HomeMy WebLinkAbout502 WelliverMr. Ronald L. Welliver
Box 323
Millville, PA 17846
Re: 86 -006 -C
Dear Mr. Welliver:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
ORDER OF THE COMMISSION
Order No. 502
GLCIDED AUG 2 0 1986
MAILEDLE=2136
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 areas follows:
I. Allegation: That you, a candidate for councilman in Millville Borough,
violated Section 4(e)(2) of the Ethics Act and 4.2(c) of the Ethics
Commission's regulations which provide that announced write -in candidates for
public office shall file a Statement of Financial Interests with the
Commission and the governing authority of that political subdivision in which
he is a candidate within 15 days of declaring his candidacy or within half the
time between the declaration of candidacy and the election, if that period is
less than 15 days; Section 4.2(d)(12) of the Ethics Commission regulations
which provides that write -in winners of nominations file a Statement of
Financial Interests with the Commission and the governing authority of the
governmental body associated with the nomination within 85 days of the General
Election; and Section 4.2(d)(2) of the Ethics Commission regulations which
provide that write -in winners of elections shall file a Statement of Financial
Interests with the Commission and the governing authority of the governnental
body of the office to which they have been elected 5 days prior to taking the
oath of office.
A. Findings:
1. You were a candidate for the office of councilmember of Millville Borough
in the 1985 municipal election.
2. On April 5, 1985, you were notified of your obligations to file the
Statement of Financial Interests. On April 8, 1985, the State Ethics
Commission received a receipt signed by you, acknowledging your receipt of the
1 etter.
3. The following actions were taken subsequent to the primary election:
a. On August 30, 1985, a second certified letter was sent to
you notifying you of your obligation to file a Statement of Financial
Interests.
Mr. Ronald L. Welliver
Page 2
b. On September 5, 1985, the State Ethics Commission received a receipt
signed by you acknowledging receipt of this letter.
4. On March 7, 1986, the State Ethics Commission mailed a letter to you
notifying you that they were investigating your failure to file. The
following actions occurred as a result of this letter.
a. On March 14, 1986, our investigator contacted you and you stated the
following: r..
(1) You failed to file a Statement of Financial Interests in
response to our initial correspondence because you did not want
to file the necessary forms. You believe the entire process is
ridiculous.
b. You have taken your loyalty oath and are serving on borough council.
c. You were a candidate several years ago and did file a Statement of
Financial Interests at that time.
5. On March 18, 1986, the Commission received your Statement of Financial
Interests.
R. Discussion:
Section 4(b) of the Ethics Act states:
(b) Each candidate for public office shall file a
statement of financial interests for the preceding
calendar year with the commission prior to filing a
petition to appear on the ballot fo7 election as a public
official. A petition to appear on the ballot shall not he
accepted by an election official unless the petition
includes an affidavit that the candidate has filed the
required statement of financial interests with the
commission. 65 P.S. 404(b).
Section 4(e)(2) of the Ethics Act states:
(e)(2) Any candidate for local office shall file a statement
of financial interests with the commission pursuant to
this act and shall file a copy of that statement with the
governing authority of the political subdivision in which
he is a candidate. 65 P.S. 404(e)(2).
Mr. Ronald L. Welliver
Page 3
Section 4.2(c) of the Commission Regulations states:
(c) Announced write -in candidates must file a Statement of
Financial Interests with the Commission and a copy with
the governing authority of that political subdivision for
which he is a candidate within 15 days of declaring their
candidacy or within half the time between the declaration
of candidacy or and the election, if that period is less
than 15 days.
In the instant situation, you failed to file your Statement pursuant to
the State Ethics Act. Your reason for your failure to file was that - in your
belief - the entire process was ridiculous. This is not sufficient
justification for a public official's failure to comply with the law. The
State Ethics Act provides as follows:
Section 4. Statement of financial interests required to be filed.
(d) No public official shall be allowed to take the oath
of office or enter or continue upon his duties, nor shall
he receive compensation from public funds, unless he has
filed a statement of financial interests with the
commission as required by this act. 65 P.S. 404(d).
This Commission has, in the past, held that this provision of law would
require, in appropriate circumstances, that public officials who have received
compensation during a period for which they have not filed and received such
in violation of the above provision. The Commission has in such cases ordered
that a public official return the compensation received in violation of the
law. Metzler; 389 -R, Huhn; 431.
While it is clear that the regulations require filing of a Statement of
Financial Interests prior to announcing your write -in candidacy, Pennsylvania
Supreme Court interpretation of Section 4(b) of the Ethics Act provides for a
reasonable application of these requirements especially where the public's
right to view this information dur-ihy the selection process has not been
unduly impaired. See State Ethics Commission v. Boards of Election
in Allegheny County, et. al., No. 1266 C.D. 1981 where candidates failing to
file a Statement of Financial Interests up through the primary election were
removed from the general election ballot. See also State Ethics Commission v.
Baldwin, Pa. , 445 A.wd 1208 (1982). In addition, previous Ethics
Commission decisions have also recognized the need for judicious application
of the law unless there is reason to believe that the delay in filing the
Statement of Financial Interests was caused by a conscious action of the
public official or the public employee in an attempt to conceal or realize
personal, financial gain or some other special advantage in being a candidate
for officeholder.
Mr. Ronald L. Welliver
Page 4
In the instant situation, it is clear that you were aware of the filing
requirement. We had attempted, on a number of occasions, to contact you
through the mailing of certified letters and which were, in fact, received by
you as early as September 5, 1985. Nevertheless, you continued to fail to
file your Statement of Financial Interests. Your reason for not filing, your
belief that the process is ridiculous, is not sufficient justific °tion. Fully
aware of the fact that you had not filed your Statement of Financial
Interests, you entered upon your duties as a member of the Miliville Borough
Council. On March 7, 1986, you were once again contacted by the State Ethics
Commission as to the instant investigation. On March 14, you . were once again
telephonically contacted by a representative of the State Ethics Commission
regarding this matter. The Commission, finally, on March 18, 1986, received
your Statement of Financial Interests.
Although you have now filed a Statement of Financial Interests, we are
gravely concerned by your reaction to your obligation to file. We must note,
and you must be aware, that the filing requirement is a matter of law and one
means of insuring the public you serve as a member of borough council that you
are serving the public and deserbe their trust. As a borough councilperson,
you have a responsibility to enact ordinances and insure that the borough's
citizens obey those laws. If the citizens have the same attitude about laws
that you displayed in failing to meet your filing obligation, the borough
would become an anarchy. For government to succeed, public officials must
hold themselves to the highest standards, especially in meeting their legal
obligations.
C. Conclusion: You violated the State Ethics Act by failing to file a
Statement of Financial Interests. However, you have now filed a statement
and we will take no further action.
Our files in this case will remain 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 one, including the Respondent unless he
waives his right to challenge this Order, may violate this confidentiality by
releasing, discussing or circulating this Order.
Mr. Ronald L. Welliver
Page 5
Any person who violates the 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, see 65 P.S. 409(e).
By the Commission,
G. Sieber Pancoast
Chairman