HomeMy WebLinkAbout89-015 MeyerMr. Evan Meyer
Assistant City Solicitor
City of Philadelphia
Law Department, 15th Floor
Municipal Services Building
Philadelphia, PA 19102 -1692
I. Issue:
*ATE ETHICS COMMISSION
348 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
OPINION OF THE COMMISSION
Before; Helena G. Hughes, Chair
Robert W. Brown, Vice Chair
W. Thomas Andrews
G. Sieber Pancoast
James M. Howley
Michael J. Washo
DATE DECIDED: September 27, 1989
DATE MAILED: October 10, 1989
II. Factual Basis For Determination:
9 - 015
Re: Former Public Employee; Section 3(e); Commerce Director; City of
Philadelphia; Philadelphia Industrial Development Corporation;
Appeal of Advice of Counsel
Dear Mr. Meyer:
This Opinion is issued pursuant to your appeal of the Advice of
Counsel No. 89 -549 issued on June 6, 1989.
Whether the Ethics Act presents any prohibition or restrictions
upon the employment of a former city commerce director with the
industrial development corporation in the city for a period of one
year after termination of his service.
The issue which you presented was originally processed as a
request for an advice of counsel and as a result, on June 6, 1989
Advice of Counsel No. 89 -549 was issued. That advice concluded that
Mr. William P. Hankowsky as (former) Commerce Director of the City of
Philadelphia was considered a public employee and would become a
former public employee upon termination of service with the
Philadelphia Department of Commerce subject to the restrictions
imposed by Section 3(e) of the Ethics Act. On June 20, 1989, this
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Page 2
Commission received your two letters wherein you appealed the above
advice. By letter of June 27, 1989, you were notified that your
appeal would go before the full Commission and that you would be
notified of the date, time and location of that meeting by separate
letter which was sent to you on July 10, 1989.
In your appeal of advice you express your disagreement with the
conclusion of the Advice of Counsel. In particular, you argue that
the Advice was in error in concluding that Section 3(e) of the Ethics
Act applied to Mr. Hankowsky's situation. In the alternative, you
argue that if Section 3(e) does apply to Mr. Hankowsky, his activities
on behalf of the Philadelphia Industrial Development Corporation
(PIDC) as well as with the Philadelphia Authority for Industrial
Development (PAID) should be permitted under 3(e) of the Ethics Act
under the rubric of "administering an existing contract ".
Initially, a review of the facts is in order. William P.
Hankowsky has served as Commerce Director for the City of Philadelphia
until April 1, 1989, when he terminated service to take the position
of President of PIDC. By ordinance, PIDC was established to
"promot(e) the industrial and economic development of the City of
Philadelphia...." Thus, PIDC is the official industrial development
agency for the City of Philadelphia to carry out the functions and
purposes of this type of agency as provided for in the Industrial
Development Assistance Law, the Act of May 31, 1956, P.L. 1911, 73
P.S. 351 -358. The Industrial Development Assistance Law makes
provision for assisting counties on a matching grant basis as to the
planning and promotion of programs designed to stimulate new or
existing (through enlargement) industrial, commercial or manufacturing
enterprises. The City of Philadelphia (City) accomplishes the
foregoing through a cooperative program among the City, PIDC and PAID.
PAID is an authority organized under the Industrial Development
Authority Act, the Redevelopment Area Economic Cooperation and
Implementation Act, and the Industrial and Commercial Development
Authority Law. The contractual dealings which PIDC has with the City
may classified into three categories:
1. Contracts with the City to pass on Federal, State and City
monies as loans to companies to create jobs;
2. Contracts with the City to manage projects for the City; and
3. Nominations for purchasers of property in the City to be
disposed of by PAID.
In addition, PIDC entered into a contract with the City to
provide certain services including the staffing of the Developers
Services Committee in which PIDC assists developers in preparing the
agenda of issues to be reviewed by the Committee and also in
preparing the minutes of committee meetings. You express your view
Mr. Evan Meyer
Page 3
that PIDC is in the nature of a quasi - public /non - profit corporation
which basically acts as agent for the City Commerce Department. You
then argue that Mr. Hankowsky's new position with PIDC falls within
the ambit of an exception wherein this Commission has not applied the
provisions of Section 3(e) of the Ethics Act to situations where a
public official /employee leaves governmental service and obtains
employment with another governmental body which he represents before
his former governmental body. You argue that you fit within the above
exception because the PIDC is a quasi - governmental body.
