HomeMy WebLinkAbout573 DouglasMr. Daniel A. Douglas
9781 Cross Station Extension
Girard, PA 16417
Re: 85 -129 -C
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
ORDER OF THE COMMISSION
Order No. 573
DECIDED: May, 26, 1987
MAILED: June 2, 1987
Dear Mr. Douglas:
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, a Supervisor in Girard Township, violated Section
3(a) of the Ethics Act, 65 P.S. .5403(a), 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
when you received pay from the township without being properly appointed to a
position and having auditor approval of your wages.
A. Findings:
1. You served as a Girard Township Supervisor from January, 1980 until
December, 1986. As an elected public official you are subject to the
provisions of the State Ethics Act.
2. Minutes of the Girard Township Supervisors' reorganization meetings
disclosed that for the years 1980 through 1985, the board appointed a
roadmaster to supervise the road crew.
a. Records further disclose that during tIfis period, the board of
supervisors did not authorize any supervisors to be employed as
part -time road workers.
You were not appointed roadmaster in any year from 1980 -1985.
3. Minutes of the Girard Township Auditors for the years 1980 through 1987
disclosed the follov.ing regarding compensation for township supervisors:
a. January 8, 1980: Part -time supervisor salary set at $5.75 /hour.
$350.00 annual salary set for supervisors attending
outside meetings. Payment to be a non - taxable
reimbursement for travelling expenses.
Conventions, schools, and supervisor meetings shall
be paid by state mandate.
Mr. Daniel A. Douglas
Page 2
b. January 6, 1981: Roadmaster salary set at $7.00 /hour; part -time
supervisor wage set at $6.25 hour.
$350.00 annual pay set for supervisors attending
outside meetings.
c„ January 5, 1982: Roadmaster salary set at $13,000.00 /year.
Part -time supervisor wage set at $ /hour.
$400.00 annual •pay set for supervisors attending
outside meetings.
d. January 18, 1982: Auditors passed motion that the supervisor keep a
written record of all meetings attended and
location of meetings.
Full -time qualified roadmaster salary set at
$16,965.00.
e. January 14, 1983: Roadmaster pay set at $17,737.20/year.
Part -time supervisor wage set at $6.80 /hour.
Auditors recommend use of PennDot form MS907 by al'
supervisors to substantiate their pay.
Outside meeting pay for supervisors set ?': t.i a same
hourly rate as part -time supervisors plus
$.17 /mile. Auditors motion that the supervisors
appoint one person as the delegate and submit a
voucher listing the name, nature of :he meting and
location monthly to the township secretary/
treasurer.
Insurance benefits:
Ray Sanders: Life -.$21.45/quarter.
Hospitalization $319.27 /quarter.
Daniel Douglass: Life - $ /quarter
Hospitalization $306.56 /quarter,
Mr. Daniel A. Douglas
Page 3
William Borland:
f. January 4, 1984: Roadmaster pay set at $362.00 /week.
Outside meeting pay set at $7.20 /hour plus
$.20 /mile for use of personal vehicle.
Insurance benefits:
Borland - Hospitalization - $498.14 /quarter
Life - $21.45 /quarter
Pension - $500.00 /year.
Sanders - Hospitalization - $473.24 /quarter
Life - $21.45 /quarter
Douglas - Hospitalization - $363.07 /quarter
Life - $21.45 /quarter.
January 8, 1985: Roadmaster pay set at $375.00 /week.
Supervisors working part -time - $7.45 /hour.
Outside meeting pay for supervisors designated as
the township representative set at $7.45 /hour plus
$.20 /mile for use of personal vehicle.
g.
Life - $21.45 /quarter
Hospitalization $426.55 /quarter.
Pension - $500.00 /year.
Insurance Benefits:
Borland - Hospitalization - $498.14 /quarter
Life - $21.45 /quarter
Pension - $500.00 /year
Sanders - Hospitalization - $473.24 /quarter
Life - $21.45 /quarter
Douglas - Hospitalization - $363.07 /quarter
Life - $21.45 /quarter
h. January 8, 1986: Roadmaster pay and benefits to remain the same as
1985.
Mr. Daniel A. Doi!.!
