HomeMy WebLinkAbout23-534 Batula
PHONE: 717-783-1610
STATE ETHICS COMMISSION FACSIMILE: 717-787-0806
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613 NORTH STREET, ROOM 309
HARRISBURG, PA 17120-0400
ADVICE OF COUNSEL
June 5, 2023
To the Requester:
Melissa J. Batula
23-534
Dear Ms. Batula:
This responds to your letter dated May 19, 2023, by which you requested an advisory from
the Pennsylvania State Ethics Commission (“Commission”), seeking guidance as to the issue
presented below:
Issue:
Whether the Public Official and Employee Ethics Act (“Ethics Act”), 65 Pa.C.S. § 1101 et
seq., would impose any prohibitions or restrictions upon you following termination of your
employment as the Deputy Secretary for Highway Administration for the Pennsylvania
Department of Transportation (“PennDOT”).
Brief Answer: YES. During the first year following termination of your employment with
PennDOT, 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 a new employer — before your “former governmental body,” PennDOT.
For a period of two years following termination of your employment with PennDOT,
Section 1103(i) of the Ethics Act would restrict you from being employed by, receiving
compensation from, assisting, or acting in a representative capacity for a business that you
actively participated in recruiting to the Commonwealth or actively participated in inducing
to open or expand a plant, facility, or branch in the Commonwealth through a grant or loan
of money or a promise of a grant or loan of money from the Commonwealth.
Batula, 23-534
June 5, 2023
Page 2
Facts:
You request an advisory from the Commission based upon submitted facts that may be
fairly summarized as follows.
You began employment with PennDOT in March 2006. You served as the Deputy
Secretary for Highway Administration for PennDOT from approximately January 2020 until
March 2021, when you became the Acting Executive Deputy Secretary for PennDOT. You
resumed serving as the Deputy Secretary for Highway Administration in February 2023. Your
employment with PennDOT ended on March 31, 2023.
Effective May 15, 2023, you began employment as a Principal Program Manager for HDR
Engineering, Inc. (“the Firm”). You state that prior to taking this position, you informed the Firm
that you would be precluded from working on any projects with PennDOT for a period of one year
following termination of your employment with PennDOT.
You seek guidance as to whether the Ethics Act would impose any prohibitions or
restrictions upon you following termination of your Commonwealth employment. In particular,
the following questions are posed by your advisory request:
(1) Whether there would be any restrictions upon you with regard to doing work for
agencies or other entities that receive funding from PennDOT, such as the
Southeastern Pennsylvania Transit Authority (“SEPTA”), Pittsburgh Regional
Transit, the Pennsylvania Turnpike Commission, the Cities of Philadelphia or
Pittsburgh or other local governments, or the Delaware Valley Regional Planning
Commission or other planning organizations;
(2) Whether there would be any restrictions upon you with regard to doing work for
agencies or other entities for which PennDOT has oversight responsibilities, such
as, for example, being included as part of the staff on a general engineering contract
for SEPTA;
(3) Whether there would be any restrictions upon you with regard to doing work on
behalf of a third party where such work would ultimately be submitted to PennDOT
for approval or acceptance (examples of such work would include the preparation
of bridge inspection reports for a local partner, a safety audit for a transit provider,
or a grant application for a planning partner); and
(4) Whether there would be any restrictions upon you with regard to attending,
participating in, or speaking/making presentations at national or industry
conferences, informal charity events, or other engagements at which PennDOT
staff may also be in attendance.
Batula, 23-534
June 5, 2023
Page 3
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.
During your employment as the Deputy Secretary for Highway Administration for
PennDOT, you were considered a public official/public employee and an “executive-level State
employee” subject to the provisions of 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 your
employment with PennDOT, you became a former public official/public employee and former
executive-level State employee subject to the restrictions of Section 1103(g) and Section 1103(i)
of the Ethics Act.
Section 1103(i) restricts former executive-level State employees as follows:
§ 1103. Restricted activities
(i) Former executive-level employee.--No former
executive-level State employee may for a period of two years from
the time that he terminates employment with this Commonwealth be
employed by, receive compensation from, assist or act in a
representative capacity for a business or corporation that he actively
participated in recruiting to this Commonwealth or that he actively
participated in inducing to open a new plant, facility or branch in
this Commonwealth or that he actively participated in inducing to
expand an existent plant or facility within this 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.
