September 6, 1996
Mr. Jonathan Bergman
1720-16th Street, NW
Washington, D.C. 20009
Re: Applicability of Contribution Limitations to Party Delegate-Aides
Dear Mr. Bergman:
This is in response to your [oral] request for an opinion concerning whether the contribution limits applicable to political party delegates also apply to political party delegate-aides. You state that you are a delegate-aide to the D.C. Republican State Committee, and that you wish to raise funds for your travel and related expenses to the Republican National Convention in San Diego, California where you will provide assistance to elderly convention participants.
D.C. Code § 1-1401(3) defines the term, “Office”, as “the office of Mayor of the District of Columbia, . . . or an official of a political party.” According to D. C. Code § 1-1401 (4), the term, “official of a political party” refers to [includes] National Committeemen and National Committeewomen, delegates to conventions of political parties nominating candidates for President and Vice President of the United States, and alternates to national committee persons and [national] delegates
Pursuant to D.C. Code § 1-1441 (5) campaign contributions to any political party candidate enumerated in the preceding paragraph are restricted to $200 or less. However, for the purposes of D.C. campaign finance law, a delegate-aide to a political party is not an elected political position for which D.C. contribution limits apply, nor is a delegate-aide otherwise regulated by the D.C. Office of Campaign Finance. Therefore, we would suggest that as you attempt to identify sponsors for your trip to San Diego that you clearly distinguish yourself as a not-elected party worker so as to avoid even the appearance of impropriety.