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In Re: Susan Caughlan,
Respondent
..... .....
File Docket:
X-ref-
Date Decided
Date Mailed:
FACMILE: 717-787-0806
WEBSITE: m88L.ethLcs,12a,gp_v
19-022
Order No. 1784
3/29/21
4/1/21
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�Leq., 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 Stipulated Findings are set forth as the Findings in this
Order. The Consent Agreement has, been approved.
1. ALLEGATION:
That Susan Caugblan, a public official/public employee in her capacity as a Supervisor for
Worcester Township, Montgomery County, violated Section 1103 (a) of the State Ethics Act (Act
93 of 1998) when she participated in discussions and actions of the Township Board of Supervisors
regarding property owners' applications for designation/inclusion within the Township's
Agricultural Security Area, at a time when she was providing legal representation to the same
applicant(s) in the same matter(s) before the Township Board of Supervisors.
11. FINDINGS:
Susan Caughlan ("Ms. Caughlan") served as a Supervisor for Worcester Township
("Township"), Montgomery County, from January 2010 until October 21, 2020.
Caughlan, 19-022
Page 2
2. The Township is a Second Class Township governed by a three -Member Board of
Supervisors.
THE FOLLOWING FINDINGS RELATE TO ALLEGATIONS THAT MS. CAUGHLAN
PARTICIPATED IN DISCUSSIONS AND ACTIONS OF THE BOARD OF
SUPERVISORS REGARDING PROPERTY OWNERS' APPLICATIONS FOR
DESIGNATIONANCLUSION WITHIN THE TOWNSHIP'S AGRICULTURAL
SECURITY AREA, AT A TIME WHEN SHE WAS PROVIDING LEGAL
REPRESENTATION TO THE SAME APPLICANTS.
3. Ms. Caughlan is employed in the private practice of law.
4. The Disciplinary Board of the Supreme Court of Pennsylvania identifies Ms. Caughlan as
a person authorized to practice law in the State of Pennsylvania.
5. Ms. Caughlan's legal practice is concentrated on land preservation, including conservation
easements and estate planning.
6. The Agricultural Area Security Law (Act 43 of 1981) allows for the creation of joint
municipality agricultural security areas.
7. An Agricultural Security Area ("ASA") is a tract of agricultural land officially designated
as an "Agricultural District" by the local municipality.
a. There is no fee to join an ASA, and there is no financial, zoning, or other penalty
for the change of land use in an ASA,
b. An ASA is intended to promote permanent and viable farming operations by
strengthening the farming community's sense of security in land use and the right
to farm.
C. Creating an ASA is a collaborative effort between farmers and the local
government.
d. To establish an ASA, landowners submit a proposal to the local municipality.
1. The local governing municipality then decides whether to approve the
creation of an ASA.
2. Once established, the local municipality is responsible for reviewing the
area every seven years.
8. Prior to establishing an ASA, the following conditions must be met:
a. In order to create a new ASA, a 250 acre or more farm tract is required. The 250-
acre tract does not have be under the same ownership or even be in the same
municipality.
Cau Ig plan, 19-022
Page 3
b. Noncontiguous farm parcels must be comprised of at least 10 acres in size or have
an anticipated yearly gross income of at least $2,000.00 from agricultural
production.
C. The property must be viable agricultural land. Cropland, pasture, and woodland can
all be included in an ASA.
d. Land proposed must have soils that are conducive to agriculture. This factor will
be automatically satisfied if at least 50% of the soils are classified in Classes I -IV
or if the soil is currently in active farm use and is being maintained in accordance
with a soil erosion and sedimentation plan.
The property must be zoned to permit agricultural uses but is not required to be
zoned to exclude other uses.
£ Additional factors to be considered are the extent and nature of farm improvements,
anticipated trends in agricultural economic and technological conditions, and any
other relevant factors.
9. Enrolling a property in an ASA affords the land certain protections and is beneficial for an
active farm.
a. Farms in an ASA are protected from new ordinances which would restrict normal
farming operations or define farms as nuisances.
b. An ASA farm is also protected from any portion of the property being seized by
eminent domain through additional approvals being required prior to any
condemnation.
