BEFORE THE

STATE OF FLORIDA

COMMISSION ON ETHICS

 

 

 

In re RON D. BAKER,     )

                        )                            Complaint No. 97-103

     Respondent.        )                            DOAH Case No. 99-3250FE

                        )

                        )                            Final Order No. 00-054

________________________)

 

 

 

ORDER DENYING PETITION FOR COSTS AND ATTORNEY FEES

 

This matter came before the State of Florida Commission on Ethics, meeting in public session on Friday, November 17, 2000, pursuant to the Recommended Order of the Division of Administrative Hearings' Administrative Law Judge rendered in this matter on June 29, 2000 [a copy of which is attached and incorporated by reference].  The Administrative Law Judge (“ALJ”) recommends that the Commission enter a final order and public report finding that the Respondent [in this fee petition proceeding], JAMES E. CHANDLER, is not liable for attorney's fees and costs and dismissing the Petition for Attorney's fees.

 

BACKGROUND


This matter began with the filing of a complaint on July 1, 1997, and an amended complaint on January 28, 1998 by James A. Chandler, as Indian River County Administrator, alleging that the Petitioner, RON D. BAKER, as Personnel Director of Indian River County, violated various provisions of the Code of Ethics for Public Officers and Employees (Part III, Chapter 112, Florida Statutes).  The Executive Director of the Commission on Ethics determined that, based on the information provided in the complaint and amended complaint, the allegations were sufficient to warrant a preliminary investigation under Sections 112.313(2), (4), (6), (7)(a), and 112.3148(4), Florida Statutes.  Commission staff undertook a preliminary investigation of these matters to aid in the Commission's determination of probable cause.  The findings of the investigation were summarized in a Report of Investigation (ROI) issued on March 8, 1999.  On June 3, 1999, after considering the ROI and the Commission Advocate's Recommendation, and after hearing from the Advocate and the Petitioner, the Commission found that no probable cause existed to believe that the Petitioner violated Sections 112.313(2), (4), (6), (7)(a), and 112.3148(4), as alleged.  Thereafter, Petitioner timely filed a Petition for Attorney's Fees and Costs.

The matter was forwarded by the Commission on Ethics to the Division of Administrative Hearings for assignment of an ALJ to conduct the final hearing and prepare a recommended order.  A formal evidentiary hearing was held before the ALJ on December 6, 1999 and February 22 and 23, 2000.  A transcript of the hearing was filed and the parties then filed proposed recommended orders with the ALJ.  The ALJ”s Recommended Order was transmitted to the Commission and to the parties on June 29, 2000, and the parties were notified of their right to file exceptions to the Recommended Order with the Commission within 15 days from the date that the Recommended Order was rendered (by July 14, 2000).  Thereafter,  both Petitioner and the Respondent timely filed  exceptions to the ALJ’s Recommended Order.  The Respondent also filed a “Response to Petitioner Baker’s Exceptions to Recommended Order” (“Respondent’s Response”).

 

STANDARDS FOR REVIEW


Under Section 120.57(1)(l), Florida Statutes, an agency may reject or modify the conclusions of law and interpretations of administrative rules contained in the recommended order.  However, the agency may not reject or modify findings of fact made by the ALJ unless a review of the entire record demonstrates that the findings were not based on competent, substantial evidence or that the proceedings on which the findings were based did not comply with the essential requirements of law.  See, e.g., Freeze v. Dept. of Business Regulation, 556 So. 2d 1204 (Fla. 5th DCA 1990); and Florida Department of Corrections v. Bradley, 510 So. 2d 1122 (Fla. 1st DCA 1987).  Competent, substantial evidence has been defined by the Florida Supreme Court as such evidence as is "sufficiently relevant and material that a reasonable mind would accept it as adequate to support the conclusions reached."  DeGroot v. Sheffield, 95 So. 2d 912, 916 (Fla. 1957).

The agency may not reweigh the evidence, resolve conflicts therein, or judge the credibility of witnesses, because those are matters within the sole province of the hearing officer.  Heifetz v. Dept. of Business Regulation, 475 So. 2d 1277, 1281 (Fla. 1st DCA 1985).  Consequently, if the record of the DOAH proceedings discloses any competent, substantial evidence to support a finding of fact made by the ALJ, the Commission is bound by that finding.

Under the Section 120.57(1)(l), Florida Statutes, an agency may reject or modify the conclusions of law over which it has substantive jurisdiction and interpretations of administrative rules over which it has substantive jurisdiction.  When rejecting or modifying such conclusion of law or interpretation of administrative rule the agency must state with particularity its reasons for rejecting or modifying such conclusion of law or interpretation of administrative rule and must make a finding that its substituted conclusion of law or interpretation of administrative rule is as or more reasonable than that which was rejected or modified.


