HomeMy WebLinkAbout88-558 ClarkeMr. F. Kenyon Clarke
216 So. Bristol Road
Chalfont, PA 18914
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
April 26, 1988
88 - 558
Re: Former Public Official, Section 3(e), Municipal
Chairman and Member
Authority
This responds to your letter of March 8, 1988, 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 Chalfont -New Britain Township Joint Sewage
Authority.
Facts: In your advice request you state that you are a former
chairman and member of the Chalfont -New Britain Township Joint
Sewage Authority, hereinafter Authority, with offices located at
1645 Upstate Road, Doylestown, Pennsylvania, 18901. After noting
that you have been chairman for the last ten years and a member
for the last 15 years, you state that without prior notice the
borough council did not reappoint you to the Authority in
January, 1988. You then note that the council appointed another
individual who is qualified and presently serving on the board of
the Authority. You then state that the Authority is in the midst
of an eleven million dollar plant expansion and that you devoted
many hours to this project relative to supervision, negotiating
change orders and generally reviewing the construction as well as
being the primary member who reviewed on a day -to -day basis the
activities of the general contractor. You feel that you are
intimately aware of all problems associated with the
administration of this plant expansion contract. After you were
not reappointed, you state that several members of the Authority
approached you and asked you to serve as a consultant to the
Authority so as to continue your work in supervising the contract
whereby your expertise relative to this contract could be
utilized. Before agreeing to become a consultant for the
Authority, you request advice from the Ethics Commission as to
the propriety of your proposed conduct.
Mr. F. Kenyon Clarke
April 26, 1988
Page 2
Discussion: As member and chairman of th Authcrty, you were a
public official as that term is defined under the Ethics Act.
65 P.S. 5402; 51 Pa. Code 51.1. As such, your conduct is subject
to the provisions of the Ethics Act.
Upon termination of you service, you would be come a
"former public official" subject to Section 3(e) of the Ethics
Act. Section 3(e) of the Ethics Act provides that:
Y--
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 tha "governmental body"
with which you were associated while working with the Authority
mu;t 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,
Opinion 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 the Authority. Thus, the "governmental body" with
which you have been "associated" upon the termination of your
service would be the Authority. Therefore, within the first
year after you would leave the Authority, Section 3(e) of the
Ethics Act would apply and restrict your "representation" of
persons or new employers vis -a -vis the Authority.
The Ethics Act would not affect your 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 you may engage, following your departure
from the Authority. It is noted, however, that the conflicts of
interest la- is primarily concerned with financial conflicts and
violations of the public t qst. The intent of the law generally
Mr. F. Kenyon Clarke
April 26, 1988
Page 3
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.
In respect to the one year representation the Ethics
Commission has promulgated regulations to define " epresentation"
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 employee.
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
Authority), including, but not limited to, negotiations or
renegotiations on contracts with the Authority;
2. Attempts to influence Authority;
3. Participating in any matters before the Authority over
which you had supervision, direct involvement, or responsibility
while employed by the Authority;
4. Lobbying, that is representing the interests of any
person or employer before the Authority in relation to
legislation, regulations, etc. See Russell, Opinion 80 -048 and
Seltzer, Opinion 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 Authority, constitutes an
attempt to influence your former governmental body. See
Mr. F. Kenyon Clarke
April 26, 1988
Page 4
Kilareski, Opinion 80 -054. Therefore, within the first year
after you leave the Authority, you shouted not engage in the type
of activity outlined above. The Commission, however, has stated
that the inclusion of your name as an employees or con ultant on a
"pricing proposal," even if submitted to or reviewed by the
Authority, is not prohibited as "representation." See Kotalik,
Opinion 84 -007.
You may, assist in the preparation of any documents
presented to the Authority so long as you are not. i as
the preparer. You may also counsel any person regarding that
person's appearance before the Authority. Once again, however,
your activity in this respect should not be revealed to the
Authority. Of course, any ban under the Ethics Act would not
prohibit or preclude you from making general informational
inquiries of the Authority to secure information which is
available to the general public. See Cutt, Opinion 79 -023.
This, of course, must not be done in an effort to indirectly
influence these entities or to otherwise make known to the
Authority your representation of, or work for your new employer.
In the instant situation, the activity you contemplate
consists of providing services as a consultant to your former
employer, the Authority. Such contemplated conduct is the
precise activity which Section 3(e) of the Act was designed to
prohibit or restrict, namely the representation of yourself
individually before your former governmental body, the Authority.
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 violated Sections 3(a) and 3(c), when he
negotiated a consulting contract and appeared before his former
governmental body 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 terminated his service. Therefore, under Section 3(e) of
the Ethics Act you may not appear before your former governmental
body, the Authority, by engaging in the activity of or serving as
a consultant.
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 member and chairman of the Authority, you were a
"public official" subject to the provisions of the Ethics Act.
Following the termination of service, you became a "former public
Mr. F. Kenyon Clarke
April 26, 1988
Page 5
official" subject to the restrictions of Section 3(e) of th
Ethics Act. Under Section 3(e) of the Ethics Act, you may not
for a period of one year'after you terminate your service with
the Authority appear individually for the purpose of engaging in
consulting services before your former governmental body.
Lastly, the propriety of your conduct has only been addressed
under the Ethics Act.
Pursuant to Section 7(9)(ii), this Advice is a compinte
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 former Opinion from th'
Commission will be issued. Any such appeal must be made, in
writing, to the Commission within 15 days of service of thf,s
Advice pursuant to 51 Pa. Code S2.12.
Sincerely,
tn-o)CN C
Vincent J. Dopko,
General Counsel