HomeMy WebLinkAbout10-547 Rowe
ADVICE OF COUNSEL
February 19, 2010
Greg A. Rowe
rd
249 South 23 Street
Philadelphia, PA 19103
10-547
Dear Mr. Rowe:
This responds to your letters dated December 22, 2009, and December 28,
2009, by which you requested an advisory from the Pennsylvania State Ethics
Commission.
Issue:
Whether the Public Official and Employee Ethics Act (“Ethics Act”), 65
Pa.C.S. § 1101 et seq., would impose any restrictions upon an attorney, who has
served as a Senior Policy Manager with the Governor’s Policy Office and Special
Assistant to the Governor for Public Safety, with regard to lobbying Executive Branch
agencies following termination of Commonwealth employment.
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.
At the time that you submitted your inquiry, you were employed as a Senior
Policy Manager with the Governor’s Policy Office and Special Assistant to the Governor
for Public Safety. You noted that there is neither an official position description nor
official job classification specifications for either of your aforesaid positions with the
Commonwealth.
You stated that since April 2004, you have worked in the Governor’s Policy Office
as a Senior Policy Manager for criminal justice, in which capacity you have coordinated
various matters of public safety on behalf of the Governor. You stated that where
appropriate, you have worked closely with members/staff of the Pennsylvania
Department of Corrections (“Department of Corrections”), the Pennsylvania State
Police, the Pennsylvania Board of Probation and Parole, and the Pennsylvania
Commission on Crime and Delinquency. You stated that you also worked on various
occasions on a variety of other issues with staff from the Pennsylvania Emergency
Management Agency, the Pennsylvania National Guard, the Pennsylvania Liquor
Control Board, and the Pennsylvania Department of State.
Beginning in October 2009, you assumed additional duties as Special Assistant
to the Governor for Public Safety. You stated that you have served as the Governor’s
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February 19, 2010
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day-to-day contact for the Pennsylvania State Police, the Pennsylvania Board of
Probation and Parole, the Department of Corrections, and the Pennsylvania
Commission on Crime and Delinquency.
You stated that you have not supervised any of the aforementioned agencies or
any their employees but have instead worked with them on behalf of the Governor and
other senior staff on various matters, including policy development, legislative
advocacy, budget issues, and grant funding strategies.
You stated that in your capacity as Senior Policy Manager, you have reported to
the Governor’s Secretary of Policy and Planning. You stated that you have reported to
the Chief of Staff in your capacity as Special Assistant to the Governor for Public Safety.
You stated that the Department of Corrections has paid for your salary and
provided you with a laptop and Blackberry. You further stated, however, that the
Department of Corrections has not supervised you in any manner. You stated that you
have not reported to anyone at the Department of Corrections and that your relationship
with said agency has been no different than your relationships with the other agencies
with which you have worked.
You stated that you would be leaving your Commonwealth employment on
December 28, 2009, to become Chief of the Legislation and Policy Unit in the
Philadelphia District Attorney’s Office.
Finally, it is noted that you are an attorney licensed to practice law in the
Commonwealth.
Based upon the above facts, you seek guidance as to whether the Ethics Act
would impose any restrictions upon you with regard to lobbying the Office of the
Governor or Executive Branch agencies during the first year following termination of
your Commonwealth employment.
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 a Senior Policy Manager with the Governor’s Policy Office and Special
Assistant to the Governor for Public Safety, you 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.
Upon termination of Commonwealth employment, you would become a former
public official/public employee and a former executive-level State employee.
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
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February 19, 2010
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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(g) of the Ethics Act provides as follows:
§ 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.
Section 1103(g) of the Ethics Act restricts a former public official/public employee
with regard to “representing” a “person” before “the governmental body with which he
has been associated.” However, Section 1103(g) of the Ethics Act may not be applied
to restrict an attorney’s conduct insofar as it constitutes the practice of law, because the
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February 19, 2010
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Pennsylvania Supreme Court has the exclusive authority to regulate an attorney’s
conduct in that regard. Shaulis v. Pennsylvania State Ethics Commission, 574 Pa. 680,
833 A.2d 123 (2003).
The governmental body with which you would be deemed to have been
associated upon termination of Commonwealth employment, hereinafter collectively
referred to as your “former governmental body,” would be the Office of the Governor in
its entirety (including but not limited to the Executive Offices, the Office of
Administration, and the Office of the Budget) as well as the Department of Corrections.
Therefore, for the first year following termination of your Commonwealth employment,
Section 1103(g) of the Ethics Act would apply and restrict “representation” of “persons”
before your former governmental body as delineated above, to the extent such
representation would not constitute the practice of law. Cf., Moore, Opinion 05-008;
Confidential Advice, 05-583; Confidential Advice, 04-524.
The Commonwealth Court of Pennsylvania has held that lobbying by a lawyer is
the practice of law. Gmerek v. State Ethics Commission, 751 A.2d 1241 (Pa. Commw.
Ct. 2000), affirmed by evenly divided Court, 569 Pa. 579, 807 A.2d 812 (2002).
Therefore, you are advised that during the first year following termination of your
Commonwealth employment, Section 1103(g) of the Ethics Act would not apply to
prohibit you from lobbying your former governmental body to the extent your activity(ies)
would constitute the practice of law. Additionally, Section 1103(g) of the Ethics Act
would not prohibit you from lobbying any other Commonwealth agencies or bodies.
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 or the Rules of Professional Conduct.
Conclusion:
As a Senior Policy Manager with the Governor’s Policy Office and
Special Assistant to the Governor for Public Safety, you 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 Commonwealth employment, you would become a former public
official/public employee and a former executive-level State employee. The
governmental body with which you would be deemed to have been associated upon
termination of Commonwealth employment, hereinafter collectively referred to as your
“former governmental body,” would be the Office of the Governor in its entirety
(including but not limited to the Executive Offices, the Office of Administration, and the
Office of the Budget) as well as the Pennsylvania Department of Corrections. For the
first year following termination of your Commonwealth employment, Section 1103(g) of
the Ethics Act would apply and restrict “representation” of “persons” before your former
governmental body to the extent such representation would not constitute the practice
of law. During the first year following termination of your Commonwealth employment,
Section 1103(g) of the Ethics Act would not apply to prohibit you from lobbying your
former governmental body to the extent your activity(ies) would constitute the practice of
law. Additionally, Section 1103(g) of the Ethics Act would not prohibit you from lobbying
any other Commonwealth agencies or bodies. 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.
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February 19, 2010
Page 5
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