Having reviewed the Recommended Order and listened to the arguments of the parties, the Commission makes the following findings, conclusions, rulings and recommendations.

 

RULINGS ON PETITIONER'S EXCEPTIONS TO THE

ALJ’S FINDINGS OF FACT

 

1.  The Petitioner excepts to paragraph 35 of the ALJ's Recommended Order which he claims demonstrates her misunderstanding of the law and her apparent "prejudicial bias" towards him.  The ALJ notes that Petitioner's case focused mainly on his assertion that the alleged violations in Respondent's complaint against him were not proven.  She finds that that issue has already been determined by the Ethics Commission, as indicated by its dismissal of his complaint and amended complaint.  She then distinguishes that issue from the issue in this case, which she correctly notes is whether the Respondent filed the complaint and amended complaint with a malicious intent to injure the reputation of Petitioner by filing the complaint and amended complaint with knowledge that they contained one or more false allegations, or with reckless disregard for whether they contained false allegations of fact material to a violation of the Ethics Code.

Petitioner's exception is rejected.  We do not find that the ALJ demonstrated any bias or prejudice towards the Petitioner in these proceedings, nor do we find that she mischaracterizes Petitioner's arguments or the issue in this case.

 


2.  Petitioner next excepts to the ALJ's finding of fact No. 36 wherein she finds that, rather than filing his complaint and amended complaint against the Petitioner in order to injure his reputation, he filed the complaint in order to carry out the responsibilities of his job as appointed County Administrator.  She found that, as County Administrator, the Respondent could not reasonably nor justifiably ignore the serious allegations of impropriety made against Petitioner merely because Petitioner denied or disputed the allegations.

As noted above, and as stated by the court in Heifetz v. Department of Business Regulation, Division of Alcoholic Beverages & Tobacco, 475 So. 2d 1277, 1281 (Fla. 1st DCA 1985):

 

It is the hearing officer’s function to consider all the evidence presented, resolve conflicts, judge credibility of witnesses, draw permissible inferences from the evidence, and reach ultimate findings of fact based on competent substantial evidence.  State Beverage Department v. Ernal, Inc., 115 So. 2d 566 (Fla. 3d DCA 1959).  If, as is often the case, the evidence presented supports two inconsistent findings, it is the hearing officer’s role to decide the issue one way or the other.

 

The ALJ properly fulfilled her function here.  It is not our function to reweigh the evidence or attempt to draw different inferences from the evidence as long as there is competent substantial evidence to support the ALJ’s findings, as there is here.  We also are not free to reevaluate the quantity and quality of the evidence beyond determining whether the evidence is competent and substantial.  Because there is competent substantial evidence of record to support the ALJ’s finding, Petitioner's exception is rejected.


Moreover, contrary to Petitioner's argument[1] that, before he filed his complaint with the Commission on Ethics, Respondent had a duty to read the statutes that he was claiming that Petitioner violated in order to determine whether the information available to him was sufficient to prove each element of the statutes allegedly violated by the Petitioner, Rule 34-5.002(1), F.A.C., specifically states

 

Complaints need not be as precise as would be required by the rules of civil procedure in a court of law and shall be deemed sufficient if the complainant under oath upon knowledge or belief alleges matters which, if true, may constitute a breach of the public trust.  A complaint shall not be insufficient because it is based upon evidence which would be hearsay evidence in a court of law.   .   .   . [E.S.]

 

 

Nor did Respondent have a duty, as Petitioner claims, to investigate in order to determine whether the actions he was accusing the Petitioner of violating were in fact true.  The duty that the Respondent had with respect to the filing of his complaint is set forth in Section 112.317(8), Florida Statutes, that is, not to file a complaint with a malicious intent to injure Petitioner’s reputation by filing the complaint with knowledge that it contained one or more false allegations or with reckless disregard for whether the complaint contained false allegations of fact material to Part III of Chapter 112, Florida Statutes.

 


3.  Petitioner excepts to the ALJ’s Finding of Fact No. 37 wherein she finds that  the allegations in Respondent’s complaint and amended complaint were based upon sworn testimony, interviews, and documents obtained during investigations by trained investigators and confirmed by documentary evidence and sworn testimony presented at official proceedings.  He argues that many of the allegations were not based on sworn testimony, interviews or documents which were before the Respondent when he filed his complaint.  Petitioner also argues that the recommendations that the Commission Advocate made to the Commission and the Commission’s findings of no probable cause indicate that Respondent’s allegations did not satisfy all of the elements required by the Code of Ethics statutes alleged to have been violated by the Petitioner.

