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HomeMy WebLinkAbout1772 GreenleePHONE: 7'17-783-1610 TOLL FREE: 1-800-932-0936 In Re: John Greenlee, Respondent STATE ETHICS COMMISSION FINANCE BUILDING 613 NORTH STREET, ROOM 309 HARRISBURG, PA 17120-0400 File Docket: X-ref: Date Decided Date Mailed: FACSIMILE: 717-787-0806 WEBSITE: www.ethics.pa.gov 19-008 Order No. 1772 6/22/20 6/24/20 Before: Nicholas A. Colafella, Chair Mark R. Corrigan, Vice Chair Roger Nick Melanie DePalma Michael A. Schwartz Shelley Y. Simms This is a final adjudication of the State Ethics Commission. 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 seq., 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 Investiative Division issued and served upon Respondent a Findings Report identified as an In'Investigativevestigative Complaint." An Answer was filed and a hearing was requested. 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. ALLEGATIONS: That John Greenlee, a public official/public employee in his capacity as a Member of the Bethlehem -Center School District Board of Directors, Washington County, violated Sections 1103(a), 1104(a), 1104(dL8) 1105(b)(1), 1105(b)(2), 1105(b)(5), and 1105(b)(8) of the State Ethics Act (Act 93 of 1 when he used the authority offi his public position for a private pecuniary benefit by participating in discussions and actions of the Board resulting in his nomination and subsequent approval to serve as the School Board Treasurer at an annual stipend of $975.00; voted to approve/authorize issuance of stipend to himself in calendar ears 2018 and 2019; and when he failed to file a 2014 calendar year Statement of Financial Interests; filed a deficient 2015 calendar year Statement of Financial Interests by failing to respond to disclosure of address, governmental entity, and occupation and [failing to list] reportable income from the District; and filed deficient 2016 and 2017 calendar year Statements of Financial Interests by failing to report his office/directorship/employment in Greenlee Realty. II. FINDINGS: John Greenlee 4"Greenlee") has served as a Member of the Bethlehem -Center School District ('District") Board of Directors ("Board"), Washington County, from April 22, 2013, to the present. Greenlee was appointed to serve the unexpired term of Board Member Mary Mazeppa (' Mazeppa"). Greenlee, 19-008 a� 1. Mazeppa resigned from the Board "effective immediately" (April 22, 2013). b. Greenlee was subsequently elected as the Treasurer of the Board at the December 3, 2013, reorganizational meeting of the Board. C. Greenlee served as the Treasurer of the Board from December 3, 2013, until June 30, 2019. 2. The District is governed by a nine -Member Board. a. The Board holds an agenda meeting and a legislative meeting on the fourth Monday of each month. 1. Agenda meetings are held immediately prior to the legislative meetings. 2. Voting occurs solely at legislative meetings. b. Special meetings are held as necessary. 3. Voting at Board legislative meetings occurs via individual roll call vote and/or group aye/nay voice vote depending on the issue before the Board. a. Voting on District business relating to the expenditure of funds (e.g., personnel decisions, Board officer elections, etc.) occurs via individual roll call vote. b. Voting on District business relating to routine and/or procedural matters occurs via group aye/nay voice vote. 1. Any abstention or objection cast triggers an individual roll call vote. 2. Meeting minutes only reflect the individuals) who cast an abstention or objection. 3. Affirming (aye) votes are not recorded. C. At the subsequent legislative meeting, minutes of the District's prior meetings are reviewed for accuracy, following which a vote is taken to adopt/approve the official minutes. 4. In the event of an abstention, the District utilizes abstention forms to document the individual Board Members who abstained from action/vote. a. Board Members are responsible for submitting an abstention form to the Board's Recording Secretary for any action from which they abstained. 5. On or by the IF ida prior to the legislative meeting, the Board receives informational packets agenda packets) via email from the Administrative Assistant to the Superintendent. a. Examples of items contained within the informational packets include but are not limited to the upcoming legislative meeting agenda, a list of approved substitutes, [information for] applicants for District positions (e.g., resume, cover letter, letter of recommendation), and a bill list. Greenlee, 19-008 al e-- 6. The motion and vote to approve the Treasurer's Report and bill list occur at each Board legislative meeting. a. The motion and vote regarding approval of the Treasurer's Report occur as a single, all -encompassing aye/nay group vote. b. The motion and vote regarding approval of the payment of bills occur as a separate, all -encompassing roll call vote. 7. Payment checks to vendors are held until the bill list is approved at the legislative meeting. a. An exception may be made for normal recurring bills, minor accounts that may incur penalties, and/or Board stipends. 