HomeMy WebLinkAbout14-2003 King
DETERMINATION OF THE COMMISSION
Before: John J. Bolger, Chair
Nicholas A. Colafella, Vice Chair
Raquel K. Bergen
Mark R. Corrigan
Roger Nick
Kathryn Streeter Lewis
Maria Feeley
DATE DECIDED: 10/1/14
DATE MAILED: 10/8/14
14-2003
Adrian R. King, Jr., Esquire
Ballard Spahr LLP
st
1735 Market Street, 51 Floor
Philadelphia, PA 19103-7599
Dear Mr. King:
This is in response to your letter dated June 30, 2014, by which you requested a
determination from this Commission pursuant to Section 1512.1(e)(1) of the
Pennsylvania Race Horse Development and Gaming Act (“Gaming Act”), 4 Pa.C.S. §
1512.1(e)(1).
I.ISSUE:
Whether a former First Deputy Attorney General for the Pennsylvania Office of
Attorney General would be subject to Section 1512.1(a)(1)-(3) of the Gaming Act, 4
Pa.C.S. § 1512.1(a)(1)-(3), where: (1) upon assuming the aforesaid position, the
individual recused himself from any and all matters involving the regulation and
oversight of casino gaming and delegated any and all gaming matters to another
attorney; (2) while serving in such position, the individual’s duties did not substantially
involve licensing or enforcement, the development of laws or the development or
adoption of regulations or policy related to gaming; and (3) while serving in such
position, the individual never maintained other discretionary authority which might affect
or influence the outcome of an action, proceeding or decision under the Gaming Act.
II.FACTUAL BASIS FOR DETERMINATION:
As a former First Deputy Attorney General for the Pennsylvania Office of
Attorney General, you request a determination from the Pennsylvania State Ethics
Commission as to whether you would be subject to Section 1512.1(a)(1)-(3) of the
Gaming Act, 4 Pa.C.S. § 1512.1(a)(1)-(3).
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October 8, 2014
Page 2
You state that the First Deputy Attorney General reports directly to the Attorney
General and serves as “second-in-command” in the office of Attorney General. The
First Deputy Attorney General is responsible for day-to-day operations of the
Commonwealth’s chief law enforcement, consumer protection and civil litigation agency.
You state that immediately prior to assuming the First Deputy Attorney General
position, you were a partner in the Philadelphia-based law firm Ballard Spahr LLP,
where a primary focus of your legal practice was representation of gaming related
businesses before the Pennsylvania Gaming Control Board. Such gaming related
businesses included entities seeking a license to operate a casino in Pennsylvania,
entities granted a license to operate a casino in Pennsylvania, and entities seeking to
provide goods and services to a Pennsylvania casino in the capacity of a vendor.
On January 16, 2013—the day following her swearing-in—Attorney General
Kathleen Kane held the first meeting of her senior executive staff. You state that during
this meeting, you identified the actual, potential and/or perceived conflicts of interest
that could arise as a result of your past representation of gaming companies doing
business in Pennsylvania, and you directed that you be ethically screened from and not
participate in any and all matters involving the regulation and oversight of casino
gaming. In addition, you directed that any and all gaming matters requiring Office of
Attorney General Executive Office attention and oversight be handled by another
attorney in the office. You have submitted a copy of a January 25, 2013, memorandum
from you to the Office of Attorney General Executive Staff documenting your aforesaid
recusal from, and delegation of, any and all matters involving the regulation and
oversight of casino gaming.
You note that when your recusal from gaming matters was previously brought to
the attention of this Commission’s Executive Director, in connection with a request to
have your position removed from the Gaming List maintained by this Commission
pursuant to Section 1512.1(e)(2) of the Gaming Act, 4 Pa.C.S. § 1512.1(e)(2), the
request was granted, and your position was removed from such list.
You assert that because the factual prerequisites necessary to trigger application
of Section 1512.1(a)(1)-(3) of the Gaming Act are not present, you are not subject to the
post-government service prohibitions contained within those provisions.
By letter dated August 12, 2014, you were notified of the date, time and location
of the public meeting at which your request would be considered.
At the public meeting on October 1, 2014, you appeared for the purpose of
answering any questions of this Commission.
