HomeMy WebLinkAbout95-626 BrownJames W. Brown
819 Mandy Lane
Camp Hill, PA 17011
Dear Mr. Brown:
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O, BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
December 18, 1995
95 -626
Re: Former Public Official; Section 3(g); Executive -Level State
Employee; Section 3(i); Chief of Staff to Governor; PSERS;
SERS.
This responds to your letter of November 14, 1995, in which
you requested advice from the State Ethics Commission.
Issue: Whether the Public Official and Employee Ethics Law
presents any restrictions upon employment of a former public
official following termination of service as Chief of Staff to the
Governor of Pennsylvania and the Pennsylvania Public School
Employes' Retirement System ( PSERS).
Facts: You were Chief of Staff to the Governor of Pennsylvania
from January 1, 1989 to December 2, 1994. As part of your duties,
you served as the designee of the Secretary of Education to PSERS.
In that capacity, you attended PSERS board meetings, voted on
matters before the board and served on various committees. Your
official dealings with PSERS ended on or before December 2, 1994,
the date you resigned as Chief of Staff and entered the private
sector.
You are currently serving as a member of the board of the
Pennsylvania State Employes' Retirement System (SERS), having been
nominated for this position by the Governor and confirmed by the
Senate. This term will end in November 1996. PSERS and SERS are
independent legal entities which were established by separate state
statutes.
You have recently been invited to become a managing director
of a fund (the Fund) which, as a limited partnership, manages money
for institutional investors. The Fund is managed by a general
James W. Brown, 95 -626
December 18, 1995
Page 2
partner and the investors are limited partners. As a managing
director of the general partner, you would receive a salary and a
percentage of the Fund's profits. The Fund is seeking investors
and has approached PSERS as a possible investor /limited partner.
Your current status with regard to the Fund vis -a -vis PSERS is
that you have no legal relationship with the Fund, having signed no
partnership agreement or any other legal document relating to the
Fund. You do not receive any salary or benefits from the Fund nor
do you have any interest in the Fund's profits. You have not
represented the Fund in any dealings with PSERS and have not
discussed the Fund or related matters with anyone from PSERS. You
have not appeared before PSERS, its board or employees, regarding
the Fund nor have you attempted to influence PSERS' decision on
this matter in any way. Your name does not appear in any bid or
contract proposals or .other materials submitted to PSERS by the
Fund. You state that you intend to maintain the above status with
regard to PSERS and the Fund until December 2, 1995.
You note in your letter that the Fund has not approached SERS
as a possible investor /limited partner and will not do so while you
are a member of the SERS board. Your inquiry relates only to
PSERS, specifically whether you are subject to any restrictions
regarding your desire to become a managing director of the Fund at
some date after December 2, 1995.
Discussion: As a former Chief of Staff for the Governor, you are
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 §11.1.
This conclusion is based upon '''the job description, which when
reviewed on an objective basis, indicates clearly that the power
exists to take or recommend 'official action of a non - ministerial
nature with respect to 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.
- In addition, you are an executive's - level state employee as that
term is defined under the Ethics Law, and hence you are subject to
the requirements of Section 3(i) of the Ethics Law, infra.
Section 3(a) of the Ethics Law provides:
Sec ion 3. Restricted Activities.
(a) No public official or public
employee shall engage in conduct that
constitutes a conflict of interest.-
James W. Brown, 95 -626
December 18, 1995
Page 3
The following terms are defined in the Ethics Law as follows:
$ectipn 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 of his immediate family or
a business with which he or a member of his
immediate family is associated.
"Authority of office or employment." The
actual power provided by law, the exercise of
which is necessary, to the performance of
duties and responsibilities unique to a
particular public office or position of public
employment.
"Executive-level State employee." The
Governor, Lieutenant Governor, cabinet
members, deputy secretaries, the Governor's
office staff, any State employee with
discretionary powers which may affect the
outcome of a State agency's decision in
relation to a private corporation or business
or any employee who by virtue of his job
function could influence the outcome of such a
decision.
In addition, 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 anything 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
been or will be any transgression thereof but merely to provide a
complete response to the question presented.
