HomeMy WebLinkAbout86-524 FeltyLanny G. Felty, Esquire
320 First & School Streets
Pine Grove, PA 17963
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
March 11, 1986
ADVICE OF COUNSEL
86 -524
Re: Divorce Master, Public Employee, Statement of Financial Interests
Dear Mr. Felty:
This responds to your letter of January 7, 1986, wherein you requested
the advice of the State Ethics Commission.
Issue: Whether a Permanent Divorce Master on contract with a county is to he
considered a public employee within the purview of the State Ethics Act and,
thereby, required to file a Statement of Financial Interests.
Facts: You have advised that under the Pennsylvania Divorce Code you have
been appointed as a Master by the Court of Common Pleas in your county. You
indicate that various counties, including the county where you practice, have
chosen to have one person designated as a Permanent Divorce Master to whom all
divorce cases are referred. The fees that you obtain for this service are
paid into the prothonotary and are turned over by the prothonotary to the
county. You receive your compensation directly from the county under a
contract. You indicate that you have been retained and employed by the county
on a contract basis as a Permanent Divorce Master. Your compensation is a set
monthly fee plus a set monthly secretarial stipend. The contract is signed
between you and the county commissioners.
Pursuant to the Pennsylvania Rules of Civil Procedure, the master is
responsible for hearing evidence presented in divorce matters. The master
must file a record and a transcript of the testimony together with a report
and a recommendation to the court with jurisdiction over the matter. The
Lanny G. Felty, Esquire
March 11, 1986
Page 2
master's report must contain findings of fact, conclusions of law and a
recommendation. Pursuant to the Rules of Civil Procedure, specific items are
to he included in the findings of fact. See Pa. R.C.P. 1920.53, 42 Pa. C.S.A.
The master's report must contain a recommendation to the court to either deny
or grant the divorce in question. The master also must perform certain duties
in relation to any claims for alimony or child support. The recommendations
of the master, of course, are suhject to review and approval by the
appropriate court.
piscussion: Initially, it should he noted that the Commission has previously
addressed the issue of whether the method of employment of a particular
individual who serves a governmental body is determinative in deciding whether
said individual is within the purview of the State Ethics Act. Specifically,
the Commission has held that the fact that an individual is employed on a
contract hasis would not, in and of itself, result in the individual heing
declared outside of the scope of the State Ethics Act. See Massiah - Jackson,
80 -036. In that opinion, the Commission determined that an attorney who is
employed on a service purchase contract hasis as counsel to a senate committee
would he a puhlic employee within the purview of the State Ethics Act, therehy
required to file a Statement of Financial Interests. The Commission
determined that when an individual performs all of the duties and functions
otherwised performed by a puhlic employee, the fact that said individual was
employed on a contract hasis as opposed to some other method of employment
would not he determinative. Rather it was the scope, functions, and duties of
said employment that would he the factors upon which said determination would
he made. Thus, the fact that you are employed on a contract hasis with the
county, would not automatically exclude you from the purview of the State
Ethics Act.
In relation to this specific question presented in your letter of
request, the Commission has previously ruled that masters serving at the
county level would he within the purview of the State Ethics Act and, therehy,
required to file Statements of Financial Interests. See McRride, 83 -011.
Specifically, the Commission in McRride determined that individuals serving in
a position of master for juvenile matters in Reaver County, Pennsylvania, were
considered puhlic employees and therehy suhject to the financial reporting and
disclosure requirements of the State Ethics Act. This determination was based
upon a review of the Act and upon the specific definitions of puhlic employee
as set forth in the Act.
The State Ethics Act provides as follows:
Section 2. Definitions.
"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:
Lanny G. Felty, Esquire
March 11, 19R6
Page 3
(1) contracting or procurement;
(2) administering or monitoring grants or
suhsidies;
(3) planning or zoning;
(4) inspecting, licensing, regulating or auditing
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.
"Puhlic employee" shall not include individuals who are
employed by the State or any political suhdivision thereof
in teaching as distinguished from administrative duties.
65 P.S. 402.
The regulations of the State Ethics Commission further provide as
follows:
Section 1.1. Definitions.
Puhlic employee - --
(R) who meets the criteria of either suhclause
(I) or (II):
(I) The individual is:
( -a -) a person who normally
performs his responsihility in the field
without on -site supervision;
( -h -) the immediate supervisor of a
person who normally performs his
responsihility in the field without
on -site supervision; or
( -c -) the supervisor of any highest
level field office.
(II) The individual is a person:
( -a -) who:
( -1 -) has the authority to
make final decisions;
Lanny G. Felty, Esquire
March 11, 1q86
Page 4
( -2 -) has the authority to
forward or stop recommendations
from heing sent to the person or
holy with the authority to make
final decisions;
( -3 -) prepares or
supervises the preparation of
final recommendations; or
( -4 -) makes the final
technical recommendations; and
( -h -) whose recommendations or
actions:
( -1 -) are an inherent and
recurring part of his position;
and
( -2 -) affect organizations
other than his own organization.
(ii) The term does not include individuals
who are employed by the Commonwealth or a political
subdivision of the Commonwealth in teaching as
distinguished from administrative duties.
(iii) Persons in the positions listed below are
generally considered puhlic employees.
(A) Executive and special directors or
assistants reporting directly to the agency head or
governing hody.
(R) Commonwealth hureau directors, division
chiefs, or heads of equivalent organization
elements and other governmental hody department
heads.
(C) Staff attorneys engaged in representing
the department, agency, or other governmental
holies hefore the puhlic.
Rased upon the foregoing, the Commission has determined that one who
serves as a master is not exempt from filing hecause said individuals do take
and recommend action in that capacity that is other than ministerial. In
Lanny G. FPlty, Fsgl.i re
march 11, 1986
Page 5
setting forth this previous ruling, the Commission did recognize the fact that
certain judicial officers were exempt from the filing requirements. However,
the Commission's determination also noted that the court decison's holding
said individuals exempt from the Act were primarily based upon the fact that
the judiciary had estahlished other codes of conduct that were applicahle to
said officers which contained detailed provisions designed to prevent
conflicts of interest and financial reporting requirements. See
Kremer v. State Ethics Commission, 503 Pa. 358, 469 A.2d 593, (1983). In
relation to one who serves as a master for divorce matters, there is no
separate or distinct code of conduct which would he at this time applicable to
said individuals. As such, the Commission has determined that said
individuals would he puhlic employees within the purview of the State Ethics
Act and thereby required to file the financial interests disclosure
statements. See McRride, supra.
Conclusion: Rased upon the foregoing, and haled upon the previous opinions of
this Commission, you are to he considered a puhlic employee within the purview
of the State Ethics Act and, therefore, required to file a Statement of
Financial Interests in accordance with the Act. The Act requires such filings
he made hy May 1 of every calendar year for which you serve in such position.
Said filing is to he made with the local governing authority, in this case the
county.
Pursuant to Section 7(9)(ii), this Advice is a complete defense in any
enforcement proceeding initiated hy the Commission, and evidence of good faith
conduct in any other civil or criminal proceeding, providing the regiiestor 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 he 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 will he scheduled and a formal
Opinion from the Commission will he issued. Any such appeal must he made, in
writing, to the Commission within 15 days of service of this Advice pursuant
to 51 Pa. Code 2.12.