HomeMy WebLinkAbout1500 Complainant AIn Re: Complainant A File Docket:
X -ref:
Date Decided:
Date Mailed:
Before: Louis W. Fryman, Chair
John J. Bolger, Vice Chair
Donald M. McCurdy
Paul M. Henry
Raquel K. Bergen
Nicholas A. Colafella
ID # 07 -108
LD # 07- 108 -WUA
Order No. 1500
12/4/08
12/19/08
The Investigative Division of the State Ethics Commission conducted an
investigation regarding a possible wrongful use of act and breach of confidentiality under
the Public Official and Employee Ethics Act, 65 Pa.C.S. § 1101 et seq., by the above -
named "Complainant." Written notice of the specific allegations was served at the
commencement of the investigation. Upon completion of the investigation, the
Investigative Division issued and served upon Complainant a Findings Report identified as
an "Investigative Complaint," which constituted the Investigation Division's Complaint
against the Complainant. An Answer was filed and a hearing was requested. A Stipulation
of Findings and a Consent Agreement waiving an evidentiary hearing were subsequently
submitted by the parties to the Commission for consideration. The Stipulated Findings are
set forth as the Findings in this Order. The Consent Agreement has been approved.
Upon issuance, the portion of this adjudication and Order pertaining to wrongful use
of the Ethics Act shall constitute the "preliminary determination" of this Commission as to
wrongful use of the Ethics Act. Per the Commission Regulations at 51 Pa. Code § 25.3(d),
this Commission shall notify the Complainant and the "Subject" (the person against whom
the original Complaint was filed) of the Commission's preliminary determination in this
case. If no appeal is filed with this Commission within thirty days after the mailing date
noted above, the preliminary determination will become absolute, will constitute the final
determination of this Commission as to wrongful use of the Ethics Act (51 Pa. Code §
25.4), and will be made available in redacted form as a public document.
If the final determination of this Commission is that the Complainant has wrongfully
used the Ethics Act, then upon receiving a written request from the Subject, this
Commission shall provide to such Subject the name and address of the Complainant,
together with a copy of the final determination in redacted form. 65 Pa.C.S. § 1110(c).
The files in this case will remain confidential in accordance with Section 1108 of the
Ethics Act, 65 Pa.C.S. § 1108.
Complainant A,
ID # 07- 108 /LD # 07- 108 -WUA
Page 2
I. ALLEGATIONS:
That Complainant A, a private citizen, violated Sections 1108(k), 1110(a)(1) and
1110(a)(2) of the State Ethics Act (Act 93 of 1998), 65 Pa.C.S. § §1108(k), 1110(a)(1) and
1110(a)(2), when he disclosed or acknowledged to other persons information relating to a
complaint he was filing or filed against a public official with the Commission; when the
complaint was filed without probable cause and made primarily for a purpose other than
that of reporting a violation of the Ethics Act; and when he publicly disclosed or caused to
be disclosed that a complaint against a person had been filed with the State Ethics
Commission regarding the conduct of Public Official B of Body C by providing copies of the
complaint to the media.
II. FINDINGS:
1. Complainant A is a D who has complained about [types of issues] in state
government.
a. Complainant A was involved in the protest of [governmental action], which
occurred in [year].
b. Complainant A also has protested [type of issues] over the years.
c. Complainant A earned a Bachelor of Arts Degree from [educational
institution] in [year] and a [professional degree] from [educational institution]
in [year].
2. Complainant A's involvement with state government in Pennsylvania includes
employment with Governmental Body E, a [year] bid for the position of [public office]
and numerous lawsuits filed against the Commonwealth and /or various officials.
3. Complainant A was employed by Governmental Body E from approximately [date]
through [date] and from [date] until [date].
a. Complainant A held positions including Position 1, Position 2 and Position 3.
b. Complainant A was employed as a Position 1 for Public Official F from [date]
until [date].
c. Complainant A was employed as a Position 2 for Public Official F from [date]
until [date].
d. Complainant A was employed as a Position 3 to Public Official G from
approximately [date] until [date].
