HomeMy WebLinkAbout21-555 Mosca
PHONE: 717-783-1610 STATE ETHICS COMMISSION FACSIMILE: 717-787-0806
TOLL FREE: 1-800-932-0936 FINANCE BUILDING WEBSITE: www.ethics.pa.gov
613 NORTH STREET, ROOM 309
HARRISBURG, PA 17120-0400
ADVICE OF COUNSEL
October 12, 2021
To the Requester:
Thomas J. Mosca, Esquire
21-555
Dear Attorney Mosca:
This responds to your correspondence dated October 6, 2021, by which you requested an
advisory from the Pennsylvania State Ethics Commission (Commission), seeking guidance as to
the issue presented below:
Issue:
Would the Public Official and Employee Ethics Act (Ethics Act), 65 Pa.C.S. § 1101 et seq.,
place any restrictions upon the Township serving as the location of a County Board of
Elections Ballot Drop Box?
Brief Answer: NO. The Ethics Act is not implicated in the above situation since there is
no reason to believe, or factual basis to support, that a transgression of the Ethics Act would
occur by the Township serving as the location of a County Board of Elections Ballot Drop
Box.
Facts:
You serve as the Solicitor for Dallas Township, Luzerne County, Pennsylvania. You have
been authorized by the Board of Supervisors to request an advisory opinion as to the applicability
of the Pennsylvania Public Official and Employee Ethics Act (65 Pa.C.S.§1101 et seq.) should the
Township serve as the location of a County Board of Elections Ballot Drop Box. At a Regular
meeting of the Township Board of Supervisors, the Chairperson of the Luzerne County Board of
Elections requested the Township host a Ballot Drop Box, to be placed in the lobby of the
Township municipal building on October 19, 2021. The Ballot Drop Box will be in serve as a
depository for ballots concerning the November 2, 2021 election. The Pennsylvania Department
of State provides, in part, the following concerning Ballot Drop Boxes: \[v\]oters may return their
mail-in or absentee ballot at their county election boards designated drop box(es) or drop-off
Mosca, 21-555
October 12, 2021
Page 2
location. Ballots must be dropped off before 8 p.m. on election day. See
https://www.vote.pa.gov/Voting-in-PA/pages/drop-box.aspx.
Additionally, the Supervisors note that a State Representative leases space within the
municipal building; and one of the Dallas Township Supervisors is presently running for re-
election during the November 2, 2021 election.
Discussion:
It is initially noted that pursuant to Sections 1107(10) and 1107(11) of the Ethics Act, 65
Pa.C.S. §§ 1107(10), (11), advisories are issued to the requester based upon the facts that the
requester has submitted. In issuing the advisory based upon the facts that the requester has
submitted, the Commission does not engage in an independent investigation of the facts, nor does
it speculate as to facts that have not been submitted. It is the burden of the requester to truthfully
disclose all of the material facts relevant to the inquiry. 65 Pa.C.S. §§ 1107(10), (11). An advisory
only affords a defense to the extent the requester has truthfully disclosed all of the material facts.
Section 1103(a) of the Ethics Act reads:
§ 1103. Restricted activities
(a) Conflict of interest.--No public official or public
employee shall engage in conduct that constitutes a conflict of
interest.
65 Pa.C.S. §§ 1103(a).
Furthermore, the following terms pertaining to conflicts of interest pursuant the Ethics Act
are defined as follows:
§ 1102. 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 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.
The term 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
Mosca, 21-555
October 12, 2021
Page 3
performance of duties and responsibilities unique to a particular
public office or position of public employment.
65 Pa.C.S. § 1102.
Subject to the statutory exclusions to the Ethi
is prohibited 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. The use of authority of office is not limited merely to voting but extends to
any use of authority of office including, but not limited to, discussing, conferring with others, and
lobbying for a particular result. Juliante, Order 809.
Conclusion:
Having established the above general principles, you are advised that as stated the facts
do not implicate a use of office by a public official/public employee in furtherance of a pecuniary
benefit. There is no reason to believe, or factual basis to support, that a transgression of the Ethics
Act would occur solely by the Township serving as the location of a County Board of Elections
Ballot Drop Box.
Lastly, the propriety of the proposed conduct has only been addressed under the Ethics Act.
Pursuant to Section 1107(11) of the Ethics Act, an 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, provided the requester 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 appeal the Advice to the full Commission. A personal appearance before the Commission
will be scheduled and a formal Opinion will be issued by the Commission.
Any such appeal must be in writing and must be actually received at the Commission within
thirty (30) days of the date of this Advice pursuant to 51 Pa. Code § 13.2(h). The appeal may be
received at the Commission by hand delivery, United States mail, delivery service, or by FAX
transmission (717-787-0806). Failure to file such an appeal at the Commission within thirty (30)
days may result in the dismissal of the appeal.
Respectfully,
Brian D. Jacisin
Chief Counsel