Page 4
No hospitalization or life insurance approved for
non - working supervisors (Douglas, Sanders) per
recommendation of Solicitor Schroeck by letter
dated September 18, 1985.
Roadmaster pay set at $ /week, plus overtime
for overtime over 40 hours. Life insurance and
hospitalization to terminate when full -time
employment ceases pension plan disapproved. Pay for
supervisor working part -time approved at
$7.00 /hour.
4. Girard Township payroll records confirm that
amounts as a part -time supervisor/laborer:
you were paid the following
a .
b.
c .
d.
e.
f.
1980: 167 hours at
1981: 114.5 hours
1982: 249.5 hours
1983: 108 hours at
1984: 121.5 hours
1985: 222.5 hours
a.
b.
c .
d.
e .
f.
i . January 6, 1987:
5. Township payroll records also confirm that you were paid the following
amounts for outside meeting pay:
1980:
1981:
1982:
1983:
1984:
1985:
$350.00
$350.00
$400.00
$120.79 - 6 meetings at
$148.40 - 9 meetings at
187.20 - 7 meetings at $
b. Ciscussion: Township supervisors in
publi as that term is defined
§402. As such, their conduct must confo
Ethics Act. See, Sowers, 80 -050.
$5.75 /hour = $960.25
at $6.25 /hour = 715.63
at $6.50 /hour = $1,621,75
$6.50 /hour = $734.40
at $7.20 /hour = $874.80
at 7 .44 /hour = $1,653.00
$6.80 /hour plus $.20 -- ileage
$ /hour, plus $.20 mile °ge.
7.45 /hour, plus $.20 mileage.
;
townships of the second class are
in the State Ethics Act. 65 P.S.
rm to the requirements of the State
•
Mr. Daniel A. Douglas
Page 5
The State Ethics Act provides 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).
Within the above provision of law, this Commission has already determined
that township superviors may not approve or accept any compensation for
themselves that is not in accordance with the compensation set forth in the
Second Class Township Code. This determination has been affirmed by the
Commonwealth Court of Pennsylvania. See McCutcheon v. State Ethics
Commission, 77 Pa. Comm. 529, 466 A.2d 283, (1982). Compensation awarded or
received by a township supervisor that is not in accordance with the
provisions of law could constitute a violation of the above cited Section of
the State Ethics Act.
The Second Class Township Code provides that township supervisors shall
receive the following compensation:
Compensation of Supervisors -- Supervisors may
receive from the general township fund, as compensation,
an amount fixed by ordinance not in excess of the
following:
Township Population
Not more than $,9999
5,000 to 9,999
10,000 to 14,999
15,000 to 24,000
25,000 to 34,999
Such salaries shall be payable menthly or quarterly
for the duties imposed by the provisions of this act. The
population shall be determined by the latest available
official census figures. The compensation of supervisors,,
when acting as superintendents, roadmasters or laborers,
Annual Maximum Compensation
Fifteen hundred dollars
Two thousand dollars
Twenty -six hundred dollars
Thirty -three hundred dollars
Thirty -five hundred dollars
Mr. b<.ni1 A.. DougTaS
Page 6
shall be fixed by the township auditors either per hour,
per day, per week, semi- monthly or monthly, which
compensation for the use of a passenger car, or a two
axled four - wheeled motor truck having a chassis weight of
less than two thousand pounds when required and actually
used for the transportation of road and bridge laborers and
their hand tools and for the distribution of cinders and
patching material from a stock pile, as the auditors shall
determine and approve; but no supervisor shall receive
compensation as a superintendent or roadmaster for any
.time he spends attending a meeting of supervisors. 65
P.S. §65515, as amended Act 68,1985.
(Prior to the above amendment, the above provision
provided for a set fee of $50 per meeting).
In reference to the meetings for which supervisors may receive
compensation, the code, as applied for the time period in question further
provided as follows:
The township supervisors shall meet for the
transaction of business at least once each month, at a
time and place to be fixed by the board, but they shall
not be paid for more than sixteen meetings in any one
year, except in any township where, on account of the
exercise of governmental functions other than those
relating to roads, more meetings are necessary, in which
case, the number of meetings for which the supervisors may
be paid may be increased to any number, not exceeding
fifty meetings in any year which shall include hearings of
a judicial or quasi - judicial nature. Two members shall
constitute a quorum. Except as otherwise provided in this
act, an affirmative vote of a.majority of the entire board
of supervisors shall be necessary in order to transact any
business. Necessary expenses incurred in such meetings,
including office rent, stationery, light and fuel, shall
be paid out of the general township fund. 53 P.S. §65512.