4. Complainant A has filed several lawsuits seeking [type of reform] within the
Commonwealth of Pennsylvania over the years.
a. Complainant A is not registered as a [type of professional] with the [board
that regulates such professionals].
b. As part of these actions, Complainant A would routinely distribute press
releases to reporters in the Capitol Newsroom.
5. News agencies, including but not limited to News Agency 1, News Agency 2 and
News Agency 3, have offices within the Capitol Newsroom.
Complainant A,
ID # 07- 108 /LD # 07- 108 -WUA
Page 3
a. The Capitol Newsroom is located in Room 524, Main Capitol Building,
Harrisburg, Pennsylvania.
6. On Significant Date 1, an article written by Reporter H, a staff writer for News
Agency 2, appeared on Web Site 1, News Agency 2's online newspaper.
a. The subject of this article was approximately [dollar amount] of taxpayer
money which was spent by [type of public officials] for J purposes.
b. Public Official B is identified in the article as authorizing nearly [dollar
amount] for J in [year].
7 On Significant Date 2 [the day after Significant Date 1], Complainant A prepared a
[number] page press release for distribution.
a. Complainant A's press release consisted of a cover page dated Significant
Date 2, including his name and phone number; a notarized copy of a State
Ethics Commission complaint against Public Official B and a copy of the
Significant Date 1 Web Site 1 article.
b. The press release cover page stated, in part: In light of the [News Agency 2
publication] article on [Body C] [J] contracts the Pennsylvania State Ethics
Commission will be asked to investigate the use of taxpayer funds for
political purposes. The contracts totaled [dollar amount] during [year]. The
complaint is attached."
8. Attached to the press release cover page were pages of documents which included
the following:
a. A State Ethics Commission notarized complaint form identifying the
following: Person Complaining about: Public Official B or Person who
signed for Public Official B.
b. The complaint is against the practice of Body C involving the use of J
contracts that are paid using state taxpayer funds. Newspaper articles
reveal that the K may involve political uses.
c. Also attached was a Web Site I [number] page newspaper article.
d. The complaint was signed by Complainant A.
9. On the morning of Significant Date 2, Complainant A hand delivered copies of the
[number] page press release to reporters in the Capitol Newsroom.
a. Following this distribution, Complainant A then filed the actual complaint with
the State Ethics Commission.
10. On Significant Date 2 at 12:11 p.m. a signed, notarized complaint was received by
the State Ethics Commission filed against the "[Public Official B] or person who
signed for [Public Official B]."
a. The complaint was notarized on [Significant Date 2].
b. State Ethics Commission complaint number 551 was assigned to the matter.
c. The State Ethics Commission complaint form containing a revision date of
SEC 3 11/05 was used for the complaint.
Complainant A,
ID # 07- 108 /LD # 07- 108 -WUA
Page 4
11. The reverse side of the complaint form SEC 3 11/05 (or on page one when obtained
from the State Ethics Commission's web site) contains the following information
from Sections 8, 9 and 10 of the State Ethics Act regarding prohibited retaliation,
confidentiality, penalties and wrongful use of the Act. Specific language includes
the following *:
Prohibited Retaliation — Section 8
(j )
No public official or public employee shall discharge any official or
employee or change his official rank, grade or compensation, or deny
him a promotion or threaten to do so for filing a complaint with or
providing information to the Commission or testifying in any
Commission proceeding.
Confidentiality
(k) As a general rule, no person shall disclose or acknowledge to any
other person any information relating to a complaint, preliminary
inquiry, investigation, hearing or petition for reconsideration which is
before the Commission. However, a person may disclose or
acknowledge to another person matters held confidential in
accordance with this subsection when the matters pertain to any of
the following:
1. Final orders of the Commission as provided in section 8(h).
2. Hearings conducted in public pursuant to section 8(g).
3. For the purpose of seeking advice of legal counsel.
4. Filing an appeal from a Commission order.
5. Communicating with the Commission or its staff in the course
of a preliminary inquiry, investigation, hearing or petition for
reconsideration by the Commission.
6. Consulting with a law enforcement official or agency for the
purpose of initiating, participating in or responding to an
investigation or prosecution by the law enforcement official or
agency.
