HomeMy WebLinkAbout522 MoyeMr. Theodis Moye
3809 Gawayne Terrace
Silver Spring, MO 20906.
Re: 86 -097 -C
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
ORDER OF THE COMMISSION
Order No. 522
DECIOEDAU 2 0 1986
MAILED filieiramen6
Dear Ms. Moye:
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, a member of the State Board of Auctioneer
Examineers, violated Section 4(a) and 4(d) of the State Ethics Act and Section
4.4(h) of the State Ethics Commission regulations which require that public
officials file a Statement of Financial Interests for the preceding calendar
year by May 1 of each year they hold office by failing to file a Statement of
Financial Interests for calendar year 1984 by May 1, 1985.
A. Findings:
1. You were appointed to the State Board of Auctioneer Examiners in May,
1985.
2. In July, 1985, you telephoned an administrative assistant in the
administrative offices and said you were resigning from the Board because you
were moving out of state. The person to whom you talked sent a memo to the
Commissioner of the Bureau of . . . : . Affairs.
R. Discussion:
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 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
Mr. Theodis Moye
Page 2
governing authority of the political suhdivision 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).
The above provisions are equally applicable to all " public officials ".
See Kremer v. State Ethics Commission, 56 Pa. Comm. Ct. 160, 424 A.2d 968,
(1981), Carter, 79 -066. Also, the regulations of the State Ethics Commission
which have the force and' effect of law specify that "public officials" shall
file Statements of Financial Interests for each year they hold office. 51 Pa.
Code 4.4(a).
The regulations further provide:
, 54.3.Appointed officials.
(b) Any person appointed as an official in the
Commonwealth's executive, legislative, judicial branches
and other statewide offices who is not a candidate shall
file his Statement of Financial Interests with the
Commission and a copy with the agency to which he is
appointed by May 1 of the year appointed or within 15 days
if appointed after May 1. 51 Pa. Code 4.3(b).
b4.4.Incumbent and former public officials.
(d) Former public officials shall file a Statement
of Financial Interests for their last year of sevice by
May 1 of the succeeding year. This statement shall he
filed at the same offices they filed when they were
incumbent officials. 51 Pa. Code 4.4(d).
The Ethics Act provides that:
A member of this Board is clearly a public official as that term is
defined in the State Ethics Act. 65 P.S. X402. This is especially true in
that the powers and duties of this hoard or commission, as set forth above,
indicate that this body has either the authority to expend public funds or to
otherwise exercise the power of the State or any political subdivision.
Section 4. Statement of financial interests reed reti to be filed.
(d) No public official shall he allowed to take the oath
of office or enter or continue upon his duties, nor shall
he receive compensation from puhlic funds, unless he has
filed a statement of financial interests with the
commission as required by this act. 65 P.S. 404(d).
Mr. Theodis Moye
Page 3
Pursuant to the Act, accurate and complete Statements of Financial
Interests must be available to the public, served by the public official or
puhlic employee. We realize that policies to achieve these purposes must
consider the possibility that an oversight or misunderstanding of the filing
requirements may occur and corrections allowed.
Section 4(d), quoted above, prohibits a puhlic official from continuing
in office and receiving compensation from public funds unless he files a
Statement of Financial Interests as required by the Ethics Act. These are
serious penalties and judicious application of the law requires its use only
where there is substantial reason to believe that the failure to file was
willful. C.F. Metzler, No. 389 -R; Huhn, No. 431.
While a member of the Board of Auctioneer Examiners is a public official
subject to the provisions of the Ethics Act, we believe that it would he
inappropriate to require filing in your circumstances.
C. Conclusion: You did not violate the Ethics Act by not filing a Statement
of Financial Interests because you were unable to serve almost immediately
after your appointment and before you participated in official board actions.
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 he made available as a puhlic 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 this3rder, may violate this confidentiality by
releasing, discussing or circulating this Order.
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).
Ry the Commission,
G. Sieber Pancoast
Chairman