HomeMy WebLinkAbout1401 Complainant AIn Re: Complainant A and Mr. B : File Docket:
X -ref:
Date Decided:
Date Mailed:
Before: Louis W. Fryman, Chair
John J. Bolger, Vice Chair
Donald M. McCurdy
Paul M. Henry
Raquel K. Bergen
Nicholas A. Colafella
Reverend Scott Pilarz
ID # 06 -014
LD # 06- 014 -WUA (A &B)
Order No. 1401
5/31/06
6/12/06
This is a preliminary determination of the State Ethics Commission as to wrongful
use of the Public Official and Employee Ethics Act, Act 9 of 1989, P.L. 26, 65 P.S. § 401 et
seq., as codified by Act 93 of 1998, Chapter 11, 65 Pa.C.S. § 1101 et seq., which Acts are
hereinafter referred to as the "Ethics Act."
Procedurally, the Investigative Division of the State Ethics Commission conducted a
preliminary inquiry under case number 04 -042 based upon alleged violation(s) of the
Ethics Act by an individual referred to herein as the "Subject." Following the preliminary
inquiry, the case was closed, and the Investigative Division so informed the Complainant
and the Subject. Thereafter, the Subject sought a finding as to wrongful use of the Ethics
Act by the Complainant, alleging that the information provided to this Commission was
frivolous and that the complaint was initiated without probable cause and primarily for a
purpose other than reporting a violation of the Ethics Act. The Subject also asserted a
confidentiality violation by the individual referred to herein as Mr. B, who the Subject
believed to be the Complainant.
The Investigative Division conducted a preliminary inquiry as to wrongful use of act
and submitted a report and recommendation for consideration. Upon review, this
Commission adopts the recommendation of the Investigative Division and preliminarily
determines that there has not been a wrongful use of the Ethics Act in this matter.
The Subject may appeal this preliminary determination to this Commission. 65
Pa.C.S. § 1110(c); 51 Pa. Code § 25.3(c)(2). Any such appeal must be in writing and must
be actually received at this Commission within thirty (30) days of the mailing date of this
preliminary determination, pursuant to 51 Pa. Code §§ 25.4(a), 11.1. If no timely appeal is
filed, this preliminary determination will become absolute and will become the final
determination of this Commission in this matter regarding wrongful use of the act, 51 Pa.
Code § 25.4(a), and will be released as a public document.
In the event of an appeal, an Order to Show Cause will be issued to the Subject
requiring the Subject to show cause why the rule should not be made absolute as to a
finding of no wrongful use of the act (65 Pa.C.S. § 1110(c); 51 Pa. Code § 25.4(b)(1)).
The Subject's answer to the rule must contain specific factual averments that establish a
basis for believing the Ethics Act was wrongfully used. One or more of the following shall
be inadequate to establish wrongful use of the Ethics Act: (1) the dismissal of the
complaint; (2) dismissal for lack of probable cause; or (3) dismissal on jurisdictional
grounds. 51 Pa. Code § 25.4(b)(1). Thereafter, a hearing may be held at which the
Subject bears the burden of proving wrongful use of the act by clear and convincing
In Re: Complainant A and Mr. B, Case 06- 014 -WUA (A &B)
Page 2
evidence. 51 Pa. Code § 25.4(b)(2). This Commission will then make a final
determination.
I. FINDINGS:
1. At all times relevant to this matter, the Subject has served as a Lieutenant or Chief
of Police for a Pennsylvania Township of the Second Class.
2. The Complainant filed a sworn complaint with this Commission against the Subject,
and the Investigative Division initiated a preliminary inquiry.
3. The preliminary inquiry as to the Subject focused upon the Subject's use, for
personal purposes, of the Township police vehicle assigned to him.
4. The Investigative Division's preliminary inquiry as to the Subject indicated that:
a. There was confirmation that the Subject used the Township police vehicle
assigned to him to attend a Penn State football game in State College,
Pennsylvania.
b. There was information indicating that the Subject might also have taken the
Township police vehicle assigned to him on vacation for one week in August
2003 at a South Carolina beach location.
5. Following the preliminary inquiry, the investigative proceedings as to the Subject
were closed based upon a determination that there was insufficient information to
support a finding of probable cause that the Ethics Act had been violated.
6. The Subject has alleged that the information provided to this Commission was
frivolous and that the complaint was initiated without probable cause and primarily
for a purpose other than reporting a violation of the Ethics Act.
7 The Investigative Division is of the view that the complaint against the Subject was
not frivolous or without probable cause.
8. The Investigative Division is of the view that the complaint against the Subject had
a basis in law and fact.
9. The Investigative Division has indicated that it exercised its prosecutorial discretion
to not further pursue the matter against the Subject because: (a) other individuals
in the Township had similarly used Township equipment for non - Township
purposes; and (b) the Township had no applicable policy in existence at that time
but subsequently remedied the situation by enacting a policy prohibiting the
utilization of Township equipment for such purposes.
