HomeMy WebLinkAbout719 ParishMr. Stephen Parish
c/o Robert L. Ceisler, Esq.
200 Washington Trust Building
Washington, PA 15301
Re: - 88 -042 -C
Dear Mr. Parish:
SLATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
ORDER OF THE COMMISSION
Order No. 719
Before: Helena G. Hughes, Chair
G. Sieber Pancoast
Dennis C. Harrington
Michael J. Washo
Date Decided: July 27, 1989
Date Mailed: July 28, 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. Alleaation: That you, a Supervisor in Union Township, violated
the following provisions of the Ethics Act (Act 170 of 1978), when
you were compensated for duties other than those of roadmaster,
secretary, treasurer or laborer including administrative duties:
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. S403(a).
Mr. Stephen Parish
Page 2
A. Findinas:
1. You served as a Supervisor of Union Township, Washington County,
since 1976.
a. From 1976 to 1987 you served as a part -time road supervisor
and assistant secretary - treasurer.
2. Minutes of the Union Township Supervisors' reorganization
meetings disclosed the following:
a. January 5, 1981: A motion was made by Nurnberger, seconded
by Speer that Stephen J. Parish, Jr. be re- appointed
Assistant Secretary for 1981, recommended salary increase of
12 %. Roll call vote: Nurnberger -Aye; Gabig -Aye; Parish -
abstained; Spahr -Aye and Speer -Aye. Motion carries.
b. January 4, 1982: A motion was made by Speer, seconded by
Nurnberger that Stephen J. Parish, Jr. be re- appointed
Assistant Secretary for 1982. Bond to be set at $25,000.
Roll call vote: Nurnberger -Aye; Gabig -Aye; Parish -
abstained; Spahr -Aye and Speer -Aye. Motion carries.
A motion was made by Speer, seconded by Spahr and carried
unanimously that 5 supervisors be roadmasters for 1982.
A motion was made by Nurnberger, seconded by Gabig and
carried unanimously suggesting that roadmasters' wages be
set at $6.80 per hour for 1982, same as 1980 and 1981.
c. January 3, 1983: A motion was made by Gabig, seconded by
Spahr and carried unanimously to reappoint Stephen J.
Parish, Jr. as Assistant Secretary for 1983. Bond to remain
at $25,000.00.
A motion was made by Speer, seconded by Spahr and carried
unanimously that all five supervisors be appointed
roadmasters for 1983.
A motion was made by Speer, seconded by Parish that
suggested pay to be $6.80 per hour for roadmasters. Roll
call vote: Nurnberger -Aye; Gabig -No; Parish Aye; Spahr -Aye;
and Speer -Aye. Motion carries.
d. January 3, 1984: A motion was made by Speer, seconded by
Spahr and carried unanimously that Stephen J. Parish, Jr. be
re- appointed Assistant Secretary of the Board of 1984. Bond
to be set at $25,000.00. Salary to be established between
Mr. Stephen Parish
Page 3
Secretary - treasurer and Assistant Secretary. Secretary -
Treasurer to pay Assistant Secretary from his compensation.
A motion was made by Speer, seconded by Nurnberger and
carried unanimously that all five supervisors be appointed
roadmasters for 1984.
A motion was made by Speer, seconded by Spahr and carried
unanimously that suggested pay for roadmaster be $7.15 per
hour for 1984.
e. January 7, 1985: A motion was made by Spahr, seconded by
Nurnberger that Stephen J. Parish, Jr. to reappointed
Assistant Secretary of the Board for 1985. Bond to be set
at $25,000.00. Salary to be established between Secretary -
treasurer and Assistant Secretary. Secretary- treasurer to
pay assistant secretary from his compensation. Roll call
vote: Nurnberger -Aye; Gabig -Aye; Parish -Aye; Spahr -Aye,
Wilson -No. Motion carries.
A motion was made by Spahr, seconded by Nurnberger and
carried unanimously that all five supervisors be appointed
roadmaster /employees for 1985.
