In re Cioppa, 2012 WL 3029657

Board filed a complaint against Magisterial District Judge Ross Cioppa for uninvited sexual contact with two female litigants and he was indicted on bribery, official oppression, and indecent assault counts.
Respondent pleaded guilty to two misdemeanors on April 12, 2012; the felony bribery charges were withdrawn; sentence imposed.
Respondent admitted all factual allegations in his Answer dated May 14, 2012.
Board charged violations of Rule 2A and Article V, §§ 17(b) and 18(d)(1) of the Pennsylvania Constitution.
Respondent served as judge from 1999 until resignation in December 2011; he resigned effective December 9, 2011.
Record includes detailed Presentment facts: two victims were alone with Respondent in court; he engaged in coercive sexual conduct, attempted to coerce, and threatened disbelief due to his status; Victim 1 was photographed; Victim 2 was similarly subjected to inappropriate advances.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Cioppa violate Rule 2A?	Board says conduct violated Rule 2A’s integrity standard.	Cioppa admitted facts; no substantive defense to violation.	Yes, Rule 2A violated.
Did violation of Rule 2A automatically violate Article V, §17(b)?	Rule 2A violation triggers §17(b) derivative violation.	Not disputed; Board's derivation standard applies.	Yes, derivative violation under §17(b).
Did Respondent’s conduct prejudice the proper administration of justice?	Conduct intended to affect outcomes for sexual quid pro quo.	Admission of facts negates any prejudice claim.	Yes, prejudiced administration of justice.
Did Respondent’s conduct bring the judicial office into disrepute?	Extreme, tawdry coercive conduct damages public confidence.	Not contested; no separate defense offered.	Yes, conduct brought the office into disrepute.

In re Cicchetti, 697 A.2d 297 (Pa.Ct.Jud.Disc.1997) (canon 2 / integrity and impartiality standard; harassment not actionable in earlier context)
In re Cicchetti, 560 Pa. 183 (2000) (Supreme Court affirmed that Cicchetti analysis limits Canon 2's reach to decision-making context)
In re Joyce and Terrick, 712 A.2d 834 (Pa.Ct.Jud.Disc.1998) (derivative §17(b) violation based on canon violations by judges)
In re Smith, 687 A.2d 1229 (Pa.Ct.Jud.Disc.1996) (disrepute standard tied to public expectations of judicial conduct)
In re Zupsic, 893 A.2d 875 (Pa.Ct.Jud.Disc.2005) (prejudice to administration of justice requires intent to affect outcome)
In re Berry, 979 A.2d 991 (Pa.Ct.Jud.Disc.2009) (extremity standard for disrepute)
In re Berkhimer, 828 A.2d 19 (Pa.Ct.Jud.Disc.2003) (relevance to impartiality and integrity standards)