HomeMy WebLinkAbout01-511 GriffinJeffrey L. Griffin
241 South Baltimore Street
Dillsburg, PA 17019 -1010
ADVICE OF COUNSEL
January 30, 2001
01 -511
Re: Simultaneous Service; Bankruptcy Specialist, Commonwealth of Pennsylvania
Department of Revenue; Borough Tax Collector.
Dear Mr. Griffin:
This responds to your letter of December 27, 2000, by which you requested advice
from the State Ethics Commission.
Issue: Whether the Public Official and Employee Ethics Act imposes any
prohibition or restrictions upon a Bankruptcy Specialist for the Department of Revenue with
regard to simultaneously serving as an elected borough tax collector.
Facts: As a Bankruptcy Specialist for the Commonwealth of Pennsylvania
Department of Revenue, you seek an advisory from the State Ethics Commission. Your
request pertains to your proposed simultaneous service as a Bankruptcy Specialist for the
Department of Revenue and a Tax Collector for the Borough of Dillsburg ( "Borough "). You
ask whether such simultaneous service would be prohibited by the Public Official and
Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. §1101 et seq.
You have submitted a copy of your job description, which is incorporated herein by
reference.
You have also submitted copies of: (1) the Tax Collectors Manual, published by the
Governor's Center for Local Government Services; (2) the Standards of Conduct for
Employes of the Department of Revenue, which include, inter alia, restrictions as to
conflicts of interest, political activity, running for public office, and outside employment; (3)
various letters from the Borough Solicitor, Borough Tax Collector, and a Local Government
Policy Specialist for the Governor's Center for Local Government Services; and (4) various
letters from the Director of Personnel for the Department of Revenue and related
documents pertaining to the denial by the Department of your supplementary employment
request, based upon the stated conclusion that your proposed simultaneous service would
create a conflict of interest. Included among the latter is your response to the Department,
Griffin, 01 -511
January 30, 2001
Page 2 of 4
in which you did not check any of the formatted responses on the form, but instead wrote
your own: "Asking the State Ethics Commission for an Advisory Opinion."
Discussion: It is initially noted that pursuant to Sections 1107(10) and 1107(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 advisories issued by the State Ethics Commission are
based upon an application of the Ethics Act. However, a public official /public employee
who is subject to the Ethics Act may also be subject to other requirements. 65 Pa.C.S.
§1111. A Commonwealth agency is free to impose upon its employees supplemental
requirements which do not conflict with, and are not Tess restrictive than, the requirements
of the Ethics Act. 65 Pa.C.S. § §1111, 1112.
As a Bankruptcy Specialist for the Department of Revenue, you are a "public
employee" as that term is defined in the Ethics Act and hence you are subject to the
provisions of the Ethics Act. 65 Pa.C.S. §1102; 51 Pa. Code §11.1.
Sections 1103(a) and 1103(j) of the Ethics Act provide:
§1103. Restricted Activities
(a) Conflict of interest. —No public official or public
employee shall engage in conduct that constitutes a conflict of
interest.
(j) Voting conflict. —Where voting conflicts are not
otherwise addressed by the Constitution of Pennsylvania or by
any law, rule, regulation, order or ordinance, the following
procedure shall be employed. Any public official or public
employee who in the discharge of his official duties would be
required to vote on a matter that would result in a conflict of
interest shall abstain from voting and, prior to the vote being
taken, publicly announce and disclose the nature of his
interest as a public record in a written memorandum filed with
the person responsible for recording the minutes of the
meeting at which the vote is taken, provided that whenever a
governing body would be unable to take any action on a matter
before it because the number of members of the body required
to abstain from voting under the provisions of this section
makes the majority or other legally required vote of approval
unattainable, then such members shall be permitted to vote if
disclosures are made as otherwise provided herein. In the
case of a three - member governing body of a political
subdivision, where one member has abstained from voting as
a result of a conflict of interest and the remaining two members
of the governing body have cast opposing votes, the member
who has abstained shall be permitted to vote to break the tie
vote if disclosure is made as otherwise provided herein.
Griffin, 01 -511
January 30, 2001
Page 3 of 4
65 Pa.C.S. § §1103(a), (j).
The following terms that pertain to conflicts of interest under the Ethics Act are
defined 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.
65 Pa.C.S. §1102.
In applying the above provisions of the Ethics Act to the question of simultaneous
service, it is initially noted that the General Assembly has the constitutional power to
declare by law which offices are incompatible. Pa. Const. Art. 6, §2. There does not
appear to be any statutorily - declared incompatibility precluding simultaneous service in the
positions in question.
Turning to the question of conflict of interest, 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, a member of his
immediate family, or a business with which he or a member of his immediate family is
associated.
Where simultaneous service would place the public official /public employee in a
continual state of conflict, such as where in one position he would be accounting to himself
in another position on a continual basis, there would be an inherent conflict (See, Johnson,
Opinion 86 -004). Where an inherent conflict would exist, it would appear to be impossible,
as a practical matter, for the public official /public employee to function in the conflicting
positions without running afoul of Section 1103(a).
Absent a statutorily - declared incompatibility or an inherent conflict under Section
1103(a), the Ethics Act would not preclude an individual from simultaneously serving in
more than one position, but in each instance of a conflict of interest, the individual would
be required to abstain and to satisfy the disclosure requirements of Section 1103(j) as set
forth above.
Griffin, 01 -511
January 30, 2001
Page 4 of 4
In this case, based upon the facts which have been submitted, there does not
appear to be an inherent conflict under the Ethics Act that would preclude your proposed
simultaneous service as Bankruptcy Specialist for the Department of Revenue and Tax
Collector for the Borough. Consequently, such simultaneous service -- within the
parameters of Sections 1103(a) and 1103(j)- -would not be prohibited by the Ethics Act.
However, the propriety of the proposed conduct has only been addressed under the
Ethics Act. Specifically not addressed herein is the applicability of the Civil Service Act, the
Governor's Code of Conduct, or additional requirements to which you may be subject as
an employee of the Department of Revenue.
Conclusion: As a Bankruptcy Specialist for the Department of Revenue, you are a
"public employee" subject to the provisions of the Public Official and Employee Ethics Act
( "Ethics Act "), 65 Pa.C.S. §1101 et seq. Subject to the restrictions, conditions and
qualifications set forth above, your proposed simultaneous service as a Bankruptcy
Specialist for the Department of Revenue and Tax Collector for the Borough of Dillsburg
would not be prohibited by the Ethics Act. The propriety of the proposed course of conduct
has only been addressed under the Ethics Act. Specifically not addressed herein is the
applicability of the Civil Service Act, the Governor's Code of Conduct, or additional
requirements to which you may be subject as an employee of the Department of Revenue.
Pursuant to Section 1107(11), this 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 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