Shaulis v. Pennsylvania State Ethics Commission

Justice SAYLOR

dissenting.

I respectfully disagree with the conclusion of the majority that an advisory opinion issued pursuant to Section 1107(10) of the Ethics Act is a “final opinion” subject to appeal, as well as its determination that Section 1103(g) is unconstitutional as applied to former government employees who are attorneys.

With respect to appealability, in Section 1108 of the Ethics Act, entitled “Investigations by commission,” the Legislature provided for appeals from opinions and orders “which become[ ] final in accordance with the provisions of this chapter.” 65 Pa.C.S. § 1108(i). Section 1108 contains the Ethics Act’s sole prescription for appealability; Section 1107, pertaining to advisory opinions such are at issue in the present case, has no corollary provision. Moreover, the statute’s only designation of finality also appears in Section 1108 and expressly attaches to orders arising from Commission investigations, which commence upon the filing of a complaint or on Commission motion, may proceed through preliminary inquiry and investigation, and culminate in a findings report and, where requested, an evidentiary hearing. See 65 Pa.C.S. § 1108(f) (delineating as final an order required to be issued by the Commission ■within thirty days of receipt of the investigative hearing record or response to the findings report, where a hearing has not occurred). Conversely, no provision of the statute designates advisory opinions issued under Section 1107(10) as final and/or subject to appellate review in the judiciary.

In light of this framework, I would honor the definitional specifications for appealability and finality contained within the Ethics Act. Accord Cheyenne-Arapaho Gaming Comm’n v. National Indian Gaming Comm’n, 214 F.Supp.2d 1155, 1171 (N.D.Okla.2002) (holding that Congress’ specification of the character of final agency actions in enabling legislation supported the implied corollary proposition “that the other agency actions are not final, and ergo, not reviewable.” (citing Thunder Basin Coal Co. v. Reich, 510 U.S. 200, 208, 114 S.Ct. *701771, 777, 127 L.Ed.2d 29 (1994))). Of course, a statute which too closely limits the right of appeal might be vulnerable to constitutional challenge.1 Here, however, the advisory character of Section 1107(10) opinions and the associated ripeness question would seem to alleviate the salient, due process concern. Cf. Kemler v. Poston, 108 F.Supp.2d 529, 589-43 (E.D.Va.2000) (concluding that an advisory opinion by a state judicial ethics commission was not a final, appealable order, inter alia, on ripeness grounds); Transit Mgmt. of Southeast La., Inc. v. Commission on Ethics for Pub. Employees, 703 So.2d 576, 578 (La.1997) (explaining that “until there is some proceeding before the [state ethics cjommission which could result in the [cjommission’s imposing a penalty, there is no preliminary or procedural action or ruling by the [cjommission that is appropriate for judicial review, either by appeal or by supervisory writs[;] [ijndeed, there is no justiciable controversy for the courts to decide”), modified, 710 So.2d 792 (La. 1998) .

In the present matter, the Commission did not initiate any form of investigative, prosecutorial, or enforcement proceeding — Appellee merely requested and received the Commission’s view concerning provisions of its enabling legislation. As the Commission notes, when this occurs under Section 1107(10) of the Ethics Act, the designed effect is merely to afford certain defenses to a requestor who truthfully submits the material facts and who in good faith, follows the advice given. See 65 Pa.C.S. § 1107(10); Suehr v. State Ethics Comm’n, 651 A.2d 648, 649 (Pa.Cmwlth.1994). I also note, in accordance with the dissenting opinions of Judges Leadbetter and McGinley, that a requestor in such circumstances is not entirely without a remedy. See Shaulis v. Pennsylvania State Ethics Comm’n, 739 A.2d 1091, 1108-09 & n. 2 (Pa.Cmwlth. 1999) (Leadbetter, J., dissenting) (citing the Declaratory Judgments Act, 42 Pa.C.S. §§ 7532-7541); Shaulis, 739 A.2d at *7021106-07 (McGinley, J., concurring and dissenting) (citing Pa. R.A.P. 1504). Indeed, I believe that the best course for the Commonwealth Court to take upon receipt of a petition for review in these circumstances, as Judge McGinley suggests, would be to apply Rule of Appellate Procedure 1504, and treat the matter in its original jurisdiction as a declaratory judgment proceeding. See id.