Because there is competent substantial evidence of record to support the ALJ’s finding, as noted in Respondent’s Response at p. 6, and for the reasons stated in paragraph 2 above, Petitioner’s exception is rejected. 

Moreover, Petitioner has not excepted to the ALJ’s finding that Detective Beckerdite conducted interviews, took sworn statements and obtained documents supporting the allegations [Finding of Fact No. 12].  Nor did he except to her finding that Investigator Von Buelow took sworn statements and/or interviewed several individuals and reviewed documents which appeared to substantiate the claims or allegations made in the complaint and amended complaint [Finding of Fact No. 22].  He also did not except to the ALJ’s  finding that Respondent’s complaint included a copy of Detective Beckerdite’s report and the attachments thereto [Finding of Fact No. 17] and that the allegations of the amended complaint were based on the “testimony or statements of individuals given during the pre-determination or post-determination hearing, depositions, or Investigator Von Buelow’s investigation and on documents received during the aforementioned proceedings or investigations.” [Finding of Fact No. 31].  Therefore, Petitioner, in effect, conceded that these findings are supported by substantial competent evidence of record.  The ALJ’s finding here is nothing more than her making an ultimate finding of fact based on the competent substantial evidence of record and on her prior findings of fact.  Inasmuch as the ALJ fulfilled her function of weighing the evidence, judging the credibility of witnesses, and drawing permissible inferences from the evidence, Respondent’s exception must be rejected.

 


4.  Petitioner excepts to the ALJ’s Finding of Fact No. 38 wherein she finds that, although Petitioner denied Respondent’s allegation concerning James Carraway, who had an ownership interest in a company providing contractual services to the County, providing Petitioner’s daughter with an airline ticket to travel from Colorado to Florida, the allegation was based on Jon Peterson’s sworn statement to Detective Beckerdite.  Petitioner argues that there was no evidence that James Carraway provided Petitioner’s adult daughter with airline tickets, as the ALJ finds, and that the allegations, if true, would not constitute violations of the Code of Ethics, since all of the elements of the statutes alleged to have been violated were not “satisfied.”

Apart from Petitioner’s misreading of the ALJ’s finding,[2] which warrants our rejection of his argument that there was no evidence that James Carraway provided Petitioner’s daughter with an airline ticket, we find that there is competent substantial evidence of record, as noted at p. 6 of the Respondent’s Response,  to support the ALJ’s finding.  We also find that the proceedings on which the findings are based complied with the essential requirements of law.  Therefore, Petitioner’s exception is rejected.

 


5.  Petitioner excepts to the ALJ’s Finding of Fact No. 39 relative to the allegation in Respondent’s complaint concerning Petitioner’s daughter’s receipt of an airline ticket from James Carraway and, specifically, her finding that Catherine Wendt, James Carraway’s secretary, advised the Commission on Ethics’ investigator under oath that she had arranged a trip for Petitioner’s daughter using Mr. Carraway’s frequent flyer miles, and that this fact was significant when viewed together with Respondent’s allegation that Petitioner may have violated the Code of Ethics because the provision of the airline ticket to Petitioner’s daughter allegedly occurred at or near the time that Respondent had contacted Jon Peterson to request that he submit a bid for the Indian River County drug screening contract.  The ALJ found that it also was significant because Mr. Peterson was a partner with James Carraway in Brevard Drug Screening which was awarded the contract.  The ALJ found that Peterson’s allegation regarding the airline ticket, which was included in Respondent’s complaint was not false.

Because we find that the ALJ’s finding is supported by competent substantial evidence of record, as noted in Respondent’s Response at p. 6, and because we find that the proceedings on which the ALJ’s findings are based complied with the essential requirements of law, Petitioner’s exception is rejected.

 


6.  Petitioner next excepts to the ALJ’s Finding of Fact No. 40 wherein she finds that with respect to Respondent’s allegation concerning Petitioner’s use of a cabin, chalet or condominium owned by James Carraway and located in North Carolina, Jon Peterson gave a sworn  statement to Detective Beckerdite and testified at the pre-determination hearing that arrangements had been made for Petitioner to use the Carraway cabin or chalet.  While noting that Petitioner denied the allegation, the ALJ found that evidence existed to support the allegation.  Such evidence was Commission on Ethics Investigator Reaves’ determination that Mr. Carraway, in fact, owned a cabin, chalet, or condominium in North Carolina that was available for use by friends and associates, and that a request was made for Petitioner to use it.  Petitioner argues that the ALJ’s “incredibly naive and legally erroneous” conclusion of law which “assumes that just because James Carraway sometimes let people use his cabin and that someone may have requested the cabin for Baker that, ipso facto, this was evidence that Baker did, in fact use Carraway’s cabin.  He argues that the finding that Petitioner actually used Mr. Carraway’s cabin is not supported by competent substantial evidence and does not comply with the essential requirements of law.

