HomeMy WebLinkAbout97-008 ConfidentialI. ISSUE:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
OPINION OF THE COMMISSION
Before: Daneen E. Reese, Chair
Austin M. Lee, Vice Chair
Roy W. Wilt
Allan M. Kluger
Rev. Joseph G. Quinn
Julius Uehlein
DATE DECIDED: 5/29/97
DATE MAILED: 6/11/97
97 -008
Re: Former Public Official; City; Commissioner; Contract; Hearing Officer;
Represent; Section 3(g); Compensation.
This Confidential Opinion is issued in response to your advisory request on
February 12, 1997.
Whether the Public Official and Employee Ethics Law imposes any prohibition
or restrictions upon a former City Commissioner in contracting with his former
governmental body to provide some of the services he performed during his term on
the Commission.
II. FACTUAL BASIS FOR DETERMINATION:
Mr. A formerly served as a Commissioner of Commission B which regulates a
Utility. Mr. A performed two specific additional duties while serving at Commission
B: as a D wherein Mr. A heard appeals from the Reports and Recommendations issued
by a Hearing Officer as to appeals filed by the Utility's customers; and as a Hearing
Examiner as to the Utility's capital budget. At the conclusion of Mr. A's service, he
was asked by Commission B's Chair and Executive Director to continue performing
these two additional duties as a compensated Special Master and Hearing Examiner.
This request has been submitted to determine if such service would be prohibited
under the Ethics Law.
Mr. A asserts that the issue and facts presented in his case are sufficiently
analogous to Confidential Opinion, 92 -005 which is controlling.
After proffering your statement of the issue, you present the facts as follows.
On or about June 8, 1992, Mr. A was appointed by Mayor C to serve a four year term
Confidential Opinion, 97 -008
June 11, 1997
Page 2
as a Commissioner for Commission B. Mr. A was one of the two Members of the five -
member Commission who served on a voluntary basis, excepting [sic] a minimal
stipend. The other three positions are always filled by two City Councilpersons and
by the City Controller. Mr. A's official duties as a Commissioner ended on or about
September 24, 1996.
Commission B is charged with the responsibility of regulating and overseeing the
Utility, a collection of assets owned by the City, which provides service to commercial,
industrial and residential customers within the City.
In addition to his regular duties as Commissioner and Vice - Chairman of
Commission B, Mr. A also served as a D regarding customer service appeals and as a
Hearing Officer regarding capitol budget proceedings. As a D, Mr. A heard appeals
from Reports and Recommendations issued by a Hearing Officer as to customer service
appeals. Specifically, customers would appeal decisions rendered by the Utility to the
Commission Hearing Examiner. These appeals were forwarded to the Hearing
Examiner who would then hold hearings and submit a Report and Recommendation to
Commission B. The customer or the Utility could file exceptions to the Hearing
Examiner's Report and Recommendation. Mr. A, as a D, would conduct further
proceedings to review the exceptions and submit his own Report and Recommendation
to Commission B. Commission B would either accept, reject or modify Mr. A's Report
and Recommendation. Thereafter, the customer or Utility could appeal the final
decision of Commission B to the Common Pleas Court.
The work of the Hearing Examiner as to customer service appeals and the
Utility's operating budget is often performed by non - Commissioners. You have
attached a contract between the Commission and the present Hearing Examiner which
is incorporated herein by reference. Mr. A has served as D and as capitol budget
Hearing Examiner for his entire term. But for the fact that Mr. A's term with
Commission B ended, the Commission would not be seeking to contract with Mr. A
to act as Special Master and Hearing Examiner.
You state that in the conduct of both his regular and additional duties, Mr. A
conducted himself well, tirelessly performed his duties with distinction and served as
a valuable resource to the other Commissioners so as to be viewed as fair, frank, hard-
working and committed. Based upon his prior service, commitment, sense of justice
and fair play, the Chair and Executive Director of Commission B have requested Mr.
A to continue his service as D and Hearing Officer by a proposed contract between Mr.
A and Commission B, a copy of which is incorporated herein by reference.
Your provide an analysis wherein you compare our prior ruling in Confidential
Opinion, 92 -005 to the instant matter. As in Confidential Opinion, 92 -005, you assert
that Mr. A will not be acting in the normal representative capacity but in a quasi -
judicial capacity as an independent arbitrator, mediator and fact - gatherer.
