HomeMy WebLinkAbout08-570 ConfidentialADVICE OF COUNSEL
August 18, 2008
08 -570
This responds to your letter of July 18, 2008, by which you requested a
confidential advisory from the Pennsylvania State Ethics Commission.
Issue: Whether the Public Official and Employee Ethics Act ( "Ethics Act "), 65
Pa. .S. § 1101 et seq., would impose any prohibitions or restrictions upon the former A
with regard to serving on an advisory board within Commonwealth Department B.
Facts: As C for Commonwealth Department B, you have been authorized by
Individual D, the former A, and Individual E, the F, to request a confidential advisory
from the Pennsylvania State Ethics Commission. You have submitted facts that may be
fairly summarized as follows.
Individual D resigned from her public position as the A effective [date].
You state that Individual D may be interested in serving as a public
representative on various Commonwealth boards or advisory committees. Specifically,
Individual D is presently considering an opportunity for appointment to the G Body. The
G Body advises Commonwealth Department B with regard to the implementation of the
provisions of the H Act ( "Act "), Act [number] of [year].
It is administratively noted that Section [number] of the Act establishes the G
Body within Commonwealth Department B. It is further administratively noted that
pursuant to Section [number] of the Act, Members of the G Body shall serve without
compensation but may be reimbursed for necessary and reasonable travel and other
expenses incurred during the performance of their duties.
You state that the aforesaid prospective appointment to the G Body, if accepted
by Individual D, would be within one year of Individual D's departure from
Commonwealth service. You further state that there would be no promised or actual
compensation associated with Individual D's position as a G Body Member. You
additionally state that as a G Body Member, Individual D would not be personally
representing another person before Commonwealth Department B.
Based upon the above submitted facts, you ask whether the Ethics Act would
permit Individual D to serve as a Member of the G Body.
Confidential Advice, 08 -570
August 18, 2008
Page 2
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 the A, Individual D would be considered a public
official /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 service as the A, Individual D became 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) of the Ethics Act 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). In that you have posed a narrow inquiry that does not pertain to
Section 1103(i), that Section shall not be further addressed in this advisory.
Section 1103(g) of the Ethics Act, which is relevant to your request, restricts a
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).
Confidential Advice, 08 -570
August 18, 2008
Page 3
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
Confidential Advice, 08 -570
August 18, 2008
Page 4
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 bodies with which Individual D is deemed to have been
associated upon termination of service as the A, hereinafter collectively referred to as
her "former governmental body," would be: the I, Office J in its entirety, Commonwealth
Department B in its entirety, and all commissions, committees, councils, and boards on
which Individual D served. Therefore, for the first year following termination of Individual
D's service as the A, Section 1103(g) of the Ethics Act would apply and restrict
"representation" of "persons" before Individual D's "former governmental body" as
delineated above.
Turning to your specific inquiry, you are advised as follows. Based upon the
submitted facts that: (1) if Individual D would accept a position as a Member of the G
Body, she would be returning to a position on an advisory board within Commonwealth
Department B; (2) Individual D would receive no promised or actual compensation for
serving as a Member of the G Body; and (3) as a G Body Member, Individual D would
not be personally representing another person before Commonwealth Department B,
Section 1103(g) of the Ethics Act would not prohibit Individual D from serving as a
Member of the G Body.
To the extent the G Body is a purely advisory board, Individual D would not
resume status as a "public official" with Commonwealth Department B as a result of
serving as a Member of the G Body (see, definition of "public official, 65 Pa.C.S. §
1102). The restrictions of Section 1103(g) of the Ethics Act would apply during the first
year following termination of service as A. Goddard, Opinion 07 -019.
Lastly, the propriety of the proposed conduct has only been addressed under the
Ethics Act. Specifically not addressed herein is the applicability of the K.
Conclusion: In the former capacity as the A, Individual D would be considered a
public official /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 as the A, Individual D became 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. To the extent you have posed a
narrow inquiry under Section 1103(g) only, you are advised as follows. The
governmental bodies with which Individual D is deemed to have been associated upon
termination of service as the A, hereinafter collectively referred to as her "former
governmental body," would be: the I, Office J in its entirety, Commonwealth Department
B in its entirety, and all commissions, committees, councils, and boards on which
Individual D served. For the first year following Individual D's termination of service as
the A, Section 1103(g) of the Ethics Act would apply and restrict "representation" of
"persons" before Individual D's "former governmental body" as delineated above.
Confidential Advice, 08 -570
August 18, 2008
Page 5
Based upon the submitted facts that: (1) if Individual D would accept a position
as a Member of the G Body, she would be returning to a position on an advisory board
within Commonwealth Department B; (2) Individual D would receive no promised or
actual compensation for serving as a Member of the G Body; and (3) as a G Body
Member, Individual D would not be personally representing another person before
Commonwealth Department B, Section 1103(g) of the Ethics Act would not prohibit
Individual D from serving as a Member of the G Body. To the extent the G Body is a
purely advisory board, Individual D would not resume status as a "public official' with
Commonwealth Department B as a result of serving as a Member of the G Body. The
restrictions of Section 1103(g) of the Ethics Act would apply during the first year
following termination of service as A.
Lastly, the propriety of the proposed conduct has only been addressed under the
Ethics Act.
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