HomeMy WebLinkAbout90-005 HittMs. Mary E. Hitt
Thorp, Reed & Armstrong
One Riverfront Center
Pittsburgh, PA 15222
Dear Ms. Hitt:
1990.
I. Issue:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
OPINION OF THE COMMISSION
Before: Helena G.
Robert W.
W. Thomas
G. Sieber
Dennis C.
II. Factual Basis for Determination:
Hughes, Chair
Brown, Vice Chair
Andrews
Pancoast
Harrington
DATE DECIDED: February 23, 1990
DATE MAILED: March 6, 1990
90 - 005
Re: Public Employee; Former Public Employee; County; Board of
Property Assessment, Appeals and Review; Governmental Body;
Governmental Body With Which A Public Official or Public
Employee Is or Has Been Associated; Represent; Assessment Office;
Tax Assessments.
This Opinion is issued in response to your request of January 12,
Whether Section 3(g) of the Public Official and Employee Ethics
Law restricts the former manager of the commercial and industrial
section of the Office of the Director of Assessments of Allegheny
County from representing persons before the Allegheny County Board of
Property Assessment, Appeals and Review for a period of one year after
termination of service.
On behalf of Realty Tax Associates (RTA) which is a Pennsylvania
corporation that has recently hired Mr. Wayne D. Biernacki, you
request an opinion as to the restrictions which the Ethics Law would
impose upon Mr. Biernacki following termination of his employment with
the County of Allegheny, hereinafter County. RTA is in the business
of providing real estate tax consulting services in 34 counties
(including Allegheny) to owners of commercial and industrial real
estate. RTA performs reviews of the official assessments of
clients' lands and buildings to determine if the properties have been
equitably assessed. If RTA determines that the assessed value of the
Ms. Mary E. Hitt
Page 2
property is excessive, RTA then provides services to assist the client
in appealing the assessment. Once an appeal is filed, RTA may testify
at the hearing on the appeal regarding the value of the property as
well as negotiate with the local school districts or taxing
authorities to arrive at a settlement of the assessment prior to or
after the initial hearing. Effective November 16, 1989, Mr. Wayne D.
Biernacki resigned his position as manager of the commercial and
industrial section of the Office of the Director of Assessments of
Allegheny County, hereinafter Office, to become an employe of RTA.
During his twenty -one years of service with the County, Mr.
Biernacki's duties and responsibilities lay in the area of the
assessment of real estate. While employed as manager of the
commercial and industrial section of the Office, Mr. Biernacki's
duties included the supervision of assessors who prepared the
valuations of commercial and industrial real estate as well as the
review of proposed assessments. After such review, Mr. Biernacki was
responsible for recommending to the director any changes for final
approval and assessment. Some of Mr. Biernacki's duties with RTA
include reviewing tax records, conducting real estate tax seminars,
generating reports, and reviewing quality assurances and
prequalification of property values. Due to Mr. Biernacki's twenty
years of experience and his expertise in the appraisal of commercial
of industrial real estate, it would be beneficial to RTA's clients if
Mr. Biernacki could appear before the Allegheny County Board of
Property Assessment Appeals and Review, hereinafter Board, either to
give testimony as to the valuation of property or to assist RTA
clients in the appeal process. RTA does not intend for a period one
year from termination of service to utilize Mr. Biernacki in support
of seeking a reduction for a RTA client of an assessed value that Mr.
Biernacki activity participated in determining or approving while
employed by the Office. However, RTA would anticipate that Mr.
Biernacki might provide testimony to defend an assessment if the
taxing authorities had increased the assessment. In addition Mr.
Biernacki would not represent clients before the Office nor would he
contact the Office except in a capacity which would be permitted by
law to members of the general public. You then pose six questions
regarding Mr. Biernacki's conduct during the one year period after
termination of service.
1. Whether Mr. Biernacki could appear at hearings before the
Board on behalf of RTA clients in any capacity or for the purpose of
defending an assessment against any increase requested by the taxing
authorities?
2. Whether Mr. Biernacki could appear before the Board as an
expert witness to testify as to his opinion of the proper valuation
of land or buildings?
3. Whether Mr. Biernacki may negotiate with school districts or
taxing authorities within the County on behalf of RTA clients prior to
Ms. Mary E. Hitt
Page 3
an appeal being filed with the Board, or after an appeal is filed but
prior to a hearing before the Board or after the Board has held a
hearing and issued a determination?
