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In Re: Shelley Dixon,
Respondent
STATE ETHICS COMMISSION
FINANCE BUILDING
613 NORTH STREET, ROOM 309
HARRISBURG, PA 17120-0400
File Docket:
Order No.
Date Decided:
Date Mailed:
25-003-P
831-S
9/18/25
9/22/25
Before: Michael A. Schwartz, Chair
David L. Reddecliff, Vice Chair
Paul E. Parsells
Robert P. Caruso
Emilia McKee Vassallo
FACSIMILE: 717-787-0806
WEBSITE: www.ethics.pa.gov
This is a final adjudication of the Pennsylvania State Ethics Commission as to the alleged
delinquency and/or deficiency of Statement(s) of Financial Interests required to be filed pursuant
to Sections 1104 and 1105 of the Public Official and Employee Ethics Act ("Ethics Act"), 65
Pa. C.S. § 1101 et se .
The Investigative Division initiated these proceedings by filing with the State Ethics
Commission and serving upon Respondent an Order to Show Cause and a Petition for Civil
Penalties. A Stipulation of Findings and a Consent Agreement were subsequently submitted by
the parties to the Commission for consideration. The Stipulated Findings are set forth as the
Findings in this Order. The Consent Agreement has been approved.
L FINDINGS:
1. Respondent is an adult individual who resides or maintains a mailing address at [address
redacted].
2. At all times relevant to these proceedings, Respondent has been an Early Learning Program
Certification Representative with the Department of Human Services, and as such,
Respondent has at all times relevant to these proceedings been a "public official/public
employee" as defined in Section 1102 of the Ethics Act, 65 Pa.C.S. § 1102,
3. Respondent, as a public official/public employee, is subject to the Statement of Financial
Interests filing provisions of the Ethics Act.
4. Respondent failed to timely provide full financial disclosure as required by the Ethics Act.
Respondent failed to timely file a Statement of Financial Interests for calendar year 2023,
which was due by May 1, 2024. Respondent has therefore violated Sections 1104 and 1105
of the Ethics Act, 65 Pa.C,S. §§ 1104 and 1105.
Dixon,25-003-P
Page 2
5. By Notice Letter dated August 29, 2024, Respondent was served with Notice in accordance
with Section 1107(5) of the Ethics Act of the specific allegations against Respondent
concerning the above transgression. Said Notice Letter provided Respondent an
opportunity to avoid the institution of these civil penalty proceedings by filing an accurate
and complete Statement of Financial Interests for calendar year 2023 within twenty (20)
days of the date of the Notice letter. Respondent has failed and/or otherwise refused to file
a Statement of Financial Interests for calendar year 2023 so as to comply with the specific
requirements of the Ethics Act.
6. By Notice Letter dated October 2, 2024, Respondent was served with Notice in accordance
with Section 1107(5) of the Ethics Act of the specific allegations against Respondent
concerning the above transgression. Said Notice Letter provided Respondent an
opportunity to avoid the institution of civil penalty proceedings by fling an accurate and
complete Statement of Financial Interests for calendar year 2023 so as to comply with the
specific requirements of the Ethics Act.
7. Respondent failed to file her Statement of Financial Interest for calendar year 2023 with
the State Ethics Commission by the deadlines imposed in the Notice Letters.
11. DISCUSSION:
As an Early Learning Program Certification Representative with the Department of Human
Services ("Human Services"), Shelley Dixon ("Dixon") was at all times relevant to these
proceedings a "public employee" subject to the provisions of the Public Official and Employee
Ethics Act ("Ethics Act"), 65 Pa.C.S. § 1101 et seMc .
Pursuant to Section 1104(a) of the Ethics Act, Dixon was specifically required to file a
Statement of Financial Interests for calendar year 2023 with Human Services on or before May 1,
2024. Section 1104(a) provides:
§ 1104. Statement of financial interests required to be filed
(a) Public official or public employee. --Each public official of the
Commonwealth shall file a statement of financial interests for the preceding
calendar year with the commission no later than May 1 of each year that he holds
such a position and of the year after he leaves such a position. Each public
employee and public official of the Commonwealth shall file a statement of
financial interests for the preceding calendar year with the department, agency,
body or bureau in which he is employed or to which he is appointed or elected no
Iater than May 1 of each year that he holds such a position and of the year after lie
leaves such a position. Any other public employee or public official shall file a
statement of financial interests with the governing authority of the political
subdivision by which he is employed or within which he is appointed or elected no
later than May 1 of each year that he holds such a position and of the year after he
leaves such a position. Persons who are Rill -time or part-time solicitors for political
subdivisions are required to file under this section.
Dixon, 25-003-P
Page 3
65 Pa.C.S. § 1104(a).
The complete financial disclosure which Dixon as an Early Learning Program Certification
Representative was required to provide in the Statement of Financial Interests form is statutorily
mandated in detail at Section 1105 of the Ethics Act, 65 Pa.C.S. § 1105.
Section 1109(f) of the Ethics Act provides as follows:
§ 1109. Penalties
(f7 Civil penalty.-- In addition to any other civil remedy or criminal penalty
provided for in this chapter, the commission may, after notice has been served in
accordance with section 1107(5) (relating to powers and duties of commission)
and upon a majority vote of its members, levy a civil penalty upon any person
subject to this chapter who fails to file a statement of financial interests in a timely
manner or who files a deficient statement of financial interests, at a rate of not more
than $25 for each day such statement remains delinquent or deficient. The
maximum penalty payable under this paragraph is $250.