8. Signature authority over District accounts is maintained, at a minimum, by the Board Treasurer, Board Secretary, Board President, and Board Vice President. a. The number of signatures required on District checks is account specific. The District's general fund account requires a minimum of three authorized signatories per check. b. District checks are generated electronically by the Business Office. The Board Treasurer's signature is electronically printed on the checks when drafted. C. All other required signatures are live signatures. THE FOLLOWING INFORMATION PERTAINS TO GREENLEE'S PARTICIPATION IN ACTIONS OF THE BOARD RESULTING IN HIS NOMINATIONS AND ELECTIONS AS THE BOARD TREASURER AND HIS SUBSEQUENT COMPENSATION AS A RESULT OF HIS PARTICIPATION IN HIS ELECTIONS, 9. Section 401 of the Pennsylvania Public School Code addresses the beginning of the school year and organizational meetings. a. Section 401(b) states in part that all school districts of the second, third, and fourth class shall begin the school year on the first day of July of each year and the school directors are to meet and organize annually during the first week of December. 10. Section 404 of the Pennsylvania Public School Code requires that each district of the third class annually elect a treasurer to a term beginning on July 1st a. Members of the board are permitted to serve in the office of board treasurer in districts of the third class. b. The same person cannot hold more than one of the offices of president, vice president, secretary, or treasurer of the board at the same time. 11. Pursuant to Bethlehem -Center School District Local Board Procedure, the Board Treasurer shall receive an annual stipend of $975.00. a. The Board Treasurer, in part, is responsible for the following: Paying all District expenses from District funds upon Board Greenlee, 19-008 a�� authorization; 2. Making a monthly report of funds received and disbursed for the Board Secretary; and 3. Serving as an authorized District signatory on District checks issued to vendors. 12. At the Board's December 3, 2013, legislative meeting, Board President Chad Novotney called for nominations for the vacant Board Treasurer position. a. Board Member Valerie Caprini nominated Greenlee for the position. b. No other individuals were nominated. C. Greenlee accepted his nomination. 13. Upon closing the nominations, the Board conducted a unanimous roll call vote to elect Greenlee to the Board Treasurer position. a. Greenlee was elected to serve as the Board Treasurer for the remainder of the balance of the one-year term. 1. Greenlee was present for, and voted in favor of, his election to the office of Board Treasurer. b. The motion did not identify any type of stipend to be paid to Greenlee in his capacity as the Board Treasurer. 1. Although not specified within the motion, Greenlee was aware at the time of the vote that he was to receive an annual stipend of $975.00 as the Board Treasurer. 14. Greenlee was present for, and participated in, Board votes regardinghis election to the compensated pposition of Board Treasurer on four separate occasions between May 19, 2014, and May 29, 2018, as detailed below: LEGISLATIVE MEETING GREENLEE PRESENT MOTION SECOND FINAL VOTE GREENLEE'S VOTE 05/19/14 Yes Katrus a Gwyer 9-0 Aye 06/29/15 Yes Caprini KatrusKa 9-0 Aye 05/23/16 Yes Frost Trump 8-0 Aye 051221 7 Yes Katruska Trump 8-0 Aye 05 29 8 Yes _-7r—ump Marcolini 8-0-1 staine a. Greenlee abstained from the vote to elect him to the position of Board Treasurer at the District's May 29, 2018, legislative meeting. b. Greenlee filed a written memorandum with the District in relation to his abstention. 1. Greenlee's abstention memorandum confirmed him doing so, "under advice of the solicitor as it is a salaried position." 15. Greenlee's participation in the motion to elect the Board Treasurer led directly to his election to a compensated position on the Board. 16. As the Board Treasurer, Greenlee received annual compensation from the District totaling $5,118.75 for the period of July 2015 through January 2019 as follows: Greenlee, 19-008 Page CHECK PAY TO THE SIGNED BY DATE NO. ORDER OF GREENLEE 07/28/20 5 54257 Greenlee Yes 10/28/2016 54679 Greenlee Yes 02/17/2017 54772* Greenlee Unknown 03/01/2018 52592 Greenlee Yes 01/11/2019 53956 Greenlee Yes TOTALS *Check No. 54722 not available for inspection DEPOSIT ENDORSED GROSS DATE BY AMOUNT 08103 20 5 Greenlee $1,462.50 12/08/2016 Greenlee $1,218.75 Unknown Unknown $487.50 03/08/2018 Stamp to Payee $975.00 01/17/2019 Greenlee $975.00 a. Check numbers 54257, 54679, and 54772 were issued to Greenlee through the District's payroll. 