HomeMy WebLinkAbout94-651 PogashDear Mr. Pogash:
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
December 22, 1994
William J. Pogash
Associate Director of Special Studies
Department of Transportation
Room 905, Transportation and Safety Building
Harrisburg, PA 17120
94 -651
Re: Former Public Employee; Section 3(g); PennDOT; Video Producer.
This responds to your letter of December 7, 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 a Video Producer
following termination of service with the Commonwealth of
Pennsylvania, Department of Transportation.
Facts: Robert Kelly is a recently retired employee of PennDOT and
is seeking an advisory opinion relative to the program with which
he will be working which is a PennDOT sponsored program. Kelly was
employed by PennDOT as a Video Producer in the Bureau of Personnel -
Training Division. The Program, the Local Technical Assistance
Program (LTAP), is federally funded and administered by your office
at PennDOT; however, the program is run through a research
agreement between PennDOT and Penn State University (PSU). Kelly
will be working as a consultant to PSU and would be paid directly
by PSU as a media coordinator. Kelly will have an additional duty
of working through Commonwealth Media Services (CMS) to schedule
video editing and copying for the LTAP Program. Kelly played no
part in either the negotiation or execution of the Agreement with
PSU which seeks to hire Kelly as a consultant given PSU's knowledge
and satisfaction with Kelly's past work product. You seek approval
for Kelly to be given authorization to work on the project if
permissible under the Ethics Law and regulations.
Discussion: As a Video Producer for the Commonwealth of
Pennsylvania, Department of Transportation ( "PennDOT "), Kelly is
considered a "public employee" within the definition of that term
as set forth in the Public Official and Employee Ethics Law and the
Pogash, William J., 94 -651
December 22, 1994
Page 2
Consequently, upon termination
a "former public employee" subject
Official and Employee Ethics Law.
provides that:
Regulations of this Commission. 65 P.S. 5402; 51 Pa. Code 511.1.
This conclusion is based upon the 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.
of public service, Kelly became
to Section 3(g) of the Public
Section 3(g) of the Ethics Act
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 Kelly has 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
necessary conclusion is that the governmental body with which Kelly
has been associated upon termination of public service will be
PennDOT in its entirety, including but not limited to PennDOT. The
above is based upon the language of the Ethics Law, the legislative
intent (Legislative Journal of House, 1989 Session, No. 15 at 290,
Pogash, William J., 94 -651
December 22, 1994
Page 3
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 PennDOT.
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
Kelly has been associated is PennDOT in its entirety, including but
not limited to PennDOT.
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
Pogash, William J., 94 -651
December 22, 1994
Page 4
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;
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 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
Pogash, William J., 94 -651
December 22, 1994
Page 5
termination of service, Kelly should not engage in the type of
activity outlined above.
Kelly may assist in the preparation of any documents presented
to PennDOT. However, Kelly may not be identified on documents
submitted to PennDOT. Kelly 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.
Furthermore, 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.
As to your specific inquiry concerning Kelly working as a
consultant for PSU, the Ethics Law would not prohibit such a
contractual arrangement in that PSU is not the former governmental
body of Kelly. In addition, assuming that CMS is a separate
governmental body from PennDOT, the Ethics Law would likewise
impose no prohibition as to Kelly working with CMS. However, the
Ethics Law would prohibit Kelly from any type of representation
before his former governmental body, PennDOT, as noted above. In
Pogash, William J., 94 -651
December 22, 1994
Page 6
this regard, see Carlton, Advice 91 -564 wherein it was determined
that the Director of Communications and Special Assistant to the
Labor and Industry Secretary was prohibited, after termination of
service, from contracting to complete a video production that he
was making for Labor and Industry prior to his termination of
service. However, in this case, it would appear that Kelly would
be contracting with PSU and working with CMS which is not
prohibited as long as Kelly restricts his conduct as to PennDOT
within the parameters as noted above.
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 Governor's Code of
Conduct.
Conclusion: As a Video Producer for the Commonwealth of
Pennsylvania, Department of Transportation ( "PennDOT "), Kelly is
considered a "public employee" as defined in the Ethics Law. Upon
termination of service with PennDOT, Kelly became a "former public
employee" subject to Section 3(g) of the Ethics Law. The former
governmental body is PennDOT in its entirety, including but not
limited to PennDOT. 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.
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
Pogash, William J., 94 -651
December 22, 1994
Page 7
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 PAS 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. P 711/6
ko
Chief Counsel