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HomeMy WebLinkAbout678 CasperMr. Donald S. Casper c/o Design Services Company 524 West Pike Street P.O. Box 215 Meadowlands, PA 15347 Re: 87 -079 -C STATE ETHICS COMMISSION 308 FINANCE BUILDING HARRISBURG, PENNSYLVANIA 17120 ORDER OF THE COMMISSION ORDER NO. 678 DATE DECIDED: September 28, 1988 DATE MAILED: October 13, 1988 Dear Mr. Casper: 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 Supervisor for Chartiers Township, Washington County, violated the following provisions of the Ethics Act when you received health insurance coverage at township expense without auditor approval. A. Findings: 1. You serve as a Township Supervisor in Chartiers Township, Washington County, Pennsylvania. a. You have served in this position since 1979. b. You serve as Chairman of the Township Board of _Supervisors. c. You are not employed by the township in any capacity. 2. Medical and hospitalization insurance for township employees and Supervisors is administered by Blue Cross /Blue Shield of Western Pennsylvania, Box 1018, Pittsburgh, Pennsylvania 15230. 0 Mr. Donald S. Casper Page 2 3. You participated in this medical and hospitalization program at the township's expense. 4. Minutes of the Chartiers Township Board of Supervisors Meetings reflect the following regarding medical /hospitalization benefits: A. January 7, 1985: ( 1) ( All in favor - Casper and Kovatch (Kusky absent). Supervisors appoint themselves Superintendents of the township road system, and shall be entitled to all benefits provided the employees of said township. Supervisors are encouraged to donate their time as much as possible within reason in the execution of their duties and specific duties related to Township matters. Motion by Casper. Seconded by Kovatch. All in favor - Casper and Kovatch (Kusky absent). B. January 5, 1987: ( 3) (1) Regarding insurance benefits: Motion by Casper, seconded by Kovatch to retain the same coverage as last year, as follows: Township will continue providing of benefits for Life Insurance, disability, and hospitalization insurance. This applies to full -time employees and Supervisors. Motion carried - Casper and Kovatch (Kusky absent). Motion by Casper to continue to extend hospitalization coverage to extra or full -time employees at the discretion of Board when reasonable cause has been indicated that such is necessary. Seconded by Kovatch. Insurance benefit coverage: Motion by Casper, seconded by Kovatch to remain the same as last year -- Township will continue coverage of benefits for Life Insurance, disability, and hospitalization insurance. This applies to full -time employees and Supervisors. Motion carried. (No listing of any abstentions or no votes). ( ?) Supervisors voted themselves Superintendents of the Township road system, and shall be entitled to any and Mr. Donald S. Casper Page 3 (3) C. January 4, 1988: ( 1) ( ( (4) all benefits provided to work on road so designated in the Second Class Township Code. Supervisors are encouraged to donate their time as much as possible within reason in the execution of their duties and specific duties related to Township matters. Motion by Kovatch, seconded by Kusky. (All in favor. Present Kovatch, Kusky, Casper). Compensation for Supervisors attending Township meetings under the new rule - Casper entitled to $100.00 per month. Casper commented, since Kovatch was re- appointed as Supervisor he would be entitled to the new amount. Kovatch wished to go on record saying "I refuse to accept the new rate." Motion made by Casper that Kusky be paid on monthly basis, the sum of $166.67. Seconded by Kovatch. Motion carried. Motion made by Kusky to continue insurance benefit coverage as in previous years. Motion died for lack of second. Kovatch felt that Supervisors are not entitled to hospitalization benefits. Kovatch made a motion to pay hospitalization benefits for all full -time employees (leave out Supervisors). Motion died for lack of a second. Kovatch felt that if Kusky receives insurance, so should Casper. Casper made a motion for the township to continue coverage of benefits of life insurance, disability, hospitalization insurance, and dental for *all full -time employees and Supervisors as permitted by law pending Auditor approval. Motion seconded by Kusky. Roll Call: Casper - yes, Kovatch - no, Kusky - yes. Motion carried. Motion to acknowledge the fact that the Supervisors of the Township of Chartiers will continue to act as Superintendents of the Township road system, and shall be entitled to any and all benefits provided to work on Mr. Donald S. Casper Page 4 ( the roads so designated in the Second Class Township Code. All in favor. In a discussion regarding compensation, and punching time cards, it was sated that there will be no compensation for workshops. All in favor. 