HomeMy WebLinkAbout94-629 GrahamDonald P.
Attorneys
Cranberry
501 Smith
Cranberry
Re:
STATE ETHICS COMMISSION
309 FINANCE BUILDING
PO. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
ADVICE OF COLT'SEL
November 18, 1994
Graham, Esquire
at Law
Professional Park
Drive, Suite 3
Township, PA 16066
94 -629
Conflict, Public Official /Employee, Borough Council Member,
Business with which Associated, Business Client, Retiree.
Dear Mr. Graham:
This responds to your letter of October 12, 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 borough council
member from participating in matters involving a company when the
business with which he is associated is a supplier to that company
and upon another borough council member in participating as to
matters involving a company from which he is retired, and receiving
a pension.
Facts: After referencing Advice of Counsel No. 94 -565 issued on
April 26, 1994, you seek another advisory regarding Timothy
Sapienza (Sapienza) who has been appointed to replace Anna
Kanigowski on the Borough Council. The question has risen whether
Sapienza has a conflict regarding Paragon Trade Brands (Paragon/ in
that Sapienza is employed as a manager by Pennsylvania Power
Company (PPC) which is the electrical supplier to Paragon. The
question of conflict has arisen as to Sapienza because he is
manager of PPC and might vote on matters involving Paragon.
Council may be required to vote on a request for an amendment to a.
Zoning Ordinance, a site plan, a petition to vacate a street and a
conditional use request that has been submitted; by Paragon.
Charles Beighey (Beighey) is a Council Member who is a retire
of PPC and is currentky receiving a pension. As part of the
monthly payment of bills, Beighey is calked upon to approve
peyments to PPC for utility $ es: as to street lighting and
Graham, Donald P., Esquire, 94 -629
Noveer 18, 1994
Page 2
general Borough operations. You request advice as to whether
Beighey is precluded from voting on the payment gf bills because of
the inclusion of PPC bills in the list of'invoicea to be paid.
Discussion: It is initially noted that pursuant to Suctions 7(10)
and 7(11) of the Ethics Law, 65 P.S. 5 §407(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 P.S. 85407(10), (11). An
advisory only affords a .defense to the extent the requestor has
truthfully disclosed all of the material facts. Further, this
advice is limited to the facts presented in this advisory request
only.
As Council Members for Harmony Borough, Sapiegza ea4 Beighey
are public officials as that term is defined under t ie Ethics Law,
and hence they are subject to the provisions of that lair.
Section 3(s) of the Ethics Law provides:
Secta o,n 3 . Restricted Activities.
(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:
Segtion 2. Definitions.
"Conflict or conflict of interest.' Use
by a public official or public employee of the
authority of h.s office or employment or any
confidential information received through hie
bolding public office or employment for t
private pecuniary benefit of himself, a member
of his immediate family or a bu$iness 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 miaimis economic- impact or which .affects to
the same decree a class consisting of the
general public or a subclass consisting of an
industry, occupation or other group which
includes the public : Qpff icial or public
employee, a member of his ;immediate family or
Graham, Donald P., Esquire, 94 -62 -9:
November, 1'8, 1994
Page 3
a business with which he or a member. o€ his
immediate family is associated.
"Business with which he is associated."
Any business. in which the person or a member,
of the person's immediate family is a
director, officer, owner, employee or has a
financial interest -.
"Financial interest." Any financial
interest in a legal entity engaged in business
for profit which comprises more than 5% of the
equity of the business or more than 5% of the
assets of the economic interest in
indebtedness.
In addition, Sections 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 anything of monetary value based upon the
understanding that the vote, official action, or judgement of the
public otticial /employee would be influenced thereby. Reference is
made to these provisions of the law not to imply that there has
been oT 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
wpvld 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
Graham, Donald P., Esquire, 94 -629
November 18, 1994
Page 4`
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 opp sing vote$ 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
abltehtioa and reasons for same, both orally and by filing a
wr4t mewoiinai m to that effect with the person recording the
minutes Q su e*visor.
In applying the above provisions of Section(a) of the Ethics
Law tQ the - instant matter, Sapienza would have a conflict regarding
matte rs invoo.v n „ Paragon. In Miller, Opinion 89 -024, the
Com aeaiQn field that a Public official who Was employed by a
iO ens 'wool s have a conflict of interest not only as to that
bi. 4�nes but t4 the clients of that business. In addition, in
Itannebe Opinion 92 -010, the Commission held that townsh p
supe yieor whp - had a private law practice would have a conflict as
tq'* law ' glieuts Coming before the township board even though his
legal representation of those clients was not related to the issues
the 'clients hail before that municipal body. In this case, since
Pafagq,i i a v endee as to electrical supplies by PPC, it is clear
t.at Sapienza has a conflict based upon Miller. Sapienza is
e ployed as a manger by. EEC which is a "business with which he is
associated" as per the' above quoted definition in the Ethics Law.
544G-041-8 is. supplied bj PRC and hence is a client or vendee of PPC.
4400Kdingly• basec'� uR�?n M
i iller, Sapien has a conflict and may not
�
partiipate aril must 'obse"rve' the disclosure requirements of Section
3(j) , 'toted move.
However, as to Eeighey, based upon the submitted facts, it
oes nqt ea that Be�gfiey
app -�' is associated with PPC in that he is
yr
q,urrenv;]:y, retired and receiving a pension. Therefose.., ass ng
that Beighey
d oes not any posi With PPC, and does not have
,
% •�rfiria4eial ygterest ": as that term is defined under the Ethics Law
abov FC wld not be a' business with which Beighey is associated
4n4 hence' he wQUld' c have: a conf .ict regardin vot ng on the
aPB.rc val g.i bi.laby p$C..
The p, .c .riety, of the proposed conduct has only been addressed
ux de the a Law; the applicability -o£ a.ny of stat: te, code,
oraz:lance,, regulati or other code ot conduct other than the
Graham, Donald P., Esquire, 94 -6Z9
November 18, 1994
Page 5
Ethics Law has not been considered in that they do not involve an
interpretation of the Ethics Law. Specifically not addressed
herein is the applicability of the respective municipal code.
Conclusion: As Council Members for Harmony Borough, Sapienza and
Beighey are public officials subject to the provisions of the
EChias Law. Under Section 3(a) of the Ethics Law, Sapienza has a
conflict on matters involving Paragon Trade Brands, Inc. when
Sapienza is an employee of Pennsylvania Power Company which is a
supplier to Paragon. Sapienza must abstain and observe the
disclosure requirements of Section 3(j) as noted above. Beighey as
a retired employee of Penn Power Company who is currently receiving
a pension from that company would not have a conflict participating
on the approval of monthly payments of bills which include
Pennsylvania Power Company based upon the above submitted facts.
Lastly, the propriety of the proposed conduct has only been
addressed under the Ethics Law.
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 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
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
Cession.
such.
Any such appeal must be in writing and : must be actually
received at the Commission within fifteen (15) days of the date
of this Advice pursuant to 51 Pa. Code 513.2(11). The appeaEl may
be received at the Commission by hand delivery, United States
wail, delivery service, or by FAS transmis ion (717_707= -0006).
F&ilure to file such an appeal at the Commission aion ,within fifteen
115) days may result in the dismissal of the appeal.
Vincent J.V Dopko
Chief Counsel