7. Testifying under oath before a governmental body or a similar
body of the United States of America.
8. Any information, records or proceedings relating to a
complaint, preliminary inquiry, investigation, hearing or petition
for reconsideration which the person is the subject of.
9. The publication or broadcast of information legally obtained by
the news media regarding a confidential Commission
proceeding.
10. The divulgence by individuals who are interviewees or
witnesses as to confidential Commission proceedings
regarding information that was already in their possession or
the disclosure of their own statements.
Penalties — Section 9
(e) Any person who violates the confidentiality of a Commission
proceeding pursuant to Section 8, is guilty of a misdemeanor and
shall be fined not more than $1,000.00 or imprisoned for not more
than one year, or be both fined and imprisoned. Any person who
engages in retaliatory activity proscribed by Section 8(j) is guilty of a
misdemeanor and, in addition to any other penalty provided by law,
Complainant A,
ID # 07- 108 /LD # 07- 108 -WUA
Page 5
shall be fined not more than $1,000.00 or imprisoned for not more
than one year, or be both fined and imprisoned. Any person who
willfully affirms or swears falsely in regard to any material matter
before a Commission proceeding pursuant to Section 8 is guilty of a
felony and shall be fined no more than $5,000.00 or imprisoned for
not more than five years, or be both fined and imprisoned.
Wrongful Use of Act — Section 10
(a) A person who signs a complaint alleging a violation of this act against
another is subject to liability for wrongful use of this act if:
1. The complaint was frivolous * *, as defined by this act, or
without probable cause and made primarily fora purpose other
than that of reporting a violation of this act, or
2. He publicly disclosed or caused to be disclosed that a
complaint against a person had been filed with the
Commission.
(b) A person who signs a complaint alleging a violation of this act has
probable cause for doing so if he reasonably believes in the existence
of the facts upon which the claim is based and either
1. Reasonably believes that under those facts the complaint may
be valid under this act, or
2. Believes to this effect in reliance upon the advice of counsel,
sought in good faith and given after full disclosure of all
relevant facts within his knowledge and information.
*[The Sections of the Ethics Act summarized in Finding 11 are at 65 Pa.C.S. §§
1108(j), 1108(k), 1109(e), and 1110.]
* *Frivolous Complaint — A complaint filed in a grossly negligent manner without
basis in law or fact.
12. Specifically alleged in the complaint was the following practice:
a. This is a complaint against a practice used by [Body C] involving the use of
[J] contracts that are paid for using Pennsylvania State taxpayer funds. In
news articles it has been revealed that [K] may involve political uses. The
contracts involved a total [of dollar amount]. The investigative article from
[News Agency 2] is attached. Please review the article for your
investigation. This complaint does not know who signed the contracts for the
[J] because it has recently been discovered that certain contracts in [Body C]
may have been signed by others in the name of [Public Official B]. It cannot
be said who signed for whom on the contract. It is clear that certain [K] is
political in nature. It is clear that taxpayer funds were used for this contract.
It is clear that someone in [Body C] signed the contract. It is clear that you
have the resources to investigate this matter. It is clear that individual
taxpayers cannot ask for an advisory opinion from the Pennsylvania State
Ethics Commission. It is clear that actions in regard to use of taxpayer funds
for political purposes falls clearly in investigate path and mission of the
Pennsylvania State Ethics Commission.
(It is clear that this online computer program for this online form needs a
major overhaul. It is antiquated.)"
b. The complaint did not specifically name any particular individual.
1. The complaint did identify "[Public Official B] or Person who signed
Complainant A,
ID # 07- 108 /LD # 07- 108 -WUA
Page 6
for the [Public Official B]."
c. Public Official B's offices and phone number of [number] were also listed.
1. The [individual serving in the position of Public Official B] at the time
was Individual L.
13. The copy of the complaint included with Complainant A's Significant Date 2 press
release did not include the complaint number or date and time stamp affixed by the
State Ethics Commission, reflecting that the complaint was distributed by
Complainant A prior to its filing with the State Ethics Commission.
