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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
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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
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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
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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
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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
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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
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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
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[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,