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In Re: Quimon Broady,
Respondent
STATE ETHICS COMMISSION
FINANCE BUILDING
613 NORTH s,rREET, ROOM 309
HARRISBURG, PA 17120-0400
File Docket:
X-ref.
Date Decided:
Date Mailed:
FACSIMILE: 717-787-0806
WEBSITE: www.ethics.pa.gov
22-005-P
Order No. 728-5
6/28/22
6/29/22
Before: Mark R. Corrigan, Acting Chair
Roger Nick
Melanie DePalma
Michael A. Schwartz
Shelley Y. Simms
Rhonda Hill Wilson
Paul Parsells
This is a final adjudication of the Pennsylvania State Ethics Commission as to the alleged
delinquency and/or deficiency of Statement(s) of Financial Interests required to be filed pursuant
to Sections 1104 and 1105 of the Public Official and Employee Ethics Act ("Ethics Act"), 65
Pa.C.S. § 1101 et�j�q.
The Investigative Division initiated these proceedings by filing with the State Ethics
Commission and serving upon Respondent a Petition for Civil Penalties, An Order to Show Cause
was issued to Respondent. An Answer was not filed by the Respondent,, and a hearing was deemed
waived. The record is complete. The Findings in this Order are derived from the Petition for Civil
Penalties filed by the Investigative Division.
1. FINDINGS:
Respondent is an adult individual who resides or maintains a mailing address at [address
redacted].
2. At all times relevant to these proceedings, Respondent has been a Member of the
Pennsylvania Commission on Crime and Delinquency, Juvenile Justice and Delinquency
Prevention Committee, and as such, Respondent has at all times relevant to these
proceedings been a "public official" as defined in Section 1102 of the Ethics Act, 65
Pa.C.S. § 1102.
3. Respondent as a public official is subject to, the Statement of Financial Interests filing
provisions of the Ethics Act.
4. Respondent has failed to provide full financial disclosure as required by the Ethics Act.
Respondent has failed to file Statements of Financial Interests for calendar years 2019 and
2020, which Statements of Financial Interests were to be filed by May 1 of 2020 and May
Broady,22-005-P
Page 2
1 of 2021, respectively. Respondent has therefore transgressed Sections 1104 and 1105 of
the Ethics Act, 65 Pa.C.S. §§ 1104, 1105.
5. By Notice letter dated July 16, 2021, Respondent was served with Notice in accordance
with Section 1107(5) of the Ethics Act of the specific allegations against Respondent
concerning the above transgressions. Said Notice letter provided Respondent an
opportunity to avoid the institution of these civil penalty proceedings by filing accurate and
complete Statements of Financial Interests for calendar years 2019 and 2020 within twenty
(20) days of the date of the Notice letter. Respondent has failed and refused to file complete
Statements of Financial Interests for calendar years 2019 and 2020 so as to comply with
the specific requirements of the Ethics Act,
6. By Notice letter dated December 9, 2021, Respondent was served with Notice in
accordance with Section 1107(5) of the Ethics Act of the specific allegations against
Respondent concerning the above transgressions. Said Notice letter provided Respondent
an opportunity to avoid the institution of these civil penalty proceedings by filing accurate
and complete Statements of Financial Interests for calendar years 2019 and 2020 within
twenty (20) days of the date of the Notice letter. Respondent has failed and refused to file
Statements of Financial Interests for calendar years 2019 and 2020 so as to comply with
the specific requirements of the Ethics Act.
7. Section 1109(f) of the Ethics Act provides:
§ 1109. Penalties
(1) Civil penalty. --In addition to any other civil remedy
or criminal penalty provided for in this chapter, the
commission may, after notice has been served in accordance
with section 1107(5) (relating to powers and duties of
commission) and upon a majority vote of its members, levy
a civil penalty upon any person subject to this chapter who
fails to file a statement of financial interests in a timely
manner or who files a deficient statement of financial
interests, at a rate of not more than $25 for each day such
statement remains delinquent or deficient. The maximum
penalty payable under this paragraph is $250.
