HomeMy WebLinkAbout89-026 MorrisDear Mr. Morris:
I. Issue:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
OPINION OF THE COMMISSION
Before: Robert W. Brown, Vice Chair
G. Sieber Pancoast
Dennis C. Harrington
James M. Howley
Michael J. Washo
DATE DECIDED: October 26, 1989
DATE MAILED: November 8. 1989
Mr. Roland Morris 89 -026
Duane, Morris & Heckscher
1 Franklin Plaza
Philadelphia, PA 19102
Re: Former Public Official, Pennsylvania Health Care Cost Containment
Council, Represent, Person, Hospital Association, Government
Body with Which Associated.
This Opinion is issued in response to your request of September
20, 1989.
Whether a former noncompensated member of the Pennsylvania Health
Care Cost Containment Council is restricted by Section 3(g) of the
Public Official and Employee Ethics Law from representing a hospital
association before the Council for a period of one year after the
termination of his service.
II. Factual Basis for Determination:
Mr. Douglas J. Spurlock is a former member of the Pennsylvania
Health Care Cost Containment Council, hereinafter Council, and is
currently employed by the Hospital Association of Pennsylvania,
hereinafter Association, as its Chief Operating Officer. Mr. Spurlock
was employed as the Chief Executive Officer of Polyclinic Medical
Center of Harrisburg, an acute care general hospital, and in that
capacity had occasion to become active with and render assistance to
the Association. The Association, as one of the leading hospital
associations in the nation, includes as members those hospitals which
provide acute care in the Commonwealth. The Association advocates for
member hospitals in order to bring their positions, capabilities and
Mr. Roland Morris
Page 6
political subdivision if one of the
following exists:
(I) The body makes binding
decisions or orders adjudicating
substantive issues which are
appealable to a body or person
other than the governing authority.
(II) The body exercises a
basic power of government and
performs essential governmental
functions.
(III) The governing authority
is bound by statute or ordinance to
accept and enforce the rulings of
the body.
(IV) The body may compel the
governing authority to act in
accordance with the body's
decisions or restrain the
governing authority from acting
contrary to the body's decisions.
(V) The body makes
independent decisions which are
effective without approval of the
governing authority.
(VI) The body may adopt,
amend and repeal . resolutions,
rules, regulations, or ordinances.
(VII) The body has the power of
eminent domain, or condemnation.
(VIII) The enabling
legislation of the body indicates
that the body is established for
exercising public powers of the
Commonwealth or a political
subdivision.
(ii) The term does not include judges
and inspectors of elections, notary publics
and political party officers.
Mr. Roland Morrie
Page 7
(iii) The term generally includes
persons in the following offices:
(A) Incumbents of offices filled
by nomination of Governor and
confirmation of the Senate.
(B) Heads of executive,
legislative, and independent agencies,
boards and commissions.
(C) Persons who report directly to
heads of executive, legislative and
independent agencies, boards and
commissions except clerical personnel.
(D) Members of agencies, boards
and commissions appointed by the General
Assembly or its officers.
(E) Persons appointed to
positions designated as offices by
code, charter or the like of the
Commonwealth or its political
subdivisions.
(F) Members of municipal,
industrial development, housing,
parking and similar authorities.
(G) Members of zoning hearing
boards and similar quasi judicial
bodies.
(H) Members of the public bodies
meeting the criteria set forth in
subparagraph (i)(A). 51 Pa. Code $1.1.
One need look no further than the enabling legislation of the
Pennsylvania Health Care Containment Council to determine that it is
indeed more than merely an advisory board and that it has the power to
expend public funds.
Thus members of said council are public officials within the
purview of the Ethics Law.
You argue that Act 9 of 1989 should not control because Section 9
provides that the Act does not have application to violations
committed prior to the effective date of the Act. As previously noted
however, there were in fact no activities by Mr. Spurlock which took
Mr. Roland Morris
Page 8
place prior to the effective date of Act 9. Thus there could have
been no violations to which the cited provision would apply. In any
event, as noted above, our decision would be the same under Act 170 in
light of the decision in Snider V. Thornburgh, supra.
Finally, you assert that Mr. Spurlock should not be treated as a
public official for purposes of prohibiting representation pursuant to
§3(g), since he would represent the same interests as he did while
serving on the Council. Although Mr. Spurlock would be dealing with
the same subject matter in his capacity as a representative for the
Association, he would now be representing their private interest, in
contrast to the public interest which he represented as a member of
the Council. Conflicts between the public interest and the private
interests of individuals prompted the passage of the Ethics Law; this
underlying principle is formulated in Section 3(g) as well as other
sections of the Ethics Law which is intended to protect the public
interest. In this case, Mr. Spurlock is no longer representing the
public interest.
In summary, Mr. Spurlock would be prohibited from representing
the Association before his former governmental body, the Council,
under Section 3(g) of the Ethics Law for a period of one year after
the termination of his service on July 13, 1989.
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 Law has not been considered in that they do not
involve an interpretation of the Ethics Law.
IV. Conclusion:
A member of the Pennsylvania Health Care Cost Containment
Council, was a public official as that term is defined in the Ethics
Law. Consequently, upon the termination of his governmental service
he became a former public official subject to Section 3(g) of the
Ethics Law. The governmental body with which said official was
associated was the Council and therefore he may not represent any
"person," including the Hospital Association of Pennsylvania, before
that body for a period of one year. The propriety of the proposed
conduct has been addressed only under the Ethics Law.
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 on the advice
given.
Mr. Roland Morris
Page 9
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,
Robert W. Brown,
Vice Chair