HomeMy WebLinkAbout483 StreightiffMs. Mamie Streightiff
SRBox45E
Three Springs, PA 17264
Re: 84 -171 -C
Dear Ms. Streightiff:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
ORDER OF THE COMMISSION
May 2, 1986
Order No. 483
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 School Board Director in Southern Huntingdon
School District, violated Section 3(c) of the Ethics Act when you were
appointed without an open and puhlic process to the position of board
secretary at an annual salary of $8,600.
A. Findings:
1. You were appointed to the Southern Huntingdon School Board in June of 1981
to f i l l an unexpired term. You were elected to a full four year term in
Novemher of 1981.
2. Minutes of the Southern Huntingdon School Board Meetings record the
following information relating to your appointment:
a. Minutes of Octoher 19, 1983, page 2.13:
Board unanimously approves Mrs. Reck to return to position as Board
Secretary effective Novemher 7, 1983 with the understanding that
she could take second half of leave during the second semester of
the 1983 - 84 school year or the first semester of the 1984 -85 school
year.
h. Minutes of May 16, 1984, page 17:
Reck announces she is going to take remaining six months of
sahhatical leave.
Motion Yingling; second Streightiff to authorize District
Superintendent Dr. Gerald Rau to appoint a suhstitute. Motion
carried unanimously. The hoard to confirm the appointment at ,the
meeting of June 20, 1984.
Ms. Mamie Streightiff
Page 2
May 2, 1986
c. Minutes of June 20, 1984, page 27:
Approval of board needed to confirm your appointment as Acting Board
Secretary /Superintendent's Secretary. Bau advises that the
situation was checked with Attorney Schock, School District
Solicitor, who had also checked the appointment with Attorney
Stephen Russell of the Pennsylvania School Board Association. Both
attorneys said the appointment was legal.
Bau highly recommended you for the job. Your appointment
and wages to be retroactive to May 2.9, 1984, your first day on the
job.
Motion Smith, second Allison to accept Bau's recommendation and
appoint you as Acting Board Secretary /Superintendent's Secretary at
an annual salary of $8,600. This to be a six month position with no
fringe benefits. Roll call vote: (8) yes (1) you abstained.
d. Minutes of August 15, 1984, page 47:
Motion Smith, second Allison to approve amending of the June 20,
1984 minutes so that Page Seven, Section K, appointment of Acting
Board Secretary /Superintendent's Secretary reads only appointment of
Acting Board Secretary. Roll call vote (8) yes, (1) you abstained.
3. Superintendent Bau states that there was no public notice posted for this
vacancy although it was standard practice for the district to post a notice to
fill non - professional positions.
4. There were two applicants to fill the position, you and Susan Oswald.
a. Both of you were interviewed by Dr. Bau and given a spelling,
grammar, and typing test.
b. You had the better test results.
B. Discussion: As a member of the school hoard for the Southern Huntingdon
County School District, you are a public official as that term is defined in
the State Ethics Act. See Yaw, 85 -011; Krier, 84 -002. As such, your conduct
must conform to the requirements of the State Ethics Act. 65 P.S. §401 et.
seq.
Generally the State Ethics Act provides as follows:
Ms. Mamie Streightiff
Page 3
May 2, 1986
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).
Within the above provision of law, a public official may not use their public
position to accept or otherwise obtain through that position any financial
gain other than the compensation provided for by law. in this respect, a
public official may not use their position or obtain in that position
compensation to which they are not entitled. See Domalakes, 85 -010. You may
not use confidential information obtained in your public position for similar
purposes. Ire the instant situation, we must review the_Public School Code in
order to determine if you, in fact, obtained any compensation to which you
were not entitled.
Generally, the School Code provides that no school director shall, during
the term for which the director was elected, engage in any business
transactions with the school district in which he or she is elected or be
employed in any capacity by the school district in which he or she is elected
or receive from the school district any pay for services rendered to the
district except as provided in the Act. 24 P.S. §3 -324. Thus, unless there
existssome exception you would be prohibited, as a school director, from
rendering services for compensation to the district. In the instant
situation, we note that the School Code does contain such an exception. In
certain school districts a school director may hold the position of secretary
or treasurer for the school board. 24 P.S. §4 -404. Thus, it appears as
though pursuant to the School Code, you may serve in the position of school
secretary and receive compensation, therefor. See
Rencker v. German Township School District, 341 Pa. 369, 19 A.2d 402, (1941).