In reviewing and making a determination in this matter, we will
be guided by an application of the State Ethics Act and Regulations of
the Commission.
III. Discussion:
Since your primary challenge relates to the legal status of Mr.
Hankowsky's new employer, PIDC, we must focus our review on the nature
of this body so as to determine whether PIDC would come within the
ambit of our exception which allows, in certain instances, former
public officials /employees to represent a new governmental employer
before their former governmental body. You do not question and you
have so noted that industrial development corporations are prescribed
for under the Industrial Development Assistance Law, supra. Section
3 of that law defines the term "industrial development agency" to be:
. . any non - profit corporation, organization,
association or agency which shall be designated by
proper resolution of the governing body of any
county . . ." 73 P.S. 353.
You do not argue that the PIDC is "wholly a 'public body'", but
assert that it is ". . . at least a quasi - governmental body such as
distinguishes it from clearly private enterprises . . You compare
the PIDC to the Harristown Development Corporation (HDC), the status
of which was considered by Commonwealth Court in the case of Appeal of
German, 27 Pa. Commw. Ct. 108, 366 A.2d 311 (1976). Since you note
that Commonwealth Court found that HDC was "not a private enterprise"
and since you assert that HDC is quite similar to PIDC, you believe
that Mr. Hankowsky's situation falls within our exception as to the
applicability of Section 3(e) of the Ethics Act because Mr.
Hankowsky's, in your view, has not entered the private sector. In
that regard, you emphasize the tri- partite participation between the
City, PIDC and PAID of promoting the industrial and economic
development of the City. In particular, you note the above provision
of the industrial development statutes and the City ordinances which
form the basis for PAID and PIDC to have a continuing contract since
January of 1969 with PIDC designated as management agent and
administrator of PAID as part of the process wherein PIDC transfers
property to PAID which in turn transfers the property to developers
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for development as industrial parks. Finally, you note the purpose of
industrial development authorities such as PAID is set forth in the
Industrial and Commercial Development Authority Law:
"to promote the health, safety, morals,
employment, business opportunities and general
welfare of the people [of the Commonwealth] . . .
for the public purpose of alleviating
unemployment, maintaining employment at a high
level, eliminating and preventing blight and
eliminating or reducing air and water pollution,
and creating and developing business opportunities
by the construction, improvement, rehabilitation,
revitalization and financing of industrial,
commercial, manufacturing and research and
development enterprises."
We must now determine whether Section 3(e) of the Ethics Act
would restrict Mr. Hankowsky in his new position as President of the
PIDC from representing either PIDC or PAID before his former
governmental body, the City Commerce Department. Initially we must
note that because you terminated your position of employment with The
City of Philadelphia in April 1989, the questions addressed herein
will be reviewed under the provisions of the Ethics Act of 1978 as the
most recent law was not enacted until after (June 1989) your
resignation.
Section 3(e) of the Ethics Act provides:
Section 3. Restricted activities.
(e) No former official or public employee
shall represent a person, with or without
compensation, on any matter before the
governmental body with which he has been
associated for one year after he leaves that
body. 65 P.S. §403.
The term "representation" as used in Section 3(e) of the Ethics
Act is defined in our Regulations as follows:
Section 1.1 Definitions.
Representation - -- Any act on behalf of any
person including but not limited to the following
activities: personal appearances, negotiating
contracts, lobbying, and submitting bid or
contract proposals which are signed by or contain
the name of the former public official or public
employee. 51 Pa. Code S1.1.
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This Commission has interpreted Section 3 of the Ethics Act to
prohibit personal appearances before one's former governmental body,
participating in any matters over which the individual had
supervision, direct involvement or responsibility while employed by
that governmental body or lobbying as to that governmental body.
Russell, Opinion 80 -048; Seltzer, Opinion 80 -044. We have determined
that Section 3(e), however, would not preclude a former public
employee from administering an existing contract as opposed to
negotiating or renegotiating a contract. Dalton, Opinion 80 -056.
This Commission has also determined that the employment by a
government agency by the former public employee would not preclude
that individual from appearing before his governmental body. Thus, in
Hagan, Opinion 84 -019 and Pinto, Opinion 84 -021, we noted that the
legislative intent behind Section 3(e) of the Ethics Act was to
prohibit representation of persons in circumstances that might give
rise to a conflict, the typical case being where public
officials /employees would leave public service and enter into the
private sector. However, in the two cited Opinions, we found that
Section 3(e) of the Ethics Act would not restrict the ability of new
government employees from representing their new governmental body or
entity before the former governmental body with which they were
associated. In these cases, we opined that the post public
employment was with another governmental body or entity and hence the
concerns the General Assembly sought to address in Section 3(e) of the
Ethics Act were allayed because the new governmental body could not be
expected to influence the former governmental body.
