HomeMy WebLinkAbout89-549 MeyerSTATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
June 6, 1989
Evan Meyer 89 -549
Assistant City Solicitor
Law Department
15th Floor, Municipal Services Building
Philadelphia, PA 19102 -1692
Re: Former Public Employee; Section 3(e), Commerce Director,
City of Philadelphia; Philadelphia Industrial Development
Corporation
Dear Mr. Meyer:
This responds to your letter of May 3, 1989, in which you
requested advice from the State Ethics Commission.
Issue: You ask whether the Ethics Act presents any restrictions
upon the employment of a commerce director with an industrial
development corporation following his termination of service with
the commerce department.
Facts: At the direction of William P. Hankowsky, who was
Commerce Director for the City of Philadelphia, hereinafter
Philadelphia, until April 1, 1989, you request an advisory
opinion from the Ethics Commission regarding the post - employment
restrictions upon Mr. Hankowsky as President of the Philadelphia
Industrial Development Corporation, hereinafter PIDC. After
stating that PIDC is a public non - profit corporation, the purpose
of which is "to promote the industrial and economic development
of the City of Philadelphia ", you note that PIDC was designated
as the official industrial development agency for Philadelphia as
per the Industrial Development Assistance Law, the Act of May 31,
1956, P.L. 1911, 73 P.S. SS351 -358. You then recite the purpose
for the Industrial Development Assistance Law which is, in part,
to provide assistance to counties on matching grant basis for
purpose of planning and promoting programs designed to stimulate
the establishment of new or enlarged industrial, commercial and
manufacturing enterprises. You then assert that Philadelphia
accomplishes the foregoing through a cooperative program among
Philadelphia, PIDC and the Philadelphia Authority for Industrial
Development, hereinafter PAID. After stating that PAID is an
Evan Meyer
June 6, 1989
Page 2
authority organized under the Industrial Development Authority
Act, the Redevelopment Area Economic Cooperation and
Implementation Act and finally the Industrial and Commercial
Development Authority Law which are codified at 73 P.S. SS301-
386, you recite the various duties and responsibilities of PAID.
You then note that PIDC has various contracts with Philadelphia
which may be categorized into three kinds of agreements:
(1) contracts to pass on Philadelphia, Federal or State
moneys as loans to companies to create jobs,
(2) contracts to manage projects for Philadelphia and
(3) contracts wherein PIDC nominates purchases for property
of Philadelphia to be disposed of by PAID.
In addition, you note that PIDC is under contract with
Philadelphia to provide certain services including the staffing
of the Developer Services Committee. In the latter regard, you
note that PIDC assists developers relative to agenda preparation
of issues to be reviewed by the Developer Services Committee.
You then assert that PIDC's role is similar to the Commerce
Department in that both entities provide assistance to developers
so that they will understand requirements necessary for obtaining
requisite approvals. You then conclude that PIDC acts in a
capacity of an agent for the Commerce Department. After raising
the issue as to whether Mr. Hankowsky as President of PIDC may
represent that agency before the Philadelphia Commerce Department
in matters relating to contracts, present and future, you express
your view that the State Ethics Act would not restrict such
activities on the part of Mr. Hankowsky. You then cite several
advisory opinions of this Commission, such as Heverlina, Advice
of Counsel No. 88 -540 and Haaan, Opinion No. 84 -19 wherein it was
determined that an exception exists as to the applicability of
Section 3(e) of the Ethics Act as to certain intra - governmental
employment transfers. According to your analysis, the exception
relates to the recognition that the general concerns of Section
3(e) of the Ethics Act regarding termination of state service
followed by employment with a non - governmental employer do not
exist in situations of employment by another governmental body.
In addition, you cite Appeal of German, 27 Pa. Commw. 108, 366
A.2d 311 (1976), which involves the status of Harristown
Development Corporation, and conclude that PIDC is not a private
enterprise but is rather in the nature of a quasi- governmental
agency. You finally request advice as to whether Section 3(e) of
the Ethics Act restricts Mr. Hankowsky's employment with PIDC and
if so the precise nature of the restrictions, noting that prior
advisory opinions of the Commission have allowed for the
administering of existing contracts as to individuals who have
Evan Meyer -
June 6, 1989
Page 3
terminated their governmental service and obtained employment
with another entity.
