HomeMy WebLinkAbout738 GerhartMr. Ernest E. Gerhart, Sr.
R.D. #1, Johnsoville Road
Bangor, PA 18013
Re: 89 -098 -C
89 -008 -C
Dear Mr. Gerhart:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
ORDER OF THE COMMISSION
Order No. 738
Before: Helena G. Hughes, Chair
Robert W. Brown, Vice Chair
W. Thomas Andrews
G. Sieber Pancoast
Dennis C. Harrington
James M. Howley
Date Decided: February 22, 1990
Date Mailed: March 6, 1990
The State Ethics Commission received a complaint regarding you
and a possible violation of the State Ethics Act, No. 170 of 1978, 65
P.S. 401 et. seq. You were notified in writing as to the
commencement of the investigation and as to the specific
allegation(s). The investigation has now been completed and a
Findings Report was issued to you which constituted the Complaint by
the Investigation Division of the State Ethics Commission. An Answer
was filed and a hearing was waived. The record is now completed.
This Order of the Commission is hereby issued which sets forth the
individual allegations, findings, discussion and conclusion as
follows:
I. Alleaation: That you, a Supervisor for Upper Mount Bethel
Township, Northampton County, violated the following provisions of the
Ethics Act (Act 170 of 1978), when you failed to file Statements of
Financial Interests:
Section 4. Statement of financial interests
required to be filed.
(a) Each public employee employed by the
Commonwealth shall file a statement of financial
interests for the preceding calendar year with the
department, agency or bureau in which he is
employed no later than May 1, of each year that he
Ernest E. Gerhart, Sr.
Page 2
holds such a position and of the year after he
leaves such a position. Any other public employee
shall file a statement of financial interests with
the governing authority of the political
subdivision by which he is employed no later than
May 1 of each year that he holds such a position
and of the year after he leaves such a position.
65 P.S. §404(a).
54.4.Incumbent and former public officials.
(b) Incumbent public officials in
governmental bodies other than those specified in
subsection (a) who are not candidates shall file
their. Statement of Financial Interests only with
their governmental body. 51 Pa. Code §4.4(b).
A. Findings:
1. You serve as a Township Supervisor in Upper Mount Bethel Township,
Northampton County, Pennsylvania.
a. You have served in this position since January of 1984.
2. Prior to serving in this position, you were employed by the
township as a police officer for eleven years and as a laborer on the
roads for two years.
a. You have also been employed as a road worker while serving
as a township supervisor.
3. A review of the Upper Mount Bethel Township records indicate the
following Statements of Financial Interests on file for you.
a. Statement dated April 6, 1983 -
interest indicated as none.
b.
c .
d.
e .
Statement dated April 23, 1984
interest indicated as none.
Statement
interests
Statement
interests
Statement
interests
dated April 20, 1985
indicated as none.
dated April 18, 1986
indicated as none.
dated April 6, 1987
indicated as none.
all categories of financial
- all categories of financial
- all categories of financial
- all categories of financial
- all categories of financial
Ernest E. Gerhart, Sr.
Page 3
f. Statement dated March 22, 1989 - direct or indirect sources
of income listed as Upper Mount Bethel Township.
All other categories of financial interests listed as none.
4. Minutes of the Upper Mount Bethel Township Board of Supervisors
for 1985 through 1989 indicate the following actions regarding your
appointment to a position of employment as a township roadworker:
a. The January 3, 1985 minutes indicate that Supervisor Ernest
Gerhart was approved to work as roadmaster.
b. The January
Gerhart was
c. The January
Gerhart was
d. The January
Gerhart was
6, 1986 minutes indicate that Supervisor Ernest
approved to work as roadmaster.
5, 1987 minutes indicate that Supervisor Ernest
approved to work as roadmaster.
4, 1988 minutes indicate that Supervisor Ernest
approved to work as Assistant Road Foreman.
e. The January 3, 1989 minutes indicate that a motion was made
to eliminate Mr. Gerhart's position as working supervisor
with the Road Department. The vote was 2 to 2 with Gerhart
abstaining. The motion failed.
5. Records of Upper Mt. Bethel Township contained a letter dated
April 27, 1988 from Ernest E. Gerhart, Sr., to the State Ethics
Commission.
a. A letter indicates that attached were three statements of
Financial Interests for calendar years 1985 through and
including 1987.
b. The letter further indicates that in reviewing his files,
Mr. Gerhart realized that he had not filed the Statements of
Financial Interests for these years. He indicated that he
was filing these statements at that time as a result of this
review. The statements enclosed in the letter were the
statements identified in Findings 3(a), (b) and (e) above.
6. You provided the following information in relation to the instant
situation:
a. You serve as a township supervisor in Upper Mount Bethel
Township, Northampton County, Pennsylvania.
b. You served in that position since January of 1984.
Ernest E. Gerhart, Sr.
Page 4
c. Prior to that time, you were serving as a township police
officer and for eleven years as a laborer for two years.
d. You did not file Statements of Financial Interests for
calendar years 1985, 1986 and 1987.
e. You assert this was an oversight on your part.
f. You did file statements for calendar years 1983 and 1984.
g.
The former secretary of the township provided blank
statements to the supervisors for completion on an annual
basis. The new secretary did not do this and you forgot to
fill out -the forms for the years noted above.
h. You realized this mistake about the same time that a-State
Ethics Commission investigator was at the township building.
i. You asked the investigator how you should handle that
situation and you were advised that said statements should
be filed.
