HomeMy WebLinkAbout01-520 McLaughlinRobert L. McLaughlin, Esquire
431 Center Street
Ashland, PA 17921
ADVICE OF COUNSEL
March 1, 2001
01 -520
Re: Former Public Employee; Section 1103(g); Senior Counsel; Board of Claims;
Contract; Member, Hearing Panel.
Dear Mr. McLaughlin:
This responds to your letter of January 24, 2001, by which you requested advice
from the State Ethics Commission.
Issue: Whether the Public Official and Employee Ethics Act, 65 Pa.C.S. §1101 et
seq. ("Ethics Act "), presents any restrictions upon on employment of a Senior Counsel
following termination of service with the Board Claims, particularly with regard to
contracting with his former governmental body to serve as a member of a panel hearing
cases.
Facts: You have served as Senior Counsel to the Board of Claims for the past
eleven and one half years. Prior to accepting that position, you served on the Board's
Panel hearing cases and making recommendations to the Board of Claims. Such
service on the panel was pursuant to a service purchase contract between you and the
Board.
Following your resignation from the Board of Claims on January 26, 2001, you
desire to again enter into a service purchase contract with the Board to once again
serve as a Panel Member on a per diem basis. You do not intend to practice law before
the Board of Claims; you simply intend to serve as a Panel Member. You ask whether
the Ethics Act would permit you to do so.
Discussion: It is initially noted that pursuant to Sections 1107(10) and 1107(11)
of the Ethics Act, 65 Pa.C.S. § §1107(10), (11), advisories are issued to the requestor
based upon the facts which the requestor has submitted. In issuing the advisory based
upon the facts which the requestor has submitted, the Commission does not engage in
an independent investigation of the facts, nor does it speculate as to facts which have
not been submitted. It is the burden of the requestor to truthfully disclose all of the
material facts relevant to the inquiry. 65 Pa.C.S. § §1107(10), (11). An advisory only
affords a defense to the extent the requestor has truthfully disclosed all of the material
facts.
McLaughlin, 01 -520
March 1, 2001
Page 2
As Senior Counsel to the Board of Claims, you would be considered a "public
employee" subject to the Ethics Act and the Regulations of the State Ethics
Commission. See, 65 Pa.C.S. §1102; 51 Pa. Code §11.1. Consequently, upon
termination of public service, you would become a "former public employee" subject to
Section 1103(g) of the Ethics Act.
While Section 1103(g) does not prohibit a former public official /public employee
from accepting a position of employment, it does restrict the former public official /public
employee with regard to "representing" a "person" before the governmental body with
which he has been associated ":
§1103. Restricted activities
(g) Former official or employee. - -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.
65 Pa.C.S. §1103(g) (Emphasis added).
The terms "represent," "person," and "governmental body with which a public
official or employee is or has been associated" are specifically defined in the Ethics Act
as follows:
§1102. Definitions
"Represent." To act on behalf of any other person in
any activity which includes, but is not limited to, the
following: 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.
"Person." A business, governmental body,
individual, corporation, union, association, firm, partnership,
committee, club or other organization or group of persons.
"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.
65 Pa.C.S. §1102.
The term "person" is very broadly defined. It includes, inter alia, corporations and
other businesses. It also includes the former public employee himself, Confidential
Opinion, 93 -005, as well as a new governmental employer. Ledebur, Opinion 95 -007.
The term "representation" is also broadly defined to prohibit acting on behalf of
any person in any activity. Examples of prohibited representation include: (1) personal
appearances before the former governmental body or bodies; (2) attempts to influence;
(3) submission of bid or contract proposals which are signed by or contain the name of
the former public official /public employee; (4) participating in any matters before the
McLaughlin, 01 -520
March 1, 2001
Page 3
former governmental body as to acting on behalf of a person; and (5) lobbying.
Popovich, Opinion 89 -005.
Listing one's name as the person who will provide technical assistance on a
proposal, document, or bid, if submitted to or reviewed by the former governmental
body, constitutes an attempt to influence the former governmental body. Section
1103(g) also generally prohibits the inclusion of the name of a former public
official /public employee on invoices submitted by his new employer to the former
governmental body, even though the invoices pertain to a contract that existed prior to
termination of public service. Shay, Opinion 91 -012. However, if such a pre - existing
contract does not involve the unit where the former public employee worked, the name
of the former public employee may appear on routine invoices if required by the
regulations of the agency to which the billing is being submitted. Abrams/Webster,
Opinion 95 -011.
A former public official /public employee may assist in the preparation of any
documents presented to his former governmental body. However, the ublic
official /public employee may not be identified on documents submitted to the former
governmental body. The public official /public employee may also counsel any person
regarding that person's appearance before his former governmental body. Once again,
however, the activity in this respect should not be revealed to the former governmental
body. The Ethics Act would not prohibit or preclude making general informational
inquiries to the former governmental body to secure information which is available to the
general public, but this must not be done in an effort to indirectly influence the former
governmental body or to otherwise make known to that body the representation of, or
work for the new employer.
