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Interpretative Opinion 01-06: Contribution Limitations

March 8, 2001
 

Stephen G. Callas
Member, DC Board of Elections and Ethics
2730 Wisconsin Avenue, NW #78
Washington, DC 20007

Re: Political Activity

Dear Mr. Callas:

This responds to your request for an interpretative opinion, concerning whether you, as a member of the Board of Elections and Ethics, would be permitted by DC Law to contribute $2000 to the “2001 Victory Fund”.  You state contributions to the 2001 Victory Fund “will benefit the New Jersey Democratic State Committee’s 2001 Coordinated Campaign”.  You opine that means the proceeds will be spent on a “variety of elections for this year’s elections, including the gubernatorial, State (N.J.) Assembly, State Senate and perhaps-other elections in New Jersey”.

You also inquire whether you may attend on March 27, 2001, the “2001 Victory Gala” “In Honor of Mayor Jim McGreevey”, a candidate for Governor, with special guest U.S. Senator Joseph I. Liberman. You forwarded a copy of the invitation to this event for OCF review.

DC Code, Section 1-1304(b) (1999 Replacement Volume) prohibits a member of the Board of Elections and Ethics from campaigning for any other public office, holding any office in any political party or political committee, and participating in or contributing to any political campaign of any candidate in any election held in the District of Columbia.  Simply put, this means Board members must refrain from engaging in the foregoing activities only with regard to District of Columbia elections.

Further, Section 201.3 of Title 3, “Elections and Ethics” of the District of Columbia Municipal Regulations (June 1998), prohibits a member of the Board from engaging in “any activity, including attending local and national political dinners, fundraisers, parties, meetings, or conferences which would imply support of or opposition to a candidate or group of candidates for office, an initiative, referendum, or recall measure, or a political party or committee”. Clearly, the purpose of the statute and the Board regulations is to ensure that the members of the Board of Elections and Ethics remain impartial in the execution of their responsibilities under both the Election and Campaign Finance Acts, pertaining to the conduct of local elections and the related campaign operations of local candidates and committees.

Based on your representations, and our review of the invitation, it does not appear that the statute or the regulations would prohibit your attendance at an event in honor of a state elected official or candidate for office, or your contribution to a fund which will benefit a state party committee.