61 A.3d 402
Ct. Jud. Disc. Pa2012Background
- Board filed a complaint against former Philadelphia Traffic Court Judge Singletary for alleged Rule 4C and constitutional violations.
- Stipulations of Fact 1-55 were accepted; events involved December 19-21, 2011 at Impoundment Court and cashier area.
- F, PWRT employee, and Respondent exchanged and viewed photographs on F’s phone during off-court moments.
- Respondent showed F photos, including two erect-penis images, and later additional photographs; some interactions suggested romantic interest.
- Respondent resigned February 27, 2012; Court later issued sanctions leading to removal from office on December 13, 2012.
- The Board sought sanctions under Article V, §18(d)(1) after finding conduct brought the judiciary into disrepute.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Rule 4C violation examined | Board contends Rule 4C violated during non-adjudicative conduct. | Singletary argues no adjudicative conduct occurred; no Rule 4C breach. | No Rule 4C violation established. |
| Constitutional violation for disrepute (17(b)) | Board argues automatic violation via Rule 4C breach. | Singletary asserts no Rule 4C violation, so no §17(b) violation. | No §17(b) violation established. |
| Disrepute under Article V, §18(d)(1) | Board contends the conduct brings judicial office into disrepute. | Singletary disputes the disrepute finding; argues limited or accidental conduct. | Conduct brought the judicial office into disrepute; sanctions warranted. |
Key Cases Cited
- In re Cicchetti, 697 A.2d 297 (Pa.Ct.Jud.Disc.1997) (disrepute analysis and non-adjudicative conduct considerations)
- In re Joyce and Terrick, 712 A.2d 834 (Pa.Ct.Jud.Disc.1998) (automatic derivative §17(b) analysis when Rule 4C violated)
- In re Zoller, 792 A.2d 34 (Pa.Ct.Jud.Disc.2001) (one-time on-bench misconduct; adjudicative context)
- In re Marraccini, 908 A.2d 377 (Pa.Ct.Jud.Disc.2006) (non-adjudicative misconduct; distinction from daily office conduct)
- In re Berkhimer, 877 A.2d 579 (Pa.Ct.Jud.Disc.2005) (extensive, routine misconduct; conduct in office)
- In re Brown, 907 A.2d 684 (Pa.Ct.Jud.Disc.2006) (ongoing office conduct; demeaning language and conduct)