HomeMy WebLinkAbout07-569ADVICE OF COUNSEL
August 14, 2007
07 -569
This responds to your letter of June 28, 2007, and your faxed transmissions
received July 13, 2007, and July 17, 2007, by which you requested confidential advice
from the State Ethics Commission.
Issue: Whether the Public Official and Employee Ethics Act ( "Ethics Act "), 65
Pa. .S. § 1101 et seq., would present any prohibitions or restrictions upon employment
of an A following termination of service with a B of a Governmental Body C.
Facts: As an A to Public Official D, a B of Governmental Body C of Political
S ubdivision E, you request an advisory from the State Ethics Commission regarding the
post - employment restrictions of Section 1103(g) of the Ethics Act.
You have submitted copies of your current job description and an organizational
chart for the F of Public Official D, which documents are incorporated herein by
reference. You state that your responsibilities as an A include:
[list of duties].
In your current position, you serve at the discretion of Public Official D, who
appointed you to your position. You state that you do not oversee any employee /staff
member. You note that you have filed a Statement of Financial Interests for calendar
year 2006.
You are considering leaving your public position to become a partner in a private
company, G ( "the Company "). The Company provides public and government relations
consulting services to [type of businesses], among others. You state that the
Company's goal is to [quote]. The Company's services include coordinating meetings
with appointed and elected government officials to discuss and solve problems,
connecting clients with community leaders, determining necessary permits, and
assisting in media and public relations. The Company's clients include [list of types of
entities] and Governmental Body C.
Noting that you are not an attorney, you pose the following questions:
(1) Whether, in your current position, you would be considered a public official or
public employee subject to the Ethics Act, such that upon leaving your current
position to join the Company as a partner, you would become subject to the
prohibitions of Section 1103(g) of the Ethics Act;
Confidential Advice, 07 -569
August 14, 2007
Page 2
(2) To the extent Section 1103(g) of the Ethics Act would apply to you, whether the
governmental body with which you would be deemed to have been associated
would be limited to Governmental Body C or would also include the
administrative /executive agencies of Political Subdivision E, such as the H or the
I; and
To the extent Section 1103(g) of the Ethics Act would apply to you, whether you
would be limited in representing a client before: (a) Governmental Body C; or (b)
an agency of Political Subdivision E, such as the H, the I, or the J.
You state that Sections [cites] of the H create a clear separation between the
legislative branch and the administrative and executive branch of Political Subdivision E
government. You contend that under Section [cite] of the H, your appointing power is
Governmental Body C.
It is administratively noted that the aforesaid Sections of the H provide in
pertinent part as follows:
[Quote and Cite].
[Quote and Cite].
[Quote and Cite].
Discussion: It is initially noted that pursuant to Sections 1107(10) and 1107(11) of
the Ethics Act, 65 Pa.C.S. §§ 1107(10), (11), advisories are issued to the requester
based upon the facts that the requester has submitted. In issuing the advisory based
upon the facts that the requester has submitted, the Commission does not engage in an
independent investigation of the facts, nor does it speculate as to facts that have not
been submitted. It is the burden of the requester to truthfully disclose all of the material
facts relevant to the inquiry. 65 Pa.C.S. §§ 1107(10), (11). An advisory only affords a
defense to the extent the requester has truthfully disclosed all of the material facts.
As an A to Public Official D, you are a public official /public employee subject to
the provisions of the Ethics Act. This conclusion is based upon the submitted fact that
you were appointed to your position by Public Official D and upon the job description,
which when reviewed on an objective basis, indicates clearly that the power exists to
take or recommend official action of a non - ministerial nature with respect to one or more
of the following: contracting; procurement; planning; inspecting; administering or
monitoring grants; leasing; regulating; auditing; or other activities where the economic
impact is greater than de minimis on the interests of another person.
If you would terminate employment in your aforesaid public position to become a
partner in the Company, you would become a "former public official /public employee"
subject to Section 1103(g) of the Ethics Act.
