Loading...
HomeMy WebLinkAbout1855 EbrightPHONE: 717-783-1610 TOLL FREE: 1-800-932-0936 In Re: Lori Ebright, Respondent STATE ETHICS COMMISSION FINANCE BUILDING 613 NORTH STREET, ROOM 309 HARRISBURG, PA 17120-0400 File Docket: Order No. Date Decided: Date Mailed: 25-0090-C t855 4/16/26 4/23/26 Before: Michael A. Schwartz, Chair David L. Reddecliff, Vice Chair Paul E. Parsells Robert P. Caruso Emilia McKee Vassallo This is a final adjudication of the State Ethics Commission, FACSIMILE: 717-787-0806 WEBSITE: www.ethics.pa.gov Procedurally, the Investigative Division of the State Ethics Commission conducted an investigation regarding possible violation(s) of the Public Official and Employee Ethics Act ("Ethics Act"), 65 Pa.C.S. § 1101 et sec.., by the above -named Respondent. At the commencement of its investigation, the Investigative Division served upon Respondent written notice of the specific allegations. Upon completion of its investigation, the Investigative Division issued and served upon Respondent a Findings Report identified as an "Investigative Complaint." A Stipulation of Findings and a Consent Agreement were subsequently submitted by the parties to the Commission for consideration. The Findings in this Order are derived from the parties' Stipulation of Findings. The Consent Agreement has been approved. I. ALLEGATIONS: That Lori Ebright, a public official as a Supervisor for Montour Township ("Township"), violated Sections 1103(a) and 1105(b)(2)-(10) of the Ethics Act: (1) When she participated in actions, including voting, which resulted in the hiring of her daughter as the Planning Commission Clerk, Zoning Hearing Board Secretary, and the Codes/Zoning Officer, resulting in a private pecuniary benefit to her daughter; (2) When she participated in actions, including voting, which resulted in a raise for her daughter, resulting in a private pecuniary benefit to her daughter; (3) When she filed a deficient Statement of Financial Interests ("SFI") for calendar year 2020 by failing to fully complete the form; (4) When she filed a deficient SFI for calendar year 2021 by failing to fully complete the form; Ebright, 25-0090-C Page 2 (5) When she filed a deficient SFI for calendar year 2022 by failing to fully complete the form; (6) When she filed a deficient SFI for calendar year 2023 by failing to disclose her occupation and failing to report all income received over $1,300; and (7) When she filed a deficient SFI for calendar year 2024 by failing to fully complete the forin. II. FINDINGS: 1. Lori Ebright ("Ebright") sewed as a Member of the Montour Township ("Township") Board of Supervisors from approximately 2013 until her resignation on March 13, 2025. a. The Township is a Second Class Township, governed by a three -member Board of Supervisors. b. Compensation for Township Supervisors ("Supervisors") employed by the Township is annually approved by the Township Board of Auditors. C. Compensation for Township employees who are not Supervisors is annually approved by the Township Board of Supervisors ("Board of Supervisors"). d. The Board of Supervisors enters into employment contracts with the Township's administrative employees. 2. Ashley Ebright ("A. Ebright") is the adult daughter of Ebright. a. At all times relevant to this investigation, Ebright and A. Ebright shared a common residence. 3. In 2021, the Board of Supervisors consisted of Ebright, Linda Woodward ("Woodward"), and Mike Hinkle ("Hinkle"). a. Ebright was Chair of the Board of Supervisors and the Township S ecretary/Treasurer. b. Woodward oversaw administrative functions including the office, codes enforcement, zoning, and the Township Planning Commission ("Planning Commission"). 4. During 2021, the Township's administrative positions included Office Clerk, Planning Commission Secretary, and Codes/Zoning Enforcement Officer. a. Employee resignations created vacancies for the pant -time positions of Planning Commission Secretary and Codes/Zoning Enforcement Officer in early 2021. Ebi�iPlrt, 25-0090-C Page 3 5. During the Board of Supervisors' meeting on February 22, 2021, Danielle Berkes ("Berkes"), the Township Treasurer and Office Clerk, was laid off due to COVID-19 pandemic shutdowns. 6. Ebright participated in the action that laid off Berkes. 7. Ebright, who already held the position of Township Secretary, was appointed as the Township Treasurer and the Township Right -to -Know Officer, replacing Berkes. S. The Township did not advertise or solicit applicants for any of its vacant administrative positions in February 2021. 9. Woodward was unable to find interested individuals to hold these positions, which she believed was due in part to COVID-19 restrictions. 10. Woodward initiated a conversation with A. Ebright to inquire whether she would have interest in working for the Township in an administrative capacity. a. Ebright was present for the conversation and was not in favor of A. Ebright working for the Township. b. Woodward and A. Ebright continued the conversation, with A. Ebright indicating that she would be interested in working for the Township. C. A. Ebright was employedRill-time by the Columbia Montour Agency on Aging at the time. 11. Woodward decided to merge the vacant positions of Planning Commission Secretary, Zoning/Codes Enforcement Officer, and Office Clerk into one full-time position. 12. A. Ebright volunteered to help with Township administrative tasks beginning in late February/early March 2021, prior to being fired by the Board of Supervisors to a full-time position. 13. During the Board of Supervisors' March 11, 2021, meeting, Woodward made a motion to appoint A. Ebright to the combined position of Planning Commission Clerk, Zoning Hearing Board Secretary, and Codes/Zoning Officer. a. Ebright was present for the meeting but is not on record as seconding the motion. b. Minutes include the following recorded discussion: "Ms. Woodward stated she has researched the option of combining these duties into one position. Zoning and Planning Secretary duties are pretty much the same. In previous years these duties were performed by the office staff. Ms. Woodward stated codes/zoning and planning need to be combined with the above duties to Eb.