HomeMy WebLinkAbout94-559 WallaceRobert S. Wallace
20 W. Luzerne Avenue
Larksville, PA 18704
Dear
This
requested
Issue:
presents
"business
Borough.
Mr. Wallace:
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 114
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
April 20, 1994
94 -559
Re: Conflict of Interest, Public Official, Borough Council Member,
Contracting with Governmental Body, Use of Authority of
Office, Manager of Auto Service, Repairs for Borough Equipment
and Vehicles, Business with which Associated, Immediate
Family, Wife, Employee of Borough Sewer Authority.
responds to your letter of April 5, 1994, in which you
advice from the State Ethics Commission.
Whether the Public Official and Employee Ethics Law
any prohibition upon a Borough Council Member or a
with which he is associated" from contracting with his
Facts: You are requesting an advisory from the State Ethics
Commission. You were sworn in as a Councilman for Larksville
Borough on January 3, 1994. You are employed as Manager of
Petriga's Auto Service. Your wife and your two brothers -in -law are
the owners of the business. The auto shop does minor repairs to
the Borough equipment and vehicles. All of the bills to the
Borough from the business have been under five- hundred dollars
($500.00) . You abstain from voting on any bills concerning payment
to the business.
Your questions are:
1. Should the bills submitted for payment to Petriga's Auto
Service be separate from all the other bills?
2. The business does not have any type of contract with
Larksville Borough. The maintenance and repair work is
brought into the business without any solicitation from
you. Is this a violation of the Ethics,AOt?
Wallace, Robert S., 94 - 559
AFL 20 , 1994
Pale 2
•
T,P'1� . d� • >./...s 1.
3. Tour wife is employed. by Larksville Borough Sewer
Authority, which is separate from the Borough. Since she
is part owner of the business, is there any violation of
any
Discussion: As Member of Council for Larksville Borough, you are
a "public official" as that term is defined in the Ethics Law. 65
P.S. 5402. 51 Pa. Code S11.1. As such, you are subject to the
provisions of the Ethics Law and the restrictions therein are
applicable to you.
Section 3(a) of the Ethics Law provides:
Restricted: Activities,
No public official or public employee
shall engage in conduct that constitutes a
conflict of interest.
The following terms are defined under the Ethics Law:
"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 or 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,
"Business with which he is associated."
Any business in which the person or a member
of the person's immediate family is a
Wallace, Robert S., 94 -559
April 20, 1994
Page 3
director, officer, owner, employee or has a
financial interest.
"Immediate family." A parent, spouse,
child, brother or sister.
Under Section 3(a) of the Ethics Law quoted above, a public
official may not use the authority of office or confidential
information to obtain a private pecuniary benefit for himself, a
member of his immediate family or a business with which he is or a
member of his immediate family is associated.
Generally, the Ethics Law places no per se prohibition upon a
public official or business with which he is associated from
contracting with his governmental body. Pancoe, Opinion 89 -011.
As Manager of Petriga's Auto Service, it is clear that the
foregoing entity is a "business with which you are associated" as
that term is defined under the Ethics Law.
Under Sections 3(a), you could not participate or vote on
matters involving the contract: between the government body and
Petriga's Auto Service or the "business with which you are
associated." In addition, the requirements of Section 3(j) of the
Ethics Law must be followed whereby the reasons for the abstention
must be publicly noted as well as a written memorandum to that
effect must be filed with the secretary recording the minutes.
Therefore, under Section 3(a), you or the "business with which
you are associated" is not .precluded from contracting with
Larksville Borough but you could not participate or vote as to the
matter of the contract and must comply with the disclosure
requirements of Section 3(j) of the Ethics. Law.
Section 3(b) and 3(c) of the Ethics Law provide in part that
no person shall offer to a public official /employee anything of
monetary value and no public official /employee shall solicit or
accept any thing of monetary value based upon:the understanding
that the vote, official action, or judgement of the public
official /employee would be influenced thereby.
Section 3. Restricted activities.
(f) No public official or public
employee or his spouse or. gild or any
business in which the person or his spouse or
child is associated shall enter into any
contract valued at $500 or more with the
governmental body with which the public
official or public employee As associated or
Wallace, Robert S., 94 -559
April 20, 1994
Page 4
any subcontract valued at $500 or more . with
any person who has been awarded a contract
with the governmental body with which the
public official or public employee is
associated, unless the contract has been
awarded through an open and public process,
including prior public notice and subsequent
public disclosure of all proposals considered
and contracts awarded. In such a case, the
public official or public employee shall not
have any supervisory or overall responsibility
for the implementation or administration of
the contract. Any contract or subcontract
made in violation of this subsection shall be
voidable b a court of competent jurisdiction
if the suit is commenced within 90 days of the
making of the contract or subcontract.
In relation to the above provision of law, the State Ethics
Commission has generally determined that this provision is a
procedure to be used when a public official employee contracts
with his own governmental body in an amount of $500 or more. The
process must be open and public with prior public notice and
subsequent public disclosure. In addition, the public - official/
employee may not have any supervisory or overall responsibility for
the implementation or administration of the contract.
Thus, the open and public process, must be used in all
situations where a public official is otherwise appropriately
contracting with his own governmental body in an amount of $500 or
more. This open and public process would require:
(1) prior public notice of the employment or
contracting possibility;
(2) sufficient time for a reasonable and prudent
competitor /applicant to be able to prepare and
present an application or proposal;
(3) public disclosure of all applications or
proposals considered and; _
(4) public disclosure of the contract awarded and
offered and accepted.
