Advisory Opinion No. 1995-20
Client Who Pays Attorney To Engage In Exempt Activities
Need Not Register As A Client Lobbyist
An individual or entity who pays an attorney to engage in an
activity, such as the negotiation of a contract, which is exempted from the
definition of lobbying by P.A. 95-144, has not made or agreed to make
lobbying expenditures within the meaning of Conn. Gen. Stat. §1-91(1), and
need not register or report such expenditures to the State Ethics Commission. Conn. Gen. Stat. §1-91(k). See State Ethics Commission Advisory Opinion
No. 95-12, supra. It must be kept in mind, however, that an
individual or entity which pays someone other than an attorney to negotiate the
same contract will, in general, be deemed to have made lobbying
expenditures. If such latter
expenditures total $1,000 or more, both the individual or entity paying for the
negotiating services, and the negotiator himself, will be required to register
as lobbyists, pursuant to Conn. Gen. Stat. §§1-91(k), 1-91(1), 1-95 and 1-96,
unless another statutory or regulatory exemption applies. See,
e.g., Conn. Gen.
Stat. §1-91(k)(2) (which exempts salesperson activity) and Regulations of
Connecticut State Agencies §1-92-42a(e)(1) (which exempts the preparation of a
response to a request for contract proposals). By order of the Commission, David T. Nassef
Chairperson