Louisiana Ethics Administration Program
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Entry Properties
Last modified
7/1/2025 10:46:15 AM
Creation date
5/2/2025 2:05:00 PM
Metadata
2025-127
Fields
Template:
Opinion Item
Opinion Type
Advisory Opinion
Docket Number
2025-127
Requesting Party
Pamela Lewandowski
Parties Involved
Pamela Lewandowski
Agency at Issue
Louisiana Housing Corporation (LHC)
LHC Training Center
LSU La House Research and Education Center
Decision Date
5/2/2025
Law
La. R.S. 42:1121B(1)
Caption
The Code of Governmental Ethics prohibits Pamela Lewandowski, a former employee of the Louisiana Housing Corporation (LHC) Training Center, from rendering contractual services instructing the LHC Energy Auditor Curriculum for her former agency until December 3, 2026, since she rendered those services to the LHC Training Center during her public employment.
Ethics Subject Matters
Post Employment
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(2)(a) "Agency" means a department, office, division, agency, commission, board, committee, or <br /> other organizational unit of a governmental entity. <br /> (16) "Person" means an individual or legal entity other than a governmental entity, or an agency <br /> thereof. <br /> (18)(a) "Public employee" means anyone, whether compensated or not,who is: <br /> (i) An administrative officer or official of a governmental entity who is not filling an <br /> elective office. <br /> (ii) Appointed by any elected official when acting in an official capacity, and the <br /> appointment is to a post or position wherein the appointee is to serve the governmental <br /> entity or an agency thereof, either as a member of an agency, or as an employee thereof. <br /> (iii)Engaged in the performance of a governmental function. <br /> (iv) Under the supervision or authority of an elected official or another employee of the <br /> governmental entity. <br /> ANALYSIS <br /> As an employee of LHC, you were a public employee pursuant to La. R.S. 42:1102(18). Your <br /> agency for the purposes of the Code was LHC Training Center pursuant to La. R.S. 42:1102(2)(a). <br /> La. R.S. 42:1121B(1) prohibits you, for a period of two years following the termination of your <br /> public employment, from assisting another person, for compensation, in a transaction, or in an <br /> appearance in connection with a transaction in which you participated at any time during your <br /> public employment, or from rendering, any service which you had rendered to the LHC during the <br /> term of your public employment on a contractual basis, regardless of the parties to the contract. <br /> Even though,LSU La House Research and Education Center is not a"person"under the Code,La. <br /> R.S. 42:1121B(1) still prohibits you from rendering instructions services for the Energy Auditor <br /> Curriculum on a contractual basis, regardless of the parties, for two years from the termination of <br /> your public employment since you instructed the LHC Energy Auditor Curriculum when you were <br /> employed at the LHC. <br /> CONCLUSION <br /> The Board concluded, and instructed me to inform you, that La. R.S. 42:112113(l) prohibits you <br /> until December 3, 2026 from instructing the LHC Energy Auditor Curriculum on a contractual <br /> basis. <br /> Changes to the facts as presented may result in a different application of the provisions of the <br /> Louisiana Code of Governmental Ethics. The Board issues no opinion as to past conduct or as to <br /> laws other than the Louisiana Code of Governmental Ethics, the Campaign Finance Disclosure <br /> Act,the Lobbyist Disclosure Acts,and the conflict of interest provisions contained in the Louisiana <br /> Gaming Control Law. <br /> If you have any questions,please contact me at(800) 842-6630 or(225) 219-5600. <br />
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