HomeMy WebLinkAbout704 BennerMr. Dennis E. Benner
R.D. #7
Bethlehem, PA
Re: 86 -033 -C
Dear Mr. Benner:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
OR DER OF THE COMMISSION
ORDER W. 704
Before: Helena G. Hughes, Chair
Robert W. Brown, Vice Chair
W. Thomas Andrews
G. Sieber Pancoast
Dennis C. Harrington
James M. Howley
DATE DECIDED: June 1, 1989
DATE MAILED: June 8. 1989
The State Ethics Commission received a complaint regarding you
and a possible violation of the State Ethics Act, No. 170 of 1978, 65
P.S. 401 et. seq. You were notified in writing as to the
commencement of the investigation and as to the specific
allegation(s). The investigation has now been completed and a
Findings Report was issued to you which constituted the Complaint by
the Investigation Division of the State Ethics Commission. An Answer
was filed and a hearing was waived. The record is now completed.
This Order of the Commission is hereby issued which sets forth the
individual allegations, findings, discussion and conclusion as
follows:
I. Allegation: That you, Councilman for Lower Saucon Township,
violated the following provisions of the Ethics Act (Act 170 of
1978), when you voted in favor of a subdivision request made by an
individual with whom you engage in joint real estate ventures:
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
Dennis E. Benner
Page 2
of his immediate family, or a business with which
he is associated. 65 P.S. S403(a).
A. Fi.ndinas
1. You served as a member of Lower Saucon Township Council.
a. You served from 1983 until your resignation in 1986.
2. You provided information, through your attorney, that you entered
into four (4) types of business associations with Verling Wolfe.
a. Verling Wolfe moved a home for you for a set fee.
b. Verling Wolfe moved homes for you as a partner with another
party.
c. Verling Wolfe and you purchased 3 homes as a joint venture
and he received a set fee for moving these homes.
d. You did very limited legal work for Verling Wolfe that
involved deed preparation for homes which Verling Wolfe
bought, moved and sold on his own account. You did no legal
work on the Wolfe property that is the subject of the State
Ethics Commission investigation. Mr. Wolfe was the only
house mover in the area and was moving homes not only for
you but for many other people. Most of the homes moved in
the area were moved for Mr. Wolfe's own account. He and his
family moved homes and sold them as their livelihood. You
have never had any financial interest in Mr. Wolfe's
business.
3. On October 9, 1985, Verling H. Wolfe filed with the Lower Saucon
Township Planning Commission, an application for a subdivision
approval located at Hellertown Road and Wilhelm Road.
a. The application was a preliminary plan for a minor
subdivision.
b. On October 23, 1985, the application of Verling H. Wolfe was
forwarded to the Northampton County Conservation District
for review.
c. On October 28, 1985, the Joint Planning Commission of
Lehigh /Northampton Counties advised that the Wolfe
subdivision proposal presented no conflict with existing
plans or policies.
d. On November 11, 1985, Lower Saucon Township recommended
that the Wolfe application be denied.
Dennis E. Benner
Page 3
(1) The basis for this recommendation was that the
subdivision would create a substandard lot.
4. Minutes of the December 4, 1985 meeting of the Lower Saucon
Township Council reflect that you made a public disclosure that you
had a business relationship with Verling Wolfe. You are reported as
stating that you had no financial or other involvement with Mr. Wolfe
in the matter that was before Council.
5. Minutes of the December 18, 1985 meeting of the Lower Saucon
Township Council reflect the following:
a. The matter of the Verling Wolfe subdivision application was
discussed.
b. The Verling Wolfe subdivision application had been carried
over from the previous council meeting where the following
had occurred:
Discussion centered on resubmission of the plan by
Wolfe with 30,000 square feet per lot.
Discussion occurred as to perk and sand mound testing
of the land which was the subject of a subdivision
application.
Wolfe requested to appear at the December 18, 1985
meeting and the matter was tabled.
c. Discussion occurred on the resubmitted plans by Wolfe based
on a figure of 31,000 square feet per lot.
d. Councilman Gebhart expressed opposition to the resubmitted
plan on the basis that it would constitute spot zoning.
e. Discussion was held on the issue of your business dealings
with Verling Wolfe. A question was raised as to whether you
were qualified to vote.
f. Solicitor George Hahalis opined that Mr. Benner was
qualified to vote.
