In re Roca, 151 A.3d 739

Background

Judicial Conduct Board charged Judge Angeles Roca after intercepted, recorded phone calls showed she solicited and accepted ex parte intervention from former Judge Waters to influence a case involving her son.
Respondent initially denied the allegations, then admitted involvement after FBI presented wiretap evidence; she later expressed remorse at the sanctions hearing.
The Court of Judicial Discipline found violations of former Canons 2A and 2B and Article V, §18(d)(1) (conduct prejudicing administration of justice and bringing the office into disrepute), and an automatic derivative violation of Article V, §17(b).
The court applied a multi-factor sanction analysis (adopted from In re Denting via In re Toczydlowski), considering isolation of the misconduct, use of judicial office and facilities, harm to integrity of the judiciary, lack of prior complaints, and voluntary nature of the misconduct.
The court concluded Roca’s actions were willful, exploited her position to obtain favorable treatment for a family member, and materially prejudiced the administration of justice.
Order: Judge Roca was removed from office and declared ineligible to hold judicial office in the future.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Roca violated judicial canons and Article V §18 by arranging ex parte contacts to influence her son’s case	Board: Wiretapped calls show Roca knowingly solicited and accepted unlawful ex parte intervention, violating Canons 2A/2B and Article V §18	Roca: Initially denied; after confrontation admitted and claimed she sought only advice and later expressed remorse	Held: Violations proven; conduct amounted to willful misconduct violating Canons 2A/2B and Article V §18(d)(1)
Whether the conduct prejudiced the administration of justice (mental state requirement)	Board: Roca acted with knowledge and intent to affect a specific outcome for her son	Roca: Characterized actions as family-focused, not intended to corrupt judicial process	Held: Court found the requisite mental state — she intended or knew the conduct would affect the outcome, thus prejudicing administration of justice
Whether the misconduct exploited judicial office and used official resources	Board: Calls occurred in courthouse and used government equipment; Roca used status to seek favorable treatment	Roca: Did not contest location fully but emphasized remorse and lack of prior complaints	Held: Court found she exploited her position and government resources to advance a personal interest
Appropriate sanction given violations and mitigating evidence	Board: Removal appropriate given intentional corruption and need to protect public trust	Roca: Sought mitigation via remorse, character witnesses, and long service	Held: Removal and permanent ineligibility ordered to protect integrity and public confidence in judiciary

Key Cases Cited

In re Berkhimer, 593 Pa. 366, 930 A.2d 1255 (2007) (standards of review and role of disciplinary sanctions in protecting public trust)
In re Toczydlowski, 853 A.2d 24 (Pa. Ct. Jud. Disc. 2004) (adopting Denting factors for sanction analysis)
In re Denting, 108 Wash.2d 82, 736 P.2d 639 (1987) (nonexclusive factors to consider in judicial discipline)
In re Melograne, 585 Pa. 357, 888 A.2d 753 (2005) (character evidence does not erase misconduct; disciplinary purpose explained)
In re Zupsic, 893 A.2d 875 (Pa. Ct. Jud. Disc. 2005) (fixing cases and removal precedent)
In re Cioppa, 51 A.3d 923 (Pa. Ct. Jud. Disc. 2012) (prejudice to administration of justice as serious violation)
In re Smith, 687 A.2d 1229 (Pa. Ct. Jud. Disc. 1996) (mental-state element for conduct prejudicing administration of justice)