HomeMy WebLinkAbout332 ConawayMr. Jason G. Conaway
114 3rd Street
California, PA 15419
RE: File No. 83 -139 -C
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
ORDER OF THE COMMISSION
August 15, 1984
Order No. 332
Dear Mr. Conaway:
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 you, a California Borough Councilperson, violated
Section 3(a) of the Ethics Act, 65 P.S. 403(a), which prohibits public
officials and public employees from using their office or confidential
information gained from that office to obtain financial gain by voting to
benefit yourself in your appointment as a police officer for California
Borough and on subsequent actions on police matters.
A. Findings:
1. You have served as California Borough Councilperson since January, 1983,
and are subject to the requirements of the Ethics Act.
2. You previously served as California Borough Councilman in 1980 and 1981.
a. During that time you were also a full -time Borough police officer.
b. On January 21, 1980, the solicitor ruled that the positions of Borough
Councilperson and police officer were incompatible. You resigned from Council
after that opinion.
3. Some time after your resignation from Borough Council, you were
furloughed from your Borough police officer position.
4. At a February 21, 1983 meeting, Council voted to hire a part -time police
officer because over -time for the prior year cost $9,000.
a. Councilpersons Szalay and Weld made a motion to recall one officer for
part -time work at the prevailing wage without benefits.
Mr. Jason G. Conaway
Page 2
c. Police officer salaries are set in the union contract.
August 15, 1984
b. You had the most seniority and were the person who would be hired.
d. The mayor had contacted the Borough Association and they told him there
had been no test cases regarding a conflict of interest when a Councilperson
also serves as a Borough police officer and that this situation existed in
other boroughs.
e. The motion passed 4 - 0. You abstained.
f. You were told you must abstain from voting on all police matters.
5. Subsequent to your appointment as a part -time police officer, Council
considered the following police matters:
a. On April 11, 1983, you abstained from a Council decision on paying
over -time wages for police officers when they attended a seminar.
b. On June 8, 1983, you abstained from a Council decision on charging other
municipalities for the use of borough breathalyzer equipment.
You also abstained from a decision authorizing police liability
insurance.
There was some discussion but no Council decision on the possible
conflict of interest because you held a police officer position while serving
on Council. The solicitor stated that he stood by his 1980 opinion and that
it was a conflict.
c. On July 11, 1983, you voted on a Council decision to pay over -time for
police officers when they attended seminars. You said you were not involved
in this issue even though you served as a part -time police officer. After
questions were raised and you reviewed the minutes of the February 21 meeting,
a new role call was made and you abstained from voting on this issue.
d. At an August 15, 1983 meeting, the solicitor advised Council that no
action was needed on a law suit involving police officers Horner, Steppe, and
Conaway. He said the law suit was settled and you had signed a release.
There is no evidence that this release benefitted you or that you used your
position on Council to your benefit with respect to this matter.
e. On September 12, 1983, you seconded a motion by Councilperson DiFilippo
to establish a police pension fund account with Cal -Ed Credit Union. The
motion was passed unanimously. You are not a member of this pension fund.
B. Discussion: As a Council member you are subject to the requirements of
the Ethics Act including Section 3(a) which states:
Mr. Jason G. Conaway August 15, 1984
Page 3
Section 3. Restricted activities.
(a) No public official or public employee shall use his
public office or any confidential information received
through his holding public office to obtain financial gain
other than compensation provided by law for himself, a
member of his immediate family, or a business with which
he is associated. 65 P.S. 403(a).
On September 12, 1983, you voted on a motion to establish a police
pension fund account but you did not benefit from this vote because you do not
receive benefits or participate in the police pension plan. You also voted in
Council's action to pay overtime to police officers but then abstained on a
second role call after you had reviewed your previous agreement not to
participate in police matters. There were no other instances when you
participated in actions on police matters and your participation in the two
instances (see 5c and e) did not result in personal financial gain. Under
these circumstances, we find no violation of Section 3(a) of the Ethics Act.
However, the Commission must also review the application of Section 1 of
the Ethics Act which states that a public official shall have neither a
conflict of interest nor the appearance of a conflict of interest with the
public trust.
Your participation in police matters (see 5c and e) created the
appearance of a conflict with the public trust even though you did not realize
financial gain by your vote. As long as you remain a part -time police officer
you are in a position from which you may utlimately benefit by any Council
action on police matters. For example, in succeeding years, you may become
eligibe for and participate in the pension fund. It is also possible that you
could qualify for over -time pay.
In addition, the Council discussion at the Augut 15, 1983 meeting about a
law suit in which you were involved as an adversary to the Council makes it
obvious that issues could arise - and evidently did arise - in which your
interests and those of the Borough conflict. We find an appearance of a
conflict of interest with the public trust because you did participate in
police matters despite the agreement at the time of your recall from furlough.
It is apparent that your continued employment as a police officer while
serving on Council inherently includes circumstances which could lead to a
conflict or the appearance of a conflict with the public trust and you must
exercise extreme caution in your actions in both positions.
Our findings must not be construed as commentary on the solicitor's
opinion in which he found a conflict. Our decision relates only to the Ethics
Act and his was based on other laws. As a Councilperson, you must be prepared
to accept whatever consequences arise through acting contrary to his opinion.
Mr. Jason G. Conaway August 15, 1984
Page 4
C. Conclusion: We find no violation of Section 3(a) of the Ethics Act but do
find the appearance of a conflict of interest with the public trust because
you participated, despite your prior agreement not to do so, in police matters
from which you could benefit. As long as you serve on Council and as a police
officer of the Borough, you must abstain from Council decisions on all police
matters.
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 thisUr ecT 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 more than one year or both, see 65 P.S. 409(e).
EMS /rdp
By the /Comr/ssi'n,
Herb
Chairman
er