5. Chartiers Township Auditors meeting minutes reflect the following regarding compensation for township supervisors: a. 1/8/85 Supervisors pay rate set at $5.77 per hour, for road work. Rate effective 1/1/85. Stipulation - if a rate increase is granted to the township employees during the year, the supervisor's rate may be adjusted to that of Laborer /Truck driver classification. b. 1/7/86 - Supervisors pay rate set at $6.17 per hour. Rate effective 1/1/86. Rate determined from the rate paid to Laborer /Truck driver. c. 1/6/87 - Supervisors pay rate set at $6.36 per hour. Rate effective 1/1/87. Rate determined from the rate paid to Laborer /Truck driver. d. 1/5/88 - Supervisor's pay rate set at $6.55 per hour. Rate effective 1/1/88. Rate determined from the rate paid Laborer /Truck driver. 6. Records of Chartiers Township contain a letter to the Supervisor's from the Auditor's in regard to their observations and recommendations on the completion of the 1987 audit report. In finding #6 the auditors stated: a. They have questioned in past years, the paying by the Mr. Donald S. Casper Page 5 township of hospitalization for the supervisors who are full -time employees of other organizations. b. They previously requested Casper to reimburse the township for the hospitalization benefits, and he had complied, even though he has not fully reimbursed the township to date. c. The Ethics Commission has ruled on numerous occasions that if a Supervisor is not a full -time employee of the township, he should not qualify for benefits such as hospitalization, etc. d. Kusky has been receiving hospitalization benefits paid for by the township. e. They recommend that the township be reimbursed the amount of $2,579.99 for the year 1987, by Supervisor Kusky. 7. Records of Blue Cross of Western Pennsylvania indicate the following regarding the monthly cost of your participation in this program: a. HOSPITALIZATION Invoice Date Premium 9/5/85 $192.53 11/5/85 196.43 1/5/86 196.43 3/5/87 208.33 9 208.33 11/5/87 222.47 12/10/87 238.52 b. DENTAL Invoice Date Premium 12/18/85 $19.65 12/18/86 22.30 10/20/87 22.30 12/17/87 24.45 8. The total amounts expended by the township for the above insurance coverage were as follows: a. 1985 - April through October at $192.53/mth. = $1,347.71 November and December at $196.43/mth. _ $392.86 • Dental - April through December at $19.65 /mth. = $176.85 b. 1986 - January through December at $196.43/mth.= $2,357.16 Dental - January through Dec. at $19.65 /mth. _ $235.80 Mr. Donald S. Casper Page 6 c. 1987 - January and February at $196.43/mth. = $392.86 March through June at $208.33/mth. _ $833.32 Dental - January through June at $22.30 /mth. = $133.80 Total = $5,870.36 d. Your participation in this program at the township's expense was terminated in July, 1987. At this time the township began invoicing your private employer in your participation in this plan. 9. Records of Chartiers Township indicate that payment by the township for your insurance benefits was made from the Chartiers Township General Fund checking account at Equibank on a monthly basis as part of the payment for the total benefit package for all township employees. 10. Records of Chartiers Township indicate that you participated at the township's expense in a life and disability insurance program. 11. This program was administered through the Trustees Insurance Fund, Camp Hill, Pennsylvania. 12. Invoices from Trustees Insurance Fund to the township for your participation in this program indicate the following regarding payments for these benefits on your behalf: Invoice Date 12/14/84 12/16/85; 7/15/85 12/15/86; 7/15/86 12/15/87; 7/15/87 Disability $99.00 $99.00 $99.00 $99.00 Life $ 35.64 $ 35.6 $ 29.36 13. Total expenditures by the township for your participation in the disability and life insurance programs were as follows: a. September 1984 /September 1985 at $2.97/yr. = $14.85 Disability at $99.00 /yr. pro -rated April through Dec. 1985 at $8.25 /mth.