__. _ r ht, 25-0090-C Page 4 have a single person complete the work. Ms. Woodward had asked Ashley Ebright to volunteer with codes and zoning the last two weeks and watched her handle several issues. A motion was made by Ms. Woodward and seconded by Mr. Hinkle to offer the position to Miss Ebright as a combined full-time position at a rate of $19.50 per hour with a 6-month probationary period. Motion carried." 14. Board of Supervisor meeting minutes do not include a recorded abstention by Ebright on the motion to hire A. Ebright. 15. Ebright took the official meeting minutes for the Board of Supervisors' meeting on March 11, 2021. a. These meeting minutes were approved without any changes or corrections during the Board of Supervisors' meeting on April 8, 2021. 1. Ebright was present at this meeting and was responsible for recording those minutes as well. b. Ebright and Woodward assert that Ebright abstained from voting on the hiring despite no recorded abstention in the official meeting minutes and the approval of those minutes at the following meeting. 16. On April 1, 2021, Ebright signed an employment contract for A. Ebright in her official capacity as Chair of the Board of Supervisors. a. This contract was signed by A, Ebright and attested to by Woodward. b. The contract stated that A. Ebright was to be "employed as a Codes and Zoning Officer, Planning Commission Clerk and Zoning Hearing Board Secretary." C. The contract stated that A. Ebright was to work at the Township Municipal Building. d. The contract stated that A. Ebright was to work for no more than forty hours per week. e. Compensation was set at $19.50 per hour payable on the first day of every month and the first business day after the fifteenth day of the month. f. Contract terms also provided for paid vacation, sick and holiday pay, life insurance and medical benefits. 17. A. Ebright reported to Woodward. a. Woodward reviewed and approved A. Ebright's timesheets for payment. 18. Ebright signed a second employment contract for A. Ebright dated January 1, 2022. Ebright, 25-0090-C Page 5 a. This contract established an hourly rate of $22.15 per hour for 2022. b. This contract was also signed by A. Ebright and attested to by Woodward. 19. The Board of Supervisors voted during its January 3, 2022, reorganization meeting to approve A. Ebright to serve as the Township Clerk, Zoning Officer, Codes Enforcement Officer, and Planning Commission Clerk for 2022. a. Each appointment was made by a separate motion. b. Compensation for each position was set at $22.15 per hour per A. Ebright's employment contract. C. Each of these actions included a motion, a second and the letter "Y" under the phrase, "motion carried." d. Ebright did not make or second any of these motions. e. There are no recorded abstentions for any of these approvals. 20. In the meeting minutes, the phrase "motion carried" meant that all Supervisors present voted in favor of the motion. a. Abstentions, when they occur, are noted in the official meeting minutes. 21. Ebright was present and responsible for preparing meeting minutes for the January 3, 2022, reorganization meeting in her official capacity as Secretary/Treasurer. 22. Minutes from the January 3, 2022, Board of Supervisors reorganization meeting were approved on January 14, 2022, without any changes. a. Ebright was present at the January 14, 2022, Board of Supervisors meeting. 23. Ebright did not sign the employment contracts for A. Ebright covering the 2023 and 2024 calendar years. a. These annual appointments were approved by the Board of Supervisors on January 3, 2023, and January 2, 2024, respectively. 24. Ebright voted on the 2023 appointment but abstained from the vote on the 2024 appointment. 25. On January 3, 2023, Ebright seconded the motions and voted in favor of appointing A. Ebright to the positions of Township Clerk, Zoning Officer, Codes Enforcement Officer, Planning Commission Clerk, and Zoning Hearing Board Administrative Secretary at the contracted rate of $23.48 per hour for 2023. Ebr�ighi, 25-0090-C Page 6 26. The Board of Supervisors consisted of two Members, Ebright and Woodward, on January 3, 2023, when this vote occurred. a. Meeting minutes included the following disclosure: "It was noted that Chairman Ebright would typically abstain from voting on any motions involving her position as secretary/treasurer or motions regarding the employment of Ashley Ebright as it would be a conflict of interest. Since Mr. Kirshner's resignation was placed in the mailbox while the office was closed, notice of his resignation was only received right before the meeting. Leaving only two supervisors in place for voting." 27. According to the meeting minutes, Ebright began to abstain from actions involving employment and compensation for herself and A. Ebright after January 3, 2023. 28. Township records include an abstention memo dated March 9, 2023, that was filed by Ebright. a. Ebright filed a conflict of interest abstention memo regarding the "approval of employee contracts for myself and Ashley Ebright." 1. The stated reason for the conflict/abstention was reported as: "I would not approve my own contract - my salary is set by the elected auditors. Ashley Ebright is my daughter — her contract & salary are set by the other Supervisors according to PSAT recommendations." THE FOLLOWING FINDINGS EXPLAIN THE FINANCIAL GAIN TO BOTH A. EBRIGHT AND EBRIGHT AS A RESULT OF EBRIGHT'S USE OF OFFICE TO HIRE A. EBRIGHT. 29. W-2 Wage and Tax Statements on file with the Township for A. Ebright document the following annual gross compensation received by A. Ebright while employed by the Township: 2021: $30,490.35 2022: $49,855.49 2023: $51,403.92 2024 : $29,110.23 30. A. Ebright's wages received from the Township were electronically deposited into a personal account in her name at Service 1" Federal Credit Union, A. Ebright used these funds to pay personal living expenses for herself as well as expenses incurred for her shared residence with Ebright. El. ___�,t, 25-0090-C Page 7 31. Shared expenses paid by A. Ebright included PPL Electric Utilities ("PPL Electric") and Fruits Fuel Service. a. A. Ebright is the account holder for the PPL Electric and Fruits Fuel Service accounts for the shared residence with Ebright. 32. A. Ebright continued to make regular payments on these accounts after being hired by the Township. 