HomeMy WebLinkAbout1191 WilfongIn Re: Larry Wilfong
File Docket:
X -ref:
Date Decided:
Date Mailed:
Before: Daneen E. Reese, Chair
Louis W. Fryman, Vice Chair
John J. Bolger
Frank M. Brown
Susan Mosites Bicket
Donald M. McCurdy
99- 044 -C2
Order No. 1191
2/26/01
3/12/01
This is a final adjudication of the State Ethics Commission.
Procedurally, the Investigative Division of the State Ethics Commission conducted
an investigation regarding a possible violation of the Public Official and Employee Ethics
Law, Act 9 of 1989, P.L. 26, 65 P.S. §401 et seq., by the above -named Respondent. At the
commencement of its investigation, the Investigative Division served upon Respondent
written notice of the specific allegation. Upon completion of its investigation, the
Investigative Division issued and served upon Respondent a Findings Report identified as
an "Investigative Complaint." An Answer was filed and a hearing was waived. The record
is complete. A Consent Agreement and Stipulation of Findings were submitted by the
parties to the Commission for consideration. The Consent Agreement was subsequently
approved.
Effective December 15, 1998, Act 9 of 1989 was repealed and replaced by Chapter
11, Act 93 of 1998, which essentially repeats Act 9 of 1989 and provides for the completion
of pending matters under Act 93 of 1998.
This adjudication of the State Ethics Commission is issued under Act 93 of 1998
and will be made available as a public document thirty days after the mailing date noted
above. However, reconsideration may be requested. Any reconsideration request must be
received at this Commission within thirty days of the mailing date and must include a
detailed explanation of the reasons as to why reconsideration should be granted in
conformity with 51 Pa. Code §21.29(b). A request for reconsideration will not affect the
finality of this adjudication but will defer its public release pending action on the request by
the Commission.
The files in this case will remain confidential in accordance with Chapter 11 of Act
93 of 1998. Any person who violates confidentiality of the Ethics Law is guilty of a
misdemeanor subject to a fine of not more than $1,000 or imprisonment for not more than
one year. Confidentiality does not preclude discussing this case with an attorney at law.
Wilfonq, 99- 044 -C2
Page 2
I. ALLEGATION:
That Larry Wilfong, a public official, in his capacity as Manager of Marysville
Borough, Perry County, violated Section 3(a)/1103(a) of the State Ethics Act (Act 9 of 1989
as codified by Act 93 of 1998) when he used the authority of his office for a private
pecuniary benefit for himself and /or members of his immediate family when he utilized
borough employees, equipment and materials for his personal purposes, including but not
limited to using borough employees and equipment to repair personal vehicles and boats,
using borough employees and equipment to perform tasks of a personal nature around his
home, including shredding wood, using borough gasoline for his personal purposes, and
using a borough vehicle for his personal purposes; and when he used borough facilities for
the storage of personal items.
II. FINDINGS:
1. Larry Wilfong served as the Marysville Borough Manager from 1974 until May 20,
1999.
a. Wilfong was initially hired by the borough on May 15, 1962.
b. Wilfong also performed the duties of borough secretary and zoning officer.
c. Wilfong had supervisory responsibility over the day to day operations of the
borough's sewer and street departments.
2. The Marysville Borough waste water treatment plant has a storage area for
equipment and materials.
a. This storage area is not available to the general public.
b. This storage area was not available to borough employees to store personal
items.
3. Between May 1995 and May 1999 Wilfong took it upon himself to use part of the
treatment plant for storage of personal items.
a. Wilfong did not seek or receive specific council approval to store personal
items at the treatment plant.
b. Council was unaware that Wilfong was using the storage area.
c. Wilfong was using a storage area of approximately 10' x 10'.
d. Wilfong was directed to remove the items following his retirement from the
borough.
e. Wilfong asserts that he donated the items to the borough.
4. Wilfong was storing items such as an old air conditioner, chairs, radios, automotive
parts, bicycles, household and personal items.
a. Items stored by Wilfong were not needed for normal borough operation.
b. Items stored by Wilfong were not utilized in any manner by the borough.
5. Capital Self- Storage, 10 Prospect Drive, Enola, PA 17025 offers enclosed storage
Wilfonq, 99- 044 -C2
Page 3
facilities ranging in size from 4' x 4' to 10' x 30'.
a. Since 1995 Capital Self- Storage's monthly rate for a 10' x 10' enclosed
storage area increased from approximately $67.00 per month to their current
rate of $79.50 per month.
b. Capital Self- Storage is located approximately two (2) miles from Marysville.
6. Wilfong realized a private pecuniary benefit of at least $3,283.00 by utilizing
storage space at the borough's waste water treatment plant between May 1995 and
May 1999.
a.
b.