= $74.25 b. September 1985 /September 1986 at $35.64/yr. = $35.64 Disability at $99.00 /yr. = $99.00 c. September 1986 /September 1987 at $143.1C /yr. Disability at $99.00 /yr. = $35.64 = $99.00 Mr. Donald S. Casper Page 7 d. September 1987 /September 1988 at $29.36/yr. = $29.36 Disability at $99.00 /yr. pro -rated January through August 1988 = $66.40 Total $454.14 e. Your insurance coverage was cancelled effective 9 -1 -88 and the township was reimbursed for the amount expended for September through December 1988. 14. You participated in a pension program into which the township contributed seven (7) percent of your pay. 15. Pension contributions by the Township, as taken from the Payroll summaries, April 1985 through December 1987, show the following payments made on your behalf: Period Ending Total Pay Township Cont. (7 %) Check # a. 4/28/85 $ 75.00 $5.25 5/12/85 138.48 9.69 5/26/85 50.00 3.50 7/7/85 50.00 3.50 6554 8/4/85 50.00- 3.59 6623 8/18/85 25.97 1.82 6659 9/1/85 25.00 1.75 6688 10/27/85 25.00 1.75 6789 12/85 50.00 3.50 102 Total 1985 $489.45 $34.26 b. 1/5/86 75.00 5.25 2/2/86 75.00 5.25 3/30/86 50.00 3.50 344 4/27/86 163.48 11.44 397 8/3/86 50.00 3.50 8/31/86 50.00 3.50 9/28/86 50.00 3.50 719 10/26/86 198.00 13.87 780 12/7/86 50.00 3.50 Total $761.56 $53.31 c. 1/4/87 50.00 3.50 913 undated 75.00 5.25 undated 50.00 3.50 4/2/87 (check) 25.00 1.75 1094 4/30/87 50.00 3.50 6/7/87 50.00 3.50 7/5/87 202.64 1240 undated 14.18 1293 100.00 7.00 undated 75.00 5.25 10/1/87 (check) 25.00 1.75 1518 Mr. Donald S. Casper Page 8 undated 50.00 3.50 12/10/87 252.64 17.68 Total $1,005.28 $70.36 4676 16. Total township contributions equaled $157.93. a. Contributions were terminated at the end of December 1987. 17. The township expended the following amounts for your benefits from April 1985 until they were terminated. a. Major Medical /Dental $5,870.36 b. Life and Disability $ 454.14 c. Pension $ 157.93 Total $6,482.43 18. According to the Township auditors, they never approved hospitalization or insurance benefits for the Supervisors. a. One township auditor believe that the supervisors should be entitled to participate in the program. b. One township auditor stated that she was not aware that the supervisors were receiving insurance benefits at the township's expense until 1987. 19. Township Solicitor James Liekar stated the following: a. He did not advise the Supervisor's if they did not ask. b. He was asked to draw up guidelines for hiring practices which he did. They have not been adopted yet. 20. You have stated the following in regard to the above information: a. You thought that your employer had reimbursed the Township and is current in their payments to the Township for your participation in the Township health and dental insurance plan. b. You checked the Township records yourself, and do not dispute the findings of this investigation. c. None of the supervisors rea'_ized that they were not entitled to participate in the insurance plan. Mr. Donald S. Casper Page 9 d. They considered themselves employees and this entitled them to the coverage. e. You were aware of the recent legislation granting amnesty to supervisors receiving benefits prior to 1985. II. Allegation: That you, a Chartiers Township Supervisor, violated Section 3(a) of the Ethics Act which prohibits a public employee's or public official's use of office and confidential information gained through that office to obtain financial gain, in that you voted to hire your son for a full -time position with the township road department. 21. Finding number one (1) is incorporated herein by reference. 22. Employment applications on file at the Chartiers Township building show the following: a. Mr. Daniel A. Casper Box 215, West Pike Street Meadowlands, PA 15347 (412) 222 -2768 b. Application dates: 'April 2, 1987 Social Security: 210 -64 -3697 18 yrs. or older: no Graduated High School: June, 1987 c. Date of Birth: July 19, 1969 d. Donald Casper is listed as a relative. e. Application indicated previous employment with the township in 1985. 