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HomeMy WebLinkAbout471 PellegriniMr. Alfred Pellegrini R.D. #3, Ella Hollow Road Elizabeth, PA 15037 Re: 83 -158 -C a. 1979 - 35.nn /hr. Y �t STATE ETHICS COMMISSION 308 FINANCE BUILDING HARRISBURG, PENNSYLVANIA 17120 ORDER OF THE COMMISSION May 2, 1986 Order No. 471 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 #1: That you, a Township Supervisor and Roadmaster in Forward Township, violated Section 3(a) of the Ethics Act, 65 P.S. 403(a), by using your office and /or confidential information gained through that office to receive compensation from the township without performing the services for which you were compensated. A. Findings: 1. You were appointed Forward Township Supervisor in 1975 to fill an ' unexpired term. You subsequently were elected to that position, most recently in 1983. As an elected public official you are subject to the provisions of the Ethics Act. 2. Examination of the minutes of the meetings of the Forward Township Supervisors Reorganization meetings from 1979 to 1985 confirm that annually all three township supervisors were appointed roadmasters. a. You attended those meetings and cast affirmative votes for the supervisors appointments as roadmasters. The votes were all unanimous. h. You stated the appointment of supervisors as roadmasters has been a long time practice in Forward Township. This has been confirmed hy the other supervisors. 3. You have also heen appointed annually as Supervisor of Police. 4. Your wages as roadmaster were set hy the Forward Township Auditors. The rates of pay were as follows: Mr. Al red Pel legri ni Page 2 5. Forward Township Payroll records disclosed that you earned the following: b. 1980 - $5.50 /hr. c. 1981 - $6.05 /hr. d. 1982 - $7.00 /hr. e. 1983 - $7.00 /hr. f. You admit that each °'eir the supervisors requested an hourly rate and that these requests have aeon approved Fy the auditors. g. The requests for wages from the L - rd of supervisors to the auditors were form letters which read as fc lows ... we the auditors set the following hourly rates ... a. 1979 The requests only required the signature oY the auditors. Pay Period Hours Rate of Gross Met Ending Submitted Pay Pay May 2, 1986 1/15/79 32 $5.00 $160.00 $107.47 1/31/79 32 5.00 160.00 107.47 2/15/79 32 5.00 160.00 107.47 2/28/79 32 5.00 160.00 107.47 3/15179 32 5.00 160.00 107.47 3/31/75 32 5.00 160.00 107.47 4/15/79 20 5.00 100.00 67.17 4/30/.9 0 0.00 000.00 0.00 5/15/79 '.0 5.00 100.00 67.17 E./31/79 32 5.00 167.00 107.47 6/15/79 32 5.00 167.00 107.47 6/30//9 32 5.00 167.00 107.47 7/15/79 S2 5.00 167.00 107.47 7/31/79 32 5.00 167.00 107.47 8/15/79 32 5.00 167.00 107.47 8/31/79 32 5.00 167.00 107.47 9/15/79 32 5.00 167.00 107.47 9/30/79 32 5.00 167.00 107.47 10/15/79 32 5.00 167.00 107.47 10/31/79 32 5.00 167.00 107.47 11/15/79 32 5.00 167.00 107.47 11/30/79 32 5.00 167.00 107.47 12/15/79 32 5.00 167.00 107.47 12/31/79 32 5.00 167.00 107.47 Total $3,560.00 $2,391.21 Mr. Alfred Pel leg ri ni Page 3 b. 1980 Pay Period Hours Ending Submitted 1/15/80 1/31/80 2/15/80 2/29/80 3/15/80 3/31/80 4/15/80 4/30/80 5/15/80 5/31/80 6/15/80 6/30/80 7/15/80 7/31/80 8/15/80 8/31/80 9/15/80 9/30/80 10/15/80 10/31/80 11/15/80 11/30/80 12/15/80 12/31/80 c. 1981 Pay Period Ending 1/15/81 1/31/81 2/15/81 2/28/81 3/15/81 3/31/81 4/15/81 4/30/81 5/15/81 5/31/81 6/15/81 6/30/81 32 32 32 32 32 32 32 32 32 32 32 32 32 32 32 32 32 32 32 32 32 32 32 32 Hours Submitted 34 32 36 31 35 40 36 35 36 36 35 36 Rate of Gross Pay Pay $5.50 $176.00 5.50 176.00 5.50 176.00 5.50 176.00 5.50 176.00 5.50 176.00 5.50 176.00 5.50 176.00 5.50 176.00 5.50 176.00 5.50 176.00 5.50 176.00 5.50 176.00 5.50 176.00 5.50 176.00 5.50 176.00 5.50 176.00 5.50 176.00 5.50 176.00 5.50 176.00 5.50 176.00 5.50 176.00 5.50 176.00 5.50 176.00 Total $4,224.00 Rate of Gross Pay Pay $6.05 6.05 6.05 6.05 6.05 6.05 6.05 6.05 6.05 6.05 6.05 6.05 $205.70 193.60 217.80 187.55 211.75 242.00 217.80 211.75 217.80 217.80 211.75 217.80 May 2, 1986 Net $118.23 118.23 118.23 118.23 118.23 118.23 118.23 