HomeMy WebLinkAbout94-608 CookSTATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
September 26, 1994
George Donald Cook
P.O. Box 232
Dauphin, PA 17018 -0232 94 -608
Re: Conflict, Public Official /Employee, Private Employment or
Business, Former Public Employee, Section 3(g), PennDOT,
Senior Highway Designer, Mellow Bill, 95 -Day Return Provision.
Dear Mr. Cook:
This responds to your letter of August 29, 1994, in which you
requested advice from the State Ethics Commission.
Issue: Whether a retired Senior Highway Designer working for the
Commonwealth of Pennsylvania, Department of Transportation
( "PennDOT ") pursuant to a 95 -day return provision as allowed by the
Mellow Bill is prohibited or restricted by the Public Official and
Employee Ethics Law from working with, being employed by or
associated with a business /person in a private capacity in addition
to public service, and whether the Public Official and Employee
Ethics Law presents any restrictions upon employment of the Senior
Highway Designer following termination of such service with
PennDOT.
Facts: You served in a contract proposal review and specification
writer position as a Senior Highway Designer in the Specification
and Proposal Review Section, Contract Management Division, of
PennDOT's Bureau of Design at the central office in Harrisburg,
until retiring on December 20, 1991 under the Mellow Bill.
Subsequently, you were asked by PennDOT on three separate occasions
to return as an employee under the 95 -day return provision in order
to assist the Bureau of Design in meeting its contract letting
goals for fiscal years 1991/92, 1992/93 and 1993/94. The 95 -day
periods were strategically selected time frames, conducive to
meeting letting schedules by the June 30 fiscal year closeouts.
You have posed numerous specific inquiries. You ask whether
the Ethics Law would prohibit a "public employee" from engaging in
outside employment or business activities. You ask whether a
Cook, George Donald, 94 -608
September 26, 1994
Page 2
retired Senior Highway Designer working under the 95 -day return
provision per the Mellow Bill in the Contracts Management Division,
Bureau of Design of PennDOT is prohibited or restricted by the
Ethics Law from working with or being employed by or associated
with a business /person in the private sector in addition to public
service. You ask for advice as to any obligations you may have as
to filing written memoranda as required by Section 3(j) of the
Ethics Law. You ask whether such businesses that you would be
associated with may engage in contractual agreements with PennDOT.
You ask what restrictions the Ethics Law would impose upon your
employment following termination of service with PennDOT following
a 95 -day return provision as allowed by the Mellow Bill. Finally,
you ask whether you may secure technical information from PennDOT
and provide assistance in the preparation of engineering drawings,
specifications, calculations and similar documents presented or
submitted to PennDOT while engaged in private business employment.
You have submitted a copy of your job classification
specifications and an organizational chart, which documents are
incorporated herein by reference. It is noted that the Senior
Highway Designer does advanced professional highway design work in
designing highway projects. An employee in this class
independently prepares or reviews complete sets of plans for
complex highway projects. The work may include lead work over
lower level technicians and designers. Your assignments would be
performed independently and reviewed upon completion by a
managerial supervisor. Among the numerous examples of your work
would be designing the most complex highway projects; developing
complete sets of design plans for such projects, preparing plans
and specifications, and computing cost estimates; reviewing certain
statewide contract proposals; reviewing complex design plans
prepared by consultants for technical standards and adherence to
applicable specifications; acting as liaison contact with
consultants; coordinating department and outside agency activities
relative to highway planning and location; administering and
coordinating a specialized engineering district function such as
planning and programming, grade crossing, transportation systems
management, pavement evaluation, and safety design liaison;
preparing an engineering district's project proposal and estimate
to include special provisions and indicating specifications,
quantities, and descriptive material as indicated in related
specifications.
It is noted that your analysis of your level of responsibility
in the Bureau of Design appears to contradict your job
classification specifications, as well as your acknowledgement
noted below that you would be a "public employee" as set forth in
the Ethics Law. You state that your responsibilities did not
include activities requiring official actions of a decision making
nature with regard to contracting, procurement, administering or
Cook, George Donald, 94 -608
September 26, 1994
Page 3
monitoring grants, leasing, developing regulations or financial
management. You also state that you were not in any way delegated
with authority for granting official approvals, consultant
selection or official actions in shaping PennDOT policy decisions.
Therefore you feel that your actions would involve a de minimis
impact. You state that you took no action of a nonministerial
nature.
