HomeMy WebLinkAbout82-532 SprecherJeffrey K. Sprecher
Criminal Court Administrator
Court of Common Pleas
Of Berks County
23rd Judicial District of PA
Berks County Courthouse
Reading, PA 19601
Dear Mr. Sprecher:
Mailing Address:
STATE ETHICS COMMISSION
P.O. BOX 1179
HARRISBURG, PA 17108
TELEPHONE: (717) 783 -1610
April 2.0, 1982
ADV -ICE OF COUNSEL
RE: Constables, Financial Interest Statements
82 -532
This responds to your letter of March 29, 1982 in which
you request advice regarding the application of the Ethics
Act to constables.
Issue: You request advice as to whether constables are
required to complete Statements of Financial Interest on a
yearly basis.
Facts: Constables may be in some instances appointed, but
more commonly elected. The Supreme Court of Pennsylvania
has prescribed a code of conduct for constables. Currently,
the State Ethics Commission does not require incumbent
judges (as incumbents or candidates) to submit Statements of
Financial Interest.
Discussion: The Ethics Act, 65 P.S. 401 et seq. defines
public official as "any elected or appointed official in the
executive, legislative or judicial branch of the state or
any political subdivision." 65 P.S. 402. Thus, a constable
would typically be subject to the Ethics Act and be required
to file Financial Interest Statements pursuant to Section
4(a) and (b) of the Ethics Act unless other circumstances
intervene.
State Ethics Commission • 308 Finance Building • Harrisburg, Pennsylvania
Jeffrey K. Sprecher
April 20, 1982
Page 2
In the current situation other circumstances do
intervene which indicate that, at present, incumbent
constables, either appointed or elected, as in ^urnbents or
candidates will not be required to file Financial Interest
Statements pending the Supreme Court's disposition of its
review in the Kremer v. State Ethics Commission case. The
reason for this current, interim ruling, is as follows..
Basically, the Supreme Court in its decision in
relation to Section 3(e) of the Ethics Act in Wajert v.
State Ethics Commission, Pa. , 420 A.2d 439 (7930),
indicated that the constitution of Pennsylvania gives the
Supreme Court of the Commonwealth the exclusive power to
promulgate regulations governing practice, procedure, and
conduct of all officers of the Court system. Constables are
included in the category of "all officers" who would serve,
process or inforce orders, judgments or decrees of the
Court. See Article 5 Section 10(c) of the Pennsylvania
Constitution. In addition the Commonwealth'Court has ruled
that Sections 4(d) and.5 of the Ethics Act may not consti-
tutionally be applied to judges. See Kremer v.' State Ethics
Commission, Pa. Cmwlth. , 424 A.2d 986 (1981).
Given the precedents and given the fact that Supreme
Court has prescribed a code 'of conduct for constable. they
must be considered persons who serve, process issue by
justices of the peace and enforcing their judgment it must
be logically perceived that such persons as constables are
thought to be essential officers of the Court. See Note 2
Rule 2, 13 P.S. Chapter 1 Appendix. Essentially, the
Supreme Court's Code states that "a constable is an integral
part of the judicial system." As an integral part of the
judicial system, constables are to be regulated by the
Supreme Court under Article 5, Section 10(c) of the Pennsyl-
vania Constitution. Since the ability of the Legislature to
promulgate the Ethics.Act and to apply that Act to members
of the "judicial system" is in question under the previously
cited rulings, the Ethics Commission will not at the present
time require incumbent constables, elected or appointed, as
incumbents or candidates to file Financial Interest State-
ments. This ruling is only applicable pending the final
determination of the Supreme Court in the Kremer case. This
ruling is consistent with the policy adopted by the Commission
in relation to judges in general.
L
Jeffrey K. Sprecher
April _Q, 1982
Page 3
This ruling does not effect the requirement that non -
incumbent candidates for the post of constable are, in the
Commission's estimation, required to file Financial Interest
Statement as candidates for that office.
Conclusion: Pending the Supreme Court's determination in
the Kremer case, the Ethics Commission, at its discretion,
will apply the same policy to incumbent constables as
members of the judicial system as it is currently applying
to incumbent members of the judiciary itself. Thus,
incumbents, constables, elected or appointed as incumbents
or candidates for re- election or re appointment need not
file Financial Interest Statements on an annual basis or
otherwise. This determination is, as noted above, applicable
only until the Supreme Court's final determination in the
Kremer case.
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 Commission may be scheduled and a formal Opinion
from the Commission will be issued. You should make such a
request or indicate your disapproval of this Advice within
the next 30 days.
SSC /rdp
Sincerely,
Sandra S. C istianson
General Co•nsel
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