HomeMy WebLinkAbout88-545 RovitoVincent V. Rovito, Jr., Esquire
Four West Independence Street
Shamokin, PA 17872
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PA 17120
TELEPHONE: (717) 783 -1610
April 12, 1988
ADVICE OF COUNSEL
88 - 545
Re: Former Public Official; Section 3(e), Housing Authority Board,
Inspections as an Independent Contractor
Dear Mr. Rovito:
This responds to your letters of February 16 and February 19, 1988, in
which you requested advice from the State Ethics Commission.
Issue: Whether the State Ethics Act presents any restrictions or prohibitions
upon a former housing authority board member, following the termination of his
service, in obtaining a contract to perform inspections as an independent
contractor with his former governmental body.
Facts: You state that you are the solicitor for Northumberland County Housing
Authority and represent the former director, Daniel L. Venn. After Mr. Venn
resigned on February 1, 1988, following a number of years of service with the
Housing Authority Board, hereinafter Board, you state that the directors made
a policy change whereby housing inspections would be let under contract rather
than being done "fn house. You state that the inspections are performed to
determine whether homes meet HUD guideline and eligibility requirements. You
then state that although Mr. Venn had no prior knowledge of the policy change
regarding inspections, he has contacted the Board to seek employment as an
independent contractor to make the inspections. It is then stated by
you
the U.S. Department of Housing and Urban Development (HUD) has indicated that
they have not objection to Mr. Venn obtaining the position if he is the
successful candidate. You state that Mr. Venn has sufficient qualifications
to do the job and that as an independent contractor he would receive no
benefits from the Authority. You further note that HUD has determined that
they would waive their requirements and that it was only necessary for a
determination to be made by the Authority's solicitor. In this regard, Mr.
Kirk L. Gray, the Regional Director of the Office of Public Housing, HUD,
advised by letter of March 17, 1988 that a waiver of Section 515(a) of the
Vincent V. Rovito, Jr. Esquire
April 12, 1988
Page 2
Annual Contributions Contract was granted as to the one year waiting period
for Mr. Venn. In a supplemental letter with attachments, you also state that
there would be savings to the Authority if Mr. Venn would perform this work as
an independent contractor. After stating that it costs the Authority
approximately $35 per unit for an inspection, where a reinspection is not
necessary, Mr. Venn would be paid $10 per inspection. After noting that the
Authority inspects approximately 30 units per month, you state that the cost
of inspections on an in house basis would be approximately $1,050 per month
whereas it would only be $300 per month if Mr. Venn performed the work as an
independent contractor, thus, saving approximately $750 per month. You then
conclude by expressing your view that Section 3(e) of the Ethics Act would not
appear to restrict Mr. Venn's activities on a theory that he is merely seeking
employment for himself, that he is not representing any one before the board
and that he would be employed as an independent contractor.
Discussion: As a director for the Authority, he is 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.
Consequently, upon termination of this employment, he 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.3: 403.
Initally, it is noted that the "governmental body" with which Mr. Venn
was associated was the Authority.
The Ethics Act would not affect his ability to appear before agencies or
entities other than with respect to the Authority. Likewise, there is no
general limitation on the type of employment in which he may engage, following
his departure from the Authority. 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, Opinion 83 -014; Zwikl, Opinion 85 -004.
Vincent V. Rovito, Jr., Esquire
April 12, 1988
Page 3
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 he has been associated, including, but not limited to, negotiations or
renegotiations of contracts;
2. Attempts to influence;
3. Participating in any matters over which he had supervision, direct
involvement, or responsibility while employed;
4. Lobbying, that is representing the interests of any person or
employer before his governmetal body in relation to legislation, regulations,
etc. See Russell, Opinion 80 -048 and Seltzer, Opinion 80 -044.
In the instant situation, the activity which Mr. Venn contemplates
consists of performing inspections as an independent contractor through a
contract with his former employer, the Authority. Such contemplated conduct
is the precise activity which Section 3(e) of the Ethics Act was designed to
prohibit or restrict, namely representation before his former governmental
body, the Authority. The fact that Mr. Venn would not be representing some
other person or entity before the Authority does not take the contemplated
activity out of the restricion of Section 3(e) of the Act. Thus, the State
Ethics Commission in the Toohey, Opinion 83 -003 decided that a public official
could not even represent his own personal interests, as opposed to
representing another or a firm, in order to acquire a contract with his former
governmental body. Further, in Kreger, Order 595, The Ethics Commission found
that a former member of a municipaT authority violated Section 3(e) of the
Ethics Act, as well as violated Sections 3(a) and 3(c), when he negotiated a
contract and appeared before his governmental body within one year after he
resigned as Authority member. See also Wolpert, Order 169, wherein the Ethics
Commission found that a school director violated Section 3(e) of the Ethics
Vincent V. Rovito, Jr., Esquire
April 12, 1988
Page 4
Act when he contracted with his school district within one year after he
terminated his service. Therefore, under Section 3(e) of the Ethics Act, Mr.
Venn may not appear before his governmental body and enter into a contract as
an independent contractor for inspections with his governmental body, the
Authority.
Lastly, the propriety of the proposed conduct has only been addressed
under the Ethics Act; the applicability of any other statute, code, ordinance,
regulation or other code of conduct other than the Ethics Act has not been
considered in that they do not involve an interpretation of the Ethics Act.
Conclusion: As Director of the Authority, Mr. Venn is to be considered a
"public employee" subject to the provisions of the Ethics Act. Under Section
3(e) of the Ethics Act, he may not for a period of one year after he
terminates his service with the Authority enter into a contract with that
Authority to perform housing inspections as an independent contractor.
Lastly, the propriety of his conduct has only been addressed under the Ethics
Act.
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 crimi nal 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 . Dopko
General Counsel