118.23 118.23 118.23 118.23 118.23 118.23 118.23 118.23 118.23 118.23 118.23 118.23 118.23 118.23 118.23 118.23 118.23 $2,837.52 Net $137.10 129.04 145.17 125.01 141.14 161.30 145.17 141.14 145.17 145.17 141.14 145.17 Mr. Al red Pel legri ni Page 4 May 2, 1986 7/15/81 35 6.05 211.75 141.14 7/31/81 39 6.05 235.90 157.25 8/15/81 24 6.05 145.20 96.79 8/31/81 36 6.05 217.80 145.17 9/15/81 32 6.05 193.60 129.05 9/30/81 32 6.05 193.60 129.05 10/15/81 32 6.05 193.60 129.05 10/31/81 34 6.05 205.70 137.12 11/15/81 36 6.05 217.80 145.17 11/30/81 32 6.05 193.60 129.05 12/15/81 36 6.05 217.80 145.17 12/31/81 37 6.05 223.85 148.86 Total $5,003.35 $3,334.59 d. 1982 Pay Period Hours Rate of Gross Net Ending Submitted Pay Py 1/15/82 32 $7.00 $224.00 $149.18 1/31/82 32 7.00 224.00 149.20 2/15/82 36 7.00 252.00 167.84 2/28/82 32 7.00 224.00 149.20 3115/82 34 7.00 238.00 158.50 3/31/82 32 7.00 224.00 149.18 4/15/82 30 7.00 210.00 139.86 4/30/82 24 7.00 168.00 111.88 5/15/82 0 0.00 000.00 000.00 5/31/82 32 7.00 224.00 149.18 C/15/82 32 7.00 224.00 149.18 6/30/82 32 7.00 224,00 149.18 7/15/82 32 7.00 22f.00 149.18 7/31/82 32 7.09 224.)0 149.18 8/15/82 32 7.00 224.00 149.18 8/30/82 0 0.00 000.00 000.00 9/15/82 32 7.90 224.00 149.18 9/30/82 32 7.00 224.00 149.18 10/15/82 32 7.00 224.00 149.18 10/31/82 32 7.00 224.00 149.18 11/15/82 32 7.00 224.00 149.18 11/30/82 32 7.00 224.00 149.18 12/15/82 32 7.00 224.00 149.18 12/31/82 32 7.00 224.00 149.18 Total $4,900.00 $3,2633.6 Mr. Al red Pel legri ni Page 5 e. 1983 May 2, 1g86 Pay Period Hours Rate of Gross Net Ending Submitted Pay Pay 1/15/83 32 $7.00 $224.00 $149.18 1/31/83 32 7.00 224.00 149.18 2/15/83 32 7.00 224.00 149.18 2/28/83 32 7.00 224.00 149.18 3/15/83 32 7.00 224.00 149.18 3/31/83 32 7.00 224.00 149.18 4/15/83 32 7.00 224.00 149.18 4/30/83 12 7.00 84.00 55.94 5/15/83 0 0.00 000.00 000.00 5/31/83 32 7.00 224.00 149.18 6/15/83 40 7.00 280.00 186.48 6/30/83 40 7.00 280.00 186.48 7/15/83 38 7.00 266.00 177.16 7/31/83 31 7.00 217.00 144.54 8/15/83 24 7.00 168.00 110.89 8/31/83 26 7.00 182.00 120.13 9/15/83 26 7.00 182.00 120.13 9/30/83 18 7.00 126.00 83.17 Additional 10/15/83 18 7.00 126.00 83.17 pay sheet - -- 10/31/83 to 20 7.00 140.00 92.40 added 11/8/83 11/15/83 20 7.00 140.00 92.40 11/30/83 10 7.00 70.00 46.20 12/15/83 30 7.00 210.00 136.60 12/31/83 36 7.00 252.00 166.33 Total $4,515.00 $2,875.33 6. The checks you received for the above amounts were based on hours you submitted to Township Secretary Audrey Julian. a. You stated that each supervisor is required to maintain a personal record of hours worked and that at the end of each pay period the hours are submitted to the township secretary. Those hours are not documented or approved by any of the other supervisors. i. Payroll records of the township do not reflect what services, if any, were performed by you. 8. The roadmaster position is not a full -time job, and work by the supervisors acting as roadmasters is to be done on an as needed basis. The supervisors were to do jobs not completed by the part -time road crew. Mr. Al red Pel legri ni Page 6 9. Until January, 1984 Forward Township did not employ a full -time road crew. The work force consisted of workers who were considered "part- time" although township records confirm that from 1981 through 1983 at least two workers worked on a regular basis. 10. Throughout your term of service as a Forward Towhship Supervisor you have also been employed full -time by Allegheny County as Superintendent if Round Hill Park. 11. Records maintained at Round Hill Park disclose the fol lovri ng periods of leave used by you from mid -1980 to =resent: a. 1980: Vacation From May 1980) - November 3, 10, 12, 13, and 14. - December 1, 2, 3, 22, 23, 24, 26, 29, 30 and 31. Compensatory September 12, 30 - 1/2 day each. October 7, 14, 16, 17, 21, 23 - 1/2 day each. b. 1981: Vacation - August 3, 4, 5. 6, 7 - November 10, 30 - December 1, 2, 14, 15, 23, 24, 28, 29 (12/3, 12/15 - 1/2 da:'s. Personal - November 3 - December 30, 31 Compensatory Leave c. 1982: Vacation Personal Death leave - February 18 - 1/2 - ;larch 24, 25, 26 - - April 3, 22, 28 - May 5, 12, 19, 28 - June 4, 19 - September 22, 25 - October 6, 14, 21, i4ovembc 2 May 6, 7, 10, 11, 12, 13, 14, 1/ August 16, 17. 