HomeMy WebLinkAbout1468 ArrowIn Re: Judith Arrow,
Respondent
File Docket:
X -ref:
Date Decided:
Date Mailed:
Before: Louis W. Fryman, Chair
John J. Bolger, Vice Chair
Donald M. McCurdy
Raquel K. Bergen
Nicholas A. Colafella
Reverend Scott Pilarz
07 -036
Order No. 1468
6/16/08
6/19/08
This is a final adjudication of the State Ethics Commission.
Procedurally, the Investigative Division of the State Ethics Commission conducted
an investigation regarding possible violation(s) of the Public Official and Employee Ethics
Act ( "Ethics Act "), 65 Pa.C.S. § 1101 et seq., by the above -named Respondent. At the
commencement of its investigation, the Investigative Division served upon Respondent
written notice of the specific allegation(s). Upon completion of its investigation, the
Investigative Division issued and served upon Respondent a Findings Report identified as
an "Investigative Complaint." An Answer was not filed and a hearing was deemed waived.
The averments in the Investigative Complaint are admitted and are set forth as the
following Findings. The record is complete.
This adjudication of the State Ethics Commission is issued under the Ethics Act and
will be made available as a public document thirty days after the mailing date noted above.
However, reconsideration may be requested. Any reconsideration request must be
received at this Commission within thirty days of the mailing date and must include a
detailed explanation of the reasons as to why reconsideration should be granted in
conformity with 51 Pa. Code § 21.29(b). A request for reconsideration will not affect the
finality of this adjudication but will defer its public release pending action on the request by
the Commission.
The files in this case will remain confidential in accordance with the Ethics Act.
Arrow, 07 -036
Page 2
I. ALLEGATIONS:
That Judy Arrow, a (public official /public employee) in her capacity as a Member of
the Municipal Authority of Washington Township violated the following provisions of the
State Ethics Act (Act 93 of 1998) when she received compensation not provided for by law
by participating in actions of the Authority Board to authorize the expenditure of authority
funds for Board Members' compensation in excess of that approved by the appointing
authority; and when she accepted an increase in compensation prior to the beginning of a
new term of office.
§ 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).
§ 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.
65 Pa.C.S. § 1102.
II. FINDINGS:
1. The Investigative Division of the State Ethics Commission received a signed, sworn
complaint alleging that Judith Arrow violated provisions of the State Ethics Act (Act
93 of 1998).
2. Upon review of the complaint, the Investigative Division initiated a preliminary
inquiry on March 5, 2007.
3. The preliminary inquiry was completed within sixty days.
4. On May 1, 2007, a letter was forwarded to Judith Arrow, by the Investigative
Division of the State Ethics Commission informing her that a complaint against her
was received by the Investigative Division and that a full investigation was being
commenced.
a. Said letter was forwarded by certified mail, no. 7006 2150 0000 8771 6420.
b. The letter was returned to the Investigative Division marked undeliverable.
c. The letter was personally served on Judith Arrow on May 11, 2007, by an
Arrow, 07 -036
Page 3
investigator for the State Ethics Commission.
5. On September 13, 2007, the Investigative Division of the State Ethics Commission
filed an application for a ninety day extension of time to complete the Investigation.
6. The Commission issued an order on October 23, 2007, granting the ninety day
extension.
7 On December 17, 2007, the Investigative Division of the State Ethics Commission
filed an application for a second ninety day extension of time to complete the
Investigation.
8. The Commission issued an order on December 19, 2007, granting the ninety day
extension.
9. On March 4, 2008, an amended Notice of Investigation was forwarded to Judith
Arrow, c/o Samuel J. Davis, Esquire, Law Offices of Davis & Davis, by the
Investigative Division of the State Ethics Commission informing her that the
allegations contained in the May 1, 2007, Notice of Investigation were being
amended.
a. Said letter was forwarded by certified mail, no. 7006 2150 0002 5372 6703.
b. The domestic return receipt bore the signature of Michael Mosko, with a
delivery date of March 7, 2008.
10. Periodic notice letters were forwarded to Judith Arrow in accordance with the
provisions of the Ethics Law advising her of the general status of the investigation.
11. The Investigative Complaint was mailed to the Respondent on April 24, 2008.
12. Judith Arrow served as a member of the Municipal Authority of Washington
Township (hereafter Authority) from August 11, 1999, until July 31, 2007.
a.
Arrow served as the Board Secretary from January 9, 2000, until February
27, 2007.
Arrow was also employed as an Authority employee from February 23, 1982,
until July 31, 2007.
1. Arrow was most recently employed in a full time capacity as the
Authority Office Manager, before her separation from the Authority.
13. The Authority is governed by a seven - member board of directors.
a. The Authority board holds one regularly scheduled meeting per month on the
last Tuesday of each month.*
*[Cf., Fact Finding 29 a.]
1. Special meetings are held as necessary.
14. Authority board members are currently compensated at the rate of $75.00 (gross)
per meeting.
b.
c.
Arrow was initially appointed to fill a vacant seat on the board and was
subsequently re- appointed to full terms in 2000 and 2005.
Arrow, 07 -036
Page 4
a. Board members must be present to receive the $75.00 payment.
15. Individuals in the positions of Board Secretary and Board Treasurer currently
receive an extra $35.00 per month in their respective positions.
a. From at least April 2002 through June 2007, the Board Secretary received
an extra $70.00 per month and the Board Treasurer received an extra
$35.00 per month.
b. Arrow received extra monthly payments of $70.00 as board secretary.
16. Voting at Authority meetings is normally conducted via group "aye /nay" vote after a
motion is made and properly seconded.
a. If any Authority member objects during the group vote, an individual roll call
vote is taken and recorded.
b. Any objections or abstentions cast are specifically noted in the minutes.
1. Minutes of Authority board meetings are approved for accuracy at
subsequent meetings.
17. Authority board members are provided with a meeting packet the Friday prior to the
regularly scheduled meeting.
a. The packet is compiled by the Authority's office staff, which includes Judith
Arrow.
b. The packet includes the upcoming meeting agenda, the prior month meeting
minutes, the treasurer's report including monthly bill list, other various
reports, and correspondence, etc.
1. The bill list represents all expenses paid since the previous meeting.
2. Checks issued to Authority board members are included on the bill
list.
18. Signature authority over Authority accounts is maintained by the Authority Board
Chairman, Treasurer, and Secretary.
a. Authority checks require two signatures.
b. Facsimile stamps representing the signature of the Chairman and Treasurer
previously existed at the Authority office for use by Authority staff.
1. Facsimile stamps are not currently utilized by Authority office staff.
19. The Washington Township Board of Supervisors created the Authority via
Ordinance presented at the August 4, 1952, regular supervisors meeting.
a. The township supervisors created the Authority pursuant to the authority
granted by the Pennsylvania Municipality Authorities Act.
