HomeMy WebLinkAbout94-008 PerperJoshua A. Perper, M.D.
3546 S. Ocean Boulevard, #202
Palm Beach, FL 33480
Dear Dr. Perper:
I. ISSUE:
DATE DECIDED:
DATE MAILED:
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
John R. Showers
12/16/94
12/27/94
94 -008
Re: Conflict, Public Official, County, Coroner, Autopsy, Expert
Witness, Compensation, Civil Matter, Former Public Official.
This Opinion is issued in response to your request of October
21, 1994.
Whether a former county coroner is prohibited or restricted by
the Public Official and Employee Ethics Law from testifying as an
expert witness in a civil case relative to an autopsy he performed
while coroner.
II. FACTUAL BASIS FOR DETERMINATION:
During your tenure as the Coroner for Allegheny County which
ended on June 1, 1994, you, being a forensic pathologist, performed
an autopsy on the body of a decedent, an activity not mandated by
the Coroner's Law. You have recently been approached by an
attorney who has asked you to act as an expert witness in a case
wherein you would testify concerning the findings of that autopsy.
Perper, Joshua A., M.D., 94 -008
December 27, 1994
Page 2
You made inquiry regarding your acting as an expert witness for a
fee to the Allegheny County Solicitor who advised "from the
County's point of view," that there would be no limitation on your
ability to act as an expert witness in the civil matter noting that
the Coroner is an independent elected official and not subject to
the County Code of Conduct. The letter of the County Solicitor
suggested that consideration be given to making an inquiry of this
Commission.
III. DISCUSSION:
It is initially noted that pursuant to Sections 7(10) and
7(11) of the Ethics Law, 65 P.S. § §407(10), (11), advisories are
issued to the requestor based upon the facts which the requestor
has submitted. In issuing the advisory based upon the facts which
the requestor has submitted, this Commission does not engage in an
independent investigation of the facts, nor does it speculate as to
facts which have not been submitted. It is the burden of the
requestor to truthfully disclose all of the material facts relevant
to the inquiry. 65 P.S. § §407(10), (11). An advisory only affords
a defense to the extent the requestor has truthfully disclosed all
of the material facts.
As former Coroner for Allegheny County, you were a public
official as that term is defined under the Ethics Law, and hence
you are subject to the provisions of that law.
Section 3(a) of the Ethics Law provides:
Section 3. Restricted Activities.
(a) No public official or public
employee shall engage in conduct that
constitutes a conflict of interest.
The following terms are defined in the Ethics Law as follows:
Section 2. Definitions.
"Conflict or conflict of interest." Use
by a public official or public employee of the
authority of his office or employment or any
confidential information received through his
holding public office or employment for the
private pecuniary benefit of himself, a member
of his immediate family or a business with
which he or a member of his immediate family
is associated. "Conflict" or "conflict of
interest" does not include an action having a
de minimis economic impact or which affects to
Perper, Joshua A., M.D., 94 -008
December 27, 1994
Page 3
IV. CONCLUSION:
the same degree a class consisting of the
general public or a subclass consisting of an
industry, occupation or other group which
includes the public official or public
employee, a member of his immediate family or
a business with which he or a member of his
immediate family is associated.
In addition, Sections 3(b) and 3(c) of the Ethics Law provide
in part that no person shall offer to a public official /employee
anything of monetary value and no public official /employee shall
solicit or accept anything of monetary value based upon the
understanding that the vote, official action, or judgement of the
public official /employee would be influenced thereby. Reference is
made to these provisions of the law not to imply that there has
been or will be any transgression thereof but merely to provide a
complete response to the question presented.
In applying the provisions of Section 3(a) of the Ethics Law
to the instant matter, we must preliminarily note the fact that the
performance of an autopsy which is not an activity mandated by the
Coroner's Law is not relevant or material to the disposition of
this case. It is sufficient that you did perform the autopsy in
your capacity as Coroner.
We do not believe that the proposed activity is prohibited by
Section 3(a) of the Ethics Law. You performed this autopsy while
serving as the elected Coroner. Following the conclusion of that
autopsy, you prepared various reports which would be matters of
public record. The fact that you now, as a former public official
on your own time, are willing to testify as an expert witness for
a fee as to such documents does not rise to a use of authority of
office on your part. We also note in this regard that since you
are not now a public official, you would not be taking any such
action as Coroner. Hence, there would be no use of authority of
office and derivatively no conflict under Section 3(a) of the
Ethics Law. Our decision in this matter is necessarily and
strictly limited in light of the unique facts of this case.
The propriety of the proposed conduct has only been addressed
under the Ethics Law; the applicability of any other statute, code,
ordinance, regulation or other code of conduct other than the
Ethics Law has not been considered in that they do not involve an
interpretation of the Ethics Law.
A former county coroner was a public official subject to the
provisions of the Ethics Law. Section 3 (a) of the Ethics Law would
Perper, Joshua A., M.D., 94 -008
December 27, 1994
Page 4
not prohibit or restrict a former county coroner from testifying as
an expert witness in a civil case relative to an autopsy he
performed while coroner. Lastly, the propriety of the proposed
conduct has only been addressed under the Ethics Law.
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,
James M. How]j
Chair
Commissioner Dennis C. Harrington did not participate in this
matter.