James W. Brown, 95 -626
December 18, 1995
Page 4
Section 3(i) of the Ethics Law provides:
Section 3. Restricted,. ct ,ivities
(i) No former executive -level State
employee may for a period of two years from
the time that he terminates his State
employment be employed by, receive
compensation from, assist or act in a
representative capacity for a business or
corporation that he actively participates in
recruiting to the Commonwealth of Pennsylvania
or that he actively participated in inducing
to open a new plant, facility or branch.in the
Commonwealth or that he actively participated
in inducing to expand an existent plant or
facility within the Commonwealth, provided
that the above prohibition shall be invoked
only when the recruitment or inducement is
accomplished by a grant or loan of money or a
promise of a grant or loan of money from the
Commonwealth to the business or corporation
recruited or induced to expand.
Under Section 3(a)'of the Ethics Law quoted above, a public
official /employee, may not use the authority of public office/
employment or confidential information received by holding such a
public position for the private pecuniary benefit of himself, a
member of his immediate family, or business with which he or a
member of his immediate family is associated.
In applying Section 3(a) of the Ethics Law to the proffered
facts, Section 3(a) would prohibit you from using the position or
emoluments of your public position'or confidential information to
advance an opportunity of private employment with the Fund. Once
again, it is not that you have engaged in such conduct
and the foregoing is provided to give a complete response to your
inquiry.
As to Section 3(i) of the Ethics Law, you are subject to that
provision of law since you are an executive -level state employee.
However,_ Section 3(i) would not restrict you from the position of
'employment with.t Fund provided you did not actively participate
in recrui.ting'or inducing the Fund to open a new facility or branch
in' the.commmonwea.lth or. participate in inducing the Fund to expand
an existing plant, or facility that was accomplished by a grant or
loan of money or a 'promise' of a grant or loan of money from the
Commonwealth of Pennsylvania to the Fund: -
James W. Brown, 95 -626
December 18, 1995
Page 5
The facts do not indicate whether you actively participated in
recruiting or inducing the Fund to open a new facility or branch or
expand through a grant or loan of money or a promise of a grant or
loan of money from the Commonwealth. Conditioned upon the
assumption that there has been no active participation by you in
such recruitment or inducement of the Fund to open or expand a
facility or branch through a grant or loan of money or a promise of
a grant or loan of money from the Commonwealth of Pennsylvania, you
would not be prohibited from accepting the position of employment
with the Fund.
Upon termination of public service, you would become 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.
Initially, to answer your request the governmental body with
which you were associated while working with the Governor's Office
must be identified. Then, the scope of the prohibitions associated
with the concept and term of "representation" must be reviewed.
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.
In applying the above definition to the instant matter, we
must conclude that the governmental body with which you were
associated upon termination of public service would be (2). The
above is based upon the language of the Ethics Law, the legislative
intent (lJegislative Journal of House, 1989 Session, No. 15 at 290,
James W. Brown, 95 -626
December 18, 1995
Page 6
291) and the prior precedent of this Commission. Thus, in Sirolli,
Opinion 90 -006, the Commission found that a former Division
Director of the Department of Public Welfare (DPW) was not merely
restricted to the particular Division as was contended but was in
fact restricted to all of DPW regarding the one year representation
restriction. Similarly in Sharp, Opinion 90- 009 -R, it was
determined that a.former legislative assistant to a state senator
was not merely restricted to that particular senator but to the
entire Senate as his former governmental body.
Therefore, within the first year after termination of service
with the Governor's Office, Section 3(g) of the Ethics Law would
apply and restrict representation of persons or new employers vis-
a-vis the executive branch of the Commonwealth of Pennsylvania,
PSERS and any other agencies as to which you were a member or acted
in the Governor's stead or otherwise exercised influence, control
or discretionary authority, hereafter collectively referred to as
the executive branch /PSERS.
It is noted that 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." It was the
specific intent of the General Assembly to define 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. The foregoing intent is reflected in the
legislative debate relative to the amendatory language for the
above term:
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..." Legislative Journal of House, 1989
Session, No. 15 at 290, 291.
Therefore, since the Ethics :Law must be construed to ascertain
and effectuate the intent of. the General Assembly under 1 Pa.
C.S.A. §1901, it is clear that the governmental body with which you
were associated is executive branch / PSERS.
Turning now to the scope of the restrictions under Section
3(g), the Ethics Law does not affect one's ability to appear before
agencies or entities other than with respect to the former
governmental body. Likewise, there is no general limitation on the
type of employment in which a person may engage, following
departure from their governmental body. It is noted, however, that
the conflicts of interest law is primarily concerned with financial
James W. Brown, 95 -626
December 18, 1995
Page 7
conflicts and violations of the public trust. The intent of the
law generally is that during the term of a person's public
employment he must act consistently with the public trust and upon
departure from the public sector, that individual should not be
allowed to utilize his association with the public sector,
officials or employees to secure for himself or a new employer,
treatment or benefits that tray be obtainable only because of his
association with his former governmental body.