1. Per the Municipality Authorities Act, compensation provided for
Authority board members must be established by the appointing
authority.
Arrow, 07 -036
Page 5
aa. Board members are not permitted to receive an increase or
decrease in compensation during their existing terms.
1. Any increase or decrease in salary becomes
effective only upon the beginning of a new term
after the increase /decrease is enacted.
b. The Authority was incorporated with the Pennsylvania Department of State,
Corporation Bureau, as a Municipal Authority under Entity Number 381069
on August 21, 1952.
1. The Authority has a registered filing address of 1390 Fayette Ave.,
Belle Vernon, PA 15012.
c. The initial objective of the Authority was to provide water services not only
for the majority of its residents but various adjacent communities surrounding
Washington Township as well.
1. The Authority primarily serves residential customers but also provides
services to select commercial and industrial accounts.
20. The original Articles of Incorporation associated with the Authority provided for a
five member board of directors.
a. The original Authority board occasionally discussed both water and sewage
services at monthly meetings.
1. Minutes of the June 25, 1962, Authority regular meeting document the
Authority's Consulting Engineer, John T. Kane, outlining the proposed
sewage system for the township.
aa. Each board member was provided with a copy of the sewage
system plans for review.
2. Minutes of the June 25, 1962, regular meeting document discussions
regarding water and sewage services occurring during the same
meeting.
b. The original by -laws adopted by the Authority board at the September 8,
1952, meeting established that the board meet once per month to conduct
Authority business.
c. The by -laws also permitted special meetings to be held if necessary.
21. Over the next several years, the Washington Township Supervisors became
involved in reviewing the possibility of instituting a sewage system for the township.
a. Washington Township residents utilized individual on -lot systems for sewage
purposes at that time.
1. Residents continue to utilize on -lot systems currently.
b. The Authority was responsible only for the oversight of water services at that
time.
1. The Authority board accomplished its responsibility regarding the
Arrow, 07 -036
Page 6
The supervisors approved the amendments to the Authority's Articles of
Incorporation as documented in the resolution submitted for consideration.
27. In a second undated Resolution, the Authority board voted 4 -0 at its September29,
1998, regular meeting to approve the Amendments to the Authority's Articles of
Incorporation as presented to the township supervisors.
22. In the mid- 1990s, the Department of Environmental Protection (DEP) encouraged
the township to provide sewage services to township residents.
a. Although supportive of a sewage system, DEP was not in favor of the
township owning and operating its own sewage treatment plant.
b. DEP recommended that the township utilize existing treatment facilities in
either Fayette City, PA or Belle Vernon, PA.
23. The township supervisors at the time were not receptive to DEP's proposal which
prompted potential litigation between the township and DEP.
a. Negotiations between the township and DEP resulted in the diffusing of the
potential litigation.
b. As a result of the negotiations, the township agreed to utilize one of the
existing treatment plants in Fayette City or Belle Vernon.
24. The supervisors subsequently met with representatives from Fayette City, Belle
Vernon, and DEP to determine which treatment facility would be utilized.
a. The supervisors eventually opted to utilize the Belle Vernon treatment plant
for the proposed sewage system.
25. At the July 21, 1998, meeting of the Authority Board, the Authority passed a
Resolution proposing the submission of amendments to the original Articles of
Incorporation to the township supervisors for action thereon.
a. The proposed amendments included increasing the number of board
members from five to seven and proposed that the purpose of the Authority
now include the planning, funding, construction, and operation of sewage
facilities throughout the township.
1. The Resolution notes that due to the extensive nature of the planning,
constructing, and operating of the system, two additional Authority
board members were necessary.
2. The Resolution notes the Authority's desire to plan, construct, and
operate the sewage system in Washington Township.
26. Upon submission to the township supervisors, the supervisors adopted Resolution
No. 98 -03 titled, "A Resolution of the Board of Supervisors of Washington
Township, Pennsylvania, Adopting the Amendments to the Articles of Incorporation
of the Municipal Authority of the Township of Washington, Fayette County,
Pennsylvania" at the July 29, 1998, regular supervisor's meeting.
a.
oversight of water services via the conduction of one regularly
scheduled meeting per month with special meetings held as
necessary.
Arrow, 07 -036
Page 7
a. The Resolution also directed the proper officers of the Authority to take all
actions necessary to file the Amendment to the Articles of Incorporation with
the proper authorities.
b. The Amendment to the Articles of Incorporation was filed with the
Pennsylvania Department of State on July 14, 1999.
28. The Authority board held discussions regarding a sewage system for the township
at monthly board meetings as early as 1999.
a. Initial sewage system discussions were incorporated into regular monthly
Authority meetings upon recommendation by representatives from Bankson
Engineers.
1. Bankson Engineers representatives recommended that both water
and sewage issues be discussed at the same monthly meeting.
2. From at least mid -1999 through February 2000, both water and
sewage issues were discussed at the same meeting.
b. Authority board members received $50.00 (gross) per monthly meeting
attended at this time.
1. Each Authority member's check was distributed the night of the
advertised meeting.
2. Checks were generated by Authority Clerk Laura Snyder under
Arrow's direction.
1. Arrow was also an Authority member.
29. Although Bankson Engineers representatives recommended discussing both water
and sewage issues at monthly meetings, the Authority board decided to hold
separate water and sewage meetings on the same evening.
a. From approximately March 2000 through the present, the Authority board
has conducted two separate meetings on the published meeting night.
*[Cf., Fact Finding 13 a.]
b. Arrow was an authority member when the decision was made to hold two
meetings.
30. There was no formal vote by the Authority board to hold two separate meetings on
the same night.
a. Public notices published in The Valley Independent, a local newspaper, from
2003 through 2006 for the Authority describe a single Authority meeting to
be held on the last Tuesday of each month at 7:00 p.m.
1. The notices provide no information regarding two separate meetings
to be held on the same evening.
31. The Authority board made the decision to hold two separate meetings based on the
following:
a. The separation of financial information, billing information, etc. between
Arrow, 07 -036
Page 8
water service and sewage service.
1. The separation of information was considered due to the fact that
various customers residing outside the township who received water
from the Authority would not have the ability to tie into the proposed
sewage system.
2. The Authority board did not feel that customers not eligible for
sewage service should have to pay for costs associated with the
sewage project.
b. The belief that as the sewage project progressed, the time necessary to
discuss relevant issues would increase significantly.
c. The convenience of those in attendance at the meeting.
32. The Authority maintains various bank accounts in relation to its operations.
a. The Authority utilized two separate financial institutions regarding its
General Fund Account from April 2001 through the present.
1. During the time period of April 2001 through approximately October
2003, the Authority General Fund was maintained at PNC Bank under
Account Number 0001930621.