4. Whether Mr. Biernacki may negotiate on behalf of a client
with a school district or taxing authority to settle a dispute as to
an appeal which has been filed in the Court of Common Pleas prior to
its resolution by the Court?
5. Whether Mr. Biernacki may participate in report generation
for RTA clients if RTA employees other than Mr. Biernacki would
represent them before the Board?
6. Whether Mr. Biernacki may deal with employees of the Office
in order to obtain assessment valuation information which is of public
record and which is available to members of the general public upon
request?
In considering Mr. Biernacki's relationship with his employer and
the relationship between the Office and the Board, you suggest that
the organizational structure of the Board and Office would not bar an
appearance by Mr. Biernacki before the Board.
After quoting Section 3(g) of the Ethics Law and the definitions
of "represent" and "public employee ", you interpret those provisions
of law to mean that a former public employe may not represent a person
before the governmental body with which he has been associated.
After noting that the County is of the second class and is
charged with the responsibility inter alia of supervising the making
of assessments and valuations, revising assessments, and hearing
appeals from assessments, you note that the Board sits as the first
avenue of the administrative review of its own actions, wherein
appeals may be made by property owners or by taxing authorities such
as school districts, municipalities or county governments. Although
the Board is legally authorized to perform both appeal and assessment
functions, the courts have determined that the appeal function and the
assessment function are to be handled by separate governmental bodies.
Because of the separation between the Board and Office, you suggest
that Mr. Biernacki's appearance before the Board should not be
considered as an appearance before the governmental body with which he
has been associated.
The genesis of the separation between the appeal and the
assessment functions of the Board and Office came about as a result of
protracted litigation in two cases which were consolidated for
settlement: Borough of Green Tree v. Board of Property Assessment,
Appeals and Review of Allegheny County, No. 341, April 1970 (C.P.
Allegheny) (the "Green Tree Case ") and Borouah of Wilkinsburq v. Board
of Property Assessment, Appeals and Review, No. GD -77 -18166 (C.P.
Ms. Mary E. Hitt
Page 4
Allegheny) (the "Wilkinsburg Case "). A study committee was appointed
by the County Commissioners to study and report on assessment
practices, procedures and policies in the County during the pendency
of the Green Tree Case. The study committee concluded that the Board
should cease functioning in its capacity as both administrator and
appeal board and as a result recommended that the Board continue to
perform the appeal function whereas the making and supervising of all
assessments and valuations including the direction and supervising of
assessors and other employees be handled by a Director of Assessments.
Thereafter by Order of October 5, 1978 Judge Papadakos implemented the
recommendation. The position of Director of Assessments was created
and an appointment was made to that position.
You argue that because Mr. Biernacki was associated with the
Office and not the Board and because the Board and Office function as
separate entities, the potential harm which is restricted by Section
3(g) of the Ethics Law regarding public employees realizing personal
financial gain by acting in a conflict with the public trust does not
exist if a former employee of the Office appeared before the Board.
Further you argue that Mr. Biernacki would not be in a conflict
situation because he would not be attacking an assessment he had
recommended, that is, Mr. Biernacki would contest proposed increases
to only those assessments which he had not activity determined while
he was a public employee.
III. Discussion:
As the manager of the commercial and industrial section of the
Assessment Office of Allegheny County, Mr. Biernacki was a public
employee as that term is defined under the Public Official and
Employee Ethics Law. Upon termination of his service on November 16,
1989, Mr. Biernacki became a former public employee subject to the
provisions of Section 3(g) of the Ethics Law.
Section 3(g) of the Ethics Law provides:
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.
The following terms are defined under the Ethics Law:
"Governmental body." Any department,
authority, commission, committee, council, board,
bureau, division, service, office, officer,
administration, legislative body, or other
Ms. Mary E. Hitt
Page 5
establishment in the Executive, Legislative or
Judicial Branch of a State, a nation, or a
political subdivision thereof or an agency
performing a governmental function.
"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.
"Person." A business, governmental body,
individual, corporation, union, association, firm,
partnership, committee, club or other organization
or group of persons.
"Represent." To act on behalf of any other
person in any activity which includes, but is not
limited to, the followings 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.