III.DISCUSSION:
It is initially noted that determinations under Section 1512.1(e)(1) of the Gaming
Act are issued by the State Ethics Commission to the requester based upon the facts
that the requester has submitted. 4 Pa.C.S. § 1512.1(e)(1). In issuing the determination
based upon the facts that the requester has submitted, this 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. Id. A determination only affords a defense
to the extent the requester has truthfully disclosed all of the material facts. Id.
Section 1512.1(a)(1)-(3) of the Gaming Act provides as follows:
§ 1512.1. Additional restrictions.
(a) Restrictions.--No individual trooper or
employee of the Pennsylvania State Police or
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October 8, 2014
Page 3
employee of the Office of Attorney General or the
department whose duties substantially involve
licensing or enforcement, the development of laws or
the development or adoption of regulations or policy
related to gaming under this part or who has other
discretionary authority which may affect or influence
the outcome of an action, proceeding or decision
under this part shall do any of the following:
(1) Accept employment with or be retained by an
applicant or licensed entity, or an affiliate,
intermediary, subsidiary or holding company of
an applicant or licensed entity, for a period of
two years after the termination of employment.
(2) Appear before the board in any hearing or
proceeding or participate in any other activity
on behalf of any applicant, licensee, permittee
or licensed entity, or an affiliate, intermediary,
subsidiary or holding company of an applicant,
licensee, or licensed entity, for a period of two
years after termination of employment.
Nothing in this paragraph shall prevent a
current or former trooper or employee of the
Pennsylvania State Police, the Office of
Attorney General or the department from
appearing before the board in any proceeding
or hearing as a witness or testifying as to any
fact or information.
(3) As a condition of employment, a potential
employee who would be subject to this
subsection shall sign an affidavit that the
individual will not accept employment with or
be retained by any applicant or licensed entity,
or an affiliate, intermediary, subsidiary or
holding company of an applicant or licensed
entity, for a period of two years after the
termination of employment.
4 Pa.C.S. § 1512.1(a)(1)-(3).
On its face, Section 1512.1(a)(1)-(3) of the Gaming Act would only be applicable
to you if your duties as a First Deputy Attorney General for the Pennsylvania Office of
Attorney General substantially involved licensing or enforcement, the development of
laws or the development or adoption of regulations or policy related to gaming under the
Gaming Act, or if you had other discretionary authority which might affect or influence
the outcome of an action, proceeding or decision under the Gaming Act. Because of
your recusal from, and delegation to another attorney of, all gaming matters, your
position did not include such duties/authority.
The determination of this Commission is that based upon the submitted facts,
upon leaving Commonwealth employment as a First Deputy Attorney General for the
Pennsylvania Office of Attorney General, you would not be subject to Section
1512.1(a)(1)-(3) of the Gaming Act, 4 Pa.C.S. § 1512.1(a)(1)-(3). This determination is
based upon the submitted facts that your duties as a First Deputy Attorney General for
the Pennsylvania Office of Attorney General did not substantially involve licensing or
enforcement, the development of laws or the development or adoption of regulations or
policy related to gaming under the Gaming Act, and that you did not have other
King, 14-2003
October 8, 2014
Page 4
discretionary authority which might affect or influence the outcome of an action,
proceeding or decision under the Gaming Act.
This determination is limited to addressing the specific question posed under
Section 1512.1(e)(1) of the Gaming Act, 4 Pa.C.S. § 1512.1(e)(1).
IV.CONCLUSION:
Based upon the submitted facts, upon leaving
Commonwealth employment as a First Deputy Attorney General for the Pennsylvania
Office of Attorney General, you would not be subject to Section 1512.1(a)(1)-(3) of the
Pennsylvania Race Horse Development and Gaming Act (“Gaming Act”), 4 Pa.C.S. §
1512.1(a)(1)-(3). This determination is based upon the submitted facts that your duties
as a First Deputy Attorney General for the Pennsylvania Office of Attorney General did
not substantially involve licensing or enforcement, the development of laws or the
development or adoption of regulations or policy related to gaming under the Gaming
Act, and that you did not have other discretionary authority which might affect or
influence the outcome of an action, proceeding or decision under the Gaming Act.
An individual who relies in good faith on a determination issued by this
Commission as to such individual pursuant to Section 1512.1(e)(1) of the Gaming Act
shall not be subject to any penalty for an action taken in reliance on the determination,
provided that all material facts are accurately set forth in the request for a determination.
This determination is a public record and will be made available as such.
By the Commission,
John J. Bolger
Chair