Discussion: As a former Commerce Director for City of
Philadelphia, Mr Hankowsky is to be considered a "public
employee" within the definition of that term as set forth in the
Ethics Act and the regulations of this Commission. 65 P.S. S402;
51 Pa. Code S1.1.
Consequently, upon termination of this employment, he would
become a "former public employee" subject to Section 3(e) of the
Ethics Act. Section 3(e) of the Ethics Act provides that:
Section 3. Restricted activities.
(e) No former official or public employee
shall represent a person, with or without
compensation, on any matter before the
governmental body with which he has been
associated for one year after he leaves that
body. 65 P.S. S403.
Initially, to answer your request the "governmental body"
with which he was associated while working with the Philadelphia
Commerce Department must be identified. Then, the scope of the
prohibitions associated with the concept and term of
"representation" must be reviewed. In this context, the Ethics
Commission has previously ruled that the "governmental body" with
which an individual may be deemed to have been associated during
his tenure of public office or employment extends to those
entities where he had influence, responsibility, supervision, or
control. See Ewina, Opinion 79 -010. See also Kury v.
Commonwealth of Pennsylvania, State Ethics Commission, 435 A.2d
940 (1981).
From the description and analysis of his duties and
responsibilities and based upon the facts outlined above, his
jurisdiction, responsibility, influence and control appears to
have been Philadelphia Department of Commerce. Thus, the
"governmental body" with which he was "associated" upon the
termination of his employment would be Philadelphia Commerce
Department. Therefore, within the first year after he would
leave Philadelphia Department of Commerce, Section 3(e) of the
Ethics Act would apply and restrict his "representation" of
persons or new employers vis -a -vis Philadelphia Department of
Commerce.
You, however, argue that the restrictions of Section 3(e)
have no application to this case on the theory that Mr. Hankowsky
Evan Meyer
June 6, 1989
Page 4
will now be employed by PIDC which is a quasi - governmental
agency. In particular, you assert that Mr. Hankowsky comes
within the exception regarding intra - governmental transfers
which are discussed in the Hagan and Heverlina supra.
The exception set forth in the foregoing advisories have
application only if Mr. Hankowsky is transferring from one
governmental body to another. Although it is clear the
Philadelphia Department of Commerce is a governmental body, the
question as to the nature of the PIDC is in question. The
Industrial Development Assistance Law in Section 3 defines and
"Industrial Development Agency ", in part, as follows:
The term "industrial development agency" shall mean any
nonprofit corporation, organization, association or
agency which shall be designated by proper
resolution..." 73 P.S. 353.
Thus, an industrial development agency is statutorily
defined not as a quasi - governmental agency but as a nonprofit
corporation. See also 252 Op. Att'y. Gen. 82 (1962), wherein
the Attorney General of Pennsylvania opined as to whether a
I.D.A. would be subject to the minimum wage law which was
applicable only as to "public bodies ". The Attorney General
concluded that the I.D.A.'s were private local nonprofit agencies
rather than public bodies even though they received funding from
public bodies. In arriving at his decision the Attorney General
noted that the mere receipt or dispersal of public funds did not
raise an agency to the level of an instrumentality of the state.
Since Appeal of_,German did not define the nature of I.D.A.'s,
the case appears to have no applicability or relevance to the
instant matter. Therefore, PIDC is not a governmental entity.
Turning now to the question of the restrictions which the
Ethics Act would impose upon Mr. Hankowsky in his new employment
with the PIDC, it is noted that the Ethics Act would not affect
his ability to appear before agencies or entities other than
with respect to the Philadelphia Department of Commerce.
Likewise, there is no general limitation on the type of
employment in which he may engage, following his departure from
Philadelphia Department of Commerce. It is noted, however, that
the conflicts of interest law is primarily concerned with
financial conflicts and violations of the public trust. The
intent of the law generally is that during the term of a person's
public employment he must act consistently with the public trust
and upon departure from the public sector, that individual should
not be allowed to utilize his association with the public sector,
officials or employees to secure for himself or a new employer,
treatment or benefits that may be obtainable only because of his
association with his former public employer. See Anderson,
Evan Meyer
June 6, 1989
Page 5
Opinion 83 -014; Zwikl, Opinion 85 -004.
