HomeMy WebLinkAbout91-005 ConfidentialI. Issue:
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STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
OPINION OF THE COMMISSION
Before: Helena G. Hughes, Chair
Robert W. Brown, Vice Chair
Dennis C. Harrington
James M. Howley
Daneen E. Reese
Austin M. Lee
DATE DECIDED: May 23, 1991
DATE MAILED: June 10, 1991
91-005
Re: Conflict, Public Employee, City Solicitor, City, Attorney on
Loan, Compensation, Salary Paid by Law Firm
This opinion is issued in response to your confidential request
of April 10, 1991.
Whether the Public Official and Employee Ethics Law imposes any
prohibition or restrictions upon a city solicitor from utilizing
attorneys on loan to the city from a law firm.
II. Factual Basis for Determination:
A joint confidential opinion is requested, both by the city
solicitor for A and by a member of the law firm of B, as to the
propriety of the city's prospective utilization of attorneys on loan
from the law firm for a period of time to handle some of the work load
in the city solicitor's department. Noting that the city of A is in a
financial crisis, such that the city solicitor does not have the funds
necessary to hire the number of lawyers needed to handle the city's
legal work load to the disadvantage of the city and its citizens, the
law firm of B proposes to send three of its associate lawyers to the
city solicitor's office for a period commencing immediately and ending
on September 30, 1991. The law firm does not, at the present time,
have enough legal work of an appropriate kind for the experience and
background of these associates and therefore would pay their
compensation while they work in the city solicitor's office, which in
no way would be contingent upon their working in that latter
capacity. The law firm has made it clear that all three associates
will receive their full salary and benefits from the law firm for the
six -month period from April 1, 1991 through September 31, 1991, after
which they would no longer work for the city. It is possible that the
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three lawyers would be asked to return to the law firm as of October
1, 1991 if there is appropriate work for them at that time. Although
the salaries of the three associate lawyers are higher than the salary
paid by the city solicitor's office to lawyers of similar experience,
there is no statute or rule which specifies the level of salaries of
lawyers in the city solicitor's office. While noting that the law
firm is presently performing no legal services for the city, you
advise that if such a situation would arise between now and September
30, 1991, the city solicitor would insulate the three associate
lawyers from any contact with the matter. Further, although it is
true that the law firm would represent clients whose interests would
be adverse to the city or who seek to do business with the city, both
the city solicitor and the law firm would make certain that the three
associate lawyers involved would be insulated from any conflict as to
such matters. You conclude by jointly requesting advice from the
Commission as to whether the city solicitor could receive the benefit
of the three associate lawyers under the above facts and
circumstances.
III. Discussion:
As the solicitor for the city of A, you are a public employee as
that term is defined under the Ethics Law. 65 P.S. 402; Davis Opinion
89 -012. As such, your conduct is subject to the provisions of the
Ethics Law. The following terms are defined under the Ethics Law.
Section 2. Definitions.
"Conflict or conflict of interest." Use by a
public official or public employee of the
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 or his immediate family or a
business with which he or a member of his
immediate family is associated. 65 P.S. 5402.
Section 2. Definitions.
"Authority of office or employment." The .
actual power provided by law, the exercise of
which is necessary to the performance of duties
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and responsibilities unique to a particular public
office or position of public employment. 65 P.S.
S402.
Section 2. Definitions.
"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. 65
P.S. §402.
Sections 3(a) and 3(e) of the Ethics Law provide as follows:
Section 3. Restricted Activities.
(a) No public official or public employee
shall engage in conduct that constitutes a
conflict of interest. 65 P.S. §403(a).
Section 3. Restricted activities.
(e)(1) No person shall solicit or accept a
severance payment or anything of monetary value
contingent upon the assumption or acceptance of
public office or employment.
(2) This subsection shall not prohibit:
(i) Payments received pursuant to
an employment agreement in existence
prior to the time a person becomes a
candidate or is notified by a member of
a transition team, a search committee
or a person with appointive power that
he is under consideration for public
office or makes application for public
employment.
(ii) Receipt of a salary, fees,
severance payment or proceeds resulting
from the sale of a person's interest in
a corporation, professional corporation,
partnership or other entity resulting
from termination or withdrawal therefrom
upon the assumption or acceptance of
public office or employment.
