HomeMy WebLinkAbout12-580 Taylor
ADVICE OF COUNSEL
November 28, 2012
Keith Taylor
1030 Hoff Road
Hanover, PA 17331
12-580
Dear Mr. Taylor:
This responds to your letter dated October 16, 2012, 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 employment of a former
Park Operations Manager 1 with the Pennsylvania Department of Conservation and
Natural Resources (“DCNR”) who, following retirement from the Commonwealth of
Pennsylvania, has provided services to DCNR as an annuitant under the 95-day “return
to state service” provision at 71 Pa.C.S. § 5706(A.1).
Facts:
You request an advisory from the Pennsylvania State Ethics Commission
regarding the post-employment restrictions of the Ethics Act. You have submitted facts
which may be fairly summarized as follows.
In April 2012, you retired from your employment as a Park Operations Manager 1
with DCNR. You have submitted copies of your official DCNR position description and
organization charts pertaining to DCNR, which documents are incorporated herein by
reference. A copy of the job classification specifications for the position of Park
Operations Manager 1 (job code 54350) has been obtained and is also incorporated
herein by reference.
Following your retirement from the Commonwealth, you returned to work with
DCNR as an annuitant under the 95-day “return to state service” provision at 71 Pa.C.S.
§ 5706(A.1) (“the 95-day Annuitant Program”), to assist the executive staff with the
budget and your replacement as section chief. Your period of service as an annuitant
with DCNR under the 95-day Annuitant Program was to be terminated on October 31,
2012.
You state that you have been offered a temporary part-time job with US eDirect,
which offers software solutions for permits and licenses, campgrounds, marinas,
venues, parks and recreation, team sports, leagues, and golf courses. You state that
US eDirect does not currently have any contracts with the Commonwealth and that US
eDirect’s client base consists mainly of local and county governments along with a few
private sector companies. You further state that US eDirect executed its first state client
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reservation system contract with Minnesota in January 2012 and that US eDirect plans
to bid on a Missouri reservation contract which is expected to be released in 2013.
Pennsylvania recently executed a reservation system contract with another
business. That contract expires in December of 2015 and has extension options, which
you expect to be exercised. You state that US eDirect did not bid on Pennsylvania’s
contract in 2010.
The job that you have been offered with US eDirect would be fifteen hours per
week for six months starting in November 2012, and your part-time status could
potentially be extended depending upon the needs of US eDirect. You state that your
primary duties would involve providing assistance and knowledge from a field-user
perspective to improve US eDirect’s software to meet the needs of federal and state
clients. You would work with US eDirect’s membership, recreation, point of sale, and
activity modules to accomplish certain goals. You state that you would also provide
some input for US eDirect’s response to the Missouri request for proposals for a turnkey
reservation program.
Based upon the above submitted facts, you ask whether you would violate the
Ethics Act or the State Adverse Interest Act if you would accept employment with US
eDirect.
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 a Park Operations Manager 1 with DCNR, you would
be considered a “public 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. This
conclusion is based upon the position description and the job classification
specifications, which when reviewed on an objective basis, indicate clearly that the
power exists to take or recommend official action of a non-ministerial nature with
respect to one or more of the following: contracting; procurement; administering or
monitoring grants or subsidies; planning or zoning; inspecting; licensing; regulating;
auditing; or other activity(ies) where the economic impact is greater than de minimis on
the interests of another person.
Consequently, upon retiring from the Commonwealth, you became a "former
public employee" subject to Section 1103(g) of the Ethics Act.
It is clear that when a former public employee returns to service as an annuitant
to again perform services falling within the Ethics Act’s definition of “public employee”
(see, 65 Pa.C.S. § 1102), the annuitant again becomes a “public employee” subject to
the Ethics Act. See, Graves, Opinion 00-009; McGlathery, Opinion 00-004.