33, A. Ebright paid $2,940,00 to Fruits Fuel Service on the account for her shared residence with Ebright from March 12, 2021, through December 2023. 34. A. Ebright made at least 34 payments to PPL Electric totaling $4,339.19 on the account for her shared residence with Ebright covering the period of March 12, 2021, through December 2023. 35. A. Ebright paid a total amount of $7,279.19 to Fruits Fuel Service and PPL Electric on accounts for her shared residence with Ebright from March 12, 2021, through December 2023. 36. Ebright realized a private pecuniary benefit of $3,639.60 from March 12, 2021, through December 2023 as a result of A. Ebright's employment with the Township. 37. Ebright used the authority of her office when she participated in Board of Supervisors actions, including voting, which resulted in A. Ebright being hired by the Township. 38. Ebright used the authority of her office when she participated in Board of Supervisors actions, including voting, which resulted in a raise for A. Ebright. THE FOLLOWING FINDINGS RELATE TO EBRIGHT'S FILING OF DEFICIENT STATEMENTS OF FINANCIAL INTERESTS FOR CALENDAR YEARS 2020, 2021, 2022, 2023, AND 2024. 39. As a Supervisor, Ebright was required to file Statements of Financial Interests ("SFIs") each year that she was in office by May 1 of the following year. 40. Ebright filed deficient SFIs for calendar years 2020, 2021, 2022, 2023, and 2024 when she failed to fully complete the SFIs and did not provide all required disclosures. 41. On her SFI filed for calendar year 2020, Ebright had the following deficiencies: a. Failed to disclose the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more in Block 10. b. Failed to list gifts valued at $250 or more in Block 11. EbriZht, 25-0090-C Page 8 C. Failed to disclose transportation, lodging or hospitality exceeding $650 in Block 12. d. Failed to list office, directorship, or employment in any business in Block 13. e. Failed to list financial interest in any legal entity in business for profit in Block 14. f. Failed to list business interests transferred to immediate family member in Block 15, 42. On her SFI filed for calendar year 2021, Ebright had the following deficiencies: a. Failed to list real estate interests in Block 8. b. Failed to list creditors to whom is owed more than $6,500 in Block 9. C. Failed to disclose the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more in Block 10. d. Failed to list gifts valued at $250 or more in Block 11. e. Failed to disclose transportation, lodging or hospitality exceeding $650 in Block 12. 43. On her SFI filed for calendar year 2022, Ebright had the following deficiencies: a. Failed to list her occupation in Block 6. b. Failed to list real estate interests in Block 8. C. Failed to list creditors to whom is owed more than $6,500 in Block 9. d. Failed to disclose the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more in Block 10. e. Failed to list gifts valued at $250 or more in Block 11. f. Failed to disclose transportation, lodging or hospitality exceeding $650 in Block 12. g. Failed to list office, directorship or employment in any business in Block 13. h. Failed to list financial interest in any legal entity in business for profit in Block 14. EbE�igh , 25-0090-C .Page 9 i. Failed to list business interests transferred to immediate family member in Block 15. 44. On her SFI filed for calendar year 2023, Ebright had the following deficiencies: a. Failed to list her occupation in Block 6. b. Failed to report the Township as a source of income in BIock 10. 45, On her SFI filed for calendar year 2024, Ebright had the following deficiencies: a. Failed to list real estate interests in Block 8. b. Failed to list creditors to whom is owed more than $6,500 in Block 9. C. Failed to disclose the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more in Block 10. d. Failed to list gifts valued at $250 or more in Block 11. e. Failed to disclose transportation, lodging or hospitality exceeding $650 in Block 12. f. Failed to list office, directorship, or employment in any business in Block 13. g. Failed to list financial interest in any legal entity in business for profit in Block 14. h. Failed to list business interests transferred to immediate family member in Block 15. 46. On July 18, 2025, Ebright filed amended SFIs for the 2020 through 2024 calendar years to correct deficiencies in her original filings. a. Review of these amended filings found no deficiencies. III. DISCUSSION: As a Supervisor for Montour Township ("Township") from approximately 2013 until March 13, 2025, Lori Ebright ("Ebright") was a public official subject to the provisions of the Public Official and Employee Ethics Act ("Ethics Act"), 65 Pa.C.S. § 1101 et sec . The relevant allegations in this matter are that Ebright violated Sections 1103(a) and 1105(b)(2)-(10) of the Ethics Act: (1) When she participated in actions, including voting, which resulted in the hiring of her daughter as the Planning Commission Clerk, Zoning Hearing Board Secretary, Ebrightt, 25-0090-C Page 10 and the Codes/Zoning Officer, resulting in a private pecuniary benefit to her daughter; (2) When she participated in actions, including voting, which resulted in a raise for her daughter, resulting in a private pecuniary benefit to her daughter; (3) When she filed a deficient Statement of Financial Interests ("SFI") for calendar year 2020 by failing to fully complete the form; (4) When she filed a deficient SFI for calendar year 2021 by failing to fully complete the form; (5) When she filed a deficient SFI for calendar year 2022 by failing to fully complete the form; (6) When she filed a deficient SFI for calendar year 2023 by failing to disclose her occupation and failing to report all income received over $1,300; and (7) When she filed a deficient SFI for calendar year 2024 by failing to fully complete the form. Per the Consent Agreement, the Investigative Division has exercised its prosecutorial discretion to nolle pens other allegations. Pursuant to Section 1103(a) of the Ethics Act, a public official/public employee is prohibited from engaging in conduct that constitutes a conflict of interest: § 1103. Restricted activities (a) Conflict of interest. —No public official or public employee shall engage in conduct that constitutes a conflict of interest. 