HomeMy WebLinkAbout05-002 ConfidentialOPINION OF THE COMMISSION
Before: Louis W. Fryman, Chair
John J. Bolger, Vice Chair
Daneen E. Reese
Donald M. McCurdy
Paul M. Henry
Raquel K. Bergen
DATE DECIDED: 2/28/05
DATE MAILED: 3/14/05
05 -002
Re: Conflict; Public Official; Legislator; Pennsylvania General Assembly; Part -Time
Employment; Fund Development Officer; Nonprofit Corporation; A; Federal and
State Grants; Solicitations; Donations and Gifts.
This Opinion is issued in response to your confidential advisory request dated
February 1, 2005.
I. ISSUE:
Whether the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. §
1101 et seq., would impose any prohibition or restrictions upon a Member of the
Pennsylvania General Assembly (Legislator) with regard to engaging in part -time
employment as a Fund Development Officer for a nonprofit organization, specifically an A,
when the duties of the Fund Development Officer would include applying for federal and
state grants and soliciting donations and gifts from public and private entities, charities and
foundations, other public officials including Pennsylvania Legislators, Members of the U. S.
Congress, and private individuals who might include the Legislator's constituents.
II. FACTUAL BASIS FOR DETERMINATION:
You have requested a confidential advisory from this Commission. In your public
capacity, you are a Legislator. In addition to serving as a Legislator, you are interested in
being employed on a part -time basis as the Fund Development Officer for a nonprofit
organization ( "Nonprofit "), specifically an A. You have submitted facts that may be fairly
summarized as follows.
Prior to becoming a Nonprofit, the A was affiliated with a B. The B continues to
have an ownership interest in the land and building and contributes to a trust for the
operation and maintenance of the A. Currently some of the income that the Nonprofit
receives consists of rental fees, which include government funds.
The duties of the Fund Development Officer for the Nonprofit would include the
Confidential Opinion, 05 -002
March 14, 2005
Page 2
following: applying for Federal and State grants; soliciting various forms of donations and
gifts; establishing a planned giving program, including solicitation of gifts in trust and
endowments; coordinating an annual giving program; and developing an Internet site for
online contributions. The Fund Development Officer would solicit various forms of
donations and gifts from public and private entities, charities and foundations, other public
officials including Pennsylvania Legislators, Members of the U. S. Congress, and private
individuals who might include constituents. You anticipate that the governmental bodies to
whom solicitations would be directed would specifically include: County Board C; State
Department D; State Department E; and State Commission F. Forms of solicitation would
include personal meetings and direct mailings.
You have identified as possible concerns your receipt of salaries as both a
Legislator and the Fund Development Officer for the Nonprofit, as well as a possible
perception that a portion of the proceeds solicited for the Nonprofit would include your
salary as Fund Development Officer.
By letter dated February 8, 2005, you were notified of the date, time and location of
the executive meeting at which your request would be considered.
III. 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, this 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.
As a Legislator, you are a public official subject to the provisions of the Ethics Act.
Sections 1103(a) and 1103(j) of the Ethics Act provide:
§ 1103. Restricted Activities
(a) Conflict of interest. —No public official or public
employee shall engage in conduct that constitutes a conflict of
interest.
(j) Voting conflict. —Where voting 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 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
interest 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 permitted to vote if
disclosures are made as otherwise provided herein. In the
case of a three - member governing body of a political
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March 14, 2005
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subdivision, where one member has abstained from voting as
a result of a conflict of interest and the remaining two members
of the governing body have cast opposing votes, the member
who has abstained shall be permitted to vote to break the tie
vote if disclosure is made as otherwise provided herein.
65 Pa.C.S. §§ 1103(a), (j).
The following terms pertaining to conflicts of interest under 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 performance of duties and responsibilities unique to a
particular public office or position of public employment.
"Business." Any corporation, partnership, sole
proprietorship, firm, enterprise, franchise, association,
organization, self - employed individual, holding company, joint
stock company, receivership, trust or any legal entity
organized for profit.
"Business with which he is associated." Any
business in which the person or a member of the person's
immediate family is a director, officer, owner, employee or has
a financial interest.
65 Pa.C.S. § 1102.
We note that to the extent the activities of a Legislator relate to "legislative actions"
(introducing, considering, debating, voting, enacting, adopting, or approving legislation),
they are constitutionally controlled and are exempt from the purview of the Ethics Act and
the State Ethics Commission. Confidential Opinion, 04 -010; Corrigan, Opinion 87 -001.
