HomeMy WebLinkAbout93-504 DanielsMs. Katherine Daniels
606 State Street
Lancaster, PA 17603
Dear Ms. Daniels:
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
January 13, 1993
93 -504
Re: Conflict, Public Official /Employee, Senior Planner, Lancaster
County Planning Commission, Participation in Selection of
Consultant, Position of Employment with Successful Applicant,
Former Public Employee, Section 3(g).
This responds to your letter of December 9, 1992, in which you
requested advice from the State Ethics Commission.
Issue: Whether the Public Official and Employee Ethics Law
presents any prohibition or restrictions upon a senior planner with
a county planning commission with regard to employment with a firm
which was selected as the consultant for two regional comprehensive
plans funded in large part by the county, where this individual
participated in the selection of the consultant; prepared a
contract between the county and the funded municipalities for one
of the plans; and provided county guidance at monthly meetings on
both plans.
Facts: Noting a prior telephone conversation with Commission
staff, you state that you are writing for guidance concerning a
change in employment from the public to the private sector. You
are currently employed as a Senior Planner for the . Lancaster County
Planning Commission and have just resigned your position effective
December 31, 1992 to take a position with a private local planning
firm. You have worked closely with that firm in your assigned
duties and you are anxious that public confidence in the County and
yourself be maintained during the transition and after.
In your current position, you were assigned to be a liaison to
the development of two regional comprehensive plans funded in large
part by the County. The firm you will be joining was chosen as the
consultant for both plans. You were involved in the short - listing
of the consultant for one of the plans, but did not participate in
the final selection of the consultant for either of the plans. You
also prepared a contract between the County and the funded
municipalities for one of the plans, and provided County guidance
Ms. Katherine Daniels
January 13, 1993
Page 2
at monthly meetings on both plans.
You state that three weeks prior to your inquiry with this
Commission, you were offered a position with the said firm which
you accepted. For the remainder of your employment with the County
and in your new position, you would like to avoid any improprieties
or even the appearance of impropriety in your new duties and
specifically in your "relationship" with municipalities and the
Planning Commission. You state that you do not foresee any
conflicts. However, you are interested in knowing specifically how
the State Ethics Law would apply to you.
Discussion: As a Senior Planner for the Lancaster County Planning
Commission, you are a public employee as that term is defined under
the Ethics Law, and hence you are subject to the provisions of that
law.
Section 3(a) of the Ethics Law provides:
Section 3. Restricted Activities.
(a) No public official or public
employee shall engage in conduct that
constitutes a conflict of interest.
The following terms are defined in the Ethics Law as follows:
Section 2. Definitions.
"Conflict or conflict of interest." Use
by a public official or public employee of the
authority of his office or employment or any
confidential information received through his
holding public office or employment for the
private pecuniary benefit of himself, a member
of his immediate family or a business with
which he or a member of his immediate family
is associated. "Conflict" or "conflict of
interest" does not include an action having a
de minimis economic impact or which affects to
the same degree a class consisting of the
general public or a subclass consisting of an
industry, occupation or other group which
includes the public official or public
employee, a member of his immediate family or
a business with which he or a member of his
immediate family is associated.
"Authority of office or employment." The
actual power provided by law, the exercise of
which is necessary to the performance of
Ms. Katherine Daniels
January 13, 1993
Page 3
duties and responsibilities unique to a
particular public office or position of public
employment.
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
anything of monetary value 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. Thus, for
example, Sections 3(b) and 3(c) of the Ethics Law would prohibit
the offer, solicitation, or acceptance of a position of employment
based upon the understanding that the vote, official action, or
judgment of the public official /public employee would be influenced
by the proffered employment. This Advice is expressly conditioned
upon the assumption that there are no such understandings in this
case which would violate Sections 3(b) and /or 3(c) of the Ethics
Law.
Under Section 3(a) of the Ethics Law quoted above, a public
employee may not use the authority of public office /employment or
confidential information to obtain a private pecuniary benefit for
himself, a member of his immediate family, or a business with which
he or a member of his immediate family is associated. In applying
Section 3(a) of the Ethics Law to the proffered facts, Section 3(a)
would prohibit you from using the status of your public employment
or your activities to advance an opportunity of private employment
with the private local planning firm. See, Wall, Advice 90 -567;
Stewart, Advice 92 -500. It is expressly assumed for purposes of
this Advice that you have not taken any such action. In addition,
you could not use the authority of your public employment, or any
confidential information received by being in your position of
public employment, either as a means of obtaining or advancing an
opportunity of private employment, or as a means of attempting to
eliminate any potential competitors who would be competing with you
for such an employment position. See, Wall, supra (Citing Pepper,
Opinion 87 -008).