In light of the above, we must specifically decide whether
Section 3(e) of the Ethics Act would be applicable to Mr. Hankowsky in
his post city employment with the PIDC in terms of representing PIDC
or PAID before the City Commerce Department.
As a threshold issue we must decide whether PIDC is to be
considered a governmental employer so as to exempt Mr. Hankowsky from
the restrictions of Section 3(e) of the Ethics Law.
Our analysis leads us to the conclusion that the PIDC cannot, for
the purposes of this advisory opinion, be considered a governmental
body. As to the exception that we have applied in the Hunt and Hagan
Opinions supra, we will not engage in semantics as to whether a given
body might be considered as "quasi" governmental because it is a non-
profit corporation performing a worthwhile function. We are
constrained to follow the definition in the Industrial Development
Assistance Law which defines such entities to be non - profit
corporations; hence, we must conclude that the PIDC, as other
industrial corporations, are not considered governmental bodies.
Therefore, Mr. Hankowsky is subject to the provisions of Section 3(e)
of the Ethics Act for a period of one year after he leaves
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Page 6
governmental service with the City Commerce Department.
Turning to your subsidiary questions as to whether Mr.
Hankowsky's activities as President of PIDC may be considered as
administering an existing contract, we are guided by our prior
decision in Dalton, Opinion 80 -056. In the cited opinion, a public
employee in the Office of Administration had the responsibility of
reviewing bids by contractors who administered state benefit programs.
The public employee contemplated termination of service followed by
employment by one of those contractors which was a non - profit
corporation. We held in that case that the individual could continue
to administer an existing contract with the prospective employer even
though that individual had responsibility or supervision over that
program while in governmental service, subject to the limitation that
the individual could not negotiate a new contract or change an
existing contract as an employee of the prospective employer.
In the instant matter, we find that the PIDC is not a
governmental body. As such, Mr. Hankowsky as a former public employe
is subject to the provisions of Section 3(e) of the Ethics Act which
would restrict his appearances and representation before the
Philadelphia Commerce Department for a period of one year after
termination of service as to any new contractual matters involving the
City since his arrival at PIDC; however, Mr. Hankowsky may administer
any ongoing contracts that were in existence with the City prior to
his arrival at PIDC.
Finally, it is noted that Section 403(b) of the State Ethics Act
would prohibit any public employee or public official from accepting a
position of employment if said position has been offered based upon
the understanding that the official conduct of the employee or
official, while working for his former governmental body, was
influenced by such offer. See 65 P.S. §403(b).
The propriety of the proposed conduct has only been addressed
under the Ethics Act; 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 Act.
The Advice of Counsel No. 89 -549, with the above clarification,
is affirmed.
IV. Conclusion:
As a former Commerce Director, Mr. Hankowsky was a "public
employee" as defined under the Ethics Act. Upon termination of
service with the Philadelphia Department of Commerce, Mr. Hankowsky
would become a "former public employee" subject to the restrictions
imposed by Section 3(e) of the Ethics Act. The Philadelphia
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Industrial Development Corporation is not a governmental body and
hence Mr. Hankowsky did not transfer from one governmental body to
another. Section 3(e) of the Ethics Act restricts appearances and
representation by Mr. Hankowsky before the Philadelphia Commerce
Department for a period of one year after termination of service as to
any new contractual matters involving the City since his arrival at
PIDC; however, Mr. Hankowsky may administer any ongoing contracts that
were in existence with the City prior to his arrival at PIDC. Lastly,
the propriety of the proposed conduct has only been addressed under
the Ethics Act.
The Advice of Counsel, with clarification, is affirmed.
Pursuant to Section 7(9)(i), this Opinion is a complete defense
in any enforcement proceeding initiated by the Commission, and
evidence of good faith conduct in any civil or criminal proceeding,
providing the requestor has disclosed truthfully all the material
facts and committed the acts complained of in reliance of the evidence
of the advice given.
such.
This letter is a public record and will be made available as
Finally, any person may request the Commission to reconsider its
Opinion. The reconsideration request must be received at this
Commission within fifteen days of the mailing date of this Opinion.
The person requesting reconsideration should present a detailed
explanation setting forth the reasons why the Opinion requires
reconsideration.
By the Commission,
elena G. Hughes,
Chair