HomeMy WebLinkAbout92-558Edwin W. Tompkins, III, Esquire
Tompkins & Tompkins
P.O. Box 31
Emporium, PA 15834
Dear Mr. Tompkins:
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
March 18, 1992
92 -558
Re: Conflict, Public Official /Employee Township Supervisor,
Township Paid Benefits, Life Insurance, Cash Surrender Value
to the Insured.
This responds to your letters of January 23, 1992 and February
6, 1992, 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 second class township
supervisors with regard to authorizing the township to purchase
life insurance policies for all current employees including the
supervisors, where the township would own the policies, the
employees would designate their beneficiaries, and the policies
would be cashed in at retirement or discharge with the cash
surrender values belonging to the insured.
Facts: As Solicitor for the Shippen Township Board of Supervisors,
you seek the advice of the State Ethics Commission on behalf of all
three Members of the Board of Supervisors.
Shippen Township is a Second Class Township located in Cameron
County. Approximately 16 years ago, a pension plan was developed
and instituted on behalf of all Township employees, including the
Supervisors. When the plan was first initiated, monies from said
pension plan were also used to purchase life insurance policies on
behalf of each employee, with each policy having a cash surrender
value.
You state that the practice of purchasing life insurance
policies for employees by utilizing funds earmarked for the pension
plan was discontinued some time ago. The Township now finds itself
in a position where certain long -time employees have existing life
insurance policies, but certain newly hired employees have no such
Township sponsored life insurance policies.
Edwin W. Tompkins, III, Esquire
March 18, 1992
Page 2
You state that on the advice of a representative of the
Department of the Auditor General, the Township is presently taking
steps to return all of the existing life insurance policies (the
Township being the owner of all of said policies, with each
employee designating beneficiaries on same), and once cash
surrender value is received from the carrier, such monies will be
placed into the existing pension fund for existing employees, and
one retired employee will receive the cash surrender value.
Having provided the above historical background, you state
that the question which has arisen and which is the purpose of your
inquiry, is whether the Board of Supervisors can legally and
ethically take action, by ordinance or resolution in the near
future, authorizing the Township to purchase new policies for all
current employees (including the Supervisors) so that the newly
hired employees and the long -time employees will be assured of
equal benefits. If proper, the Township intends to purchase the
new policies utilizing Township funds, with the Township being the
owner of the policies, the employees designating beneficiaries of
their choice, and with the intent that said policies will be cashed
in at time of retirement or discharge of any employee with the
respective cash surrender value going to the employee affected.
Based upon all of the above, you request an advisory as to the
propriety of the above proposed action in light of the Second Class
Township Code, this Commission's Rules and Regulations, and any
other laws applicable to this scenario.
Discussion: It is initially noted that your request for advice may
only be addressed with regard to prospective conduct. A reading of
Sections 7(10) and (11) of the Ethics Act makes it clear that an
opinion /advice may be given only as to prospective (future)
conduct. If the activity in question has already occurred, the
Commission may not issue an opinion /advice but any person may then
submit a signed and sworn complaint which will be investigated by
the Commission if there are allegations of Ethics Law violations by
a person who is subject to the Ethics Law.
As Supervisors for Shippen Township in Cameron County,
Pennsylvania, each of the three Shippen Township Supervisors is a
public official as that term is defined under the Ethics Law, and
hence each Supervisor is subject to the provisions of that law.
Section 3(a) of the Ethics Law provides:
Section 3. Restricted Activities.
Edwin W. Tompkins, III, Esquire
March 18, 1992
Page 3
(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 employee of the
authority of his office or employment or any .
confidential information received through his
holding public office or employment fot 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 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 necessary to the performance of
duties and responsibilities unique- to a
particular public office or position of public
employment.
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 monetaty value and no public official /employee "shall
solicit or 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 reviewing the question posedf this Advice is limited to
whether the Supetvisors may receive these benefits under the Ethics
Law. Although this ComIiission would hot have the express statutory
jurisdiction to intetp'et the Second Class TeWhship Code, it is
Edwin W. Tompkins, III, Esquire
March 18, 1992
Page 4
necessary in this case to review 53 P.S. §65515 to the extent that
it impacts upon the Ethics Law regarding the issue of whether the
Supervisors would be using the authority of office to obtain a
private pecuniary benefit for themselves.
