HomeMy WebLinkAbout063-S SiposIN RE: ARPAD K. SIPOS
Respondent
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
File Docket: 94 -011 -P
Date Decided: 05/04/95
Date Mailed: 05/16/95
Before: Daneen E. Reese, Chair
Austin M. Lee, Vice Chair
Roy W. Wilt
Boyd E. Wolff
The Investigative Division of 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 seq. Written Notice
was mailed to Respondent by the Investigative Division in
accordance with Section (7)(5) of the Ethics Law, as to which there
was a letter response. The Investigative Division filed with the
State Ethics Commission and served upon Respondent a Petition for
Civil Penalties. An 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 § 52.38 (b) , (c) /21.29 (b) .
Sipos, 94 -011 -P
Page 2
I. FINDINGS:
1. Respondent Arpad K. Sipos is an adult individual who resides
or maintains a mailing address at 132 Sholly Drive,
Mechanicsburg, PA 17055.
2. At all times relevant to these proceedings, Respondent was an
Electrical Construction Inspector for the Pennsylvania
Department of General Services, having resigned the aforesaid
position on or about August 30, 1994.
(a) Respondent specifically held the aforesaid position in
1990, 1991, 1992 and 1993.
3. Respondent filed Statements of Financial Interests for
calendar years 1990, 1991, 1992 and 1993 which are alleged to
be deficient.
a. The Petition for Civil Penalties does not allege any
specific deficiencies in the said forms.
4. A first Notice letter dated September 1, 1994 and a final
Notice letter dated September 27, 1994 were served upon
Respondent by the Investigative Division of the State Ethics
Commission. The said Notice letters stated specific details
concerning the deficiency of Respondent's Statements of
Financial Interests for calendar years 1990, 1991, 1992 and
1993 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
accurate and complete Statements of Financial Interests for
calendar years 1990, 1991, 1992 and 1993 within twenty (20)
days of the dates of the respective Notice letters.
a. The said Notice letters from the Investigative Division
to Respondent are attached to the Petition for Civil
Penalties as Exhibit "A" and are made a part thereof.
b. The final notice letter from the Investigative Division
to the Respondent references (but does not attach)
material and statements in the possession of the Office
of Inspector General, which information is stated to
indicate that control of DCI was transferred to
Respondent by power of attorney as of April 20, 1990 and
that Respondent performed work regarding twelve (12)
construction permits in the City of Harrisburg issued to
DCI which resulted in payment to Respondent. That notice
directs that "both your interest in DCI as well as the
income derived therefrom which exceeded $1,000.00 in each
year must be reported on your Statement of Financial
Sipos, 94 -011 -P
Page 3
Interests."
c. A responsive letter from Respondent to the Executive
Director of the State Ethics Commission is attached to
the Petition for Civil Penalties as Exhibit "B ".
d. The said letters specifically pertain to whether
Respondent had a reportable interest and reportable
income from Dauphin Contractors, Inc. ( "DCI ") which
should have been reported on the 1990 -1993 calendar year
Statements of Financial Interests.
5. Respondent did not file amended Statements of Financial
Interests for calendar years 1990, 1991, 1992 and 1993 on or
before the expiration of twenty days from the date of the said
final Notice letter.
6. Thereafter, the Petition for Civil Penalties was filed with
the State Ethics Commission on October 28, 1994 and was served
upon Respondent by the Investigative Division.
7. An Order to Show Cause was issued to Respondent on November
18, 1994, and was promptly served upon Respondent, ordering
that any Answer to the Petition for Civil Penalties be in
writing and be received by the State Ethics Commission within
thirty (30) days of the date of the said Order.
a. The said Order to Show Cause specifically stated:
"IT IS FURTHER ORDERED that any Answer filed in
response to this Order to Show Cause must be in writing
and must be RECEIVED at this Commission within thirty
days of the date of this Order as stated above. The
Answer must specifically admit or deny each of the .
allegations made in the attached Petition for Civil
Penalty(ies), and must set forth the facts and state
concisely the matters of law upon which Respondent
relies. Matters not specifically denied shall be deemed
admitted. Failure to file an Answer or the filing of
general denial(s) will be deemed an admission of the
allegations set forth in the attached Petition for Civil
Penalty(ies) ."
