HomeMy WebLinkAbout80-726 Della GuardiaSTATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
October 21, 1980
ADVICE OF CHIEF COUNSEL
Joseph L. Della Guardia, Esquire
612 Two Penn Center Plaza
15th & J. F. Kennedy Blvd.
Philadelphia, PA 19102
80 -726
RE: Section 3(e), Deputy Commissioner, Philadelphia
Dear Mr. Della Guardia:
This responds to your inquiry of September 22, 1980.
Issue: You request an opinion in regard to the extent of
the prohibition contained in Section 3(e) of the Ethics Act
as applied to a former public employee, a Deputy Commissioner
for the City of Philadelphia, Department of Licenses and
Inspections.
Facts: You indicated that you served as one of the two
Deputy Commissioners for the City of Philadelphia in the
Department of Licenses and Inspections from March 31, 1975
until January 21, 1980. The Department of Licenses and
Inspections is one of the ten operating departments in the
City of Philadelphia. The Deputy Commissioners, such as
yourself are appointed by the Mayor and serve at the
pleasure of the Mayor. While the Commissioner has the
responsibility for the entire department, each Deputy
Commissioner has jurisdiction only over those sections
within the department to which he is specifically assigned.
In this capacity you were responsible for the following
sections: The Bureau of Weights & Measures; Licenses
Issuance section; the Enforcement section, and the Service
and complaint section. The other Deputy Commissioner had
jurisdiction over the remaining sections within the Depart-
ment of Licenses and Inspections. These departments
included: Field operations; the Building section; Mechanical
services; Commercial and Industrial; and Zoning. With
specific reference to this latter section, the Zoning section,
it is noted that anyone aggrieved by the action taken by
the Zoning section could appeal to the Zoning Board of
Adjustment.
Joseph L. Della Guardia, Esquire
October 21, 1980
Page 2
You indicate that you had no specific involvement or
jurisdiction over those areas other than those to which you
were assigned. You had no involvement or jursidiction over
those areas which were assigned to the other Deputy Commissioner.
However, the Enforcement Section over which you had responsi-
bility, did handle prosecution of violations of the codes
which were within the jurisdiction of other Sections of your
Department.
In regard to the Zoning Board of Adjustment it must be
noted that the Board consists of six members, five of whom
are appointed by the Mayor while the sixth member is the
Commissioner of the Department of Licenses and Inspections,
as an ex officio member. While the Commissioner of Licenses
and Inspections may substitute a Deputy Commissioner to
serve on his behalf on the Zoning Board of Adjustments you
indicate that you have not been so designated as the substi-
tute for the Commissioner for some three years prior to your
departure from the Department, January 21, 1980. You
further note that any decision of the Zoning Board of
Adjustment is considered a determination of an independent
board which is appealable directly to court.
Discussion: First it should be noted that there is no
dispute or doubt that you are a "public employee as that
term is defined in the Ethics Act. Therefore, as a "former
public employee" you would be subject to the prohibitions
found in Section 3(e) of the Ethics Act. This section
indicates that no former public employee may represent any
person on any matter before the governmental body with which
he had been associated for a period of one year after he
leaves that body. While the provisions of Section 3(e) of
the Act are applicable, your specific question relates to
the extent of prohibition in your case. Specifically, you
inquire as to whether you are precluded from appearing
before the Zoning Board of Adjustment and representing any
person before that Board.
Essentially, the question to be answered is the extent
of your "governmental body." The Commission has in previous
decisions indicated that Section 3(e) was to be interpreted
to preclude representation before a "governmental body" over
which the former employee had or could have had authority or
influence. For example, in Kline, 79 -001 the former
Lieutenant Governor of the Commonwealth was deemed to have
been associated with the Senate, the Lieutenant Governor's
Office, the Board of Pardons, the Governor's Office and all
Joseph L. Della Guardia, Esquire
October 21, 1980
Page 3
executive departments, boards, agencies and commissions.