14. Complainant A's Significant Date 2 press release resulted in, at least, three (3)
separate news articles making reference to the complaint in the days that followed.
a. Articles appeared in the News Agency 3 publication and the News Agency 2
publication /Web Site I.
b. Representatives from both of these news organizations have offices within
the Capitol Newsroom.
15. On Significant Date 3 [the day after Significant Date 2], an article written by
Reporter H appeared in the News Agency 2 publication that made specific
reference to Complainant A and his filing of a complaint with the State Ethics
Commission:
Complainant A provided Reporter H with a copy of the press release on
Significant Date 2.
In that article Reporter H wrote: also yesterday a [location] [D] filed a
complaint with the State Ethics Commission, asking the agency to
investigate the [Ms]."
c. Reporter H followed that statement with the following direct quote from
Complainant A: "[quote], [Complainant A], [N] of [0], said moments before
filing the complaint."
a.
b.
16. On Significant Date 2, Complainant A also distributed a copy of the press release,
including the State Ethics Commission complaint, to Reporter P of News Agency 3.
a. Excerpts from the actual complaint were included in a News Agency 3
publication article on Significant Date 3.
b. The article specifically mentions Complainant A's intention to file the
complaint along with direct quotes from the complaint.
c. Complainant A also had two (2) follow up telephone conversations about the
complaint with Reporter P, one on Significant Date 2, and the other on
Significant Date 3.
17. On Significant Date 3, excerpts from an article written by Reporter P appeared in
the News Agency 3 publication, which included information on a complaint
Complainant A intended to file with the State Ethics Commission:
[Location] [D] [Complainant A] said Wednesday he planned to file a state
ethics complaint against [Public Official B] over [quote], according to a copy
of the complaint.
Complainant A,
ID # 07- 108 /LD # 07- 108 -WUA
Page 7
[discussion of substantive issue]
[Complainant A's] complaint with the State Ethics Commission doesn't name
[Public Official B] directly but rather names as the public official being
complained about: "[Public Official B] or Person Who Signed for [Public
Official B]."
[quote from complaint] [Complainant A] wrote on the complaint form. [quote
from complaint]
[Complainant A] was referring to [Public Official B's] statement that [contents
of statement].
[Public Official B's] spokesman declined to comment on Complainant A's
complaint.
Complainant A, when reached Wednesday night, declined to comment
further on the complaint saying that once an ethics complaint is filed with the
Ethics Commission, it is against the law to discuss it. He said he didn't
violate the law by providing copies of the complaint to reporters since he
provided copies of it before filing it Wednesday. The Ethics Act states that a
person can be liable for "wrongful use" of the ethics complaint process if the
person "publicly disclosed or caused to be disclosed that a complaint against
a person had been filed with the commission."
18. On Significant Date 4 [the day after Significant Date 3], a follow up article written by
Reporter P appeared in the News Agency 3 publication discussing whether
"disclosing (an) Ethics complaint before filing it, (is) a violation of law ?"
a. In the article, Complainant A is referenced as filing a complaint with the
State Ethics Commission against Public Official B.
b. Excerpts from the article included the following:
[Location] [D] [Complainant A] said Wednesday that he didn't violate the
state Ethics Act by disclosing to reporters that he planned to file a complaint
against [Public Official B] with the State Ethics Commission.
The Ethics Act states that a person can be liable for "wrongful use" of the
ethics complaint process if the person "publicly disclosed or caused to be
disclosed that a complaint against a person had been filed with the
commission." But [Complainant A] said he didn't violate the law because he
provided copies of the complaint to reporters before filing it with the
commission Wednesday.
[reference to Commission Order]
[Complainant A], when reached Thursday for comment, said: "I can't say
anything."
19. During an interview with a State Ethics Commission investigator, Complainant A
confirmed providing copies of a news release and the complaint form to reporters in
the Capitol newsroom.
a. Complainant A confirmed that he routinely issues press releases to the
Capitol newsroom.
Complainant A,
ID # 07- 108 /LD # 07- 108 -WUA
Page 8
b. Complainant A stated the complaint form was given to reporters prior to filing
the complaint with the State Ethics Commission.
c. Complainant A believed that distributing the complaint prior to filing with the
State Ethics Commission would not breach the confidentiality provisions of
the State Ethics Act.
