HomeMy WebLinkAbout90-512 KremerJudge I. Raymond Kremer
Court of Common Pleas
Judge's Chambers
604 City Hall
Philadelphia, PA 19107
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
February 20, 1990
•
90 -512
Re: Public Employee /Official, FIS, Judicial Branch, Judge
Dear Judge Kremer:
This responds to your letter of January 8, 1990, in which
you requested advice from the State Ethics Commission.
Issue: Whether a member of the judiciary is to be considered a
"public employee" or "public official" under the State Ethics
Law, and therefore, required to comply with the financial
reporting and disclosure provisions ofL th' State Ethics Law.
Facts: You inquire as to whether judges must file a Statement of
Financial Interests under Act 9 of 1989 which amends Act 170 of
1978. After noting that the General Assembly continued to
define "public official" to include officials in the Judicial
Branch, you reference the Pennsylvania Supreme Court ruling that
such filing was not required under Act 170 of 1978. You
conclude by requesting the position of the State Ethics
Commission on this matter.
The primary question to be answered is whether a member of
the judiciary is to be considered a "public official" or "public
employee" as that term is defined in the State Ethics Law:
Section 2. Definitions.
"Public Official." Any person elected
by the public or elected or appointed by a
governmental body, or an appointed official
in the Executive, Legislative or Judicial
Branch of the State or any political subdivi-
sion thereof, provided that it shall not in-
clude members of advisory boards that have no
Mr. I. Raymond Kremer
Page 2
authority to expend public funds other than
reimbursement for personal expense, or to
otherwise exercise the power of the State or
any political subdivision thereof.
"Public employee." Any individual
employed by the Commonwealth or a political
subdivision who is responsible for taking or
recommending official action of a
nonministerial nature with regard to:
(1) contracting or procurement;
(2) administering or monitoring
grants or subsidies 1
(3) planning or zoning;
(4) inspecting, licensing,
regulating or auliting any
person; or
(5) any other activity where the
official action has an
economic impact of greater
than a de minimus nature on
the interests of any person.
"Public employee" shall not include
individuals who are employed by the State or
any political subdivision thereof in teaching
as distinguished from administrative duties.
The issue of whether members of the Judicial Branch are .
required to file Statements of Financial Interests has been
addressed by the Pennsylvania Supreme Court in Kremer v. State
Ethics Commission, 503 Pa. 358, 469 A.2d 593 (1983) wherein the
court held as follows:
We, now, hold. that (the financial .
disclosure provisions of the Ethics Law
infringe on our power to supervise courts . and
are, therefore, unconstitutional as . applied
in the instant °case. Pursuant to our
supervisory power, we have established a
Code of Judicial Conduct applicable to
judges, which rules contain detailed
provisions designated to prevent conflicts of
interests, financial and otHerwise. Where
judges are involved these rules advance the
Mr. 1. Raymond Kremer
Page 3
0
interests that the Ethics Commission seeks to
serve through application ofjthf Ethics Law.
If further refinement is required, it must be
accomplished through rules promulgated by
this Court and not by legislative enactment.
Id. 595, 596.
See also Waiert v. State Ethics Commission, 491 Pa. 255, 420 A.2d
439 (1980).
Although the definition of "public official" has been
amended in Act 9 of 1989, such amendments are not material
relative to the inquiry herein. The !relevant portions of the
definition of "public official" havejjreexi�aained unchanged under Act
9 of 1989. Since the aforecited decitaions have held that the
filing requirements of the Ethics Law as it relates to public
officials /employees have no application to judges, we conclude
that judges are not to be considered public officials /employees
as those terms are defined in the State Ethics Law.
Conclusion: Judges are not to be considered public
officials /employees as defined in the Ethics Law and
accordingly, would not be subject to the reporting and disclosure
requirements of the State Ethics Law and need not file Statements
of Financial Interests. t
Pursuant to Section 7(9)(ii), this Advice is a complete
defense in any enforcement proceeding initiated by the
Commission, and evidence of good faith conduct in any other civil
or criminal proceeding, providing the requestor has disclosed
truthfully all the material facts and committed the acts
complained of in reliance on the Advice given.
This letter is a public record and will be made available as
such.
Finally, if you disagree with this Advice or if you have any
reason to challenge same, you may request that the full
Commission review this Advice. A personal appearance before the will be scheduled and a formal Opinion from the
Commission will be issued. Any such appeal must be in writing
and must be received at the Commission within 15 days of the date
of this Advice pursuant to 51 Pa. Code S2.12.
Sincerely,
Vincent . Dopko,
Chief Counsel