8. No Answer was filed to the Petition for Civil Penalties.
9. Respondent did forward amended Statements of Financial
Interests for calendar years 1990, 1991, 1992, and 1993 to the
State Ethics Commission which were dated November 17, 1994 and
were received on November 21, 1994.
a. It is the position of the Investigative Division, as
Situps, 94 -011 -P
Page 4
reflected in a letter docketed December 21, 1994, that
said filings do not constitute an "Answer" and that they
remain deficient.
10. On its face, Respondent's original Statement of Financial
Interests for calendar year 1990 is deficient in that block 14
is not completed in any way but is left blank.
a. Respondent's amended Statement of Financial Interests for
calendar year 1990 has notations at paragraphs 9, 10, 14
and 15 of the form which are partially illegible but
appear to state that Respondent helped his daughter start
DCI; loaned funds; purchased two houses and paid bills
out of his pocket; helped his daughter start out and
finance DCI; and worked for free to help.
11. On its face, Respondent's Statements of Financial Interests
for calendar years 1991 and 1992 are completed incorrectly in
that block 11 indicates that there are no direct or indirect
sources of income, yet also indicates the Commonwealth of
Pennsylvania, Department of General Services as such a source.
a. Respondent's amended Statement of Financial Interests for
calendar year 1991 indicates a "slash" and the word "no"
in block 11 and also has various notations regarding DCI
which appear to allege that Respondent's daughter and
son -in -law eloped to Las Vegas and left Respondent to pay
all the bills; that Respondent loaned funds to help his
daughter; and that he paid the bills.
b. Respondent's amended Statement of Financial Interests for
calendar year 1992 has a notation which covers block 10
and 11 and another notation at block 14 which are
partially illegible but appear to state that Respondent
fixed the house with his funds and labor; put a lien on
the property to protect his grandchildren's money which
he invested in the business; that he helped to run DCI
without compensation; and that all funds that the
corporation received were used to pay bills with the
corporation making no money and paying no wages.
12. There are no facially apparent deficiencies to the
Respondent's original Statement of Financial Interests for
calendar year 1993.
a. Respondent's amended Statement of Financial Interests for
calendar year 1993 notes under block 9 a mechanical lien
with a notation as to his grandchildren's funds; block 11
states "no income" to Respondent; block 14 states that
Respondent helped to run DCI; and finally at the bottom
of the form, there appears a notation by which Respondent
Sipos, 94 -011 -P
Page 5
asks that the Commission not waste any more of his time,
and that he has to make a living and work.
13. DCI is not listed under block 11 as a direct or indirect
source of income for the years 1990 through 1993 on either the
Respondent's Statements or amended Statements of Financial
Interests.
II. DISCUSSION
Respondent has been an Electrical Construction Inspector for
the Pennsylvania Department of General Services at all times
relevant to these proceedings. Respondent specifically held the
aforesaid position in 1990, 1991, 1992 and 1993.
Having failed to file any answer to the Petition for Civil
Penalties, the averments therein are deemed admitted by Respondent.
As an Electrical Construction Inspector for the Pennsylvania
Department of General Services, Respondent has at all times
relevant to these proceedings been a "public employee" as that term
is defined under the Public Official and Employee Ethics Law
( "Ethics Law "), 65 P.S. §401, et seq., and as such, Respondent is
subject to the provisions of the Ethics Law.
Pursuant to Section 4(a) of the Ethics Law, Respondent is /was
required to file a Statement of Financial Interests for the
preceding calendar year with the Department of General Services
each year Respondent held the above position and the year after
Respondent left 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.
Sioos,, 94 -011 -P
Page 6
65 P.S. 5404(a).
The complete financial disclosure which Respondent as a
( "public employee ") is /was 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, which provides:
Section 5. Statement of financial interests
(a) The statement of financial interests
filed pursuant to this act shall be on a form
prescribed by the commission. All information
requested on the statement shall be provided
to the best of the knowledge, information and
belief of the person required to file and
shall be signed under oath or equivalent
affirmation.
(b) The statement shall include the
following information for the prior calendar
year with regard to the person required to
file the statement.
(1) Name, address and public
position.
(2) Occupation or profession.
(3) Any direct or indirect
interest in any real estate which
was sold or leased to the
Commonwealth, any of its agencies or
political subdivisions; purchased or
leased from the Commonwealth, any of
its agencies or political
subdivisions; or which was the
subject of any condemnation
proceedings by the Commonwealth, any
of its agencies or political
subdivisions.