The Second Class Township Code provides for participation by
supervisor- employees in insurance plans as follows:
(1) Supervisor- employes and their
dependents shall be eligible for inclusion in
group life, health, hospitalization, medical -
service and accident insurance plans paid in
whole or in part by the township. No policy
of group life insurance shall contain any
provision for the accrual or de- ferral of a
cash surrender value, loan value or any other
nonforfeitable benefit, in addition to or
beyond the face amount of insurance, that
shall inure to the benefit of the supervisor, .
any beneficiary or any other individual having
an insurable interest in the life of a
supervisor. Such insurance, however, may
contain a provision that when the insurance,
or any portion of it, on a person covered
under the policy ceases because of termination
of employment or the termination of the
insured's term of office, such person shall be
entitled to have issued to him by the insurer,
without evidence of insurability, an
individual policy of insurance on any form
customarily issued by the insurer at the age
and for the amount applied for if: (i) such
amount is not in excess of the amount of life
insurance which ceases because of such
termination; and (ii) the application for the
individual policy is made and first premium is
paid to the insurer within thirty -one days
after such termination. Participation by
supervisor- employes shall not require auditor
approval. Supervisor- employes eligible for .
inclusion in such plans must meet the -same
requirements _as.other employes of the township
who are eligible to participate in an
insurance plan._ Such plans shall not
improperly _discri ninate in favor of a
$upervisor eiaploye .
53 P.S. S65515(d)(1) (Emphasis added
Edwin W. Tompkins, III, Esquire
March 18, 1992
Page 5
It is clear that on the face "of. the above provision that in
order for a Shippen Township. Supervisor to participate in a
Township paid life insurance plan, the Supervisor must `be a
Supervisor- employee and must meet the same requirements as other
employees of the Township who are eligible to participate in such
an insurance plan. There must be no discrimination in favor of
supervisor - employees.
It is further clear on the face of the above provision of the
Second Class Township Code that the type of life insurance in which
Supervisor - employees and their dependents are eligible to
participate is group life ins urance . There does appear to be
any authorization in the Second Class Township Code for any other
type of township paid life insurance for Supervisor - employees and
their dependents.
Finally, the above provision of the Second Class Township 'Code
clearly prohibits any provision in such a group life insurance
policy for the accrual or deferral of a cash surrender value, loan
value, or any other nonforfeitable benefit, in addition to or
beyond the face amount of insurance, inuring to the benefit of the
supervisor, any beneficiary, or any other individual having an
insurable interest in the life of a Supervisor.
In considering the above provision to the extent that it
impacts upon the Ethics Law, Section 3(a) of the Ethics Law,
prohibits the use of 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.
Section 3(a) of the Ethics Law would not prohibit the Shippen
Township Supervisor - employees and their dependents from
participating. in Township paid group life insurance policies which
would conform to the express requirements of 53 P.S. §65515.
However, you state that such policies would be cashed in at the
time of retirement or discharge of any employee with the respective
cash surrender values going to the employee affected. In the case
of Supervisor- employees, such a proposed arrangement would not
conform to the clear requirements of 53 P.S: S65515(c)(1).
Therefore, Section 3(a) of the Ethics Law would prohibit the
Shippen Township Supervisors from authorizing the Township to
purchase insurance policies which the Supervisors could cash in.
You may wish to review Hoak, Order 128, and McCutcheon,
Order No. 129, involving supervisors who received the cash
surrender value of life insurance - policies to which they were not
entitled under the Second Class Township Code. See, McCutcheon v.
Eddizi W. Tompkins, It1, Esquire
March 18, 1992
Page 6
Com. State Ethics` Com'n 77 Pa. Cmwlth 529, 466 A.2d 283 (1982)
(affirming these Orders of the Commission).
A postscript is necessary so that this Advice is not
misconstrued. First, as noted above, the Commission's jurisdiction
is limited to interpreting the provisions of the Ethics Law.
Therefore, although you sought an advisory in light of the Second
Class Township Code, the Commission's Rules and Regulations, and
other laws applicable to the scenario you posed, this Advice does
not and cannot offer any interpretation as to whether the proposed
conduct would violate other laws such as the Second Class Township
Code.
Secondly, this Advice expressly does not address action by
these Supervisors to return all of the existing life insurance
policies and deposit the cash surrender value for same into the
existing pension fund. The question of the legality of such a
practice would be determined within the parameters of some law
other than the Ethics Law. The Ethics Law would only be implicated
to the extent that a public official /public employee would use the
authority of office to obtain a private pecuniary benefit to
himself where in this case such private pecuniary benefit received
would be contrary to the express requirements of the Second Class
Township Code, 53 P.S. §65515.
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.
Conclusion: As Township Supervisors for Shippen Township in
Cameron County, Pennsylvania, each Shippen Township Supervisor is
a public official subject to the provisions of the Ethics Law.
Section 3(a) of the Ethics Law would not prohibit the authorization
of Township paid group life insurance policies in which the
Supervisor - employees and their dependents would participate, as
long as those policies conformed to the requirements of 53 P.S.
§65515. Section 3(a) of the Ethics Law would specifically prohibit
the Supervisors from using the authority of office to obtain a
private pecuniary benefit for themselves where such private
pecuniary benefit received would be contrary to the express
requirement of the Second 'Class Township Code, 53 P.S. S65515.
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
Edwin W. Tompkins, III,, Esquire
March 18, 1992
Page 7
proceeding, providing the requester. has disclosed truthfully all
the material facts and committed the acts complained of in .reliance
on the Advice given.
such.
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 request that the fizil 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 §2.12.
Vincent . Dopko
Chief Counsel
GL