HomeMy WebLinkAbout10-632 DeWitt
ADVICE OF COUNSEL
December 22, 2010
Myron B. DeWitt, Esquire
DeWitt & Cordner
1220 Main Street, P.O. Box 244
Susquehanna, PA 18847
10-632
Dear Mr. DeWitt:
This responds to your letters dated October 28, 2010, and November 3, 2010, 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 a former borough council
member with regard to serving as the borough codes enforcement officer.
Facts:
As Solicitor for the Borough of Susquehanna Depot (“Borough”), you have
been authorized by Borough Council to request an advisory from the Pennsylvania
State Ethics Commission based upon the following submitted facts.
The Borough has advertised to fill a vacancy in the appointed position of
Borough Codes Enforcement Officer. The Borough Codes Enforcement Officer has the
following duties: fielding and investigating complaints of potential code violations;
inspecting potential code violations; issuing appropriate citations or compliance orders
when warranted; and appearing in court when necessary to enforce compliance orders
and/or citations.
You state that the Borough received an application for the position of Borough
Codes Enforcement Officer from Roy Williams (“Mr. Williams”). Until approximately a
few months ago, Mr. Williams served as a Member of Borough Council. You state that
in his former capacity as a Borough Council Member, Mr. Williams was not involved in
any way with the creation of the currently vacant Codes Enforcement Officer position.
You further state that Mr. Williams, as a Borough Council Member, would have
participated in the adoption of the past year’s budget, which would have included an
allocation for the Codes Enforcement Department. The President of Borough Council
has advised you that Mr. Williams did not participate in any decisions regarding any
pending or outstanding code violations in his former capacity as a Borough Council
Member.
Before considering the potential appointment/hiring of Mr. Williams to the position
of Borough Codes Enforcement Officer, Borough Council seeks an advisory as to
whether Mr. William’s prior service as a Borough Council Member would preclude such
an appointment.
DeWitt, 10-632
December 22, 2010
Page 2
Based upon the above submitted facts, you ask whether the Ethics Act would
impose any restrictions upon Mr. Williams with regard to serving as the Borough Codes
Enforcement Officer.
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.
It is further initially noted that, pursuant to the same aforesaid Sections of the
Ethics Act, an opinion/advice may be given only as to prospective (future) conduct. To
the extent that your inquiry relates to conduct that has already occurred, such past
conduct may not be addressed in the context of an advisory opinion. However, to the
extent your inquiry relates to future conduct, your inquiry may and shall be addressed.
In the former capacity as a Borough Council Member, Mr. Williams would be
considered a “public official” 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 a Borough Council Member, Mr.
Williams became a “former public official” 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
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.
DeWitt, 10-632
December 22, 2010
Page 3
"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 “represent” is also broadly defined to prohibit acting on behalf of any
person in any activity.
The governmental body with which Mr. Williams is deemed to have been
associated upon termination of service as a Borough Council Member is Borough
Council in its entirety. Therefore, for the first year following termination of Mr. William’s
service on Borough Council, Section 1103(g) of the Ethics Act would apply and restrict
“representation” of “persons” before Borough Council.
However, per State Ethics Commission precedents, Section 1103(g) of the Ethics
Act does not prohibit the appointment/rehiring of a former public official/public employee
to a public office or position of public employment with the former governmental body.
Confidential Opinion, 93-005; Confidential Opinion, 97-008; Long, Opinions 97-010 and
97-010-R; McGlathery, Opinion 00-004.
Therefore, you are advised as follows. Based upon the submitted facts, Section
1103(g) of the Ethics Act would not prohibit Mr. Williams from being appointed to serve
as the Borough Codes Enforcement Officer. If Mr. Williams would be appointed to
serve as the Borough Codes Enforcement Officer, he would in that capacity be
considered a public official/public employee subject to the Ethics Act, and the
restrictions of Section 1103(g) of the Ethics Act would cease to apply to him.
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.
Conclusion:
In the former capacity as a Member of Council for the Borough of
Susquehanna Depot (“Borough”), Roy Williams (“Mr. Williams”) would be considered a
“public official” subject to the Public Official and Employee Ethics Act (“Ethics Act”), 65
Pa.C.S. § 1101 et seq., and the Regulations of the State Ethics Commission, 51 Pa.
Code § 11.1 et seq. U pon termination of service as a Borough Council Member, Mr.
Williams became a “former public official” subject to Section 1103(g) of the Ethics Act.
The governmental body with which Mr. Williams is deemed to have been associated
upon termination of service as a Borough Council Member is Borough Council in its
entirety. Section 1103(g) of the Ethics Act would prohibit Mr. Williams from engaging in
any activity that would constitute prohibited representation before Borough Council for
one year following termination of his service on Borough Council. Based upon the
submitted facts, Section 1103(g) of the Ethics Act would not prohibit Mr. Williams from
being appointed to serve as the Borough Codes Enforcement Officer. If Mr. Williams
would be appointed to serve as the Borough Codes Enforcement Officer, he would in
that capacity be considered a public official/public employee subject to the Ethics Act,
and the restrictions of Section 1103(g) of the Ethics Act would cease to apply to him.
DeWitt, 10-632
December 22, 2010
Page 4
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