2. From approximately November 2003 through approximately January
2005, the Authority General Fund was maintained at PNC Bank under
Account Number 1016806468.
3. From February 2005 through the present, the Authority General Fund
has been maintained at National City Bank under Account Number
981420167.
b. The Authority utilized two separate financial institutions regarding its
Sewage Account from April 2001 through the present.
1. During the time period of April 2001 through January 2005, the
Authority Sewage Account was maintained at PNC Bank under
Account Number 1011719242.
aa. At the August 31, 2000, regular Authority meeting, the
Authority board approved the use of $5,000.00 for expenses
associated with the sewage project.
bb. The $5,000.00 initial deposit credited to the Sewage account
originated from the General Account at PNC Bank.
2. From February 2005 through the present, the Authority General Fund
has been maintained at National City Bank under Account Number
981420183.
33. From approximately March 2000 through March 2001 the Authority board
conducted separate meetings for water and sewage issues but received only one
check as payment for both meetings.
a. Although two separate meetings were held on the same evening, the
meetings were conducted by the Authority board as a single governing body.
Arrow, 07 -036
Page 9
34. In or about April 2001, the Authority board members began receiving two checks,
one check for the water meeting and an additional check for the sewage meeting.
a. Both meetings were held on the same date and [at the] same location.
1. The second meeting would commence immediately after the first
meeting would adjourn.
b. No official vote was taken by the Authority board authorizing the issuance of
an additional check.
1. The Authority board accepted the additional check without seeking
advice from the authority solicitor or Washington Township, the
appointing body.
c. The Washington Township Supervisors took no official action to approve
separate payments for separate sewage meetings.
1. The Board of Supervisors was not aware, in April 2001, that the
Authority was paying its members for two meetings on the same
dates.
35. Payments to board members for attendance at Authority water meetings were
issued from the Authority General Fund Account while checks representative of
board member attendance at Authority sewage meetings were issued from the
Authority Sewage Account.
a. Board members routinely received both checks the night of the advertised
meeting.
1. Checks generated for board members not in attendance were to be
voided.
b. Board members did not question the number or amounts of checks received.
36. Compensation for the Authority board members was increased at the January 2,
2002, re- organization meeting of the Washington Township Supervisors.
a. The Washington Township Supervisors approved an increase for Authority
board members from fifty dollars per meeting to seventy -five dollars per
meeting via unanimous vote.
b. No records exist of the Authority being notified at the time by the township of
the meeting pay increase.
37. The motion to increase the compensation specifically increased the salaries of,
"Board Members of [sic] Water and Sewage Authority."
a. The motion identified the board members as officials for a single Authority.
b. The motion did not include any language authorizing payments for two
separate meetings.
38. From April 2002 through June 2007, Arrow routinely received separate checks for
her attendance at Authority water and sewage meetings held on the same evening.
CHECK
DATE
CHECK
NUMBER
GROSS
SIGNATURE
AUTHORITY
01/27/04
2118
$370.00
Arrow /Weiss
01/27/04
2125
$350.00
Arrow /Weiss
01/27/04
2131
$475.00
Arrow /Weiss
02/24/04
2172
$295.00
Arrow /Weiss
03/30/04
2209
$220.00
Arrow /Weiss
04/27/04
2236
$145.00
Arrow /Weiss
Arrow, 07 -036
Page 10
a. Arrow, as Authority manager, was responsible for the preparation and
distribution of checks to Authority members.
b. Arrow received $50.00 (gross) for her attendance at each water meeting
from April 2002 through December 2003 and $75.00 (gross) for her
attendance at each water meeting from January 2004 through June 2007.
1. On January 27, 2004, Arrow received two additional checks from the
general fund account to account for the increase in compensation
approved by the supervisors which was not included in water meeting
checks issued in 2002 and 2003.
aa. No vote or official action was taken by the Authority board
authorizing the issuance or receipt of the retroactive
payments.
bb. No presentation was made by representatives of the Authority
to the township supervisors for approval of retroactive
payments issued or received.
cc. Arrow was not eligible for the increase in compensation until
the beginning of her second full term in January 2005.
[c]. Arrow received $50.00 (gross) for her attendance at each sewage meeting
from April 2002 through December 2003 and $75.00 (gross) for her
attendance at each sewage meeting from January 2004 through June 2007.
1. On January 27, 2004, Arrow received two additional checks from the
sewage account to account for the increase in compensation
approved by the supervisors which was not included in sewage
meeting checks issued in 2002 and 2003.
aa. No vote was taken by the Authority board authorizing the
issuance or receipt of the retroactive payments.
bb. No presentation was made by representatives of the Authority
to the township supervisors for approval of retroactive
payments issued or received.
cc. Arrow was not eligible to receive sewage checks as the
Authority board was responsible for both water and sewage
issues as a single Authority board.
39. From January 2004 through December 2004, Arrow received and negotiated fifteen
checks for attendance at Authority water meetings which included the $25.00 per
meeting increase in compensation as shown below:
Check
Number
Number
Meetings
For
of
Paid
Excess
Payment
Amoun
(Gross) Pe
Meeting
05/25/04
Total
Excess
Payment
2118
4
$25.00
$100.00
2125
14
$25.00
$350.00
2131
19
$25.00
$475.00
2172
3
$25.00
$75.00
2209
2
$25.00
$50.00
2236
1
$25.00
$25.00
2263
1
$25.00
$25.00
2291
1
$25.00
$25.00
2318
2
$25.00
$50.00
2389
1
$25.00
$25.00
2411
1
$25.00
$25.00
2461
1
$25.00
$25.00
2494
2
$25.00
$50.00
2529
3
$25.00
$75.00
2547
1
$25.00
$25.00
Total
$1,400.00
CHECK
DATE
CHECK
NUMBER
GROSS
SIGNATURE
AUTHORITY
05/25/04
2263
$145.00
Check Not Available
06/29/04
2291
$145.00
Arrow /Weiss
07/27/04
2318
$220.00
Arrow /Weiss
08/31/04
2389
$145.00
Arrow /Weiss
09/28/04
2411
$145.00
Arrow /Weiss
11/05/04
2461
$145.00
Arrow /Weiss
12/03/04
2494
$220.00
Arrow /Weiss
12/21/04
2529
$295.00
Arrow /Weiss
12/30/04
2547
$75.00
Arrow /Weiss
Arrow, 07 -036
Page 11
a. Check Numbers 2125 and 2131, both issued on January 27, 2004, were
issued as retroactive payments for water meetings attended in 2002 and
2003 to account for the difference in amounts of checks previously issued
and the increase approved by the township supervisors respectively.
b. Arrow was not eligible for the increase in compensation until the beginning of
her second full term in January 2005.