(4) The name and address of
each creditor to whom is owed in
excess of $5,000 and the interest
rate thereon. However, loans or
credit extended between members of
the immediate family and mortgages
securing real property which is the
principal or secondary residence of
the person filing shall not be
included.
Sipos, 94 -011 -P
Page 7
(5) The name and address of
any direct or indirect source of
income totalling in the aggregate
$1,000 or more. However, this
provision shall not be construed to
require the divulgence of
confidential information protected
by statute or existing professional
codes of ethics or common law
privileges.
(6) The name and address of
the source and the amount of any
gift or gifts valued in the
aggregate of $200 or more and the
circumstances of each gift. This
paragraph shall not apply to a gift
or gifts received from a spouse,
parent, parent by marriage, sibling,
child, grandchild, other family
member or friend when the
circumstances make it clear that the
motivation for the action was a
personal or family relationship.
However, for the purposes of this
subsection, the term "friend" shall
not include a registered lobbyist or
an employee of a registered
lobbyist. This paragraph shall not
be applied retroactively.
(7)(i) The name and address of
the source and the amount of any
payment for or reimbursement of
actual expenses for transportation
and lodging or hospitality received
in connection with public office or
employment where such actual
expenses for transportation, and
lodging or hospitality exceed $500
in thee course of a single
occurrence. This paragraph shall
not apply to expenses reimbursed by
the governmental body or to expenses
reimbursed by an organization or
association of public officials or
employees of political subdivisions
which the public official or
employee serves in an official
capacity.
Sipos, 94 -011 -P
Page 8
65 P.S. §405.
(ii) This paragraph shall not
be applied retroactively.
(8) Any office, directorship,
or employment of any nature
whatsoever in any business entity.
(9) Any financial interest in
any legal entity engaged in business
for profit.
(10) The identity of any
financial interest in a business
with which the reporting person is
or has been associated in the
preceding calendar year which has
been transferred to a member of the
reporting person's immediate family.
(c) Except where an amount is required
to be reported pursuant to subsection (b)(6)
and (7), the statement of financial interests
need not include specific amounts for the
items required to be listed.
(d) On a biennial basis commencing in
January 1991, the Commission shall review the
dollar amounts set forth in this section and
may increase these amounts to such rates as
are deemed reasonable for assuring appropriate
disclosure. The commission shall publish any
such adjusted threshold amounts in the
Pennsylvania Bulletin by February 1, 1991, and
every two years thereafter as necessary.
In light of the fact that Respondent failed to file any Answer
to the Petition for Civil Penalties, Respondent is deemed to have
admitted the allegations in the Petition for Civil Penalties.
Additionally, certain facial deficiencies are apparent on three of
the four Statements of Financial Interests in question:
1. Respondent failed to complete block number 14 for his
Statement of Financial Interests for calendar year 1990,
and failed to legibly complete said block on his amended
filing.
2. Block 11 of Respondent's Statements of Financial
Interests for calendar years 1991 and 1992 have been
incorrectly completed in that they give conflicting
Sipos, 94 -011 -P
Page 9
information as to Respondent's direct or indirect sources
of income.
The Respondent has failed to list DCI as a source of income
for the calendar years 1990 through 1993 which, given the failure
to file an Answer to the Petition for Civil Penalties, are now
deemed as a source of income for the four years in question.
Therefore, the Respondent filed deficient Statements of
Financial Interests for calendar years 1990, 1991, 1992, and 1993
which constitute a failure to comply with Sections 4 and 5 of the
Ethics Law. 65 P.S. §404, 405.
As for this particular action, we are presently only dealing
with a Petition for Civil Penalties.
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. 5409(f).
An application of Section 9(f) to this case establishes that
this Commission has the discretion to levy a civil penalty against
the Respondent for each such delinquent or deficient Statement of
Financial Interests.
The prerequisite service of a Notice letter in accordance with
Section 7(5) was satisfied.
Furthermore, upon being notified of the above
transgression(s), Respondent did not remedy Respondent's failure to
comply with the Ethics Law, although he was given until the
expiration of twenty days from the date of the final Notice letter
in which to comply so as to avoid the institution of these formal
proceedings. The Investigative Division then instituted formal
proceedings against Respondent by filing with the State Ethics
Commission and serving upon Respondent a Petition for Civil
Penalty(ies). The State Ethics Commission issued an Order to Show
Cause, ordering Respondent to show cause why civil penalties should
not be levied against him.
