HomeMy WebLinkAbout15-552 Heeter
ADVICE OF COUNSEL
August 5, 2015
Heather J. Heeter
9011 Franklin Hill Road
East Stroudsburg, PA 18301
15-552
Dear Ms. Heeter:
This responds to your letter dated June 30, 2015 (postmarked July 2, 2015, and
received July 7, 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 Highway
Design Manager following termination of employment with the Pennsylvania
Department of Transportation (“PennDOT”).
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.
You are currently employed as a Highway Design Manager with PennDOT in
Engineering District 5-0 (“District 5-0”). 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 Highway
Design Manager (job code 10340) has been obtained and is also incorporated herein by
reference.
You state that you intend to retire from your Commonwealth employment as of
July 31, 2015, and accept a position as a Highway Leader/Project Manager for a firm
named “Borton Lawson” (the “Firm”).
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 you would be permitted to represent the Firm in marketing
meetings before PennDOT’s Central Office or any PennDOT District
(including District 5-0), the Pennsylvania Turnpike Commission (“Turnpike
Commission”), or any other state, federal, or local agency;
(2) Whether you would be permitted to represent the Firm with regard to
existing contracts that the Firm has with PennDOT’s Central Office or any
PennDOT District (including District 5-0), the Turnpike Commission, or any
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August 5, 2015
Page 2
other federal, state, or local agency, and in particular, whether you would
be permitted to attend design review/project status meetings and public
meetings;
(3) Whether your name could appear on invoices for the Firm on existing
contracts with PennDOT’s Central Office or any PennDOT District
(including District 5-0), the Turnpike Commission, or any other state,
federal, or local agency;
(4) Whether you would be permitted to assist in the preparation of any
documents or designs for the Firm on existing or future contracts with
PennDOT’s Central Office or any PennDOT District (including District 5-0),
the Turnpike Commission, or any other state, federal, or local agency;
(5) Whether your name and credentials could be included on any proposals
for work with PennDOT’s Central Office or any PennDOT District
(including District 5-0), the Turnpike Commission, or any other state,
federal, or local agency;
(6) Whether you would be permitted to seek information—especially if that
information is available to the general public—from PennDOT’s Central
Office or any PennDOT District (including District 5-0), the Turnpike
Commission, or any other state, federal, or local agency, in an effort to
assist in the preparation of designs, proposals, or other deliverables to
PennDOT or other agencies such as the Turnpike Commission; and
(7) Whether you would be permitted to work on design/build or
design/bid/build projects for which the Firm is the designer for a low bid
construction contractor which in turn has a contract with PennDOT’s
Central Office or any PennDOT District (including District 5-0), the
Turnpike Commission, or any other state, federal, or local agency.
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 Highway Design Manager 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; Bendo, Advice 13-563;
McClain, Advice 07-533. 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
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August 5, 2015
Page 3
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
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/
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August 5, 2015
Page 4
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.
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 5-0. 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 addressed.
In response to your first question, you are advised that during the first year
following termination of your employment with PennDOT, Section 1103(g) of the Ethics
Act would prohibit you from representing the Firm in marketing meetings before any unit
of PennDOT, including but not limited to the Districts and the Central Office, as such
activity(ies) would necessarily involve prohibited representation of the Firm before your
former governmental body. Section 1103(g) would not prohibit you from representing
the Firm in marketing meetings before the Turnpike Commission or any other state,
federal, or local agency provided that such activity(ies) would not involve prohibited
representation before PennDOT as delineated above.
With regard to your second and third questions, you are advised as follows.
During the one year period of applicability of Section 1103(g), you would be
prohibited from representing the Firm before any unit of PennDOT, including but not
limited to the Districts and the Central Office, with regard to any matter(s), including
existing contract(s) that the Firm would have with any entity. Section 1103(g) would not
apply to restrict you from representing the Firm before the Turnpike Commission or
other state, federal, or local agencies with regard to existing contracts. However, where
the Turnpike Commission or such other agency(ies) would have involvement with
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August 5, 2015
Page 5
PennDOT, you would need to exercise caution to ensure that you would not engage in
prohibited representation before PennDOT.
