HomeMy WebLinkAbout92-554-SEdward M. Gallagher, Esquire
Gallagher '& Gallagher
18 East Second Street
P.O. Box 348
Media, PA 19063
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG. PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
April 29, 1992
92 -554 -S
Re: Conflict, Public Official /Employee, Township Supervisor, Use
of Authority Office or Confidential Information, Vote, Sewer
Extension, Sewer Line Construction by Township Employees,
Business with which Associated, Family Business Involving
Sewage Services, Sewer Line Hook -ups by Supervisor,
Supplemental Advice.
Dear Mr. Gallagher:
This responds to your letter of March 18, 1992, in which you
requested supplemental advice from the State Ethics Commission.
Issue: Whether the Public Official and Employee Ethics Law
presents any prohibition or restrictions upon a township supervisor
as to official action regarding the use of township employees to
undertake construction of a sewer extension, which extension has
been authorized by a joint authority, where the supervisor is
qualified and registered to perform services including sewer line
construction and a family business with which the supervisor is
associated services septic tanks, cesspools and on -site sewage
systems.
Facts: As legal counsel for Mr. Glenn Cockerham, a Supervisor in
East Whiteland Township in Chester County, Pennsylvania, you
request a supplemental advisory from the State Ethics Commission.
Following a letter of request of February 3, 1992, Advice of
Counsel 92 -554 was issued which is incorporated herein by
reference. Based upon the averments of fact submitted by Mr.
Cockerham, that Advice concluded that Mr. Cockerham would have a
conflict of interest as to any matters before the East Whiteland
Township Board of Supervisors pertaining to the proposed sewer
extension. Mr. Cockerham was advised that in each instance of a
conflict of interest, he would be required to abstain from any
participation of any nature whatsoever and to fully satisfy the
Edward M. Gallagher, Esquire
April 29, 1992
Page 2
disclosure requirements of Section 3(j).
Following the issuance of Advice 92 -554, you undertook
representation of Mr. Cockerham and have requested a supplemental
advisory on his behalf in light of revised facts, or in the
alternative, an appearance before the Commission.
You now advise that certain statements in Mr. Cockerham's
letter of inquiry dated February 3, 1992, are incorrect. You state
that pursuant to the Municipality Authorities Act of 1945, 53 P.S.
5301, et sea., it is the Joint Authority rather than the Township
Board of Supervisors which has the legal power to decide whether to
undertake the sewer extension. You affirmatively represent that
the decision to undertake the sewer extension is not made by the
Township Board of Supervisors. Accordingly, you state that Mr.
Cockerham's letter of February 3,. 1992 is in error when he
discusses his role in deciding whether the extension would occur
since this is not his decision to make as a Township Supervisor.
In this regard, it is noted that in various telephone
conversations, Assistant Counsel for the Commission was informed
that the Township Board of Supervisors have voted upon a matter
consisting of a conglomeration of the following two issues:
1. Whether to ratify the decision of the Authority to
approve the proposed sewer extension; and
2. Whether to use township employees to do the work.
Assistant Counsel was also informed that Mr. Cockerham took part in
this matter.
You specifically acknowledge that there has been and may
continue to be discussion and formal action taken by the Township
Supervisors regarding whether the Authority could hire Township
employees to undertake construction of the sewer line extension.
You state that since Mr. Cockerham has nothing to do with the
decision regarding the undertaking of the sewer line expansion, it
does not seem that there would be any conflict of interest
regarding his participating in decisions concerning the use of
Township employees. You seek advice on this issue.
You confirm that Mr. Cockerham's business deals primarily with
cleaning on -site septic tanks and cesspools and maintenance and
repair of on -site systems. However, you affirmatively represent
that Mr. Cockerham's company is not involved in the type of work
required for sewer line extensions and that Mr. Cockerham would not
under any circumstances be interested in participating in this type
of work. Furthermore, you acknowledge that a small part of Mir.
Cockerham's business does involve the lateral "hook -ups" wherein a
Edward M. Gallagher, Esquire
April 29, 1992
Page 3
private property owner taps into a municipal sewer line. However
you state that Mr. Cockerham in his capacity as a Township
Supervisor has done nothing to increase or enhance this small part
of his business.
You conclude by stating your opinion that since the Township
did not decide to expand the sewer system, there is no conflict of
interest by Mr. Cockerham continuing to function as a Township
Supervisor under the circumstances as you have submitted them.