65 Pa.C.S. § 1109(f).
An application of Section 1109(f) to this case establishes that this Commission has the
discretion to levy a maximum civil penalty against Dixon for the delinquent Statement of Financial
Interests for calendar year 2023.
The prerequisite service of a Notice letter in accordance with Section 1107(5) was satisfied.
Dixon did not remedy the failure to comply with the Ethics Act although given more than the usual
grace period following Notice in which to do so. The Investigative Division then instituted formal
proceedings against Dixon by filing with the State Ethics Commission and serving upon Dixon an
Order to Show Cause and a Petition for Civil Penalties, ordering Dixon to show cause why a civil
penalty should not be levied against her. The parties then filed a Stipulation of Findings and a
Consent Agreement.
The parties propose that this case be resolved by: (1) this Commission finding that Dixon
failed to timely file a Statement of Financial Interests for the 2023 calendar year in compliance
with Section 1104(a) of the Ethics Act; (2) Dixon making payment of a civil penalty in the amount
of $150.00 in settlement of this matter by certified check or money order payable to the
Commonwealth of Pennsylvania and forwarded to this Commission no later than three months of
the issuance of the final adjudication in this matter; and (3) Dixon filing a complete and accurate
Statement of Financial Interests for calendar year 2023 in compliance with Section I I04(a) of the
Ethics Act within thirty days of the issuance of the final adjudication in this matter.
We believe that the Consent Agreement sets forth a proper disposition for this case, based
upon our review of the totality of the facts and circumstances. Accordingly, we approve the
Consent Agreement that has been submitted by the parties.
DixL , 25-003-P
Page 4
We hereby find that Dixon, as an Early Learning Program Certification Representative,
failed to timely file a Statement of Financial Interests for the 2023 calendar year in compliance
with Section 1104(a) of the Ethics Act, 65 Pa.C.S. § 1104(a).
Per the Consent Agreement of the parties, we hereby levy a civil penalty against Dixon in
the total amount of $150.00 for Dixon's delinquent Statement of Financial Interests for calendar
year 2023.
To the extent Dixon has not already done so, Dixon shall be ordered to make payment of
the aforesaid civil penalty in the total amount of $150.00 by no later than three months after the
mailing date of this adjudication and Order, by utilizing the Commission's electronic payment
system or by forwarding to this Commission a certified check or money order in the amount of
$150.00 made payable to the Commonwealth of Pennsylvania for deposit in the State Treasury.
To the extent Dixon has not already done so, Dixon shall be ordered to file a complete and
accurate Statement of Financial Interests for calendar year 2023 with Human Services by no later
than the thirtieth (30'h) day after the mailing date of this adjudication and Order, with one copy
forwarded to this Commission for compliance purposes.
III, CONCLUSIONS OF LAW:
Shelley Dixon ("Dixon"), as an Early Learning Program Certification Representative, was
at all times relevant to these proceedings a "public employee" subject to the provisions of
the Public Official and Employee Ethics Act ("Ethics Act"), 65 Pa.C.S. § 1101 et seq.
2. Dixon, as an Early Learning Program Certification Representative, failed to timely file a
Statement of Financial Interests for the 2023 calendar year in compliance with Section
I I04(a) of the Ethics Act.
3. Notice of the delinquency of Dixon's Statement of Financial Interests for calendar year
2023 was previously served upon her in accordance with Section 1107(5) of the Ethics Act,
65 Pa.C.S. § 1107(5).
4. Based upon the totality of the circumstances in this case, a civil penalty in the total amount
of $150.00 is warranted.
In Re: Shelley Dixon, File Docket: 25-003-P
Respondent Date Decided: 9/18/25
Date Mailed: 9/22/25
ORDER NO. 831-S
Shelley Dixon ("Dixon"), as an Early Learning Program Certification Representative with
the Pennsylvania Department of Human Services ("Human Services"), failed to timely file
a Statement of Financial Interests for the 2023 calendar year in compliance with Section
1104(a) of the Public Official and Employee Ethics Act, 65 Pa.C.S § 1104(a).
2. Per the Consent Agreement of the parties, we hereby levy a civil penalty against Dixon in
the total amount of $150.00 for Dixon's delinquent Statement of Financial Interests for
calendar year 2023.
3. To the extent Dixon has not already done so, Dixon is ordered to make payment of the
aforesaid civil penalty in the total amount of $150.00 by no later than three months after
the mailing date of this Order, by utilizing this Commission's electronic payment system
or by forwarding to this Commission a certified check or money order in the amount of
$150,00 made payable to the Commonwealth of Pennsylvania, for deposit in the State
Treasury.
4. To the extent Dixon has not already done so, Dixon is ordered to file a complete and
accurate Statement of Financial Interests for calendar year 2023 with Human Services by
no later than the thirtieth (30"') day after the mailing date of this Order, with a copy of such
filing forwarded to this Commission.
5. Failure to comply with Paragraph 3 of this Order will result in the initiation of an
appropriate enforcement action,
BY THE COMMISSION,
r
Michael A. Schwartz, Chair