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HomeMy WebLinkAbout571 StanleyDr. Emory R. Stanley c/o James A. Kelly, Esquire 1428 South Webster Avenue Scranton, PA 18505 Re: 85 -081 -C STATE ETHICS COMMISSION 308 FINANCE BUILDING HARRISBURG, PENNSYLVANIA 17120 ORDER OF THE COMMISSION Order No. 571 DECIDED: May, 26, 1987 MAILED: June 2, 1987 Dear Dr. Stanley: The 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, Superintendent of Blue Ridge Schools, violated Section 3(a) of the Ethics Act which prohibits a public employee's or public official's use of office or confidential information gained through that office to obtain financial gain other than compensation allowed by law or Section 3(b) which prohibits a public official from soliciting or accepting anything of value and from offering anything of value to a public official with the understanding that that official's judgment or action will be influenced thereby, when you stated the following in a Blue Ridge Schools Newsletter, Second Edition of May, 1985. "I understand that plans are underway to vote for write -in candidates on election day on May 21 and defeat those incumbents running for office and then even getting rid of the superintendent or some other administrator. The present board members are doing a superb job. But even if the plan is successful, the new board members will find that the problem did not go away nor will the new administrator find that the problems disappeared. Similar decisions will still have to be made only at a later date and by then the problems will have to be made and by then the problems will have grown worse and the actid`ns taken will have to be even more drastic. Please get out and vote, get your whole family to vote on May 21. By not doing so you let someone else make your decisions for you." A. Findings: 1. You served as Superintendent of -the Blue Ridge School District from 1971 • to June 1986. Ur, Emory R. Stanley Page 2 2. School Bo' rd minutes of the meeting of August 12, 1985, refl < ct 'Oa'. on motion by Mr. Richards, seconded by Mr. Whitehead, t +,E Beavd agreed to buy out the last two years of Respondent Stanley's five year contract. The board agreed to pay Stanley 75% of the salary he would have received for both 1986 -87 and 1987 -88. It was noted that Stanley was also eligible to receive professional employee's benefits under the Early Retirement Incentive Plan dated November 12, 1984, and the benefits due all administrators under the Administrative Employees Compensation Plan also dated November 12, 1984. a. A Resolution was approved by roll call vote with eight members voting affirmatively and none negatively. One Board member was absent. b. Minutes reflect that a motion was then made by Mr. Richards, seconded by Longacre, that Assistant Superintendent Richard Karr be elected Superintendent effective July 1, 1986, and that he receive a three year contract. This motion carried on a roll call vote with eight members also voting affirmatively. 3. The minutes of the August 12, 1985 meeting further reflect the following: a. The board announced that it would not be filling the vacated position of assistant superintendent. b. A motion was made by Mr. Whitehead, seconded by Mr. Longacre, to immediately place advertisements for a Business Manager so this person could be employed by January 2, 1986, and be trained by Stanley prior to his retirement on June 30, 1986. This motion carried. c. The school district will be saving in excess of $44,000.00 because it will not have to pay Stanley's retirement benefits and other fringes for the last two years of his contra'ct,> d. The differences between Stanley's salary and Mr. Karr's salary, and Mr. Karr's salary and the new Business Manager's prospective salary were also viewed as savings to the school district. e. The agenda for the school board meeting of August 12, 1985 called attention to the fact that Mr. Karr's contract as Assistant superintendent would end in June 1986. Dr. Emory R. Stanley Page 3 f. The School Code dictates that Mr. Karr be advised, at least 150 days before the contract ends, what the board intends to do with his contract. A statement in the agenda for the school board meeting of August 12, 1985, indicated that Karr's situation, and Stanley's tentative plans to retire in June 1986 were weighed by the Board. h. A statement in the agenda for the school board meeting of August 12, 1985, indicated the board had considered hiring a Business Manager for a period of months, possibly years. i. The early retirement plan for Stanley included a provision for the last two years of Stanley's contract as follows: 75% x 54,000 salary in 1986 -87 - $40,500.00 75% x 57,000 salary in 1987 -88 - 42,750.00 Total - $83,250.00 This sum of $83,250.00 was then placed in an escrow money market account on June 30, 1986. It was agreed that in January 1987 would receive $40,500.00 plus interest and in January 1988 a payment of $42,750.00 plus interest. 4. The Blue Ridge School Newsletter is utilized to forward school information to parents of school children. a. This newsletter is paid for by school district funds. b. It is either mailed or taken home by school students. c. A school calendar has been included in one newsletter, and student events are usually publicized. d. This newsletter is published regularly. 