HomeMy WebLinkAbout23-505 O'Donnell
PHONE: 717-783-1610
STATE ETHICS COMMISSION FACSIMILE: 717-787-0806
FINANCE BUILDING WEBSITE: www.ethics.pa.gov
TOLL FREE: 1-800-932-0936
613 NORTH STREET, ROOM 309
HARRISBURG, PA 17120-0400
ADVICE OF COUNSEL
January 30, 2023
To the Requester:
Patrick O’Donnell
23-505
Dear Mr. O’Donnell:
This responds to your emails received January 3, 2023, and January 4, 2023, by which you
requested an advisory from the Pennsylvania State Ethics Commission (“Commission”), seeking
guidance as to the issues presented below:
Issues:
(1) Whether the Public Official and Employee Ethics Act (“Ethics Act”), 65 Pa.C.S. § 1101 et
seq., would impose restrictions upon you following termination of your employment as a
Deputy Commissioner for the City of Philadelphia (“City”) Department of Public Property.
Brief Answer: YES. During the first year following termination of your employment with
the City Department of Public Property, Section 1103(g) of the Ethics Act would apply and
restrict you from engaging in any activity that would involve “representation” of a “person”
— including but not limited to yourself or a consulting firm owned by you and your wife
— before your “former governmental body,” the City Department of Public Property.
(2) Whether Section 1103(g) of the Ethics Act would prohibit youfrom representing the
consulting firm owned by you and your wife before any City agencies or departments other
than the City Department of Public Property.
Brief Answer: NO. Section 1103(g) of the Ethics Act would not prohibit you from
representing the consulting firm owned by you and your wife before City agencies or
departments other than the City Department of Public Property.
Facts:
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January 30, 2023
Page 2
You request an advisory from the Commission based upon submitted facts that may be
fairly summarized as follows.
You are currently employed as a Deputy Commissioner for the City Department of Public
Property, in which capacity you oversee facility maintenance for five of the City’s larger buildings
in Center City. You and your wife are the minority owner and the majority owner, respectively, of
a consulting firm (the “Consulting Firm”). Your role with the Consulting Firm is that of Chief
Operating Officer. The Consulting Firm’s work involves work zone traffic control and project
design for private developers and their contractors, and it may expand to provide materials and
supplies to its clients.
The Consulting Firm has been receiving inquiries about performing services in relation to
public works projects in the City. You plan to retire from your employment with the City because
you are prohibited from being employed by the City if the Consulting Firm is pursuing or
participating on a City-funded project.
Based upon the above submitted facts, you seek guidance as to whether the Ethics Act
would impose prohibitions or restrictions upon youduring the first year following termination of
your City employment. In particular, you ask whether the Ethics Act would impose any restrictions
upon your or the Consulting Firm’s ability to perform work for City agencies or departments other
than the City Department of Public Property.
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 requester based upon the facts that the
requester has submitted. In issuing the advisory based upon the facts that the requester has
submitted, the Commission does not engage in an independent investigation of the facts, nor does
it speculate as to facts that have not been submitted. It is the burden of the requester 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 requester has truthfully disclosed all of the material facts.
It is further initially noted that this advisory is limited to addressing your prospective
conduct and does not address the conduct of the Consulting Firm. This is because the restrictions
of Section 1103(g) of the Ethics Act, discussed herein, apply to former public officials/public
employees and would not apply to restrict the conduct of the Consulting Firm.
As a Deputy Commissioner for the City Department of Public Property, you are a “public
employee” subject to the Ethics Act and the Regulations of the State Ethics Commission.
Consequently, upon termination of your employmentwith the City Department of Public Property,
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”:
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January 30, 2023
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§ 1103. Restricted activities
(g) Former official or employee.--No former public
official or public employee shall representa 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 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 official/public employee himself, Confidential
Opinion, 93-005, as well as a new governmental employer. Ledebur, Opinion 95-007.
The term “represent” 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 former governmental body as to acting on behalf of a
person; and (5) lobbying. Popovich, Opinion 89-005.
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January 30, 2023
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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 if the invoices pertain to a contract that
existed prior to termination of service with such governmental body. Shay, Opinion 91-012.
However, if such a pre-existing contract does not involve the unit where a 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 former public official/public employee
may not be identified on documents submitted to the former governmental body. The former
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 thatbody 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 deemed to have been associated upon
termination of your employment with the City Department of Public Property would be the City
Department of Public Property in its entirety. Therefore, for the first year following termination
of your employmentwith the City Department of Public Property, Section 1103(g) of the Ethics
Act would apply and restrict “representation” of a “person”— including but not limited to yourself
or the Consulting Firm — before the City Department of Public Property. Section 1103(g) of the
Ethics Act would not prohibit you from representing the Consulting Firm before City agencies or
departments other than the City Department of Public Property.
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.
Conclusion:
As a Deputy Commissioner for the City Department of Public Property, you are a “public
employee” subject to the Ethics Act and the Regulations of the State Ethics Commission.Upon
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January 30, 2023
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termination of your employmentwith the City Department of Public Property, you would become
a “former public employee” subject to Section 1103(g) of the Ethics Act. Your former
governmental body would be the City Department of Public Property in its entirety. For the first
year following termination of your employmentwith the City Department of Public Property,
Section 1103(g) of the Ethics Act would apply and restrict “representation” of a “person” —
including but not limited to yourself orthe Consulting Firm — before theCity Department of
Public Property. The restrictions as to representation outlined above must be followed. Section
1103(g) of the Ethics Act would not prohibit you from representing the Consulting Firm before
City agencies or departments other than the City Department of Public Property. Lastly, the
propriety of the proposed conduct has only been addressed under the Ethics Act.
Pursuant to Section 1107(11) of the Ethics Act, 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 requester 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 receivedat 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.
Respectfully,
Bridget K. Guilfoyle
Chief Counsel