18, 20, 23, 24, 25 - May 18 November 2 January 5, 6, 7, 8 April 26, 27, 28, 29 December 8, 9, 10, 13 day. 24, ano 26 1/2 days. 1/2 days. - 1/2 days. May 2, 1986 1/2 days. 22, 27, 28 - 1/2 days. Mr. Alred Pellegrini Page 7 May 2, 1986 Compensatory - April 8, 19, 16 April 22 - 1/2 day. Leave - June 1, 8, 10, 15, 17, 22 29 - 1/2 days except 6/10. - August 19 - October 21 - Novmeber 1, 29, 30 - December 14, 27, 30 Sick Leave . - August 26, 27, 30, 31 - September 1, 2, 3 d. 1983: Vacation - November 21, 22, 23, 25, 28, 29, 30 December 20, 21, 22, 23, 27, 28, 29, 30 Personal - May 17 November 8 - December 12 Compensatory - March 30 Leave - April 26 - 1/2 day 27 - May 5, 6, 18 - July 28 - August 3, 4, 5, 8, 9, 12, 27 - 1/2 day. - September 27, 30 - 1/2 days October 20, 31 - 1/2 day Novmeber 2 1/2 day 4, 7, 8, 9 December 19 e. 1984: Vacation - May 14, 15, 16, 17, 18, 23, 24, 25 - November 27 - December 12, 13, 14, 17, 18, 19, 20, 21, 24, 26, 31 Personal - April 10 - November 6, 7 Compensatory - April 20 Leave - May 9, 10, 11, 21, 22 - October 22, 25 - November 19, 20, 26 - 1/2 day. - December 11 Sick Leave - February 24 - December 27, 28 12. Payroll records of Forward Township and your leave records of Allegheny to Round Hill Park disclosed the following: Mr. Al red Pel l eg ri ni Page 8 May 2, 1986 a. You used death leave from Allegheny County on April 26, 27, 28, 29 of 1982 and also claimed (4) hours work for each of April 27, 28, 29, 1982 to Forward Township. b. You used death leave on December 13, 1982 and also claimed (8) hours work for Forward Township. c._ For the period August 26, 1982 through September 3, 1982 you used sick leave from Allegheny County. On September 3, 1982 you claimed (4) hours work for Forward Township. d. You submitted (4) hours work to Forward Township on Friday, August 20, 1982, bat are also shown to be working for Allegheny County on that date. e. In June, 1983, you submitted the following hours to Forward Township while also working for Allegheny County. 1. June 1, 1983 - 3 hours 2. June 7, 1983 - 3 hours 3. June 9, 1983 - 3 hours 4. June 10, 1983 - 3 hours E . June 13, 1983 - 3 hours 6. Jvn : 14, 1983 - 9 hours 7. June 16, 1983 - 2 hours 8. June 22, 1983 - 2 hours 9. June 29, 1983 - 2 hours 10. Jure 30, 1983 - 2 hours f. In July, 1983, you submitted the following hours to Forward Township while also working for Allegheny County. 1. July 4, 1983 - holiday - 8 hours. 2. July 6, 1983 - 2 hours 3. July 7, 1923 - 2 hours 4, July 13, 1983 - 3 hours 5. July 14, 1983 - 3 hours 6. July 15, 1983 -• 1 hours 7. July 27, 1983 - 3 hours In August, 1983 you submitted the following hours to Forward Township while also working for Allegheny County. 1. August 3, 1983 - 3 hours 2. August 10, 1983 - 2 hours 3. August 11, 1983 - 2 hours 4. August 12, 1983 - 11 hours 5. August 15, 1983 - 2 hours 6. August 17, 1983 - 2 hours 7. August 18, 1983 - 2 hours 9. Mr. Al red Pel legri ni Page 9 8. August 25, 1983 -. 4 hours 9. August 29, 1983 - 2 hours h. In September, 1983, you submitted the following hours to Forward Township while also working for Allegheny County. 1. September 1, 1983 - 3 hours 2. September 2, 1983 - 3 hours 3. September 7, 1983 - 4 hours 4. September 8, 1983 - 3 hours 5. September 12, 1983 - 3 hours 6. September 14, 1983 - 4 hours 7. September 19, 1983 - 2 hours 8. September 21, 1983 - 3 hours 9. September 22, 1983 - 4 hours 10. September 26, 1983 - 3 hours 11. September 29, 1983 - 2 hours i. In October, 1983, you submitted the following hours to Forward Township while also working for Allegheny County. 1. October 10, 1983 - 3 hours 2. October 12, 1983 - 4 hours 3. October 19, 1983 - 2 hours J. • In November, 1983 you submitted the following hours to Forward Township while also working for Allegheny County. 