One example of a prohibited use of authority of public office/
employment to obtain a private pecuniary benefit of prospective
employment would be to participate as a public employee in matters
pertaining to a prospective employer so as to favor that firm.
This could even occur at the "short- list" stage in selecting a
consultant. The facts which you have submitted do not reveal
whether you engaged in such conduct. It is not clear at what point
the consulting firm became your prospective employer. In the
context of a request for an advice /opinion, there is no independent
investigation of the facts by this Commission such as would be
performed in the context of a complaint filed with this Commission.
To the contrary, the advice /opinion process requires that the
Commission issue the advice /opinion assuming the submitted facts to
Ms. Katherine Daniels
January 13, 1993
Page 4
be true.
It is because of this reliance upon the inquirer for the facts
that advices must frequently have stated conditions set forth
within them. Conditions upon which this Advice is based include,
therefore, the conditions that you did not use your public
employment status or activities, the authority of your public
employment or any confidential information received by holding your
position of public employment to obtain or advance an opportunity
for private employment and /or to eliminate competition for such a
position.
Subject to all of the qualifications noted above, Section 3(a)
of the Ethics Law would not preclude you from accepting the
position with the said local planning firm.
For purposes of providing a complete response to your inquiry,
you are advised that upon termination of your employment with the
Lancaster County Planning Commission, you will become a former
public employee subject to the restrictions of Section 3(g) of the
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 you have been associated while working with the Lancaster
County Planning Commission 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
Ms. Katherine Daniels
January 13, 1993
Page 5
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 you have been
associated upon termination of public service would be the
Lancaster County Planning Commission 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 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 Lancaster County Planning Commission, Section 3(g) of the
Ethics Law would apply and restrict representation of persons or
new employers vis -a -vis the Lancaster County Planning Commission.
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. 51901, it is clear that the governmental body with which you
have been associated is the Lancaster County Planning Commission 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
Ms. Katherine Daniels
January 13, 1993
Page 6
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
a 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 governmental body.
In respect to the one year restriction against such
"representation," the Ethics Law defines "Represent" as follows:
Section 2. Definitions.
"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
by or contain the name of the former public official /employee;
4. Participating in any matters before the former
Ms. Katherine Daniels
January 13, 1993
Page 7
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.
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, you should not engage in the type of
activity outlined above.
You may assist in the preparation of any documents presented
to the Lancaster County Planning Commission. However, you may not
be identified on documents submitted to the Lancaster County
Planning Commission. You may also counsel any person regarding
that person's appearance before the Lancaster County Planning
Commission. Once again, however, the activity in this respect
should not be revealed to the Lancaster County Planning Commission.
Of course, any ban under the Ethics Law would not prohibit or
preclude the making of general informational inquiries of the
Lancaster County Planning Commission 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.
Thus, during the one -year period of applicability of Section
3(g), you specifically could not have a "relationship" with the
Lancaster County Planning Commission where you would be
representing your new employer and /or its clients.
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 Law 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 County Code.
Conclusion: As a Senior Planner for the Lancaster County Planning
Commission, you are a public employee subject to the provisions of
the Ethics Law. Subject to the qualifications noted above, Section
3(a) of the Ethics Law would not restrict you from accepting a
position with the private local planning firm which was selected as
Ms. Katherine Daniels
January 13, 1993
Page 8
the consultant for two regional comprehensive plans funded in large
part by the County. This Advice is expressly conditioned upon the
assumptions that there are no understandings in this case which
would violate Sections 3(b) and /or 3(c) of the Ethics Law, and that
you did not use your public employment status or activities, the
authority of your public employment or any confidential information
received by being in your position to obtain or advance an
opportunity for employment with the said planning firm and /or to
eliminate competition for such a position. Upon termination of
your service with the Lancaster County Planning Commission, you
would become a "former public employee" subject to Section 3(g) of
the Ethics Law. You must comply with the restrictions of Section
3(g) as a former public employee, as those restrictions have been
outlined above. Your former governmental body would be the
Lancaster County Planning Commission in its entirety. 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.
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 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.
cerely,
Vincent x! Dopko
Chief Counsel