Section 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 any
thing 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 or will be any transgression thereof but
merely to provide a complete response to the question presented.
Before we may address the specific questions that you have posed,
we must first resolve the pivotal issue as to the governmental body
with which Mr. Biernacki has been associated. To this end, it is
Important that we review the legislative intent behind the amendment
to the Ethics Act which resulted in changes by the General Assembly
from the prior language of Section 3 (e) of Act 170 of 1978 to the
current language of Section 3 (g) of Act 9 of 1989.
During our sunset review process and during the debate on House
Bill 75, criticism was made about our prior decisions regarding the
narrow interpretation applied to the term governmental body. On
February 15, 1989, an amendment was offered to the definition of
"Governmental body with which a public official or public employee is
Ms. Mary E. Hitt
Page 6
or has been associated" to include the phrase "and subdivisions and
offices within that entity." The following reflects the reason for
the amendment which was subsequently adopted:
This amendment deals with a narrow situation
which we discovered in hearings on this subject in
the Judiciary Committee last session.
Employees, for instance, of the Pennsylvania
Department of Transportation who worked for one
engineering district were found by a decision of
the Ethics Commission to be able to, immediately
upon retiring or leaving employment, represent
clients in practice with other parts of the
Pennsylvania Department of Transportation,
including their neighboring engineering district.
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, and my language
simply makes it clear in the definition of
"governmental body" that we are including
subdivisions and offices within that entity.
Lecrislative Journal of House, 1989 Session, No. 15
at 290, 291.
Subsequently, on June 12, 1989 the phraseology of the definition
was again amended to delete the word "entity" and substitute
"governmental body ". The latter amendment was made in Senate
Committee without comment.
The General Assembly has thus amended the definition at issue
with the intent to broaden that definition to make it more
encompassing. Since the General Assembly has duly enacted this
change, we must carry out the legislative intent. See 1 Pa. C.S.A.
1921(a) which provides in part:
(a) The object of all interpretation and
construction of statutes is to ascertain and
effectuate the intention of the General Assembly.
See also 1 Pa. C.S.A. 1901.
We also note that we have on five occasions since the passage of
Act 9 of 1989 applied the provisions of Section 3(g) to determine
what constituted a former public official /employee's governmental
body.
In Popovich, Opinion 89 -005, we determined that a public employee
Ms. Mary E. Hitt
Page 7
who worked in a district office of PennDot was restricted for a period
of one year after termination of service to all of PennDot.
The application of former governmental body was extended further
in Nixon, Opinion 89 -006. In the cited case, the public employee
served as the marketing director in the Department of General Service
(DGS). Because the influence and input of the marketing director
extended beyond DGS, we found that the former governmental body
included all of DGS but could also extend to other agencies as well.
In confidential Opinion, 89 -019, we opined that the former
governmental body of a public employee who worked in the director's
office of a municipality extended to the municipality and not merely
the director's office.
In Morris, Opinion 89 -026 we found that a former member of. the
Pennsylvania Health Care Cost Containment Council was restricted for a
one year period from representing a person before that Council.
Finally, in Pollock, Opinion 89 -031, we decided that the former
governmental body of a Pittsburgh City Councilmember was not merely
limited to Council but to the entire City of Pittsburgh including
other government units and authorities in Pittsburgh.
Parenthetically, our decision in the cited case resulted in part from
testimony from the Councilmember as to the inter connection and
commingling of functions as to the various governmental units within
the City of Pittsburgh.
In light of the clear and unequivocal intent of the General
Assembly that the former governmental body of a public employee is now
no longer limited to specifically the area wherein he exerts influence
and control, we must conclude that the governmental body with which
Mr. Biernacki was associated is the Office and Board. We are mindful
of the separation in the County between the Office and Board. While
we do not question that the Board and Office are separate, such a
division within the County is not controlling as to a determination
under the Ethics Law on the question of the governmental body with
which Mr. Biernacki was associated.
There can be no question that whenever an appeal would come
before the Board, the Board would review the assessment that was made
by the Office in which Mr. Biernacki played a supervisory role
regarding the preparation of valuations for commercial and industrial
real estate together with making recommendations for changes or final
approval of the assessments to the Director of the Office. Thus,
given the inter - connection between the Board and Office, we cannot
accept such a narrow limitation of the former governmental body in
this case. Nixon;Pollock, supra.