The extent of this prohibition and the reasons for the
prohibition were based on the determination that the
Lieutenant Governor was "associated with" the entities
described. Likewise, the Commission has determined that the
prohibition may extend to the whole department, where the
individual involved worked in or with a whole department to
the extent that he could be said to have "influence" over
the entire Department. Cutt, 79 -023.
We must note, two decisions of the Commission which are
particularly pertinent in regard to your specific question
of whether you may appear before the Zoning Board of Adjust-
ment. These are Berger /Beaser, 79 -060 and Kuller, 80 -004.
In Berger, a former member of the Law Bureau of the City of
Philadelphia who represented primarily the Zoning Board of
Adjustment was precluded from appearing or representing any
person before the Zoning Board of Adjustment only, rather
than the whole entity of the City of Philadelphia. Similarly,
in Kuller, a former borough councilman was not precluded
from representing any person before the borough's zoning
hearing board. The Commission ruled that the zoning hearing
board was not the same "governmental body" as the borough
council and that, therefore, the provisions of Section 3(e)
would not preclude the former borough councilman from repre-
senting any person before the borough's zoning hearing
board.
Consequently, on facts as you have presented them,
which indicate quire clearly that you had no authority or
juridiction of the Zoning Board of Adjustment, you would not
be precluded from appearing before that board or represen-
ting any person before that board. Essentially, the term
"governmental body" with which you had been associated is
the Department of Licenses and Inspections - because you may
be said to have "influence" within that Department. The
independence of the Zoning Board supports its exclusion from
the phrase "governmental body" in your case.
Having decided that the Department of Licenses and
Inspections constitutes the "governmental body" with which
you had been associated, you should be advised that decisions
of the Commission have addressed the question of what consti-
tutes "representation." In particular, the decision rendered
in Morris, 80 -039 generally indicates that:
1. personal appearance before the governmental body
is prohibited for the one -year period;
2. attempts to influence the governmental body are
prohibited for the one -year period;
Joseph L. Della Guardia, Esquire
October 21, 1980
Page 4
3. a former public employee or official is prohibited
by the Ethics Act and the applicable provisions of
the Code of Professional Responsibility from
participating in any case over which he or she had
supervision, direct involvement or responsibility
while associated with the governmental body;
4. members of the former public employee's firm are
not barred from representing clients before the
governmental body with which the former public
employee was associated;
5. general informational inquiries on matters which
are subject to inquiry by the general public are
not prohibited, even as to the governmental body
named above;
6. former public employees are not barred from
generally utilizing the knowledge and expertise
gained from there tenure as public employees
except as set forth above;
7. Appearance in a third form such as State or
Federal Court is not prohibited.
Incidentally, one final note as to your obligations
under the Ethics Act should be made. Section 4(a) indicates
that you must file a Statement of Financial Interest each
year you are employed by a governmental body and by May 1 of
the year after you leave a public employment. You should
file such a statement by May 1, 1981.
Conclusion: You are not prohibited by Section 3(e) of the
Ethics Act from appearing before the Zoning Board of Adjust-
ment for the reasons set forth above. The "governmental
body" with which you were associated while serving as a
Deputy Commissioner, City of Philadelphia, is the Department
of Licenses and Inspections excluding the Zoning Board of
Adjustment. As to this governmental body, you are prohi-
bited from "representing any person" before the Department
for a period of one year from the date you left the employ
of the City of Philadelphia, January 21, 1980. The term
"representation" is as set forth above, and you must not
engage in any of the activities within categories 1, 2 and 3
above.
Joseph L. Della Gaurdia, Esquire
October 21, 1980
Page 5
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.
This letter is a public record and will be made avail-
able 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 may be scheduled and a formal Opinion
from the Commission will be issued. You should make such a
request or indicate your disapproval of this Advice within
the next 30 days.
SSC /rdp
Sincerely,
ndra S. Ch stianson
General Cou el