HomeMy WebLinkAbout96-549 CohenHenry Allen Cohen, R.A.
Cohen Associates Architects
927 -929 North Second Street
Harrisburg, PA 17102
Dear Mr. Cohen:
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
April 30, 1996
96 -549
Re: Former Public Official; Section 3(g); Board Member; School District;
Architectural Services.
This responds to your letters of March 28, 1996 and April 4, 1996 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 member of a school board following termination of
service with the school district.
Facts: You have served as a Member of the Board of School Directors of the
Camp Hill School District until your term expired in December, 1995. You and your
wife are both registered architects and the sole owners of Cohen Associates
Architects. You are interested in performing architectural services for the Camp Hill
School District and are inquiring as to any restrictions that may apply prior to
December, 1996. At the option of the School Board, you would be providing said
services to the School District in the capacity of either the Architect of Record or an
independent contractor.
Discussion: In the former capacity as a Member of the Board of School
Directors for Camp Hill School District, you would be considered a "public official"
within the definition of that term as set forth in the Public Official and Employee Ethics
Law and the Regulations of the Commission. 65 P.S. §402; 51 Pa. Code §11.1.
Consequently, upon termination of public service, you became a "former public
official" 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
Cohen, 96 -549
April 30, 1996
Page 2
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 the Camp Hill School District 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.
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.
The Ethics Law must be construed to ascertain and effectuate the intent of the
General Assembly under 1 Pa. C.S.A. §1901.
Based upon the above, the governmental body with which you were associated
upon termination of public service would be the Camp Hill School District. 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.
Cohen, 96 -549
April 30, 1996
Page 3
Therefore, within the first year after termination of service with the Camp Hill
School District, Section 3(g) of the Ethics Law would apply and restrict representation
of persons or new employers vis -a -vis the Camp Hill School District.
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 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. Section 3(g) would also prohibit in general the inclusion
of the name of a former public official /public employee on invoices submitted by his
Cohen, 96 -549
April 30, 1996
Page 4
new employer to the former governmental body, even though the invoices pertain to
a contract which existed prior to termination of public service. Shay, Opinion 91 -012.
However, in the event of work performed on a contract already awarded and not
involving the unit where the former public employee worked, the name of the former
public employee may appear on routine invoices if required by the regulations of the
agency to which the billing is being submitted. Abrams /Webster, Opinion 95 -01 1.
Therefore, within the first year after termination of service, you should not engage in
any of the prohibited activities outlined above.
You may assist in the preparation of any documents presented to the School
District. However, you may not be identified on documents submitted to the School
District. You may also counsel any person regarding that person's appearance before
the School District. Once again, however, the activity in this respect should not be
revealed to the School District. Of course, any ban under the Ethics Law would not
prohibit or preclude the making of general informational inquiries of the School District
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 applying the definition of "Person" quoted above, the Commission has held
that the term includes a former public employee representing himself in providing
consulting services to his former governmental body. Confidential Opinion 93 -005.
Further, the term "Person" includes a new government employer which is represented
by the former public employee before his former governmental employer. Ledebur,
Opinion 95 -007.
As to the specific question posed, Section 3(g) of Act 9 of 1989 would prohibit
you from providing such services to the School District, regardless of whether you
attempt to take such action as an independent contractor or Architect of Record. In
Confidential Opinion, 89 -019, the full Commission held that Section 3(g) prohibited an
individual from leaving governmental service and coming back within the one year
period to provide services through a contract between the governmental body and a
corporation of which he was president and C.E.O. The fact that you would
alternatively attempt such action as Architect of Record would not change the result
because it appears under these facts that you would be offering such service as to
certain specified project(s) and would be considered substantively as an independent
contractor. See, Rogers v. STATE ETHICS COMMISSION, 80 Pa.Commw. 43, 470
A.2d 1120 (1984).
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
Cohen, 96 -549
April 30, 1996
Page 5
been or will be any transgression thereof but merely to provide a complete response
to the question presented.
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: In the former capacity as a Member of the Board of School
Directors for the Camp Hill School District, you would be considered a "public official"
as defined in the Ethics Law. Upon termination of service with the School District, you
became a "former public official" subject to Section 3(g) of the Ethics Law. The
former governmental body is the Camp Hill School District. The restrictions as to
representation outlined above must be followed. Section 3(g) of the Ethics Law would
prohibit you for a period of one year after termination of service from providing
architectural services to the Camp Hill School District. 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 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 §13.2(h). The appeal may be 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 thirty (30) days may result in the dismissal of
the appeal.
erely,
p/1
Vincent J. opko
Chief Counsel