HomeMy WebLinkAbout84-509 MlakerLeslie J. Mlakar, Esquire
c/o Edward M. Bilik
Loughran, Mlakar & Bilik
704 First National Bank Bldg.
Greensburg, PA 15601
Mailing Address.
STATE ETHICS COMMISSION
P.O. BOX 1179
HARRISBURG, PA 17108
TELEPHONE: (717) 783 -1610
Janauary 18, 1984
ADVICE OF COUNSEL
84 - 509
RE: Former Township Supervisor, Section 3(e), Restricted Activities
Dear Mr. Mlakar:
This responds to your letter of December 22, 1983, in which you requested
advice from the State Ethics Commission.
Issue: You asked what restrictions are placed upon the conduct of an
individual who has recently finished a term as Township Supervisor.
Facts: You indicate that you are writing as Counsel on behalf of Mr. Edward
M. Bilik. Mr. Bilik has been a Supervisor in the Township of Mount Pleasant,
hereinafter the Township, for over 20 years and has recently completed his
terms of office as of January 1, 1984. In addition to serving as a Township
Supervisor, Mr. Bilik also is an insurance agent trading and doing business as
Edward M. Bilik Insurance Agency, hereinafter the Agency. This Agency is
composed of Mr. Bilik who is a licensed insurance broker and Mark J. Bilik,
his son.
The question has been posed as to whether in the calendar year 1984 and
thereafter, Mr. Bilik's Agency can submit proposals to the Township with
respect to the Township's insurance policies or needs. You have rendered an
opinion that under Act 170, the Agency could submit proposals to the Township
provided the Township followed the proper process of considering and awarding
bids regarding their needs. The question is whether Mr. Bilik himself could
personally present these proposals to the Township.
You indicate that your analysis of the Ethics Act is such that if Mr.
Bilik, consistent with Section 3(c) of the Ethics Act, could obtain the
insurance business of the Township while he was serving as a Supervisor, it
would be inconsistent to prohibit him from seeking and securing this insurance
business within the first year after he leaves public office, pursuant to
Section 3(e) of the Ethics Act.
State Ethics Commission • 308 Finance Building • Harrisburg, Pennsylvania
Leslie J. Mlakar, Esquire
January 18, 1984
Page 2
Discussion: As are elected official, Mc 3ilik was a "public official" as that
term is defined in the State Ethics Act. Upon completion of his terms of
office with the Township, Mr Bilik became a "former public official ". As a
"former public official" his conduct must conform to the requirements of
Section 3(e) of the State Ethics Act as set forth below:
(e) No former official or public eployce shall represent
a person, with or without compensation, on any rnatte.r
before the governmental body with which he has been
associated for one year after he leaves that body.
65 P.S. 403(e).
As a former public official Mr. Bilik must, for the first calendar year
following the end of his term of office, refrain from "representation" as the
Commission has futher defined that terra vis -a -vis those governmental bodies
with which he may have been associated.
We begin our review of your request by asking the following questions:
1. What is the scope of the term and activity known as
"representation ?" and
2. To which governmental bodies do the restrictions and prohibitions
against representation extend in Mr. Bilik's case? We will address
this latter question first.
It is clear that as a public official elected to serve within the
Township, Mr. Bilik has been associated with the Township. Therefore, for the
first year following his departure from public office, pursuant to Section
3(e) of the Ethics Act, he faces restrictions with respect to his activities
vis -a -vis the Township.
In response to the first question, it is clear that the Commission has
determined that the term "representation" as defined in the regulations of the
Commission includes at least the following activities:
Representation -- Any act on behalf of any person
including but not limited to the following activities:
personal apperances, 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.
Additionally, decisions of the Ethics Commission clearly indicate that
the concept of the prohibited activity described as "representation" in
Section 3(e) extends to such activities as:
Leslie J. Mlakar, Esquire
January 18, 1984
Page 3
1.
