HomeMy WebLinkAbout15-520 McCombie
ADVICE OF COUNSEL
March 17, 2015
John L. McCombie, P.E.
113 Merchant Street
Johnstown, PA 15904
15-520
Dear Mr. McCombie:
This responds to your letter dated January 21, 2015, and your submission
received February 13, 2015, 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 restrictions upon employment of a Senior Civil
Engineer Supervisor – Transportation following termination of employment with the
Pennsylvania Department of Transportation (“PennDOT”).
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.
You are currently employed as a Senior Civil Engineer Supervisor –
Transportation with PennDOT in District 10-0. You have submitted a copy of your
official Commonwealth position description, which document is incorporated herein by
reference. A copy of the job classification specifications for the position of Senior Civil
Engineer Supervisor – Transportation (job code 1114T) has been obtained and is also
incorporated herein by reference.
You are considering terminating your employment with PennDOT and accepting
employment with an engineering consultant that does work on PennDOT projects.
You seek guidance as to whether the Ethics Act would impose prohibitions or
restrictions upon you following termination of your employment with PennDOT. In
particular, you pose the following questions:
(1) Whether you would be permitted to perform bridge and highway design for
state projects in accordance with the standards set by PennDOT and any
other state, federal, or local governmental body;
(2) Whether the appearance of your name on any invoices or other formal
submissions to PennDOT would be considered representing yourself
before PennDOT;
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March 17, 2015
Page 2
(3) Whether you would be permitted to assist in the preparation of any
documents submitted to PennDOT where your name would not appear on
such documents;
(4) Whether you would be permitted to review any documents or plans that
another person has prepared for submission to PennDOT; and
(5) Whether you would be prohibited from working on P3 projects for one of
the sub-consultants teaming with the winning bidder of the P3 contract.
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 Civil Engineer Supervisor – Transportation for PennDOT, 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; DeLacio,
Advice 15-516; Sokoloski, Advice 14-558; Rusiewicz, Advice 13-577. 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 termination of your employment with PennDOT, you would
become a "former public employee" 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
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March 17, 2015
Page 3
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
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 (hereinafter referred to as a “pre-existing contract”).
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
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March 17, 2015
Page 4
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 body with which you would be deemed to have been
associated upon termination of your employment with PennDOT would be PennDOT in
its entirety, including but not limited to District 10-0. Therefore, for the first year
following termination of your employment with PennDOT, Section 1103(g) of the Ethics
Act would apply and restrict “representation” of a “person” before PennDOT.
Having set forth the restrictions of Section 1103(g) of the Ethics Act, your specific
questions shall now be considered.
In response to your first and fifth questions, you are advised as follows.
Section 1103(g) of the Ethics Act would not prohibit you from accepting
employment with an engineering consultant that does work on PennDOT projects.
However, during the first year following termination of your employment with PennDOT,
Section 1103(g) of the Ethics Act would prohibit you from engaging in any activity(ies)
that would involve prohibited representation before PennDOT as delineated above.
Section 1103(g) of the Ethics Act would prohibit you from performing bridge and
highway design for state projects or working on P3 projects for one of the sub-
consultants teaming with the winning bidder of the P3 contract unless you would be able
to do so without engaging in prohibited representation before PennDOT as set forth
above.
With regard to your second question, you are advised as follows.
The appearance of your name on invoices to PennDOT would constitute
prohibited representation of yourself and/or your new employer before PennDOT unless
such invoices would be under pre-existing contract(s) that would not involve District 10-
0. Abrams/Webster, supra. The appearance of your name on other formal submissions
to PennDOT would constitute representation of yourself and/or your new employer
before PennDOT and would be prohibited as delineated above.
Your third question has been addressed above.
In response to your fourth question, you are advised that Section 1103(g) of the
Ethics Act would not prohibit you from reviewing documents or plans that another
person has prepared for submission to PennDOT subject to the condition that in so
doing, you would not engage in any activity(ies) that would involve prohibited
representation before PennDOT as set forth above.
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.
McCombie, 15-520
March 17, 2015
Page 5
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.
Conclusion:
As a Senior Civil Engineer Supervisor – Transportation for the
Pennsylvania Department of Transportation (“PennDOT”), 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 termination of your employment with PennDOT, you would
become a "former public employee" subject to Section 1103(g) of the Ethics Act. The
former governmental body would be PennDOT in its entirety, including but not limited to
District 10-0. For the first year following termination of your employment with PennDOT,
Section 1103(g) of the Ethics Act would apply and restrict “representation” of a “person”
before PennDOT. The restrictions as to representation outlined above must be
followed. 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