While Section 1103(g) does not prohibit a former public official /public employee
from accepting a position of employment, it does restrict the former public official /public
employee with regard to "representing" a "person" before the governmental body with
which he has been associated ":
(3)
§ 1103. Restricted activities
(g) Former official or employee. - -No former public
official or public employee shall represent a person, with
promised or actual compensation, on any matter before the
Confidential Advice, 07 -569
August 14, 2007
Page 3
governmental body with which he has been associated for
one year after he leaves that body.
65 Pa.C.S. § 1103(g) (Emphasis added).
The terms "represent," "person," and "governmental body with which a public
official or public employee is or has been associated" are specifically defined in the
Ethics Act as follows:
§ 1102. Definitions
"Represent." To act on behalf of any other person in
any activity which includes, but is not limited to, the
following: personal appearances, negotiations, lobbying and
submitting bid or contract proposals which are signed by or
contain the name of a former public official or public
employee.
"Person." A business, governmental body,
individual, corporation, union, association, firm, partnership,
committee, club or other organization or group of persons.
"Governmental body with which a public official
or public employee is or has been associated." The
governmental body within State government or a political
subdivision by which the public official or employee is or has
been employed or to which the public official or employee is
or has been appointed or elected and subdivisions and
offices within that governmental body.
65 Pa.C.S. § 1102.
The term "person" is very broadly defined. It includes, inter alia, corporations and
other businesses. It also includes the former public employee himself, Confidential
Opinion, 93 -005, as well as a new governmental employer. Ledebur, Opinion 95 -007.
The term "representation" is also broadly defined to prohibit acting on behalf of
any person in any activity. Examples of prohibited representation include: (1) personal
appearances before the former governmental body or bodies; (2) attempts to influence;
(3) submission of bid or contract proposals which are signed by or contain the name of
the former public official /public employee; (4) participating in any matters before the
former governmental body as to acting on behalf of a person; and (5) lobbying.
Popovich, Opinion 89 -005.
Listing one's name as the person who will provide technical assistance on a
proposal, document, or bid, if submitted to or reviewed by the former governmental
body, constitutes an attempt to influence the former governmental body. Section
1103(g) also generally prohibits the inclusion of the name of a former public
official /public employee on invoices submitted by his new employer to the former
governmental body, even though the invoices pertain to a contract that existed prior to
termination of public service. Shay, Opinion 91 -012. However, if such a pre - existing
contract does not involve the unit where the former public employee worked, the name
of the former public employee may appear on routine invoices if required by the
regulations of the agency to which the billing is being submitted. Abrams/Webster,
Opinion 95 -011.
A former public official /public employee may assist in the preparation of any
documents presented to his former governmental body. However, the former public
Confidential Advice, 07 -569
August 14, 2007
Page 4
official /public employee may not be identified on documents submitted to the former
governmental body. The former public official /public employee may also counsel any
person regarding that person's appearance before his former governmental body. Once
again, however, the activity in this respect should not be revealed to the former
governmental body. The Ethics Act would not prohibit or preclude making general
informational inquiries to the former governmental body to secure information which is
available to the general public, but this must not be done in an effort to indirectly
influence the former governmental body or to otherwise make known to that body the
representation of, or work for the new employer.
Section 1103(g) only restricts the former public official /public employee with
regard to representation before his former governmental body. The former public official/
public employee is not restricted as to representation before other agencies or entities.
However, the "governmental body with which a public official /public employee is or has
been associated" is not limited to the particular subdivision of the agency or other
governmental body where the public official /public employee had influence or control
but extends to the entire body. See, Legislative Journal of House, 1989 Session, No.
15 at 290, 291; Sirolli, Opinion 90 -006; Sharp, Opinion 90- 009 -R.
The governmental body with which you would be deemed to have been
associated upon termination of public service would be Governmental Body C in its
entirety. Therefore, for the first year following your termination of public service, Section
1103(g) of the Ethics Act would apply and restrict "representation" of "persons" —
including but not limited to the Company and clients of the Company— before
Governmental Body C.