40. Arrow received $1,400.00 in excess payment as a result of accepting checks issued
for attendance at Authority water meetings which included the $25.00 increase in
compensation to which she was not entitled as shown below:
a. Arrow's signature as an authorized Authority signatory appears on at least
fourteen of fifteen checks issued to Arrow which included excess payment
for attendance at Authority meetings.
b. Arrow cashed or deposited into her personal bank account all checks
received and utilized the funds for various personal use.
CHECK
DATE
CHECK
NUMBER
GROSS
SIGNATURE
AUTHORITY
05/28/02
1622
$ 50.00
Arrow /Canigiani
06/18/02
1630
$ 50.00
Arrow /Canigiani
08/27/02
1645
$ 50.00
Arrow /Canigiani
09/24/02
1654
$ 50.00
Arrow /Sotta
10/30/02
1662
$ 50.00
Arrow /Canigiani
11/19/02
1677
$ 50.00
Arrow /Canigiani
01/28/03
1685
$ 50.00
Arrow /Sotta
02/25/03
1693
$ 50.00
Arrow /Weiss
04/29/03
1708
$ 50.00
Arrow /Weiss
05/27/03
1716
$ 50.00
Arrow /Sotta
06/24/03
1731
$ 50.00
Arrow /Sotta
07/29/03
1740
$ 50.00
Arrow /Weiss
08/21/03
1747
$ 50.00
Arrow /Sotta
09/30/03
1755
$ 50.00
Arrow /Weiss
10/28/03
1765
$ 50.00
Arrow /Weiss
11/25/03
1773
$ 50.00
Arrow /Weiss
12/16/03
1781
$ 50.00
Arrow /Weiss
01/27/04
1798
$300.00
Arrow /Weiss
01/27/04
1805
$300.00
Arrow /Weiss
Meeting
Date
Arrow's
Vote
Final
Vote
Check
Date
Check
No
Check
Amount
(Gross)
$370.00
$350.00
$475.00
01/27/04
Yes
7 -0
01/27/04
01/27/04
01/27/04
2118
2125
2131
02/24/04
Yes
7 -0
02/24/04
2172
$295.00
03/30/04
Yes
7 -0
03/30/04
2209
$220.00
04/27/04
Yes
7 -0
04/27/04
2236
$145.00
05/25/04
Yes
6 -0
05/25/04
2263
$145.00
06/29/04
Yes
6 -0
06/29/04
2291
$145.00
07/27/04
Yes
7 -0
07/27/04
2318
$220.00
08/31/04
Yes
7 -0
08/31/04
2389
$145.00
09/28/04
Yes
6 -0
09/28/04
2411
$145.00
11/30/04
Yes
7 -0
11/05/04
2461
$145.00
12/21/04
Yes
7 -0
12/03/04
12/21/04
12/30/04
2494
2529
2547
$220.00
$295.00
$275.00
Arrow, 07 -036
Page 12
41. Arrow participated in actions as an Authority board member in approving monthly
bill lists on which excess payment received for attendance at the water portion of
Authority meetings was documented as shown below:
a. Arrow voted to approve monthly bill lists on eleven of eleven instances that
excess payment to Arrow was documented to which Arrow was not entitled.
42. From April 2002 though June 2007, Arrow received and negotiated fifty -nine checks
totaling $4,825.00 (gross) from the Authority's sewage account at either PNC Bank
(Account No. 1011719242) or National City Bank (981420183) representative of
payment for sewage meetings attended on the same night as regular Authority
water meetings as shown below:
CHECK
DATE
CHECK
NUMBER
GROSS
SIGNATURE
AUTHORITY
01/27/04
1812
$ 75.00
Arrow /Weiss
02/24/04
1820
$ 75.00
Arrow /Weiss
03/30/04
1828
$ 75.00
Check Not Available
04/27/04
1838
$ 75.00
Arrow /Weiss
05/25/04
1846
$ 75.00
Check Not Available
06/29/04
1854
$ 75.00
Arrow /Weiss
07/27/04
1864
$ 75.00
Arrow /Weiss
08/31/04
1879
$ 75.00
Arrow /Weiss
09/28/04
1881
$ 75.00
Arrow /Weiss
11/05/04
1899
$150.00
Arrow /Weiss
11/05/04
1907
$ 75.00
Arrow /Weiss
12/03/04
1914
$150.00
Arrow /Weiss
12/21/04
1922
$ 75.00
Arrow /Weiss
01/25/05
1931
$ 75.00
Arrow /Weiss
02/22/05
1000
$ 75.00
Arrow /Weiss
03/29/05
1009
$ 75.00
Arrow /Weiss
04/26/05
1018
$ 75.00
Arrow /Weiss
05/31/05
1027
$ 75.00
Arrow /Weiss
06/28/05
1036
$ 75.00
Arrow /Weiss
07/26/05
1044
$ 75.00
Arrow /Weiss
08/30/05
1053
$ 75.00
Arrow /Weiss
09/27/05
1063
$ 75.00
Arrow /Weiss
10/25/05
1074
$ 75.00
Arrow /Weiss
11/29/05
1082
$ 75.00
Arrow /Weiss
12/07/05
1091
$225.00
Arrow /Weiss
12/19/05
1100
$ 75.00
Arrow /Weiss
01/31/06
1111
$ 75.00
Arrow /Weiss
02/28/06
1118
$ 75.00
Arrow
03/24/06
1125
$ 75.00
Arrow /Weiss
04/25/06
1136
$ 75.00
Arrow /Weiss
05/30/06
1145
$ 75.00
Arrow /Weiss
07/25/06
1160
$150.00
Arrow /Weiss
08/29/06
1170
$ 75.00
Arrow /Weiss
09/26/06
1183
$ 75.00
Arrow /Weiss
10/28/06
1196
$ 75.00
Arrow /Weiss
11/28/06
1206
$ 75.00
Arrow /Weiss
12/19/06
1213
$ 75.00
Arrow /Weiss
01/30/07
1221
$ 75.00
Sotta /Weiss
02/27/07
1231
$ 75.00
Sotta /Weiss
06/29/07
1263
$ 75.00
Zadrozny /Russell
TOTAL:
$4,825.00
Arrow, 07 -036
Page 13
a. Check Numbers 1798 and 1805, both issued on January 27, 2004, were
issued as retroactive payments for sewage meetings attended in 2002 and
2003 to account for the difference in amounts of checks previously issued
and the increase approved by the township supervisors respectively.
1 Retroactive payment issued was based on the supposition of Arrow
attending one sewage meeting each month during 2002 and 2003
(i.e. 1 meeting per month multiplied by twelve months per year
multiplied by $25.00 difference equals $300.00).
Meeting
Date
Arrow's
Vote
Final
Vote
Check
Date
Check
No.
