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HomeMy WebLinkAbout05-580 MillardThe Honorable David R. Millard 36 Woodside Drive Millville, PA 17846 Dear Mr. Millard: ADVICE OF COUNSEL October 18, 2005 05 -580 Re: Conflict; Public Official; Member; General Assembly; State Representative; Private Employment or Business; Board of Directors; State Fair; Firemen's Relief Association. This responds to your letter of September 21, 2005 by which you requested advice from the State Ethics Commission. Issue: Whether the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1101 et seq., imposes any prohibition or restrictions upon a State Representative with regard to continuing to serve as the president of a firemen's relief association and a member of the board of directors of a state fair. Facts: You are a State Representative for the 109 District. In addition, you are the President of the Bloomsburg Firemen's Relief Association, and a Member of the Bloomsburg Fair Board of Directors, serving in the capacity of Director of Arts & Crafts. You state that the Bloomsburg Firemen's Relief Association receives state funds. Having served on the Bloomsburg Fair Board of Directors since 1995, your present three -year term will expire at the end of this year. You wish to seek re- election as Director of Arts & Crafts, which is a paid position as reflected on both your taxes and your Statement of Financial Interests. You state that the Bloomsburg Fair is a non - profit organization. You further state that although you are far removed from decisions concerning matching grants from the state fair fund, you are very supportive of keeping those funds in place in the annual state budget for all the fairs in the Commonwealth. You note that you recently established the Fair Caucus and serve as the Chairman from the Pennsylvania House of Representatives. Based upon the foregoing facts, you ask whether you may continue to serve as the President of the Bloomsburg Firemen's Relief Association and a member of the Board of Directors of the Bloomsburg Fair. Discussion: It is initially noted that pursuant to Sections 1107(10) and (11) of the Millard, 05 -580 October 18, 2005 Page 2 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 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 a State Representative for the 109 District, you are a public official subject to the provisions of the Ethics Act. Section 1103(a) of the Ethics Act provides: §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). The following terms are defined in the Ethics Act 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. Millard, 05 -580 October 18, 2005 Page 3 Section 1103(j) of the Ethics Act provides as follows: §1103. Restricted activities (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 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(j). You are advised that Section 1103(a) of the Ethics Act does not per se prohibit public officials /public employees from having outside business activities or employment. However, subject to certain exceptions delineated in the definition of "conflict" or "conflict of interest" above, Section 1103(a) of the Ethics Act ordinarily applies to prohibit the public official /public employee from using 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. Ordinarily, a public official /public employee with a conflict under the Ethics Act is required to abstain fully and to fully satisfy the disclosure requirements of Section 1103(j) of the Ethics Act. However, in Corrigan, Opinion 87 -001, the Commission addressed the question of whether the Ethics Act would prohibit a member of the General Assembly from voting in relation to a measure or bill pending before the Pennsylvania State Senate or the Pennsylvania House of Representatives when such measure or bill would affect the legislator's private interests. The Commission considered the following provisions of the Constitution of Pennsylvania: Privileges of Members Section 15. The members of the General Assembly shall in all cases, except treason, felony, violation of their oath of office, and breach of surety of the peace, be privileged from arrest during their attendance at the sessions of their respective Houses and in going to and returning from the same; and for any speech or debate in either House they shall not be questioned in any other place. Millard, 05 -580 October 18, 2005 Page 4 Constitution of Pennsylvania, Article 11, Section 15. Vote Denied Members with Personal Interest Section 13. A member who has a personal or private interest in any measure or bill proposed or pending before the General Assembly shall disclose the fact to the House of which he is a member, and shall not vote thereon. Constitution of Pennsylvania, Article 111, Section 13. In reviewing the above constitutional provisions and pertinent case law, the Commission held: The activities of a member of the General Assembly insofar as such relate to legislative actions, defined as the introduction, consideration, debating, voting, enactment, adoption or approval of legislation, are constitutionally controlled. Such legislative actions are therefore exempt from the purview of the State Ethics Act and the State Ethics Commission.... the application of the State Ethics Act to non - legislative activities [is] in no way affected by this opinion. Corrigan, Opinion 97 -001 at 4. Based upon the above, you are advised that Section 1103(a) of the Ethics Act would not prohibit you from continuing to serve as the President of the Bloomsburg Firemen's Relief Association and a member of the Board of Directors of the Bloomsburg Fair. As to these two organizations, Section 1103(a) would apply to any non - legislative activities undertaken by you as a public official. However, to the extent your activities would relate to "legislative actions" (introducing, considering, debating, voting, enacting, adopting, or approving legislation), they would be constitutionally controlled and would be exempt from the purview of the Ethics Act and the State Ethics Commission. Confidential Opinion, 04 -010; Corrigan, Opinion 87 -001. Thus, any legislative action that you would take with respect to the Bloomsburg Firemen's Relief Association or the Bloomsburg Fair would be exempt from the purview 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 Legislative Code of Conduct. Conclusion: As a State Representative for the 109 District, 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. Section 1103(a) of the Ethics Act would not prohibit you from continuing to serve as the President of the Bloomsburg Firemen's Relief Association and a member of the Board of Directors of the Bloomsburg Fair. As to these two organizations, Section 1103(a) would apply to any non - legislative activities undertaken by you as a public official. However, to the extent your activities would relate to "legislative actions" (introducing, considering, debating, voting, enacting, adopting, or approving legislation), they would be constitutionally controlled and would be exempt from the purview of the Ethics Act and the State Ethics Commission. Thus, any legislative action that you would take with respect to the Bloomsburg Firemen's Relief Association or the Bloomsburg Fair would be exempt from the purview of the Ethics Act. Millard, 05 -580 October 18, 2005 Page 5 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