Private pecuniary gain calculated as follows:
49 months at $67.00 per month = $3,283.00
Financial gain per year:
1995: May — December
1996: January — December
1997: January — December
1998: January — December
1999: January — May
Eight (8) months
Twelve (12) months
Twelve (12) months
Twelve (12) months
Five (5) months
Total
$ 536.00
$ 804.00
$ 804.00
$ 804.00
$ 335.00
$3,283.00
7 Wilfong asserts his belief he had approval of the Marysville Borough Council to
utilize borough facilities for personal storage and feels the storage space actually
used was not 10' x 10' in size.
8. Minutes of Marysville Borough Council for its public meeting held November 13,
1978, reflect that council approved use of a portion of the borough maintenance
building by Wilfong to store a camper unit as the borough manager was on call 24
hours per day.
9. In relation to the allegation that Wilfong utilized Borough employees for repairs and
maintenance on his personal vehicle, information developed indicates as follows:
a. Repair of the exhaust system to Wilfong's personal vehicle was documented
by receipt from P & R Auto Repair, for which Wilfong personally paid.
b. Undercoating and painting of Wilfong's personal vehicle was completed by a
private individual and paid for by Wilfong.
c. Insufficient information was available to indicate that Borough employees
performed repairs to Wilfong's boat and boat trailer.
d. Information developed regarding repairs to a clothesline pole, coal bin and
gutter on Wilfong's property indicate that any such activities would be de
minimis in nature, amounting to less than $50.00.
10. Wilfong asserts that he did not utilize Borough employees, equipment and time for
his personal benefit.
a. Wilfong has produced receipts to verify the purchase of fuel and repairs
completed on his private vehicles.
Wilfonq, 99- 044 -C2
Page 4
11. Wilfong realized a total private pecuniary benefit of $3,283.00 as the result of his
use of borough property for his personal storage purposes.
III. DISCUSSION:
At all times relevant to this matter, the Respondent, Larry Wilfong, hereinafter
Wilfong, has been a public official subject to the provisions of the Public Official and
Employee Ethics Law ( "Ethics Law "), Act 9 of 1989, Pamphlet Law 26, 65 P.S. §401, et
seq. as codified by the Public Official and Employee Ethics Act, Act 93 of 1998, Chapter
11, 65 Pa.C.S. §1101 et seq., which Acts are referred to herein as the "Ethics Act."
The allegation is that Wilfong, as borough manager, violated Section 3(a)/1103(a)
of the Ethics Act when he used the authority of his office for a private pecuniary benefit for
himself when he utilized borough employees, equipment and materials for his personal
purposes, including but not limited to using borough employees and equipment to repair
personal vehicles and boats, using borough employees and equipment to perform tasks of
a personal nature around his home, including shredding wood, using borough gasoline for
his personal purposes, and using a borough vehicle for his personal purposes; and when
he used borough facilities for the storage of personal items.
Section 3/1103. Restricted activities
(a) Conflict of interest. —No public official or public
employee shall engage in conduct that constitutes a conflict of
interest.
65 P.S. §403(a)/65 Pa.C.S. §1103(a).
The term "conflict of interest" is defined under as follows:
Section 2/1102. 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. "Conflict" or "conflict of interest" 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.
65 P.S. §402/65 Pa.C.S. §1102.
Section 3(a)/1103(a) of the Ethics Act prohibits a public official /public employee
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.
Wilfonq, 99- 044 -C2
Page 6
As noted above, the parties have submitted a Consent Agreement and Stipulation of
Findings. The parties' Stipulated Findings are reproduced above as the Findings of this
Commission. We shall now summarize the relevant facts as contained therein.
Wilfong served as the Marysville Borough Manager from 1974 until May of 1999. In
addition, Wilfong had supervisory responsibilities over the daily operations of the
borough's sewer and street departments as well as performed duties of the borough
secretary and zoning officer.
The borough waste water treatment plant has a storage area for equipment and
materials. That storage area is not available to employees for the storage of personal
items. Without seeking or receiving council approval, Wilfong, on his own initiative
between May 1995 and 1999, stored personal items in an area of the plant that was
approximately 10' x 10' in size. Although Wilfong claims that he donated certain items to
the borough which were placed in the storage area, he was directed to remove those items
following his retirement. The items consisted of household and personal items such as an
old air conditioner, chairs, radios, automotive parts, and bicycles.
It appears that Wilfong received a pecuniary benefit of $3,283.00 for the storage of
his personal items between May 1995 and 1999, which is calculated by using comparable
rates for storage in the vicinity.