You contend that the instant matter is different factually from Confidential
Opinion, 93 -005 where a management -level state employee sought to resign from his
position in order to start a new business to provide to his former governmental body
the same services he previously performed in his public employment. You note that
Mr. A has not decided to terminate his employment in order to develop a business
which would capitalize on his governmental contacts. Mr. A has been solicited by
Commission B within the one year prohibition period to continue to perform the
Confidential Opinion, 97 -008
June 11, 1997
Page 3
services which he had performed while a Commissioner. You argue that Mr. A would
be resuming the same duties which he had while a Commissioner so that his return to
service could be considered to be a resumption of his public employment with a limited
change in his status. You reiterate that, as in Opinion 92 -005, Mr. A would be acting
as a quasi - judicial officer on behalf of Commission B in the capacity of an impartial
mediator, arbitrator and fact - gatherer. The issue and facts in Confidential Opinion, 92-
005 in your opinion are sufficiently analogous to your case so that Confidential
Opinion, 92 -005 would be controlling. You conclude that Mr. A's service as Special
Master and Hearing Examiner would not be prohibited under the Ethics Law.
III. DISCUSSION:
In his former capacity as a Commissioner for Commission B, Mr. A 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 this Commission. 65 P.S.
§402; 51 Pa.Code § 1 1.1.
Consequently, upon termination of public service, Mr. A 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
with which he has been associated for one year after he
leaves that body.
Mr. A was associated with Commission B as his governmental body.
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.
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" by
defining 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. See the 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.
Confidential Opinion, 97 -008
June 11, 1997
Page 4
The former governmental body with which Mr. A was associated following
termination of public service would be Commission B. 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. See,
Boonin, Opinion 90 -003.
Therefore, within the first year after termination of service with Commission B,
Section 3(g) of the Ethics Law would apply and restrict representation of persons
before Commission B.
As to the scope of the restrictions under Section 3(g), such restrictions have
been discussed in detail in Popovich, Opinion 89 -005, which are incorporated by
reference and will not be repeated.
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, we have 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.
In the instant matter, it is argued that our decision in Confidential Opinion, 93-
005 is distinguishable and that our decision in Confidential Opinion, 92 -005 is
controlling.
In Confidential Opinion, 93 -005, we concluded that a public employee could not
terminate public service and then contract to provide those same services to his former
governmental body within one year of termination of service. In Confidential Opinion,
92 -005, we found that Section 3(g) did not apply because the former public employee
was acting as an impartial arbiter between his former governmental body and the labor
unions and hence was not representing himself before his former governmental body.
In the instant matter, we find Confidential Opinion, 92 -005 to be inapposite but
Confidential Opinion, 93 -005 to be on point. Mr. A would be contracting as a
consultant to provide some of the same services to his former governmental body that
he performed while serving as a public official. Mr. A would not be acting as an arbiter
between his former governmental body and a third party. To the contrary, Mr. A
would be doing that which he did before his termination of service but now would be
representing himself doing such services. Such activity is prohibited by Section 3(g)
of the Ethics Law. Confidential Opinion, 93 -005, supra.
We reject the argument that Mr. A could be considered as resuming his public
employment with a limited change in status. The submitted facts and proposed
contract reflect that Mr. A would not be hired as an employee but as an independent
consultant via a contract. Parenthetically, we have held that if a former public
Confidential Opinion, 97 -008
June 11, 1997
Page 5
official /employee is rehired by the former governmental body so that a true public
employment relationship exists, such action would not be prohibited by Section 3(g)
of the Ethics Law. See, Confidential Opinion, 93 -005, supra.
Our decision is consonant with the purpose of Section 3(g), namely, to prohibit
former public officials /employees from capitalizing on their prior service by using their
connections with their former governmental body to their advantage for financial gain.
Two scenarios involving Section 3(g) relate to former public officials /employees using
their contacts or knowledge of operations within their former governmental body for
the benefit of their new employer or clients and second, using their former employment
to obtain consulting contracts with their former governmental bodies. As to the latter,
it makes no difference whether the solicitation for a consulting contract is by the
governmental body, the former public official /employee, or by mutual desire. Similarly,
even if the proposed conduct does not involve any inappropriate intent, such is
irrelevant. Yocabet v. SEC, 531 A.2d 536 (1987). The point is that Section 3(g) of
the Ethics Law prohibits this type of conduct. Parenthetically, assuming that the date
of termination for Mr. A was on September 24, 1996, the one year prohibition of
Section 3(g) would end on September 24, 1997.
Lastly, the propriety of the proposed conduct has only been addressed under
Section 3(g) of 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:
A City Commissioner is a public official subject to the Ethics law. Section 3(g)
of the Ethics Law prohibits a former public official from entering into a consulting
contract for compensation with his former governmental body within one year of
termination of service to provide services that he performed while a public official.
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.
This letter is a public record and will be made available as such.
Finally, any person may request the Commission to reconsider its Opinion. The
reconsideration request must be received at this Commission within thirty 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.
Vice Chair Austin M. Lee dissents.
By the Commission,
1 0 AtisAu6
Daneen E. Reese
Chair