HomeMy WebLinkAbout87-582 FrankMichael J. Frank
The Almshouse
Neshaminy Manor Center
Doylestown, PA 18901
STATE ETHICS COMMISSION_
308 FINANCE BUILDING
HARRISBURG, PA 17120
TELEPHONE: (717) 783 -1610
June 3, 1987
ADVICE OF COUNSEL
87 -582
Re: Former Public Employee, Section 3(e), Director of Community Planning
Dear Mr. Frank:
This responds to your letter of May 26, 1987, in which you requested
advice from the State Ethics Commission.
Issue: You ask whether the Ethics Act presents any restrictions upon you when
you establish a consulting firm which will represent both municipal and
private clients following your termination of employment as Director of
Community Planning for the Bucks County Planning Commission.
Facts: As the current Director of Community Planning for the Bucks County
Planning Commission, you provide technical and planning assistance to various
municipal planning commissions. Further, you and your staff review
subdivision and land development proposals, zoning change requests, amendments
to municipal ordinances and certain municipal and school district proposals.
Technical and policy recommendations are made by you but you do not take any
formal action to approve or deny requests or proposals.
Your job description indicates that your prime responsibilities are to
supervise your staff in carrying out the designated community planning duties,
to assist the executive director in developing policies, to advise the county
commissioners and local officials concerning planning activities, to
coordinate community planning work with county wide plans, to develop new
concepts and approaches to planning problems and possible solutions, and
finally, to conduct contract work with local officials. You are required to
train personnel and to develop educational programs for local officials and to
compile and analyze statistical data for the preparation of reports and
articles for publication. Lastly, you conduct land use and housing surveys
and prepare reports of your findings. You prepare specifications for various
facilities, prepare legal documents and notices, and perform any related
duties that are necessary to carrying out the responsibilities of your
position as Director.
Michael J. Frank
June 3, 1987
Page 2
You have requested the advice of the State Ethics Commission regarding
what, if any, prohibitions would be placed upon you following your termination
as Director of Community Planning followed by the creation of a consulting
firm which would retain municipal and private clients.
Discussion: At the outset, it must be noted that the Ethics Commission may
only address your question within the purview of the Ethics Act. The
Commission may not and will not offer advice with respect to any duties or
obligations that may be imposed by other provisions of law.
As Director of Community Planning for the Bucks County Planning
Commission, you are to be considered a "public employee" within the definition
of that term as set forth in the Ethics Act and the regulations of this
Commission. 65 P.S. §402; 51 Pa. Code §1.1. This conclusion is based upon
your job description as set forth in your letter of request, which when
reviewed on an objective basis, indicates clearly that you have the power to
take or recommend official action of a non - ministerial nature with respect to
contracting, procurement, planning, inspecting or other activities where the
economic impact is greater than de minimus on the interests of another person.
Consequently, upon termination of your employment, you would become a "former
public employee" subject to Section 3(e) of the Ethics Act. Section 3(e) of
the Ethics Act provides that:
Section 3. Restricted activities.
(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.
Initially, to answer your request it is necessary to identify the
"governmental body" with which you were associated while working with the
Bucks County Planning Commission, hereinafter the Commission. Then, the scope
of the prohibitions associated with the term of "representation" must be
reviewed. In this context, the Ethics Commission has previously ruled that
the "governmental body" with which an individual may be deemed to have been
associated during his tenure of public office or employment extends to those
entities where he had influence, responsibility, supervision, or control. See
Ewin, 79 -010. See also Kury vs. Commonwealth of Pennsylvania, State Ethics
Commission, 435 A.2d 940 (1981).
From the description and analysis of your duties and responsibilities and
based upon the facts outlined above, your jurisdiction, responsibility,
influence and control appears to have been exercised within the Commission.
Thus, the "governmental body" with which you have been "associated" upon the
Michael J. Frank
June 3, 1987
Page 3
termination of your employment would be the Commission. Therefore, within the
first year after you would leave the Commission, Section 3(e) of the Ethics
Act would apply and restrict your "representation" of clients before the
Commission.
