HomeMy WebLinkAbout26-549 CoheePHONE: 717-783-1610
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To the Requester:
Anna G. Cohee
Dear Ms. Cohee:
STATE ETHICS COMMISSION
FINANCE BUILDING
613 NORTH STREET, ROOM 304
HARRISBURG, PA 17120-0400
FACSIMILE: 717-787-0806
WEBSITE: www.ethics.pa.gov
ADVICE OF COUNSEL
July 24, 2026
26-549
This responds to your submission received July 17, 2026, 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
sec.., would impose prohibitions or restrictions upon you regard to performing work for a
federal contractor due to your former employment as a Biologist Aide with the
Pennsylvania Game Commission ("Game Commission") from January 2018 to May 2018.
Brief Answer: NO. Because your employment with the Game Commission terminated
more than eight years ago, the "revolving door" restrictions of Section 1103(g) of the Ethics
Act, which apply to former public officials/public employees during the first year following
termination of public service/public employment, would not impose restrictions upon you
with regard to performing work for a federal contractor.
Facts:
You were employed as a Biologist Aide with the Game Commission from January 2018 to
May 2018. You are currently being considered for a position as an Environmental Planner with
ICF, which is a federal contractor. ICF requires that you obtain confirmation that there are no
conflicts between your potential new role with ICF and your former work with local, state, and
federal government.
Cohee, 26-549
July 24, 2026
Page 2
The question that is posed by your advisory request is whether the Ethics Act would impose
any prohibitions or restrictions upon you with regard to performing work for ICF due to your
former employment as a Biologist Aide with the Game Commission.
Discussion/Conclusion:
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 relevantto 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.
As the submitted facts do not include a position description for your former position with
the Game Commission, this Advice assumes, without deciding, that during your employment as a
Biologist Aide with the Game Commission, you were a "public employee" subject to the
provisions of the Ethics Act. Consequently, upon termination of your employment with the Game
Commission, you became a "former public employee" subject to the "revolving door" restrictions
of Section 1103(g) of the Ethics Act.
Section 1103(g) of the Ethics Act provides as follows:
§ 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 restrictions of Section 1103(g) of the Ethics Act,
which apply to former public officials and former public employees, apply for one year following
termination of service in the public position.
Based upon the submitted fact that your employment with the Game Commission
terminated in May 2018, more than eight years ago, you are advised that the restrictions of Section
1103(g) of the Ethics Act are not applicable to you now. Therefore, Section 1103(g) would not
impose restrictions upon you with regard to performing work for ICF.
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.
Cohee, 26-549
July 24, 2026
Page 3
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 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