1. Payroll is not voted on or otherwise specifically approved at Board legislative meetings. b. Check numbers 52592 and 53956 were issued to Greenlee through the District's General Fund as detailed below: LEGISLATIVE MEETING DATE 01/22/19 1 GREENLEE PRESENT Yes Yes APPROVED FINAL VOTE GREENLEE'S VOTE STIPEND AMOUNT 8-1 Aye TOTAL 9t Greenlee was present for both legislative meetings and voted in favor of approving both District bill lists, which included compensation to Greenlee as the Board Treasurer. 2. Greenlee endorsed and negotiated each of the checks received from the District in relation to his position of Board Treasurer. C. Greenlee's signature as a District signatory was electronically affixed to each check he received as the Board Treasurer. 1. Greenlee, as the Board Treasurer, held signature authority over all District accounts. THE FOLLOWING PERTAINS TO GREENLEE'S STATEMENT OF FINANCIAL INTERESTS FORMS FILED WITH THE DISTRICT. 17. Greenlee was required to file Statements of Financial Interests ("SFIs") by May 1st annually for each calendar year in which he served as a Member of the Board. 18. On January 23, 2019, an SFI compliance review was conducted for the District. a. The District could not locate SFI forms pertaining to calendar year 2016. b. The District located calendar year 2016 SFI forms and provided said forms to the Investigative Division on April 8, 2019. 19. Greenlee was required to have SFIs on file with the District for calendar years 2014, 2015, 2016, 2017, and 2018. 20. Greenlee's calendar year 2014 SFI could not be located at the District. a. Greenlee asserts that he filed a calendar year 2014 SFI with the District. b. In light of the District misplacing calendar year 2016 SFIs, Greenlee's Greenlee, 19-008 aaT age assertion is credible. 21. Greenlee filed a deficient calendar year 2015 SFI by failing to respond to disclosure of address, governmental entity, and occupation and failing to list reportable income from the District. a. Greenlee neglected to include either a home or business address. b. Greenlee neglected to include the District as the political subdivision for which he held public office. C. Greenlee neglected to include his current occupation or profession. d. Greenlee's calendar year 2015 SFI filing did not disclose his income from the District. 22. Greenlee held no reportable office, directorship, and/or employment with Greenlee Realty during calendar years 2016 and 2017. III. DISCUSSION: As a Member of the Board of Directors ("Board") of the Bethlehem -Center School District ("District"), Washington County, Pennsylvania, from April 22, 2013, to the present, and as the Board Treasurer from December 3, 2013, until June 30, 2019, Respondent John Greenlee, also referred to herein as "Respondent." "Respondent Greenlee," and "Greenlee," has been a public official subject to the provisions of the Public Official and Employee Ethics Act ("Ethics Act"), 65 Pa.C.S. § 1101 et seq. The allegations are that Greenlee violated Sections 1103(a), 1104(a), 1104(d), 1105(b)(1), 1105(b)(2), 1105(b)(5), and 1105(b)(8) of the Ethics Act: (1) when he used the authhority of his public position as a Member of the Board for a private pecuniary benefit by participating in discussions and actions of the Board resulting in his nomination and subsequent approval to serve as the Board Treasurer at an annual stipend of $975.00; Vdwhen he voted to approvelauthorize issuance of a stipend to himself in calendar years 18 and 2019, 3 when he failed to file a calendar year 2014 Statement of Financial Interests ("SFI"); �4 when he filed a deficient calendar year 2015 SFI by failing to respond to disclosure of ad ress, governmental entity, and occupation and failing to list reportable income from the District; and 5) when he filed deficient SFIs for calendar years 2016 and 2017 by failing to report his o iceldirectorshiplemployment in Greenlee Realty. Per the Consent Agreement of the parties, the Investigative Division has exercised its prosecutorial discretion to withdraw the alleged violation of Section 1103(a) of the Ethics Act with regard to Greenlee voting to approve/authorize issuance of a stipend to himself in calendar years 2018 and 2019 as well as the alleged violation of Section 1104(a) of the Ethics Act. Therefore, we need not address the allegations that are no longer before us. 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 public employee shall conflict of interest. 65 Pa.C.S. § 1103(a). of interest. —No public official or engage in conduct that constitutes a Greenlee, 19-008 a� The term "conflict of interest" is 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 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. 