HomeMy WebLinkAbout92-516Dear Mr. Ehrman:
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783-1610
ADVICE OF COUNSEL
January 23, 1992
Mr. William A. Ehrman
York County Solid Waste and Refuse Authority
2653 Blackbridge Road
York, PA 17402
92 -516
Re: Former Public Official; Section 3(g); Municipal Authority
Member; Consultant to Authority.
This responds to your letter of November 26, 1991, in which
you requested advice from the State Ethics Commission.
Issue: Whether the Public Official and Employee Ethics Law
presents any restrictions upon employment of a municipal
authority member following termination of service with the
municipal authority, specifically with regard to serving as a
paid consultant to that authority.
Facts: As the Executive Director of the York County Solid Waste
and Refuse Authority ( "Authority ") in York, Pennsylvania, you
seek the advice of the State Ethics Commission on behalf of a
present Authority Member, Dr. Lloyd E. Lerew. You note that the
Authority was created under the Municipality Authorities Act of
1945, and that Dr. Lerew's position on the Authority is an unpaid
position. You specifically inquire as to whether Dr. Lerew would
be permitted to serve as a paid consultant to the Authority upon
leaving office. You acknowledge that the consulting position
would be filled within one year of completion of Dr. Lerew's term
of office.
Discussion: As a Member of the York County Solid Waste and
Refuse Authority ( "Authority "), Dr. Lloyd E. Lerew is to be
considered a "public official" within the definition of that term
as set forth in the Public Official and Employee Ethics Law and
the Regulations of the Commission. 65 P.S. 402; 51 Pa. Code 1.1.-
Mr. William A. Ehrman
January 23, 1992
Page 2
Consequently, upon termination of public service, Dr. Lerew
would become a "former public official" 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.
Initially, to answer your request the governmental body with
which Dr. Lerew has been 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.
The term "governmental body with which a public official or
public employee is or has been associated" is defined under the
Ethics Law as follows:
Section 2. Definitions.
"Governmental body with which a public
official or public employee is or has been
associated." The governmental body within
State government or a political subdivision
by which the public official or employee is
or has been employed or to which the public
official or employee is or has been appointed
or elected and subdivisions and offices
within that governmental body.
In applying the above definition to the instant matter, we
must conclude that the governmental body with which Dr. Lerew has
been associated upon termination of public service would be the
York County Solid Waste and Refuse Authority in its entirety.
The above is based upon the language of the Ethics Law, the
legislative intent (Legislative Journal of House, 1989 Session,
No. 15 at 290, 291) and the prior precedent of this Commission.
Thus, in Sirolli, Opinion 90 -006, the Commission found that a
former Division Director of the Department of Public Welfare
(DPW) was not merely restricted to the particular Division as was
contended but was in fact restricted to all of DPW regarding the
Mr. William A. Ehrman
January 23, 1992
Page 3
one year representation restriction. Similarly in Sharp, Opinion
90- 009 -R, it was determined that a former legislative assistant
to a state senator was not merely restricted to that particular
senator but to the entire Senate as his former governmental body.
Therefore, within the first year after termination of
service with the York County Solid Waste and Refuse Authority,
Section 3(g of the Ethics Law would apply and restrict
representation of persons or new employers vis -a -vis the York
County Solid Waste and Refuse Authority.
It is noted that Act 9 of 1989 significantly broadened the
definition of the term "governmental body with which a public
official or public employee is or has been associated." It was
the specific intent of the General Assembly to define the above
term so that it was not merely limited to the area where a public
official /employee had influence or control but extended to the
entire governmental body with which the public official /employee
was associated. The foregoing intent is reflected in the
legislative debate relative to the amendatory language for the
above term:
We sought to make particularly clear
that when we are prohibiting for 1 year that
revolving -door kind of conduct, we are
dealing not only with a particular
subdivision of an agency or a local
government but the entire unit..."
Legislative Journal of House, 1989 Session,
No. 15 at 290, 291.
Therefore, since the Ethics Law must be construed to
ascertain and effectuate the intent of the General Assembly under
1 Pa. C.S.A. 1901, it is clear that the governmental body with
which Dr. Lerew has been associated is the York County Solid
Waste and Refuse Authority in its entirety.
Turning now to the scope of the restrictions under Section
3(g), the Ethics Law does not affect one's ability to appear
before agencies or entities other than with respect to the former
governmental body. Likewise, there is no general limitation on
the type of employment in which a person may engage, following
departure from their governmental body. 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,
Mr. William A. Ehrman
January 23, 1992
Page 4
treatment or benefits that may be obtainable only because of his
association with his former governmental body.
In respect to the one year restriction against such
"representation," the Ethics Law defines 'Represent" as follows:
Section 2. Definitions.