1. November 3, 1983 - 2 hours 2. November 10, 1983 - 2 hours 3. November 11, 1983 - 8 hours - holiday 4. November 18, 1983 - 2 hours k. In December, 1983 you submitted the following hours to Forward Township while also working for Allegheny County. 1. December 2, 1983 - 6 hours 2. December 5, 1983 - 3 hours 3. December 9, 1983 - 2 hours 4. December 12, 1983 - 3 hours 5. December 13, 1983 - 3 hours 13. Your family owns a bar in Forward Township known as Rapp's Bar. a. You were a bartender in that bar until the latter part of 1982 working during the evenings and on weekends. b. You are also known to frequent that establishment on saturdays. Reports confirm that this is an every saturday occurrence. May 2, 1986 Mr. Al red Pel l eg ri ni Page 10 May 2, 1986 14. Forward Township payroll records confirm that a significant part of your compensation was for hours worked on saturdays. 15. Records confirm that while you worked for Allegheny County on April 7, 1983 and April 8, 1983, you also received per diem from Forward Township in an amount of $180.00 attending a conference at Seven Springs. You also were compensated for four (4) hours on both April 7, 1983 and April 8 1983, by Forward Township. B. Discussion: As a Township Supervisor in a township of the second class, you are. clearly a public official as that term is defined in the State Ethics Act. 65 P.S. §402. As such, your conduct must conform to the requirements of the Act. Sowers, 80 -050; King, 86 -025. The State Ethics Act provides as follows: Section 3,, i:estricted 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). Within the above provision of law, a township official may not use his position in order to obtain any financial gain for himself other than the compensatior provided for by law. Such an official may not use confidential information obtained in his official position for similar purposes. As an elected township official you were, of course, permitted to be appointed to the position of township roadmaster, or laborer and were also authorized to receive compensation for serving in such a position. In order to receive such compensation, however, and in order for such compensation to be that which is provided for by law, it must have been fixed by the township board of auditors and a supervisor so employed must be physically able to and actually work on the township roads and facilities. 53 F.S. §65514; §65515. Thus, any township supervisor, who in his official position, approves and accepts payments for worki ng on township roads when that individual actually does not work, would be in violation of the State Ethics Act as well as potentially in violation of other provisions of law. We have reviewed the instant situation in light of the above principles of law. Substantial questions have been raised in relation to certain hours for which you were paid for working on Forivard Township business. Specifically, as set forth in Finding 12, you had taken leave on certain days from your position with Allegheny County. We note that you were employed by Allegheny County which is a governmental body. As set forth in Finding 12 a, b, and c you had taken death leave from Allegheny County on four Mr. Alred Pellegrini Page 11 16. You sought re- election as a Forward Township Supervisior in 1983. May 2, 1986 consecutive days in April of 1982 when you also claimed working and were paid for working by Forward Township on those same days. This also occurred on one day in December of 1982. Additionally, you claimed sick leave from your county position on September 3, 1982, at the same time, however, you also claimed to be working for Forward Township. In addition to the foregoing, we note that you claimed hours for working on Forward Township business on days that you were also working for Allegheny County. These are not days during which you were on vacation or other personal leave. In addition to the foregoing, records of the township confirm that you claimed pay for working for Forward Township on April 7, 1983 and April 8, 1983, when in fact you attended and received compensation for attending a conference in Seven Springs. We believe that the fact that you claimed