10. The Township has an established ASA which was last certified via approval of Resolution
2016-30 at the September 21, 2016, Board of Supervisors meeting.
11. Bethel Road Associates, LP ("Bethel Road Associates") is a Pennsylvania limited
partnership that was owned during the relevant time period by Lisa Evans, D.V.M. ("Dr.
Evans") and Michael Evans. Bethel Road Associates owned property in the Township
located at 2045 Bethel Road, Lansdale, PA (112045 Bethel Road").
12. Dr. Evans and her husband, Hansell Stedman, M.D. ("Dr. Stedman"), own property in the
Township located at 1907 Berks Road, Norristown, PA ("1907 Berks Road").
13. Dr. Evans contacted Ms. Caughlan in or around October 2016 and asked for legal
representation with regard to preserving the 1907 Berks Road and 2045 Bethel Road
properties. Ms. Caughlan agreed to assist in seeking to preserve the properties through a
private land trust.
14. After retaining Ms. Caughlan, and after Ms. Caughlan began work related to preservation
of the 2045 Bethel Road and 1907 Berks Road properties via a private land trust, Dr. Evans
Caughlan, 19-022
Page 4
also asked Ms. Caughlan to prepare an application to enroll the 2045 Bethel Road and 1907
Berks Road properties in the Township's ASA.
a. Ms. Caughlan prepared an application seeking to enroll the 2045 Bethel Road and
1907 Berks Road properties in the Township's ASA.
b. Enrollment of the parcels in the Township's ASA would neither prevent nor
facilitate the parcels being preserved via a private land trust.
Preparation of an ASA application consists of the insertion of the name of the
municipality, the total acreage of the existing ASA, the names and signatures of the
parcel owners, and the address, parcel number and acreage of the parcel proposed
for addition onto a standardized form, along with a map reflecting the location of
the parcel proposed for addition.
d. Ms. Caughlan did not use the authority of her office or any confidential information
received through holding her office when preparing the ASA application for the
2045 Bethel Road and 1907 Berks Road properties.
15. On or about January 16, 2017, an application was submitted to the Township to enroll the
properties located at 2045 Bethel Road and 1907 Berks Road in the Township's ASA.
16. At the February 15, 2017, Board of Supervisors business meeting, a motion was approved
to acknowledge the Township's receipt of the ASA application for the 2045 Bethel Road
and 1907 Berks Road properties. By unanimous vote the Board of Supervisors adopted the
motion to acknowledge receipt of the application.
a. Ms. Caughlan participated in approving the motion.
b. Ms. Caughlan did not disclose she was, as an attormey-at-law, representing the
applicants (Bethel Road Associates and Dr. Evans/Dr. Stedman) regarding
preservation of the two properties being considered for inclusion in the Township's
ASA.
17. At the Worcester Township Planning Commission ("Planning Commission") meeting held
March 23, 2017, a recommendation was made to the Board of Supervisors to approve the
addition of the 2045 Bethel Road and 1907 Berks Road properties within the Township's
ASA.
a. Ms. Caughlan did not attend this Planning Commission meeting or communicate
with any Planning Commission Members regarding the ASA application for the
2045 Bethel Road and 1907 Berks Road properties.
18. At the April 19, 2017, business meeting of the Board of Supervisors, the Supervisors by
unanimous vote adopted a motion to approve Resolution 2017-09, authorizing the addition
of the properties located at 2045 Bethel Road and 1907 Berks Road to the Township's
ASA.
Caughlan, 19-022
Page 5
a. Ms. Caughlan was present for the meeting and participated in the motion to approve
Resolution 2017-09, which was approved without public comment or discussion by
the Supervisors.
b. A short time before the meeting began, Ms. Caughlan sought verbal advice from
the Township Solicitor regarding her vote on admission of the properties into the
Township's ASA and was not advised to abstain from voting. She acknowledges,
however, that she did not allow adequate time for the Township Solicitor to receive
all operative facts, carefully consider those facts, research applicable law, and
provide her with a written opinion.