A motion was made by Spahr, seconded by Parish and carried
unanimously that suggested pay for roadmaster employees for
1985 be the same as operators - $9.11 per hour.
f. January 6, 1986: A motion was made by Spahr, seconded by
Nurnberger that Stephen J. Parish, Jr. be reappointed
Assistant Secretary of the board for 1986. Bond to be set
at $25,000.00. Salary to be established between secretary -
treasurer and assistant secretary. Secretary- treasurer to
pay assistant secretary from his compensation. Roll call
vote: Nurnberger -Aye; Gabig -Aye; Parish - abstained; Spahr -
Aye; and Uremovich -Aye. Motion carries.
A motion was made by Spahr, seconded by Uremovich and
carried unanimously that suggested pay for roadmaster
employees for 1986 be $9.46 per hour (same as operator on
township road crew).
Minutes reflect that no roadmaster appointments were made.
g. January 5, 1987: A motion was made by Spahr and seconded by
Nurnberger to appoint Stephen J. Parish, Jr. as Assistant
Secretary. He is to assume responsibility in the event the
secretary- treasurer is incapacitated and is unable to
perform the responsibilities and duties of secretary-
Mr. Stephen Parish
Page 4
treasurer including the keeping of the minutes. Roll call
vote. Nurnberger -Aye; Gabig -Aye; Parish - abstained, Spahr -
Aye and Uremovich -Aye. Motion carries.
A motion was made by Gabig, and seconded by Spahr that
Stephen J. Parish, Jr. be appointed as roadmaster employee
for 1987. Roll call vote. Nurnberger -Aye; Gabig -Aye;
Parish - declined to vote, Spahr -Aye; and Uremovich -aye.
Motion carries.
A motion was made by Spahr, seconded by Uremovich and
carried unanimously that the suggested pay rate for
roadmaster employees for 1987 be set at $9.81 per hour.
(Same as operator on township road crew).
h. January 4, 1988: A motion was made by Spahr, seconded by
Rostosky and carried unanimously to appoint Stephen J.
Parish, Jr. as assistant secretary. He is to assume
responsibility in the event the secretary is incapacitated
and is unable to perform his duties. Parish's bond set at
$25.000.00.
A motion was made by Smida and seconded by Uremovich that
Stephen J. Parish, Jr. be appointed roadmaster- operator-
employee for 1988. Roll call vote. Spahr, Uremovich, Smida
and Rostosky voted aye. Parish abstained. Motion carries.
A motion was made by Rostosky, seconded by Spahr and
carried unanimously that the suggested pay rate for
roadmasters- operator - employees for 1988 be set at $10.21,
the same as an operator on the township road crew and also
including time and one half for overtime and fringe benefits
as spelled out in the workers' contract.
3. Minutes of the Union Township Board of Auditors' meetings reflect
the following regarding compensation for supervisors.
a. January, 1981 - Minutes not available.
b. January 5, 1982 - compensation for supervisors was set at
$6.80 per hour.
c. January 4, 1983
roadmasters was
d. January 4, 1986
set at $9.41 per
- compensation for supervisors acting as
fixed at $6.80 per hour.
- compensation for roadmaster supervisors
hour.
Mr. Stephen Parish
Page 5
e. January 6, 1987 - compensation was set for roadmaster
supervisors who operate equipment at $9.81 per hour and
$9.09 for those who do not.
g. January 5, 1988 compensation for supervisor roadmasters
set at $10.21 per hour with time and one half for work
exceeding 8 hours per day or 40 hours per week.
(1)
George Uremovich and Steve Parrish requested
hospitalization insurance for roadmasters /employees
working full time or a minimum of 15 hours per week.
(ii) The auditors also authorized certain paid holidays for
supervisor /employees.
4. Pursuant to a standard procedure, the Union Township Auditors
would make a notation as the last item on the annual reorganizational
meeting minutes indicating the compensation that had been fixed for
the township supervisors.
a. These notations indicate as follows:
(i) January 5,
$6.80 per hour.