Check
Amount
(Gross)
05/28/02
Yes
7 -0
05/28/02
1622
50.00
06/18/02
Yes
7 -0
06/18/02
1630
$ 50.00
08/27/02
Yes
7 -0
08/27/02
1645
$ 50.00
09/24/02
Yes
7 -0
09/24/02
1654
$ 50.00
10/29/02
Yes
7 -0
10/30/02
1662
$ 50.00
11/19/02
Yes
7 -0
11/19/02
1677
$ 50.00
01/28/03
Yes
6 -0
01/28/03
1685
$ 50.00
02/25/03
Yes
7 -0
02/25/03
1693
$ 50.00
04/29/03
Yes
7 -0
04/29/03
1708
$ 50.00
05/27/03
Yes
7 -0
05/27/03
1716
$ 50.00
06/24/03
Yes
6 -0
06/24/03
1731
$ 50.00
07/29/03
Yes
7 -0
07/29/03
1740
$ 50.00
08/21/03
Yes
7 -0
08/21/03
1747
$ 50.00
09/30/03
Yes
7 -0
09/30/03
1755
$ 50.00
10/28/03
Yes
7 -0
10/28/03
1765
$ 50.00
11/25/03
Yes
7 -0
11/25/03
1773
$ 50.00
12/16/03
Yes
7 -0
12/16/03
1781
$ 50.00
01/27/04
Yes
7 -0
01/27/04
01/27/04
01/27/04
1798
1805
1812
$300.00
$300.00
$ 75.00
02/24/04
Yes
7 -0
02/24/04
1820
$ 75.00
03/30/04
Yes
7 -0
03/30/04
1828
$ 75.00
04/27/04
Yes
7 -0
04/27/04
1838
$ 75.00
05/25/04
Yes
6 -0
05/25/04
1846
$ 75.00
06/29/04
Yes
6 -0
06/29/04
1854
$ 75.00
07/27/04
Yes
7 -0
07/27/04
1864
$ 75.00
08/31/04
Yes
7 -0
08/31/04
1879
$ 75.00
09/28/04
Yes
6 -0
09/28/04
1881
$ 75.00
10/26/04
Yes
7 -0
NCI*
NCI*
NCI*
11/30/04
Yes
7 -0
11/05/04
11/05/04
1899
1907
$150.00
$ 75.00
12/21/04
Yes
7 -0
12/03/04
12/21/04
1914
1922
$150.00
$ 75.00
01/25/05
Yes
7 -0
01/25/05
1931
$ 75.00
02/22/05
Yes
7 -0
02/22/05
1000
$ 75.00
03/29/05
Yes
7 -0
03/29/05
1009
$ 75.00
04/26/05
Yes
7 -0
04/26/05
1018
$ 75.00
05/31/05
Yes
7 -0
05/31/05
1027
$ 75.00
06/28/05
Yes
6 -0
06/28/05
1036
$ 75.00
07/26/05
Yes
7 -0
07/26/05
1044
$ 75.00
08/30/05
Not Present
6 -0
08/30/05
1053
$ 75.00
Arrow, 07 -036
Page 14
b. Of the fifty -nine checks issued to Arrow representative of attendance at
sewage meetings, Arrow's signature appears on at least fifty -four checks
totaling $4,450.00 as an authorized Authority signatory.
c. Arrow cashed or deposited Authority checks received into her personal bank
account(s) and utilized the funds for various personal use.
43. Arrow participated in actions as an Authority board member in approving monthly
bill lists on which payment received for attendance at the sewage portion of
Authority meetings was documented as shown below:
Meeting
Date
Arrow's
Vote
Final
Vote
Check
Date
Check
No.
Check
Amount
( Gross)
$ 75.00
09/27/05
Yes
6 -0
09/27/05
1063
10/25/05
Yes
7 -0
10/25/05
1074
$ 75.00
11/29/05
Yes
7 -0
11/29/05
1082
$ 75.00
12/20/05
Yes
7 -0
12/07/05
12/19/05
1091
1100
$225.00
$ 75.00
01/31/06
Yes
7 -0
01/31/06
1111
$ 75.00
02/28/06
Yes
7 -0
02/28/06
1118
$ 75.00
03/28/06
Yes
7 -0
03/24/06
1125
$ 75.00
04/25/06
Yes
7 -0
04/25/06
1136
$ 75.00
05/30/06
Not Present
5 -0
05/30/06
1145
$ 75.00
07/25/06
Yes
7 -0
07/25/06
1160
$150.00
08/29/06
Yes
7 -0
08/29/06
1170
$ 75.00
09/26/06
Yes
7 -0
09/26/06
1183
$ 75.00
10/31/06
Yes
6 -0
10/28/06
1196
$ 75.00
11/28/06
Yes
6 -0
11/28/06
1206
$ 75.00
12/19/06
Yes
7 -0
12/19/06
1213
$ 75.00
01/30/07
January bills tabled until February meeting
02/27/07 No 5 -1 01/30/07 1221 $ 75.00
January bills approved at February meeting- February bills tabled until March
meeting
03/27/07 I Not Present 1 6 -0 1 02/27/07 11231 I$ 75.00
February bills approved at March meeting -No official action on
March bills
04/24/07
Not Present
No official action on April bills
06/26/07
Yes
7 -0
06/29/07
1263
$ 75.00
Meeting Date
Arrow Present
Check
Number
Gross
07/30/02
No
1512
$50.00
08/30/05
No
1257
75.00
05/30/06
No
1613
75.00
Total
$200.00
Arrow, 07 -036
Page 15
NCI = No Check Issued
a. Arrow was present and voted to approve fifty of fifty -one bill lists on which
payment to her was noted for attendance at sewage portions of Authority
meetings.
44. In addition to Arrow's receipt of payment for sewage meetings held on the same
evening as Authority water meetings, errors were made in the issuance or non -
issuance of checks to Arrow regarding her attendance at regular Authority
meetings.
a. Authority board members must be present at Authority meetings in order to
receive compensation.
45. Arrow was responsible for the issuance of payments to her for an Authority water
meeting held on July 30, 2002, and for Authority water and sewage meetings held
on August 30, 2005, and May 30, 2006, totaling $200.00, which she did not attend
as shown below:
a. Arrow was the manager responsible for the issuance of payments to board
members for meeting attendance.
Arrow, 07 -036
Page 16
b. Minutes document Arrow's absence at the meetings.
1. Arrow accepted Authority checks for attendance at meetings for which
she was not present.
c. Payment noted represents payment for the water portion of the Authority
meetings only.
1. Erroneous payment for the sewage portion of the Authority meetings
noted was previously accounted for (See, Finding No. 43).
2. The $25.00 retroactive compensation issued for the July 30, 2002,
meeting was previously accounted for (See, Finding No. 41).
46. Arrow was erroneously not issued payment for the Authority meeting held on
October 26, 2004, which she attended.
a. Minutes document Arrow's attendance at the meeting.
b, Compensation due Arrow for attendance at the meeting totals approximately
$50.00.