65 Pa.C.S, § 1103(a). The following teens relevant to Section 1103(a) are defined in the Ethics Act as follows: § 1102. Definitions "Conflict" or "conflict of interest." Use by a public official or public employee of the authority of his office or employment or any confidential information received through his holding public office or employment for the private pecuniary benefit of himself, a member of his immediate family or a business with which he or a member of his immediate family is associated. The term does not include an action having a de minimis economic impact or which affects to the same degree a class consisting of the Ebright, 25-0090-C Page 1 I general public or a subclass consisting of an industry, occupation or other group which includes the public official or public employee, a member of his immediate family or a business with which he or a member of his immediate family is associated. "Authority of office or employment." The actual power provided by law, the exercise of which is necessary to the performance of duties and responsibilities unique to a particular "Immediate family." A parent, spouse, child, brother or sister. 65 Pa.C.S. § 1102. Subject to the statutory exclusions to the Ethics Act's definition of the term "conflict' or "conflict of interest," 65 Pa.C.S. § 1102, pursuant to Section 1103(a) of the Ethics Act, a public official/public employee is prohibited from using the authority of public office/employment or confidential information received by holding such a public position for the private pecuniary (financial) benefit of the public official/public employee himself, any member of his immediate family, or a business with which he or a member of his immediate family is associated. A child is a member of "immediate family" as the Ethics Act defines that term. Section 1105(b) of the Ethics Act and its subsections detail the financial disclosure that a person required to file the SFI form must provide. Section 1105(b)(2) of the Ethics Act requires the filer to disclose on the SFI his occupation or profession. Section 1105(b)(3) of the Ethics Act requires the filer to disclose on the SFI any direct or indirect interest in any real estate which was sold or leased to or purchased or leased from the Commonwealth, any of its agencies or political subdivisions, or which was the subject of any condemnation proceedings by the Commonwealth or any of its agencies or political subdivisions. Subject to certain statutory exceptions, Section 1105(b)(4) of the Ethics Act requires the filer to disclose on the SFl the name and address of each creditor to whom is owed in excess of $6,500 and the interest rate thereon. Subject to certain statutory exceptions, Section 1105(b)(5) of the Ethics Act requires the filer to disclose on the SFI the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more. Subject to certain statutory exceptions, Section 1105(b)(6) of the Ethics Act requires the filer to disclose on the SFI the name and address of the source and the amount of any gift or gifts valued in the aggregate at $250 or more and the circumstances of each gift. Subject to certain statutory exceptions, Section 1105(b)(7) of the Ethics Act requires the filer to disclose on the SFI the name and address of the source and the amount of any payment for Ebright, 25-0090-C Page 12 or reimbursement of actual expenses for transportation and lodging or hospitality received in connection with public office or employment where such actual expenses exceed $650 in an aggregate amount per year. Section 1105(b)(8) of the Ethics Act requires the filer to disclose on the SFI any office, directorship or employment in any business entity. Section 1105(b)(9) of the Ethics Act requires the filer to disclose on the SFI any financial interest in any legal entity engaged in business for profit. Section 1105(b)(10) of the Ethics Act requires the filer to disclose on the SFI any financial interest in a business with which he is or has been associated in the preceding calendar year which has been transferred to a member of his inunediate family, The term "financial interest" is defined in the Ethics Act as "[a]ny financial interest in a legal entity engaged in business for profit which comprises more than 5% of the equity of the business or more than 5% of the assets of the economic interest in indebtedness." 65 Pa. C.S. § 1102. As noted above, the parties submitted a Stipulation of Findings with their Consent Agreement. The Findings of this Commission set forth above are derived from the parties' Stipulation of Findings, We shall now summarize the relevant facts in this matter. Ebright served as a Member of the Township Board of Supervisors (`Board") from approximately 2013 until her resignation on March 13, 2025. The Board consists of three Members. The Board approves the compensation for Township employees who are not Township Supervisors ("Supervisors") and enters into employment contracts with the Township's administrative employees. Ashley Ebright ("A, Ebright") is Ebright's daughter. At all times relevant to this matter, Ebright and A. Ebright shared a residence. In early 2021, the Board consisted of Ebright, Linda Woodward ("Woodward"), and Mike Hinkle ("Hinkle"). Ebright was Chair of the Board and the Township Secretary at that time. Woodward oversaw the Township's administrative functions and positions. At the time, the Township's administrative positions included Office Clerk, Planning Commission Secretary, and Zoning and Codes Enforcement Officer. As a result of employee resignations, vacancies existed in the part-time positions of Planning Commission Secretary and Zoning and Codes Enforcement Officer. The Office Clerk position also became vacant when the Township Treasurer and Office Clerk, Danielle Berks, was laid off on February 22, 2021, due to the COVID-19 pandemic shutdown. When Woodward was unable to find individuals interested in holding the vacant positions, she initiated a conversation with A. Ebright to inquire whether she would be interested in working for the Township in an administrative capacity. Although Ebright was present for the conversation and was not in favor of A. Ebright working for the Township, A. Ebright indicated that she would be interested in working for the Township. Woodward then decided to merge the vacant positions into one full-time position, Ebright, 25-0090-C Page 13 During