HomeMy WebLinkAbout91-522 BrownDear Mr. Brown:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
March 13, 1991
91 -522
Mr. Balinger "Skip" Brown
Box 164
Boiling Springs, PA 17007
Re: Former Public Employee, Section 3(g), Pennsylvania Commission on
Crime and Delinquency, Department of Public Welfare, Dauphin
County, New Public Employment.
This responds to your letter of January 29, 1991, in which you
requested advice from the State Ethics Commission.
Issue: Whether the Public Official and Employee Ethics Law presents
any restrictions upon your employment following termination of service
with the Pennsylvania Commission on Crime and Delinquency as of July
1990, and your prospective termination of service with the Department
of Public Welfare where you are presently employed followed by
employment with Dauphin County.
Facts: Since July 1990, you have been employed with the Department of
Public Welfare (DPW) in the Office of Administration as a Human
Resources /Organizational Consultant classified as a Personnel Analyst
III. Your present position is not affiliated with the adult criminal
justice system or with state /federal grants. Prior to July 1990, you
were employed by the Pennsylvania Commission on Crime and Delinquency
(PCCD). During most of your tenure with PCCD, you were a Program
Analyst III with the Bureau of Statistics and Policy Research. During
the several months prior to your leaving PCCD, your position was in
the Bureau of Program Development. Your function at the PCCD was
manager of the Jail Overcrowding Program where you provided technical
assistance to counties as they developed projects to help deal with
crowding. Included in this was helping counties prepare applications
to PCCD for federal funds to be used to implement projects.
As of January 22, 1991, you were notified that your name was
submitted as a candidate for furlough due to the state fiscal crisis.
Since that notification, you have inquired with various private,
county and state agencies regarding employment. Subsequently, you
have been contacted by Dauphin County regarding a position at the
county prison as associate deputy warden. This position was part of
Mr. Bolinger "Skip" Brown
Page 2
the project developed by Dauphin County while you assisted Dauphin
County during your tenure with the PCCD, and it was included as part
of the federal grant awarded to Dauphin County by the PCCD. PCCD
approves all such grants, and you note that its membership includes
members of the state Legislature, the Attorney General, the
Commissioner of the Department of Corrections, gubernatorial
appointees and other members. You specifically inquire as to whether
your acceptance of the position being considered by Dauphin County
would violate any written or understood ethics, rules, standards, laws
or guidelines.
You have submitted your resume and, for organizational
documentation, you have included a page from the state phone
directory that lists the PCCD's "Jail Overcrowding Program." The
Department of Public Welfare has submitted your job description for
your current position. PCCD has submitted the most recent job
description it has on file for you, with an attached memo from the
Director of the Bureau of Administration and Finance with PCCD, which
memo indicates that just prior to your departing from PCCD your job
description was being revised. The cover memo indicates that although
your duties changed to some degree as a result of your internal
transfer within PCCD, the submitted job description generally
represents your major duties and responsibilities during your final
year of employment with PCCD. The Director of the Bureau of
Statistics and Policy Research with PCCD has also submitted a
memorandum describing your job duties while under his supervision.
All of the above documents are incorporated herein by reference,
including your resume, the page from the state phone directory, and
all of the submitted job descriptions and memoranda.
Discussion: Initially, it must be noted that your inquiry may only be
addressed under the Ethics Law. The applicability of any other
statute, code, ordinance, regulation, or other code of conduct other
than the Ethics Law has not been considered in that they do not
involve an interpretation of the Ethics Law.
As a Human Resources /Organizational Consultant classified as a
Personnel Analyst III in the Office of Administration for the
Department of Public Welfare, you are to be considered a "public
employee" within the definition of that term as set forth in the
Public Official and Employee Ethics Law and the Regulations of this
Commission. 65 P.S. Section 402; 51 Pa. Code Section 1.1.
Additionally, in each of your former positions with PCCD for which you
were classified as a Program Analyst III, you were a "public employee"
as defined by the above cited sections of the Ethics Law and the
Commission Regulations. These conclusions are based upon the
submitted documents including your job descriptions and related
memoranda, which when reviewed on an objective basis, indicate clearly
that the power exists within these positions to take or recommend
official action of a non - ministerial nature with respect to
Mr. Balinger "Skip" Brown
Page 3
contracting, procurement, planning, inspecting, administering or
monitoring grants, leasing, regulating, auditing or other activities
where the economic impact is greater than de minimus on the interests
of another person.
Consequently, upon termination of public service, you would
become a "former public employee" subject to Section 3(g) of the
Public Official and Employee Ethics Law. Section 3(g) of the Ethics
Act provides that:
Section 3. Restricted activities.
(g) No former public official or public
employee shall represent a person, with promised
or actual compensation, on any matter before the
governmental body with which he has been
associated for one year after he leaves that body.
Generally, in a request of this nature, the Commission would
attempt to identify the governmental bodies with which you have
associated during public employment. The restrictions which are set
forth in the Ethics Law prohibiting "representation" before the
governmental bodies would then be reviewed. However, in light of the
particular circumstances involved herein, it appears that you would
not be subject to these restrictions should you leave your present
employment for employment with Dauphin County.