leave other than vacation or compensatory leave from your county job on the same days when you were being paid for working on Forward Township roads, creates a question as to whether you were truly on the type of leave that had been requested or whether you, i fact, were not working on Forward Township roads. We believe that the patter of activity evidenced by the foregoing factual situation, when reviewed in it totality, requires us to refer this matter to the appropriate law enforcement authorities so that a further determination can be made as to whether you have, in fact, violated any provision of the laws in this Commonwealth and whether appropriate proceedings should be initiated as a result thereof. C. Conclusion: The evidence presented in relation to days on which you were on sick or death leave from your county position and for which you also received payment from Forward Township for working on the roads; and the evidence presented in relation to days on which you claimed that you worked and received compensation for both Allegheny County and Forward Township; and the evidence presented in relation to your attending a conference in Seven Springs and receiving compensation, therefor, and working on the township roads on the same days and receiving compensation warrant further review by appropriate law enforcement authorities. We are, therefore, referring this matter to the appropriate law enforcement authority with the recommendation that further review be undertaken in order to determine whether your actions are in accordance with the appropriate laws and that appropriate actions be initiated if warranted. Allegation #2: That you violated Section 3 Act, 65 P.S. 403(a) and 403(h) respectively personnel and equipment used to oil private and deliver slag to private persons includi A. Findings: (a) or Section 3(b) of the Ethics , by using or having township driveways, grade prvi ate property, ng your relatives. n n s Mr. Al red Pel legri ni Page 12 May 2, 1986 17. The following is a listing of work done on private driveways /roadways by the Forwarrd Township road crew completed prior to the 1983 primary and general elections: a. Mary Protz, Torrence Road, April, 1983. Approximately (6) ton slag /gravel dumped in driveway. Protz is an aunt to you. b. Dean Smith, coal yard Kelly Hollow Road, April -May 1983. (3) ton gravel /slag. c. East Monongahela Sportsmen's Club, April-May, 1983. Road dust oil d. Lock #3 Oil, coal and dock, April -May 1983. Road dust oil. e. Frank Rostosky, R.D. #3, Monongahela, April -May, 1983.. Road dust oil. f. Glenn Dyer, R.D. #1, Monongahela, April -May, 1983. Road dust oil. g. James McClintick, R.D. #3, Monongahela, April -May, 1983. Road . graded, shale /gravel work. h. Jay Davis, Sunnyside Road, April -May, 1983. (5) ton gravel, road graded. 1. Ken Manown, . River Hill, May -June, 1983. (5) ton blacktop. j. John Koynock, Kelly Hollow Road, April and September, 1983. Approximately (10) tons of gravel /slag. k. Walter Crovak, Bunola Area, October 3, 1983. (5) ton gravel /slag. The work performed above was done by the roadcrew per orders from you and Supervi so Vincent Jule an. 18. Records obta►, fray Forward Tot Secretary Audrey Julian regarding work done on the private (.' riveways of Forward Township residents were exami ned, and the fol1owi ng i nfcrmation w,s obtained from monthly billings: a, July, 1983: Listing wider icceipts presented at monthly meetings: Glenn Dyer - $37.80 Road dust oil. Lock 3 Coal to Dock Co. - $126.00 Road dust oil. Mr. Alred Pellegrini Page 13 May 2, 19R6 Bank deposit slips for township general fund at Equibank confirm $37.80 deposited on July 18, 1983 and $126.00 on July 30, 1983. b. August, 1983: Listing under receipts presented at monthly meeting: Frank Rostosky - $88.20 road dust oil East Monongahela - $329.80 road dust oil Sportsmen's Club Bank deposit slips for township general fund at Equibank $88.20 deposited on August 23, 1983 and $329.28 on August 19, 1983. Letters dated June 17, 1983 indicating amounts due for road dust oil: a. Lock 3 Oil, coal and dock, 150 gal. at $.84 gal - $126.00 b. Frank Rostosky - 105 gal. at $.84 gal - $88.20 c. Glenn Dyer - 45 gal. at $.84 - $37.80 d. East Monongahela Sportsmen's Club - 392 gal. at $.84 gal. - $3,129.28 c. October, 1983: Listing under receipts presented at monthly meeting: John Koynack - $25.00 - slag. Walter Crovak - $20.00 - slag. Bank deposit slips for township general fund at Equibank confirm both amounts deposited October 11, 1983. 