HomeMy WebLinkAbout87-658 CarmellaJames D. Carmella, Esquire
724 Church Street
Indiana, PA 15701
Dear Mr. Carmella:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PA 17120
TELEPHONE: (717) 783 -1610
December 31, 1987
ADVICE OF COUNSEL
87 -658
Re: Former Public Official; Section 3(e), County Commissioner, County
Insurance Policies
This responds to your letter of December 14, 1987, in which you
requested advice from the State Ethics Commission.
Issue: You ask whether the Ethics Act presents any restrictions upon a county
commissioner following his termination of service with the the county.
Facts: In your letter you state that you are the solicitor for County
and that you are requesting advice on behalf of County Commissioner Anthony S.
Hewitt, who is presently serving and has been re- elected to serve an
additional four year term beginning on January 3, 1988. You further state
that Commissioner Hewitt has accepted employment outside the Commonwealth and
consequently will not fulfill his second term which will result in a vacancy
that will be filled by the Court of Common Pleas. You also state that
Commissioner Hewitt owns an insurance agency in Indiana County and that he
wrote insurance for the county prior to taking office. You state that when he
originally took office, he discontinued writing insurance for the county but
now that he is leaving office, he is interested in once again writing
insurance policies for Indiana County. You indicate that the commissioner
would be interested in writing insurance in either of two ways: submitting
proposals to write insurance as the current county policies expire or
alternatively arranging with the present insurance agent for the county that
Commissioner Hewitt could take over the insurance and become broker of record.
As to the second proposal, you note that when Commissioner Hewitt took office
he represented Traveler's Insurance Company but he withdrew his name as broker
of record when he was elected and had another Traveler's agency underwrite the
insurance while he was commissioner. Commissioner Hewitt now suggests that
James D. Carmel la, Esquire
December 31, 1987
Page 2
the other agent withdraw as broker of record so that Mr. Hewitt may resume his
former insurance underwriting after he leaves public office. You further note
that Commissioner Hewitt has accepted a position in Raltimore, Maryland, where
he w i l l move; however, he w i l l , as owner of the insurance agency in Indiana
County, continue to operate that business which will he managed by local
people. You conclude by requesting advice as to whether Commissioner Hewitt,
after his resignation, may write insurance for the county; whether
Commissioner Hewitt would be restricted from writing insurance if the county
put the insurance out on bid and lastly, what effect Section 3(e) of the
Ethics Act would have on this matter.
Discussion: As a county commissioner for Indiana County, Mr. Hewitt is to be
considered a "public official" 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. See Huff Opinion, 84 -015
Consequently, upon termination of this employment, he would become a
"former public official" 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 he was associated while working with the
county. 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
Kury vs. Commonwealth of Pennsylvania, State Ethics Commission, 435 A.2d 940
T1981).
Based upon the facts outlined above, his jurisdiction, responsibility,
influence and control appears to have been Indiana County. Thus, the
"governmental body" with which he has been "associated" upon the termination
of his employment would be Indiana County. Therefore, within the first year
after he would leave Indiana County, Section 3(e) of the Ethics Act -would
apply and restrict his "representation" of persons or new employers vis -a -vis
Indiana County.
James D. Carmelia, Esquire
December 31, 1987
Page 3
The Ethics Act would not affect his ability to appear before agencies or
entities other than with respect to Indiana County. Likewise, there is no
general limitation on the type of employment in which he may engage, following
his departure from the county. 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 one has been associated, (that is Indiana County), including, but not
limited to, negotiations or renegotiations on contracts with Indiana County;
2. Attempts to influence Indiana County;
3. Participating in any matters before Indiana County over which he had
supervision, direct involvement, or responsibility while employed by Indiana
County;
4. Lobbying, that is representing the interests of any person or
employer before Indiana County 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 one's name as the person who will provide
technical assistance on such proposal, document, or hid, if submitted to or
reviewed by the governmental body, constitutes an attempt to influence one's
James D. Carmel la, Esquire
December 31, 1987
Page 4
former governmental body. See Kilareski, 80 -054. Therefore, within the first
year after Mr. Hewitt leaves Indiana County, he should not engage in the type
of activity outlined above. The Commission, however, has stated that the
inclusion of one's name as an employee or consultant on a "pricing proposal,"
even if submitted to or reviewed by the governmental body, is not prohibited
as "representation." See Kotalik, 84 -007.
One may, assist in the preparation of any documents presented to the
governmental body so long as he is not identified as the preparer. He may
also counsel any person regarding that person's appearance before Indiana
County. Once again, however, his activity in this respect should not he
revealed to the county. Of course, any ban under the Ethics Act would not
prohibit or preclude him from making general informational inquiries of
Indiana County to secure information which is available to the general public.
See Cutt, 79 -023. This, of course, must not he done in an effort to
indirectly influence these entities or to otherwise make known to Indiana
County his representation of, or work for his new employer.
In the instant situation, the activity which Mr. Hewitt contemplates is
providing insurance coverage to Indiana County. Such contemplated conduct is
precisely the activity which Section 3(e) of the Ethics Act was designed to
prohibit or restrict, namely the representation of Mr. Hewitt's insurance
agency or Mr. Hewitt individually before his former governmental body, Indiana
County. In Kreger, No. 595, the Ethics Commission found that a former member
of a municipal authority violated Section 3(e) of the Ethics Act, as well as
Sections 3(a) and 3(c), when he negotiated a consulting contract and appeared
before governmental within one year after he resigned as authority member.
