HomeMy WebLinkAbout85-502 BurnsBeatrice A. Burns, President
Borough Council
Borough of Westmont
1560 Menoher Blvd.
Johnstown, PA 15905
Re: Joint Recreation Commission, Recreation Authority
Dear Ms. Burns:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
January 4, 1985
ADVICE OF COUNSEL
85 -502
This responds to your letter of August 17, 1984, in which you requested
advice from the State Ethics Commission.
Issue: You ask whether the Ethics Act prohibits a public official from
serving as a paid employee of a Recreation Commission and as a member of the
Board of such Recreation Commission.
Facts: In your capacity as President of the Borough Council of Westmont
Borough, hereinafter, the Borough, on 'behalf and with the acquaintance ence of
several members of the Borough Council, you asked the State Ethics Commission
for an opinion regarding the propriety of certain conduct. Specifically, you
ask whether paid employees of a Recreation Commission may also be officials
within the municipalities which constitute and create this Commission.
You indicate that Westmont Borough, another neighboring borough, a
township and a school district have formed a joint Recreation Commission and a
Recreation Authority. The Recreation Commission is operated by a Board
consisting of two people from each participating borough and township for a
total of six members plus three other members appointed by the school board.
Each of the participating municipalities, in addition to providing members and
appointees to the Board of the Recreation Commission contribute money to the
Recreation Commission so that it may carry out its functions.
Beatrice A. Burns, President
January 4, 1985
Page 2
Essentially, the Recreation Commission receives its funds from participating
municipalities and is dependent on these municipalities' and the decisions of
the elected officials therein for its operating revenues. It has been the
practice, in the past, for elected officials from the participating
municipalities to serve on the Recreation Commission and it is anticipated
that there may be, on occasion, paid employees of the Recreation Commission as
well as elected officials within the participating municipalities who may wish
to serve on the Board of the Recreation Commission. It should be noted,
finally, that the participating municipality usually enters into a contract
with the Recreation Commission in an amount representing the funds that they
will contribute to the Recreation Commission which amount reflects or is based
upon the employees' salary and operating costs of the Recreation Commission.
In turn, under this contract the Recreation Commission provides to the
municipalities, the recreation services required by the Borough or the other
participating and contracting municipalities.
You also ask whether a member of the Recreation Board can also be an
employee of the Recreation Commission and whether this kind of situation would
give rise to a conflict of interest.
Discussion: We must intially note that our jurisdiction and authority is
limited to interpreting and providing responses under the State Ethics Act.
We cannot, therefore, provide you with any response as to whether or not the
above - referenced situation would give rise to a conflict of interest under the
provisions of the Borough Code, for example. Thus, this response should not
be taken as "clearance" to act under any other statute, regulation, etc.,
other than the Ethics Act.
The elected officials, of course, who serve within the participating
municipality as outlined above, would be "public officials" as that term is
set forth in the Ethics Act. As such, their conduct must conform to the
requirements of the State Ethics Act. Likewise, those paid employees of the
Recreation Commission who fall within the parameters of the definition of
"public employee" as set forth in the Ethics Act would also be bound by the
restrictions and prohibitions of the Ethics Act. Essentially, we understand
your question to be whether or not it is an inherent conflict for an elected
official or an employee of the Recreation Commission to serve and participate
as a member of the Recreation Board, which operates the Recreation Commission
and which provides services and receives funds under contract from the
participating municipalities, including the Borough. If this is not your
question please advise.
Beatrice A. Burns, President
January 4, 1985
Page 3
If the individuals who are serving on the Recreation Commission and the
Board thereof are puhlic officials by virtue of their election as officials
within one of the participating municipalities or if these individuals as paid
employees of the Recreation Commission are to be considered "public
employees ", they should be alert to Section 3(a) of the Ethics Act which
states as follows:
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. 403.
As can be seen from this Section, any "public official" or "public
employee ", whether serving the Borough or employed by the Recreation Board or
Commission, may not use their public office or employment to benefit their
private financial interests. Likewise, each of these individuals must assure
the public that their financial interests do not conflict nor appear to
conflict with the public trust. See Section 1 of the Ethics Act, 65 P.S. 401.