Section 1103(g) of the Ethics Act would prohibit you from attending meeting(s)
with PennDOT on behalf of the Firm—including but not limited to design/review project
status meetings and public meetings—as such would necessarily involve prohibited
representation before PennDOT. Section 1103(g) of the Ethics Act would not prohibit
you from attending meeting(s) with the Turnpike Commission or other state, federal, or
local agencies subject to the condition that in performing such activity(ies), you would
not engage in prohibited representation before PennDOT.
Generally, during the one-year period of applicability of Section 1103(g), your
name could not appear on invoices submitted to PennDOT by the Firm. However, if you
would perform work for the Firm on PennDOT contracts that existed before you
terminated your employment with PennDOT, and if such contracts would not involve the
“unit” of PennDOT where you formerly worked, specifically District 5-0, your name could
appear on routine invoices submitted to PennDOT as to those particular pre-existing
contracts if required by the regulations of PennDOT. See, Abrams/Webster, supra.
However, the foregoing is limited to the submission of billing hours. Section 1103(g) of
the Ethics Act would still prohibit you from engaging in conduct falling within the ambit of
prohibited representation before PennDOT as set forth above. Section 1103(g) would
not prohibit your name from appearing on invoices submitted to the Turnpike
Commission or other state, federal, or local agencies by the Firm. However, to the
extent that the Turnpike Commission or such other agency(ies) would have involvement
with PennDOT, you would need to exercise caution to ensure that you would not
engage in prohibited representation before PennDOT as to such invoices, such as, for
example, through the prohibited inclusion of your name on invoice(s) that you know or
reasonably expect will be submitted to PennDOT.
Turning to your fourth and fifth questions, you are advised that Section 1103(g) of
the Ethics Act would prohibit you from assisting in the preparation of documents or
designs for the Firm on existing or future contracts with PennDOT’s Central Office or
any PennDOT District (including District 5-0), the Turnpike Commission, or any other
state or federal agency unless you would be able to do so without engaging in
prohibited representation before PennDOT.
You are further advised that Section 1103(g) of the Ethics Act would prohibit you
from including your name and credentials on proposal(s) for the Firm for work with any
unit of PennDOT, including but not limited to the Districts and the Central Office, as
such activity(ies) would necessarily involve prohibited representation of the Firm before
your former governmental body. Section 1103(g) would not prohibit you from including
your name and credentials on proposal(s) for the Firm for work with the Turnpike
Commission or other state, federal, or local agencies. However, where the Turnpike
Commission or such other agency(ies) would have involvement with PennDOT, you
would need to exercise caution to ensure that you would not engage in prohibited
representation before PennDOT.
In response to your sixth question, you are advised that Section 1103(g) of the
Ethics Act would not prohibit you from making general informational inquiries to
PennDOT’s Central Office or any PennDOT District, including District 5-0, provided that:
(1) the information you would request would be available to the general public; and (2)
such communications would not include prohibited representation as delineated above.
Section 1103(g) of the Ethics Act would not prohibit you from making general
informational inquiries to the Turnpike Commission or other state, federal, or local
agencies.
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August 5, 2015
Page 6
With regard to your seventh question, you are advised that Section 1103(g) of
the Ethics Act would not prohibit you from working on design/build or design/bid/build
projects for which the Firm is the designer for a low bid construction contractor which in
turn has a contract with PennDOT’s Central Office or any PennDOT District (including
District 5-0), the Turnpike Commission, or any other state, federal, or local agency,
subject to the condition that in so doing, you would not engage in prohibited
representation before PennDOT.
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.
Conclusion:
As a Highway Design Manager 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 Engineering District 5-0.
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,
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August 5, 2015
Page 7
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