65 Pa.C.S. § 1102. Section 1103(a) of the Ethics Act prohibits a public official/public employee from using the authority of public office/employment or confidential information received by holding such a public position for the private pecuniary 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. Section 1104(d)of the Ethics Act provides that no public official shall be allowed to take the oath of office, or enter or continue upon his duties, nor shall he receive compensation from public funds, unless he has filed an SFI as required by the Ethics Act. 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)(1) of the Ethics Act requires the filer to disclose on the SFI his name, address, and public position. Section 1105(b)(2) of the Ethics Act requires the filer to disclose on the SFI his occupation or profession. 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. 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. As noted above, the parties have submitted a Consent Agreement and Stipulation of Findings. The parties' Stipulated Findings are set forth above as the Findings of this Commission. We shall now summarize the relevant facts as contained therein. The Board consists of nine Members. Greenlee has served as a Member of the Board from April 22, 2013, to the present. At the reorganizational meeting of the Board on December 3, 2013, Board President Chad Novotney called for nominations for the vacant office of Board Treasurer. Greenlee was nominated for the office of Board Treasurer by Board Member Valerie Caprini. No other individuals were nominated, and Greenlee accepted his nomination. Greenlee participated in a unanimous Board vote that elected him to serve as the Board Greenlee, 19-008 a�� Treasurer for the remainder of the vacant one-year term of office. Pursuant to Bethlehem - Center School District Local Board Procedure, the Board Treasurer shall receive an annual stipend of $975.00. Although the motion regarding Greenlee's election as the Board Treasurer did not identify any type of stipend to be paid to him for serving as the Board Treasurer, he was aware at the time of the vote on the motion that he was to receive an annual stipend of $975.00 for serving as the Board Treasurer. Between May 19, 2014, and May 22, 2017, Greenlee participated in four unanimous Board votes that elected him as the Board Treasurer for a one-year term. On May 29, 2018, Greenlee abstained from a Board vote that elected him as the Board Treasurer for a one-year term. Greenlee filed an abstention memorandum with the District which confirmed that he was abstaining "under advice of the solicitor as it is a salaried position." Greenlee ultimately served as the Board Treasurer from December 3, 2013, until June 30, 2019. For the period of July 2015 through January 2019, Greenlee received compensation totaling $5,118.75 from the District for serving as the Board Treasurer. See, Fact Finding 16. Greenlee, as the Board Treasurer, held signature authority over aff-District accounts. Greenlee's signature as the Board Treasurer was electronically printed on each check that he received from the District for serving as the Board Treasurer. As for Greenlee's SFIs, on January 23, 2019, an SFI compliance review was conducted for the District. Greenlee filed a deficient SFI for calendar year 2015 by: (1) neglecting to list either a home or business address; (2) neglecting to list the District as the political subdivision for which he held public office; 3) negglecting to list his current occupation or profession; and ((4) failing to disclose the istrict, from which he received gross compensation totaling $1,462.50 in 2015, as a reportable source of income. The parties have stipulated that Greenlee held no reportable office, directorship, or employment with Greenlee Realty during calendar years 2016 and 2017. Having highlighted the Stipulated Findings and issues before us, we shall now apply the Ethics Act to determine the proper disposition of this case. 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 in relation to John Greenlee, as a N(ember of the Bethlehem -Center School District Board of Directors, participating in discussions and actions of the Board of Directors resulting in his nomination and subsequent appointment as the School Board Treasurer. That a technical violation of Sections 1105(b)(1), and 5) of the Public Official and Employee E�2) hics Act, 65 Pa-C.S. §§ 1105(b)(1), (2) and (5), occurred when Greenlee filed a deficient 2015 calendar year Statement of Financial Interests by failing to respond to disclosure of address, governmental entity, Greenlee, 19-008 of e-- [and] occupation, and [by failing to list] reportable income from the District. That no violation of Section 1105(b)(8) of the Public Official and Employee Ethics Act, 65 Pa.C.S. § 1105(b)(8), occurred