There does appear to be a potential for conflict between the interests that an
individual would serve as an elected official within a municipality or as an
employee of the Recreation Commission and the service of such individual as a
member of the Board of the Recreation Commission. Specifically, those members
who are elected in a municipality would be in a position to make, as members
of that municipality's governing body, decisions regarding contracting or
funding for the Recreation Commission in which they would be interested in as
members of the Board of the Recreation Commission. At least, in order to
assure the public that their interests as elected officials within the
municipality, such as the Borough, did not conflict with their interests as
members of the Board of the Recreation Commission, those elected officials in
a participating municipality who serve or are appointed as members of the
Recreation Commission or Board should decline to participate as members of the
Borough Council on the Borough's decisions regarding the funding and
contracting with the Recreation Commission. In this manner, by this
abstension, those public officials serving on Borough Council and also serving
as members of the Board of or the Recreation Commission would obviate any
appearance of a conflict with the public trust insofar as the
interests of the Borough and the Recreation Commission may be adverse to each
other.
Beatrice A. Burns, President
January 4, 1985
Page 4
Thus, while it would not necessarily be an inherent conflict for a member
of the Borough to be appointed to and to serve as a member of the Recreation
Board or Commission he or she, in such a capacity, if appointed, would be
required to abstain as a member of the Borough from decisions which would
affect or be related to the contract of the Borough with the Recreation Board
or Commission. Likewise, as a member of the Recreation Commission such an
individual would be required to abstain from participation in matters which
would relate to the contract or provision of services to the Borough. Under
such circumstances, it is unclear whether the extent of such abstention would
render such a member serving in a dual capacity ineffective. This question is
one which must be answered by the appointing municipality and, should be the .
subject of any code of conduct or regulations which might be adopted by the
participating municipality's with respect to their relationship with the
Recreation Commission and Authority or Board.
We would, of course, reach a similar conclusion with respect to any
individual who serves as a paid employee of the Recreation Commission, who
would fall within the definition of "public employee," and who might also seek
to serve in the capacity as a member of the Board of the Recreation
Commission.
We note that the preliminary question would be whether such a paid
employee would also be a "public employee" as defined in the Ethics Act. For
purposes of this response we will assume such a situation and coverage exists.
Thus, under these facts, this "public employee," as a member of the Recreation
Commission would also have an opportunity to participate in decisions of the
Recreation Commission through the Board as to his or her status as an employee
of the Recreation Commission, in general. In such a case, as a member of the
Board of the Recreation Commission such an individual should probably abstain
from participating in decisions of the Recreation Commission made by or
through the Board, if any, that would affect him or her as a paid employee.
However, it is unclear whether or not you are authorized to seek and secure a
binding interpretation or opinion with respect to any such employee. You have
indicated that there are no paid employees of the Recreation Commission at
present who are so seeking to or do serve as members of the Board of the
Recreation Commission, Board, or Authority. Thus, these comments should be
considered non - binding at the present time. Should such a situation arise
where a paid employee of the Recreation Commission would be asked to or be
appointed to serve as a member of the Board of the Recreation Commission
and/or Authority, we suggest that you raise this question to us with the
knowledge and participation of such an employee so that a binding advice can
be rendered and the protections of the Ethics Act with resepct to such a
situation can be secured.
Beatrice A. Burns, President
January 4, 1985
Page 5
Conclusion: Insofar as members of the Borough Council of the Borough of
Westmont may be asked to and would be serving as members of the Board of the
Recreation Commission and /or the Authority which is an arm of the Recreation
Commission to provide services to the Borough, abstention of these individuals
on questions relating to the Borough's contracting with the Recreation
Commission would be required as set forth above. While there is no per se
conflict in an elected official serving in such capacity on the Recreation
Commission or the Board thereof and /or the Authority, given the requirement of
abstention as set forth above , such an individual may not be able to
effectively serve in both capacities. The cautions and concerns regarding the
conduct of a paid employee of the Recreation Commission, who may be a "public
employee" vis -a -vis serving on the Recreation Board should be considered when
and if such a situation arises.
If we do not fully appreciate the facts or questions you have presented,
please advise and we will respond accordingly.
Pursuant to Section 7(9)(ii), 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, providing the
requestor has disclosed truthfully all the material facts and committed the
acts complained of in reliance on the Advice given.
SSC /sfd
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 request that the full Commission review this Advice.
A personal appearance before the full Commission will be scheduled and a
formal Opinion from the Commission will be issued. Any such appeal must be
made, in writing, to the Commission within 15 days of service of this Advice
pursuant to 51 Pa. Code 2.12.
Sincerely,
Sandra S. Christianson
General Counsel