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HomeMy WebLinkAbout99-002-R JohnsonWallace G. Johnson, P.E. 666 Kelso Road Pittsburgh, PA 15243 Dear Mr. Johnson: I. ISSUE: OPINION OF THE COMMISSION III. DISCUSSION: Before: Daneen E. Reese, Chair Austin M. Lee, Vice Chair Julius Uehlein Louis W. Fryman John J. Bolger Frank M. Brown Susan Mosites Bicket DATE DECIDED: 6/1/99 DATE MAILED: 6/10/99 99 -002 -R Re: Public Employee; PennDOT; Engineer; Temporary Wage Employee; Bridge Coordinator; Section 1103(g) Reconsideration; Opinion 99 -002. This Opinion is issued in response to your timely request for reconsideration of Opinion 99 -002. Whether this Commission should grant reconsideration of Opinion 99 -002. II. FACTUAL BASIS FOR DETERMINATION: On February 3, 1999, you appealed Advice of Counsel 99 -500. At a public meeting on February 26, 1999 we decided the appeal of advice and then issued Johnson, Opinion 99 -002 on March 10, 1999. In a timely reconsideration request received on April 9, 1999, you argue that our finding that you had the ability to take or recommend official action which has an economic impact of greater than a de minimis nature on the interests of any person must be viewed from the perspective of its entirety whereby there must be a resultant effect before a restriction or prohibition under the Ethics Act arises. You assert that because you take no action, there is no economic impact upon the interests of any person. Finally, you argue that it is inconceivable that Commonwealth Court intended to hold an individual responsible for the actions which he could, but does not actually, perform. Johnson, 99 -002 -R June 10, 1999 Page 2 We have been asked to reconsider Opinion 99 -002. This Commission may exercise broad discretion in determining whether to grant or deny reconsideration as long as such discretion is exercised in a sound manner. Krane, Opinion 84- 001 -R; PSATS v. State Ethics Commission, 499 A.2d 735 (1985). The Regulations of this Commission provide: §13.3. Opinions. (d) Reconsideration may be granted in the discretion of the Commission under §21.29(e). §21.29. Finality; reconsideration. (b) Any party may ask the Commission to reconsider an order or opinion within 30 days of service of the order or opinion. The requestor shall present a detailed explanation setting forth the reason why the order or opinion should be reconsidered. (c) A request for reconsideration filed with the Commission will delay the public release of an order, but will not suspend the final order unless reconsideration is granted by the Commission. (d) A request for reconsideration may include a request for a hearing before the Commission. (e) Reconsideration may be granted at the discretion of the Commission if: (1) A material error of law has been made. (2) A material error of fact has been made. (3) New facts or evidence are provided which would lead to reversal or modification of the order or opinion and if these could not be or were not discovered by the exercise of due diligence. 51 Pa.Code § §13.3(d); 21.29(b), (c), (d), (e). We must now address the question as to whether you meet the criteria for this Commission to exercise its discretion to either grant or deny reconsideration. You raise two arguments as to our decision in Opinion 99 -002: that your actions do not have an economic impact of greater than a de minimis nature on the interests of any person; and that the decision of Commonwealth Court does not apply to an individual who could, but does not actually, perform such actions. The first argument was extensively considered and rejected in Opinion 99 -002. The second issue concerning your interpretation of the decision of Commonwealth Court in Phillips v. State Ethics Commission, 470 A.2d 659 (Pa. Commw. Ct. 1984) is simply contrary to the holding of the Court. Accordingly, since there is no material error of fact or law, we deny reconsideration in the exercise of our discretion. Johnson, 99 -002 -R June 10, 1999 Page 3 IV. CONCLUSION: Reconsiderationn of Opinion 99 -002 is denied. Pursuant to Section 1107(10), the person who acts in good faith on this opinion issued to him shall not be subject to criminal or civil penalties for so acting provided the material facts are as stated in the request. This letter is a public record and will be made available as such. By the Commission, Daneen E. Reese Chair