47. Authority board members are no longer receiving separate checks representative of
payment for attendance at Authority water and sewage meetings held on the same
evening.
a. In July 2007, the Authority board elected to stop the receipt of separate
checks for water and sewage meetings held on the same evening based on
the advice of the Authority's newly appointed solicitor.
b. The decision to cease the separate meeting payment was not formally voted
on by the Authority board.
1. The decision was based on informal discussions held with the newly
appointed solicitor.
48. During a sworn statement with Commission investigators on February 26, 2008,
Arrow stated the following:
a. Snyder routinely generated checks to be issued to Authority board members.
1. Arrow instructed Snyder on the amounts of the checks to be written.
2. Arrow distributed checks the night of the actual meeting to those
Authority board members in attendance.
3. Any checks written in the name of Authority board members not in
attendance were to be voided.
b. The decision to hold and be paid for two separate meetings for water and
sewage issues was made by then Chairman Melvin Weiss upon soliciting
input from other board members.
c. The Authority board never formally voted to hold separate water and sewage
meetings.
Arrow, 07 -036
Page 17
1 Arrow did not know if the Washington Township Board of Supervisors
ever formally authorized payment of two checks to the Authority board
members for separate water and sewage meetings held.
d. Arrow issued retroactive checks to Authority board members for water and
sewage meetings held in 2002 and 2003 based on Weiss's direction to do
so.
49. Arrow, as a member of the Authority board, realized a financial gain of
approximately $6,375.00 as a result of approving bill lists documenting payment to
herself for attendance at water and sewage portions of Authority meetings in excess
of that approved by the appointing authority, signing checks representing partially
or in whole the excess payment, and accepting said payment; and when she
accepted an increase in compensation prior to the beginning of a new term of office:
Excess payment received for water portions of Authority meetings: $1100.00
Payment for attendance at sewage portions of Authority meetings: $4,800
Payment for Authority meetings at which Arrow was not present: $ 200.00
Credit for payment not received for Attendance at Authority meetings: $ 5 0.00
Total: $6,37500
III. DISCUSSION:
As a Member of the Municipal Authority of Washington Township from August 11,
1999, until July 31, 2007, Respondent Judith Arrow, hereinafter also referred to as
"Respondent," "Respondent Arrow," or "Arrow," has been a public official subject to the
provisions of the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1101
et seq.
The allegations are that Arrow violated Section 1103(a) of the Ethics Act when she
received compensation not provided for by law by participating in actions of the Authority
Board to authorize the expenditure of Authority funds for Board Members' compensation in
excess of that approved by the appointing authority; and when she accepted an increase
in compensation prior to the beginning of a new term of office.
Pursuant to Section 1103(a) of the Ethics Act, a public official /public employee is
prohibited from engaging in conduct that constitutes a conflict of interest:
§ 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 term "conflict of interest" is 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
Arrow, 07 -036
Page 18
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.
65 Pa.C.S. § 1102.
Section 1103(a) of the Ethics Act prohibits a public official /public employee from
using the authority of public office /employment or confidential information received by
holding such a public position for the private pecuniary benefit of the public official /public
employee himself, any member of his immediate family, or a business with which he or a
member of his immediate family is associated.
We shall now summarize the facts pertaining to this case. Given Respondent's
failure to file an Answer to the Investigative Complaint, the facts as averred by the
Investigative Complaint are deemed admitted by Respondent. 65 Pa.C.S. § 1108(e); 51
Pa. Code § 21.5(k)(1).
The Washington Township Board of Supervisors ( "Board of Supervisors ") created
the Municipal Authority of Washington Township ( "Authority ") in 1952, pursuant to the
authority granted by the Pennsylvania Municipality Authorities Act. The original by -laws
adopted by the Authority Board in 1952 established that the Authority Board would meet
once per month to conduct Authority business. The by -laws also permitted special
meetings to be held if necessary.
The initial objective of the Authority was to provide water services for the majority of
residents of Washington Township ( "Township "), as well as residents of various adjacent
communities. However, in 1999, with the approval of the Board of Supervisors, the
Authority's Articles of Incorporation were amended to include as a purpose of the Authority
the planning, funding, construction, and operation of sewage facilities throughout the
Township.
Respondent Arrow served as a Member of the seven - Member Authority Board from
August 11, 1999, until July 31, 2007. Arrow served as Secretary of the Authority Board
from January 9, 2000, until February 27, 2007. Arrow also served as an Authority
employee from February 23, 1982, until July 31, 2007. Most recently, Arrow was employed
by the Authority as the full time Office Manager, in which capacity she was responsible for
the preparation and distribution of checks to Authority Board Members.
Per the Fact Findings, from at least mid -1999 through February 2000, the Authority
Board followed the recommendations of an engineering firm to discuss water and sewage
issues at the same monthly meetings. At that time, Authority Board Members received
$50.00 (gross) per monthly meeting attended. However, subsequently, and without a
formal vote, the Authority Board decided to hold separate water and sewage meetings on
the same evenings. Arrow was an Authority Board Member when this decision was made.
From approximately March 2000 through the present, the Authority Board has
conducted two separate meetings on published meeting nights. Such meetings have been
held consecutively and at the same location. From approximately March 2000 through
March 2001, Board Members attending Authority Board meetings continued to receive one
check per meeting night, which was for both meetings. However, in or about April 2001,
Arrow and other Authority Board Members began receiving two checks per meeting night,
Arrow, 07 -036
Page 19
with one check being for the water meeting and an additional check being for the sewage
meeting.
Per the Municipality Authorities Act, compensation provided for authority board
members must be established by the appointing authority (in this case, the Board of
Supervisors). 53 Pa.C.S. § 5610(d). Authority board members are not permitted to
receive an increase or decrease in compensation during their existing terms. Id. Any
increase or decrease in salary becomes effective only upon the beginning of a new term
after the increase /decrease is enacted. Id.
The Board of Supervisors took no official action to approve payments to Authority
Board Members for separate water and sewage meetings. In April 2001, the Board of
Supervisors was not aware that the Authority was paying its Board Members for two
meetings on the same dates.
At the January 2, 2002, re- organization meeting of the Board of Supervisors, the
compensation for Authority Board Members was increased from fifty dollars per meeting to
seventy -five dollars per meeting. The motion to increase the compensation identified the
Board Members as officials for a single Authority. The motion did not include any
language authorizing payments for two separate meetings. No records exist of the
Authority being notified by the Township at that time of the meeting pay increase.
From April 2002 through June 2007, Arrow routinely received separate checks for
her attendance at Authority Board water and sewage meetings held on the same evening.