Based upon all of the above, a supplemental advice has been
requested.
Discussion: It is initially noted that your request for a
supplemental advisory .may only be addressed with regard to
prospective conduct. To the extent that Mr. Cockerham may already
have :taken action in his official capacity, through reported
"ratification" of the action of the= Joint Authority, such past
conduct would be beyond the scope of an advisory and may not be
addressed.
As a Township Supervisor for East Whiteland Township in
Chester :County, Pennsylvania, Mr. Glenn Cockerham is •a public
official as that term is defined under the Ethics Law, and hence he
is subject to the provisions of that law.
The relevant provisions of the Ethics Law which would be
applicable in this matter have already been fully set forth in
Advice 92 -554 and are incorporated herein by reference. They will
not be repeated, but rather," the focus of this supplemental Advice
shall be directed toward the narrow issues which you have raised in
light of the erroneous statements previously submitted to thif
Commission as "facts."
Based upon your affirmative representations and assurance; to
this Commission that it was the Joint Authority, rather than the
East Whiteland Township Board of Supervisors, which had the legal
power to decide whether to undertake the proposed sewer extension;
that the Township Board of Supervisors and specifically Mr.
Cockerham have nothing to do with that decision; and further that
Mr. Cockerham's business is not involved in the type of work
required for sewer line extensions and that he would not under any
circumstances "be interested" in participating in this type of
work, from which it is assumed that neither Mr. Cockerham, any of
hisinmediateiy family members, nor the .company itself would so
participate, Mr. Cockerham would not have a conflict of interest
Under the Ethics prospective matters before the Board of
Supervisors as to - whether the Authority could hire Township
employees to undertake construction of the sewer line expansion.
Edward M. Gallagher, Esquire
April 29, 1992
Page 4
-As for the lateral hook -ups, whereby a private property owner
taps into - a municipal sewer line, you have specifically represented
and assured this Commission that Mr. Cockerham in his capacity as
a Township Supervisor has done nothing to increase or enhance this
small part of his business. Therefore, based upon your
representations and assurances, you are advised as to Mr. Cockerham
that Section 3(a) of the Ethics Law does not apply to restrict a
public official in his purely private business pursuits, but rather
only applies to restrict the conduct of a public official where
that conduct is in his official capacity.
It is parenthetically observed that this matter has been a
reprehensible example of how the advisory process should not be
used . Although the Commission recognizes and fulfills the
statutory duty of providing written advisories to persons who
truthfully -disclose all of the material facts pertaining to their
request, the intended process has, in this case, been undermined
from its inception through the submission of erroneous, misstated
"facts which -not surprisingly - resulted in the pointless
issuance of the prior Advice. An Advice is only as good as the
facts upon which it is based.
The extensive time and resources expended by this agency in:
issuing the prior Advice, which was at best an academic exercise;
issuing this supplemental Advice; handling the numerous informal
inquiries from the public and press as well as Mr. Cockerham and
attorneys, have largely been a waste of limited resources allocated
to this Commission and funded by taxpayers, which would have been
better spent pursuing legitimate purposes under the Ethics Law.
See, Swick/Aman, Opinion 91 -006, where the full Commission rebuked
such avoidable waste.
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 not addressed
herein is the applicability of the Second Class Township Code.
Conclusion: As a Township Supervisor for East Whiteland
Township in Chester County, Pennsylvania, Mr. Glenn Cockerham is a
public official subject to the provisions of the Ethics Law. Based
upon the facts as they have been submitted in the supplemental
request for an advisory, and conditioned upon the affirmative
representations and assurances made to this Commission as noted
above, Mr. Glenn Cockerham would not have a conflict of interest in
prospective matters before the Board of Supervisors regarding
whether the Joint Authority could hire Township employees to
undertake construction of the sewer line extension. 4ection 3
of the Ethics Law would not apply to restrict Mr. Cocks am as to
Edward M. Gallagher, Esquire
April 29, 1992
Page 5
purely private business pursuits such as installing lateral hook-
ups, but - rather applies to Mr. cockerham's conduct in his official
capacity. 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 has disclosed truthfully all
the material facts and committed the acts complained of in reliance
on the Advice given.
such.
This_ietter 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 request .. that the full Commission
review this Advice. A personal appearance before the Commission
will be scheduled and a formal 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 51 Pa. Code 52.12.
ncerely,
Vincent . Dopko
Chief Counsel