The submitted facts are insufficient to enable a conclusive determination as to
whether, upon returning to work with DCNR as an annuitant, your duties/authority were
such that you again became a “public employee” subject to the Ethics Act. Without that
information, this Advice cannot determine the particular time at which the restrictions of
Section 1103(g) most recently began to apply to you as a former “public employee” (that
is, April 2012 or October 31, 2012). However, this Advice will provide the requested
guidance to you by generally referring to the “time when you most recently terminated
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service with DCNR as a public employee subject to the Ethics Act,” without specifying a
particular date.
At the time when you most recently terminated service with DCNR as a public
employee subject to the Ethics Act, you became a former public employee subject to
the restrictions of 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.
"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 official/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. 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
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November 28, 2012
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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 a 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 public
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.
At the time when you most recently terminated service with DCNR as a public
employee subject to the Ethics Act, you became a “former public employee” subject to
Section 1103(g) of the Ethics Act, and the one-year period of applicability of Section
1103(g) commenced.
The governmental body with which you are deemed to have been associated
upon termination of the aforesaid service is DCNR in its entirety.
Therefore, until the expiration of a full one-year period from the time when you
most recently terminated service with DCNR as a public employee subject to the Ethics
Act, or until you would resume providing services to DCNR under the 95-day Annuitant
Program in a position falling within the Ethics Act’s definition of “public employee,”
whichever would come first, Section 1103(g) of the Ethics Act would apply to restrict you
from engaging in conduct that would constitute the representation of a “person” before
DCNR with promised or actual compensation as set forth above.
Having set forth the restrictions of Section 1103(g) of the Ethics Act, your specific
question shall now be addressed.
You are advised that Section 1103(g) of the Ethics Act would not prohibit you
from accepting employment with US eDirect. However, when Section 1103(g) of the
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Ethics Act would be applicable, Section 1103(g) would prohibit you from performing any
job duty(ies) that would involve prohibited representation before DCNR as outlined
above.
You are further advised that the State Ethics Commission does not have the
statutory jurisdiction to administer or interpret the State Adverse Interest Act.
Based upon the facts that have been submitted, this Advice has addressed the
applicability of Section 1103(g) only. It is expressly assumed that there has been no
use of authority of office or employment, or confidential information received by being in
the public position, 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; 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. Specifically not addressed herein is the
applicability of the Governor’s Code of Conduct or the State Adverse Interest Act.
Conclusion:
In the former capacity as a Park Operations Manager 1 with the
Pennsylvania Department of Conservation and Natural Resources (“DCNR”), you would
be considered a “public employee” 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. Upon retiring from Commonwealth
employment in April 2012, you became a “former public employee” subject to Section
1103(g) of the Ethics Act. The submitted facts are insufficient to enable a conclusive
determination as to whether, upon returning to work with DCNR as an annuitant under
the 95-day “return to state service” provision at 71 Pa.C.S. § 5706(A.1) (“the 95-day
Annuitant Program”), your duties/authority were such that you again became a “public
employee” subject to the Ethics Act.
At the time when you most recently terminated service with DCNR as a public
employee subject to the Ethics Act, you became a “former public employee” subject to
Section 1103(g) of the Ethics Act, and the one-year period of applicability of Section
1103(g) commenced. The governmental body with which you are deemed to have been
associated upon termination of the aforesaid service is DCNR in its entirety. Until the
expiration of a full one-year period from the time when you most recently terminated
service with DCNR as a public employee subject to the Ethics Act, or until you would
resume providing services to DCNR under the 95-day Annuitant Program in a position
falling within the Ethics Act’s definition of “public employee,” whichever would come
first, Section 1103(g) of the Ethics Act would apply to restrict you from engaging in
conduct that would constitute the representation of a “person” before DCNR with
promised or actual compensation as set forth above. The restrictions as to
representation outlined above must be followed. Section 1103(g) of the Ethics Act
would not prohibit you from accepting employment with US eDirect. However, when
Section 1103(g) of the Ethics Act would be applicable, Section 1103(g) would prohibit
you from performing any job duty(ies) that would involve prohibited representation
before DCNR as outlined above.
Lastly, the propriety of the proposed conduct has only been addressed under the
Ethics Act.
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November 28, 2012
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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