C. Neither Bethel Road Associates nor Dr. Evans/Dr. Stedman at any time requested
that Ms. Caughlan vote on the ASA application for the 2045 Bethel Road and 1907
Berks Road properties or vote in any particular manner if she did vote.
d. Ms. Caughlan did not promise or intimate at any time that she would vote on the
ASA application for the 2045 Bethel Road and 1907 Berks Road properties or vote
in any particular manner if she did vote.
C. Ms. Caughlan asserts that at the time of her vote on the ASA application for the
2045 Bethel Road and. 1907 Berks Road properties, she did not believe that
admission of the properties into the Township's ASA would result in any direct or
indirect pecuniary benefit to her clients or herself.
f. Neither Bethel Road Associates nor Dr. Evans/Dr. Stedman offered any
compensation or pecuniary benefit at any time to Ms. Caughlan in exchange for
voting on the ASA application for the 2045 Bethel Road and 1907 Berks Road
properties.
g. Ms. Caughlan did not request any compensation or pecuniary benefit at any time
for Ms. Caughlan in exchange for voting on the ASA application for the 2045
Bethel Road and 1907 Berks Road properties.
h. Ms. Caughlan did not receive any direct compensation or pecuniary benefit from
Bethel Road Associates or Dr. Evans/Dr. Stedman as a result of her vote on the
ASA application for the 2045 Bethel Road and 1907 Berks Road properties.
i. Ms. Caughlan did not receive any indirect compensation or pecuniary benefit from
Bethel Road Associates or Dr. Evans/Dr. Stedman as a result of her vote on the
ASA application for the 2045 Bethel Road and 1907 Berks Road properties, in the
form of additional legal work or otherwise.
j. While a Supervisor, Ms. Caughlan generally supported land preservation efforts
within the Township and voted to approve the addition of every parcel proposed
for inclusion in the Township's ASA that was recommended by the Planning
Commission after its consideration of the statutory criteria.
Cain, 19-022
Page 6
19. Ms. Caughlan asserts that at the time of her vote on the ASA application for the 2045 Bethel
Road and 1907 Berks Road properties, she was not aware of the Commission's opinion in
Kannebecker, Opinion 92-010, and was not otherwise aware that voting on a matter
involving a client was considered a conflict of interest in the absence of receipt of a private
pecuniary benefit by the official or client as a result of the vote or official action.
20. Ms. Caughlan participated in approving the minutes of the Township's meeting held April
19, 2017, at the Township's May 17, 2017, meeting.
a. No corrections were made by Ms. Caughlan to the meeting minutes.
21. Ms. Caughlan submitted billing statements for the legal work she performed for Bethel
Road Associates and Dr. Evans/Dr. Stedman between November 1, 2016, and March 31,
2017.
22. Payments were made to Ms. Caughlan by Dr. Evans for the legal work Ms. Caughlan
performed for Bethel Road Associates and Dr. Evans/Dr. Stedman and were deposited by
Ms. Caughlan.
23. Some of the payments to Ms. Caughlan were for the legal work Ms. Caughlan performed
during the time Dr. Evans was seeking inclusion of properties in the Township's ASA,
which Ms. Caughlan subsequently approved via Township Resolution 2017-09 as a
Supervisor.
24. After the properties at 2045 Bethel Road and 1907 Berks Road were approved for inclusion
in the Township's ASA in April 2017, Dr. Evans decided not to pursue preservation of
those properties any further.
a. Ms. Caughlan did not perform any other Iegal work for Bethel Road Associates
and/or Dr. Evans/Dr. Stedman, and did not submit any billing statements to Bethel
Road Associates and/or Dr. Evans/Dr. Stedman, other than the billing statements
referenced above for work performed between November 1, 2016, and March 31,
2017.
