HomeMy WebLinkAbout060-S GagliardiIN RE: MICHAEL GAGLIARDI
Respondent
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
File Docket: 94 -002 -P
Date Decided: 06/23/94
Date Mailed: 06/30/94
Before: James M. Howley, Chair
Daneen E. Reese, Vice Chair
Roy W. Wilt
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. 5401 et sea. 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 not filed and a hearing was
deemed 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 §21.29(b).
Michael Gagliardi
June 27, 1994
Page 2
I. FINDINGS:
1. Respondent Michael Gagliardi is an adult individual who
resides or maintains a mailing address at P.O. Box 42,
Walston, PA 15781.
2. At all times relevant to these proceedings, Respondent has
been an Auditor for Young Township, Jefferson County,
Pennsylvania.
(a) Respondent specifically held the aforesaid position in
1990.
3. The State Ethics Commission was advised that Respondent did
not have a Statement of Financial Interests for calendar year
1990 on file with Young Township, which Statement of Financial
Interests was due on or before May 1, 1991.
4. A first Notice letter dated January 31, 1994 and a final
Notice letter dated February 24, 1994 were served upon
Respondent by this Commission. The said Notice letters 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 letters 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
twenty (20) days of the dates of the respective Notice
letters.
5. Respondent did not file a Statement of Financial Interests
with Young Township for calendar year 1990 within the twenty
day period from the date of the said final Notice letter.
6. Respondent has telephonically advised the Commission that the
Township Secretary was supposed to have filed the form on
time, two years ago, and that Respondent and his wife have had
serious health problems causing them to be hospitalized.
7. The State Ethics Commission has received independent
information that many Township records were misplaced when
they were moved from the former Township Secretary to the
present Township Secretary.
8. As a matter of public record, Respondent filed with the State
Ethics Commission a Statement of Financial Interests for
calendar year. 1990 after issuance of the Order to Show Cause
which Statement of Financial Interests is dated March 15, 1994
Michael Gagliardi
June 27, 1994
Page 3
and was received by this Commission on April 2, 1994.
a. Block 2 of said Statement of Financial Interests is
incomplete, with the only indication of an address being:
"P.O. Box."
II. DISCUSSION:
Respondent has been a Township Auditor for Young Township in
Jefferson County, Pennsylvania at all times relevant to these
proceedings. Respondent specifically held the aforesaid position
in 1990.
As a Township Auditor for
"public official" as that term is
and Employee Ethics Law ( "Ethics
as such, Respondent is subject to
65 P.S. §404(a).
Young Township, Respondent is a
defined under the Public O
Law "), 65 P.S. §401, et se q., and
the provisions of the Ethics Law.
Pursuant to Section 4(a) of the Ethics Law, Respondent is
required to file a Statement of Financial Interests for the
preceding calendar year with Young Township each ,year Respondent
holds the above position and the year after Respondent leaves said
position:
(a) Each public official of the
Commonwealth shall file a statement of
financial interests for the preceding calendar
year with the commission no later than May 1
of each year that he holds such a position and
of the year after he leaves such a position.
Each public employee and public official of
the Commonwealth shall file a statement of
financial interests for the preceding calendar
year with the department, agency, body or
bureau in which he is employed or to which he
is appointed or elected no later than May 1 of
each year that he holds such a position and of
the year after he leaves such a position. Any
other public employee or public official shall
file a statement of financial interests with
the governing authority of the political
subdivision by which he is employed or within
which he is appointed or elected no later than
May 1 of each year that he holds such a
position and of the year after he leaves such
a position. Persons who are full -time or
part -time solicitors for political
subdivisions are required to file under this
section.
Michael Gagliardi
June 27, 1994
Page 4
The complete financial disclosure which Respondent as a
Township Auditor is required to provide in the Statement of
Financial Interests form is statutorily mandated in detail at
Section 5 of the Ethics Law, 65 P.S. §405.
In applying Section 9(f) to this case, the prerequisite
service of a Notice letter in accordance with Section 7(5) was
satisfied. Furthermore, Respondent did not submit a Statement of
Financial Interests for calendar year 1990 within twenty days from
the date of the final Notice letter, which would have avoided the
institution of these formal proceedings. Formal proceedings were
instituted against Respondent by an Order to Show Cause, ordering
Respondent to show cause why a civil penalty should not be levied
against him. Respondent did not file an answer to the Order to
Show Cause.
However, the Commission has received certain information
pertaining to this matter which causes us to exercise our
discretion so as to not levy a civil penalty against Mr. Gagliardi.
Specifically, Mr. Gagliardi has indicated that the Township
Secretary was supposed to have filed the form on time two years
ago, and the Commission has received independent information that
many Township records were misplaced when the records were
transferred from the former Township Secretary to the present
Township Secretary. Given the state of the Township records it is
unclear whether Respondent failed to comply with Sections 4 and 5
of the Ethics Law by failing to timely file a Statement of
Financial Interests for calendar year 1990 with Young Township.
Following the issuance of the Order to Show Cause, Respondent
filed a Statement of Financial Interests dated March 15, 1994 for
calendar year 1990. The form is technically deficient in that Mr.
Gagliardi failed to provide his address per the requirements of 65
P.S. §405(b)(1).
Based upon the totality of the circumstances, no civil penalty
shall be levied in this case. Respondent shall be ordered to file
an amended, complete and accurate Statement of Financial Interests
for calendar year 1990.
III. CONCLUSIONS OF LAW:
1. Respondent Michael Gagliardi was at all times relevant to
these proceedings a Township Auditor for Young Township of
Jefferson County, Pennsylvania and as such Respondent was at
all times relevant to these proceedings a "public official"
subject to the provisions of the Ethics Law, Act 9 of 1989.
2. It is unclear whether Respondent failed to comply with
Sections 4 and 5 of the Ethics Law by failing to timely file
Michael Gagliardi
June 27, 1994
Page 5
a Statement of Financial Interests for calendar year 1990 with
Young Township.
3. Based upon the totality of the circumstances in this case, a
civil penalty will not be levied.
4. Respondent's Statement of Financial Interests for calendar
year 1990, dated March 15, 1994, and received by this
Commission April 2, 1994, is technically deficient.
IN RE: Michael Gagliardi
Respondent
File Docket: 94 -002 -P
Date Decided: 06/23/94
Date Mailed: 06/30/94
ORDER NO. 060 -S
1. Michael Gagliardi, as a Township Auditor for Young Township in
Jefferson County, Pennsylvania is subject to the requirement
to timely file Statements of Financial Interests pursuant to
65 P.S. SS404, 405.
2. Based upon the circumstances of this case, no civil penalty
shall be levied against Respondent in this matter as to the
filing requirement for calendar year 1990.
3. Respondent Michael Gagliardi is directed within 30 days of
issuance of this Order to file an amended, complete and
accurate Statement of Financial Interests for calendar year
1990 with Young Township, correcting the technical deficiency
noted above as to the incomplete address in Block 2 of the
form, and providing full financial disclosure as required by
the Ethics Law, and to forward a copy of same to this
Commission at the following address to evidence compliance:
State Ethics Commission
309 Finance Building
P.O. Box 11470
Harrisburg, PA 17108 -1470
Attention: Robin M. Hittie, Assistant Counsel
4. Failure to comply with any provision of this Order will result
in the initiation of an approp1iate enforcement action.
BY THE COMMISSION,
James M. Howley, Chair