HomeMy WebLinkAbout87-644 MinyardHandsel B. Minyard, Esquire
Municipal Services Building
Room 1520
Philadelphia, PA 19102
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PA 17120
TELEPHONE: (717) 783 -1610
December 21, 1987
ADVICE OF COUNSEL
Re: Attorney, City Solicitor, Representation, Sec. 3(e),
Dear Mr. Minyard:
87 -644
This responds to your letter of November 17, 1987, in which you
requested advice from the State Ethics Commission.
Issue: You have requested advice regarding the permissible scope of your
practice of law upon termination of your employment with the City of
Philadelphia.
Facts: In your advice request, you state that you are the City Solicitor of
the City of Philadelphia and also the ex officio member of certain boards and
commissions, one of which is the Board of Pensions and Retirement, hereinafter
Board. You state that the Board is an independent City agency responsible for
administering the pension and retirement system of Philadelphia. In this
regard, you state that although a deputy generally serves as your
representative on the Board, you do attend Board meetings which deal with
investments from the pension fund. You also state that, in 1986, the Board
determined to invest in realty and real estate - backed investments and pursuant
to that decision engaged MIG Realty, hereinafter MIG, as a consultant to
assist in making those investments. You further state MIG was specifically
engaged both to evaluate real estate investments which would be presented to
the Board and also to seek investments for the Board's consideration. You
state that although you did not participate in the Board's decision to engage
MIG, which receives a fee for services, you did participate in the contract
negotiations with MIG in your capacity as City Solicitor once the decision had
been made to retain MIG. You then state that you will be leaving your
position as solicitor at the end of the calendar year and that MIG has
Handsel B. Minyard, Esquire
December 21, 1987
Page 2
approached you regarding the possibility of working with them by performing
certain legal work and interacting with the Board. You state that your
activity would consist of attending meetings with the Board and Board members
so as to apprise them of the work being done by MIG for the Board and advise
them of the progress being made on MIG projects on behalf of the Board.
Following the citation of the Ballou, Snelbaker and PUC v. Thornburgh cases,
you request advice of this Commission both as to your status as a lawyer under
the Ethics Act and the possible restrictions the Ethics Act would impose upon
you for performing the services as outlined above.
You are aware of Pennsylvania Public Utility Bar Association v.
Thornburgh, 434 A.2d 1327, 62 Pa. Cmwlth. 88 (1981), affirmed per curiam 450
A.2d 613, 498 Pa. 589 (1982) which deals with the applicability of Section
3(e) of the Ethics Act to attorneys in the regulation of their practice of
law. However, you seek clarification of the question of the applicability of
the Ethics Act to your situation and any restrictions that might be placed
upon your conduct with respect to your practice of law and new work and /or
employment.
Discussion: In light of the recent decision in Pennsylvania Public Utility
Commission Bar Association, supra, where the Court held that Section 3(e) of
the Ethics Act, 65 P.S. 403(e), was an impermissible intrusion upon the
Supreme Court's authority to regulate an attorney's conduct, the State Ethics
Commission has applied this decision to mean that there are no prohibitions
under Section 3(e) of the Ethics Act upon your conduct insofar as that conduct
constitutes the practice of law.
Under the Ballou, Snelbaker Cases, it was decided that solicitors who
were not full -time employees but who served in a capacity akin to a consultant
were not "public employees" or "public officials" under the Ethics Act.
However, this Commission has determined that attorneys who are full -time
public employees are subject to the Ethics Act, Maunus /Thau, 84 -020B, 84 -020A,
subject of course to the limitation imposed by the Court in PUC v. Thornburgh,
supra.
Therefore, insofar as your conduct before the City of Philadelphia, the
Board or any other board or commission on which you serve, the agencies or
entities with which you were associated, would constitute the practice of law,
Section 3(e) of the Ethics Act cannot be applied to restrict that proposed
activity. Particular reference should be made to the decision of the
Commonwealth Court at Footnote 7, 434 A.2d at page 1331 - 1332. In this note,
the Court indicates that any activity in which the attorney proports to render
professional services to a client may only be regulated by the Supreme Court.
The State Ethics Commission, therefore, must conclude that to the extent that
you would represent a client, as a lawyer, before the City of Philadelphia,
the Board, or any other board or commission on which you serve, or otherwise,
Section 3(e) of the Ethics Act would not operate to bar such activity.
Handsel B. Minyard, Esquire
December 21, 1987
Page 3
If, however, the activities that you intend to undertake before the City
of Philadelphia, the Board or any other board or commission on which you
serve, the governmental body with which you have been associated while
employed by the City of Philadelphia -- do not fall within the category of the
"practice of law" the prohibitions of Section 3(e) of the Ethics Act might be
applicable. Activities which might be considered, by the Commission, not to
constitute the "practice of law" or to be undertaken in the capacity as
lawyer - client, might include activities such as lobbying and negotiating on
contracts. However, it is assumed, for the purposes of this Advice, that you
intend to undertake these activities in the capacity of lawyer - client, that
these activities would constitute the practice of law, and that the provisions
of Section 3(e) of the Ethics Act, pursuant to the mandates of the Supreme
Court's ruling would, therefore, be inapplicable.
In any event, you should be advised that your activity, even if Section
3(e) of the Ethics Act were to be applicable, would not regulate your conduct,
except with respect to the City of Philadelphia or the Board, or any other
boards or commissions on which you served, the "governmental body" with which
you are "associated" while employed by the City of Philadelphia. Therefore,
any representation which you might undertake with respect to a client or
employer before any entity other than the City of Philadelphia or the Board,
or any other boards or commissions on which you served, would.not be
restricted by Section 3(e) of the Ethics Act in any event.
Lastly, under Section 3(a) and 3(b) of the Ethics Act, no public official
may use his public office or confidential information received through his
holding public office to obtain financial gain for himself or a business with
which he is associated and no public official may receive anything of value,
including the promise of future employment, on the understanding that his
official conduct will be influenced thereby. See Section 3(a) and (b) of the
Ethics Act, 65 P.S. 403(a) and (b). It is assumed that such a situation does
not exist here. Referenced to this section is made not to indicate that any
such activity has been or will be undertaken but in an effort to provide a
complete response to your inquiry.
Conclusion: Section 3(e) of the Ethics Act does not restrict your
representation or your activities, as outlined above, insofar as those
activities constitute the practice of law.
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.
Handsel B. Minyard, Esquire
December 21, 1987
Page 4
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. Dopko
General Counsel