the March 11, 2021, meeting of the Board, Woodward made a motion to appoint A. Ebright to a combined full-time position as the Planning Commission Clerk, Zoning Hearing Board Secretary, and Codes/Zoning Officer at the pay rate of $19.50 per hour. Woodward's motion was seconded by Hinkle. Although minutes of the meeting taken by Ebright reflect that Woodward's motion carried and do not reflect that Ebright abstained from the vote, Ebright and Woodward assert that Ebright did abstain from the vote. On April 1, 2021, Ebright, in her capacity as Chair of the Board, and A. Ebright signed an employment contract for A. Ebright to be employed as the Planning Commission Clerk, Zoning Hearing Board Secretary, and Codes/Zoning Officer for up to forty hours per week at the pay rate of $19.50 per hour. The contract terms also provided for paid vacation, sick and holiday pay, life insurance and medical benefits. As a Township employee, A. Ebright reported to Woodward, who reviewed and approved A. Ebright's timesheets. At the January 3, 2022, reorganization meeting of the Board, the Supervisors, by way of a series of motions, voted to appoint A. Ebright to serve in the positions of Township Clerk, Zoning Officer, Codes Enforcement Officer, and Planning Commission Clerk for 2022. Ebright was responsible for preparing the minutes of the meeting, which reflect that each motion carried and do not reflect that Ebright abstained from any of the votes. Ebright and A. Ebright signed a contract for A. Ebright's Township employment for 2022 at an hourly pay rate of $22.15. When the Board held its reorganization meeting on January 3, 2023, the Board consisted of only Ebright and Woodward, as the Township had received notice of the third Supervisor's resignation before the meeting. During the meeting, Ebright seconded and voted in favor of motions made by Woodward to appoint A. Ebright to the positions of Township Clerk, Zoning Officer, Codes Enforcement Officer, Planning Commission Clerk, and Zoning Hearing Board Administrative Secretary for 2023 at an hourly pay rate of $23.48. Ebright did not sign A. Ebright's employment contract for 2023, and she abstained from fixture actions of the Board that involved A. Ebright's Township employment. A. Ebright used some of the compensation that she received from her Township employment to pay expenses incurred for electric and fuel service for the residence that she shared with Ebright. A. Ebright held accounts with PPL Electric Utilities and Fruits Fuel Service, and from March 12, 2021, through December 2023, she paid $3,339.19 to PPL Electric Utilities and $2,940.00 to Fruits Fuel Service for services for the Ebrights' shared residence. The parties have stipulated that Ebright realized a private pecuniary benefit of $3,639.60 from March 12, 2021, through December 2023 as a result of A. Ebright's employment with the Township. As a Supervisor, Ebright was annually required to file an SFI by May 1 containing information for the prior calendar year. The Stipulated Findings reflect that there were numerous deficiencies in Ebright's SFIs for calendar years 2020 through 2024 due to her failure to fully complete her SFIs and make all of the required disclosures. On July 18, 2025, Ebright filed amended SFIs for calendar years 2020 through 2024 to correct the deficiencies in her original filings. A review of Ebright's amended SFIs found no deficiencies. Having highlighted the Stipulated Findings and issues before us, we shall now apply the Ethics Act to determine the proper disposition of this case. Ebright, 25-0090-C Page 14 The parties' Consent Agreement sets forth a proposed resolution of the allegations as follows: The Investigative Division will recommend the following in relation to the above allegations: a. That a violation of Section 1103(a) of the Public Official and Employee Ethics Act, 65 Pa.C.S. § 1103(a), occurred when Ebright participated in actions, including voting, which resulted in the hiring of her daughter as the Planning Commission Clerk, Zoning Hearing Board Secretary, and the Codes/Zoning Officer, resulting in a private pecuniary benefit to her daughter; b. That a violation of Section 1103(a) of the Public Official and Employee Ethics Act, 65 Pa.C.S. § 1103(a), occurred when Ebright participated in actions, including voting, which resulted in a raise for her daughter, resulting in a private pecuniary benefit to her daughter; G. That a violation of Sections 1105(b)(5), (6), (7), (8), (9), and (10) of the Public Official and Employee Ethics Act, 65 Pa.C.S. §§ 1105(b)(5), (6), (7), (8), (9), and (10), occurred when Ebright filed a deficient Statement of Financial Interests for calendar year 2020 when she failed to disclose the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more; failed to list gifts valued at $250 or more; failed to disclose transportation, lodging, or hospitality exceeding $650; failed to list office, directorship, or employment in any business; failed to list financial interest in any legal entity in business for profit; and failed to list business interests transferred to immediate family member; d. That a violation of Sections 1105(b)(3), (4), (5), (6), and (7) of the Public Official and Employee Ethics Act, 65 Pa.C.S. §§ 1105(b)(3), (4), (5), (6), and (7), occurred when Ebright filed a deficient Statement of Financial Interests for calendar year 2021 when she failed to disclose real estate interests sold or leased to the Commonwealth, any of its agencies or political subdivisions; failed to list creditors to whom she owed more than $6,500; failed to disclose the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more; failed to list gifts valued at $250 or more; and failed to disclose transportation, lodging, or hospitality exceeding $650; Ebrigh , 25-0090-C Page 15 C. That a violation of Sections 1105(b)(2), (3), (4), (5), (6), (7), (8), (9), and (10) of the Public Official and Employee Ethics Act, 65 Pa.C.S. §§ 1105(b)(2), (3), (4), (5), (6), (7), (8), (9), and (10), occurred when Ebright filed a deficient Statement of Financial interests for calendar year 2022 when she failed to disclose her occupation; failed to disclose real estate interests sold or leased to the Commonwealth, any of its agencies or political subdivisions; failed to list creditors to whom she owed more than $6,500; failed to disclose the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more; failed to list gifts valued at $250 or more; failed to disclose transportation, lodging, or hospitality exceeding $650; failed to list office, directorship, or employment in any business; failed to list financial interest in any legal entity in business for profit; and failed to list business interests transferred to immediate family member; f. That a violation of Sections 1105(b)(2) and (5) of the Public Official and Employee Ethics Act, 65 Pa.C.S. §§ 1105(b)(2) and (5), occurred when Ebright filed a deficient Statement of Financial Interests for calendar year 2023 when she failed to list her occupation and failed to report all direct or indirect sources of income totaling in the aggregate $1,300 or more; and g. That a violation of Sections 1105(b)(3), (4), (5), (6), (7), (8), (9), and (10) of the Public Official and Employee Ethics Act, 65 Pa.C.S. §§ 1105(b)(3), (4), (5), (6), (7), (8), (9), and (10), occurred when Ebright filed a deficient Statement of Financial Interests for calendar year 2024 when she failed to disclose real estate interests sold or leased to the Commonwealth, any of its agencies or political subdivisions; failed to list creditors to whom she owed more than $6,500; failed to disclose the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more; failed to list gifts valued at $250 or more; failed to disclose transportation, lodging, or hospitality exceeding $650; failed to list office, directorship, or employment in any business; failed to list financial interest in any legal entity in business for profit; and failed to list business interests transferred to immediate family member. The remaining counts are nolle prossed. Ebi�igh , 25-0090-C Page 16 4. Ebright agrees to make payment in the amount of $1,819.80 in settlement of this matter payable to Montour Township, and forwarded to the Pennsylvania State Ethics Commission, within thirty (30) days of the issuance of the final adjudication in this matter. This amount is half of the calculated private pecuniary benefit to Ebright, based on payment of household bills by her daughter that are in her daughter's name, b. Ebright also agrees to make additional payment in the amount of $750 in settlement of the violations stemming from the deficient Statements of Financial Interests. This is to be payable to the Commonwealth of Pennsylvania and forwarded to the Pennsylvania State Ethics Commission within thirty (30) of the issuance of the final adjudication in this matter. 5. To the extent Ebright has not already done so, Ebright agrees to file complete and accurate amended Statements of Financial Interests with Montour Township, through the Pennsylvania State Ethics Commission, for calendar years 2020 through 2024 within thirty (30) days of the issuance of the final adjudication in this matter. 6. Ebright agrees to not accept any reimbursement, compensation or other payment from Montour Township representing a full or partial reimbursement of the amount paid in settlement of this matter. 7. The Investigative Division will recommend that the State Ethics Commission take no further action in this matter and make no specific recommendations to any law enforcement or other authority to take action in this matter. Such, however, does not prohibit the Commission from initiating appropriate enforcement actions in the event of Ebright's failure to comply with this agreement or the Commission's order or cooperating with any other authority who may so choose to review this matter further. a. Ebright has been advised that as a matter of course, all orders from the Commission are provided to the Attorney General, albeit without any specific recommendations pursuant to Paragraph 7 above. b. Ebright has been advised that all orders become public records and may be acted upon by law enforcement as they deem appropriate. C. The non -referral language contained in this paragraph is considered an essential part of the negotiated Consent Agreement. Ebright, 25-0090-C Page 17 Consent Agreement, at 2-4. In considering the Consent Agreement, we agree with the parties that violations of Section 1103(a) of the Ethics Act occurred in relation to Ebright's participation in matters involving her daughter's employment with the Township. A. Ebright was initially appointed to a combined full- time position as the Planning Commission Clerk, Zoning Hearing Board Secretary, and Codes/Zoning Officer at the Board meeting held on March 11, 2021. A. Ebright was again appointed to various Township positions of employment at the Board's January 3, 2022, reorganization meeting. Although the parties' Stipulated Findings do not clearly resolve the issue of whether Ebright participated in the votes that appointed A. Ebright to employment with the Township in March 2021 and January 2022, it is clear that Ebright signed A. Ebright's employment contracts for 2021 and 2022 and participated in the January 3, 2023, Board vote that once again appointed A. Ebright to various Township positions of employment. Ebright's actions facilitated both the hiring of her daughter and an increase in her daughter's hourly pay rate from $19.50 in 2021 to $23.48 in 2023, which resulted in a private pecuniary (financial) benefit to her daughter. Based upon the Stipulated Findings and the Consent Agreement, we hold that: (1) a violation of Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), occurred when Ebright participated in actions, including voting, which resulted in the hiring of her daughter as the Planning Commission Clerk, Zoning Hearing Board Secretary, and Codes/Zoning Officer, resulting in a private pecuniary benefit to her daughter; and (2) a violation of Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), occurred when Ebright participated in actions, including voting, which resulted in a raise for her daughter, resulting in a private pecuniary benefit to her daughter. Turning to the allegations regarding Ebright's SFIs, we agree with the parties, and we hold, that: (1) A violation of Sections 1105(b)(5)-(10) of the Ethics Act, 65 Pa.C.S. §§ 1105(b)(5)-(10), occurred when Ebright filed a deficient SFI for calendar year 2020 when she failed to disclose the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more; failed to list gifts