HomeMy WebLinkAbout08-543 STEPHENSArthur C. Stephens
701 Spring Garden Street
Elizabethtown, PA 17022
ADVICE OF COUNSEL
April 24, 2008
08 -543
Dear Mr. Stephens:
This responds to your letters of March 17, 2008, and March 24, 2008, by which
you requested advice from the Pennsylvania 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 the Deputy
Chief of Staff in the Governor's Office following termination of service with the
Commonwealth of Pennsylvania.
Facts: You request an advisory from the Pennsylvania State Ethics Commission
regarding the post- employment restrictions of the Ethics Act. You have submitted facts
that may be fairly summarized as follows.
Since June, 1, 2005, you have served as Deputy Chief of Staff in the Governor's
Office, with the exception of the period from June 16, 2007, through September 3, 2007,
when you were on an unpaid leave of absence. You previously served as the Deputy
Secretary for Information Technology for the Office of Administration ( "OA ") from March
2003 to June 2005.
As Deputy Chief of Staff, you report to the Governor's Chief of Staff. You note
that there is neither an official position description nor official job classification
specifications for your current position.
You state when you began serving as Deputy Chief of Staff in June 2005, you
served as the Governor's primary liaison to public safety agencies under the Governor's
jurisdiction, including: the Pennsylvania Emergency Management Agency ( "PEMA "); the
Pennsylvania Office of Homeland Security; the Pennsylvania State Police; the
Pennsylvania Commission on Crime and Delinquency; the Pennsylvania Department of
Corrections; the Pennsylvania Board of Probation and Parole; and the Pennsylvania
Department of Military and Veterans' Affairs. You state that while the agencies for
which you acted as a liaison reported to the Governor and did not report directly to you,
such agencies conveyed information through you to the Governor and his senior staff.
You state that you also interacted with: the Pennsylvania Department of
Environmental Protection ( "DEP ") on radiological emergency matters and flooding; the
Commonwealth of Pennsylvania Department of Transportation ( "PennDOT'') on
emergency and critical infrastructure matters; the Pennsylvania Department of Health
and the Pennsylvania Department of Agriculture on pandemic planning efforts; and OA
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April 24, 2008
Page 2
on Continuity of Government matters. You did not oversee any budget and had no
authority over personnel or procurement.
You state that you continued in this capacity until June 16, 2007, when you
began an unpaid leave of absence that continued through September 3, 2007.
In September 2007, the Deputy Secretary for the Office of Information
Technology ("OIT ") resigned. You state that upon returning from your leave of absence,
the Governor's Chief of Staff asked you to serve in an interim assignment to assist the
Secretary of Administration ( "the Secretary ") in supporting OIT.
In your interim assignment, you spent approximately seventy percent of your time
advising the Secretary and working with Deputy Chief Information Officers within OIT.
You also led the search for a full -time Deputy Secretary for OIT, which position was
filled in January 2008. You state that from September 2007 to January 2008, you did
not have budgetary, procurement, or human resource responsibilities for OIT but served
in an advisory capacity to OIT on those matters.
You state that since you returned to your position as Deputy Chief of Staff on
September 4, 2007, you have not continued in your public safety liaison capacity. You
currently do not serve as the primary liaison to any Commonwealth entity. However,
since your return, you have served as an advisor to PEMA and the Pennsylvania
Department of Health in emergency management, pandemic, and homeland security
matters. In addition, you continue to assist OA with Continuity of Government planning.
You state that in the aforesaid roles, you do not have budgetary, procurement, or
human resource responsibilities. You note that since February 2008, you have also
been acting as an advisor to PennDOT on technology, administrative, and continuity of
government issues.
You state that you have not made any decisions regarding your potential career
options. One option is to return to the private sector, which could include providing
consulting services to governmental entities.
Based upon the above submitted facts, you pose the following specific questions
as to restrictions on your activities following termination of Commonwealth service:
1. In general, whether the Ethics Act would present any restrictions upon
your employment following your termination of service as Deputy Chief of
Staff;
2. Whether you would be permitted to have contact with state agencies, and
specifically what restrictions would apply to you under the Ethics Act;
and
3. Whether the Ethics Act would permit you to advise businesses on the
functions of government and other strategies as long as you would not
have direct contact with a "restricted agency or employee."
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 Deputy Chief of Staff in the Governor's Office, you would be considered a
"public official /public employee" and an "executive -level State employee" subject to the
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April 24, 2008
Page 3
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 Commonwealth service, you would become a
former public official /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
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).
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April 24, 2008
Page 4
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.
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
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April 24, 2008
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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 Commonwealth service, hereinafter referred to as your
"former governmental body," would be the Governor's Office in its entirety, including but
not limited to the Executive Offices and OA, as well as any boards, commissions, or
other governmental bodies that you serve as an employee, appointee /member, or
designee. See, Confidential Opinion, 01 -006. Therefore, for the first year following
termination of your Commonwealth service, Section 1103(g) of the Ethics Act would
apply and restrict "representation" of "persons" before your former governmental body
as identified above.
Having set forth the restrictions of Section 1103(g) of the Ethics Act, it is noted
that your first and second questions have already been addressed above.
In response to your third question, you are advised as follows. Following
termination of your Commonwealth service, Section 1103(i) of the Ethics Act would not
prohibit you from advising a given business on the functions of government and other
strategies conditioned upon the assumptions that you did not actively participate in
recruiting such business to Pennsylvania, and that you did not actively participate in
inducing such business 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 to such business. Section 1103(g) of the Ethics Act
would not prohibit you from advising businesses on the functions of government and
other strategies as long as in so doing, you would not engage in prohibited
representation before your former governmental body during the first year following
termination of Commonwealth service.
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
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 Governor's Code
of Conduct.
Conclusion: As Deputy Chief of Staff in the Governor's Office, you would be
considered a "public official /public employee" and "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 Commonwealth service, you would become a former public
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April 24, 2008
Page 6
official /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. The prohibitions of
Section 1103(i) of the Ethics Act set forth above would have to be followed. Under
Section 1103(1) 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. The restrictions of Section
1103(g) of the Ethics Act as outlined above must be followed. The governmental body
with which you would be deemed to have been associated upon termination of
Commonwealth service, hereinafter referred to as your "former governmental body,"
would be the Governor's Office in its entirety, including but not limited to the Executive
Offices and Office of Administration, as well as any boards, commissions, or other
governmental bodies that you serve as an employee, appointee /member, or designee.
For the first year following termination of your Commonwealth service, Section 1103(g)
of the Ethics Act would apply and restrict "representation" of "persons" before your
former governmental body as identified above. The propriety of the proposed conduct
has only been addressed under the Ethics Act.
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) of the Ethics Act, 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