HomeMy WebLinkAbout882 RobinsonSTATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
In Re: Gerald Robinson File Docket: 92- 060 -C2
: Date Decided: May 6, 1993
Date Mailed: Mav 11, 1993
Before: James M. Howley, Chair
Daneen E. Reese, Vice Chair
Roy W. Wilt
Austin M. Lee
Allan M. Kluger
The State Ethics Commission received a complaint regarding a
possible violation of the State Ethics Act, Act 9 of 1989, 65 P.S.
§401 et secs. Written notice, of the specific allegation(s) was
served at the commencement of the investigation. A Findings Report
was issued and served, upon completion of the investigation, which
constituted the Complaint by the Investigation Division. An Answer
was filed and a hearing was held. The record is complete. This
adjudication of the Commission is hereby issued which sets forth
the individual Allegations, Findings of Fact, Discussion,
Conclusions of Law and Order
This adjudication is final and will be made available as a
public document fifteen days after- issuance. However,
reconsideration maybe requested which will defer public release of
this adjudication pending action on the request by the Commission.
A request for reconsideration, however, does not affect the
finality of this adjudication. A reconsideration request most be
received at this Commission within fifteen days of issuance and
must include a detailed explanation of the reasons as to why
reconsideration should be granted in conformity with 51 pa. Code
52.38.
The files in this case will remain confidential in accordance
with Act 9 of 1989, 65 P.S. §408(h) during the fifteen day period
and no one unless the right to challenge this Order is waived, may
violate confidentiality by releasing, discussing or circulating
this Order. However, confidentiality does not preclude discussing
this case with an attorney at law.
Any person who violates confidentiality of the ,E,tlii,cs Act is
guilty of a misdemeanor subject to a fine of not more than $1,000
-or imprisonment for not more than one year,. 6 P . -S . , 541 (e) .
Robinson, 92- 060 -C2
Page 2
I. E TION:
That Gerald Robinson, a member of the Water Authority ter , the
Borough of Newport, Perry County, violated the €dllowing prob4 Lehs
of the State Ethics Act (Act 9 of 1989) when he used the Mhthe
of his position to obtain compensation hat provided fof by lAW by
participating in the decision to !et compensation fof hie sef"r° rice
on the Authority.
Section 3. Restricted Activities
(a) No public official or ptiblie
employee shall engage in Conduet that
constitutes a conflict of interest. 65 P.t.
5403(a).
Section Definitions
"Conflict" or '` cenf li€t of ithtefest.
Use by a public official or public efpleyee at
the authority of his office cr efiiployffleht or
any confidential iiif ormatiOn received thfa1i fl
his holding public office of ernplbyfneht fef
the private pecuniary benefit 6f himseif, a
member of his immediate family dr a busiheess
with which he or a member Of his imMediate
family is associated. "Conflict" or "oonfliot
of interest" doers not ineltude ah action having
a de minimis economic impact or which affe'ets
to the same . degree a class C€>nsisting of the
general public or a subclass consisting of an
industry, occupation or other gfcup which
includes the public Official Or public
te
employee, a mr of his immedia fay ly of
a business with which he or a mesbei 6f hat
immediate family is associated. 65 P.S. S402 .
II. FIItMO:
A. PLEADINGS':
1. Gerald Robinson has served. as a measber of the ifetopdtt Bo ±®tqh
Water Authority for fort y=am`s:
2. The members of the Newport 1 orOugn fiatee Atthoti-ty ere
appointed by the Newport Cdundi e
3.. The Newport Borough Council • tievt at 'ed cbitipensittion for
members' of the Water Authority.
4. In early 1991, the memb.rs of the Autrhogi began d sciissi iig
Robinson, 92- 060 -C2
Page 3
the issue of compensation for Authority members.
5. The Authority Secretary was instructed to determine the
average amount of member's water bill and report back to
the Authority members with . the information.
a. This action was not approved at any Authority meeting
since instructing an employee to carry out an assigned
task . required no formal action.
6. At the April, 1991 meeting of the Authority, board members
decided not to pay their water bills as compensation for their
work.
a. The members decided to begin the compensation by not
paying their second quarter of 1991 water bill.