valued at $250 or more; failed to disclose transportation, lodging, or hospitality exceeding $650; failed to list office, directorship, or employment in any business; failed to list financial interest in any legal entity in business for profit; and failed to list business interests transferred to immediate family member; (2) A violation of Sections 1105(b)(3)-(7) of the Ethics Act, 65 Pa.C.S. §§ 1105(b)(3)-(7), occurred when Ebright filed a deficient SFI for calendar year 2021 when she failed to disclose real estate interests sold or leased to the Commonwealth, any of its agencies or political subdivisions; failed to list creditors to whom she owed more than $6,500; failed to disclose the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more; failed to list gifts valued at $250 or more; and failed to disclose transportation, lodging, or hospitality exceeding $650; Ebright, 25-0090-C Page 18 (3) A violation of Sections 1105(b)(2)-(10) of the Ethics Act, 65 Pa.C.S. §§ 1105(b)(2)-(10), occurred when Ebright filed a deficient SFI for calendar year 2022 when she failed to disclose her occupation; failed to disclose real estate interests sold or leased to the Commonwealth, any of its agencies or political subdivisions; failed to list creditors to whom she owed more than $6,500; failed to disclose the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more; failed to list gifts valued at $250 or more; failed to disclose transportation, lodging, or hospitality exceeding $650; failed to list office, directorship, or employment in any business; failed to list financial interest in any legal entity in business for profit; and failed to list business interests transferred to immediate family member; (4) A violation of Sections 1105(b)(2) and (5) of the Ethics Act, 65 Pa.C.S. §§ 1105(b)(2) and (5), occurred when Ebright filed a deficient SFI for calendar year 2023 when she failed to list her occupation and failed to report all direct or indirect sources of income totaling in the aggregate $1,300 or more; and (5) A violation of Sections 1105(b)(3)-(10) of the Ethics Act, 65 Pa.C.S. §§ 1105(b)(3)-(10), occurred when Ebright filed a deficient SFI for calendar year 2024 when she failed to disclose real estate interests sold or leased to the Commonwealth, any of its agencies or political subdivisions; failed to Iist creditors to whom she owed more than $6,500; failed to disclose the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more; failed to list gifts valued at $250 or more; failed to disclose transportation, lodging, or hospitality exceeding $650; failed to list office, directorship, or employment in any business; failed to list financial interest in any legal entity in business for profit; and failed to list business interests transferred to immediate family member. As part of the Consent Agreement, Ebright has agreed to make payment in the amount of $1,819.80 payable to the Township and forwarded to this Commission within thirty (30) days of the issuance of the final adjudication in this matter. Ebright has further agreed to make payment in the amount of $750.00 payable to the Commonwealth of Pennsylvania for her SFI violations, with such payment to be forwarded to this Commission within thirty (30) days of the issuance of the final adjudication in this matter. Ebright has additionally agreed to not accept any reimbursement, compensation or other payment from the Township representing a full or partial reimbursement of the amount paid in settlement of this matter. We determine that the Consent Agreement submitted by the parties sets forth a proper disposition of this case, based upon our review as reflected in the above analysis and the totality of the facts and circumstances. IV. CONCLUSIONS OF LAW: Ebright, 25-0090-C Page 19 As a Supervisor for Montour Township from approximately 2013 until March 13, 2025, Lori Ebright ("Ebright") was a public official subject to the provisions of the Public Official and Employee Ethics Act ("Ethics Act"), 65 Pa.C.S. § 1101 et sec . 2. A violation of Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), occurred when Ebright participated in actions, including voting, which resulted in the hiring of her daughter as the Planning Commission Clerk, Zoning Hearing Board Secretary, and Codes/Zoning Officer, resulting in a private pecuniary benefit to her daughter. 3. A violation of Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), occurred when Ebright participated in actions, including voting, which resulted in a raise for her daughter, resulting in a private pecuniary benefit to her daughter. 4. A violation of Sections 1105(b)(5)-(10) of the Ethics Act, 65 Pa.C.S. §§ 1105(b)(5)-(10), occurred when Ebright filed a deficient Statement of Financial Interests ("SFI") for calendar year 2020 when she failed to disclose the naive and address of any direct or indirect source of income totaling in the aggregate $1,300 or more; failed to list gifts valued at $250 or more; failed to disclose transportation, lodging, or hospitality exceeding $650; failed to list office, directorship, or employment in any business; failed to list financial interest in any legal entity in business for profit; and failed to list business interests transferred to immediate family member. 5. A violation of Sections 1105(b)(3)-(7) of the Ethics Act, 65 Pa.C.S, §§ 1105(b)(3)-(7), occurred when Ebright filed a deficient SFI for calendar year 2021 when she failed to disclose real estate interests sold or leased to the Commonwealth, any of its agencies or political subdivisions; failed to list creditors to whom she owed more than $6,500; failed to disclose the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more; failed to list gifts valued at $250 or more; and failed to disclose transportation, lodging, or hospitality exceeding $650. 6. A violation of Sections 1105(b)(2)-(10) of the Ethics Act, 65 Pa.C.S. §§ 1105(b)(2)-(10), occurred when Ebright filed a deficient SFI for calendar year 2022 when she failed to disclose her occupation; failed to disclose real estate interests sold or leased to the Commonwealth, any of its agencies or political subdivisions; failed to list creditors to whom she owed more than $6,500; failed to disclose the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more; failed to list gifts valued at $250 or more; failed to disclose transportation, lodging, or hospitality exceeding $650; failed to list office, directorship, or employment in any business; failed to list financial interest in any legal entity in business for profit; and failed to list business interests transferred to immediate family member. 