(ii) January 4,
$6.80 per hour.
(iv) January 3, 1984
$7.15 per hour.
1981 - wages for
1982 - wages for
supervisor - roadmasters,
supervisor- roadmasters,
(iii) January 3, 1983 - wages for supervisor -
roadmasters, $6.80 per hour.
- wages for supervisor- roadmasters,
(v) January 7, 1985
$9.11 per hour.
(vi) January 7, 1986 - wages for supervisor- roadmasters,
$9.46 per hour.
- wages for supervisor- roadmasters,
(vii) January 5, 1987 - wages for supervisor -
roadmasters fixed at $9.09 for non - operators and
$9.81 for operators.
(viii) January 4, 1988 - wages for roadmaster- operator-
employee fix at $10.21 /hour.
5. Township records further disclosed that following the audit of the
financial records for 1987, the auditors informed the board of
Mr. Stephen Parish
Page 6
supervisors of four items requiring adjustment, correction and /or
attention.
a. Item 4. Supervisors acting as roadmasters performing
extensive managerial duties not directly related to road
maintenance should not be considered for road maintenance.
6. Minutes of the Board of Supervisors' meeting of April 6, 1988
disclosed the following regarding the 1987 audit report and the
auditors' letter (No. 5):
a. A motion was made by Parish, seconded by Rostosky and
carried unanimously to accept the audit for 1987 as
presented by the township auditors.
b. A motion was made by Rostosky, seconded by Parish and
carried unanimously instructing the secretary to write to
Mr. Donald Bucich, Township auditor, asking them to be more
specific about item No. 4 in their comments._ Also, the
supervisors would like to have a discussion for
clarification at this time.
7. Minutes of the Union Township Supervisors' meetings for February
3, 1988, disclosed the following regarding supervisor- roadmaster
attendance at a PennDot seminar.
a. A motion was made by Spahr and seconded by Smida
authorizing George Uremovich to attend the PennDot
Teleconference Workshop on February 23, 1988 at Mon Valley
Hospital. Roll call vote. Parish, Spahr, Smida and
Rostosky voted aye. Uremovich abstained. Motion carries.
b. A motion was made by Smida and seconded by Spahr
authorizing Stephen Parish to attend the PennDot
Teleconference Workshop on February 23, 1988 at Mon Valley
Hospital. Roll call vote. Spahr, Uremovich, Smida and
Rostosky voted aye. Parish abstained. Motion carries.
8. Union Township participates in the federal program of dispensing
surplus cheese and butter to qualified citizens of the township.
a. The board of supervisors is responsible for the
distribution of the surplus food items.
9. David Mathies, Union Township Secretary - treasurer, provided the
following information:
a. The township has participated in the surplus food program
for at least the past twenty years.
Mr. Stephen Parish
Page 7
b. The township supervisors are in charge of the program.
Currently, Supervisors Parrish and Uremovich as
roadmasters, are in charge of the program.
c. When surplus food becomes available, the township will
receive notification from Washington County. The township
road crew will then pick up the items.
d. The township road crew is directed by a road foreman, who is
not a supervisor. Supervisor- roadmasters are directed by
the road foreman.
e. The food distribution occurs at two sites within the
township and usually takes the better part of the day to
distribute.
f. The comments raised at the April 6, 1988 supervisors'
meeting regarding payment to supervisors for non -road
maintenance work were made regarding the supervisors
sitting in the office doing managerial non -road related
work. No examples were cited, and the matter was not
pursued.
10. Union Township road crew work logs disclose the following
regarding hours spent on surplus food distribution and attendance at
PennDot seminar:
Date Hours Worked Rate of Pav Work Performed
a. 12 -15 -87 8 $9.81 /hr. Pick -up cheese,
butter and rice in
Washington.
Work on guard
rails, Pleasant
view.
b. 2 -23 -88 8 $10.21 /hr. PennDot Highway
maintenance and
liquid fuels.
c. 3 -24 -88 8 $10.21 /hr. Cheese, butter and
commodities
distribution.