We reject Petitioner’s exception.  First, we note that findings of fact form the basis for conclusions of law, not vice versa.  Next we note that Petitioner again misreads the ALJ’s finding.  The ALJ does not find that Petitioner, in fact, used James Carraway’s cabin; rather, she finds that there was evidence to support the Respondent’s allegation. Finally, we find that there is competent substantial evidence of record, as noted at p. 6 of Respondent’s Response, to support the ALJ’s finding of fact, and that the proceedings upon which the ALJ’s findings are based complied with the essential requirements of law.

 

7.     Finding of Fact No. 41 also is excepted to by the petitioner.  There, the ALJ found that evidence existed to support the allegation in Respondent’s complaint relative to Petitioner’s allegedly receiving stock car race tickets from James Carraway.  The ALJ found that such evidence included Jon Peterson’s giving sworn statements to Detective Beckerdite, his testifying under oath that he had received stock car race tickets from James Carraway and had given the tickets to the Petitioner, and James Carraway’s admitting to the Commission on Ethics Investigator that he had given stock car race tickets to Mr. Peterson and that such tickets may have been given to the Petitioner.  


Again, we note that the Petitioner misreads the ALJ’s finding here.  Inasmuch as there is competent substantial evidence of record to support the ALJ’s finding, as noted in Respondent’s Response at p. 6, Petitioner’s exception is rejected.  Although throughout his exceptions, as in this exception, Petitioner continuously claims that the ALJ’s findings of fact, do not comply with the essential requirements of law, he neglects to indicate how the proceedings upon which the findings are based fail to comply with the “essential requirements of law.”  Because we  find that the proceedings upon which the ALJ’s findings of fact are based do comply with the “essential requirements of law,” we reject this claim as well.

 

8.  Petitioner excepts to the ALJ’s Findings of Fact Nos. 42 and 43 which relate to the allegations in Respondent’s complaint concerning the hiring of Petitioner’s son by James and Zander Carraway and Jon Peterson.  The ALJ finds that, notwithstanding Petitioner’s statement that he gave to Detective Beckerdite indicating that he had asked James Carraway to “help” his son “get on his feet” and denying that he ever asked Jon Peterson to hire his son, the statements of Colleen and Jon Peterson and the documents that they also gave to Detective Beckerdite provide some support for the allegation.


For the reasons stated in paragraph 2 above, Respondent’s exception is rejected.  We find that competent substantial evidence of record, as noted in Respondent’s Response at p. 6, existed to support the ALJ’s finding, and the proceedings on which the ALJ’s findings of fact are based complied with the essential requirements of law.  In addition, we find that Petitioner’s reliance of CEO 85-35 is misplaced.  In CEO 85-35, we found that no conflict of interest existed under Section 112.313(3), Florida Statutes, where the sons of a Director of the Division of Purchasing, Department of General Services (now Department of Management Services), were employed as salesmen by corporations doing business with the Division and other State agencies because his sons were employees rather than officers or owners of the corporations.  This opinion was not based on the same or a similar set of facts or circumstances as alleged in this complaint nor did it discuss Sections 112.313(2), (4), (6), and 112.3148(4), Florida Statutes, the provisions of the Code of Ethics that were alleged to have been violated by the Petitioner.

 

9.  Petitioner excepts to the ALJ’s Finding of Fact No. 44 which relates to the allegation in Respondent’s complaint concerning “Petitioner’s potential involvement in a joint venture with James Carraway, owner of a County vendor, and his son, Zander Carraway, and Dr. Leo Bradman.  Petitioner argues that the ALJ’s findings are not supported by competent substantial evidence and do not comply with the essential requirements of law, and the evidence to support each and every element of the Ethics Code provisions which the Respondent claimed that Petitioner violated did not exist.

For the reasons stated in paragraph 2 above, and because we find both that there exists substantial competent evidence of record, as noted in Respondent’s Response at p. 7, to support the ALJ’s findings, and the proceedings upon which the ALJ’s findings are based complied with the essential requirements of the law, Petitioner’s exception is rejected.