23. Daniel A. Casper is your son. 24. Minutes of the Chartiers Township Board of Supervisors meetings indicate the following regarding the employment of your son. a. June 12, 1985: Casper approached the Board, if it is appropriate that Daniel Casper be considered for summer employment on the minimum wage basis. Motion by Kovatch to appoint Daniel Casper, for summer employment, seconded by Kusky, provided he furnish working papers prior to work. Mr. Donald S. Casper Page 10 Roll call: Casper abstained, Kovatch and Kusky voted yes. Motion carried. b. June 11, 1986: Henry Alexy requested one Township resident youth for summertime work. Applications were reviewed. Motion made by Kovatch to appoint Daniel Casper, for summertime employment, based on recommendation of Alexy for past summer performance, when needed at minimum wage $3.35 hr. Seconded by Kusky. Motion carried. Kovatch commented that "we will try to distribute work among different persons for a few days a week, when needed." Casper was absent. c. Aug. 19, 1986: Invoices presented for approval of payment - Daniel Casper (police car washes) $45.00, motion by Kovatch, seconded by Casper to approve payment of invoices, as presented, all in favor, motion carried. d. Jan. 5, 1987: Re- organizational meeting. Motion to appoint "emergency extra's" as follows: Deith Kovatch; Donnie Casper; Frank Przystup (not sure if he has #3 license); Bazzoli; Altieri; Almo; Johnson. Roll call: Casper - yes, Kovatch - yes, Kusky - abstained. Motion carried. e. April 8, 1987: Applications were presented for appointment with the road department. Daniel Casper asked to be put on with the road department. An application for John Kusky, who is somehow related to Mike Kusky, he too would like to work on the road department. Jeff Henderson would also like to work on the road department. Motion by Casper to appoint Daniel and the Kusky boy and put them on the road department. There was a discussion. Motion by Casper to appoint Daniel Casper on the road department, seconded by Kovatch for Daniel. Motion carried. No abstentions or no votes recorded. Mr. Donald S. Casper Page 11 Motion by Casper to appoint John Kusky, discussion, Kovatch said he wanted to see the application. Motion seconded by Kusky. Roll call: Casper - yes, Kovatch - abstain, Kusky - yes. Motion carried. f. April 22, 1987: Kovatch said his son works for the township when needed, during the winter from 4:00 p.m. to 9:00 p.m., during the summer hours to operate the tractor mower. Residents and laid off extra's want an answer to hiring practice. Resident, Przystup, questioned the Board for age discrimination practice, when he was by- passed over others to be appointed as regulars. The others had not even worked on the road department, as he had, part -time. c. May 12, 1987: Question on the status of the.>two regulars appointed to the-road department and where part -time employee Przystup stands. Casper stated there is no change in the hiring status at the present time. On the hiring of relatives as Township employees - Liekar received an answer from the Ethics Commission regarding hiring relatives as Township employees. Casper read the reply to the audience. Copy attached to the minutes. Liekar recommended the Supervisor's take action on the letter at the next meeting. Casper indicated a change in their voting will take place at that meeting. h. June 10, 1987: Re: Letter from Ethics Commission on the hiring of relatives as township employees. Liekar explained that the township must remove personnel from the payroll roster who were hired in violation of the Ethics Commission ruling. Casper made a motion to remove his son Daniel Casper from the payroll roster. Seconded by Kovatch. Mr. Donald S. Casper Page 12 Casper, Donald S. $644.45 Casper, Daniel $1,123.53 a. DATE 8/30/85 10/23/85 1985 Motion carried: Casper - abstained, Kovatch - yes, Kusky - yes. Kovatch made a motion to hire Daniel Casper and Ronnie Chappel as summer help to be used at the discretion of the road foreman. Motion died for lack of a second. Casper made a motion to remove Dolores Kovatch from the payroll roster as a township employee. Seconded by Kusky. Motion carried. Casper - yes, Xusky - yes, Kovatch - abstained. Casper made a motion to Kovatch as the township rate established in the organizational meeting. lack of a second. rehire Dolores custodian at the January 1987 Motion died for i. June 24, 1987: Kovatch made a motion to remove John Kusky from the Township payroll roster. Motion died for lack of a second. Kovatch made a motion to hire Daniel Casper, Ron Chappel, Frank Przystup and John Kusky as summer help because the road department is falling behind on planned projects and grass cutting. All four motions died for lack of a second. 