(1) Hahalis indicated that Mr. Benner had no financial
interest in the development project.
g. Motion by Councilman Chehi to approve the resubmitted plans
and grant conditional approval subject to satisfactory
D.O.D. for Wilhelm Road.
Dennis E. Benner
Page 4
(1) Motion carried
Danyluk; Nays -
on 3 -2 vote. Ayes - Chehi, Benner,
Gebhart, Oren.
provided the following information in
6. Mr. Verling H. Wolfe
relation to this situation:
a. He engaged in joint ventures with you after
Pennsylvania Department of Transportation
which were in the path of new Interstate 78.
(1) The joint ventures involved Mr. Wolfe moving houses
which you purchased.
(2) He preferred that written contracts not be prepared and
executed as to these business dealings.
b. He entered into a joint venture with you in the fall of 1985
wherein a house of Mr. Campbell was moved from the property
he previously owned to a lot on Hickory Hill Road.
(1) After the job was completed, expenses were deducted and
the profits were shared between you and Wolfe.
Another joint venture concerned the purchase by you and
Wolfe of a lot on Peachtree Lane.
c.
he met you at a
sale of houses
(1) A house was moved onto this lot.
(2) The property was listed and eventually sold.
d. The most recent joint venture involved the relocation of a
house owned by Mr. Becker which was moved to a lot on
Sidlerville Road.
e. He has moved houses from the Easton to Allentown areas and
has used you and other lawyers to prepare deeds, attend
settlements and complete the closing paperwork.
(1) He paid set fees to you as his attorney.
f. Regarding the subdivision plan approved at the December 18,
1985 council meeting, he indicated that he was the sole
owner of the house and property.
g. He denied that he exerted any influence upon you regarding
your vote on his subdivision plan.
7. You provided the following information regarding the statements
made by Verling Wolfe.
Dennis E. Benner
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a. You met Mr. Wolfe shortly before a PennDot house sale. You
had asked PennDot to place you on a bidders list to be
advised when homes in the path of I -78 were to be sold for
demolition and /or removal.
b. Mr. Wolfe and you entered into several transactions.
Allcontractual terms and conditions between Mr. Wolfe and
you were established at least six (6) months before December
18, 1985. Once a home is purchased and a move decision is
made, ground to which the home could be moved had to be
secured and overhead powerline estimates secured. Homes
could not be moved until PennDot gave a notice to proceed.
Sometimes this would take several months.
c. Mr. Wolfe is a Mennonite and upon meeting him and his family
members, you felt comfortable dealing with Mr. Wolfe on a
"hand shake" basis. Mr. Wolfe would tell you his price to
move a house and the hourly rate he would charge to get a
home operational after the move.
For several of the homes Mr. Wolfe and you moved together,
you borrowed money. The lending institution required a
written agreement between the parties so one was prepared.
That agreement permitted either of you to move houses
independently of each other and in competition with each
other.
d. Mr. Wolfe and you entered into a business relationship
concerning a home located on Hickory Hill Road. The home
was moved to a lot once owned by Mr. Campbell along Cross
Lane in the Cherrywood subdivision. The business agreements
were made in the Summer of 1985, however, the home could not
be moved until sometime in the fall of 1985 because the
notice to proceed was not received.
e. Mr. Wolfe and you shared risks and profits of that move. At
no time did any matter with regard to this home ever come
before the Lower Saucon Council.
f. A home was purchased in Colesville, Pennsylvania and moved
to a lot on Peachtree Lane. All business agreements were
made in the Summer of 1985. No matter concerning this home
ever came before the Lower Saucon Council.
g. All business agreements regarding the Becker home were made
in the Summer of 1985. No matters concerning the home owned
by Becker came before the Lower Saucon Council.
h. You represented Mr. Wolfe in the sale of two (2) homes he
had moved from the PennDot right away. In early 1986, Mr.
Dennis E. Benner
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Wolfe asked you to represent him a third time in a house
sale but you declined since the subject of the sale was the
property on which you voted in December, 1985. It was your
opinion that you could not receive anything from Mr. Wolfe
with respect to that home.
