HomeMy WebLinkAbout433-S Avila
In Re: Jennine Avila, : File Docket: 14-027-P
Respondent : X-ref: Order No. 433-S
: Date Decided: 1/28/15
: Date Mailed: 1/30/15
Before: Nicholas A. Colafella, Chair
Mark R. Corrigan
Roger Nick
Kathryn Streeter Lewis
Maria Feeley
Melanie DePalma
Brian Westmoreland
This is a final adjudication of the State Ethics Commission as to the alleged
delinquency and/or deficiency of Statement(s) of Financial Interests required to be filed
pursuant to Sections 1104 and 1105 of the Public Official and Employee Ethics Act
("Ethics Act"), 65 Pa.C.S. §1101 et seq.
The Investigative Division initiated these proceedings by filing with the State Ethics
Commission and serving upon Respondent a Petition for Civil Penalties. An Order to
Show Cause was issued to Respondent. A Stipulation of Findings and a Consent
Agreement 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 as modified at this Commission’s public meeting
on January 28, 2015.
I. FINDINGS:
1. Jennine Avila (“Respondent”) is an adult individual who resides or maintains a
mailing address at 6752 Rutland Street, Philadelphia, PA 19149.
2. At all times relevant to these proceedings, Respondent has been an Income
Maintenance Caseworker with the Pennsylvania Department of Public Welfare, and
as such, Respondent has at all times relevant to these proceedings been a "public
employee" as defined in Section 1102 of the Ethics Act, 65 Pa.C.S. § 1102.
3. Respondent, as a public employee, is subject to the Statement of Financial
Interests filing provisions of the Ethics Act.
4. Respondent has failed to provide full financial disclosure as required by the Ethics
Act. Respondent has failed to file a Statement of Financial Interests for calendar
year 2013, which Statement of Financial Interests was to be filed by May 1 of 2014,
and Respondent has therefore transgressed Sections 1104 and 1105 of the Ethics
Act, 65 Pa.C.S. §§ 1104, 1105.
5. By Notice Letter dated August 18, 2014, Respondent was served with Notice in
accordance with Section 1107(5) of the Ethics Act of the specific allegations against
Avila, 14-027-P
Page 2
Respondent concerning the above transgression. Said Notice Letter provided
Respondent an opportunity to avoid the institution of these civil penalty proceedings
by filing an accurate and complete Statement of Financial Interests for calendar
year 2013 within twenty (20) days of the date of the Notice Letter. Respondent has
failed and/or otherwise refused to file a Statement of Financial Interests for
calendar year 2013 so as to comply with the specific requirements of the Ethics Act.
6. By Notice Letter dated October 2, 2014 (sent via Certified Mail), Respondent was
served with Notice in accordance with Section 1107(5) of the Ethics Act of the
specific allegations against Respondent concerning the above transgression. Said
Notice Letter provided Respondent an opportunity to avoid the institution of civil
penalty proceedings by filing an accurate and complete Statement of Financial
Interests for calendar year 2013 so as to comply with the specific requirements of
the Ethics Act.
7. Respondent did not file her Statement of Financial Interests for calendar year 2013
within the twenty (20) day time allotment afforded by the Notice Letters of August
18, 2014, and/or October 2, 2014.
8. As of December 17, 2014, Respondent had not filed a complete and accurate
Statement of Financial Interests for calendar year 2013.
II. DISCUSSION:
As an Income Maintenance Caseworker for the Pennsylvania Department of Public
Welfare (“Department of Public Welfare”), Jennine Avila (“Avila”) was at all times relevant
to these proceedings a “public employee” subject to the provisions of the Public Official
and Employee Ethics Act ("Ethics Act"), 65 Pa.C.S. § 1101 et seq. See, Quaglia v. State
Ethics Commission, 986 A.2d 974 (Pa. Cmwlth. 2010), amended by, 2010 Pa. Commw.
LEXIS 8 (Pa. Cmwlth. January 5, 2010), allocatur denied, 607 Pa. 708, 4 A.3d 1056
(2010).
Pursuant to Section 1104(a) of the Ethics Act, Avila was specifically required to file
a Statement of Financial Interests for calendar year 2013 with the Department of Public
Welfare on or before May 1, 2014. See, Quaglia, supra. Section 1104(a) provides:
§ 1104. Statement of financial interests required to be filed
(a) Public official or public employee.--
Each public official of the
Commonwealth shall file a statement of financial interests for the preceding
calendar year with the commission no later than May 1 of each year that he
holds such a position and of the year after he leaves such a position. Each
public employee and public official of the Commonwealth shall file a
statement of financial interests for the preceding calendar year with the
department, agency, body or bureau in which he is employed or to which he
is appointed or elected no later than May 1 of each year that he holds such a
position and of the year after he leaves such a position. Any other public
employee or public official shall file a statement of financial interests with the
governing authority of the political subdivision by which he is employed or
within which he is appointed or elected no later than May 1 of each year that
he holds such a position and of the year after he leaves such a position.
Persons who are full-time or part-time solicitors for political subdivisions are
required to file under this section.
65 Pa.C.S. § 1104(a).
Avila, 14-027-P
Page 3
The complete financial disclosure which Avilaas an Income Maintenance
Caseworker for the Department of Public Welfare was required to provide in the Statement
of Financial Interests form is statutorily mandated in detail at Section 1105 of the Ethics
Act, 65 Pa.C.S. § 1105.