III. DISCUSSION:
As a Supervisor for Worcester Township ("Township"), Montgomery County,
Pennsylvania, from. January 2010 until October 21, 2020, Respondent Susan Caughlan, also
referred to herein as "Respondent," "Respondent Caughlan," and "Caughlan," was 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 allegation is that Caughlan violated Section 1103(a) of the Ethics Act when she
participated in discussions and actions of the Township Board of Supervisors ("Board of
Supervisors") regarding property owners' applications for designation/inclusion within the
Caughlan, 19-022
Page 7
Township's Agricultural Security Area, at a time when she was providing legal representation to
the same applicant(s) in the same matter(s) before the Board of Supervisors.
Pursuant to Section 1103(a) of the Ethics Act, a public off cial/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 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.
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
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.
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 Township is a Second Class Township. The Board of Supervisors consists of three
Members. Caughlan served as a Township Supervisor from January 2010 until October 21, 2020.
Caughlan, 19-022
Page 8
Caughlan is an attorney licensed to practice law in Pennsylvania. Caughlan's legal practice
is concentrated on land preservation.
The Agricultural Area Security Law (Act 43 of 1981) allows for the establishment of
agricultural security areas ("ASAs") by municipalities. An ASA is a tract of agricultural land
officially designated as an "Agricultural District" by the local municipality. An ASA is intended
to promote permanent and viable farming operations by strengthening the farming community's
sense of security in land use and the right to farm. Creating an ASA is a collaborative effort
between farmers and the local municipality. Landowners interested in the creation of an ASA
submit a proposal to the local municipality, which then decides whether to approve the
establishment of an ASA.
Enrolling a property in an ASA affords the property certain protections and is beneficial
for an active farm. A farm in an ASA is protected from new ordinances that would restrict normal
farming operations or define farms as nuisances. A farm in an ASA also receives additional
protection from eminent domain proceedings. There is no fee to enroll a property in an ASA. The
Township has an ASA.
Bethel Road Associates, LP ("Bethel Road Associates") is a Pennsylvania limited
partnership that was owned during the relevant time period by Lisa Evans, D.V.M. ("Dr. Evans")
and Michael Evans. Bethel Road Associates owned property in the Township located at 2045
Bethel Road, Lansdale, PA ("2045 Bethel Road"). Dr. Evans and her husband, Hansell Stedman,
M.D. ("Dr. Stedman"), own property in the Township located at 1907 Berks Road, Norristown,
PA ("1907 Berks Road").
In or around October 2016, Dr. Evans contacted Caughlan and asked her for legal
representation with regard to preserving the 2045 Bethel Road and 1907 Berks Road properties.
Caughlan agreed to assist in seeking to preserve the properties through a private land trust.
After Caughlan began work related to preserving the 2045 Bethel Road and 1907 Berks
Road properties via a private land trust, Dr. Evans asked Caughlan to prepare an application to
enroll the 2045 Bethel Road and 1907 Berks Road properties in the Township's ASA. Enrollment
of the properties in the Township's ASA would neither prevent nor facilitate the preservation of
the properties via a private land trust.
Caughlan subsequently prepared an ASA application seeking to enroll the 2045 Bethel
Road and 1907 Berks Road properties in the Township's ASA. An ASA application is prepared
by completing a standardized form with the name of the municipality, the total acreage of the
existing ASA, the names and signatures of the parcel owners, and the address, parcel number, and
acreage of each parcel proposed for addition. Caughlan did not use the authority of her office or
any confidential information received through holding her office when she prepared the ASA
application for the 2045 Bethel Road and 1907 Berks Road properties.
On or about January 16, 2017, an ASA application to enroll the 2045 Bethel Road and 1907
Berks Road properties in the Township's ASA was submitted to the Township. On February 15,
2017, Caughlan participated in a unanimous vote of the Board of Supervisors that acknowledged
receipt of the ASA application. Caughlan did not disclose that in her capacity as an attorney, she
Caughlan, 19-022
Page 9
was representing the applicants —specifically, Bethel Road Associates and Dr. Evans/Dr.
Stedman —with regard to the preservation of the 2045 Bethel Road and 1907 Berks Road
properties.
