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STATE ETHICS COMMISSION
309 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
In Re: David J. Croyle, File Docket: 16 -052 -P
Respondent X -ref: Order No. 515 -S
Date Decided: 10/20/16
Date Mailed: 1113116
Before: Nicholas A. Colafella, Chair
Mark R. Corrigan, Vice Chair
Roger Nick
Melanie DePalma
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 sect.
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. An Answer was not filed by the Respondent, and a
hearing was deemed waived. The record is complete. The Findings in this Order are
derived from the Petition for Civil Penalties filed by the Investigative Division.
I. FINDINGS:
1. Respondent is an adult individual who resides or maintains a mailing address at
[address redacted].
2. At all times relevant to these proceedings, Respondent has been a Council Member
for Kittanning Borough, and as such, Respondent has at all times relevant to these
proceedings been a public official" as defined in Section 1102 of the Ethics Act, 65
Pa. C.S. § 1102.
3. Respondent as a public official 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 b e Ethics
Act. Respondent has failed to file Statements of Financial Interests Zr fo calendar
years 2013 and 2014, which Statements of Financial Interests were to be filed by
May 1 of 2014, and May 1 of 2015, respectively, and Respondent has therefore
transgressed Sections 1104 and 1105 of the Ethics Act, 65 Pa.C.S. §§ 1 104, 1105.
5. By Notice letter dated February , 2016, Respondent was served with Notice in
accordance with Section 1107() of the Ethics Act of the specific allegations against
Respondent concerning the above transgressions. Said Notice letter provided
Respondent an opportunity to avoid the institution of these civil penalty proceedings
by filing accurate and complete Statements of Financial Interests for calendar years
2013 and 2014 within twenty (20) days of the date of the Notice letter. Respondent
has failed and refused to file Statements of Financial Interests for calendar years
2013 and 2014 so as to comply with the specific requirements of the Ethics Act.
6. By Notice letter dated March 16, 2016, Respondent was served with Notice in
accordance with Section 1107(5) of the Ethics Act of the specific allegations against
Respondent concerning the above transgressions. Said Notice letter provided
P.O. BOX 11470, HARRISBURG, PA 17108-1470 • 717 - 783.1610 ^ 1.800- 932 -0936 • www.ethics.state.pa.us
Crro le 16 -052 -P
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Respondent an opportunity to avoid the institution of these civil penalty proceedings
by filing accurate and complete Statements of Financial Interests for calendar years
2013 and 2014 within twent� (20) days of the date of the Notice letter. Respondent
has failed and refused to fie Statements of Financial Interests for calendar years
2013 and 2014 so as to comply with the specific requirements of the Ethics Act.
Section 1109(f) of the Ethics Act provides:
§ 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).
For each violation the Commission finds, Respondent is subject to civil penalty
liability under Section 1109(f) of the Ethics Act, 65 Pa.C.S. § 1109�f), at a rate of not
more than $25.00 per day for each day the Statement of Financial nterests remains
delinquent or deficient, for a maximum civil penalty of $250.00 per violation.
Because Respondent has committed two violations alleged herein, Respondent is
subject to total maximum civil penalty liability of $500.00.
There are no mitigating circumstances and Respondent should be assessed the
maximum civil penalty of $500.00, in that the twenty -day deadline set forth in the
said final Notice letter to Respondent has expired and the Respondent has not
complied.
DISCUSSION:
As a Council Member for Kittanning Borough, David J. Croyle ( "Croyle ") was at all
times relevant to these proceedings a "public official" subject to the provisions of the Public
Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 110'1 et seq.
Pursuant to Section 1104(a) of the Ethics Act, Croyle was specifically required to file
Statements of Financial Interests for calendar years 2013 and 2014 with Kittanning
Borough on or before May 1, 2014, and May 1, 2015, respectively. 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 receding calendar year with the
department, agency, body or bureau in Uich 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
Croyle, 16 -052 -P
Page 3
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).
The complete financial disclosure which Croyle as a Council Member for Kittanning
Borough 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 $250.
65 Pa.C.S. § 1109(f).
An application of Section 1109(f) to this case establishes that this Commission has
the discretion to levy a maximum civil penalty against Croyle for each delinquent Statement
of Financial Interests for calendar years 2013 and 2014.
