HomeMy WebLinkAbout89-561 RiggieriDino P. Riggieri
838 West Baltimore Pike
Kennett Square, PA 19348
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
July 24, 1989
89 -561
Re: Former Public Official Section 3(e), Township Supervisor
Dear Mr. Riggieri:
This responds to your letter of June 14, 1989, in which you
requested advice from the State Ethics Commission.
Issue: You ask whether the Ethics Act presents any restrictions upon
your potential employment following your termination of service with
the Second Class Township Board of Supervisors.
Facts: After noting that you were an elected supervisor in New
Garden Township, Chester County, in November of 1961 and were
reelected in 1968, 1974, 1980 and 1986, you state that you served as
the Chairman of the Board of Supervisors in 1966 - 67, 1972 -73, 1978
- 79 and 1984 - 85 and continued to serve until January 9, 1989 when
you resigned from office for reasons related to health. You advise
that during your ten years with the Township, many changes occurred
including the adoption and readoption of zoning ordinances,
subdivision ordinances, Act 537 Sewage Facilities Plans and other
legislation. You note that as a supervisor, you voted on approvals
and disapprovals of numerous subdivision plans and zoning matters as
well as voted on countless motions relating to a broad spectrum of
normal Township policy and administrative issues. You then advise
that the East end of the Township along Baltimore Pike, for some
years, has experienced problems relative to malfunctions of individual
lot sewage systems. You indicate that the forgoing problem led to an
engineering study at the direction of the Supervisors in July of
1980; based upon the findings and conclusions, the township undertook
an expansion of the sewer collection system which resulted in public
sewer becoming available to the properties abutting near the Baltimore
Pike, Bancroft Road, Chambers Road and some other lesser areas. You
indicate that the proposed improvement would include a new force main
at the Toughkenamon collections system and a new waste water treatment
facility to serve the Township system. After noting that an
application was made and a permit was received by DER for the East End
Dino P. Riggieri
Page 2
Main extension in 1986, permit No. 1586404, you state that in August
of 1988 specifications were prepared for the main portion of the
project. A force main permit was then granted by DER in March of
1989, No. 1588457, and the preliminary engineering was done for the
sewage treatment facility but a permit has not been applied for
because of delays relative to condemnation proceedings involving the
site of the new facility. You state that the condemnation appeal is
in the courts and consequently neither the east end ain extension nor
force main have been constructed. After advising that you own a
substantial amount of undeveloped land abutting Baltimore Pike and
Bancroft Road at several points which property was acquired in
parcels over the years consisting of, in part, 33 acres and 45 acres
acquired in 1970 and 1979 respectively, a 7 acre parcel in 1981 and
3.5 acre parcel in 1987 and lastly an 8.5 acre parcel in 1989, you
indicate your intent to move forward with the land development plan
although actual construction may take place in several years. After
noting that you are a former public official under Act 170 of 1978,
you posed two questions to the commission: The nature of the
prohibitions that exist regarding your land development plans of the
above property vis -a -vis your former role as supervisor wherein you
voted for the adoption of zoning ordinances, subdivision ordinances,
sewer main extension and other issues and secondly, the permissibility
of submitting plans and applications for development if your name
would to appear on such documents before the formal governmental body
with which you are associated. In addition to the above questions,
you request comment on any other issues which may have bearing.
Discussion: As a Township Supervisor for New Garden Township, you are
to be considered a "public official" 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, you would
become a former public official" 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 you were associated while working for New Garden Township must
be identified. Then, the scope of the prohibitions associated with
the concept and term of "representation" must be reviewed. In this
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Page 3
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).
Since it appears that your jurisdiction, responsibility,
influence and control appears to have been the Board of Supervisors of
New Garden Township, your governmental body would be that Board.
Thus, the "governmental body" with which you have been "associated"
upon the termination of your employment would be the New Garden
Township Board of Supervisors, hereafter the Board. Therefore, within
the first year after you would leave New Garden Township, Section 3(e)
of the Ethics Act would apply and restrict your "representation" of
persons or new employers vis -a -vis the Board.
The Ethics Act would not affect your ability to appear before
agencies or entities other than with respect to the Board. Likewise,
there is no general limitation on the type of employment in which you
may engage following your departure from New Garden Township. 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, 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 S1.1.
Dino P. Riggieri
Page 4
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 you have been associated, (that is the Board), including,
but not limited to, negotiations or renegotiations on contracts with
the Board;
2. Attempts to influence the Board;
3. Participating in any matters before board over which you had
supervision, direct involvement, or responsibility while employed by
New Garden Township;
4. Lobbying, that is representing the interests of any person or
employer before the board 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 your name as the person who
will provide technical assistance on such proposal, document, or bid,
if submitted to or reviewed by the Board, constitutes an attempt to
influence your former governmental body. See Kilareski, Opinion 80-
054. Therefore, within the first year after you leave New Garden
Township, you should not engage in the type of activity outlined
above. The Commission, however, has stated that the inclusion of your
name as an employee or consultant on a "pricing proposal," even if
submitted to or reviewed by the Board, is not prohibited as
"representation." See Kotalik, Opinion 84 -007.
You may assist in the preparation of any documents presented to
the Board so long as you are not identified as the preparer. You may
also counsel any person regarding that person's appearance before the
Board. Once again, however, your activity in this respect should not
be revealed to the Board. Of course, any ban under the Ethics Act
would not prohibit or preclude you from making general informational
inquiries of the Board 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 Board your representation of, or work for
your new employer.
Finally, the Commission has concluded that if you are
administering an existing contract as opposed to negotiating or
renegotiating a contract your activities would not be prohibited by
the Ethics Act. See Dalton, Opinion 80 -056 and Beaser, Advice 81 -538.
Dino P. Riggieri
Page 5
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
on 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. §403(b).
As to the specific questions that you have posed under the
Ethics Act, an advisory cannot be as to the first question you pose
since that is past action on your part; advisory opinions may only be
issued as to prospective conduct. Therefore, that question cannot be
answered because all of your action as Township Supervisor occurred in
the past. Turning to your second question, you are advised that the
submission of plans or applications for development before your former
governmental body, the Board, would constitute representation which is
restricted under the Ethics Act, as explained above.
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 New Garden Township Supervisor, you are to be
considered a "public official" as defined in the Ethics Act. Upon
termination of your service with New Garden Township, you would become
a "former public official" subject to the restrictions imposed by
Section 3(e) of the Ethics Act. As such, your conduct should conform
to the requirements of the Ethics Act as outlined above. Your
governmental body for the purpose of the one year representation
restriction is the Board.
Further, should you terminate your employment or service, as
outlined above, you are reminded that the Ethics Act also requires you
to file a Statement of Financial Interests for the year following your
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
Dino P. Riggieri
Page 6
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 S2.12.
,incerely,
` -03
Vincent . Dopko
Chief Counsel