8. George Hahalis, Lower Saucon Township Solicitor, provided the
following written declaration:
During 1985 and up to the present, I have been solicitor for the
Lower Saucon Township Council and in that capacity I attended
both the meetings of December 4 and December 18, 1985.
At those meetings, the issue of whether Mr. Benner had any
business dealings with Mr. Verling H. Wolfe was publicly raised
and Mr. Benner made a public statement that he had paid Mr. Wolfe
to move several houses for him. I specifically asked Mr. Benner
whether he had any pecuniary interest at all in the application
which Mr. Wolfe had before the Council or in the property
concerned in that application. Mr. Benner publicly responded
that he had no such financial interest in that property nor in
Mr. Wolfe's overall business. On the basis of that information,
I advised him that he could vote on the application at the
December 18, 1985 meeting, and following that advice, he did
vote.
During this period, the Township Council had adopted an
unofficial policy to permit the use of substandard lots where a
hardship was created by I -78. There were a number of instances
where the Council permitted the use of properties which did not
otherwise meet minimum lot standards in order to permit the use
of lots or houses which were affected by the I -78 construction.
Mr. Wolfe's application was one such instance and it was decided
in accord with the Council's informal policy.
9. Mr. Raymond LaBuda provided the following information in relation
to the instant situation:
a. He is an owner of a lot in the Saucon Hills Development.
b.
Verling Wolfe moved a house you owned to a lot in Saucon
Hills in December, 1985.
(1) The house was old and in disrepair but
area where homes were selling in
$120,000.00.
(2) Wolfe moved approximately five homes
manner.
was moved to an
the range of
for you in this
Dennis E. Benner
Page 7
(3) You were the only individual who was moving properties
that were in the way of Interstate 78.
10. Mr. Thomas E. Rowe gave the following information:
a. He is a businessman who purchased three or four homes in
Lower Saucon Township.
(1) The houses had to be moved because they were condemned
and in the path of new Interstate 78.
(2) The houses were small in size and worth approximately
$2,000.00.
b. He was denied approval to move the houses by the township.
c. He observed that you, as councilman, were able to obtain
township approval to move your houses.
11. You provided the following information regarding statements made
by Raymond LaBuda and Thomas Rowe:
a. The home referred to by LaBuda was not old and in
disrepair. Homes in this area were selling in the range of
$120,000.00. This house sold for $120,000.00.
b. Wolfe only moved (3) houses for you, not five.
c. There were many people moving homes during the I -78
construction. Every house move was separate and independent
of the other. You had no interest in homes or land which
Mr. Wolfe moved for himself or others including the homes
which is the subject of Mr. Wolfe's subdivision application.
d. You have no detailed knowledge about Mr. Rowe's transactions
except you have heard that he hired Mr. Wolfe to move
several homes he purchased in the I -78 corridor.
e. Mr. Rowe did move several houses presently located along
Sherry Hill Road in Lower Saucon Township.
f. You received the same township approval to move homes as
every other person did, and no preferential treatment.
12. You supplied the following information:
a. You recall voting on the Wolfe subdivision plan.
(1) A question arose at the meeting as to whether you could
vote.
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(2) Solicitor Hahalis opined that you could vote after you
indicated that you had no interest in the subdivision
project.
(3) You indicated that you voted in favor of the Wolfe
subdivision plan because the house was already on.the
lot and not to do such would result in hardship.
b. You have engaged in three or four joint ventures with Wolfe.
(1) The joint ventures involved moving houses.
(2) You consider Wolfe as the only reliable house mover in
the area.
c. You performed legal work for Wolfe but charged him the same
fees as you would charge other clients.
d. Solicitor George Hahalis has done some legal work for you.
(1) You indicate that this occurred after you resigned from
council.
B. Discussion
As a councilman for Lower Saucon Township, you were a "public
official," as that term is defined under the Ethics Act. 65 P.S.
Section 402; 51 Pa. Code Section 1.1. As such, your conduct is
subject to the provisions of the Ethics Act and the restrictions
therein are applicable to you.
Section 3(a) of the Ethics Act quoted above provides in part that
a public official may not use public office to obtain a financial gain
for himself other than compensation provided for by law.