5. In the Blue Ridge School Newsletter, Second Edition, May 1985 you stated: g. P Ur. Emory E Stanley Page 4 "1 understand that plans are undcrw - y to vote for wi_ i to -i n candidates on election day on May 21 and defeat those incumbents running for office and then even getting rid of the Superintendent or some other administrator. These present board members are doing a superb job. But even if the plan is successful, the new board members will find that the problem did not go away nor will the new Administrator find that the problems disappeared. Similar decisions will still have to be made only at a later date and by then the problems will have grown worse and the rctions taken will have to be even more drastic. Please get out and vote, get your whole family to vote on May 21, By not doing so you let someone else make your decisions for you." a. The newsletter also contained information regarding the school district's surplus, financial status, information regarding the elimination of certain projects and information regarding other public sector concerns. 6.. Sdecific facts, as set forth in a letter your attorney forwarded to the Late Ethics Commission are as follows: a.. You denied that you misused the Superintendent's Office or confidential information gained through your position when you had the above passage released. b. You denied that you solicited or accepted anything of value, or that anything of value was offered to you to release the passage in the newsletter. c. You believed that you were defending attack a on your administration of the school district as a professional administrator. d. You also stated that you urged the public to vote and to consider all candidates, whether they were write -in., new ballot candidates or incumbents. • e. You denied that the passage in the newsletter favored one candidate over the other. You related that each of these electoral areas chooses two di rectors and a di rector -at- large. You described the electoral areas as being divided by two separate districts, i.e., Dr. Emory R. Stanley Page 5 g. township and borough. Under such circumstances, you stated it was virtually impossible for your passage in the newsletter to favor one school board candidate over another. 7. Board Member Karen A. Worden provided the following information: a. She recalled the school district newsletter of May 1985 and the specific passage authored by Stanley. b. Worden averred that the newsletter was paid for and distributed through the use of school district funds or personnel. c. Worden believed that Stanley was urging all eligible voters to participate in the May 1985 primary election and, thereby, not let others decide who would represent them on the school board. d. Worden denied having knowledge of any circumstances where Stanley was pressuring either her or other individuals for personal gain. e. She stated that Stanley followed normal procedures when he applied for an early retirement under a program which was already in place. f. She attributed Stanley's surprise decision to retire to failing health as a result of high blood pressure, which was compounded by pressures of the superintendent's duties. Worden acknowledged that Stanley was under considerable pressure from teachers and citizens due to forthcoming budget cuts when he declared his decision to retire. 8. Board Member William Richards provided the following information: a. Richards averred that he was a successful candidate for the school board during May 1985, and was re- elected in November 1985. b. He recalled the school district newsletter of May 1985 and the specific passage authored by Stanley. • c. Richards offered his opinion that Stanley was urging all eligible voters to participate in the May 1985 primary election so that they would decide who would represent them. Dr. Emory R. Starlit/ Page 6 d. Richards denied that Stanley's message was meant to favor him or any other incumbent school board member. e. He denied having any knowledge that the paying -off of the last two years of Stanley's contract was a pay -off to Stanley for his statements made in the Blue Ridge School Newsletter of May 1985. f. Richards stated he observed nothing unusual about the circumstances surrounding Stanley's early retirement. He related that three other school district employees were granted early retirement. Richards continued that these individuals served under a one year contract. Richards explained that as superintendent, Stanley was serving under a five year contract. g. Richards related that the circumstances of buying -back the last two years of Stanley's contract pertained to Stanley's particular situation. He denied that any favoritism was afforded Stanley when compared to other early retirees. 9. Board Member Daniel E. Denny advised that he was a successful candidate in the May, 1985 primary election. Denny advised as follows: a. Denny stated he was initially against the concept of an early retirement program but later changed his mind, and voted for Stanley's early retirement. b. He stated that a drastic decline in student enrollment convinced him that the early retirement of some school district employees was a partial solution to the problem. c. Denny related that there was never any pressure brought to bear on him by Stanely or any other individual concerning the 8 - 0 vote approving Stanley's early retirement. 