•
(The above provision was amended in 1985)
Mr. Daniel A. Douglas
Page 7
The duties that a supervisor is responsible for performing are also
regulated by statute. As can be seen from the foregoing, the compensation to
be paid for a supervisor who is not otherwise employed by the township is
strictly regulated by the Second Class Township Code. A supervisor may only
receive compensation, as set forth above, for supervisor meetings regarding
the transaction of township business. The type of meetings for which a
township supervisor may be compensated must be one at which official township
business is transacted. Additionally, the township code provides for
compensation at the specific meetings outlined in §65512, above. The code
does not appear to permit the compensation of a township supervisor for
attending other types of meetings or for performing the administrative
functions of his office. Any other compensation must be earned in and as part
of the services performed while serving in one of the statutory authorized
positions. Thus, if the township supervisors were to award to themselves
compensation for attendance at meetings that are not official township
meetings of the board of supervisors, or for performing duties not authorized
by law such would violate the provisions of the State Ethics Act as such
payment would not constitute compensation provided by law. We note that the
above interpretation of the Second Class Township Code is a view that has also
been expressed by the State Association of Township Supervisors which
specifically indicated that supervisors may not be compensated for meetings
with engineers, solicitors, planning commissions, authorities, or recreation
boards. See Township News, May, 1985, Page 66.
The township code sets forth clearly when supervisors may receive
compensation other than as set forth above. Generally, township supervisors
may be employed by the township as a roadmaster, laborer, or
secretary /treasurer. 53 P.S. §65410. The compensation to be paid to
supervisors working in such positions is to be fixed by the township board of
auditors. 53 P.S. §65515; §65531; §65410. Township supervisors may not
receive any other compensation except as provided above. This concept has
been upheld by various courts in the Commonwealth. In Coltar v. Warminster
Township, 8 Pa. Commnw. Ct. 163, 302 A.2d 859, (1973), the Commonwealth Court
of Pennsylvania held that a second class township supervisor may not appoint
himself to positions other than those set forth in the township code
(roadmaster, laborer, or secretary /treasurer), and receive compensation
therefor. See also Conrad v. Exeter Township, 27 D & D 3d 253, (Berks 1983).
It is clear, therefore, that the duties for which a township supervisor may be
compensated are strictly regulated by the township code, and when performing
in the positions set forth in the code, the supervisors' pay must be
i4r. Daniel A. Douglas
Page 8
specifically set
matter indicated
compensated were
in that position)
No. 539.
forth by the township board of auditors. Our review of this
that the "administrative services" for which you were
not related to the roadmaster position (you were not serving
but were related to the office supervisor. See Szymanowksi
You, thus, received compensation that was not part of that provided for
by law.
With relation to the fact that the auditors approved this compensation,
we note that this Commission has already held that township auditors have no
authority to fix compensation for township supervisors who are performing
duties outside of those fixed by law or for working in positions not
established in the township code. Nanovic, 85 -005. Thus, even though the
auditors may have indicated an approval for this "administrative pay" such was
of no effect as the auditors did not have the power to fix a compensation that
was not allowed by law and that was regulated by statute (compensation as a
supervisor). We also note that in 1980, the funds were allocated not as
compensation but for reimbursement for expenses incurred.
The funds received by you as "outside meeting pay" as outlined in the
findings totalled $1,206.39. (Finding No. 5).
Our conclusion and the appropriate remedy in respect to this matter are
set forth further below.
II. Allegation: That you, a Supervisor in Girard Township, violated Sectior
3(a) of the Ethics Act, 65 P.S. 403(a), which prohibits a public employee's or
public official's use of office or confidential information gained through
that office to obtain financial gain when you received and retained mo :ley
a `rom,
pension benefits program in which you participated up to 1981, despite your
solicit;)r's advice that you were not entitled to these benefits.