Section 1103(g) only restricts the former public official /public employee with
regard to representation before his former governmental body. The former public
official /public employee is not restricted as to representation before other agencies or
entities. However, the "governmental body with which a public official /public employee
is or has been associated" is not limited to the particular subdivision of the agency or
other governmental body where the public official /public employee had influence or
control but extends to the entire body. See, Legislative Journal of House, 1989
Session, No. 15 at 290, 291; Sirolli, Opinion 90 -006; Sharp, Opinion 90- 009 -R.
The governmental body with which you would be associated upon termination of
public service is the Board of Claims in its entirety. Therefore, for the first year after
termination of service with the Board of Claims, Section 1103(g) of the Ethics Act would
apply and restrict "representation" of "persons" before the Board of Claims.
Having set forth the general restrictions of Section 1103(g) of the Ethics Act, your
specific inquiry shall now be addressed.
You ask whether you may, following your resignation from the Board of Claims,
serve as a member of a Hearing Panel pursuant to a service purchase contract with the
Board of Claims. You are advised that such an arrangement would be prohibited by
Section 1103(g) of the Ethics Act during the first year following your resignation.
With few exceptions, contractual arrangements between a former public
official/ public employee and the former governmental body are prohibited by Section
1103(g). Exceptions include where: (1) the restrictions do not apply because a former
public official /public employee is acting as an impartial arbiter between the former
governmental body and others, and hence is not representing himself before his former
governmental body, Confidential Opinion, 92 -005; and (2) where the payments to the
former public official /public employee are limited to expenses incurred, Confidential
Opinion, 97 -012.
McLaughlin, 01 -520
March 1, 2001
Page 4
In the instant matter, no exception would apply, and Section 1103(g) would, for
the first year following your resignation from the Board of Claims, preclude the provision
of the proposed services to the Board of Claims pursuant to a service purchase
contract. See, e.q. Confidential Opinion, 93 -005 (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); Confidential Opinion, 97-
008 (Former public official was prohibited from entering into a consulting contract for
compensation with his former governmental body within one year of termination of
service to provide services as a compensated Special Master and Hearing Examiner).
As noted above, the restrictions of Section 1103(g) would apply for the first year
following your resignation from the Board of Claims.
Based upon the facts which have been submitted, this Advice has addressed the
applicability of Section 1103(g) only. It is expressly assumed that there has been no
use of authority of office for a private pecuniary benefit as prohibited by Section 1103(a)
of the Ethics Act. Further, you are advised that Sections 1103(b) and 1103(c) of the
Ethics Act provide in part that no person shall offer to a public official /public employee
and no public official /public employee shall solicit or accept anything of monetary value
based upon the understanding that the vote, official action, or judgment of the public
official /public employee would be influenced thereby. Reference is made to these
provisions of the law not to imply that there has been or will be any transgression
thereof but merely to provide a complete response to the question presented.
Lastly, 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.
Conclusion: As Senior Counsel with the Board of Claims, you would be
considered a "public employee" subject to the provisions of the Public Official and
Employee Ethics Act, 65 Pa.C.S. §1101 et seq. ( "Ethics Act "). Upon termination of
service with the Board of Claims, you would become a "former public employee" subject
to Section 1103(g) of the Ethics Act. The former governmental body would be the
Board of Claims in its entirety. Section 1103(g) of the Ethics Act would prohibit you
from serving on a Panel pursuant to a service purchase contract with the Board of
Claims during the first year following your resignation from the Board of Claims. The
restrictions as to representation outlined above must be followed. The propriety of the
proposed conduct has only been addressed under the Ethics Act.
Further, should service be terminated, as outlined above, the Ethics Act would
require that a Statement of Financial Interests be filed by no later than May 1 of the year
after termination of service.
Pursuant to Section 1107(11), an Advice is a complete defense in any
enforcement proceeding initiated by the Commission, and evidence of good faith
conduct in any other civil or criminal proceeding, provided the requestor has disclosed
truthfully all the material facts and committed the acts complained of in reliance on the
Advice given.
The letter is a public record and will be made available as such.
Finally, if you disagree with this Advice or if you have any
reason to challenge same, you may appeal the Advice to the full
Commission. A personal appearance before the Commission will be
scheduled and a formal Opinion will be issued by the Commission.
McLaughlin, 01 -520
March 1, 2001
Page 5
Any such appeal must be in writing and must be actually
received at the Commission within thirty (30) days of the date of this
Advice pursuant to 51 Pa. Code §13.2(h). The appeal may be received
at the Commission by hand delivery, United States mail, delivery
service, or by FAX transmission (717 - 787 - 0806). Failure to file such
an appeal at the Commission within thirty (30) days may result in the
dismissal of the appeal.
Sincerely,
Vincent J. Dopko
Chief Counsel