Advisory Opinion No. 1999-9
Application Of Conn. Gen. Stat. §1-86(c)
To Work As A Consultant
Pursuant to Conn. Gen. Stat. §1-86(c), "No person required to register with the state ethics commission under section 1-94 shall accept employment with the general assembly or with any member of the general assembly in connection with legislative action " In essence, this provision bans registered lobbyists from employment with the Legislature regarding legislative matters.
The Commission has been asked whether the prohibition applies to work as a consultant. The answer is yes. Under the Commissions regulations, which define employment for purposes of the Codes ban on improper use of office for personal benefit, the term encompasses " any work or endeavor, whatever its form, undertaken in order to obtain financial gain (e.g. independent contractor )" Regulations of Conn. State Agencies §1-81-14.
There is no discernable reason why an alternative analysis should apply in interpreting "employment" for purposes of §1-86(c ) . To the contrary, whether the work is performed as a state employee or a consultant, no lobbyist should provide compensated services to the General Assembly regarding legislative matters.
By order of the Commission,
Stanley Burdick
Chairperson