HomeMy WebLinkAbout88-527 Hafner IIClaude Hafner, II, Esquire
407 1/2 North Hanover Street
Hershey, PA 17033
Dear Mr. Hafner:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PA 17120
TELEPHONE: (717) 783 -1610
March 4, 1988
ADVICE OF COUNSEL
88 -527
Re: Attorney, General Assembly Member, Representation, Section 3(a)
This responds to your letter of January 29, 1988, in which you requested
advice from the State Ethics Commission.
Issue: Whether the State Ethics Act imposes any prohibition or restrictions
upon a member of a General Assembly from representing clients as an attorney
at law before Departments of the Commonwealth of Pennsylvania.
Facts: You state that you represent a client who is a member of the General
Assembly of the Commonwealth of Pennsylvania and who is also an attorney
engaged in the private practice of law. You further state that your client
has been retained by two organizations which seek his legal representation in
cases against the Commonwealth. The first case relates to a facility which
participates in the Department of Public Welfare's (DPW) Medical Assistance
Program. You state that this organization has appealed a determination made
by DPW's Office of Medical Assistance relative to the facility's rate
determination. You note that the appeal will be heard by DPW's Office of
Hearings and Appeals. You then describe the appeal process whereby if either
party is dissatisfied with the initial appeal, a review may be requested by
the Secretary of DPW followed by an appeal of that decision to Commonwealth
Court. In these proceedings wherein both DPW and the organization will have
legal representation, you inquiry as to whether the member may represent the
organization in the DPW appeal process, in Commonwealth Court and in other
courts if an appeal is taken. You also ask whether the member's status as a
minority chairman of a Legislative Committee would have an impact on his
duties under the Ethics Act. The second situation concerns a contract dispute
between a publicly traded corporation and the Department of the Commonwealth.
You state that the contract which related to cost cutting in providing certain
services, was cancelled for reasons allegedly unrelated to the quality of
Claude Hafner, II, Esquire
March 4, 1988
Page 2
service provided by the contractor. It is further noted by you that at the
time of cancellation there was a balance oweing of 500,000 for serves
allegedly provided and unpaid. You note that the contractor has requested the
member to represent him in litigation with the Commonwealth both for the
recovery of payment of services allegedly rendered as well as for the claim
for additional damages. You further state that prior to the actual
litigation, negotiations will take place both with the representatives of the
Department and the Governor's Office in an effort to amicably resolve the
matter without litigation. You then note that the member is a lawyer and
member of the minority party who holds less than 1 /10% of the stock in the
parent company of the contractor. You then inquiry as to whether the member
may represent the contractor in the discussions with the Department and the
Governor's Office prior to the commencement of litigation regarding payment
for prior services and re- negotiation of the contract; whether the member may
represent the contractor in litigation before the Board of Claims as to the
payment for prior services and as to damages for alleged wrongful cancellation
of the contract and whether the member may represent the contractor in
litigation or in the participation in settlement negotiations after litigation
is commenced relative to payment for prior services and re- negotiation of the
contract. You also inquiry as to whether a member status as a minority
chairman of any Legislative Committee would impact upon the advice.
Discussion: As a member of the General Assembly the attorney is a "public
official" as that term is defined in the Ethics Act. 65 P.S. §402; 51 Pa.
Code §1.1. As such, his conduct is subject to the provisions of the Ethics
Act.
Section 3(a) of the Ethics Act provides:
Section 3. Restricted activities.
(a) No public official or public employee shall use his
public office or any confidential information received
through his holding public office to obtain financial gain
other than compensation provided by law for himself, a
member of his immediate family, or a business with which
he is associated. 65 P.S. 403(a).
In the instant matter, you have requested advice as to the conduct of a
member of the General Assembly not as it relates to him as a Legislator but
solely as it relates to his private practice of law regarding representing
private clients before Departments of the Commonwealth of Pennsylvania.