"Represent." '
Represent. To act on behalf of any
other person in any activity which includes,
but is not limited to, the following:
personal appearances, negotiations, lobbying
and submitting bid or contract proposals
which are signed by or contain the name of a
former public official or public employee.
In addition, the term "Person" is defined as follows under
the Ethics Law:
Section 2. Definitions.
"Person." A business, governmental
body, individual, corporation, union,
association,' firm, partnership, committee,
club or other organization or group of
persons.
The Commission, in Popovich, Opinion 89 -005, has also
interpreted the term "representation" as used in Section 3(g) of
the Ethics Law to prohibit:
1. Personal appearances before the former governmental
body or bodies, including, but not limited to, negotiations or
renegotiations'in general or as to contracts;
2. Attempts to influence;
3. Submission of bid or contract proposals which are
signed or contain the name of the former public
official/employee;
4. Participating in any matts.rs before the former
governmental body as to acting on behalf of a person;
5. Lobbying, that is representing the interests of any
person or employer before the former governmental body in
relation to legislation, regulations, etc.
Mr. William A. Ehrman
January 23, 1992
Page 5
The Commission has also held that 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 former
governmental body constitutes an attempt to influence the former
governmental body. In Shay, Opinion 91 -012, the Commission held
that Section 3(g) would prohibit the inclusion of the name of a
former public official /public employee on invoices submitted by
his new employer to the former governmental body, even though the
invoices pertained to a contract which existed prior to
termination of public service. Therefore, within the first year
after termination of service, Dr. Lerew should not engage in the
type of activity outlined above.
Dr. Lerew may assist in the preparation of any documents
presented to the York County Solid Waste and Refuse Authority so
long as Dr. Lerew is not identified as the preparer. Dr. Lerew
may also counsel any person regarding that person's appearance
before the Authority. Once again, however, the activity in this
respect should not be revealed to the Authority. Of course, any
ban under the Ethics Law would not prohibit or preclude the
making of general informational inquirics of the Authority to
secure information which is available to the general public.
This must not be done in an effort to indirectly influence the
former governmental body or to otherwise make known to that body
the representation of, or work for the new employer.
In applying the above restrictions of Section 3(g) of the
Ethics Law to your specific inquiry, Section 3(g) of the Ethics
Law would prohibit Dr. Lerew from providing consulting services
directly to the York County Solid Waste and Refuse Authority for
one year following termination of his service as a public
official with that governmental body. As a paid private
consultant, Dr. Lerew might serve the interest of the Authority,
but he would also be upholding his own interest in a private
capacity. Such representation by Dr. Lerew of his own private
interest would be prohibited by Sectio.. 3(g) during the one
year period of its applicability. Confidential Opinion 89 -019.
It is noted that Section 3(a) of the Ethics Law would
prohibit a use of the authority of office or confidential
information received by holding a public position so as to obtain
a private consulting contract with the governmental body upon
termination of public service, and that Section 3(f) of the
Ethics Law would prohibit such contracting with an incumbent
public official /public employee where there has been no open and
public process, but rather, private negotiations between the
governmental body and the public official /public employee. 111,,
Confidential Opinion 89 -019, supra. It is therefore assumed -
that such prohibited activities have not occurred.
Mr. William A. Ehrman
January 23, 1992
Page 6
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. Reference
is made to these provisions of the law not to imply that there
has or will be any transgression thereof tut merely to provide a
complete response to the question presented.
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. Specifically
not addressed herein is the applicability of the Municipality
Authorities Act.
Conclusion: As a Member of the York County Solid Waste and
Refuse Authority ( "Authority "), Dr. Lloyd E. Lerew is to be
considered a "public official" as defined in the Ethics Law.
Upon termination of service with the York. County Solid Waste and
Refuse Authority, Dr. Lerew would become a former public
official" subject. to Section 3(g) of the Ethics Law. The former
governmental body is the York County Solid Waste and Refuse
Authority in its entirety. The restrictions as to representation
and as to Sections 3(a), (b), (c), and (f) outlined above must be
followed. The propriety of the proposed conduct has only been
addressed under the Ethics Law.
Further, should service be terminated, as outlined above,
the Ethics Law also requires that a Statement of Financial
Interests be filed for the year following termination of service.
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.
This letter is a public record and will be made available as
such.
Finally, if you disagree with
reason to challenge same, you
Commission review this Advice. A
Commission will be scheduled and a
this Advice or if you have any
may request that the full
personal appearance before the
formal Opinion from the
Mr. William A. Ehrman
January 23, 1992
Page 7
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.
truly yours,
Vincent J. Dopko,
Chief Counsel