In respect to the one year restriction against such
"representation," the Ethics Law defines "Represent" as follows:
Section 2. 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.
The Commission, in Popovich, Opinion 89 -0 05, has also
interpreted the term "representation" as used in Section 3(g) of
the Ethics Law to prohibit:
1. Personal appearances before the former governmental body
or bodies, including, but not limited to, negotiations or
renegotiations in general or as to contracts;
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;
5. Lobbying, that is representing the interests of any
person or employer bef=ore the fatter goverrrth Iital body in
relation to legislation, regulat:.ione et -.
The. Commission has also held that lis=ting name as the
person who. will provide technical aseietai e on such proposal,
document, or bid, if submitted to or reviewed by the former
governmental body constitutes an attempt to influence the former
governmental body.. Section 3(g) would also prohibit in general the
inclusion of the name of a former public, official /
on invoices submitted by his new employer t
o the emformer
James W. Brown, 95 -626
December 18, 1995
Page 8
governmental body, even though the invoices pertain to a contract
which existed prior to termination of public service. Shay,
Opinion 91 -012. However, in the event of work performed on a
contract already awarded and not involving 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. Therefore, within the first year
after termination of service, you should not engage in any of the
prohibited activities outlined above.
You may assist in the preparation of any documents presented
to Executive Branch /PSERS. However, you may not be identified on
documents submitted to Executive Branch /PSERS. You may also
counsel any person regarding that person's appearance before
Executive Branch / PSERS. Once again, however, the activity in this
respect should not be revealed to Executive Branch /PSERS. Of
course, any ban under the Ethics Law would not prohibit or preclude
the thaking of general informational inquiries of Executive
Branch /PSERS to secure information which is available to the
general public. 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.
In addition, 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 . onfidential.Opinion 93 - 005, the Commission held that
Section 3 precludes a former public official /employee from
providing consulting services to his former governmental body for
a pef i.bd o.f one year after termination of service in that the
prohJbitidn against representing a person includes the former
public :of f .E ial /employee representing himself.
As to your specific inquiry, you would not be prohibited from
becoming a managing director of the Fund provided your conduct
conforms to Sections '3(a), 3 (.g) and 3 (i) as detailed above. This
advice does not address any issues relative to SERS.
Lastly, the 'propriety of the proposed conduct has only been
addressed under the Ethict :Law; the applicability of any other
statute cbde, brdinance, regulation or other code of conduct other
James W. Brown, 95 -626
December 18, 1995
Page 9
than the Ethics Act has not been considered in that they do not
involve an interpretation of the Ethics Law.
Conclusion: As former Chief of Staff for the Governor, you are
considered a "public official" and an executive -level state
employee subject to the provisions of the Ethics Law. Under
Section 3(i) of the Ethics Law, you would not be prohibited from
accepting a position of employment with the Fund based upon the
assumption that you did not actively participate in inducing or
recruiting said company to open or expand a facility or branch
through a grant or loan of money or a promise of a grant or loan of
money from the Commonwealth of Pennsylvania. Upon termination of
service with the Governor's Office, you would become a "former
public official" subject to Section 3(g) of the Ethics Law. The
former governmental body is the executive branch of the
Commonwealth of Pennsylvania, PSERS and any other agencies as to
which you were a member or acted in the Governor's stead or
otherwise exercised influence, control or discretionary authority.
The restrictions as to representation outlined above must be
followed. The propriety of the proposed conduct has only been
addressed under the Ethics Law.
Further, should service be terminated, as outlined above, the
Ethics Law also requires that a Statement of Financial Interests be
filed for the year following termination of service.
Pursuant to Section 7(11), this 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, providing 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
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 Corny ission.
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
513.2(h) . The appeal may be received at the Commission
by hand delivery, United States mail, delivery service,
or by FAX transmission ( 787 - 0806). Failure to file
such.
James W. Brown, 95 -626
December 18, 1995
Page 10
such an appeal at the Commission within thirty (30) days
may result in the dismissal of the appeal.
Vincent J.'.opko
Chief Counsel
rely,