The minutes of the Marysville Borough Council for November 13, 1978, reflect an
approval for Wilfong to use a portion of the borough maintenance building to store a
camper because Wilfong, as the borough manager, was on 24 -hour call. Wilfong,
however, asserts that the approval by council was for his utilization of the facilities for
personal storage.
Separate and apart from the above, factual issues exist as to the allegation that
Wilfong utilized borough employees for the repair or maintenance of his private property:
the repair of an exhaust system for his personal vehicle, undercoating and painting of a
personal vehicle, repairs to a boat and trailer, and repairs to a clothesline pole, coal bin,
and gutter on Wilfong's property. As to the exhaust system and undercoating /painting,
Wilfong personally paid for such items. As to the matter of borough employees performing
repairs on the boat and trailer, there is insufficient information on that issue. Regarding
the other miscellaneous items, such items were less than $50.00 and hence de minimis in
nature.
Having highlighted the Stipulated Findings and issues before us, we shall now apply
the Ethics Act to determine the proper disposition of this case.
The parties' Consent Agreement sets forth a proposed resolution of the allegations.
The Consent Agreement proposes that this Commission find that Wilfong unintentionally
violated Section 3(a)/1103(a) of Ethics Act when he used the authority of his office for a
private pecuniary benefit by using borough facilities for storage of personal items; that
insufficient evidence exists to prove that Wilfong used the authority of his office for a
private pecuniary benefit by using borough employees, equipment, materials and vehicles
to perform tasks and services of a personal nature on borough time; and that Wilfong will
make payment in the amount of $2,000.00 to the Commonwealth of Pennsylvania within 30
days of issuance of this order.
In applying Section 3(a)/1103(a) to the above, there were uses of authority of office
on the part of Wilfong. See, Julliante, Order 809. But for the fact that he was the manager
for the borough, he would not have been able to store his personal property in the
municipal facilities. Such uses of office resulted in a private pecuniary benefit to Wilfong
in that he did not have any out of pocket expenses to pay for the storage of his personal
property. Hence, the private pecuniary benefit inured directly to Wilfong. Accordingly,
Wilfon , 99- 044 -C2
Page 6
Wilfong unintentionally violated Section 1103(a) of the Ethics Act when he used the
authority of office for private pecuniary benefit for himself by storing personal property in
the borough facilities. See, Bausch, Order 846; Rakowsky, Order 943.
As to the allegation regarding the utilization of borough employees, equipment,
materials, and vehicles to perform personal services for Wilfong, there is insufficient
evidence to support that allegation. Accordingly, Wilfong did not violate Section 1103(a)
as to the allegation that he utilized borough employees, equipment, and materials to
perform personal services based upon insufficient evidence.
We determine that the Consent Agreement submitted by the parties sets forth the
proper disposition for this case, based upon our review as reflected in the above analysis
and the totality of the facts and circumstances. Accordingly, Wilfong is directed to
pay $2,000.00 through this Commission to the Commonwealth of Pennsylvania within 30
days of the issuance of this Order. Compliance with the foregoing will result in the closing
of this case with no further action by this Commission. Noncompliance will result in the
institution of an order enforcement action.
IV. CONCLUSIONS OF LAW:
1. Wilfong, as a Manager of Marysville Borough, is a public official subject to the
provisions of Act 9 of 1989, as codified by Act 93 of 1998.
2. Wilfong unintentionally violated Section 3(a)/1103(a) of the Ethics Act when he
used the authority of office for a private pecuniary benefit for himself by storing
personal property in the borough facilities.
3. Wilfong did not violate Section 3(a)/1103(a) of the Ethics Act as to the allegation
that he utilized borough employees, equipment, and materials to perform personal
services based upon insufficient evidence.
In Re: Larry Wilfong
ORDER NO. 1191
File Docket: 99- 044 -C2
Date Decided: 2/26/01
Date Mailed: 3/12/01
1 Wilfong, as a Manager of Marysville Borough, unintentionally violated Section
3(a)/1103(a) of the Ethics Act when he used the authority of office for a private
pecuniary benefit for himself by storing personal property in the borough facilities.
2. Wilfong did not violate Section 3(a)/1103(a) of the Ethics Act as to the utilization of
borough employees, equipment, and materials to perform personal services based
upon insufficient evidence.
3. Per the Consent Agreement of the parties, Wilfong is directed to pay $2,000.00
through this Commission to the Commonwealth of Pennsylvania within 30 days of
the date of issuance of this Order.
a. Compliance with the foregoing will result in the closing of this case with no
further action by this Commission.
b. Non - compliance will result in the institution of an order enforcement action.
BY THE COMMISSION,
DANEEN E. REESE, CHAIR