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HomeMy WebLinkAbout80-504 Hussie•$ FACTS: DISCUSSION: STATE ETHICS COMMISSION P. 0. Box 1179 Harrisburg, PA 17108 January 18, 1980 ADVICE OF CHIEF COUNSEL TO: Edward C. Hussie Chief Counsel to Majority Leader House of Representatives Commonwealth of Pennsylvania RE: Lawyer - Legislator Disclosure Obligations 80 - 504 On this date Edward C. Hussie, Chief Counsel to the Majority Leader of the House of Representatives, asked what are the disclosure responsibilities of lawyer- legis- lators with respect to their clients. On November 7, 1979, the State Ethics Commission issued a ruling, Lowery, 79 -064, requiring lawyer- public officials and lawyer- public employees to disclose the names of those clients who have matters before the governmental body which that public official or public employee represents. The issue before the Commission is what clients must lawyer - legislators disclose? Lawyer - legislators and candidates for the General Assembly must disclose those clients involved in matters with state agencies in matters involving non - ministerial action of such agencies in cases where a member receives $500 adjusted gross income as a result of personal repre- sentation before that agency, or representation by his or her firm. Examples of ministerial activity are as follows: A) The uncontested or routine action by the Commonwealth administrative officers for employees in issuing or renewing licenses, charters, certificates or any other docu- ments of a similar nature; or B) The preparation, filing and review of tax returns and supporting documents required by law; or (7 (- ADVICE OF CHIEF COUNSEL Edward C. Hussie Page 2 - January 18, 1980 C) The preparation, filing and review of engineering and architectural plans, drawings, specifications and reports; or D) Any other initially routine or uncontested preparation, filing, review or other action not enumerated above and considered and normally handled by the Commonwealth or its agencies as a ministerial action.' In the event the regulations which are adopted differ from this Advice, any member is hereby protected from civil and criminal prosecution, as set forth below, pending receipt of an amended form within a reasonable time of the adoption of regulations. Individuals may request a meeting in executive session with the State Ethics Commission on any question relating to the State Ethics Act. CONCLUSION: Lawyer - legislators and candidates for the General Assembly must disclose those clients involved in disputes with state agencies in matters involving non - ministerial action of such agencies in cases where a member receives $500 adjusted gross income as a result of personal repre- sentation before that agency, or representation by his or her firm. 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. A personal appearance before the Commission and a formal opinion will be issued upon your request, if you feel this reply does not suffice. This letter is a public record and will be made available as such. DRM:jc cc: Russell Davis DAVID RITTENHOUSE MORRISON Chief Counsel Taken from Rule 65(A), History of House Resolutions, Page I -33