HomeMy WebLinkAbout02-621-S StarrDona L. Sjarr
53 W. 33 Street
Reading, PA 19606
Re: Conflict; Public Official /Employee; Township Supervisor; Immediate Family;
Spouse; Business With Which Associated; Business Client /Customer; Vote; Five -
Member Board; Supplemental Advice.
Dear Ms. Starr:
ADVICE OF COUNSEL
September 4, 2003
02 -621 -S
This responds to your letter of August 4, 2003, by which you requested
supplemental advice from the State Ethics Commission.
Issue: Whether the Public Official and Employee Ethics Act ( "Ethics Act "), 65
Ha.GS. § 1101 et seq., would present any prohibition or restrictions upon a township
supervisor with regard to a request for relief from zoning regulations or a development
plan relating to a proposed addition to a local parish, when the supervisor's spouse: (1)
has previously performed work for the parish; (2) has a pending contract to perform
additional work for the parish; and (3) may have a reasonable and legitimate
anticipation of performing work for the parish as to the proposed addition.
Facts: You initially requested an advisory from the State Ethics Commission by
Mier of October 29, 2002. In response to your initial request, Advice 02 -621 was
issued to you on December 2, 2002, which Advice is incorporated herein by reference.
In your supplemental advisory request, you state that the Exeter Township Board
of Supervisors ("Board") is comprised of five members. The Board will soon be
considering a request for relief from zoning regulations. You state that you are aware
that two Board members will vote for and two Board members will vote against the
zoning request. You ask whether you may vote against the request for zoning relief
when it comes before the five - member Board if the vote is two in favor and two against
and you are otherwise disqualified from voting.
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 requestor
based upon the facts which the requestor has submitted. In issuing the advisory based
upon the facts which the requestor has submitted, the Commission does not engage in
an independent investigation of the facts, nor does it speculate as to facts which have
not been submitted. It is the burden of the requestor to truthfully disclose all of the
Starr 02 -621 -S
Date
Page 2
material facts relevant to the inquiry. 65 Pa.C.S. §§ 1107(10), (11). An advisory only
affords a defense to the extent the requestor has truthfully disclosed all of the material
facts.
As to the question you have posed, Mlakar, supra, makes it clear that it is only
when the governmental body is unable to take official action because the majority or
other legally required vote is unattainable due to the number of members required to
abstain, that such abstaining members will be permitted to vote if proper disclosures are
made. Thus, in the case of the Exeter Township Board of Supervisors, a five member
board, three Supervisors would have to have a conflict under the Ethics Act in order to
make the majority or other legally required vote "unattainable." Only in such an instance
would you be permitted to vote on the matter under the voting exception of Section
1103(j) of the Ethics Act.
The propriety of the proposed conduct has only been addressed under the Ethics
Act; the applicability of any other statute, code, ordinance, regulation or other code of
conduct other than the Ethics Act has not been considered in that they do not involve an
interpretation of the Ethics Act. Specifically not addressed herein is the applicability of
the respective municipal code.
Conclusion: As a Supervisor for Exeter Township, you are a public official
subject to the provisions of the Public Official and Employee Ethics Act ( "Ethics Act "), 65
Pa.C.S. § 1101 et seq. Since the Exeter Township Board of Supervisors is a five -
member board, three Supervisors would have to have a conflict under the Ethics Act in
order to make the majority or other legally required vote of approval "unattainable." Only
in such an instance would you be permitted to vote on the matter under the voting
conflict exception of Section 11030) of the Ethics Act. Lastly, the propriety of the
proposed conduct has only been addressed under the Ethics Act.
Pursuant to Section 1107(11), 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 requestor 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.
Sincerely,
Vincent J. Dopko
Chief Counsel