(1) Robinson classifies the above as a water bill
forgiveness by action of the board officers.
b. Robinson asserts that some form of compensation was
-e, appropriate in order to offset the increasing duties of
the officers.
(1) To minimize the financial impact it was agreed to
accept the water assessment of the combined water
and sewer billing since the water production and
delivery was a lesser expense to the Authority.
7. The discussions and the decision on the compensation were not
recorded in the minutes of the Water Authority meetings.
8. The minutes of the January 14, 1991, Water Authority meeting
indicate Steve Flickinger was elected Chairman, Jerry Robinson
was elected Vice Chairman, and James Shiek was elected
Secretary /Treasurer.
9. The minutes of the January 13, 1992, Water Authority meeting
do not reflect a Chairman, Vice Chairman, Secretary or any
other officer being elected or appointed.
a. No change in the makeup of the Authority board occurred.
10. Minutes of the June 8, 1992, Water Authority meeting confirm
that _a discussion ensued among members of .he Authority that
since the second quarter of 1992, the water.. . pert' on of
Authority members water and sewer bills- had, waiyed as an
incentive to serve on the Water Authority.
a. Members 'discussed provisions of , tfe Municipal Code and
indicated that borough council sets remuneration for
Robinson, 92=060-C2
4
1 1.
b. Based on the discgggion, a
Amsler, secg4ed by Jim Shicis
of the AuthffitY
remuneration Motion carried
No gbstentiong -rioted.
c,
b.-
b,
members of a W9PsIng Agthority, but the Aut.hority Pets
remuneration fpr officers of the working Authogity,
motien WeS 0 49 1 e OY Dick
to waive 7 el4ter pgrtion
water WI Sewer biii es
• Neater Robinson present,
The minutes also indicate the following gppointmepts #g
officers of the Agthority:
Chairman:
Vice PIO-rms./
Ile
gecretafyi
ASsistant §gcEetary/TFegsurer;
Oe4 A444§@4
1404E4 1
Ja404 Mick
Daniel §teigleman
New Member
1) The above action occurred following the regigp#tion
of Steve Flickinger.
Ttl@
40.a S of the AlltheFltY M@Miaers di4 not change following
th isppointmerAs M4de 4t the June §, 1992, meeti
4- Pgin 4,Wert§ th4t the dlities of the AuthoritY
gfficeFs are cPASten01 changing-
iP 9.14lPe4 bY P-obin§@n that the Authority officers
S4pPleMent the Ofer4.4 Of regular employees.
12. Al4h9EitY IneMPerP cOnflrill that not paying the Water bill AP
coMPenSetign fo r Serving en the Autherity was .discussed fe„r
some
a Membefs elleyog they should be colgP@AA4t04 for sttep4ing
meetings much the same as members isefe4gh council-
i%) RolginsOn denies that soRNEVAPetion 941Y Fel4t94 t9
meeting atten4apee but resqltq frem various duties
444 hours o time by the Authority officers,
4@ifit@r§ tePk the compenSgtien /4 the fgEm cfwatve4 water
bills bePAUse it was betteg. than taking a salary,
13. Agthffity Fe99rAs in4ig4te eqcount # 146 is in the name of H.F,
:?Ahnestockf R.P 41,2, Be4 13, Newport, PA 17074 gpd is the
residence rented by paral4 Robinson.
14. 14-409E Fecc;dg ind that R01E411E94 0i4 !Let pay the
following bills as cempensation ter his service on the
Authority;
Robinson, 92- 060 -C2
Page 5
Third Quarter 1991
Fourth Quarter 1991
First Quarter 1992
Second Quarter 1992
TOTAL
B. TESTIMONY:
- $ 35.45
$ 33.11
- $ 24.95
$ 40.20
$133.71
15. Gerald Robinson is a Member of the Newport Borough Water
Authority (NBWA).
a. The following arguments are made by Robinson.
1. That pecuniary is defined as money exacted or money
given as a reward so that no member or officer
received a pecuniary 'benefit,
2. That the duties of the Authority have changed
dramatically.