The Ethics Act would not affect your ability to appear before agencies or
entities other than with respect to the Commission. Likewise, there is no
general limitation on the type of employment in which you may engage,
following your departure from the Commission. It is noted, however, that the
conflicts of interest law is primarily concerned with financial conflicts and
violations of the public trust. The intent of the law generally is that
during the term of a person's public employment he must act consistently with
the public trust and upon departure from the public sector, that individual
should not be allowed to utilize his association with the public sector,
officials or employees to secure for himself or a new employer, treatment or
benefits that may be obtainable only because of his association with his
former public employer. See Anderson, 83 -014; Zwikl, 85 -004.
In respect to the one year representation restriction the Ethics
Commission has promulgated regulations to define "representation" as follows:
Section 1.1. Definitions.
Representation - -- Any act on behalf of any person
including but not limited to the following activities:
personal appearances, negotiating contracts, lobbying, and
submitting bid or contract proposals which are signed by
or contain the name of the former public official or
public employe. 51 Pa. Code 1.1.
The Commission, in its opinions, has also interpreted the term
"representation" as used in Section 3(e) of the Ethics Act to prohibit:
1. Personal appearances before the governmental body or bodies with
which you have been associated, (that is the Commission), including, but not
limited to, negotiations or renegotiations of contracts with the Commission;
2. Attempts to influence the Commission;
3. Participating in any matters before the Commission over which you had
supervision, direct involvement, or responsibility while employed by the
Commi ssion;
4. Lobbying, that is representing the interests of any person or
employer before the Commission in relation to legislation, regulations, etc.
See Russell, 80 -048 and Seltzer, 80 -044.
Michael J. Frank
June 3, 1987
Page 4
The Commission has also held that preparing and signing a proposal,
document or bid, or listing your name as the person who will provide technical
assistance on such proposal, document, or bid, if submitted to or reviewed by
the Commission, constitutes an attempt to influence your former governmental
body. See Kilareski, 80 -054. Therefore, within the first year after you
leave the Commission, you should not engage in the type of activity outlined
above.
You may, assist in the preparation of any documents presented to the
Commission so long as you are not identified as the preparer. You may also
counsel any person regarding that person's appearance before the Commission.
Once again, however, your activity in this respect should not be revealed to
the Commission. Of course, any ban under the Ethics Act would not prohibit or
preclude you from making general informational inquiries of the Commission to
secure information which is available to the general public. See Cutt,
79 -023. This, of course, must not be done in an effort to indirectly
influence these entities or to otherwise make known to the Commission your
representation of, or work for your clients.
Finally, the Commission has concluded that if you are administering an
existing contract as opposed to negotiating or renegotiating a contract, your
activities would not be prohibited by the Ethics Act. See Dalton, 80 -056 and
Beaser, 81 -538.
Additionally, it i
would prohibit any publ
position of employment
understanding that the
working for his former
65 P.S. §403(b).
s noted that Section 403(b) of the State Ethics Act
is employee or public official from accepting a
if said position has been offered based upon the
official conduct of the employee or official, while
governmental body, was influenced by such offer. See
Conclusion: As Director of Community Planning of the Bucks County Planning
Commission, you are considered a "public employee" as defined in the Ethics
Act. Upon termination of your service with the Commission, you would become a
"former public employee" subject to the restrictions imposed by Section 3(e)
of the Ethics Act. As such, your conduct should conform to the requirements
of the Ethics Act as outlined above. Your governmental body for the purpose
of the one year representation restriction is the Commission generally.
Further, when you terminate your employment or service, as outlined
above, you are reminded that the Ethics Act also requires you to file a
Statement of Financial Interests for the year following your termination of
service.
Michael J. Frank
June 3, 1987
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 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.
Sincerely,
Vincent J. 'opko
General Counsel