HomeMy WebLinkAbout254 Walker?ir, Francis Walker&
Secretary, PA State Athletic Commission
c/o Davit'. Phifer, Esq.
Commonwealth of Pennsylvania
307 North Office Building
Harrisburg, PA 17120
Re: No. 83-21 -C
Dear Mr. Walker:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
ORDER OF THE COMMISSION
November 10, 1983
Order No. 254
The State Ethics Commission has received a complaint regarding you and a
possible violation of Act 170 of 1978. The Commission has now completed its
investigation. The individual allegations, conclusions, and findings on which
those conclusions are based are as follows:
I. Allegation: That you serve as Ratings Chairman for or of the USBA and
that this creates an inherent conflict with your position as Executive
Secretary of the Pennsylvania State Athletic Commission.
A. Findings:
1. You served as Executive Secretary of the Pennsylvania State Athletic
Commission (SAC) during all times pertinent to this inquiry,
a. You are compensated for this service by SAC.
b. As Executive Secretary you are responsible for taking or recommending
official action of a non - ministerial nature with respect to the categories
outlined in the Ethics Act, definition of "public employee," 65 P.S. 402.
c. You are a "public employee" as that term is defined in the Ethics Act
and, therefore, are subject to the jurisdiction ofthe State Ethics Commission
and Ethics Act.
Francis Walker
November 10, 1983
Page 2
2. The SAC is responsible for administering and enforcing the State Athletic
Code.
3. The United States 'Wing Association (USBA) and the World Boxing
Association (WBA) are organizations for the purpose of encouraging and
supporting the sport ofEboxing; obtaining professionalism in the sport; and
striving to achieve efficiency and uniformity in supervising and controlling
boxing events.
4. The USBA is composed of among others, the commissions which regulate
boxing in the various satiates, including SAC, which is a member of USBA as well
as of WBA.
5. Neither USBA nor Ws4• is °regulated by SAC although bouts sponsored by
either would be subjecthto the provisions of the State Athletic Code and SAC
rules.
6. You are a member ofsboth. USBA and WBA and serve as Chairman of the USBA
Ratings Committee.
a. The Ratings Committee of USBA is responsible for rating boxers according
to their ability and record for match - making considerations and determining
various champions in each classification.
b. There is no evidobce.that you represented the interests of USBA before
SAC or that the interests 9f USBA and the SAC are adverse to each other. •
c. There is no evidepc:e7,that you used your post with SAC to benefit the:.
interests of the USBA- gryour own interests as Chairman of the USBA Ratings
Committee or otherwise.
B. Discussion: As a:•;uitifilic employee" you must conform your conduct to the
requirements of the Et:htcsrAct. The Ethics Act requires that you avoid the
following activity:
Section 3. Restricted Activities.
(a) No pgb1ic;>official or public employee
shall istnfyis public office or any
confideniztal± received through
his holdall public office to obtain
financiahsgain other than compensation
providedrn' law for himself, a member of
his immediate family, or a business with
which he).is associated. 65 P.S. 403(a),
Francis Walker
November 10, 1983
Page 3
The provisions of the Ethics Act are designed to effect the following
"Purpose" as expressed in Section 1 of the Ethics Act as follows:
Section 1. Purpose.
The Legislature hereby declar es that public office is a
public trust and that any effort to realize personal
financial gain through public office other than
compensation provided by law is a violation of that trust.
In order to strengthen the faith and confidence of the
people of the State in their government, the Legislature
further declares that the people have a right to be
assured that the financial interests of holders of or
candidates for public office present neither a conflict
nor the appearance of a conflict with the public trust.
Because public confidence in government can best be
sustained by assuring the people of the impartiality and
honesty of public officials, this act shall be liberally
construed to promote complete disclosure. 65 P.S. 401.
Although you serve as Ratings Committee Chairman of the USBA there is no
evidence that you used your public post with SAC to benefit USBA, the Ratings
Committee thereof, or yourself in violation of Section 3(a) of the Ethics
Act.
In order to comply with Section 1 of the the Ethics Act you should be
particularly alert, however, to any situation where the interests of USBA and
WBA would be adverse to those of the SAC and where the SAC may be urged or
requested by the USBA or WBA to adopt rules, regulations, etc. proposed by
USBA or WBA which you have reviewed or recommended to these entities.
Likewise, should you be in an office or position within USBA or WBA where you
are involved in formulating policy for or attempting to influence the actions
of SAC on behalf of !'SBA or 41:,, a different case might be presented requiring
abstention or removal from one pos :. or role, ie, either on SAC or as USBA/
Officer or Chairman. Compare Allen /Lutton, 79 -024; Vavro, 79 -074 and
Aspen /Miller, 82 -576.
C. Conclusion: The provisions of Section 3(a) are not violated under these
circumstances.
II. Allegation: That as Executive Secretary of the Pa. State Athletic
Commission (PSAC) you used PSAC offices /address to conduct business of the
USBA.
Francis Walker
November 10, 1983
Page 4
A. Findings: The Findings 1 -6 above are incorporated here by reference, in
addition to which we find the following:
7. Occasional reports regarding USBA conventions or meetings were prepared
and these appeared on paper under the words "Commonwealth of Pennsylvania,
Department of State, State Athletic Commission" in some instances.
a. These reports generally constituted reports to SAC as a member of USBA
and were designed for the use of SAC as such.
b. There is evidence that you prepared these reports, but these were not
beneficial or were not designed to be personally beneficial to you.
c. There is no evidence that these reports were prepared in this manner to
benefit the USBA.
d. These reports and other work done with respect to the USBA and your role
as Ratings Committee Chairman were beneficial to SAC.
8. As a member of SAC certain amounts are budgeted annually for sending
persons to WBA and USBA conventions.
a. You attended such conventions on occasion.
b. Your expenses for such attendance were approved by and paid for by SAC.
c. Your attendance was authorized because SAC is a member of USBA and or
because of your responsibility as a member of SAC.
B. Discussion: Your use of SAC offices to prepare reports of USBA meetings
and conventions was minimal and appropriate given SAC's membership in USBA.
These circumstances do not give rise to a violation of Section 3(a) or other
provisions of the Ethics Act.
Your attendance at USBA or WBA conventions resulted from your role as a
member of SAC and were approved by SAC. These actions do not amount to a
violation of Section 3(a) or other provisions of the Ethics Act.
C. Conclusion: These actions do not violate the Ethics Act, under the fact;
as found above.
Francis Walker
November 10, 1983
Page 5
Our files in th•; s Lase will ;amain confidential in accordance with
Section 8(a) of the Ethics Act, 65 P.S. 408(a). .However, this Order is final
and will be made available as a public document 15 days after service (defined
as mailing) unless you file documentation with the Commission which justifies
reconsideration and /or challenges pertinent factual findings. See 51 Pa. Code
2.38. During this 15 -day period, no once, including the Respondent unless he
waives his right to challenge this Order, may violate this confidentiality by
releasing, discussing or circulating this Orde
Any person who violates the confidentiality of a Commission proceeding
is guilty of a misdemeanor and shall b: fined not more than $1,000 or
. imprisoned for not more than one year or bar;,, see 65 P.S. 409(e).
PJS /jc
By, the Commission,
/
C 1 '
al J.
Chairman
/
ith