HomeMy WebLinkAbout025-S CopeIN RE: D. JEAN COPE
Respondent
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
: File Docket: 92 -017 -P
: Date Decided: Juae 23, l9t2;
Date Mailed: June 29, 1992
Before: James M. Howley, Chair
Daneen E. Reese, Vice Chair
Dennis C. Harrington
Austin M. Lee
Allan M. Kluger
The State Ethics Commission received information regarding
possible violation(s) of Section 4 and /or Section 5 of the Public
Official and Employee Ethics Law ( "Ethics Law "), Act 9 of 1989, 65
P.S. §401 et Egg. Written Notice was mailed to Respondent in
accordance with Section (7)(5) of the Ethics Law, as to which there
was no response. A Notice and Order to Show Cause was issued and
served upon Respondent. An Answer was filed and a hearing was
waived. The record is complete. This adjudication of the
Commission is hereby issued, which sets forth Findings of Fact,
Discussion, Conclusions of Law and Order.
This Adjudication is final and is a public document.
Reconsideration may be requested. A request for reconsideration,
however, does not affect the finality of this adjudication. A
reconsideration request must be received at this Commission within
fifteen days of issuance and must include a detailed explanation of
the reasons as to why reconsideration should be granted in
conformity with 51 Pa. Code §2.38.
D. Jean Cope
June 29, 1992
Page 2
I. FINDINGS:
1. Respondent D. Jean Cope is an adult individual who resides or
maintains a mailing address at 12A Montgomery Village,
Danville, Pennsylvania 17821.
2. Respondent is now and at all times relevant to these
proceedings has been a Member of the Montour County Board of
Assistance.
Respondent has been a Member of the Montour County Board
of Assistance since her appointment by Governor
Thornburgh on March 31, 1981.
(b) Respondent specifically held the aforesaid position in
calendar year 1990.
(c) Respondent admits that she is subject to the provisions
of the Ethics Law.
3. The public records of the State Ethics Commission reflect that
Respondent did not file a Statement of Financial Interests for
calendar year 1990 with the State Ethics Commission and the
Governor's Office of Administration on or before May 1, 1991.
(a)
Respondent states that she did file the required
Statement of Financial Interests but concedes that it was
probably filed late.
(b) Respondent avers that late filing of the aforesaid
Statement is excusable as there was just cause for the
tardy filing due to Respondent's various specified
serious health problems from 1987 to the present; the
serious health problems and eventual demise of
Respondent's mother on December 14, 1991; and the stress
and strain from the aforementioned factors, all of which
Respondent alleges caused her to miss work, caused her to
be unable to easily discharge her regular duties, and
affected her ability to function efficiently.
4. A Notice letter dated June 18, 1991 was served upon Respondent
by this Commission. The said Notice letter stated in detail
the specific allegations against Respondent concerning the
delinquency of Respondent's Statement of Financial Interests
for calendar year 1990 and the penalties for failure to file
or for filing a deficient Statement of Financial Interests.
The said Notice letter provided Respondent an opportunity to
avoid the institution of these civil penalty proceedings by
filing an accurate and complete Statement of Financial
Interests for calendar year 1990 within fourteen (14) days of
(a)
D. Jean Cope
Jane 29, 1992
Page 3
the date of the Notice letter.
(a) Respondent does not deny receiving the June 18, 1991
Notice letter, but states that she does not specifically
recall receiving it.
(b) Respondent acknowledges receiving correspondence from
this Commission but states that she does not recall when
it was received as it was during the period of the
aforesaid health problems suffered by Respondent and her
mother.
5. The public records of the State Ethics Commission reflect that
Respondent did not file a Statement of Financial Interests
with the State Ethics Commission and the Governor's Office of
Administration for calendar year 1990 within fourteen days of
the date of the said Notice letter.
(a) Respondent states that she recalls that she did file a
Statement of Financial Interests for 1990 but that it
probably was a late filing.
6. Respondent admits that Two Hundred Fifty Dollars ($250.00) is
the maximum civil penalty which could be imposed against her
in this matter.
(a) For the aforesaid reasons alleged by Respondent,
Respondent denies that it would be appropriate to impose
a civil penalty upon her.