Section 1109(f) of the Ethics Act provides as follows:
§ 1109. Penalties
(f)Civil penalty.--
In addition to any other civil remedy or criminal
penalty provided for in this chapter, the commission may, after notice has
been served in accordance with section 1107(5) (relating to powers and
duties of commission) and upon a majority vote of its members, levy a civil
penalty upon any person subject to this chapter who fails to file a statement
of financial interests in a timely manner or who files a deficient statement of
financial interests, at a rate of not more than $25 for each day such
statement remains delinquent or deficient. The maximum penalty payable
under this paragraph is $250.
65 Pa.C.S. § 1109(f).
An application of Section 1109(f) to this case establishes that this Commission has
the discretion to levy a maximum civil penalty against Avila for the delinquent Statement of
Financial Interests for calendar year 2013.
The prerequisite service of a Notice letter in accordance with Section 1107(5) was
satisfied. Avila did not remedy the failure to comply with the Ethics Act although given
more than the usual grace period following Notice in which to do so.
The Investigative Division then instituted formal proceedings against Avila by filing
with this Commission and serving upon her a Petition for Civil Penalties. The Commission
Chair issued an Order to Show Cause, ordering Avila to show cause why a civil penalty
should not be levied against her. The parties then filed a Stipulation of Findings and
Consent Agreement.
In the Consent Agreement, the parties proposed that this case be resolved by: (1)
this Commission finding that Avila failed to timely file her Statement of Financial Interests
for the 2013 calendar year in compliance with Section 1104(a) of the Ethics Act; (2) Avila
making payment of a civil penalty in the amount of $250.00 in settlement of this matter,
payable to the Commonwealth of Pennsylvania and forwarded to this Commission upon
execution of the Consent Agreement; and (3) Avila paying $100.00 to this Commission,
representing a portion of the costs incurred by the Commission in the investigation and
enforcement of this matter, to be made payable to the Pennsylvania State Ethics
Commission. At this Commission’s public meeting on January 28, 2015, we granted a
Motion of the Investigative Division to withdraw the proposed payment to the Commission
for costs.
We believe that the Consent Agreement as modified by the withdrawal of the
proposed payment to the Commission for costs sets forth a proper disposition for this case,
based upon our review of the totality of the facts and circumstances. Accordingly, we
approve the Consent Agreement as modified by such withdrawal.
We hereby find that Avila, as an Income Maintenance Caseworkerfor the
Department of Public Welfare, failed to timely file her Statement of Financial Interests for
the 2013 calendar year in compliance with Section 1104(a) of the Ethics Act, 65 Pa.C.S. §
1104(a).
Avila, 14-027-P
Page 4
Per the Consent Agreement of the parties, we hereby levy one civil penalty against
Avila in the total amount of $250.00 for Avila’s delinquent Statement of Financial Interests
for calendar year 2013.
Avila shall be ordered to make payment of the aforesaid civil penalty in the amount
th
of $250.00 by no later than the thirtieth (30) day after the mailing date of this adjudication
and Order, by forwarding to this Commission a certified check or money order in the
amount of $250.00 made payable to the Commonwealth of Pennsylvania, for deposit in the
State Treasury.
Avila shall be ordered to file a complete and accurate Statement of Financial
Interests for calendar year 2013 with the Department of Public Welfare by no later than the
th
thirtieth (30) day after the mailing date of this adjudication and Order, with one copy
forwarded to this Commission for compliance verification purposes.
III. CONCLUSIONS OF LAW:
1. As an Income Maintenance Caseworker for the Pennsylvania Department of Public
Welfare, Jennine Avila (“Avila”) was at all times relevant to these proceedings a
"public employee" subject to the provisions of the Public Official and Employee
Ethics Act (“Ethics Act”), 65 Pa.C.S. § 1101 et seq.
2. Avila, as an Income Maintenance Caseworkerforthe Pennsylvania Department of
Public Welfare, failed to timely file her Statement of Financial Interests for the 2013
calendar year in compliance with Section 1104(a) of the Ethics Act, 65 Pa.C.S. §
1104(a).
3. Notice of the delinquency of Avila's Statement of Financial Interests for calendar
year 2013 was previously served upon herin accordance with Section 1107(5) of
the Ethics Act, 65 Pa.C.S. § 1107(5).
4. Based upon the totality of the circumstances in this case, the imposition of a civil
penalty in the total amount of $250.00 is warranted.
In Re: Jennine Avila, : File Docket: 14-027-P
Respondent : Date Decided: 1/28/15
: Date Mailed: 1/30/15
ORDER NO. 433-S
1. Jennine Avila (“Avila”), as an Income Maintenance Caseworker for the
Pennsylvania Department of Public Welfare, failed to timely file her Statement of
Financial Interests for the 2013 calendar year in compliance with Section 1104(a) of
the Public Official and Employee Ethics Act, 65 Pa.C.S. § 1104(a).
2. Per the Consent Agreement of the parties, we hereby levy one civil penalty against
Avila in the total amount of $250.00 for Avila’s delinquent Statement of Financial
Interests for calendar year 2013.
3. Avila is ordered to make payment of the aforesaid civil penalty in the total amount of
th
$250.00 by no later than the thirtieth (30) day after the mailing date of this Order,
by forwarding to this Commission a certified check or money order in the amount of
$250.00 made payable to the Commonwealth of Pennsylvania, for deposit in the
State Treasury.
4. Avila is ordered to file a complete and accurate Statement of Financial Interests for
calendar year 2013 with the Pennsylvania Department of Public Welfare by no later
th
than the thirtieth (30) day after the mailing date of this Order, with one copy
forwarded to the Pennsylvania State Ethics Commission for compliance verification
purposes.
5. Failure to comply with Paragraph 3 or 4 of this Order will result in the initiation of an
appropriate enforcement action.
BY THE COMMISSION,
______________________
Nicholas A. Colafella, Chair