 


10.  Petitioner excepts to the ALJ’s Findings of Fact No. 45 which relate to the allegation in Respondent’s amended complaint about Petitioner’s admission in a deposition taken in a civil action that while serving as Personnel Director for Indian River County, he negotiated for the purchase of the EAP business from James Carraway. The ALJ found that evidence existed to support the allegation.  However, Petitioner argues that the ALJ’s findings are a “gross mischaracterization of the facts, are not supported by competent substantial evidence, and do not comply with the essential requirements of the law.

For the reasons stated in paragraph 2 above, and because we find that there exists substantial competent evidence of record, as noted in Respondent’s Response at page 7, to support the ALJ’s findings, and that the proceedings upon which the ALJ’s findings are based complied with the essential requirements of law, Petitioner’s exception is rejected.

 

11.  Petitioner excepts to the ALJ’s Findings of Fact Nos. 46 and 47 relating to the allegation in Respondent’s complaint that Petitioner co-signed a credit card application with Colleen Peterson, who is Petitioner’s subordinate, the County’s personnel administrator and the wife of Jon Peterson, owner of Brevard Drug Screening, an Indian River County vendor.  The ALJ found that the allegation was based on sworn statements made by Colleen Peterson as well as documents provided by the Petersons to Investigator Von Buelow.  However, Petitioner again argues that Respondent failed to allege facts sufficient to prove each element of the statute that he was alleging that Petitioner had violated.  He claims that because the Respondent knew that no evidence existed to prove that by applying for a credit card with Colleen Peterson, Petitioner violated a provision of  the Ethics Code, Respondent must have maliciously included this “false” allegation to injure Petitioner’s reputation.

For the reasons stated in paragraph 2 above, and because we find both that there exists  substantial competent evidence of record, as noted in Respondent’s Response at p. 7, to support the ALJ’s findings, and that the proceedings on which the ALJ’s findings are based complied with the essential requirements of law, Petitioner’s exception is rejected.


12.  Petitioner excepts to the ALJ’s Findings of Fact Nos. 48, 49 and 50 which relate to the circumstances surrounding Petitioner’s hiring of Colleen Peterson as Personnel Assistant.  The ALJ found that the allegations were based on statements made by Colleen Peterson and documents provided to Investigator Von Buelow during his investigation, and that a comparative review of Ms. Peterson’s resume with her actual experience, as well as a review of the applications of the other applicants for the same position, indicated that she may not have met the advertised job requirements, education, or experience as a grievance adjuster, which some of the other applicants possessed.  Consequently, the ALJ found that evidence existed to support this allegation in Respondent’s complaint.

In addition to asking where the ALJ was when testimony and evidence was presented during the hearing which “proved that the changes that Colleen Peterson made to her resume were not untrue,”  Petitioner claims that because the Respondent knew that the allegation that he was making was not being made “in good faith,” that it was a “maliciously false claim” intended to injure Petitioner’s reputation, and that he did nothing wrong in hiring Colleen Peterson, the ALJ’s finding was not supported by competent substantial evidence, and does not comply with the essential requirements of law.

For the reasons stated in paragraph 2 above, and because we find both that there exists substantial competent evidence of record, as noted in Respondent’s Response at p. 7, to support the ALJ’s findings, and that the proceedings on which the ALJ’s findings are based complied with the essential requirements of law, Petitioner’s exception is rejected.

 


13.  Petitioner excepts to the ALJ’s Findings of Fact Nos. 51, 52 and 53 which relate to the allegation in Respondent’s amended complaint concerning Petitioner’s directing an Indian River County employee with a substance abuse problem to an in-patient treatment program at Heritage Hospital which was owned by James Carraway or in which Mr. Carraway held a financial interest.  After discussing the circumstances surrounding the referral, Mr. Carraway’s interest in the Hospital, and the significance of the referral to the alleged Ethics Code violation, the ALJ found that because the allegation was based on statements that Jon Peterson had made to Investigator Von Buelow and on the deposition testimony of Dr. Leo Bradman, evidence existed to support the allegation.  However, Petitioner argues that it was Jon Peterson, rather than he, who sent the employee to the Heritage Hospital, and, if the Respondent had asked the employee, he would have known that Mr. Peterson’s statement was not credible.  Petitioner argues further that, even if he had referred the employee to Heritage Hospital, this fact alone would not support a charge that he had violated the Ethics Code and that the Respondent knew that his allegation did not constitute a violation of the Ethics Code when he made it.