Ms. Mary E. Hitt
Page 8
Given the language of Section 3 (g) of the Ethics Law and the
accompanying definitions together with the legislative intent and
prior precedent under Act 9 of 1989, it is our opinion that Mr.
Biernacki's former governmental body is the Office and Board. We will
now address the specific questions which you have posed seriatim.
As to your first inquiry Section 3 (g) would prohibit Mr.
Biernacki from appearing at hearings before the Board either to
represent a client in any capacity or to defend an assessment against
an increase by the taxing authorities. Such activity is restricted
because the Board is part of Mr. Biernacki's governmental body and the
activities he contemplates are within the restrictions set forth in
the definition of represent.
The same result would follow as to the second question you pose
because Mr. Biernacki's representation as an expert witness before the
Board would obviously be done at the behest of a client in support of
their respective position as to a tax assessment.
Regarding the third inquiry you raise concerning the possibility
of Mr. Biernacki negotiating with school districts or taxing
authorities on behalf of RTA clients either prior to an appeal being
filed with the Board, or after the filing of an appeal but prior to a
hearing or after the Board has held a hearing and issued an
determination, Section 3 (g) of the Ethics Law would not restrict such
activity subject to the following qualification. Mr. Biernacki could
negotiate with a school district or taxing authority since they are
not the Board or Office; however, the Ethics Law would require Mr.
Biernacki to insure that such activities on his part on behalf of RTA
clients would be strictly limited to the school district and taxing
authorities so that Mr. Biernacki's representation would not become
known or submitted through documentation to the Board. As a
practical matter the foregoing restriction would probably be limited
to the first two of the three scenarios presented.
Your fourth inquiry, as posed in your request, would not be
restricted by the Ethics Law because if a case has been appealed to
the Court of Common Pleas, it would be finalized by the Board at that
time and therefore Mr. Biernacki would not be restricted from
negotiating on behalf of the RTA client with the school district or
taxing authorities prior to the matter being adjudicated.
Concerning your fifth inquiry as to whether Mr. Biernacki may
participate in report generation for RTA clients if RTA employees
other than Mr. Biernacki will represent them before the Board, Section
3 (g) of the Ethics Law would not restrict such activity provided Mr.
Biernacki's name or participation would not be reflected in the report
or made known to the Board.
Ms. Mary E. Hitt
Page 9
Concerning your last inquiry as to whether Mr. Biernacki may deal
with employees of the Office in order to obtain assessment valuation
information that is available to the public and which may be received
by the general public upon request, Section 3 (g) of the Ethics Law
would not restrict such activity provided that the contacts are
strictly limited by Mr. Biernacki to seeking information or obtaining
it upon request which is available to the general public.
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.
IV. Conclusion:
The former manager of the commercial and industrial section of
the office of director of assessment of Allegheny County was a public
employee and upon termination of service became former a public
employee subject to the provisions of Section 3 (g) of the Ethics Law.
Section 3 (g) of the Ethics Law would restrict the former public
employee from representing any person before both the Office of
Assessments as well as the Allegheny County Board of Property
Assessments, Appeals and Review for a period of one year after
termination of service. The representation restrictions would apply
to representing clients generally or in a capacity of defending
increases of assessments and appearing as an expert witness at the
Board. Section 3 (g) would not restrict the former public employee
from negotiating with taxing authorities either prior to or after the
filing of an appeal with the Board or after hearing has been held by
the Board which has issued a determination providing the former public
employee insures that such activities on his part are not made known
to the Board directly or through various documentation. Section 3
(g) of the Ethics Law would not restrict a former public employee from
becoming involved in negotiations after a matter is appealed from the
Board to the Court of Common Pleas. In addition, the former public
employee may through his new employer participate in report
generations for clients provided his name or his participation is not
included in such reports nor is made known to his former governmental
body. Lastly, the former public employee may under the Ethics Law
obtain assessment or valuation information and deal with employees of
the Board or Office provided that such activities on his part are
limited to those made by members of the general public. Lastly, the
propriety of the proposed conduct has only been addressed 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
Ms. Mary E. Hitt
Page 10
facts and
given.
This
such.
committed the acts complained of in reliance on the advice
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 t - Commission
74/
elena G. Hughes,
Chair