25. Chartiers Township W -2 Wage and Tax Statements and Payroll records reflect the following: 1986 $836.56 $1,333.18 TOTAL AMOUNT $27.00 21.00 1987 * $577.64* $37.26 ** *As of 8/2/87 * *Only worked through 2/1/87. 26. In addition to the above income listed on the W -2 Wage and Tax Statements, the following invoices in the name of Daniel Casper, for washing police department cars: #CARS /RATE 9 car washes @ $3.00 7 car washes @ $3.00 Mr. Donald S. Casper Page 13 b. b. 3/14/86 3/28/86 4/10/86 5/16/86 6/27/86 7/11/86 7/25/86 8/15/86 9/25/86 10/10/86 11/14/86 12/30/86 12.00 36.00 21.00 33.00 45.00 24.00 15.00 45.00 99.00 42.00 54.00 54.00 $528.00 4 car washes 12 car washes Police car washes 11 car washes 15 car washes @ $3.00 8 car washes 5 car washes 15 car washes 33 car washes 14 car washes 18 car washes 18 car washes 1• N N p 176 car washes @3.00 Records and invoices reflecting payments made to Daniel Casper in 1985, for washing cars: (1) Police Car Washes - dated 8/8/85 and 8/21/85, and signed by Daniel Casper. Chartiers Township Supervisors Purchase Order - dated 8/21/85, to Daniel Casper, for 9 car washes at $3.00 /car =total $27.00. Check invoice: (2) Car Washes Chartiers 10/24/85, $3.00 /car 8/30/85 to Daniel Casper for $27.00. — dated 10/23/85, and signed by Dan Casper. Township Supervisors Purchase Order - to Daniel Casper, for 7 car washes at - total $21.00. Check invoice: 11/25/85 to Daniel Casper for $21.00. 27. You provided the following information regarding the township employment of your son: a. You were not aware of the conflict of interest in your minor /dependent son, Daniel, to the Township department until 1987. At that time you made the fire Daniel. hiring road motion to You did discuss considering Daniel for employment with the Township in front of the Board. You did not know that you should not have voted to hire your son. c. You have another son, Donald, Jr. who was hired in 1987, but Mr, Donald S. Caspei Page 14 never worked. You believe that Donald, Jr. did wash cars for the Township, as Daniel did, but you are not sure when. d. You do not dispute the fact that you discussed the hiring of your son Daniel, voted to hire him, and signed invoices to pay him for work done for the Township. A review of the Township invoices from 1983 to the present, show that there are no invoices for washing cars in Donald, Jr.'s name. III. Allegation: That you, a Township Supervisor for Chartiers Township, Washington County, Pennsylvania indicated the following provisions of the State Ethics Act and Regulations of the State Ethics Commission in that you failed to file a Statement of Financial Interests for the 1984 through 1987 calendar years: Section 4. Statement of financial interests required to be filed. (a) Each public employee employed by the Commonwealth shall file a statement of financial interests for the preceding calendar year with the department, agency or bureau in which he is employed no later than May 1, of each year that he holds such a position and of the year after he leaves such a position. Any other public employee shall file a statement of financial interests with the governing authority of the political subdivision by which he is employed no later than May 1 of each year that he holds such a position and of the year after he leaves such a position. 65 P.S. §404(a). §4.4. Incumbent and former public officials. (d) Former public officials shall file a Statement of Financial Interests for their Nast year of service by May 1 of the succeeding year. This statement shall be filed at the same offices they filed when they were incumbent officials. 51 Pa. Code §4.4(d). A. Findings: 28. Finding number one (1) is incorporated herein by reference. 