6. )cnny denied having knowledge that statements made by Stanley in the n:wsl etter of May 1985 were a form of pay -off for board members buying out the last two years of Stanley's contract. • 10. F Board Member Roland V. Tompkins advised that he served from December 1979 to December, 1985. He provided the following information: a. Tompkins averred that he voted affirmatively fcr the early retirement plan of Stanley during August 1985. r Dr. Emory R. Stanley Page 7 b. He recalled that a problem with high blood pressure was instrumental in Stanley's decision to seek early retirement. c. Tompkins recalled that Stanley would receive a percentage of his salary during the 1986 -87 and 1987 -88 years of his contract. d. Tompkins advised that he never observed pressure in any form from Stanley or anyone else with regard to the above vote. B. Discussion: As an appointed superintendent of a local school district, you are a public employee as that term is defined in the State Ethics Act. 65 P.S. Section 402. As such, your conduct must conform to the requirements of that law. Nye, 435 -R. The instant situation must be reviewed within the provision of certain sections of the State Ethics Act which provide as follows: 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). (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, under Section 403(b) as set forth above, no public official may receive or accept anything of value based upon the understanding that his official decision will be influenced thereby. Similarly, no person or public official may offer to another public official anything of value for a similar Dr. Emory R. Stanley Page 8 purpose. In the instant situation, there 's roc rv; :rzce "c,, indicate that you were offered anything of value based upon the understanding that your official actions or decisions would be influenced thereby. Similarly, there is no indication that you offered anything of value to any public official to influence that individual's official conduct or decisions. Even if this Commission were to determine that your political support for the re- election of the board of school directors was a thing of value, there is no evidence that such was offered in order to influence the decision of those individuals. Additionally, there is no indication that you accepted or received anything of value based upon the understanding that your official actions would be influenced thereby. As such, we find no violation of Section 403(b) of the State Ethics Act. In addition to the foregoing, this Commission must review the instant situation, as noted above, within the provisions of Section 403(a) of the State Ethics Act. This provision of law would prohibit a public official from u °ing his position in order to obtain a financial gain for himself, a member n� his immediate family, or a business with which he is associated. A public employee would also be prohibited from utilizing confidential information tained in his public position for similar purposes. This Commission, in the has determined that a public official who uses the benefits of his pl,!hiic office to advance his own re- election campaign would be in violation of t.;':is particular provision of the State Ethics Act. See Cessar, 82 -002. Of F:..urse, in the instant situation, you were not seeking public office and :•efore, even if your statements in the newsletter could be construed to be aid of an election campaign, such would not have been to benefit your own :nation. In any event, it is not explicitly clear from the wording of the issages in the newsletter that you were indeed supporting the election (,- .ampaign of any particular individual. While that passage did, in fact, urge. is citizens of the community to cast a vote as they saw fit during the ection, such does not appear to have bren done in aid of any pat't icu' ar ndi vi dual . As such, we do not believe; that your cor:rluct speci f i ral ly violated the �:-ovisions of the State Ethics Act, We do, however, note that the Ethics Act also provides ar follows: • Dr. Emory R. Stanley Page 9 Section 1. Purpose. The Legislature hereby declares that public office is a public trust and that any effort to realize personal financial gain through public office other than compensation provided by law is a violation of that trust. In order to strengthen the faith and confidence of the people of the State in their government, the Legislature further declares that the people have a right to be assured 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. Because public confidence in government can best be sustained by assuring the people of the impartiality and honesty of public officials, this act shall be liberally construed to promote complete disclosure. 65 P.S. 401. In the instant situation, your publication of the previously set forth statement at a time when an election of the school board was at hand clearly created the appearance that you were acting to further the interests of these incumbents and thus your own interests. The use of public funds for this purpose thus fostered the appearance of a conflict of interest. The Ethics Act was without a doubt promulgated in order to prevent this type of perception such must be avoided in the future. Additionally, we believe that the school board should be aware of this matter and we also strongly recommend that the board consider the implementation of regulations that will in the future prevent the use of school district facilities and publications for purposes that are ostensibly political in nature. C. Conclusion: You did not violate the State EthicsAct when you caused to be published, printed and distributed in a newsletter of the school district, a statement requesting that the'school district resident cast a vote in the primary election. Your conduct did however create the appearance of a conflict between your private interests and your public position. Such conduct must be avoided in the future. • Additionally, the school district should consider the implementation of regulations that would prohibit the use of the district's facilities and materials in such a manner. Dr. Emory 1 Stanley Page 10 Our files in this case will e c:r id :.;:ia" y 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, .fcCa tA. G. Sieber Pancoast Chai rman •