1. Complainant A refused to discuss the complaint with reporters after
the filing.
III. DISCUSSION:
Complainant A is a private citizen who, on Significant Date 2, filed a complaint with
this Commission. As a Complainant, Complainant A is subject to the confidentiality and
wrongful use of act provisions of the Ethics Act, 65 Pa.C.S. §§ 1108(k), 1110(a)(1), and
1110(a)(2).
The allegations are that Complainant A violated Sections 1108(k), 1110(a)(1) and
1110(a)(2) of the Ethics Act: (1) when he disclosed or acknowledged to other persons
information relating to a complaint he was filing or filed against a public official with the
Commission; (2) when the complaint was filed without probable cause and made primarily
for a purpose other than that of reporting a violation of the Ethics Act; and (3) when he
publicly disclosed or caused to be disclosed that a complaint against a person had been
filed with the State Ethics Commission regarding the conduct of Public Official B of Body C
by providing copies of the complaint to the media.
Section 1108(k) of the Ethics Act provides in part that no person shall disclose or
acknowledge to any other person any information relating to a complaint, preliminary
inquiry, investigation, hearing or reconsideration petition which is before this Commission.
Section 1108(k) of the Ethics Act and Section 21.6 of this Commission's Regulations, 51
Pa. Code § 21.6, further provide for certain exceptions to the confidentiality requirements,
which exceptions are not relevant to this case.
Section 1110(a)(1) of the Ethics Act provides that a wrongful use of the Ethics Act
occurs: (1) if a complaint was frivolous, that is, filed in a grossly negligent manner without
basis in law or fact; or (2) if a complaint was without probable cause and made primarily for
a purpose other than reporting an Ethics Act violation.
Section 1110(a)(2) of the Ethics Act provides that a wrongful use of the Ethics Act
occurs when a complainant publicly discloses or causes to be publicly disclosed that a
complaint against a person has been filed with this Commission. Public disclosure
requires the divulging of the complaint to two or more people. In Re: Complainant A, Order
1469; In Re: Complainant A, Order 1407 -2; In Re: Complainant A, Order 1486.
As noted above, the parties have submitted a Consent Agreement and Stipulation of
Findings. The parties' Stipulated Findings are set forth above as the Findings of this
Commission. We shall now summarize the relevant facts as contained therein.
Complainant A is a D. On Significant Date 2, Complainant A prepared a press
release that included a copy of a State Ethics Commission complaint. The complaint was
signed by Complainant A. The complaint pertained to a practice of Body C involving the
use of J contracts that are paid for using state taxpayer funds. The complaint identified the
person complained about as the "[Public Official B] or person who signed for [Public
Official B]." Public Official B's offices and phone number were also listed on the complaint.
The parties have stipulated that the complaint was against the Public Official B (Fact
Finding 7 a), and that the individual serving as Public Official B at the time was Individual L
(Fact Finding 12 c 1).
Complainant A,
ID # 07- 108 /LD # 07- 108 -WUA
Page 9
On the morning of Significant Date 2, Complainant A hand delivered copies of the
press release to reporters in the Capitol Newsroom located in Room 524, Main Capitol
Building, Harrisburg, Pennsylvania. The reporters to whom Complainant A provided the
press release included Reporter H, a staff writer for News Agency 2, and Reporter P of
News Agency 3.
Following the distribution of the complaint to reporters, Complainant A filed the
actual complaint with this Commission. The complaint was received by this Commission
on Significant Date 2 at 12:11 p.m.
Complainant A's distribution of the press release and complaint to reporters on
Significant Date 2 resulted in at least three (3) separate news articles making reference to
the complaint.
On Significant Date 3 [the day after Significant Date 2], an article by Reporter H
appeared in the News Agency 2 publication that made specific reference to Complainant A
and his filing of a complaint with the State Ethics Commission. The article stated, in part:
"... also yesterday a [location] [D] filed a complaint with the State Ethics Commission,
asking the agency to investigate the [Ms]."
Complainant A had two follow up telephone conversations about the complaint with
Reporter P on Significant Date 2 and Significant Date 3.