The question that you have posed for review by this Commission does not pertain to
"legislative actions," but rather, to your prospective activities as Fund Development Officer
for the Nonprofit. We note that in promulgating the Ethics Act, the General Assembly
specifically recognized that many public officials, including Legislators, are citizen - officials
and should not be discouraged from maintaining contacts with their community through
their occupations /professions. 65 Pa.C.S. § 1101.1(b).
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March 14, 2005
Page 4
Thus, Section 1103(a) of the Ethics Act pertaining to conflicts of interest does not
prohibit public officials /public employees from having outside business activities or
employment. However, the public official /public employee may not use the authority of his
public position - -or confidential information obtained by being in that position - -for the
advancement of his own private pecuniary benefit or that of a business with which he is
associated. Pancoe, Opinion 89 -011. Some examples of conduct that would be prohibited
under Section 1103(a) of the Ethics Act would include: (1) the pursuit of a private
business opportunity in the course of public action, Metrick, Order 1037; and (2) the use of
governmental facilities, such as governmental telephones, postage, equipment, research
materials, or other property, or the use of governmental personnel, to conduct private
business activities, Heck, Order 1251, Freind, Order 800; Pancoe, supra.
As for the specific question that you have posed, you are advised that Section
1103(a) of the Ethics Act would not prohibit you as a Legislator from also being employed
part -time as the Fund Development Officer for the Nonprofit; applying for Federal and
State grants on behalf of the Nonprofit; or soliciting various forms of donations and gifts for
the Nonprofit from public and private entities, charities and foundations, other public
officials including Pennsylvania Legislators, Members of the U. S. Congress, and private
individuals who might include your constituents, provided that you would not, in whole or in
part, use your public position as a Legislator to do so. Confidential Opinion, 04 -010;
Guloien, Opinion 90 -011. In this regard, you must exercise diligence and care to ensure
that your status as a Legislator would not be used as to such solicitations or grant
applications. Id.
This Opinion is limited to addressing the applicability of Section 1103(a) of the
Ethics Act. It is expressly assumed that there has been no use of authority of office for a
private pecuniary benefit as prohibited by Section 1103(a) of the Ethics Act. Further, you
are advised that Sections 1103(b) and 1103(c) of the Ethics Act provide in part that no
person shall offer to a public official /public employee and no public official /public employee
shall solicit or accept anything of monetary value based upon the understanding that the
vote, official action, or judgment of the public official /public employee would be influenced
thereby. Reference is made to these provisions of the law not to imply that there has been
or will be any transgression thereof but merely to provide a complete response to the
question presented.
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
Legislative Code of Conduct or the G.
IV. CONCLUSION:
A Member of the Pennsylvania General Assembly (Legislator) is a public official
subject to the provisions of the Public Official and Employee Ethics Act ( "Ethics Act "), 65
Pa.C.S. § 1101 et seq. Section 1103(a) of the Ethics Act would not prohibit a Legislator
from also being employed part -time as the Fund Development Officer for a nonprofit
organization ( "Nonprofit "), specifically an A; applying for Federal and State grants on
behalf of the Nonprofit; or soliciting various forms of donations and gifts for the Nonprofit
from public and private entities, charities and foundations, other public officials including
Pennsylvania Legislators, Members of the U. S. Congress, and private individuals who
might include the Legislator's constituents, provided that the Legislator would not, in whole
or in part, use his /her public position as a Legislator to do so. The Legislator would have
to exercise diligence and care to ensure that his /her status as a Legislator would not be
used as to such solicitations or grant applications.
The propriety of the proposed conduct has only been addressed under the Ethics
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March 14, 2005
Page 5
Act.
Pursuant to Section 1107(10), the person who acts in good faith on this Opinion
issued to him shall not be subject to criminal or civil penalties for so acting provided the
material facts are as stated in the request.
This letter is a public record and will be made available as such.
Finally, a party may request the Commission to reconsider its Opinion. The
reconsideration request must be received at this Commission within thirty days of the
mailing date of this Opinion. The party requesting reconsideration must include a detailed
explanation of the reasons as to why reconsideration should be granted in conformity with
51 Pa. Code § 21.29(b).
By the Commission,
Louis W. Fryman
Chair