Arrow received $50.00 (gross) for her attendance at each water meeting from April
2002 through December 2003 and $75.00 (gross) for her attendance at each water
meeting from January 2004 through June 2007. On January 27, 2004, Arrow received two
additional Authority checks to account for the increase in compensation approved by the
Board of Supervisors that was not included in water meeting checks issued in 2002 and
2003. However, Arrow was not eligible to receive the increase in compensation until the
beginning of her second full term in January 2005.
Arrow received $1,400.00 in excess payments as a result of accepting fifteen
checks issued for attendance at Authority water meetings that included the $25.00
increase in compensation to which she was not entitled, as detailed in Fact Finding 40.
Arrow participated in actions as an Authority Board Member in approving monthly bill lists
that included all of the aforesaid fifteen checks, as detailed in Fact Finding 41.
Signature authority over Authority accounts is maintained by the Authority Board
Chairman, Treasurer, and Secretary. Authority checks require two signatures. Arrow's
signature appears as an authorized Authority signatory on at least fourteen of the
aforesaid fifteen checks.
Arrow cashed or deposited into her personal bank account all of the aforesaid
checks she received and utilized the funds for various personal use.
Arrow received $50.00 (gross) for her attendance at each sewage meeting from
April 2002 through December 2003 and $75.00 (gross) for her attendance at each sewage
meeting from January 2004 through June 2007. On January 27, 2004, Arrow also received
two additional Authority checks to account for the increase in compensation approved by
the Board of Supervisors that was not included in sewage meeting checks issued in 2002
and 2003. However, Arrow was not eligible to receive sewage meeting checks at all,
because the Authority Board was responsible for both water and sewage issues as a
single Authority Board.
As detailed in Fact Finding 42, from April 2002 though June 2007, Arrow received
Arrow, 07 -036
Page 20
and negotiated fifty -nine Authority checks totaling $4,825.00 (gross) representing payment
for sewage meetings attended on the same night as regular Authority water meetings.
Arrow participated in actions of the Authority Board in approving monthly bill lists that
included fifty -five of the aforesaid checks, totaling $4,525.00, as detailed in Fact Finding
43. Arrow's signature appears as an authorized Authority signatory on at least fifty -four of
the aforesaid checks, totaling $4,450.00. There were only two such checks -- Authority
checks 1221 and 1231, totaling $150.00- -for which Arrow neither signed nor voted to
approve the payments. (Cf., Fact Findings 42 and 43). Arrow cashed or deposited
Authority checks received into her personal bank account(s) and utilized the funds for
various personal use.
Authority Board Members must be present at Authority Board meetings in order to
receive meeting compensation. Arrow was responsible for the issuance of payments
totaling $200.00 to herself for Authority Board meetings held July 30, 2002, August 30,
2005, and May 30, 2006, which meetings she did not attend.
Arrow was erroneously not issued payment for the Authority Board meeting held on
October 26, 2004, which she did attend. Compensation due Arrow for attendance at that
meeting would total approximately $50.00.
In July 2007, the Authority Board elected to stop issuing separate checks for water
and sewage meetings held on the same evening, based on the advice of the Authority's
newly appointed solicitor.
During a sworn statement with Commission investigators on February 26, 2008,
Arrow stated, inter alia, the following: Authority Clerk Laura Snyder ( "Snyder ") routinely
generated checks to be issued to Authority Board Members; Arrow instructed Snyder on
the amounts of the checks to be written; the decision to hold and be paid for two separate
meetings for water and sewage issues was made by then Chairman Melvin Weiss upon
soliciting input from other Authority Board Members; the Authority Board never formally
voted to hold separate water and sewage meetings; Arrow did not know if the Board of
Supervisors ever formally authorized payment of two checks to the Authority Board
Members for separate water and sewage meetings held; and Arrow issued retroactive
checks to Authority Board Members for water and sewage meetings held in 2002 and 2003
based on Weiss's direction to do so.
Per the Fact Findings of the Investigative Complaint, deemed admitted by Arrow,
Arrow realized a financial gain of approximately $6,375.00, consisting of the following: (1)
$1,400 in excess payments for attendance at Authority water meetings; (2) $4,825.00 in
payments for attendance at Authority sewage meetings when the Board of Supervisors had
not authorized compensation for separate water and sewage meetings; (3) and $200.00 in
payments for Authority Board meetings Arrow did not attend, less a $50.00 credit for a
payment Arrow should have received, but did not receive, for a meeting she did attend.
Having summarized the above relevant facts, we must now determine whether the
actions of Arrow violated Section 1103(a) of the Ethics Act. As we apply the facts to the
allegations, due process requires that we not depart from the allegations. Pennsy v.
Department of State, 594 A.2d 845 (Pa. Cmwlth. 1991). A violation of the Ethics Act must
be based upon clear and convincing proof. 65 Pa.C.S. § 1108(g). Clear and convincing
proof is "so `clear, direct, weighty, and convincing as to enable the trier of fact to come to a
clear conviction, without hesitance, of the truth of the precise facts in issue." In Re:
Charles E.D.M., 550 Pa. 595, 601, 708 A.2d 88, 91 (1998) (Citation omitted).
The allegations are that Arrow violated Section 1103(a) of the Ethics Act when she
received compensation not provided for by law: (1) by participating in actions of the
Authority Board to authorize the expenditure of Authority funds for Board Members'
compensation in excess of that approved by the appointing authority (Board of
Arrow, 07 -036
Page 21
Supervisors); and (2) when she accepted an increase in compensation prior to the
beginning of a new term of office.
The first allegation pertains to unauthorized payments Arrow received for attending
sewage meetings as separate meetings. Each element of a violation of Section 1103(a) of
the Ethics Act has been established as to this allegation.
From April 2002 though June 2007, Arrow received and negotiated fifty -nine
Authority checks totaling $4,825.00 (gross) representing payment for sewage meetings
attended on the same night as regular Authority water meetings. Arrow used the authority
of her public office as an Authority Board Member when she participated in actions of the
Authority Board in approving monthly bill lists that included fifty -five of these Authority
checks totaling $4,525.00, as detailed in Fact Finding 43. See, Cours, Order 1150;
Hoover, Order 1402; Nagele, Order 1403; Harton, Order 1421. Arrow also used the
authority of her public office when she, as the Authority Board Secretary, signed as an
authorized Authority signatory at least fifty -four of the checks totaling $4,450.00. See,
Schlanger, Order 1257; Hoover, supra; Nagele, supra; Harton, supra; Latkanich, Order
1445.
The payments Arrow received for sewage meetings constituted a private pecuniary
benefit to Arrow, specifically, unauthorized compensation. Per the Municipality Authorities
Act, compensation provided for authority board members must be established by the
appointing authority (in this case, the Board of Supervisors). 53 Pa.C.S. § 5610(d). The
Board of Supervisors took no official action to approve payments to Authority Board
Members for separate water and sewage meetings.