    It is not our function to reweigh the evidence or to rewrite the ALJ’s finding as long as there is competent substantial evidence to support the finding, as there is here. (See Respondent’s Response at p. 8)  Here, it appears that the ALJ fulfilled her function of resolving conflicts, judging the credibility of witnesses, drawing permissible inferences from the evidence, and reaching ultimate findings of fact based on competent substantial evidence.  Therefore, Petitioner’s exception is rejected.

 


14.  Petitioner excepts to the ALJ’s Finding of Fact No. 54 which concerned allegations in Respondent’s amended complaint concerning Petitioner’s allegedly requesting that Jon Peterson and the Carraways, both County vendors, make certain payments to Petitioner or Petitioner’s relatives.  Specifically, an allegation was made that payment was made by Brevard Drug Screening to Petitioner for construction work he did on a bathroom at the Brevard Drug Screening Office and of medical expenses incurred by Petitioner’s wife.  The ALJ found that the allegations were based on statements that Jon Peterson had made to Investigator Von Beulow and on “substantiating” documents that the Petersons provided, both of which were included in or along with Von Beulow’s investigative report.  The ALJ also found that, notwithstanding the later determination that the alleged payments were not improperly made, at the time that the amended complaint was prepared and filed by the Respondent, evidence existed which supported the allegations.

In addition to summarily claiming that the ALJ’s finding was not supported by competent substantial evidence and did not comply with the essential requirements of law, Petitioner argues that because the Respondent did not personally investigate to determine whether the allegations that Peterson made to Investigator Von Beulow were “credible and trustworthy,” as was his duty, Respondent acted with malice.

For the reasons stated in paragraph 2 above, and because we find both that there exists substantial competent evidence of record, as noted in Respondent’s Response at p. 8, to support the ALJ’s findings, and that the proceedings on which the ALJ’s findings are based complied with the essential requirements of law, Petitioner’s exception is rejected.

 


15.  Petitioner excepts to the ALJ’s Finding of Fact No. 55 which he mistakenly labels as No. 54.  There, the ALJ finds that, because the allegation concerning the Carraways advancing Petitioner’s son the sum of $2,000 was based on statements made by Jon Peterson during the Von Buelow investigation and during the August 1997 pre-determination hearing, evidence existed to support the allegation.

For the reasons stated in paragraph 2 and 8 above, and because there exists substantial competent evidence of record, as noted in Respondent’s Response at pp. 8 and 9, to support the ALJ’s findings, and the proceedings on which the ALJ’s findings are based complied with the essential requirements of the law, Petitioner’s exception is rejected.

 

16.  Petitioner excepts to the ALJ’s Finding of Fact No. 56 which relates to the allegation in Respondent’s amended complaint concerning Jon Peterson’s allegedly paying Petitioner’s cellular telephone bill.  The ALJ found that this allegation was supported by the testimony of Colleen Peterson, by Jon Peterson’s testimony at the August 13, 1997 predetermination hearing, and by a copy of a canceled check given by the Peterson’s to Detective Beckerdite.  The ALJ found further that, notwithstanding Petitioner’s testimony explaining the reason for the payment, at the time that Respondent “completed” his amended complaint, evidence existed to support the allegations.

Petitioner argues that, apart from the allegation being false and malicious, there was no evidence to support it and Respondent knew that he had no evidence to prove all of the necessary elements required for a violation of the statute that he claimed that the Petitioner had violated to exist.  Therefore, the ALJ’s finding was not supported by competent substantial evidence and does not comply with the essential requirements of law, Petitioner asserts.


For the reasons stated in paragraph 2 above, and because we find both that there exists substantial competent evidence of record, as noted in Respondent’s Response p. 8, to support the ALJ’s findings, and the proceedings on which the ALJ’s findings are based complied with the essential requirements of the law, Petitioner’s exception is rejected.

 

17.  Petitioner excepts to the ALJ’s Finding of Fact No. 57 wherein she found that the allegation in Respondent’s amended complaint concerning Petitioner’s directing Colleen Peterson, a County employee, to prepare personal letters for him during business hours using County equipment was based on Colleen Peterson’s statements to Investigator Von Beulow and on supporting documentary evidence.  Therefore, she found that evidence existed to support the allegation at the time that Respondent filed his amended complaint.  However, Petitioner argues to the contrary by claiming that no evidence existed to support either Respondent’s allegation or the elements of the Ethics Code provisions that Respondent was “falsely and maliciously” accusing Petitioner of violating.  Petitioner asserts that if Colleen Peterson typed letters while she was on duty at her job with Indian River County indicates, she may have violated the Ethics Code -- not the Petitioner.