• That the investigation relates to compensation that
he; 'Amster and Shic1 , Mad , AVailable to "themselves
4. That the Municipality Authorities Act may be
construed h mean that'theliKtthority may compensate
officers.
5. That he, Amsler and Shick did not take money but
only water.
b. The Authority serves three municipalities.
1. Board. members attend Meetings of the
municipalities. a■ ._
•
c. Authority members provide in -1ie4a assistance to
permanent staff of the Authority.
d. The .first members of the Authority just like the current
Board had the same responsibilities of issuing bonds, of
deciding which water wells were needed, .of deciding
whether new wells were needed and of determining whether
other wells should be shut down. '
e. The Authority officer position of Assistant Secretary/
Treasurer did not exist prior t6'1992.
f. In 1991, the Authority officer positions we' 'Chairmart,
Vice - Chairman, and.Secretary /Treasurer.'
:4tctbi on, 92- 060 -C2
Page {6
g•
h. In 1991, there were five members but only three were
elected to ptsitions.
i
In 1992, these were four members with five elected
positions.
1. Four members Were each el+ec?tea to a pnsi.t oh
2. The fifth position was left open for the new siei&Ber
to be appointed
Each Authority meitber does what is necessary to get a job
done irrespectitre of their pdsitiofi title.
1. The duties that the members perform are not unique
to office pOsltiOns.
2. The duties that ate performed aft as board members.
j
C. EXHIBITS:
1. TA prior years, the position of Secretary and
Treasurer were sepatd.
(a) At that time, there were four memrs.
The slew Authority position Of Assistant Secretary/
Treasurer occurred at the June. 1992 Authority meeting.
16. The minutes of the Newport Bofough Water Authority (NBWA) for
January 14, 1991, reflect in p&ft that Authority members were
elected as officers.
a . ' Jerry Robinson Bras made Vice - Chairman upon motion by
Shick, seconded by rliakinger, which carried:
b. James Shick was made Secretary /treasurer upon motion by
Flickinger, seconded by Steiglemai, which carried.
17. As to the January 11, 19$`2 meetifig of the NBWA, the minutes
reflect in= part that no action was taken to elect officers for
the NBWA.
a. The followinq exettpt ag15664§ on p t o three of the
minutes:
Have council, • re•a64it Lek Aitsler
retroactivvtly to the= 1st ckt tie yeah'.
18. The following, is a quatexi ecei"p f t' th'eriiiiiiiiit4S ' of the NBWA
for the meeting of Junt 8,, 19392:
jtobir;son, 92- 060 -C2
Page 7
III. DISCUSSION:
A motion was made by Dick Am.1e ,,Q
nominate Gerald Robinson as Chairman sic. ; ; by
Jim Shick. There were no other nominatins.
Motion carried.
A motion was made by Jim Shick sec. by
Jerry Robinson to nominate Dick Amsler as Vice
Chairman. There were no other nominations.
Motion carried.
Chairman:
Vice Chairman:
Treasurer:
Secretary:
Assistant Sec. /Treas.:
* * *
Since the second quarter of 1992, the
water portion of the authority members water
and sewer bills has been waived as incentive
to serve on the Water Authority.
According to Municipal Code, borough
council sets renumeration for members of a
working authority, however the Water Authority
themselves set renumeration for officeFs,,of
the working authority. Therefore:
A motion was made by Dick Amsler sec. by
Jim Shick for waiver of the water portion of
the officers of the Water Authority's water
and , sewer bill as renumeration. Motion
carried.
The officers of the Newport Borough Water
Authority are as follows:
Gerald Robinson
Richard Amster
James Shick
Daniel Steigleman
New Member
As a Member - of the Water Authority for the Borough of Newport,
Perry County, Gerald Robinson, hereinafter Robinson,. is a public
official-as that term is defined under Act 9 of 1989. 65 f.S.
§402. As such, his conduct is subject to = the . - provisions of the
Ethics Law and the restrictions therein are applicable to him.