Mr. Stephen Parish
Page 8
Brushing Coal -
Bluff Road.
d. 9 -22 -88 8 $10.21 /hr Food pick -up and
distribution.
Work on slide on
Gilmore Road
install stop signs.
11. You provided the following information to a State Ethics
Commission investigator:
a. You have been a Union Township road supervisor since 1976,
and a roadmaster- operator employee full -time since 1977.
b. The township participates in the surplus cheese and butter
program. The township supervisors are coordinators for the
program.
c. The township distributes the food from two sites. The
centers are open from 10 a.m. to 3 p.m. on a normal day.
d. Normally, there are five employees and two roadmasters
(supervisors) who go to the food bank in Washington,
Pennsylvania to pick up the surplus food items. It varies,
but sometimes they use one truck and occasionally two
trucks. The roadmasters (supervisors) sign for the food
items, usually Supervisor Uremovich and you.
e. The process of picking up and delivering the surplus food
usually takes the road crew about two hours.
f. Normally, the supervisors have someone at the distribution
site to distribute the food, keep the records and complete
the tally sheets.
On December 15, 1987, the township road foreman directed the
entire road crew to go to Washington to pick up the surplus
cheese and butter. The items were split up for the two
distribution centers. This assignment did not take the
entire work day to complete.
h. In regards to March 24, 1988 distribution, the volunteer,
Mrs. Gabig, who kept the records suffered a heart attack.
You then took her place and distributed food and completed
records for the rest of the day.
i. On September 22, 1988, the entire road crew went to the
food bank, picked up the food and delivered it to the
Mr. Stephen Parish
Page 9
distribution centers. The food crew then went to clear a
rock slide on Gilmore Road. The trip to the food bank
probably took about two hours.
j. The Second Class Township Code authorizes townships to
appropriate funds for the storage handling and distribution
of surplus foods.
k. Every township distributes the surplus food in a similar
fashion, and supervisors and /or councilmembers participate
in the distribution.
1. You are employed full -time as a road worker, and you work as
directed by the road foreman who is not a supervisor.
m. You believe that supervisors should not be discriminated
against when they are working under the direction of a road
foreman.
n. The wages paid to you on February 23, 1988 . to attend a
seminar were approved by the board of supervisors. You
were directed to attend this PennDot seminar on highway
maintenance and liquid fuels by the board. While at the
seminar, the officials were told that they would be
compensated for attending.
o. The entire complaint is nothing but a political vendetta.
There is no evidence of fraud at the township.
12. Township records confirm that on June 4, 1989, you voluntarily
repaid $60.46 to the township by personal check No. 1851.
a. This amount represents the six hours pay you received from
cheese and butter distribution on December 15, 1987, March
24, 1988 and September 22, 1988.
B. Discussion: Township Supervisors in townships of the second
class are public officials as that term is defined in the State
Ethics Act. 65 P.S. 5402. As such, their conduct must conform to the
requirements of the State Ethics Act. See, Sowers, 80 -050,
Szvmanowski, Order No. 539.
Initially, it is noted that Section 5 of Act 9 of June 26, 1989
provides, in part, as follows:
"This amendatory act shall not apply to
violations committed prior to the effective date
Mr. Stephen Parish
Page 10
of this act, and cause of action initiated for
such violations shall be governed by the prior
law, which is continued in effect for that purpose
as if this act were not in force. For the
purposes of this section, a violation was
committed prior to the effective date of this act
if any elements of the violation occurred prior
thereto."
Since the occurrences in this case transpired prior to the
effective date of Act 9 (June 26, 1989), we must apply the provisions
of Act 170 of October 4, 1978, P.L. 883 to determine whether the
Ethics Act 'was violated.
Under Section 3(a) of the Ethics Act quoted above, this
Commission has already determined that township supervisors 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 Eth,.cs
Commission, 77 Pa. Commw. 529, 466 A.2d 283, (1982); Yocabet v.