29. Records of Chartiers Township disclosed that you filed a Statement of Financial Interest form with that office on February 19, 1983. Mr. Donald S. Casper Page 15 a. You filed a Statement of Financial Interest in April 1988. b. You stated as follows: (1) Your understanding was that once you filed, you were not required to file again. (2) You did not know you should file every year. 30. By way of letter dated July 19, 1988, and received by the State Ethics Commission on July 26, 1988, you filed the Statements of Financial Interests as follows: a. For calendar year 1984 b. For calendar year 1985 c. For calendar year 1986 d. For calendar year 1987 B. Discussion: As a supervisor- in Chartiers Township, you are a public official subject to the provisions of the Ethics Act. 65 P.S. S402; Sowers, Opinion 80 -050; Szymanowski, Order No. 539. Section 3(a) of the Ethics Act provides: 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. Code S403(a). Section 3(a) specifically provides that a public official may not use his public office or confidential information to obtain a financial gain for himself other than compensation provided for by law. The compensation which is allowed for a supervisor is strictly regulated by statutory and decisional law. Under Section 3(a) of the Ethics Act, this Commission has previously determined that a township supervisor may not receive at township's expense, health, hospitalization, medical and life insurance benefits when such supervisor acts only in the capacity of a supervisor. Krane, Opinion 84 -001; Cowie Opinion 84 -010. Mr. Donald S. Casper Page 16 Additionally, even if such a supervisor is employed by the township as a superintendent, secretary /treasurer, roadmaster or laborer 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 Svnoski v. Hazel Township, 93 Pa. Commw. 168, 500 A.2d 1282, (1985); In re: Appeal of the Auditors Report of Muncv Creek Township, Pa. Commw. Ct. , 520 A.2d 1241, (1987); Hunt, Order No. 348 -R. The foregoing principle was recently reaffirmed by Pennsylvania Commonwealth Court in Yocabet v. State Ethics Commission, Pa. Commw. Ct., 531 A.2d 536 (1987). In the cited case, the Court held inter alia that a township supervisor violated Section 3(a) of the Ethics Act when he received a salary for the position of secretary /treasurer which had not been set by the auditors. The Court, in affirming the Order of the Ethics Commission which required a restitution of the financial gain, noted on page 539 of its Opinion: Section 7 of the Ethics Act instructs the Commission to investigate situations where there is a reasonable belief that financial conflict may exist, and if conflict is found, to require the offender to remove himself from the conflict without gain. Any benefits received other than as provided for above, would constitute 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, 27 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 Audit of South Union Township, 47 Pa. Commw. 1, 407 A.2d 906, (1979). Further, the right to sue for the restitution of the financial gain obtained in violation of the Ethics Act has been upheld by Commonwealth Court in Fee v. Commonwealth of Pennsylvania and Township of Union, Pa. Commw. Ct. , 540 A.2d 1385 (1988). In the instant matter, you were not a full -time or part -time employee (supervisor) of the township but you received medical /life insurance and pension benefits at township expense. The minutes of January 7, 1985 for the township reflect that you made and voted for a motion to provide benefits to the supervisors. In a January 5, 1987 meeting of the Board of Supervisors, you made a motion and voted in favor of a motion to continue the insurance coverage for you and the other supervisors. The Supervisors voted themselves Superintendents which appears to be contrary to the Second Class Township Code, 53 P.S. S65514. In a January 4, 1988 meeting a motion was made and approved to continue insurance coverage subject to auditor approval. The auditors of Chartiers Township have stated that they never approved insurance benefits for the supervisors. Even if the auditors had approved such insurance benefits, their actions would be to no avail since you were not a working supervisor. Mr. Donald S. Casper Page 17 Although it appears that you may have been receiving insurance /pension benefits for most if not all of the time that you have been a supervisors since 1979, Act No. 1988 -41 in Section 1(b)(2) provides amnesty for any benefits received between January 1, 1959 and March 31, 1985. Thus, even though Section 3(a) of the Ethics Act would be implicated for any benefits you received during the amnesty period, no penalty may be assessed against you for the benefits you received between January 1, 1959 and March 31, 1985. However, in