19. There is no listing for payments received from any of the other above listed individuals. 20. At least one invididual (Frank Rostosky) reported to a township citizens group that payment would not have been required had the citizens group not questioned the private work performed by the township roadcrew. 21. In July, 1983, a member of the citizens group made a request in writing to the township to have work done on his driveway. That request was refused. Mr. Al red Pellegrini Page 14 May 2, 1986 22. The work done on private roadways was discussed at township meetings in June, July and August, 1983. a. At the June, 1983 meeting, Chairman Vincent Julian denied that work was done on private roadways. b. At the July, 1983 meeting, Julian stated that the road crew did do some private work. c. At the August, 1983 meeting, Ju i i L.n stated that individuals who had work done on private driveways would be billed. d. Billings related to Finding #18 are dated June 17, 1983 prior to Julian's announcement that the individuals would be billed. e. At the August 1, 1983 meeting, in regards to the road work, you are quoted as stating, "We're the bosses; we'll do what we want to do." B. Dis ussion: We must review this allegat:on under Section 403(a) of the State Ethic Act as previously cited. In the instant situation, it is clear and the evidence unequivocally shows that township equipment and personnel were used to do ;goi•k on the residence and property of private individuals in the Commonwealt{,„ While some of the individuals involved did, in fact, reimburse the townshp for the materials that were used in relation to these projects, there is no indication that the township was completely reimbursed for all of the materials and for the use of the township's personnel and equipment in relation to this matter. There is no evidence, however, that any of the aforementioned projects resulted in your obtaining any Ji nanci al gain or resulted in any member of your immediate family or business with which you are associated obtaining any financial gain. While the use of township equipment and personnel for other than appropriate township purposes may be a questionable expenditure of township funds, such is a question that must be reviewed by the township board of auditors and not by the State Ethics Commission. We have also reviewed the foregoing within Section 3(b) of the Act which provides that: Section 3. Restricted activities. (b) No person shall offer or give to a public official or public employee or candidate for public office or a member of his immediate family or a business with which he is associated, and no public official or public employee or candidate for public office .shall solicit or accept, anything of value, including a gift, loan, political contribu ":ion, reward, or promise of Suture employment based on any understandi ng that the vote, of fici al action, or judgment of the public official o publi employee or candidate for public office would be influenced thereby. 65 P.S. 403(b). Mr. Al red Pel legri ni Page 15 May 2, 1986 We find no evidence that this provision of law has been violated. C. Conclusion: Based upon the foregoing evidence, we do not believe that you violated the State Ethics Act when township materials, equipment and personnel were used to do work on private property in light of the fact that you di'd not receive any financial gain from such activity and in light of the fact that there is no evidence to indicate that such was a violation of Section 3(b) of the Act. Allegation #3: That you violated Section 3(b) of the Ethics Act, 65 P.S. §403(b) , by firing a township employee who refused to display your 1983 campaign ads and promising other persons township jobs in return for their support of your candidacy. A. Findings: 23. You sought re- election to the Forward Township Board of Supervisors in 1983. 