The Commission has previously determined under former Act 170 of
1978 that where a public employee leaves one governmental body to
accept employment with another governmental body, the Ethics Law would
not restrict the ability to represent the new governmental body before
the former governmental body. Heverlina, Advice 88 -540, reviews prior
Commission decisions in this regard. Although these prior Commission
decisions were under former Act 170 of 1978 and, therefore, would not
be controlling in this case, the same reasoning set forth in those
determinations would apply to this question under Act 9 of 1989. As
the Commission has previously noted, the legislative intent was to
prohibit the representation of persons in circumstances that may give
rise to a conflict, that is, where the government employees or
officials leave the public sector and enter the private sector.
Heverlincr, Advice 88 -540 at 3. The Commission's conclusions have been
primarily based upon the fact that where the post - Commonwealth
employment is with another governmental body or entity, the concerns
the legislature sought to address through former Section 3(e) of the
Ethics Act were allayed or reduced because the new governmental
employer could not be expected to seek to influence the governmental
body formerly served by these individuals, in the same manner as a
non - governmental employer would. Therefore, the Commission has
concluded that the restrictions of former Section 3(e) would not be
applicable in such circumstances.
Id. at 4.
Mr. Balinger "Skip" Brown
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In Hagen, Opinion 84 -019, the Commission considered a situation
similar to the circumstances presented in this case. Where a state
employee left state service to accept employment with Montgomery
County, the Commission concluded that the individual became a "former
public employee" upon termination of Commonwealth service, but that
the restrictions of former Section 3(e) would not restrict the
individual's ability to represent the county before the former
governmental body. Id. at 4. The Commission specifically addressed
the questions of whether the county was a "person" as defined by the
Ethics Act, and whether the Legislature could be said to have intended
to apply the same restrictions under these circumstances where the
post - Commonwealth employer is another level of government, as would be
applied where a government employee leaves government and joins a
private, profit- making enterprise. The definition of "person" was
considered and the Commission stated its belief that the Legislature
intended to prohibit the individual's activity or ability to represent
"persons" in circumstances most likely to occur and most likely to
give rise to a conflict, specifically, where a government employee
leaves and enters the private sector. The Commission stated:
In such a situation, the former public employee's
ability to use his or her prior experience,
influence, etc., with the agency he served to the
new (private sector) employer's financial
advantage is more apparent. Likewise, a
prospective private sector employer, unlike a
governmental employer, might be able and motivated
to attempt to influence a public employee's
judgment or conduct by the promise of future
employment with the private sector employer.
Similarly, in this situation, you would be leaving state
employment to accept a governmental position with Dauphin County, and
the reasoning set forth in prior decisions of the Commission would
equally apply to your case. You would be considered a former public
employee with regard to your Commonwealth employment, but the
restrictions of Section 3(g) under present Act 9 would not apply to
you under these circumstances. You are cautioned, however, that in
your new capacity with Dauphin County you may be a "public employee"
as defined in the Ethics Law and may therefore continue to be subject
to the requirements of the Ethics Law in your new capacity.
In addition, sections 3(b) and 3(c) of the Ethics Law provide in
part that no person shall offer to a public official /employee and no
public official /employee shall solicit or accept anything of monetary
value based upon the understanding that the vote, official action, or
judgement of the public official /employee would be influenced thereby.
Mr. Balinger "Skip" Brown
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You will note that Sections 3(b) and 3(c) apply to everyone, whether
or not the person is a public official or public employee. It is
expressly assumed that there has been no such improper understanding
between you and your prospective employer.
Although the prohibitions of Section 3(g) would not restrict you
in your prospective county employment, it is important to note that
should you leave governmental employment, those restrictions would
apply to you. In that event, you may seek further advice of the
Commission with regard to the prohibitions and restrictions of the
Ethics Law.
Lastly, the propriety of the proposed conduct has only been
addressed under the Ethics Law; 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 Law.
Conclusion: As a Personnel Analyst III with the Department of Public
Welfare (DPW), you are to be considered a "public employee" as defined
in the Ethics Law. Additionally, in each of your former positions
with PCCD as a Program Analyst III, you were a "public employee" as
defined in the Ethics Law. Upon termination of service with DPW, you
would be a "former public employee" as regards your Commonwealth
employment. The former governmental bodies are PCCD and DPW. Section
3(g) of the Ethics Law would not restrict you in your prospective
employment with Dauphin County. In the event you terminate
governmental service, you would be subject to the restrictions of
Section 3(g) the Ethics Law, and you may seek further advice from
the Commission in that event. The propriety of the proposed conduct
has only been addressed under the Ethics Law.
Further, as long as you meet the definition of "public employee"
as set forth in the Ethics Law, you are required to comply with the
filing requirements for financial interests statements as set forth in
Section 4 of the Ethics Law,.65 P.S.S404. When service is
terminated, the Ethics Law also requires that a Statement of Financial
Interests be filed for the year following termination of service. You
are required to comply with these filing requirements with regard to
each governmental body with which you have been or will be a "public
employee ".
Pursuant to Section 7(11), 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.
Mr. Balinger "Skip" Brown
Page 6
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 in writing and must be received at the
Commission within 15 days of the date of this Advice pursuant to 51
Pa. Code 52.12.
Vincent . Dopko,
Chief Counsel