For the reasons stated in paragraph 2 above, and because we find both that substantial competent evidence of record, as noted in Respondent’s Response at p. 9, existed to support the ALJ’s findings, and the proceedings on which the ALJ’s findings are based complied with the essential requirements of law, Petitioner’s exception is rejected.

 


18.  Petitioner excepts to the ALJ’s Findings of Fact Nos. 58 and 59 regarding the allegation in Respondent’s amended complaint pertaining to Petitioner’s alleged use of the research resources of the County Attorney’s office to obtain information and materials for his son for a project unrelated to County business.  Notwithstanding the fact that the allegations could not be substantiated and/or did not constitute violations of the Code of Ethics, the ALJ found that their inclusion in the allegations was reasonably based on information that the Respondent had obtained from reliable sources, including the Beckerdite and Von Beulow’s investigative reports, the records of the predetermination and the post-determination hearings, and depositions from other legal proceedings.  Nevertheless, Petitioner argues that the ALJ’s findings of fact are not supported by competent substantial evidence and do not comply with the essential requirements of law.

For the reasons stated in paragraph 2 above, and because we find both that competent substantial evidence of record, as noted in Respondent’s Response at pp. 9 and 10, existed to support the ALJ’s findings, and the proceedings on which the ALJ’s findings are based complied with the essential requirements of the law, Petitioner’s exception is rejected.

 


19.  In her Finding of  Fact No. 60, the ALJ finds that Petitioner’s Attorney’s regular hourly rate is $225.  She also finds that trial time is billed by the Attorney at $450 per hour and his travel time is billed at half of his regular hourly rate or $112.50 an hour.   Next, in her Finding of Fact No. 61, the ALJ finds that for the period July 9, 1997, when Petitioner’s Attorney was retained, through March 23, 2000, when Petitioner’s proposed recommended order was filed with the ALJ, Petitioner’s Attorney expended 233.70 hours working on his case.  Consequently, she finds that Petitioner has incurred total attorney’s fees and costs of $55,576.25 and $10,296.83, respectively.  The ALJ concludes that these fees and costs are reasonable.  However, the Petitioner argues that the ALJ “ignored, misapprehended, and overlooked, or failed to consider that the contract between the Petitioner and his attorney” contemplated that the Attorney’s rates were minimum fees and that the price for services would be adjusted upward based on a number of factors or a multiplier applied  based on a number of factors when billing or claiming against third parties.  He also excepts to the ALJ’s failure to consider his costs and attorney’s fees for work performed after the conclusion of the DOAH evidentiary hearing, including this proceeding.

Because there is competent substantial evidence of record to support the ALJ’s failure to adjust Petitioner’s Attorney’s fee upward or to include a multiplier when considering the amount of reasonable Attorney’s fees, Petitioner’s exception to this part of the ALJ’s finding is rejected.   However, we grant Petitioner’s exception regarding the ALJ’s failure to include a reasonable amount of costs and attorney’s fees for work performed after the conclusion of the DOAH evidentiary hearing, including this proceeding.  Nevertheless, because we agree with the ALJ’s finding and conclusion that the Petitioner is not entitled to an award of attorney’s fees and costs from the Respondent, we decline to remand this matter back to the DOAH for further findings.

 

20.  Petitioner excepts to the ALJ’s Finding of Fact No. 62 in which she makes an ultimate finding based on her prior findings.  She finds that the Respondent did not file his complaint and amended complaint with a malicious intent to injure the reputation of Petitioner by filing his complaints with knowledge that the complaints contained one or more false allegation[s] or with reckless disregard for whether the complaints contained false allegations of fact material to a violation of the Ethics Code.  Therefore, she concludes that the Petitioner is not entitled to an award of attorney’s fees and costs from the Respondent.


However, Petitioner disputes this finding and claims that proof of Respondent’s malice towards him is his [Petitioner’s] testimony regarding the occurrence of eleven actions that the Respondent allegedly took against him. All of this, Petitioner claims, indicates that the ALJ “overlooked or misapprehended and misconstrued the controlling law,” and “misconceived, misconstrued, misapprehended, mistakenly ignored or for some reason failed to recall” and apply to law to the evidence that Petitioner presented during the seven hour hearing in December 1999 and the 13 hour hearing in February 2000.  Petitioner asserts that the ALJ’s findings and conclusions are contrary to the law and contrary to the “manifest weight of the evidence,” are not “based on credible, competent and admissible evidence,” and “constitute an about of her discretion.”