10. The Subject has also asserted a wrongful use of act based upon an alleged breach
of confidentiality by the individual referred to herein as Mr. B, who the Subject
believes to be the Complainant.
a. The Subject has asserted that Mr. B made certain public comments to the
Township Board of Supervisors regarding Mr. B's possession of Ethics
complaint forms.
11. The Investigative Division's investigative review as to the alleged breach of
confidentiality by Mr. B has indicated that:
In Re: Complainant A and Mr. B, Case 06- 014 -WUA (A &B)
Page 3
a. The information submitted by the Subject's counsel in support of the
Subject's position does not contain any references by Mr. B regarding an
Ethics complaint or investigation as to the Subject.
(1) The Subject's Counsel has submitted meeting minutes for a June 14,
2004, meeting of the Township Board of Supervisors, which minutes
state that Mr. B was here with Ethics complaint forms that he is filing
with the state re: [Mr. C] and [Mr. D]," and that Mr. B stated that [Mr.
C] had not filed an Ethics form by [date] with the township.
(a) Neither of the individuals referred to herein as Mr. C and Mr. D
is the Subject.
(2) The meeting minutes indicate further discussion regarding Mr. D
failing to list income on his Ethics form.
The meeting minutes indicate that Mr. B later questioned whether the
Subject had used one of the police cars to go to a Penn State game.
(a) The question was not answered and no reference was made to
an Ethics complaint or investigation.
b. The Subject's attorney has acknowledged that he was not aware of any
specific confidentiality breaches during the preliminary inquiry into the
allegations against the Subject.
(3)
II. DISCUSSION:
At all times relevant to this matter, the Subject has served as a Lieutenant or Chief
of Police for a Pennsylvania Township of the Second Class (the "Township "), and as such,
the Subject has been a public official /public employee subject to the provisions of the
Ethics Act.
The Complainant filed a complaint with this Commission against the Subject (case
number 04 -042), and the Investigative Division opened a preliminary inquiry. The
preliminary inquiry focused upon the Subject's use for personal purposes of the Township
police vehicle assigned to him.
We note that the use of government staff, time, equipment, facilities, or property for
non - governmental purposes — including business, personal, or political purposes —is
generally prohibited and may form the basis for a violation of Section 1103(a) of the Ethics
Act, 65 Pa.C.S. § 1103(a). See, e.q., Confidential Opinion, 05 -001; Heck, Order 1251,
Holt, Order 1153 (business purposes); Moore, Order 1317, Meduka, Order 1277, Sullivan,
Order 1245, Dovidio, Order 1202 (personal purposes); Habay, Order 1313, Livingston,
Order 1030, Rockefeller, Order 1004, Freind, Order 800 (political purposes). This
Commission has long held that government offices, facilities, equipment, and personnel
are to be used for governmental purposes and not for private, business or campaign /re-
election activities. See, Smythe, Order 1121; Rakowsky, Order 943; Eck, Order 787;
Freind, supra; Ferlo, Opinion 97 -005.
Recently, we have found violations of Section 1103(a) of the Ethics Act by a
township supervisor who went grocery shopping during township work hours using a
township vehicle, Marhefka, Order 1388, and by another township supervisor who used his
township's high -lift, trimmer /mower, and other equipment for personal purposes, Mook,
Order 1356.
In Re: Complainant A and Mr. B, Case 06- 014 -WUA (A &B)
Page 4
In the instant matter, the Investigative Division's preliminary inquiry as to the Subject
indicated that there was confirmation that the Subject used the Township police vehicle
assigned to him to attend a Penn State football game in State College, Pennsylvania, and
that there was information indicating that the Subject might also have taken the Township
police vehicle assigned to him on vacation for one week in August 2003 at a South
Carolina beach location.
Although the Investigative Division concluded that the complaint against the Subject
was not frivolous or without probable cause, but rather, had a basis in law and fact, the
Investigative Division exercised its prosecutorial discretion in not further pursuing the
matter against the Subject because: (a) other individuals in the Township had similarly
used Township equipment for non - Township purposes; and (b) the Township had no
applicable policy in existence at that time but subsequently remedied the situation by
enacting a policy prohibiting the utilization of Township equipment for such purposes.
The base case having been closed, the Subject has now requested a determination
as to wrongful use of act by the Complainant, alleging that the information provided to this
Commission was frivolous and that the complaint was filed without probable cause and
primarily for a purpose other than reporting a violation of the Ethics Act.
The Subject has also asserted a wrongful use of act based upon an alleged breach
of confidentiality by the individual referred to herein as Mr. B, who the Subject believes to
be the Complainant. The information submitted by the Subject's counsel in support of the
Subject's position does not contain any references by Mr. B regarding an Ethics complaint
or investigation as to the Subject.