At the Worcester Township Planning Commission meeting held on March 23, 2017, a
recommendation was made to the Board of Supervisors to approve adding the 2045 Bethel Road
and 1907 Berks Road properties to the Township's ASA. On April 19, 2017, Caughlan
participated in a unanimous vote of the Board of Supervisors that approved Resolution 2017-09,
which authorized adding the 2045 Bethel Road and 1907 Berks Road properties to the Township's
ASA.
Neither Bethel Road Associates nor Dr. Evans/Dr. Stedman requested that Caughlan vote
on the ASA application for the 2045 Bethel Road and 1907 Berks Road properties, and Caughlan
did not promise or intimate at any time that she would vote on the ASA application. Caughlan was
not offered, and she did not request, any compensation or pecuniary benefit in exchange for voting
on the ASA application. The parties have stipulated that Caughlan did not receive any direct or
indirect compensation or pecuniary benefit from Bethel Road Associates or Dr. Evans/Dr.
Stedman as a result of voting on the ASA application.
After the 2045 Bethel Road and 1907 Berks Road properties were approved for inclusion
in the Township's ASA, Dr. Evans decided not to further pursue preservation of those properties.
Dr. Evans made payments to Caughlan for legal work that she performed for Bethel Road
Associates and Dr. Evans/Dr. Stedman between November 1, 2016, and March 31, 2017. Caughlan
did not perform any other legal work for Bethel Road Associates or Dr. Evans/Dr. Stedman.
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:
3. The Investigative Division will recommend the following in relation
to the above allegations:
a. That a technical violation of Section 1103(a) of the
Public Official and Employee Ethics Act, 65 Pa.C.S.
§ 1103(a), occurred in relation to Susan Caughlan, as
a Supervisor for Worcester Township, Montgomery
County, participating in discussions and actions of
the Board of Supervisors regarding property owners'
application for designation inclusion within the
Township's Agricultural Security Area, at a time
when she was providing legal representation to the
same applicant(s).
Caughlan, 19-022
Page 10
4. Ms. Caughlan agrees to make payment in the amount of $1,000.00
in settlement of this matter payable as follows:
a. $800.00 payable to the Commonwealth of
Pennsylvania and forwarded to the Pennsylvania
State Ethics Commission within thirty (30) days of
the issuance of the final adjudication in this matter.
b. $200.00 which represents a portion of the expenses
and costs incurred by the State Ethics Commission in
the investigation and administrative prosecution of
the instant matter, payable by certified check or
money order made payable to the Pennsylvania State
Ethics Commission within thirty (30) days of the
issuance of the final adjudication in this matter.
5. Ms. Caughlan agrees to not accept any reimbursement,
compensation or other payment from the Worcester Township,
Montgomery County representing a full or partial reimbursement of
the amount paid in settlement of this matter.
6. 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 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.
Consent Agreement, at 1-2.
We accept the recommendation of the parties for a finding that a technical violation of
Section 1103(a) of the Ethics Act occurred in relation to Caughlan, as a Township Supervisor,
participating in discussions and actions of the Board of Supervisors regarding an application by
property owners for inclusion within the Township's ASA, at a time when she was providing legal
representation to the same applicants.
In or around October 2016, Caughlan, in her private capacity as an attorney, began
providing legal representation to the owners of the 2045 Bethel Road and 1907 Berks Road
properties with regard to preserving the properties. Caughlan subsequently prepared an application
to enroll the 2045 Bethel Road and 1907 Berks Road properties in the Township's ASA. Enrolling
a property in an ASA protects a farm from new ordinances that would restrict normal farming
operations or define farms as nuisances. A farm in an ASA also receives additional protection
from eminent domain proceedings.
Cau hg lan, 19-022
Page 11
Caughlan used the authority of her office as a Township Supervisor when, on April 19,
2017, she participated in a unanimous vote of the Board of Supervisors that approved Resolution
2017-09, which authorized adding the 2045 Bethel Road and 1907 Berks Road properties to the
Township's ASA. Although the Stipulated Findings do not quantify the private pecuniary benefit
realized by the property owners as a result of Caughlan's participation in the approval of their
application to enroll the 2045 Bethel Road and 1907 Berks Road properties in the Township's
ASA, in light of the Consent Agreement, it would appear that the parties are in agreement that
such private pecuniary benefit was not de minimis.