You are probably aware of the case entitled Pennsylvania Public Utility
Bar Association v. Thornburgh, 434 A.2d 1327, 62 Pa. Cmwlth. (19817
affirmed per curiam 450 A.2d 613, 498 Pa. 589 (1982) which deals with the
applicability of Section 3(e) of the Ethics Act to attorneys in the regulation
of their practice of law.
Claude Hafner, II, Esquire
March 4, 1988
Page 3
In light of the recent decision in Pennsylvania Public Utility
Commission Bar Association, supra, where the Court held that Section 3(e) of
the Ethics Act, 65 P.S. 403(e), was an impermissible intrusion upon the
Supreme Court's authority to regulate an attorney's conduct, the State Ethics
Commission has applied this decision to mean that there are no prohibitions
under Section 3(e) of the Ethics Act upon his conduct insofar as that conduct
constitutes the practice of law.
Therefore, insofar as his conduct before the Departments of the
Commonwealth would constitute the practice of law, Section 3(a) of the Ethics
Act also cannot be applied to restrict that proposed activity. Particular
reference should be made to the decision of the Commonwealth Court at Footnote
7, 434 A.2d at page 1331 - 1332. In this note, the Court indicates that any
activity in which the attorney proports to render professional services to a
client may only be regulated by the Supreme Court. The State Ethics
Commission, therefore, must conclude that to the extent that he would
represent a client, as a lawyer, before the Departments of the Commonwealth or
otherwise, Section 3(a) of the Ethics Act would not operate to bar such
activity. If, however, the activities that he intends to undertake do not
fall within the category of the "practice of law ", the prohibiton of Section
3(a) of the Ethics Act might be applicable. However, for the purposes of this
advice, it is assumed that he intends to undertake these activities in the
capacity of lawyer - client, that these activities would constitute the practice
of law and that the provisions of Section 3(a) of the Ethics Act, pursuant to
the mandates of the Supreme Court's ruling would therefore be inapplicable.
Section 3(b) of the Ethics Act provides:
Section 3. Restricted activities.
(b) No person shall offer or give to a public official or
public employee or candidate for public office or a member
of his immediate family or a business with which he is
associated, and no public official or public employee or
candidate for public office shall solicit or accept,
anything of value, including a gift, loan, political
contribution, reward, or promise of future employment
based on any understanding that the vote, official action,
or judgment of the public official or public employee or
candidate for public office would be influenced thereby.
65 P.S. 403(b).
Section 3(b) of the Ethics Act must be referenced in order to provide a
complete response to your inquiry. Under Section 3(b) of the Ethics Act cited
above, which a public official or employee must observe, a public official or
employee must neither offer nor accept anything of value on the understanding
Claude Hafner, II, Esquire
March 4, 1988
Page 4
or with the intention that his judgment would be influenced thereby. It is
assumed such a situation does not exist here. This Section is referenced not
to indicate that any such activity has been or will be undertaken but in an
effort to provide a complete response to your inquiry.
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 in this advice is the applicability of either the
Legislative Code of Ethics or the Code of Professional Responsibility in that
those codes do not involve an interpretation of the Ethics Act.
Conclusion: Section 3(a) does not restrict the activities of a member of the
General Assembly regarding the representation of private clients before the
Departments of the Commonwealth insofar as those activities constitute the
practice of law. The propriety of the proposed conduct has only been
addressed under the Ethics Act. Specifically not addressed is the propriety
of the the proposed conduct under either the Legislative Code of Ethics or the
Code of Professional Responsibility.
Pursuant to Section 7(9)(ii), this Advice is a complete defense in any
enforcement proceeding initiated by the Commission, and evidence of good faith
conduct i n any other civi 1 or crimi nal proceeding, providing the requestor 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 request that the full Commission review this Advice.
A personal appearance before the Commission will be scheduled and a formal
Opinion from the Commission will be issued. Any such appeal must be made, in
writing, to the Commission within 15 days of service of this Advice pursuant
to 51 Pa. Code 2.12.
cerely,
Vincent a. Dopko
General Counsel