HomeMy WebLinkAbout15-542 Powers
ADVICE OF COUNSEL
June 29, 2015
Joseph R. Powers
3713 Woodridge Drive
Harrisburg, PA 17110
15-542
Dear Mr. Powers:
This responds to your letters received April 30, 2015, and May 20, 2015, by
which you requested an advisory from the Pennsylvania State Ethics Commission
(“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 Special
Assistant to the Governor following termination of Commonwealth employment.
Facts:
You request an advisory from the Commission regarding the post-
employment restrictions of the Ethics Act. You have submitted facts that may be fairly
summarized as follows.
In June 2009, you retired from Commonwealth employment. During the last six
years of your Commonwealth employment, you served in positions with the
Pennsylvania Department of Environmental Protection (“Department of Environmental
Protection”). Following your retirement, you taught classes in political science as an
adjunct professor at St. Joseph’s University in Philadelphia, Pennsylvania.
On January 15, 2015, you were asked if you would be interested in being named
to the position of Special Assistant to the Governor. You accepted the position, and you
were sworn in as a Special Assistant to the Governor on January 20, 2015.
You state that for a variety of reasons, you decided not to move forward with the
job, and that you submitted your resignation in a letter dated January 30, 2015. You
further state that you received a paycheck for your short time in the Governor’s Office,
but you never cashed the paycheck.
You note that there is no official position description for your former position as a
Special Assistant to the Governor. You state that during your tenure in the aforesaid
position, you were tentatively assigned to the following state agencies with which you
had the following contact:
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June 29, 2015
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Pennsylvania Emergency Management Agency - you visited the agency to
discuss a snow emergency and had several phone conversations with the
agency’s Director concerning a prospective emergency planning exercise;
Pennsylvania Department of Military and Veterans Affairs - you had two
phone conversations with the Adjutant General to discuss a request for
federal aid and a planned ceremony;
Pennsylvania Department of Corrections - you had a meeting with the
Secretary of Corrections to discuss a prison situation;
Pennsylvania Office of Inspector General - you sat in on a meeting at
which the functions of the agency were discussed;
Pennsylvania Office of the State Fire Commissioner - you had two
conversations with the State Fire Commissioner to discuss general
matters;
Pennsylvania Department of Conservation and Natural Resources - you
had a phone conversation with the Secretary of Conservation and Natural
Resources to discuss personnel matters;
Department of Environmental Protection - your only contact was to
congratulate the Secretary of Environmental Protection on his new
position; and
Pennsylvania State Police - you had no contact with anyone at the
agency.
You state that you were also tentatively to be assigned to work with the
Lieutenant Governor, the Pennsylvania Attorney General, the Pennsylvania State
Treasurer, and the Pennsylvania Auditor General. You had no contact with the
Lieutenant Governor, but you did discuss some matters with his Chief of Staff. You had
one phone call with the Pennsylvania Auditor General, with whom you have a personal
relationship, to inform him of your plans to leave your position with the Commonwealth.
You had no contact with the then-Pennsylvania State Treasurer or the Pennsylvania
Attorney General.
In the fall of 2015, you will be teaching a course entitled “Pennsylvania
Government and Politics” (the “Course”) at St. Joseph’s University. You state that as
you have done in the past, you would like to occasionally bring in guest lecturers to
speak to the Course class. You state that the guest lecturers receive no compensation.
You further state that you receive no compensation from the guest lecturers and that
you make no effort to influence their actions or positions.
In addition to teaching the Course, during the year following termination of your
Commonwealth employment, you might obtain employment with an entity that does
business with the Commonwealth.
Based upon the above submitted facts, you seek guidance as to whether the
Ethics Act would impose prohibitions or restrictions upon you following termination of
your Commonwealth employment. In particular, you pose the following questions:
(1) Whether and to what extent you would be prohibited from engaging in any
professional dealings with the Governor’s Office, such as for example,
offering advice to potential clients or associates about matters that could
relate to the Governor’s Office;
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June 29, 2015
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(2) Whether you would be prohibited from having professional contact with
any or all of the state agencies or offices to which you were tentatively
assigned;
(3) Whether you would be prohibited from having contact with any other state
agencies;
(4) Whether you would be prohibited from having social contact with members
of the Governor’s staff with whom you have had personal relationships or
friendships for many years;
(5) Whether you would be prohibited from having social contact with friends
who are employed with agencies to which you were to be assigned,
including the Department of Environmental Protection; and
(6) Whether you would be prohibited from inviting any state government
officials to speak to the Course class.
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 Special Assistant to the Governor, 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; Marrazzo, Advice 07-549; Bigley, Advice 95-614.
Consequently, upon termination of Commonwealth employment, you became a
former public official/public employee and a former executive-level State employee
subject to the restrictions of Section 1103(g) and Section 1103(i) of the Ethics Act.
Section 1103(i) 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
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).
