HomeMy WebLinkAbout01-525 StalloneGuy Stallone, Jr.
637 Grant Street
Franklin, PA 16323
Dear Mr. Stallone:
ADVICE OF COUNSEL
March 9, 2001
01 -525
Re: Former Public Employee; Section 1103(g); Real Estate Specialist; PennDOT; 95-
Day Program; Private Contractor.
This responds to your letter of February 1, 2001, by which you requested advice
from the State Ethics Commission.
Issue: Whether the Public Official and Employee Ethics Act ( "Ethics Act "), 65
Pa.C.S. §1101 et seq., presents any restrictions upon employment of a Real Estate
Specialist following termination of service with the Commonwealth of Pennsylvania,
Department of Transportation ( "PennDOT ").
Facts: From 1968 until your retirement in 1991, you were employed by PennDOT
in various capacities in the Right -Of -Way Unit. In October 1999, you returned to work
for PennDOT as a Real Estate Specialist. As a Real Estate Specialist, you are involved
in acquiring property for a new highway in Erie County.
You were informed that you would be permitted to work up to 95 days in a fiscal
year. A fiscal year begins on July 1 and ends on June 30. You are now completing your
second 95 -day period with PennDOT.
You are considering working for a private contractor presently under contract with
PennDOT. You state that the contractor is working on the same highway project [in Erie
County], but on a different section of the road.
Given the above facts, you ask the following questions.
1. Whether you may work for the private contractor on the Erie County
highway project;
2. Whether you may work for the private contractor on other projects; and
3. Whether you are permitted to "make contact" with PennDOT employees in
District 1 -0.
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
Stallone, 01 -525
March 9, 2001
Page 2
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.
You have not submitted a job description for your position as Real Estate
Specialist for PennDOT. It will be assumed for purposes of this advisory that the duties
and responsibilities of Real Estate Specialist are such that the power exists to take or
recommend official action of a non - ministerial nature with respect to one or more of the
following: contracting; procurement; planning; inspecting; administering or monitoring
grants; leasing; regulating; auditing; or other activities where the economic impact is
greater than de minimis on the interests of another person, so that 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 public 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
Stallone, 01 -525
March 9, 2001
Page 3
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 /employee; (4) participating in any matters before the 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 /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 No. 90 -006; Sharp, Opinion 90- 009 -R.
Although you have not supplied a job description, it would appear from the
submitted facts that you work in PennDOT District 1 -0. Therefore, the governmental
body with which you would be associated upon termination of public service would be
PennDOT in its entirety including, but not limited to, District 1 -0. For the first year after
termination of your service with PennDOT, Section 1103(g) of the Ethics Act would
apply and restrict "representation" of "persons" before PennDOT.
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March 9, 2001
Page 4
It is noted that your request involves participation in program that permits a
retiree to work for PennDOT for up to 95 "days" in a fiscal year. A "day" is defined as
four hours or more. For participants in the "95 -day program,' PennDOT withholds taxes
and Social Security, but does not deduct for retirement or hospitalization /health. See,
Ickes, Advice of Counsel 99 -535.
It is further noted that you terminated employment with PennDOT in 1991 but
returned to work for that agency in October 1999 under the "95 -day program." As to
your subsequent return to work in October 1999, you once again became a public
employee. Upon completion of your second 95 -day period of working for PennDOT,
you will once again become a former public employee. Hence, you could not engage in
prohibited representation for one year after completing work under the 95 -day program.
See, McGlathery, Opinion 00 -004 (where the full Commission held that a public
employee who would retire from PennDOT but would subsequently return to work for
PennDOT under a program which allows retirees to work up to 95 days per fiscal year
would, in so doing, become a "public employee" again. Upon termination of service
under that program, the retiree would once again become a former public employee
subject to the restrictions of Section 1103(g). The restrictions of Section 1103(g) would
apply for a full one year period each time the individual would become a former public
employee).
Having established the above, your specific inquiries shall now be addressed.
With regard to your first question pertaining to working for the private contractor
on the Erie County highway project, you state, The Contractor is working on the same
highway project but different section of the road." Assuming that in performing such
work for the private contractor, no prohibited contacts would occur as to PennDOT and
no written materials containing your name would be submitted to PennDOT except
within the narrow and limited circumstances permitted by Webster, supra, as set forth
above, it would not appear that you would transgress Section 1103(g) of the Ethics Act.
With regard to your second question, you would be permitted to work on other
projects for the private contractor conditioned upon the assumption that you would not
be engaging in prohibited representation before PennDOT during the one -year period of
applicability of Section 1103(g).
With regard to your third question, you are advised that the restrictions set forth
in Section 1103(g) of the Ethics Act extend to your former governmental body in its
entirety. Therefore, the prohibition against representation before your former
governmental body would include District 1 -0, all other Districts, as well as PennDOT,
that is, PennDOT in its entirety.
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 /employee and no
public official /employee shall solicit or accept anything of monetary value based upon
the understanding that the vote, official action, or judgment of the public
official /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
Stallone, 01 -525
March 9, 2001
Page 5
involve an interpretation of the Ethics Act. Specifically not addressed herein is the
applicability of the Governor's Code of Conduct.
Conclusion: As a Real Estate Specialist for the Commonwealth of Pennsylvania,
Department of Transportation ( "PennDOT "), it is assumed for purposes of this advisory
that you are a "public employee" subject to the Public Official and Employee Ethics Act,
65 Pa.C.S. §1101 et seq. (`Ethics Act "). Upon termination of service with PennDOT,
you would become a "former public employee" subject to Section 1103(g) of the Ethics
Act. The former governmental body is PennDOT in its entirety including, but not limited
to District 1 -0. 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.
This 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.
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