HomeMy WebLinkAbout88-617 StewartSTATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
Mr. Leonard L. Stewart, Esquire
Mellon Square
435 Sixth Avenue
Pittsburgh, PA 15219 -1886
Re: Former Public Official; Section 3(e), Municipal Authority
Board Member; Computer Operations Consultant
Dear Mr. Steward:
ADVICE OF COUNSEL
August 1, 1988
88 - 617
This responds to your letter of June 21, 1988, in which you
requested advice from the State Ethics Commission.
Issue: You ask whether the Ethics Act presents any prohibition
or restrictions upon the potential employment as a Computer
Operations Consultant of a former Municipal Authority Board
Member within one year of the termination of service with the
Authority.
Facts: You have telephonically advised that you represent a
former board member of a municipal authority who seeks to provide
consulting services with his former governmental body. You then
state that the former member of the Municipal Authority Board
would provide consulting services for compensation as to the
Authority's computer operations including the training of
Authority employees in the operation of the computer software
program. You then advise that the proposed contract would be
entered into one year after termination of service of the former
board member, that it would be entered into personally with the
board member and that it would be entered into at an open public
meeting of the Board of the Authority. You then advise that
since the contract would be less than $4,000, the Authority would
not be required under the Municipal Authority's Act to award the
contract pursuant to the public bidding requirements. You then
express your belief that since the individual is no longer a
public official and would not be representing a person other than
himself before the Authority Board, you believe that the proposed
contract would not contravene any provisions under the Ethics
Leonard L. Stewart, Esquire
August 1, 1988
Page 2
Act. After assuming that the proposed contract would be
otherwise lawful, you request advice as to the propriety of the
proposed conduct under the applicable provisions of the Ethics
Act.
Discussion: As a member of the Board of a Municipal Authority,
the individual is a public official as that term is defined under
the_Ethics Act. 65 P.S. Section 402; 51 Pa. Code §1.1. As such
his conduct is subject to the provisions of the Ethics Act and
the restrictions therein are applicable to him.
Upon termination of his service, 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 the "governmental body"
with which the former board member was associated while working
with the Authority 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, Opinion 79 -010. See also Kury vs.
Commonwealth of Pennsylvania, State Ethics Commission, 435 A.2d
940 (1981).
Based upon the facts outlined above, the former Board
member's jurisdiction, responsibility, influence and control
appears to have been the Municipal Authority. Thus, the
"governmental body" with which he was "associated" upon the
termination of his service would be the Municipal Authority,
hereinafter Authority. Therefore, within the first year after he
would leave the Authority, Section 3(e) of the Ethics Act would
apply and restrict his "representation" of persons or new
employers vis -avis the Authority.
Leonard L. Stewart, Esquire
August 1, 1988
Page 3
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 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
"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 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 he was 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 he 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.
Leonard L. Stewart, Esquire
August 1, 1988
Page 4
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 bid, if submitted to or reviewed by the Authority, constitutes
an attempt to influence the former governmental body. See
Kilareski, Opinion 80 -054. Therefore, within the first year
after he would leave the Authority, the former Board member
should not engage in the type of activity outlined above. The
Commission, however, has stated that the inclusion of his name
as an employee or consultant on a "pricing proposal," even if
submitted to our reviewed by the Authority, is not prohibited as
"representation." See Kotalik, Opinion 84 -007.
He may, assist in the preparation of any documents
presented to the Authority so long as he is not identified as
the preparer. He may also counsel any person regarding that
person's appearance before the Authority. Once again, however,
his activity in this respect should not be revealed to the
Authority. Of course, any ban under the Ethics Act would not
prohibit or preclude him 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 his representation.
In the instant situation, the activity which the former
Board Member contemplates consists of providing services as a
Computer Operations Consultant to his former governmental body
through a proposed contract. The contemplated activity of
entering into a contract and serving as a consultant with the
Authority, the former governmental body, is the precise activity
which Section 3(e) of the Ethics Act was designed to prohibit or
restrict, namely the representation of the former Board member
individually before his former governmental body. The
restriction against representation before one's governmental
body includes the situation where one is advancing one's own
personal interests and is not limited to the situation where one
must represent someone else or some entity. Toohev, Opinion 83-
003.
In Kreger, No. 595, the Ethics Commission found that a
former member of a municipal authority violated Sections 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
Leonard L. Stewart, Esquire
August 1, 1988
Page 5
Commission found that a school director violated Section 3(e) of
the Ethics 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 the former Board member may not
appear before his former body, the Authority, by
entering into a contract and 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 a Board member of a municipal Authority the
individual is a "public official" subject to the provisions of
the Ethics Act. Following the termination of service, he would
become a "former public official" subject to the restrictions of
Section 3(e) 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 appear individually for the purpose of
engaging in consulting services before his former governmental
body. Lastly, the propriety of the proposed 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 criminal proceeding, providing the requestor has disclosed
truthfully all the material facts and committed the acts
complained of in reliance on the Advice given.
such.
This letter is a public record and will be made available as
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 7. Dopko,
General Counsel