HomeMy WebLinkAbout92-542-Ms. Maryann Conway, Esquire
Board of Commissioners
Schuylkill County Court,House
401 North Second Street
Pottsville, PA 17901 -2528
Dear Ms. Conway:
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
ADVICE OF _COUNSEL
`February 19 .1992
92 -542
Re: Conflict, Public Official / Employee, Private Employment or
Business, County Commissioner,and Attorney at Law.
This responds to your letter of January 10, 1992, in which
you requested advice from the State Ethics Commission.
Issue: Whether a county commissioner is prohibited or restricted
by the Public Official and Employee Ethics Law from working as an
attorney in a private capacity in addition to public service.
Facts: Having been sworn in as Minority Commissioner of
Schuylkill County on January 6, 1992, you are acting upon the
advice of Chester Corse, Esquire, to seek an advisory from this
Commission with regard to . your accepting cases in Schuylkill
County while simultaneously serving as a County Commissioner.
You . note that you are particularly concerned that you do not
_
violate any of the provisions of the Ethics Law or accept cases
which may pose a conflict of interest to your position as
Commissioner. You point out that the County Commissioners are
responsible for approving the salaries of the Assistant District
Attorneys and the court personnel, including the divorce, support
and custody masters who are employed directly by the Court, You
have abstained from voting on those salaries, because you did not
want to preclude yourself from a general practice of law.
In the past, you have practiced domestic relations law, real
estate law, and Orphan Court's law, as well as criminal law. You
believe that sometime in the future you may want to resume your
private practice.
Based upon all
of the above, you request an advisory fro*
this Commission to define the areas where there may be a conflict
or violation of the law.
Ms. Maryann Conway, Esquire
February 19, 1992
Page 2
Discussion: As a County Commissioner. for Schuylkill- County,
Pennsylvania, you are a public official as that term is defined
under the Ethics Law, and hence you are subject to the provisions
of that law.
Section 3(a) of the Ethics Law provides:
' Section 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:
Section 2. Definitions.
"Conflict or conflict of interest." Use
by a public official or public`emplvyee of
the authority of his office or employment or
any confidential information received tough
his holding public . office or employment f<r
the private pecuniary benefit of himself, a
member of his immediate family or a busiri ss
with which he or a member of his ii ediate
family is associated. _ _ __ donflict" or
"conflict of interest" does not include an
action having a de minimis economic impact or
which affects to the ` same' degree c1 S
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.
"Authority . of office or employment."
The actual power provided by law, the
exercise of which is e
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
Ms. Maryann Conway, Esquire
February 19, 1992
Page 3
director, officer, owner,, employee or has a
financial interest.
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 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.
In applying the above provisions of the Ethics Law to the
instant matter, Section 3(a) of the Ethics Law 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.
We note that Section 3(a) of the Ethics Law does not
prohibit public officials /employees from outside business
activities_or employment; however, public official /employee
may not use the authority of office for the advancement of his
own private pecuniary benefit or that of a business with which he
is associated. Pancoe,_Opinion 89 -011. Similarly, Section 3(a)
would expressly prohibit any use of confidential information
received, by holding office /employment. for such a
prohibited private pecuniary benefit... A public official /employee
must "exercise }caution so that his private business activities do
not conflict with his public duties. Opinion 89 -013.
Thus, a public official /employee could not'perform private
business using governmental facilities or personnel. In
particular, the governmental telephones, postage, staff,
equipment, research materials, personnel or any other property
could not be used as -_ means, in whole or part, to carryout
private business activities Ins addition, the public
official /employee could not during government working hours,
solicit or promote such business activity. Pancoe, supra.
It is generally noted that in the event-your- private
employer or- business has a matter- pending before your
governmental body ' or if you as part of such official ".duties must
participate, review or pass upon that matter, a conflict would
exist. _Killer, Opinion 89-024. In those instances, it will be
necessary that .you be removed from that pxocess.
Ms. Maryann Conway, Esquire
February 19, 1992
Page 4
In such cases as noted above, Section 3(j) of the Ethics Law
would require not only that you abstain from participation but
also publicly announce your abstention and the reasons for same,
both orally_andby filing a written memorandum to that effect
with the person recording the minutes.
In summary, the Ethics Law would restrict the following:
1. The use of authority of office t,- obtain any business
in a private capacity;
2. utilization of confidential information gained through
public position;
3. participating in discussions, reviews, or
recommendations on matters which relate to the business/private
employer which may come before the governmental body and in Such
cases publicly announcing the relationship or advising the
supervisor as well as filings written memorandum as per the
requirements of Section 3 of the Ethics Law. Brooks, Opinion
89 -023.
As for your concern that the County Commissioners are
responsible for approving the salaries of the Assistant District
Attorneys and various Court personnel with whom you would be
dealing in the private practice of law, absent any factual nexus -
between the setting of the salaries and your private practice,
such as, for example, improper understandings which would
transgress Sections 3(b) and/or 3(c) set forth above, the setting
of these individuals' -- salaries -in and of itself would not
constitute a conflict of interest for yoL.
It is necessary to clearly delineate the parameters within
which your inquiry has been addressed. Specifically, your
conduct has been addressed from the perspective of your capacity
as a public official - not from your perspective as an attorney
engaged in the private practice of law. Insofar as your 'inquiry
relates to your proposed conduct as a private attorney engaged in
the private practice of law, Section 3(a) . of the Ethics Law
cannot be applied to restrict that proposed activity. See,
Pennsylvania Public Utility Commission Bar Association v.
Thornburch, 6 Pa., Cmwlth. 88, 434 A.2d 1327 (1981), aff'd per
curiae, . Fa . 589:, 450: A. 2d 613 (1982) (interpreting former
Secttipn 3.(ej of: .ct 17'0 0 of. 1978) .
The PrePr .ety, of the proposed conduct has only been
addressed under the Ethics. Law; the app1ioability,;of' any other
statute, code, ordinance, regulation or other code of conduct-
Ms. Maryann Conway, Esquire
February 19, 1992
Page 5
Sincerely,
other than the 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 Rules of
'Professional "Conduct. It is recommended that questions regarding
your obligations under the 'Rules of Professional Conduct be
directed to the Ethics Committee of the Pennsylvania Bar
Association.
Conclusion: As a County Commissioner for Schuylkill County,
Pennsylvania, you are a public official subject to the provisions
of the Ethics Law. Section 3(a) of the Ethics Law would not
preclude you from outside employment /business activity such as
the private practice of law, subject to the restrictions and
qualifications as noted above. In the event that the
employer /business has matters pending before your governmental
body, then you could not participate in that matter and the
disclosure requirements of Section 3(j) of the Ethics Law as
outlined above must be satisfied. Section 3(a) of the Ethics
Law would not restrict your conduct insofar as it constitutes the
private practice of law. 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
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
Commission will be scheduled and a Opinion from the
Commission will be issued. Any such appeal,must be in writing
'and must be received at the. Commission within 15 days of the date
of this Advice pursuant to : Pa. Code 12.12.
Vincent J. ' Dopko
Chief Counsel
..71..44.