HomeMy WebLinkAbout93-575 DoughertyMr. Thomas J. Dougherty
645 South 26th Street
Harrisburg, PA 17111
Re:
Parole Supervisor;
Board of Probation
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:±fir t ie It
STATE ETHICS COMMISSION
309 FINANCE BUILDING
'P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
June 25, 1993
93 -575
Bureau of Institutional Parole Services;
and Parole; Public Employee; FIS.
Dear Mr. Dougherty:
This responds to your letter dated June 17, 1993, in which you
appeal the determination of the Board of Probation and Parole dated
June 7, 1993. That determination denied your initial Financial
Disclosure Appeal dated May 28, 1993. Your appeal will be treated
as a request for advice from the State Ethics Commission.
Issue: You ask whether in your capacity as a Parole Supervisor
with the Board of Probation and Parole, you are to be considered a
"public employee" as that term is defined in the Public Official
and Employee Ethics Law.
Facts: You question whether your activities and functions fall
within the purview of the definition of "public employee" as that
phrase is defined in the Ethics Law and the regulations of this
Commission. In order to review the question presented, we will
briefly outline the duties and responsibilities associated with
your position. Your duties and responsibilities, as set forth in
the Memorandum to you from Thomas A. Marshall, Director, Division
of Personnel, dated June 7, 1993, are incorporated herein by
reference. You prepare and supervisor the preparation of final
recommendations as to the paroleability of inmates. The
recommendations concerning the paroleability of inmates in state
correctional institutions are made by you and your subordinates to
the Board with regard to your personal judgment of the desirability
of said action. These recommendations are based on analysis and
evaluation of numerous factors including the behavior of inmates
while incarcerated, the participation of inmates in various
treatment and vocational programs and the quality of the parole
plan. Further, as an Institutional Parole Supervisor, you are a
supervisor at the highest level field office within the Bureau of
Institutional Parole Services.
June 25, 1993
Page 2
Discussion: The question to be answered is whether you, in your
capacity as a Parole Supervisor for the Board of Probation and
Parole, Bureau of Institutional Parole Services, are to be
considered a "public employee." The Ethics Law defines that term
as follows:
65 F.S. 5402 .
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:
(1) contracting or procurement;
(2) administering or monitoring grants or
subsidies;
(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 minimis nature on the interests
of any person.
"Public employee" shall not include individ-
uals who are employed by the State or any
political subdivision thereof in teaching as
distinguished from administrative duties.
The regulations of the State Ethics Commission similarly
define the term public employee as above with the additional
following criteria:
(ii) The following criteria will be
used, in part, to determine whether an
individual is within the definition of "public
employee ":
(A) The individual normally performs his
responsibility in the field without onsite
supervision.
(B) The individual is the immediate
supervisor of a person who normally performs
his responsibility in the field without onsite
supervision.
June 25, 1993
Page 3
(C) The individual is the supervisor of
a highest level field office.
(D) The individual has the authority to
make final decisions.
(E) The individual has the authority to
forward or stop recommendations from being
sent to the person or body with the authority
to make final decisions.
(F) The individual prepares or
supervises the preparation of fin al
recommendations.
(G) The individual makes final teahnica - -1
recommendations.
(H) The individual's recommendations or
actions are an inherent and recurring part of
his position.
(I) The individual's recommendations or
actions affect organizations other than his
own organization.
(iii) 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.
(iv) Persons in the following positions
are generally considered public employes:
(A) Executive and special directors or
assistants reporting directly to the agency
head or governing body.
(B) Commonwealth bureau directors,
division chiefs or heads of equivalent
organization elements and other governmental
body department heads.
(C) Staff attorneys engaged in
representing the department, agency or other
governmental bodies.
(D) Engineers, managers and secretary -
treasurers acting as managers, police chiefs,
June 25, 1993
Page 4
51 Pa. Code 511.1.
chief clerks, chief purchasing agents, grant
and contract managers, .administrative
officers, housing and building inspectors,
investigators, auditors, sewer enforcement
officers and zoning officers in all
governmental bodies.
(E) Court administrators, assistants for
fiscal affairs and deputies for the minor
judiciary.
(F) School superintendents, assistant
superintendents, school business managers and
principals.
(G) Persons who report directly to heads
of executive, legislative and independent
agencies, boards and commissions except
clerical personnel.
(v) Persons in the following positions
are generally not considered public employes:
(A) City clerks, other clerical staff,
road masters, secretaries, police officers, .
maintenance workers, construction workers,
equipment operators and recreation directors.
(B) Law clerks, court criers, court
reporters, probation officers, security guards
and writ servers.
(C) School teachers and clerks of the
schools.
The question you present must be reviewed under these
provisions of the statute and the regulations of the Commission in
light of your duties and obligations as described in your job
description and /or classification specifications, under which you
operate. The inquiry necessarily focuses on the job itself and not
on the individual incumbent in the position, the variable functions
of the position, or the manner in which a particular individual
occupying a position may carry out those functions. See Phillips
v. State Ethics Commission, 79 Pa. Commw. 491, 470 A.2d 659 (1984);
and Mummau v. Ranck, 531 Fed. Supp. 402 (E.D. Pa. 1982).
Also, in reviewing your question, the Commonwealth Court in
its ruling in Phillips, supra, at page 661, directs that coverage
June 25, 1993
Page 5
of the Ethics Act be construed broadly, rather than narrowly, and
conversely, directs that exclusions from the Ethics Law should be
narrowly construed. Based upon this directive and reviewing the
definition of "public employee" in the statute and the regulations
and opinions of this Commission, in light of your job functions and
the information available to us, the necessary conclusion that you
are a "public employee" subject to the financial reporting and
disclosure requirements of the State Ethics Act.
It is clear that in your capacity as a Parole Supervisor, you
have the ability to recommend official action with respect to
subparagraph (4) and (5) within the definition of "public employee"
as set forth in the Ethics Law, 65 P.S. §402. Specifically, you
use your own judgment without onsite supervision and make
recommendations directly to the Board concerning the paroling of
inmates. You supervise others in the preparation of
recommendations to the Board. You independently evaluate various
factors in making such recommendations. These decisions not only
directly affect the inmates, but also the Department of
Corrections. These activities fall within the definition of public
employee as contained in the regulations of the Commission in
Section 11.1, subparagraphs (ii)(A), (C), (E), (F), (H), and (I),
and (iv)(G). 51 Pa. Code §11.1. Under these circumstances and
given your duties and responsibilities as outlined above, you are
a "public employee" as that term is defined in the Ethics Law.
Conclusion: You are to be considered a "public employee" in your
capacity as a Parole Supervisor with the Board of Probation and
Parole, Bureau of Institutional Parole Services. Accordingly, you
must file a Statement of Financial Interests for each year in which
you hold the position outlined above and for the year following
your termination of this service.
If you have not already done so, a Statement of Financial
Interests must be filed within 15 days of this Advice. This
Statement of Financial Interests would report information of the
prior calendar year.
Pursuant to Section 7(11), 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.
such.
This letter is a public record and will be made available as
Finally, if you disagree with this Advice or if you have any
reason to challenge same, you may request that the full Commission
June 25, 1993
Page 6
review this Advice. A personal appearance before the Commission
will be scheduled and a formal Opinion from the Commission will be
issued. Anv such appeal must be in w4tinq and must be received at
the Commission within 15 days of the date of this Advice pursuant
to 51 Pa. Code 513.2(h).
'ncerely,
y—vir\ (
Vincent Dop o
Chief Counsel