HomeMy WebLinkAbout80-048 RussellPaul E. Russell, Esquire
2 N. Ninth Street
Allentown, PA 18101
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
October 14, 1980
OPINION OF THE COMMISSION
80 -048
RE: Section 3(e) - Prohibition Against Representation
Dear Mr. Russell:
I. Issue:
You requested an Opinion as to the application of
Section 3(e) of the Ethics Act and a delineation of the
extent of the prohibition of Section 3(e) of the Act.
II. Factual Basis for Determination:
You indicated that you were employed by the Pennsyl-
vania Public Utility Commission (PUC) from 1975 through July
1, 1980 as an Associate Counsel. On July 14, 1980 you began
employment as an attorney with Pennsylvania Power & Light
Company in PP &L's Regulatory Affairs Section. PP &L is an
electric public utility regulated by the PUC.
In all other respects your situation is identical to
that of Kathy L. Pape who requested and was given Advice of
Chief Counsel No. 80 -538.
III. Applicable Law:
There is no dispute or doubt that as an Associate Counsel
for the PUC you were a "public employee" within the definition
of that term in the Ethics Act. As such, when you left that
position as of July 1, 1980 you became a "former public
employee" subject to the requirements of Section 3(e) of the
Ethics Act which provides:
Paul E. Russell, Esquire
October 14, 1980
Page 2
Regulations of the Commission define "representation"
as follows:
The Commission has had occasion to interpret Section
3(e) in several Opinions in addition to the Advice No. 80-
538 to which you refer. The most comprehensive analysis
to date may be found in Opinion 80 -039, Morris issued August
20, 1980. This Opinion will be discussed more fully below.
There are no Court cases on this topic to date.
IV. Discussion:
"No former official or public employee
shall represent a person, with or without
compensation, on any matter before the
governmental body with which he has been
associated for one year after he leaves
that body."
"Any act on behalf of another person or
advice to any person for the purpose of
influencing the outcome of any event."
51 Pa. Code 1.1
Section 3(e) has been held in Opinion 80 -039, Morris to
prohibit for the one -year period:
1. personal appearance before the governmental body
with which you were associated, including, but not
limited to negotiations;
2. attempts to influence that governmental body;
3. participation in any manner in any case over
which you had supervision, direct involvement
or responsibility while employed by the govern-
mental body. (See also Code of Professional
Responsibility)
4. lobbying, i.e. representing the interests of any
person as to legislation, regulations, etc. See
Seltzer.
Paul E. Russell, Esquire
October 14, 1980
Page 3
Former public employees are not prohibited from:
(a) appearing in third forums, such as state or federal
court, except as set forth in (3) above;
(b) making general informational inquiries of the nature
made by the public of their governmental body;
(c) utilizing the knowledge and expertise gained in
their tenure as public employees, except as set
forth above.
One final note is necessary. To the extent that
Advice No. 80 -538 may be read to allow a former employee
to file interrogatories and /or briefs and to sign same
on cases pending before or presented to the PUC, that
Advice is clarified, as set forth above. No former
public employee can sign and file such items himself for
the one year period. This would clearly constitute
prohibited activity in (1) or (2) above. Assisting others
in preparing such items where another signs, files and
therefore "represents" the person, is distinguishable.
V. Conclusion:
- You are a former public employee and your conduct as
such is to be guided by this Opinion. You are prohibited
for the one year period from activities within categories
(1), (2), (3) and (4) above. Specifically, you may not:
(1) personally appear before the PUC or submit documents
(Briefs, Interrogatories, etc.) under your signature;
(2) attempt to influence the PUC, its staff or employees;
(3) participate in any matter over which you had supervi-
sion, direct responsibility or involvement while
employed by the PUC.
(4) "lobby" before the PUC.
Paul E. Russell, Esquire
October 14, 1980
Page 4
Pursuant to Section 7(9)(i), this opinion is a complete
defense in any enforcement proceeding initiated by the Commission,
and evidence of good faith conduct in any 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 such.
PJS /rdp
UPDATE: A Commonwealth Court ruling (434 A.2d 1327) on similiar factual circumstances should be reviewed. Former
Commonwealth employees or officials who are attorneys may practice law before the governmental body with
which he /she has been associated regardless of the Section 3(e) (one year) prohibition. The court ruling did not
specificially address this particular opinion, but the factual circumstances may be applied to it. This Common-
wealth Court opinion was affirmed, without further opinion by the Pennsylvania Supreme Court.