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June 29, 2015
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Section 1103(i) restricts the ability of a former executive-level State employee to
accept employment or otherwise engage in business relationships following termination
of State service, under certain narrow conditions. The restrictions of Section 1103(i)
apply even where the business relationship is indirect, such as where the business in
question is a client of a new employer, rather than the new employer itself. See,
Confidential Opinion, 94-011. However, Section 1103(i) would not restrict you from
being employed by, receiving compensation from, assisting, or acting in a
representative capacity for a business subject to the conditions that you did not actively
participate in recruiting such business to Pennsylvania, and that you did not actively
participate in inducing such business to open or expand a plant, facility, or branch in
Pennsylvania, through a grant or loan of money or a promise of a grant or loan of
money from the Commonwealth of Pennsylvania.
Unlike Section 1103(i), Section 1103(g) does not prohibit a former public
official/public employee from accepting a position of employment. However, 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.
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June 29, 2015
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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. 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.
Upon termination of your service as Special Assistant to the Governor, the
governmental body with which you are deemed to have been associated--hereinafter
collectively referred to as your “former governmental body”--consists of: (1) the
Governor’s Office in its entirety, including but not limited to the Executive Offices and
the Governor’s Office of Administration; and (2) any boards, commissions, or other
governmental bodies that you served as an employee, appointee/member, or designee
except for those whose members are not considered public officials subject to the
Ethics Act. Cf., Hafer, Opinion 04-016; Confidential Opinion, 01-006; Marrazzo, supra.
Your former governmental body does not include governmental bodies/agencies that
you were assigned to work with but with which you did not hold a position as an
employee, appointee/member, or designee. Confidential Opinion, 01-006.
For the first year following termination of your Commonwealth employment,
Section 1103(g) of the Ethics Act would apply and restrict “representation” of a “person”
before your former governmental body as delineated above.
Your specific questions shall now be addressed.
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June 29, 2015
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In response to your first, second, and third questions, you are advised as follows.
Section 1103(g) of the Ethics Act would not prohibit you from accepting
employment with an entity that does business with the Commonwealth. However,
during the first year following termination of your Commonwealth employment, Section
1103(g) of the Ethics Act would prohibit you from engaging in any activity(ies) that
would involve prohibited representation before your former governmental body as set
forth above.
You are further advised that Section 1103(g) of the Ethics Act would prohibit you
from engaging in professional dealings with the Governor’s Office. However, Section
1103(g) of the Ethics Act would not prohibit you from offering advice to potential clients
or associates about matters that could relate to the Governor’s Office or from having
contact with state agency(ies) not included within your former governmental body as
delineated above.
With regard to your fourth and fifth questions, you are advised as follows.
Section 1103(g) of the Ethics Act would not prohibit you from having social
contact with officials/employees of governmental bodies not included within your former
governmental body as delineated above.
Section 1103(g) of the Ethics Act would not prohibit you from having social
contact with officials/employees of your former governmental body—including but not
limited to members of the Governor’s staff—subject to the condition that in so doing,
you would not engage in conduct that would constitute prohibited representation in
contravention of Section 1103(g). Cf., Conti, Opinion 07-007.
In response to your sixth question, you are advised that Section 1103(g) of the
Ethics Act would prohibit you from inviting state government official(s) from your former
governmental body to speak to the Course class; however, Section 1103(g) of the
Ethics Act would not prohibit you from inviting other state government official(s) to
speak to the Course class.
Based upon the facts that have been submitted, this Advice has addressed the
applicability of Sections 1103(g) and 1103(i) 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.
Conclusion:
In the former capacity as a Special Assistant to the Governor, 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., and the Regulations of the State Ethics Commission, 51 Pa.
Code § 11.1 et seq. Upon termination of your service as Special Assistant to the
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June 29, 2015
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Governor, you became a former public official/public employee and a former executive-
level State employee subject to the restrictions of Section 1103(g) and Section 1103(i)
of the Ethics Act, 65 Pa.C.S. §§ 1103(g), 1103(i). Under Section 1103(i) of the Ethics
Act, you would not be prohibited from being employed by, receiving compensation from,
assisting, or acting in a representative capacity for a business subject to the conditions
that you did not actively participate in recruiting such business to Pennsylvania, and that
you did not actively participate in inducing such business to open or expand a plant,
facility, or branch in Pennsylvania, through a grant or loan of money or a promise of a
grant or loan of money from the Commonwealth of Pennsylvania.
Upon termination of your service as Special Assistant to the Governor, the
governmental body with which you are deemed to have been associated--hereinafter
collectively referred to as your “former governmental body”--consists of: (1) the
Governor’s Office in its entirety, including but not limited to the Executive Offices and
the Governor’s Office of Administration; and (2) any boards, commissions, or other
governmental bodies that you served as an employee, appointee/member, or designee
except for those whose members are not considered public officials subject to the
Ethics Act. Your former governmental body does not include governmental
bodies/agencies that you were assigned to work with but with which you did not hold a
position as an employee, appointee/member, or designee. For the first year following
termination of your Commonwealth employment, Section 1103(g) of the Ethics Act
would apply and restrict “representation” of a “person” before your former governmental
body as delineated above. 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