You have proffered your own analysis of the application of the
Ethics Law to your situation, which is summarized as follows. You
proffer your view that the Ethics Law does not prohibit a public
employee from engaging in employment with outside business
activities. You acknowledge that if you would be asked by PennDOT
to serve during any future 95 -day period, you would most likely be
considered a "public employee" as defined by the Ethics Law. You
state that if your private employer or business would require a
decision from PennDOT where you would be participating in official
duties such as review of project submission whereby a conflict
would result, you would be removed from that process. You note
Section 3 (f) as applying to contracts between a business with which
you would be associated and PennDOT. Upon any termination of
service with PennDOT, you state that it appears that you would be
subject to the restrictions of Section 3(g) of the Ethics Law but
not those of Section 3(i). You proffer that the conflict of
interest law primarily focuses on financial conflicts and
violations of public trust rather than engineering or technical
support. You propose a firm commitment to any restrictions imposed
by the Ethics Commission pursuant to your request in order to act
in good faith and avoid controversy.
Based upon all of the above you request an advisory from the
State Ethics Commission.
Discussion: As a Senior Highway Designer for the Commonwealth of
Pennsylvania, Department of Transportation ( "PennDOT "), you would
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 job classification
specifications, which when reviewed on an objective basis, indicate
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. Thus, at any given time that you are serving in
the position of Senior Highway Designer -- even if pursuant to the
95 -day return provision allowed by the Mellow Bill -- you would be
a "public employee" subject to the Ethics Law.
Cook, George Donald, 94 -608
September 26, 1994
Page 4
This advisory shall first address your inquiry with regard to
the restrictions of the Ethics Law applicable to you during your
service as a public employee, and shall subsequently address the
restrictions applicable to you at such times as you are a former
"public employee."
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
duties and responsibilities unique to a
particular public office or position of public
employment.
"Business with which he is associated."
Any business in which the person or a member
of the person's immediate family is a
director, officer, owner, employee or has a
financial interest.
Cook, George Donald, 94 -608
September 26, 1994
Page 5
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. Reference is
made to these provisions of the law not to imply that there has or
will be any transgression thereof but merely to provide a complete
response to the question presented.
In applying the above provisions of the Ethics Law to the
instant matter, it is noted that Section 3(a) of the Ethics Law
does not prohibit public officials /employees from outside business
activities or employment; however, the public official /employee may
not use the authority of office for the advancement of his own
private pecuniary benefit or that of a business with which he is
associated. Pancoe, Opinion 89 -011. A public official /employee
must exercise caution so that his private business activities do
not conflict with his public duties. Crisci, Opinion 89 -013.
Thus, a public official /employee could not perform private business
using governmental facilities or personnel. In particular, the
governmental telephones, postage, staff, equipment, research
materials, personnel or any other property could not be used as a
means, in whole or part, to carry out private business activities.
In addition, the public official /employee could not during
government working hours, solicit or promote such business
activity. Pancoe, supra. Similarly, Section 3(a) would expressly
prohibit the use of confidential information received by holding
public office / employment for such a prohibited private pecuniary
benefit.
In the event that your private employer or business has a
matter pending before PennDOT or if you as part of such official
duties must participate, review or pass upon that matter, a
conflict would exist. Miller, Opinion 89 -024. In those instances,
it will be necessary that you be removed from that process.
In such cases as noted above, Section 3(j) of the Ethics Law
would require not only that you abstain from participation but also
file a written memorandum to that effect with your supervisor.
In summary, the Ethics Law would restrict the following:
1. The use of authority of office to obtain any business in
a private capacity;
2. utilization of confidential information gained through
public position;
3. participating in discussions, reviews, or recommendations
Cook, George Donald, 94 -608
September 26, 1994
Page 6
on matters which relate to the business /private employer
which may come before the governmental body and in such
cases publicly announcing the relationship or advising
the supervisor as well as filing a written memorandum as
per the requirements of Section 3(j) of the Ethics Law.
Brooks, Opinion 89 -023.
Having set forth the above restrictions which would apply to
you with regard to private employment at such times that you would
serve as a public employee, the restrictions of the Ethics Law
which apply to former public employees shall now be addressed.
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 PennDOT 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, the
governmental body with which you have been associated upon
termination of public service would be PennDOT in its entirety,
including but not limited to the Specification and Proposal Review
Section, the Contracts Management Division and /or the Bureau of
Design. The above is based upon the language of the Ethics Law,
Cook, George Donald, 94 -608
September 26, 1994
Page 7
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 PennDOT, Section 3(g) of the Ethics Law would apply and
restrict representation of persons or new employers vis -a -vis
PennDOT in its entirety, including but not limited to the
Specification and Proposal Review Section, the Contract Management
Division and /or the Bureau of Design.