The prerequisite service of a Notice letter in accordance with Section 1107(5) was
satisfied. Croyle did not remedy the failure to comply with the Ethics Act although given
more than the usual grace period following Notice in which to do so. The Investigative
Division then instituted formal proceedings against Croyle by filing with the State Ethics
Commission and serving upon Croyle a Petition for Civil Penalties. The Commission Chair
issued an Order to Show Cause, ordering Croyle to show cause why civil penalties should
not be levied against him. Croyle did not file an answer to the Order to Show Cause.
There is nothing of record that would constitute a defense or excuse for Croyle's failure to
comply with the Ethics Act. Croyle has failed to show cause why civil penalties should not
be levied against him in this matter.
We find that Croyle, as a Council Member for Kittanning Borough, failed to comply
with Section 1104(x) of the Ethics Act, 65 Pa.C.S. § 1104(a), when he failed to file
Statements of Financial Interests for calendar years 2013 and 2014 with Kittanning
Borough.
We hereby ley two maximum civil penalties against Croyle, each at the rate of
Twenty -Five Dollars ($y25.0%14 per day, for each day his Statements of Financial Interests for
calendar years 2013 and have remained delinquent. Given the number of days
during which the Statements of Financial Interests have remained delinquent, the resultant
amount to be levied against Croyle totals Five Hundred Dollars ($500.00).
Croyle shall be ordered to make payment of the above civil penalties in the total
amount of $500.00 by no later than the thirtieth (30 ) day after the mailing date of this
adjudication and Order, by forwarding a check to this Commission made payable to the
Commonwealth of Pennsylvania, for deposit in the State Treasury.
Croyle, 16 -052 -P
Page 4
Croyle shall be ordered to file complete and accurate Statements of Financial
Interests for calendar years 2013 and 2014 with Kittanning Borough by no later than the
thirtieth (30 ) day after the mailing date of this adjudication and Order, with a copy of each
such filing forwarded to this Commission for compliance verification purposes.
III. CONCLUSIONS OF LAW:
1. David J. Croyle ( "Croyle "), as a Council Member for Kittanning Borough, was at all
times relevant to these proceedings a "public official" subject to the provisions of the
Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1101 et seg.
2. Croyle, as a Council Member for Kittanning Borough, failed to comply with Section
1104(a) of the Ethics Act, 65 Pa.C.S. § 1104(a), when he failed to fife Statements of
Financial Interests for calendar years 2013 and 2014 with Kittanning Borough.
3. Notice of the delinquency of Croyle's Statements of Financial Interests for calendar
years 2013 and 2014 was previously served upon him in 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 two
maximum civil penalties in the total amount of $500.00 is warranted.
In Re: David J. Croyle, File Docket: 16 -052 -P
Respondent Date Decided: 10/20/16
Date Mailed: 1113116
ORDER NO. 515 -S
David J. Croyle ( "Croyle "), as a Council Member for Kittanning Borough, failed to
comply with Section 1104(a) of the Public Official and Employee Ethics Act ( "Ethics
Act "), 65 Pa.C.S. § 1104(a), when he failed to file Statements of Financial Interests
for calendar years 2013 and 2014 with Kittanning Borough.
This Commission hereby levies two maximum civil penalties against Croyle, each at
the rate of Twenty -Five Dollars ($25.00) per day, for each day his Statements of
Financial Interests for calendar years 2013 and 2014 have remained delinquent, for
total civil penalty liability of Five Hundred Dollars ($500.00). Croyle is ordered to
payy said civil penalties in the total amount of $500.00 by no later than the thirtieth
(30` ") day after the mailing date of this Order, by forwarding a check to the State
Ethics Commission made payable to the Commonwealth of Pennsylvania, for
deposit in the State Treasury.
3. Croyle is ordered to file complete and accurate Statements of Financial Interests for
calendar years 2013 and 2014 with Kittanning Borough by no later than the thirtieth
i30 ) day after the mailing date of this Order, with a copy of each such filing
orwarded to the State Ethics Commission for compliance verification purposes.
Failure to comply with Paragraph 2 or 3 of this Order will result in the initiation of an
appropriate enforcement action.
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