(3) Payments made or received pursuant to
paragraph (2)(i) and (ii) shall not be based on
the agreement, written or otherwise, that the vote
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or official action of the prospective public
official or employee would be influenced thereby.
(4) This subsection shall not be applied
retroactively. 65 P.S. §403(e).
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 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.
As to Section 3(a) of the Ethics Law quoted above, although you
are a public employee, the issue before us involvs the propriety of
the utilization of attorneys from the law firm to the city for a
period of time which conduct does not fall within the ambit of Section
3(a). Accordingly, we will limit our analysis to Section 3(e) of the
Ethics Law.
As to Section 3(e) of the Ethics Law quoted above, this provision
of law restricts an individual from either soliciting or accepting a
severance payment or anything of value contingent upon the acceptance
of public employment. As we noted in Confidential Opinion 90 -014, the
operative phrase in this section is "contingent." In the cited
confidential opinion, we concluded that the city mayor was prohibited
under Section 3(e) of the Ethics Law from appointing an individual to
a position with the city where the current corporate employer would
continue to pay his salary since the individual would be accepting
something of monetary value contingent upon the acceptance or
assumption of public employment. In that analysis, we concluded that
there were pre- existing negotiations and discussions prior to the
acceptance or assumption of public employment and that the salary
received by the individual would be higher than that set by
ordinance. We determined that the contemplated activity was
prohibited by Section 3(e) of the Ethics Law:
"In applying the facts of this matter to the
provisions of Section 3(e), we believe that such
an arrangement would be prohibited under the
Ethics Law. We note that the individual is being
considered for this appointment and further that
the Mayor is contemplating having this individual
serve on an executive -on -loan status. Under the
circumstances, we must assume that there have been
discussions or negotiations between this
individual, the Mayor and possibly the corporation
as to the source of payment of the salary.
Therefore, because of the pre- existing
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negotiations or discussion prior to the acceptance
of assumption of the public employment, we believe
that the requisite "contingent" element exists
which would prohibit such an arrangement. In
addition, the salary for this position is set by
ordinance. If the individual were to take his
corporate salary which exceeds the amount set by
ordinance, such would be a subsidization of his
salary: This we believe was the exact situation
that the Legislature was attempting to avoid
through the implementation of this provision. We
also note that these two enumerated exceptions set
forth in Section 3(e)(2) have no application. The
two exceptions relate to payments received from
pre- existing employment agreements or payments
received as a result of a termination or
withdrawal agreement." Id at p.5
In the instant situation, we believe the above opinion is
dispositive of the issue before us. We fail to discern any meaningful
difference between the instant matter and Confidential Opinion, 90-
014.
In both cases, the employer (corporation or law firm) would have
had discussions with the city official /employee (mayor or city
solicitor) which establishes the "contingent" requirement under the
Ethics Law. In addition, the salary for the attorneys exceeds the
compensation paid for attorneys in the city solicitor's office.
Although it is true that in the Confidential Opinion the salary for
the position was set by ordinance which is not the case in the instant
matter, the salaries paid by the law firm would be higher than the
compensation paid by the city for its staff attorneys. We believe
that the instant matter is substantively within the ambit of
Confidential Opinion 90 -014. Consequently, the proposed activity is
prohibited based upon the clear legislative intendment for this
section of the Ethics Law. Simply stated, the situation exists that
these attorneys, as associates of the law firm, would be accepting
public employment contingent upon the acceptance of the monetary value
as to their respective salaries through the continuation of their
salaries which might otherwise terminate. Such proposed activity is
prohibited by Section 3(e) of Act 9 of 1989. See Confidential Opinion
90 -014.
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. Specifically, not
addressed is the applicability of the Rules of Professional Conduct.
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IV. Conclusion:
Under Section 3(e) of the Ethics Law, three associate attorneys
from a private law firm could not be utilized by a city solicitor's
office for a period of time wherein their salary and benefits would be
paid by the law firm. Lastly, the propriety of the proposed conduct
has only been addressed under the Ethics Law.
Pursuant to Section 7(10), the person who acts in good faith on
this opinion issued to him shall not be subject to criminal or civil
penalties for so acting provided the material facts are as stated in
the request.
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 th
/Commission,
; 'Helena G. Hughes,
Chair
Commissioners Dennis C. Harrington and James M. Howley dissent.