(b) Respondent alleges that the health problems of herself
and her mother are mitigating circumstances in this
matter, and requests that this Commission not impose a
civil penalty upon her.
7. As a matter of public record, Respondent filed a Statement of
Financial Interests for calendar year 1990 after receiving the
Order to Show-Cause which Statement of Financial Interests is
dated April 23, 1992, and was received by this Commission on
April 28, 1992.
II. DISCUSSION:
Respondent is now and at all times relevant to these
proceeding has been a Member of the Montour County Board of
Assistance. Respondent has been a Member of the Montour County
Board of Assistance since her appointment by Governor Thornburgh on
March 31, 1981, and Respondent specifically held the aforesaid
position in 1990.
D. Jean Cope
June 29, 1992
Page 4
As a Member of the Montour County Board of Assistance,
Respondent is a "public official" as that term is defined under the
Public Official and Employee Ethics Law ( "Ethics Law "), 65 P.S.
S401, al sac., and as such, Respondent is subject to the provisions
of the Ethics Law.
Pursuant to Sections 4 and 5 of the Ethics Law, Respondent was
required to file a Statement of Financial Interests providing
complete financial disclosure for calendar year 1990 with the State
Ethics Commission and the Governor's Office of Administration by
May 1, 1991. 65 P.S. SS404,405.
Section 9(f) of the Ethics Law provides as follows:
(f) In addition to any other civil remedy or
criminal penalty provided for in this act, the commission
may, after notice has been served in accordance with
section 7(5) and upon a majority vote of its members,
levy a civil penalty upon any person subject to this act
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 P.S. S409(f).
An application of Section (f) to this case establishes, that
this Commission has the discretion to levy a maximum civil penalty
against the Respondent for the delinquent Statement of Financial
Interests for calendar year 1990. Respondent has admitted that Two
Hundred Fifty Dollars ($250.00) is the maximum civil penalty which
could be imposed against her in this matter.
Factually, Respondent failed to timely file a Statement of
Financial Interests for calendar year 1990 with the State Ethics
Commission and the Governor's Office of Administration, which
constitutes a failure to comply with Sections 4 and 5 of the Ethics
Law.
Pursuant to Section 7(5) of the Ethics Law, a Notice letter
dated June 18, 1991 was issued to Respondent notifying Respondent
in detail of the specific allegations against Respondent concerning
the delinquency of Respondent's Statement of Financial Interests
for calendar year 1990 and the penalties for failure to file or for
filing a deficient Statement of Financial Interests. Respondent
does not deny receiving the June 18, 1991 Notice letter. She
states that she does not specifically recall receiving said letter
but does acknowledge that she received correspondence from the
Commission during the period of the health problems suffered by her
D. Jean Cope
June 29, 1992
Page 5
and her mother. The service of a Notice letter in accordance with
Section 7(5) is a prerequisite to the levying of a civil penalty
under Section 9(f) of the Ethics Law. 65 P.S. S409(f). This
prerequisite has been met in this case. Respondent's averment that
she does not specifically recall receiving the Notice letter would
not invalidate service of the Notice letter upon her.
The public records of the State Ethics Commission reflect that
Respondent did not remedy the failure to file a Statement of
Financial Interests for calendar year 1990 although given fourteen
days from the date of the aforesaid Notice letter in which to do
so. This Commission then instituted formal proceedings against
Respondent by issuing an Order to Show Cause, ordering Respondent
to show cause why a civil penalty should not be levied against
Respondent.
Respondent's Answer to the Order to Show Cause fails to show
cause why a civil penalty should not be levied against Respondent
in this matter. Although Respondent alleges that she did file the
Statement of Financial Interests while conceding that it would have
been late, the public records of the State Ethics Commission have
no indication of any such alleged filing until April 28, 1992 after
the Order to Show Cause had been issued to Respondent.
Respondent's recollection of such a filing is simply insufficient
in and of itself to overcome the public records of this Commission.
We would parenthetically note that Respondent has admitted that her
memory is unclear as to mailings which she received from the
Commission during this same time period.