On Significant Date 3, the News Agency 3 publication published news
article(s) /excerpts with information on a complaint Complainant A intended to file with this
Commission. The articles(s) /excerpts included the following information:
[Location] [D] [Complainant A] said Wednesday he planned to file a state
ethics complaint against [Public Official B] over [quote], according to a copy
of the complaint.
[Complainant A's] complaint with the State Ethics Commission doesn't name
[Public Official B] directly but rather names as the public official being
complained about: "[Public Official B] or Person Who Signed for [Public
Official B]."
Fact Finding 17. These articles(s) /excerpts also included direct quotes from the complaint.
Id.
On Significant Date 4, a follow up article written by Reporter P appeared in the
News Agency 3 publication discussing whether disclosing an Ethics complaint before filing
it is a violation of law. In the article, Complainant A is referenced as filing a complaint with
the State Ethics Commission against Public Official B.
Complainant A believed that distributing the complaint prior to filing the complaint
with this Commission would not breach the confidentiality provisions of the Ethics Act.
Complainant A refused to discuss the complaint with reporters after the filing.
Having highlighted the Stipulated Findings and issues before us, we shall now apply
the Ethics Act to determine the proper disposition of this case.
The parties' Consent Agreement sets forth a proposed resolution of the allegations
as follows:
3. The Investigative Division will recommend the following in relation to
Complainant A,
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Page 10
the above allegations:
a. That a violation of Section 1108(k) of the Public Official
and Employee Ethics Act, 65 Pa.C.S. §1108(k)
occurred when [Complainant A] disclosed or
acknowledged to other persons information relating to a
complaint he was filing or filed against a public official
with the Commission; and
b. That a violation of Section 1110(a)(2) of the Public
Official and Employee Ethics Act, 65 Pa.C.S.
§1110(a)(2) occurred when [Complainant A] publicly
disclosed or caused to be disclosed that a complaint
against a person had been filed with the State Ethics
Commission regarding the conduct of [Public Official B]
of [Body C] by providing copies of the complaint to the
media; and
c. That no violation of Section 1110(a)(1) of the Public
Official and Employee Ethics Act, 65 Pa.C.S.
§1110(a)(1) occurred when [Complainant A] filed a
complaint with the Ethics Commission as there is
insufficient information to establish that the complaint
was filed without probable cause and primarily for a
purpose other than reporting a violation of the Ethics
Act.
4. [Complainant A] agrees to make payment in the amount of $500.00 in
settlement of this matter payable to the Commonwealth of
Pennsylvania and forwarded to the Pennsylvania State Ethics
Commission within thirty (30) days of the issuance of the final
adjudication in this matter.
5. That pursuant to Section 1110(c) of the Public Official and Employee
Ethics Act, 65 Pa.C.S. §1110(c), upon a finding that a violation of
Section 1110(a) of the Public Official and Employee Ethics Act, 65
Pa.C.S. §1110(a), has occurred, the name of the complainant
([Complainant A]) shall be provided to the subject(s) of the underlying
complaint.
6. The Investigative Division will recommend that the State Ethics
Commission take no further action in this matter; and make no
specific recommendations to any law enforcement or other authority
to take action in this matter. Such, however, does not prohibit the
Commission from initiating appropriate enforcement actions in the
event of Respondent's failure to comply with this agreement or the
Commission's order or cooperating with any other authority who may
so choose to review this matter further.
Consent Agreement, at 1 -2.
In considering the Consent Agreement, we agree with the parties that a violation of
Section 1108(k) of the Ethics Act occurred when Complainant A disclosed or
acknowledged to other persons information relating to the complaint he was filing or filed
against a public official with this Commission.
Factually, on the morning of Significant Date 2, Complainant A hand delivered
Complainant A,
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Page 11
copies of a press release and the completed complaint form to reporters in the Capitol
Newsroom shortly before filing the actual complaint with this Commission. ComplainantA
also had two follow up telephone conversations about the complaint with Reporter P on
Significant Date 2 and Significant Date 3.
Complainant A's Significant Date 2 press release resulted in at least three (3)
separate news articles making reference to the complaint.
