an Authority member, a "public official" or
"public employee" who sought to contract with the Authority, Section 3(c)
would have application. However, having concluded above that as an
uncompensated, appointed member of the Authority Board and Secretary to the
Authority, you are not a "public official" or "public employee," Section 3(c)
would be inapplicable and in this hiring, you would not be required to enter
into the "open and public" process set forth in Section 3(c) of the Ethics
Act. As set forth above, upon your appointment as Manager, you became a
"public employee." However, any restrictions upon your ability as a "public
employee" to contract with the Authority relate only to activities undertaken
after you became a "public employee" upon your appointment as Manager.
We wish, finally, to reiterate, however, the directions in the Advice
referenced above which indicate that as a "public employee," ie. General
Manager, you may not take or recommend actions favorable to yourself and /or
then act upon those same actions or recommendations as a member of the Board.
We would expand upon this Advice only slightly to indicate that in the
alternative it would be acceptable if you, a General Manager, were to refrain
from undertaking to make recommendations to the Board (or Receiver) or to take
actions as General Manager on matters which affect you personally.
C. Conclusion: Section 3(c) of the Ethics Act is inapplicable under these
facts and does not bar or place restrictions upon this contract or process of
your appointment as Manager.
Our files in this case will remain confidential in accordance with
Section 8(a) of the Ethics Act, 65 P.S. 408(a). However, this Order is final
and will be made available as a public document 15 days after service (defined
as mailing) unless you file documentation with the Commission which justifies
reconsideration and /or challenges pertinent factual findings. See 51 Pa. Code
2.38. 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 circulating this Order.
Any person who violates the confidentiality of a Commission proceeding
is guilty of a misdemeanor and shall be fined not more than $1,000 or
imprisoned for not m"re than one year or both, see 65 P.S. 409(e).
PJS /jc
By the Commission,
Paul J./5
Chairma