HomeMy WebLinkAbout83-603 NickleachMr. Joseph A. Nickleach, Esquire
Nickleach & Owen
310 Maket Street
Kittanning, PA 16201
RE: Municipal Authority, Contracting
Dear Mr. Nickleach:
Mailing Address.
STATE ETHICS COMMISSION
P.O. BOX 1 179
HARRISBURG, PA 17108
TELEPHONE: (717) 783 -1610
October 17, 1983
ADVICE OF COUNSEL
83 -603
This responds to your letter of September 28, 1983, in which-you
requested advice from the State Ethics Commission.
Issue: You ask whether a member of an Authority, which you serve as
Solicitor, may engage in contracting under certain circumstances with the
Authority.
Facts: You are Solicitor for a Municipal Water Authority, hereinafter the
Authority, and as such requested advice from the State Ethics Commission. You
ask us to assume that the Authority members receive a small payment for
attending meetings and to assume that this payment is not reimbursement for
actual expenses.
The Authority is in the pcocess of building a new water - treatment plant.
Specifications have been drawn by the Authority engineer and the particular
Authority member about whose conduct you raise this question had nothing to do
with the drafting of specifications. Bidding will be undertaken in accordance
with the Municipal Authorities Act and the project will be duly advertised and
bids opened at a public meeting and awarded in accordance with the
requirements of the Municipal Authority Act.
The particular Authority member in question may wish to submit a bid for
this project. You indicate that you have drawn the conclusion from your own
research and from previous conversations with this office that so long as:
(1) the bidding process is an open and public one; (2) this particular
Authority member had nothing to do with the drafting of the specifications;
(3) the particular Authority member who may wish to contract to the Authority
does not participate in any way in the discussions or voting on the awarding
State Ethics Commission • 308 Finance Building • Harrisburg, Pennsylvania
Mr. Joseph A. Nickleach, Esquire
October 17, 1983
Page 2
of the contracts, then he may remain a member of the Authority and bid on the
Authority's project. Likewise, it is also your understanding that if this
particular Authority member resigns from the Authority, he would be prohibited
from dealing directly with the Authority for a period of one -year after he
would leave the Authority.
Discussion: Based on your assumption that these individuals are appointed and
receive compensation which is not reimbursement for actual expenses, we will
assume that the Authority members are "public officials" as that term is set
forth in the Ethics Act, 65 P.S. 402. Accordingly, the conduct of this
particular Authority member as a "public official" would be governed by the
Ethics Act. While the Ethics Act contains some restrictions against contracts
between the business with which a "public official" is associated and the
governmental body with which the official is associated, the Ethics Act does
not totally prohibit a public official or his family or business from engaging
in business activities or contracting, in general with the body he serves.
Section 3(a) of the Ethics Act provides that no public official shall use
his public office or any confidential information obtained through holding
public office to acquire financial gain for himself, his immediate family, or
a business with which he is associated. 65 P.S. 4503(a). A "business with
which he is associated" is defined in the Ethics Act as follows:
"Business with which he is associated." Any business in
which the person or a member of the person's immediate
family is a director, officer, owner, employee or holder
of stock. 65 P.S. 402.
For purposes of this Advice, we will assume that the individual Authority
member in question is a director, officer, owner, or employee or holder of
stock of the business which would seek to contract with the Authority. As
such, then the Authority member would be "associated" with this business and
would be required to observe the prohibitions set forth in Section 3(a) of the
Ethics Act. This means that the Muncipal Authority member could not use his
position as a member of the Authority to secure financial gain for his
business and could not use any confidential information acquired through the
holding of public office on the Authority to the benefit of that business.
Thus, you are correct that the Municipal Authority member should not
participate in any decisions, discussions, or recommendations that would lead
the Authority to award the contract in question to his business. Since you
have indicated that this individual was not involved with the drafting of
specifications for the bid proposals, it would also seem that the requirement
that he not acquire or use confidential information to the benefit of his
business is also being met.
Mr. Joseph A. Nickleach, Esquire
October 17, 1983
Page 3
Section 3(b) of the Ethics Act also states, no person shall give to a
public official or employee nor shall any public official or employee accept
anything of value based on the understanding that the officials vote, action,
or judgment would be influenced thereby. See 65 P.S. 403(b). The Authority
member who would seek to contract with the Authority must be cognizant of this
requirement and observe this provision of the Ethics Act. Reference to this
Section is made not to indicate that any violation or potential violation
exists but merely to provide a complete review of the Sections of the Ethics
Act which may be generally applicable to the individual members of the
Authority.
