HomeMy WebLinkAbout644 FeeMr. James J. Fee
1945 Wilson Drive
New Castle, PA 16101
Re: 86 -050 -C
Dear Mr. Fee:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
ORDER OF THE COMMISSION
Order No. 644
Date Decided: April 8, 1988
Date Mailed: April 19, 1988
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 Supervisor in Union Township,
Lawrence County, violated Section 4(a) of the State Ethics Act
which states that a public employee shall file a Statement of
Financial Interests with his political subdivision no later than
May 1 of each year that he holds a position and of the year after
he leaves such a position, by failing to file a Statement of
Financial Interests for the 1984 calendar year; and, Section 5(b)
of the State Ethics Act which requires reporting of all sources
of income of $500 or more by failing to report Union Township as
a source of income on your Statement of Financial Interests for
calendar years 1982 and 1983.
A. Findings:
1. You have served as a Township Supervisor of Union Township
from 1966 to 1977 and from 1982 to December, 1987.
2. Records on file with the Union Township Secretary /Treasurer
indicate the following regarding your Statements of Financial
Interests:
a. Filing date - February 20, 1987
For the year - 1987
Source of Income - Union Township
All other financial interest categories - none
Mr. James J. Fee
Page 2
b. Filing date - January 7, 1986
For the year - 1985
Source of Income - Union Township
All other financial interest categories - none
c. Filing date - 1985 for the year 1984, no record of a
filing.
d. filing date - March 18, 1983
For the year - 1983
Sources of Income - "NONE" is listed in the first two
lines, Union Township is added on the third line.
All other financial interest categories - none
e. Filing date - March 12, 1984
For the year - 1983
Source of Income - Union Township
All other financial interest categories - none
f. Filing date - March 10, 1982
For the calendar year - 1982
Source of Income - Union Township
All other financial interest categories - none
Filing date - February 24, 1981
Source of Income - "NONE."
Filed as a candidate running for the term beginning in
1982.
g.
3. The above listed records indicated that there is no Statement
of Financi1 Interests filed by you for the year 1984.
4. There are two Statements of Financial Interest filed by you
for the year 1983.
5. Union Township is listed as a source of income on all the
Statements of Financial Interests filed by you except in 1981.
6. On the Statement filed on March 18, 1983, for the calendar
year 1983 (2(d) above) - Union Township is added after the word
"NONE" was written.
7. Two Statements of Financial Interests were found dated March
12, 1984.
a. On one of these statements, which was located at the
Mr. James J. Fee
Page 3
Union Township Secretary /Treasurer's Office, the
township was listed as a source of income (See 2e).
b. On the other Statement of Financial Interests which was
provided to the State Ethics Commission, Union Township
is not listed as a source of income and "NONE" is
written in the space. This form, although filed on the
same date as the other form, is completely different
from that form.
8. You have copies of the above listed Statements of Financial
Interests in your possession with the exception of the statement
dated March 18, 1983 for the calendar year 1983.
a. You have a receipt for the statement filed in 1981,
from Susan Currie, Township Secretary /Treasurer.
b. You have a receipt for the statement filed in 1983,
from Susan Currie who wrote on the front page of the
statement "I, Susan Currie, received this Ethics Report
for the year 1983."
9. You stated that you have no idea why the Statement for 1984
is not on file, and cited an instance of missing meeting minutes
from the township building.
a. You stated that there would be no reason for you not to
have filed, in light of the fact that you filed for all
the other years.
b. ..T,ou stated that you are sure you filed every year.
10. You stated that you did not amend or refile any of the
Statements of Financial Interests after you received the five -
day letter from the State Ethics Commission regarding the
allegations made against you.
11. According to then Secretary /Treasurer, Susan Currie, she did
not recall any year that you did not file a Statement of
Financial Interests.
a. No records were kept as to who filed and who did not
file.
b. There was no check list on who should file in the
township.
Mr. James J. Fee
Page 4
c. Currie stated that to her knowledge, you did not refile
any of your Statements of Financial Interests.
12. According to Union Township payroll records, you were paid
the following amounts:
1982 - Gross: $932.30
Net: $696.31
1983 - Gross: $657.00
Net: $543.40
1984 - Gross: $980.00
Net: $778.40
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 governing authority of the political
subdivision by which he is employed no later
'han 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).
Section 5. Statement of financial interests.
(b) The statement shall include the following
information for the prior calendar year with
regard to the person required to file the
statement:
(5) The name and address of any person who is
the direct of indirect source of income
totalling in the aggregate $500 or more.
However, this provision shall not be
construed to require the divulgence of
Mr. James J. Fee
Page 5
confidential information protected by statute
or existing professional codes of ethics.
There is no doubt that as a Supervisor for Union Township,
you are within the purview of the above provisions of the State
Ethics Act. 65 P.S. §402.
The State Ethics Act defines "public official" as follows:
Section 2. Definition.
"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.
The filing requirement, as set forth in the Ethics Act has
been determined to apply equally to public officials and public
employees. Kremer v. State Ethics Commission, 56 Pa. Commw. Ct.
160, 424 A.2d 968, (1981); Carter, 79 -066.
The Ethics Act provides penalties for failure to file a
Statement of Financial Interests as follows:
Section 9. Penalties.
(b) Any person who violates the provisions of
Section 3(c) through (h) or 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 P.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).
Additionally, the Commission has recognized the need for
judicious application of the law and also reviews matters such as
the instant situation to determine if the failure to file or
delay in filing was occasioned by conscious action or in an
Mr. James J. Fee
Page 6
attempt to conceal or realize prohibited financial gain or
interests.
In the instant matter, it appears that you have filed all of
the requisite Statements of Financial Interests except for the
1984 calendar year. Although you have stated that you are
('ertain that you filed in every year and that you would have no
reason not to file since you have filed in other years, the fact
remains that the 1984 calendar year statement is not on file with
the township. This Commission finds a technical violation of
Section 4(a), as to the failure to file the 1984 calendar year
Statement of Financial Interests but will take no further action
provided you file the Statement of Financial Interests for the
1984 calendar year with Union Township within 30 days of this
Order.
Turning to the matter of your direct or indirect sources of
income in excess of $500 for the 1982 and 1983 calendar years, it
is a matter of concern to this Commission that for the 1983
calendar year, the inclusion of Union Township is entered below
the word "none" for such category. It might seem that "none" was
originally entered and "Union Township" was subsequently entered.
There is a second 1983 calendar year statement which lists Union
Township as a source of income in excess of $500 without any
other notation. For the 1982 calendar year, Union Township is
listed without the inclusion of the word "none" in that category.
Since Union Township is listed as a source of income on the
Statements of Financial Interests as they are on file with the
Township, this Commission finds that there is no violation of
Section 5(b) regarding these statements.
C. Conclds on and Order:
1. As a Union Township Supervisor, you are a public official
subject to the provisions of the State Ethics Act.
2. There is a technical violation of Section 4(a) of the Ethics
Act in that no Statement of Financial Interests is on file with
the Township for the 1984 calendar year.
3. If you file a 1984 calendar year Statement of Financial
Interests with Union Township within 30 days of the date of this
Order, this Commission will take no further action.
4. There is no violation of Section 5(b) of the Ethics Act
since you included Union Township as a source of income for your
1982 and 1983 calendar year Statement of Financial Interests.
Mr. James J. Fee
Page 7
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,
Joseph W. Marshall, III
Chairman