Sipos, 94 -011 -P
Page 10
Respondent did not file an answer to the Order to Show Cause.
There is nothing of record which would constitute a defense or
excuse for Respondent's failure to comply with the Ethics Law.
Respondent has failed to show cause why civil penalties should not
be levied against him in this matter.
It is noted that following the issuance of the Order to Show
Cause, Respondent filed amended Statements of Financial Interests
dated November 17, 1994 for calendar years 1990, 1991, 1992 and
1993, which filings failed to cure the facial deficiencies noted
above as well as failed to list DCI as a source of income under
block 11.
Based upon the totality of circumstances in this case, we
hereby levy one civil penalty against Respondent Arpad K. Sipos in
the total amount of $250.00. In levying the aforesaid civil
penalty, we are cognizant that we could assess a per diem civil
penalty against Respondent for each violation up to the total
maximum amount of Two Hundred Fifty Dollars ($250.00) per violation
allowed by the Ethics Law with a total of $1,000.00 for the four
years, but have determined that an appropriate exercise of our
discretion on the record before us in this case would be to assess
the aforesaid lesser civil penalty.
In Port, Order 42 -S, we assessed a total penalty of $250.00
for the failure to file for three years. In the cited case, the
respondent sought to file an Answer after the 30 day period expired
as well as filed the Financial Interest Statements after the Order
to Show Cause was issued which were deficient. Although we could
have imposed a penalty of $750.00 in that case, we imposed a
penalty of $250.00 based upon no prior history of civil penalty
proceedings. Respondent in this case similarly has no such prior
history.
Respondent shall be ordered to file complete and accurate
Statements of Financial Interests for calendar years 1990, 1991,
1992 and 1993 as delineated above.
III. CONCLUSIONS OF LAW:
1. Respondent Arpad R. Sipos was at all times relevant to these
proceedings an Electrical Construction Inspector for the
Pennsylvania Department of General Services, and as such,
Respondent was at all times relevant to these proceedings a
"public employee" subject to the provisions of the Ethics Law,
Act 9 of 1989.
2. Respondent failed to comply with the requirements of Sections
4 and 5 of the Ethics Law when Respondent filed deficient
Statements of Financial Interests for calendar years 1990,
1991, 1992, and 1993.
Si os, 94 -011 -P
Page 11
3. Notice of the deficiency of Respondent's Statements of
Financial Interests for calendar years 1990, 1991, 1992 and
1993 was previously served upon Respondent in accordance with
Section 7(5) of the Ethics Law, 65 P.S. 5407(5).
4. Based upon the totality of the circumstances in this case, a
civil penalty is warranted.
5. Respondent's Amended Statements of Financial Interests for
calendar years 1990, 1991 and 1992, dated November 17, 1994,
and received on November 21, 1994 by this Commission, are
technically deficient.
6. Respondent failed to list DCI as a source of income on either
his Financial Interest Statements or amended Financial
Interest Statements for the calendar years 1990 through 1993.
IN RE: ARPAD K. SIPOS
Respondent
File Docket: 94 -011 -P
Date Decided: 05/04/95
Date Mailed: 05/16/95
ORDER NO. 063 -S
1. Arpad K. Sipos, as an Electrical Construction Inspector for
the Pennsylvania Department of General Services failed to
comply with Sections 4 and 5 of the Ethics Law, 65 P.S. § §404,
405, by filing deficient Statements of Financial Interests for
calendar years 1990, 1991, 1992 and 1993.
2. Based upon the circumstances of this case, one civil penalty
is hereby levied against Respondent Sipos in the amount of
$250.00.
3. Respondent Sipos is ordered to pay the above civil penalty in
the amount of $250.00 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.
4. Respondent Sipos is directed within 30 days of issuance of
this Order to file complete and accurate Statements) of
Financial Interests for calendar years 1990, 1991, 1992 and
1993 correcting all technical deficiencies noted above,
listing DCI as a source of income for each year and providing
full financial disclosure as required by the Ethics Law, and
to forward a copy /copies 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: Legal Division
5. Failure to comply with any provision of this Order will result
in the initiation of an appropriate enforcement action.
BY THE COMMISSION,
A .,) , u E
&MJ
Daneen E. Reese, Chair