Subject to certain exceptions not applicable to this case, Section 1108(k) of the
Ethics Act provides that no person shall disclose or acknowledge to any other person any
information relating to a complaint that is before this Commission. Complainant A believed
that distributing the complaint prior to filing the complaint with this Commission would not
breach the confidentiality provisions of the Ethics Act. However, we have held that the
prohibition of Section 1108(k) of the Ethics Act encompasses a complaint that will be
pending before this Commission. Rittenbaugh, Order No. 1074. To hold otherwise would
lead to an absurd result that Section 1108(k) could be nullified through the timing of the
filing of the complaint. See, 1 Pa.C.S. § 1922.
Accordingly, we hold that a violation of Section 1108(k) of the Ethics Act occurred
when Complainant A disclosed or acknowledged to other persons information relating to a
complaint he was filing or filed against a public official with the Commission.
We also agree with the parties that a violation of Section 1110(a)(2) of the Ethics
Act occurred when Complainant A publicly disclosed or caused to be disclosed that a
complaint against a person had been filed with the State Ethics Commission regarding the
conduct of Public Official B of Body C by providing copies of the complaint to the media.
As noted above, public disclosure requires the divulging of the complaint to two or
more people. In Re: Complainant A, Order 1469; In Re: Complainant A, Order 1407 -2; In
Re: Complainant A, Order 1486. By providing copies of the aforesaid complaint to multiple
members of the media, who then published articles regarding the filing of the complaint,
Complainant A both publicly disclosed (to multiple members of the media) and caused to
be further publicly disclosed (to the general public) the filing of the complaint.
For the same reasons noted above as to Section 1108(k) of the Ethics Act, a
violation of Section 1110(a)(2) of the Ethics Act may be found even if the complaint is
received at this Commission after public disclosure is made. Rittenbaugh, supra.
We hold that a violation of Section 1110(a)(2) of the Ethics Act occurred when
Complainant A publicly disclosed or caused to be disclosed that a complaint against a
person had been filed with the State Ethics Commission regarding the conduct of Public
Official B of Body C by providing copies of the complaint to the media.
As for Section 1110(a)(1) of the Ethics Act, the facts before us fail to establish that
the complaint was without probable cause and made primarily for a purpose other than
reporting a violation of the Ethics Act. Therefore, we hold that no violation of Section
1110(a)(1) of the Ethics Act occurred when Complainant A filed the Significant Date 2
complaint with this Commission as there is insufficient information to establish that the
complaint was filed without probable cause and primarily for a purpose other than reporting
a violation of the Ethics Act.
As part of the Consent Agreement, Complainant A has agreed to make payment in
the amount of $500.00 in settlement of this matter, payable to the Commonwealth of
Pennsylvania and forwarded to this Commission within thirty (30) days of the issuance of
the final adjudication in this matter.
The Consent Agreement further acknowledges that the requirement of Section
Complainant A,
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Page 12
1110(c) of the Ethics Act for disclosure of the name and address of the complainant to the
subject(s) of the complaint is applicable in this matter.
We determine that the Consent Agreement submitted by the parties sets forth the
proper disposition for this case, based upon our review as reflected in the above analysis
and the totality of the facts and circumstances.
Accordingly, pursuant to the Consent Agreement, Complainant A is directed to
make payment in the amount of $500 made payable to the Common of Pennsylvania
and forwarded to this Commission by no later than the thirtieth (30 day after the mailing
date of this adjudication and Order.
We determine there is only one Subject of the complaint at issue in this matter,
specifically, Individual L. First, the parties have stipulated that the complaint was against
the Public Official B (Fact Finding 7a), and that the individual serving as Public Official B at
the time was Individual L (Fact Finding 12 c 1). Furthermore, pursuant to this
Commission's Regulations, a complaint must contain the name, position or office held by
the Subject of the complaint. 51 Pa. Code § 21.1(a). The required information was
provided only as to one person, Individual L.
Given the statutory confidentiality afforded to a complainant, Chief Counsel is
directed to publicly release only fully redacted copy(ies) of this adjudication and Order at
such time as this determination becomes a public record. Following public release, upon
receiving a written request from the Subject of Complainant A's complaint, specifically,
Individual L, Chief Counsel shall provide the name and address of Complainant A to such
Subject, together with copies of the redacted adjudication and Order of this Commission.