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
have been associated is PennDOT in its entirety, including but not
limited to the Specification and Proposal Review Section, the
Contract Management Division and /or the Bureau of Design.
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
Cook, George Donald, 94 -608
September 26, 1994
Page 8
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,
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.
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
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
Cook, George Donald, 94 -608
September 26, 1994
Page 9
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 PennDOT. However, you may not be identified on documents
submitted to PennDOT. You may also counsel any person regarding
that person's appearance before PennDOT. Once again, however, the
activity in this respect should not be revealed to PennDOT. Of
course, any ban under the Ethics Law would not prohibit or preclude
the making of general informational inquiries of PennDOT 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.
It is noted that each time that you return to perform the
duties of a Senior Highway Designer for PennDOT - even if it is
pursuant to the 95 -day return provision allowed by the Mellow Bill
-- you will become a "public employee" subject to the Ethics Law,
and each time that you terminate such employment with PennDOT, the
one year period of applicability of Section 3(g) will commence to
run anew as to you. See, Solomon, Advice of Counsel No. 91- 576 -S2.
All of your specific inquiries but one have been addressed
above. The remaining question which you have posed is whether your
private employer may engage in a contractual agreement with
PennDOT.
During such times as you are employed as a Senior Highway
Cook, George Donald, 94 -608
September 26, 1994
Page 10
Designer for PennDOT, the restrictions of Section 3(f) of the
Ethics Law must be observed for such contracting. Section 3(f) of
the Ethics Law provides as follows:
Section 3. Restricted activities
(f) No public official or public
employee or his spouse or child or any
business in which the person or his spouse or
child is associated shall enter into any
contract valued at $500 or more with the
governmental body with which the public
official or public employee is associated or
any subcontract valued at $500 or more with
any person who has been awarded a contract
with the governmental body with which the
public official or public employee is
associated, unless the contract has been
awarded through an open and public process,
including prior public notice and subsequent
public disclosure of all proposals considered
and contracts awarded. In such a case, the
public official or public employee shall not
have any supervisory or overall responsibility
for the implementation or administration of
the contract. Any contract or subcontract
made in violation of this subsection shall be
voidable by a court of competent jurisdiction
if the suit is commenced within 90 days of the
making of the contract or subcontract.
Parenthetically, where contracting is otherwise allowed or
where there appears to be no expressed prohibitions to such
contracting, the above particular provision of the law would
require that an open and public process must be used in all
situations where a public official /employee is otherwise
appropriately contracting with his own governmental body, or
subcontracting with any person who has been awarded a contract with
the governmental body, in an amount of $500.00 or more. This open
and public process would require that the following be observed as
to the contract with the governmental body:
(1) prior public notice of the employment or contracting
possibility;
(2) sufficient time for a reasonable and prudent competitor/
applicant to be able to prepare and present an
application or proposal;
(3) public disclosure of all applications or proposals
Cook, George Donald, 94 -608
September 26, 1994
Page 11
considered and;
(4) public disclosure of the contract awarded and offered and
accepted.
Section 3(f) of the Ethics Law also requires that the public
official /employee may not have any supervisory or overall
responsibility as to the implementation or administration of the
contract with the governmental body.
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 Governor's Code of Conduct.
Conclusion: As a retired Senior Highway Designer for the
Commonwealth of Pennsylvania Department of Transportation ( PennDOT)
serving in said capacity pursuant to a 95 -day return provision as
allowed by the Mellow Bill, you would be a public employee subject
to the provisions of the Ethics Law. Section 3(a) of the Ethics
Law would not preclude you from outside employment /business
activity subject to the restrictions and qualifications as noted
above. In the event that the private employer /business has matters
pending before PennDOT, then you could not participate in such
matters and the disclosure requirements of Section 3(j) of the
Ethics Law as outlined above must be satisfied. During such times
as you are employed by PennDOT as a Senior Highway Designer,
contracting between your private employer and PennDOT must conform
to the restrictions of Section 3.(f) as set forth above. In each
instance of termination of service with PennDOT, you would become
a "former public employee" subject to a one -year period of
applicability of Section 3(g) of the Ethics Law. The former
governmental body would be PennDOT in its entirety, including but
not limited to the Specification and Proposal Review Section, the
Contract Management Division and /or the Bureau of Design. 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, in each instance that service would 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
Cook, George Donald, 94 -608
September 26, 1994
Page 12
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 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 may
be received at the Commission by hand delivery, United States
mail, delivery service, or by FAS 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.
Vincent J Dopko
Chief Counsel