HomeMy WebLinkAbout95-568 ReillySTATE ETHICS COMMISSION
309 FINANCE BUILDING
PO. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
May 16, 1995
Margaret A. Reilly
2137 Rudy Road
Harrisburg, PA 17104 95 -568
Re: Conflict, Public Official /Employee, Private Employment or
Business, Independent Contractor, Existing Contract; Former
Public Employee, Section 3(g), Radiation Health Physicist IV,
Chief of Division, Agency Split, New Agency, DER.
Dear Ms. Reilly:
This responds to your letter of April 25, 1995, in which you
requested advice from the State Ethics Commission.
Issues: First, whether the Public Official and Employee Ethics Law
presents any restrictions upon employment of a Radiation Health
Physicist IV and Chief of the Division of Radiation Protection
following termination of service with the Deparmtent of
Environmental Resources. Second, whether a Radiation Health
Physicist IV 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.
Facts: On December 30, 1994, you retired from DER as Radiation
Health Physicist IV. Your last position with DER was Chief,
Division of Radiation Protection, Deputate for Air and Waste
Management. Before your retirement, your responsibilities included
providing technical support to the DER Deputate for State Parks and
Forestry in attending to the cleanup of a contaminated state -owned
facility, which is administered by the Deputate for Parks and
Forestry. After DER is split into two agencies, the Deputate for
State Parks and Forestry and the Deputate for Air and Waste
Management will be in separate agencies. You state that DER
appears to be interested in you contributing to the cleanup of the
contaminated state -owned facility over the next few years. You
state that you have read the Guide to Pennsylvania Public Official
and Employee Ethics Law (Rev. 4/93) and that you have questions
concerning appropriate activities under the Ethics Law,
particularly paragraph (g). You seek advice from the Commission
Reilly, Margaret A., 95 -568
May 16, 1995
Page 2
under the Ethics Law concerning several employment opportunities
following your retirement. You ask four questions. First, you
ask, following retirement, whether you can work on a DER project as
an independent contractor to a contractor already working on the
DER project. In this regard, you ask for clarification of the
meaning of the words "represent" and "governmental body." Second,
you ask, if you were reemployed by DER under the provisions of the
"window," which was applicable at the time of your retirement and
provides for a retiree's "emergency" reemployment for up to ninety -
five days a year, whether the effective date of your "leaving"
would be revised to coincide with the end of the emergency service.
Third, you ask whether you may work for DER on an emergency basis
for one project while you are working on another DER project as an
independent contractor for a contractor that has an existing
contract with DER. Fourth, you ask whether the split of DER into
two agencies would have any effect on your obligations under the
Ethics Law.
Discussion: As a Radiation Health Physicist IV and Chief of the
Division of Radiation Protection of DER, you were 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 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 DER must be
identified. Then, the scope of the prohibitions associated with
the concept and term of "representation" must be reviewed.
Reilly, Margaret A., 95 -568
May 16, 1995
Page 3
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 DER. 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 DER, Section 3(g) of the Ethics Law would apply and restrict
representation of persons or new employers vis -a -vis DER.
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
Reilly, Margaret A., 95 -568
May 16, 1995
Page 4
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 DER. In your request for advice, you asked
whether the split of DER into two agencies would have an effect on
your obligations under the Ethics Law. As stated above, you are
prohibited from representing a person before all subdivisions of
DER. A split in DER creating two agencies would not change the
prohibition; you would not be allowed to represent a person before
any subdivision of the two agencies, which were formerly DER.
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,
treatment or benefits that may be obtainable only because of his
association with his former governmental body.
In your request for advice, you asked whether emergency
employment with DER would change the date of your leaving. As an
emergency employee of DER, you would be a public employee as
defined under the Ethics Law. Consequently, upon termination of
your emergency employment with DER you would be a former public
employee subject to Section 3(g) of the Ethics Law quoted above.
The date of your "leaving" would be the date of the termination of
your emergency employment and the one -year restriction on
representation would apply again, starting from that date.
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
Reilly, Margaret A., 95 -568
May 16, 1995
Page 5
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
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 DER. However, you may not be identified on documents submitted
to DER. You may also counsel any person regarding that person's
appearance before DER. Once again, however, the activity in this
respect should not be revealed to DER. Of course, any ban under
the Ethics Law would not prohibit or preclude the making of general
informational inquiries of DER 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. References to DER in the preceding paragraph
refer to the agency as it exists today as well as any agencies
created as a result of a DER split.
Reilly, Margaret A., 95 -568
May 16, 1995
Page 6
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.
As to whether you could work on a DER project as an
independent contractor to a contractor already working on a DER
project, Section 3(g) of the Ethics Law does not prohibit
employment but rather than representation of a person before the
former public official's governmental body. Thus, although you may
seek whatever employment you choose, you must insure that you do
not represent your new employer before your former governmental
body. It is difficult to fathom how you could work for the
contractor on the existing DER contract without transgressing
Section 3(g) in that your appearance or the submission of documents
which would include your name would constitute prohibited
representation.
This advice now turns to your employment by DER as an
emergency employee. As Radiation Health Physicist IV /emergency
employee for DER, you would be a public employee as that term is
defined under the Ethics Law, and hence you would be 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
Reilly, Margaret A., 95 -568
May 16, 1995
Page 7
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.
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
been 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
Reilly, Margaret A., 95 -568
May 16, 1995
Page 8
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 DER 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 the person recording
the minutes or 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
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.
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.
Conclusion: As a Radiation Health Physicist IV /Chief of the
Division of Radiation Protection, you were considered a "public
employee" as defined in the Ethics Law. Upon termination of
service with DER, you became a "former public employee" subject to
Section 3(g) of the Ethics Law. The former governmental body is
DER and any agencies created as the result of a split of DER. The
Reilly, Margaret A., 95 -568
May 16, 1995
Page 9
restrictions as to representation outlined above must be followed.
As a Radiation Health Physicist IV /emergency employee for DER, 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
employer /business has matters pending before your governmental
body, then you could not participate in that matter and the
disclosure requirements of Section 3(j) of the Ethics Law as
outlined above must be satisfied. Lastly, the propriety of the
proposed conduct has only been addressed under the Ethics Law.
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 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 thirty (30) 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, Tnited States
mail, delivery service, or by FAX transmission (71 787 - 0806).
Failure to file such an appeal at the Commission within thirty
(30) days may result in the dismissal of the appeal.
cerely,
Vincent J. Do
Chief Counsel