HomeMy WebLinkAbout81-549 SciortinoSTATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
April 10, 1981
ADVICE OF COUNSEL
Henry V. Sciortino
Monessen Redevelopment Authority
Municipal Building
Monessen, PA 15062
Dear Mr. Sciortino:
RE: Former Authority Member, Representation
81 -549
This responds to your letter of October 8, 1980, in which
you, as Executive Director of the Monessen Redevelopment
Authority requested an opinion from the Ethics Commission.
Issue: You requested advice as to what restrictions the Ethics
Act places on your activities as a former Executive Director of
the Monessen Redevelopment Authority.
Facts: You informed us that you plan to leave your part -time
position as Executive Director of the Monessen Redevelopment
Authority (Authority).
Discussion: Municipal Authorities are generally subject to the
Ethics Act. 65 P.S. §401 et seq. See Forney v. State Ethics
Commission, Pa. Commonwealth Ct. A.2d (No.
1003 C.D. 1980). The Act imposes several restrictions on the
behavior of former "public officials" and "public employees."
Specifically, Section 3(e) of the Act prohibits former officials
and employees from representing any person, (including indivi-
duals, businesses, corporations, or associations) on any matter
before the governmental body with which he has been associated
for one year after he leaves that body. 65 P.S. §403(e).
The governmental body with which you are associated is the
Monessen Redevelopment Authority. Accordingly, you may not
make a personal appearance (except on your own behalf) before
the Authority for one year after you leave the Authority.
Morris, 80 -039; Widoff 79 -055. Nor may you attempt to influence
the Authority for one year after leaving the Authority. Cutt,
79 -023.
As a former official or employee you may make general
information inquiries of the Authority similar to tlose made by
the general public. Morris, 80 -039; Cutt, 79 -023. You may
Henry V. Sciortino
April 10, 1981
Page 2
represent third parties in a forum other than the Monessen
Redevelopment Authority. Morris, 80 -039. You may use knowledge
and experience gained as a public employee subject to the above
restrictions. You may administer a contract with your present
Authority if you did not attempt to influence the award of the
contract by, for example, placing you name on the bid proposal.
Kilareski, 80 -054.
Further, Section 4 of the Act requires that you file a
Statement of Financial Interests for the year after you leave
the Authority. 65 P.S. §404.
Conclusion: As a former public official you may not represent
any person, business, corporation, or association on any matter
before the governmental body with which you gave been associated
for one year after leaving the governmental body. The govern-
mental body with which you are associated is the Monessen
Redevelopment Authority.
As a former official you may not:
(1) make personal appearances before the Authority; and
(2) attempt to influence the Authority, such as lobbying
or preparing and signing contract or bid proposals
submitted to the Authority for one year after leaving
the Authority.
As a former official you may
(1) make inquiries for information available to the
general public;
(2) represent persons in a forum other than the Authority;
(3) use knowledge and expertise gained with the Authority,
subject to the above restrictions; and
(4) administer a contract between the Authority and your
present or future employer, provided you did not
attempt to influence the award of the contract.
You must file a statement of financial interests for the
year after leaving the Authority by May 1 after you leave the
Authority.
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 tacts and committed the
acts complained of in reliance on the Advice given.
Henry V. Sciortino
April 10, 1981
Page 3
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 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.
SW /rdp
Sincerely,
Sandra S. Christianson
General Counsel