III. Allegation: That you, a Supervisor in Girard Township, violated Section
3(a) of the Ethics Act, 65 P.S. §403(a), which prohibits a public employee's
or public official's use of office or confidential information gained through
that office to obtain financial gain by having the township pay for hospital
and life insurance in which you participated.
A. Findings:
6. Finding number 1 through 5 are incorporated herein by reference.
Mr. Daniel A. Douglas
Page 9
7. Girard Township records disclose that on October 5, 1973, the township
supervisors entered into a Group Pension (Annuity) Plan, #DA -153 with Columbia
Life Insurance Company.
a. The plan was a Group Deposit Annuity contract. All supervisors and
full -time employees were eligible to participate.
b.. The plan had 100% full and immediate vesting.
c. The application was signed by Girard Township Supervisors Korb Bryant
and Ray Sanders and was dated December 28, 1973.
d. The register and anniversary dates of the plan was listed as October
5, 1973.
8. Minutes of the township supervisors meeting of October 1, 1973 discloses
on motion by Sanders, second by Korb Bryant and passed unanimously the
township approved the group pension plan as well as an accident and health
plan with Columbia Insurance Company.
9. Township records confirm that in 1980 the township made a $300.00
contribution to the Columbia Life Insurance pension plan on your behalf.
a. By letter dated September 17, 1981 from Gail Kipp, Columbia Life
Pension Manager, the township was advised that no billing was made
for you or supervisor, Ray Sanders in 1981. The reason for that was
due to a conversation with Solicitor James Toohey in regard to
supervisors who are not ful 1 -time working employees.
10. Contributions to the group annuity were discontinued in 1981 upon the
advice of Solicitor James Toohey that such contributions were improper.
Toohey presented, to the township, an opinion dated May 13, 1981 drafted by
Toohey's law partner. That opinion cited the case of Hendricks v. East
Rockhill Township, 1 D & C 3d 763 (1977), and held that such contributions
were improper. That opinion also stated in part:
a. In addition to holding that supervisor) per se are not entitled to
pension benefits, the case also holds that in this situation where
one or more of the supervisors are appointed as roadmaster, then in
that event the auditors must approve the payment into the pension
plan pursuant to 53 P.S. 65514 and 53 P.S. 65515.
Mr. Daniel A. Doug.:
Page 10
be As far as the money contributed to tne plan on behalf of tne
supervisors is concerned, it would be my opinion, based on the
Rockhill Township case, that that money is properly the property of
the township and should be refunded.
11. Township records confirm that by letter dated December 20, 1985, you
requested that all of your pension money be returned to the township as of
December 31, 1985.
a. Records disclose that receipt No. 16949 dated February 3, 1986 was
issued to you in an amount of $455.07 for endorsing Columbia check
#010066 to the township.
The amount of $455.07 represented the 1980 contribution, plus
interest through December 31, 1985.
12. Findings number 1 through 11 are incorporated herein by reference.
13. Girard Township paid accident, health and life insurance premiums on your
behalf to Columbia Insurance Company from 1980 through 1985 to policy number
KSM 3674. Payments were made on a quarterly basis.
a. 1980: Accident and Health
Life
b. 1981: Accident and Health
Life
c. 1982: Accident and Health
Life
d. 1983: Accident and Health
Life
e. 1984: Accident an Health
Life
$1,044.02
95.43
1,139.45
$1,120.12
85.80
$1,205.92
$ 840.09
64:35
904.44
(3 payments)
$1,616.79
107.25
$1,724.04
$1,452.28
85.80 (3 quarterly
$1,538.08 payments)
Mr. Daniel A. Douglas
Page 11
14. By letter dated December 20, 1985, you informed Columbia Life Insurance
Company to discontinue your accident, health and life insurance policies.
