HomeMy WebLinkAbout93-003 ConfidentialI. ISSUES:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
OPINION OF THE COMMISSION
Before: James M. Howley, Chair
Daneen E. Reese, Vice Chair
Dennis C. Harrington
Roy W. Wilt
Austin M. Lee
Allan M. Kluger
Joseph W. Marshall, III
DATE DECIDED: June 28, 1993
DATE MAILED: July 7, 1993
93 -003
Re: Conflict, Public Official /Employee, Municipal Authority
Member, Reimbursement for Lost Wages, Governing Body, Appeal
of Advice, Timeliness.
This responds to your letter of February 1, 1993, in which you
appeal Confidential Advice of Counsel No. 93 -507 issued January 15,
1993.
A. Timeliness of appeal of Advice.
B. Whether a municipal authority board member under the Public
Official and Employee Ethics Law may receive reimbursements or
payments from the authority arising from lost wages in private
employment which resulted from the performance of duties for
the authority.
II. FACTUAL BASIS FOR DETERMINATION:
A chronology of the events in this case is important and is as
follows:
1. December 16, 1992 - State Ethics Commission received request
for a confidential advisory from authority board members dated
December 9, 1992.
Confidential Opinion 93 -003
July 7, 1993
Page 2
2. December 23, 1992 - State Ethics Commission acknowledged
receipt of the above letter and docketed the matter as a
confidential Advice of Counsel.
3. January 15, 1993 - Confidential Advice 93 -507 issued and
mailed to authority board members.
4. February 8, 1993 - State Ethics Commission received letter
dated February 1, 1993 appealing Confidential Advice No. 93-
507.
III. APPLICABLE LAW:
The law to be applied to this question is as follows:
Regulations of the State Ethics Commission:
52.12. Appeal from an advice.
(a) Any person who requested an opinion
or advice and who is dissatisfied with an
advice given may appeal to the full Commission
for review.
(b) Any such appeal shall be made, in
writing, to the Commission within 15 days of
service of the advice.
The Regulations .which govern the practice and 'procedure ..`o
Commonwealth administrative agencies provide in pertinent part:
In computing a period of time involving
the date of issuance of an order by an agency,
the day of issuance of an order shall be the
day the office of the agency mails or delivers
copies of the order to the parties. . .
1 Pa. Code 531.13(a).
It is further provided in the foregoing Regulations as
follows:
Pleadings, submittals or other documents
required or permitted to be filed under this
part, the regulations of the agency or any
other provision of law shall be received for
filing at the office of the agency within the
time limits, if any, for the filing. The date
Confidential Opinion 93 -003
July 7, 1993
Page 3
of receipt at the office of the Agency and not
the date of deposit in thg mails is
determinative.
1 Pa. Code §31.11 (Emphasis added).
IV. DISCUSSION:
In order for this Commission to consider the substance of your
appeal of advice, it was necessary for you to file such in a timely
fashion.
Necessary to our determination is the computation of the
fifteen (15) day reconsideration period. It is undisputable that
the appeal period begins to run from the time of mailing of the
original Advice of Counsel from the Commission to the time of
actual receipt by the agency of the appeal of that Advice.
It is clear that in computing any period of time regarding
requests for appeal or reconsideration by an administrative agency,
the day of issuance (defined as mailing) is the date from which the
time period is determined. Additionally, the date at which time
such a request or appeal is considered filed is the date of receipt
at the office of the agency and not the date of deposit in the
mail. See, Getz v. Pennsylvania Game Commission, 83 Pa. Commw. Ct.
59, 475 A.2d 1369 (1984).
These time requirements are mandatory and absent fraud or
negligent conduct by the administrative agency, such timing
requirements may not be extended. See, Dilenno v. Unemployment
Compensation Board of Review, 59 Pa. Commw. Ct. 496, 429 A.2d 1288
(1981); Mayer v. Unemployment Compensation Board of Review, 27 Pa.
Commw. Ct. 44, 366 A.2d 665 (1976).
As noted previously, the Advice of Counsel was mailed on
January 15, 1993. Your appeal was dated February 1, 1993. That
request, however, was not received in the office of the State
Ethics Commission until February 8, 1993. The fifteen (15) day
period during which the appeal was required to be made terminated
on January 30, 1993. The appeal, therefore, was filed nine (9)
days after the time period had expired. This Commission, in the
past, has determined the filing requirements regarding a request
for reconsideration or appeal are mandatory and absent, of course,
a showing of fraud or break down in the postal systems, such will
not be extended. See, Smith, Opinion 85 -015; Silver, Opinion 85-
012; Rovito, Opinion 88 -003; Cowie, Opinion 88- 010 -R; Minor,
Opinion 90- 016 -R.
Parenthetically, we do note that the envelope transmitting
your appeal of Advice has a date stamp of the United State Postal
Confidential Opinion 93 -003
July 7, 1993
Page 4
Service dated February 1, 1993, in Pittsburgh, Pennsylvania. Even
assuming that Monday, February 1, 1993, rather than Saturday,
January 30, 1993, was the last day for filing your appeal, it is
clear that your appeal was in postal transit and not at this
Commission on February 1, 1993. Thus, the time stamped envelope
factually establishes the untimeliness of the appeal. See, Borland
v. State Ethics Commission, Memorandum Opinion of Commonwealth
Court filed at 2599 C.D. 1987 on September 22, 1988.
It is clear that your appeal is untimely and must be
dismissed.
V. CONCLUSION:
The appeal of Advice of Counsel 93 -507 is dismissed as
untimely filed.
Pursuant to Section 7(10), the person who acts in good faith
on this opinion issued to him shall not be subject to criminal or
civil penalties for so acting provided the material facts are as
stated in the request.
such.
This letter is a public record and will be made available as
Finally, any person may request the Commission to reconsider
its Opinion. The reconsideration request must be received at this
Commission within fifteen days of the mailing date of this Opinion.
The person requesting reconsideration should present a detailed
explanation setting forth the reasons why the Opinion requires
reconsideration.
By the Commission,
oiV
James M. Howl
Chair