Advisory Opinion No. 1997-23

Effect of June 18 Special Session Public Act No. 97-6 on the Giving
and Reporting of Tickets to Charity Events by Registered Lobbyists

June 18 Special Session Public Act No. 97-6 makes significant changes in the law regarding the giving and reporting of tickets to charitable events. Specifically, Sections 1 and 6 of the Act add the following to the list of items which are not considered "gifts" for the purpose of calculating the gift limit under the Codes of Ethics:

Admission to a charitable or civic event, including food or beverage provided at such an event, but excluding lodging or travel expenses, at which a public official or state employee participates in his official capacity, provided such admission is provided by the primary sponsoring entity.

Also, Section 7 of the Act amends the lobbyist reporting requirements of Conn. Gen. Stat. §1-96(e), in part, as follows:

The requirement of an itemized statement shall not apply to an expenditure made by a reporting registrant . . . for (2) benefits personally and directly received by a public official or state employee at a charitable or civic event at which the public official or state employee participates in his official capacity, unless the expenditure is thirty dollars or more per person, per event.

State Ethics Commission Staff Attorney Catherine Nasto has asked how these new rules apply (1) if a registered lobbyist/charity sponsors a charity golf tournament and wishes to invite a public official to play without buying a ticket and (2) a registered lobbyist who is not the sponsor of the tournament buys a ticket costing $150 (of which $50 is the cost of the golf, $25 is the cost of the meals and the rest is a contribution to the charity) and wishes to give the ticket to a public official.

Under the new law, the registered lobbyist which is also the primary sponsor of the event may allow the public official to participate without triggering the gift limits of the Codes of Ethics. However, because the benefits personally and directly received by the public official exceed $30 ($50 for the cost of the golf and $25 for the cost of the meals), this lobbyist must itemize the name of, and benefits received by, the public official on its next financial report.

Turning to Attorney Nasto’s second question, since the value of the golf exceeds the new gift restrictions of the Codes of Ethics (which, effective January 1, 1998, limit gifts to items worth less than $10), the registered lobbyist who is not the primary sponsor of the tournament may not give the ticket to a public official.

By order of the Commission,

Maurice FitzMaurice
Chairperson