In respect to the one year representation the Ethics
Commission has promulgated regulations to define "representation"
as follows:
Section 1.1 Definitions.
Representation - -- Any act on behalf of any
person including but not limited to the
following activities: personal appearances,
negotiating contracts, lobbying, and
submitting bid or contract proposals which
are signed by or contain the name of the
former public official or public employee.
51 Pa. Code $1.1.
The Commission, in its opinions, has also interpreted the
term "representation" as used in Section 3(e) of the Ethics Act
to prohibit:
1. Personal appearances before the governmental body or
bodies with which he has been associated, (that is Philadelphia
Department of Commerce), including, but not limited to,
negotiations or renegotiations on contracts with the Philadelphia
Department of Commerce;
2. Attempts to influence Philadelphia Department of
Commerce;
3. Participating in any matters before Philadelphia
Department of Commerce over which he had supervision, direct
involvement, or responsibility while employed by Philadelphia;
4. Lobbying, that is representing the interests of any
person or employer before Philadelphia Department of Commerce in
relation to legislation, regulations, etc. See Russell, Opinion
80 -048 and Seltzer, Opinion 80 -044.
The Commission has also held that preparing and signing a
proposal, document or bid, or listing his name as the person who
will provide technical assistance on such proposal, document, or
bid, if submitted to or reviewed by Philadelphia Department of
Commerce, constitutes an attempt to influence his former
governmental body. See Kilareski, Opinion 80 -054. Therefore,
within the first year after he leaves Philadelphia Department of
Commerce, he should not engage in the type of activity outlined
above. The Commission, however, has stated that the inclusion
of his name as an employee or consultant on a "pricing
Evan Meyer
June 6, 1989
Page 6
proposal," even if submitted to or reviewed by Philadelphia
Department of Commerce, is not prohibited as "representation."
See Kotalik, Opinion 84 -007.
He may, assist in the preparation of any documents
presented to Philadelphia Department of Commerce so long as he
is not identified as the preparer. He may also counsel any
person regarding that person's appearance before Philadelphia
Department of Commerce. Once again, however, his activity in
this respect should not be revealed to the Philadelphia
Department of Commerce. Of course, any ban under the Ethics Act
would not prohibit or preclude him from making general
informational inquiries of Philadelphia Department of Commerce to
secure information which is available to the general public.
See Cutt,, Opinion 79 -023. This, of course, must not be done in
an effort to indirectly influence these entities or to otherwise
make known to the Philadelphia Department of Commerce his
representation of, or work for his new employer.
Finally, the Commission has concluded that if he is
administering an existing contract as opposed to negotiating or
renegotiating a contract, his activities would not be prohibited
by the Ethics Act. See Dalton, Opinion 80 -056 and Beaser, Advice
81 -538.
Additionally, it is noted that Section 403(b) of the State
Ethics Act would prohibit any public employee or public official
from accepting a position of employment if said position has
been offered based upon the understanding that the official
conduct of the employee or official, while working for his former
governmental body, was influenced by such offer. See 65 P.S.
5403(b).
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.
Conclusion: As a former Commerce Director, Mr Hankowsky is to be
considered a "public employee" as defined in the Ethics Act.
Upon termination of his service with Philadelphia Department of
Commerce, he would become a "former public employee" subject to
the restrictions imposed by Section 3(e) of the Ethics Act. As
such, his conduct should conform to the requirements of the
Ethics Act as outlined above. His governmental body for the
purpose of the one year representation restriction is
Philadelphia Department of Commerce.
Evan Meyer
June 6, 1989
Page 7
Further, since Mr. Hankowsky has terminated his employment
or service, as outlined above, he is reminded that the Ethics
Act also requires him to file a Statement of Financial Interests
for the year following his termination of service.
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 in any other civil
or criminal proceeding, providing the requestor has disclosed
truthfully all the material facts and committed the acts
complained of in reliance on the Advice given.
such.
This letter is a public record and will be made available as
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 in writing
and must be received at the Commission within 15 days of the date
of this Advice pursuant to 51 Pa. Code 52.12.
SiryQerely,
O
Vincent 3! Dopko,
General Counsel