State Ethics Commission, 109 Pa. Commw. Ct. 432, 531 A. 536 (1987).
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 4,999
5,000 to 9,999
10,000 to 14,999
15,000 to 24,000
25,000 to 34,000
35,000 or more
Annual Maximum Compensation
Fifteen hundred dollars
Two thousand dollars
Twenty -six hundred dollars
Thirty -three hundred dollars
Thirty -five hundred dollars
Four - thousand dollars
Such salaries shall be payable monthly or quarterly for
the duties imposed by the provisions of this act. The
population shall be determined by the latest available
Mr. Stephen Parish
Page 11
official census figures. The compensation of supervisors,
when acting as superintendents, roadmasters or laborers,
shall be fixed by the township auditors either per hour, per
day, per week, semi - monthly or monthly, which compensation
shall not exceed compensation paid in the locality for
similar services, and such other reasonable compensation for
the use of a passenger car, or a two axle four - wheeled motor
truck having a chases weight of less than two thousand
pounds when required and actually used for the
transportation of road and grudge 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. S65515.
In reference to the meetings for which supervisors may receive
compensation, the Code further provides 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 the supervisors
may be paid may be increased to any number, not
exceeding fifty meetings in any year which shall
include hearings by aggrieved parties under the
Pennsylvania Sewage Facilities Act and other
hearings by aggrieved parties hearings of a
judicial or quasi - judicial nature. Two members of
any board of supervisors consisting of three
members shall constitute a quorum and three
members shall constitute a quorum. Except as
otherwise provided in this act, an affirmative
vote of a majority of the entire board of any
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. S65512.
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,
Mr. Stephen Parish
Page 12
for supervisor meetings regarding the transaction of township
business. The type of meeting for which a township supervisor may be
compensated must be one at which official township business is
transacted. Additionally, the Code provides for compensation at the
specific meetings outlined in S512, above. The Code does not appear
to permit the compensation of a township supervisor for attending
other types of meetings for performing the administrative functions of
his office. Any such 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. 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 the supervisors may not be compensated for meetings with
engineers, solicitors, planning commissions, authorities, or
recreation boards. See Township News, May, 1985, Page 66.
The 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. S65410. The compensation to be paid
to supervisors working in such positions is to be fixed by the
township board of auditors. 53 P.S. S65515, 65531; 65540. 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. Commw. 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 therefore.
See also Conrad v. Exeter Township, 27 D & C 3d 253, (Berke 1983). It
is clear, therefore, that the duties for which a township supervisor
may be compensated are strictly regulated by the Code, and when
performing in the positions set forth in the Code, the supervisor's
pay must be specifically set forth by the township board of auditors.
The "administrative services" for which you were compensated were
related to the office supervisor.
In this case, you received $60.46 in "administrative services
pay" for cheese and butter distribution which was other than
compensation provided by law.
Mr. Stephen Parish
Page 13
It is clear that the auditors did not approve this compensation;
even if they had, 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, Opinion 85 -005.
As a result, this Commission finds that you violated Section
3(a) of the Ethics Act when you received compensation in the form of
administrative pay that was not in accordance with that set forth by
law. However, since you have already made a voluntary repayment of
$60.46 to Union Township, this Commission will take no further action.
C. Conclusion and Order:
1. As a township supervisor in Union Township, you are a public
official subject to the provisions of the State Ethics Act.
2. You violated Section 3(a) of the State Ethics Act by using public
office to obtain a financial gain which was not compensation provided
by law when you were paid for distributing cheese and butter.
3. The amount of gain received by you referenced in paragraph 2
amounts to $60.46. This amount has already been paid by you to the
township and, as such, we do not believe that any further action
should ensue.
4. Since you have already made restitution of the $60.46 to Union
Township, this Commission will take no further action.
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.
Hr. Stephen Parish
Page 14
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).
Commis on,
e ena G. Hughes
Chair