when Greenlee neglected to report his office/directorshipp) employmeat in Greenlee Realty upon his 2016 and 2017 calendar year Statements of Financial Interests, in that he did not hold any reportable off ice/directorship/employment in Greenlee Realty during those years. The Investigative Division withdraws the allegation as to Section 1103(a) of the Public Official and Employee Ethics Act, 65 Pa.C.S. § 1103(a), concerning Respondent's vote to approve/authorize issuance of a stipend payable to him as School Board Treasurer. The Investigative Division withdraws the allegation as to Section 1104(a) of the Public Official and Employee Ethics Act, 65 Pa.C.S. § 1104(a). The Investigative Division seeks no disgorgement pursuant to Section 1104(d) of the Public Official and Employee Ethics Act, 65 Pa.C.S. § 1104(d). 4. Greenlee agrees to make payment in the amount of $1,950.00 in settlement of this matter, payable to the Bethlehem --Center School District and forwarded to the Pennsylvania State Ethics Commission within thirty (30) days of the issuance of the final adjudication in this matter. 5. Greenlee agrees to file complete and accurate amended Statements of Financial Interests with the Bethlehem -Center School District through the Pennsylvania State Ethics Commission, for calendar years 2014, 2015, 2016 and 2017 within thirty (30) days of the issuance of the final adjudication in this matter. 6. Greenlee agrees to not accept any reimbursement, compensation or other payment from the Bethlehem -Center School District 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 apppropriate enforcement actions in the event of Respondent'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. Greenlee, 19-008 aP g�T Consent Agreement, at 1-2. In considering the Consent Agreement, we agree with the parties that a violation of Section 1103(a) of the Ethics Act occurred in relation to Greenlee, as a Member of the Board, participating in discussions and actions of the Board resulting in his nomination and subsequent appointment as the Board Treasurer. Greenlee used the authority of his office as a Member of the Board when, between May 19, 2014, and May 22, 2017, he participated in four unanimous Board votes that elected him as the Board Treasurer for a one-year term. For the period of July 2015 through January 2019, Greenlee received compensation totaling $5,118.75 from the District for serving as the Board Treasurer. Based upon the Stipulated Findings and Consent Agreement, we hold that Greenlee, as a Member of the Board, violated Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), in relation to his participating in discussions and actions of the Board resulting in his nomination and subsequent appointment as the Board Treasurer. We accept the recommendation of the parties, and we hold, that a technical violation of Sections 1105(b)(1), (2), and (5) of the Ethics Act, 65 Pa.C.S. §§ 1105b)(1) (2), and (5), occurred when Greenlee filed a deficient calendar year 2015 Fl by ailing to respond to disclosure of address, governmental entity, and occupation, and by failing to list reportable income from the District. The parties have agreed, and we hold, that no violation of Section 1105(b)(8) of the Ethics Act, 65 Pa.C.S. § 1105(b)(8), occurred in relation to the allegation that Greenlee neglected to report his office/directorship/employment in Greenlee Realty upon his SFIs for calendar years 2016 and 2017, in that he did not hold any reportable office/directorship/employment in Greenlee Realty during those years. We note that the Investigative Division is not seeking any disgorgement of Greenlee's Board Treasurer compensation pursuant to Section 1104(d) of the Ethics Act, 65 Pa.C.S. § 1104(d). As part of the Consent Agreement, Greenlee has agreed to make payment in the amount of $1,950.00 payable to the Bethlehem -Center School District and forwarded to this Commission within thirty (30) days of the issuance of the final adjudication in this matter. Greenlee has agreed to not accept any reimbursement, compensation or other payment from the District representing a full or partial reimbursement of the amount paid in settlement of this matter. Additionally, to the extent he has not already done so, Greenlee has agreed to file complete and accurate amended SFIs with the District, through this Commission, for calendar years 2014, 2015, 2016, and 2017 within thirty (30) days of the issuance of the final adjudication in this matter. We agree that the aforesaid recommendations are appropriate, including the recommendation that Greenlee file complete and accurate amended SFIs for calendar years 2014, 2015, 2016, and 2017 notwithstanding: (1) the withdrawal of the Section 1104(a) allegation regarding Greenlee's SFI for calendar yyear 2014, and (2) the recommendation of the parties for a