In addition to the foregoing, it is noted that you neither voted for yourself
to obtain this position nor participated in the fixing of compensation that
was to be paid for your service in this position. As a_ result, we do not
believe that there was any violation of Section 403(a) of the State Ethics
Act.
In addition to the foregoing, the State Ethics Act provides as follows
Section 3. Restricted activities.
(c) 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
di rector, 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
Ms. Mamie Streightiff
Page 4
May 2, 1986
through an open and public process, including prior public
notice and subsequent public disclosure of all proposals
considered and contracts awarded. Any contract made i n
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).
This Commission has previously determined that Section 403(c) of the
State Ethics Act would be applicable to any situation wherein a public
official attempted to enter into a contract with his governmental body in
excess of $500. This would include employment contracts as well as contracts
for other types of services, goods, or materials. Section 3(c) of the State
Ethics Act does not absolutely prohibit a public official from entering into a
contract with his governmental body, but rather places certain restrictions on
the obtaining of such a contract. Within this provision of law, an open and
public process must be employed in obtaining such a contract. This Commission
has previously determined that that process is met by applying the following
standards.
1. Prior public notice of the employment or contracting possibility;
2. Sufficient time for a reasonable and prudent competitor /applicant to
be able to prepare and present an application or proposal;
3. Public disclosure of all applications or proposals considered;
4. Public disclosure of the contract awarded or offered and accepted.
See Howard, 79 -044; Fields, 82 -006; Cantor, 82 -004.
We must review the instant situation in light of the above standards.
The facts in this matter indicate that while the contracting or employment
possibility was not publicly advertised in a newspaper, the availability of
the position was announced at a public meeting of the school board at which
time it was indicated that a substitute would be appointed. That meeting was
held in May of 1984. After that point in time, applications were received.
There were only two applicants, you and another individual. The time period
between the announcement and the appointment of the board secretary was
approximately one month. We believe that this was a sufficient and reasonable
amount of time for individuals to present applications. The other individual
who applied for the position was interviewed as well as tested and the test
results indicate that you were the better qualified candidate. You were
appointed to the position on June 20, 1983, and this was done during a public
meeting of a school board. The only element of the open and public process
that does not appear to have been met was that there was no public disclosure
of the other application considered. We do not believe, however, this missing
element, in and of itself, rises to a violation of the State Ethics Act.
Ms. Mamie Streightiff
Page 5
May 2, 1986
Additionally, we note that while it is the better practice to publicly
advertise the availability of such a position, in the instant situation and
based upon the facts of this matter we do not believe that the absence of an
advertisement would alter this result. We note that our conclusion is
occasioned by the fact that our investigation revealed that the announcement
at the public meeting was sufficient to draw additional applications. Under
different circumstances, this result may be altered.
Finally, we note that under Section 3(c), in order to obtain a contract
with one's own governmental body, the individual involved must not participate
to any extent i n the contract review or award. In the instant situation, you
abstained from all participation in this matter. We also note that
Section 3(c) of the State Ethics Act would only permit a person to contract
with their own governmental body to the extent that such is not prohibited by
other provisions of law. Thus, in the instant situation, a contract of
employment by a board director to serve in a position as secretary /treasurer
appears to be expressly permitted. The School Code does, however, appear to
prohibit other types of contracts and a school director's interest in such
contracts.
C. Conclusion: You did not violate Section 3(a) or 3(c) of the State Ethics
Act when you obtained the position as secretary to the Southern Huntingdon
School Board when you are also a member of that board. You abstained from
participating in the board's consideration and final disposition of this
matter and we believe that the facts indicate that the matter was conducted
through an open and public process,
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 more than one year or both, see 65 P.S. 409(e).
By the Commission,
G. Sieber Pancoast
Chairman