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Interpretative Opinion 03-21: Use of Campaign and Citizen-Service Funds

November 06, 2003

Michael C. Morgan
Brazil Constituent Fund
1350 Pennsylvania Avenue, NW
Washington, DC 20004

Re: Constituent Services

This responds to your request for an opinion concerning whether citizen-services funds may be used to purchase 12 tee shirts for staff of councilmember Brazil’s office to wear during community events so constituents can identify them as staff members. You indicated that the words “The Brazil Team” will be embossed on the front of the shirts and “Keeping the Momentum Going” will be embossed on the back.

DC Official Code §1-1104.03(a) states “the Mayor, the Chairman of the Council, and each member of the Council may establish citizen-service programs within the District of Columbia. …The Mayor, the Chairman of the Council, and each member of the Council shall file a quarterly report of all contributions received and monies expended in accordance with this subsection with the Director of Campaign Finance. No campaign activities shall be conducted nor shall campaign literature or paraphernalia be distributed as part of citizen-services programs conducted pursuant to this subsection.”

3 DCMR §3014 provides that “a citizen-services program shall encompass any activity or program which provides services to the residents of the District of Columbia; and promotes their general welfare, including but not limited to, charitable, scientific, educational, medical or recreational purposes.”

Based upon the information you have provided, it does not appear that the purchase of the tee shirts with citizen-services funds would violate any of the prohibitions on the use of the funds, as long as the staff members utilize the tee shirts exclusively for non campaign related events, that are designed to promote the general welfare of the residents of the District of Columbia

The foregoing is an Interpretive Opinion of the Director of the Office of Campaign Finance. Pursuant to D.C. Official Code §1-1103.05, you are entitled to request an Advisory Opinion from the Board of Elections and Ethics on this transaction or activity.