HomeMy WebLinkAbout01-507 FilbeyGary R. Filbey
1274 Jefferson Road
P.O. Box 12
Jefferson, PA 15344
ADVICE OF COUNSEL
January 17, 2001
01 -507
Re: Conflict; Public Official /Employee; Board Member; Water Authority; Immediate
Family; Wife; Hiring; Vote.
Dear Mr. Filbey:
This responds to your letter of December 14, 2000, by which you requested
advice from the State Ethics Commission.
Issue: Whether the Public Official and Employee Ethics Act ( "Ethics Act "), 65
Pa. .S. §1101 et seq., presents any prohibition or restrictions upon a member of the
board of directors of a water authority with regard to the hiring of his wife by the
authority.
Facts: As a Member of the Board of Directors ( "Board ") of the Southwestern
Pennsylvania Water Authority ( "Water Authority "), you seek an advisory from the State
Ethics Commission. You have submitted the following facts.
For the past sixteen years, you have been an employee of the Water Authority.
In May 2000, you also became a member of the Water Authority Board. Due to
expansion, the Board has been discussing hiring an additional secretary. You state that
your wife has had an application on file with the Water Authority for more than seven
years. You ask whether the Ethics Act would impose restrictions with regard to the
hiring of your wife by the Water Authority.
Discussion: It is initially noted that pursuant to Sections 1107(10) and (11) of
the Ethics Act, 65 Pa.C.S. §1107(10), (11), advisories are issued to the requestor based
upon the facts which the requestor has submitted. In issuing the advisory based upon
the facts which the requestor has submitted, the Commission does not engage in an
independent investigation of the facts, nor does it speculate as to facts which have not
been submitted. It is the burden of the requestor to truthfully disclose all of the material
facts relevant to the inquiry. 65 Pa.C.S. §1107(10), (11). An advisory only affords a
defense to the extent the requestor has truthfully disclosed all of the material facts.
It is further initially noted that, pursuant to the same aforesaid Sections of the
Ethics Act, an opinion /advice may be given only as to prospective (future) conduct. If
the activity in question has already occurred, the Commission may not issue an
opinion /advice but any person may then submit a signed and sworn complaint which will
be investigated by the Commission if there are allegations of Ethics Act violations by a
person who is subject to the Ethics Act. To the extent you have inquired as to conduct
which has already occurred, such past conduct may not be addressed in the context of
Filbey, 01 -507
January 17, 2001
Page 2
an advisory opinion. However, to the extent you have inquired as to future conduct,
your inquiry may, and shall be addressed.
As a Member of the Water Authority Board, you are a public official subject to the
provisions of the Ethics Act.
Section 1103(a) of the Ethics Act provides:
$1103. Restricted activities.
(a) Conflict of interest. - -No public official or public
employee shall engage in conduct that constitutes a conflict
of interest.
65 Pa.C.S. §1103(a).
The following terms that pertain to Section 1103(a) are defined in the Ethics Act
as follows:
$1102. Definitions.
"Conflict" or "conflict of interest." Use by a public
official or public employee of the authority of his office or
employment or any confidential information received through
his holding public office or employment for the private
pecuniary benefit of himself, a member of his immediate
family or a business with which he or a member of his
immediate family is associated. The term does not include
an action having a de minimis economic impact or which
affects to the same degree a class consisting of the general
public or a subclass consisting of an industry, occupation or
other group which includes the public official or public
employee, a member of his immediate family or a business
with which he or a member of his immediate family is
associated.
"Authority of office or employment." The actual
power provided by law, the exercise of which is necessary to
the performance of duties and responsibilities unique to a
particular public office or position of public employment.
"Immediate family." A parent, spouse, child, brother
or sister.
65 Pa.C.S. §1102.
In applying the above provisions of the Ethics Act to the circumstances which you
have submitted, pursuant to Section 1103(a) of the Ethics Act, a public official /public
employee is prohibited from using the authority of public office /employment or
confidential information received by holding such a public position for the private
pecuniary benefit of the public official /public employee himself, any member of his
immediate family, or a business with which he or a member of his immediate family is
associated. Your wife is a member of your immediate family.
Although the Ethics Act would not preclude the hiring of your wife by the Water
Authority, pursuant to Section 1103(a) of the Ethics Act, you would have a conflict of
interest and would be prohibited from using the authority of your office as a Water
Filbey, 01 -507
January 17, 2001
Page 3
Authority Board Member or confidential information that you would have access to by
being in that position to advance the hiring of your wife by the Water Authority.
A conflict would exist even as to action to eliminate competitor(s), where such
action would assure or increase the possibility that your wife would be hired by the
Water Authority. See, Pepper, Opinion 87 -008.
In each instance of a conflict of interest, you would be required to abstain fully
and to satisfy the disclosure requirements of Section 1103(j) of the Ethics Act as set
forth above. The abstention requirement would not be limited to voting, but would
extend to any use of authority of office. The use of authority of office as defined in the
Ethics Act includes, for example, discussing, conferring with others, and lobbying for a
particular result. See, Juliante, Order 809.
Lastly, the propriety of the proposed conduct has only been addressed under the
Ethics Act; the applicability of any other statute, code, ordinance, regulation or other
code of conduct other than the Ethics Act has not been considered in that they do not
involve an interpretation of the Ethics Act. Specifically not addressed herein is the
applicability of the Municipality Authorities Act of 1945.
Conclusion: As a Member of the Board of Directors ( "Board ") of the
Southwestern Pennsylvania Water Authority ( "Water Authority"), you are a public official
subject to the p rovisions of the Public Official and Employee Ethics Act ( "Ethics Act "), 65
Pa.C.S. §1101 seq.
Although the Ethics Act would not preclude the hiring of your wife by the Water
Authority, pursuant to Section 1103(a) of the Ethics Act, you would have a conflict of
interest and would be prohibited from using the authority of your office as a Water
Authority Board Member or confidential information that you would have access to by
being in that position to advance the hiring of your wife by the Water Authority. A
conflict would exist even as to action to eliminate competitor(s), where such action
would assure or increase the possibility that your wife would be hired by the Water
Authority. In each instance of such a conflict of interest, you would be required to
abstain fully and to satisfy the disclosure requirements of Section 1103(j) set forth
above.
Lastly, the propriety of the proposed conduct has only been addressed under the
Ethics Act.
Pursuant to Section 1107(11), an Advice is a complete defense in any
enforcement proceeding initiated by the Commission, and evidence of good faith
conduct in any other civil or criminal proceeding, provided the requestor has disclosed
truthfully all the material facts and committed the acts complained of in reliance on the
Advice given.
This letter is a public record and will be made available as such.
Finally, if you disagree with this Advice or if you have any
reason to challenge same, you may appeal the Advice to the full
Commission. A personal appearance before the Commission will be
scheduled and a formal Opinion will be issued by the Commission.
Any such appeal must be in writing and must be actually
received at the Commission within thirty (30) days of the date of this
Advice pursuant to 51 Pa. Code §13.2(h). The appeal may be received
at the Commission by hand delivery, United States mail, delivery
Filbey, 01 -507
January 17, 2001
Page 4
service, or by FAX transmission (717 -787- 0806). Failure to file such an
appeal at the Commission within thirty (30) days may result in the
dismissal of the appeal.
Sincerely,
Vincent J. Dopko
Chief Counsel