Initially, it is noted that Section 9 of Act 9 of June 26,
1989 provides, in part, as follows:
"This amendatory act shall not apply to
violations committed prior to the effective
34
,92- 0_fi0 -C2
date of =this ate, .and „causes of action
initiated for ,sixth vidiations shall lbe
governed by the parixr '1 -a4 - Ts continued
in effect for that purpaa ,mss :if This act were
not in force. For the ;purposes .af this
s ption, a violation wnm committed xceimr to
the 1pf fxective date °Qf fib'i. act if -am-elements
of the violation occurred-prior thereto
; ce the -occurrences in -till case - tr piredi after the
e f f epti;,ve :date f ,Act 9 (June 28, 1'9B9 ),, we .must 'may the
prgv tA os of t V to determine whether the :Ethics A'ct was
vi.�aad,.
Under _Sect :gin (a;) of At =g of 1989 Aparted allows, a public
Uf a /empl,oyge Khal.J- not enrage ln conduct that constitutes a
t1:4 tt -o-f illtereSt,
The jL a before us is whether 'Robinson at Member of the
Newpg t 13o_tolIgh Water Aut o-r ty :(TWA) violated Section .3; of Act
9 gf .1. 1 9 V using t. e authority of office to obtain a primate
Pfle..vniary beinetit Vhen. bie voted to provide compensation to himself
$sj.Sttgg ,Qf the tog fovgiverlers of Authority ntiLity bills from the
third ,gooney t .fling .of 2991 forward.
Yactual' :y, Aobinson is a giber of the : UL with the Newport
Borough ; council as the governing body. Due to NBWA board members
perfor ing additional Mies, action was taken 'whereby, ". . . the
water portion of the authority members water and sewer bills has
been waf.ved as incentive to serve on the Water Authority." NBWA
Public Meeting Min teP Of June 16, 1993. The foregoing occurred by
motion and vote of tbeA board members.
Robinson, on behalf of - himself and Shick and Armlet, argues
that the duties of the Authority members have drastically changed,
that the Municipality Authorities Act allows the Authority to
compensate Officers, and that they did not take money but (the
forgiveness of) their water bills.
Prior to making our determination of whether a violation
occurred, we must consider and review the Municipality Authorities
Act in the context of whether such compensation is allowable under
the law. If such compensation is prohibited by law, it is cleat
that the use of authority of office by municipal authority board
members to give themselves such compensation would constitute a
Private pecuniary benefit. Means, Opinion 90 -007; SwickLAmerk,
Opinion 91 -006.
The Municipality Authorities Act provides in part as follows:
Every Authority is hereby granted, and
Robinson, 92- 060 -C2
Page 9
(f) To make by -laws for the management and
regulation of its affairs.
(g) To appoint officers, agents, employees
. and servants, to prescribe their duties and to
,,o tix their compensation.
•S.• $306p.
The Municipality l uthorities. At further provide's :
LC
B. Members shall hold 'Qf<fice until 'their
successors have been , a } 5 iointed, Apd 'mtay
succeed themselves, and, except" members of the
boards of Authorities organized or created by
a school district or school districts, shall
receive such salaries as may be determined by
the aoverning body bTr - bodi _ - of - ' the
municipality or municipalities; but - none of
such salaries shall be increased. or diminished
by such governingg, riaody or bodies during the
term for which the meitber receiving the same
shall have been appginted. . .
shall have and may exercise all powers
necessary or convenient for the carrying out
of the aforesaid purposes, including but
without limiting the generality of the
foregoing, the following rights and powers:
C. A majority ..of the members shall
constitute a .gtpdm: of the board for the
purpose. of organizing the Authority 'and
conducting the.busihess thereof and for all
other purposes,., and`"all action may be taken by
vote of a majority of the;' - present,
unless in an ;case the by -laws ha11 require a
larger number.` The board` shall have full
authority to manage the.. properties and
business of the Authority aid to prescribe,
amend and.,- repeal ky -laws, rules and
regulations governi the m4iner in which the
business of the Authority hay' be conducted,
and the. powers granted tp it l ay ,be exgrFised
and ,embodied. the beard °°Shall fix `'and
determine the iumi i t.5f i ;fir ` atie fte — *nd
employees of el e AutItb
respective pd5gers. __$litres' - compensation
may appoint to ".suc off re or o ffices any
member of 7 th su w w
bh - - poers ; ` ilir
r. :aud.,,compen og a s » oard may deem proper:
/tabir an, 92- 060 -C
Peg ._
53 ' • 55309B, C (Emphakis added) .