15. Records from the township disclosed that in 1984 and 1985, the township
solicitors were asked for opinions regarding accident and health insurance for
non - employee supervi sors and part -time empl oyee supervi sors.
a. By correspondence dated March 29, 1984 addressed to William Borland,
Chairman of the Board of Supervisors, Solicitor Howard Rubenfield
issued an opinion that a non - employee supervisor may not participate
in the township medical and hospitalization plan. Further, an
employee - supervisor may be covered only if such coverage is
specifically approved by the township auditors as part of the
employee - supervisor's compensation.
b. By correspondence dated September 18, 1985 addressed to Daniel
Douglas, Chairman of the Board of Supervisors, Solicitor George
Schroeck issued an opinion that a part -time employee supervisor may
not participate in the township's medical and hospital or life
insurance plans. Further, an employee - supervisor may be covered only
if such coverage is specifically approved by the township auditors as
part of this compensation.
16. You were interviewed by a State Ethics Commission investigator on
November 18, 1986 and made the following statements:
a. When elected to the board, the supervisors were already receiving
pension benefits, accident and health and life insurance and outside
meeting pay.
b. You did not know why the accident and health insurance was not
discontinued until late 1985. The auditors approved the plan. Also,
members of the State Association of Township Supervisors indicated
that the law would change permitting all supervisors to receive the
insurance. You thought the issue would be resolved in your favor.
c. You received outside meeting pay at a flat rate in 1980, 1981, and
1982. The supervisors were receiving outside meeting pay prior to
your election. In 1983, supervisors were paid by the hour for
attending outside meetings. You received outside meeting pay for
attending meetings of the area communications center, a body which
you were appointed the township representative. You were required to
submit a slip naming the meeting hours attended and mileage driven.
Mr. Daniel A. Douglas
Page 12
d. After the solicitor's 1981 ruling, the pension plan was terminated.
You refunded a check in excess of $400.00 to the township. You
planned on seeking an earlier refund but were advised against it by
Columbia Insurance Agent Frank Gigliotti who told you to seek
reimbursement at the end of the year, thereby earning more interest.
B. Discussion: As a township supervisor, you are a public official as that
term is defined in the State Ethics Act. 65 P.S. §402; Sowers, 80 -050. Your
conduct as such an official must, therefore, conform to the requirements of
the State Ethics Act.
Generally, the State Ethics Act provides 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).
Within the above provision of law, this Commission has previously
determined that a township supervisor may not receive at the township's
expense pension health, hospitalization, medical and life insurance benefits
when such supervisor acts only in the capacity of a supervisor. Krane,
84 -001; Cowie, 84 -010. Additionally, even if such a supervisor is employed by
.he township as a roadmaster in accordance with the Second Class Township
Code, such benefits are considered compensation and must, therefore, be fixed
as such by the township board of auditors. See Synoski v. Hazle Township,
Pa. Commw. , 500 A.2d 1282, (1985); In re: Appeal of the Auditors Report
of Muncy Creek Township, Pa. Commw. Ct. , 520 ).2d 1241, (1985); Hunt,
No. 348 -R. Any benefits received other than as provided for above, would
consitute a financial gain obtained in violation of the State Ethics Act.
See, McCutcheon v. State Ethics Commission, 77 Pa. Commw. 529, 466 A.2d 283,
(1983 Conrad v. Exeter Township, 2 D & C 3d 253, (1983). These principles
of law are now well settled and constitute the law under which this situation
must be reviewed. See, In Re: Report of Auditor South Union Township, 47
Pa. Commw. 1, 407 A.2d 9
1
Mr. Daniel A. Douglas
Page 13
In the instant situation, while you were not an appointed township
roadmaster, you did work on the township roads and, therefore, may have been
eligible to receive the in question benefits. Such, however, required
approval by the township board of auditors in order to be considered part of
your authorized compensation. See, McCutcheon v. State Ethics Commission,
supra. The facts in the instant situation clearly reveal that the auditors
never fixed as part of your compensation the pension benefits. You never
received a financial gain in relation to these benefits in that the funds were
returned to the township. (See finding 11) As such there would have been no
violation of the State Ethics Act in relation to the pension benefits.
Additionally as noted, you also received life and hospitalization
benefits as outlined in Finding 13.
Once again, while you may have been eligible for such benefits, auditor
approval was required. From 1980 through 1982 no such approval was obtained.