In the instant matter, the issue is whether you violated Section
3(a) of the Ethics Act when you voted in favor of a subdivision
request of Verling H. Wolfe, an individual with whom you engaged in
several real estate ventures as to the movement of houses and for wham
you provided limited legal services. The houses in question were in
the path of the new interstate 78. You purchased these houses and
then arranged with Mr. Wolfe, through a joint venture, to move the
houses to a new location. Specific instances of your business
arrangements involved the movement of a house of a Mr. Campbell to a
lot on Hickory Hill Road; the purchase of a lot on Peach Tree Lane and
the movement of a house onto that lot, the relocation of a home owned
by Mr. Becker to a lot on Sidlerville Road and the movement of other
houses from the Easton to Allentown areas wherein your legal services
have been utilized by Mr. Wolfe. Your contractual relations were
Dennis E. Benner
Page 9
established approximately six months prior to the time when Mr. Wolfe
filed an application with the Lower Saucon Township Planning
Commission for a subdivision approval located at Hellertown and
Wilhelm Road. The Planning Commission referred the Wolfe subdivision
proposal to the Northampton County Conservation District for review
which found no conflict with existing plans or policies. However, the
Lower Saucon Township recommended the denial of the application on the
basis that it would create a subdivision with a substandard lot.
Thereafter, at a December 18, 1985 meeting of the Lower Saucon
Township Council, the Wolfe subdivision application, as resubmitted,
was discussed. At that meeting, Councilman Gebhart expressed
opposition to the resubmitted plan on the basis that it would
constitute spot zoning. In addition, the question arose as to whether
there would be a conflict of interest on your part in light of the
fact that you had a financial relationship with Mr. Wolfe. Solicitor
George Hahalis gave his opinion that you were qualified to vote
because you had no financial interest in the subdivision plan of Mr.
Wolfe. Thereafter, the Wolfe plan was put to a vote which carried by
a three -two margin with you in the majority. Mr. Wolfe has indicated
that he did not exert any influence upon you regarding the vote;
however, Mr. Thomas Rowe, a business man who purchased three or four
homes in Lower Saucon Township, indicated that he was denied approval
to move his homes by the township although you as councilman were able
to obtain township approval to move your houses. After asserting that
you received no preferential treatment in receiving township approval
to move homes, you indicate that the reason that you voted in favor of
the Wolfe's subdivision plan was because the house was already on the
lot and that it would result in hardship if he did not receive the
approval. You state that you engaged in the joint ventures with Mr.
Wolfe because he was the only reliable house mover in the area and
lastly that you performed legal work for Mr. Wolfe but charged him the
same fees as you would any other client.
Although you did have several joint ventures with Mr. Wolfe at
the time that he submitted his subdivision plan, the evidence does not
establish that you had an interest in the subdivision plan or that you
were influenced to vote in favor of the Wolfe application because of
your joint ventures with him. Therefore, the evidence is insufficient
to establish that you violated Section 3(a) of the Ethics Act when you
voted to approve the Wolfe application for a subdivision in Lower
Saucon Township.
C. Conclusion,:
1. As a member of the Lower Saucon Township Council, you were a
public official subject to the provisions of the Ethics Act.
2. The evidence does not establish that you violated Section 3(a) of
the Ethics Act when you voted in favor of the subdivision request by a
Dennis E. Benner
Page 10
Verling Wolfe, an individual with whom you engaged in joint real
estate ventures.
This Order is final and will be made available as a public
document fifteen days after issuance. However, you may request
reconsideration which will defer public release of this Order pending
action on your request by the Commission. A request for
reconsideration, however, does not affect the finality of this Order.
A reconsideration request must be received at this Commission within
fifteen days of issuance and must include a detailed explanation of
your reasons as to why reconsideration should be granted in conformity
with 51 Pa. Code S2.38.
The files in this case will remain confidential in accordance
with Section 8(a) of the Ethics Act, 65 P.S. 408(a) during the fifteen
day period and no one, including yourself, unless the right to
challenge this Order is waived, may violate confidentiality by
releasing, discussing or circulating this Order. However,
confidentiality does not preclude you from discussing this case with
your attorney at law.
Any person who violates 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, 65 P.S.
409(e).
By t = Commiss •n,
lena G. Hug es
Chair