The Subject has asserted that Mr. B made certain public comments to the Township
Board of Supervisors regarding Mr. B's possession of Ethics complaint forms. The
Subject's Counsel has submitted meeting minutes for a June 14, 2004, meeting of the
Township Board of Supervisors, which minutes state that Mr. B was here with Ethics
complaint forms that he is filing with the state re: [Mr. C] and [Mr. D]," and that Mr. B stated
that [Mr. C] had not filed an Ethics form by [date] with the township. Neither of the
individuals referred to herein as Mr. C and Mr. D is the Subject. The meeting minutes
indicate further discussion regarding Mr. D failing to list income on his Ethics form. The
meeting minutes indicate that Mr. B later questioned whether the Subject had used one of
the police cars to go to a Penn State game. The question was not answered and no
reference was made to an Ethics complaint or investigation.
The elements of wrongful use of act are set forth in Section 1110 of the Ethics Act:
§ 1110. Wrongful use of chapter
(a) Liability. —A person who signs a complaint alleging
a violation of this chapter against another is subject to liability
for wrongful use of this chapter if:
(1) the complaint was frivolous, as defined by this
chapter, or without probable cause and made primarily for a
purpose other than that of reporting a violation of this chapter;
or
(2) he publicly disclosed or caused to be disclosed
that a complaint against a person had been filed with the
commission.
(b) Probable cause. —A person who signs a
complaint alleging a violation of this chapter has probable
In Re: Complainant A and Mr. B, Case 06- 014 -WUA (A &B)
Page 5
cause for doing so if he reasonably believes in the existence of
the facts upon which the claim is based and either:
(1) reasonably believes that under those facts the
complaint may be valid under this chapter; or
(2) believes to this effect in reliance upon the advice
of counsel, sought in good faith and given after full disclosure
of all relevant facts within his knowledge and information.
65 Pa.C.S. §§ 1110(a), (b).
The term "frivolous complaint" is defined in the Ethics Act as follows:
§ 1102. Definitions
"Frivolous complaint." A complaint filed in a grossly
negligent manner without basis in law or fact.
65 Pa.C.S. § 1102.
In applying the above provisions to the facts and circumstances presented in this
case, it is the preliminary determination of this Commission that there has been no
wrongful use of the Ethics Act established in this matter.
First, in light of the precedents of this Commission, the fact that the Subject used,
for personal purposes, the Township police vehicle assigned to him necessitates the
conclusion that the complaint against the Subject had a basis in law and fact and was
neither frivolous nor without probable cause. Given that conclusion, we need not and do
not address whether the complaint was made primarily for a purpose other than that of
reporting a violation of the Ethics Act.
We shall now address the Subject's allegation of wrongful use of the Ethics Act
based upon an alleged breach of confidentiality by Mr. B. Section 1110 of the Ethics Act
pertaining to wrongful use of the act applies exclusively to complainants. The Subject has
asserted that Mr. B was the Complainant in case number 04 -042.
Without addressing the identity of the Complainant, we find that there is insufficient
evidence to support a wrongful use of the Ethics Act based upon an alleged breach of
confidentiality by Mr. B. There is no evidence whatsoever that Mr. B publicly disclosed or
caused to be disclosed that a complaint against the Subject had been filed with this
Commission. As for alleged references to other individuals, the sweeping assertion in the
meeting minutes that Mr. B was here with Ethics complaint forms that he is filing with the
state re: [Mr. C] and [Mr. D]," is an insufficient basis upon which to reach any conclusions
or find any violations of the Ethics Act based upon what, if anything, Mr. B actually said.
The essential elements for a wrongful use of the Ethics Act have not been
established in this matter.
III. CONCLUSIONS OF LAW:
1. At all times relevant to this matter, the Subject has served as a Lieutenant or Chief
of Police for a Pennsylvania Township of the Second Class (the "Township "), and
as such, the Subject has been a public official /public employee subject to the
provisions of the Ethics Act.
In Re: Complainant A and Mr. B, Case 06- 014 -WUA (A &B)
Page 6
2. Under the facts and circumstances presented in this matter, there is no basis for
concluding that the complaint filed against the Subject at case number 04 -042 was
frivolous or without probable cause.
3. Without addressing the identity of the Complainant, there is insufficient evidence to
support a wrongful use of the Ethics Act based upon an alleged breach of
confidentiality by Mr. B.
4. The essential elements for a wrongful use of the Ethics Act have not been
established in this matter.
In Re: Complainant A and Mr. B : File Docket:
Date Decided:
Date Mailed:
ORDER NO. 1401
ID # 06 -014
LD # 06- 014 -WUA (A &B)
5/31/06
6/12/06
1 It is the preliminary determination of this Commission that Complainant A did not
wrongfully use the Ethics Act as to the filing of the complaint against the Subject
under case number 04 -042.
2. Without addressing the identity of the Complainant, it is the preliminary
determination of this Commission that there is insufficient evidence to support a
wrongful use of the Ethics Act based upon an alleged breach of confidentiality by
Mr. B.
3. If no timely appeal is filed, this preliminary determination will become absolute and
will become the final determination of this Commission in this matter regarding
wrongful use of the act and will be released as a public document.
BY THE COMMISSION,
Louis W. Fryman, Chair