With respect to the submitted fact that Governmental Body C is a client of the
Company, you are advised that you would be prohibited from performing work for
Governmental Body C, on behalf of the Company, to the extent your activities would
constitute prohibited representation as defined above.
Having set forth the restrictions of Section 1103(g) of the Ethics Act, your specific
inquiries shall be addressed.
Your first specific inquiry has been addressed above.
In response to your second specific inquiry, you are advised that under the
submitted facts, the agencies in the executive and administrative branch of Political
Subdivision E would not be considered part of the governmental body with which you
would be deemed to have been associated upon termination of public service.
In response to your third specific inquiry, you are advised that during the first
year following termination of service in your public position, Section 1103(g) of the
Ethics Act would prohibit you from performing any job duties that would constitute
prohibited representation of the Company or a client before Governmental Body C.
Section 1103(g) of the Ethics Act would only apply to restrict you from engaging in
prohibited "representation" before Governmental Body C and would not apply as to
agencies in the executive and administrative branch of Political Subdivision E.
However, where such agencies would have involvement with Governmental Body C,
you would have to exercise caution to ensure that you would not engage in prohibited
representation before Governmental Body C.
Lastly, the propriety of the proposed conduct has only been addressed under the
Ethics Act; the applicability of any other statute, code, ordinance, regulation, or other
code of conduct other than the Ethics Act has not been considered in that they do not
involve an interpretation of the Ethics Act. Specifically not addressed herein is the
potential applicability of any restrictions contained within the H or K.
Confidential Advice, 07 -569
August 14, 2007
Page 5
Conclusion: As an A to Public Official D, a B of Governmental Body C of
Political Subdivision E, you would be considered a public official /public employee
subject to the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1101
et seq. If you would terminate employment in your aforesaid public position to become
a partner in a private company, G ( "the Company "), you would become a "former public
official /public employee" subject to Section 1103(g) of the Ethics Act. The former
governmental body would be Governmental Body C in its entirety. The agencies in the
executive and administrative branch of Political Subdivision E would not be considered
part of the governmental body with which you would be deemed to have been
associated upon termination of public service. The restrictions as to representation
outlined above must be followed. Section 1103(g) of the Ethics Act would prohibit you
from performing any job duties that would constitute prohibited representation of the
Company or a client before Governmental Body C. Section 1103(g) of the Ethics Act
would only apply to restrict you from engaging in prohibited "representation" before
Governmental Body C and would not apply as to agencies in the executive and
administrative branch of Political Subdivision E. However, where such agencies would
have involvement with Governmental Body C, you would have to exercise caution to
ensure that you would not engage in prohibited representation before Governmental
Body C.
Act.
The propriety of the proposed conduct has only been addressed under the Ethics
Further, should service be terminated, as outlined above, the Ethics Act would
require that a Statement of Financial Interests be filed by no later than May 1 of the year
after termination of service.
Pursuant to Section 1107(11), an Advice is a complete defense in any
enforcement proceeding initiated by the Commission, and evidence of good faith
conduct in any other civil or criminal proceeding, provided the requester has disclosed
truthfully all the material facts and committed the acts complained of in reliance on the
Advice given.
This letter is a public record and will be made available as such.
Finally, if you disagree with this Advice or if you have any
reason to challenge same, you may appeal the Advice to the full
Commission. A personal appearance before the Commission will be
scheduled and a formal Opinion will be issued by the Commission.
Any such appeal must be in writing and must be actually
received at the Commission within thirty (30) days of the date of this
Advice pursuant to 51 Pa. Code § 13.2(h). The appeal may be
received at the Commission by hand delivery, United States mail,
delivery service, or by FAX transmission (717 - 787 - 0806). Failure to
file such an appeal at the Commission within thirty (30) days may
result in the dismissal of the appeal.
Sincerely,
Robin M. Hittie
Chief Counsel