B. Discussion:
You sent the forms to the State Ethics Commission and they
were returned to you with an indication that they should not
be filed with this Agency but rather only with the Township.
As a township supervisor in Upper Mount Bethel Township, you are
a public official as that term is defined under the Ethics Act. 65
P.S. 402. As such, your conduct is subject to the provisions of the
Ethics Law and the restrictions therein are applicable to you.
Initially, it is noted that Section 5 of Act 9 of June 26, 1989
provides, in part, as follows:
"This amendatory act shall not apply to
violations committed prior to the effective date
of this act, and causes of action initiated for
such violations shall be governed by the prior
law, which is continued in effect for that purpose
as if this act were not in force. For the
purposes of this section, a violation was
committed prior to the effective date of this act
if any elements of the violation occurred prior
thereto."
Since the occurrences in this case transpired prior to the
effective date of Act 9 (June 26, 1989), we must apply the provisions
Ernest E. Gerhart, Sr.
Page 5
of Act 170 of October 4, 1978, P.L. 883 to determine whether the
Ethics Act was violated.
Under Section 4(a) of the Ethics Act and Section 4.4(b) of the
Regulations quoted above, these two provisions of law require that
incumbent public officials who are not candidates must file a
Financial Interests Statement on or before May 1 for the proceeding
calendar year with their governmental body.
In this case you have been serving as a township supervisor in
Upper Mount Bethel Township since January of 1984. In addition, you
were also appointed township road master for the years 1985 through
1989. However, you did not file Financial Interests Statements for
the calendar years 1985, 1986 and 1987. Upon receipt of the notice of
the above allegations, you realized that you did not file the
Financial Interests Statements for these three years and thereafter
filed same which were acknowledged as received by the township by
letter of April 27, 1988. At the present time, the township has on
file Financial Interests Statements from you for the years 1983
through 1988, all of which forms except for the 1988 year list "none"
in all categories of Financial Interests. The 1988 calendar year
Financial Interests Statements does list Upper Mount Bethel Township
as a direct or indirect source of income.
In light of the fact that you failed to file Financial Interests
Statements for the calendar years 1985 through 1987 on or before the
filing deadline, we find a technical violation of Sections 4(a) and
Sections 4.4(b) of the Ethics Act.
We also note that you have listed none for all categories of
Financial Interests for your filings for the calendar years 1983
through 1987. We find such statements deficient in light of the fact
that you have been serving as a supervisor since 1984 for which you
received statutory compensation as a supervisor; in addition you have
been elected roadmaster since 1985 for which you received compensation
as a township employee. Therefore, you are directed to file amended
Financial Interests Statements for the calendar years 1984 through
1987 which would list Upper Mount Bethel Township as a direct or
indirect source of income. Failure to comply with the foregoing will
result in the referral of this matter to the appropriate law
enforcement authority for review and appropriate action. However, if
you comply within thirty days of the date of this order, no further
action will be taken.
C. Conclusion and Order:
1. As a supervisor in Upper Mount Bethel Township you are a public
official subject to the provisions of the Ethics Law.
Ernest E. Gerhart, Sr.
Page 6
2. There is a technical violation of Sections 4(a) and 4.4(b) of the
Regulations regarding the failure to file Financial Interests
Statements for the calendar years 1985 through 1987.
3. Since you now have filed Financial Interests Statements for the
calendar years 1985 through 1987, this Commission will take no
further action provided you file amended Financial Interests
Statements for the calendar years 1984 through 1987 which would
list Upper Mount Bethel Township as a direct or indirect source
of income within thirty days of the date of this Order.
4. Failure to comply with the provisions of paragraph three above
will result in the referral of this matter to the appropriate law
enforcement authority for review and appropriate action.
This Order is final and will be made available as a public
document fifteen days after issuance. However, you may request
reconsideration which will defer public release of this Order pending
action on your request by the Commission. A request for
reconsideration, however, does not affect the finality of this Order.
A reconsideration request must be received at this Commission within
fifteen days of issuance and must include a detailed explanation of
your reasons as to why reconsideration should be granted in conformity
with 51 Pa. Code 52.38.
The files in this case will remain confidential in accordance
with Section 8(a) of the Ethics Act, 65 P.S. 408(a) during the fifteen
day period and no one, including yourself, unless the right to
challenge this Order is waived, may violate confidentiality by
releasing, discussing or circulating this Order. However,
confidentiality does not preclude you from discussing this case with
your attorney at law.
Any person who violates confidentiality of a Commission
proceeding is guilty of a misdemeanor and shall be fined not more
than $1,000 or imprisoned for not more than one year or both, 65 P.S.
409(e).
By th Commission,
A 014.4.--/
e lena G. Hughes
Chair
Mr. Ernest E. Gerhart, Sr.
R.D. #1, Johnsoville Road
Bangor, PA 18013
Dear Mr. Gerhart:
VJD /emg
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
March 19, 1990
This is to acknowledge that the State Ethics Commission has
received your letter of March 8, 1990 and the enclosed original
or amended Statements of Financial Interests for the years 1983
through 1989 that list Upper Mount Bethel Township inter alia as
a direct or indirect source of income.
Very truly yours,
A
Vincent J. Dopko
Chief Counsel