HomeMy WebLinkAbout494 SalvatoreHonorable Frank Salvatore
Senate of Pennsylvania
Commonwealth of Pennsylvania
14219 Barcalow Street
Philadelphia, PA 19116
Re: 84 -133 -C
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ORDER OF THE COMMISSION
June 20, 1986
Order No. 494
Dear Senator Salvatore:
The State Ethics Commission has received a complaint regarding you and a
possible violation of Act 170 of 1978. The Commission has now completed its
investigation. The individual allegations, conclusions, and findings on which
those conclusions are based are as follows:
I. Allegation: That you, as a member of the Pennsylvania House of
Representatives, violated Section 3(a) of the State Ethics Act, 65 P.S.
403(a), which prohibits the use of public office or confidential information
gained through that office by a public official or public employee when you
distributed campaign literature and taxpayer - funded literature as part of your
campaign for the Pennsylvania Senate.
A. Findings:
1. You served as a member of the House of Representatives of the Commonwealt),
of Pennsylvania from 1973 to January 1985 and, as such, are a "public
official" subject to the Ethics Act.
2. You sought election to the Serrate of the Commonwealth of Pennsylvan
running in the May, 1984 primary and the November, 1984 general election by
a. You were elected and currently serve in the Fifth Senate District o;"
Pennsylvania.
3. During March and April, 1984, a letter entitled "Salvatore for Senate" was
distr-i buted door -to -door.
Honorable Frank Salvatore
June 20, 1936
Page 2
a. The "Salvatore for Senate" letter head contained the following:
Salvatore for Senate Committee
316 Ruxmont Street, Philadelphia, PA 19116
Mort 0orl1ck /Co- Chairmen /George Costello
John Eagan, Finance Chairman /Edith Kitchin, Treasurer
It also had a phone number - 215- 464 -4480 on it.
4 . According to your attorney, taxpayer funded literature was distrihuted
around July, 1984.
a. "Your Guide to the State Sales Tax and Non - Taxable Items" contained
the Hnrrse a Representatives seal, your district office and
Harrishurg office addresses and phone numbers on it.
h. "A Guide to Philadelphia Services" also contained your district
office and Harrishurg addresses and phone numbers on it.
5. You also distributed a letter dealing with legislative action on the state
lottery.
a. This letter contained the House of Representatives letter head and
your district and Harrisburg addresses and phone numbers.
h. It did not appeal for political support, discuss political issues or
opponents.
6. nn March 7, 1986, your Attorney, Richard H. Glanton, wrote to Edward M.
Seladones, Executive Director of the State Ethics Commission, and stated the
following:
a. He was submitting information that he believed would cause a
conclusion that the complaint was without merit and make an interview
with you unnecessary.
h, You distrihuted campaign material paid for hy your campaign
committee to residents of the senatorial district for which you were
a candidate.
c. Yon did not use state personnel , equipment or funds in this effort.
d. Section 3(a) of the Ethics Act does not restrict communications
hetween voters and their elected officials unless the relationship is
used for "personal financial gain restricted hy the Act itself ".
e.
That, the distrihution of taxpayer- funded literature is governed hy
House rules which provide:
Honorahle Frank Salvatore
June 20, 1986
Page 3
"Such allowable expenses of members may be used for any
legislative purpose or function, including hut not
limited to the following:
(3) Rent for legislative office space; purchase of office
supplies; postage; telephone and answering services;
printing services and rental only of office equipment;
voucher and vendor's receipt, except for postage expense.
No reimbursement or expenditure shall be made out of any
appropriation account for any mass:_ mailing including a
hulk -rate mailing made at the direction or on behalf of
any member which is mailed or delivered to a postal
facility within sixty (60) days immediately preceding any
primary or election at which said member is a candidate
for public office.
Mass mailing shall mean a newsletter of similar
mailing of more than fifty (50) pieces in which the
content of the matter is substantially identical. Nothing
in this rule shall apply to any mailing which is in direct
response to inquiries or requests from persons to whom
matter is mailed, which is addressed to colleagues in the
General Assemhly or other governmental officials or which
consists entirely of news releases to the communications
media." (emphasis supplied).
(1) That the taxpayer funded literature was "prepared by your
legislative staff, deals with relevant legislative issues, does
not appeal for political support, discuss campaign issues, nor
refer to political opponents ".
(2) That a mailing to "potential constituents in the legislator's (new)
district, or more aptly stated, non- constituent at the time of the
mailing does not automatically determine that the mailing is a
non - official one ".
(3) That most of the mailings were made in July, 1984 and months before
the Novemher election.
H. Discussion:
Section 3(a) of the Ethics Act prohibit s the use of puhlic office for
personal financial gain.. See 65 PeS. 403(a). A legislator may not use his
office or, in this case, puhlic money which is to he expended only for
"legislative" purposes to secure or primarily advance his own personal goal or
re- election. A legislator, however, when running for re- election cannot he
Honorable Frank Salvatore
June 20, 1986
Page 4
restrained because of Section 3(a) of the Ethics Act from performing his
official or legislative business during the campaign. The question can be
reduced to simply whether or not the activity (mailing -or printing) in
question constitutes "official business" of the member. If not, then the
activity amounts to using the public purse to finance purely personal efforts
and violates the Ethics Act. See, McClatchy, No. 130; Rappaport, No. 129.