The severe adversities suffered by the Respondent are taken
into consideration, however, in determining the amount of the civil
penalty to be assessed. Respondent has alleged various specific
severe health problems suffered by herself from 1987 to the present
and suffered by her mother who died on December 14, 1991.
Respondent has alleged that the aforesaid circumstances resulted in
stress and strain which caused her to miss work and to be unable to
easily discharge her regular duties and which affected her ability
to function efficiently. We would further note that following the
issuance of the Order to Show Cause, Respondent did file a
Statement of Financial Interests for calendar year 1990.
On the other hand, the public records of the State Ethics
Commission reflect that Respondent has a history of delinquency
with regard to filing Statements of Financial Interests.
Respondent has previously been served with Notices of the
delinquency of her Statements of Financial Interests for other
calendar years, specifically calendar years 1987, 1988, and 1989.
Although these filings were also due during the alleged period of
adversities suffered by Respondent, these repeated delinquencies
may not be ignored in determining this matter.
D. Jean Cope
June 29, 1992
Page 6
Based upon the totality of the circumstances in this case, we
hereby levy one civil penalty against Respondent D. Jean Cope in
the total amount of Two Hundred Dollars ($200.00). In levying the
aforesaid civil penalty, we are cognizant that we could assess a
per diem civil penalty against Respondent up to the total maximtim
amount of Two Hundred Fifty Dollars ($250) allowed by the Ethics
Law, but have determined that an appropriate exercise of our
discretion in this case would be to assess a lesser civil penalty
in the total amount of $200.00.
III. CONCLUSIONS OF LAW:
1. Respondent D. Jean Cope is now and at all times relevant to
these proceedings has been a Member of the Montour County
Board of Assistance and as such Respondent is a "public
official" as that term is defined in the Ethics Law.
2. Pursuant to Section 4 of the Ethics Law, Respondent is
required to file the Statement of Financial Interests each
year Respondent holds the above position and the year after
leaving said position.
3. Respondent was required by the Ethics Law to file a Statement
of Financial Interests for calendar year 1990 with the State
Ethics Commission and the Governor's Office of Administration,
which Statement of Financial Interests was due no later than
May 1, 1991.
4. Respondent failed to comply with the requirements of Sections
4 and 5 of the Ethics Law when Respondent failed to timely
file a Statement of Financial Interests for calendar year 1990
with the State Ethics Commission and the Governor's Office of
Administration.
5. Notice of Respondent's delinquent Statement of Financial
Interests for calendar year 1990 was previously served upon
Respondent in accordance with Section 7(5) of the Ethics Law,
65 P.S. S407(5).
6. The public records of the State Ethics Commission reflect that
Respondent failed to remedy the delinquency of Respondent's
Statement of Financial Interests for calendar year 1990,
although Respondent was given fourteen (14) days from the date
of the aforesaid Notice letter in which to do so.
7. Following the issuance of the Order to Show Cause, Respondent
filed a Statement of Financial Interests for calendar year
1990 dated April 23, 1992.
8. Based upon the totality of the circumstances in this case, a
total civil penalty in the amount of Two Hundred Dollars
($200.00) shall be levied against Respondent in this matter.
IN RE: D. JEAN COPE
Respondent
: Pile Docket: 92 -017 -P
Date Decided: June 23, 1992
: Date Mailed: June q9 1992
ORDEF1 NO. 025 -S
1. D. Jean Cope, as a Member of the Montour County Board of
Assistance failed to comply with Sections 4 and 5 of the
Ethics Law, 65 P.S. SS404, 405, by failing to timely file a
Statement of Financial Interests for calendar year 1990 with
the State Ethics Commission and the Governor's Office of
Administration.
2. Based upon the circumstances of this case, a total civil
penalty in the amount of Two Hundred Dollars ($200.00) is
hereby levied against Respondent D. Jean Cope. Respondent is
ordered to pay the above civil penalty in the total amount of
$200.00 within thirty days of the issuance of this Order, by
forwarding a check to this Commission payable to the
Commonwealth of Pennsylvania for deposit in the State
Treasury.
3. Failure to comply with any provision of this Order will result
in the initiation of appropriate enforcement action.
BY THE COMMISSION,
James M. Howley, C •