In re Appeal from Somerset Co. Auditors

26 Pa. D. & C.3d 205, 1983 Pa. Dist. & Cnty. Dec. LEXIS 330
CourtPennsylvania Court of Common Pleas, Somerset County
DecidedMay 20, 1983
Docketno. 15 Misc. 1981
StatusPublished

This text of 26 Pa. D. & C.3d 205 (In re Appeal from Somerset Co. Auditors) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Somerset County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Appeal from Somerset Co. Auditors, 26 Pa. D. & C.3d 205, 1983 Pa. Dist. & Cnty. Dec. LEXIS 330 (Pa. Super. Ct. 1983).

Opinion

KIESTER, S.J:,

This case is before the court on a petition for appeal from the Somerset County Auditors Report for 1980. The appeal was filed by ten taxpayers. Answers to the petition were filed by the Auditors and the County Commissioners.

The taxpayers object to 76 items alleging that those items were improperly charged as expenses to Somerset County in 1980. The relief prayed for is that the County Commissioners be surcharged and the money refunded to Somerset County. The County Commissioners deny that the 76 items were other than lawful and proper expenses of the county.

By stipulation the record consists of that of the hearing conducted by the Somerset County Auditors on April 27, 1981 and the stipulation of specific items commencing with 1 and continuing through 76. Each item prepared by the Commissioners has exhibits attached and contains a face [206]*206sheet on which information as to each expense item is outlined.

A typical face sheet (Item No. II) is attached.

Also, part of the record is a letter dated August 31, 1982 of Thomas J. Cook, Esq. attorney for petitioners in which he identifies the specific items between one and 76 to which objection is made. The oral argument of counsel on March 9, 1983 has been transcribed. In disposing of the objections the court will adopt in general the groupings of objectionable items as presented in the latter.

This is a case of first impression. There are statutes and there are cases stating general principles. There are no cases in point with the facts presented by these exceptions.

The facts are simplified in that the contested expenses were all incurred while the Somerset County Commissioners engaged in transactions related to county business. Much of the litigation across the nation has involved the question of whether the contested expenditure was made for a public purpose. That is not an issue in this case.

The principal issue as to each exception is whether the expense was proper and complied with the law. Although there may have been a legitimate public purpose this does not mean that exceptants agree that the expense was “necessarily incurred” as required by law or that it was properly documented. In examining the record the court will principally address two questions

1. Was the expense necessarily incurred?

2. Was the expense properly documented?

THE LAW

As to expenses the General Assembly has provided

[207]*207“Section 507. Expenses. — The county commissioners shall be allowed their expenses, necessarily incurred and actually paid, in the discharge of their official duties, or in the performance of any service, office, or duty imposed upon county commissioners.” (Act No. 130 of 1955 — County Code)

The only specific provision fixing and limiting the amount that can be paid is the mileage fee of .17 cents which applies to county commissioners, their employees as well as to others in state and local government. (Act No. 51 approved July 20, 1979)

The key words are “necessarily incurred.” Websters New International Dictionary and Words and Phrases defines necessarily as unavoidable, indispensable, inevitable.

The intent of the legislature is not explained. What is clear is that what is necessary and indispensable to one person is a luxury to another. There is nothing more evident than the fact that what is a luxury in one generation becomes a necessity even to a welfare recipient in another generation. A necessity is not necessarily something that is indispensable and unavoidable. This has been decided by a variety of cases. Cases have interpreted what is necessary, necessary and proper, necessary and essential, reasonably required, reasonably necessary, authorized and what are and what are not public purposes depending on particular facts and circumstances.

Changing conditions of society including population, business, industry, transportation, communication, the sciences and government itself may determine from time to time what are expenses “necessarily incurred” in the transaction of government business.

There is a presumption that action taken by commissioners is proper. If county commissioners [208]*208spend county funds for a meal-time meeting with employees or others while transacting county business this is a discretionary matter.

Its wisdom is not subject to judicial review. The burden rests on the objector to show fraud, bad faith or abuse of power. This does not negate the burden that rests on the Commissioners to show that the funds wer legally disbursed. In re Auditors Report 245 Pa. 17 _ Atl. _, (1914).

The salary of a County Commissioner is fixed by an Act of Assembly. That salary can neither be increased nor decreased during the term of office. A county commissioner is not entitled to receive additional compensation for the performance of the duties of the office. This is basic law.

There is no suggestion in these exceptions that any of the meal-time meetings were called for the purpose of providing the Commissioners or others a free meal so as to increase their compensation.

Commissioners operate a multi-million dollar program with a large payroll, several departments and agencies and a requirement of many meetings. When a meeting is called and conducted on county business outside regular business hours, expenses “necessarily incurred” could reasonably include breakfast, lunch or dinner. Persons attending such meetings including commissioners, employees, volunteers, solicitors, county business invitees and others would normally expect the expenses including the cost of the meal to be paid by the county.

In the absence of bad faith or other evidence of abuse the meal expense would be “necessarily incurred.”

Meal-time business meetings constitute a practical way of extending a busy work-day into another meeting that the schedule of one or another participant would not otherwise permit.

[209]*209It is unlikely that county commissioners will schedule a meal-time meeting with the objective of obtaining a meal at public expense for themselves or others. A meal-time meeting may mean a sacrifice of time that would preferably be spent with family or friends; it may mean the sacrifice of a tasty and nutritious meal at home; it may result in the loss of needed rest, relaxation or exercise.

To deny commissioners reasonable expenses for meals for themselves, county employees and invited business guests, when, in the exercise of their discretion, they conclude that there are special circumstances and that it is important in the transaction of county business, would be unrealistic. Such a restriction would not be in the best interest of the people the commissioners represent. In a measure it would handicap a Board of Commissioners by withholding from them an accepted and often efficient means of expediting business.

Approximately 21 meal-time meetings occurred in 1980 with expenditures ranging from $7.32 for a 7:00 am working breakfast meeting with the County Solicitor to $225.31 for a dinner meeting with the Secretary of Community Affairs. Local borough and township officials attended the latter meeting which was concerned with flooding problems in the county.

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Related

In re Auditors' Report
91 A. 517 (Supreme Court of Pennsylvania, 1914)

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Bluebook (online)
26 Pa. D. & C.3d 205, 1983 Pa. Dist. & Cnty. Dec. LEXIS 330, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-appeal-from-somerset-co-auditors-pactcomplsomers-1983.