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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
December 27, 2023
To the Requester:
David A. Walls
23-562
Dear Mr. Walls:
This responds to your letter dated November 27, 2023, by which you requested an advisory
from the Pennsylvania State Ethics Commission (“Commission”), seeking guidance as to the
general issue presented below:
Issue:
Whether the Public Official and Employee Ethics Act (“Ethics Act”), 65 Pa.C.S. § 1101 et
seq., would impose restrictions upon you with regard to performing work for a civil
engineering consulting firm following termination of your employmentas aSenior Civil
Engineer Supervisor — Transportation with 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 your new employer, the civil engineering consulting firm — before your “former
governmental body,” PennDOT.
Facts:
You request an advisory from the Commission based upon submitted facts that may be
fairly summarized as follows.
Until October 6, 2023, you were employed as a Senior Civil Engineer Supervisor —
Transportation with PennDOT, in which capacity you served as a Project Manager in Engineering
District 11-0. You have submitted a copy of your official Commonwealth position description,
which document is incorporated herein by reference.
Walls, 23-562
December 27, 2023
Page 2
Following termination of your employment with PennDOT, you accepted a position as a
Project Engineer at a civil engineering consulting firm named “HNTB” (“the Consulting Firm”).
Per materials that you submitted with your advisory request, as a Project Engineer, you may work
as a task lead on projects that could consist of corridor improvements, bridge replacements,
interstate widening, traffic safety, and transit-oriented site development. The Consulting Firm’s
clients may include PennDOT, the Pennsylvania Turnpike Commission, and other state or federal
entities.
You seek guidance as to whether the Ethics Act would imposeprohibitions or restrictions
upon youwith regard to performing work for the Consulting Firm during the first year following
termination of your employmentwith PennDOT.In particular, you ask whether, pursuant to the
Commission’s holding in Abrams/Webster, Opinion 95-011, you would be permitted to perform
work oncontracts which were executed prior to your departure from PennDOT and which do not
involve Engineering District 11-0. As examples of such contracts, you have submitted a list of
contracts which were executed prior to 2023 and which involve PennDOT units other than
Engineering District 11-0
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 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 a Senior Civil Engineer Supervisor — Transportation with
PennDOT, you were 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. This conclusion is
based upon the position description, which when reviewed on an objective basis, indicates clearly
that the power existedto take or recommend official action of a non-ministerial nature with respect
to one or more of the following: contracting; procurement; administering or monitoring grants or
subsidies; planning or zoning; inspecting; licensing; regulating; auditing; or other activity(ies)
where the economic impact is greater than de minimis on the interests of another person.
Consequently, upon termination of your employment with PennDOT, you became 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, itdoes 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
Walls, 23-562
December 27, 2023
Page 3
(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 associatedfor 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.
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
Walls, 23-562
December 27, 2023
Page 4
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 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 isPennDOTin its entirety, including but not
limited to Engineering District 11-0. Therefore, for the first year following termination of your
employment with PennDOT, Section 1103(g) of the Ethics Act would apply and restrict
“representation” of a “person” — including but not limited to the Consulting Firm — before
PennDOT.
You are advised that during the first year following termination of your employment with
PennDOT, Section 1103(g) of the Ethics Act would prohibit you from performing any job duties
that would involve prohibited representation of the Consulting Firm before PennDOT as delineated
above.Section 1103(g) would prohibit you from performing work for the Consulting Firm on any
contract with PennDOT — including but not limited to a contract which was executed prior to
your departure from PennDOT and which does not involve Engineering District 11-0 — unless
you would be able to do so without engaging in prohibited representation before PennDOT.
The Commission’s holding in Abrams/Webster, supra, is limited to the submission of
billing hours. As noted above, generally, during the one-year period of applicability of Section
1103(g), your name cannot appear on invoices submitted to PennDOT by the Consulting Firm.
However, if you would perform work for the Consulting Firm on PennDOT contracts that existed
before you terminated your employment with PennDOT, and if such contracts do not involve the
“unit” of PennDOT where you formerly worked, specifically Engineering District 11-0, your name
could appear on routine invoices submitted to PennDOT as to those particular pre-existing
Walls, 23-562
December 27, 2023
Page 5
contracts if required by the regulations of PennDOT. See, Abrams/Webster, supra. However,
Section 1103(g) of the Ethics Act would still prohibit you from engaging in conduct falling within
the ambit of prohibited representation before PennDOT as set forth above.
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 notbeen considered.
Conclusion:
During your employment as a Senior Civil Engineer Supervisor — Transportation with
PennDOT, you were considered a “public employee” subject to the Ethics Act and the Regulations
of the State Ethics Commission. Upon termination of your employmentwith PennDOT, you
became a “former public employee” subject to Section 1103(g) of the Ethics Act.Your former
governmental body isPennDOT inits entirety, including but not limited to Engineering District
11-0. For the first year following termination of your employmentwith PennDOT, Section
1103(g) of the Ethics Act would apply and restrict “representation” of a “person” — including but
not limited to your new employer, HNTB — before PennDOT. 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 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