HomeMy WebLinkAbout08-526 ConfidentialADVICE OF COUNSEL
March 18, 2008
08 -526
This responds to your letter of February 3, 2008, and your faxed transmission
received February 8, 2008, by which you requested a confidential advisory 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 an A
following termination of service with Commonwealth Agency B, C Office.
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.
You are currently employed as the A in the C Office within Commonwealth
Agency B. You have submitted a copy of your official position description, which is
incorporated herein by reference. It is noted that the position description lists your job
title as [title 1 ] and your working title as [title 2]. You have also submitted copies of the
job classification specifications for [title 1 ] (job code [number]) and the organizational
charts for Commonwealth Agency B's C Office and D Office, which documents are
incorporated herein by reference.
You state that you are under consideration for the position of E with Entity F.
You have submitted copies of the job description for the aforesaid position and an
organizational chart for Entity F, which documents are incorporated herein by reference.
You express your understanding that the E position will be primarily funded by
federal and local sources. It is also your understanding that you would not represent
Entity F before Commonwealth Agency B or sign invoices for at least twelve months
from accepting the position of E.
You note that you were employed with Entity F prior to commencing your
employment with Commonwealth Agency B.
Confidential Advice, 08 -526
March 18, 2008
Page 2
In a telephone conversation with Commission staff on February 8, 2008, you
confirmed that you would resign from your position with Commonwealth Agency B if,
pursuant to the Ethics Act, you would be permitted to work as the E for Entity F
following termination of employment with Commonwealth Agency B.
Based upon the above submitted facts, you seek guidance as to whether the
Ethics Act would impose any restrictions upon you with regard to your prospective
employment as the E for Entity F following termination of employment with
Commonwealth Agency B.
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 the A for Commonwealth Agency B, you would be considered a "public
employee" and an "executive -level State 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
Consequently, upon termination of public service, you would become a "former
public employee" and a "former executive -level State employee" subject to the
restrictions of Section 1103(g) and Section 1103(i) of the Ethics Act.
Section 1103(i) restricts former executive -level State employees as follows:
§ 1103. Restricted activities
(i) Former executive -level employee. - -No former
executive -level State employee may for a period of two
years from the time that he terminates employment with this
Commonwealth be employed by, receive compensation
from, assist or act in a representative capacity for a business
or corporation that he actively participated in recruiting to this
Commonwealth or that he actively participated in inducing to
open a new plant, facility or branch in this Commonwealth or
that he actively participated in inducing to expand an existent
plant or facility within this Commonwealth, provided that the
above prohibition shall be invoked only when the recruitment
or inducement is accomplished by a grant or loan of money
or a promise of a grant or loan of money from the
Commonwealth to the business or corporation recruited or
induced to expand.
65 Pa.C.S. § 1103(i).
Section 1103(i) restricts the ability of a former executive -level State employee to
accept employment or otherwise engage in business relationships following termination
of State service, under certain narrow conditions. The restrictions of Section 1103(i)
apply even where the business relationship is indirect, such as where the business in
question is a client of a new employer, rather than the new employer itself. See,
Confidential Opinion, 94 -011. However, Section 1103(i) would not restrict you from
being employed by, receiving compensation from, assisting, or acting in a
representative capacity for a business or corporation subject to the conditions that you
Confidential Advice, 08 -526
March 18, 2008
Page 3
did not actively participate in recruiting such business or corporation to Pennsylvania,
and that you did not actively participate in inducing such business or corporation to
open or expand a plant, facility, or branch in Pennsylvania, through a grant or loan of
money or a promise of a grant or loan of money from the Commonwealth of
Pennsylvania.
Unlike Section 1103(i), Section 1103(g) does not prohibit a former public
official /public employee from accepting a position of employment. However, 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
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 /employee; (4) participating in any matters before the former
Confidential Advice, 08 -526
March 18, 2008
Page 4
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 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 would be deemed to have been
associated upon termination of public service would be Commonwealth Agency B in its
entirety, including but not limited to the C Office. Therefore, for the first year following
termination of your service with Commonwealth Agency B, Section 1103( of the Ethics
Act would apply and restrict "representation" of "persons" before Commonwealth
Agency B.
You are advised that Section 1103(g) of the Ethics Act would not prohibit you
from accepting employment with Entity F as the E. However, during the first year
following termination of your employment with Commonwealth Agency B, Section
1103(g) of the Ethics Act would prohibit you from performing any job duties for Entity F
that would involve prohibited representation before Commonwealth Agency B as set
forth above.
Based upon the facts that have been submitted, this Advice has addressed the
applicability of Sections 1103(g) and 1103(i) 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 or give 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
Confidential Advice, 08 -526
March 18, 2008
Page 5
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. Specifically not addressed herein is the applicability of the G.
Conclusion: As the A with Commonwealth Agency B, C Office, you would be
considered a "public employee" and an "executive -level State employee" subject to the
Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1101 et seq. Upon
termination of service with Commonwealth Agency B, you would become a former
public employee and a former executive -level State employee subject to the restrictions
of Section 1103(g) and Section 1103(i) of the Ethics Act. Under Section 1103(i) of the
Ethics Act, you would not be prohibited from being employed by, receiving
compensation from, assisting, or acting in a representative capacity for a business or
corporation subject to the conditions that you did not actively participate in recruiting
such business or corporation to Pennsylvania, and that you did not actively participate
in inducing such business or corporation to open or expand a plant, facility, or branch in
Pennsylvania through a grant or loan of money or a promise of a grant or loan of money
from the Commonwealth of Pennsylvania. With regard to Section 1103(g), the
restrictions as to representation outlined above must be followed. The former
governmental body would be Commonwealth Agency B in its entirety, including but not
limited to the C Office. For one year following termination of employment with
Commonwealth Agency B, Section 1103(g) of the Ethics Act would restrict you from
engaging in any activity that would constitute prohibited representation before
Commonwealth Agency B. Section 1103(g) of the Ethics Act would not prohibit you
from accepting employment with Entity F as the E. However, during the first year
following termination of your employment with Commonwealth Agency B, Section
1103(g) of the Ethics Act would prohibit you from performing any job duties for Entity F
that would involve prohibited representation before Commonwealth Agency B as set
forth above.
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
Confidential Advice, 08 -526
March 18, 2008
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