It is not our function to reweigh the evidence or to rewrite the ALJ’s finding as long as there is competent substantial evidence to support the finding, as there is here. Here, it appears that the ALJ fulfilled her function of resolving conflicts, judging the credibility of witnesses, drawing permissible inferences from the evidence, and reaching ultimate findings of fact based on competent substantial evidence.  For these reasons, as well as the reasons stated by the Respondent in his Response at pp. 10 and 11, Petitioner’s exception is rejected.

 

RULINGS ON PETITIONER’S EXCEPTIONS TO THE

ALJ’S CONCLUSIONS OF LAW

 

21.  Petitioner excepts to paragraph No. 70 of the ALJ’s Conclusions of Law wherein she finds

Petitioner has failed to establish that the complaint was filed against him with a malicious intent to injure his reputation by filing the complaint with knowledge that the complaint contained one or more false allegations or with reckless disregard for whether the complaint contained false allegations of fact material to a violation of the Code of Ethics.  Thus, Petitioner is not entitled to an award of attorney’s fees and costs.

 


As the Court reiterated in Goin v. Commission on Ethics, 658 So 2d 1131 (Fla. 1st DCA 1995), and initially held in Langston v. Jamerson, 653 So. 2d 489 (Fla. 1st DCA 1995), the question of whether the facts, as found in the recommended order, constitute a violation of a rule or statute, is a question of ultimate fact which the agency may not reject without adequate explanation.  Inasmuch as the ALJ’s conclusion flows from the facts found and inasmuch as they are supported by competent substantial evidence in the record, Petitioner’s exception is rejected.

 

RULINGS ON RESPONDENT’S EXCEPTIONS TO

ALJ’S FINDINGS OF FACT

 

 

22.  Respondent also excepts to the ALJ’s Finding of Fact No. 61 wherein she finds that Petitioner’s attorney’s fees and costs of $55,576.25 and $10,296.83, respectively are reasonable.  He disputes the reasonableness of the fees as being excessive and the costs as including amounts that are not taxable.  However, he also writes that should the Commission accept the ALJ’s recommended order as proposed, then his exceptions may be overruled as moot.

Because we agree with the ALJ’s finding and conclusion that the Petitioner is not entitled to an award of attorney’s fees and costs, we find that Respondent’s exception is moot and decline to rule on it at this time.

 

FINDINGS OF FACT

Accordingly, the Findings of Fact set forth in the Recommended Order are approved, adopted, and incorporated herein by reference.

 

CONCLUSIONS OF LAW


1.  The Conclusions of Law set forth in the Recommended Order also are approved, adopted, and incorporated herein by reference; and

2.  The Petition for attorney’s fees and costs filed by Petitioner RON D. BAKER is hereby denied.

 

   ORDERED by the State of Florida Commission on Ethics meeting in public session on November 17, 2000.

                      

____________________________

Date Rendered

 

 

_______________________________

Howard Marks

Chair


 

 

THIS ORDER CONSTITUTES FINAL AGENCY ACTION. ANY PARTY WHO IS ADVERSELY AFFECTED BY THIS ORDER HAS THE RIGHT TO SEEK JUDICIAL REVIEW UNDER SECTION 120.68, FLORIDA STATUTES, BY FILING A NOTICE OF ADMINISTRATIVE APPEAL PURSUANT TO RULE 9.110 FLORIDA RULES OF APPELLATE PROCEDURE, WITH THE CLERK OF THE COMMISSION ON ETHICS, 2822 REMINGTON GREEN CIRCLE, SUITE 101, P.O. DRAWER 15709, TALLAHASSEE, FLORIDA 32317-5709; AND BY FILING A COPY OF THE NOTICE OF APPEAL ATTACHED TO WHICH IS A CONFORMED COPY OF THE ORDER DESIGNATED IN THE NOTICE OF APPEAL ACCOMPANIED BY THE APPLICABLE FILING FEES WITH THE APPROPRIATE DISTRICT COURT OF APPEAL. THE NOTICE OF ADMINISTRATIVE APPEAL MUST BE FILED WITHIN 30 DAYS OF THE DATE THIS ORDER IS RENDERED.

 

 

 

cc:  Mr. Jack B. Nichols, Attorney for Petitioner

     Mr. George B. Roberts, Jr., Attorney for Respondent

The Honorable Carolyn S. Holifield, Administrative Law Judge

Division of Administrative Hearings

 



[1]No specific authority is cited by the Petitioner to support his argument.

[2]The ALJ found that the allegation was based on Jon Peterson’s sworn statement to Detective Beckerdite that James Carraway had given an airline ticket to Petitioner’s daughter, rather than on the actual giving of the ticket to Petitioner’s daughter by James Carraway.