On the merits, I have previously expressed the view that the Court should defer to the General Assembly with respect to incidental regulation of legal practice such as may be conducted in the other branches of government. See Gmerek v. State Ethics Comm’n, 569 Pa. 579, 602-04, 807 A.2d 812, 826-27 (2002) (Saylor, J., opinion in support of reversal).2 Moreover, here, I would give credence to the Legislature’s explanation that its one-year, post-employment limitation is not intended to regulate the practice of law as such, but rather, to prevent pernicious practices and the appearance of impropriety, thereby strengthening public confidence in government by assuring its constituents of the impartiality and honesty of its public officials.3 Accord Forti v. New York State Ethics Comm’n, 75 N.Y.2d 596, 555 N.Y.S.2d 235, 554 N.E.2d 876, 885 (1990) (explaining that New York’s revolving door law “is not directed specifically at admitted attorneys but rather is aimed at all *703former executive branch employees[;] [i]ts effect on the practice of law is, thus, merely incidental”). With regard to the argument that the Court has already addressed the mischief to be remedied by Section 1103(g), as applied to attorneys, by promulgating Rule 1.11 of Professional Responsibility, I would follow the view of other courts which would regard revolving door legislation as supplemental to such rules, and not as conflicting. See, e.g., Howard v. State Comm’n on Ethics, 421 So.2d 37, 39 (Fla.Dist.Ct.App.1982) (“The [revolving door] statutes enacted by the legislature merely supplement the Canons of Professional Responsibility adopted by the Supreme Court. When an attorney decides to accept public employment, he does so subject to the legislative proscription on his conduct.”); accord Pennsylvania PUC Bar Ass’n v. Thorn-burgh, 498 Pa. 589, 593, 450 A.2d 613, 615 (1982) (Hutchinson, J., dissenting to per curiam order) (“There is no apparent contradiction between the Code of Professional Responsibility and the Ethics Act. The legislature has merely exercised its authority to enact a more stringent rule addressing the same subject as [the Court’s rules], declaring that a particular private employment within a specified period presents the appearance of impropriety we generally condemn. A determination that such employment is offensive in appearance is not manifestly unreasonable.”).

I acknowledge the burden that the one-year, post-employment restriction places on former government employees. See generally Forti, 555 N.Y.S.2d 235, 554 N.E.2d at 883-84 (discussing the important competing interests and concerns that must be balanced in implementing revolving door legislation). The deference that I would afford to the statutory constraint arises from my view of the respective roles and prerogatives of the legislative and judicial branches, not out of personal agreement with the particular balance that the General Assembly has struck. I simply view regulation of representative activity in the executive, administrative arena as within the legitimate sphere of legislative interest, and would invoke this Court’s authority under Article V, Section 10(c) of the Pennsylvania Constitution to disapprove only those legisla*704tive acts that infringe on the essential functioning of the judiciary. Accord Gmerek, 569 Pa. at 602-04, 807 A.2d at 826-27 (Saylor, J., opinion in support of reversal). I would also note that the Court’s position insulating attorneys from the legislative proscriptions, unfortunately, gives rise to the appearance of preferential treatment.

Thus, I would reverse the order of the Commonwealth Court, and disapprove the supporting rationale from the line of Commonwealth Court precedent following Pennsylvania PUC Bar Ass’n v. Thornburgh, 62 Pa.Cmwlth. 88, 434 A.2d 1327 (1981), aff'd per curiam, 498 Pa. 589, 450 A.2d 613 (1982).

Justice NIGRO joins this dissenting opinion.

. This would be the case, for example, upon any suggestion that the Legislature did not intend for a right of appeal to attach to the imposition of criminal penalties under Section 1109 of the Ethics Act, 65 Pa.C.S. § 1109, or the award of monetary damages under Section 1110, 65 Pa.C.S. § 1110.

. I also disagree with the majority's assessment that Appellee’s status as a former (as opposed to present) employee should control in determining the constitutionality of Section 1103(g), and that this establishes a material basis on which the Court’s reasoning from the PJ.S. case may be distinguished. See Majority Opinion, at 132. When determining whether a regulation intrudes on the Court’s core functions, I believe that the inquiry should not turn on employment status or identity of the entity prescribing the regulation, but rather, on the character and substance of the regulation, including the scope of its applicability. See Gmerek, 569 Pa. at 599 n. 6, 807 A.2d at 825 n. 6 (Saylor, J., opinion in support of reversal). I do find the Court’s decision in Wajert v. State Ethics Comm’n, 491 Pa. 255, 420 A.2d 439 (1980), to be fairly distinguishable, as the circumstances involved regulation of legal practice before the judiciary, see id. at 262, 420 A.2d at 442, which is far closer to the core area of this Court's authority than regulation in the administrative arena.

. See 65 Pa.C.S. § 1101.1(a); see also Act of October 4, 1978, P.L. 883, No. 170, § 1, 65 P.S. § 403(e) (reenacted and amended by the Act of June 26, 1989, P.L. 26, No. 9, § 1, 65 P.S. § 403(g)) (repealed by the Act of October 15, 1998, P.L. 729, No. 93, § 1, 65 Pa.C.S § 1103(g)).