7. A violation of Sections 1105(b)(2) and (5) of the Ethics Act, 65 Pa.C.S. §§ 1105(b)(2) and (5), occurred when Ebright filed a deficient SFI for calendar year 2023 when she failed to list her occupation and failed to report all direct or indirect sources of income totaling in the aggregate $1,300 or more. Eb_ right, 25-0090-C Page 20 S. A violation of Sections 1105(b)(3)-(10) of the Ethics Act, 65 Pa.C.S. §§ 1105(b)(3)-(10), occurred when Ebright filed a deficient SFI for calendar year 2024 when she failed to disclose real estate interests sold or leased to the Commonwealth, any of its agencies or political subdivisions; failed to list creditors to whom she owed more than $6,500; failed to disclose the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more; failed to list gifts valued at $250 or more; failed to disclose transportation, lodging, or hospitality exceeding $650; failed to list office, directorship, or employment in any business; failed to list financial interest in any legal entity in business for profit; and failed to list business interests transferred to immediate family member. In Re: Lori Ebright, File Docket: 25-0090-C Respondent Date Decided: 4/16/26 Date Mailed: 4/23126 ORDER NO.1855 A violation of Section 1103(a) of the Public Official and Employee Ethics Act ("Ethics Act"), 65 Pa.C.S. § 1103(a), occurred when Lori Ebright ("Ebright"), as a Supervisor for Montour Township, participated in actions, including voting, which resulted in the hiring of her daughter as the Planning Commission Clerk, Zoning Hearing Board Secretary, and Codes/Zoning Officer, resulting in a private pecuniary benefit to her daughter. 2. A violation of Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), occurred when Ebright participated in actions, including voting, which resulted in a raise for her daughter, resulting in a private pecuniary benefit to her daughter. 3. A violation of Sections 1105(b)(5)-(10) of the Ethics Act, 65 Pa.C.S. §§ 1105(b)(5)-(10), occurred when Ebright filed a deficient Statement of Financial Interests ("SFI") for calendar year 2020 when she failed to disclose the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more; failed to list gifts valued at $250 or more; failed to disclose transportation, lodging, or hospitality exceeding $650; failed to list office, directorship, or employment in any business; failed to list financial interest in any legal entity in business for profit; and failed to list business interests transferred to immediate family member. 4. A violation of Sections 1105(b)(3)-(7) of the Ethics Act, 65 Pa.C.S. §§ 1105(b)(3)-(7), occurred when Ebright filed a deficient SFI for calendar year 2021 when she failed to disclose real estate interests sold or leased to the Commonwealth, any of its agencies or political subdivisions; failed to list creditors to whom she owed more than $6,500; failed to disclose the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more; failed to list gifts valued at $250 or more; and failed to disclose transportation, lodging, or hospitality exceeding $650. 5. A violation of Sections 1105(b)(2)-(10) of the Ethics Act, 65 Pa.C.S. §§ 1105(b)(2)-(10), occurred when Ebright filed a deficient SFI for calendar year 2022 when she failed to disclose her occupation; failed to disclose real estate interests sold or leased to the Commonwealth, any of its agencies or political subdivisions; failed to list creditors to whom she owed more than $6,500; failed to disclose the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more; failed to list gifts valued at $250 or more; failed to disclose transportation, lodging, or hospitality exceeding $650; failed to list office, directorship, or employment in any business; failed to list financial interest in any legal entity in business for profit; and failed to list business interests transferred to immediate family member. Ebright, 25-0090-C Page 22 6. A violation of Sections 1105(b)(2) and (5) of the Ethics Act, 65 Pa.C.S. §§ 1105(b)(2) and (5), occurred when Ebright filed a deficient SFI for calendar year 2023 when she failed to list her occupation and failed to report all direct or indirect sources of income totaling in the aggregate $1,300 or more. 7. A violation of Sections 1105(b)(3)-(10) of the Ethics Act, 65 Pa.C.S. §§ 1105(b)(3)-(10), occurred when Ebright filed a deficient SFI for calendar year 2024 when she failed to disclose real estate interests sold or leased to the Commonwealth, any of its agencies or political subdivisions; failed to list creditors to whom she owed more than $6,500; failed to disclose the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more; failed to list gifts valued at $250 or more; failed to disclose transportation, lodging, or hospitality exceeding $650; failed to list office, directorship, or employment in any business; failed to list financial interest in any legal entity in business for profit; and failed to list business interests transferred to immediate family member. 8. Per the Consent Agreement of the parties, Ebright is directed to make payment in the amount of $1,919.80 payable to Montour Township and forwarded to the Pennsylvania State Ethics Commission by no later than the thirtieth (30th) day after the mailing date of this Order. 9. Per the Consent Agreement of the parties, Ebright is directed to make payment in the amount of $750.00 payable to the Commonwealth of Pennsylvania and forwarded to the Pennsylvania State Ethics Commission by no later than the thirtieth (30"') day after the mailing date of this Order. 10. Ebright is directed to not accept any reimbursement, compensation or other payment from Montour Township representing a full or partial reimbursement of the amount paid in settlement of this matter. 11. Compliance with paragraphs 8, 9, and 10 of this Order will result in the closing of this case with no further action by this Commission. a. Non-compliance will result in the institution of an order enforcement action. BY THE COMMISSION, ////X(Z4� , ichaef A. Se iwartz, Chair