See, 65 Pa.C.S. § 1110(c).
IV. CONCLUSIONS OF LAW:
1. Complainant A, as a private citizen who, on Significant Date 2, filed a complaint
with the Pennsylvania State Ethics Commission, is a Complainant subject to the
confidentiality and wrongful use of act provisions of the Public Official and
Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. §§ 1108(k), 1110(a)(1), and
1110(a)(2).
2. A violation of Section 1108(k) of the Ethics Act occurred when Complainant A
disclosed or acknowledged to other persons information relating to a complaint he
was filing or filed against a public official with the Pennsylvania State Ethics
Commission.
3. A violation of Section 1110(a)(2) of the Ethics Act occurred when Complainant A
publicly disclosed or caused to be disclosed that a complaint against a person had
been filed with the Pennsylvania State Ethics Commission regarding the conduct of
Public Official B of Body C by providing copies of the complaint to the media.
4. No violation of Section 1110(a)(1) of the Ethics Act occurred when Complainant A
filed the Significant Date 2 complaint with the Pennsylvania State Ethics
Commission as there is insufficient information to establish that the complaint was
filed without probable cause and primarily for a purpose other than reporting a
violation of the Ethics Act.
5. The only Subject of the complaint at issue in this matter is Individual L.
In Re: Complainant A
File Docket: ID # 07 -108
LD # 07- 108 -WUA
Date Decided: 12/4/08
Date Mailed: 12/19/08
ORDER NO. 1500
1 A violation of Section 1108(k) of the Public Official and Employee Ethics Act
( "Ethics Act "), 65 Pa.C.S. § 1108(k), occurred when Complainant A, a private
citizen, disclosed or acknowledged to other persons information relating to a
complaint he was filing or filed against a public official with the Pennsylvania State
Ethics Commission.
2. A violation of Section 1110(a)(2) of the Ethics Act, 65 Pa.C.S. § 1110(a)(2),
occurred when Complainant A publicly disclosed or caused to be disclosed that a
complaint against a person had been filed with the Pennsylvania State Ethics
Commission regarding the conduct of Public Official B of Body C by providing
copies of the complaint to the media.
3. No violation of Section 1110(a)(1) of the Ethics Act, 65 Pa.C.S. § 1110(a)(1),
occurred when Complainant A filed the Significant Date 2 complaint with the
Pennsylvania State Ethics Commission as there is insufficient information to
establish that the complaint was filed without probable cause and primarily for a
purpose other than reporting a violation of the Ethics Act.
4. Pursuant to the Consent Agreement of the parties, Complainant A is directed to
make payment in the amount of $500 made payable to the Commonwealth of
Pennsylvania and forwarded to the Pennsylvania State Ethics Commission by no
later than the thirtieth (30 day after the mailing date of this Order.
5. At such time as this determination becomes a public record, Chief Counsel shall
publicly release only fully redacted copy(ies) of the adjudication and this Order.
6. Following public release, upon receiving a written request from the Subject of
Complainant A's complaint, specifically Individual L, Chief Counsel shall provide the
name and address of Complainant A to such Subject, together with copies of the
redacted adjudication and Order of this Commission.
7 Compliance by Complainant A with Paragraph 4 of this Order will result in the
closing of this case with no further action by this Commission beyond that set forth
in Paragraphs 5 and 6 of this Order.
a. Non - compliance will result in the institution of an order enforcement action.
BY THE COMMISSION,
Louis W. Fryman, Chair
PLEASE NOTE:
After the Commission issued Order 1500, the federal Courts ruled that Section 1108(k) of the Public
Official and Employee Ethics Act, 65 Pa.C.S. § 1108(k), is unconstitutional insofar as it prohibits public
disclosure by a complainant of the fact that a complaint has been filed with the Commission. See, Stilp
v. Contino, 613 F.3d 405 (3d Cir. Pa 2010), on remand, 743 F. Supp. 2d 460 (M.D. Pa. 2010).