65 Pa.C.S. § 1103(i).
Section 1103(i) restricts the ability of a former executive-level State employee to accept
employment or otherwise engage in business relationships following termination of State service,
under certain narrow conditions. The restrictions of Section 1103(i) apply even where the business
relationship is indirect, such as where the business in question is a client of a new employer, rather
than the new employer itself. See, Confidential Opinion, 94-011. However, Section 1103(i) would
not restrict you from being employed by, receiving compensation from, assisting, or acting in a
Batula, 23-534
June 5, 2023
Page 4
representative capacity for a business subject to the conditions that you did not actively participate
in recruiting such business to Pennsylvania, and that you did not actively participate in inducing
such business to open or expand a plant, facility, or branch in Pennsylvania, through a grant or
loan of money or a promise of a grant or loan of money from the Commonwealth.
Unlike Section 1103(i), Section 1103(g) does not prohibit a former public official/public
employee from accepting a position of employment. However, 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 following terms related to Section 1103(g) are 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.
Batula, 23-534
June 5, 2023
Page 5
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 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 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 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 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 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 are deemed to have been associated upon
termination of your employment with PennDOT is PennDOT in its entirety. Therefore, for the
first year following termination of your employment with PennDOT, Section 1103(g) of the Ethics
Batula, 23-534
June 5, 2023
Page 6
Act would apply and restrict you from representing a "person" — including but not limited to the
Firm —before PennDOT.
Having set forth the restrictions of Section 1103(g) of the Ethics Act, your specific
questions shall now be addressed.
In response to your first and second questions, you are advised that Section 1103(g) of the
Ethics Act would not prohibit you from: (1) doing work for agencies or other entities that receive
funding from PennDOT, such as SEPTA, Pittsburgh Regional Transit, the Pennsylvania Turnpike
Commission, the Cities of Philadelphia or Pittsburgh or other local governments, or the Delaware
Valley Regional Planning Commission or other planning organizations; or (2) doing work for
agencies or other entities for which PennDOT has oversight responsibilities, subject to the
condition that in performing such work, you would not engage in prohibited representation before
PennDOT as set forth above.
With respect to your third question, you are advised as follows. Section 1103(g) of the
Ethics Act would not prohibit you from doing work on behalf of a third party subject to the
condition that in performing such work, you would not engage in prohibited representation before
PennDOT. If work that you would perform on behalf of a third party would ultimately be
submitted to PennDOT for approval or acceptance (bridge inspection reports for a local partner, a
safety audit for a transit provider, a grant application for a planning partner, etc.), you would need
to exercise caution to ensure that you would not engage in prohibited representation before
PennDOT, such as for example, through the inclusion of your name on that work.
In response to your fourth question, you are advised that Section 1103(g) of the Ethics Act
would not prohibit you from attending, participating in, or speaking/making presentations at
national or industry conferences, informal charity events, or other engagements at which PennDOT
staff may also be in attendance subject to the condition that in so doing, you would not act in such
a way as to make known to PennDOT your representation of, or work for, the Firm. Cf., Valentine,
Opinion 20-003; Confidential Opinion, 17-007; Koser, Advice 21-540; Healey, Advice 18-518;
Anderson, Advice 16-504.
Conclusion:
During your employment as the Deputy Secretary for Highway Administration for
PennDOT, you were considered a public official/public employee and an “executive-level State
employee” subject to the Ethics Act and the Regulations of the State Ethics Commission. Upon
termination of your employment with PennDOT, you became a former public official/public
employee and a former executive-level State employee subject to the restrictions of Section
1103(g) and Section 1103(i) of the Ethics Act. Under Section 1103(i) of the Ethics Act, you would
not be prohibited from being employed by, receiving compensation from, assisting, or acting in a
representative capacity for a business subject to the conditions that you did not actively participate
in recruiting such business to Pennsylvania, and that you did not actively participate in inducing
such business to open or expanda plant, facility, or branch in Pennsylvania, through a grant or
loan of money or a promise of a grant or loan of money from the Commonwealth.
Batula,23-534
June 5, 2023
Page 7
The governmental body with which you are deemed to have been associated upon
termination of your employment with PennDOT is PennDOT in its entirety. For the first year
following termination of your employmentwith PennDOT, Section 1103(g) of the Ethics Act
would apply and restrict you from representing a "person"—including but not limited to your
new employer,the Firm —before PennDOT as delineated above. The restrictions as to
representation outlined above must be followed.
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 publicrecord 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.
Respectfully,
Bridget K. Guilfoyle
Chief Counsel