Further, Section 3(f) requires that the public official could
not have supervisory or overall responsibility as to the
implementation or administration of the contract.
Section 3(j) of the Ethics Law provides as follows:
Wallace, Robert S., 94 -559
April 20, 1994
Page 5
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
majority is unattainable due to the abstention(s) from conflict
under the Ethics Law, then in that event participation is
permissible provided the disclosure requirements noted above are
followed. See, Mlakar, Advice 91- 523 -S.
Your specific inquiries will now be addressed.
As to your first inquiry, it is not within the jurisdiction of
Wallace, Robert S., 94 -559
April 20, 1994
Page 6
the State Ethics Commission to instruct,you as to how certain bills
should be submitted for payment. The caution that must be
expressed, of course, is that you would have a conflict as to any
matter before you relating to the business with which you and your
wife are associated. in such cases, you must abstain from
participation and observe the provisions of Section _3(j) must be
followed as set forth above.
Your second specific question has been addressed above.
Again, the business with which you are associated is not precluded
from contracting with the Borough. The restriction is that if the
contract is in excess of $500.00, Section 3(f) of the Ethics Law
must be followed and with a of any amount, Section 3(j)
must be followed. Finally, the Commission has indicated that
contracts nevertheless be included within the statutory
requirements of Section 3(f) if it is determined that .fragmentation
has occurred. Parenthetically, fragmentation is an action where
contracts are broken down into several contracts of lesser amounts
so as to avoid contracting limitations or bidding requirements.
As to your third inquiry, you would not have a conflict in
your positiori as Borough Council Member merely because your wife is
an employee of the Borough Sewer Authority. However, if in your
position as Borough Council Member, you are required to review any
matter involving your wife, you would have a conflict of interest.
You must abstain from participation of any nature and comply with
the disclosure requirements of Section 3(j) of the Ethics Law set
forth above. Any conflict as to the ownership of the business has
been discussed above. Finally,•since advisories can only address
the Ethics Law as to the individual requestor, any question as to
conflicts regarding your wife in her position as Sewer Authority
employee and as owner of the business, if any such conflicts
exists, cannot be discussed here.
Parenthetically, although the contracting in question would
-not be prohibited under the Ethics Law provided the requirements of
Sections 3(a), (f) and (j) are satisfied, a problem may exist as to
such contracting under the Borough Code.
In the instant situation, the Borough Code provides as
follows:
S46404. Penalty for personal interest in
contracts or purchases
Except as otherwise provided in this act, no
borough official either elected or appointed,
who knows or who by the exercise of reasonable
diligence could know, shall be interested to
any appreciable degree either directly or
Wallace, Robert S., 94 -559
April 20, 1994
Page 7
indirectly in any purchase made or contract
entered into or expenditure of money made by
the borough of relating to the business of the
borough, invoIvtng the expenditure by the
borough of more than one thousand dollars
($1000) in any calendar year, but this
limitation shall not apply to cases where such
officer or appointee of the borough is an
employee of ` the person, firm Or' corporation to
which the money is to be paid in a capacity
with no possible influence on the transaction,
and in which he cannot be possibly benefited
thereby either financially or otherwise. But
in the case of a councilman or mayor, if he
knows that he is within the exception just
mentioned he shall so inform council and shall
refrain from voting on the expenditure or any
expenditure or any ordinance relating thereto,
and shall in no manner participate therein.
Any official or appointee who shall knowingly
violate the provisions of this section shall
be subject to surcharge to the extent of the
damage shown to be thereby sustained by the
borough and to ouster from office, and shall
be guilty of a misdemeanor, and upon
conviction thereof shall be sentenced to pay a
fine not exceeding one thousand dollars
($1000), or not exceeding'one hundred eighty
days' imprisonment, or both. 1966, Feb. 1,
P.L. (1965) , No. 581, §1404. 53 P.S.
S46404.
Since such contracting may be prohibited by the above quoted
provision of the Code, but not under the Ethics Law, it is
suggested that advice in that regard be sought from the Borough
Solicitor or from private counsel.
Lastly, the propriety of the proposed conduct has only been
addressed under the Ethics Law; the applicability of any other
statute, code, ordinance, regulation or other code Of conduct other
than the Ethics Law has not been considered in that they do not
involve an interpretation of the Ethics Law. Specifically riot
addressed in this advice is the applicability of the Borough Code:
Conclusion: As a Member of Larksville Borough Council, yOu are a
public official subject to the provisions of the-Ethics Law. Under
Section 3(a) of the Ethics Law, a public official /employee or a
"business with which you are associated" may contract with the
governmental body but could not vote or participate in the matter
of the contract. The disclosure requirements of Section 3(j)
Wallace, Robert S. 94 -55 '
April 20, 1994
Page 8
outlined above must be observed. Finally,' if the contract is $500
or more, the open and public process as outlined above must be
accomplished. The public official /employee could not have any
supervisory or overall responsibilities as to the contract.
Lastly, the propriety of the proposed conduct has only been
addressed under the Ethics Law. nue to the possible application of
the above referenced code in this matter, it is suggested that
advice be obtained from the Borough Solicitor or private counsel in
that regard.
Pursuant to Section 7(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, providing the requester 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 actual
ly
received at the Commission within fifteen (15) days of the date of this
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).
ncerely,
Vincen '' J. ' opko
Chief Counsel