24. In 1983, Forward Township employed a road crew mainly consisting of Franklin Pascarella and James Large. Other workers on a limited basis were George Scagli ne, cousin of Supervisor Vi ncent Julian, and Tony Pi scitel li . 25. Forward Township payroll records confirm that Franklin Pascarella began working for the Township on January 16, 1981, while James Large is reflected as starting on April 14, 1982. 26. Payroll records for 1981 averaged (68) hours worked pe in 1982. Large averaged (66) 31, 1983, Pascarella averaged (55) hours per pay period. and 1982 also confirm that in 1981 Pascarella r pay period and (81) hours worked per pay period hours worked per pay period in 1982. Until May (72) hours per pay period while Large averaged 27. Prior to the 1983 primary election held in May, you admit that you gave campaign posters to Pascarella and directed him to display the posters in his private vehicle. Pascarel la refused to do so. 28. On May 25, 1983, Pascarel la had a discussion with Vincent Julian regarding Pascarella's failure to display your campaign posters in his private vehicle. a. Pascarel la was shortly, thereafter, dismissed from his position. 29. On May 26, 1983, Pascarella went to see you at your office located at Round Hill Park to discuss why he was to be terminated from the road crew. a. Pascarella testified that you stated that any body working for you will campaign and that you had other men wi 1 li ng to work. Mr. Al red Pel legri ni Page 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). May 2, 1986 O. On May 31, 1983, Pascarella reported for work at the Forward Township garage. Although it was not a cormon practice, you were present that morning a. Pascarella testified that you asked who told you to report to work and that you stated we'll call you when we need you. b. You confirm that that exchange occurred. 31. You admit that you have a personality conflict with Pascarella but deny that his termination was related to his failure to campaign for our re-election. a. You contend Pascarella's dismissal was related to a lack of work in th_ toslchip. 32. Forty rd Township payroll records for June and July, 1983 confirm that the number of h oirs worked by James barga increased significantly during that period. in zddi tion, two other pare -Yore workers were called out to work, and an individual who never previously worked for the township was called out tc work or Jun 6, 7, 8, 1983. 33. Fran i n Pascarella obtained legal counsel in June or July, 1983 to initiate leg1 action in hopes of retaining his employment. There is evidence to suggest that you, as well as the other township supervisors, were aware of that. a. Pasc,arel was subsequently returned to the payroll effective August 1, 1983. Payroll records confirm that Pascarella remained employed until December 31, 1983. He then was not recalled to work. 34. You acrd the township solicits tong., +d t:prt none of the township employees are ful 1 -time and that the township was not requi red to mai ntai n Pascarella on the payroll, even though he was the employee with the most seniority. B. Discussion: The above &legation must be reviewed both under Section 3(a) of the State Ethics Act as well as Section (b) of the Act which provides as follows: Mr. Al red Pel legri ni Page 17 May 2, 1986 Section 3. Restricted activities. (b) No person shall offer or give to a public official or public employee or candidate for public office or a member of his immediate family or a business with which he is associated, and no public official or public employee or candidate for public office shall solicit or accept, anything of value, including a gift, loan, political contribution, reward, or promise of future employment based on any understanding that the vote, official action, or judgment of the public official or public employee or candidate for public office would be influenced thereby. 