65 Pa.C.S. § 1109(f).
8. For each violation the Commission finds, Respondent is subject to civil penalty liability
under Section 1109(f) of the Ethics Act, 65 Pa.C.S. § 1109(f), at a rate of not more than
$25.00 per day for each day the Statement of Financial Interests remains delinquent or
deficient, for a maximum civil penalty of $250.00 per violation. Because Respondent has
committed two violations alleged herein, Respondent is subject to total maximum civil
penalty liability of $500,00.
Broadv,22-005-P
Page 3
9. There are no mitigating circumstances and Respondent should be assessed the maximum
civil penalty of $500.00, in that the twenty -day deadline set forth in the said final Notice
letter to Respondent has expired and the Respondent has not complied.
II. DISCUSSION:
As a Member of the Pennsylvania Commission on Crime and Delinquency, Juvenile Justice
and Delinquency Prevention Committee, Quimon Broady ("Broady") was at all times relevant to
these proceedings a "public official" subject to the provisions of the Public Official and Employee
Ethics Act ("Ethics Act"), 65 Pa.C.S. § 1101 et seq.
Pursuant to Section I I04(a) of the Ethics Act, Broady was specifically required to file
Statements of Financial Interests for calendar years 2019 and 2020 with the State Ethics
Commission and the Pennsylvania Commission on Crime and Delinquency, Juvenile Justice and
Delinquency Prevention Committee, on or before May 1, 2020 and May 1, 2021, respectively.
Section I I04(a) provides:
§ 1104. Statement of financial interests required to be filed
(a) Public official or public employee. --Each public official of the
Commonwealth shall file a statement of financial interests for the preceding
calendar year with the commission no later than May I of each year that he holds
such a position and of the year after he leaves such a position. Each public
employee and public official of the Commonwealth shall file a statement of
financial interests for the preceding calendar year with the department, agency,
body or bureau in which he is employed or to which he is appointed or elected no
later than May 1 of each year that he holds such a position and of the year after he
leaves such a position. Any other public employee or public official shall file a
statement of financial interests with the governing authority of the political
subdivision by which he is employed or within which he is appointed or elected no
later than May 1 of each year that he holds such a position and of the year after he
leaves such a position. Persons who are full-time or part-time solicitors for political
subdivisions are required to file under this section.
65 Pa.C.S. § 1104(a).
The complete financial disclosure which Broady as a Member of the Pennsylvania
Commission on Crime and Delinquency, Juvenile Justice and Delinquency Prevention Committee
was required to provide in the Statement of Financial Interests form is statutorily mandated in
detail at Section 1105 of the Ethics Act, 65 Pa.C.S. § 1105.
Section 1109(f) of the Ethics Act provides as follows:
§ 1109. Penalties
(f) Civil penalty.-- In addition to any other civil remedy or criminal penalty
Broad ,22-005-P
Pa
provided for in this chapter, the commission may, after notice has been served in
accordance with section 1107(5) (relating to powers and duties of commission)
and upon a majority vote of its members, levy a civil penalty upon any person
subject to this chapter who fails to file a statement of financial interests in a timely
manner or who files a deficient statement of financial interests, at a rate of not more
than $25 for each day such statement remains delinquent or deficient. The
maximum penalty payable under this paragraph is $250.
65 Pa.C.S. § 1109(f).
An application of Section 1109(f) to this case establishes that this Commission has the
discretion to levy a maximum civil penalty against Broady for each delinquent Statement of
Financial Interests for calendar years 2019 and 2020.
The prerequisite service of a Notice letter in accordance with Section 1107(5) was satisfied.
Broady did not remedy the failure to comply with the Ethics Act although given more than the
usual grace period following Notice in which to do so. The Investigative Division then instituted
formal proceedings against Broady by filing with the State Ethics Commission and serving upon
Broady a Petition for Civil Penalties. The Commission Chair issued an Order to Show Cause,
ordering Broady to show cause why civil penalties should not be levied against him. Broady did
not file an answer to the Order to Show Cause. There is nothing of record that would constitute a
defense or excuse for Broady's failure to comply with the Ethics Act. Broady has failed to show
cause why civil penalties should not be levied against him in this matter.
