Opinion
1 JD 21
01-31-2023
IN RE: Sonya M. McKnight Magisterial District Judge Magisterial District Court 12-2-04 Dauphin County
BEFORE: Honorable Ronald S. Marsico, P.J., Honorable Daniel D. McCaffery, J., Honorable Daniel E. Baranoski, J., Honorable Jill E. Rangos, J., Honorable Thomas E. Flaherty, J., Honorable Sonya M. Tilghman, J., Honorable Charles L. Becker, J., Honorable James J. Eisenhower, P.J.E.
OPINION AND ORDER
PER CURIAM.
Magisterial District Judge Sonya McKnight is before this Court for the determination of the appropriate sanction for her violations found in our Opinion and Order of September 8, 2022. In that Opinion and Order this Court found violations in Magisterial District Judge McKnight's actions mainly for her interactions with the Harrisburg Police concerning the arrest of her son.
Factors Considered in Determining Sanction
In determining what sanction will be imposed for an ethical violation this Court is guided by the jurisprudence of our Supreme Court, and also by its own prior decisions. Pennsylvania has adopted ten non-exclusive factors, sometimes called "Deming factors" from the original Washington State case where they were exposited. In re Roca, 151 A.3d 739, 741 (Pa.Ct.Jud.Disc. 2016), aff'd, 173 A.3d 1176 (Pa. 2017), citing In re Toczydlowski, 853 A.2d 20 (Pa.Ct.Jud.Disc 2004); In re Deming, 736 P.2d 639 (Wa. 1987). The ten factors and their application to this case are as follows:
1. Whether the misconduct is an isolated instance or evidenced a pattern of conduct: The misconduct in this case is the only incident at issue.
2. The nature, extent, and frequency of occurrence of the acts of misconduct: The misconduct by Magisterial District Judge McKnight involved improper contact with the Harrisburg Police to advance her interests and a failure to properly notify the Supreme Court that she was under investigation in accordance with Rule 1921 of the Pennsylvania Rules of Judicial Administration.
3. Whether the conduct occurred in or out of the courtroom: The conduct occurred outside of the courtroom.
4. Whether the misconduct occurred in the judge's official capacity: The misconduct at issue here was committed by Magisterial District Judge McKnight in her misusing her influence as a judicial officer.
5. Whether the judge acknowledged or recognized that the acts occurred: Magisterial District Judge McKnight has acknowledged her improper conduct.
6. Whether the Judge has evidenced an effort to change or modify the conduct: Magisterial District Judge McKnight has voiced contrition over her misconduct.
7. The length of service on the bench: Magisterial District Judge McKnight has been on the bench for eight years.
8. Whether there have been prior complaints about the judge: There have not been prior misconduct cases brought against Magisterial District Judge McKnight, but she had been informally sanctioned for violating Rule 1921 of the Pennsylvania Rules of Judicial Administration before.
9. The effect the misconduct has upon the integrity of and respect for the judiciary: Magisterial District Judge McKnight's misconduct eroded respect for the judiciary.
10. The extent to which the judge exploited his or her position to satisfy personal desires: Magisterial District Judge McKnight's misconduct was committed to advance her own interests or that of her family.
Discussion
Magisterial District Judge McKnight's misconduct was reviewed at length in this Court's Opinion and Order of September 13, 2022.
We repeat that her misconduct is inexcusable. Any action by a judge which might interfere with the justice system, even if that was not her goal, is forbidden.
Magisterial District Judge McKnight was suspended without pay from February 9, 2021, until August 18, 2021, a period of 190 days. As her sanction, the Court of Judicial Discipline ORDERS that Magisterial District Judge McKnight is suspended without pay for 200 days with credit given to her for the 190 days she has already served. The ten remaining days Magisterial District Judge McKnight is to be suspended without pay will commence on February 9, 2023. Additionally, Magisterial District Judge McKnight will serve one year on probation starting on the date of this ORDER. A specific condition of this probation is that Magisterial District Judge McKnight not commit any more ethical violations of any nature.
Although his term has expired, Former President Judge Eisenhower participates in this Opinion and Order pursuant to Article V, §18(b)(2) of the Constitution of Pennsylvania.