65 P.S. 403(b). Initially, with relation to Section 3(b) of the Act, we are called upon to determine if any person has offered to any public official or public employee or candidate for public office anything of value or if any public official has solicited, accepted, anything of value based upon the understanding that his official decision would be based upon such offer, acceptance or receipt. In the instant situation, you are the public official whose conduct has been questioned. If you accepted Mr. Pascarella's efforts on behalf of your re- election campaign based upon the understanding that your decision to retain him as a township employee would be influenced thereby, then such could be a violation of the Act. Under this fact pattern we would be required to find that his work, on your behalf, is a thing of value. While we believe that such, in fact, would be reviewable within Section 3(b) of the Act, we do not believe that sufficient evidence exists to find a violation of the Act, as we shall set forth below. In addition to the foregoing, we must also determine whether you used your public position in order to obtain a financial gain other than the compensation provided for by law. 65 P.S. §403(a). In the instant situation, several facts are clear. You had asked Mr. Pascarella, a township emplopee, to place an election campaign poster in his private vehicle. Shortly after Mr. Pascarella refused to comply with your request, his employment with the township was terminated. There is no direct evidence to indicate that such termination was based upon Mr. Pascarella's refusal of your request. There is information that has been received from Mr. Pascarella that you, in fact, made statements indicating that his failure to campaign on your behalf was the reason for his termination from the township's payroll. You have subsequently denied that such statements were made. The above is the only information that has been found in relation to this situation. In light of the foregoing, we do not believe that the evidence clearly indicates that you used your position in order to obtain a financial gain other than the compensation provided for by law. We do note, however, that in the event that such activity was clearly provable, we do believe that a violation of the Act would have occurred. In addition, we also believe that substantial questions would have been raised as Mr. Al red Pel legrini Page 18 May 2, 1986 to other provisions of law. See 18 P.S. §4701. (Regarding bribery in political matters). We believe, that because of the implication of other laws r1utside of the jurisdiction of the State Ethics Commission may be involved, this matter should be further reviewed by appropriate law enforcement authorities in this Commonwealth and, as a result, we are forwarding this matter to the such authorities for appropriate review and for their determination as to whether any further action should be initiated. C. Conclusion: We do not believe that the evidence clearly indicates that you violated th' State Ethics Act in the instant situation. We do believe, however, that other provisions of law not within the jurisdiction of the Ethic.: Commission may have been implicated in the instant situation and, as such, this matter should be reviewed by the appropriate law enforcement authorities for their consideration disposition. Orr 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 ma unless you file documentation with the Commission which justifies reconsider'ton and /or challenges pertinent factual findings. See 51 Pa. Code 2.38. Duri:ig this 15 -day period, no one, including the Respondent unless he waives his right to challenge this Order, may violate this confidentiality by releasing, di scLssi ng or circulating this Order. Any person who violates the confidentiality of a Commission proceeding is guilty of a mi scLmeanor 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). By the Commission, /2". G. Sieber Pancoast Chairman