this case, you have received $6,482.43 in township paid insurance benefits after the end of the amnesty period. Your receipt of these benefits at township expense violated Section 3(a) of the Ethics Act; you must return this unlawful gain to your township. McCutcheon and Yocabet, supra. You are hereby directed to forward a check to the State Ethics Commission in the amount of $6,482.43 payable to Chartiers Township within thirty (30) days of the date of this order or this matter will be referred to the appropriate law enforcement authority. Turning to the second allegation concerning the hiring of your son to a position with the township, it is noted that you abstained on the vote to appoint your son to a position of summer employment in the June 12, 1985 meeting of the Board of Supervisors. However, on August 19 - , 1986 you seconded and voted for a motion to approve payment for your son for police car washes which he .performed. You voted in favor of a motion to appoint your son as an emergency extra. - Lastly, on April 8, 1987 you made a motion and voted for the appointment of your son to the road department. It is also noted that your son was a minor dependent during the above period and hence was a member of your immediate family. "Immediate family" is defined under Section 2 of the Ethics Act as follows: Section 2. Definitions. "Immediate family." A spouse residing in the person's household and minor dependent children. 65 P.S. S402. Since your son was under 18 years of age at the times of his various appointments, he was a member of your "immediate family" under the Ethics Act. As such, your actions in using your office to appoint your son to a position of employment with the township was a violation of the State Ethics Act. As a result, you must make restitution of the financial gain received therefrom which amounted to $2,493.97. As to the third allegation regarding your failure to file Statements of Financial Interests, it is noted that you subsequently filed Statements of Financial Interests for the calendar years 1984 4r. Donald S. Casper Page 18 through 1987 on July 26, 1988 with this Commission. Since you now have filed the requisite statements and since there is no evidence to indicate that your failure to file related to any attempt on your part to conceal financial information, this Commission finds a technical violation of Section 4 of the Ethics Act but will take no further action as to this violation. C. Conclusion and Order: 1. As a Chartiers Township Supervisor, you are a public official subject to the provisions of the Ethics Act. 2. You violated Section 3(a) of the Ethics Act when you received insurance benefits at township expense from April, 1985 to the termination of the benefits. 3. The amount of the financial gain you received, referenced in paragraph 2, amounts to $6,482.43. 4. You are hereby directed to forward a check to the State Ethics Commission payable to Chartiers Township in the amount of $6,482.43 within thirty (30) days of the date of this order. 5. Failure to comply with the provision of paragraph 4 above will result in the referral of this matter to the appropriate law enforcement authority. ti. There was a violation of Section 3(a) of the Ethics Act when you voted for matters regarding the employment of your son by the township. You must, within 30 days of the date of this order, forward to the State Ethics Commission a check in the amount of $2,493.97 payable to Chartiers Township. 7. The total amount of restitution required to be forwarded to the State Ethics Commission equals $8,976.40. 8. There is a violation of Section 4 of the Ethics Act regarding the failure to file the Statement of Financial Interests for the calendar years 1984 through 1987 but the Commission will take no further action since you have filed the Statements of Financial Interests and since there is no evidence to indicate that you attempted to conceal any financial information. Our files in this case will remain confidential in accordance with Section 8(a) of the Ethics Act, 65 P.S. S408(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 S2.38. During this 15- day period, no one, including the respondent unless he waives his Mr. Donald S. Casper Page 19 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. 5409(e). By the Commission, 4�b.1�2,s Joseph W. Marshall, III Chairman