See also Wolpert, No. 169, wherein this Commission found that a school
director violated Section 3(e) of the Ethics Act when he contracted with a
school district within one year after he terminated his service. See also
Komoroski, No. 550. Therefore, under Section 3(e) of the Ethics Act,
Commissioner Hewitt may not appear before his farmer governmental body,
Indiana County, by proposing, submitting or underwriting insurance policies
for the county.
Regarding the alternative proposal whereby Commissioner Hewitt would
request the current broker of record to withdraw followed by the substitution
of Commissioner Hewitt, such contemplated activity would not remove the 3(e)
prohibition of the Ethics Act because Commissioner Hewitt would be attempting
to do indirectly that which he could not do directly. See Motto Opinion,
83 -015. See also Welz Opinion, 86 -001. Additionally, if Mr. Hewitt were to
substitute as broker of record and if a claim or dispute regarding a policy
arose, Commissioner Hewitt, through his firm, would have to appear before the
county and represent his insurance agency relative to the dispute or- claim.
The fact that Commissioner Hewitt would be working in Maryland and having
James D. Carmel la, Esquire
December 31, 1987
Page 5
local people manage the insurance company would not alter the result because
the insurance agency would be a "business with which he is associated" as that
term is defined in the Ethics Act:
Section 2. Definitions.
"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.
Regarding you last concern as to whether the county could put the
insurance out on bid and, if so, what restrictions would he imposed upon
Commissioner Hewitt regarding that contracting process, Section 3(c) of the
Ethics Act provides:
Section 3. Restricted activities.
(c) No public official or public employee or a member of
his immediate family or any business in which the person
or a member of the person's immediate family is a
director, officer, owner or holder of stock exceeding 51
of the equity at fair market value of the business shall
enter into any contract valued at $500 or more with a
governmental body unless the contract has been awarded
through an open and public process, including prior public
notice and subsequent public disclosure of all proposals
considered and contracts awarded. Any contract made in
violation of this subsection shall be voidable by a court
of competent jurisdiction if the suit is commenced within
90 days of making of the contract. 65 P.S. 403(c).
In relation to the above provision of law, the State Ethics Commission
has generally determined that this provision is a procedure to be used when a
public official or employee contracts with his own governmental body in excess
of $500. Bryan, 80 -014; Lynch, 79 -047. The Commission, however, has also
determined that the above provision of law is not a general authorization for
a public official to contract with his own governmental body where such is
otherwise prohibited by law. The above provision of law clearly is intended
to be a procedure to he utilized where contracting is otherwise allowed by
law. For example, if a particular business transaction was prohibited under
Section 3(a) or 3(e) of the State Ethics Act, this particular provision of law
would not authorize that transaction. Additionally, if a particular code
prohibits a public official from being interested in a contract, this
provision would not allow that interest.
James D. Carmelia, Esquire
December 31, 1987
Page 6
Parenthetically, where contracting is otherwise allowed or where there
appears to be no expressed prohibition to such contracting, the above
particular provision of law would require that an additional procedure he
utilized when such business is transacted. This procedure, the open and
public process, must he used in all situations were a public official is
otherwise appropriately contracting with his own governmental body in excess
of $500. This open and public process would require:
(1) prior public notice of the employment or contracting possibility;
(2) sufficient time for a reasonable and prudent competitor /applicant to
he able to prepare and present an application or proposal;
(3) public disclosure of all applications or proposals considered and;
(4) public disclosure of the contract awarded and offered and accepted.
See, Cantor, 82 -004.
Thus, in the event that contracting would be allowed, the above process
must be employed. However, in the instant matter, Section 3(e) would be
applicable and would bar the contracting process as discussed above.
Lastly, it must be noted that your questions have only been addressed
under the Ethics Act; the propriety of the proposed conduct has not been
considered under any other statute, code, regulation, or ordinance or other
code of conduct other than the Ethics Act.
Conclusion: As a county commissioner, Mr. Hewitt is to be considered a
"public official" as defined in the Ethics Act. Upon termination of his
service with Indiana County, he would become a "former public official"
subject to the restrictions imposed by Section 3(e) of the Ethics Act. As
such, his conduct should conform to the requirements of the Ethics Act as
outlined above. Under Section 3(e) of the Ethics Act, Commissioner Hewitt for
a period of one year after he leaves his position as county commissioner may
not submit proposals or contract with Indiana County regarding insurance
underwriting for the county either directly or indirectly by having the agent
of record withdraw with Commissioner Hewitt substituting. His governmental
body for the purpose of the one year representation restriction is Indiana
County.
Lastly, the propriety of the proposed conduct has only been considered
under the Ethics Act; the applicability of any other statute, code,
regulation, or ordinance other than the Ethics Act has not been considered.
Further, should Commissioner Hewitt terminate his employment or service,
as outlined above, he is reminded that the Ethics Act also requires him to
file a Statement of Financial Interests for the year following his termination
of service.
James D. Carmel la, Esquire
December 31, 1987
Page 7
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 ful 1 Commission review this Advice.
A personal appearance before the Commission wi 11 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 .