In the current situation, we have_ been called upon to review the
distribution of certain-:-items as, follows:
1. letter entitled Salvatore for Senate
2. two Guides to Services
3. letter regarding the State Lottery
With relation to the first item listed above, it is noted that while that
material was specifically related to your re- election efforts, such material
was paid for with private funds. No public funds, personnel or facilities
were employed regarding the printing and distribution of that item.
Similarly, the guides listed in item two above, while printed at public
expense, do not - appear to have been used in relaton to the re- election
activities. Members of the General Assembly are authorized, pursuant to the
law, to print and distribute this type of material to their constituents.
There is no evidence-that these items were used as part of your door -to -door
campaign activities. Absent such evidence, we do not believe that there has
been any violation in relation to the State Ethics Act.
The final item to be reviewed is the letter regarding the State Lottery.
This letter, while containing the House of Representatives letter head and
your district office locations, did not appeal for any political support and
did not reference to your campaign. Generally, i n reviewing similar
situations, we have employed the folIowi ng criteria in analyzing whether a
mailing or distribution is for non - legislative purposes:
1. What per -cent of the mailing can be said to be clod :rated to "other
matters which strongly lends itself to the suspicion that it is
promotive of getting votes for the sender? In Rising v. Brown, 313
F. Supp. 824 (D. C. Cal. 1970) a 50% rate of such material was
involved. It is also notable that in Rising, the mailing was
prepared by the same Public Relations firm which was managing the
legislator's election campaign. In Rising, the court concluded the
"franki ng" privilege had been abused.
2. What was the main content matter of the mailings' written ..porti.ons?
Honorable Frank Salvatore
June 20, 1986
Page 5
a. Did it include appeals for political support?
b. Did it refer to what a member expects to do in the next
session?
c. Did it discuss the upcoming political campaign /contest?
d. Did it refer to political opponents?
e. Can it reasonably be said to relate to legislative
responsibilities.
f. Can mailing be viewed as one designed primarily to advance
electoral prospects? See Schaiffo v. Helstoski, 492 F.2d 413
(3rd Cir. 1974).
3. How extensive was the mailing? Examine total copies and
distribution. In Hoellen v. Annunzio, 468 F.2d 522 (7th Cir. 1972),
cert. den. 93 S. Ct. 3001, 412 U.S. 953, a total mailing of 134,000
copies was sent; 100,000 to potential constituents and 34,000 to
old constitutents (defendant was serving representative in 7th
District, running for seat in 11th District). The Court found
34,000 copies were properly "franked" as official business but
100,000 were for the purpose of advancing candidacy and, therefore,
not properly "franked."
4. When was mailing made? In Rising, supra, a massive state -wide
mailing two weeks prior to election was sanctioned.
In the instant situation, we believe that the "lottery letter" was a
proper mailing under the above criteria. That letter informed constituents of
recent legislative actions in relation to the lottery. It did not appeal for
support or otherwise mention any election.
I t did not set forth any future plans and was issued mainly as a result
of requests for information.
As such, we do not believe that there has been any violation of the State
Ethics Act.
Finally, we note that we have recently issued an advice in relation to
similar activity which generally outlines the permissible scope of an
official's actions in similar matters. In relation to election campaign
activities, we have determined that:
1. Use of the Commonwealth seal; the House of Representatives
letterhead, and official title is permitted.
Honorable Frank Salvatore
June 20, 1986
Page 6
2. All stationery containing the aforementioned items should set forth a
disclaimer indicating that the stationery is not official
Commonwealth stationery and has heen paid for with private funds.
3. An official may not use the address of the Commonwealth offices,
legislative offices or legislative phone numbers as campaign contact
points.
4. The purchase of the stationery in support of a campaign should not be
made through the House of Representatives and an official may not
take advantage of any special rates accorded to the House of
Representatives by any printing company for the purchase of
Commonwealth supplies.
5. An official may not use the House mails or postage for dissemination
of this material.
6. Finally, the content of the letter should not indicate or leave the
impression that the letter is an official governmental document or
part of the legislative function. Fee, 86 -542.
C. Conclusion:
There was no violation of the State Ethics Act as there is no evidence
that you used Commonwealth funds to print or distrihute re- election campaign
materials. There was also no evidence that the distribution of items paid for
with public funds was for campaign purposes.
Our files in this case will remain confidential in accordance with
Section 8(a) of the Ethics Act, 65 P.S. 408(a). However, this Order is final
And will he mad; available as a public document 15 days after service (defined
as mailing) unless you file documentation with the Commission which justifies
reconsideration and /or challenges pertinent factual findings. See 51 Pa. Code
2.3R, During this 15-day period, no one, including the Respondent unless he
waives his right to challenge this Order, may violate this confidentiality by
releasing, discussing or circulating this Order.
Any person who violates the confidentiality of a Commission proceeding
is guilty of a misdemeanor and shall he fined not more than 51,000 or
imprisoned for not more than one year or both, see 65 P.S. 409(e).
Ry the Commission,
G. Sieher Pancoast
Chairman