HomeMy WebLinkAbout94-521 RussellJacqueline L. Russell,
Thompson Building
3rd Floor, Room 310
Pottsville, PA 17901
Dear Ms. Russell:
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -16.10
ADVICE OF COUNSEL
March 7, 1994
Esquire
Re: Conflict, Public Official. /Employee, Township
Township Auditor, Use of Authority of Office or
Information, Immediate Family, Husband and Wife.
94 -521
Supervisor,
Confidential
This responds to your letters of January 6 and February 7,
1994 in which you requested advice from the State Ethics
Commission.
Issue: Whether the Public Official and Employee Ethics Law
presents any prohibition or restrictions upon a T6wnship Supervisor
and a Township Auditor who are husband and Wife.
Facts: You represent two individuals in a second class township.
One is a supervisor, the other is an auditor; They are husband and
wife. They have requested you to Obtain an advisory froM this
Commission regarding their conduct as to each other. It it need
that there are three auditors in the township. You state that the
Second Class Township Code provides that the audit6r's duties
include examining the books of the supervisors, determihiiig whether
a surcharge is appropriate and setting the rate of pay for the
supervisors. Accordingly, you seek advice from the State Ethids
Commission.
Discussion: It is initially noted that pursuant to Sections 7(1C )
and 7(11) of the Ethics Law, GS P.S. Ss407(10), (11), advisories
are issued to the requester based upon the facts which the
requestor has submitted. In issuincl the advisory based updn the
facts which the requestor has submitted, the Commission deed diet
engage in an independent investigation of the facts, net Mesta it
speculate a$ 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 P.S. SS407(10), (11). An
advisory only affords a defense to the extent the requester has
Russell, Jacqueline L., Esgtire, 54 -521`
March 7, 1994
Page 2
truthfully disclosed all of the material facts.
As a Township Supervisor and Township Auditor for a Second
Class Township, these individuals are public officials as that term
is defined under the Ethics Law, and hence they are subject to the
provisions of that law.
Section 3(a) of the Ethics Law provides:
Sectio i .._...__Fte. tricted..Act .vities.
(a) NO public official or public
employee shall engage in conduct that
constitutes a conflict of interest.
The following terms are_defined in the Ethics Law as follows:
Section. 2. Defi :tiofs
"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 pectiniary benefit of himself, a member
of his immediate family Or a business with
which ' he or a member of hie 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, stry, occupation or other group which.
includes the public official or public
employee, a member of his immediate family or
a bUdiness with which he or ' fa member Of his
mediate 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
etplOyTlent .
° 1a►ediate Family." A parent, spouse,
child, brother or sister.
In addition, Sectiens 3(b) and 3(c) of the Ethics Law provide
in part that no person shall offer to a public official/employee
anything of mbiletary value and no public official /employee shall
Russell, Jacqueline L., Esquire, 94 521
March 7, 1994
Page 3
solicit or accept anything of monetary value based upon the
understanding that the vote, official action, or judgement of the
public official /employee would be influenced thereby. Reference is
made to these provisions of the law not to imply that there has
been or will be any transgression thereof but merely to provide a
complete response to the question presented.
Section 3(j) of the Ethics Law provides as follows:
Section 3. Restricted activities
(j) 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.
If a conflict exists, Section 3(j) requires the public
official /employee to abstain and to publicly disclose the
abstention and reasons for same, both orally and by filing a
written memorandum to that effect with the person recording the
minutes or supervisor.
In the event that the required abstention results in the
inability of the governmental body to take action because a
Russell, Jacqueline L., Esquire,;.94 --521
March 7, 1994
Page 4
majority is unattainable . due to the abstention(s) from conflict
under the Ethics Law, .them in that event participation is
permissible provided the disclosure requirements noted above are
followed. See, Mlakar, Advice 91- 523 -S.
In applying the provisions of the Ethics Law quoted above to
the instant_ matter, the Ethics Law does not prohibitor restrict
members of the same family from seeking or being elected to public
office. The restriction of Section 3(a) is that a public official
may not use the authority of office to obtain a private pecuniary
benefit for. himself or -a member of his immediate family.
In this case it is clear that the individuals, as spouses, are
members of the same immediate family as that term is defined under
the Ethics Law. Accordingly, although there is no prohibition or
restriction from one spouse serving as auditor when the other
spouse is supervisor in the same township, the spouse who is
auditor could not participate in any matter which could result in
a financial .. benefit to her husband nor could she participate in any
personal matter as to..him. In particular, she could not
participate in fixing his compensation. She could not participate
in auditing that part of the books and accounts of the Board of
Supervisors dealing with the receipt of a pecuniary benefit by her
spouse.
As to the Supervisor, a conflict of interest would arise
whereby the use of his .authority of office or confidential
information which he has obtained through holding office, would
result in a private pecuniary benefit, either for himself, for a
member of your immediate family such as his spouse, or for a
business with which he or a member of his immediate family is
associated. In such. conf licts , the Supervisor would have to remove
himself from any aspect' of participation. The prohibited
participation would include not only voting but would extend to
other forms of pfficial participation such as participating in
negotiations or discussions regarding such matters or lobbying for
a particular result.
Where such a. conflict -of interest exists, the public official
must not only abstain, but under the . provisions ,'of the Ethics Law
set forth above, he must.also publicly announce the nature of his
interest and also file a written memorandum with the person
recording the minutes,. disclosing the nature of bis interest.
'In light of the above, Section 3(j) of the Ethics Law would
require these individuals to publicly announce their interests and
the limitation of their participation as outlined above and in
addition file written memorandums to that effect with the person
responsible for recording the minutes of the meeting of the
township supervisors and township auditors.
Russell, Jacqueline L., Esquiri, 94.523
March 7, 1994
Page 5
The propriety of the proposed conduct has only been addressed
Under the Ethics Law; the applicability of any other statute, code,
ordinance, gulatlbh or other code of conduct other than the
Ethics Law has hot be€n Obnsidered in that they do not involve an
interpretation of the Ethics Law. Specifically not addressed
herein is the iftlidebilitY of the Second Class Township Code.
Conclusion: As a Tow iShiEup and a Township Auditor for a
Second tlass Township, these individuals are public officials
subject to the provisions of the Ethics Law. The Auditor may not
participate, inspect dr audit the books of the board of supervisors
relating to the ceipt 'df cothpensation by her spouse, nor could
she fix compensation for her spouse. A conflict of interest would
arise for the Supervisor wPiere the use of authority of office or
confidential information received by holding his position would
result in a private pecuniary benefit to his spouse. In each
instance of a conflict of interest, the disclosure requirements of
Sectidh 3(j) of the Ethics Law would have to be met. Lastly, the
pro 3rety of the proposed conduct has only been addressed under the
Ethics Lava.
Pursuant to Section 7(11), this Advice is a complete defense
in any a forcemiht proceeding initiated by the Commission, and
eviagheb of good faith conduct in any other civil or criminal
probbedin #,,providing the requestor has disclosed truthfully all
the material facts ind committed the acts complained of in reliance
on the Achrice 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 forttal Opinion will be issued by the Commission.
Any such appeal must be In writing and must be actually
received at the Commission within fifteen (15) days 0f 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 mall, delivery
service, or by FAX transmission (717 - 787 - 0806).
Vincent J. Dopko
Chief Counsel