Personal appearances before the Township with which Mr. Bilik was
associated, including but not limited to negotiation or
re- negotiation on contracts;
2. attempts to influence the Township or its personnel;
3. participation in any manner before the Township in a case or matter
over which he had direct supervision, involvement, or responsibility
while Mr. Bilik served the Township; and,
4. lobbying, that is representing the interests of any persons before
the Township where Mr. Bilik served in relation to legislation,
regulations, etc.
In addition, it should be noted that the mere act of signing and
preparing and presenting a proposal which would bear Mr. Bilik's name or would
refer to Mr. Bilik as the person who would serve under the proposal, if
accepted, has been held to constitute an attempt to influence the former
governmental body should such a proposal be presented to or reviewed by that
body, in this case the Township. Therefore, such activity is also prohibited
for the one -year period immediately following the end of Mr. Bilik's term of
office. See Kilareski, 80 -054. This is because the Commission has concluded
that the inclusion of Mr. Bilik's name as preparer or technical advisor on
such a proposal which would be submitted to the Township has the potential for
influencing the decision of the Township -- the body of with which he was
associated -- and is, therefore, prohibited for this one year period. Also
you should know that a submission which is made to an entity other than the
Township which would be reviewed by the Township should, likewise, not include
Mr. Bilik's name as preparer or person who would serve pursuant to the
proposal. See Anderson, 83 -014.
However, the above restrictions that are = applicable to Mr. Bilik as an
individual are personal to him and do not extend to or taint the Agency or
other employees of the Agency where Mr. Bilik may be employed, serve, or act
as owner. See Morris, 80 -039. Accordingly, so long as Mr. Bilik does not
engage in persons appearances or any of the other restricted activities
itemized in Nos. 1 - 4 above and refrains from signing or preparing or being
listed on any proposal that would be submitted to the Township, his Agency may
submit proposals to the Township even within the first year after Mr. Bilik
has ended his term of office as a Supervisor in the Township.
Additionally, while the above - referenced restrictions apply to Mr. Bilik
for the one year period following his term of office with the Township, he may
nevertheless, within the one -year period following his departure from public
service, engage in the following activities:
Leslie J. Mlakar, Esquire
January 18, 1984
Page 4
A. He may administer rather than to negotiate or re- negotiate any
contract that exists or is to be awarded to his Agency so long as
that contract or sub - contract is awarded and entered into without
the inclusion of his name as outlined above.
B. He may make general informational inquiries of the Township so long
as there is no attempt to influence the Township as prohibited
above.
C. He may utilize the knowledge and expertise gained during his tenure
as a public official so long as he does not use any confidential
information gained during his service as a public official.
n. He may appear and represent any person or client before any entity
or governmental body except the Township, as outlined above.
Basically, the restrictions which Mr. Bilik faces are personal to him and
do not necessarily prohibit the Agency from soliciting or securing contracts
with the Township even within the first year after Mr. Bilik ceases to serve
as a Township Supervisor. However, Mr. Bilik may not personally appear before
the Township and must observe the other requirements as set forth above in
order to conform his conduct to the requirements of the State Ethics Act.
Conclusion: Upon Mr. Bilik's departure from public office, he will have
become a "former public official" subject to the restrictions imposed by
Section 3(e) of the Ethics Act. His conduct as a former pubic official must
conform to the requirements of the Act as described above and he must take
note of and abide by prohibited and allowable activities as discussed above.
Additionally, as a former public official, Mr. Bilik is required to file
a Financial Interests Statement for each year._in which he held office and for
the year following his termination of service in office. Thus, a Statement of
Financial Interests should be filed no later than May 1, 1984, which
represents the filing required for the year following his termination of
service with this Township. This Financial Interests Statement will record
information for the calendar year 1983.
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.
Leslie J. Mlakar, Esquire
January 17, 1984
Page 5
SSC /rdp
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.
Sin erely,
Sandra S. Chri ' ianson
General Counsel