We find that Broady, as a Member of the Pennsylvania Commission on Crime and
Delinquency, Juvenile Justice and Delinquency Prevention Committee, failed to comply with
Section 1104(a) of the Ethics Act, 65 Pa.C.S. § 1104(a), when he failed to file Statements of
Financial Interests for calendar years 2019 and 2020 with the State Ethics Commission and the
Pennsylvania Commission on Crime and Delinquency, Juvenile Justice and Delinquency
Prevention Committee.
We hereby levy two maximum civil penalties against Broady, each at the rate of Twenty -
Five Dollars ($25.00) per day, for each day his Statements of Financial Interests for calendar years
2019 and 2020 have remained delinquent. Given the number of days during which the Statements
of Financial Interests have remained delinquent, the resultant amount to be levied against Broady
is Five Hundred Dollars ($500.00).
Broady shall be ordered to make payment of the above civil penalties in the total amount
of $500.00 by no later than the thirtieth (301h) day after the mailing date of this adjudication and
Order, by forwarding a check to this Commission made payable to the Commonwealth of
Pennsylvania, for deposit in the State Treasury.
Broady shall be ordered to file complete and accurate Statements of Financial Interests for
calendar years 2019 and 2020 with the State Ethics Commission and the Pennsylvania Commission
on Crime and Delinquency, Juvenile Justice and Delinquency Prevention Committee, by no later
than the thirtieth (301h) day after the mailing date of this adjudication and Order.
Broady,22-005-P
Page 5
III. CONCLUSIONS OF LAW:
Quimon Broady (`Broady"), as a Member of the Pennsylvania Commission on Crime and
Delinquency, Juvenile Justice and Delinquency Prevention Committee, was at all times
relevant to these proceedings 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. Broady, as a Member of the Pennsylvania Commission on Crime and Delinquency,
Juvenile Justice and Delinquency Prevention Committee, failed to comply with Section
1104(a) of the Ethics Act, 65 Pa.C.S. § 1104(a), when he failed to file Statements of
Financial Interests for calendar years 2019 and 2020 with the State Ethics Commission and
the Pennsylvania Commission on Crime and Delinquency, Juvenile Justice and
Delinquency Prevention Committee.
3. Notice of the delinquency of Broady's Statements of Financial Interests for calendar years
2019 and 2020 was previously served upon him in accordance with Section 1107(5) of the
Ethics Act, 65 Pa.C.S. § 1107(5),
4. Based upon the totality of the circumstances in this case, the imposition of two maximum
civil penalties in the total amount of $500.00 is warranted.
In Re: Quimon Broady, File Docket: 22-005-P
Respondent Date Decided: 6/28/22
Date Mailed: 6/29/22
ORDER NO. 728-S
Quimon Broady ("Broady"), as a Member of the Pennsylvania Commission on Crime and
Delinquency, Juvenile Justice and Delinquency Prevention Committee, failed to comply
with Section 1104(a) of the Public Official and Employee Ethics Act ("Ethics Act"), 65
Pa.C.S. § 1104(a), when he failed to file Statements of Financial Interests for calendar years
2019 and 2020 with the State Ethics Commission and the Pennsylvania Commission on
Crime and Delinquency, Juvenile Justice and Delinquency Prevention Committee.
2. This Commission hereby levies two maximum civil penalties against Broady, each at the
rate of Twenty -Five Dollars ($25.00) per day, for each day his Statements of Financial
Interests for calendar years 2019 and 2020 have remained delinquent, for total civil penalty
liability of Five Hundred Dollars ($500.00). Broady is ordered to pay said civil penalties
in the total amount of $500.00 by no later than the thirtieth (301h) day after the mailing date
of this Order, by forwarding a check to the Pennsylvania State Ethics Commission made
payable to the Commonwealth of Pennsylvania, for deposit in the State Treasury.
Broady is ordered to file complete and accurate Statements of Financial Interests for
calendar years 2019 and 2020 with the State Ethics Commission and the Pennsylvania
Commission on Crime and Delinquency, Juvenile Justice and Delinquency Prevention
Committee, by no later than the thirtieth (301h) day after the mailing date of this Order.
4. Failure to comply with Paragraph 2 or 3 of this Order will result in the initiation of an
appropriate enforcement action.
BY THE COMMISSION,
k R. Corfigan, Acting Chair