Further, Section 3(c) of the Act states that no public official, member
of his immediate family, or a business in which the person or member of his
immediate family is an officer, director, or owner of greater than 5% of the
equity at fair market value may contract in an amount in excess of $500 with
the governmental body with which the official is associated unless the
contract has been awarded through an open and public process. See Howard,
79 -044. In this Advice we will also assume that the individual Authority
member who wishes to contract with the Authority is either an officer,
director, or owner of greater than 5% of the equity at fair market value of
the business in question. Assuming this, you should be advised of previous
Opinions of the Commission held that the term "governmental body" in Section
3(c) refers to the governmental body with which the individual is
"associated." Bryan, 80 -014 and Lynch, 79 -047. The "governmental body" with
which the Authority member is associated is clearly the Authority. Therefore,
the open and public process requirements of Section 3(c) would apply if and
when the Authority member's business would seek to contract with the Authority
in an amount in excess of $500.
It should be emphasized, however, that Section 3(c) presents no absolute
prohibition to the contract between the Authority and this business. Section
3(c) has been interpreted by the Commission to require the following:
1. prior public notice of the contract possibility;
2. public disclosure of all proposals considered; and
3. public disclosure of the award of the contract.
In determining whether the requirements of Section 3(c) of the Ethics Act
had been met, the Commission has adopted a "reasonableness test" which means
that reasonable and prudent competitors of the Authority members business
should be provided a sufficient time within which to submit their proposals
and, of course, should have had prior notice of the opportunity to secure such
a contract. Since you indicate that the Authority will be advertising for and
receiving bids in relation to this contract, it is clear that the open and
public process requirements of the Ethics Act will be met.
.r. Joseph A. Nickleach, Esquire
October 17, 1983
Page 4
Finally, you ask whether, if the Authority member were to resign, whether
he would be faced with any restrictions on his activity vis -a -vis the
Authority within the first year after his resignation from the Authority.
Section 3(e) of the Ethics Act regulates the conduct of "former public
officials" as follows:
(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. 403(e).
It is obvious that upon resignation from the Authority, this individual
would become a "former public employee" whose conduct would be subject to the
restrictions of Section 3(e). Further, you should be advised that the term
"representation" has been interpreted by the Ethics Commission to preclude
such activities as:
1. personal appearances before the governmental body with which the
individual has been associated, in this case the Authority and this
personal appearance restriction has been interpreted to include
negotiating contracts with that body;
2. attempts to influence the governmental body;
3. participating in any manner before the former governmental body in
any case or matter over which the individual former public official
had supervision, direct involvement, or responsibility while
employed or serving on the governmental body, in this case the
Authority;
4. lobbying, that is representing the interests of any person before
the Authority to influence that body in relation to legislation,
regulations, etc.
Opinions of the Commission further indicate that a former public employee
may appear in a third forum such as state or federal court, may make general
informational inquiries of the governmental body with which he was associated
and may generally utilize the knowledge and expertise gained through their
service as public officials except as set forth above. Additionally, a former
public official would not violate Section 3(e) of the Ethics Act if he were to
merely administer a contract that has already been awarded in accordance with
the above restrictions. Notably, however, this allowable activity would not
extend to negotiating or re- negotiating such contract that might exist between
a former governmental body and the former employee or official or a business
Mr. Joseph A. Nickleach, Esquire
October 17, 1983
Page 5
with which he is associated following his termination of service with the
governmental body. Additionally, the Commission has held that within the
first year after an individual leaves public service he may not sign and
submit under his own signature or permit his name to appear on bids or
proposals which would be submitted to the governmental body which he served.
The business or other persons within the business with which the former public
official may become associated or employed may make, submissions to the
governmental body so long as the individual former public official's name does
not appear on such a submission as either the signator, the preparer, or the
individual listed in the proposal as potential technical or other advisor.
See Kilareski, 80 -054 and Dalton, 80 -056.
Conclusion: Under the facts as you have set forth above, this individual
would be a "public official" as that term is defined in the Ethics Act and
must conform his conduct to the requirements of the Ethics Act. Assuming that
this individual stands in the relationship to the business as set forth in
either Section 3(a) or Section 3(c) of the Ethics Act to the business which
would seek to contract with the governmental body with which he is associated,
the Authority, the requirements of Section 3(a) and Section 3(c) mandate
that:
1. the member should not have anything to do with the Authority's
decisions or discussions regarding the awarding of the contract upon
which he may bid;
2. an open and public process as described above be undertaken prior to
any such award of a contract by the Authority to the business with
which this individual board member is associated;
3. that no confidential information received through his holding of
public office be used to obtain advantages or financial gain for
this business.
Additionally, if this individual were to resign from the Authority, the
restrictions of Section 3(e) would be applicable and must be met. These
restrictions as outlined above, would apply to the individual for a one -year
period following his resignation from 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 facts and committed the acts complained
of in reliance on the Advice given.
Mr. Joseph A. Nickleach, Esquire
October 17, 1983
Page 6
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.
SSC /rdp
Sincerely,
Sandra S. ristianson
General Counsel