HomeMy WebLinkAbout94-588 BenderADVICE OF COUNSEL
Jeannine M. Bender, Ph.D.
Director of Governmental Affairs
Mustard Seed Incorporated
Neshaminy Plaza One
Suite 102
3070 Bristol Pike
Bensalem, PA 19020
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
July 29, 1994
94 -588
Re: Former Public Employee; Section 3(g); DPW; Executive Assistant
to the Deputy for the Office of Mental Health.
Dear Ms. Bender:
This responds to your letter of July 1, 1994, 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 an executive assistant
following termination of service with DPW.
Facts: You seek an advisory regarding the representation of your
current employer, Mustard Seed Inc. before the Department of Public
Welfare (DPW). Your prior position with DPW was as an Executive
Assistant to the Deputy for the Office of Mental Health with job
duties consisting primarily of assisting the Deputy in running the
office and representing him in meetings when he was unable to
attend. You assume under the Ethics Law that you will not be
permitted to contact the Office of Mental Health on behalf of
Mustard Seed for a period of one year but are unsure of what
restrictions may apply to the rest of DPW in that the Office of
Mental Health is only one of eight major subdivisions within that
Department. You do assume that you may attend public meetings of
DPW as long as you do not participate on behalf of Mustard Seed.
Lastly, you have submitted your job description which is
incorporated herein by reference.
Discussion: As a Executive Assistant for Office of Mental Health,
DPW, 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. §402; 51 Pa. Code §11.1. This conclusion is based upon the
Bender, Jeannine M., 94 -588
July 29, 1994
Page 2
job description, which when reviewed on an objective basis,
indicates clearly that the power exists to take or recommend
official action of a non - ministerial nature with respect to
contracting, procurement, planning, inspecting, administering or
monitoring grants, leasing, regulating, auditing or other
activities where the economic impact is greater than de minimis 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.
Initially, to answer your request the governmental body with
which you were associated while working with DPW 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 you were
associated upon termination of public service would be DPW. 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
Bender, Jeannine M., 94 -588
July 29, 1994
Page 3
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 DPW, Section 3(g) of the Ethics Law would apply and restrict
representation of persons or new employers vis -a -vis DPW.
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 you
were associated is DPW.
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 pf 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,
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
Bender, Jeannine M., 94 -588
July 29, 1994
Page 4
"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.
The Commission, in Povovich, 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
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 Shav, 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 DPW. However, you may not be identified on documents submitted
to DPW. You may also counsel any person regarding that person's
appearance before DPW. Once again, however, the activity in this
respect should not be revealed to DPW. Of course, any ban under
Bender, Jeannine M., 94 -588
July 29, 1994
Page 5
the Ethics Law would not prohibit or preclude the making of general
informational inquiries of DPW 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 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.
In Confidential Opinion 93 -005, the Commission held that
Section 3(g) precludes a former public official /employee from
providing consulting services to his former governmental body for
a period of one year after termination of service in that the
prohibition against representing a person includes the former
public official /employee representing himself.
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 been or will be any transgression
thereof but merely to provide a complete response to the question
presented.
In answer to the two specific questions that you have posed,
you are precluded by the Ethics Law from representing your employer
Mustard Seed Inc. for a period of one year before DPW including but
not limited to the Office of Mental Health. As to your second
inquiry about attending public meetings as long as you do not
participate on behalf of Mustard Seed, you are advised that the
Ethics Law would not preclude yo14 from attending such public
meetings; however, you could not participate or lobby or act in a
fashion which would constitute representation of Mustard Seed at
such meetings.
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.
Bender, Jeannine M., 94 -588
July 29, 1994
Page 6
such.
Conclusion: As an Executive Assistant of Mental Health, DPW, you
were to be considered a "public employee" as defined in the Ethics
Law. Upon termination of service with DPW, you would become a
"former public employee" subject to Section 3(g) of the Ethics
Law. The former governmental body is DPW. The restrictions as to
representation 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
Finally, if you disagree with this Advice or if you
have any reason to challenge same, you may appeal the
Advice to the full Commission. A personal appearance
before the Commission will be scheduled and a formal
Opinion will be issued by the Commission.
Any such appeal must be in writing and must be
actually received at the Commission within fifteen (15)
days of the date of this Advice pursuant to 51 Pa.Code
513.2(h). The appeal maybe received at the Commission
by hand delivery, United States mail, delivery service,
or by FAX transmission (717- 787 - 0806). Failure to file
such an appeal at the Commission within fifteen (15)
days may result in the dismissal of the appeal.
Sincerely,
0
Vincent J. .opko
Chief Counsel