Sect 7 of Municipality Authorities Act of 1945, 53 P.S.
5307 ,does ,grant an authorirty wtth all powers necessary or
convenient (or the carrying out of the purposes of the Act.
Subsection C provides that all actions of an authority may be taken
py avgte of the majority pf the :members present and further
ewers a authority to fix as d determine the number of officers,
s and employees of the authority and the respective powers,
0 #nc componsation. The board may appoixit to euch office or
.cep any member' of the board with ss, h pow s, duties and
copyp?epsati,on as the board may deem proper. As to the three
di.f'firept references to the phraseology of the municipality
Aut orWes Act, the genesalized language of the first phrase does
not 'form a basis for a specific autho4e4ti94 to appoint oneself to
an authority office or position and theh vote to set the salary for
such position. See, SwickfAman, supra.
As to the second phrase which authorizes all actions to be
taken by 9 rote of the majority of the members present, such
language is werely a statefgent that a majority vote is sufficient
to take ofi'icial action. That phraseOlggi does A2t, countenance or
authorize votes by authority members in ea *ass where they have a
conflict. it if Were the intent of the General Assembly to allow
munici:?01 authority members to vote in matters wherein they had a
personal financial interest, the General Assembly would have done
so with very clear specific language. For example, the Second
Class " Township Code as to three Member boards makes it clear that
the members Township-Code
those boards may specifically vote for themselves to
enumerated. township compensation positions. See, 53 P.S. 565514.
Thus, if the G eneral Assembly had the intent for municipal
authority members to vote in all instances through a majority vote
of the members present, specific language would have been utilized
for such "purpose,. As noted above,, the instant phraseology merely
directs that official, action, oc.enr; by a vote of the majority of the
members present but does not condone a blanket voting in cases
where conflicts, would exist as to the individual member so voting.
As to the third referenced phrase concerning the fi..iag of
officers, agents and employaa with, compensation and appointments
to, those positions by board member we mus-t once again nxate the
express absence of any la<ng age wbijc rr w%4 authorize an individual
l
mepaher of a municipal` board to vot tor his own appointment ar:
vote, f or the setting at the, cr mpensa:t ; oja, for his own: g¢tsistimrm..
Absent such an express au we. halve. concJ d it that t i m
contrary. to the Ethics Law- f a municipal1 authority hoard member
to vote for his own appointment and compe rsatiort. qv, Swick/ ;man,,,
supra,. It is important to note that the Muni,ci Authorities,
Act, 5 ; 3, P.S. 5309B, does require that, the compensation. of an
itobinsor;, 92- 060 -C2
Page 11
authority boaE4 fiber must be determined by the appointing
authorit ,r.
As wg notR4 j., §wick /Amara, we are particularly concerned about
those instailpes vh ' a Ogioipal boaEd attempts to create so
called offigff petitions 444 'set tae compensation for those
positions a4 , L
m nt board members as a means'of ctrc.imventing the
at
stutory . , 4 ',ons` that the compensation _ for a municipal
s.uthority boar metier be set by the governing body.
In applying the provisions of Section 3(a) of Act 9 of 1989
quoted above °to the instant matter, we find that Robinson violated
the Ethics Law by goting to provide compensation for the members.
§ee, Abraham, Order jo. 827; Koelschi Order No. 828; and Abbott,
Order No. 829. It is c lear that there has been a use of authority
of office by Robinson n voting. As a result of such use of
authority of office, Robinson received a private pecuniary benefit,-,
consisting of the compensation consisting of the forgiveness of his
NBWA utility bills. As to the privte pecuniary benefit, we need
only summarize our review of the Municipality Authorities Act as to
whether the compensation was authorized in law. As noted above,
although it is true that the 44i4paiity Authorities Act does
allow a municipal authority boara to fix abd dQtermine the number
of officers and appciint bard $}e ?gyp§ tp tho §e offices (53 P.S.