In 1983 through 1985 approval was received as follows for your benefits:
1983 Life Insurance
Hospitalization
1984 Life Insurance
Hospitalization
1985 Life Insurance
Hospitalization
The township expended
benefits as follows:
1983
1984
and you, as supervisor, approved payment for your
Total $1,724.04
Total $1,538.08
As such in 1983, your received $412.00 in excess of that provided for by the
auditors.
r
21.45 /quarter, $ 85.80 /year
306.56 /quarter, 1,226.24/year
Total $1,312.04
21.45 /quarter, $ 85.80 /year
363.07 /quarter, 1,452.28 /year
Total $1,538.08
21.45 /quarter, $ 85.80 /year
363.07 /quarter, 1,452.28/year
Total $1,538.08
Additionally and as noted, the township expended funds as follows in
1980 - 1982 when no auditor approval was obtained.
Mr. Daniel A. Dougla_
Page 14
1980 Total $1,139.45
1981 Total 1,205.95
1982 Total 904.44
$3,249.84
The above plus the excess from 1983 total $412.00 equals $3,661.84.
It also should be noted that even if these benefits had been received in
good faith, such would not be controlling. Good faith receipt of such
benefits, even when based upon a solicitor's advice, will not alleviate the
necessity of a public official reimbursing governmental body for the
receipt of a financial gain for which he was not entitled. See Allegheny
County v. Grier, 179 Pa. 639, 36 A. 353, (1897); McCutcheon v. State Ethics
Commission, 77 Pa. Commw. 539, 466 A.2d 283, (1983); Kestler Appeal, 66 Pa.
Commw. 1, 444 A.2d 761, (1982). As a result, we believe that you must
reimburse Girard Township for this financial gain.
The State Ethics Act provides as follows:
Section 9. Penalties.
(a) Any person who violates the provisions of Section 3(a)
and (b) is guilty of a felony and shall be fined not more
than $10,000 or imprisoned for not more than five years,
or be both fined and imprisoned. 65 P.S. 409(a).
(c) Any person who obtains financial gain from violating
any provision of this act, in addition to any other
penalty provided by law, shall pay into the State
Treasury a sum of money equal to three times the
financial gain resulting from such violation. 65 P.S.
409(c).
In addition to the above, the State Ethics Act provides that the
Commission may forward the results of any investigation to the appropriate
prosecuting authority unless the alleged offender removes himself from the
conflict of interest by divesting himself of any financial gain received in
violation of the State Ethics Act. 65 P.S. §40a 9(iii). See also, McCutcheon
v. State Ethics Commission, 77 Pa. Commw. Ct. 529, 466 A.2d 283, (198`
(Commission may order restitution of financial gains received in violation of
the law.)
1
.Mr. Daniel A. Douglas
Page 15
In relation to allegations I and III as set forth, we believe that this is the
appropriate remedy.
C. Conclusion and Order: As a township supervisor in a township of the
second class your are a public offficial and subject to the provisions of the
State Ethics Act.
Your receipt of "outside meeting pay" and life and hospitalization
benefits in and through that position was a violation of the State Ethics Act.
As such, you used your public office to receive a financial gain other than
the compensation provided by law.
The amount of gain received total $4,868.23 ($1,206.39 + $3,661.84).
You are hereby ordered to remit to the State Ethics Commission, within
thirty (30) days of the date of this order, the amount of $4,868.23 made
payable to Girard Township as restitution for the financial gain that you
received. Failure to comply with the provisions of this order will result in
a referral of this matter to the appropriate authority for further civil or
criminal proceedings. There was no violation of the Act in relation to the
pension benefits as these funds were turned over to the township.
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 ssi on 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,
St/ . std ,«2t— aa- . , c�
G. Sieber Pancoast
Chairman
Mr. Daniel Douglas
7603 Welcana Drive
Fairview, PA 16415
Re: Order 573, File 85 -129 -C
Dear Mr. Douglas:
JJC /na
cc: Public Binder
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PA 17120
TELEPHONE: (717) 783 -1610
June 29, 1987
On June 29, 1987, the State Ethics Commission received your payment
for reimbursing Girard Township as required by Order 573.
We have forwarded your check No. 547 in the amount of $4,868.23 to the
township.
This letter will be part of the Order and a public record as such.
Sincerely,
C k i -w ti )-
� t
- John J. Contino
Executive Director