HomeMy WebLinkAbout07-593 MunleyRyan P. Munley
727 W. Market St.
Pottsville, PA 17901
ADVICE OF COUNSEL
November 13, 2007
07 -593
Dear Mr. Munley:
This responds to your letter of October 3, 2007, by which you requested 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 restrictions upon employment of a
Transportation Construction Inspector following termination of service with the
Commonwealth of Pennsylvania, Department of Transportation ( "PennDOT ").
Facts: You request an advisory from the State Ethics Commission regarding the
post- employment restrictions of the Ethics Act. You have submitted facts that may be
fairly summarized as follows.
On September 28, 2007, you resigned from Commonwealth employment as a
Transportation Construction Inspector for the Materials Unit of PennDOT Engineering
District 5 -0 ( "District 5 -0 "). You have submitted a copy of your official PennDOT position
description, which is incorporated herein by reference. A copy of the job classification
specifications for your former position (job code 10620) has been obtained and is also
incorporated herein by reference.
You state that as a Transportation Construction Inspector with the Materials Unit
of PennDOT District 5 -0, you did not have authority or influence in the process of
selecting consultant firms to provide transportation construction services.
Following your resignation, you will be employed as an Assistant Construction
Manager with Prudent Engineering LLP ( "Prudent Engineering "), a Certified
Disadvantaged Business Enterprise. Prudent Engineering provides transportation
construction services to PennDOT, the Pennsylvania Turnpike Commission, and other
agencies. Prudent Engineering acts as a subordinate to primary firms on these
projects.
You state that as an Assistant Construction Manager, you will provide
administrative and technical support to the Construction Manager with regard to
marketing, recruiting, and staffing for transportation construction projects, including
projects for PennDOT, the Pennsylvania Turnpike Commission, and other agencies.
Your specific job duties will include: orientation of new employees /inspectors; jobsite
marketing visits to meet Field Project Managers and staff; preparing monthly invoices
and cost proposals for all active projects; coordinating inspector training; preparing
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November 13, 2007
Page 2
Statements of Interest; recruiting inspectors for new projects; attending mandatory
PennDOT and Pennsylvania Turnpike Commission meetings for consultants; and
attending conferences relating to construction practices.
You seek guidance as to whether the Ethics Act would impose any restrictions
upon you in your position with Prudent Engineering. In particular, you pose the
following specific questions:
1. Whether you may visit the jobsite of projects for which Prudent
Engineering is the subconsultant to primary firms in order to speak with
Prudent Engineering inspectors and other field personnel;
2. Whether you may make contact with the Resident Engineer(s) to find out
how Prudent Engineering inspectors are doing on the projects;
3. Whether you may contact the Resident Engineer(s) to resolve concerns or
issues with Prudent Engineering inspectors;
4. Whether you may contact prime consultants regarding PennDOT
Statements of Interest; and
5. Whether you may attend meetings, conferences, or marketing -type
outings where PennDOT personnel may be in attendance.
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.
In the former capacity as a Transportation Construction Inspector for PennDOT,
you would be considered a "public employee" subject to the Ethics Act and the
Regulations of the State Ethics Commission. See, 65 Pa.C.S. § 1102; 51 Pa. Code §
11.1. Cf., Blazer, Advice 04 -570. This conclusion is based 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; administering or monitoring grants or
subsidies; planning or zoning; inspecting; licensing; regulating; auditing; or other
activity(ies) where the economic impact is greater than de minimis on the interests of
another person.
Consequently, upon termination of public service, you became a "former 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 ":
§ 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
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November 13, 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 if the invoices pertain to a contract that existed prior to termination of service
with such governmental body. 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.
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November 13, 2007
Page 4
A former public official /public employee may assist in the preparation of any
documents presented to his former governmental body. However, the former ublic
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 are deemed to have been associated
upon termination of public service is PennDOT in its entirety, including but not limited to
District 5 -0. Therefore, for the first year following termination of service with PennDOT,
Section 1103(g) of the Ethics Act would apply and restrict "representation" of "persons"
before PennDOT.
Having set forth the restrictions of Section 1103(g) of the Ethics Act, your specific
inquiries shall be addressed.
In response to your first specific inquiry, you are advised as follows. It would
appear to be impossible for you to visit the jobsite of a PennDOT project on behalf of
Prudent Engineering without running afoul of Section 1103(g) of the Ethics Act. Under
such a scenario, it would seem inevitable that you would reveal to your former
governmental body (PennDOT) your employment with Prudent Engineering.
As to your second and third specific inquiries, you are advised as follows.
Conditioned upon the assumption that the Resident Engineers would not be PennDOT
employees, Section 1103(g) of the Ethics Act would not prohibit you from contacting
such Resident Engineers to find out how Prudent Engineering inspectors are doing on
projects and /or to resolve concerns or issues with Prudent Engineering inspectors.
However, in making such contacts, you would have to exercise caution to ensure that
your actions would not result in prohibited representation before PennDOT.
In response to your fourth specific inquiry, you are advised that Section 1103(g)
of the Ethics Act would not prohibit you from contacting prime consultants regarding
PennDOT Statements of Interest as long as in so doing, you would not engage in any
conduct that would constitute prohibited representation before PennDOT as set forth
above.
In response to your fifth specific inquiry, you are advised as follows. During the
one -year period of applicability of Section 1103(g), you would generally be permitted to
attend meetings, conferences or outings that would be open to the public as long as
your role would not go beyond that of a general observer. However, to the extent you
would attend a meeting, conference, or outing as a representative of Prudent
Engineering, you would be engaging in "representation" before the attendees of such an
event. If employee(s) of PennDOT would be in attendance at such an event, it would be
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November 13, 2007
Page 5
difficult if not impossible, as a practical matter, for you to attend the event without
running afoul of Section 1103(g) of the Ethics Act. Cf., MacKinnon, Advice 07 -580.
Based upon the facts that have been submitted, this Advice has addressed the
applicability of Section 1103(g) only. It is expressly assumed that there has been no
use of authority of office for a private pecuniary benefit as prohibited by Section 1103(a)
of the Ethics Act. Further, you are advised that Sections 1103(b) and 1103(c) of the
Ethics Act provide in part that no person shall offer to a public official /public employee
and no public official /public employee shall solicit or accept anything of monetary value
based upon the understanding that the vote, official action, or judgment of the public
official /public employee would be influenced thereby. Reference is made to these
provisions of the law not to imply that there has been or will be any transgression
thereof but merely to provide a complete response to the question presented.
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
applicability of the Governor's Code of Conduct.
Conclusion: In the former capacity as a Transportation Construction Inspector
for the Commonwealth of Pennsylvania, Department of Transportation ( "PennDOT "),
you would be considered a "public employee" subject to the Public Official and
Employee Ethics Act, 65 Pa.C.S. § 1101 et seq. ( "Ethics Act "). Upon termination of
service with PennDOT, you became a "former public employee" subject to Section
1103(g) of the Ethics Act. The former governmental body is PennDOT in its entirety
including, but not limited to, PennDOT Engineering District 5 -0. Section 1103(g) of the
Ethics Act would restrict you from engaging in any activity that would constitute
prohibited representation before PennDOT for one year following termination of
Commonwealth employment. The restrictions as to representation outlined above must
be followed. The propriety of the proposed conduct has only been addressed under the
Ethics Act.
Further, since service in your former Commonwealth position has been
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
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November 13, 2007
Page 6
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