HomeMy WebLinkAbout87-604 VochkoDear Dr. Vochko:
Mailing Address
State Ethics Commission
308 Finance Building
P. 0. Box 11470
Harrisburg, Pa. 17108 -1470
August 12, 1987
ADVICE OF COUNSEL
Dr. Paul R. Vochko
1531 Woodside Drive
Ambridge, PA 15003
Re: Former Public Official; Section 3(e), School Superintendent, State Board
of Education Member
87 -604
This responds to your letters of July 24 and August 4, 1987, in which
you requested advice from the State Ethics Commission.
Issue: You ask whether the Ethics Act presents any restrictions upon your
potential employment following your termination of service with the
Ambridge Area School District.
Facts: You were the Superintendent of Schools of the Ambridge Area School
District, hereinafter the District, prior to your retirement on June 30, 1987.
Subsequent thereto, you became employed as an Educational Consultant with N.
John Cunzolo, who is a former architect for the District. You also serve as a
member of the State Board of Education, hereinafter the Board, which sets
policies for all the schools in the Commonwealth of Pennsylvania. You ask
what restrictions would be imposed upon your employment with N. John Cunzolo
in relation to your retirement from the District and your continued service
with the Board.
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 such as the State
Adverse Interest Act or the Governor's Code of Conduct.
State Ethics Commission • 308 Finance Building • Harrisburg, Pennsylvania
Dr. Paul R. Vochko
August 12, 1987
Page 2
As a Superintendent of Schools for the District, 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, 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.
See Persing, No. 244.
Consequently, upon termination of this 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, the "governmental body" with which you
were associated while working with the District, must be identified. Then,
the scope of the prohibitions associated with the concept and 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 Ewing, 79 -010. See also Kur vs.
Commonwealth of Pennsylvania, State Ethics Commission, A. d 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 the District. Thus, the
"governmental body" with which you have been "associated" upon the termination
of your employment would be the District. Therefore, within the first year
after you would leave the District, Section 3(e) of the Ethics Act would apply
and restrict your "representation" of persons or new employers vis -a -vis the
District.
The Ethics Act would not affect your ability to appear before agencies or
entities other than with respect to the District. Likewise, there is no
general limitation on the type of employment in which you may engage,
following your departure from the District. We do note, however, that the
conflicts of interest law is primarily concerned with financial conflicts and
Dr. Paul R. Vochko
August 12, 1987
Page 3
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 District), including, but not
limited to, negotiations or renegotiations on contracts with the District;
2. Attempts to influence the District;
3. Participating in any matters before the District over which you had
supervision, direct involvement, or responsibility while employed by the
District;
4. Lobbying, that is representing the interests of any person or
employer before the District in relation to legislation, regulations, etc.
See Russell, 80 -048 and Seltzer, 80 -044.
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 District, constitutes an attempt to influence your former governmental
body. See Kilareski, 80 -054. Therefore, within the first year after you
leave the District, you should not engage in the type of activity outlined
above. The Commission, however, has stated that the inclusion of your name as
an employee or consultant on a "pricing proposal," even if submitted to or
reviewed by the District, is not prohibited as "representation." See Kotalik,
84 -007.
Dr. Paul R. Vochko
August 12, 1987
Page 4
You may, assist in the preparation of any documents presented to the
District so long as you are not identified as the preparer. You may also
counsel any person regarding that person's appearance before the District.
Once again, however, your activity in this respect should not be revealed to
the District. Of course, any ban under the Ethics Act would not prohibit or
preclude you from making general informational inquiries of the District 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 District your
representation of, or work for your new employer.
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, Section 403(b) of the State Ethics Act would prohibit any
public employee or public official from accepting a position of employment if
said position has been offered based upon the understanding that the official
conduct of the employee or official, while working for his former governmental
body, was influenced by such offer. See 65 P.S. §403(b).
Further, in light of your position as member of the Board, you should not
participate in any natter the District would have before the Board on an
individual basis i.e., any matter that specifically relates to only the
District.
Similarly, you should not participate as a Board member in any matter
that N. John Cunzolo might have before the Board; in this regard, it is highly
unlikely that this circumstance would ever occur given the function of the
Board which is to set statewide policies /mandates for all schools.
Conclusion: As a Superintendent of Schools, you are to be considered a
"public employee" as defined in the Ethics Act. Upon termination of your
service with the District, 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 District. Lastly, you should not participate as a member
of the Board in any matter directly involving the District or in any matter
that N. John Cunzolo would have before the Board.
Further, should 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.
Dr. Paul R. Vochko
August 12, 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,
cctAi
Vincent J. Dopko
General Counsel