HomeMy WebLinkAbout92-627STATE ETHICS COMMISSION M '
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -14
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
September 18, 1992
Ms. Jean Swartwood 92 -627
Vernon Township Sanitary Authority
66 Jackson Avenue
Meadville, PA 16335
Re: Service, Township Supervisor, Township Sanitary
Authority, Recording Secretary /Bookkeeper/'Clerk for Authority.
Dear Ms. Swartwood:
This responds to your letter of August 11, 1992, in which you
requested advice from the State Ethics Commission.
- a-
Issue: - Whether the Public Official and Employee Ethics Law imposes
any prohibition or restrictions union a township sanitary
authority's recording secretary /bookkeeper /clerk from also holding
office as a township supervisor.
Facts: As" Authority Clerk for the Vernon Township Sanitary
Authority, you request an advisory regarding • any prohibitions or
restrictions placed upon you regarding your prospective
'simultaneous service as a Township Supervisor.
The Vernon: Township Sanitary Authority ( "Authority ") was
incorporated on September 26, 1961, in compliance with the
Municipality Authorities Act of 1945. The Authority constructed
two sewer systems in Vernon Township. The Authority .. executed an
Agreement of "Lease' with the Township Supervisors who subsequently
engaged and appointed the Authority to be General: Manager of the
systems. o
You advise that Article I, subsection (b) of the Management
'Agreement states, "the Authority shall employ and direct the work
of all persons required to operate' and maintain the system and
shall fix, determine and negotiate the rates of pay of such
persons." You state that y as authority Clerk, have no vote in
any decision making by the Authority. j; It appears that in addition
to acting as Clerk, you are the Recording Secretary and Bookkeeper
of the Authority.
You plan to run for the office of Township Supervisor, :and
Jean Swartwood
September 18, 1992
Page 2
specifically request an advisory from this Commission as to whether
any conflict would arise for you due to your serving, as an elected
Township Supervisor and as an Authority employee simultaneously.
Dis lion: If elected a Township Supervisor for Vernon Township,
you w3,11 be a "public official" as that term is defined in the
ethics Law and hence you will be subject to the provisions of the
Ethics Law. 65 P.S. 5402; 51 Pa. Code S1.1.
Section 3(a) of the Ethics Law provides: -
Sectio 3.est et¢,ci Acti viti e g.
(a) 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;
Sea n ;, pefinitions
"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 ; class consisting of the
genera, 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 monetary value and no public official /employee shall
Jean Swartwood
September 18, 1992
Page 3
solicit or accept anything of monetary value based upon the
understanding that the vote,' official action, or judgment of the
public official /employee would be influenced thereby.
Section 3(j) of the Ethics Law provide: as follows:
Section 3. Restricted activities.
(j) Where _ votinc 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 r -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 Enterest 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 11
permitted to vote if disclosures are made ._asl
otherwise provided herein. In the case of
three -member governing body of a poli alBz:, !ol .::1*
subdivision, where one member has absta4redf rig <
from voting as a result of a conflict of<0.,.e:i rtic:
interest,' and the remaining two members of the
governing body have cast opposing votee; a .
member who has abstained shall be perraitteki >to ': • s.: ��
vote to break the tie ` vote if disclosure.:
made as otherwise provided here, ,7- IC
If a : exists,- Section . i3 (j') ` 'requires the public
official /employee` to abstain .'and to publicly 'disclose the
abstention and reasons for saute, both orally and by filing a
written memorandum' to that effect with the person recording the
minutes or supervisor.
, 'It is initially noted that the Second Class Township Code at
53 P.S. §65410(b), specifically `enumerates 'the• limited townsh g
offices or .positions which' a supervisor may simultaneously hold'.
However, it is not clear '+hether "& position with a Township
Jean Swartwood
September 18, 1992
Page 4
Sanitary Authority, which has been duly .created under the
Municipality Authorities Act, 53. P.S. §301 et sea., and is a
separate goyrnmental body from the Board of Supervisors, would be
deemed to be a township position. It would be for_ a court, .rather
than for the $?hate Ethics Commission, to interpret the Second Class
Township Code s end /or the Municipality Authorities Act as they may
impact npon yogr inquiry. Thus, this Advice shall be limited to
interpreting the Ethics Law, and shall assume there are no contrary
restrictions under the Second Class Township Code and Municipality
Authorities Act. It is recommended thatLyou seek. the :advice of
legal counsel as to any restrictions, ,under the Second Class
Tonship Code and the Municipality Authorities Act.
r ^`
In applying the above provisions cif' .t 0 Ethics Law to the
question of sin } .taneous service, there does " - appear to be any
real possibility of a private pecuniary, benefit or inherent
conflict arising if you were to ,serve both -as. a Vernon Township
Sanitary Agthority - employee and as a .Township Supervisor.
Basi.ca 4y, the gthics Law does nots'tate that it is inherently
incompatible for a Township Supervis4 to serve or be employed as
a Township Sanitary Authority's Recording ,Secretary /Bookkeeper/
Clerk. The main prghibition under the_ thics Law and Opinions of
the Ethics Commission is that one may not serve the interests of
two persons, grogps, or entities whose in erests may be adverse.
Smith Opinion, 894410. In the,situation:outl above, you would
not sery n g entities with . which are.: adverse to each
other,
However, if a situation arises where or the respective
entities yeu represent develop an adverse illterest .then you must
remove yourself from that particular matter and fully satisfy the
disclosure requipements of Section 3(j) set.fgrth above. If such a
situation would arise, additional advice meype from the
Commission.
Lastly, the propriety of the proposed conduct has only been
addressed under the Ethics Law; the appiicsbaityof any other
statute, code, ordinance, regulation or other . codes of conduct other
than the Ethics Law has not been considered An that they do not
involve an interpretation of the Ethics LaW. Specifically not
a ddressee( herein j.s the applicability of the Second Class Township
Gede or the 4M49441itY Authorities Aot. It is recommended that
yo4 seek the advice of legal COunsel as to any restrictions under
tk99e 14WS. This Advige is condl.tiAned upon there being no contary
restrictions in Vile S econd Mass Township Code or Municipality
Authorities Act.
4Qeelus1ens If elected a Township $Upervisor for Vernon Township,
u A1,1 e a. 1 #41111c Official" $ub JeCt to the provisions of the
; tki4 Lew,F.. As . 4 pub-10 official, you may, consistent with Section
Jean Swartwood
September 18, 1992
Page 5
3(a) of the Ethics Law, siMultanedusly serve in the positions of
Vernon Township Supervisor and Recording Secretary /Bookkeeper /Clerk
for the Vernon Township Sanitary Authority. However, this Advice
is expressly conditioned upon there being no contrary restrictions
in the Second Class Township Code or Municipality Authorities Act.
It is recommended -that you seek theadvice of legal counsel as to
any restrictions under those laws. Lastly, the propriety of the
proposed course of condtct 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 materiall facts 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 dallenge 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:
Very truly yours,
Vincent J'J Dopko,
Chief Counsel
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