HomeMy WebLinkAbout582 MillerMr. L. W. Miller
176 Armour Drive
Washington, PA 15301
Re: 86 -163 -C
Dear Mr. Miller:
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STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
ORDER OF THE COMMISSION
Order No. 582
DATE DECIDED: July 21, 1987
DATE MAILED: July 28, 1987
The 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 North Franklin Township Supervisor, violated
Section 4(a) of the Ethics Act which states that each public employee shall
file a Statement of Financial Interests with the governing authority of the
political subdivision 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
and Section 4.4(b) r::iich states that incumbent public officials in other
governmental bodies who are not candidates shall file their Statement of
Financial Interests only with their governmental body, in that you failed to
file Statements of Financial Interests in 1981, 1983, 1984, and 1985.
A. Findings:
1. You serve as an elected township supervisor in North Franklin Township,
Washington County, Pennsylvania.
a. You served in this position from January 1, 1980 through December
1985.
b. You are currently filling out the unexpired term of a supervisor who
resiyned from office.
2. Statements of Financial Interests were on file for you at the office of
the North Franklin Township secretary's office for 1984.
a. Statements for other township officials and employees were filed with
the township secretary /treasurer.
3. You advised that the Statements of Financial Interests for township
supervisors were maintained by the Township Solicitor, George Retos.
Mr. L. W. Miller
Page 2
a. You stated that Mr. Retos was appointed to maintain the statements.
b. You stated that you filed the form every year but never checked to
see if copies were on file with the township.
4. Mr. Retos the township solicitor maintained Statements of Financial
Interests which had been filed by you for the years 1979 -1986. (Except for
1982 regarding your financial interests for calendar year 1981.)
a. No statement for 1982 could be found.
b. Mr. Retos advised that he maintained these statements for township
supervisors because in the past certain records had been missing from
the township building.
5. You received income from the township in each year of service as follows:
1980 - $425.00
1981 - $925.00
1982 - $325.00 (2 quarters)
1983 - $375.00 (1 quarter)
1984 - $650.00
1985 - $625.00
6. You failed to list North Franklin Township as a source of income in excess
of $500.00 in all years for which you filed a Statement of Financial
Interests.
B. Discussion: The State Ethics Act provides as follows:
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. L. W. Miller
Page 3
governing authority of the political subdivision 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 Regulations of the State Ethics Commission further provide that:
§4.4.Incumbent and former public officials.
(b) Incumbent public officials in governmental
bodies other than those specified in subsection (a) who
are not candidates shall file their Statement of Financial
Interests only with their governmental body. 51 Pa. Code
§4.4(b).
There is no doubt that as a Township Supervisor for North Franklin
Township you are within the purview of the above provisions of the State
Ethics Act. Pennsylvania State Association of Supervisors v. Thornburgh, 496
Pa. 324, 437 A.2d (1981); Welz, 86 -001.
The Ethics Act defines public official as follows:
Section 2. Definitions.
"Public official." Any elected or appointed official in
the Executive, Legislative or Judicial Branch of the State
or any political subdivision thereof, provided that it
shall not include members of advisory boards that have no
authority to expend public funds other than reimbursement
for personal expense, or to otherwise exercise the power
of the State or any political subdivision thereof.
"Public official" shall not include any appointed official
who receives no compensation other than reimbursement for
actual expenses. 65 P.S. §402.
Your position as supervisor clearly falls within the above definition.
The filing requirement, as set forth in the Ethics Act has been determined to
apply equally to public employees and public officials. Kremer v. State
Ethics Commission, 56 Pa. Commw. Ct. 160, 424 A.2d 968, (1981); Carter,
79 -066.
The Ethics Act provides penalities for failure to file a Statement of
Financial Interests as follows:
(ir. L. W. Miller
Page 4
Section 9. Penalties.
(b) Any person who violates the provisions of Section 4 is
guilty of a misdemeanor and shall be fined not more than
$1,000 or imprisoned for not more than one year, or be
both fined and imprisoned. 65 F.S. §409(b).
This Commission has been mandated to make recommendations to law
enforcement officials either for criminal prosecution or dismissal of charges
arising out of violations of the Act. 65 P.S. §409(11).
The State Ethics Act also provides that:
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).
Pursuant to this provision of the Act, the Commission has taken action to
prohibit candidates who are in violation of the law from continuing in the
election process, State Ethics Commission v. Landauer, Pa. Commw. Ct.
496 A.2d 862, (1985), and has also required public officials and emloyees in
violation of the Act to return any compensation obtained in violation of the
above provision. Metzler, No. 389 -R; Huhn, No. 431.
In the instant situation, while the Statements of Financial Interests
that you filed in your position of township supervisor, were not on file with
the township secretary /treasurer as were statements other township employees,
they were in the possession of the township solicitor. The solicitor produced
all of the Statements of Financial Interests for you except for the statement
that was to be filed by May 1, 1982. No statement for that year could be
found. Additionally, . it is noted that Statements of Financial Interests must
include the identification of sources of income in excess of $500.00. 65 P.S.
§405(5). A review of the Statements of Financial Interests on file for you
indicates that in 1981, 1984, 1985, you had income from North Franklin
Township in excess of $500.00. The township, however, was never reported as a
source of income on your Statements of Financial Interests for those years.
Such would have been required under the provisions of the State Ethics Act.
As a result of the foregoing, your failure to file a Statement of
Financial Interests for the year 1982 was a violation of the State Ethics Act.
Mr. L. W. Miller
Page 5
Additionally, your failure to list North Franklin Township as a source of
income in excess of $500.00 is a technical violation of the State Ethics Act.
A review of the instant situation, however, does not reveal any intent in your
failure to file the Statements of Financial Interests or to list North
Franklin Township on your statements. We do, however, believe that amended
filings should be made and you must file a Statements of Financial Interests
for 1982.
C. Conclusion and Order: As a Township Supervisor you are a public official
subject to the provisions of the State Ethics Act. You are, therefore,
required to file a Statement of Financial Interest. Your failure to file a
Statement of Financial Interests for calendar year 1982 is a violation of the
State Ethics Act. Your failure to list North Franklin Township as a source of
income in excess of $500.00 on your Statements of Financial Interests for
1981, 1984 and 1985 is also a violation of the State Ethics Act. You are
hereby ordered to file a Statement of Financial Interests for 1982 indicating
your financial interest for calendar year 1981. You similarly must file
amended Statements of Financial Interests for the aforementioned calendar
years listing North Franklin Township as a source of income in excess of
$500.00. Upon the filing of these statements, we will take no further action
in relation this matter. Said statements must be filed with this Commission
within 30 days of the date of this order.
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.
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,
st!Y. i t:4 t's•' )6.)4;64.4".112-4t.
G. Sieber Pancoast
Chairman