309C) and furtnet' provides that thg aut }grity, ma pit officers
and . fix ' their compensation (5 3 F . . Q 5 (g)) , 4 t rd mgm�agr may
na vote to .set the salary for his 9f icer pas3.tir�1,} ea 4.MR1
t offi o a.tion d are bon {,j] y O -tionS
v
supra. . Fin lly, the setting of t cpmpensatip r gr . a b- d
melmbers themseives must be set b# ;Ile governing authority as plar 53
P.S. S309A.
In the context of the TBWA, it is clear that the bos.sd A}embers
to
were we must look at the s u enga
e trying fix their cola tign as boar�}me ; } this
_ _ _ look _ - stance over f oran . $� 4gthgF§ v.
i clear a ""t mh `t Y - bedo s that the :
the s b s az g of th A
tran was for th ragmbirs to recei Cam► asatio
and` in order_ to achieve that reset the NBWA b9a14 un4 of €icep
Pci5-itions% Tau a1thc41 the f9FR pf the tPaaaaF was ilk! utilization of the officer position, the si}b leAs the NB
board 'compensating its board embers �.a de =ggatigm Q tke
M Authorf ties Pict whit re that suci ar tg
done - authority. authority.
Having found that the subs of the NBWA board getign was
to compen §4te authority members .P1%411 gific P9aitigns it is
clear that such is coflttary tq tag thics Lei: pa fact, such
con senstion is stricti h4 .
rot0 the Municipali +,�}t horities
Act, $3098. T e efore, 44itson did lag pub4E Office by
voting to obtain private pecuniary benefit w} .Fh was in violation
Robinson, 92- 060 -C2
Page 12
of Section 3 ( ti Qf -Act : of 1,,W.
We ..do j.ot S need to question whether the duties of the NBWA
»card membe have changed since that is not material to our
determination. As to the issue of whether such forgiveneso of the
utility bills is not a pecuniary benefit, the fact thattau out -of-
pocket expense ' `does nbt have to be paid Is a private
benefit. 136e, S'zvmanowski, Opinion 87 -002. TLa-st as to the
argument that such compensation is allowed by-the 'Municipality
Authorities Act, we considered and rejected that argument for the
reasons noted above.
In reaching the above result we do not believe that Robinson
acted with an intent to violate the EthicsLaw or with any improper
motive. We likewise do not need to question or. dispute that
additional work was performed. In any event,- an' such work was not
as officers but as board members As Stich, the additional
compensation must be obtained from the'governing' body and not the
authority board as was done in this case. GivelYthe totality of
the circumstances .iii this case, we will take no •further action.
Robinson is reminded-as to future action that the appropriate and
regal mechanism for authority board members seeking additional
`compensation is through action by the governing body.
IV. CONCLUSIONS OF LAW:
1 ?' -Gerald Robinson, as a Member of the Newport Borough Water
Authority, is a public official subject to the provisions of
At 9 of 1989.
2. Robinson violated Section 3(a) of Act 9 when he used the
authority of office to obtain a private pecuniary benefit for
himself when he participated in obtaining compensation
r of the forgiveness of his own authority utility
bills.
In Re: Gerald Robinson : File Docket: 92- 060 -C2
: Date Decided: )av 6. 1993
: Date Mailed: rav 11. 1993
ORDER NO. 882
1. Gerald Robinson, as a Member of the Newport Borough Water
Authority, violated Section 3(a) of Act 9 when he used the
authority of office to obtain a private pecuniary benefit for
himself when he participated in obtaining compensation
consisting of the forgiveness of his own authority utility
bills.
2. Based upon the totality df the facts and circumstances, no
further action will be taken.
BY THE COMMISSION,
0osw Af
JAMES M. HOWLEY,
t
Commissioner Allan M. Rluger did not participate in the final
decision of this case because he presided at the hearing as one
Commissioner and recused himself.