Because the first allegation does not encompass Arrow's actions in signing
Authority checks as an authorized signatory, but rather, is limited to Arrow's participation in
actions of the Authority Board, we hold that Arrow violated Section 1103(a) of the Ethics
Act when she received compensation in the amount of $4,525.00, which was not provided
for by law, by participating in actions of the Authority Board to authorize the expenditure of
Authority funds for Authority Board Members' compensation in excess of that approved by
the Board of Supervisors.
The second allegation pertains to Arrow's acceptance of an increase in meeting pay
prior to the beginning of a new term of office.
As noted above, at the January 2, 2002, re- organization meeting of the Board of
Supervisors, the compensation for Authority Board Members was increased from fifty
dollars per meeting to seventy -five dollars per meeting. However, per the Municipality
Authorities Act, authority board members are not permitted to receive an increase or
decrease in compensation during their existing terms. 53 Pa.C.S. § 5610(d). Any increase
or decrease in salary becomes effective only upon the beginning of a new term after the
increase /decrease is enacted. Id. Arrow was not eligible to receive the increase in
compensation until the beginning of her second full term in January 2005.
Arrow received $1,400.00 in excess payments as a result of accepting fifteen
checks issued for attendance at Authority water meetings that included the $25.00
increase in compensation to which she was not entitled, as detailed in Fact Finding 40.
Such excess compensation was not authorized in law and constituted a private pecuniary
benefit to Arrow.
The element of use of authority of office has been established. Arrow used the
authority of her public office when she participated in actions as an Authority Board
Member in approving monthly bill lists that included all of the aforesaid fifteen checks, as
detailed in Fact Finding 41. Arrow also used the authority of her public position when she,
as the Authority Board Secretary, signed as an authorized Authority signatory at least
Arrow, 07 -036
Page 22
fourteen of the aforesaid fifteen checks.
With each element of a violation of Section 1103(a) established, we hold that Arrow
violated Section 1103(a) of the Ethics Act when she received compensation in the amount
of $1,400.00, which was not provided for by law, when she accepted an increase in
compensation (meeting pay) prior to the beginning of a new term of office. See, Trimer,
Order 1285.
As for the amount of $150.00 ($200.00 minus $50.00 credit) that Arrow received for
Authority Board meetings she did not attend, we find no violation of Section 1103(a) of the
Ethics Act based upon the applicability of the "de minimis" exclusion to the Ethics Act's
definition of "conflict" or "conflict of interest," 65 Pa.C.S. § 1102. See, Bixlerv. State Ethics
Commission, 847 A.2d 785 (Pa. Cmwlth. 2004).
Section 1107(13) of the Ethics Act empowers this Commission to require restitution
in instances where a public official /public employee has obtained a financial gain in
violation of the Ethics Act. We shall now determine whether restitution would be
appropriate in this case.
The Investigative Division has filed a Position Statement seeking an order for
restitution. Respondent has filed a Position Statement asserting that she lacked "evil
intent" and that she is presently experiencing adverse financial circumstances.
We determine that restitution in the total amount of $5,925.00 is warranted in this
case as to the aforesaid private pecuniary benefits ($4,525.00 plus $1,400.00) that
Respondent received in violation of Section 1103(a) of the Ethics Act. However, we shall
permit Respondent to pay the aforesaid restitution in 36 monthly installments as set forth
below.
Respondent Arrow is directed to pay restitution to the Authority in the total amount
of $5,925.00 in monthly payments of $164.58 for thirty -five (35) months, and a final
payment of $164.70, with all such payments to be payable to the Authority and forwarded
to this Commission for processing, and with the first such payment to be forwarded to this
Commission by no later than the thirtieth (30 day after the mailing date of this
adjudication and Order. Respondent may prepay the amount due at any time.
Non - compliance will result in the institution of an order enforcement action.
IV. CONCLUSIONS OF LAW:
1. As a Member of the Municipal Authority of Washington Township ( "Authority ") from
August 11, 1999, until July 31, 2007, Respondent Judith Arrow ( "Arrow") has been a
public official subject to the provisions of the Public Official and Employee Ethics
Act ( "Ethics Act "), 65 Pa.C.S. § 1101 et seq.
2. Arrow violated Section 1103(a) of the Ethics Act when she received compensation
in the amount of $4,525.00, which was not provided for by law, by participating in
actions of the Authority Board to authorize the expenditure of Authority funds for
Authority Board Members' compensation in excess of that approved by the
Washington Township Board of Supervisors.
3. Arrow violated Section 1103(a) of the Ethics Act when she received compensation
in the amount of $1,400.00, which was not provided for by law, when she accepted
an increase in compensation (meeting pay) prior to the beginning of a new term of
office.
4. Arrow did not violate Section 1103(a) of the Ethics Act as to the amount of $150.00
Arrow, 07 -036
Page 23
($200.00 minus $50.00 credit) that she received for Authority Board meetings she
did not attend, based upon the applicability of the "de minimis" exclusion to the
Ethics Act's definition of "conflict" or "conflict of interest," 65 Pa.C.S. § 1102.
5. Restitution is warranted in this case.
In Re: Judith Arrow,
Respondent
ORDER NO. 1468
File Docket: 07 -036
Date Decided: 6/16/08
Date Mailed: 6/19/08
1 Respondent Judith Arrow ( "Arrow "), a public official in her capacity as a Member of
the Municipal Authority of Washington Township ( "Authority ") from August 11, 1999,
until July 31, 2007, violated Section 1103(a) of the Public Official and Employee
Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1103(a), when she received compensation in
the amount of $4,525.00, which was not provided for by law, by participating in
actions of the Authority Board to authorize the expenditure of Authority funds for
Authority Board Members' compensation in excess of that approved by the
Washington Township Board of Supervisors.
2. Arrow violated Section 1103(a) of the Ethics Act when she received compensation
in the amount of $1,400.00, which was not provided for by law, when she accepted
an increase in compensation (meeting pay) prior to the beginning of a new term of
office.
3. Arrow did not violate Section 1103(a) of the Ethics Act as to the amount of $150.00
($200.00 minus $50.00 credit) that she received for Authority Board meetings she
did not attend, based upon the applicability of the "de minimis" exclusion to the
Ethics Act's definition of "conflict" or "conflict of interest," 65 Pa.C.S. § 1102.
4. Respondent Arrow is directed to pay restitution to the Authority in the total amount
of $5,925.00 in monthly payments of $164.58 for thirty -five (35) months, and a final
payment of $164.70, with all such payments to be payable to the Authority and
forwarded to this Commission for processing, and with the first such payment to be
forwarded to this Commission by no later than the thirtieth (30 day after the
mailing date of this Order. Respondent may prepay the amount due at any time.
a. Non - compliance will result in the institution of an order enforcement action.
BY THE COMMISSION,
Louis W. Fryman, Chair