Based upon the above, we hold that Caughlan, as a Township Supervisor, technically
violated Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), in relation to her participating in
discussions and actions of the Board of Supervisors regarding an application by property owners
for inclusion within the Township's ASA, at a time when she was providing legal representation
to the same applicants.
As part of the Consent Agreement, Caughlan has agreed to make payment in the amount
of $800.00 payable to the Commonwealth of Pennsylvania and forwarded to this Commission
within thirty (30) days of the issuance of the final adjudication in this matter.
Caughlan has further agreed to make payment to this Commission in the amount of
$200.00, representing a portion of the expenses and costs incurred by this Commission in the
investigation and administrative prosecution of the instant matter, payable by certified check or
money order made payable to the Pennsylvania State Ethics Commission within thirty (30) days
of the issuance of the final adjudication in this matter.
Caughlan has also 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 for this case, based upon our review as reflected in the above analysis and the totality
of the facts and circumstances.
Accordingly, per the Consent Agreement of the parties, Caughlan is directed to make
payment in the amount of $800.00 payable to the Commonwealth of Pennsylvania and forwarded
to this Commission by no later than the thirtieth (30th) day after the mailing date of this adjudication
and Order.
Per the Consent Agreement of the parties, Caughlan is further directed to make payment to
this Commission in the amount of $200.00, representing a portion of the expenses and costs
incurred by this Commission in the investigation and administrative prosecution of the instant
matter, payable by certified check or money order made payable to the Pennsylvania State Ethics
Commission by no later than the thirtieth (30th) day after the mailing date of this adjudication and
Order.
Caughlan is directed 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.
Caughlan, 19-022
Page 12
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:
As a Supervisor for Worcester Township ("Township"), Montgomery County,
Pennsylvania, from January 2010 until October 21, 2020, Respondent Susan Caughlan
("Caughlan") was a public official subject to the provisions of the Public Official and
Employee Ethics Act ("Ethics Act"), 65 Pa.C.S. § 1101 et seq.
2. Caughlan, as a Township Supervisor, technically violated Section 1103(a) of the Ethics
Act, 65 Pa.C.S. § 1103(a), in relation to her participating in discussions and actions of the
Township Board of Supervisors regarding an application by property owners for inclusion
within the Township's Agricultural Security Area, at a time when she was providing legal
representation to the same applicants.
In Re: Susan Caughlan, File Docket: 19-022
Respondent Date Decided: 3/29/21
Date Mailed: 411121
ORDER NO. 1784
Susan Caughlan ("Caughlan"), as a Supervisor for Worcester Township ("Township"),
Montgomery County, Pennsylvania, technically violated Section 1103(a) of the Public
Official and Employee Ethics Act, 65 Pa.C.S. § 1103(a), in relation to her participating in
discussions and actions of the Township Board of Supervisors regarding an application by
property owners for inclusion within the Township's Agricultural Security Area, at a time
when she was providing legal representation to the same applicants.
2. Per the Consent Agreement of the parties, Caughlan is directed to make payment in the
amount of $800.00 payable to the Commonwealth of Pennsylvania and forwarded to the
Pennsylvania State Ethics Commission by no later than the thirtieth (30`h) day after the
mailing date of this Order.
M
5.
Per the Consent Agreement of the parties, Caughlan is further directed to make payment to
the Pennsylvania State Ethics Commission in the amount of $200.00, representing a portion
of the expenses and costs incurred by this Commission in the investigation and
administrative prosecution of the instant matter, payable by certified check or money order
made payable to the Pennsylvania State Ethics Commission by no later than the thirtieth
(301h) day after the mailing date of this Order.
Caughlan is directed 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.
Compliance with paragraphs 2, 3, and 4 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,
G�J
Nicholas A. Colafella, hair