HomeMy WebLinkAbout1058R DellmuthIn re:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
Carl Dellmuth
File Docket:
X -Ref:
Date Decided:
Date Mailed:
95- 074 -C2
Order No. 1058 -R
10/2/97
10/14/97
Before: Daneen E. Reese, Chair
Austin M. Lee, Vice Chair
Roy W. Wilt
Boyd E. Wolff
Julius Uehlein
The State Ethics Commission received a request for reconsideration on September 22,
1997, with respect to Order No. 1058 issued on August 26, 1997. Pursuant to Section
21.29 of the Regulations of the Commission, the discretion of the State Ethics Commission
to grant reconsideration is properly invoked as follows:
§21.29. Finality: reconsideration.
(b) Any party may ask the Commission to reconsider an order or
opinion within 15 days of service of the order or opinion. The requestor shall
present a detailed explanation setting forth the reason why the order or opinion
should be reconsidered.
(c) A request for reconsideration filed with the Commission will delay
the public release of an order, but will not suspend the final order unless
reconsideration is granted by the Commission.
(d) A request for reconsideration may include a request for a hearing
before the Commission.
(e) Reconsideration may be granted at the discretion of the
Commission if:
(1) A material error of law has been made.
(2) A material error of fact has been made.
(3) New facts or evidence are provided which would lead to reversal or
modification of the order or opinion and if these could not be or were not
discovered by the exercise of due diligence.
51 Pa. Code §21.29(b), (c), (d), (e).
This adjudication of the Commission is hereby issued which sets forth the Discussion
and Reconsideration Order.
This Reconsideration Order is final and shall be made available with Order No. 1058 as
public documents on the fifth (5th) business day following the date of issuance of this Order.
Dellmuth, 95- 074 -C2
Page 2
DISCUSSION
On August 26, 1997, we issued Dellmuth, Order No. 1058, following our
review of the record in this case.
The allegation was that Carl Dellmuth, a former public employee in his capacity
as a Chief of Staff, Department of Education, violated Section 3(g) of the State Ethics
Act (Act 9 of 1989) when he represented a person, with promised or actual
compensation, on any matter before the governmental body with which he was
associated within one year of leaving state employment by representing his new
employer, the Philadelphia School District, before the Pennsylvania Department of
Education.
In approving a proposed Consent Agreement submitted by the parties, we found
that:
1. Carl Dellmuth, as a Chief of Staff with the Department of Education, was a
public employee subject to the provisions of Act 9 of 1989.
2. Dellmuth violated Section 3(g) of Act 9 of 1989 when he met with
representatives of the Pennsylvania Department of Education, his former
governmental body, within one year after leaving his position with the
Department, regarding a Pennsylvania Department of Education study on Family
Resource Networks and the creation of a Community and Student Services
Support Center by the Philadelphia School District, his new employer.
Following the issuance of
Reconsideration alleging factual
The Investigative Division has
challenging the substance of the
response would not be filed. The
raised do not rise to the level of
Order No. 1058, Dellmuth timely filed a Petition for
inaccuracies in the Discussion portion of the Order.
filed a letter stating that since Dellmuth is not
Consent Agreement or Stipulated Findings, a formal
Investigative Division further notes that the matters
a material error of fact in its view.
In his Petition for Reconsideration, Dellmuth states that he is not challenging the
finding of violation nor is he challenging the decision to impose discipline. Dellmuth
states that his purpose in requesting reconsideration is to correct two factual
inaccuracies contained in the Discussion portion of the adjudication which are not
consistent with the Stipulation of the parties.
First, Dellmuth quotes page 8 of Order No. 1058, which states the following:
When PSD was awarded a $200,000 grant through the
Department of Public Welfare and PDED for the Model Child Care
Program for the 1994/1995 fiscal year, Ledebur met with Dellmuth and
other PSD representatives to discuss the grant in the context of insuring
its use for preschool programs.
Dellmuth argues that the grant of $200,000 was awarded when he was still an
employee of the Pennsylvania Department of Education and not an employee of the
Philadelphia School District. Dellmuth states that Stipulation No. 3 indicates that he
worked for the Pennsylvania Department of Education until October 14, 1994 and that
the $200,000 grant was approved and received prior to that date. Dellmuth further
contends that he did not meet with Ledebur to discuss the grant in the context of
ensuring its use for preschool programs; rather, Dellmuth asserts that the only contact
he had with Ledebur on that particular issue was a telephone call from Ledebur's
Dellmuth, 95- 074 -C2
Page 3
secretary asking whom she should contact in the Philadelphia School District for
contract revisions. Dellmuth argues that Stipulation No. 17 confirms that the
$200,000 grant was awarded on September 12, 1994 before Dellmuth left PDED.
Dellmuth states that the second factual inaccuracy is found in the following
quote on page 8 of Order No. 1058:
Dellmuth contacted Joseph Bard in PDED who was the
Commissioner for Elementary and Secondary Education to discuss the
possibility of PDED reviewing PSD's Community and Student Service
Program.
Dellmuth argues that the statement is incorrect in that he did not initiate the contact
with Bard. Dellmuth contends that Bard stopped by Dellmuth's backyard when they
were neighbors in Harrisburg. Dellmuth states that Stipulation No. 9 only indicates
that he and Bard had a discussion which occurred as a result of a chance meeting in
Dellmuth's backyard. Dellmuth asserts that there is no evidence that he initiated the
contact with Bard.
As to the first claimed error of fact, the language of the particular sentence in
the Discussion is prefaced by the clause which recites that the grant "was awarded"
When Ledebur met with Dellmuth. The verb "was awarded" is past tense. Obviously,
the clause is written in the context of action which had been completed as to the
grant. Hence, the sentence is factually correct and there is no error of fact, material
or otherwise.
Dellmuth also asserts that he did not meet with Ledebur to discuss the grant
in the context of ensuring its use for preschool programs and that his only contact
with Ledebur on that issue was by a telephone call from Ledebur's secretary asking
whom she could contact for contract revisions. First, we note that this proffered ,
statement is not in the Fact Findings or anywhere else in the Order. Second, the
phraseology we used was summarized from Fact Finding 20, which states:
Ledebur met with Dellmuth and other representatives of the Philadelphia
School District January 1995 to discuss the grant.
a. The discussions concerned who was to be contacted at the
school district to ensure the grant would be used for
preschool programs.
Once again, there was no error of fact.
As to the last asserted error of fact, it is true that the Fact Findings merely
reflect that Bard and Dellmuth had a discussion but not who initiated the contact.
However, such a paraphrase of the facts from the Fact Findings is not a material error
of fact. At most, we have a picayune misstatement in the Discussion.
No argument has been raised by the Dellmuth which would meet the requisite
standard for reconsideration. No material error of law has been established. No
material error of fact has been established. No new facts or evidence has been
provided which would lead to a reversal or modification of the Order. Dellmuth has
failed to meet his burden of proof to establish any need for reconsideration. The
Petition for Reconsideration is denied.
In re: Carl Dellmuth
File Docket: 95- 074 -C2
Date Decided: 10/2/97
Date Mailed: 10/14/97
RECONSIDERATION ORDER NO. 1058 -R
1. The Petition for Reconsideration of Dellmuth, Order No. 1058, is denied.
BY THE COMMISSION,
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DANEEN E. REESE, CHAIR