finding of no violation as to the Section 1105(b)(8) allegation regarding Greenlee's SFIs for calendar years 2016 and 2017. Acdordingly, per the Consent Agreement of the parties, Greenlee is directed to make payment in the amount of $1,950.00 payable to the Bethlehem -Center School District and forwarded to this Commission by no later than the thirtieth (30th) day after the mailing date of this adjudication and Order. Greenlee, 19-008 aPgem'— Greenlee is directed to not accept any reimbursement, compensation or other payment from the District representing a full or partial reimbursement of the amount paid in settlement of this matter. To the extent he has not already done so, Greenlee is directed to file complete and accurate amended SFIs for calendar years 2014, 2015, 2016, and 2017 with the District, through this Commission, by no later than the thirtieth (30#h) day after the mailing date of this adjudication and Order. Compliance with the foregoing will result in the closing of this case with no further action by this Commission. Noncompliance will result in the institution of an order enforcement action. IV. CONCLUSIONS OF LAW: 1. As a Member of the Board of Directors (`Board") of the Bethlehem -Center School District ("District" ), Washington County, Pennsylvania, from April 22, 2013, to the present, and as thhe Board Treasurer from December 3, 2013, until June 30, 2019, Respondent John Greenlee ("Greenlee") has been a public official subJJ'ect to the rovisions of the Public Official and Employee Ethics Act ("Ethics Act"), 65 Pa.C.S. p§ 1101 et seq. 2. Greenlee, as a Member of the Board, violated Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), in relation to his participating in discussions and actions of the Board resulting in his nomination and subsequent appointment as the Board Treasurer. 3. A technical violation of Sections 1105(b)(1), (2), and (5) of the Ethics Act, 65 Pa.C.S. §§ 1105(b))(1 , (2), and (5), occurred when Greenlee filed a deficient calendar year 2015 Statement of Financial Interests by failing to respond to disclosure of address, governmental entity, and occupation, and by failing to list reportable income from the District. 4. No violation of Section 1105(b)(8) of the Ethics Act, 65 Pa.C.S. § 1105(b)(8), occurred in relation to the alllegation that Greenlee neglected to report his officeldirectorshiplemployment in Greenlee Realty upon his Statements of Financial Interests for calendar years 2016 and 2017, in that he did not hold any reportable office/directorship/employment in Greenlee Realty during those years. In Re: John Greenlee, File Docket: 19-008 Respondent Date Decided: 6/22/20 Date Mailed: 6/24/20 ORDER NO. 1772 1. John Greenlee ("Greenlee"), as a Member of the Board of Directors ("Board") of the Bethlehem -Center School District ("District"), Washington County, Pennsylvania, violated Section 1103(a) of the Public Official and Employee Ethics Act ("Ethics Act"), 65 Pa.C.S. § 1 03(a), in relation to his participating in discussions and actions of the Board resulting in his nomination and subsequent appointment as the Board Treasurer. 2. A technical violation of Sections 1105(b)(1), (2), and (5) of the Ethics Act, 65 Pa.C.S. §§ 1105(b)(1), (2), and (5), occurre when Greenlee filed a deficient calendar year 2015 Statement of Financial Interests by failing to respond to disclosure of address, governmental entity, and occupation, and by failing to list reportable income from the District. 3. No violation of Section 1105(b}(8) of the Ethics Act, 65 Pa.C.S. § 1105(b)(8), occurred in relation to the allegation that Greenlee neglected to report is office/directorship/employment in Greenlee Realty upon his Statements of Financial Interests for calendar years 2016 and 2017, in that he did not hold any reportable officeldirectors hiplemployment in Greenlee Realty during those years. 4. Per the Consent Agreement of the parties, Greenlee is directed to make payment in the amount of $1,950.00 payable to the Bethlehem -Center School District and forwarded to the Pennsylvania State Ethics Commission by no later than the thirtieth (30th) day after the mailing date of this Order. 5. Per the Consent Agreement of the parties, Greenlee is further directed to not accept any reimbursement, compensation or other payment from the District representing a full or partial reimbursement of the amount paid in settlement of this matter. 6. To the extent he has not already done so, Greenlee is directed to file complete and accurate amended Statements of Financial Interests for calendar years 2014, 2015, 2016, and 2017 with the District, throw h the Pennsylvania State Ethics Commission, by no later than the thirtieth (30thj day after the mailing date of this Order. 7. Compliance with paragraphs 4, 5, and 6 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,